ML20071M252
| ML20071M252 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/22/1994 |
| From: | Lamberski J GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE, TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#394-15460 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9408040123 | |
| Download: ML20071M252 (29) | |
Text
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' g 7 3 COF.UES M DOCKETED ly 22,1994 UNITED STATES OF AMEP.!CA
'94 Jll 25 All :45 NUCLEAR REUULATORY COMMISSIOMFFICE OF SECRETARY 00CKETiHG & SERVICE Before the Atomic Safety and Licensing Board BRANCH
)
In the Matter of
)
Docket Nos. 50-424-OLA 3
)
50-425-OLA-3 GEORGIA POWER COMPANY, )
etal.
)
Re: License Amendment
)
(Transfer to Southern (Vogtle Electric Generating
)
Nuclear)
Plant, Units 1 and 2)
)
)
ASLBP No. 93-671-01-OLA-3 GEORGIA POWER COMPANY'S RESPONSES TO INTERVENOR'S FIFTH INTERROGATORY AND DOCUMENT REOUEST I.
INTRODUCTION Georgia Power Company ("GPC") hereby responds to Intervenor's Fifth Interrogatory and Document Request to Georgia Power, dated July 8,1994 (the "Fifth Request"). This response addresses Interrogatory Nos. 1, 2, 6-9,11,12,15, and 16. GPC's response to Document Request Nos. 3-5,10,13,15,17, and 18 will be provided by August 8,1994.
GPC notes that some responses to these interrogatories state an objection on the ground that Intervenor continues to seek infonnation whV N outside the scope of discovery established by the Board's Memorandum and Order (Scope of Discovery), dated June 2,1994.
II.
GENERAL OBJECTIONS A.
GPC objects to Instruction D of the Fifth Request (p. 3) which requires GPC to provide detailed information with respect to each document referred to in any of the 1
050[$f
}g()
Ph4
e interrogatory responses. Given that Intervenor is intimately familiar with most of these docurnents, GPC objects to providing detailed information about those documents on the j
grounds that it would be unduly burdensome and oppressive, r
B.
As a general matter, GPC objects to Intervenor's definition of " Licensee,"
" Georgia Power Company," "The Southern Company," and "SONOPCO," and consequently to interrogatories which request information known to "GPC" as defined by Intervenor.
Intervenor defines these terms as including every agent or employee of GPC, The Southern i
Company, and/or SONOPCO, past or present, their counsel and all their respective agents, t
servants, associates, employees, representatives, and private investigators, and others who are or have been in possession of or may have obtained information for or on behalf of any of those entities. As a result, Intervenor would have GPC conduct an investigation as to the knowledge of every employee, agent or representative of each of these companies and indi-viduals. Such an investigation of each of Intervenor's interrogatories would be unduly burdensome and oppressive. Without waiving this objection, 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 these requests.
C.
GPC generally objects to the identification, or disclosure, of those communications and documents which are subject to the attorney work product doctrine or the attorney-client ccmmunication privilege. GPC has been defending actions initiated by Intervenor since mid-1990. In addition to this proceeding, such actions include (1) NRC inspections, an NRC Office of Investigations ("Ol") investigation, and an NRC enforcement 2
acton respect'ng those allegations lodged by Intervenor ir. the Hobby /Mosbaugh Petition related to the diesel generator statements issue, (2) three separate actions before the Department of labor, (3) an investigation by the Department of Justice, and (4) an inquiry by a Congressional Subcommittee. GPC's legal counsel has been heavily involved in the 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 confidence for the purpose of obtaining legal advice and counsel).
III.
RESPONSFS TO INTERROGATORIFA
- 1. (Webb) GPC is not aware of the existence today of the diesel start list that was prepared by Mr. Webb on April 19, 1990.
