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Category:AFFIDAVITS
MONTHYEARML20094J9201995-11-0101 November 1995 Affidavit of Ck Mccoy to Correct Info Contained in Intervenor Exhibit II-97,which Consists of Portions of Deposition in a Mosbaugh Complaint Against Gap ML20092M6721995-09-28028 September 1995 Affidavit.* Affidavit of Gr Frederick Re Recollection of Recommendation Made to Keep Special Record of Diesel Testing Activities ML20092M6771995-09-28028 September 1995 Affidavit.* Affidavit of H Handfinger Re Review of Documents & Amount of Involvement of Quality Control Organization. W/Certificate of Svc ML20092H6621995-09-20020 September 1995 Affidavit.* Affidavit of MD Duncan Re Testimony on 950609, Concerning Alnor Test Instrument ML20092H7211995-09-19019 September 1995 Affidavit of J Lamberski.* Discusses Violations of NRC Regulations at Plant,Filed by a Mosbaugh W/Nrc.W/Certificate of Svc & Svc List ML20092H7891995-09-13013 September 1995 Affidavit.* Affidavit of Kc Stokes Certifying That Statements & Opinions in Such Response True & Correct to Best of Personal Knowledge & Belief.W/Certificate of Svc ML20087C0621995-07-31031 July 1995 Affidavit.* Affidavit of D Huyck Providing Info Re Entrances & Exits for Secured Areas of Plant by E Dixon ML20085M1601995-06-23023 June 1995 Affadavit.* Affidavit of J Aufdenkampe Re Info Re Reporting of Safety Sys Performance Indicator Data ML20083L5161995-05-12012 May 1995 Affidavit of Kr Holmes Discussing Evaluation of Test Plan for 1A Diesel Following 900320 Site Area Emergency,In Order to Determine Root Cause of 900320 Diesel Failure ML20083L5801995-05-11011 May 1995 Affidavit of G Bockhold,Describing Decision Making Involved W/Util Determination as of 900409,that Plant Diesels Operable & Capable of Performing Intended Safety Functions ML20080S9301995-03-0303 March 1995 Affidavit of Ck Mccoy Re Events Surrounding Util Statements to NRC in Respecting Plant DG Instrument Air Quality ML20080E1021994-12-27027 December 1994 Affidavit of Lk Stevens Re Review of Public Affairs Dept Files,Including Articles,Speeches & Press Releases Re Formation of Sonopco Project or Southern Nuclear Operating Co ML20080E0951994-12-23023 December 1994 Affidavit of LB Long Re Formation of Sonopco Project or Southern Nuclear Operating Co Concerning Files in Possession of Employee While Under Util Employ ML20080E1011994-12-22022 December 1994 Affidavit of T Wright Re Review of Util Publication Entitled This Week for Documents Dealing W/Sonopco Project or Southern Nuclear Operating Co from 880101-901231 ML20076K1431994-10-13013 October 1994 Affidavit of MD Kohn.* Affidavit Stating That Author Has first-hand Knowledge Re Factual Assertions That Represent Substance of Corresponding Statements Made by Deponent in Author Presence ML20024J3051994-10-0303 October 1994 Affidavit of Fr Allenspach & Ds Hood Re Util Motion for Summary Disposition of Alleged Illegal Transfer.* Informs That No Error Found in Factual Assertions of Util. W/Certificate of Svc ML20070A8961994-06-22022 June 1994 Affidavit of John O Meier.* Certifies That Listed Statements True & Correct to Best of Personal Knowledge & Belief. W/Certificate of Svc ML20029D9421994-05-0606 May 1994 Affidavit of Mj Wilmoth.* Affidavit Re 940412 Conversation W/M Kohn Re Close Call When Red Sports Car at Corner of Ofc Building of Troutman Sanders,Nearly Missed Running Him Down ML20059L9891993-11-0808 November 1993 Affidavit of Wg Hairston Re Reputation of Util & Mgt Continuing to Be Adversely Affected by Stigma Associated W/Wilful Wrongdoing.W/Certificate of Svc ML20059E9071993-10-27027 October 1993 Affidavit of RA Fortuna.* Requests That Investigation Matls Collected During Ongoing Investigation Be Withheld from Disclosure at Least Until 940218 to Allow More Time for Completion of Review.W/Certificate of Svc ML20059E8981993-10-27027 October 1993 Affidavit of J Lieberman.* Requests That Investigatory Matls Collected During Ongoing Investigation Be Withheld from Disclosure at Least Until After 940218 ML20056G5231993-08-25025 August 1993 Affidavit of J Lieberman.* Provides Info Re Status of Ofc of Enforcement Activities Re Alleged Violations of NRC Requirements by Util to Support NRC Request That Board Defer Decision on Util Motion.W/Certificate of Svc ML20056G5221993-08-24024 August 1993 Affidavit of Bb Hayes.* Provides Info Re Status of Ofc of Investigations Activities Re Investigation of Alleged Misconduct by Util Re Reporting of Diesel Generator Reliability ML20045G9721993-07-0101 July 1993 Affidavit.