ML20091H498
| ML20091H498 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/07/1995 |
| From: | Kohn M GEORGIA POWER CO. |
| To: | |
| References | |
| OLA-3-S-096, OLA-3-S-96, NUDOCS 9508110102 | |
| Download: ML20091H498 (49) | |
Text
kh CPC E *)4 i
00CKETED UNITED STATES OF AMERICA USHRC i
NUCLEAR REGULATORY COMNISSION h
ATOMIC SAFETY AND LICENSING BOARD
'95 JUL J8 P4 :01 Before Administrative Judges:
0FFICE OF SECRETARY Peter B.
Bloch, Chair Dr. James H.
Carpenter DOCKETING e SERVICE Thomas D.
Murphy B W CH
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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 at AL.,
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Re: License Amendment (Vogtle Electric Generating
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(transfer to Southern Nuclear)
Plant, Unit 1 and Unit 2)
)
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ASLBP-No. 93-671-01-OLA-3 INTERVENOR'S RESPONSE TO THE SECOND SET OF INTERROGATORIES OF GEORGIA POWER COMPANY Intervenor, 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, Intervenor 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 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.
NUCLEAR REGULATORY COMMISSION De:ket No. 50-4?4/425-OLA-3 EXHIBIT NO.
C,k Ifa94 9508110102 950707
'" '" 'nauer f Go la Pmw Co. et at Voatte Units 1 & 2 PDR ADOCK 05000424 O Staff [H Applicari O lntervenor D Othw 0
PDR.
m identified O Received O Rejected Reporter
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1 statements ma'de.beyond stating that statements contained in this documents and facts related thereto were discussed.
of his Nonetheless, Intervanor believes that ' the transcript interviews with NRC-OI will accurately reflect any discussions occurring at that time.
d.
Since March 20,
- 1990, 1B diesel had problems or j
failures on at least start numbers 1, 2,
4, 5, 13, 14, 15, 17, l
and a problem occurring on April 3,
1990 at 05:15 ' between starts 26 and 27.
Intervenor has not determined the root cause of these failures and problems, but believes that start numbers 13, 15, and 17 may be associated with the problems a
experienced with the A diesel on March-20, 1990.
^
Intervenor objects to responding to this portion of e.
i the interrogatory question as it requires Intervenor to provide a
speculative response.
Without waiving this objection, Intervanor states that the answer is yes.
The bases for this response is as follows: 1) NRC was not fully aware of the extent of the continuing reliability problems i
associated with the Calcon Switchest 2) NRC was not aware that operational problems with the control air system were not i
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corrected; and 3) NRC was not aware that the diesel had yet to i
achieve the required level of reliability.
i f.
Based on a comment from John Aufdenkampe, Intervanor I
was under the impression that information and source documents were provided to Al Chaffee and/or someone on his team by i
persons then reporting to John Aufdenkampe.
Intervenor does 2
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not know the exact date this occurred, and his knowledge is based on hearsay.
Most likely this comment is contained somewhere in the Mosbaugh tape recordings.
Intervenor's best guess as to the time frame is some time between late March and j
i early to mid June of 1990.
Intervenor cannot speak for NRC as to which starts g.
NRC was unaware of having occurring by April 12, 1990.
h.
Intervanor has no recollection of being advised on or before April 9,
1990 that NRC was informed of all of the failures and problems occurring on the 1 B diesel generator that occurred up to that point.
i.
GPC's April 9, 1990 Confir=ation of Action letter states at page 4:
" completion of these investigations,
Based on this statement, if these investigations,
- reviews, tests and corrective actions were not adequately completed, then it stands to reason that the diesel generators may not have been operable.
Intervanor contends that until the root cause of the fmilure was corrected (i.a.,
removal of the calcon j
l switches) and the diesel was proven reliable, it was imprudent to, declare the diescis operable.
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j.
Intervanor contends that at a minimum, the problems f
with the Calcon switches should have been corrected, and that this correction would not include either re-calibration or replacement of the calcon switches (as this activity was 4
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already known to be an ineffective remedy to the root cause of the reliability problem).
j k.
Intervenor recalls being involved with an in-house review of the. feasibility of the replacement of the pneumatic control system, during which time he discussed the benefits replacing the control system would have on the reliability of l
f I
the diesel generator.
Mr. Mosbaugh also consulted with an intervenor group who wanted the control systems replaced. Mr.
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Mosbaugh advised the intervenor group that it was an idea worth consideration and that other plants had replaced their control systems.
1.
Intervenor does not have specific knowledge of 1
information provided to or retained by Al chaffee.
- However, Intervenor does not believe that he knew the extent of the unreliability of the calcon switches or of the true feeling of the Instrument and control group at Plant Vogtle about the calcons.
Yes, the 95% reliability f actor per diesel generator m.
is an ongoing requirement.
As a result of the diesel's failure to adequately perform its safety function when actually called upon to do so, the continuing 95% reliability factor was disrupted.
At that point GPc was required to correct the root cause and establish that the diesel system i
had regained the 99% - reliability factor (and each diesel had regained a 95% reliability f actor) before the diesel system could be declared operable and before NRC should have lifted 4
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c
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I the. hold on the restart of Unit 1.
This is based on NRC l
j requirements set out in Diesel Generator System T F e ---_ f Guide and NRC Branch Technical Position EICS (b)(2), " Diesel 4
Generator Reliability Quality Testing,"
dated 11-24-95, 4
)
Standard Review Plan app. 7(a) of NUREG 75/087;2 and NRC
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j 2.
a-c.
Intervanor incorporates his response to f
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Interrogatory 1, subparts a, b and c, as stated above.
j l
d.
The 4-18-90 date is incorrect as the conversations j
occurred on 4-19-90.
The conversations occurring on 4-19-90 j
were previously identified in Intervenor's response to GPC's 4
l first set of interrogatory questions (the actual conversations i-were produced in the tapes Intervenor provided to GPC).
4 e.
Mr. Mosbaugh saw a list of diesel starts, but does.
not know who prepared this list.
Intervanor does not recall.
i ever possessing a final list prepared by Webb and/or Odem and f
i does not have in his custody or control any list he believes 2
l were prepared by Webb or Odem.
3.
- a. June, 1991.
b.
Intervenor incorpor,ates his response to Interrogatory response 1(b).
i 2
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%.
l 5
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i c.
Intervenor made oral statements regarding the issues
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discussed in the document to Larry Robinson in June of.1991.
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In' addition, prior to the Senate subcommaittee hearings, Intervenor met with Senator Lieberman's aid, Dan Berkowitz, j
and discussed the issues detailed in this document.
Between l
l July 18-19,1990, during the course of a transcribed interview Mr. Mosbaugh provided NRC-OI, Intervanor made additional statements regarding the issues contained in this document.
3 i
d.
