ML20086U090

Applicant Exhibit A-74B,consisting of a Mosbaugh Response to Second Set of Interrogatories of Gap

ML20086U090
Person / Time
Site:	Vogtle
Issue date:	05/23/1995
From:	AFFILIATION NOT ASSIGNED
To:
References
OLA-3-A-074B, OLA-3-A-74B, NUDOCS 9508030267
Download: ML20086U090 (4)

Text

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. UNITED. STATES.OF AMERICA. '

NUCLEAR REGUIATORY COMMISSION y:-

~ ATOMIC SAFETY AND IICENSING BOARG : JL 14 40:40-Before' Administrative Judges:-

Peter B. Bloch,' Chair Dr. James:H. Carpenter;. - FFICE OF SECRETARY -

Thomas D. Murphy OCKET!NG & SERVICE BRANCH

)

'In the Matter of )

E GEORGIA POWER COMPANY

) Docket Nos. 50-424-OIA-3 at AL.,

) 50-4 25-OIA-3

)

) Re: License Amendment

,(Vogtle Electric Generating ) (transfer to Southern Nuclear)

Plant, Unit 1 and Unit 2) )

) ASLBP No." 93-671-01-OIA-3 INTERVENOR'S RESPONSE TO TER SECOND SET OF INTE88'MBATORIEs OF GEORGIA POWER OE-DANY Intervanor, Allen L. Mosbaugh, files his responses to the interrogatories filed by Georgia Power Company ("GPC") on July 26,

'1993.

Interrogatory Responses.

1. a. On June 13 or 14, 1990.

b.

Prior to July 15, 1993, Intervanor provided copies to counsel and United States Congressional staff personnel.

, c. Intervenor discussed virtually all aspects of this.

document with Mr. Robinson between June 13-14, 1990. The exact comments are not recorded and Intervenor has no notes of his meetings with NRC-OI. Additional discussions occurred between July 18-19, 1990, when Mr. Mosbaugh was interviewed under oath by NRC-OI.1 Mr. Mosbaugh cannot recall the 1

Intervenor is relying on NRC's response to GPC's request

' :for documents for the accuracy of the July 18 and 19, 1990' dates.

Intervenor knows-that his interviews. occurred in July but he does

.not have an independent recollection of the dates.

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the hold on the restart of2 Unit 1. This is based'on NRC  !

requirements set out in Diesel Generator ' System Regulatory .

Guide and NRC Branch Technical Position EICS (b) (2) , " Diesel'  !

i Generator Reliability Quality Testing," dated 11-24-95,

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Standard Review Plan' app. 7(a) of NUREG 75/087;2- and NRC Generic Letter 84-15.3 l; I

2. a-c. Intervenor incorporates his response to l Interrogatory 1, subparts a, b and c, as stated above, d.- The 4-18-90 date is incorrect as the conversations occurred on 4-19-90. The conversations occurring on 4-19-90 l were previously identified in Intervenor's response to GPC's j first set of interrogatory questions (the actual conversations -

were produced in the tapes Intervenor provided to GPC) . I j

e. Mr. Mosbaugh saw a list of diesel starts, but does-not know who prepared this list. Intervenor does not recall  !

ever possessing a final list prepared by Webb and/or odem and .

does not have in his custody or control any list he believes were prepared by Webb or odem.  !

3. a. June, 1991.

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b. Intervenor incorporates his response to Interrogatory response 1(b).

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This document requires GPC to establish a 99% reliability at a nominal 50% confidence level for a plant diesel generator system (i.e., both diesels combined).

3 This document states that the reliability goal on a per diesel basis is to be at a minimal reliability level of 95%.

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UNITED STATES . OF AMERICA NUCLEAR REGUIATORY CCHMISSION ATCHIC 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 i GEORGIA POWER COMPANY ) 50-425-01A-3

.th 3.L., ) ~

) Re License Amendment (Vogtle Electrio Generating. ) (transfer to Southern Nuclear) i Plant, Unit 1 and Unit 2) )

) ASLBP No. 93-671-01-0IA-3 AFFIDAVIT OF AL N L. MOSBAUGM l My name is Allen L. Mosbaugh and I am over the age of 18.

The following statements are made under the pains and penalties  !

of perjury and are true and correct to the best of my knowledge and belief.

1. I as the intervenor in the above-captioned proceeding.

2. I hereby certify that the statements and opinions set out in Intervenor's response to Georgia Power's Second Set of Interrogatories are true and correct to the best of my personal knowledge and belief.

AFFIANT SAYETH FURTHER NOT, Allen L. Mosbaugtf V4 ll.liV3 '

Date-054\verifica.aff

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