ML20112E038

Third Set of Interrogatories & Requests to Produce Identified Documents Involving Intervenor Contentions 7,10, 11,12 & 14.Certificate of Svc Encl.Related Correspondence

ML20112E038
Person / Time
Site:	Vogtle
Issue date:	01/07/1985
From:	Johnson T CAMPAIGN FOR PROSPEROUS GEORGIA (EDUCATIONAL), GEORGIANS AGAINST NUCLEAR ENERGY
To:	GEORGIA POWER CO.
Shared Package
ML20112E028	List: ML20112E027 ML20112E038
References
OL, NUDOCS 8501150008
Download: ML20112E038 (19)

Text

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itCLATED CCRRESPONDEGCE ,,

UNITED STATES OF AMERICA Opc ,

NUCLEAR REGULATORY COMMISSION j E8 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'gp d, y y In the Matter of ) .

$hj GEORGIA POWER CO., et al.

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Docket Nos. 50-424 and 50-425

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(Vogtle Electric Generating Plant, )

Units 1 and 2) ) *4 ',

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CAMPAIGN FOR A PROSPEROUS GEORGIA / GEORGIANS AGAINST NUCLEAR ENERGY THIRD SET OF INTERROGATORIES AND REQUESTS TO PRODUCE Pursuant to 10 CFR Sections 2.740 (b) and 2.741. Intervenors Campaign for a ProsperousGeorgiaandGeorgiansAgainstNuclearEnergy(hereinafter" CPG /GANE")

hereby serves its Third Set of Interrogatories and Requests to Produce upon the Applicant in the above-styled proceeding. These interrogatories and requests to produce involve CPG /GANE's Contentions 7, 10, 11, 12 and 14 >

Each interrogatory shall be answered fully in writing, under oath or affirmation, and include all pertinent information known to the Applicant including its officers, employees, agents, advisors or counsel. Each request to produce applies to pertinent documents which are in the possession, custody or control of, or are otherwise available to, the Applicant, including its officers, employees, agents, advisors or cou:.2el.

In answering each interrogatory and responding to each request, please recite Lne interrogatory or request preceding each answer or response. Also, identify the person providing each answer or response, including but r.ot limited to his m' her name, address, employer, current position and a statenar.t of pr6fessf 6ti3} Walifications.

Thesd inNrf@stoH4 and requests sPall be continuing in nature. Thus, wheniMi sn) liif6FcMtio*1 {s. Obtained which renders any previous response incorrect or incomplete or indicates that a response was incorrect or incomplete when made, the Applicant is hereby requested to supplement its previous response to the 1

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• appropriateiinterrogatory or request to produce.

The term > document" shall include any writings, drawings, graphs, charts, iphotographs, and other data compilations from which information can be obtained.

s CPG /,bANErequests'thatatdatestobeagreedupon,the' Applicant make available 'or 3 y ins'pection and copying all documents subject to the requests set forth below. .

,,' Requests for Documents Purst t to 10 CFR Section 2.741, CPG /GANE requests Applicant, by and through t

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-its attorneys, make available for inspection and copying, at a time and location to ,

-be designated, any and all documents of whatsoever description identified in tr.? .

responses to the Intervenors' interrogatories below, f r.cluding but not limited,to': ,

(1) any britten record of any oral communication between or among Applicant,

-its advisors, consultants, contractors, agents, attorneys, and/or any other

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pers'ni, o including but not limited to the NRC staff, the Intervenors, and their advisors, consultants, contractors, agents, attorneys and/or any other persons; e

and *

(2)'any documents, correspondence, letters, memoranda, diagrams, reports, charts, photographs, or any other writing of whatsoever description, including but not limited to work papers, prior drafts and notes of meetings, w

t .If' pplicant maintains that some documents should not be y made.available for y inspection, Applicant should specify the documents and explain why such are not .

being made available. This requirement extends to.any such do'cument, described

. v above, in the possession of or available to the/ Applicant, its advisors, l;

/ s 'l consultants, t.gehts dr attorneys. -

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i Interrogatories du'suantte10CFRSection2.740(b),

r CPG /GANErequeststhEApplicalitbyand'l through its attorneys answer separately and fully in writing, under oath or h

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[-[ 'affinnation, by persons having knowledge of the information requested, the following int,crrogatories. .

