ML20115J462
| ML20115J462 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/16/1985 |
| From: | Teper D CAMPAIGN FOR PROSPEROUS GEORGIA (EDUCATIONAL), GEORGIANS AGAINST NUCLEAR ENERGY |
| To: | |
| Shared Package | |
| ML20115J454 | List: |
| References | |
| OL, NUDOCS 8504230556 | |
| Download: ML20115J462 (23) | |
Text
o .
pTEDCO@_M UNITED STATES OF AMERICA , .
NUCLEAR REGULATORY COMMISSION
'O '
80CNETED Before the Atomic Safety and Licensing Board USNRC In the Matter of ) '85 APR 22 Aii:28
)
GEORGIA POWER CO., et al ) Docket Nos. 50-424.and-50-4253c : ,
) .
(Vogtle Electric Generating Plant, ) .. .
Units 1 and 2) )
JOINT INTERVENORS' RESPONSE TO APPLICANTS' FOURTH SET OF INTERROGATORIES AND REQUESTS TO PRODUCE These responses are directed to Applicants Georgia Power g al. and pertain to contention Number 8 as accepted by the Atomic Safety and Licensing Board in its
" Memorandum and Order (Ruling on Intervenors' Objections to Order of September 5, 1984 and Other Matters") (Nov. 5,1984). These responses constitute the Intervenors' second round of responses on Contention No. 8.
I. OBJECTIONS TO INSTRUCTIONS The following objections to instructions apply to Applicants' interrogatories and request for production of documents.
- 1. Most of the documents requested by the Applicants are already in the possession of the Applicants. Joint Intervenors will comply with all requests that i are not unduly burdensome, l
- 2. When identification of a person is requested, Joint Intervenors will respond to the best of their knowledge as to the details requested by the Applicants.
- 3. Joint Intervenors will provide all information requested which is relevant to Contention No. 8 and which does not violate the prisacy or the constitutional rights of anyone.
1 85042305% 850416 gDR ADOCK 05000424 PDR j
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- 4. For purposes of these responses, Intervenors employ the definitions of terms provided by the Applicants in the questions; this should not be construed in any way to mean that the Intervenors accept the Applicants' definitions in any other context.
- 5. The responses to the interrogatories shall be on-going; Intervenors shall provide further documentation and evidence as it is obtained. The responses herein are not final in the sense that new information may be added.
- 6. Intervenors' responses to the interrogatories shall be worded in such a way as to provide the most accurate, complete response possible. Intervenors object to-Applicants' efforts to word Intervenors responses by limiting them to inappropriate "either/or" choices.
II. INTERROGATORIES A. Specific Interrogatories
- 1. PROCUREMENT:
8.1-17 (a)Yes (b)Yes (c)Yes 8.1-18 Tube-Line Corporation; Transamerica Delaval, Inc.; Limitorque; Pullman Power i Products; General Electric; G.H. Bettis; Pacific-Scientific 8.1-19 I&E Bulletin 83-06, "Non-conforming Materials Supplied by Tube-Line Corporation Facilities at Long Island City, New York; Houston, Texas; and Carol Stream, Illinois": The Vogtle Project architect / engineer "N" certificate holder, Bechtel Power Corporation, conducted a supplier quality audit of Tube-Line Corporation's Carol Stream Facility and verified that Tube-Line sub-vendors' quality
' assurance programs did not meet all the requirements of the " Code." Bechtel's Materials and Quality Service Group performed chemical and physical property analyses of a sample of fifteen heats out of ninety-three and still found a discrepency when compared to the certified material test reports (CMTR) provided by 2
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Tube-Line.
The Vogtle Project piping contractor and "NA" certificate holder, Pullman Power Products, recommended that Georgia Power Company (GPC) verify that liquid penetrant testing had actually been performed since, according to Tube-Line CMTR's for Class I fittings indicating that the represented materials have been tested and qualified in accordance with subarticle NB-2000 of the Code. Since NB-2000 contains the NDE requirements for Class I components, GPC document reviewers accepted this statement as an adequate indication that required NDE testing had been performed. After reviewing the situation, GPC fnitiated a Deviation Report for design engineering resolution to determine if required liquid penetrant testing records were available.
