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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20092H7681995-09-13013 September 1995 Georgia Power Co Fourth Suppl Response to AL Mosbaugh Third Set of Interrogatories & Request for Documents.* Related Correspondence ML20087K3481995-08-17017 August 1995 Gap First Supplemental Response to Intervenor Fifth Interrogatory & Document Request.* Response Suppls Gap Prior Response to Interrogatory 7.W/Certificate of Svc & Svc List. Related Correspondence ML20086H1291995-06-30030 June 1995 Georgia Power Company Supplemental Response to Intervenor Seventh Request for Interrogatories.* W/Certificate of Svc & Svc List.Related Correspondence ML20082L2001995-04-12012 April 1995 Intervenor Supplemental Responses to Georgia Power Company First,Second & Third Requests for Interrogatories & Prior Requests for Documents.* W/Certificate of Svc & Svc List. Related Correspondence ML20080N8401995-02-28028 February 1995 Intervenor Document Request to NRC Staff.* Intervenor Requests That Response Be Submitted within 10 Days as Law Requires.W/Certificate of Svc & Svc List ML20080N9451995-02-28028 February 1995 Intervenor Document Request to MW Horton.* Request Made for Personal Documents Not Previously Produced in Case. W/Certificate of Svc.Related Correspondence ML20080N9311995-02-28028 February 1995 Intervenor Document Request to Ck Mccoy.* Request Made for Personal Documents Not Previously Produced in Case. W/Certificate of Svc.Related Correspondence ML20080N9081995-02-28028 February 1995 Intervenor Document Request to Gr Frederick.* Request Made for Personal Documents Not Previously Produced in Case. W/Certificate of Svc.Related Correspondence ML20080N8971995-02-28028 February 1995 Intervenor Document Request to Tv Greene.* Request Made for Documents Not Previously Produced in Case.W/Certificate of Svc.Related Correspondence ML20080N8901995-02-28028 February 1995 Intervenor Document Request to H Majors.* Requests Made for Personal Documents Not Previously Produced in Case. W/Certificaate of Svc.Related Correspondence ML20080N8771995-02-28028 February 1995 Intervenor Document Request to G Bockhold.* Requests for Personal Documents Not Previously Produced in Case. W/Certificate of Svc.Related Correspondence ML20080N8441995-02-28028 February 1995 Intervenor Document Request to Ga Power Company.* Requests for Personal Documents Not Previously Produced in Case. W/Certificatte of Svc.Related Correspondence ML20072P2231994-08-26026 August 1994 Georgia Power Company Response to Intervenor Document Request.* Util Not to Further Respond to Intervenor Request Since 940801 Deadline Not Met.W/Certificate of Svc & Svc List ML20072L1371994-08-17017 August 1994 Intervenor Document Request to Georgia Power Company.* NRC Advises Util to Identify & Produce All Documents Used in Creation of Georgia Power Company Response to 940731 Nov. W/Certificate of Svc & Svc List.Related Correspondence ML20072A6641994-08-10010 August 1994 Gpc Addl Response to Intervenor Second Request for Admissions.* W/Certificate of Svc.Related Correspondence ML20072A6031994-08-0808 August 1994 Util Response to Intervenor Seventh Request for Interrogatories.* Informs That Util Objects to Instruction D of Seventh Request.W/Certificate of Svc & Svc List.Related Correspondence ML20072A5611994-08-0808 August 1994 Util Third Suppl Response to AL Mosbaugh Third Set of Interrogatories & Request for Documents.* Provides Addl Info Required by Board Memorandum & Order Dtd 940714. W/Certificate of Svc.Related Correspondence ML20072A5851994-08-0808 August 1994 Util Addl Response to Intervenor Fifth Interrogatory & Document Request.* Informs That Response Addresses Document Request 3-5,10,13,14,17 & 18 of Fifth Request.W/Certificate of Svc & Svc List.Related Correspondence ML20071P4021994-07-29029 July 1994 Util Addl Response to Intervenor Fourth Interrogatory & Document Request.* Response Addresses Document Request 6-17 & 19 of Fourth Request.W/Certificate of Svc & Svc List. Related Correspondence ML20071P4031994-07-29029 July 1994 Util Response to Intervenor Second Request for Admissions.* Informs That Second Request for Admissions Would Be Done in Two Listed Steps.W/Certificate of Svc.Related Correspondence ML20071M1841994-07-25025 July 1994 Intervenor Seventh Request for Interrogatories to Georgia Power Co.