A. General Interrogatories The following interrogatories apply severally to each of the contentions admitted as issues in controversy in this proceeding: CPG /GANE Contentions 7, 8, 10,~ 11, 12 and 14.

1. Please identify (by name, business address, occupation and employer) all g  ; individuals' who have knowledge or information responsive to each interrogatory and b

' designate the interrogatory or the part thereof which that individual answered.

/

'2. - Please identify any Open Items and identify (by name, business address.

Y occupation and employer) all individuals working on the resolution of the Open Items

[andd'esignatetheItemortheportionthereoftheindividualisworkingon. Please also provide any documents related'to the Open Items.

~3. VEGP Response to IQA-1 identified almost seven pages of names, addresses, and organizations of individuals providing technical information to VEGP and their r responses to Intervenor questions, but the VEGP responses did not include the financial relationship among themselves, the organizations they represent and VEGP.

Nor did the VEGP response to question A-1 identify the specific renumeration between VEGP and these individuals. The Rosenthal experimenter expectancy effect is a well

' documented research bias displayed unwittingly by an experimenter that can skew or

-lead 'tect'nical statements to predictable conclusions. As F. W. Bessel, a Gennan-

. astronomer, first proved 1:1 1815, individual differences even among most experienced

' astronomers can lead to observational differences. Rosenthal experimenter expectancy effect builds Gr1 top of individual differences by skewing an experiment alongl'inesofbiasorprejudgment. The VEGP technical consultants should assist in

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. measuring the p/onouncem#nt of this'effect on VEGP technical responses. Please

' provide an estimate of this'effect.

.4. - How much independent data gathering has the NRC staff done~ on VEGP? Has an 3

w . _ _ _ __ - _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ - - - -

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independent assessment of the NRC staff's analyses of VEGP been completed? Please *

' detail all technical differences between the VEGP and the NRC.

B. Specific Interrogatories

1. When will Morton Goldman have " compiled the facts [and] fonnulated the opinions to which he will testify," as stated in " Applicants' Response to Intervenors' First

. Set of Interrogatories and Request for Production of Documents" (hereinafter

" Applicants' First Response"), page 97 2[ Do'the Applicants have no intention of designing post-operational radiological monitoring programs prior to operation of the plant, as implied in " Applicants'

. First Response" p. 20?

3. In " Applicants' First Response" p. 26, Applicants state, "However, construction of the major features of the plant has been completed and the ground water table has recovered to levels similar to.those measured prior to construction..." Please describe the levels of the groundwater during construction from which it has

" recovered."

4. What provisions have Applicants made for availability of " temporary tanks or containers," including assurances that such containers will provide safe storage for radioactively contaminated water and that they would be available in a timely fashion, as stated in "AF.licants' First Response" p. 307 5 .- How would radioactive contamination of the Mathes Pond "be intercepted"

("ApNicants' First Response" p. 40)?

6. 'In "/.pplicant::' Firs R:sponse" the-Apolicants made'available certain documents and ' numbereij tfis_ paget Mfn. The following questions concerning TDI generators N relate tc thew OEushb

. a} . EHC.140diO. 'dobitcants stato "cause r Maring wear has not been-

. determined." Has the cause been de? sa ee ince that time? Please provide g .the basis for the response.

i

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y b) Page 140028, the cause is " unknown at this time." Has the cause since been

• determined? Provide the basis for the response.

c) ~Page 140323, the cause is " suspected." Has the cause since been confirmed?

' Provide'the basis for the response.

d)~ Page 140385, the cause is " suspected." Has the cause since been confi'rmed?

Please provide the basis for the response.

e) Page 140488, the cause is " suspected." Has the cause since been confirmed?

Please provide the bases for the response, f)- Page 140626, the cause is " unknown." Has the cause since been ascertained?

.Please provide details, including the bases for the response, g) Page 140684, the cause is " suspected." Has the cause since been confinned?

