ML20205A875

Forwards Ltrs Exchanged Subsequent to 850417 Meeting of Parties to Attempt to Resolve Issues Raised by Joint Intervenors 850301 Motion to Compel.Certificate of Svc Encl. Related Correspondence

ML20205A875
Person / Time
Site:	Vogtle
Issue date:	04/22/1985
From:	Joiner J TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA
To:	Linenberger G, Margulies M, Paris O Atomic Safety and Licensing Board Panel
References
CON-#285-700 OL, NUDOCS 8504260151
Download: ML20205A875 (14)

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TROUTMAN, SANDERS. LOCKERMAN &*ASHMORE '

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ATTORNEYS AT LAW ca~otER suitoisa. suite e4oo 00CKETED a27 PEACHTREE STREET, N E.

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April 22, 19859Q:r:,C Fjyf{ l Morton B. Margulies, E'sq., Chairman Administrative Judge Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. Oscar H. Paris Administrative Judge Atomic Safety and Lic~ensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Mr. Gustave A. Linenberger, Jr.

Administrative Judge Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 RE: Georgia Power Company, et al.;

Plant Vogtle Operating License Proceeding; NRC Docket Numbers 50-424 and 50-425.

(Vogtle Generating Plant, Units 1 and 2) 4

Dear Administrative Judges:

! As requested in Chairman Margulies' letter to the parties

! of March 26, 1985, the parties met on April 17, 1985, to con-I fer in an attempt to resolve the issues raised by the Motion l to Compel filed by the Joint Intervenors on March 1, 1985, which concerned the Applicants' responses to the Joint Inter-venors' Third Set of Interrogatories. Subsequent to that l

meeting the parties exchanged letters, which are attached hereto, outlin'ing the discussions that occurred on April 17th and stating the positions of the parties.

l The Applicants have agreed to respond further.to interrog-atories B-6 (p) and B-46 of the Joint Intervenors' Third l Interrogatories and the Joint Intervenors have agreed to with-draw those two interrogatories from their motion to compel.

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Dr. Oscar H. Paris Mr. Gustave A. Linenberger, Jr.

April 22, 1985 Page 2 The Joint Intervenors have also agreed to withdraw interrog-atories A-2, A-3, B-6 (r) , B-40, B-41, and B-45 from that motion. The parties have been unable to reach agreement concerning interrogatories B-6 (s) , B-19, B-20, B-24, B-25, B-26, B-27 (c) ,' B-29, B-42, B-4 3, B-4 4, B-47, and B-4 8, and the Joint Intervenors' motion to compel remains before the Board with respect to those interrogatories.

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Ms. Laurie Fowler Legal Environmental Assistance Foundation 1102 Healey Building Atlanta, Georgia 30303 RE: In re Georgia Power Company, et al. (Vogtle Electric Generating Plant, Un E f1 and 2)

NRC Docket Nos. 50-424 and 50-125 Meeting held on April 17, 198f to discuss Intervenors' March 1, 1985 P'.otion to Compel.

Dear Laurie:

l In our meeting on April 17, 1985, we agreed to exchange letters by Friday, April 19, 1985 addressing certain ques-

! tions raised in that meeting. This letter will indicate I which of those interrogatories that are the subject of the Joint Intervenors' March 1, 1985 Motion to Compel the Applicants will respond to based upon our discussions on Wednesday, or may respond to upon receiving further informa-tion from Joint Intervenors. We would also like to identify those interrogatories that the Intervenors agreed to withdraw, or are considering withdrawing, and to outline briefly our position concerning the remaining interrogatories.

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4 Ms. Laurie Fowler April 19,-1985 Page Two t

With respect to interrogatory A-2 of the Joint Inter-venors' Third Interrogatories, the Joint Intervenors indi-

cated in our meeting that that question was intended to i elicit information about any item referred to by the NRC staff as a "open item" whether or not listed as such in the Draft' Safety Evaluation Report. Our position remains that the question is vague, confusing, and largely irrelevant, particularly in light of the fact that it is not limited to open items identified in the draft SER, and that few, if any, of such open items have any relevance to the issues raised by the contentions admitted in the licensing pro-ceeding. You indicated that you would attempt to identify

, for us what you meant by the term "open item" and to identify certain specific items that you felt were relevant to issues raised in the licensing proceeding. We will look at any specific items that you can identify to determine whether a further response with respect to those items would be appropriate.

