ML20083D034
| ML20083D034 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/19/1995 |
| From: | Lamberski J GEORGIA POWER CO., TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA |
| To: | |
| References | |
| OLA-3-I-MOS-057, OLA-3-I-MOS-57, NUDOCS 9505230322 | |
| Download: ML20083D034 (25) | |
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UNITED STATES.0F AMERICA .
NUCLEAR' REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,
i I
In the Matter of
- i
- GEORGIA POWER COMPANY,
- Docket Nos. 50-424-OLA-3 {
Al A1
- 50-425-OLA-3
-(Vogtle Electric
- Re: License. Amendment I Generating Plant, * (Transfer to Southern i Units 1 and 2)
- Nuclear) l l
FIRST SET OF INTERROGATORIES ~
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()
1 I. INTRODUCTION.
Georgia Power Company ("GPC") hereby responds to the NRC Staff's First Set of Interrogatories to Georgia Power I t
company, dated July 16, 1993. On August 4, 1993, after .j obtaining the agreement of both NRC Staff counsel and 1
Intervenor's counsel, GPC requested and the Licensing Board :
granted an extension of time, to August 9, 1993, to file this response. ,
l The first paragraph of page one of the NRC's t interrogatories states that the interrogatories, relate to diesel starts, or attempts to start, occurring between March' PDR ,
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s HUCLEAR REGULATORY COMMISSION (so-42%-OL A =3 Docket No 53 -9 25 -**^ -) O'ficial Exh. No. ^ 4- O to the r%ter of don 4 (c. UL : & 5 ( 6 2.
St#f !La NTIRED v Ap;& cant RECE:VED 7 Int.trsenar # REJECTED Conro 0:tr Contrac:er DATE O 9 - I 'i- 9 I Other V4tness /b c k ko (d Reporter T 2 : ( .'s 5 k .'
L gS 20, 1990 and April 9, 1990, inclusive. Certain of the q'; .
interrogatories, however, request information relative to diesel starts occurring as late as April 19, 1990. In responding to each of those interrogatories, GPC has )
included information concerning diesel starts which occurred between April 9 and April 19.
Unless otherwise noted, the source of knowledge of each person responsible for verifying GPC's interrogatory responses herein is their personal recollections as well as I any documents referred to in the responses they are verifying.
II. GPC RESPONSES TO SPECIFIC INTERROGATORIES.1 l
- 1. a. and b. (Cash /Bockhold) Jimmy Paul Cash counted '
diesel generator starts in preparation for GPC's meeting l l
with the NRC on April 9, 1990. He used the Unit Control Log !
and Shift Supervisor Log2 and prepared"a handwritten list of l
diesel starts which, he believes, is the same as the l l
1 GPC's responses are numbered to correspond to the numbers of the requests in NRC Staff First Interrogatories to Georgia l Power Company, dated July 16, 1993. j 2
As of April 9, 1990, the Diesel Start Log had not been updated since March 13, 1990. When this Start Log was updated in l late April, it included 1B diesel starts (nos. 1-90-128 through i 131) which had not been recorded in either the Unit Control Log I or Shift Supervisor Log. )
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(S! typewritten list which he brought to his oI interview on
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June 14, 1993. Mr. Cash provided to Mr. Bockhold the number of diesel starts (18 and 19) for the 1A and 1B diesels which appeared in the April 9, 1990 presentation transparency and the April 9, 1990 GPC letter to NRC. At present, Mr. Cash cannot definitively recall which specific starts he counted in arriving at the 18 and 19 numbers. Relying on Mr. Cash, Mr. Bockhold did not personally count the starts and does not know which ones are the "18 and 19" which Mr. Cash counted. Those same numbers together with subsequent review by site personnel formed one of the bases for the "at least i
18 times each" statement in the signed LER 90-006. l l
The " test program" which is referred to in the sentence ,
I
("N from the April 19, 1990 LER and quoted in interrogatory no.
V 1, was intended by Mr. Bockhold to refer to the testing of the diesel control systems which did not require diesel starts, i.e., the calibration of the calcon sensors and the logic testing of the control systems. According to the Plant Vogtle IR2 D/G TRN A Target vs. Actual Schedule and Maintenance Work order Control No. 19001576, this control systems testing was completed for the 1A diesel before start no. 148 on March 30, 1990; according to the Plant Vogtle IR2 D/G TRN B Target vs. Actual Schedule, it was completed for the IB diesel before start no. 137 on March 27, 1990.
