ML20056C892

Georgia Power Co Response to Intervenors Second Set of Interrogatories & Request for Documents.* W/Certificate of Svc.Related Correspondence

ML20056C892
Person / Time
Site:	Vogtle
Issue date:	07/16/1993
From:	Lamberski J GEORGIA POWER CO., TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA
To:	Mosbaugh A AFFILIATION NOT ASSIGNED
References
CON-#393-14129 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9307260094
Download: ML20056C892 (25)

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' guTEo CORRESPONDENCE t ,rtite UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '93 JUL 19 P4 :13 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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. A lp s, " V !f.i In the Matter of

• GEORGIA POWER COMPANY,

• Docket Nos. 50-4 2 4 -OLA-3 gt al.

• 50-425-OLA-3 (Vogtle Electric

• Re: License Amendment Generating Plant, *

(Transfer to Southern Units 1 and 2)

• Nuclear)

• ASLBP No. 93-671-01-OLA-3 GEORGIA POWER COMPANY'S RESPONSE TO INTERVENOR'S SECOND SET OF INTERROGATORIES AND REQUEST FOR DOCUMENTS I. INTRODUCTION.

Georgia Power Company ("GPC") hereby responds to ,

Allen L. Mosbaugh's Second Set of Interrogatories and Request for Documents to Georgia Power Company, dated June 27, 1993.

GPC objects to many of Intervenor's second set of interrogatories and document requests as overbroad because they seek information not relevant to the Factual Bases, as hereinafter defined. In addition, Intervenor has served this second round of discovery requests before he-has reviewed a single document made available by GPC in response l

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e to Intervenor's first set of discovery requests. Had he reviewed GPC's documents, Intervenor would have located virtually all of the information which he seeks in his second set of document requests. Finally, GPC objects to Intervenor's second set of discovery requests to the extent that they seek information subject to the attorney-client communication privilege or the attorney work product doctrine.

II. GENERAL OBJECTIONS.1/

Many of Intervenor's interrogatories (e.g., nos. 20 through 40) request information as to matters which Intervenor has not specifically pleaded in his Petition or Amended Petition. It appears to be Intervenor's position that any matter concerning GPC or Southern Nuclear, regardless of whether Intervenor has previously raised the particular subject matter in his prior pleadings, is. fair game for discovery inquiries. For example, Intervenor's second set of discovery requests seek information with respect to matters that Intervenor raised in his 1990 2.206 petition, including diesel generator air quality (interrogatories 20-23), FAVA filter (interrcyatories 24-1/ For the definitions of terms used herein, see Georgia Power Company's Response to Allen L. Mosbaugh's First Set of Interrogatories, dated June 2, 1993,Section II.

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31), safeguards (interrogatories 31-36)-and dilution valves j (interrogatories 37-39). Intervenor elsewhere requests ]

information which concerns only Plant Farley (interrogatory 40). None of these matters have been specifically pleaded. -)

by Intervenor in this proceeding.

It is GPC's position, which it has previously stated,1/ j that matters not specifically pleaded are outside of the scope of this proceeding. Therefore, GPC's responses to Intervenor's second set of interrogatories and requests for documents are limited to addressing those factual bases pleaded with reasonable specificity in the Petition and Amended Petition: that is, Intervenor's allegations that (1) during 1988-90 GPC illegally transferred the operating licenses for Plant Vogtle, and (2) GPC officials conspired to and knowingly submitted material false statements to the l

NRC with respect to the number of diesel starts reported in GPC's LER 1-90-06, dated April 19, 1990 (collectively referred to herein as the " Factual Bases"). Because each of Intervenor's request nos. 20 through 40 seek only I/ Egg Georgia Power Company's Response to Allen L.

Mosbaugh's First Set of Interrogatories, dated June 2, 1993, at 3 and Georgia Power Company's Response to Intervenor's First Request for Production of Documents, dated June 2, 1993, at 2-3 ,

(hereinafter collectively referred to as "GPC's June 2, 1993 l Responses").

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information beyond the Factual Bases, no response to those interrogatories is provided herein.