* Affidavit of AL Mosbaugh Re Statements & Opinions Set Out in Intervenor Response to Licensee First Set of Interrogatories.W/Certificate of Svc ML20045G9341993-06-30030 June 1993 Affidavit.* Affidavit of AL Mosbaugh Re Statements & Opinions Set Out in Intervernor Supplemental Responses to Util First Set of Interrogatories.W/Certificate of Svc ML20045D2351993-06-0909 June 1993 Affidavit of MD Kohn in Support of AL Mosbaugh ML20045D2411993-06-0808 June 1993 Affidavit of AL Mosbaugh.W/Certificate of Svc ML20083B6691991-09-0606 September 1991 Affidavit of G Carroll Re Georgians Against Nuclear Energy Interest Re Appropriate Testing Schedule for Facility Being Inadvertently Omitted from 910809 Amend to Petition for Leave to Intervene.W/Svc List ML20076N1231991-03-18018 March 1991 Affidavit of Jd Lisenby in Support of Applicant Response to Board 910122 Memorandum & Order ML20076N1461991-03-15015 March 1991 Affidavit of Kc Stokes in Support of Applicant Response to Board 910122 Memorandum & Order ML20076N1501991-03-11011 March 1991 Affidavit of C Meyer in Support of Applicant Response to Board 910122 Memorandum & Order ML20076N1121991-03-0707 March 1991 Affidavit of Wf Kitchens in Support of Applicant Response to Board 910122 Memorandum & Order ML20076N1321991-03-0707 March 1991 Affidavit of L Ward in Support of Applicant Response to Board 910122 Memorandum & Order ML20062F7231990-11-14014 November 1990 Affidavit of L Ward in Support of Applicant Supplemental Statement Re Matters Raised by Board.* W/Supporting Info & Certificate of Svc ML20059M0211990-09-18018 September 1990 Affidavit of DB Matthews in Support of NRC Staff Response in Opposition to Georgians Against Nuclear Energy Amended Petition for Leave to Intervene ML20214W2381986-12-0303 December 1986 Affidavit of Sj Cereghino,Wv Cesarski & G Bockhold Re Statements in Hm Deutsch 861126 Affidavit.Certificate of Svc Encl.Related Correspondence ML20214W1791986-12-0202 December 1986 Affidavit of Sj Cereghino & Wv Cesarski Re Temp Margins in Environ Qualification by Thermal Lag Analysis of Asco Valve Models NP-8616,NP-8320 & NP-8321.Related Correspondence ML20214P4331986-11-26026 November 1986 Affidavit of Hm Deutsch in Response to ASLB Reopening Matter Re Safety & Qualifications of Asco Valves. Certificate of Svc Encl.Related Correspondence ML20214P3951986-11-25025 November 1986 Affidavit of a Masciantonio in Response to Sj Cereghino & Wa Cesarski 861028 Affidavit & Board 861106 Memorandum & Order Reopening Record of OL Proceeding on Contention 10.5 Re Asco Solenoid Valves.Certificate of Svc Encl ML20214A5961986-11-14014 November 1986 Affidavit of RM Bellamy Re New Allegations Raised by Georgians Against Nuclear Energy.Notice of Appearance & Certificate of Svc Encl ML20211H4531986-10-28028 October 1986 Affidavit of Sj Cereghino & Wv Cesarski Confirming That Asco Solenoid Valves Used in Facility Environmentally Qualified W/Sufficient Margin & Will Function Under Normal & Accident Conditions.Certificate of Svc & Svc List Encl ML20214L6101986-09-0404 September 1986 Supplemental Affidavit of Kp Twine Re Contention EP-5. Savannah River Plant Emergency Plan Will Be Amended to Include Info Re Location of Reception Ctrs & Ctr Capacities ML20211N6521986-06-27027 June 1986 Supplemental Affidavit of Cl Stovall Supporting Proposed Changes to Emergency Plans for State of Ga & Burke County Re Medical Treatment of Contaminated Injured Individuals & 24 H Manning of Communication Links.Related Correspondence ML20206D8321986-06-16016 June 1986 Affidavit of Kp Twine in Support of Applicant Motion for Summary of Disposition of Joint Intervenors Contention EP-5 Re Capacity of Schools Receiving Evacuees from Emergency Planning Zone ML20198A0161986-05-13013 May 1986 Supplemental Affidavit of Cl Stovall in Response to Applicant Motion for Summary Disposition of Contention EP-5 Re Reception Ctr Capacity.Adequate Emergency Facilities Will Be Readily Available.Certificate of Svc Encl ML20155G7681986-04-22022 April 1986 Affidavit of Cl Stovall Supporting Applicant Motion for Reconsideration of Denial of Summary Disposition of Intervenor Contention EP-2/EP-2(c) Re Use of NOAA Tone Alert Radios.Certificate of Svc Encl ML20203D5771986-04-16016 April 1986 Supplemental Affidavit of Dn Keast on Contention EP-2/EP-2(C) Re Use of NOAA Tone Alert Radios for Public Alerting.Certificate of Svc Encl ML20203B7311986-04-15015 April 1986 Affidavit of Cl Stovall Supporting Applicants 860310 Motion for Summary Disposition of Contention EP-2/EP-2(h) Re Public Info for Transients ML20203B6151986-04-11011 April 1986 Affidavit of Cl Stovall in Response to Applicant 860310 Motion for Summary Disposition of Contention EP-5 Re Reception Ctr Capacity.Certificate of Svc Encl ML20203B4061986-04-0909 April 1986 Affidavit of Cl Stovall in Support of Applicant 860306 Motion for Summary Disposition of Contention EP-4 Re Identification of Existing Hosps for Treatment of Contaminated Injured Individuals.Certificate of Svc Encl 1995-09-28
