ML20082L241
| ML20082L241 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/17/1995 |
| From: | Kohn M, Mosbaugh A AFFILIATION NOT ASSIGNED, GEORGIA POWER CO., KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA |
| To: | |
| References | |
| CON-#295-16630 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9504210060 | |
| Download: ML20082L241 (9) | |
Text
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i lh$30 DOCKETED USNRC 35 APR 17 P2 :58 April 17, 1995 0FFICE DE RMETARY UNITED STATES OF AMERICA h~,
NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
Peter B.
Bloch, Chair Dr. James H.
Carpenter Thomas D. Murphy
)
In the Matter of
)
)
Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY
)
50-425-OLA-3 31 al_,_,
)
)
Re: License Amendment (Vogtle Electric Generating
)
(transfer to Southern Nuclear)
Plant, Unit 1 and Unit 2)
)
)
ASLBP No. 93-671-01-OLA-3 INTERVENOR'S PHASE II EXHIBIT LIFT (AMENDED)
Intervenor hereby submits his list of exhibits for Phase II of above captioned licensing proceeding:
EXHIBIT LIST l
EXHIBIT 1-Resume of Allen L. Mosbaugh l
EXHIBIT 2-2-16-88 Bockhold letter " Accuracy of Information" EXHIBIT 3-1-7-90 Anonymous Allegation, Dilution Valves l
l EXHIBIT 4-Tape #99, 5-8-90, Tr. 48-51 EXHIBIT 5-May 1990 Performance Pay Program Survey gXHJBIT 5A-Enhancina NRC Communication and Kev Princioles of
. Nuclear Personnel 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 b())
9504210060 950417 PDR ADOCK 05000424 O
j i
EXHIBIT 9-Tape #10, 3-23-90 Segments 1,2,3 4
EXHIBIT 10-NUREG 1410 diagram DG Air System, D.
3-47 I
EXHIBIT 11-ISA Standard ISA-S7.3 l
EXHIBIT 12-Vogtle Diesel Air Dryer Vendor Manual 1
EXHIBIT 13-2-17-89 Response to Generic Letter.88-14 i
EXHIBIT 14-NUREG 1410, pictures of Control Air Tubing, pp.
3-49 and J-33 j
EXHIBIT 15-GPC Diesel Logs DG1A, DG1B, DG2A, DG2B for 1989 and 1990.
EXHIBIT 16-Tape #58, 4-19-90 (stipulated version) i EXHIBIT 17-Louis Ward's Notebook i
\\
i EXHIBIT 18-Handwritten List of As Found Set points on CALCON i
l JWTS Sensors; Bockhold EXHIBIT 19-Tape # 25, 3-30-90 Segments 1,2 1
EXHIBIT 20-4-7-90 IIT Transcript, IIT Document 205 1
l l
EXHIBIT 21-Tape #32, 4-4-90 l
EXHIBIT 22-Tape #89, 5-2-90 Segment 1 j
1 i
EXHIBIT 22A-4-9-90 IIT Telephone Conference call IIT document 206 l
EXHIBIT 23-Tape #29, 4-3-90 j
EXHIBIT 24-4-9-90 COA Response Letter, final f
EXHIBIT 25-Tape #40, 4-10-90, Segments 1,2 i
EXHIBIT 26-4-10-90 Memo from Mosbauch 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 from Mosbauch to Bockhold Diesel Start Statements EXHIBIT 30-Tape #89, 5-2-90 Segment 2 2
4 i
EXHIBIT 31-5-10-90 PRB Meeting Minutes EXHIBIT 32-Tape #187, 6-29-90 EXHIBIT 33-5-24-90 Bockhold Action Item 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 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, Side B, 45%
EXHIBIT 46-2-8-94 Vootle Coordinating Group Analysis Report i
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 3
EXHIBIT 53-Tape #184, End of.'.ugust, Segment 1,2 EXHIBIT 54-8-30-90 Draft Diesel Start List, with Note #2 EXHIBIT 55-4-19-90 LER 90-006 final
)
EXHIBIT 56-Shipman Deposition, August 1994 j
EXHIBIT 57-GPC's Response to NRC Staff's First Set of Interrogatories, dated 8-9-93 i
EXHIBIT 58-Interrogatory response of Kenneth Brockman to GPC's first set of Interrogatories to NRC, dated 10-8-93; Date of resconse 12-23-93 j
i t
EXHIBIT 59-Brockman Deposition, 12-26-94 l
l EXHIBIT 60-3-13-95 NRC letter acknowledging Payment of CP &
(
EXHIBIT 61-Blue Folder Traveler Sheets for LER 90-006 rev.0 I
EXHIBIT 62-6-29-90 LER 90-006 rev.