* a Mosbaugh Requests That Georgia Power Co Answer Listed Interrogatories in Writing & Under Oath.W/Certificate of Svc & Svc List.Related Correspondence ML20070H8231994-07-20020 July 1994 Gap Responses to Intervenor Fourth Interrogatory & Document Request.* W/Certificate of Svc & Svc List.Related Correspondence ML20070G9621994-07-18018 July 1994 Gpc Objections to Intervenor 940707 Discovery Requests & Motion for Protective Order.* Gpc Moves Board for Protective Order Providing That Intervenor 940707 Discovery Request Not Be Had.W/Certificate of Svc ML20070H1161994-07-18018 July 1994 Intervenor Response to Georgia Power Co Second Request for Admissions.* Objects to Admissibility by Licensee of Portions of Transcripts &/Or Tape Recordings &/Or Paraphrasing.W/Certificate of Svc.Related Correspondence ML20070E8921994-07-0808 July 1994 Intervenor Fifth Interrogatory & Document Request to Georgia Power Co.* Intervenor a Mosbaugh Requests That Georgia Power Co Answer Listed Interrogatories in Writing.W/Certificate of Svc & Svc List.Related Correspondence ML20070E8551994-07-0808 July 1994 Intervenor Fourth Set of Interrogatories & Request for Documents to Staff of Nrc.* Intervenor a Mosbaugh Requests That Staff of NRC Answer Listed Interrogatories in Writing. W/Certificate of Svc & Svc List.Related Correspondence ML20070E9961994-07-0707 July 1994 Intervenor Second Request for Admissions to NRC Staff.* Requests for NRC to Answer Request for Admissions & Interrogatory & Produce Documents as Required.Certificate of Svc & Svc List Encl.Related Correspondence ML20070F0091994-07-0707 July 1994 Intervenor Fifth Request for Interrogatories & Document Request to Georgia Power Co.* W/Certificate of Svc & Svc List.Related Correspondence ML20070F0541994-07-0707 July 1994 Intervenor'S Third Request for Admissions to Gpc.*Requests Util Answer Request for Admissions & Interrogatories & That Util Provide Required Documentation by 940721.W/Certificate of Svc & Svc List.Related Correspondence ML20071G9511994-07-0707 July 1994 Ga Power Company Response to Intervenor First Request for Admissions.* W/Certificate of Svc & Svc List.Related Correspondence ML20071G9071994-07-0505 July 1994 Georgia Power Co Second Supplemental Response to Am Mosbaugh Third Set of Interrogatories & Request for Documents.* W/Certificate of Svc & Svc List.Related Correspondence ML20071G9421994-07-0101 July 1994 Intervenor Second Request for Admissions to Georgia Power.* Requests That Util Answer Listed Request of Admissions & Deliver Answer on or Before 940715.W/Certificate of Svc & Svc List.Related Correspondence ML20071G8851994-07-0101 July 1994 Ga Power Company Objections to Document Requests in Intervenor Notice of Depositions.* W/Certificate of Svc & Svc List.Related Correspondence ML20070D4901994-06-29029 June 1994 Intervenor Fourth Interrogatory & Document Request to Gpc.* Requests That Responses Be Filed within 14 Days from Svc of Request & All Relevant Documents Be Made Available for Insp. W/Certificate of Svc & Svc List.Related Correspondence ML20070A9051994-06-22022 June 1994 Intervenor Suppl to Licensees Third Set of Interrogatories & Request for Documents.* W/Certificate of Svc & Svc List. Related Correspondence ML20069P2611994-06-17017 June 1994 Georgia Power Co First Supplemental Response to AL Mosbaugh Third Set of Interrogatories.* Responds to Interrogatories & Document Requests for Persons Listed.W/Certificate of Svc. Related Correspondence ML20069L5641994-06-13013 June 1994 Intervenor Amended Response to Licensee Third Set of Interrogatories & Request for Documents.* W/Certificate of Svc & Svc List ML20069K4091994-06-10010 June 1994 Util Response to AL Mosbaugh Third Set of Interrogatories.* Licensee Objects to Interrogatory as Unduly Burdensome & Duplicative of Preliminary Designation of Anticipated Witnesses.W/Certificate of Svc.Related Correspondence ML20069F2981994-06-0101 June 1994 Intervenor Response to Licensee Third Set of Interrogatories & Request for Documents.* W/Certificate of Svc.Related Correspondence ML20149E4291994-05-18018 May 1994 Intervenors Third Set of Interrogatories & Request for Documents to Util.* W/Certificate of Svc.Related Correspondence ML20149E4421994-05-17017 May 1994 Intervenors Second Set of Interrogatories & Request for Documents to Staff of Usnrc.