ML20112H438

Response to Second Set of Interrogatories & Request for Production of Documents.Affidavits & Certificate of Svc Encl.Related Correspondence

ML20112H438
Person / Time
Site:	Vogtle
Issue date:	01/11/1985
From:	Joiner J GEORGIA POWER CO., TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA
To:	CAMPAIGN FOR PROSPEROUS GEORGIA (EDUCATIONAL), GEORGIANS AGAINST NUCLEAR ENERGY
References
CON-#185-115 OL, NUDOCS 8501170146
Download: ML20112H438 (57)

Text

r REL4 ten cav-~ .> ,,,,,Encg w , s January,f l1, 1985 UNITED STATES OF AMERICA ' E*a ;; ;

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NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board 4

In the matter of.  :

GEORGIA POWER COMPANY, et al. -

DOCKET-NUMBERS 50-424 and 50-425 (b-1 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

APPLICANTS' RESPONSE TO INTERVENORS' SECOND SET OF-INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS

.. -On: December _7,:19843. Joint:Intenvenors. Campaign;for_a.

Prosperous Georgia and Georgians Against Nuclear Energy served upon Applicants by mail their Second Set of Inter-rogatories, and Requests to Produce. Applicants provide herein their responses to thos,e discovery requests.

. I. GENERAL OBJECTIONS r

I , A. Obiections to Instructions Applicants object to the-preliminary instructions con-

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tained in Intervenors' Second Set of Interrogatories

. and Requests to Produce to the extent that

l. the Intervenors seek to impose requirements upon the Applicants beyond those permitted by the Nuclear 8501170146 850111

• gDRADOCK 05000424

PDR - -,

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i Regulatory Commission's Rules of practice for Domestic Licensing proceedings; and

2. those instructions request the production of l documents protected from discovery by the attorney-client privilege or the work product privilege.

B. Obiections to Interrogatories and Requests for Documents Applicants object to any interrogatory or request for documents, or portion of an interrogatory or request for documents, which seeks information beyond that which relates to matters in controversy which have been iden-tified by the Board in its Memorandum and Order dated November 5, 1984. See, 10 C.F.R. S 2.740(b)(1) .- The scope of Contention No. 8, as admitted by the Board, is '

, _. _;: .r..:-.:_.- .;:  :- .....  :: .. .

stated as follows:

Applicants have not and will not implement a quality assurance program for Plant Vogtle for welding, for proper.ly documenting the placement of concrete, for adequately testing concrete, for the preparation of' correct concrete quality test records, for procuring material and equipment that. meet. applicable standards, for protecting equipment and'for taking corrective action as required, so as to adequately provide for the .

safe functioning of. diverse structures, systems and components, as. required by 10 CFR Part.50, .. .

Appendix B, such that reasonable assurance exists that operation of_the facility'will not. endanger. .

-the public health and safety.

I Applicants consider to be beyond the scope of Conten-tion No. 8 any inquiry into, or request for document concerning, a non-Contention No. 8 activity. A Contention 4 - ,

, _ _ . _ . ._. . . . _ . . , . _ _ _ _ _ . . . _ . . . _ . . - , , _ . . , _ _ , _ . . , _ - - _ . _ . ~ __ -,, , _ _ . . . . . _ . - .

No. 8 activity is considered to be any one of, or combina-tion of, the following:

1. welding;

2. documenting the placement of concrete;

3. testing concrete:

4. preparation of concrete quality test records;

5. procuring material and equipment;

d. protecting equipment; and

7. taking corrective action in response to Notices of Viblation as' required by the'NRC.

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Because Applicants object to any discovery beyond the scope of the contentions as admitted by the Board, Appli-cants have limited their response to Intervenors' Second Set of Interrogatdries and Request for Documents to such Contention No. 8 activities. In some instances a specific interrogatory or request is entirely outside the scope of Contention No. 8. In such instance a specific objection is stated ,and'no answer is given or no document will be produced.

II. SPECIFIC RESPONSES:

. A. heneralInterrocatories:

A-1.

Question: - -

Please identify-(by name, business address, occupation and employer) a) all individuals who have knowledge or ,

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information responsive to each interrogatory and designate the interrogatory or the part thereof which that individ-ual answered; and b) each person you expect to call as an expert witness in this proceeding as well as a brief description ~of the subject matter on shich that person is expected to testify and~the substance of that testimony, the witness's educational and professional backtround, and the identity of any previous. proceedings in which that person has testified.

Response

a) Objection. Applicants object to this Interroga-tory because~it is. vague.. confusing and not susceptable to i a proper response. -To -the extent this Interrogatory requests -information about persons other than those who have provided :informattan used-by : Applicants :in . responding to these discovery requests, it is overly broad, burden-some, and oppressive. Subject to these objections, those who provided answers to these interrogatories are identi-fled in the attached af'fidavits, b) Applicants currently have.not identified an expert whom they will call as a witness in this proceed-

ing.

To the extent it.is required, this response will be supplemented as required _by the.-NRC. Rules of-Practice for Domestic-Licensing: proceedings.-

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1 B. Interrogatories Relatino to CPG /GANE Contention No. 8 I T-1.

Question:

When the Applicant recently fired employees involved in procurement due to allegations of bidrigging, what investigations were performed to assure that quality of materials and work was not affected as well as pricing?

What was the result of these investigations? Please pro-vide details, includi,ng copies of the investigation r'esult s .

Response

Objection., _ Applicants object to this interrogatory because it calls for information which is not re' levant to the subject matter of this proceeding and is not reason- -

ably calculated to lead to discovery of admissible evi-dence. It is entirely beyond the scope of Contention No. 8, as admitted by the Board. In its Memorandum and

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Order dated November 5, 1984, the Board rejected Inter-venors' request to add the procurement irregularities in question as a basis.for Contention No. 8. Therefore, they

&re not a proper matter for inquiry.

T-2.

. Q'ues t' ion : ,,

How were vendors approved for the Qualified Vendors

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List? Describe in detail any and all methods for choosing qualified vendors. .

, Response:

VEGP does not have a document called a " Qualified Vendors List," but rather evaluates potential suppliers and successful bidders on a case-by-case basis for each purchase. The list of bidders is generally selected from a master list of suppliers (an Evaluated Supplier List or ESL) who have been evaluated and proven to have an accept-able QA Program for the equipment or materials.which are being procured. However, prior to.actually awarding a purchase order and/or:beginning . work, the supplier's QA Program is reviewed extensively, including appropriate

. detailed procedures, to assure that the program meets-VEGP quality requirements. ~This review is conducted-by qualified QA personnel in the Georgia Power Company, Southern _ Company: Services or:Bechtel. Power-Corporation. . .

organizations.

T-3.

Question: -

! What provisions doe's the Applicant have for auditing vendors to assure compliance with contract specifications ,

and QA/QC requirements?.' .

Response:. . . - -

The provisions- utilized inr Applicants for' auditing l

vendors to assure compliance with contract specifications and QA/QC requirements are described in detail in PSAR and FSAR Chapters 17', 17.1, 17A, 17B and 17C.