.Please provide the bases for the response.

h)~~Page 140723, the cause is " unknown." Has the cause since been determined?

Please provide details, including the bases for the response.

1) Page 140749, the cause is " suspected." Has the cause since been confinned?

Please provide the bases for the response, j) Page 140936, the cause is " suspected." Has the cause since been confirmed?

Please provide the bases for the response.

k) Page 141223, the cau e is " suspected." Has the cause since been confirmed?

Please provide the bases for the response.

1) Page 141256, the cause is " unknown." Has the cause since been ascertained?

Please provide details, including the bases for the response.

m) = Page'_141401, ori 0=$-84, the results were marked " sat [isfactory]" and on 8-10'-84,-wsre chinged to "(!nsat[isfactory]." Why were the results changed? _ Why

_was E initiilly ma6 N satisfactory? Provide' details, including the bases for

'the response, n)_ Page 141826, the cause is described as "apparently..." Has the cause since.

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'been confirmed? Provide details, including the bases for the response,

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,o) Page 144505, the Applicants state, "A review has also been made of the quality assurance program at TDI and it has been concluded that there has not been 'a significant breakdown in the quality program at TDI." In view of the

. extraordinarily poor record at TDI, what would be a significant breakdown in th'e quality program at TDI? Please be specific and provide the bases for'the response.

p) ~Page 1414811 Applicants state, " Suppliers were evaluated prior to award to assure that their quality assurance program and facilities complied with the

. procurement document requirements... based on surveys, past performance, audits I'

iand the review and. approval of the suppliers' documented quality programs."

Would the Applicants again choose TDI if ordering new emergency diesel generator for a new nuclear power plant today? If not, why not? If so, why?

Provide the bases for the response.

.q) Page 1414812, Applicants state, " Surveillance inspections were performed at the supplier's facility. . ." Was the supplier notified in advance of these inspections?. Describe the inspection process in detail, r) Page 149258, TDI' states, " Georgia Power Company extension of cooperation to

~ Transamerica Delaval Inc. over the last three months.has been one of

' hardship..i"' What is the Applicants' response to this accusation? Have

-? relationships between TDI and the Applicants improved since that' time?

s): Page-1410976, the Applicants state, "Should we not hear from Transamerica i

by this date, we will assume that'there exist in your organization a lack of dedication to ensura $ quality product per the specification and the contract."

'Ditbu,5pk11MntsOsliPle.thatTDIisdedicatedtoensuringaqualityproduct

. psr (P.8f.5P96fdthtlPf14, contracts and regulatory requirements?- Provide the

bases for the response.

it)' Page 1411006,- the Applicants' contractor (Bechtel) states, " Compliance with 6

ca--

m Appendices EA Revision 2 and QG Revision 0 for qualification of the equipment

• will not be required. Appendices EA and QG will not be incorporated as part of the contract." What are the bases for this decision?

u) Page 149327, TDI states, "...not all requests made in your June 19, 1984 letter can be fulfilled by TDI at this time...TDI has not accepted the Owrrers' Group X-ray criteria for rod bearings and therefore declines your request to X-ray the shells prior to delivery." Has TDI maintained this position? Has the Owners' Group maintained its position? Has this controversy been resolved?

Provide details, including the bases for the response.

v) Page 149327, TDI says it " sees no reason to issue purchase orders and invoice after fact. The possibility of muddled documentation and responsibility exists in trying to rectify this kind of situation." Have the Applicants requested that TDI issue purchase orders and invoice after the fact?

Provide the justification and bases for the response, w) Page 149327, TDI asks the Applicants to " inform TDI if GPC wishes to wave source inspection on any parts ordered..." Did the Applicants waive such inspection in this or any other instances? Provide details, including dates, parts, justificacion and the bases for the response.

x) Page 149472, TDI says its improvements "added over 13-1/2 percent to the cost of the engines," What is the cost of the engines?

y) Page 1433156 states that certain equipment "is not available pre-qualified IE. Hostir.ghouse son they have no intention of qualifying it."

How was the problen dssertbed ir, ibis letter resolved? Provide details.

z )' Pave the A6plienif b considered replacing the TDI generators with another t

Cd5psfi N pfDducti If 40, provide details as to the reason (s) this has not been done. If not, why not? Provide details, including the bases for the response.

