ML20082H506
| ML20082H506 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/03/1995 |
| From: | Kohn M GEORGIA POWER CO., KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA |
| To: | |
| References | |
| CON-#295-16601 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9504170172 | |
| Download: ML20082H506 (8) | |
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DOCKETED USHRC A
3, 1995 0FP : <'2F'
' TW UNITED STATES OF AMh1ICAHi/,
NUCLEAR REGULATORY COMMISSION-ATOMIC-SAFETY AND LICENSING BOARD Before Administrative Judges:
Peter B. Bloch, Chair Dr. James H. Carpenter Thomas D. Murphy
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In the Matter of
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Docket:Nos. 50-424-OLA-3 GEORGIA POWER COMPANY
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50-425-OLA-3 ga al,
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Re: License Amendment, (Vogtle Electric Generating
)
(transfer to. Southern' Nuclear)
Plant, Unit l'and Unit 2)
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ASLBP No. 93-671-01-OLA-3 j
INTERVENOR'S PHASE II EXHIBIT LIST Intervenor hereby submits his list of exhibits for Phase II l
of above captioned licensing proceeding:
l EXHIBIT LIST EXHIBIT 1-Resume of Allen L. Mosbaugh EXHIBIT 2-2-16-89 Bockhold letter " Accuracy of Information" EXHIBIT 3-1-7-90 Anonymous Allegation, Dilution Valves EXHIBIT 4-Tape #99, 5-8-90 EXHIBIT 5-May 1990 Performance Pay Program Survey EXHIBIT 6-Waynesboro, GA, Vogtle Weather Data, March 1990 EXHIBIT 7-GPC 9-4-90 NRC Presentation on the-SAE EXHIBIT 8-Tape #8, 3-23-90 EXHIBIT 9-Tape'#10, 3-23-90 Segments 1,2,3 O
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9504170172 950403 PDR ADOCK 05000424 O
EXHIBIT 10-NUREG'1410 diagram DG Air System EXHIBIT 11-ISA Standard ISA-S7.3 EXHIBIT'12-Vogtle Diesel Air Dryer Vendor Manual EXHIBIT 13-2-17-89' Response to Generic Letter 88-14 EXHIBIT 14-NUREG 1410, pictures of Control: Air Tubing DG2B for 1989 EXHIBIT 15-GPC Diesel Logs.DG1A, DG1B, DG2A,_.
and 1990.
EXHIBIT 16-Tape #58, 4-19-90' (stipulated version)
EXHIBIT 17-Louis Ward's Notebook EXHIBIT 18-Handwritten List of As Found Set points on CALCON i
JWTS Sensors; Bockhold-EXHIBIT 19-Tape # 25, 3-30-90 Segments 1,2 EXHIBIT 20-4-7-90 IIT Transcript, IIT Document: 205 EXHIBIT 21-
. Tape #32,'4-4-90 EXHIBIT 22-Tape-#89, 5-2-90 Segment 1 EXHIBIT 22A-4-9-90 IIT Telephone Conference call'IIT 206
~
EXHIBIT 23-Tape #29, 4-3-90 EXHIBIT 24-4-9-90' COA Response Letter, final EXHIBIT 25-Tape #40, 4-10-90, Segments 1,2 EXHIBIT 26-4-10-90 Memo to Bockhold Air Quality Statements EXHIBIT 27-Tape,#41, 4-11-90 Segments 1, 2,
NRC proposed version EXHIBIT 28-Tape #57, 4-19-90 EXHIBIT 29-4-30-90 Memo to Bockhold Diesel Start Statements EXHIBIT 30-Tape #89, 5-2-90' Segment 2 EXHIBIT 31-5-10-90 PRB Meeting Minutes EXHIBIT 32.
Tape #187, 6-29-90
.EXHIBT.T 33.