- 2. (Aufdenkampe, Odom, Webb) Mr. Webb completed his task of listing diesel starts on April 19, 1990, and recalls providing the list to Mr. Odom. He recalls Mr. Odom stating that he had given the list to "the man down the hall." Mr. Webb understood this to mean that the list had been given to either Mr. Aufdenkampe or Mr. Mosbaugh. Mr. Webb does not recall ever copying the document. The documents used to prepare the list were the Vogtle Unit 1 Control Room logs (i.e., the Shift Supervisor's log and the Unit Control log).
GPC believes that the last person to have the list was Mr. Mosbaugh. No one currently 3
employed by GPC recalls seeing the diesel start list after it was provided to Mr. Mosbaugh on April 19, 1990.
- 6. (Kochery) GPC believes the NRC first discussed the possibility of quarantining components on March 23,1990. Sec NRC Confirmation of Action Letter, dated March 23, 1990.
- 7. (Kochery) Mr. Kochery recalls that someone may have told him that water was discovered in the 2" air start line, but does not recall who told him.
- 8. (Holmes) Mr. Holmes does not recall any individual informing him that there may be water in the diesel trip lines.
- 9. (Kochery) GPC interprets this interrogatory as seeking information concerning who from Cooper Industries provided on-site assistance to GPC following the March 20, 1990 event. Personnel who assisted GPC were Messrs. Sheldon Owyoung, Robert Johnston, and Donald Pesout.
r
- 11. (Dixon, Walker) No.
- 12. (Bailey, Sheibani) GPC objects to this interrogatory as being overbroad to the extent that it requests the identification of files or fHe listings related to matters that are i
outside the scope of this proceeding. Without waiving this objection, GPC notes that the i
individuals named in this interrogatory did not personally have computers in their workplace during the March 20,1990 to August 30,1990 time frame. Their secretaries created files on their behalf using Xerox Memorywriter typewriters. The relevant file list for Mr. Bockhold, and corresponding documents, have been previously produced. Mr. Bailey's file list includes two documents that may be related to the scope of this proceeding. A copy of these 4
i
documents is attached. Mr. Kitchen's file list includes four relevant documents, which are also attached. The file lists for Messrs. Hairston, McCoy and Stringfellow are either blank or include only documents regarding matters not related to this proceeding.
- 15. (Domby, Bailey) GPC interprets this interrogatory as requesting the identity of FOIA requests filed by GPC. GPC objects to this interrogatory to the extent it requests the identification of FOIA requests regarding the Site Area Emergency (other than matters related to diesel generators) as being outside the scope of this proceeding. A file search identified the following FOIA requests responsive to the unobjectionable portion of this interrogatory: FOIA-91-305, 306, 458, 459, 468, 515, 516;92-150,151, 330, 338;93-555.
- 16. (Warren) The individual whose name is listed as the supervisor or coordinator on the document identified in this interrogatory is Mr. Fred Warren, Mr. Warren was responsible for filling out the document.
5
i Respectfully submitted, W W />
o Johri Lamberiki '
TROUTMAN SANDERS Suite 5200 600 Peachtree Street, N.E.
Atlanta, GA 30308-2216 (404) 885-3360 Ernest L. Blake David R. Iewis SHAW, PITTMAN, POTFS & TROWBRIDGE 2300 N Street, N.W.
Washington, D.C. 20337 (202) 663-8084 Counsel for Georgia Power Company Dated:
July 22,1994
'l i
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INTERROGATORY NO.12 DOCUMENTS PRODUCED BY MR. JAMES A. BAILEY i
ELV-01469 0312 Docket No.
50-424 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D. C.
20555 Gentlemen:
V0GTLE ELECTRIC GENERATING PLANT WAIVER OF COMPLIANCE This letter is a follow-up written request for a waiver of compliance for Georgia Power Company's Vogtle Electric Generating Plant Unit 1.
A one-time Technical Specification waiver of compliance was requested to make Technical Specification 3.0.4 '.st applicable to Technical Specification 3.8.1.2.
This -
waiver was required to allow entry into Mode 5 with the operability of Diesel Generator IA and itssociated load sequenenverified.
The Plant Review Board has reviewed and approved this waiver.
This waiver was necessary because recent failures of the Unit 1, Train A Diesel Generator and its associated load sequencer rendered their operability questionable.
