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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217P3791999-10-21021 October 1999 Forwards NRC Form 396 & NRC Form 398 for Renewal of Licenses SOP-20607-1 & SOP-20610-1.Without Encls ML20217N2521999-10-20020 October 1999 Provides Supplemental Info Re 990405 Containment Insp Program Requests for Relief RR-L-1 & RR-L-2,in Response to 991013 Telcon with NRC ML20217K7541999-10-15015 October 1999 Forwards Rev 1 to Unit 1,Cycle 9 & Unit 2 Cycle 7 Colrs,Iaw Requirements of TS 5.6.5.Figure 5, Axial Flux Difference Limits as Function of Percent of Rated Thermal Power for RAOC, Was Revised for Both Units ML20217G6751999-10-13013 October 1999 Requests Withholding of Proprietary Info Contained in Application for Amend to OLs to Implement Relaxations Allowed by WCAP-14333-P-A,rev 1 ML20217G1071999-10-0707 October 1999 Informs That on 990930,NRC Staff Completed mid-cycle PPR of Vogtle & Did Not Identify Any Areas in Which Performance Warranted More than Core Insp Program.Nrc Plans to Conduct Core Insps at Facility Over Next Six Months ML20216J9041999-10-0101 October 1999 Forwards Response to RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves ML20216J9161999-10-0101 October 1999 Forwards Response to NRC 990723 RAI Re GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves ML20217B0141999-10-0101 October 1999 Forwards Insp Repts 50-424/99-06 & 50-425/99-06 on 990725- 0904 at Vogtle Units 1 & 2 Reactor Facilities.Determined That One Violation Occurred & Being Treated as non-cited Violation ML20212E8751999-09-20020 September 1999 Forwards Response to NRC GL 99-02, Lab Testing of Nuclear Grade Activated Charcoal. Description of Methods Used to Comply with Std Along with Most Recent Test Results Encl ML20212E7481999-09-20020 September 1999 Requests Approval Per 10CFR50.55a to Use Alternative Method for Determining Qualified Life of Certain BOP Diaphragm Valves than That Specified in Code Case N-31.Proposed Alternative,Encl ML20212C2191999-09-16016 September 1999 Forwards NRC Form 536, Operator Licensing Exam Data, Which Is Current Need for NRC Operator Licensing Exams for Years 2000 Through 2003 of Plant Vogtle,Per Administrative Ltr 99-03 ML20211Q4801999-09-0101 September 1999 Informs That on 990812-13,Region II Hosted Training Managers Conference on Recent Changes to Operator Licensing Program. List of Attendees,Copy of Slide Presentations & List of Questions Received from Participants Encl ML20211J5291999-08-30030 August 1999 Forwards Snoc Copyright Notice Dtd 990825,re Production of Engineering Drawings Ref in VEGP UFSAR ML20211J5251999-08-30030 August 1999 Forwards Response to NRC 990727 RAI Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design Basis Accident Conditions ML20211J7381999-08-27027 August 1999 Informs That Licensee Vessel Data Is Different than NRC Database Based on Listed Info,Per 990722 Request to Review Rvid ML20211E9251999-08-23023 August 1999 Forwards fitness-for-duty Performance Data for Jan-June 1999,as Required by 10CFR26.71(d).Data Reflected in Rept Covers Employees at Vogtle Electric Generating Plant ML20210V0881999-08-16016 August 1999 Forwards Insp Repts 50-424/99-05 & 50-425/99-05 on 990620- 0724.No Violations Noted.Vogtle Facility Generally Characterized by safety-conscious Operations,Sound Engineering & Maintenance Practices ML20210Q4611999-08-0505 August 1999 Informs That NRC Plans to Administer Generic Fundamentals Exam Section of Written Operator Licensing Exam on 991006 for Vogtle.Requests Info Re Individuals Who Will Take Exam. Sample Registration Ltr Encl ML20210L2181999-08-0202 August 1999 Forwards NRC Form 396 & Form 398 for Renewal of Listed Licenses,Iaw 10CFR55.57.Without Encl ML20210N1191999-08-0202 August 1999 Discusses 990727 Telcon Between Rs Baldwin & R Brown Re Administration of Licensing Exam at Facility During Wk of 991213 ML20210G3351999-07-27027 