Interrogatory A-3 requested information about the "Rosenthal experimenter expectancy effect." We reiterated that we have not attempted to analyze any such effect, and the Joint Intervenors agreed to withdraw the question.

Interrogatory B-6(p) asked the Applicants whether they would "again choose TDI if ordering new emergency diesel generators for a new nuclear power plant today." The Appli-cants objected to the interrogatory on the grounds that it asked a hypothetical question that could only be answered through speculation and sought information not relevant to this proceeding.- In our meeting, you asked whether we could explain the reasons why we felt that the question would require speculation and why the Applicants did not wish to engage in such speculation. We will further respond to Interrogatory B-6 (p) to provide that information.

Interrogatory B-6(r) asked about the Applicants' rela-tionship with TDI and whether that relationship had improved since the date of a letter sent by TDI to Georgia Power in April 1984.- Based upon th_ statement in the Applicants'

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Ms. Laurie Fowler April 19, 1985 ,

Page Three response to your motion to compel indicating that the answer to that question is yes, the Joint Intervenors have agreed to. withdraw Interrogatory B-6(r).

. Interrogatory B-6 (s) asks the Applicants whether they "believe that TDI is dedicated to insuring a quality product,"

and the Applicants objected to that interrogatory on the ground that it required them to speculate concerning the subjective-intent of TDI and that it sought information not relevant to the subject matter of this proceeding. Our i position on that interrogatory has not changed as a result

.of our discussions. We feel that responding to the inter-rogatory would require speculation, that any such specula-tion by_the Applicants concerning TDI's intent would not have any relevance to the issue whether the TDI diesel generators will perform their intended function, and that any such speculation would be based upon the correspondence between the Applicants and TDI, which has been produced for inspection by the Intervenors.

The Joint Intervenors' motion to compel with respect to Interrogatories B-19, B-20, B-24, and B-29 related to_that part of those interrogatories that asks the Applicants to

" discuss uncertainty ranges." The Applicants responded,by objecting that that request was vague, confusing, and not susceptible to a proper response. As we indicated in our

meeting, a discussion of " uncertainty ranges" has relevance primarily in the context of statistical analyses and none of the analyses discussed in the Applicants' responses to those interrogatories were statistical analyses. We also indicated that'the Applicants have not performed any mathematical

' analyses of uncertainty with respect to the informa' ion provided in response to those interrogatories. We remain unsure exactly what analyses the Joint Intervenorr are asking the Applicants to perform. For example, wa do not know whether you are referring to the possible margin for error in instrument readings or more generally our confi-dance that our analyses are correct. The data on which those analyses were based has been made available to the Intervenors in response to discovery requests. In our meeting, the Joint Intervenors advised us that you would try L_ to identify the specific parameters about which you were l seeking information concerning ranges of uncertainty. Once we have that information we will determine whether we can make any further response to those interrogatories.

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' TROUTMAN,SANDECS, LOCMERMAN & ASHMORE

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Ms. Laurie Fowler April 19, 1985

.Page Four Interrogatory B-25 requested information about radio nuclides and other contaminants released at Plant Hatch and all:other electric generating-plants in the United States.  ;

The Applicants objected to that interrogatory on relevance .

i grounds and on the ground that it was overly broad and

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unduly burdensome. Our position remains the same. Pro-viding the information would clearly impose an unreasonable burden upon the Applicants without advancing any of the issues raised.in this proceeding. Addressing Plant Hatch specifically, that facility is not at all similar to Plant Vogtle-since it is a boiling water reactor and the geology

. and hydrology of the region in which Plant Hatch is located is completely different from the geology and hydrology in the vicinity of Plant Vogtle.