1, final w/coicr letter l
EXHIBIT 63-Tape #157, 6-8-90 l
EXHIBIT 64-6-28-90 and 6-29-90 Multiple Cover Letters EXHIBIT 64A-5-9-94 Notice of Violation j
i 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 COA 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 Interrogatories, dated 9 15-93 4
l
-c-n r
l EY."IBIT 73-GPC's 4-1-91 Response to 2.206 Petition, Footnote
- 3 EXHIBIT 74-GPC's 10-3-91 Additional 2.206 Petition Response EXHIBIT 74A-Intervenor's memo to Michael Kohn 4-19-90 regarding Conference Call 3
EXHIBIT 75-12-10-91 Supplemental letter McCoy to Murley
+
f l
EXHIBIT 76-Tape #259, 8-17-90 j
EXHIBIT 76a Tape #246, 8-13-90 EXHIBIT 77-
-Blue Folder Traveler Sheets for LER-90-06 rev.1, l
LER 2-90-006, 8-30-90 letter l
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.
j EXHIBIT 81-Outage Turnover Ic;g 3-15-90 to 4-6-90 EXHIBIT 82-4-11-90 Dew Point List IIT #202 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 7-2:f-94 EXHIBIT 88-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 l
i l
F
1 EXHIBIT 94-Tape #32, 4-4-90 EXHIBIT.95-GPC position papers, " White Paper" Full version issued by Ajuluni 8-23-90 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 j
i EXHIBIT 101-GPC's 2.206 Petition Response Section II.3 pp.
1-11,,
4-1-91
\\
EXHIBIT 102-Phone Logs of Bill Shipman and Ken McCoy 1990 l
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's 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 EXHI3IT 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 111-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 6
i i
EXHIBIT 114-Reserved EXHIBIT 115-6-9-94 NRC Inspection Report 50-424,425/94-12 EXHIBIT 116-12-18-92 Lavine Letter to DOJ EXHIBIT 117-WITHDRAWN j
i EXHIBIT 118-Tape 24, Side A; 3-30-90 EXHIBIT 119-Cash's Typed diesel start list, marked by Frederick e
EXHIBIT 120-12-19-90 memo from Ajuluni to McCoy EXHIBIT 121-3-5-92 Letter to David Hembree (INPO) from Hairston EXHIBIT 122-7-31-90 letter to Atlanta Business Chronicle from l
.Dahlberg l
EXHIBIT 123-Outage log GPC project no. 030467-030538 EXHIBIT 124-SAE critique Report., 5-24-90 EXHIBIT-125-DUPLICATE EXHIBIT 126-DUPLICATE EXHIBIT 127-OI Statement index EXHIBIT 128-NUREG 1410 EXHIBIT 129-11 15 90 Lcttcr frc "cthcuc te nucccl1 Should read March 3, 1995 letter to ASLB from Mitzi Younc i
with attachments EXHIBIT (S)-
All Exhibits to the OI Report EXHIBIT (S)-
All Exhibits used in the deposition of any witness EXHIBIT (S) -
Rebuttal Exhibits i
EXHIBIT (S)-
The deposition of each person identified as a 1
witness in this proceeding EXHIBIT (S)-
Any exhibit introduced into evidence or offered into evidence during the Phase I proceeding i
EXHIBIT (S)-
The trial and/or deposition testimony each person
)
identified as a witness in this proceeding gave i
7
o purstuant to Section 210 of the Energy Reorganization Act, or in another legal proceeding EXHIBIT (S)-
All exhibits identified by Georgia Power Company and/or NRC Staff EXHIBIT (S)-
The answers to interrogatories and admissions filed by the NRC Staff and GPC I
EXHIBIT (S)-
The demonstrative aids pre-filed with the testimony of Allen L. Mosbaugh j
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 i
of fered by Intervenor] ~
EXHIBIT (S)-
Any document (including tape recordings) necessary to refresh the memory of a witness EXHIBIT (S)-
Any prior statement of any witness which may be needed to impeach that witness Respectfully submitted, pffW,A)(4 Y t Michael D.
Kohn Mary Jane Wilmoth
]
Kohn, Kohn & Colapinto, P.C.
517 Florida Ave.,
N.W.
Washington, D.C.
20001 (202) 234-4663 CERTIFICATE OF SERVICE I hereby certify that on this 17th day of April 1995 the preceding document was served by hand delivery upon the persons listed on the attached service list.
l
/
Mary Jfne Wilmoth C:\\ FILES \\301\\EXPl!
8
i i
DOCKETED UNITED STATES OF AMERICA ggyRC NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD 95 NT 17 P2 :58 In the Matter of
)
i
)
Docket Nos. 50-42tf 0LA-3F SECREJ,ARY j
~
50-420fd11A 3 m a SEn v (CE J
GEORGIA POWER COMPANY
)
et alm,
)
BRANCd
)
Re: License Amendment j
(Vogtle Electric Generating
)
(transfer to Southern Nuclear) l Plant, Unit 1 and Unit 2)
)
l
)
ASLBP No. 93-671-01-OLA-3 i
SERVICE LIST Administrative Judge Administrative Judge Peter B. Bloch, Chair James H. Carpenter i
Atomic Safety and Licensing Board 933 Green Point Drive U.S. Nuclear Regulatory Commission Oyster Point Washington, D.C.
20555 Sunset Beach, NC 28468 Administrative Judge Charles A.
Barth, Esq.
Thomas D. Murphy Office of General Counsel Atomic Safety and Licensing Board U.S. N.R.C i
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 John Lamberski, Esq.
Ernest L. Blake, Jr.
Troutman Sanders David R. Lewis Suite 5200 SHAW, PITTMAN, POTTS &
600 Peachtree Street, N.E.
TROWBRIDGE i
Atlanta, GA 30308-2216 2300 N Street, N.W.
Washington, D.C.
20037 Office of the Secretary Attn: Docketing and Service U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Office of Commission Appellate Adjudication U.S. Nuclear Regulatory Commission Washington, D.C.
20555 301\\ Cert.Lst I