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196J3291999-06-28028 June 1999 Comment Supporting Proposed Rule 10CFR50 Re Industry Codes & Standards ML20206M7291999-04-30030 April 1999 Comment Supporting Draft RG DG-1083, Content of UFSAR IAW 10CFR50.71(e). Licensee of Listed Plants in Total Agreement with Comments Provided to NRC by NEI HL-5717, Comment Supporting Proposed Rule 10CFR50,52 & 72 Re Changes, Tests & Experiments.Util in Total Agreement with NEI Comments to Be Provided to NRC1998-12-18018 December 1998 Comment Supporting Proposed Rule 10CFR50,52 & 72 Re Changes, Tests & Experiments.Util in Total Agreement with NEI Comments to Be Provided to NRC HL-5715, Comments on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Util Is in Total Agreement with NEI Comments1998-12-14014 December 1998 Comments on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Util Is in Total Agreement with NEI Comments HL-5702, Comment Supporting NEI Comments Totally on Proposed Draft RG DG-4005, Preparation of Supplemental Environmental Repts for Applications to Renew Nuclear Power Plant Ols1998-10-23023 October 1998 Comment Supporting NEI Comments Totally on Proposed Draft RG DG-4005, Preparation of Supplemental Environmental Repts for Applications to Renew Nuclear Power Plant Ols HL-5695, Comment Supporting Nuclear Energy Institute (NEI) Comments on 10CFR50.55(a) Pr, Streamlined Hearing Process for NRC Approval of License Transfers1998-10-13013 October 1998 Comment Supporting Nuclear Energy Institute (NEI) Comments on 10CFR50.55(a) Pr, Streamlined Hearing Process for NRC Approval of License Transfers HL-5690, Comment on Integrated Review of Assessment Process for Commercial Nuclear Plants. Util in Total Agreement with NEI Comments Provided to NRC1998-10-0505 October 1998 Comment on Integrated Review of Assessment Process for Commercial Nuclear Plants. Util in Total Agreement with NEI Comments Provided to NRC HL-5983, Comment on Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors. Snoc in Total Agreement with NEI Comments,To Be Provided to Nrc.Requests That NRC Provide Guidance to Application of NUREG-1022,rev 1 as Listed1998-09-21021 September 1998 Comment on Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors. Snoc in Total Agreement with NEI Comments,To Be Provided to Nrc.Requests That NRC Provide Guidance to Application of NUREG-1022,rev 1 as Listed ML20153B2391998-09-15015 September 1998 Comment on Draft NUREG-1633, Assessment of Use of Ki as Protective Action During Severe Reactor Accidents. Endorses NEI Comments HL-5682, Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents, & Endorsing Comments Submitted by Nuclear Energy Institute1998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents, & Endorsing Comments Submitted by Nuclear Energy Institute HL-5602, Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds1998-04-0303 April 1998 Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds HL-5586, Comment on Proposed Generic Ltr, Year 2000 Readiness of Computer Sys at Npps1998-03-0404 March 1998 Comment on Proposed Generic Ltr, Year 2000 Readiness of Computer Sys at Npps HL-5582, Comment on Draft Reg Guide DG-5008, Reporting of Safeguards Events1998-02-27027 February 1998 Comment on Draft Reg Guide DG-5008, Reporting of Safeguards Events HL-5564, Comment on Draft NUREG 1555, Updated Environ Standard Review Plan1998-01-30030 January 1998 Comment on Draft NUREG 1555, Updated Environ Standard Review Plan HL-5554, Comment Supporting NEI Comments on PRM 50-63A by P Crane Recommending Emergency Planning Standard for Protective Actions Be Changed to Require Explicit Consideration of Prophylactic Use of Potassium Iodide for General Public1998-01-15015 January 1998 Comment Supporting NEI Comments on PRM 50-63A by P Crane Recommending Emergency Planning Standard for Protective Actions Be Changed to Require Explicit Consideration of Prophylactic Use of Potassium Iodide for General Public HL-5546, Comment Supporting Proposed Rule & Direct Final Rule on 10CFR50.68 & 10CFR70.24, Criticality Accident Requirements1997-12-31031 December 