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C .
- Based on Mr. . Bockhold's understanding of the completion x2 of the test program, there were at least 18 consecutive j successful starts of the 1A diesel (start nos. 148 through 173) and the 18 diesel (start nos. 137 through 154). GPC's June 29, 1990 Safety Analysis and Engineering Review
("SAER") audit report and GPC's August 30, 1990 letter to NRC are' sources of knowledge for this response.
- c. (Bockhold) Yes. On April 19, 1990, Mr. Bockhold I
understood the starts to be, consecutive. Also, 1A diesel start nos. 148-173 and 1B diesel start nos. 137-154, discussed in the response to interrogatory 1.a. and b. ;
above, are indeed consecutive.
- d. Based on the answer to interrogatory 1.c., GPC l considers this interrogatory to be inapplicable. ;
- e. (Stokes /Bockhold) Pegulatory Guide 1.108, Section C.2.e.(3) refers to but does not define " successful starts."
That paragraph does define a " valid successful test" as a successful start "followed by successful loading (sequential or manual) to at least 50% of continuous rating and .
continued operation for at least one hour." The diesel starts described in LER 90-006 were not limited to " valid successful tests" (as defined in Section c.2.e. of the Reg.
Guide), or starts associated with such tests. The starts described in LER 90-006 were intended to be consistent with
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P 4-the use of. " successful starts" in Reg. ; Guide 1.108, Section C.2.c. (1), connoting proper start-up to required voltage and .
i L frequency. l
- f. (Bockhold/McCoy/Hairston) As noted above,. Reg. ;
. Guide 1.108, Section c.2.e.(3) does not define " successful x
start," although it does define a " valid successful test."
The diesel start information which GPC included in LER 90- 1 006 was not limited to valid successful tests. GPC does not i believe that,it expressly informed the NRC on or before April 19, 1990 of the definition of " successful starts" used in the April 9, 1990 transparency. GPC did not use this term in either the April 9, 1990 letter or the April 19, 1990 LER. Nor does CPC believe that, in discussions with !
l the NRC concerning those starts in the April 1990 time ]
O frame, it referred to Reg. Guide 1.108 or used the term !
" valid successful tests."
Given the NRC's review of diesel generator testing ;
. A subsequent to the March 20, 1990 site area emergency and the ;
1 nature of the special diesel testing conducted- by GPC, the f
NRC knew or should have known that the " starts" referred to a i
in these instances were not limited to " valid successful '
tests" as defined in Reg. Guide 1.108, Section C.2.e.
- g. (Bockhold/McCoy) As of April 19, 1990, the late LER a0-006 was issued, there were no unsuccessful starts or I
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-y;g, x failures to. start 1the'1A or'1B diesels subsequent to'the f-i .
- Q' " test. program" as that' term was intended by Mr. Bockhold (see the response to 1.a. and b. above). GPC's June 29, 1990 SAER report and GPC's August 30, 1990 letter to NRC are sources of knowledge for this response.
- h. and i.. (Stringfellow) NRC Inspection Report 50-424/91-19, dated August 1, 1991, concluded that several l failures of the IB diesel (start nos. 1-90-132, 134 and
. 136), which occurred between March 20, 1990 and April 19,-
1990, were not reported in accordance with VEGP Tech. Spec.
S 4.8.1.1.3. Those starts were not reported pursuant to the Tech. Spec.3 because GPC interpreted recommendations of Reg.: >
Guide 1.108, Section C.3.b. as not applying'to starts performed prior to the diesel being declared operable
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following an engine disassembly, inspection and instrument calibration procedure during the refueling outage.
Following discussions with the NRC concerning the interpretation of Reg.' Guide 1.108, GPC submitted Special Report No. 1-91-1 on June 4, 1991 which discussed 18 diesel start nos. 1-90-132, 134 and 136. That report also
' discussed 1B diesel start nos. 1-90-120 through 124 which, 3
VEGP Technical Specification Section 4.8.1.1.3 provides, in part, that "[r)eports of diesel generator failures shall include
- the information recommended in Regulatory Position C.3.b of Regulatory Guide 1.108...."