* W/Certificate of Svc.Related Correspondence ML20029D9281994-05-0606 May 1994 Georgia Power Co Third Set of Interrogatories & Request for Documents to AL Mosbaugh.* Requests That AL Mosbaugh Answer Interrogatories in Writing & Under Oath within 14 Days of Svc.W/Certificate of Svc & Svc List.Related Correspondence ML20065R5831994-05-0303 May 1994 Intervenor Request for Interrogatories Documents to Gpc Related to Illegal Transfer of Control.* Intervenor Requests That Gpc Answer Listed Interrogatories in Writing & Under Oath & Produce Requested Documents.W/Certificate of Svc ML20029D5331994-04-28028 April 1994 Georgia Power Co Second Set of Interrogatories & Third Request for Production of Documents to NRC Staff.* W/ Certificate of Svc.Related Correspondence ML20058P4041993-12-20020 December 1993 Interrogatory Response of NRC Staff to Gap 931008 First Set of Interrogatories & Second Request for Production of Documents.* ML20058P5861993-12-20020 December 1993 Interrogatory Response of Jf Rogge to 931008 Gap First Set of Interrogatories & Second Request for Production of Documents to NRC Staff.W/Certificate of Svc.Related Correspondence ML20058P5201993-12-20020 December 1993 Interrogatory Response of L Trocine to Gap 931008 First Set of Interrogatories & Second Request for Production of Documents to NRC Staff.* ML20058P4391993-12-17017 December 1993 Interrogatory Response of Ae Chaffee to 931008 Gap First Set of Interrogatories & Second Request for Production of Documents to NRC Staff.* ML20058P4301993-12-17017 December 1993 Interrogatory Response of Jf Rogge to 931008 Gap First Set of Interrogatories & Second Request for Production of Documents to NRC Staff.* ML20058P4521993-12-14014 December 1993 Interrogatory Response of SD Ebneter to Gap 931008 First Set of Interrogatories & Second Request for Production of Documents to NRC Staff.* 1995-09-13
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196J3291999-06-28028 June 1999 Comment Supporting Proposed Rule 10CFR50 Re Industry Codes & Standards ML20206M7291999-04-30030 April 1999 Comment Supporting Draft RG DG-1083, Content of UFSAR IAW 10CFR50.71(e). Licensee of Listed Plants in Total Agreement with Comments Provided to NRC by NEI HL-5717, Comment Supporting Proposed Rule 10CFR50,52 & 72 Re Changes, Tests & Experiments.Util in Total Agreement with NEI Comments to Be Provided to NRC1998-12-18018 December 1998 Comment Supporting Proposed Rule 10CFR50,52 & 72 Re Changes, Tests & Experiments.Util in Total Agreement with NEI Comments to Be Provided to NRC HL-5715, Comments on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Util Is in Total Agreement with NEI Comments1998-12-14014 December 1998 Comments on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Util Is in Total Agreement with NEI Comments HL-5702, Comment Supporting NEI Comments Totally on Proposed Draft RG DG-4005, Preparation of Supplemental Environmental Repts for Applications to Renew Nuclear Power Plant Ols1998-10-23023 October 1998 Comment Supporting NEI Comments Totally on Proposed Draft RG DG-4005, Preparation of Supplemental Environmental Repts for Applications to Renew Nuclear Power Plant Ols HL-5695, Comment Supporting Nuclear Energy Institute (NEI) Comments on 10CFR50.55(a) Pr, Streamlined Hearing Process for NRC Approval of License Transfers1998-10-13013 October 1998 Comment Supporting Nuclear Energy Institute (NEI) Comments on 10CFR50.55(a) Pr, Streamlined Hearing Process for NRC Approval of License Transfers HL-5690, Comment on Integrated Review of Assessment Process for Commercial Nuclear Plants. Util in Total Agreement with NEI Comments Provided to NRC1998-10-0505 October 1998 Comment on Integrated Review of Assessment Process for Commercial Nuclear Plants. Util in Total Agreement with NEI Comments Provided to NRC HL-5983, Comment on Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors. Snoc in Total Agreement with NEI Comments,To Be Provided to Nrc.Requests That NRC Provide Guidance to Application of NUREG-1022,rev 1 as Listed1998-09-21021 September 1998 Comment on Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors. Snoc in Total Agreement with NEI Comments,To Be Provided to Nrc.Requests That NRC Provide Guidance to Application of NUREG-1022,rev 1 as Listed ML20153B2391998-09-15015 September 1998 Comment on Draft NUREG-1633, Assessment of Use of Ki as Protective Action During Severe Reactor Accidents. Endorses