Even though an extensive investigation is being conducted, the specific cause of the failure of tnis equipment s not been identified.
The current Reactor Coolant System water level is at mid-loop.
This waiver allows tensioning of the Reactc Pressure Vessel head which also allows filling and venting of the Reactor Cool
,t System.
Filling and venting the RCS will result in an increase in RCS *,ater inventory and make the steam generators available for heat removal should they be required.
As additional compensatory action, on-shift operators have been briefed on the condition of the equipment and how to respond by manually initiating a Diesel Generator emergency start should it be required.
This is a one-time request due to present plant conditions and equipment status.
Since Technical Specification 3.8.1.2 action requirements are the same for Modes 5 and 6 the probability of occurrence and consequences of an accident are not increased by this request and no significant safety hazards are involved.
The additional inventory and addition of the steam generators as an available heat sink improves the margin of safety.
I i
U. S. Nuclear Regulatory Commission ELV-01469 Pace Two Since no change in plant design occurs as a result of this waiver of compliance and since the plant is being placed in an improved condition with respect to water inventory and available heat sinks, no adverse environmental effects are involved.
Sincerely, I
R. P. Mcdonald RPM /HWM/gm I
xc: Georaia Power Company Mr. C. K. McCoy Mr. G. Bockhold, Jr.
Mr. R. H. Odom Mr. P. D. Rushton NORMS U. S. Niiclear Reaulatory Commission Mr. S. D. Ebneter, Regional Administrator Mr. T. A. Reed, Licensing Project Manager, NRR j
Mr. R. F. Aiello, Senior Resident Inspector, Vogtle t
[
V0GTLE SITE EMERGENCY MARCH 20, 1990 PLANT CONDITIONS o
Unit I was in a refueling oJtage and Unit 2 was operating at 100%
power.
o Unit I was in mid-loop in operational Mode 6.
o The RCS level was being maintained at mid-loop for valve repairs and S/G manway restoration.
o The Unit 1 8 reserve auxiliary transformer (RAT) was tagged out of service for maintenance.
o The Unit 1 B emergency diesel generator (EDG) was tagged out of service and disassembled for maintenance.
o The Unit 1 A RAT was supplying offsite power to the crosstied Unit 1 A and B vital buses.
o The reactor coolant system (RCS) temperature was being maintained at around 90 degrees Fahrenheit (F) via the train A residual heat removal (RHR) pump, the train B pump was in standby, o
The vessel head was in place with the bolts not fully tensioned.
o The pressurizer manway cover was removed.
o The containment equipment hatch and the containment personnel hatch were open o
Non-vital power was provided via a backfeed thru the main generator transformer.
f
4 V0GTLE SITE EMERGENCY MARCH 20, 1990 EVENT o
At about 9:20 a.m. a truck backed into a support colnmn for the feeder line supplying power to the Unit IA RAT and the Unit 2B RAT.
o The insulator for the C phase of the feeder line fractured and initiated a phase-to-ground electrical fault.
o The fault resulted in a loss of power to the lA and 2B RATS.
o The 2B EDG started and loaded to the deenergized Unit 2 vital bus.
o Unit 2 tripped becaused of an improperly connected differential current transformer.
(Wrong tap setting) o Loss of IA RAT deenergized both Unit 1 vital buses.
(i.e., loss of power to RHR pump) o Unit lA EDG started on bus undervoltage and shut down after about one minute and 20 seconds.
o Declared site area emergency about 9:40.
o About 18 minutes after the first 1A EDG started, operators locally reset load sequencer and EDG started on UV.
o After about one minute and ten seconds EDG shut down again.
o At about 9:56 a.m. operators performed an " Emergency" manual start which bypassed most of the EDG protective trips.
o The EDG started and loaded the bus, a RHR pump was restarted and core cooling was re-established, o
Site Area Emergency downgraded to " Alert" at about 10:15 a.m.
o Reactor coolant system heated up to 136 degrees F from 90 degrees F before EDG was started.