On 4-19-90 Messrs. Shipman and Stringfellow stated to Mr. Mosbaugh that they were about to discuss the fact that i
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the diesel generators had experienced failures and trips with Mr. Hairston.
After making this statement, during the course of a subsequent telephone conference call, Mr.
Hairston stated:
"so we didn't have no trips?"
Mr.
Hairston's 1;!
reference to " trips" evidences that he did, in fact, have f.
discussions with Shipman and/or Stringfellow concerning trips of the diesel generator.
l e.
Statements contained in the Six Tapes set out the statements Intervenor knows to have been made.
One such statement not contained in this document concerns a statement made by Mr. Aufdenkampe after April 9, 1990, where he refers to GPC's April 9, 1990 Confirmation of Action letter as a document "where they lied" to the NRC.
s 4.
a-c.
Intervenor incorporates his response to Interrogatory 3, subparts a, b.and c, as stated above.
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5.
a-b.-
This information is set out in the Six Tapes provided to GPC and in the conversations referenced in j
Interrogatory question 3 (a) above.
GPC's counsel had discussed with counsel to Intervenor the desirability of attempting to verify the accuracy of transcripts of these conversations, including the individuals speaking and the statements made.
This future effort-will provide GPC with the information herein requested.
Nonetheless, Intervenor believes the transcripts of conversations set out as Attachments 1 (entitled " Transcript Mosbaugh Tape of conversation A")
and 2 (entitled " Transcript Mosbaugh Tape of Conversation B") hereto accurately reflect conversations occurring on April 19, 1990.
c.
Intervenor formally drew the conclusion that the inaccuracy was willful by 6-13-90, and initially began to draw this conclusion on 4-19-90.
The conclusion was based on the information discussed in the documents referenced in interrogatories 1-4 above, as well as the tape recording of the 3-23-90 Site Area Emergency critique team, and statement l
l made by Cash as to his knowledge of the diesel trips which i
occurred of 3-23-90.
The critique team meeting was recorded
[
by Intervenor and is contained on one of the Six Tapes provided to GPC.
d.
At no time did Mr. Mosbaugh specifically tell any GPC employee that he concluded the inaccuracies were willful out i
f of fear that such an accusation of criminal conduct would 7
4 g
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l result in adverse employment action.
Nonetheless, Mr.
4 Mosbaugh did hint his concerns to John Aufdenkampe.
1 i
e.
Mr. Mosbaugh first contacted the NRC to report the material f also statement sometime in early June,1990, shortly I
before 6-13-90.
He first informed the NRC that these I
statements may be willful in-a June 13, 1990 meeting with
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Larry Robinson.
All documents responsive to this interrogatory have already been produced.
4 f.
J.P. Cash and Ken Burr compiled and counted the start information from a review of control Room Logs following the instruction cash received from George Beckhold to "just get the good stuff."
g.
Intervenor believes that someone should have questioned the accuracy of this language and he will not be able to fully respond until after Intervanor completes the deposition process.
Intervenor objects on the ground of duplication as 6.
a.
this information was provided in response to Intervenor's response to GPC's first set interrogatory questions.
The information is also contained in the Six Tapes and in and 2 to hereto.
b.
Intervenor provided first-hand information demonstrating that this statement was inaccurate on April 19, 1990 to Stringfellow, Shipman and Aufdenkampe.
It was provided second-hand to Hairston and others that same day.
Statements relating to these events are included in the Six 8
Tapes.
On April 30, 1990, Intervenor provided Mr. Bockhold with a written memorandum demonstrating the inaccuracy of this information.
Mr. Mosbaugh began to suspect willful wrongdoing on-c.
or about April 19, 1990 and formally concluded such on June P
13, 1990.
d.
Intervenor indirectly advised GPC the first time when his counsel provided GPC's counsel with a copy of the September 11, 1990 2.206 Petition on the afternoon of September 11, 1990.
4 Intervenor incorporates his response to Interrogatory e.
questions 2a and 3a above.
f.
Yes.
In discussions occurring on April 19, 1990, Mr.
Mosbaugh participated to phone conversations wherein Shipman and Stringfellow were told that language equivalent to this constituted a material false statement.
l g.
Intervenor was present when the phrase " subsequent to I
this test program was being developed for inclusion into the a
LER.
At that time Mr. Bockhold and Mr. McCoy stated t.he following with respect to the number of starts that were to be included in the language of the LER:
l Bockhold:
0.K., so we8ll say greater than those numbers
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l that were used in the conference (held on April 9,1990, at NRC Region II headquarters).
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f d
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McCoy:
O.K.,
and those numbers you used were used in the conference were after they had completed i
the comprehensive test of'the control system 1
on each diesel.
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Bockhold: That is correct, those numbers were not before that time.
{
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i Shipman:
18 and 197 What did you have in your presentation George, 17 and 18, or is and 197 Bockhold: 18 and 19.
The reference to the ccmpletion of a comprehensive test program for the diesel generators is synonymous with the diesel
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testing and start information presented to NRC Region II in on i
April 9, 1990 in a transparency presented by George Bockhold, and which was then reconfirmed in writing in the April 9,
1990 t
f Confirmation of Action response submitted by Mr. Hairston to NRC.
l h.
Yes. The conversations related to this communication l'
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are set out in Attachments 1 and 2 hereto.
I 7.
The PRB and Mr. Aufdenkampe8 s departments prepared the i
revision and sent it to the corporate office by May 15, 1990.
The I
i documents Intervenor is aware of which evidence such a revision are the PRB meeting minutes.
i 8.
Stokes and Kochery prepared a list of diesel start information.
Intervenor does not recall exactly when he reviewed l
this document, sometime between 4-9-90 and 4-19-90.
Mr. Mosbaugh i
either had a copy or wrote down information contained in the
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Stokes /Kochery list.
Intervenor cannot locate either the list I
prepared by Stokes /Kochery or notes he made concerning failures of the diesel generators.
Mr. Mosbaugh also receivert a copy of Bockhold's transparencies on 4-10-90.
l 9.
The tabulation was finished sometime after April 19 but j
before April 30, 1990, most likely sometime in the middle of that time period.
The information was then provided to Mr. Bockhold on 4
April 30, 1990.
10.
Intervanor objects on the basis that the term " successful starts" is not adequately defined and it is not a term defined in s
s Intervenor incorporates his response to Interrogatory d.
11.
10 above.
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12.
On April 19, 1990, Mr. Aufdenkampe was pressed by Mr.
1 i
Shipman to buy into the language contained in LER 90-006 (i.e.,
Shipman stated to Aufdenkampe something to the effect that changing the start numbers would create a huge selling job with the NRC).
At this point in time Mr. Aufdenkampe stated to the effect that if George Bockhold asserts that the number of starts is accurate,
- then, he must be right.
Mr.
