ML20133L861
| ML20133L861 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 08/08/1985 |
| From: | Joiner J TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA |
| To: | Fowler L JOINT INTERVENORS - VOGTLE |
| References | |
| CON-#385-196 OL, NUDOCS 8508120754 | |
| Download: ML20133L861 (4) | |
Text
.
.l%
TROUTMAN, SANDERS, LOCKERMAN & ASHMORE ATTORNEYS AT LAW CANDLER BulLDING, SUlTE 4400 12 7 PEACHTREE STREET, N E.
ATLANTA, GEORGIA 30043 JAMES E. solNER, P.C.
404 658 8000 w eettps DistCT O'4 NWestte DMETE August 8, 1985
- 85 AUG 12 A9 :58 Laurie Fowler, Esq.
I 218 Flora Avenue, NE
{[g[fyjgh, Atlanta, Georgia 30307 BRANCH i
1 l
Re:
Vogtle Electric Generating Plant, ASLB Docket Nos. 50-424 and 50-425 L (Intervenors' Response to Motion for Summary Disposition of Quality Assurance Issues)
- i
Dear Laurie:
We have received Joint Intervenors' July 31, 1985 Response to Applicants' Motion for Summary Disposition of Intervenors' i
Contention No. 8.
In that pleading, Messrs. Johnson and Teper represent to the Atomic Safety and Licensing Board that "Intervenors are in touch with current and former workers of the plant, some of whom are willing to testify on QA concerns" (Response at p.5).
Joint Intervenors also represent to the Board that there may be additional instances involving "QA breakdowns" (Response at p.6).
While no particulars were provided, Joint Intervenors referred parenthetically to the j
meeting of a subcommittee of the Advisory Committee on Reactor i
-- Safeguards held in Augusta, Georgia on July 18 and 19, where Mr. Johnson made a number of allegations based on statements of unidentifed individuals.
I We have carefully reviewed Mr. Johnson's statements to the ACRS subcommittee.
Because they were so sketchy, it is difficult for Georgia Power to follow up on them.
Our attempts are further hampered by not knowing the identity of the individuals 4
who made the allegations.
For example, we do not know when or where the events were supposed to have occurred, and in many cases we cannot even determine whether the alleged occurances involved safety-related work, or whether they had previously been documented and corrected in accordance with the project's QA procedures.
)
h $5000424 l
DR PDR i.
I
TROUTMAN, SANDERS, LOCKEINAN & ASHMcKE Laurie Fowler, Esq.
i August 8, 1985 Page Two i
J To the extent discernable, most of the allegations appear to be outside the scope of Contention 8 as defined by the Licensing Board.
Also, the allegations are in the nature of discrete occurances which, if true, could certainly not be fairly characterized as QA " breakdowns."
Joint Intervenors, however, have suggested to the Licensing Board the possibility
'that some unidentified individuals may be presented to testify 4
on QA concerns.
We have repeatedly asked for the identity i
of individuals who have provided information upon which Joint i
Intervenors rely in support of Contention 8 and we have asked for the substance of that information.
In written discovery, and in Mr. Teper's deposition, we specifically called upon 1
Intervenors to provide us with all pertinent QA information in their possession and to identify individuals who provided information related to Contention 8.
Pursuant to 10 C.F.R.
Section 2.740(e)(1), Joint Intervenors are under a duty to i
supplement their response to discovery and provide us with the identity and location of persons having knowledge of discoverable matters.
In Mr. Teper's deposition, he agreed j
to provide the name of any person who supplied information i
related to Contention 8, although you reserved the right to file a Motion for Protective Order if the informant requested j
anonymity. (Teper deposition at pp.250-257).
Beyond the requirements of 10 C.F.R. Section 2.740(e)(1),
l however, Georgia Power Company is committed to assuring that l
Plant Vogtle is safely constructed and operated and to thoroughly investigating all safety-related allegations made known to it, no matter how vague or what the source.
This commitment i
exists at all levels of corporate management and is unrelated to the <3 resent contested licensing proceeding.
Thus, regardless f
of whether allegations of unsafe construction practices at l
Plant Vogtle are within or without the scope of Contention l
8 as raised by the Intervenors, Georgia Power Company needs to be informed immediately of any and all allegations relating i
l to safety, so that full and complete investigations can be conducted and any problems resolved.
We ask Joint Intervenors l
l to assist us in this regard.
Because of the implications of I
i such matters on the public health and safety, we consider your i
i cooperation to be a responsibility which far outweighs anyone's j
desire to withhold or delay information.
l f
i i
1 l
t i
l I
i
-c________,_.
TROUTMAN, SANDERS, LOCKEZMAN & ASHMo:E Laurie Fowler, Esq.
August 8, 1985 Page Three For these reasons, we ask that you define and more specifically identify the instances of improper construction practices which Joint Intervenors believe calls into question the safety of Plant Vogtle and provide us with the identity of each individual who has provided information which Joint Intervenors believe calls into question the safety of Plant Vogtle.
We ask you to do this immediately so that we can begin the proper investigation and resolution of any such issues.
Sincerely.
OM.
James E.
oiner JEJ/sgp cc:
Service List
a 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)
)
SERVICE LIST Morton B. Margulies, Chairman Douglas C. Teper Atomic Safety and Licensing Board 1253 Lenox Circle U. S. Nuclear Regulatory Commission Atlanta, Georgia 30306 Washington, D. C. 20555 Laurie Fowler Mr. Gustave A. Linenberger Legal Environmental Assistance Atomic Safety and Licensing Board Foundation U. S. Nuclear Regulatory Commission 218 Flora Avenue, N. E.
Washington, D. C. 20555 Atlanta, Georgia 30307 Dr. Oscar H. Paris Tim Johnson Atomic Safety and Licensing Board Campaign for a Prosperous Georgia U. S. Nuclear Regulatory Commission 175 Trinity Avenue, S. W.
Washington, D. C. 20555 Atlanta, Georgia 30303 Bernard M. Bordenick, Esquire Docketing and Service Section Office of Executive Legal Director Office of the Secretary U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Washington, D. C. 20555 Commission Washington, D. C. 20555 Atomic Safety and Licensing Board Panel Bradley Jones, Esquire U. S. Nuclear Regulatory Commission Regional Counsel Washington, D. C. 20555 U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Suite 3100 Appeal Board Panel 101 Marietta Street U. S. Nuclear Regulatory Commission Atlanta, Georgia 30303 Washington, D. C. 20555
.