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In summary, Applicants have established an audit pro-gram for the VEGP which encompasses, as applicable, design, procurement, construction and preoperational test-ing activities of Georgia Power Company, Southern Company Services, Bechtel Power Corporation, Westinghouse and site contractors. This program is under the direct supervision of the Vogtle Quality Assurance Manager ("VQAM") who per-sonally conducts certain audits, and observes - lected audits performed by others. The VQAM-has responsibility

for the audits conducted on VEGP activities and has final i authority on any matters relating to the conduct of P.ny audit. - .

The Applicants' Quality Assurance Manual and the- -

internal procedures of the VQAM office outline the way in which the_various audits are conducted. The audit proce-dures require that the following be accomplished for all audits conducted or observed by the VQAM.

A. Preparation of audit. agendas or checklists.

B. VQAM approval of audit agendas or checklists.

C. ' Preparation of audit report with suitable means

, for identifying open items.

, D.* VQAM approval and appropriate distribution of audit reports. .

The. specific audits applicable to the VEGF program are

. described .in FSAR Subsection 17.1.18.1. Among the. audits

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performed or observed by the VQAM to provide a comprehen-sive verification and evaluation of all phases'of the VNP'

QA program activities are Vendor Audits. In conjunction with their surveillance activities, the Bechtel Power Corporation procurement Supplier Quality Department and the Southern Company Services Quality Assurance Department conduct planned audits of selected suppliers. Checklists, as referenced in their respective department manuals, are used during these audits. The VQAM receives from the S*uthern o Company Services Project Quality Assurance Engineer the schedule of planned audits, and for selected audits the VQAM or his. representative accompanies the audit team. A preaudit meeting is held prior to each audit, and any specific questions of Georgia power Company or Southern-Company-Services are given to th~e audit team leader. The VQAM participation is to assure the adequacy of the Isupplier.'s : quality. assurance program .and to:. assure the effectiveness of the Bechtel Power Corporation audit.

An exit interview is held at the conclusion of each audit, and recommendations or discrepancies are presented

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- to the supplier's management. Open items are listed in the audit report and are reaudited. The VQAM receives copies of audit and re-audit reports. Any Georgia Power Company questions or comments on the audit or re-audit reports are resolved through the Southern Company Services .

Profect-Quality Assurance Engi-neer.

The VQAM assures that Southern Company Services,

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Bechtel Power Corporation and Westinghouse implement an audit program for,their assigned work scope. This O

includes internal audits of activities on VEGP and audits of subcontractors or suppliers.

T-4.

Question:

Have>any employees or bidders alleged that_ political or personal' favoritism has resulted in preferential treat-ment being given to some contractors? please provide detaiIs. -

Response

Objection. Applicants object to this interrogatory because it calls for information which is not relevant to the subject matter of this proceeding and is not calcu-lated: to lead to_ the: discovery of admissible evidence.. -It is entirely beyond the scope.of. Contention No. 8 as admitted by the Board.

T-5.

Question:

Has any contractor, including but not limited to Westinghouse Corporation and Bechtel, taken officials of the Applicant.on trips to Europe or provided other bene-fits to them? Please provide details.

- 'Re'sponse:  : . ..

Objection..' Applicants. object to this interrogatory because it calls-for information which is'not. relevant to the subject matter of this proceeding and.is not calcu-lated to lead to the discovery of admissible evidence. It

is entirely beyond the scope of Contention No. 8 as admitted by the Board.

T-6.

Question:

How often has the Applicant been cited for violation of NRC rules, regulations and procedures at plant Vogtle since the construction permit was issued? How many viola-tions were at each severity level?

Response

As of the date of- this Response, Applicants have been cited for violation of NRC rules, regulations or proce-dures at Plant Vogtle a total of thirty-one (31) times since the construction permit was issued. These included two (2) deviations and nine (9) infractions. There were five .(5) violations involving severity Level IV, thirteen - ;

(13) at Level V, and two (2) at Level VI.

T-7.

Question: -

Describe in detail"any such violations which were at the most severe, second most severe, or third most severe level of violation.

Response: . . .

None. - -

T-8 .-

Question:

For each contractor or subcontractor at plant Vogtle, briefly describe ,the area and type of work they are O

responsible for, given the date on which they became involved with Plant Vogtle, and if their contract has been terminated, the date of and reason for terminttion.

Response

A document identified as "Alvin W. Vogtle Electric Generating Plant Labor Contract History as of 1/08/85" will be produced at VEGP at a mutually convenient time in lieu of.a narrative. response.to this interrogatory and in Response to Request for Production of~ Documents No. 9.

. - T-9.

Question:

Who is responsible for training workers'(laborers, craftspeople; inspectors, etc.) at the plant: the Appli-cant, Bechtel, the individual contractor / subcontractor or the union?'.: - ~-: ;' .;- : - - _..:-..

Response

Most skilled workers at VEGP came to work having already acquired-their skill. Their initial training may have come from any number of sources. However with regard to training of workers at the Plant, training (of laborers, craftspeople and inspectors) is conducted by their respective. contractor-employer. (See.also,. Response to In,terrogatory No. 10, infra.) .In some-instances, a third party is utilized because of a particular experience and expertise. Georgia Power Company is responsible for training Georgia Power-Company inspectors.

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T-10.

Question:

What assurance is there that workers are properly trained and qualified before they are permitted to do their work? List all recognized industrial standards (e.g. ANSI) for the training of workers which are appli-cable to Plant.Vogtle and indicate how they are being met.

Response

To assure itself the greatest potential for obtaining quality workers, Georgia Power Company has utilized orga-nized labor for most of its construction projects.

Accordingly,. Georgia power Company entered into the Vogtle Project Agreement (VPA) with organized labor to construct VEGP thereby assuring itself an adequate supply of skilled labor. - .

For activities affecting quality, on-site training is formulated in harmony with accepted industry standards, Bechtel design specifications and/or, manufacturer instruc-tions, and Vogtle proje'6t procedure, as appropriate to the particular activity.-

Craftsmen performing activities which affect quality items receive classroom and in.some instances hands-on training and. testing. For some training, craftsmen are issu'ed a wallet-card si'gnifying their qualification to.

perform those activities and their qualification date.

Inspectors are certified at the site by authorized individuals. The, inspector must have the experience in O

his/her area of certification as required by ANSI, pass a l

certification exam and be observed through on the job training by his/her immediate supervisor prior to certifi-cation. The inspector's immediate supervisor, the organi-zation responsible for training and administering the exams, and the authorized individual for certification must all agree that the individual is fully qualified before the inspector is certified and released to perform inspections. -

Workers.are trained to perform work to recognized industrial standards. Those standards which are appli-cable to Contention.No. 8 activities at VEGP include:

(a) ASME~Section IX and B31.1 - Welding;-

(b) AWS D.l.1: . Welding; -

.(c) - -ANSI :45-2.2 and .4 5-2 :3 ,- Housekeeping -and . Equip-ment Storage and Maintenance; (d) AWS 39.1 - Welding; (e) SMACNA - H .V.-A. C. ;

(f) ACI - Concrete; (g) NRMCA - Concrete; (h) CRD - Concrete.

- ' Georgia Power Company regularly provides : profession-ally ., instructed training classes for craf t supervisors.

The applicable standards for training Georgia power Company quality control inspectors are as follows:

(a). ANSI-N45.2.6 - 1978; L

(b) Regulatory Guide 1.58 - September, 1980:

(c) ASNT SNT-TC-1A - 1980; T-ll.