Design engineering examined the documentation packages for Class 1 fittings but could find no liquid penetrant examination records. Tube-Line Corporation's Carol Stream facility was contacted and requested to provide the missing records. Tube-Line was unable to provide the missing records. Tube-Line was unable to produce the records. (Letter to Mr. James P. O'Reilly [ sic] from GPC, January 14, 1985 File:
X78C24 Log: GN-507)
Emergency diesel generators from Transamerica Delaval are a disaster, as has been extensively documented in Intervenors' responses to interrogatories related to Contention No.14 (herein incorporated by reference).
Radiographs of pipe spools supplied by Pullman Power Products (PPP) were reviewed by GPC after receipt of the components at the jobsite. Indications were found which had not been noted or reported in the PPP radiographic inspection reports. The examination by GPC also detected violations of ASME code radiographic techniques. Radiographic examiners from Bechtel Power Corporation confirmed GPC's findings. (Letter to James P. O'Reilly [ sic] from GPC January 19, 1985 File:
X7B603-MS2 Log: GN-513) i Actuators supplied by G. H. Bertis in laboratory testing resulted in a potential to encounter a degradation of stroking time related to elapsed time from 3
original manufacture. The reason for the potential degradation of actuator performance was traced to the specific combination of seals and grease used in the original actuator. The seal material and grease were identical to those tested in G. H. Bettis qualification report 37274 which had been submitted to and approved by nuclear customers of G. H. Bettis. (Letter to O'Reilly [ sic] from GPC Dec. 6, 1984 File: X7B603-M69 Log: GN 443)
All General Electric AKR-30 and AKR-50 Circuit Breakers had to be returned to General Electric (letter to James P. O'Reilly [ sic] from GPC Dec. 20, 1984 File:
S7B603-PU2 Log: GN-499)
Pacific Scientific shock arrestors contained defective capstan springs which could have resulted in unacceptably compromised system function performance and adversely affected plant safety. This represents a significant deficiency and substantial safety hazard. (Letter to James P. O'Reilly [ sic] from GPC, July 3, 1984 File:X78603-M54 Log: GN-380) 8.1-20 Substance: At a certa 1n date, the procurement office at Vogtle realized they had no QA letters for many of their vendors; the next couple of days they made some up.
Date: After GPC fired 7 of its 11 p'rocurement employees.
How we found out and from whom: Disclosure of this information would violate the confidence in which it was given as well as the privacy and constitutional rights of the individual from whom it was received.
8.1-21 Both.
8.1-22 Please see the responses to 8.1.20 and 8.1.21 above.
8.1-23 Intervenors have not yet chosen a witness or witnesses on Contention No. 8 and have not chosen which documents will be introduced at the time of the hearing.
8.1-24 Please see response to 8.1-23 above.
8.1-25 Intervenors have not yet reviewed documents at the Plant Vogtle site 4
responding to Intervenors' Interrogatories and Request for Production of Documents.
Intervenors will provide this information following such review.
8.1-26 Yes 8.1-27 a) Plant Vogtle facility b) The acceptance of unqualified vendors as suppliers for components and equipment for the Plant Vogtle facility means the Applicants cannot guarantee the ability to cool down the reactor in case of a LOCA which could result in a large contamination of the area endangering thousands of people in the geographic area as well as downstream the Savannah River, c) Many of the procurement employees GPC fired because of unscrupulous behavior should know if they forged QA procurement documents. It is also probable that the supplier salesmen who profitted from the documents realize that somebody provided some kind of QA documents in order for them to provide the Vogtle Nuclear Facility with their unqualified products.
d) See Objection to Instructions 5.
8.1-28 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.1-29 Please see the response to 8.1-28 above.
8.1-30 Intervenors have not yet reviewed the information at the Plant Vogtle site j provided in response to Intervenors' Interrogatories and Requests to Produce.
Intervenors will respond more fully to this interrogatory following such review.
j 8.1-31 Yes 8.1-32 Substance: At a certain date, the procurement office at Plant Vogtle realized it lacked QA letters for many of its vendors and consequently fabricated i them.
Date this became known: After GPC fired 7 of 11 procurement officers.