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7. When will Applicants complete the list of polymer materials contained in the

- safety related equipment at Plant Vogtle as stated in " Applicants' First Response" .

p. 51 and again on p. 55?

8. Applicants state that " drift deposition rates predicted for five similar power plants were used to estimate a range of drift rates that could be expected at Plant Vogtle...Thus, although some of these plants are now operating, the data used was based on design information." (" Applicants' First Response" p. 93). Please provide empirical data comparing the actual deposition rates during operations for those plants that are in operation and on whose predictions the Applicants relied in calculating deposition rates for Plant Vogtle. Provide the bases for the response.

9. a) In " Applicants' First Response" p. 98, Applicants state that they "have decided to increase the duration of chlorination during corbicula spawning season." Please provide details--the duration planned at tlie Construction Permitting stage and the duration now planned. Provide the bases for the response.

b) What will be the environmental impacts of this increased duration for

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chlorine-injection?

, 10. Why does Research-Cottrell state that the expected drift rate is four times smaller than the expected drift rate used by the Applicants (" Applicants' First Response" p. 100)? Provide the bases for the response.

-11. Update the number of wells on the VEGP facility. Include historical data.

Differentiate between groundwater and confined aquifer wells. Include closed wells.

(The FSAR 1ists nine well) in the confined aquifer,16 in the unconfined aquifer,11 initial 1y in backfill; oincP information suggests 2-3 makeup water wells, I test well,.1400 gpm well and canQ 100 gpm well; the VEGP Response to Intervenor Question (herefnafter 1Q) 94 stated there were 8 confined aquifer production wells.)

Precisely locate all open, active, inactive, and abandoned wells on a clear surface -

map of VEGP. Use-applicable well numbers. Explain the rationale on why each well 8

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site ' drilled or abandoned by YEGP was chosen by VEGP, especially why each well in the observation network was chosen (see Item 13 below). Discuss uncertainties in

.the VEGP observation network.

12. The FSAR (Table 2.4.12-3) lists 18 wells and water quality analyses for those

- 18 wells. The analyses were done in 1971. Table 4.5 of the Vogtie CES lists the known characteristics of the VEGP water, low volume waste and combined effluent systems. In the FSAR data base does not have all of these same characteristics listed and may not therefore establish the premigration level of certain nuclides (e.g., PSS, mercury, zinc, etc. ; cf., VEGP Response to IQ B-18, p. 32). Neither DES

~ Table 4.5 nor the FSAR tables establish a radionuclide datum.

Update the water quality for all wells for all characteristics listed in DES Tables 4.2 and 4.5. Establish a quarterly datum in all wells for liquid waste l radioactive and hazardous nuclides treated, stored, or released as an airborne or liquid effluent from VEGP. Duplicate for springs and surface water data in the FSAR I

(Tables'2.4.12-5,6). Precisely locate each spring and surface water sampling point

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on a ' clear surface map of VEGP denoting all boundaries. Explain all monitoring

. techniques.

13. - There are 34 observation wells listed in Table 2.4.12-7, FSAR, vs. - the 36 noted-

in the FSAR text (p. 2.4.12-19). Table 2.4.12-7 lists two sets -of data for well water levels through 1974 an'd then for 1979.

0nly 14 of 34 wells are to be found in both sets of data. Explain. List all wells in Item 11 above from these data sheets i

and any other wells not' included,- whether the wells are operational or have been

- closed or abandoned. . Include-data for well 42E (cf. Items 33, 34, 35 below)..

14.- Aq'uiclude wells 42B/C-data (Table 2.4.12-7, sheet 1/3) showed varying water heights. If these wells were in marl, supposedly an " impermeable" marl, what was the source of the water? Explain the varying water heights. Were these. wells

- pumped.? If pumped, ' provide the pumping data.. Provide water flow rates for wells 9 ,

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m 428/C.

