ML20086U086

Applicant Exhibit A-74A,consisting of Gap Second Set of Interrogatories & Request for Documents to AL Mosbaugh

ML20086U086
Person / Time
Site:	Vogtle
Issue date:	05/23/1995
From:	GEORGIA POWER CO.
To:
References
OLA-3-A-074A, OLA-3-A-74A, NUDOCS 9508030264
Download: ML20086U086 (3)

Text

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DOCKETED USNRC y_y

'd UNITED STATES OF AMERICA 95 JL 14 No:40 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARDJFFICE OF SECRETARY DOCKETlHG & SERVICE BRANCH- 4 In the Matter of * '

GEORGIA POWER COMPANY,

• Docket Nos. 50-424-OLA-3 at 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 SECOND SET OF INTERROGATORIES AND REQUEST FOR DOCUMENTS TO ALLEN L. MOSBAUGH O I. INTRODUCTION.

Pursuant to 10 C.F.R. $ 2.740b, Georgia Power Company hereby requests that Allen L. Mosbaugh answer the following interrogatories in writing and under oath within 14 days of service of this document.

II. INSTRUCTIONS.

l A. If you cannot answer a particular interrogatory in full, after exercising due diligence to secure the  :

j information to do so, so state and answer to the extent, possible, specifying and exclaining your inability to answer fldCLEAP RECT'LAT0dY COMMISSION go <f n.4.c L A - 5

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either demonstrate that the diesel gener tors were requalified'and/or met a reliability factor of 95%

in accordance withLReg. Guide 1.108? If the

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answer is "yes," describe in detail what GPC was required to demonstrate and state the basis'for such contention and quote the specific NRC l l

regulations orfrequirements which support that  ;

contention. l

2. This interrogatory refers to the six page document ,

which Intervenor submitted to the NRC, the first paragraph.

3 of which begins as follows:

. Georgia power has made an additional Material false statement in written correspondence to the.NRC in i g Licensee Event Report 90-006 submitted 4-19-90.

a. On what date did Intervenor submit this  !

document to NRC? '

b. Beside NRC, who else did Intervenor provide with a copy of this document?

c. Describe all oral statements made by Intervenor to the NRC or any other person with.

respect to this document. Identify the date of  !

such statement,.who they were made to and what was  ;

, discussed.

d. With respect to the sentence at the bottom of:  !

page one of this document which begins " Concern ,

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was raised by plant staff on 4-18-90...," respondi to.the following:-

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1. Identify each~ individual-by name, including those who' vere ~ raising the concerns and to whom they were raised.

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2. State whether Mr. Mosbaugh was presenti during each occasion when a concern was raised and whether he tape recorded the conversation.

3. Describe in detail what the concern was that raised in each instance, including the specific language of the LER to which the concern related. U

e. Has Mr..Mosbaugh ever seen a list of diesel starts prepared by either Mr. Tom Webb or Mr. Rick Odom? Did Mr. Mosbaugh ever have such a list in his possession custody-or. control? If the answer is "yes" to.either, describe the list in detail

' and state in detail Mr. Mosbaugh's knowledge of the location and disposition of the list since its creation.

.3. This interrogatory relates to the document Intervenor submitted to the NRC and which is entitled " Georgia

_ Power /SONOPCO 2.206 Petition Response is filled with lies?"

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