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based on NRCLInspection Report 91-19, the NRC apparently
(_) concluded were not required to be reported pursuant to the
- Tech. Spec.
NRC personnel associated with the Augmented Inspection Team and the Incident Inspection Team were informed by GPC of the circumstances concerning 18 diesel start nos. 1 3 2 ,- i 134 and 136 prior to April 9, 1990. Sources of knowledge' for this paragraph include: an April 6, 1990 telecopy from Plant Vogtle to the NRC transmitting two documents designated by the IIT as nos. 178 and 180; handwritten notes of Mr. Rick Kendall, a member of both the AIT and the IIT, i
dated March 24 and 25, 1990; transcripts of telephone L i
conversations between GPC and NRC personnel, dated April 3 and 10, 1990; Plant Vogtle Maintenance Work Order Control No. 19001511; and NRC Inspection Report No. 90-05, dated-April 26, 1990.
- 2. a. and b. (Bockhold/McCoy) Mr. Cash cannot recall l which specific starts make up the 18 and 19 numbers used in (
the April 9, 1990 transparency. Based-on the total number ,
of starts counted by Mr. Cash, however, it11s clear that he included some starts that were part of the test program (as f redefined in the cover letter to the June 29, 1990 revised LER). As used in the June 29, 1990 revised LER, the P
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completion of.the test program was expressly defined to be "the first successful test in accordance with (VEGP) procedure 14980-1 ' Diesel Generator Operability Test ' . . . . "
1 These tests are identified on Tables 1 and 2 of GPC's August 30, 1990 letter as " normal surveillance;" for'the 1A E diesel this operability test was start no. 164 (April 1, 1990) and for the 1B diesel rc was start no. 143 (March 28, 1990). Using that definition of the completion of the test program, GPC computes that there were at least eight 1A diesel starts and at least six 1B diesel starts which were included in the diesel start numbers reported in the April 19, 1990 LER that were "part of the test program."
As discussed in the response to interrogatories 1.a.
and b. above, at the time the April 19, 1990 LER was prepared, Mr. Bockhold had a different understanding of what
" completion of the test program" meant. If the completion of the test program is defined as Mr. Bockhold interpreted it on April 19, 1990, then none of the starts reported in~
the. April 19, 1990 LER were "part of the test program." .
GPC's June 29, 1990 SAER Report and its August 30, 1990 letter to NRC are sources of knowledge for this response.
- c. and d. (Bockhold/McCoy) Mr. Cash cannot recall which specific starts make up the 18 and 19 numbers used in the April 9, 1990 transparency. However, as stated above,
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(_)' Bockhold interpreted it on April 19, 1990, then-none of the starts reported in the April 19, 1990 LER were "part of the test program." GPC's June 29, 1990 SAER Report and its l August 30, 1990 letter are sources of knowledge for this P response.
- e. and f. Please refer to the responses to interrogatories 1.a.-and b. and 2.a. and b. above. !
The commencement and termination,
- g. and h. (Bockhold) of activities associated with the testing conducted on the diesel generators during the outage of March 1990 are 1 1
identified on the Plant Vogtle D/G 1R2 TRN A and B Target vs. Actual Schedules, which schedules will be made available to the NRC Staff upon request. GPC notes that testing schedules were developed and revised from time to time during the course of the outage, and do not contain all the information concerning the " test program."
4
- 3. (Stokes) Today, the 1B ' Diesel Start Log, at p. 10, indicates that start nos. 1-90-120 and 121, both of which I occurred on March 21, 1990, were (1) invalid tests, (2) successful, and (3) failures. Initially, on May 2, 1990, these starts were identified as invalid tests and as l successful. (GPC has a copy of the Diesel Start Log as it
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existed on May 2, 1990.) Following discussions with the NRC
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\j beginning in August 1990, GPC changed its method of classifying certain starts. As a result, the failure column was checked for starts 120 and 121. When the failure column was checked, the check marks in the successful column should have been stricken but, due to oversight, were not.
- 4. a., c. and d. (Stokes) As used in the Diesel Start Log, with respect to valid tests, the heading ','S" for
" successful" over the fifth column connotes a valid successful test. This term was defined in March of 1990 in Section 3.3 of VEGP Procedure No. 55038-C, consistent with the description of " valid tests and failures a in Reg. Guide
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%J 1.108, Section C.2.e. (1)-(8) .