In addition, GPC objects to Intervenor's requests to

" produce any and all documents relating to" the subject of Intervenor's interrogatories. Given the nature of Intervenor's allegations, an investigation of such documents.

within the custody or control of GPC would be oppressive and unduly burdensome. Moreover, Intervenor's latest document requests were formulated before Intervenor took the time to review the documents which GPC made available to Intervenor on June 2, 1993. Such prior production includes all documents, not privileged, which GPC identified after a reasonable inquiry, within its possession, custody or control and which may be relevant to the Factual Bases. The only additional documents which GPC has received since June 2, 1993 are those documents produced by the NRC Staff and by Intervenor pursuant to GPC's discovery requests.

The NRC Staff Response to Georgia Power Company's First Request for Production of Documents by the NRC Staff, dated  ;

June 18, 1993, stated, at p. 3, that the NRC was making )

available to Intervenor the same documents that the Staff made available to GPC. Therefore, GPC is not producing  ;

those same documents to Intervenor.

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Furthermore, as stated in GPC's June 2, 1993 Responses, GPC generally objects to the identification, or disclosure, of those documents which are subject to the attorney work product doctrine or the attorney-client communication privilege. GPC has been defending actions initiated by Intervenor since mid-1990. In addition to this proceeding, such actions include (1) NRC inspections and an NRC Office of Investigations ("OI") investigation of those allegations lodged by Intervenor in his 1990 2.206 petition related to the Factual Bases, (2) three separate actions before the Department of Labor, (3) an investigation by the Department of Justice, and (4) two inquiries by separate Congressional Subcommittees. GPC's legal counsel has been heavily involved in GPC's defense of these actions and, as a result, has generated a large number of documents in preparation of such defenses. It would be oppressive and unduly burdensome and expensive for GPC to identify each and every one of such documents which are subject to either or both of (1) the attorney work product doctrine (i.e., they were prepared by legal counsel in anticipation of litigation and their disclosure would reveal the mental impressions of legal counsel), or (2) the attorney-client communication privilege (i.e., communications from GPC to its legal counsel made in l

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confidence for the purpose of obtaining legal advice and l

counsel).

GPC also objects to Intervenor's definition of "NRC,"

"you," and "your." Apparently, Intervenor inadvertently included this definition when it intended instead to include a definition of "GPC," "you" and "your." Although there is no definition for GPC, GPC has interpreted "GPC," "you" and "your" in the same manner as stated in GPC's June 2, 1993 Responses. That is, GPC has endeavored to respond to Intervenor's interrogatories and document requests by making a reasonable inquiry of those individuals who GPC believes have material information related to the Factual Bases.

Finally, the addresses and telephone numbers of the individuals named herein are not provided in the cases of current employees of any of the companies within The Southern Company system. Intervenor is requested to contact GPC counsel if he or his counsel wishes to contact any such employees relative to any matter connected with this proceeding.

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III. GPC RESPONSES TO SPECIFIC INTERROGATORIES.II

1. Information responsive to this request was provided to Intervenor in GPC's June 2, 1993 Responses, interrogatory response no. 10, and in Georgia Power Company's First Supplemental Response to Allen L. Mosbaugh's First Set of Interrogatories, dated July 13, 1993 ("GPC's Supplemental Response") , response no. 15. In addition, NRC OI has interviewed current and former GPC employees, identified in-response no. 4 herein, in June and July of 1993. OI has not yet released the transcripts of those interviews. This response does not include communications between Mr.

Mosbaugh and the NRC.

2. Information responsive to this request was provided to Intervenor in GPC's June 2, 1993 Responses, interrogatory response nos. 10 and 15, and in GPC's Supplemental Response, response no. 15. In addition, NRC's Office of Investigations has interviewed current and former GPC employees, identified in response no. 4 herein, in June and July of 1993. OI has not yet released the transcripts of Il GPC's responses are numbered to correspond to the numbers of the requests in Intervenor's Second Set of Interrogatories and Request for Documents to Georgia Power Company, dated June 27, {

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those interviews. This response does not include communications between Mr. Mosbaugh and the NRC.