July 1999 Forwards Second Request for Addl Info Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design Basis Accident Conditions ML20210E0121999-07-23023 July 1999 Forwards Second Request for Addl Info Re GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves ML20210D9341999-07-22022 July 1999 Discusses Closure of TACs MA0581 & MA0582,response to Requests for Info in GL 92-01,rev 1,suppl 1, Reactor Vessel Structural Integrity ML20210C8011999-07-21021 July 1999 Provides Response to NRC AL 99-02,which Requests That Addressees Submit Info Pertaining to Estimates of Number of Licensing Actions That Will Be Submitted for NRC Review for Upcoming Fy 2000 & 2001 ML20210E0431999-07-15015 July 1999 Forwards Insp Repts 50-424/99-04 & 50-425/99-04 on 990502- 0619.Two Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy ML20209H3881999-07-14014 July 1999 Forwards Revs 1 & 2 to ISI Program Second 10-Year Interval Vogtle Electric Generating Plant Unit 1 & 2 ML20209C4041999-07-0101 July 1999 Forwards Rev 29 to VEGP Units 1 & 2 Emergency Plan.Rev 29 Incorporates Design Change Associated with Consolidation of Er Facilities Computer & Protues Computer.Justifications for Changes & Insertion Instructions Are Encl ML20196H8081999-06-28028 June 1999 Discusses 990528 Meeting Re Results of Periodic PPR for Period of Feb 1997 to Jan 1999.List of Attendees Encl ML20212J2521999-06-21021 June 1999 Responds to NRC RAI Re Yr 2000 Readiness at Nuclear Power Plants.Gl 98-01 Requested Response on Status of Facility Y2K Readiness by 990701 ML20196F9171999-06-21021 June 1999 Forwards Owner Rept for ISI for Vogtle Electric Generating Plant,Unit 1 Eighth Maint/Refueling Outage. Separate Submittal Will Not Be Made to NRC on SG Tubes Inspected During Subj Outage ML20195F8031999-06-11011 June 1999 Forwards Changes to VEGP Unit 1 Emergency Response Data Sys (ERDS) Data Point Library.Changes Were Completed on 990308 While Unit 1 Was SD for Refueling Outage ML20207E7421999-06-0303 June 1999 Refers to from NRC Which Issued Personnel Assignment Ltr to Inform of Lm Padovan Assignment as Project Manager for Farley Npp.Reissues Ltr with Effective Date Corrected to 990525 ML20207F6201999-06-0202 June 1999 Sixth Partial Response to FOIA Request for Documents.Records in App J Encl & Will Be Available in Pdr.App K Records Withheld in Part (Ref FOIA Exemptions 7) & App L Records Completely Withheld (Ref FOIA Exemption 7) ML20207D9861999-05-28028 May 1999 Informs That,Effective 990325,LM Padovan Was Assigned as Project Manager for Plant,Units 1 & 2 ML20207D2701999-05-19019 May 1999 Forwards Insp Repts 50-424/99-03 & 50-425/99-03 on 990321- 0501.One Violation of NRC Requirements Identified & Being Treated as non-cited Violation Consistent with App C of Enforcement Policy ML20206M5141999-05-11011 May 1999 Informs That NRC Ofc of Nuclear Regulation Reorganized Effective 990328.As Part of Reorganization,Div of Licensing Project Mgt Created.Rl Emch Section Chief for Vogtle. Reorganization Chart Encl ML20206U4061999-05-11011 May 1999 Confirms Telcon with J Bailey Re Mgt Meeting Scheduled for 990528 to Discuss Results of Periodic Plant Performance Review for Plan Nuclear Facility Fo Period of Feb 1997 - Jan 1999 05000424/LER-1998-006, Forwards LER 98-006-03 Re Motor Control Ctr Breaker Buckets Not Being Seismically Qualified.Rev Is Submitted to Document Results of Seismic Testing That Demonstrated That No Condition Outside Design Basis of TS Requirements Exi1999-05-10010 May 1999 Forwards LER 98-006-03 Re Motor Control Ctr Breaker Buckets Not Being Seismically Qualified.Rev Is Submitted to Document Results of Seismic Testing That Demonstrated That No Condition Outside Design Basis of TS Requirements Existed ML20206D6411999-04-29029 April 1999 Forwards Vogtle Electric Generating Plant Radiological Environ Operating Rept for 1998 & Vogtle Electric Generating Plant Units 1 & 2 1998 Annual Rept