o Emergency was terminated at 1:47 p.m.
i 1
1
l INTERROGATORY NO.12 DOCUMENTS PRODUCED BY MR. W.F. KITCHENS
Ju_-12-1f34 14:c4 3FCt1 ETETEch.5.PF04-TO hi-404-EEE-:900 F.c5 030 CURADIT EVEUS 900 MAY 74, 1990 PLANT V0ETLE UNIT 1 On May 23,1990 at 1228 hours0.0142 days <br />0.341 hours <br />0.00203 weeks <br />4.67254e-4 months <br /> (CST), the Unit I train 8 emergency diesel generator tripped during a surveillance test.
This surveillance test was performed following calibration of three jacket water temperature switches.
(The temperature switch calibration was a corrective action taken as a result of a previous diesel generator failure on March 23, 1990.) The IB diesel generator was declared inoperable following the engine trip, and actions taken per the technical specifications.
Troubleshooting following this trip failed to inmediately identify the root cause of the failure.
An event review team has been established to evaluate the problem.
and determine the root cause. Glen McCarley, ISEG Supervisor, is the event review team leader.
e i
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~
E 1 54 1:524 ;FFJ1 LOGT_E TECH, S_F O;-
TO 9-1-404-E8 NT P 26 D3\\
DG IB _ TROUBLESHOOTING PLAN 9
Vent JW temperature switches prior to each start.
tionttor P-3 operation for each start.
Snoop each JW temperature switch during start.
Monitor JW temperature during each run and record.
Any problems stop and have meeting.
1.
Perfom 3 local emergency starts with "old" swf tches installed 2.
Calibrate new P-3 to lower setpoint (in I & C Shop) 3.
Perform 1 (or more) nomal starts with existing P-3 4.
Install new P-3 with lower setpoint 5.
Perfom 3 nonnal starts with new P-3 6.
Perfom Operations surveillance 6
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t JI.A 1994. 14:06 TVJ1
.OGT E TEcs. SJ504*
TO 9-1-424-665-2900 F,12 UD SHIFT BRIEFING UNIT 1 DIESEL GENERATOR EMERGENCY TRIPS FOR HIGH JACKET WATER TDFulATifRTAFD L_0W LLTifE DIL PRES 5URE On an emergency start of the Diesel Generator (OG), only four engine trips remain active:
(A) Engine overspeed (8) 186A Relay, C) High Jacket Water Temperature (2 of 3), and (D) Low Lube Oil Pressure 2 of 3).
The High Jacket Water Temperature trip, once the engine has tripped en high water temperature, may be reset (bypassed) by pushing the " EMERGENCY STOP RESET" outton locally on the engine control panel. Once reset, th2 cngine will auto restart and the high jacket water temperature trip will no longer be active.
NOTE: 00 NOT push the Reset from LOCA button as this will re-enstate the trip resulting in another engine trip.
At this time, it is unknown whether the Low Lube Oil Pressure trip can be reset using this method.
The problem arises from the inplementation of the DCP that added the flow orifices in the lube oil lines to maintain pressure for 70-90 seconds after engine shutdown. Engineering is evaluating this situation and information will be passed along as soon as it becones available.
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.OGTJ TECw. 5590 ~
TO 9-1-404-&G5-20CC P.13 OD' \\
UNIT 1 A TRAIN DIESEL GENERATOR AIR RECEIVER DL1 POINT EASURDOTS lef0 NO.
DATE RECEIVER KO_1_
RECEIVER K02 19001651 4/8/90 34*F 33'F 19001513 3/31/90 80'F 60*F 19000899 3/12/90 48'F 45'F 3/9/90 61*F 66*F 19000465 2/11/90 37'F 37'F 18906445 1/18/90 44*F 44*F 18906199 12/19/89 40'r 37'F 18905007 11/20/89 40*F 47'F 18904442 10/20/89 38'F 45'F 18903652 9/27/89 45'F 45'F 18903214 8/24/89 37'F 35'F 18902798 7/30/89 45'F 49'F 18902453 6/28/89 48'F K02 was tagged out t'
for maintenance 18900984 3/16/89 22.6*F 20.1*F I
l
JUL-22-1994 09:24 :0 31 St.C-/XJLE EIG L C TO TSLA
- .02 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMKISSION BEFORE TEE ATOMIC BAFETY AMD LICENSING BOARD In the Matter of I
Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY, 31 A1 t
50-4254LA-3 Eat License Amendment (Vogtle Electric Generating Plant, 3 (Transfer to Units 1 and 2)
Southern Nuclear) a ASLBP NO. 93-671-OLA-3 AFFIDAVIT OF JoHM G.