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3. GPC objects to this interrogatory as overbroad, unduly burdensome and not susceptible to response. GPC is not able to say what is the knowledge of NRC employees. Nor can GPC reasonably determine what the knowledge is of each GPC and ,

Southern Nuclear employee.

Without waiving these objections, GPC states that information responsive to this request was provided to Intervenor in GPC's June 2, 1993 Responses, interrogatory response nos. 10 and 15 and in GPC's Supplemental Response, response no. 15. In addition, OI has interviewed current and former GPC employees, identified in response no. 4 f herein, in June and July of 1993. OI has not yet released the transcripts of those interviews. This response does not include the knowledge, involvement or communications of Mr.

Mosbaugh.

4. On August 14, 1990, the NRC's Operational Safety Inspection team interviewed Jimmy Paul Cash and George Bockhold, Jr. The transcripts of those interviews were made l 1

available to Intervenor on June 2, 1993. j l

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1 In June and July of 1993, the NRC OI interviewed Jimmy Paul Cash, George Bockhold, Jr., Kenneth Burr, John G.

Aufdenkampe, Norman Jackson Stringfellow, William B.

Shipman, James A. Bailey, C. Kenneth McCoy, W. George Hairston, III, George Frederick, Harry Majors, Thomas V.

Greene and R. Patrick Mcdonald. OI has not yet released the ,

transcripts of those interviews. >

5. (Bockhold) Jimmy Paul Cash provided Mr. Bockhold with the numbers of successful starts which were used in the April 9, 1990 presentation.

a. Mr. Cash determined successful starts by reviewing the Unit 1 Control Log and Shift Supervisor Log.

It is GPC's position that the count was in error because it included too many 1B diesel starts as successful. .

b. George Bockhold was responsible for including the numbers of successful starts in the April 9, 1990 i presentation. The information was typed onto the presentation transparency entitled " Diesel resting" at Mr. Bockhold's direction.

c. On December 18, 1992, counsel for GPC provided the U.S. Attorney's Office in Atlanta with written information concerning, inter alia, the April 9,

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1990 presentation. A copy of that information was  ;

made available to Intervenor by GPC on June 2,

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1993. This information was prepared by legal i

counsel.and was not reviewed by any GPC or Southern Nuclear employee before it was submitted. ,

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c. iv. GPC objects to this request to the extent it i

seeks documents which are subject to.the l attorney-client communications privilege or  ;

i the attorney work product doctrine. This request also seeks a document provided to GPC from DOJ which GPC objects to disclocing for the reasons stated in GPC's Response to Allen .

Mosbaugh's First Set of Interrogatories, l dated June 2, 1993,Section III.10, subsection d. Without waiving these objections, documents responsive to this request were made available to Intervenor by GPC on June 2, 1993. '

6. (Hairston/McCoy/Bockhold) a. GPC. believes those.who were identified in the NRC's May 14, 1990 letter to GPC participated in the April 9, 1990 meeting.

GPC also believes IIT members Mr. Rick Kendall and

Mr. Harvey Wykoff, who were not identified in the F letter, participated by teleconference,

b. GPC has not identified any recollections of specific comments made during the April 9, 1990 presentation other than those identified in the relevant documentation.

c. Documents responsive to this request were made available to Intervenor by GPC on June 2, 1993.

7. (Bockhold) Information responsive to this request was provided to Intervenor in GPC's Supplemental Response, response no. 15. In addition, GPC states that paragraph g.

on page 3 of the April 9, 1990 letter was not fully accurate because it included too many 1B diesel starts as successful.

8. (Hairston/McCoy/ Shipman /Stringfellow/Bockhold/

Aufdenkampe) On April 19, 1990, concerns were expressed i

regarding the diesel starts information contained in the draft LER. Once that LER language was revised, no one, other than perhaps Mr. Mosbaugh, knew or suspected that the final LER language quoted below was inaccurate:

Subsequent to this test program, DG1A and DG1B have been started at least 18 times each and no failures or problems have occurred during any of these starts.