(
How this became known ar.d the source: We cannot divulge the source of this information as it would be a violation of a confidence, a violation of privacy and a 5
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E. , _ _ _ _ _ _ _ _ _ _ _
r violation of constitutional rights.
8.1-33 Both.
8.1-34 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.1-35 Please see the response to 8.1-34 above.
8.1-36 Intervenors have not yet reviewed documents at the Vogtle site provided in response to Intervenors' Interrogatories and Requests to Produce. Intervenors will provide further response to this interrogatory as warranted following such review.
8.1-37 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.1-38 Please see the response to 8.1-37 above.
G.1-39 No.
8.1-40 Please see the response to 8.1-39 above.
8.1-41 No.
8.1-42 Please see the response to 8.1-41 above.
8.1-43 No.
8.1-44 Please see the response to 8.1-43 above.
8.1-45 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.1-46 Please see response to 8.1-45 above.
8.1-47 Intervenors have not yet reviewed the documents at the Vogtle site responding to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this question following such review.
8.1-48 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.1-49 Please see response to 8.1-48, above.
8.1-50 Intervenors have not yet reviewed the documents at the Vogtle site provided 6
in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
- 2. WELDING 8.2-20 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.2-21 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.2-22 Please see response to 8.2-21 above.
8.2-23 Yes 8.2-24 Yes 8.2-25 Yes a) D. O. Foster, V.P. and Project General Manager, Vogtle Project, b) April 4,1895 (sic) letter from D. O. Foster (GPC) to Mr. Roger D. Walker (NRC) File: X78610 Log: GN-576. ISE Report 8503 (Failure to Adequately Accomplish Corrective Action). Letter to John A. Olshinski, NRC, from D. O. Foster, GPC, dated 26 February 1985. Letter to James P. O'Reilly [ sic], NRC, from D. O. Foster, GPC, 17 October 1984.
8.2-26 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
- 8.2-27 Please see response to 8.2-26 above.
8.2-28 No.
8.2-29 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.2-30 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors 7
i will respond more fully to this interrogatory following such review.
8.2-31 Intervenors have not yet selected their witness or witnesses or'the documents which they will introduce in regard to Contention No. 8.
f 8.2-32 Please see response to 8.2-31 above.
8.2-33 Intervenors have not yet reviewed the documents at the Vogtle site provided i in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.2-34. Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
i 8.2-35 Please see response to 8.2-34 above.
- 8.2-36 Yes.
8.2-37 Yes.
a) In the containment liner penetration t
. b) bud weld c) I & E. reports d) I & E reports 8.2-38 Intervenors have not yet reviewed the documents at the Yogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.2-39 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
, 8.2-40 Please see response to 8.2-39 above.
I l 8.2-41 No l
! 8.2-42 Please see response to 8.2-41 above.
8.2-43 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.2-44 Please see response to 8.2-44 above.
8.2-45 Yes 8
, , - ~ . , _ - - - - - - _ _ _ . . _ . , _ -._ ,._ __ _ ..,..,. _ - ...___, --.. . _ ......- - , ... - _
r 8.2-46 Yes 8.2-47 a) The ones that did not specify the penetrant examination test required by the NRC.
b) They did not specify the penetrant examination test required by the NRC.
c) The one that requires Applicants' construction sheets for examination of reactor coolant pressure boundary welds to specify the penetrant examination test, d) I & E reports.
e) All I & E reports.
8.2-48 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.2-49 Please see response to 8.2-48 above.
8.2-50 Yes 8.2-51 Yes 8.2-52 Please see response to 8.2-47 above.
8.2-53 No 8.2-54 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.2-55 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.2-56 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.2-57 Please see response to 8.2-56 above.
8.2-58 No 8.2-59 Please see response to 8.2-58 above.
8.2-60 Intervenors have not yet reviewed the documents at the Vogtle site provided 9
in response to Intervenors' interrogatories and requests to produce. Intervenors
- will respond more fully to this interrogatory following such review.
8.2-61 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.2-62 Please see response to 8.2-61 above.
8.2-63 Yes.
8.2-64 a) Inadequate welds are being allowed.
b) Most of the wellding present and past.
c) All I & E Reports (Report Nos.- 50-424/85-1 and 50-425/85-11 and Notices of Violation.