In the case of an invalid test, there is no definition of a " successful" invalid test. With respect to invalid tests, Mr. Stokes determined that the " successful" column of the Diesel Start Log should bd checked whenever an invalid test did not result in a failure in accordance with the description of failures appearing in Section 3.3 of Procedure 55038-C.
b., c. and d. (Stringfellow/Ajiuni/McCoy) The August ;
30, 1990 GPC letter to the NRC was signed by Mr. McCoy, not !
I Mr. Hairston. As used in the August 30, 1990 letter, the j l
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o heading." success" over the third columns of Tables 1 and 2 0
M- refers'to " successful starts," not " valid successful tests,"
and was defined in the third paragraph of that' letter. This ,
definition was formulated in August 1990 by a combination of. .
GPC personnel believed to include McCoy, Ajiuni,. Rushton and Shipman who considered this definition to be consistent with the criteria used b'y Mr. Cash when he counted diesel starts j prior to April 9, 1990.
1
- 5. (Stokes) Yes. The third column of the Diesel Start ,
l Log is entitled " Valid Test" and, in March of 1990, was ]
defined in accordance with Section 3.3 of VEGP Procedure No.
55038-C, consistent with Reg. Guide 1.108, Section C.2.e. j
- 6. Based on the answer to interrogatory no. 5, GPC l considers this interrogatory to be inapplicable.
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- 7. a. and b. (Cash /Bockhold) As noted above 'in the -l response to interrogatory 1.e., . Reg. Guide 1.108, Section . l I
C. 2.e. (3) does not define " successful start," although it j i
does define a " valid successful test." The diesel start information which GPC included on the April 9, 1990 presentation transparency was not limited to " valid ]
successful tests" (as defined in Section C.2.e. of the Reg. j
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Guide) , or ' starts associated with such tests. The diesel start.information on the transparency was' intended to be l consistent.with the'use of " successful starts" in Reg. Guide ,
1.108, Section C.2.c.(1), connoting proper start-up to required voltage and frequency.
Mr.. Cash recalls that he understood Mr. Bockhold wanted him to count starts without significant problems, where the ,
diesel had started properly and reached the required voltage- ,
and frequency. Mr,. Cash interpreted "significant. problems" to be anything which would have prevented the diesel from i operating in an emergency. Mr. Bockhold, who directed the preparation of the transparency used in the April 9, 1990 presentation, had the same understanding.
- c. The response to this interrogatory is included within the response to interrogatory 1.f. above..
c d. and e. (Cash /Bockhold/McCoy/Hairston) GPC does not '
believe that any GPC attendee at the April 9, 1990 meeting f had any questions at the time as to the accuracy of the is ,
and 19 successful starts. A conversation did apparently ]
occur between Mr. Bockhold and Mr. Cash, and possibly other GPC personnel, concerning whether the. diesel start numbers represented valid successful tests in accordance with Reg.
Guide 1.108. This conversation was described'to the NRC Operational Safety Inspection team during the transcribed O 1
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-interviews of Messrs. Bockhold and Cash on August'14, 1990.
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f..and g. (Cash /Bockhold/McCoy/Hairston) Messrs.
Cash, Bockhold, McCoy and Hairston believed and expected the NRC personnel at the . meeting to understand that the 18 and 19 successful starts were consecutive successful-starts.
- h. and i. (Cash /Bockhold/McCoy/Hairston) GPC does not believe that any GPC attendee at the April 9,1990 meeting told the NRC that the 18 and 19 successful starts were either consecutive or not consecutive.
- 8. The response to this interrogatory is included in the response to interrogatory no. 5. above.
- 9. and 10. (Cash) Although Mr. Cash cannot conclusively identify the specific diesel starts which make up the 18 and 19 successful starts referred to on the transparency (see the response to interrogatory no. 1.a. and b. above) , the total number of 1A and 18 diesel starts extracted by Mr.
Cash from the Control Log, and from which'the 18 and 19-numbers were counted, are reflected on the typewritten list which Mr. Cash ' brought to his June 14, 1993 OI interview.