1997 Comment Supporting Proposed Rule & Direct Final Rule on 10CFR50.68 & 10CFR70.24, Criticality Accident Requirements HL-5529, Comment Opposing Rule 10CFR50 Re Codes & Standards,Ieee National Consensus Standard1997-12-0101 December 1997 Comment Opposing Rule 10CFR50 Re Codes & Standards,Ieee National Consensus Standard ML20199J0031997-11-24024 November 1997 Comment Supporting Proposed Rule Re Financial Requirements for Decommissioning Nuclear Power Reactors & Draft RG 1060 HL-5424, Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Encourages NRC Not to Abandon 30 Yrs of Effective Implementation of 10CFR.50.59 for New Positions1997-07-0707 July 1997 Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Encourages NRC Not to Abandon 30 Yrs of Effective Implementation of 10CFR.50.59 for New Positions ML20148N0741997-06-19019 June 1997 Comment on Proposed Suppl to Bulletin 96-001 Re Control Rod Insertion Problems.Util in Complete Agreement That Incomplete Rcca Insertion Not Acceptable HL-5407, Comment Opposing NRC Proposed Strategies to Address Licensees Need to Establish & Maintain safety-conscious Work Environ1997-05-27027 May 1997 Comment Opposing NRC Proposed Strategies to Address Licensees Need to Establish & Maintain safety-conscious Work Environ ML20137C2581997-03-18018 March 1997 Summary of Director'S Decision Under 10CFR2.206 of Mb Hobby & AL Mosbaugh, ML20137C4261997-03-18018 March 1997 Director'S Decision Under 10CFR2.206 Re Petition Re Allegation of Illegal Transfer of OLs to Southern Nuclear Operating Co.Petitions Filed by Mb Hobby & AL Mosbaugh Denied HL-5268, Comment Supporting Draft RG DG-1047, Std Format & Content for Applications to Renew NPP Ols1996-11-27027 November 1996 Comment Supporting Draft RG DG-1047, Std Format & Content for Applications to Renew NPP Ols ML20133H1131996-11-25025 November 1996 Petition for Enforcement,Per 10CFR2.206,to Revoke Northeast Utils Operating Licenses for CT Nuclear Power Stations Due to Chronic,Systemic Mismanagement Resulting in Significant Violations of NRC Safety Regulations ML20129J5481996-10-30030 October 1996 Order.* Extends Time within Which Commission May Take Sua Sponte Review of Memorandum & Order LBP-96-16 to 961129. W/Certificate of Svc.Served on 961030 ML20129K4291996-10-0202 October 1996 Comment Supporting Proposed Rule 10CFR25 & 95, Access to & Protection of Classified Info HL-5247, Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations1996-10-0101 October 1996 Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20128K2791996-09-30030 September 1996 Order.* Time within Which Commission May Take Sua Sponte Review of Memo & Order LBP-96-16 Extended Until 961030. W/Certificate of Svc.Served on 960930 ML20116J8921996-08-0202 August 1996 Withdrawal of AL Mosbaugh.* AL Mosbaugh Voluntarily Withdraws Intervention,Opposition & Contention in Proceedings.W/Certificate of Svc & Svc List ML20116J8551996-08-0202 August 1996 Joint Notice of Termination.* AL Mosbaugh Voluntarily Withdrew Intervention,Opposition & Contentions in Proceeding.W/Certificate of Svc & Svc List ML20116J8431996-08-0202 August 1996 Intervenor Response to Georgia Power Motion for Reconsideration.* Intervenor Supports Motion for Reconsideration.W/Certificate of Svc & Svc List ML20116N5881996-07-31031 July 1996 Comment Re Proposed Rule 10CFR26, Mods to Fitness-For-Duty Program Requirements. Supports NEI Comments ML20116A4931996-07-15015 July 1996 Georgia Power Company Motion for Reconsideration of 960628 Memorandum & Order Or,In Alternative,For Certification.* Gpc Requests That Board Not Require Submittal or Approval of Settlement Between Gpc & Mosbaugh.W/Certificate of Svc ML20115H2671996-07-0808 July 1996 Comment Supporting Final Rule 10CFR51, Environ Review of Renewal of Nuclear Power Plant Operating Licenses HL-5195, Comment Supporting Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors1996-06-24024 June 1996 Comment Supporting Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors ML20114E6491996-06-20020 June 1996 Joint Motion to Defer Issuance of Initial Decision.