8.2-65 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.2-66 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.2-67 Please see response to 8.2-65 above.
8.2-68 Yes.
8.2-69 a) Unknown b) CB&I Procedure RTIN, Revision 4, " Radiograph Examination Procedure for Welds" does not specify that the heat affected zone is included in the area of interest, c) Unknown
~
d) I & E Report 83-16 8.2-70 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.2-71 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
10
. . - - - _ - - . . - . - _ . _ _ _ . . _ _ -__ L _ _ __ . __ __ _ _
8.2-72 Please see response to 8.2-71 above.
8.2-73 Heat Affected Zone (HAZ) radiographic film density on accepted Film SRT-8, R-2, for Unit 1, 458A, Seam No. 2 in the containment dome wsa 4.11 to 4.38. This is -
contrary to ASME B & PV Code Section V, paragraph T-233, which specifies a maximum radiographic film density of 3.80 in the area of interest.
8.2-74 Yes 8.2-75 a) fuel storage pool
'b) too much slag c) confidentiality, privacy and constitutional protection restrict us from disclosing the source of this information.
d) no document CONCRETE 8.3-13 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.3-14 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.3-15 Please see response to 8.3-14 above.
8.3-16 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.3-17 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.3-18 Please see response to 8.3-17 above.
8.3-19 No.
8.3-20 Please see response to 8.3-19 above.
8.3-21 Please see response to 8.3-19 above.
11
8.3-22 Intervenors have not yet selected their witness or witnesses or th2 documents which they will introduce in regard to Contention No. 8.
8.3-23 Please see response to 8.3-22 above.
8.3-24 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.3-25 No 8.3-26 Please see response to 8.3-25 above.
8.3-27 No 8.3-28 Please see response to 8.3-27 above.
8.3-29 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.3-30 Please see response to 8.3-29 above.
8.3-31 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.3-32 No 8.3-33 Please see response to 8.3-32 above.
8.3-34 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.3-35 Please see response to 8.3-34 above.
8.3-36 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.3-37 No 8.3-38 Please see response to 8.3-37 above.
8.3-39 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
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/ . - . - - ___ _ _
8.3-40 Please see response to 8.3-39 above.
8.3-41 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.3-42 No 8.3-43 Please see response to 8.3-42 above.
8.3-44 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.3-45 Please see response to 8.3-44 above.
8.3-46 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to producc. Intervenors will respond more fully to this interrogatory following such review.
8.3-47 Yes 8.3-48 a) Base mat for Reactor Vessel I b) Sept. 1978 .
c) cured incorrectly d) unknown e) I & E Report 87-07 ,
8.3-49 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.3-50 Please see response to 8.3-49 above.
8.3-51 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such revfew.
8.3-52 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.3-53 Please see response to 8.3-52 above.
13
EQUIPMENT PROTECTION 8.4-9 It lacks sufficient description of organizational / functional alignment (internal, external) and related text to describe QA activities, responsibilities and authorities, does not adequately address the major contractor QA programs, and lacks the integration of supporting documents and referencing of controlling procedures for the control of specific QA program requirements.
8.4-10 Please see response to 8.4-9 above.
8.4-11 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.4-12 Please see response to 8.4-11 above.
8.4-13 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.4-14 No 8.4-15 Please see response to 8.4-14 above.
8.4-16 No 8.4-17 Please see response to 8.4-16 above.
8.4-18 Applicants ignore the obvious fact that the first 8.4-5 was a typographical error and should have read 8.4-4.
8.4-19 Intervenors responded to 8.4-4 in their response to Applicants' second set of interrogatories (p. 14).
8.4-20 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.4-21 Please see response to 8.4-20 above.
8.4-22 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
14
9 e 8.4-23 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.4-24 Please see response to 8.4-23 above.
8.4-25 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.4-26 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.4-27 Please see response to 8.4-26 above.
8.4-28 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.4-29 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.4-30 Please see response to 8.4-29 above.
8.4-31 Intervenors have not yet reviewed the documents at the Yogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.4-32 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.4-33 Please see response to 8.4-32 above.
8.4-34 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
CORRECTIVE ACTION 8.5-4 No 8.5-5 Please see response to 8.5-4 above.