Annual Radioactive Effluent Release Rept ML20206D5881999-04-29029 April 1999 Forwards Rept Which Summarizes Effects of Changes & Errors in ECCS Evaluation Models on PCT for 1998,per Requirements of 10CFR50.46(a)(3)(ii).Rept Results Will Be Incorporated Into Next FSAR Update ML20206D6951999-04-28028 April 1999 Provides Update of Plans for VEGP MOV Periodic Verification Program Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs ML20206C2241999-04-21021 April 1999 Forwards Revised Monthly Operating Repts for Mar 1999 for Vogtle Electric Generating Plant,Units 1 & 2.Page E2-2 Was Iandvertently Omitted from Previously Submitted Rept on 990413 ML20206A6371999-04-21021 April 1999 Forwards SE Authorizing Licensee Re Rev 9 to First 10-yr ISI Interval Program Plan & Associated Requests for Relief (RR) 65 from ASME Boiler & Pressure Vessel Code ML20205Q3351999-04-15015 April 1999 Forwards Insp Repts 50-424/99-02 & 50-425/99-02 on 990214-0320.Three Violations Identified & Being Treated as Non-Cited Violations ML20205T2351999-04-0909 April 1999 Informs That on 990317,B Brown & Ho Christensen Confirmed Initial Operator Licensing Exam Scheduled for Y2K.Initial Exam Date Scheduled for Wk of 991213 for Approx 10 Candidates ML20205K7501999-04-0505 April 1999 Informs That Effective 990329,NRC Project Mgt Responsibility for Plant Has Been Transferred from Dh Jaffe to R Assa ML20209A3741999-04-0505 April 1999 Submits Several Requests for Relief for Plant from Code Requirements Pursuant to 10CFR50.55a(a)(3) & (g)(5)(iii).NRC Is Respectfully Requested to Approve Requests Prior to Jan 1,2000 ML20205H3481999-03-31031 March 1999 Forwards Georgia Power Co,Oglethorpe Power Corp,Municipal Electric Authority of Ga & City of Dalton,Ga Status of Decommissioning Funding for Each Reactor or Part of Reactor Owned for OLs NPF-68 & NPF-81 ML20205F9091999-03-29029 March 1999 Submits Rept of Number of SG Tubes Plugged During Plant Eighth Maintenance/Refueling Outage (1R8).Inservice Insps Were Completed on SGs 1 & 4 on 990315.No Tubes Were Plugged ML20205G0761999-03-26026 March 1999 Provides Results of Individual Monitoring for 1998.Encl Media Contains All Info Required by Form NRC 5.Without Encl 1999-09-20
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217P3791999-10-21021 October 1999 Forwards NRC Form 396 & NRC Form 398 for Renewal of Licenses SOP-20607-1 & SOP-20610-1.Without Encls ML20217N2521999-10-20020 October 1999 Provides Supplemental Info Re 990405 Containment Insp Program Requests for Relief RR-L-1 & RR-L-2,in Response to 991013 Telcon with NRC ML20217K7541999-10-15015 October 1999 Forwards Rev 1 to Unit 1,Cycle 9 & Unit 2 Cycle 7 Colrs,Iaw Requirements of TS 5.6.5.Figure 5, Axial Flux Difference Limits as Function of Percent of Rated Thermal Power for RAOC, Was Revised for Both Units ML20217G6751999-10-13013 October 1999 Requests Withholding of Proprietary Info Contained in Application for Amend to OLs to Implement Relaxations Allowed by WCAP-14333-P-A,rev 1 ML20216J9161999-10-0101 October 1999 Forwards Response to NRC 990723 RAI Re GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves ML20216J9041999-10-0101 October 1999 Forwards Response to RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves ML20212E7481999-09-20020 September 1999 Requests Approval Per 10CFR50.55a to Use Alternative Method for Determining Qualified Life of Certain BOP Diaphragm Valves than That Specified in Code Case N-31.Proposed Alternative,Encl ML20212E8751999-09-20020 September 1999 Forwards Response to NRC GL 99-02, Lab Testing of Nuclear Grade Activated Charcoal. Description of Methods Used to Comply with Std Along with Most Recent Test Results Encl ML20212C2191999-09-16016 September 1999 Forwards NRC Form 536, Operator Licensing Exam Data, Which Is Current Need for NRC Operator Licensing Exams for Years 2000 Through 2003 of Plant Vogtle,Per Administrative Ltr 99-03 ML20211J5291999-08-30030 