With respect to Interrogatory B-26, which requests information about the Applicants' financial ability to fund the post-operational environmental radiological and chemical monitoring programs associated with the commissioning Plant Vogtle, our position also remains the same. We feel that the interrogatory requests information concerning the i

financial qualifications of the Applicants' in contravention of 10 C.F.R. S 50.33 (f) and 10 C.F.R. S 50.40(b) and of the Board's ruling rejecting proposed Contention 3 submitted by Campaign for a Prosperous Georgia, which sought to raise the same issue.

We also view Interrogatory B-27 (c) , which requests information concerning the cumulative effects of the opera-i tion of the Savannah River Plant and Plant-Vogtle, to be an i effort by the Intervenors to avoid the effect of prior rulings by the Board.- In its Memorandum and Order on Special j- Prehearing Conference Held Pursuant to 10 C.F.R. S 2.715A l the Board rejected GANE's proposed Contention 2, which l raised the issue of the cumulative effects of the Savannah .

I River Plant and Plant Vogtle. In rejecting that contention, l the Board specifically noted that it was based in part upon l the information provided by Mr. Lawless, including his oral presentation at the Special Prehearing Conference. In light of the Board's specific rejection of the cumulative effects

. contention, our position is that the Board did not intend to allow that same issue to be raised in the context of Conten-tion 7,concerning ground water, as the Joint Intervenors suggested in our meeting.

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Ms. Laurie Fowler April 19, 1985 Page Five l

Interrogatories B-40 and B-41 requested the Applicants  !

to answer certain interrogatories'from the Joint Inter- l venors' First Interroga' tories that concerned the considera-tion of synergistic effects in environmental qualification testing. In Interrogatory B-40, the Joint Intervenors limited the scope of tho'se questions to multiconductor configurations while B-41 addressed specifically solenoid valves and multi-conductor configurations. The Applicants objected to.those interrogatories, and to the interroga-tories contained in the Joint Intervenors First Interroga-tories.that were referred to, on the grounds that they sought information concerning the issue of synergism, which the Board had specifically rejected as an issue in this l proceeding by rejecting the Joint Intervenors proposed Contention 10.2. In our meetir.; we also pointed out that the multiconductor effect, whien is the subject of Conten-tion 10.3, is limited to one specific type of cable that has not been used at Plant Vogtle. The Joint Intervenors agreed to review the information previously provided by the Appli-cants to determine whether they wish to continue to pursue Contention 10.3. To the extent that Interrogatory B-41 seeks information concerning the susceptibility of solenoid valves to synergism, the Applicants' position remains that i the Board has refused to allow synergism as an issue in this proceeding and the Intervenors cannot circumvent that ruling

by seeking to raise.the issue in the context of another contention admitted by the Board.

Interrogatory B-42 requested the Applicants to provide a further response to several interrogatories contained in j the Intervenors'.First Interrogatories that requested information concerning solenoid valves. The Applicants -

limited their responses to those interrogatories to informa-l tion concerning ASCO solenoid valves, which they believe to l

be the sole subject of Contention 10.5. Our position remains that the basis stated by the Joint Intervenors for Conten-tion 10.5 relied-solely upon information about the testing of ASCO solenoid valves by Franklin Research Center and that l Contention 10.5 is limited to the issue of the environmental l qualification of ASCO solenoid valves, i

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i Ms. Laurie Fowler April 19, 1985 ,

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Interrogatories B-43 and B-44 requested information

, concerning the operating experience of the hydrogen recom-biners used at Plant Vogtle, an analysis of problems encountered at Three Mile Island with the hydrogen'recom-biner system, and the maintenance and surveillance program for the hydrogen recombiners. The Applicants' position with

. respect to both of these interrogatories is that the informa-tion sought is not relevant to Contention 10.7, which the Board limited to two specific questions about the qualifica-tion of the hydrogen recombiners. The first question was whether the recombiners contained any transducers or sensors

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important to their functioning.- The second question concerns' l whether qualification testing in an accident environment was performed on an entire prototype recombiner. The information sought by Interrogatories B-43 and B-44 bears no relation to

- the two questions asked by the Board. You advised us in our meeting that the Joint Intervenors would review these ques-tions again to see whether they should be withdrawn.