AUFDEMEAMPE I, John G.
Aufdenkampe, being duly sworn, state as follows:
1.
I am currently employed by Southern company services as Design Team Leader, Vogtle Project.
2.
I am duly authorized to verify Georgia Power Company's.
Response to Intervenor's Fifth Interrogatory and Document Requent, specifically the response to Interrogatory No.
2.
I hereby certify that the statements and opinions in such response are true and correct to the best of my personal knowledge and belief.
u
/ John G. Aufdenkampe' Sworn to and subscq$ bed before me this f.0" day of July, 1994.
,n i,
$ IllUAn*b. Q 0 fw Notary public
/
My commission exp, ires:
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!J,-21-iM4 09:73 :: ~/1 St.C- /OTLE ENF_.C TO TS.LA
- .C2 UNITED STATE] OF AMERICA NUCLEAR REGULATORY COMMI5 BION BEFCRB THE ATOMIC _RAFyrY AND LICENSDIG BOARD In the Matter of Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY, 21 A1 50-425-OL&-3 Re License Amendment (Vogtle Electric Generating Plant, t (Transfer to Units 1 and 2)
Southern Nuclear) s ASLBP MO. 93-471-OLA-3 AFFIDAVIT.0F JAMES A.
BAILEY I, James A. Bailey, being duly sworn, state as follows:
1.
I am currently employed by Southern Nuclear Operating Company as Manager-Licensing, Vogtle Project.
2.
I am duly authorized to verify Georgia Power Company's,
Response to Intervenor's Fifth Interrogatory and Document Request, specifically the response to Interrogatory No. 12.
I hereby certify that the statements and opinions in such response are true and correct to the best of my personal knowledge and belief.
R 3
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.Dc &,
Jhmes A.
Bailey Sworntoandsubscrf bed before me this O day of July, 1994.
?! t,W k, l
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L y.
Notary Public My commission expires:
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N 1994 14:56 0F71
..OGT E TECH. 5 J* C;'~
T0 9-1-aca-E35-290c p,ca UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE 1TOMIC BAFETY AND LI,QJHgJNG BOARQ In the Matter of I
Docket Mos. 50-424-OLA-3 GEORGIA POWER COMPANY, gh 3.1 50-425-OLA-3 3
Re License Amendment (Vogtle Electric Generating Plant, 3 (Transfer to Units 1 and 2)
Southern Nuclear) 1 ASLBP No. 93-671-OLA-3
&EZIphyII OF ESTER R.
DIION I,
Ester R.
Dixon, being duly sworn, stato as follows:
1.
I am currently omployed by Georgia Power Company as Senior secretary, Vogtle Electric Conorating Plant.
2.
I am duly authorized to verify Georgia Power Company's Response to Intervenor's Fifth Interrogatory and Document Request, specifically th6 response to Interrogatory No. 11.
I hereby cortify that the statements and opinions in such response are true and correct to the bent of ny personal knowledge and belief.
&k Edf:or R. Dixon Sworn to and subscribed before me this A M day of July, 1994.
fNA/__ 0.b u Notary Publie' My com/ission expires:
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f-95 TCT4 ;1 i
t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of i
GEORGIA POWER COMPANY, Docket No. 50-424-OLA-3
_qi gl.
50-435-OLA-3 (Vogtle Electric Re:
License Amendment I
Generating Plant, (Transfer to Southern Units 1 and 2)
Nuclear)
ASLBP No. 93-671-01-OLA-3 AFFIDAVIT OF ARTHUR H.
