ML20211D239
| ML20211D239 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/17/1986 |
| From: | Joiner J GEORGIA POWER CO., TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA |
| To: | Linenberger G, Margulies M, Paris O Atomic Safety and Licensing Board Panel |
| References | |
| CON-#486-1168 OL, NUDOCS 8610220146 | |
| Download: ML20211D239 (4) | |
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TROUTMAN, SANDERS, LOCKERMAN & ASHMORE ATTORNEYS AT LAW CANDLER SulLDING SulTE 1400 127 PEACHYREE STREET. N E.
JAMES E soiN E se. p. c.
ATLANTA, GEORGIA 30043 pigt p{e@
wai o
4ostess aooo o4 so aose canst watstao rettcopera 4o4-aas o co October 17, 1986 00CKlilNG M WD.
BRMiCH Morton B. Margulies, Chairman Mr. Gustave A.
Linenberger, Jr.
Administrative Law Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing-Board Board U. S. Nuclear Regulatory U. S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C. 20555 Dr. Oscar H. Paris Administrative Judge Atomic Safety and Licensing Board U.
S. Nuclear Regulatory Commission Washington, D. C.
20555
[
In the Matter of Georgia Power Company, et al.
(Vogtle Electric Generating Plant 7 Units 1 and 2)
Docket Nos. 50-424 and 50-425 OL-Gentlemen:
On October 8, 1986, Dr. Howard M. Deutsch filed a paper entitled " Supplemental Information," purportedly on behalf of GANS and CPG.
For~the reasons discussed below, Applicants respectfully submit that Dr. Deutsch's paper should not delay your final decision on this issue.
First,'the paper is an improper submittal of a nonparty.
CPG is no longer a party to this proceeding.
Dr. Deutsch is not a duly authorized representative of GANE.
For_ this reason alone, his submittal should be disregarded.
Second, the submittal requests no action.
It does not meet the standards of pleadings for a motion and should not be construed as such.
Third, Dr. Deutsch's paper is untimely.
Dr. Deutsch indicates that his paper is a response to Board Notification 86-18.
Board Notification 86-18 transmitted to the Board an i
8610220146 861017 PDR ADOCK 05000424 G
l j
TROUTMAN, SANDERS LOCKERMAN & ASHMORE Morton B. Margulies, Chairman Mr. Gustave A. Linenberger, Jr.
.l Dr. Oscar H. Paris l
October 17, 1986 I
Page Two l
l August 12, 1986 letter from the NRC Staff to Applicants
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containing several questions concerning.ASCO solenoid valves.
I Applicants responded to the questions by letters dated August 21 and September 2.
On September 15, the NRC staff I
issued an SER and informed the Board that its questions were' resolved.
Both CPG and GANE were on'the service list.for all these letters.
To the extent Dr..Deutsch's submittal really is a response to Board Notification 86-18, it arrives l
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nearly a month after all issues were resolved.
In view of the rapidly approaching fuel load date for Vogtle (scheduled for December), this delay is extremely prejudicial to Applicants and is unacceptable.
Furthermore, to a considerable extent, Dr. Deutsch's letter addresses matters having nothing to do with Board Notification 86-18.*'
Dr. Deutsch refers to several IE notices concerning ASCO valves.
Some of these notices predate the hearing.
Even the most recent is over three months old.
None of the notices pertains to environmental qualification.
Similarly, Dr. Deutsch's query concerning the meaning of " safety-related equipment" -- the term CPG and GANE used in their contention ** -- could have been raised literally years ago.
~* Those comments of Dr. Deutsch that do pertain to Board Notification 86-18 are few and of little substance.
Dr. Deutsch refers to a March 1985 list of ASCO valves, a list which was provided to Intervenors during discovery and which show six rather than four NP8321 valves in MSIV This discrepancy is-simply a typographical error.
areas.
The two valves with the suffix A185E are NP8320's (as is quite evident from designation of all the other valves with this suffix).
The list of ASCO valves attached to and incorporated into Applicants' testimony shows the correct designation.
Dr. Deutsch also questions whether Applicants' analysis was conservative, but his comments on this point are confused.
Applicants' methodology resulted in a higher calculated maximum valve temperature than would have been derived if all the assumptions of NUREG-0588 had been adopted.. Moreover, the difference is about one degree F, which is irrelevant when compared with the 20*F margin in the environmental qualification of these valves.
Last, Dr. Deutsch refers to the Isomedix testing, which is fully addressed in Applicants' testimony.
- See LBP-84-35, 20 N.R.C.
887, 903 (1984) (quoting Intervenors' proposed Contention 10).
e TROUTMAN, SANDERS, LOCKERMAN & ASHMORE m.
on co Morton B. Margulies, Chairman Mr. Gustage A.
Linenberger, Jr.
Dr. Oscar H.
Paris s
October 17, 1986 Page Three In summary, the " Supplemental Information" submitted by Dr. Deutsch provides no basis for delaying a decision on
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Contention 10.5.
The questions that prompted Board Notifica-tion 86-18 have been fully resolved; and for that reason, Applicants submit that a decision at this time is appropriate.
Sincerely, o
ames E. J er Counsel fo Applicants JEJ:mh cc:
Service List v-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 No. 50-424
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50-425 (Vogtle Electric Generating Plant,
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Units 1 and 2)
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SERVICE LIST Gary J. Edles, Chairman Bernard M. Bordenick, Esquire Atomic Safety and Licensing Office of the Executive Arreal Board Legal Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555 Christine N. Kohl i
Atomic Safety and Licensing Bradley Jones, Esquire Appeal Board Regional Counsel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission 101 Marietta Street, Suite 3100 Howard A. Wilber Atlanta, GA 30303 Atomic Safety and Licensing Appeal Board Danny Feig U.S. Nuclear Regulatory Commission 1130 Alta Avenue Washington, D.C.
20555 Atlanta, GA 30307 Morton B. Margulies, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Gustave A. Linenberger Atomic' Safety and Licensing Atomic Safety and Licensing ADoeal Board Panel Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 i
Dr. Oscar H. Paris Docketing and Service Section Atomic Safety and Licensing Office of the Secretary Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 i
Carol Stangler 425 Euclid Terrace Atlanta, GA 30307
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