August 1999 Forwards Snoc Copyright Notice Dtd 990825,re Production of Engineering Drawings Ref in VEGP UFSAR ML20211J5251999-08-30030 August 1999 Forwards Response to NRC 990727 RAI Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design Basis Accident Conditions ML20211J7381999-08-27027 August 1999 Informs That Licensee Vessel Data Is Different than NRC Database Based on Listed Info,Per 990722 Request to Review Rvid ML20211E9251999-08-23023 August 1999 Forwards fitness-for-duty Performance Data for Jan-June 1999,as Required by 10CFR26.71(d).Data Reflected in Rept Covers Employees at Vogtle Electric Generating Plant ML20210L2181999-08-0202 August 1999 Forwards NRC Form 396 & Form 398 for Renewal of Listed Licenses,Iaw 10CFR55.57.Without Encl ML20210C8011999-07-21021 July 1999 Provides Response to NRC AL 99-02,which Requests That Addressees Submit Info Pertaining to Estimates of Number of Licensing Actions That Will Be Submitted for NRC Review for Upcoming Fy 2000 & 2001 ML20209H3881999-07-14014 July 1999 Forwards Revs 1 & 2 to ISI Program Second 10-Year Interval Vogtle Electric Generating Plant Unit 1 & 2 ML20209C4041999-07-0101 July 1999 Forwards Rev 29 to VEGP Units 1 & 2 Emergency Plan.Rev 29 Incorporates Design Change Associated with Consolidation of Er Facilities Computer & Protues Computer.Justifications for Changes & Insertion Instructions Are Encl ML20196F9171999-06-21021 June 1999 Forwards Owner Rept for ISI for Vogtle Electric Generating Plant,Unit 1 Eighth Maint/Refueling Outage. Separate Submittal Will Not Be Made to NRC on SG Tubes Inspected During Subj Outage ML20212J2521999-06-21021 June 1999 Responds to NRC RAI Re Yr 2000 Readiness at Nuclear Power Plants.Gl 98-01 Requested Response on Status of Facility Y2K Readiness by 990701 ML20195F8031999-06-11011 June 1999 Forwards Changes to VEGP Unit 1 Emergency Response Data Sys (ERDS) Data Point Library.Changes Were Completed on 990308 While Unit 1 Was SD for Refueling Outage 05000424/LER-1998-006, Forwards LER 98-006-03 Re Motor Control Ctr Breaker Buckets Not Being Seismically Qualified.Rev Is Submitted to Document Results of Seismic Testing That Demonstrated That No Condition Outside Design Basis of TS Requirements Exi1999-05-10010 May 1999 Forwards LER 98-006-03 Re Motor Control Ctr Breaker Buckets Not Being Seismically Qualified.Rev Is Submitted to Document Results of Seismic Testing That Demonstrated That No Condition Outside Design Basis of TS Requirements Existed ML20206D5881999-04-29029 April 1999 Forwards Rept Which Summarizes Effects of Changes & Errors in ECCS Evaluation Models on PCT for 1998,per Requirements of 10CFR50.46(a)(3)(ii).Rept Results Will Be Incorporated Into Next FSAR Update ML20206D6411999-04-29029 April 1999 Forwards Vogtle Electric Generating Plant Radiological Environ Operating Rept for 1998 & Vogtle Electric Generating Plant Units 1 & 2 1998 Annual Rept Annual Radioactive Effluent Release Rept ML20206D6951999-04-28028 April 1999 Provides Update of Plans for VEGP MOV Periodic Verification Program Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs ML20206C2241999-04-21021 April 1999 Forwards Revised Monthly Operating Repts for Mar 1999 for Vogtle Electric Generating Plant,Units 1 & 2.Page E2-2 Was Iandvertently Omitted from Previously Submitted Rept on 990413 ML20209A3741999-04-0505 April 1999 Submits Several Requests for Relief for Plant from Code Requirements Pursuant to 10CFR50.55a(a)(3) & (g)(5)(iii).NRC Is Respectfully Requested to Approve Requests Prior to Jan 1,2000 ML20205H3481999-03-31031 March 1999 Forwards Georgia Power Co,Oglethorpe Power Corp,Municipal Electric Authority of Ga & City of Dalton,Ga Status of Decommissioning Funding for Each Reactor or Part of Reactor Owned for OLs NPF-68 & NPF-81 ML20205F9091999-03-29029 March 1999 Submits Rept of Number of SG Tubes Plugged During Plant Eighth Maintenance/Refueling Outage (1R8).Inservice Insps Were Completed on SGs 1 & 4 on 990315.No Tubes Were Plugged ML20205G0761999-03-26026 March 1999 Provides Results of Individual Monitoring for 1998.Encl Media Contains All Info Required by Form NRC 5.Without Encl ML20205H4051999-03-25025 March 1999 Forwards Info on Status of Decommissioning Funding for Each Reactor or Part of Reactor Owned for OLs NPF-68 & NPF-81,as Requested IAW 10CFR50.75(f)(1) ML20205H3891999-03-25025 March 1999 Forwards Info on Status of Decommissioning Funding for Each Reactor or Part of Reactor Owned for OLs NPF-68 & NPF-81,as Requested IAW 10CFR50.75(f)(1).Page 2 in Third Amend Power Sales Contract of Incoming Submittal Not Included ML20205A9441999-03-25025 March 1999 Forwards VEGP Unit 1 Cycle 9 Colr,Per TS 5.6.5.d ML20205H3811999-03-24024 March 1999 Forwards Info on Status of Decommissioning Funding for Each Reactor or Part of Reactor Owned for OLs NPF-68 & NPF-81,as Requested IAW 10CFR50.75(f)(1) ML20205H3621999-03-22022 March 1999 Forwards Info on Status of Decommissioning Funding for Each Reactor or Part of Reactor Owned for OLs NPF-68 & NPF-81, as Requested IAW 10CFR50.75(f)(1) ML20204G4361999-03-18018 March 1999 Forwards Summary Rept of Present Level & Source of on-site Property Damage Insurance Coverage for Vegp,Iaw Requirements of 10CFR50.54(w)(3) ML20204C0591999-03-17017 March 1999 Forwards Rev 0 to WCAP-15160, Evaluation of Pressurized Thermal Shock for Vegp,Unit 2 & Rev 0 to WCAP-15159, Analysis of Capsule X from Vegp,Unit 2 Reactor Vessel Radiation Surveillance Program ML20207K9551999-03-11011 March 1999 Forwards Response to Rai,Pertaining to Positive Alcohol Test of Licensed Operator.Encl Info Provided for NRC Use in Evaluation of Fitness for Duty Occurrence.Encl Withheld,Per 10CFR2.790(a)(6) ML20207L9721999-03-10010 March 1999 Forwards Rev 15 to EPIP 91104-C of Manual Set 6 of Vogtle Epips.Without Encl ML20207B0191999-02-25025 February 1999 Forwards Fitness for Duty Performance Data for six-month Reporting Period 980701-1231,IAW 10CFR26.71(d) 05000424/LER-1998-009, Forwards LER 98-009-00 Re Event in Which Improper Testing Method Resulted in Inadequate Surveillances on 9812291999-01-27027 January 1999 Forwards LER 98-009-00 Re Event in Which Improper Testing Method Resulted in Inadequate Surveillances on 981229 ML20199F7701999-01-13013 January 1999 Submits Revised Response to RAI Re Licensee 980713 Proposed Amend to Ts,Eliminating Periodic Response Time Testing Requirements on Selected Sensors & Protection Channels. Corrected Copy of Table,Encl ML20199F7981999-01-13013 January 1999 Forwards Corrected Pages to VEGP-2 ISI Summary Rept for Spring 1998 Maint/Refueling Outage. Change Bar in Margin of Affected Pages Denotes Changes to Rept ML20199G1381999-01-13013 January 1999 Forwards Copy of Permit Renewal Application Package for NPDES Permit Number GA0026786,per Section 3.2 of VP Environ Protection Plan 05000424/LER-1998-007, Forwards LER 98-007-00,re Inadequate Surveillances Due to Improperly Performed Response Time Testing,On 981215,IAW 10CFR50.731999-01-13013 January 1999 Forwards LER 98-007-00,re Inadequate Surveillances Due to Improperly Performed Response Time Testing,On 981215,IAW 10CFR50.73 ML20198F6131998-12-18018 December 1998 Forwards Revised Certification of Medical Exam Form for License SOP-21147.Licensee Being Treated for Hypertension. Util Requests That Individual License Be Amended to Reflect Change in Status ML20198L6631998-12-18018 December 1998 Forwards Amend 37 to Physical Security & Contingency Plan. Encl 1 Provides Description & Justification for Changes & Encl 2 Contains Actual Amend 37 Pages.Amend Withheld,Per 10CFR73.21 ML20198D9291998-12-16016 December 1998 Forwards Requested Info Re Request to Revise TSs Elimination of Periodic Pressure Sensor Response Time Tests & Elimination of Periodic Protection Channel Response Time Tests ML20198D9991998-12-16016 December 1998 Forwards Responses to 980916 RAI Re Response to GL 97-01, Degradation of Control Rod Drive Mechanism Nozzle & Other Vessel Closure Head Penetrations ML20198D8171998-12-14014 December 1998 Forwards NRC Form 396 & Form 398 for Renewal of License OP-20993.Without Encls ML20206N3051998-12-0808 December 1998 Submits RAI Re Replacement of Nuclear Instrument Sys Source & Intermediate Range Channels & post-accident Neutron Flux Monitoring Sys 1999-09-20