Question:

Have there been any allegations of harassment or intimidation of inspectors at plant Vogtle? If so, list each such incident and provide details.

Response

Objection. Applicants object to this interrogatory because it calls-for information which is not relevant to the subject matter of this proceeding and is not calcu-lated to lead to the discovery of admissible evidence; 'It is entirely beyond the scope of Contention No. 8 as admitted by the Board.

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. r T-12.- - . :=.=:: .. ..,-

Question:

List every act of vandalism directed at the structure of Plant Vogtle or components thereof, giving the date, extent and location of Sach incident, and explain how the vandalism was discovered. .

Response

Objection; Applicants object tocthis interrogatory because;it. calls for information which is not relevant to the subject matter of this proceeding and-is'not~calcu-lated to lead to the discovery of admissible evidence. It

.is entirely beyond the scope of Contention No. 8 as -

admitted by the Board. Further, Applicants state that D

this interrogatory is vague and confusing and it does not lend itself to response.

T-13.

Question:

Have any engineering change notices been generated at Plant Vogtle due to the use of equipment that could not meet the original specifications? Provide ~detailc.

Response: -

Applicants do not use any procedure'which is known as

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an " engineering change notice." Accordingly, strict answer to this interrogatory would be negative. However, with the understanding that intervenors may:be referring-to the type of notice which is generated at VEGP. pertain-ing to deviations- f rom original equipment specifications, Applicants-offer the following response. Any:' equipment which is received at VEGP which does not meet the speci-fication requirements is reported on a " deviation report."

Copies of.these deviation reports as well as the disposi-tion of that deviation (which.in loose terms may be what the Intervenors characterize as an " engineering change notice") are included within those documents produced in response to-Requests for Production of Documents No. 21.

The a,pprgpriate response to this interrogatory can be gathered by Intervenors by a' review of those documents.

Accordingly, Applicants will make those documents avail-able at VEGP at a mutually convenient time, both in

. response to Request for production of Documents No. 21, as well as in response to this interrogatory.

T-14.

Question:

What vendors have been replaced? Why? provide details, including reasons for replacement, name and address of vendor, name and telephone number of contact person for vendor, and other relevant information.

Response:- - - -

Objection. ' Applicants object to this -interrogatory because it is vague and confusing and incapable of response. During the course of the construction of -VEGp, new materia'1 stand' equipment are customarily purchased through a purchase order which is a one-time contract for those -items. !-Di-f ferent v'endors and -dif feridt '-suppliers :

may be used from time to time as the supplier of material and equipment, and the decisions of whether to purchase from supplier A~as opposed to supplier B is made based upon a myriad of factor's such,as price, availability of supplies, and ability to deliver in a timely fashion.

Applicants do-not consider a vendor to have been -

" replaced" when -a ' subsequent purchase order -for similar

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items is 'placed wi~th a dif fe~ rent -supplier.

'To -the extent this ' interrogatory seeks informa'ti~dn regarding vendors who have been replaced during the course of an open purchase orders or before the contract is com-pleted, Applicanty state that they do not maintain any 9

records which would readily reveal the information requested. However, after conducting reasonable inquiry, I

Applicants are aware of only one vendor which has been so replaced. ABC Cutting Contractors of Atlanta, Inc., 4787 Clark Howell Highway, No. 3, College Park, GA 30349, (404)

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768-0965, was allowed to terminate its contract with Georgia Power Company on or about August 27, 1983. The reason for allowing ABC Contractors to terminate its agreement with Georgia-Power Company was not related to its qua11ty assurance piogram, and ABC Contractor's fid not

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leave any unsafe condition at VEGP. ,

Accordingly, Applicants'further object to the remain-der of this interrogatory-because it~does not call for

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i information which is relevant to the subject matter'of this proceeding, and it iE~no~t r'easonably calculated to

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lead to the discovery of admissible evidence.

T-15.

Question:

Have any procedures been changed (either applicants' 1

or contractors') because workers were unable to comply with the original procedures? Provide details.

- Re'sponse: ,

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No..

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Question: .

What impact on quality of workmanship resulted from

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alleged use of drugs by construction employees? Following s-.. . . .-. .._ - . , , . . . _ . _ . , , _ , _ _ . , . , _ , _ - - _ _ , _ _ _ _ , _ . . - _ _ _ - , . - - - , _ . _ _ , , - . , . , , - . . - ~ _ - , - - , . , -

the arrest of plant workers on . Ag charges, what studies, analyses or other action did the applicants take to assure that quality and safety were maintained in the construc-tion of plant? What were the results of these studies, analyses or other action? provide details, including copies of any reports.

Response

Applicants object to the inquiry set forth in Inter-rogatory No. 16 on the ground that it seeks information beyond the scope of.that which is relevant to the subject matter of this proceeding and it is not reasonably calcu-lated-to lead to the discovery of admissible evidence. It is entirely beyond the scope of Contention No. 8 as admitted by the Board.-

Subject:

to- this,pbjection,. Applicants: state; that there haJ been no detrimental impact on the quality of workman-hip resulting from the alleged use of drugs by construc-tion employees.at VEGPs Applicants further state that the quality control and qua'lity assurance procedures at VEGP, as written.and as implemented with-regard to Contention No. 8 activities, provide for quality control and quality assurance regardless-of whether.the particular worker is

. under the influence.oh drugs at.the time of the work.- If the' work meets the standards of quality, . it is- accepted.

If it is not acceptable, regardless of the reason, it is rejected. -

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T-17.

Question:

Have any workers been fired for any reason by the applicant and/or its contractors / subcontractors following allegations of poor. construction or QA practices at plant Vogtle they made to the NRC, news media, or any other per-son or entity? Provide details.

. Response:_

Objection. Appli. cants object to Interrogatory No. 17 gn thg ground that .it -seeks information beyond the scope of that which is relevant to Contention No. 8 as admitted by the Board. Applicants also, object to this interroga-tory on_the ground that it is burdensome and oppressive and vague and incapable of response. Subject to these objections, Applicants state that.ino worker,has been fir,ed as a result of having made allegations to anyone of poor construction or QA practi'ces at VEGP.

T-18.

Question:

Describe procedures for pouring concrete during all weather conditions, including all measures for -protection of, quality. assurance.

Response:, ,

Objection... Applicants object to this'In errogatory.on the ground _that it.is vague, confusing and incapable of complete response. Further, it. calls for information whichisbeyondthescopeofbontentionNo.8,asadmitted

by the Board because it is not limited by time, location or relation of the contractor to VEGP.

However, subject to this objection, Applicants state that the procedure for pouring concrete during adverse weather conditions is set forth in Procedure No. CD-T-02, a copy o'f which will be produced in lieu of a narrative response to this interrogatory.

T-19.

Question:

Describe procedures for welding during all weather conditions, including all measures for protection of quality assurance.

Response

Objection. Applicants object to this Interrogatory on the ground that it ,'is vigue, confusing and incapable of .

complete response. Further, it calls for information which is beyond the scope of Contention No. 8, as admitted by the Board because it is no't limited by time, location or relation of the confractor,to VEGP.