Aufdenkampe thereafter made a statement indicating his lack of trust in the accuracy of Bockhold's assertion by stating to Mr. Mosbaugh something to the effect that if Bockhold's numbers are wrong, GPc will have to revise the LER.
13.
Intervenor's knowledge of specific events and knowledge of statements made by GPC employees are contained in the tape 11
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1-
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recordings in the possession of NRC and in the tape recordings 2,
aircady in *.he possession of GPC.
Intervenor objects to providing
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l further information on the ground that the question, as worded, is vague and calls for speculation.
i 14.
Yes.
Mr. Aufdenkampe at least must have had reservations given his assertion to Mr. Mosbaugh that GPC may have to revise the j
j LER.
- Moreover, Mr.
Aufdenkampe previously stated to Mr.
i l
j Stringfellow that he believed that the language concerning the number of starts of the diesel generators set out in a prior draft i
of the LER constituted "a material f alse statement."
l 15.
On April 19, 1990, Vogtle site personnel (including i
Messrs. Aufdenkampe, Bockhold and Mosbaugh) participated in a late afternoon conference call with persons from the corporate Southern i
Nuclear offices (including Messrs. Mairston, Shipman, McCoy and j
Stringfellow).
During this conference call, Messrs. Bockhold, Stringfellow, Shipman and McCoy undertook the task of revising the l
language of the LER and saw to it that the diesel start information l
was consistent with the language previously provided to the NRC on April 9,
- 1990, and at that time included reference to a
"comprehet sive test program."
A subsequent telephone call was j
received 1 Mr. Aufdenkampe from Mr. Shipman. During this call Mr.
Shipman essentially stated to Mr. Aufdenkampe that it would be advisable to adopt the information presented during the prior i
l conference call because to do otherwise would create a huge selling
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job with the NRC.
Higher levels of management approved the language used in the LER during the prior late afternoon conference i
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1-i i
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call.
The follow-up call did not include further action with l
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respect to revising the wording that had been adopted in the earlier late af ternoon conference call.
If anything, Mr. Shipman's f
j subsequent call indicates a gut feeling on his part that lower-1evel management at the site were troubled by the events occurring l
during the conference call and wanted to bring these managers into 1
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the fold.'
f 1
Intervenor objects on the basis of the attorney-client
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and work product privileges.
To the extent that this information a
is not privileged it is set out in the response Intervanor's counsel filed to GPC's motion to compel production of the tapes.
i l
which accompanied the exhibits submitted in 17.
Exhibit 13 l
response to Mr. Mosbaugh's May,1991 Motion for Summary Decision in DOL case No. 91-ERA-11 constitutes a letter faxed to Mr. Robinson i
i by Mr. Mosbaugh's counsel (exhibit pages 1 and 2) together with two additional pages of documentation provided to Mr. Robinson on June i
This document is not the cnly documentation provided to i
13, 1990.
Mr. Robinson on that day.
In this respect, 333 responses to Interrogatory questions 1.a and 2.a, above.
/
Intervanor assumes that GPC seeks a response with respect l
15.
to his answer to GPC's first set of interrogatory questions i
and not Intervanor's response to GPC's first request for documents.
In this respect, Intervenor was referring to i
i Intervenor has no way of verifying whether Mr. Hairston I
was a party to the follow-up phone conversation between Aufdenkampo l
and Shipman, but notes that it was not unusual for managers to listen in on such phone conversations.
d 13 4
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interviews conducted by the NRC OSI.
Intervenor is not currently in possession of these interview transcripts and i
cannot state the date or persons interviewed.
Moreover, as r
GPC is in possession of these transcripts, Intervenor objects l
to further supplementation of this interrogatory question.
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j b(1). In Intervenor's statement on the bottom of page 13, i
the word " approved" or " approving" were used to connote the PRB's normal review process, which includes voting on the recommend language and/or the content of all correspondence l
concerning plant Vogtle and the NRC.
This process was the normal PRB policy and procedure in effect during 1990.
In i
this respect, reference to " approve" means that the PRB i
successfully voted or concurred with recommend language to be forwarded to the NRC.
In this respect, the Corrective Action l
Response letter of April 9,1990, was not presented to the PRB t,
5 prior to its transmittal to the NRC which violated the normal plant practice and procedure that was in place at that time.
b(2). No.
c(1). No.
By June 29, 1990,'GPC submitted to the NRC a revi,sion to LER 90-006.
c(2).
Yes.
Everyone on the April 19, 1990 conference call knew or should have known of the failures and problems with the diesel generators which would have rendered the language contained in the LER false.
c(3)-(4).
Wording related to the comprehensive test program was not in the particular draft of the LIR being discussed 14
l at that time.
The fact remains that Mr.
Mosbaugh and Mr.
I that there were Aufdenkampe notified Southern Nuclear management f
problems and f ailures that were improperly excluded from the diesel i
start data set out in the earlier draft of the LER.
The subsequent i
addition of the comprehensive test program language failed to the underlying factual reason as to why the address or correct l
earlier draft and the LER was materially false.
Finally, the exclusion of specific significant problems, - including important I
trips and failures of the diesels that were specifically identified l
by Mr. Mosbaugh prior to the issuance of the ~ER demonstrates l
intentional wrongdoing by omission.
l c(5). Yes.
Southern Nuclear prepared under the guidance of Mr.
d.
Mairston some 7-8 multiple drafts of the cover letter to accompany the revision to LER 90-006.
These various drafts include differing and conflicting explanation for the t
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inclusion of the false statement in the original LER.
Moreover, the final cover letter to the LER makes reference to record keeping errors contained in the logs.
Inasmuch as there were no record keeping errors with respect to the tripe and problems experience-by the diesel generators, this assertion is materially false.
e.
Intervenor notes that GPC states in this question that this meeting occurred on June 9, 1990 (where Intervenor stated in his response June 8,
1990).
Intervenor believes this meeting occurred on June 8, 1990, when the IIT presented 15
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a report to the Commission and that 'this meeting was attended i
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by GPC personnel. Nonetheless, Intervenor did not attend this meeting and has no first hand -knowledge of who, in fact, 3
attanded this meeting.
- f. - Yes, Intervenor was party to the conference call and i.
i the call was recorded.
j g(1). In response to this interrogatory, intervenor does
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not agree with use of the word
" independent".
It-is Intervenor's understanding that Mr. Aufdenkampe directed his 1
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staf f to compile " start" data from the main control room logs.
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g(2).
No.
Intervenor incorporates his response to t
Interrogatory No. 12 above.
Nonetheless, Intervenor does not i
believe that Mr. Aufdenkampe ussd the word " acceptable."
,i g(3).
GPC already has in its possession all written allegations in the control and possession of Intervanor that were submitted to the NRC.
l h.
Intervanor objects to responding to this l
interrogatory as it calls for speculation.