5-24-90 Bockhold Action Item 2-s
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4 EXHIBIT 34-NUREG 1410 App. I EXHIBIT 34A-4-6-90 IIT transcript, IIT #203 EXHIBIT 35-GPC Dew Point Data MWO Package EXHIBIT 36-GPC's Response to Intervenor's 7th Set of Interrogatories EXHIBIT 37-5-23-90 Time Line Sequence of Events EXHIBIT 38-Tape #127. 5-24-90 Segments 1,2,3,4,5 EXHIBIT 39-12-20-93 OI Report EXHIBIT 40-4-7-90, 08:47 fax, COA Draft from Birmingham l
EXHIBIT 41-4-7-90 Cash Diesel Start Lists, Marked by Cash EXHIBIT 42-Base System Listing from wordprocessor EXHIBIT 43-Base System package of Slide Presentation documents EXHIBIT 43A-Bockhold OI interview, 6-22-93 EXHIBIT 44-5-14-90 NRC letter confirming Bockhold Slide Presentation EXHIBIT 45-Tape #27, 4-2-90 Segment 3 EXHIBIT 46-2-8-94 Coordinating Group Report EXHIBIT 47-Blue Folder Traveler Sheets for COA response letter EXHIBIT 48-Tape #253, 8-15-90 EXHIBIT 49-8-16-90 " White Paper" NRC's DG question page EXHIBIT 50-Tape #11, 3-23-90 EXHIBIT 51-Tape #7, 3-22-90 EXHIBIT 52-Bill Shipman's Notebook Jan-Aug 1990 EXHISIT 53-Tape #184, End of August, Segment 1,2 EXHIBIT 54 8-30-90 Draft Diesel Start List, with Note #2 EXHIBIT 55-4-19-90 LER 90-006 final 3
EXHIBIT 56-
-Shipman Deposition, August 1994 I
l EXHIBIT 57-GPC's Response to NRC Staff's First Set of Interrogatories, dated 8-9-93 4
EXHIBIT 58-Interrogatory response of Kenneth Brockman to GPC's first set of Interrogatories to NRC, dated j.
10-8-93 t
EXHIBIT 59-Brockman Deposition, 12-26-94 EXHIBIT 60-3-13-95 NRC letter acknowledging-Payment of CP &
NOV EXHIBIT 61-Blue Folder Traveler Sheets for LER 90-006 rev.0.
EXHIBIT 62-6-29-90 LER 90-006 rev.
1, final w/ cover letter EXHIBIT 63-Tape #156, 6-8-90 EXHIBIT 64-6-28-90 and 6-29-90 Multiple Cover Letters EXHIBIT 64A-5-9-94 Notice of Violation.
EXHIBIT'64B-Site to corporate items status, 6-15-90 EXHIBIT 65-Reserved EXHIBIT 66-Hairston Phone Logs; April-July 1990 EXHIBIT 67-8-30-90 COh Response Letter correction EXHIBIT 67A-SONOPCO Project statement; Project no. 024311 EXHIBIT 68-Tape #184, Segment #3 EXHIBIT 69-Tape #269 EXHIBIT 70-Handwritten notes of Jim Bailey Notes for 4-9-90 presentation EXHIBIT 71-Bockhold 4-9-90 Presentation with Notes-EXHIBIT 72-NRC response to Intervenors 1st Set of i
Interrogatories, dated 9-15-93 EXHIBIT 73-GPC's 4-1-91 Response to 2.206 Petition, Footnote
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1
- 3 EXHIBIT 74-GPC's 10-3-91 Additional 2.206 Petition Response I
l 4
1
I EXHIBIT 74A-Intervenor's memo to Michael Kohn 4-19-90 regarding Conference Call EXHIBIT 75-12-10-91 Supplemental letter McCoy to Murley EXHIBIT 76-Tape #259, 8-17-90 l
EXHIBIT 76a Tape #246, 8-13-90 EXHIBIT 77-Blue Folder Traveler Sheets for LER-90-06 rev.1, LER 2-90-006, 8-30-90 letter EXHIBIT 78-SCL 00166 Dewpoint PM Procedure, revs. 0-3.
EXHIBIT 79-Dew Point DC Package, 1-90-186, 1-90-408, 1-90-412 EXHIBIT 80-War Room Unit 1 Refueling Outage Log, pp. 75-79.
EXHIBIT 81-Outage Turnover Log 3-15-90 to 4-6-90 EXHIBIT 82-4-11-90 Dew Point List IIT #202 l
EXHIBIT 82A-Transcript of 4-11-90 teleconference IIT 233 EXHIBIT 83-August 1990 NRC OSI Inspection Report EXHIBIT 84-Tape # 24, " Poured out w/o Stokes" EXHIBIT 85-Tape # 24, side B EXHIBIT 86-NUREG 1410 App.