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I On information and belief, Mr. Mosbaugh was present, and did not object, when his subordinate, Mr. Aufdenkampe, conveyed ,

i the site's concurrence with the quoted language to the corporate office. ,

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9. (Stringfellow) Mr. Mcdonald did review a draft of LER  !90-006 before it was signed.by George Hairston.

a. Jack Stringfellow probably provided Mr. Mcdonald with a copy of the draft LER. GPC believes Mr. Mcdonald received the draft LER on April 19, 1990.

10. (Stringfellow) Mr. Mcdonald did review a draft of LER 90-006 and provided comments to someone, probably Jack Stringfellow, before the LER was signed by George Hairston.

GPC believes Mr. Mcdonald's role was limited to a review of a draft of the LER and providing someone with his comments.

11. (Stringfellow) GPC objects to this interrogatory as not relevant to the Factual Bases. Without waiving this objection, GPC states the reliability of the Plant Vogtle diesel generators was established initially in accordance with the recommendations of Regulatory Guide 1.108, .

" Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants," Revision 1, August 1977. Since then, reliability has been maintained by compliance with the surveillance requirements of the VEGP' Technical Specifications, which are based on the recommendations of Regulatory Guide 1.9, Revision 2,

" Selection of Diesel Generator Set Capacity for Standby Power Supplies," December 1979; Regulatory Guide.l.108; Regulatory Guide 1.137, " Fuel-Oil Systems for Standby Diesel Generators," Revision 1, October 1979; Appendix A to Generic Letter 84-15; and Generic Letter 83-26, " Clarification of Surveillance Requirements for Diesel Fuel Impurity Level Tests."

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12. (Hairston/Bockhold) GPC interprets the term " valid  ;

tests" used in this in'terrogatory as defined in accordance with Regulatory Guide 1.108. The April 9, 1990 presentation and the April 9, 1990 CAL response were Dot, and were not intended to be, based on " valid tests," as that term is-defined in Regulatory Guide 1.108.

13. (Hairston/Bockhold) It was GPC's own understanding and-intent that the NRC understand the statements concerning I successful starts of the diesel generators, included in the -)

April 9, 1990 presentation materials, the April 9, 1990

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i letter and the April 19, 1990 LER, referred to consecutive successful starts. l i

14. (McCoy/Bockhold) GPC does not know the identity of' each individual who may have questioned the reliability of the diesel generators after the March 20, 1990 site area ~ -

emergency. However, GPC is aware that, during an April 4, 1990 telephone conference call among GPC and the NRC's IIT and Ken Brockman, Mr. McCoy informed the NRC that "the datal 1

we have here indicates that there's something wrong with the. ,

reliability of these (Calcon) switches...." l 3

15. (Stringfellow) Regulatory Guide 1.106 does not' address l I

diesel generators. GPC assumes that the language

"'requalify' the diesel generators per Regulatory Guide 1 1.106" in this interrogatory refers to the preoperational j

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testing prescribed by Regulatory Guide 1.108, Regulatory- 4 i

Position C.2.a.(9). GPC contends that it was not' required to "requalify" the diesels ' af ter the March 20, 1990. site }

area emergency pursuant to Regulatory Position C.2.a.(9).

t because that regulatory position is applicable-during the. l

-preoperational test program only. _

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16. (Bockhold) GPC does not understand what is meant by the language "re-establish to the NRC that the diesel generators had a 95% reliability goal" in this interrogatory. However, GPC is not aware of any.NRC requirement that GPC establish 95% reliability for the diesel generators before GPC could be permitted'to resume power operations of Plant Vogtle Unit 1 following the March 20, 1990 site area emergency.

17. (Stringfellow) NRC regulations did not specify a number of required consecutive successful starts before GPC could be granted permission by the NRC to restart Plant Vogtle Unit 1 following the March 20, 1990 site area emergency. As to the need to " reestablish the necessary reliability," see response no. 15, suora. l

18. (Stokes) GPC does not understand this interrogatory.

i However, GPC states that the number of " valid tests," as that term is defined by Regulatory Guide 1.108, of each of the Plant Vogtle Unit 1 diesel generators which occurred between March 20, 1990 and April 9, 1990, inclusive, was 6 for diesel 1A and 2 for diesel 1B.