* Requests That ASLB Defer Issuance of Decision in Proceeding Until 960920,in Order to Allow Gpc & Mosbaugh to Reach Settlement Agreement.W/Certificate of Svc IA-95-211, Transcript of 920507 Interview of Mc Wilkins in Waynesboro, Ga.Pp 1-391996-05-0707 May 1996 Transcript of 920507 Interview of Mc Wilkins in Waynesboro, Ga.Pp 1-39 ML20129H7151996-05-0707 May 1996 Transcript of 920507 Interview of Mc Wilkins in Waynesboro, Ga.Pp 1-39 HL-5103, Comment Supporting NEI Comments on Petition for Rulemaking PRM-50-63 Re Planning Std for Protective Actions for General Public Includes Stockpile or Predistribution of Ki for Prophylactic Use1996-02-0606 February 1996 Comment Supporting NEI Comments on Petition for Rulemaking PRM-50-63 Re Planning Std for Protective Actions for General Public Includes Stockpile or Predistribution of Ki for Prophylactic Use ML20096A4911995-12-22022 December 1995 Georgia Power Co Reply to Intervenor & NRC Staff Proposed Findings of Facts & Conclusions of Law.* W/Certificate of Svc ML20095D9821995-12-12012 December 1995 Georgia Power Co Motion to Correct Record of Exhibits of Diesel Generator Reporting Issues Allegation Hearing.* W/Certificate of Svc ML20095D9771995-12-0808 December 1995 Comment on Proposed Generic Ltr Boraflex Degradation in Spent Fuel Pool Starage Racks. Request for Licensees to Demonstrate Subcriticality Margin in Unborated Water,Seems Inconsistent W/Stated Benefit of Borated Water ML20094S2751995-11-30030 November 1995 Intervenor Final Statement of Fact & Conclusions of Law.* Board Finds That Util & Applicant Failed to Meet Burden of Proof Re Ultimate Issue of Character,Competence & Integrity. W/Svc List ML20094S2411995-11-22022 November 1995 Georgia Power Co Response to Intervenors Motion for Continuance.* Intervenor Motion Unjustified & Prejudicial & Should Be Denied.W/Certificate of Svc & Svc List ML20094S2931995-11-21021 November 1995 Intervenor Motion for Continuance for Good Cause.* Requests Deadline for Filing Post Hearing Brief Be Extended Until 951130.W/Certificate of Svc & Svc List ML20094K1161995-11-0909 November 1995 Intervenor Motion to Admit Supplementary Exhibits.* Moves That Naslp Admit Encl Documents Into Evidence for Listed Reasons.W/Certificate of Svc & Svc List ML20094J9301995-11-0606 November 1995 Georgia Power Company Motion to Correct Record of Diesel Generator Reporting Issues Allegation Hearing.* Moves Licensing Board to Order That Corrections Be Made to Transcript.W/Certificate of Svc & Svc List ML20094J9281995-11-0606 November 1995 Gap Proposed Findings of Fact & Conclusions of Law on Diesel Generator Reporting Issues.* Findings of Fact & Conclusion Accepted.W/Certificate of Svc ML20094J9201995-11-0101 November 1995 Affidavit of Ck Mccoy to Correct Info Contained in Intervenor Exhibit II-97,which Consists of Portions of Deposition in a Mosbaugh Complaint Against Gap 1999-06-28
[Table view] |
Text
UNITED STATES OF AMERICA
' NUCLEAR REGULATORY COMMISSION Before'the Atomic Safety and Licensing Board On.the matter of :
GEORGIA POWER COMPANY, et1al., : DOCKET NUMBERS'
- 50-424 and 50-425 (Vogtle Electric Generating :
Plant, units 1 andR2) :
i ._
AFFIDAVIT OF H. W. SWAIN .
COUNTY OF BURKE STATE OF' GEORGIA Before the undersigned officer duly authorized to E administer oaths'did appear H. W. Swain, who after being I duly sworn,'did state as follows:
- 1. My name is Henry W.. Swain. My business address i
l' .is Vogtle Electric Generating Plant, Route 2, Waynesboro, Georgia 30830. I am employed-by Georgia Power Company 1as Mechanical-Quality Control Section Section Supervisor. In
~
that position I am primarily responsible for quality con-trol.in several areas, including welding. I have worked on The Vogtle Project tot the past 8-1/2 years. A summary of my professional qualifications and experience is at-
.tached hereto as Exhibit'*9A."
l 8507010192 850624 DR ADOCK050%44 y 3
- 2. I make this Affidavit in support of Applicants' Motion for Summary Disposition of Joint Intervenors' Contention No. 8 (Quality Assurance). I have personal knowledge of the matters stated herein and believe them to be:true and correct. I will first discuss Intervenors' allegations regarding this omission of specified liquid penetrant examination from welding process sheets. Sec-ond, I'will discuss the although questionable surfaces on Reactor Closure Heads Internal Cladding. Finally, I will discuss Intervenors' allegations that Applicants have failed to establish proper radiographic procedures for welding.
THE OMISSION OF SPECIFIED LIQUID PENETRANT EXAMINATION FROM WELDING PROCESS SHEETS
- 3. The specific discrepancy concerning failure to
- include the liquid penetrant examination on process sheets f-for examination of' reactor coolant pressure boundary welds was identified by the NRC Inspection Report 83-15. The specific violation involved an isolated instance in which-the process sheet failed to list the required liquid penetrant examination (PT) for a weld. Geotgia Power Company acknowledged this isolated violation.
