ML20117B142
| ML20117B142 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/03/1985 |
| From: | Johnson T CAMPAIGN FOR PROSPEROUS GEORGIA (EDUCATIONAL), GEORGIANS AGAINST NUCLEAR ENERGY |
| To: | Joiner J TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA |
| References | |
| CON-#285-911 OL, NUDOCS 8505080486 | |
| Download: ML20117B142 (3) | |
Text
ctu bEduc tirnalCampoignf roPros 175 Trinity Ave.5.W., Atlanta, Georgia 30303 404-659-5675 a
May 3, 1985 DOCKETED James Joiner, esq.
Troutman, Sanders, L'ockerman & Ashmore 1400 The Candler Building
'85 MAY -8 A9 50 Atlanta, Georgia 30303 Plant Vogtle Operating License Proceebb91NCH Re:
NRC Docket Numbers 50-424 & 50-425 4 (Vogtle Generating Plant, Units 1 and 2)
Dear Jim:
This letter is a followup.to our letter of April 19, 1985 in which we provided information concerning our motion to compel.
The typed copy of the letter we sent inadvertently left out three and misnumbered one of the matters we discussed at the meeting; this letter will let you know our understanding of what was said at the meeting.
B-6(p): On our letter of April 19, this was accidentally listed as withdrawn because you had answered it; in fact, it was B-6(r) which was withdrawn because you answered it.
You agreed to provide additional information responding to B-6(p) and we will review that information upon receiving it to detennine if we find it satisfactory.
B-6(r): As stated above, you provided an answer to this question, so we withdraw our request that the Board compel it.
B-6(s): This question asked if you believe that TDI is dedicated to insuring a quality product; you had questioned this yourselves in correspondence with TDI.
You object that this requires speculation, is irrelevant and can be gleaned from TDI's correspondence with you. We responded that while some degreee of speculation, is required, such speculation would be based on your relationship and dealings with TDI (not merely on your correspondence with them) such is not grounds to refuse to answer the question, since it is entirely relevant to the safe operation of the facilities; in fact, a decision by the ASLB to license or to deny a license for the plant would involve speculation by the Board as to whether it would be safe or not based on information available to it. Applicants themselves raised the question of TDI's dedication to quality product in correspondence with TDI. Certainly, this question is relevant in that if TDI is not dedicated to assuring a quality product, it bodes ill for safe operation of the Vogtle facilities. And your response would be based on more than the correspondence which you have made available to us.
You remain firm in your refusal to respond to this interrogatory, so we are forced to maintain our request that the Licensing Board compel a response.
B-47:
You refused to respond to our question concerning procedures in a steam generator tube rupture because you say no such event has occurred in a Westinghouse reactor. As we pointed out to you, your argument is against the contention as accepted by the Board, not against the discovery question.
The Board has accepted
,h U
D 8505080486 850503 PDR ADOCK 05000424 0
.e the possibility of a steam generator tube rupture as a contention in this proceeding so you are required to respond to questions concerning it.
You continue to refuse to respond to this request, so we maintain our request that the Board compel a response.
Sincerely,
./
/,,
- -
- '"l,c n e.:r y Tim Johnson for Intervenors Campaign for a Prosperous Georgia and Georgians Against Nuclear Energy cc: Service List v
--+-, -
1-,
m p
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
DOLK 0
)
U C
GEORGIA POWER CO., et al.
)
Docket Nos. 50-424 and 425
)
(Vogtle Electric Generating Plant,
)
'85 MY -8 A9 :30 Units 1 and 2)
)
OgFig 0{ ggy CERTIFICATE OF SERVICE 4
RANCH This is to certify that copies of the foregoing letter to James Joiner 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 3rd day of May, 1985.
Tim Johnson SERVICE LIST Morton B. Margulies, Chairman Atomic Safety & Licensing Appeal 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 Commission 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 l
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 i
Bruce Churchill', esq..
Shaw, Pittman, Potts & Trowbridge Bradley Jones, esq.
l 1800 M Street, N.W.
Regional Counsel, U.S. NRC-Washington, D.C.
20036 101 Marietta Street, Ste. 3100 l
Atlanta, Georgia 30303 James Joiner, esq.
. Troutman, Sanders, Potts & Trowbridge The Candler Building l
Atlanta, Georgia 30303 l
l' e
- w Tm-m-+-w=,
eew9 eg9-
-p
- wwa, m;
e--v-vy-,,py
+M
.-we--,-y
&*wny--yv vw---=
7m---w g,-=r
-m-e
---TP---