However, subject to this objection, Applicants state that the procedures for. welding'by these whd generally and routinely perform such tasks at VEGp are set forth in the following written procedure 5'which will be produced in lied of a narrative response to this interrogatory:

(a) CB&I General' Welding Procedures Specification for "

Stud Welding process, GWpS-StudX (REV. 13);

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(b)' Georgia Power Company Plant Vogtle Units 1 & 2 Generating Plant Construction Procedure GD-T-13 (General Welding Control);

(c) Georgia Power Company Plant Vogtle. Units 1 & 2 Generating Plant Construction Procedure GD-T-14  ;

(Distribution, Field Storage, and Handling of Welding Material; (d) Nuclear-Installation Services Company. General Welding Procedure E.S. #300; .. .

(e) Pullman Power Products. General. Welding Standard GWS-Dl.1;-

(f) Pullman Power Products General-Welding: Standard GWS-III/I; -- -

c (g) Pullman. Construction Industries /KenithFortson

. . Company, a,jgint yenture. Procedure for Gas Metal. Arch Welding-Carbon Steel, #FWP-9GZ-299;.

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(h) Pullman Construction Industries /KenithFortson Company, Inc., a. joint venture Procedure for Stud .

_ Welding, V-FWP-310; (i) ' Pullman Construction Industries /KenithFortson Company, Inc., a. joint venture Procedure for FCAW

.. C/S-C/S Galyanized ik). FWP.400; .

..( j )

Pullman Construction. industries /KenithFortson Company; Inc.,.a joint-venture Proceddre for;Produc-tion Welding,of sheet and structural steel, No. JP-9.4.

The measures taken for protection of. quality assurance with regard to welding are set forth in PSAR and FSAR 6

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Chapter 17, which is available to Intervenors as a public l record. Updates of Chapter 17 of the pSAR will be pro-

vided to Intervenors in response to Request for Production No. 11.

T-20.

Question:

What is the identification of the individuals who per-formed the in-process, testing pf the plastic concrete for the Unit 1 RB basemat pour? l Response: .

Paul Ryals John Herrington

. W. N. - G ross -

Martin Peterson Barry Grier James Sursson Doug Clary

,T-21..-

Question:

What is the identification of the individuals who inspected the concrete' placement for this' pour?

Response: -

Gracien:. Rodeme r- - -

.. Bo bby- McNu r r- - -

Luther. James -

Greg Jordan ..

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T-22.

Question:

What assurance is provided that equipment stored on-site is adequately protected prior to its installation?

Response

The procedures which govern the equipment maintenance and storage program encompass the requirements of the applicable industrial standards, design specifications, vendor recommendations, and engineering directives. The maintenance and stofage sequence is as follows:

Each item of equipment (permanent plant equipment) received on-site is reviewed by the -respective drscipline equipment enginesr itho determines if the' item is~to be entered into the maintenance and' storage program. If the equipment 'is sntered -into the program, the :enginder- wil-1 specify via a maintenance report card (for each item of equipment) the storage and maintenance criteria and the frequency,of inspections to be performed by quality con-trol personnel, and he will gi.ve a detailed explanation of inspection requirements.

For each inspection performed by quality cont'rol, the maintenance report: card is-posted with approp'rtate ~

. entries,;datede. signed, and filed as a permanent quality document.The type's'of inspection!re'quife'ments'found-on the maintenance .and storage report cards arei ~

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(a) protective' covers'and sials intact ~to protect equipment internals;

(b) physical damage to equipment; (c) environmental damage; (d) proper level of storage (per ANSI N45.2.2);

(e) heat applied to internals (if required);

(f) nitrogen purge (if required);

(g) shaft rotations (if required); and (h) lubrication (as specified by the vendor).

Any non-compliance or deficiency detected at any time to an item of equipment is reported in accordance with .

site procedures. Corrective action is dispositioned by appropriate engineers, corrective action is performed, the equipment is reinspected by quality control to verify that the approved _ corrective-action was taken, and the correc-tive action report is-filed as a permanent quality document. ,. .. -: . ..- . .. ..

This maintenance and storage program serves to insure that all equipment is stored and maintained so as to remain in an."as received" condition throughout the con-struction phase of the' Plant.

Other programs which supplement and enhance the main-tenance and storage program are:

(a) Megger Program, which.is a program to. test the insulation resistance-of motors on a set frequency, to insure.the. integrity of: motor windings; - -

(b) Purge-programi whichnis designed to insure that the-proper-nitrogen purge crushers are maintained for

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all items of equipment which require a nitrogen blanket; (c) Walk through inspections performed biweekly to insure equipment storage areas are being maintained to the required levels of cleanliness; (d) Periodic inspection checklist (P.I.C.) performed once each month to insure that th'e entire plant site is being maintained to the required cleanliness standards. .

Various specifications govern the inspection and maintenance of items in storage. Rather than restating a narrative summary of each of these specific procedures, they will- be produced in 1ieu of. a narrative :respon.se-.-

These written pro.ceduces are as follows: --

- . _ .( a) .- Geo.rgia. fower. Company .Pl. ant .Vogtle Units. :14.4 Generating Plant Construction Pr'ocedure GD-T-9 (Inspection and Maintenance of Items in Storage);

(b) Georgia Power Company Plant Vogtle. Units' l & Generating Plant Construction Procedure ED-T ,

(Insulation Tests);

(c) Georgia Power Company Plant Vogtle Units 1 & 2

- Generating Plant.Constr.uction Procedure GD.-T-17 .

(Housekeeping); _. - . _ .:

[

(d) . America.n National-Stand.ard Reactdr Pl-ants and.

-their Maintenance, Packaging, Shipping, Receiving, Storage and Handling of items for Nuclear Power Plants (during the construction. phase) ANSI N45.2.2; M

(e) American National Standard Reactor Plants and their Maintenance Housekeeping (during the construc-tion phase of nuclear plants), ANSI N45.2.3; (f) Electrical Construction Specification for the Georgia Power Company Alvin W. Vogtle Nuclear Plant, Burke County, Georgia, Units 1 & 2, Specification No.

X3AR01 Section Ell Storage and Protection of Equipment

.and Materials (Rev. 5);

(g) Georgia Power Company Generating plant Construc-tion Department Mechanical Equipment Maintenance and Storage Program MI-A-13; (h) Georgia- Power. Company Generating Plant Construc-tion Department Instrumentation Equipment Maintenance and Storage- MI-A-235 - - - -

(i) _ Georgia Power Company. Generating: Plant.Construc-tion Department Mechanical Purging MI-T-03; (j) Georgia Power Company Generating. Plant Construc-tion Department- Receipt, Storage and Maintenance Pro-gram for equipment' items of the steam turbine / genera-tor package.MI-T-04; .. .

(k) General Power Company Generating Plant Construc-tion Department Maintenance Program for. Construction operated. equipment MI-T-05;- ;; -

'(1):. . Georgia. Power Company- Generating . Plant- Construc-tion Department HVAC Equipment Maintenance Storage

~

Program MI-T-06; -

(m) Georgia Power Company Generating Plant Construc-tion Desktop Procedure Vogtle Nuclear Plant Project Procedure No. DT-E-13 Description of EM/SL Inspection Requirements.

T-23.

Question:

What follow-up inspections have been performed, and with what results, to ascertain what damage was done to the electrical cabinets on-site? Provide details.