[Table view] Category:LEGAL/LAW FIRM TO NRC
MONTHYEARML20044A7461990-06-25025 June 1990 Forwards Endorsement 35 to Nelia Policy NF-302 & Endorsement 29 to Maelu Policy MF-129 ML20064B4911990-05-31031 May 1990 Forwards 900507 Court Order Instructing Parties to Provide Info to Wage & Hour Administrator Re M Hobby Claims Against Util Under ERA ML20006A6241990-01-16016 January 1990 Forwards Draft Qualified Master Trust Agreement for Decommissioning of Nuclear Plants,For Review.Licensee Will Make Contributions to Qualified & Nonqualified Trust as Appropriate ML20244D9001989-04-0606 April 1989 Forwards Endorsements 94 & 18 to Maelu Policies MF-78 & MF-129,respectively & Endorsements 112 & 24 to Nelia Policies NF-215 & NF-302,respectively ML20244D9131989-04-0505 April 1989 Forwards Endorsements 1 to Nelia Certificate N-117 & Maelu Certificate M-117 ML20247A3021989-03-21021 March 1989 Discusses 890302 Notice of Finding of No Significant Antitrust Changes Re OL for Unit.Oglethorpe Power Corp 890317 Comments Do Not Affect NRC Ability to Recommend & Commission Ability to Issue Full Power License on 890330 ML20247H3981989-03-21021 March 1989 Forwards 890228,0308 & 15 Ltrs on No Significant Change Finding Re Antitrust OL Review ML20245H7831989-02-28028 February 1989 Discusses Transaction Between Oglethorpe Power Corp & Seminole Power Cooperative,Per Antitrust Review.Antitrust Review Reflects Assertions That Are Factually Incorrect & Should Reflect Addl Facts Available ML20151Z5491988-08-23023 August 1988 Forwards Supplemental Reg Guide 9.3 Info in Response to Mathews to Wg Hairston ML20150E4781988-07-0505 July 1988 Forwards Endorsement 14 to Maelu Policy MF-129 & Endorsement 20 to Nelia Policy NF-302 ML20148H0821988-01-12012 January 1988 Forwards Endorsements 105 & 16 to Nelia Policies NF-215 & NF-302 & Endorsements 87 & 10 to Maelu Policies MF-78 & MF-129 ML20206R9481987-04-10010 April 1987 Forwards Endorsements 15 & 9 to Nelia Policy NF-302 & Maelu Policy MF-129,respectively ML20204F4841987-02-26026 February 1987 Forwards Endorsement 8 to Maelu Policy MF-129 & Endorsements 10,11,12,13 to Nelia Policy NF-302 ML20207T6041987-02-26026 February 1987 Forwards Dept of Labor 870218 Final Decision Dismissing Case 86-ERA-9 Re JW Durham Vs Util & Butler Svc Group,Per Cw Whitney Request.W/Certificate of Svc ML20210S5371987-02-0202 February 1987 Forwards Endorsement 1 to Nelia Policy N-111 & Maelu Policy M-111 ML20211J8201986-10-14014 October 1986 Forwards Endorsement 8 to Nelia Policy NF-302 ML20214Q1441986-09-18018 September 1986 Discusses ASLB 860827 Partial Initial Decision Re Several Contentions,Incuding Contention 10.1 Addressing dose-rate Effects & Applicant Submittal of Addl Info on Subj.Addl Info Should Not Change ASLB Conclusions.Svc List Encl ML20206S2701986-09-17017 September 1986 Notifies of Address Change Effective on 860927.Requests Address on Encl List of Dockets Be Changed ML20214L6021986-09-0505 September 1986 Forwards Kp Twine Supplemental Affidavit on Contention EP-5 Re Rev to Savannah River Plant Plan,Incorporating Info on Reception Ctrs.Inclusion of Reception Ctr Info in Emergency Plans Resolve ASLB Concern ML20212Q8141986-09-0303 September 1986 Forwards Applicant 860821 & 0902 Ltrs to NRC Re Board Notification 86-018,for Info.W/Svc List.Related Correspondence ML20212N0631986-08-26026 August 1986 Discusses Plant Conformance to NUREG-0654,App 3 Re Emergency Broadcast Sys,Per Board 860812 Order.Related