DOMBY I,
Arthur H.
Domby, being duly sworn, state as follows:
i 1.
I am a partner in the law firm of Troutman Sanders, where.
I have practiced law since being admitted to the State Bar of Georgia in 1979.
I am also admitted to practice in the State of New York.
2.
I am duly authorized to verify Georgia Power Company's Response to Intervenor's Fifth Interrogatory and Document Request, specifically the response to Interrogatory No. 15.
I hereby certify that the statements and opinions in such responses are true and correct to the best of my personal knowledge and belief.
A hrthur H.
Domb/
Sworn to and subscribed before me this I/u day ofm7dly, 1994
/p A./
L Notary Public My/ commission expires:
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...,. o.u..a Wy hmMica EApnes February 18,1997
JUL-22-94 FE. 10:26 E 02 SEM BMWPG 50/0 i 7-31-04 ; 2:42;M T% dTMAN SANCERS*
7CS 628 30S850 2 i
tDTITED 87&T35 0F AMIAICA NUCLEAR REGULATORY COMMISSION mmrnum Tan ATourc nonTY Awn tremmarwe mohan Za the Matter of a
Doeket Mos. 30=424-OLA-3 SECRGIA DOWER COMPANY, 8 31 50=485=014=3 I
Re License Assadment (Vogtle Electric Generating Plant, 3
(Transfer to Units 1 and 2) southern Nuclear) r i
ASL37 NO. 93-671-OL1-3 ArrinavTe ey vewwaTr m. vervas I, Kenneth R. Holmes, being duly sworn, state as follows:
1.
I am ourrently employed by Georgia Power Company as Manager-operations, vogtle Electric Generating Pli.tt.
2.
I an duly authorized to verify Georgia Power Company's Responst to Int *Wenor's Fif th Interrogatory and Document Retr.nost, specifically the response to Interrogatory No. 8.
I hereby certify that the statements and opinions in such response are true and correct to the best of my personal knowledge and belief.
Au+tfl~
Ka'nneth R.~ Holmes'
!.sw6kiie'to.and subscribed befo 4 4[4)94. ) 1 day this 3.o f u19,,
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- X~yJ) iss}io expires
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IJL-II-1994 05:25 ;R r1 sta:->031 E EH3 L:C TO TSL4
- ,;5 UNITED CTATES OF AIGRICA NUCLSAR REGULATORY COMMISCIC~3 EEFORE THE ATOMIC SAFETY 1MD LICEMSING BOARD In the Matter of a
Docket Mos. 50-424-OLA-3 03ORGIA POWER COMP &MY, 31 31 t
50-425-OLA-3 3
Ret License Amendment (Vogtle Electric Generating Plant, I (Transfer to Units 1 and 2)
Southern Nuclear) 3 ASLBP No. 93-671-OLA-3 AFFIDAVIT OF PAUL M. 10CEERY I,
Paul M.
Kochery, being duly sworn, state as follows:
l 1.
I am currently employed by Georgia Power Company as l
Engineering Supervisor, Vogtle Electric Generating Plant.
2.
I an duly authorized to verify Georgia Power Company's*
Response to Intervenor's Fifth Interrogatory and Document Request, specifically the responses to Interrogatory Nos.
6, 7,
and 9.
I hereby certify that the statements and opinions in such response are true and correct to the best of my personal knowledge and belief.
b 7*Ch Paul M.
Kochery sworn to and subseg4 bed before me this JR day of July, 1994.
Y C%1 lv h1 str Notary Public
/
My commisgion expiras:
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JJ.-22-1994 0-: N
@Dr1 94-JOTLE EtG L:C TO TSLA D.M UNITED STATES CF AMERICA NUCLEAR RC2ULATORY COMMIOCION BEFQRR TBE ATONIC SAFETY AND LICEMBIMG BOARD i
In the Matter of Docket Nos. 50-424-OLA-3 GRORGIA POWER COMPANY, d 31 50-425-OLA-3 t
Re: License Amendment (Vogtle Blootric Generating Plant, :
(Transfer to Units 1 and 2)
Southern Nuclear)
ARLBP No. 93-671-OLA-3
&lFIDAVIT OF RICHARD K. CDOM I, Richard M. Odom, being duly sworn, state as follows:
1.
