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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
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DOCKETED October 7, 1985 usMc
'85 00T -9 P2 57 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g>g,c : 3.g .,
uw. , y n, BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
GEORGIA POWER COMPANY ) Docket Nos. 50-424 et al. ) 50-425
) (0L)
(Vogtle Electric Generating Plant, )
Units 1 and 2) )
NRC STAFF'S EMEPGENCY PLANNING INTERROGATORIES TO JOINT INTERVFNORS CAMPAIGN FOR A PROSPEROUS GEORGIA (CPG) AND GEORGIANS AGAINST NUCLEAR ENERGY (GANE)
Pursuant to 10 CFR @ 2.740, 2.74db and 2.741, the NRC Staff propounds the following Interrogatories to Joint Intervenors CPG and GANE (hereafter " Joint Intervenors").
INSTRUCTIONS
- 1. Each Interrogatory set forth below shall be answered separately and fully in writing under oath or affirmation, and shall include all pertinent information available to Joint Intervenors, their respective officers, directors, members, employees, advisors, or consultants.
- 2. State the name, address, occupation and employer of the person or persons answering each Interrogatory and identify the portions of each Interrogatory such person has answered.
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- 2-
- 3. As used herein the tenn " Documents" shall be construed to mean all writings and/or records of every type in the possession, control or custody of Joint Intervenors their respective directors, officers, attorneys, ' employees or agents, including, but not limited to, memoranda, correspondence, reports, surveys, evaluations, charts, books, minutes, notes, agenda, diaries, logs, transcripts, microfilm, accounting statements, telephone and telegraphic communications, speeches, and all other records, written, electrical, mechanical or otherwise. " Documents" shall also be construed to mean copies of documents even though the originals thereof are not in the possession, custody or control of Joint Intervenors, their respective members or i consultants.
- 4. For all references to documents requested in these Interrogatories, identify such documents by author, title, date of publication and publisher if the reference is published; and if it is
- not published, identify the document by the author, title, and the date
? it was written.
- 5. As to any Interrogatory, section or subsection of the following Interrogatories that Joint Intervenors refuse to answer or to which Joint Intervenors object, for any reason, separately state the grounds for any such refusal. Where a complete answer to a particular Interrogatory, section or subsection of said Interrogatory is not possible, such Interrogatory, section or subsection of said Interrogatory should be answered to the extent possible and a statement made indicating the reason or reasons for the partial or incomplete answer.-
- 6. Identify by author, title and date any documents used as the basis for the answer to each Interrogatory.
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- 7. If the answer to any Interrogatory is based upon a calculation., describe (a) the calculation, (b) identify any documents setting forth such calculation, (c) identify the person who perfonned each calculation, (d) when it was performed, (e) each parameter used in such calculation, each valve assigned to the parameters, and the source of your data, (f) the results of each calculation, and (g) how each calculation provides a basis for the answers.
- 8. If-the answer to any Interrogatory is based upon conversa-tions, consultations, correspondence or any other type of communica-tions with one or more individuals, (a) identify each such individual by name and address, (b) state the educational and professional back-ground of each such individual, (c) describe the information received from such individual and its relation to your direct answer, and (d) identify each writing or record related to each such conversation, consultation, correspondence or other communications with such individual.
- 9. As used in these interrogatories, the word you or your shall mean Joint Intervenors or any agent or employee of Joint Intervenors.
- 10. As used in these interrogatories, the phrase NRC Staff or Staff includes the Federal Emergency Management Agency (FEMA).
- 11. The contentions and subcontentions referred to in these Interrogatories were admitted in the Atomic Safety and Licensing Board's "MemorandumandOrder(RulingonJointIntervenor'ProposedContentions on Emergency Planning)" which is dated August 12, 1985.
. INTERR0GATORIES INTERR0GATORY 1 Identify all documentary or other material that you intend to rely on during this proceeding to support Joint Intervenors' contentions and subcontentions EP-1 and EP-1(a), EP-2 and EP-2(a), (b), (c), and (h),
EP-4, EP-5, EP-6, EP-7, or which you may offer as exhibits on these contentions and subcontentions or refer to in preparation for or during your cross-examination of NRC Staff or Applicant witnesses. Provide, if available, copies of any documents you intend to rely on.
INTERROGATORY 2 a) Identify each person you rely on to substantiate in whole or in part the Joint Intervenors' contentions and subcontentions set out in Interrogatory 1 above, b) Provide the address and educational and professional qualifications of all persons named in your response to 2a above.
c) Identify which of the above persons or any other persons you may call as witnesses at a hearing on the contentions set out in Interrogatory 1 above, and identify which portions of each contention or l subcontention set out in Interrogatory 1 above that each such person will l support.