- 11. and 12. (Bockhold) The description of the testing of the diesels on the transparency entitled " Diesel Testing" O
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used by GPC at the April 9,.1990 presentation is generally in chronological order'from the top to the bottom of the
'page. Because Mr. Cash'cannot'specifically identify which starts comprise the 19 18 diesel starts reflected on-the
" Diesel' Testing" transparency, GPC cannot.otherwise identify by start number the 14 multiple starts. While the order of the entries may appear to signify that there were 14 starts between the time of the "E-Run Bubble Testing" (i.e., start no. 127 on March 27, 1990) and the "UV Run Test" (i.e.,
start no. 142' on March 27, 1990), in fact, there were not.
- 13. and 14. (Bockhold/McCoy/Hairston) No. The language
"(s)ubsequent to this test program" appearing in the April' 19, 1990 LER was selected to better delineate the time period within which at least 18 successful starts were believed to have occurred.
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Dated: August 9, 1993.
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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.
SHAW, PITTMAN, POTTS & i TROWBRIDGE 2300 N Street, NW Washington, DC 20037
^
(202) 663-8084 Counsel for Georgia Power
, company 1
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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 11 A1
- 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 the NRC Staff's First Set of Interrogatories" 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 9th day of August, 1993. -
e hn Lamberski' TROUTMMi SANDERS Suite 5200.
600 Peachtree Street, N.E.
Atlanta, GA 30308-2216 (404) 885-3360 0
'J, s
~ UNITED STATES OF AMERICA y ' NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD c , -
In the' Matter of'
- GEORGIA POWER COMPANY,-
- Docket Nos. 50-424-OLA-3 SA A1
- 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 O U.S. Nuclear Regulatory Commission Branch, Charles Barth, Esq.
Washington, D.C. 20555 Office of General: Counsel 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 one White Flint North 11555 Rockville Pike Rockville, MD 20852 ATTENTION: Docketing and Service Branch O
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UNITED STATES OF AMERICA I l
NUCLEAR REGULATORY COMNIssION I 1 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD N-) [
In the Matter of a Docket No. 50-424-OLA-3 GEORGIA POWER COMPANY, 31 31 I 50-425-OLA-3
- Re License Amendment (Vogtle Electric Generating Plant, I (Transfer to Units 1 and 2) : southern Nuclear)
I, Jimmy Paul Cash, being duly sworn, state as follows:
- 1. I am employed by Southern Nuclear Operating Company, Inc. as Strategic Analyst, in Birmingham, Alabama. ;
- 2. I am duly authorized to verify Georgia Power Company's Response to the NRC Staff First Interrogatories to Georgia Power
() Company; 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.
b/.
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/ Jimmy Pani Cash e,
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Sworn to and subscribed before me thisd((~ day of August, 1993.
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Notary Phblic / !1 My commission expires:
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NUCLEAR Hr.tn%Mung wnm aam EEFoRE THE ATOMIC s1FETY mfd LIcNEfjlG_39.&BD l
In the Matter of' s Decket No. 50-424-OLA-3 I
eroacIn Powsm coxPANY, 31 31 I 50-425-OLA-3 l 3 Re: License Amendment 1 (Vogtle slectrie senerating Plant, s (Transfer to l cnita 1 and a) : southera wuolear) l A8LEP No. 93-671-01-OLA-3 i
AFFIDAVIT OF GEORGE BOCKNOLD. JR. j I, George Bockhold, Jr., being duly sworn, state as follows:
- 1. I am employed by southern Nuclear operating company, l l
, Inc. as the General Manager - Nuclear Technical Services.
- 2. I am duly authorized to verify Georgia Power company's Response to the NRC Staff First Interrogatories to Georgia power company; specifically, those responses to which my name has been appended.
I hereby certify that the statements and opinions in such ;
~
responses are true and c rrect to the best of oy personal -
Xnowledge and belief.
I George Sockhold, Jr.
sworn to and subscribed - .
before me this {,A_ day of [
August, 1993.
ZwaA. $ i
\ Notary Qualic
,My co:anission expires:
wconma tem wtwtv u.mt
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UNITED STATES OF AMERICA
, NUCLEAR REGULATORY COMMISSION pEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,,
In the Matter of :
- Docket No. 50-424-OLA-3 GEORGIA POWER COMPANY, d 11 : 50-425-OLA-3
- Re License Amendment (Vogtle Electric Generating Plant, 3 (Transfer to Units 1 and 2) : Southern Nuclear)
- ASLBP No. 93-671-01-OLA-3 AFFIDAVIT OF KENNETH C. STOKES I, Kenneth C. Stokes, being duly sworn, state as follows:
- 1. I am employed by Georgia Power Company as a Senior Plant Engineer at Plant Vogtle.