15. Table 2.4.12/7, FSAR, lists at least three confined aquifer wells abandoned due -

to the proximity of construction, possibly underneath construction. Precisely locate all wells abandoned and correlate to all VEGP construction by precise

-location. - As at the Savannah River Plant, these wells may become a pathway for ,

contaminants to enter the confined aquifer (cf., L-Reactor EIS, discussion on well 53-A, p. F-99). Discuss.

16. Well data for well 42E is missing and was not discussed by VEGP in response to IQB-25 p. 37. Provide. VEGP stated well 428 water levels are at a higher head than well- 42A, and well 42C levels are lower than 420. Explain.

17.. In conjunction with all wells listed in Item 11 above, provide detailed

-description of each well's construction. Include su face elevation, depth, screening . interval, well history, screen type, last quarterly well water level, well status,' applicable closure-sealing techniques, date closed or abandoned, plus other pertinent data.

18. Describe well/ surface water monitoring techniques, e.g., sample collection, nuclides analyzed, sampling periods, and assay organization.

19. List all wells used to map the marl aquiclude under VEGP, Provide marl data from each. Describe test techniques and whether the marl material brought to tt.?

surface was through:corir.gs 'or cuttings. Discuss well 42E. Discuss uncertainty ranges.

20. ' How cany wells mapped the confined aquifer underlying the VEGP (the FSAR lists only MU-1 and 2). DisctM the uncertainty in the VEGP analysis of the confined aquifer mapping.

21. Provide the data that etermined the marl was absent under the Savannah River and its flood plain'(cf. Item 36 below).

22. Explain the piezometric surface differences between the data provided in the FSAR (Figure 2.'4.12-6)-and that -in Siple's report (p. 2.4.12-27; cf. L-Reactor EIS, 10

.m.

p. F-22) .and that in the L-Reactor EIS (e.g. , p. F-22, 23, 24, etc. ). Provide a *

~c lear surface map of VEGP with confined aquifer piezometric contours (cf. Item 35 below).

23. The predicted contaminant travel time to fiathes Pond of 350 years is similar to

- the 200-year estimate made by the Savannah River Plant for tritium to travel ttfrough the groundwater from the SRP radwaste burial ground to an outcropping in Four Mile Creek on the SRP, a distance of about 1500 feet. The first outcrop at the SRP was found the twenty-fifth year of operation. (There is no basin in the SRP burial

. ground to increase flow rates.) What validation techniques were performed on the

'VEGP calculations of 350 years?

24. 'Re: VEGP Response g 108-2: Provide the laboratory permeability tests conducted.-on core samples from marl exploration holes; provide core sampling techniques, core sample depths, core sample locations and other pertinent data.

Provide field test correlations for the same core sample locations.

The VEGP power block excavation exposed an upper 25 feet of marl with a surface area.of about one million square feet exposed, approximately one-third of one

. percent of the VEGP areal site. Provide the uncertainty ranges in asserting that there'are no voids, dissolution cavities, systematic fractures, or joints (exclusive of _the multiple ~ penetrations through the marl by confined aquifer observation and production well). that would provide a path for movement of groundwater contamination through the marl. Provide 'the uncertainty ranges inclusive of marl well-penetration.

Discuss the consistGntly large water level differences in light of the lack of correlition between the active, confined aquifer observation well water levels. Why

' do the dehdhed aquifer water levels vary and what is the source of variability? '

25. Re: .VEGP Response-g 108-6: VEGP has made many_ technical statements and drawn numerous technical conclusions based on esoteric assumptions and recondite theories.

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O The technical conclusions cannot be assailed without validation from two perspectives, either by finding groundwater contamination in the VEGP aquifers in -

the' future or by showing that similar technical conclusions at other facilities have been contraverted. Groundwater contamination at the nearby Savannah River Plant and at Plant Hatch are relevant. Provide the Plant Hatch information requested in IQB-6 but expand it to include all US electric generating pos.er stations and all

.radionuclide and contaminants released at each site (cf. VEGP Response p. 92 where

.VEGP uses effluent data from other sites as part of VEGP's own technical statement).