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19. GPC objects to this interrogatory as not relevant to-the Factual Bases.

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20 through 40. Egg Section II, " General objections," supra.

't Dated: July 16, 1993. l hn Lamberski s -

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, TROUTMAN SANDERS. '!

Suite 5200-

• 600 Peachtree Street, N.E.  !

Atlanta, GA 30308-2216 (404) 885-3360-  ;

i Ernest L. Blake, Jr., Esq.  :;;

David R. Lewis, Esq._ .,

a SHAW, PITTMAN, POTTS &  !

TROWBRIDGE 2300 N Street,-NW-  ;

Washington, DC 20037 l (202) 663-8084 f i

i Counsel for Georgia Power Company ..

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,tir C UNITED STATES OF AMERICA .g3 y( 19 P 4 'A 4 NUCLEAR REGULATORY COMMISSION -

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PL ,,stu BEFORE THE ATOMIC SAFETY AND LICENSING BOARD LE ;n In the Matter of

• GEORGIA POWER COMPANY,

• Docket Nos. 50-424-OLA-3 gt al.

• 50-425-OLA-3 (Vogtle Electric

• Re: License Amendment Generating Plant, * (Transfer to Southern Units 1 and 2)

• Nuclear)

• ASLBP No. 93-671-01-OLA-3 CERTIFICATE OF SERVICE This is to certify that copies of the within and fore-going " Georgia Power Company's Response to Intervenor's Second Set of Interrogatories and Request for Documents" and the affidavits appended thereto were served on all those listed on the attached service list by depositing same with an express overnight delivery service.

This is the 16th day of July, 1993.

Af n L'amberski' TROUTMAN SANDERS.

Suite 5200 600 Peachtree Street, N.E.

Atlanta, GA 30308-2216 (404) 885-3360

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- l UNITED STATES OF AMERICA ,

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of * ,

GEORGIA POWER COMPANY,

• Docket Nos. 50-424-OLA-3 gi gl.

• 50-425-OLA-3 (Vogtle Electric

• Re: License Amendment '

Generating Plant, * (Transfer to Southern Units 1 and 2)

• Nuclear)

• ASLBP No. 93-671-01-OLA-3 SERVICE LIST Administrative Judge Stewart D. Ebneter Peter B. Block, Chairman Regional Administrator Atomic Safety and Licensing USNRC, Region II Board 101 Marietta Street, NW U.S. Nuclear Regulatory Suite 2900 Commission Atlanta, Georgia 30303 Washington, D.C. 20555 Office of the Secretary Administrative Judge U.S. Nuclear Regulatory James H. Carpenter Commission Atomic Safety and Licensing Washington, D .' C. 20555 Board ATTN: Docketing and Services U.S. Nuclear Regulatory Branch Commission ,

Washington, D.C. 20555 Charles Barth, Esq.

Office of General Counsel  ;

H Administrative Judge One White Flint North Thomas D. Murphy Stop 15B18 .

Atomic Safety and Licensing U.S.. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory Washington, D. C. 20555 Commission Washington, D.C. 20555 Director, Environmental Protection Michael D. Kohn, Esq. Division Kohn, Kohn & Colapinto, P.C. Department of Natural 517 Florida Avenue, N.W. Resources Washington, D.C. 20001 205 Butler Street, S.E.

Suite 1252 Office of Commission Appellate Atlanta, Georgia 30334 Adjudication j One White Flint North 1 11555 Rockville Pike i Rockville, MD 20852 ATTENTION: Docketing-and j Service Branch I 1

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i

BEFORE THE ATOMIC 8AFETY AND LICENSING BOARD j l

l In the Matter of  :

Docket No. 50-424-OLA-3 1 GEORGIA POWER COMPANY, et al.  : 50-425-OLA-3

Re: License Amendment I

(Vogtle Electric Generating Plant, : (Transfer to Units 1 and 2)  : Southern Nuclear) I

ASLBP NO. 93-671-01-OLA-3 j l

AFFIDAVIT OF W. GEORGE HAIRSTON, III l I, W. George Hairston, III, being duly sworn, state as I

follows:  !