I am currently employed by Georgia Power company an Engineering Supervisor, Vogtle Electric Generating Plant.
2.
I am duly authorized to verify Georgia Power Company's Response to Intervenor's Fifth Interrogatory and Document Roquest, specifically the response to Interrogatory No.
2.
'I hereby certify that the statements and opinions in such response are true and correct to the best of my personal l
knowledge and belief.
S fu.
em Richard M'." Odom Sworn to and subgcr4 bed i
before me this 42 day of July, 1994.
' ~ N h s % ; k. 5 0.1 0 Notary Public My commission exp] ires:
-4%
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JL L 1 ?34 :4:55 ::Cr" LCG'LE TECH. ELIFTPT TO 9-1-404-E85-?906) c.C2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATQNIC SAFETY AND LICRMSING SOARD In the Matter of a
Docket Nos. 50-424-OLA-3 GEORGIA POWMR COMPANY, 31 m.1 50-425-OLA-3 Re License Amendment (Vogtle Electric Generating Plant, 8 (Transfer to Units 1 and 2)
Southern Nuclear) l a
ASLBP NO. 93-671-OLA-3 AFTIDAYJT OF Mustnf SERIBANI I, Mehdi Shelbani, being duly sworn, state as follows:
1.
I am currently employed by Georgia Power Company as Engineering Supervisor, Vogtle Electric Generating Plant.
2.
I am duly authorized to verify Georgia Power Company's Response to Intervenor's Fifth Interrogatory and Docunent Roquest, specifically the responno to Interrogatory No. 12.
I hereby certify that the statements and opinions in such responso are true and correct to the best of my personal knowledge and belief.
(I, f /
l Mdhd:E Sheibani Sworn to and subscribed before me this A444 day of July, 1994.
kl/L Y. 0L%fw Notary Public My commission expires:
f- & 9S~
J
Rt-22 'pa rPt ;a:21 ID:
TCL iC:
- Ii 3 rea SENT DY:WPC SUC
- 7-31-94 : 4:1tPM i IRQU WAN SANDER S 79: 620 3909:84 UNITED STAT 58 0F AMERICA NUCLEAR RB8ULATORY CCHMISSIoM BEFQRE TEE ATQEIO BAF57Y AMD LICIMSIMS_ AGARD In the Matter er i
Deaket Nos. Se=424-OLh-3 enoueza POWER cottPANY, 31 31 50-423=GLA-3 Res Lisense Amendment (Vogtle Electric Generating Plant, I (Trameter to Units & and 2) senthern Nuclear) 8 ASL37 WO. 93-671-OL&=3 AFFIhAYIT thF ALORIA L N1LEEE I
I, Gloria W. Walker, being duly sworn, state as follows:
1.
I am currently employed by Georgia Power company as senior scoretary, vogtle Electric Generating Plant.
~
j 2.
I am duly authorized to verify Georgia Power Company's Respones to Intervanor's Fifth Intarrogatory and Document l
Request, specifically the respones to Interrogatory No. 11.
I I hereby certify that the statemente and opinions in such response are true and correct to the best of my personal knowledge and belier.
s
/31eria W. Walker sworn to and subscribed before me this day of July, 1994.
Notary Public My commission expirest L
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UNITRD STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC BAFETY AND LICENSING BOARD In the Matter of s
Docket Mos. 50-424-OLA-3 j
GEORGIA POWER COMPANY,,s_t al.
1 50-425-OLA-3 Re Licenso Amendment (Vogtle Electric Generating Plant, :
(Transfer to Units 1 and 2)
Southern Nuclear)
ASLBP MO. 93-671-OLA-3 j
AFFIDAVIT OF FR_XD C.