Correspondence ML20212H4171986-08-11011 August 1986 Forwards 860430 Scheduling Svcs Agreement Between Georgia Power Co & Oglethorpe Power Corp.Partially Deleted Interconnection Agreement Between Alabama Electric Cooperative,Inc & Ogelthorpe Power Corp Also Encl ML20204K0691986-08-0404 August 1986 Informs That Listed Info on Burke County Reception Ctr Capacity Will Be Added to Emergency Plan,Per Board 860717 Memorandum & Order.Info Should Enable NRC & FEMA to Complete Verification of Plan.W/Svc List ML20202G1691986-07-10010 July 1986 Forwards Correspondence Re Application for 10CFR70 License for Possession & Storage of Unirradiated Reactor Fuel & Associated Snm.W/Svc List.Related Correspondence ML20206P7131986-06-30030 June 1986 Forwards Revised Pages to Offsite Plans Re Emergency Public Info Program for Transients (EP-2/EP-2 (H)),Per Board 860505 Memorandum & Order.W/Svc List.Related Correspondence ML20206J7821986-06-23023 June 1986 Forwards Updated Page Changes for Burke County & State of Ga Emergency Plans for Facility Plume Pathway Emergency Planning Zone.Encl Plan Changes Composite of Feb & Apr 1986 Changes.Svc List Encl.Related Correspondence ML20206D8211986-06-16016 June 1986 Responds to Re 860310 Motion for Summary Disposition of Contention EP-5.Applicants Did Not Address Savannah River Plant Plan Because Reception Ctrs Not Related to Issue Raised.Kp Twine Affidavit Encl.W/Svc List ML20206D7041986-06-16016 June 1986 Forwards Revised Burke County Plan Pages Re EP-4 & EP-1/EP-1(a)/EP-2(b).In Accordance w/860513 Ltr to Board, Revised Plan Pages Re EP-2/EP-2(h) on Public Info for Transients Will Be Provided on or Before 860701.W/svc List ML20209E7401986-06-12012 June 1986 Forwards Certified Declarations Page for Endorsements 1 Through 6 to Nelia Policy NF-302,dtd 860605 ML20155K0021986-05-20020 May 1986 Requests That Specific Revised Sections of Burke County Emergency Plan Which Accurately Identify Backup Means of Notification & Line of Succession of Emp Be Provided to NRC & FEMA by 860701.Svc List Encl ML20197G7181986-05-13013 May 1986 Discusses Steps Taken to Comply W/Aslb 860429 & 0505 Orders Re Offsite Emergency Planning.Changes Will Be Reflected in Full Plan Revs Scheduled for Fall 1986 ML20203D6621986-04-17017 April 1986 Informs of Review of Staff Response to Applicant Motion for Summary Disposition of Joint Intervenors Contention EP-2/EP-2(h) & Affidavit of Cl Stovall.State & Local Emergency Plans Will Be Revised.Related Correspondence ML20203A0071986-04-14014 April 1986 Forwards Proposed Findings of Fact & Conclusions of Law on Technical & Environ Contentions.Certificate of Svc & Svc List Encl ML20138C1491986-03-28028 March 1986 Forwards Revised Emergency Public Info/Education Matls for State of Ga Portion of Plume Exposure Pathway Emergency Planning Zone.Info Revised to Include Use of Fixed Sirens. Svc List Encl.Related Correspondence ML20137Z5791986-03-11011 March 1986 Requests That Gf Trowbridge Be Replaced as Addressee for NRC Correspondence in Accordance W/Listed Client Facility & Designated Addressee ML20203C2321986-03-0505 March 1986 Appeals Lack of Response to FOIA Request for Documents Re NRC Investigation Into Complaints of Register,L Price & JB Register Concerning Illegal & Improper Procedures & Practices at Facility ML20154B8611986-02-28028 February 1986 Forwards Draft Bechtel Rept, Groundwater Numerical Modeling, Dtd Feb 1986.Svc List Encl.Related Correspondence ML20154C4641986-02-27027 February 1986 Forwards Page 13 of Asco Catalog NP-1,omitted from Exhibit F to Applicants 860224 Testimony of Gt Baenteli,G Bockhold, Sj Cereghino,Wv Cesarski & Hj Quasny on Contention 10.5 Re Solenoid Valves.Related Correspondence ML20205J7171986-02-24024 February 1986 Forwards Applicant Testimony on Contentions 7 & 10.1 Re Groundwater,Per ASLB 860114 & 23 Scheduling Order & Suppl,Respectively.Testimony of Contention 10.5 Filed Under Separate