Intervenor will not determine this until after the deposition process is l
concluded.
19.
Intervenor brought with him the Six Tapes, handwritten i
j notes and two transcripts of conversations included in the Six Tapes.
The two transcripts are attached hereto as Attachments 1 and 2.
Attached as Attachment 3 is a four page document consisting l
of the notes Mr. Mosbaugh had in his possession at the time ha l
. presented testimony before the Senate Subcommittee.
Mr. Mosbaugh l
16 i
-. - ~ _.. - _ - -.
also referred to documents included in the prepared testimony he provided to the subcommittee the day before he presented live testimony.
Mr. Mosbaugh's written testimony and attachments thereto are available for duplication at the law offices of Kohn, Kohn & Colapinto, P.C.
20.
Marvin Hobby.
Intervanor does not recall discussing with any other current or former southern system employee matters concerning this proceeding after october 22, 1992.
Intervenor objects with respect to individuals his counsel may have contacted on the basis of the attorney work product doctrine.
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21.
Intervenor does not recall contacting any employee of any 1992.
Intervenor of the plant Vogtle co-owners since october 22, further incorporates his response to Interrogatory No. 20 above.
Intervenor has previously produced all documents in his 22.
control and possession related to the illegal license transfer.
Respectfully submitted, y-Michael D. Kohn KOMN, KOHN AND COLAPINTO i
517 Florida Avenue, N.W.
j Washington, D.C.
20001-1850 i
(202) 234-4663 i
Attorney for Intervenor i
054\\ inter.2 l
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TRANSCRIPT MOSBAUGE TAPE OF CONVERSATZ W A (A conversati an that allegedly occurred on April 19,1990)
John Aufde-kampe:
i Manager Technical Support Vogtle Nuclear Plant Allen Mosbaugh:
l Assistant General Manager Plant Support (Acting)
Vogtle Nuclear Plant 4
Jack Stringfellow Licensing Engineer South-n Nuclear Operating Company Birmingham, AL i
1 Aufdenkampe: No cormnant.
j l'
2-Stringfellow: Okay.
l 3
Aufdenkampe: Page two.
Stringfellow: Uh.
i o
5 Aufdenkampe: No comment.
6 Stringfellow: Okay.
7 Aufdenkampa: Page three.
8 Stringfellow: Uh.
9 Aufdenkampe: According to the operator, um, third paragraph.
10 Stringfellow: I'm waiting.
11 Aufdenkampe: According to the operator, several annunciators 12 were lit.
Then it -::d= 'in order to restore emergency power... '.
13 (pause) 14 Stringfellow: Power.
15 Aufdenkampe: 'The operator reset the annunciators... '
14 (pause)
4 l
1 Stringfellow: Okay.
l 2
Aufdenkampe: 'Without fully evaluating the conditions...'
3 Stringfellow: Okay.
i 4
Aufda*= r e: And then it goes 'during those times.'
Does r
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that take care of Hairston's comument?
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Stringfellow: Well,.only to the extent that, okay, it it, 4
7~
yeah. tha t ' s...
J 8-Aufdenkampe We don't know what he saw.
i 9
Stringfallow: Okay, we can not say what he saw.
Rj rrht?
j 10 Mosbaugh: The first time...
i 11 Aufdenkampe: What's written here - yeah.
12 Mosbaugh: The first trip?
13 Aufdenkampe: Yup.
14 Mosbaugh: No.
1 i
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Aufdenkampe: What's written here is...
16 Mosbaugh: Operations don't know.
17 Aufdenkampe: What was written here is what he said that his 18 report what he saw.
What I just gave you is...
5 i
19 Stritgfellow: What Hairston wants to see in there.
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20 Aufdenkampe:...is a little bit more than than what he w-w-21 we read his mind in the PRB.
(Laughter)
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22 Stringfellow: I understand.
Okay, so the-but the answer to l
23 Hairston's question is we don' t know, uh, what they actuElly 24 looked at, uh, on that first trip.
25
.ufdenkampe: n.11, you don't wet.2t to say that.
You can't 26 say we don't know what they looked at.
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1 Stringfellow: But we don't know, well, I guess what I'm l
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saying is he...
J 3
Aufdenkampe: What you' re saying is he...
4 Stringfallow:
....where, no, did they look at, you know, did l
5 they look at jacket water temperature and pressure and that sort 6
of thing?
7 Aufdenkampe: No.
i 3
8 Mosbaugh: No.
9 Aufdenh mpe-He didn't lock at much.
10 Stringfellow: Okay.
11 Mosbaugh: The machine...
l 12 Aufdenkampe: He was in a hurry to get power back.
i 13 Mosbaugh: The machine is already tripped.
4
'4 Aufdenkampe: When in and started pressing buttons.
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15 Mosbaugh: The machine is already tripped.
1 16 Stringfellow: His objective was to get the diesel started 17 so, uh, he-they probably thought, well, if I can clear these i
18 annunciators and reset, you know, and reset the thing, than I can l
19 get, you know, I can try and start it again, right?
i 20 Au f de@ ='=ae : We can speculate that that's what he thought.
l l
21 As Allen pointed out the diesel was already tripped so there l
l 22 wasn't much to see on the gauges and stuff.
23 Stringfellow: That's a point.
)
24 Aufdenkampe: So.
25 Stringfellow: Yeah.
Okay.
But that's, in other words, 26 that's all,'in-in response to Hairston's concern, that's all we 4
1
I 4
t 1
can we think we can say.
2 Aufdenkampe: Yeah.
1 3-Stringfal1N: All right.
l 4
Aufdenkampe: Go on to page, uh, the next page.
5 Stringfellow: Yes.
6 Aufdenkampe: Site area emergency.
Was declared at 8:40.
1 agencias of the of the emer.., uh, government agencies of the 7
Uh, 8
emergency at 8:48 central standard time.
d 9
Stringfellow: Uh-huh.
4 10 Aufdenkampe: Period, 11 Stringfellow: Okay.
i 12 Aufdenkampe: And delete the next,
'n, to the end of the 1
13 line.
14 Stringfellow: Okay.
j 15 Aufdenkampe: There.
Now, it doesn' t-now, it doesn't ask the 16 question wh-why it took us seventeen minutes.
i f
17 (Laughter) t l
18 How's that?
19 Stringfellow: Well, all right, we can try that.
In other i
'words, we can't say that that-that. part of that seventeen minutes 20 21 was due to the problem with the ENN.
l 22 Aufdenkampe: Not specifically.
23 Stringfellows Not specifically.
Okay, well, I-I think that-if we can't 24 that may be okay, because Hairston said, you know, i
35 say that, then he wanted to reword it, to take it-to not have the l
26 time in there.
Okay?
1
l 5
1 Aufdenkampe: Well, that takes care of that.
-2 Stringtallow: Yeah.