Response: ,

As stated in response to the preceding interrogatory, inspection of all equipment is an ongoing process'in VEGP. When: damage torthe equipment has been determined, a deviaticn rsport is prepared and~the appropriate proce a

~ ~

dures are 'followed -to remedy-the situation. :All:of-the deviation reports pertaining to damage of equipment, including damage to electrical cabinets on-site, will be produced i,n response to Intervenors' Request for-Produc-tion of Documents. Accordingly, in lieu of a narrative response to this interrogatory, Applicants offer the deviation reports in response to the Reque'st for Produc-tion of Documents -No. '21, ' as well as in response to this interrogatory.^.The'information sought by Interveners in this interrogatory may"be-gathered by Inte'rvenors' review of those documents.

9

T-24.

Question:

What provisions does the applicant have to assure that materials are traceable if defective materials are found?

Provide details.

Response

Applicants employ the following procedures to assure that items within the scope of Contention No. 8 are traceable if defective. materials are found:

(a) Weld Filler Material:

All weld filler material purchased for use at VEGP meets the : requirements of -ASME Sect-ion -III Class I and -Class -FI, -as - applicable. - .

When weld: filler material is received on-site, it

, is.placed on hold untif all the QA documentation is reviewed and accepted by the GPC Document Review Sec-tion. This review includes verification of compliance to Purchase Order / Specification for the. Equipment /

Material, review fo'r Certi.ficate of Compliance (C of C) and Certified Material Test Report ( CMTR)., a s.

applicable. If.QA Documentation is acceptable, QC remov_es item (s).ot. material (s) from hold and item (s) or material (s) are placed in storage until requisi-

'tioned for issue to the appropriate Weld Material Distribution Center' (WMDC).

Weld filler material received at the WMDC is separated into different types and sizes and stored 6

until issued for use. When weld material is issued, the welder identification and the weld material heat / lot / control numbers are documented on the weld rod issue log and weld rod issue ticket which are stored in the QA Records vault and are permanent plant documentation.

In the event that a batch of' weld filler material that was issued to a welder is later found to be defective, the area where the defective weld material

. was used can be traced through review of supporting documentation, i.e. time sheet job charges, inspection reports, and/or weld rod issue logs and tickets.

(b) - Safety.Related Equipment:

Safety -Related Equipment -is received -on-site -at

.- .the;GpC. warehouse.,,The-equipment is placed on hold ,

until receipt inspection is performed. Once receipt inspection and document review is complete, the equip-ment is -ready -for issue. Safety related. equipment is.

assigned a unique plant tag number. This tag number

. provi' des construction traceability.

In the event _that a piece of equi'pment is later

, found,to be defective, location of that equipment can

.be traced through the. equipment tag number. . .

(c) Concrete materials:_ ,

-Concrete materials received on-site are inspected, random samples-taken for testing, and required documentation verified prior to un~ loading.-

During production of concrete various tests are con-ducted to assure materials meet requirements. Fresh concrete tests are also conducted after concrete batching along with test cylinders being taken for compressive strength tests. These cylinders are traceable to the actual placement so that any below standard placements can be identified. Details for concrete work are in procedure CD-T-02 which is being produced in- response to Interrogatory No. 18 above.

- T-25.

Question:

Does the applicant or any of its contractors'or sub-con'tr' actors maintain:any quote.or target system for dis -

~

missing' workers?' Provide details. -

--Response::: I r. .  :--- - . - 1.  :- ..

Objection. Applicants object to this interrogatory on the ground that it is beyond the scope of Contention No. 8 as admitted by-the Board...Furthermore, Applicants-object on the gound that'this 1nterrogatory is vague, confusing

~

and not. capable of intelligible response. Applicants are unable to interpret _what the Intervenors mean by a " quote or target system for dismissi-dg . workers."

.- . T-26.

^~

- ~ ;.

' Question:.: I '. ~ .;" "' . :-

Does the'presenta' tion of a'new Readiness Review Plan imply-that the existing quality control / quality assurance

---

~w - , , -_ -- , . . , , , , , , _ ,

program was deficient? What changes have been proposed?

What changes have been implemented?

Response

No, the presentation of a new Readiness Review Plan does not imply that the existing quality control / quality assurance program was deficient and in fact, the quality control and quality assurance program is not deficient.

No changes have been proposed in the QC/QA program by the Readiness Review plan. No changes have been implemented in the QC/QA program by the Readiness Review Plan.

T-27.

Question:

What requirements exist to assure the proper training of engineers for the Applicant, its contractors and its subcontractors? Provide details.

Response

Objection. Applicants object to this inte.rogatory on the ground that it is vague and confusing and' incapable of intelligible response. There,are many types of engineers

~

'from those who receive bachelor of science degrees to those who are called engineer by fellow workers but who do not'have any sort of formal training. - Accordingly, this interrogatory is incapable of response as it is drafted.

-T-2 8 .

Question:

provide details on the cracking in the containment rack pipe welds. Why were workers not trained'so as to'

- -n -

- , , - , 6 ,- - ,

r , , , , - - ~ - - - - -

4 prevent such an occurrence? What measures have been taken I to assure that similar breakdowns do not occur in other 1 l

areas? Provide specific details, including specific )

changes in the existing QA/QC program in response to this discovery.

Response

The details on the cracking in th'e containment pipe rack walds are provided in a letter from Mr. D. O. Foster to the NRC dated October 17, 1984 a copy of which has already been provided to Intervenors.

The welders performing the work are trained to deposit quality welds and are qualified in accordance with the ASME Boiler and Pressure Vessel Code Section IX, Qualifi-

~

cation Standard for Welding and Brazing Procedures, Welders Brazers and Welding and Brazing Operators.

To prevent possible further occurrences with the installation of Unit 2-rack assemblies, the contractor will be provided an installation sequence developed by Bechtel. The contractol is now required to develop a specific fabrication procedure which will be reviewed and become part of the QA/QC program.

T-29. --

~ ~ ' ~

~ Question:

What vendor provides core drilling at the site? What experience does this vendor have in this field? What training do its workers have in core drillin'g? Provide details. .

n -

Response

Objection. Applicants ooject to this interrogatory on the ground that it seeks information which is not relevant to the subject matter of this proceeding and is not calcu-lated to lead to discovery of admissible evidence. It is entirely beyond the scope'of Contention No. 8. as admitted by the Board. The present subcontractor performing core drilling has not used that process in connection with documenting the placement of concrete, testing concrete or the preparation of correct concrete quality test records.

T-30.

Questi.on:

What tests have been conducted on the lifting eyes of concrete hatch covers? Provide details of the testing, including results.

Response

Objection. Applicants object to this interrogatory on the ground,that it seeks information which is not relevant to the subject matter of this. proceeding and is not calcu-lated to lead to discovery of admissible evidence. It is entirely beyond the scope of Contention No'. 8 as admitted by,the' Board. Any tests which may have been conducted on the lifting eyes-of concrete hatch covers do not involve documenting the placement of concrete, the' testing of con-crete, the. preparation of concrete quality test records, the procurement of material and equipment, or the pro-tecting of equipment. l l

. 1

T-31.

Question:

What measures have been taken regarding unqualified motors in Limitorque motor-operated valves? please pro-vide details of the problem and the applicants' response thereto.

Response

Objection. Applicants object to this interrogatory on the ground that it seeks information which is not relevant to the subject matter of Contention No. 8 and is not cal-culated to lead to discovery of admissible evidence.

T-32.