NEI Comments HL-5682, Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents, & Endorsing Comments Submitted by Nuclear Energy Institute1998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents, & Endorsing Comments Submitted by Nuclear Energy Institute HL-5602, Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds1998-04-0303 April 1998 Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds HL-5586, Comment on Proposed Generic Ltr, Year 2000 Readiness of Computer Sys at Npps1998-03-0404 March 1998 Comment on Proposed Generic Ltr, Year 2000 Readiness of Computer Sys at Npps HL-5582, Comment on Draft Reg Guide DG-5008, Reporting of Safeguards Events1998-02-27027 February 1998 Comment on Draft Reg Guide DG-5008, Reporting of Safeguards Events HL-5564, Comment on Draft NUREG 1555, Updated Environ Standard Review Plan1998-01-30030 January 1998 Comment on Draft NUREG 1555, Updated Environ Standard Review Plan HL-5554, Comment Supporting NEI Comments on PRM 50-63A by P Crane Recommending Emergency Planning Standard for Protective Actions Be Changed to Require Explicit Consideration of Prophylactic Use of Potassium Iodide for General Public1998-01-15015 January 1998 Comment Supporting NEI Comments on PRM 50-63A by P Crane Recommending Emergency Planning Standard for Protective Actions Be Changed to Require Explicit Consideration of Prophylactic Use of Potassium Iodide for General Public HL-5546, Comment Supporting Proposed Rule & Direct Final Rule on 10CFR50.68 & 10CFR70.24, Criticality Accident Requirements1997-12-31031 December 1997 Comment Supporting Proposed Rule & Direct Final Rule on 10CFR50.68 & 10CFR70.24, Criticality Accident Requirements HL-5529, Comment Opposing Rule 10CFR50 Re Codes & Standards,Ieee National Consensus Standard1997-12-0101 December 1997 Comment Opposing Rule 10CFR50 Re Codes & Standards,Ieee National Consensus Standard ML20199J0031997-11-24024 November 1997 Comment Supporting Proposed Rule Re Financial Requirements for Decommissioning Nuclear Power Reactors & Draft RG 1060 HL-5424, Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Encourages NRC Not to Abandon 30 Yrs of Effective Implementation of 10CFR.50.59 for New Positions1997-07-0707 July 1997 Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Encourages NRC Not to Abandon 30 Yrs of Effective Implementation of 10CFR.50.59 for New Positions ML20148N0741997-06-19019 June 1997 Comment on Proposed Suppl to Bulletin 96-001 Re Control Rod Insertion Problems.Util in Complete Agreement That Incomplete Rcca Insertion Not Acceptable HL-5407, Comment Opposing NRC Proposed Strategies to Address Licensees Need to Establish & Maintain safety-conscious Work Environ1997-05-27027 May 1997 Comment Opposing NRC Proposed Strategies to Address Licensees Need to Establish & Maintain safety-conscious Work Environ ML20137C2581997-03-18018 March 1997 Summary of Director'S Decision Under 10CFR2.206 of Mb Hobby & AL Mosbaugh, ML20137C4261997-03-18018 March 1997 Director'S Decision Under 10CFR2.206 Re Petition Re Allegation of Illegal Transfer of OLs to Southern Nuclear Operating Co.Petitions Filed by Mb Hobby & AL Mosbaugh Denied HL-5268, Comment Supporting Draft RG DG-1047, Std Format & Content for Applications to Renew NPP Ols1996-11-27027 November 1996 Comment Supporting Draft RG DG-1047, Std Format & Content for Applications to Renew NPP Ols ML20133H1131996-11-25025 November 1996 Petition for Enforcement,Per 10CFR2.206,to Revoke Northeast Utils Operating Licenses for CT Nuclear Power Stations Due to Chronic,Systemic Mismanagement Resulting in Significant Violations of NRC Safety Regulations ML20129J5481996-10-30030 October 1996 Order.* Extends Time within Which Commission May Take Sua Sponte Review of Memorandum & Order LBP-96-16 to 961129. W/Certificate of Svc.Served on 961030 ML20129K4291996-10-0202 October 1996 Comment Supporting Proposed Rule 10CFR25 & 95, Access to & Protection of Classified Info HL-5247, Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations1996-10-0101 October 1996 Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20128K2791996-09-30030 September 1996 Order.* Time within Which Commission May Take Sua Sponte Review of Memo & Order LBP-96-16 Extended Until 961030. W/Certificate of Svc.Served on 960930 ML20116J8921996-08-0202 August 1996 Withdrawal of AL Mosbaugh.