3 Auf dantrampe: Take out the time out.
4 Stringfellow: Alright.
L 5'
Aufdankampas okay, the next one was your sentenca you gave i
6 me - for direct cause.
7 Stringfellow Yeah.
8 Aufdenkampe: Thac went through. fine and his rrunmanes about.
9 an off site source went through fine Uh, the next page - root 10 cause.
11 Stringfallow: Mmharm.
12 Aufdenkampe: No coment.
The next page.
On the twenty 13-starts.
1.4 Stringfellow Yeah yeah yeah.
.5 Aufdenkampe: I'm struggling with that one.
16 Stringfellow: You struggle with that one, huh?
17 Aufdenkampe: I'm struggling with that one.
I'm trying to 18 verify that still.
19 St'ringfellow: Oh, okay, alright.
20 Aufdenkampe: Okay, uh, we think that it's basically a I
21 material false statement.
22 Stringfellow: Really?
1 1
23
~Aufdenkampe Yeah.
Well, we know for a fact that the B I
24 diesel tripped at least once.
After March 20th.
25 Mosbaugh: Actually, it trip-tripped twice after March 20th.
26 or it' had at least two separate problems.
t 6
~
l l
1
.Stringtallows Well, do we need to take this more than 20 i
2 times each out,tt.an?
4 3
Aufdaalr= 7.: That's what we'rs thinking, but I got Tosa Webb 4
reviewing the-the, uh, reactor operator's log and counting.
5 Stringfellows okay.
j 6-Aufdenkampe I don't know where he's at.
When's Mairston's
^
j 7
due back in the office?
l 8
Stringfellows He's supposed to be there now.
9 Aufdenkamper-Oh, so you gotta hurry and get this up here, L
10 huh?
l 11 Stringfellow: Well, yeah, yeah.
Well, I've, see, I-I have W
12 given him, I-I've given Shipman, you know, uh, the ver...,
a 13 typed version of what you guys have been looking at, so now-now
'4 as soon as we get off the phone, I'm gonna run back in there and i
15 tell him what you told me, you know?
4
,i 16 Aufdenkampe: Okay.
Uh, so anyway, I'm still looking for I
17 words for you on that one, but what that-that sentence is gonna 18 have to change.
1 19 Stringfallow: Okay.
What about, uh, the thing about, did 20 you get say message on your machine?
I 21 Aufdenkampe: Yes.
I I'm-I'm getting to that.
22 Stringfellow: Okay, I'm sorry.
23 Aufdenkampe: Next page, on corrective actions.
That went-i 24 went through fine.
25 Stringfellow: Okay.
j 26 Aufdenkampe: Okay, now, last page.
I
I i
i 1
l 1
Stringfallows Okay.
2 Aufdankampe: Itest six.
Uh, we've reworded that one 3
substantially.
I i
4-Stringfellow: Oh, alright.
+
5' Aufdank==pa: Okay, you ready?
6 Stringfellow: Yeah.
i 7
Aufdenkampe: Uh,
- A-back up ENN systest powered froot the AT&T i-8 systems which previously existed and was operational for South l
9 Carolina agencies has been extended to include Georg)
- local, 10 and state agencies.'
i 11 Stringfellow: 'Has been extended to include Georgia and l
l 12 local and state agencies.'
13 Aufdenkampe: Yes.
Okay, and then cross out the entire last j
14-sentence...and write this.
.5-Stringfallow: Oh, alright.
Okay.
i 16 Aufdenkampe:
' Instructions...have been given...to...
17 emergency directors...and consnunicators...concerning...use...of 18 the... emergency consnunication systems. '
{
13 Stringfellow: Systems plural?
j j
20 Aufdenkampe: Systems - plural.
)
21 Stringfellow: Okay.
I 22 Aufdenkampe: That's what they said.
l
)
23 Stringfallow: Let me read it back.
' Instructions have been 24 given to emergency directors and consnunicators concerning use of t
j 25 the emergency communication systems.'
l 1
j 26 Aufdenkampe: Is that right, is it? Systems?
That's on that 4
i f
l J
k
8 i
I George letter, do you have that?
I think I got. that....That-l 2
that-that's-that's, if I still have it.
George, uh, All n has a 3
hard time with with using that, but...:aa didn't vote.
- aughter)
He abstained due to the lack of review time.
4 5
Nombaught I happened to be an emergency director.
6 Aufdankampas Are you an emergency director?
7 Mosbaugh: Yeah.
i j
8 Aufdankampa Really?
9 Mosbaug" An-an-and I-I haven'
- felt-feel I've been gitan 10 very much.
11 Aufdenkampe: But you've been given something, right?
j 12 Mosbaugh: I've been given one sheet that I got with my badge L'
13 one day.
l Aufdenkampe:
I can't find it.
15 Stringfellow: Well, we had systems in there before, so I 16 quess that's a-chat's okay.
i i
17 Aufdenkampe: Okay.
18 Stringfellows okay, uh, oh, uh, on number five, uh, they've j
19 identified, instead of just. saying a laboratory test program, j
20 they said, uh, uh, they identified Wyle Laboratories.
21 Aufdenkampe: Yeah, that's why it got in.
In addition, a i
22 test program will be conducted at Wyle Laboratories.
23 Stringfellow: Okay, okay, good, you got that.
- Alright, 24 okay, I'm sorry.
I thought maybe Shipman might have adjusted i
25 something af ter I called you, but apparently not.
Okay.
Good.
i 26 Alright, John, I think we've we've, uh, let's see, we're down to,
9 we' re down to the twenty-twenty times each question.
1
- now, 2
Aufdenkampe You want me to hold on, see if I can get ahold 3
of, uh, Tom WeP', real quick?
4-Stringfellow: Yeah, I'll be glad to.
5 (phone dials-rings) 6 Aufdantr==pe: This one is a killer.
7 Rick Odom: Hey, John.
8 Aufdenkampe Hey, do you know if Tom Webb's, how Tom Webb's
.~
o-doing?
..,. c n - c, 10
. Odom:.He was, uh, heading ove o the control ro'om,d M-7.;
y' 7
,w<
.,?
A.dtd have two or three days heres.INd the logs?
11 <
/
12 Aufdenkampe: Yeah?
13 Odom: He's at the control room to fill it in.
'd.
Aufdenkampe: Okay.
Is he gonna call back, well, who's he 15 gonna call when he finds out?
i i
16 Odom: I think he's gonna come back, I think.
Is there, i
l 17 okay, is he going in the LER?
l l
18 Aufdenkampe: Uh, yeah.
l 19 Odom: Oh, and you know this is not gonna be val-valid l
20 information now?
It's gonna be control room, which is, and then 21 you gotta interpret whether it's a valid start or, you know, 4
f 22 valid attempt or not.