26. Re: VEGP Response g IQB-7: What financial assurances exist that VEGP will be able to fund not only the post-operational environmental radiological and chemical

,. monitoring programs associated with deccanissioning the VEGP plant but also the cleanup of contaminated soil and groundwater at VEGP. Since the predominant well pattern in the area surrounding VEGP fndicates primarily groundwater table well users (FSAR), what steps will VEGP take to financially and technically return the 3000 plus acre VEGP facility back to public domain free of radionuclide and hazardous waste contamination in water table aquifer?'

27. Re: VEGP Response g 1Q8-18 (c): The Savannah River Plant emissions of N0x, S0x, and TSP have been found to be within 20 to 80 percent of acceptable SRP boundary release limits measured at 30 to 40 kilometers from plant center southwest of the VEGP site. VEGP on the other hand is only fifteen km from SRP plant center, a likely location for SRP. airborne hazardous and radionuclide depositions. Also, strontium-90 released from SRP in concentrations already exceeding EPA drinking water standard have been fMd in milk at Waynesboro, Georgia, 45 km from the SRP

-plant centch V50P is bst W n Waynesboro and SRP. Therefore cumulative effects are relevant 4 Plets? ' resp 6nti io IQS-18 (c).

28. Locene water table aquifer dfvfdes on a clearly understandable VEGP surface map with noted boundary locations.

29. Re: VEGP response g 1Q3-27, p. 39: VEGP states that the marl is an aquiclude 12

and that the Cretaceous Aquifer is confined and isolated from VEGP releases. The

• Savannah River Plant made similar assurances in 1976 (C. H. Ice). What range of uncertainty exists with this VEGP claim 7 VEGP assumes a marl is nonexistent under the Savannah River and that contaminants migrating in the water table aquifer would not penetrate the Tuscaloosa Aquifer underlying the Savannah River because of higher head differentials between the Tuscaloosa and the Savannah River. SRP nas made similar assurances in the past but contamination has been found in Tuscaloosa wells.

What range of uncertainty exists with the VEGP claim that the Tuscaloosa will be open under the Savannah River alongside VEGP but that downward contamination flow will be prevented.

30. Re: VEGP Response M IQB-31, a 42: VEGP states that Cretaceous Aquifer water withdrawal will not affect the probability that a fluid spilled at the VEGP site would reach the groundwater. The Savannah River Plant has made similar assurances in the past and has found and reported this to be no longer true in their L-Reactor EIS. Defend the Applicants' position.

31. Re: VEGP Response g IQB-32: What validated VEGP assurance exists that the concrete basin and settlement pond will not become sources of groundwater contamination (cf. Item 26 above). ,

32. Re: VEGP Response g IQB-27: VEGP states that the VEGP site is located on an interfluvial high bounded by stream channels that have cut down to the marl. The FSAR surface topographs of VEGP are not clear but appear to indicate that VEGP is not bounded on all sides by stream channels and that channels cut inward into the site at numerous, various angles. Please explain the VEGP contention.

33. FSAR Figure 2.4.12-2 shows about 47 wells with about 24 wells abandoned. The data does not appear to agree with other tabulated, written N ta. In conjunction with Item 11 above, update this figure and include VEGP complete site boundaries with surface stream locations and surface stream sample locations on a clear 13

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. depiction (see FSAR figure 2.4.12-4 and Items 11 and 12 above).

34. Provide'a complete site listing of piezometers (see FSAR Figure 2.4.12-3) and -

the precautions taken to prevent piezometer contaminant entry into aquifers.

Include piezometer construction details by piezometer.

35. FSAR Figure 2.4.12-6 appears to indicate that only 7 observation wells mapped piezometric surface of the confined aquifer. Compare this data with the L-Reactor EIS pages F-22,23,24,'etc. and explain differences in the piezometric contours between the data sets. Provide piezometric confined aquifer contours on a map of the VEGP site outward a radius of at least ten kilometers. Figure 2.4.12-6 appears to indicate that 9 wells were used in the VEGP confined aquifer mapping. Explain the differences between the 2 VEGP mappings--the data presented does not lend itself to careful analysis (cf. Item 22).