Question:

Describe in detail any problems the Applicants have experienced with the residual heat removal system, includ-ing potential consequences and measures to correct each problem.

Response

Objection. Applica~nts object to this interrogatory because it calls.for information which is not relevant to the subject matter of this proceeding and is not calcu-lated to lead to the discovery of admissible evidence.

Further, it is extremely beyond the scope of Contention No.'8 as admitted by the Board. ,

l l

1 l

l i

e O

C. Request for Production of Documents Relatina to CPG /GANE Contention No. 8 U-1.

Request:

Provide a copy of the approved qualified vendors list, qualifying letters, and qualifying materials.

Response

Applicants do not have a document called a " qualified vendors list," or other documents such as those requested.

See Response to Interrogatory No. 2, above.

u-2.

Request:

Provide copies of all inter.?.l or other audits of quality assurance / quality control at Plant Vogtle.- -

Response

All such documents which are within the scope of Contention No. 8 as admit.ted by the Board and which pertain to Contention No. 8 activities will be produced at VEGP at a' mutually agreeable time.

U-3.

Request:

Provide copies of all I & E Reports relating to qu'ality assurance / quality control at Plant Vogtle.

Response: .

All such documents which are within the scope of Contention No. 8'as admitted by the Board'and which i

i pertain to Contention No. 8 activities will be produced at VEGP at a mutually agreeable time.

U-4.

Request:

Provide copies of all Stop Work Orders for Plant Vogtle.

Response

~

All such documents which are within the scope of Contention No. 8 as admitted by the Board and which pertain to Contention No. 8 activities will be produced at VEGP at a. mutually agreeable time.

U-5.

Request: -

Provide copies of all contracts with A & W Oil.

Response: - - -- .- -- -

Objection. Applicants object to the production of the contract with A & W Oil-on the ground that it seeks infor-mation which is beyond the scope of Contention No. 8 as admitted by the Board, and thus the information contained l

~

in any such contract is irrelevant to the issues in this proceeding.

U-6.

Request:

Provide .a copy 'of 'the contract f o r t he' We's ting h'ouse -

~

- '- ~

NSSS.

O

l

Response

Objection. Applicants object to the production of the NSSS contract with Westinghouse on the ground that it seeks information which is beyond the scope of Contention No. 8 as admitted by the Board, and thus the information contained in any such contract is irrelevant to the issues in this proceeding. Applicants further object on the ground that this Request calls for proprietary and confi-

~

dential informationi -

U-7.7 -

Request:

Provide a copy of the contract with Bechtel.

~

Response: - 4~ - - -

• Objection. Applicants object to the production of the contract'with Bechtel on the grodnds that it seeks infor-mation which is beyond the scope of Contention No. 8 as admitted by the Board and'thus the information contained in any such contract:is irrelevant to the issuestof'this proceeding. Applicants further object on the ground that

~

this Request calls for proprietary and confidential infor-mation.

~

. U-8.

~

~ -

Request:

-Provide -a -copy of 7the procurement' procedures manual.

~

Response

~ ~

- A copy of the procurement manual will be produced at

~

VEGP at a mutually convenient time.

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U-9.

Request:

Provide a list of all contractors and subcontractors engaged by applicants to perform any activities pertaining to the construction of Plant Vogtle (" activities" include QA documentation and audit work as-well as physical con-struction). Include contractors and subcontractors which were previously engaged by the applicants as well as those presently so.

Response

This document will be produced at VEGP at a mutually convenient time.

~ -

U210.

Request: - -

Provide-a list of all trade unions whose members are involved with Plant Vogtle and, for each union listed, the telephone number and address of the local most directly

~ ~

involved. -

Response

This document will be produced at VEGP at a mutually

^

convenient time.-

~

U-ll.

- ~ ~

Response: - --

~

Copies' ~of- a'lla~mendments tol the PSAR- Chapter will be p'roduced at VEGP'at a mutually convenient time.

U-12.

Request:

Provide all allegations made by Pullman Power Products quality control personnel concerning construction and the applicants' response (s) thereto.

Response

Copies of documents which contain allegations made by Pullman Power Products quality control personnel concern-ing construction and Applicants response thereto will be produced at VEGP at a mutually convenient time.

U-13.

Request: ,

Provide all allegations concerning Walsh Company and the applicants' response thereto.

Response: .

Copies of documents containing allegations concerning Walsh Company, and Applicants' response thereto will be produced at VEGP at a mutually convenient time; except certain personnel records will not be produced because they contain confidential information.

14.

~

Pequest:

. Provide all Plant _Vogtle Quality Concern Forms turned in si~nce'the beginning of construction. '

Response

. Objection: Applicants object to this Request because it calls for release of confidential information. One of

the assurances made by Applicants to workers at VEGP was that the Quality Concerns forms would remain confiden-tial. Applicants strongly believe that this assured anonomity has protected the integrity of the Quality Con-cerns Program. Subject to the objection, Applicants will delete from the forms any identifying information and those Quality Concern Forms which are within the scope of Contention No. 8 as admitted by the Board and which involve Contention No. 8 activities will be produced at VEGP at a mutually convenient time. - -

U-15.

Request:

Provide a list _of.all forms used to document devia-tions from design specifications or procedures.

Response:. .

. A copy of the list of all forms used to document deviations from design specifications or procedures will be produced at VEGP at a mutually convenient time.

U-16.

Request:

-Provide copies of all audit action re~ quests.

-Response: -

Copies of all audit action requests which are within the scope of Contention.No. 8 as admitted by the Board and which involve Contention 330. 8 activities have been -

included with those documents which are produced in response to Request for Production of Documents Number 2.

O

1 U-17.

Request:

provide all corrected action requests.

Response

Copies of all corrected action requests (CAR) which are within the scope of Contention No. 8 as admitted by the Board and which' involve Contentio'n No. 8 activities will be produced at VEGP at a mutually convenient time.

U-18. -

Request: - - - -

Provide all information relating to the " inadequate core cooling system" as discussed at the-meetings June 12 and June 27', 1984. - -

' ^ ~

• Response: - -

Applicants object ~ to producing- the-documents requested .

in this paragraph because none of the information con-tained in the documents requested would be within the scope of Contention-No. 8 as admitted by the Board ~ . It'is therefore irrelevant to these proceedings and not calcu-lated to' lead to the discovery of admissable evidence.

U-19.

,-Request:

Provide all.information relating'to-the' meeting of August-22, 1983 concerning subcontractor? Q~uality: Assurance.

Response

Objection. Applicants object .to this Request on- the grounds that it is overly broad and vague and' calls for-

d information beyond the scope of Contention No. 8 as admitted by the Board. Subject to this objection; Appli-cants stat that some of the documents requested in para-graph 19 are included within those documents which will be produced in response to Request for Production of Docu-ments, paragraph 12, above.

U-20.

Request:

Provide any statements or agreements which applicant or its contractors / subcontractors may require workers to sign or otherwise comply with which restrict or regulate in any way the employees' talking to or being involved with the NRC, NRC-staff,-news-media, intervenors, public interest groups;-or any-other person or entity concerning the construction of Plant Vogtle.

Response

Objection. Applicants object to producing the docu-ments requested in this paragraph because none of the information which would,be contained in such documents would be within the scope of Contention No. 8, 's admitted by the Board. Subject to this objection," Applicants state that'there.are no such documents. -

~

U-21.