J, pp. 10-11 EXHIBIT 87-GPC's responses to Intervenor's 5th Set of Interrogatories, dated 7-22-94 EXHIBIT E8-DCP-90-VIN 0040 DCP 4-28-89 to add Heaters to air compressor EXHIBIT 89-4-2-90, 08:45 SSPI document, IIT # 143 EXHIBIT 90-Tape # 27, 4-2-90, Segments 1,2 EXHIBIT 91-Draft COA response letter w/SSPI table 4-6-90 EXHIBIT 92-Tape #31, 4-3-90 EXHIBIT 93-Executive Summary Diesel Operability EXHIBIT 94-Tape #32, 4-4-90 EXHIBIT 95-GPC position papers, " White Paper" Full version issued by Ajuluni 8-23-90 5
EXHIBIT 96-Mcdonald OI Interview July 1, 1993 EXHIBIT 97-McCoy DOL Deposition 9-12-90 EXHIBIT 98-GPC Response to Intervenors 1st Set of Interrogatories dated June 2, 1993 EXHIBIT 99-Mcdonald DOL Deposition 9-17-90 EXHIBIT 100-GPC Response to Intervenors 2nd Set of Interrogatories, dated 7-16-93 EXHIBIT 101-GPC's 2.206 Petition Response Section II.3 pp.
1-11, 4-1-91 EXHIBIT 102-Phone Logs of Bili Shipman and Ken McCoy 1990 EXHIBIT 103-Hairston OI Interview June 25, 1993 EXHIBIT 104-6-20-90 Board of Directors Briefing EXHIBIT 105-GPC's 7-31-94 Response to NOV EXHIBIT 106-NRC Response to GPC'c 1st Set of Interrogatories, dated 12-20-93 EXHIBIT 107-Demand For Information Response of Ken McCoy, dated 8-1-94 EXHIBIT 108-Demand For Information Response of George Bockhold, dated 7-31-94 EXHIBIT 109-NUREG 1410 p.
3-21 EXHIBIT 109A-NUREG 1410 p. 3-15 EXHIBIT 110-NUREG 1410 p. J-25 EXHIBIT 110A-Tape #34, 4-4-90 EXHIBIT 110B-5-14-90 Corrective Actions for SAE letter EXHIBIT lil-Critique Report on DG Failure to Start EXHIBIT 112-Special Report 90-05, 8-7-90 EXHIBIT 113-DC-2-90-155, 9-21-90 EXHIBIT 114-Reserved EXHIBIT 115-6-9-94 NRC Inspection Report 50-424,425/94-12 6
i e
EXHIBIT 116-12-18-92 Lavine Letter to DOJ EXHIBIT 117-GPC's Statement of Material Facts - Air Quality, dated 3-3-95 EXHIBIT 118-Tape 24, Side A; 3-30-90 EXHIBIT 119-Cash's Typed diesel start list, marked by Frederick EXHIBIT 120-12-19-90 memo from Ajuluni to McCoy j
EXHIBIT 121-3-5-92 Letter to David Hembree (INPO) from Hairston EXHIBIT 122-7-31-90 letter to Atlanta Business Chronicle from Dahlberg EXHIBIT 123-Outage log GPC project no. 030,"7-030538
)
EXHIBIT 124-SAE critique Report, 5-24-90 EXHIBIT 125-Tape 34, 4-4-90 EXHIBIT 126-Tape 246, 8-13-90 EXHIBIT 127-OI Statement index EXHIBIT 128-NUREG 1410 EXHIBIT 129-11-15-94 Letter from Mathews to Russell EXHIBIT (S)-
All Exhibits to tae OI Report EXHIBIT (S)-
All Exhibits used in the deposition of any witness EXHIBIT (S)-
Rebuttal Exhibits EXHIBIT (S ) -
The deposition of each person identified as a witness in this proceeding EXHIBIT (S)-
Any exhibit introduced into evidence or offered into evidence during the Phase I proceeding EXHIBIT (S)-
The trial and/or deposition testimony each person identified as a witness in this proceeding gave pursuant to Section 210 of the Energy Reorganization Act, or in another legal proceeding EXHIBIT (S)-
All exhibits identified by Georgia Power Compat and/or NRC Staff 7
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EXHIBIT (S)-
The answers to interrogatories and admissions filed by the NRC Staff and GPC EXHIBIT (S) -
The demonstrative aids pre-filed with the l
testimony of Allen L. Mosbaugh EXHIBIT (S)-
Exhibits which may be identified in the future related to the expert testimony being offered by NRC Staff and the potential expert testimony,to be offered by Intervenor]
EXHIBIT (S)-
Any document (including tape recordings) necessary i
to refresh the' memory of a witness EXHIBIT (S) -
Any prior statement of any witness which may be needed to impeach that witness 1
j Respectfully submitted, M
Michael D. Kohn l
Kohn, Kohn & Colapinto, P.C.
i 517 Florida Ave.,
N.W.
' Washington, D.C.
20001 (202) 234-4663 i
CERTIFICATE OF SERVICE I hereby certify that on this 4th day of April 1995 the preceding document was served by hand delivery upon the persons listed on the attached service list.
V Michael D.
Kohn C:\\ FILES \\301\\EXPli i
P
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