- 4. A' review was conducted of 100S 2 of all other pri-
- mary loop piping isometrics (twenty drawings in all) and all associated process sneets were examined, and this was the only instance in which a process failed to call t
out the required. test. ;
- 5. It should be noted that the-personnel that were involved in performing these tests had done this over a long period of time, and it has been done over and over again. The failure of the process sheet to specify the appropriate test does not indicate that the test would not have been done or that the weld was unsafe. The weld >
wh'ich was to have been inspected by pT pursuant to this process sheet had not yet been finalized. When the weld was completed and the process sheets were returned for final review and confirmation, appropriate written pro-cedures existed such.that a quality control document 1
reviewer, in all likelihood, would have caught the previous oversight.
QUESTIONABLE SURFACES ON THE REACTOR CLOSURE HEADS INTERNAL CLADDING
- 6. In I&E Report 83-18, the NRC issued a notice or severity Level V violation ("of minor safety or environ-mental significance"). An NRC inspector had examined the Reactor Closure Heads Internal Cladding had observed ques-tionable. surface conditions, and concluded that those ,
conditions did not appear to meet the criteria for per-
' forming a meaningful liquid penetrant examination.
i 1
w ,
m
- 7. .Re-examination of two suspect areas of the clad-Lding by liquid penetrant methods revealed: linear and rounded. indications greater than acceptable limits. The reactor vessel manufacturer had properly performed the examination, and that the indications were apparently caused by gritblasting, which had been used as a form of-post-examination cleaning. Gritblasting as a method of post-examination cleaning is in accordance with ASME B&pV,
- Section III. The entire cladding surface of'the closure heads of both units was subsequently cleaned, repaired when necessary, and liquid penetrant examined.
- 8. The corrective action was described in a letter to the NRC dated December 14, 1983. Based upon that cor-rective action, the NRC closed the matter I&E Report.84-21, dated August 13, 1984. There were no ad-verse safety consequences as a result of this incident.
FAILURE TO ESTABLISH PROPER RADIOGRAPHIC PROCEDURE (HAZ)
- 9. Joint Intervenors have challenged the radio-graphic procedures used for non-destructive examination at -
VEGP. They have cited a particular-instance which in-volved the failure of Chicago Bridge and Iron Welding pro- -
cedures to specify the heat-affected zone (HAZ) as the appropriate area of inquiry when considering radiographs.
l Because this was not specified as the appropriate area of inquiry, the film density on the radiograph was allowed to deviate from the ASME mandated 3.80.
- 10. The particular radiographic procedure referred to was a CB&I procedure. That procedure specified that a film density of 3.80 be maintained only for the weld material being examined. It did not specify that the heat-affected zone (HAZ) also had the ASME specified film density.
- 11. The HAZ was routinely examined during radio-graphic examination even though the film density was not specified at 3.80. The question was not whether the HAZ was properly examined for imperfections; the question was whether the film density in the HAZ was required to be 3.80.
- 12. The particular weld in question was removed and the violation was withdrawn.
- 13. Nevertheless, Georgia power Company first took the position that the ASME, B&PV Code did not require any particular tilm density outside the weld. There-fore, Georgia power Company disputed the violation insofar as it challenged the procedures used by CB&I.
See letter from Don Foster dated September 30, 1983.
That letter identified the particular question involved in this instance. As stated by Mr. Foster:
_5_
L
The-Georgia Power Company has committed to meeting their requirements of the Code in the examination of welds at Plant Vogtle. While we
~do not deny that the heat-affected zone of a weld
'should be given proper consideration during welding inspections, it remains our position that failure to designate the heat-affected zone as part of the area of interest in radiography procedures and failure to maintain film density 3.80 over the entire heat-affected zone of a radiograph do not constitute violation of Code.
(emphasis added.)
- 14. Rather than rest upon'GPC's interpretation of the Code, Georgia Power Company referred this matter to the ASME Boiler and Pressure Vessel Code Committee for interpretation. That Committee has now clarified the question and.it appears that the heat-affected zone is included within the " area of inquiry" such that film density of 3.80 should be maintained in radiography Procedure. Accordingly, .the CB&I procedure has been revised.
Further Affiant sayeth not.
9 Os h~-v_ _-
H. W. SWAIN
, Sworn to and subscdib d before me this /4 day..oi f u s.L ,
a.
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knot'a'ry euci te M.{ j t '
PERSONAL RESUME CF HENRY WILSON SWAIN i
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- ~ .
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- - 0,6
'3 / '- <f',
, RESUME o _
NAME: Henry, Wilt.on Suttin ADDRESS: '4079 Burningttee Lane QATE OF BIRTH: June 30,:1025. y .. Aaga.ta, Ga. 30906 N( MARRIE0: Wife - Ru.tli%. Suntin TELEPHONE: (404}-798-1350
.N CHILOREN: Michael 8. Smin 13-67.