INTERROGATORY 3 a) With respect to Contention EP-1 and subcontention EP-1(a), do you assert that Burke County, Georgia, does not have a full time Emergency Management Agency Director?
b) If your answer to Interrogatory 3(a) is in the affirmative, please state the basis for this assertion.
c) Would the matters delineated by the Board order of August 12, 1985, for consideration under subcontention EP-1(a) be resolved if the Burke Coun y, Georgia emergency response plan were amended to specify (1) the responsibilities of the Burke County Sheriff's Department in the event that the County director of emergency planning or the Burke County Operating Center (E0C) could not be contacted via the Emergency Notification Net (ENN) and (2) the manner in which those responsibilities were to be exercised?
d) If your answer to the above question is in the negative, specify each other matter that must be included in the Burke County emergency plan to resolve contention EP-1(a), and the reason why it is necessary that each of these matters be included in the plan.
e) In the event that Applicants can demonstrate either that the E0C is staffed continuously or, in the alternative, that the procedures to be followed by the Burke County Sheriff's Department can initiate an emergency response in a timely and efficient fashion, would the matters delineated by the Board for consideration under subcontention EP-1(a) be resolved?
f) Set out the specific provisions which intervenors maintain must be contained in the Vogtle or Burke County emergency response plan to obviate the matters delineated by the Board Order of August 12, 1985, for consideration under subcontention EP-1(a), and why each of those provisions is necessary.
g) Set out the specific provisions of law and regulation which intervenors maintain the Vogtle or Burke County emergency response plan does not meet in regard to the matters the Board delineated for
consideration under subcontention EP-1(a), the specific manner in which the plan fails to meet those provisions of law and regulation, and why each of'those provisions is necessary.
h) Set out the specific provisions which intervenors maintain must be contained in the Vogtle emergency response plan in regard to the matters the Board delineated for consideration under subcontention 1
EP-1(a) to have the plan meet the requirements of law and regulation, and why each of those provisions is necessary.
INTERROGATORY 4 Subcontention EP-2(a) as admitted by the Licensing Board raises the
! issue of whether there are adequate administrative controls in place over the use of the ENN so as to restrict the use of dedicated lines to the transmission of official and necessary messages in the event of a radiological emergency at Vogtle, a) Set out each respect, if any, in which intervenors maintain the present administrative controls of the ENN set out in the Vogtle emergency response plan are inadequate, and why they are inadequate.
b) Set out the specific provisions of law and regulation intervenors maintain the Vogtle emergency response plan does not meet in regard to the matters the Board delineated for consideration under subcontention EP-2(a), and the manner in which the plan fails to meet those provisions of law and regulation, c) Set out.the specific provisions which intervenors maintain must be contained in the Vogtle emergency response plan to obviate each of the
i matters delineated by the Board for consideration under subcontention EP-2(a), and why each of these provisions is necessary, d)' et out the specific provisions which intervenors maintain must be contained in the Vogtle emergency response plan in regard to the matters delineated by the Board for consideration under subcontention EP-2(a) to have the plan meet the requirements of law and regulation, and why each of these provision is necessary.
1 INTERROGATORY 5 Subcontention EP-2(c) challenges the proposed use of NOAA tone alert radio receivers installed in each household in the EPZ as a means of notification.
a) Set out each respect in which intervenors maintain the NOAA tone alert radio receiver system is inadequate, and the bases for each such conclusion.
b) Set out each respect in which intervenors maintain the Vogtle emergency response plan is inadequate in regard to matters the Board delineated for consideration under subcontention EP-2(c), and the bases for such conclusions.
c) Set out each provision of law and regulation which intervenors maintain the Vogtle emergency response plan does not meet in regard to the matters the Board delineated for consideration under subcontention
't EP-2(c), and the specific manner in which the plan fails to meet those provisions of law and regulation.
d) Separately set out and describe all features that intervenors maintain a tone alert radio system or other alerting system must have to:
-. - .- - _ _ - . - = .. _ _ . . -- .
(i) be adequate; (ii) obviate all matters delineated by the Board for considerati.on under subcontention EP-2(a); (iii) meet the requirements of law and regulation.
INTERROGATORY 6 SubcontentionEP-2(h)concernsnotificationoftransientswithinthe EPZ.
a) Set out each respect in which intervenors maintain the Vogtle emergency response plan is inadequate in regard to the notification of transients in the EPZ, and the bases for each such conclusion.
b) Set out each respect in which intervenors maintain the Vogtle emergency response plan is inadequate in regard to matters alleged in the
! matters the Board has set for consideration under subcontention EP-2(h),
and the bases for each such conclusion.
c) Set out each provision of law or regulation intervenors
- maintain the Vogtle emergency response plan or the Burke County plan does not meet in regard to matters the Board has delineated for consideration i under subcontention EP-2(h), and the specific manner in which either of those plans fails to meet those provisions of law or regulation, d) Separately set out and describe each method of notification of transients which intervenors maintain must be set out in plans to
- (i)be adequate; (ii) obviate the matters the Board has delineated for a
consideration under subcontention EP-2(h); (iii) meet the requirements of law and regulation.
e) List each other sign or other notification of transients that must be made to allow the Vogtle emergency response plan to be adequate.