23 Aufdenkampe: Oh, he-all-all-we aren't at, looking for valid i
24 failures or invalid failures, all we're looking is for starts and 25 not-and trips.
That's what he's looking at, right?
26 Odom: I told him valid failures, I said valid starts and l
i
[-
n
4 10 val... ( ? ).
Yeah, starts and failures is what I t'old him.
i 2
Mosbaugh: The word-the wording in the LER that came from 3
corporate did not. use the word valid.
4 7: Yeah.
5 Odom: Well, he-he can't do that anyway, log don't call you 6
whether it's valid or not.
7-Aufdenkampe: Right.
8 Mosbaugh: Yeah.
9 Aufdenkampa-I understand.
And-and that's cause p.= doesn't 10 make that determination.
~
11 Odom: Right.
4 12 Aufdenkampe: Okay.
13 Odom: Okay, I'11 find out where ha's at.
Aufdenkampe: Yeah, you-you better.
Jack's on the other line
't 15 waiting.
16 Odom: Alright.
2 17 Audenkampe: Okay.
Thanks.
i 18 Odom: Sure.
9 4 $(phone hangs up) 19 0
20 3
Aufdenkampe: You there still?
M 21 Stringfellow: I'm here.
22g g,
Aufdenkampe: We don't know yet.
2 b
Stringfellow: We don't know yet.
But now, you know, I~just-In 24 it it just dawned on me what Allen was saying a minute ago.
25 other words, if we say 'and no failures or problems have 16 occurred during any of these starts,' you-you're saying that
11 i
l l
1 that's not true.
2 Aufdenkampe: Yes, I'm saying that's not true.
3 Stringfallows oh, wonderful. Okay.
I 4
Aufdenkampe: So, which is also telling you that, it's j
5 telling you something else I imagine.- Cause you know we, this is l
6 certa.., been written to the NRC once already.
7 Stringfellow: Yes, I know.
That-that's exactly what I was j
8 thinking.
J 9
Aufdenk Te-So, I'm working on that.
3 l
10 Stringfallow: Alright, John.
Okay, well I'll be patiently j
.11 waiting.
Or impatiently waiting, or hcwever you want to look at j
12 it.
f Aufdenkampe: Okay.
Well, I must be off.
j 13
'4 Stringfellow: Thanks.
15 Aufdenkampe: Bye.
16 Mosbaugh: You got that other letter?
i i
17 Aufdenkampet Huh?
l 18 Mosbaugh: Do you have that, uh, do you have Hairston's, j
is uh...
20 "Audenkampe Yeah j
21 mosbaugh:... confirmation and action response...
j 22 Aufdenkampe: Yeah.
23 Mosbaugh:... letter?
}
24 Aufdenkampe: Yeah.
25 Mosbaugh: Cause that's the one they, where they...
26 Aufdenkampe: Where they lied.
l J
1 12 i
i i
1 Mosbaugh:
...uh, incorporate...
2 Aufdenkampe: I mean they...
i
...nada that statsmant previously.
3 Mosbaugh:
Mr. Kenny, what are you doing down here sir?
5 4
Aufdenkaape:
5 Kenny Stokes I cCune by to say hallo, and see if, uh, I can talk to you a.Little about this connoseal, blow-down question.
6 You mean it's going to be done Friday?
i 7
Aufdenkaape 8
Stokes: It's going to be done tomorrow.
It snay be done 4
f 9
today.
j 10 Mosbaugh: That-that that went to you guys?
i 11 Stokes: Yeah.
1 i
12 Mosbaugh: Want to Cliff and then went to you?
1 l
13 Stokes: Yeah.
4-Mosbaugh: Letsne-let me see if I can't, uh, pull sorne, uh, 15 diesel stuff from Kochery.
I 16 Aufdenkampe: Okay, Ken Stokes is working on that.
17 4
l.
1
}
i l
i I
I.
I
(
L i
i l
I
4 ATTACHMENT 2 j
7 t
TRAllSCRIPT I
NOSBAUGE TAFE OF CONTERSATZW B (A conversation that allegedly occured an April 19,.190)
)
4 Bill Shipman General Manager, Nuclear Support j
Southern Nuclear Operating Company I
sirmingham, Alabama t
l Allen Mosbaugh:
Assistant General Manager l
j Plant Support (Acting)
Vogtle Nuclear Plant i
i '
s i
i 3
1 (dial phone, rings) i 2
Shipman: Hello.
i i
3 Mosbaugh: Yeah, this is Allen Mosbaugh.
1 4
shipman: Hey, Allen, this is Bill Shipman.
5-Mosbaugh: Say Bill. A.Jt Tg we 6
Shipman: - -" *re you can talk for a minute?
g l
d
\\
7 Mosbaugh: I am.
8 shipman: Great. I I I....Helo!
e l
9 Mosbaugh: Okay.
i the, uh, uh, LER, we' re we're, you know, we're 10 Shipman: Uh, i
11 trying to get all this Hairston's questions answered.
t f
12 Mosbaught Right.
l 13 Shipman: Uh, there are two things, uh, I guess, uh, George 14 has asked us, you know, to-to find out, and, and, uh, I guess you were, you and, you probably were with Tom at the time talkinq 15 16 with Jack and-and Jack's, uh, answered, uh, I:quess, one of the questions and the question has to do with, uh, when the, uh, 17 operators went into the diesel panel the first time.
4 l
l i
2 l
]
Mosbaugh: Right.
it has to do with whether they observed any of 2
shipman: Uh, the insenamentation or whether they just went and, and, uh, 3
l 4-noticed the annunciator's, uh, lit and reset the annunciators.
4 f,
5' Uh. George has remembered hearing somewhere that-that the operators looked at some pressure gauges or something for some of 6-l "I
the diesel engine, uh, functions before they reset the annunciators and, you know, I don't-I don't know what the s
1 8
9 operator did, b"- he's so insista'st in-in trying to respond to-l 10 get a response to that question.
I wonder did the operator or i
the operators who was on-on-shif t or went into the diesel roomt at i
11 12 that time, is on-shift now, and-and somebody could ask him a l
'3 direct question.
44 Mosbaugh: I'll find him and, um, we'll get him on the phone.
i 15 Shipman: That would bt great.
16 Mosbaugh: Uh, you know, I-I I mean, uh, he may, he may not j
17 he on shift, which case we can try to reach him at home, you 1
18 know, we can I can go do all that.
t 19 Shipman: You you understand, Allen, that...
My understanding is that I don't think they looked 20 Mosbaugh:
21 at much.