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8.5-6 Please see response to 8.5-4 above.
8.5-7 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.5-8 Please see response to 8.5-7 above.
8.5-9 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.5-10 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.5-11 Please see response to 8.5-10 above.
8.5-12 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.5-13 Yes 8.5-14 Supplement to Petition, p. 16.
8.5-15 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.5-16 Please see response to 8.5-15 above.
8.5-17 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
GENERAL
- 8.6-32 No 8.6-33 Please see response to 8.6-32 above.
8.6-34 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.6-35 Please see response to 8.6-34 above.
16
} .
8.6-36 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors
- i. will respond more fully to this interrogatory following such review.
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8.6-37 No
- 8.6-38 Please see response to 8.6-37. -
t i 8.6-39 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
4 8.6-40 Please see response to 8.6-39 above.
4 8.6-41 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors
, will respond more fully to this interrogatory following such review.
j 8.6-42 Yes 8.6-43 Supplement, pp. 15, 16, 17, 18, 19 8.6-44 Intervenors have not yet selected their witness or witnesses or the
- documents which they will introduce in regard to Contention No. 8.
i 8.6-45 Please see response to 8.6-44 above.
8.6-46 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review, t
8.6-47 No (although some should have been).
l 8.6-48 Inadequate construction (all the problems we have cited).
I 8.6-49 No 8.6-50 Please see response to 8.6-49.
(
- l. 8.6-51 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
t 8.6-52 Please see response to 8.6-51 above.
8.6-53 Intervenors have not yet reviewed the documents at the Vogtle site provided l
in response to Intervenors' interrogatories and requests to produce. Intervenors l
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i i _ ._ _ _ r.-______,___._____. _ , _ _ _ , _ _ _ . _ _ , , _ _ _ _ _ _ , _ _ _ _ . _ , , _ . _ , _ . . _ _
- 1. .
will respond more fully to this interrogatory following such review.
8.6-54 Yes 8.6-55 Please see response to 8.6-54 above.
8.6-56 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.6-57 Intervenors have not yet selected their witness or witnesses or the
- documents which they will introduce in regard to Contention No. 8.
8.6-58 Yes a) those workers unable to comply with the original procedures b) field change notices' 8.6-59 -Please see response to 8.6-58.
- 8.6-60 'Yes a) original procedure is not being followed b) it is unproven c) workers who are involved d) field change notices 8.6-61 Please see response to 8.6-60 above.
8.6-62 Yes 8.6-63 Each and every failure which is described in the documents cited.
8.6-64 Intervenors have not yet selected their witness or witnesses or the j documents which they will introduce in regard to Contention No. 8.
1 8.6-65 Please see response to 8.6-64 above.
8.6-66 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors I
will respond more fully to this interrogatory following such review.
8.6-67 Yes 8.6-68 Supplement page 14 18 i
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- , , - o., ,w-~ ,-wn.-------n_,,,n,,,. ,mn--,,w.-----v,, -,,v~,-,,,,,,, --,,,.,,w,,,,,,_m,
8.6-69 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.6-70 Please see response to 8.6-69 above.
8.6-71 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.6-72 a) Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
b) Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
c) Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.6-73 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.6-74 Yes 8.6-75 Yes 8.6-76 Please see all previous submissions by Intervenors related to Quality Assurance.
8.6-77 Intervenors have not yet selected their witness or witnesses or the .
documents which they will introduce in regard to Contention No. 8.
8.6-78 Please see response to 8.6-77 above.
8.6-79 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.6-80 Yes 8.6-81 Please see all submissions by intervenors related to quality assurance.
8.6-82 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
19
8.6-83 Please see response to 8.6-82 above.
8.6-84 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.6-85 Yes 8.6-86 L'e will make copies available at a time and place convenient to Applican;s and Intervenors.
8.6-87 Yes 8.6-88 a) None was issued b) That cited throughout Intervenors' submissions, plus excavation c) Frequently throughout construction d) Violated NRC rules & regulations e) Those involved f) All Vogtle-related documents 8.6-89 Yes 8.6-90 We will provide copies of the documents for inspection by the Applicants at a time and place convenient for the Applicants and the Intervenors.'
8.6-91 Please see responses to the above.