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- Interrogatories B-45, B-46, and B-47 sought information concerning the all volatile treatment to be used in the -

operation of the Westinghouse steam generators, the main-

. tenance and surveillance program for the Westinghouse steam generators, and the procedures contained in the current Operators Manual for Emergency Action during a steam generator tube rupture. The Applicants responded to these interroga-

- tories by objecting on the grounds that the information

! sought had no relevance to the issue of tube failures caused by vibration-induced fatigue cracking or bubble collapse, which is the only issue admitted by the Board. In our 4 meeting, we again pointed out that Westinghouse steam generators have never had a tube failure caused by vibra-tion-induced fatigue cracking or bubble collapse. The Joint

Intervenors agreed to consider whether they wish to continue to pursue Contention 11. In the interest of resolving that contention as expeditiously as possible, the Applicants will provide a further response to Interrogatory B-46 concerning

, the maintenance and surveillance program for the steam

. generators.

1 Interrogatory B-48 requested the Applicants to answer a i

prior interrogatory seeking information about "the surface

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Ms. Laurie Fowler April 19, 1985 Page Seven and surficial aquifer transmissions from the cooling tower effluent." We reiterated that the Applicants do not under-stand what information is being requested by this interroga-tory, and the Intervenors agreed to provide some clarification of the interrogatory. Once we receive that clarification, i we will advise you whether we will make any further response to'that interrogatory.

Very truly yours, es E. Joinel-JEJ:mh cc: Douglas C. Teper Tim Johnson

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. Educational Campaign for a Prosperous Georgia 175 Trinity Ave.5.W., Atlanta, Georgia 30303 404-659-5675 April 19,1985 coRRES #

James Joiner, esq. '85 APR 25 20:02 l Troutman, Sanders, Lockeman & Ashmore ,

1400 The Candler Building Atlant'a, Georgia 30303 ggg(EkN. s

Dear Jim:

This letter is to provide additional infomation as a result of our meeting on Wednesday concerning our motion to compel and to let you know our understanding of what was agreed upon there.

A-2 (concerning open items): We will withdraw our request that you be compelled to answer this in view of the infomation you have provided.

A-3: As we told you at the meeting, we withdraw this request since you have not done the calculation.

B-6(p): As we said, we withdraw this since N have now answered it.

B-19, B-20, B-24 and B-29: You requested a definition of " range of uncertainty":

The range of uncertainty is the potential for error involved; what is the probability that your calculations are correct? Can you mathematically prove them?

For instance: You can postulate a time for calculated groundwater travel time under the surface to the first outcrop; what is the range of uncertainty of that estimate?

B-25: As we told you, the figures for Plant Hatch are (uite relevant to this proceeding. Analytic calculations are often based on 11heral assumptions which cannot be verified. The Hatch figures will allow nomalization of your calculations for Vogtle against real world experience. In other words, we want to bound your calculations by experiencial data base. We understand that you will not provide this information unless compelled to do so by the ASLB; our request to the Board stands.

B-26: You refuse to answer the question concerning technical measures to prevent groundwater contamination following the useful life of the plant on the grounds that it is not relevant; however, this clearly relates to Contention 7 concerning groundwater. Applicants also argue that Intervenors' question as to financial provisions for preventing contamination of groundwater following plant shutdown is not relevant since it deals with a financia'l question; however, as we explained to you, we asked not whether the Public Service Commission will allow you to collect the money or whether you would be able to collect the money, but whether what mechanism would you provide (that is, are you providing a mechanism to assure that this is done)? The NRC itself, in fact, requires " acceptable decommissioning methodologies, timing, environmental review requirements and funding mechanism"

(" Final Environmental Statement related to the operation of Vogtle Electric Generating Plant, Units 1 and 2," NUREG-1087, p. 9-33, emphasis added). We maintain our request that the Board compel your response.

B-27(c): The effects on the groundwater of accumulated releases (including airborne releases) are clearly relevant to the groundwater contention. This includes data concerning the SRP releases; precipitation cateches emissions and can contaminate the groundwater. The Vogtle data base was generated in the early 1970s; since that time, there has been no effort to update it. How do you know when contamination has

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4 cccurred if the groundwater has already been ccntaminated? Arguably, it has. It is not only' relevant but essential to discriminate Vogtle releases from background releases, an impossible task without up-to-date background data. We understand that at this time you refuse to respond to this request; we therefore let stand our request that the Board compel your response.