Peter 8. Smin 30-69
- ,. ,o ,
t m EDUCATION AND QUALIFICATIONS y
, &c' '1940'- 1942. Charlotte Technical High School, Charlotte,'N C.
.1942 -^1943 -Jamestown High School, Jamestown, Nao York
- -7/43 - 11/43' U. S. Maritime School (Engineering Department)
~
- St. Petersburg, Florida r1 i :1949' a., .Sbtte of New York High School Diploma based on GEO Exans i'
' ' .,10/48:-!1/49 IBM School Data Programming
- 2/60 - }l61- O._ S. Army Nuclear Reactor Power Plant School - Graduated af qualified reactor operator seith speciality in field of
- Mechanics. .(Macitinery installation] All . types pumps,
- , motors, piping, valves, etc., macitinetuj operation ~ and associated systems; basic welding; pipe covering; tathe
- operation; drill press, and similar machine shop equLpment;
- ' use of ptec4sion tools. .
10/67 - 12/67 Navport News -Sitipbuilding and Ory Ocek Company Apprentice Schoot - Basic Er.gineering for Macitinery lotstallation.
- Passed AEC' requirements for radiation lectures, received
, special .instnuction and quaLifled in use of glove boxes, qualified to work in nuclear space.s. Qualified for nae fuet handling and storage; qualified for cutting closure
' head omega seat weld.
i
.4/70 Qualified Section 6, NSC Q.C. hinual (MIL-STD-767A - Clea> ting s and Cleanliness Maisttenance)
. 7/7b Qualified as Visual. Inspectcr and certifLed July 10, 1970
+ Requalified July 23', 1971 INAVSHIPS 250-1500-1, Welding Standa,tds )
8/70 Quatifild as Magnetic Parciele inspector and certified
' August 14, 1970. Requalified June 15, 1971 [NAVSHIPS
, 250-1500-1, Welding Standards 1 r
f
RESlNE
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> HENRV WILSON SWAIN EDUCATION AND QUALIFICATIONS CONTINUED
'4/71 Qualified as a Crane inspector in accordance with NAVSHIPS 0989-030-7000 11/72 Qualified as certifying agent for gear certification to -
U. S. Department of Labor OSHA 7/73 Qualified as Liquid Penet) tant inspector and certified July,1973 ASME, SNT-TC-1A, Level 11 2/74 Appointed Level ill Examiner, Visual Inspestion 3/74 ' Appointed Level ill Examiner,. Magnetic Particle and Liquid Penetrant inspection S/76 Qualified as Radiographer's Assistant L S/78' Attended 40 howts course in Prbiciples and Techniques of Inattuction
'6/18 Qualified by ASNT Exam, Level 111 Magnetic Particle inspector 8/78 Attended 32 hour3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> course on Eddy Cwtrent' inspection 8/78 QualifLed Level 11 - Eddy Curtent inspector 3/79 Attended New Supervisory Course - 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> 3/79 Attended Seminar for Designing Ef fective Tra.ining and Selecting Appropriate Methods, 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> 3/79 Qualified by ASNT Exam Level til Liquid Penetrant inspec tor 1/19 Attended Line Management Development - 8 Cowtse, 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> 10/79 Qualified by AWS as Certified Welding inspector 12/80 Attended 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> cowtse Ulttasonic Inspecting - Level 1 Certified Level 1, February 1981
~3/8I Attended 32 howt course on inservice inspection ( ASME Section X11
RESUME PAGE 2 A HENRY WILSON SWAIN EDUCATION AND QUALIFICATIONS CONTINUED 5/81 Attended 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> course at the George Washington University pertainting to Operating Techniques for Standards and Calibration Laboratories.
5/83 Attended 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> course at the Electric Power Institute pertaining to VisualInspection. Passed their Level I, II, and III, examinations.
Certified LevelIII.
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RESUME PAGE 3 HENRY WlLSON SWAIN EXFERIENCE 2/43 - 7/43 Norfolk Naval Shipyard Laute Operator 12/43 - 9/45 U. S. Maritime Sejtuice. Woded as Fueman, Citer and Junior Engineer; received certificate as Fiteman, Citer and Water Tender upon completion of school. Later certi-ficate was endorsed to include Junior Engineer upon successful completion of exams before ble U. S. Coast Guard, No.tfolk, Virghtia 11/45 - 1/67 U. S. Arnt) 1/49 - 12/49 Macluine Records Urtit [ operated various IBM Machines ht-cluding programming) 4/61 - 10/64 Opented vasious reactors otated by bie U. S. Army, SM-1, Fort Belvoit, VitgistLt (Cpentor - Mechansc) PM-2 Martin-Marietta, Baltimore, naryland, pre-assembly checkou,t ptior to sending it to the Soubt Pole, PM-2A Reactor (North Pote)
Camp Tuto, Greenland [ Operator - Mechanic).
2/67 - 4/70 Newport News Sitipbuilding and Dry Dock Company Machinery Installation Department.