8.6 4
- No 8.6-93 Ple6se see response to 8.6-92 above.
8.6-94 Please see response to 8.6-92 above.
8.6-95 Yes 8.6-96 Supple.1nent pp 15 & 16 8.6-97 Intervenors have not yet selected their witness or witnesses or the documentswhichtheywillintroduceinregardtoContentionNo.8. ;
8.6 t6 Please see response to 8.6-97 above.
8.6-99 Interver. ors have not yet reviewed the documents at the Yogtle site provided 20
in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.6-100 Yes 8.6-101 Supplement pp. 17, 18 & 19 8.6-102 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.6-103 Please see response to 8.6-102 above.
8.6-104 Intervenors have not yet reviewed the documents at the Vogtle site provided in response to Intervenors' interrogatories and requests to produce. Intervenors will respond more fully to this interrogatory following such review.
8.6-105 It would be impossible to give an exact number.
8.6-106 a) Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
b) Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
c) Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.6-107 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.6-108 Yes 8.6-109 No 8.6-110 Yes 8.6-111 Yes 8.6-112 Intervenors have not yet selected their witness or' witnesses or the documents which they will introduce in regard to Contention No. 8.
8.6-113 Yes 8.6-114 The responses are cumulative in nature; the documents made available were used in the preparation of all responses.
21
. _ _ . _ , . _ _ . . _ _ , , _ . , , _ _ _ , . _ . ~ , . - - _ _ _ _ _ _
0 e 8.6-115 A series of notes recording confidential conversations and similar information.
8.6-116 No, not specifically 8.6-117 Please see response to 8.6-116 above.
8.6-118 Please see response to 6.6-116 above.
8.6-119 They have been identified and/or provided.
8.6-120 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.6-121 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.6-122 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
8.6-123 Intervenors have not yet selected their witness or witnesses or the documents which they will introduce in regard to Contention No. 8.
REQUEST FOR PRODUCTION 8-47 Applicants do not explain how this relates to Applicants' definition of Contention 8 activities.
8-48 These documents are already in the possession of the Applicants.
i 8-49 Intervenors have not yet selected their witness or witnesses or the documents j
which they will introduce in regard to Contention No. 8.
f Respectfully submitted,
\ ,f,' -
3 , 3._.4. & ye Douglas Teper i for Intervenors l Georgians Against Nuclear Energy and Campaign for a Prosperous Georgia i
22 l
l
0- -J UNITED STATES OF AMERICA MED .-
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 00LKETED In the Matter of USNRC GEORGIA POWER CO., et al. ) Docket Nos. 50-424 ed 50-425 0 '
) 1D APR 22 N1:27 (Vogtle Electric Generating Plant, )
, Units 1 and 2) ) 0FFICE OF SECRETARV CERTIFICATE OF SERVICE BNC
, This is to certify that copies of the foregoing were served by deposit with the U. S. Postal Service in the City of Atlanta with first class postage attached to be delivered to the Secretary of the Commission, the members of the Licensing Board and all others listed below, this 17th day of April,1985.
, ,.. f . - .
Tim Johnson Campaign for a Prosperous Georgia SERVICE LIST Morton B. Margulies, Chairman Atomic Sifety & Licensing Appeal i Atomic Safety & Licensing Board Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Oscar H. Paris Docketing and Service Section Atomic Safety & Licensing Board Office of the Secretary
- U.S. Nuclear Regulatory Connission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. Gustave A. Linenberger Bernard M. Bordenick, esq.
Atomic Safety & Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Commission Director Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety & Licensing Board Panel Ruble A. Thomas
- U.S. Nuclear Regulatory Commission Southern Company Services, Inc.
Washington, D.C. 20555 P. O. Box 2625 Birmingham, Alabama 35202 Bruce Churchill, esq.
Shaw, Pittman, Potts & Trowbridge Bradley Jones, esq.
1800 M Street, N.W. Regional Counsel, U.S. NRC
- Washington, D.C. 20036 101 Marietta Street, Ste. 3100 Atlanta, Georgia 30303 James Joiner, esq.
Troutman, Sanders, Potts & Trowbridge The Candler Building Atlanta, Georgia 30303 i.Te ,.,,.o,-y-