B-40: We withdraw this request.

B-41: We withdraw this request.

B-42: . You refuse to respond to 'this question because you claim it goes beyond the basis for our contention; on the contrary, as we explained, our contention concerning solenoid valves goes beyond the ASCO problem (serious in itself) and wording of the Board's order in no way restricts the contention to ASCO valves. We will therefore retain our request that the Board compel a response to this question.

B-43: Applicants argue that operating experience with the type hydrogen recombiner to be used at Plant Vogtle is not relevant. Clearly, the operating experience is relevant. Intervenors maintain their request that the Board compel Applicants' response.

B-44: Applicants argue that maintenance and surveillance of the hydrogen recombiners is not relevant to the contention accepted by the Board. Clearly, it is relevant, since operating experience might lead to the recombiners not being qualified (the concern raised in the contention). Intervenors maintain their request that the Board compel you to respond to this question.

B-45: We withdraw this request.

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B-48

We agreed to further clarify this request. Please provide the rate of transmission of contaminants from the surface to the aquifer described by contaminant and pathway, seasonally adjusted. This includes surface rieases and/or cooling tower releases.

This letter also confirms taking of the deposition of Doug Teper on April 22nd and 26th, beginning at 9:45. In further clarification, as our counsel has repeatedly informed you, at this time, Mr. Teper to the only potential witness Intervenors have identified under Win the event more are identified, we will prceptly notify you.

I Sincerely, 2% - -- 7 Tim Johnson

! for Intervenors Campaign for a Prosperous Georgia and l

Georgians Against Nuclear Energy cc: Service List

'4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE T!iE ATOMIC SAFUyJNpr LICENSING BOARD pcM

~ ll In the Matter of ) SN'RC

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GEORGIA PCWER CO., et al. 2 APR 25 om&&O Nos. 50-424 and 50-425

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(Vogtle Electric Generating Plant, OFFK)D:SECGLib Units 1 and 2) 00CKEhG & SERVit;

. BRANCH JOINT INTERVENORS' OBJECTION TO APPLICANTS' ANSWER TO MOTION FOR A PROTECTIVE ORDER On April 15th,1985, Applicants filed, pursuant to 10 CFR 2.730(c), their Answer to Joint Intervenors' Motion for a Protective Order. However, 10 CFR 2.730(c) requires that answers to motions be filed within ten days after service of a written motion. As Joint Intervenors' Motion for a Protective Order was filed on April 1st,1985, Campaign for a Prosperous Georgia and Georgians Against Nuclear Energy hereby object to Applicants' Answer on the grounds that it was untimely filed. .

Respectfully submitted this the 19th day of April,1985,

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Tim Johnson for Intervenors Campaign for 3 Prosperous Georgia and Georgians Against Nuclear Energy e

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• - NUCLEAR REGULATORY COMMISSION ItELATED COMES@

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) 00CHE TEC-

) USNRC GEORGIA POWER CO., et al. ) Docket Nos. 50-424 and 50-425

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(Vogtle Electric Generating Plant, ) M APR 25 A9:59 Units 1 and 2) )

CERTIFICATE OF SERVICE bhEO DRANCH GNk This is to certify that copies of the foregoing Joint Intervenors' Objection to Applicants' Answer to Motion for a Protective Order and 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 19th day of April, 1985.

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[m Tim Johnson SERVICE LIST Morton B. Margulies, Chairman Atomic Safety & Licensing Appeal l Atomic Safety & Licensing Board Board Panel U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Oscar H. Paris Docketing an'd Service Section Atomic Safety & Licensing Board Office of the Secretary U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission 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 Comission Director Washington, D.C. 20555 U.S. Nuclear Regulatory Comission 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 1

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n 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

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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 & Vicki Breman Mr. Gustave A. Linenberger Legal Environmental Assistance Atomic Safety.and Licensing Board Foundation U. S. Nuclear Regulatory Commission 1102 Healey Building

. Washington, D. C. 20555 Atlanta, Georgia 30303 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 Atomic Safe'ty and Licensing Board

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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