* AL Mosbaugh Voluntarily Withdraws Intervention,Opposition & Contention in Proceedings.W/Certificate of Svc & Svc List ML20116J8551996-08-0202 August 1996 Joint Notice of Termination.* AL Mosbaugh Voluntarily Withdrew Intervention,Opposition & Contentions in Proceeding.W/Certificate of Svc & Svc List ML20116J8431996-08-0202 August 1996 Intervenor Response to Georgia Power Motion for Reconsideration.* Intervenor Supports Motion for Reconsideration.W/Certificate of Svc & Svc List ML20116N5881996-07-31031 July 1996 Comment Re Proposed Rule 10CFR26, Mods to Fitness-For-Duty Program Requirements. Supports NEI Comments ML20116A4931996-07-15015 July 1996 Georgia Power Company Motion for Reconsideration of 960628 Memorandum & Order Or,In Alternative,For Certification.* Gpc Requests That Board Not Require Submittal or Approval of Settlement Between Gpc & Mosbaugh.W/Certificate of Svc ML20115H2671996-07-0808 July 1996 Comment Supporting Final Rule 10CFR51, Environ Review of Renewal of Nuclear Power Plant Operating Licenses HL-5195, Comment Supporting Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors1996-06-24024 June 1996 Comment Supporting Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors ML20114E6491996-06-20020 June 1996 Joint Motion to Defer Issuance of Initial Decision.* Requests That ASLB Defer Issuance of Decision in Proceeding Until 960920,in Order to Allow Gpc & Mosbaugh to Reach Settlement Agreement.W/Certificate of Svc IA-95-211, Transcript of 920507 Interview of Mc Wilkins in Waynesboro, Ga.Pp 1-391996-05-0707 May 1996 Transcript of 920507 Interview of Mc Wilkins in Waynesboro, Ga.Pp 1-39 ML20129H7151996-05-0707 May 1996 Transcript of 920507 Interview of Mc Wilkins in Waynesboro, Ga.Pp 1-39 HL-5103, Comment Supporting NEI Comments on Petition for Rulemaking PRM-50-63 Re Planning Std for Protective Actions for General Public Includes Stockpile or Predistribution of Ki for Prophylactic Use1996-02-0606 February 1996 Comment Supporting NEI Comments on Petition for Rulemaking PRM-50-63 Re Planning Std for Protective Actions for General Public Includes Stockpile or Predistribution of Ki for Prophylactic Use ML20096A4911995-12-22022 December 1995 Georgia Power Co Reply to Intervenor & NRC Staff Proposed Findings of Facts & Conclusions of Law.* W/Certificate of Svc ML20095D9821995-12-12012 December 1995 Georgia Power Co Motion to Correct Record of Exhibits of Diesel Generator Reporting Issues Allegation Hearing.* W/Certificate of Svc ML20095D9771995-12-0808 December 1995 Comment on Proposed Generic Ltr Boraflex Degradation in Spent Fuel Pool Starage Racks. Request for Licensees to Demonstrate Subcriticality Margin in Unborated Water,Seems Inconsistent W/Stated Benefit of Borated Water ML20094S2751995-11-30030 November 1995 Intervenor Final Statement of Fact & Conclusions of Law.* Board Finds That Util & Applicant Failed to Meet Burden of Proof Re Ultimate Issue of Character,Competence & Integrity. W/Svc List ML20094S2411995-11-22022 November 1995 Georgia Power Co Response to Intervenors Motion for Continuance.* Intervenor Motion Unjustified & Prejudicial & Should Be Denied.W/Certificate of Svc & Svc List ML20094S2931995-11-21021 November 1995 Intervenor Motion for Continuance for Good Cause.* Requests Deadline for Filing Post Hearing Brief Be Extended Until 951130.W/Certificate of Svc & Svc List ML20094K1161995-11-0909 November 1995 Intervenor Motion to Admit Supplementary Exhibits.* Moves That Naslp Admit Encl Documents Into Evidence for Listed Reasons.W/Certificate of Svc & Svc List ML20094J9301995-11-0606 November 1995 Georgia Power Company Motion to Correct Record of Diesel Generator Reporting Issues Allegation Hearing.* Moves Licensing Board to Order That Corrections Be Made to Transcript.W/Certificate of Svc & Svc List ML20094J9281995-11-0606 November 1995 Gap Proposed Findings of Fact & Conclusions of Law on Diesel Generator Reporting Issues.* Findings of Fact & Conclusion Accepted.W/Certificate of Svc ML20094J9201995-11-0101 November 1995 Affidavit of Ck Mccoy to Correct Info Contained in Intervenor Exhibit II-97,which Consists of Portions of Deposition in a Mosbaugh Complaint Against Gap 1999-06-28
[Table view] |
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g m .'.a m 41" 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Q 26 p 7 ,.g GEORGIA POWER CO., et al. )- Docket Nos. 50 424 aniD50.425..