36. VEGP has stated the marl depth is 130 feet below the surface. Confined aquifer well 34 does not support this contention. Which wells do and which do not? Why was well 34 located in the river flood plain? Hell 34 appears to be on the VEGP site (FSAR Figure 2.4.12-6) and appears to contradict the VEGP argument about the VEGP

, site located on an interfluvial high. Provide a detailed explanation of where the b

l ViGP interfluvial high is theoretically intact and where not intact and relate to the VEGP geography over the entire surface and to the marl underlying VEGP. Explain where marl . boundaries are located.

L

37. Re: VEGP Response p IQ-R-2: VEGP states predicted drif t deposition rates are E based on a range of drift rates predicted for five similar power plants. The

-Savannah River Plant uses 'nostly unvalidated predictions to estimate airborne k releasq concehtrations, ect:centrations found to be orders of magnitude low. What validatiofis have been performed on the VEGP drift rate deposition models? Provide detailed validations and compare to the deposition model predictions (cf. VEGP Response to IQ-R-7). Provide the mathematical calculations used in the VEGP models.

38. . Re: VEGP Response o_to IQ-R-9: The VEGP DES states that cooling tower airborne 14 W -

m releases will have moistura contaminant concentrations approximately equal to the .

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circulating water contaminant concentrations in DES Table 4-5. Since some of the table 4-5 characteristics appear to exceed to or closely approximate the EPA drinking water standards, provide deposition model predictions on all VEGP radioactive and chemical effluent characteristics and predicted groundwater .

contaminations (analogous to the SRP airborne tritium releases where SRP burial ground background groundwater concentrations thirty feet beneath the surface 2 km upwind the predominant wind approximately equal the airborne release concentration).

Validate these VEGP predictions.

39. In " Applicants' Response," p. 34, Applicants argue that 108-22 is irrelevant and outside the scope of this proceeding. By the nature of its response (that it has studied coliform and some chemical content of some wells), Applicant demonstrates the relevance of this request. Please provide the response to IQB-22.

- 40. To IQ H-1, H-2, H-3 and H-4, Applicants argue that the questions are irrelevant and outside the scope of this proceeding. To the extent that multiconductor configurations are affected in differant ways than single conductor configurations (subcontention 10.3), this is relevant and within the scope of this proceeding.

Please provide the response to IQ H-1, ll-2, H-3 and H-4.

41. To IQ H-5 Applicants argue that the question is irrelevant and outside the scope of this proceeding. To the extent that some synergism affects multiconductor configuration and solenoid valves, it is relevant and within the scope of this proceeding. Similar relevance holds for IQ I-1 and I-2. Provide responses to IQ H-5, I-1 and I-2.

42. Tc 'IQ L-1 Applicants argue .that the question is irrelevant and outside the ,

scope df this proceeding ocept for ASCO solenoid valves. In fact, the ASLB order does not limit this subcontention to ASCO solenoid valves, nor did the intervenors limit the subcontention to ASCO. The contention made by intervenors raises the 15

question of environmenta1' qualification of all solenoid valves, not just ASCO: the ASLB implicitly acknowledges this in its order's reference to " solenoid valves used .

at Yogtle," not "ASCO solenoid valves used at Vogtle." Please provide the response to IQ L-1. For the same reasons, please provide the response to IQ L-2, L-3, L-4, and M-1 which are follow-ups to L-1.

'43. To IQ N-4, Applicants argue that the question is irrelevant and outside the scope of this proceeding. In fact, operating experience of this type recombiner is fundamentally relevant since this type recombiner is to be used at Vogtle. Question N-5, a follow-up, is similarly relevant. Please provide the responses to IQ N-4 and N-5.

44. In response to IQ N-6, Applicants argue that the question is irrelevant and outside the scope of this proceeding. In fact, maintenance and surveillance during operations are crucial to assure that equipment is environmentally qualified, since operation of the facility could have an effect on the environmental qualification of the equipment. Surely, the Applicants plen some sort of maintenance and surveillance program; for this equipment; Intervenors merely ask what it is. Please provide the response to IQ N-6.

45. In response to IQ P-2. Applicants argue that the question is irrelevant and outside the scope of this proceeding. However, this is relevant to the extent that it applies to bubble collapse and vibration-induced fatigue cracking. Within these confines, please provide a response to IQ P-2.