- 2. I am duly authorized to verify Georgia Power Company's Response to the NRC Staf f First Interrogatories to Georgia Power Company; 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'.
W Kenneth C. Stoles f .
\
Sworn to and subscribed l before ne this 1 day of August, 1993.
Jim - 42m S i potary Public
" Y co,Wc=u d- m. _ u -- i4.u,.= 4.._
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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
/G (j BEFORE THE ATOMIC SAFETY AND LICEN8ING BOARD In the Matter of : ,
a Docket No. 50-424-OLA-3 GEORGIA POWER COMPANY, e.1 31 : 50-425-OLA-3
- Re License Amendment (Vogtle Electric Generating Plant, I (Transfer to Units 1 and 2) .Scuthern Nuclear)
- ASLBP NO. fr1-671-01-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 the NRC Staff First Interrogatories to Georgia Power Company; 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.
C. Kenneth McCoy Sworn to and subscribed
before me this 3d day of August, 1993. l .
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Notary Publid
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I My commission expires: hh 'd 4f f 5 ;;,p . ?
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UNITED STATE 8 CF AMERICA I NUCLEAR REGULATORY CONNIssION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of a
- Docket No. 50-424-OLA-3 GEORGIA POWER COMPANY, it,11 50-425-OLA-3
- Re: License Amendment (Vogtle Electric Generating Plant, I (Transfer to Units 1 and 2) : southern Nuclear) )
- ASLBP NO. 93-671-01-OLA-3 AFFIDAVIT OF W. GEORGE HAIRSTON. III I, W. George Hairston, III, being duly sworn, state as 1
followS: 1 1
- 1. I am employed by Georgia Power Company as the Executive Vice President - Nuclear Operations.
- 2. I am duly authorized to verify Georgia Power Company's j Response to the NRC Staff First Interrogatories to Georgia Power Company; 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.
u d /d d .n W. George ~Hairston, III I
Sworn beforetome andthis subsi day
{ribedof August, 1993.
A . GAEkI Notary Public My commission expires:
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UNITED STATES CF AMERICA NUCLEAR REGUIATORY CoMMIESION REFORE THE ATOMIC SAFETY AND LICENSING BOARD a
In the Matter of Docket No. 50-424-OLA-3 GEORGIA POWER COMPANY, at 31 : 50-425-OLA-3
- Re License Amendment (Vogtle Electric Generating Plant, s (Authorisation for Units 1 and 2) southern Nuclear)
A8LBP No. 93-671-OLA-3 AFFIDAVIT OF N. JACKSON STRINGFELLOW I, N. Jackson Stringfellow, being duly sworn, state as folless: l
- 1. I am 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 the NRC Staff First Interrogatories to Georgia Power Company; 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 j I
knowledge and belief. .
'. b //W N. J kson StringTello '/
Sworn to and subscribed before me this gj day of August, 1993.
xdn Notary Ofublic My commission expires:
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UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION 35 FORE TEE ATOMIC BAFETY AND LICENSING BQARD
.. l In the Matter.of :- *
- Docket No. 50-424-OLA-3 oEORoIA power COMPANY, g,1 31 50-425-OLA-3 Re License Amendment .
1 (Vogtle Electric Generating Plant, 3 (Transfer to Units 1 and 2) Southern Nuclear)
- ASLBP No.- 93-671-01-OLA-3~
AFFIDAYZ.T_QF.. MARK._J _MLUNI
, I, Mark J. Aj1 uni, being duly sworn, state as follows:'
- 1. I am employed by Southern Nuclear Operating Company, Inc. as Senior Project Engineer, in Birmingham, Alabama. ;
l
- 2. I am duly authorized to verify Georgia Power Company's Response to the NRC Staff First Interrogatories to Georgia Power Company; specifically, those responses to which my name has been appended. I 1
I hereby certify that the statements and opinions in such i responses are true and correct to the best-of my personal knowledge and belief.
l Wh dM MarkJ.8Ajlghi Sworn to and subscribed before me this @ day of August, 1993. -
Modk -
, Notary Qublic My commission expires:
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