Nuetear Branch as 1st Class Mechastic. A"so woded as fuel handlet; core remov'aZ, omega seat cutting, new core htstalta-tion and otJtet retated reactor refueling ptocedures. Was a membe.t af hte crew represertting ute shipyard durutg sea trials and shde dotat cruise of the aiteraft cartier John F. Kennedy.
4/10 - 5/70 Q. C. Inspector a.t KNOLLS Atomic Powet Labora.coty on DIG Plant during tube removai and plugg41g. Maintairting Grade "A" eleanliness and smali tool inventory bt compliance wint proce-dures.
5/70 - 3/77 Responsible for conducting various non-desttuetive tests and receipt inspection of nuclear components. Followed wod 41 ptogress in support of too steam genera. tor .tepait cortttacts and shop wod for commercutt reactor cortsstucLion, hivolving wtitutg b1sttuctions, NOT Inspection procedures, monito.ted wod in progress to ascertabt compLtance, keeping requited reco.tds, and maintau:ing smail t. cots accountability.
Developed and htsttuete.d a Ltahtb19 course out c.tane certifi-cation for ble Navy 41 acco.tdance witJt NAVSHIPS 0989-030-7000.
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RESUME PAGE 4 HENRV WILSON SWAIN EXPERIENCE CONTINUED Magnetic Particle htspected att secondart) m1bt steam and mabt tat.ter fines Ptartt No.1 Surtj, Virginia.
Worked .bco constacts involvhg crane htspection; one at Norfolk Naval Shipyard, Norfolk, Vitghtia, and one a.t Charleston Navat Shipyard, Citarleston, S. C.
Supv. in charge.
Followed work in progress in support of refueling activities (NRF - Idaho}. Involubtg compliance with written insttuctions, dratabtes and procedures. NDT inspection procedures, and maintahting records. Verified Welder Qua.lifications, Pipe fit-up and welding procedures
' bt general in accordance leitJ1 NAVSHIPS 250-1500-1.
Prepared and presen,ted a 42 howt course on Pipe Welding inspection to WEDC0 of Buchanan, New York. Inetuding Quality Assurance, Quality Conttot, pipe fit-up weldb1g ptocedures, weldes qualifica.tions and NDT Inspection per ASME Standard.
Responsible for att gear certification performed by tJte company.
Tauglst a.t various companies tJt,toughout the U. S. , various courses relatutg .to ASME Codes, Weldhtg inspection and Crane Ittspection.
3/77 - 8/79 Georgia Powe,t Compant) - Senior Me,thods and Trahtbtg Spec,utL<,s t Vogtte Nuclear Plan.t - Site Tra,bsb19 Coordata, tor (Consttuction)
W. tite, ytesent, and evaluate ptograms of.htsttuetion dealbtg toith tite consttuction phase of a. Nuetear Power Plant. Super-vise otiter member of the Trainhtg Deparbnent. Petform crane inspestion as ,teques.ted. Act as a consultantt to other branches and plants of tJte Georgia Power Company Itaving crane o.t NDE ptoblems.
8/79 - 10/81 Section Supervisor of the Nondesttactive Testing Section' at Vogtle Nuclear Plant. Responsible for establisiting tite section.
Wributg and revicteing of NDE Procedures. Supervise utb1e [9) emploijees, who petform or tattness tJte petfonmance of NDE Methods in Ulttasonic, Radiograpity, Eddtj Carteutt, Magnetic Particle, Liquid ~ Penettartt, Visual Inspection and leak .te.stbtg. Perform c,tane hispection as requested. Act as a costsaltant to otJter branches and plants of the Georgia Power Company havbtg c.tane or NDE ptoblems.
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HENRV: WILSON SWAIN 10/81:. Section Supervisor ~of the Mechanical Quality
~ present Controt Section. The Nondestructive .Tes ting
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Section was combined with the Mechanical Quality Control Section and I assumed the duties of both sections. The section is comprised of 65 employees.
Two QC Supervisors, six 1nspection Supervisors, three clerks, and- 54 inspectors. Duties include
.att Receipt Storage and Handling of all site p l ant
. equipment and material. Surviettance Inspection of three contractors who have their own QA program.
First line inspection o f other contractors ' as required. . . Responsible for att NOT work and heauy rsggrng program.
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RESUME
-PAGE 6 HENRV WILSON SWAIN PROFESS 10NAL' AFFILIATION MEMBER: AMERICAN SOCIETV FOR TRAINING AND DEVELOPMENT MEMBER: AMERICAN WELDING SOCIETY MEMBER: AMERICAN SOCIETY FOR NONDESTRUCTIVE TESTING SUBCOMMITTEES: MEMBER: VISUAL INSPECTION COMMITTEE MEMBER: UTILITIES COMMITTEE MEMBER: AMERICAN NATIONAL STANDAR0 INSTITUTE STANDING COMMITTEE ON PERFORMANCE AND TESTING CHAIRbMN OF THE WORKING GROUP FOR MAINTENANCE AND PERFORSMNCE TESTING OF CRANES.
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