- l INTERROGATORY 7 Contention EP-4 deals with the identification in the Vogtle emergency response plan of medical service facilities capable of treating radiologically contaminated injured individuals.
a) Set out each respect in which intervenors maintain the Vogtle emergency response plan is inadequate in regard to the identification of medical facilities capable of treating radiologically contaminated injured individuals, and the bases for each such conclusion, b) Set out each respect in which the Vogtle emergency response I plan is inadequate in regard to the matters the Board delineated for J
consideration under contention EP-4, and the bases for each such i' conclusion, c) Set out each provision of law or regulation which intervenors maintain the Vogtle emergency plan does not meet in regard to matters the Board delineated for consideration under contention EP-4, and the specific manner in which the plan fails to meet those provision of law and regulation.
d) Separately set out and describe all matters dealing with the identification of medical service facilities capable of treating radiologically contaminated injiired individuals which intervenors 4
maintain the Vogtle emergency response plan must contain to: (i)be adequate; (ii) obviate all matters the Board delineated for consideration under contention EP-4; (iii) meet the requirements of law and regulation.
, INTERR0GATORY 8 Contention EP-5 deals with the availability of reception centers for evacuees in the event of a radiological emergency at Vogtle.
a) Set out each respect in which intervenors maintain that either the Vogtle emergency response plan or the Burke County plan is inadequate in regard to their treatment of reception centers or actions to assure the availability of those centers, and the bases for each such conclusion.
b) Set out each respect in which intervenors maintain the plans are inadequate in regard to matters the Board has delineated for consideration under contention EP-5, and the bases for each such conclusion.
c) Set out the specific details or provisions that intervenors maintain must be included in either of the plans to obviate the matters the Board l'as delineated for consideration under contention EP-5, and the i
bases for intervenors' conclusion that each of those details or provisions is necessary, d) Set out each provision of law or regulation intervenors maintain either of the plans do not meet in regard to the matters the Board delineated for consideration under contention EP-5, and the specific manner in which the plan fails to meet those provisions of law i
~
or regulation, e) Separately set out and describe the matters that either of the plans must contain in regard to the availability of reception centers for evacuees for the plans to: (i) be adequate; (ii) obviate the matter the Board delineated for consideration under contention EP-5; (iii) meet the requirements of law and regulation.
. INTERROGATORY 9 Contention 7 deals with those portions of the EPZ in South Carolina.
a) escribe the area in South Carolina that should be included within the Vogtle plume EPZ.
b) In the event Applicants or the State of South Carolina amended the emergency response plan for Vogtle to show the area intervenors believe should be included within the plume EPZ in South Carolina, would such an amendment resolve the matters delineated by the Board for hearing under contention 7.
c) If the answer to (b) is in the negative (1) set out intervenors' reasons in full, and (ii) specifically detail all other information which needs to be set out in the Vogtle emergency response plan in regard to those portions of the EPZ in South Carolina.
Respectfully submitted,
/d Bernard M. Bordenick Counsel for NRC Staff Dated et Bethesda, Maryland ,
- this 7/T day of October,1985 1
i i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
GEORGIA POWER COMPANY, ) Docket Nos. 50-424 et al.
) 50-425 (0L)
(Vogtle Electric Generating Plant, Units 1 and 2)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S EMERGENCY PLANNING INTERROGA-TORIES TO JOINT INTERVEN0RS CAMPAIGN FOR A PROSPEROUS GEORGIA (CPG) AND GEORGIANS AGAINST NUCLEAR ENERGY (GANE) in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 7th day of October,1985.
Morton B. Margulies, Esq., Chairman
- Mr. Gustave A. Linenberger, Jr.*
Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel Panel U.S. Nuclear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.-C. 20555 Dr. Oscar H. Paris
Administrative Judge Region 1 Counsel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Panel Suite 3100 U.S. Nuclear Regulatory Commission 101 Marietta Street Washington, D.C. 20555 Atlanta, GA 30303 Bruce W. Churchill, Esq. Douglas C. Teper David R. Lewis, Esq. 1253 Lenox Circle Shaw, Pittman, Potts & Trowbridge Atlanta, GA 30306 1800 M Street, N.W.
Washington, D.C. 20036,
- 2-Atomic Safety and Licensing Laurie Fowler, Esq.
Board Panel
- 218 Flora Ave. NE U.S. Nuclear Regulatory Commission Atlanta, GA 30307 Washington, D.C. 20555 Docketing and Service Section* Atomic Safety and Licensing Office of the Secretary Appeal Board Panel
- U.S. Nuclear Regulartory Commission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Washington, D.C. 20555 James E. Joiner, Esq. Ruble A. Thomas Troutman, Sanders, Lockerman, Southern Company Services, Inc. ,
& Ashmore P.O. Box 2625 i
127 Peachtree Street, N.E. Birmingham, AL 35202 4
Candler Building, Suite 1400 Atlanta, GA 30043 Tim Johnson '
Executive Director Campaign for a Prosperous Georgia 175 Trinity Avenue, S.W.
Atlanta, GA 30303
/
Bernard M. Bordenick Counsel for NRC Staff i
I I
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