1. I am employed by Georgia Power Company as the Executive l l

Vice President - Nuclear Operations. 'l I

2. I am duly authorized to verify Georgia Power Company's i Response to Intervenor's Second Set of Interrogatories and I l

Request for Documents; specifically, those responses to which my j name has been appended.

I hereby certify that the statements and opinions in such responses are true and correct to the best of my personal l knowledge and belief. l l

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W. Georg'e Hairston, III l i

I Sworn to and subsc ibed before me this / day of July, 1993.

% f lu de w Notary public My coy,ispion expires: i

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UNITED STATES OF AWMRICA NUCLEAR REGDLATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of  : >

' Docket No. 50-424-OLA-3 GEORGIA POWER COMPANY, et al.  : 50-425-OLA-3

Re: License Amendment (Vogtle Electric Generating Plant, I (Transfer to-Southern Nuclear)

Units 1 and 2)  :

ASLBP NO. 93-671-01-OLA-3 AFFIDAVIT OF C. KENNETH McCOY I, C. Kenneth McCoy, being duly sworn, state as follows:

1. I am employed by Georgia Power Company-as the Vice President - Vogtle Project.

2. I am duly authorized to verify Georgia Power Company's Response to Intervenor's Second Set of Interrogatories and Request for Documents; specifically, those responses to which my.

name has been appended.

I hereby certify that the statements and opinions in such responses are true and correct to the best of my personal knowledge and belief.

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C'.' Kehneth McCoy p/

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Sworn to and subscribed '/

before me this /S[9 day of ,/ j July, 1993.

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Notary Pbblic I commission expires:

My23 002iE50!!LF2fSMan agb . f ,

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l UNITED STATES OF AMERICA i NUCLEAR REGULATORY COMMISSION ]

1 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l 1

l In the Matter of  ;

Docket No. 50-424-OLA-3 GEORGIA POWER COMPANY, at al.  : 50-425-OLA-3 l

'Re License Amendment l (Vogtle Electric Generating Plant, : (Transfer to  !

Units 1 and 2)  : Southern Nuclear) i

ASLBP NO.- 93-671-01-OLA-3' AFFIDAVIT OF GEORGE BOCKHOLD, JR. 1 I, George Bockhold, Jr., being. duly' sworn, state as follows:

1. I am employed by Southern Nuclear Operating Company,

.i Inc. as the General Manager - Nuclear Technical Services.

2. I am duly authorized to verify Georgia Power Company's Response to Intervenor's Second Set of Interrogatories and Request for Documents; specifically, those responses to which my f name has been appended. .

I hereby certify that the statements and opinions in such responses are true and correct'to the best of my personal knowledge and belief.

Ad George Bockhold, Jr.

Sworn to and subycribed- i before me thisl_D N ay of l July, 1993.

Y Gilki Y . '

Notary Pdblic / ,

My commission expires: ,

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD In the Matter of .

. Docket No. 50-424-OLA-3 GEORGIA POWER COMPANY, .it. A l. . 50-425-OLA-3

. Re: License Amendment ,

(Vogtle Electric Generating Plant, . (Transfer to Units 1 and 2) . Southern Nuclear)

. ASLBP NO. 93-671-01-OLA-3 AFFIDAVIT OF WILLIAM B. SHIPMAN I, William B. Shipman, being duly sworn, states as follows:

1. I am employed by Georgia Power Company as the General Manager, Nuclear Support, Vogtle Project.

2. I arii duly authorized to verify Georgia Power Company's Response to Intervenor's Second Set of Interrogatories and Request for Documents; specifically, those responses to which my name has been appended.

I hereby certify that the statements and opinions in such responses are true and correct to the best of my personal knowledge and belief.

// LG WILLIAM B.(SjIIPMAN Sworn to and sub hd before me this (Ia'y of July, 1993.