~ ~

.Requesti 2 L ~ - '

Provide' copies ~of all non-conformance reports, devia-tion analysis reports, action requests,' corrective action O

e

requests, audit action requests, field variance authoriza-tions, deficiency reports, field questions, stop work notifications, stop work releases, field disposition instructions, field deviation dispositio'n requests, Plant Vogtle construction work authorizations, conditional

~

releases, and audit reports generated at Plant Vogtle from the inception of construction to the present.

Response: -

Applicants maintain no documents known as " deviation

~

analysis reports",'" action requests", " field variance authorizations", " field questions", " field disposition instructions", " field deviation disposition requests."

~

Appl'icants m'aidtdin a document known as a' construction work request which 'is presumed to be referrdd to by inte'rvenors as i

• Plant Vogt'le ' construct' ion w6rk authori-

~

zation." Those documents, and all non-conformance reports, conditional releases, and deficiency reports which are within the scope of' Contention No. 8 as admitted by the Board and which involve Contention 'le. 8 activities wi.ll be produced at VEGP at a mutually convenient time.

~

Corrective action requests will be produced in -

re,,sponse to Request No. 17, above.

Stop work notifications (which-include stop work

~

releasds)'will bekproduced in riiponse'~to Rdq'uest No. 4

' ~

~ ~

above.- ~ -

Audit Reports (which include audit action ~ req'uests)

~

willbeproducedinResponsehoRequestNo.2,'above.

• i 4

U-22.

Request:

Provide any trend analyses performed at Plant Vogtle.

Response

All such documents insofar as they are within the scope of Contention No. 8 as admitted by the Board and insofar as they involve Contention No. 8 activities will be produced at VEGP at a mutually convenient time.

U-23. ,

Request:

- - -' ~~'

Provide the master deficiency list.

Response

A copy of this document will be_ produced at V,EGP-at_a _

.mut ually convenient time. '

U-24.

Request: - --

Provide any engineering change notices generated at Plant Vogtle for any reason following the discovery that equipment could not meet the original specifications.

Response

As described in response to Interrogatory No. 13, above, Applicants do not have a specific document which is

-known as an engineering change notice. Any " engineering change notice" (as that word may be used by the Inter-venors) which document.would have been generated at VEGP following the discovery that equipment could not meet the 0

original specifications would be included within the deviation reports which have been already produced to the Intervenors in response to Request No. 21, above.

4 U-25.

Request:

Provide all documents relating to core drilling into rebars at Plant Vogtle.--

Response

Objection. This request for production of documents is beyond the scope of Contention No. 8 as admitted by the Noard. It is therefore irrelevant to these proceedings and not calculated to lead to the discov'ery of admissable evidence. Any core drilling i'nto rebars at~ Plant' Nogtle would not have been for the purpose of documenting the

~

- placement of concrete, for testing the concrete or 'for the

~

preparation of correct concrete qdality test' records ~or done in connection with any welding procedure.

U-26.

Request:

Provide all documents relating to storage of equipment on-site, including but not limited to storage of electri-cal cabinets. _

. Response:

dbjection. Applicants object to this. request for production of' documents in that it is burdensome and f

. oppressive. To the extent the Interv.enors seek to review e

J + 0

-g- ,-,,~~w-s - , ,a-,s- ,- , - - , - -

y,- --e- -

- r ,e ---w , . , - - -. - --

documents generated by QC/QA in connection with the non-e conformance of the storage procedures with regard to the storage of a particular piece of equipment on-site, those documents will be produced in response to Request for Pro-duction of Documents No. 21, above. Any further informa-tion requested would be irrelevant and beyond the scope of Contention No. 8 as admitted by the Board.

Respectfully submitted, J)n es E. Joinkt, P.C.

Ch rles W. WhlAney Kevin C. Greene Hugh M. Davenport TROUTMAN, SANDERS, LOCKERMAN

& ASHMORE George F. Trowbridge, P.C.

_, _ _ . . Ernest L. Blake,.Jr., p.C.

' David R. Lewis *

, ~

SHAW, PITTMAN, POTTS

& TROWBRIDGE Counsel for Applicants Dated: January . ' , l985 h a>r M4 m e

January 11, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the matter of _

GEORGIA POWER COMPANY, et a1  : Docket Nos. 50-424

50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)'  :

AFFIDAVIT I, E. J. Turner,. being duly sworn , hereby state that I am employed by : Georgia. , Power Company -as Project Procurement Manager. -

The information. reflected in, the interrogatory responses contained in the Applicants' Response to Intervenors'. Second Set of Interrogatories and . Request for Production of Documents No.2 and 14, is true and correct to the best of my knowledge, infonnation, and belief.

/ _l. c;C E. J. y er_ -

~Sw6rn'~to and subscribed befor'e me_this fyg[(, day of Oamw ,19857 -

V f .

ccidk YSO BOTARYU'UBLIC My Comission Expires: 84r/9 //./9I

January 11, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION A

Before the Atomic Safety and Licensing Board In the matter of  :

GEORGIA POWER COMPANY, et a1  : Docket Nos. 50-424

50-425

- (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

AFFIDAVIT I, Robert McManus, being duly sworn, hereby state that I am employed by Georgia Power Company as Assistant Project Construction Manager II.

The infonnation reflected in the interrogatory responses corttained .i.n the fLppl.1 cants'. . Response to Interv.enors'

, _S_econd Set of Interrogatories and Request for Production of Document No. 26, is true and correct to the best of my knowledge, infonnation, and belief.

~

' Robert 19cManus=

~

Sworn lo and subscr.ibed before me this

/0 day of u2,a.u s ,1985.

. _ ___ __ _ g -.

Am Ch $ ku NOTAltf-P SL K/ -

MyConnissionExpires:);,m 70.

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- . . .. . .. - - . . - . . _ . . . . . - . . - _ . ~ . . _ _ . . . . . _ . _ . . . - . . - . , . - . . - , _ . . ~ - , , _ _ _ . . , . - . - . . _ - - . . _ _ _ _ _ _

January 11, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the matter of  :

GEORGIA POWER COMPANY, et a1  : Docket Nos. 50-424

50-425 (Vogtle Electric Generating -  :

Plant, Units 1 and 2)  :

AFFIDAVIT Bishop, being duly sworn , hereby state I, J. 'L. that I am employed by Georgia Power Company as Inspection Supervisor.

The information reflected in the interrogatory responses contained in the Applicants' Response to Intervenors' Second Set of Interrogatories and Request for Production of Documents

.: ..  : . :5 -:: ' :: ::  ::._. .. :-  :..: Ia:: :

No. 20 and 21, is true and correct to the. best of my knowledge, infonnation, and belief.

j(. ,

@/3

/ s J.p.' Bishop g

.- - . . -. ~-.

Sworn to a subscribed before me this t

$ day. fhD Mr , 1985.

iau A

//#

NOTAR[PUBLIC My Comission Expires: :.ctm e . m.s;.sc,.

. v. .w.:;4.imt

3.  ;;.y n,A:t tm",s3 I

January 11, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the matter of  :

GEORGIA POWER COMPANY, et al-  : Docket Nos. 50-424

50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  : ,

AFFIDAVIT I, Bennie Harbin, being duly sworn, hereby state that

~

I am employed by Georgia Power Company as' Manager of Quality Control.