) .
(Vogtle Electric Generating Plant, )
M'<r * ' N c Units 1 and 2) )
i CPG /GANE'S RESPONSE TO NRC STAFF'S SECOND SET OF INTERROGATORIES Intervenors respond herein to "NRC Staff's Second Set of Interrogatories to Campaign for a Prosperous Georgia (CPG) and Georgians Against Nuclear Energy (GANE)."
Interrogatory 1: Interrogatory 1 of the Staff's " Interrogatories" dated November 1, 1984, is incoYporated by reference herein (with specific reference to Contention 8 as restated in the Board's " Memorandum and Order" dated November 5,1984).
RESPONSE: Intervenors will rely upon documents cited in " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia" dated April 11,1984, in " CPG /GANE's Response to NRC Staff's Interrogatories" dated December 10, 1984 and in " CPG /GANE's Response to Applicants' First Set of Interrogatories and Reques' for Production of Documents" dated December 5,1984. In addition, Intervenors have filed interrogatories with the Applicants related to this interrogatory and will respond more fully to this interrogatory after reviewing the Applicants' response and documentation thereto.
Interrbgatory 2_: Interrogatory 2 of the Staff's Interrogatories" [ sic] dated November 1,1984, is incorporated by reference herein (with specific reference to Contention 8 as restated in the Board's " Memorandum and Order" dated November 5, 1984).
i I
8412270613 841219 PDR ADOCK 05000424 o PDR
V , ..:
RESPONSE: Response to Interrogatory 2 in " CPG /GANE's Response to NRC Staff's l
Interrogatories" dated Decembar-10, 1984, is incorporated by reference herein. .
l Interrogatory 3_: With respect to Contention-8, please state the specific structures, systems and components you allege have been affected by Applicants alleged failure to implement a quality assurance program within the context of Contention 8.
RESPONSE: The basis of Contention 8, " Supplement to Petition for Leave to Intervene and Request for Hearing, Campaign for a Prosperous Georgia," dated April 11, 1984, is incorporated by reference herein. In addition, Intervenors have filed ini;errogatories with Applicants relating to this contention and will respond more fully following review of the response thereto and the documentation therefor.
Interrogatory 4_: State the specific facts you rely upon to support the general allegations contained in Contention 8 to the effect that Applicants (a) have not properly documented the placement of concrete. (b) have not adequately tested concrete, (c) have not adequately prepared correct concrete quality test records, (d) have not procured material and equipment that meet applicable standards (e) have not protected equipment, and (f) have not taken corrective action.
RESPONSE: The basis of Contention 8 is incorporated by reference herein.
" CPG /GANE's Reply to Applicant's Motion to Correct ASLB's Memorandum and Order Dated November 5, 1984" dated November 30, 1984, is incorporated by reference herein.
The response to Interrogatory 5 (below) is incorporated by reference into this response. In addition, Intervenors have asked discovery questions of the Applicants ;
and will file a supplement hereto based upon the responses thereto and the documentation therefor.
Interrogatory 5_: In regard to Contention 8, fully set forth (a) each document you maintain should have teen prepared that was not prepared, (b) the matters those I
. documents should have set forth, (c) each incomplete document, (d) the matters not covered that thould have been covered, (e) each test not conducted and what such 2
l tests should have covered, (f) each concrete quality test report inadequately i ,
prepared and matters ommitted therefrom, (g) each piece of material or equipment that did not' meet applicable standards, (h) each standard such material or equipment did not meet and the specific manner in which it did not meet such standards, (1) each piece of equipment not adequately protected, the inadequate protection.