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b Notary Pubdc My commission expires:

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC, SAFETY AND LICENSING BOARD

.s In the Matter of  : .

Docket No. 50-424-OLA-3 GEORGIA POWER COMPANY, 31 al.  : 50-425-OLA-3 ,

Re: License Amendment (Vogtle Electric Generating Plant, (Authorisation'for Units 1 and 2)  : Southern Nuclear) r

ASLBP NO. 96-671-OLA-3 i

AFFIDAVIT OF N. JACKSON STRINGFELLOW I, N. Jackson Stringfellow, being duly sworn, state as P

follows:

1. I an employed by Southern Nuclear Operating Company, Inc. as a project licensing engineer in the Vogtle Project.

2. I am duly authorized to verify Georgia Power Company's Response to Intervenor's Second Set of Interrogatories and Request for Documents; specifically, those responses to which my i

name has been appended.

I hereby certify that the statements and opinions in such Responses are true and correct to the best of my personal knowledge and belief. j A

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Sworn to and subscribed before me this /_ Day of July, 1993. J O)VA -

N6taYy Pbblic 8 My commission expires:

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UNITED STATES OF AMERICA 1 MUCLEAR REGULATORY COMMISSION l 1

BEFORE THE aTO_ MIC SnF."_TY AND LICEMBING BOARD j In the Matter of s

Docket No. 50-434-OLA-3 GEORGIA POWER COMPANY, el 11 I 50-425-OLA  : Re: License Amendment (Vogtle Electric Generating Plant, I (Transfer to Units 1 and 2)  : Southern Nuclear) '

s A8LBP WO. 93-571-01-OLA-3 i

AFFIDAVIT OF JOHN G. AUFDENKAMPE- r I, John G. AufdenXanpa, being duly sworn, state as follows:

1. I am empicyed by Southern Cor.pany Services, Inc., in Birmingham, Alabama.

2. I am duly authorized to verify Georgia' Power Company's Response to Intervenor's Second Set of Interrogatories and  ;

Request for Documents; specifically, those responses to which my ,

name has been appended.

I hereby certify that the statenants and opinions in such- ,

responses are true and correct to the best of my personal

/(hinodikdge and belief.  ;

g,. .. " vg., .

, j Q.f v av, g :-

ohn G. Aufder8;ampe f-

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's:%zEbrere me this !L subp/'2Iay of Sworgto and -j July, 1993. ,

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i Notary Public 8 TtSSMUNNWMQS j

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F ~ .. , J.L-;2-;993 15:3E FDCt' D.G 5:JPFCD'b>O3~LE) TO -914043853900 F,02 SEhT BY:FLOCR 49 '111-47-:) i 10:30 i TROJTMAN, SN CER P 700 828 3681is 2 UNITED ST&Tas OF A483RICA NUCLIER RESOLnTORY 00308188203 mapamm enn meearve asumer man un===rtsa natum In the Matter of a ananara powsR cournwy, at al. Docket Ms. 50-454=OL&-8 so-4as-osa-s .

I Re: Limasse ammeAnggg~

(vegtle slestris Generating Plant, I (Transfer te-Units a mae a) , a southern uno3 ear)

AsLas so, ss-s71-01-ot n-s 1FyrnavfT Of TEtrtfBTR S, gTMTRA I, Kenneth c. Stokes, being duly sworn, state as follows:

1. I an amployed by Georgia Power Company as a senior Plant Engineer at Plant Vogtle. '-

2. I as duly authorised to verify Georgia Power Company's Response to Intervanor's Second Set o' Interrogatories and Raquest for Documents; specificall.y, those responses to which my name has haan appended.

I hergby certify that the statsmants and opinions in such ,

responses are true and correct to the best cf my personal ,

knowledge and belief.

h c JirA-Kenneth C. Stokas

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',,Sw ho.t0.and subscribed ,

.- -Mfor't .Mihis & day of .

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'.I . D EY TUDli' R[h'o~$miission expires:

s-yr w e.s c o us w ur -

- W Deneman Eaghe Ocabar R 101s

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TOTFL P.02

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