22 Shipman: I don't either.
l 23 Mosbaugh Okay, I-I was in the critique, I-I don't, I'did-I 24 did, uh, I did, uh, was in the meeting with Al Chaffee and the team when they interviewed the operators that first responded to 25 the panel and-and I recall them telking to Al Chaffee about that.
i f
= to
~._.... ___
,i the gist of that conversation is i
1 Uh, but, uh, you know, they, Aad-and tha*. they didn't scrutinize things very much, you know.
2 indeed the d' asel had already tripped, so when they got into the I
3 it was, uh, a good number of, well, it was minutes later, 4
- rooms, Nobody was in the room when and the machine had already tripped.
i j
5 the machine tripped, and, uh, so all they could have observed.
i 6
you know, when they got in was what remained lit at that time l
7 uh, machine parameters Rat-that were still-still l
8 and-and any, k'sically That's all that was J
i valid with the machine tripped.
9
\\
t Hello?
Hello?
l 10 available to observe.
(hangs up phone, dials again, rings) 11 I
Shipman: Hey, Allen.
f 12 Something happened.
l 13 Mosbaugh:
Something about the time you started telling me 14 Shipman:
l sitting with, uh, Chaffee..
i 15 about, uh, i
16 Mosbaugh: Yeah.
l 17 shipman: We sort of left lost you.
um, anyway, I was in there, and 18 Mosbaugh: Okay (laughs),
you know, respond that they saw 19 like I say, they-they didn't, indeed nobody was in the room when it tripped.
20 very much, l
21 Shipman: Right.
All they It tripped before they got to the room.
1 Mosbaugh:
22 could have seen, all that would've been available to see, uh, 23 i
would be whatever annunciators remained lit and whatever eng ne j
24 parameters remained valid with the machine stopped.
25 26 Shipman: Right.
4
1 1
i 4
4 4
1.
Mosbaught So, so that doesn*t, you know, leave a whole lot.
l 2
Shipman Okay.
j 3
Mosbaugh: And-and-and I believe that, you know, they cleared the annunciators, uh, you know, without without auch, uh, uh, 4
i j
5-assessment.
l
'6' Shipman: Well, I put myself in their place, and-and-and I.
would walk in the room and say, yeah, there are some annunciators i
7 l
'em, and all the things that would've cleared, 8-lit and-and reset 9
would've cic.rac and those that were still valid, the alarms 4
l and I'd a would have gone on with trying 10 would've remained lit, la to get the diesel started.
And, so L you know, I don't...
l 12 Mosbaugh: Yeah.
...have a a problem with what we got written, but i
13 shipman:
)
j
.4=
George does and and, uh, I just need to get a...
15 Mosbaugh: Yeah, okay, well, let me let me do my best there.
if he's here, I'll try to find, see if the operar.or is here, uh, I
16 I
j 17 we'll try it again, and if he's, uh, at home, we'll try to call' and, um, you know, see if I can set that up, so we can, uh, 18
- him, s
19 ask the questions.
Okay, and the other, of course, the other question 20 Shipman:
l g p we've been try'ing to to get an answer to is to-to (noises) l 21 reassure George we had, uh, more than 20 valid starts since, you 22 23 know, since March the 20th, uh, like we say in the LER.
f you realize, I think there's a problem 24 Mosbaugh Yeah, that, with the way that's stated because, you know, the machine, you 25 I-I, we can, you know, there there, we got one of the guys 16
- know, 4
e i
I
5 1
.trying to find what the total number of of valid starts is, but 2
there were failures.
3 Shissaan: Yeah, The problest that we got, Allen, is
- .s that I
the data that's in the LER is what George wrote and took and told 4:
l 5
to the Ebneter last Monday in Atlanta.
6 Mosbaugh: Well, you know, if if anybody says that, uh, there i
j 7
weren't-any failures, you know, that-that's just not true, 8
Shiganan: Well, if you look at George's outline, that that ha made to take to Atlanta with him, he says, at that time Lt was 9
4 10 like eighteen and nineteen.
t l
11 Mosbaugh: Yeah.
12 shipman: And, uh, and and, without a failure, i
13 Mosbaugh: He.
.4-Shipman: So, you know, somebody had given George that i,
j 15 information, uh...
16 Mosbaught on the B...
17 Shipman: (7) we had a failure since George went to...?
f l
18 Mosbaugh: No.
On the B, let me let me tell you what I'know, 4
19 okay?
On.the B machine, um, on the 5 machine on, uh, three i
20 twenty two, at, uh, twelve forty-three, the machine tripped on 21 high lube oil temperature.
I 22 Shipman: Caused by what?
i l
23 Mosbaugh: caused by the switch that gives you high lube oil 24 '
temperature probably (laughs).
25 Shipman: No, I understand that, but did we-did we not have, l
6 uh...
t 6
I I don't believe high a high toeparature physical 1
Mosbaugh:
2 condition existed.
I-I, uh, I believe....
1' WLa that a valid, considered a valid failure?
t j
3.
Shipman:
I' haven't assessed these for being valid or not.
l 4
Mosbaugh:
You see, because I could, we could we could solve 5
shipman:
the problem that's created by that information by saying *no 6
f 7
valid fallures.'
8 Mosbaugh: Let me, uh, let me find, I think we got one other On three twenty-three at seventer-thirty-j 9
one.
Um, here it is.
10 one, machine tripped on low, this is B machine again, on low jacket water pressure slash turbo lube oil pressure low.
11 the-the first one was on what date did you J
l 12 Shipman: Okay, i
4 13 say?
I 14 Mosbaugh: Three twenty-two.
how-how, you know, with that data, um, uh, I 15 shipman: Okay, think this things already been to ".he PRB a coupie of times.
How 16 17 in the world did it get through the PR57 4
18 Mosbaugh: What's that?
2 19-Shipman: The statement.
20 Mosbaugh: The LER or...
21 Shipman: Yeah, the LER.
22 Mosbaugh: Well, I mean...
23 Shipman: Did that that data not, was not available in the l
j 24 PRB7 The previous times that this LER went through the l
25 Mosbaugh:
I'm not sure if those statements were in there.
'25
- PRS, A
e e-w m-o--
7 i
t j
4 1
Shipman: Yeah, Jack says yeah they were.
j l
Mosbaught They were?
j L
i e
3 Shipman: Yeah.
the last PRB added the parenthetical l
j
'4 Stringfellow: In fact, I say the last, not l
phrase a 'more than twenty times each'.
~
today, but the previous PRB.
6 it came to the PRB, you 7
Mosbaugh: You-you know, this thing, i
the first time, and then it was, you 8
know, fifteen pages long, know, basically sbled for a complete rewrite back to eight 9
4 i
10 pages.
- And, uh...
It. went back to the PRB as eight pages.
l 11 Stringfellow:
- And, uh...
And then it went back as eight.
i i
12 Mosbaugh:
13 shipman: Well...