The information reflected in' the interrogatory responses contained in th'e Appl'icants' Response to Intervenors' 'Second

~

Set of Interrogatories and Request for Production of Documents

~

No.10,13,15,18,19 and 23, is true and correct to the best of my knowledge, information, and belief.

4 i _

Bennie Harbin ~

1

\ .

1 Sworn to a s ubscribed before me this 3.

/O day $4_ /d{d)$ 1985. _ _

/ - . lA>AW /

OTARY UBLIC V' -

w ,. 4'. ~ ~ u .eu

- My Co ission Expires:" : w w.3 t W L5 J': l'^

January ll, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atorr Safety and Licensing Board In the matter of  :

GEORGIA POWER COMPANY, et a1  : Docket Nos. 50-424

50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

. AFFIDAVIT I, Larry Blocker, being duly sworn, hereby state that I am employed by Georgia Power Company as . Assistant Manager, Quality Control.

-The information reflected in -tbe -interrogatory responses contained - 4n - the Applicants' ' Response -to .Intervenors' .Second Set of Interrogatories and Request for Production of Document No. 24, is true and correct to .the best of my knowledge, informatio,n, and belief,

~

' k6rry amockerAJLAm

)

Sworn to a ubscribed.before me this

& day lo ' ra u d ,1985. ,

.f

/

ha ,s a /. '

s NOFARJ PUBLIC \-

/ .g g/jf n..aur...~.*d.;; A 5"'i '4; #d My Commission Expires:fr *0%nnu w.ni ;.tr u. W

• ,, -, -------y , ,-

January 11, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the matter of  :

GEORGIA POWER COMPANY, et a1  : Docket Nos. 50-424

50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

AFFIDAVIT I, Keith Caruso, being duly sworn, hereby state that I am employed by Bechtel Power Corporation as M&QS Coordinator.

The infonnation reflected in the interrogatory responses contained- in-the: Applicants' Response -to Intervenors' Second Set of Interrogatories:.and Request for.. Production -of Document No. 27, is true and correct to the best of my knowledge,

~

information, and belief.

d Keith Caruso 1 _. .

._~ ---

Sworn to and subscribed before me this ay of 1955.

~~~

p hk N IAKY &UBLIC w

My Commission Expires: /

/

N 9

l

-~.-,,--,.--,.--c-

. , . , , . . ,-e-,.,--, , , - - - , - - , , , , . , - , . , - , . . , - - - - , - . , - . - , - - - , , ,,.n,,,- ,,

JwH 11 'et 11:15 00; "GGTLE D G F.e; January 11,1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY Co MISSION Before the Atomic Safety and Licensino Board In the matter of  :

GEORGIA POWER COMPANY, et a1  : Docket Nos. 50-424

50-425 (Vogtle Electric Generating  :

Plant. Units 1 and 2)  :

AFFIDAVIT I. Charles Hayes, being duly sworn, hereby state that I am employed by Georgia Power Company as Vogtle Quality Assurance Manager.

The information reflected in the intsrrogatory responses contained in the hpplicants' Response to Intervenors' ,

Second Set of Interrogatories and Request for Production of Documents No. 3, 6 and 16. is true and correct to the best of my knowledge. .information and belief.

I

~

kAN Charles Hayes # -

• t Sworn to and subscribed before m this I ,

g day of

-y.b. -. . +_M -

, 1985.

DeJ6 Sh '

SARF'PUBLIC --

- My Comiss' ion Expires: M///98

.+, . : n :::a co: "ostu a a a.a:

January 11, 1985 l

UNITED STATES OF AMERICA NUCLEAR REGULATCRY COMMISSION

\

Before the Atomic Safety and Licensina Board 1 l

In the matter of  : -

GEORGIA POWER COMPANY. et a1  : Docket Nos. 50-424

50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

AFFIDAVIT I. Hank Swain, being duly sworn, hereby state that I am employed by Georgia Power Company as Section Supervisor, Quality Control..

The information reflected in the interrogatory responses contained in the Applicants' Rasponse to Intervanors' Second Set of Interrogatories and Request for Production of Document No. 22, is true and correct to the best of my knowledge, information. and belief.

i I

r.nk Hank Swa1n v st=

?

l l

Sworn to and bscribed_before me this l

// day at .

,1985.

f .

NJTARY PUBLIC

%g . - . , . . . .

My Commission Expirer. .- -

1' i

---

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JAN 11 '35 11: 27 30; "OGTLE P G P.04 January 11. 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atemic Safety and Licensing _ Board In the matter of  :

GEORGIA POWER COMPANY, et a1  : Docket Nos. 50-424

50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

AFFIDAVIT i

I, Harry H. Gregory. III, being duly sworn, hereby state f

that I am employed by Georgia Power Company as General Manager.

Nuclear Construction.

The information~ reflected in the interrogatory responses contained in the Applicants' Response to Intervenors' Second Set of Interrogatories and Request for Production of Documents No. 8, 9, 13 and 17. is true and correct to the best of my knowledge,1nformation, and belief.

11 AfhnV Harry H/ Gregory /I/T Sworn to and subscribed before me this

. // day o ll

, 1985.

Meh /I/.( /Ig2 NOT{RT PUBLIC 7 [f.r.f~- ;

My Comission Expires: , -- -

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W l

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of  :

GEORGIA POWER COMPANY,  : Docket Nos. 50-424 et al.  : 50-425 (Vogtle Electric Generating  :

Plant, Units 1 cnd 2)  :

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Response to Intervenors Second Set of Interrogatories and Request for Production of Documents," dated January 11, 1985, were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, or where indicated by an asterisk (*) by hand delivery, this ff ' day of January, 1985.

M.

Jam (s E. Joineg J

Dated: January ll , 1,985.

O 4

O

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board' In the Matter of  :

GEORGIA POWER COMPANY,  : Docket Nos. 50-424 et al.  : 50-425 (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

SERVICE LIST' Morton B. Margulies, Chairman

• Douglas C . Teper Atomic Safety-and Licensing Board 1253 Lenox Circle U.S. Nuclear Regulatory Commission Atlanta, GA 30366 Washington, D.C. 20555 Jeanne Shorthouse Mr. Gustave A. Linenberger 507 Atlanta Avenue Atomic Safety and Licensing Board Atlanta, GA 30315 U.S. Nuclear ' Regulatory Commission Washington, D.C. 20555 *Laurie Fowler &

Vicki Breman l Dr. Oscar H. Paris Legal Environmental Atomic ~ Safety and Licensing Board Assistance Foundation U.S. Nuclear Regulatory Commission 1102 Healy Building Washington, D.C. 20555 Atlanta, GA 30303 Bernard Ms Bordenick, Esq.

• Tim Johnson

Office of Executive Legal Director Campaign for a U.S. Nuclear Regulatory Commission Prosperous Georgia Washington, D.C. 20555 175 Trinity Avenue, S.W.

Atlanta, GA 30303 j Atomic Safety and Licens'ing .

Board Panel Carol A. Stangler

,~ U.S. Nuclear Regulatory Commission 425 Euclid Terrace ,

Washin'gton, D.C. 20555 Atlanta, GA 30307

. Docketing and Service Section '

l Offic'e of the Secretary l U.S. Nuclear Regulatory Commission Washington, D.C. 20555 j 1

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