- adequate protection and every code or standard relied upon setting forth adequate protection relevant to that equipment, and (j) each instance of corrective action that was not taken that should have been talen, a full description of the details of such corrective actions, and each document, code or standard evidencing the
" corrective action" that should have been taken.
RESPONSE: The basis of Contention 8 and documents cited therein are incorporated by reference herein. " CPG /GANE's Reply to Applicant's Motion to Correct ASLB's Memorandum and Order Dated November 5, 1984" dated November 30, 1984 and documents cited thereirr are incorporated by reference herein.
Work was begun although schedules were not prepared for final release of construction and field procedures to assure that their development occurred prior to the construction activity involved.
In 1974, the Georgia Power QA manual did not adequately describe the QA program for design and procurement.
The Georgia Power QA audit planning did not include adequate visibility in that the application of all applicable QA criteria was not clear for design and j procurement.
The Southern Services, Inc. QA manual did not reflect the requirements of the then current PSAR Section 17.
The QAE Office Procedures Manual's Procedure QA-04-03 did not include .
appropriate specification evaluation checklists. At the same time, the QA manual description of organization was inconsistent with functional organization on site.
3
( .
W
~When, according to the Applicant, in-place compaction tests conducted on-site
-could'not meet the 97% compaction criteria established in the PSAR, the definition .-
cf compaction was changed; two versions of the new definition exist.
During concrete placement A-110-003 consisting of a total of 216 yards of concrete at the Unit 2 control-building tendon gallery access shaf t, it was noted on two different occasions that the concrete was allowed to accumulate at the end of the conveying pipe to a height of approxirrately 2 feet above the finish elevation.
Vibrators were then used to move the pile of concrete to the required elevation.
GPC Construction Procedure CD-T-02, Concrete Quality Control, Section 6.1.9 paragraph 3 states " Vibrators shall not'be used for transporting or moving concrete inside the form."
The QC inspector at the batch plant documents his surveillance in a daily log which is stored.in the vault under daily inspection files. Any problems encountered at the batch plant during the day of a placement are to be entered in the daily log while the other records- for the placement are filed by pour cards number. The pour card record file and the daily inspection log files must be reviewed in order to review a completed placement record. Consolidation of concrete placement files is necesSary.
Slump tests, air tests and temperature measurement were being taken at the concrete lab located beside the batch plant. After testing, the concrete was transported approximately one fourth mile to the pumping equipment, There is not further testing of the concrete. GPC Construction Procedure CD-T-02 references ACI Standards as applicable. The ACI Standards reference ASTM C-172 which makes provisions and requirements for taking samples at the point of placement. This is another example of failure to follow procedures during concrete placement.
There are voids in the auxiliary builfing concrete. The voids occur in walls which were heavily congested with reinforcing steel, embedment, pipe sleeves and blockoud. Stop work notice number SW-C-13 was issued on 20 Dec.1979 to to stop 1
4 4
l
concrete placement. ,
1
- Fine aggregate test sieves failed to meet requirements of Criterion V of Appendix B to 10CFR50 as implemented by VNP PSAR 17.1.5 GPC Construction Procedure CD-T-02, Concrete Quality Control and referenced ASTM Standard C-136 (which require that sieves used for aggregate tests conform to requirements of ASTM Standard E-11).
The Applicant failed to follow Rebar Procedures, Construction Procedure CD-A-01 Revision 5, " Material and Equipment Receipt, Storage and Handling." Lack of inspection, improper documentation and improper identification of cut rebar appears to be in noncompliance with 10 CFR 50 Appendix B, Criterion V.
Embed assemblies in the Auxiliary Building and the Control Building suffered many defects, including: all of the plate nuts were standard hexagon nuts instead of heavy hexagon nuts; some of the bolts for a given embed plate assembly were not fully engaged with the plate nut; some of the bolts were not tack-welded to the plate nut; some of the bolts in a given embed plated assembly did not have washers; some of'the bolts having washers did not have washers tack welded to either the bolt or the end nut; some end nuts were not tack welded to the corresponding bolt; some bolts may have been bent in excess of the design drawing specified thirty degrees; and some bolts may be crackea due to excessive bending.
Three hundred spray nozzles for the containment spray systems, 44 Fisher.