46. In response to IQ P-3, Applicants argue that the question is irrelevant and outside the scope of this proceeding. In fact, the maintenance and surveillance program is relevant to the degree that it affects the possibility of vibration-induced fatigue cracking and bubble collapse. Within these confines, please provide the response to IQ P-3.

47. In response to IQ P-4, Applicants argue that the question is irrelevant and outside the scope of this proceeding. In fcct, procedures for emergency action in 16 L

7 steam' generator tube rupture are relevant since the Applicants have not demonstrated -

basis for confidence that such an accident will not occur (cf. ASLB order). IQ P-5,

'P-6, Q-1 and Q-2 are similarly relevant. Please provide responses to IQ P-4, 5 and 6 and Q-1 and 2.

48. In response to IQ R-9, Applicants argue that the question is irrelevant and

, outside the scope of this proceeding. This is directly relevant to the ASLB order in regard to groundwater and to cooling tower emissions. Please provide a response

.to IQ R-9.

49. In response to IQ R-4 and S-3, "Appilcants interpret [ chlorine to mean]

chlorine ' gas. " In fact, chlorine emissions in general are within the scope of the contention, and Intervenors request that Applicants provide this response for all chlorine.

50. In response to IQ S-4, Applicants state that Intervenors can get a computer printout or computer tape for $500 to $1000. Do the Applicants not use this data?

If the response is Yes, then why cannot Intervenors examine this at some time when it would not interfere with the Applicants' use of it? If the response is No, then

.why do the Applicants maintain the data?

~

Information Identified by the Applicants a_s_ Proprietary Please arrange for Intervenors to review the information identified in Applicants' Response as proprietary. Individuals representing Intervenors will keep any proprietary information confidential subject to the following stipulation: if Intervenors believe that any information should not be kept confidential, Intervenors shall have the right to' request the Atomic Safety & Licensing Board in this docket to review said information and determine the appropriateness of its pubi te reise u. Intervanors will release no information without the express order of the. Licensing Board or the consent of the company holding the information to be proprietary. Applicants should contact the undersigned to make appropriate l

17

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. .p -.

l s; arrangements.- .

7

-Respectfully submitted this, the seventh day of January, 1985.

~ WPA .

Tim Johnson

. Campaign for a Prosperous Georgia 175 Trinity Avenue, S.W.

Atlanta, Georgia 30303 404-659-5675 for Intervenors Campaign for a Prosperous Georgia

, and Georgians Against Nuclear Energy 1

6 18 2

w

m .

UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION ,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Inlthe Matter of )

)

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

) .

-(Vogtle Electric Generating Plant, )

Units l'and 2) )

CERTIFICATE OF SERVICE

~ This is to certify that copies of the foregoing " Third Set of Interrogatories and Requests to Produce" from Intervenors Campaign for a Prosperous Georgia and Georgians Against Nuclear Energy 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 Comission, the members of the Licensing Board and all others listed-below, this ninth day of January, 1985.

k++t N Tim Johnson Campaign for a Prosperous Georgia SERVICE LIST Morton B. Margulies, Chairman _ Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board Panel

U.S.' Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Oscar H. Paris Docketing and Service Section

-1 Atomic Safety 8 Licensing Board ' Office of the Secretary

.U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555

~ Mr. Gustave A.' Linentierger. Bernard M. Bordenick, esq.

Atomic 4 Safety 4 Licensing Board- Office of the Executive Legal

U.S. Nuclear Regulatory Commission Director

' Washington, D.C.

20555 U.S. Nuclear Regulatory Commission

Washington, D.C. 20555

. _ Atomic. Safety & Licensing Board Panel Ruble A. Thomas U.S. Nuclear Regulatory Commission Southern Company Services, Inc.

Washington, D.C. 20555 P. O.-Box 2625 Birmingham, Alabama 35202

' James E. Joiner

, lSumner C. Rosenberg - -

Troutman, Sanders, Lockerman & Ashmore 127 Peadttree Street, N.E. .

Atlanta; Georgia 30303 J