Cover.W/Certificate of Svc.Related Correspondence ML20205K3911986-02-24024 February 1986 Forwards Updated Reg Guide 9.3 Info for Antitrust Review of Facility,Per Jl Funches 861218 Request ML20153E0761986-02-18018 February 1986 Identifies Witnesses Scheduled to Testify on Applicant Behalf Re Contentions 7,10.1 & 10.5 Per ASLB 860114 & 23 Scheduling Order & Supplemental Scheduling Order, Respectively.Svc List Encl.Related Correspondence ML20147C4651986-02-14014 February 1986 FOIA Request for All Documents Re Mcnally,B Weatherford, J Register,St Register & L Price ML20151W8721986-02-10010 February 1986 Forwards Vogtle Energy Generating Plant Groundwater Monitoring Program Jul-Dec 1985 & Results of Hydrogeologic Testing Power Block Area Vogtle Electric Generating Plant.... W/Svc List.Related Correspondence ML20151U7241986-02-0505 February 1986 Forwards site-specific Emergency Response Plans,In Response to 850812 & 1001 Memorandum & Orders Re Ruling on Proposed Contentions on Emergency Planning & Ruling on 850905 Reconsideration Motion.Svc List Encl.Related Correspondence ML20199E3961986-01-15015 January 1986 FOIA Request for Documents Re Allegations,Findings & Orders That Pullman Power Products Employees Intimidated & Harassed QC Inspectors at Nuclear Facilities ML20138P6151985-12-17017 December 1985 Advises That Applicants in Accord w/851212 Ltr Stating Proceeding Expected to Commence in Mar 1986.Emergency Planning Issues Remaining After Summary Disposition Will Be Ready for Mar Hearing.Related Correspondence ML20133K9991985-10-18018 October 1985 Forwards Emergency Planning Zone Map.W/O Map.Svc List Encl. Related Correspondence ML20133F1131985-10-0404 October 1985 Forwards Emergency Public Info/Educ Matls for Plume Exposure Pathway Emergency Planning Zone.Challenges to Adequacy of Matls Should Be Submitted by Joint Intervenors within 30 Days.Svc List Encl.Related Correspondence ML20210K5041985-10-0303 October 1985 Forwards for Review,Petition & Supporting Brief Re Dept of Labor Case 85-ERA-27 (Mcnally,Et Al Vs Georgia Power Co), Per C Whitney Request.W/O Encl ML20210K5111985-10-0303 October 1985 Forwards for Review,Petition & Supporting Brief Re Dept of Labor Case 85-ERA-27 (Mcnally,Et Al Vs Georgia Power Co), Per C Whitney Request.W/O Encl 1990-06-25
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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.
Very truly yours,
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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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TELtx: SiO - 756 - e2 06 TELECOPIER: 404-22t-0469
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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
~
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.
' TROUTMAN,$ANDERS.LOCKERMAN 6 ASHMORE
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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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TCOUTMAN.SANDCES LOCMCCMAN & ASMMORE ,
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i Ms. Laurie Fowler April 19, 1985 ,
Page Six ]
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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
+
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.
i
- 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
1 4
. 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
- 6 .A-6 + - - - .
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.
l
- 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
)
GEORGIA PCWER CO., et al. 2 APR 25 om&&O Nos. 50-424 and 50-425
)
(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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4 UNITED STATES OF AMERfCA
- - 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
)
(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.
7j .
[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