Control valves and 7 albows for the reactor coolant piping system were improperly protected. Neither adequate facilities for storing the safety-related equipment nor approved procedures had been provided. The inspector made further investigation and l
determined that a "QA_ program is not in operation at Vogtle." Therefore, an l evaluation had not been made to assume that the site was prepared to receive, receipt inspect and store safety related equipment. The inspector found that although a procedure "Nonconformance Control," GD-T-01, had been written and approvcd it was not used in conjuctin with the " red hold tags" to prepare a ,
1 5 l
nonconfermance report and to provide for QA records and corrective action. In
.i
[ suneary,~ the inspector determined that the QA jprogram is not effective, auidtrs .
7 - had not been scheduled or perforred on procedures and personnel in advance of activity to assure proper receipt, inspe:: tion, storage and handling of safety-related equipment.
Based on NRC inspection No. 79-17, damage to Category I backfill andpossible undermining of Class I structure foundations as a result of 2 Nov.1979 heavy rains was not reported until 14 Nov.1979 which is an infraction of 10 CFR 50.55 (e).
I Extensive backfill repair and evaluation of the control building and Unit I and 2 reactor building foundations will be required. Moderate to severe erfosion and slumping occurred on construction slopes in the backfill. Backfill around the control building and Units 1 and 2 containment building had been severely eroded by washes and gullies with partial undercutting of some mud slabs. Seepage was visable along the south side of the Unit 2 tendon gallery wall, indicating that the foundation may have been damaged by sub-surface eriosion. The backfill contructin slope north of the auxiliary building was saturated as a result of seepage and showed evidence of partial slumping. Seepage on the backfill slope north of the auxiliary building had been ongoing since Sept. 1979. Stop Work notice SW-C-6 showed backfilling stopped as of 1 Nov.1979 because of seepage. SW-C-7 issued 9 Nov. 1979. This is compounded by surprise find of limestone area which was to be under the plant later found to have cavities, (
j Ti.e Applicant reported a potential CDR regarding the fabrication and installction of embeds to Region II on 22 Nov. 1978. All concrete work involving embeds hsti t!een stopped of, of 21 Nov.1978.
, However, on 29 Nov.1978 two QA auditors i6iirihs the auxiliary building found that empeds were being installed, a major t; Pea Nown in communication.
During excavation, "GPC QA or QC personnel had no idea what acceptance criteria was necessary for determining the proper bearing strata until they were enlightened 6
g.-w . , , . ..
P ..
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by this inspector. I feel there is a definite deficiency or lack of interest on the ..
part of GPC, QA-QC personnel toward projecting ahead into the construction schedule
- and predetermining critical checkoff points in the construction sequence where required acceptance criterion must be met."
In addition, Intervenors have asked discovery questions of the Applicant and will file a supplement hereto based upon the responses thereto and the documentation
, therefor.
Responses to these interrogatories were prepared by Doug Teper.
Respectfully submitted this, the 19th day of December, 1984,
/
pf V * ? ,j '" W DougTper / Tim Johnson Georgians Against Nuclear Energy Campaign.for a Prosperous Georgia e
l a _ -
.1 i
I hereby affirm that the information I provided for GANE/ CPG's response to NRC !
staff's second set of interrogatories is true to the best of my information and belief. .
This, the li day of ./ ectat " , 1984.
Douglay C. Teper a
9 L_ h .a,.A
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.- --i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION a' BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
GEORGIA POWER CO. , et al. Docket Nos. 50-424 and 50-425
=(Vogtle Electric Generating Plant, ) -
Units 1and2) )
CERTIFICATE OF SERVICE This is to certify 'that copies of the foregoing CPG /GANE's Response to NRC Staff's Second Set of Interrogatories were served by deposit with the U. S. Postal Service in the City of Atlanta for first class delivery to those listed on the attached Service List this 19th day of December,1984.
ws
[M/ %
Tim Johnson Executive Director Campaign for a Prosperous Georgia for Intervenors Campaign for a Prosperous Georgia and Georgians Against Nuclear Energy
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION -
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
GEORGIA POWER CO., et al. ) Docket Nos. 50-424 and 50-425
)
(Vogtle Electric Generating Plant, )
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 Washington, D.C. 20555 U.S. Naclear 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 George F. Trowbridge Ernest L. Blake, Jr.
David R. Lewis Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washington, D.C. 20036 l
James E. Jainer Sumner C. Rosenberg Troutman, Sanders, Lockerman & Ashmore 127 Peachtree Street, N.E.
Atlanta, Georgia 30303 i i
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