WARREM j
I, Fred C. Warren, being duly sworn, state as follows:
1.
I am currently employed by Georgia Power Company as Outage Area Coordinator, Vogtle Electric Generating Plant.
2.
I am duly authorized to verify Georgia Power Company's Responne to Intervenor's Fifth Interrogatory and Document Request, specifically the responso to Interrogatory No. 16.
I hereby certify that the statements and opinions in such responso are true and correct to the best of my personal knowledge and belief.
i YnD Pred C. Warren sworn to and subscribed before me this Mn/ day of July, 1994.
/ /O Y
A /Aw A
Notary Public
/
My commission expires V-f-94 a
NL 1994 14: 55 FFOt1
'.CGTLE ECw. :U:CPT TO 9-1.204 E5-29CO P.02 0
UNITED STATES OF AMERICA NUCLEAR REGUIJLTORY COMMISSION BEFORE TRE ATOMIC SAFETY AND_ LICENSING BOARD In the Matter of 3
Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY, 3_t Rl.
I 50-425-OLA-3 s
Re License Amendment (Vogtle Electric Generating Plant, I (Transfer to Units 1 and 2) southern Nuolear) 1 ASLBP NO. 93-671-OLA-3 AFFIDAVIT OF THOMA8___X. WERR I, Thomas E. Webb, being duly sworn, state as follows:
1.
I am currently employed by Georgia Power Company as Senior Engineer, Vogtle Electric Generating Plant.
2.
I am duly authorized to verify Georgia Power Company's Response to Intervenor's Fifth Interrogatory and Document Request, specifically the responses to Interrogatory Nos. 1 and 2.
I hereby certify that the statomonts and opinions in such response are true and correct to the best of my personal knowledge and belief.
$Vf Thomas E.
Webb Sworn to and subscribed before me this ##46 day i
of July, 1994.
fh Y 0fbr/W Notary Public #
My commission expiros Y~ f-9S 1
l
1 DOCKETED JulyS:!,T1994 UNITED STATES OF AMERICA T4 JUL 25 All :45 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAb'. M 'M MRY 0
00CKETlHG 2; LERVICL in the Matter of ggAncH GEORGIA POWER COMPANY, Docket Nos. 50-424-OLA-3 cial.
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 I hereby certify that copies of Georgia Power Company's Responses to Intervenor's Fifth Interrogatory and Document Request, datec July 22,1994, were served
^
by express mail upon the persons listed on the attached senice list or, where indicated by an asterisk, by U.S. mail, this 22nd day of July,1994.
MA GA auh Thomas L. Penlanii, Jr.
TROUTMAN SANDERS Suite 5200 600 Peachtree Street, N.E.
Atlanta, Georgia 30308-2216 (404) 885-3360 i
1 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 j
21 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 SERVICE LIST Administrative Judge
- Stewart D.
Ebneter Peter B.
Bloch, 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 Two White Flint North 11545 Rockville Pike Office of the Secretary Rockville, MD 20852 U.S.
Nuclear Regulatory Commission Administrative Judge Washington, D.
C.
20555 James H. Carpenter ATTN:
Docketing and Atomic Safety and Licensing Services Branch Board 933 Green Point Drive Charles Barth, Esq.
Oyster Point Office of General Counsel Sunset Beach, NC 28468 One White Flint North Stop 15B18 Administrative Judge U.S.
Nuclear Regulatory Thomas D. Murphy Commission Atomic Safety and Licensing Washington, D.
C.
20555 Board U.S.
Nuclear Regulatory
- Director, Commission Environmental Protection TVo White Flint North Division 11545 Rockville Pike Department of Natural Rockville, MD 20852 R,esources 10S Butler Street, S.E.
Michael D. Kohn, Esq.
Suite 1252 Kohn, Kohn & Colapinto, P.C.
Atlanta, Georgia 30334 517 Florida Avenue, N.W.
Washington, D.C.
20001 Office of Commission Appellate Adjudication One White Flint North 11555 Rockville Pike Rockville, MD 20852 l
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