I 4-Mosbaugh: Anyway...
f shipman:... (unintelligible) that whole question is f
15 l
16 immaterial, and, you know, it's just that, it's just sort of a uh, what-what we need to do is find out what's 17 bother, but, i
correct and make sure we only say what's correct.
l 18 you know, what I have here is is, i
Mosbaugh: Yeah, I, now I, e
19 there was a tabulation made of diesel activities, you know, p
l 20 uh, and-and that's where I'm getting this f
21 early.on, uh, by Kochery, I believe these, uh, I believe this 22 information from, and, uh, i
tabulation was provided to the Chaffee team.
23 the, uh, uh, I think people have been l
l 24 Shipman (cough) Well, reviewing the diesel generator log, but-but that's, but only i
25 because we thought the other day that only went through the 16 l
m
.=
- - -. -, = -
l l
8 1
thirteenth.... (unintelligible) 2; Mosbaugh: Yeah.
3 Shipman: (unintelligible).
Somebody did save it.
this data picks up on the thirteenth.
i 4
Mosbaugh: Yeah, 5
Shipman: Yeah, somebody, gosh, somebody saast have looked.
j I
Uh uh, Allen, would you take that as a-as a second thing and a d 6
Sounds like try to give me the correct information for that?
l 7
this whole statement needs to be just stricken.
8 3
I I-I basic'.11y don't have any better l
9 Mosbaugh: You know, than the two trips, uh, that I told you i-10
'information than the two, i
i 11 about on the, uh, twenty.second and...
Okay, are you-can we-can we determine if they I
12 Stringfellow are valid, if those are valid tests or valid failures?
1 l
13
.4 Mosbaugh: Let me let me talk to, uh, Stokes and Kochery
}
15 aboue *em.
16 Shipman: Yeah, I-I guess, uh, oh, in the point we're in now, 17 where this thing has been in the, in PRB several times and we've had several review cycles up here and everybody's, uh, gotten i
18 i
19 accustomed to sseing thae data, if if-if-the we could use the to, if it's certain, if it's not a valid 4
20 data we probably ought 21 statement, wa-then we need to get it the heck out of here, So, you know, 22 regardless of what George has told, uh, Ebneter.
if there's anything you need to do to check to make 1
23 if (noises) sure that the data you have from Paul is is correct and valid, 24 1
25 uh, would ask that you do that.
Or if you feel very confident I
I just need to see what I need to do i
16 that it is correct now, 1
I l
j i
i I
about striking this statement.
I, you know, I-I feel this is the be4t-the 2-Mosbaugh: okay, I:v'11 verify best data there is, and I-I believe it's accurate.
3 4
with Kochery though.
5 shipman: Okay.
4 uh, a.
j And I will, uh, pursue trying to get, G-Mosbaugh:
h l
7 conversation with the operator.
Jack and I are going to leave here and walk j
8 shipman: Okay.
uh, go over hir - ::enants down to_Mr._.Hairston* s of fice to, ut l
9 and what we've been able to do with those and, uh, try to, you i
l 10 Uh, finish beating out what he wants to do to this thing.
11
- know, find armaaha'4y and want to and if, so if you want to, you know, l
12
,. call back, you might just, you might just call down there.
13 l
i As Mosbaugh: What's the number?
15 shipman: 5581.
16 Mosbaugh: Okay.
17 Shipman: That's right.
Okay.
Will do. We're-we're-we are ir. to the-the i
i 18 Mosbaugh:
i 13 tortional test.
We are in to it.
i i
20 shipman: Great.
Yeah, we we spun the machine up to 1800, had a 21 Mosbaught 1.ittle problem with the, uh, a, um, seal oil, uh, emergency pump 22 and, uh, we're, uh, we're coming on, adjusted to the set point, l
23 24 back down, uh...
25
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[
l L.
l i-UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION 1
I ATOMIC SAFETY AND LICENSING BOARD
).
j In the Matter of
)
)
Docket Nos. 50-424-OLA-3 J
l GEORGIA POWER COMPANY
)
50-425-OLA-3
.et A,
)
j
)
Re: License Amendment l
(Vogtle Electric Generating
)
(transfer to Southern Nuclear) l Plant, Unit 1 and Unit 2)
)
)
ASLBP No. 93 -671-01-O LA-3 l
CERTIFICATE OF SERVICE I
i l
I hereby certify that on August 11, 1993 a copy of 4
l
'Intervenor's Response to the Second Set of Interrogatories of 1
i Georgia Power Company was served via First Class Mail upon the f
following:
h Administrative Judge Peter B.
Bloch, Chair Atomic Safety and Licensing Board l
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 i
Administrative Judge Dr. James H. Carpenter Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission l
Washington, D.C.
20555 i
i Administrative Judge l
Thomas D. Murphy j
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Charles A. Barth, Esq.
Office of General Counsel
}
U.S. Nuclear Regulatory Commission Washington, D.C.
20555
~
John Lamberski, Esq.
Troutman Sanders Suite 5200 600 Peachtree Street, N.E.
Atlanta, GA 30308-2216 t
e
4 i
l e
UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
{
l Before Administrative Judgess Peter B. Bloch, Chair jl Dr. James M. Carpenter Thomas D. Murphy j
i
)
l In the Matter of
)
i
)
Docket Nos. 50-434-OLA-3 i
GEORGIA POWER COMPANY
)
50-425-OLA-3 l
- 17. &,
)
)
Rei License Amendment j
(Vogtle Electric Generating
)
(transfer to Southern Nuclear) 1 Plant, Unit 1 and Unit 2)
)
)
ASLBP No. 93 -471-01-OIA-3
)
i AFFIDAVIT oF ALLEM L.
MOSBAUGM
,i l
My name is Allen L. Mosbaugh and I am over the age of 13.
l The following statements are made under the pains and penalties 4
f of perjury and are true and correct to the beat of my knowledge i
and belief.
1.
I am the intervanor in the above-captioned i
j proceeding.
l 2.
I hereby certify that the statements and opinions est out in Intervenor's response to Georgia Power's Second Set of Interrogatories are true and correct to the best of my personal 4
\\
i knowledge and belief.
l-AFFIANT SAYETH FURTHER NOT, i
VM. //,lV93 l
Allen L. MosbaugW Date-054\\verifica.aff 4
1
c.
4 (continued on next page]
l Ernest L. Blake, Jr.
i David R. I.mwis SHAW, PITTMAN, POTTS &
TROWBRIDGE 2300 N Street, N.W.
Washington, D.C.
20037
- 0ffice of the secretary
(* original and two copies)
Attnt Docketing and Service i
l U.S. Nuclear Regulatory Commission Washington, D.C.
20555 i
office of Commission Appellate l
Adjudication U.S. Nuclear Regulatory Commission Washington, D.C.
20555
)
By:
Michael D.
Kohn Kohn, Kohn & Colapinto, P.C.
517 Florida Ave., N.W.
Washington, D.C.
20001 (202) 234-4663 a
l 054\\ cert.dt a
i l
1 4
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2
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