Affidavit of J Kitchens Supporting Applicant Motion for Summary Disposition of Joint Intervenors Contention 10.3 Re Cable in Multiconductor Configuration.Prof Qualification Statement Attached.Certificate of Svc EnclML20128E528 |
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Vogtle |
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Issue date: |
06/27/1985 |
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From: |
Kitchens J BECHTEL GROUP, INC., GEORGIA POWER CO. |
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Shared Package |
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ML20128E517 |
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OL, NUDOCS 8507050364 |
Download: ML20128E528 (12) |
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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] |
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UNITED STATES OF AMERICA stCKETED NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
%5 dif~-3 A10:16 CFFKE Cr SECM~A' In the Matter of :
E [/h,';
GEORGIA POWER COMPANY, et al. : Docket Nos. 50-424CL-
- 5 3 -4 2 50 L-(Vogtle Electric Generating :
Plant, Units 1 and 2) :
AFFIDAVIT OF JOEL KITCHENS COUNTY OF LOS ANGELES )
)
STATE OF CALIFORNIA )
I, Joel Kitchens, being duly sworn according to law, depose and say as follows:
- 1. -My name is Joel Kitchens. I am employed by
-Bechtel Power Corporation in the position of Assistant to the Chief Electrical Engineer. My business address is Bechtel Power Corporation, 12440 East Imperial Highway, Norwalk, California 90650. Attached to this Affidavit as Exhibit A is a summary of my professional qualifications.
- 2. The purpose of this affidavit is to support Applicants' Motion for Summary Disposition of Joint Inter-venors' Contention 10.3. In that contention the Joint Intervenors challenge the environmental qualification of multiconductor electrical cable used at the Vogtle 8507050364 PDR 850701 ADOCK 05000424 0 PM s
c - . ,
Electric Generating Plant ("VEGP"), asserting that the use of single conductor configurations in qualification' testing may not adequately test the performance of a multiconductor electrical cable. I have personal knowl-edge of the matters set forth herein and believe them to be true and correct.
i I. Background.
- 3. The common practice in the nuclear industry has been to use single conductor configurations in tests per-formed to establish the environmental qualification of multiconductor cables. Performing qualification testing on a single conductor taken from a sample of the particu-lar multiconductor under scrutiny is considered to be a more conservative methodology than testing the r.ulticon-ductor itself. Multiconductor cables generally have jacketing material or additional insulation or both sur-rounding the insulated single conductors comprising the multiconductor that should provide additional protection from adverse environmental conditions not available to a single conductor. Regulatory Guide 1.131, entitled
" Qualification Tests of Electric Cables, Field Splices, and Connections for Light-Water-Cooled Nuclear Power Plants," endorses IEEE Standard 383-1974, "IEEE Standard for Type-Test of Class IE Electric Cables, Fields splices, and Connections for ';uclear Power Generating Stations."
i 1
2
y(:.
Table 1 of this standard specifically provides that single conductor or multiconductor cables may be used for type testing for qualification purposes of multiconductor cables, except for vertical tray flame tests.
II. Studies performed by Sandia Nation 61 Laboratories Comparing-Test Results for Multiconductcr Samples.
-to Results Obtained from Corresponding 3 ingle Conductor Samples Under LOCA Conditions.
A. The Study performed on_ Conductors Insulated with Ethylene-Propylene Rubber Materials.
- 4. In October 1983, Sandia National Laboratories
-("Sandia") published the results of a study spor.sored by
- the Nuclear Regulatory Commission ("NRC") that investi -
gated (a) whether qualification test results for electri-cal cable insulated with ethylene-propylene rubber (EPR) materials were sensitive to the_ order of aging and acci-dent stress application and (b) the importance of simul-taneous-versus sequential stress exposures. L.D. Bustard, The Effect of LOCA Simulation Procedures on Ethylene-Propylene Rubber's Mechanica_l and Electrical Properligs, SAND 83-1258, NUREG/CR-3538, October 1983 ("the first Sandia report"). In that study, Sandia subjected samples of commercially available single, double, and triple con-ductor cable assemblies insulated with EPR polymer materi-alfto simulated loss-of-coolant accident ("LOCA") condi-
'tions. Eight cable products were tested. Four of the
_3
products were manufactured by Anaconda Wire and Cable Company, two by Eaton Corporation, and two by Okonite Company. Three of the-cable products were single conduct-ors, two were double conductors, and three were triple co r.duc to r s . For the multiconductor cables, tests were performed on samples of th'e multiconductor cables ~ them-se'_ves and on single conductors obtained by disassembling the multiconductor cables. Test conditions were similar for each type of cable.
- 5. With one exception, all five of the multiconduct-or cable products tested had chlorosulfonated polyethylene (CS?E) (also known as Hypalon) outer jackets. The one exception was a three conductor cable manufactured by Anaconda Wire and Cable Company that had EPR insulation on-the individual conductors and an outer thermoplastic jacket of chlorinated polyethylene (CPE). Unlike most of the other multiconductor cable products tested, the single .
conductors comprising this multiconductor cable were not individually jacketed. This multiconductor cable product was referred to in the Sandia study as cable "EPR D."
- 6. When tested under simulated LOCA conditions in a multiconductor configuration, cable EPR D deteriorated to a much greater degree than the other multiconductor pro-ducts tested. More significantly for this proceeding, it also deteriorated to a much greater extent than the single
_4_
conductor samples obtained by disassembling a sample of multiconductor cable EPR D. None of the other multicon-ductor cables-tested suffered greater damage in a multi-conductor. configuration than in the corresponding single conductor configuration. While the individual conductors
~
in those multiconductors also had EPR' insulation, the outer jacket around those conductors was not made of CPE but CSPE.
- 7. The author of the first Sandia report, Larry Bustard, postulated that interaction between the chlori-nated polyethylene outer jacket and the EPR insulation arcund each of the single conductors comprising cable EPR D contributed to the. degradation of that cable product.
He observed-that the insulation around the conductors had swelled, causing the outer jacket to split. The splitting of the jacket, he hypothesized, resulted in a sudden release of the constrictive force on the insulation, allowing.-it to crack or break up. Ultimate tensile elongation measurements performed on tensile specimens suggested to Bustard that by the end of the simulated LOCA conditions the insulation ultimate elongation was similar to the calculated strain resulting from the geometry of the multiconductor configuration, which would likely lead to insulation cracking. As an alternative hypothesis, Bustard proposed that portions of the insulation that l
_5_
adhered to the outer jacket when it split were pulled away from the conductors.
- 8. Bustard concluded that these two variations of the jacket-insulation interaction hypothesis were both
' consistent with.the observed results of the testing on EPR D, which were bare copper conductors being visible at the end of the testing. While Bustard suggested for complete-ness two additional theories that might account for the degradation found with EPR D, first that a jacket-insula-tien chemical reaction may have caused the degradation and second that the cable geometry may have resulted in stress buildup, he. discounted those possible explanations as less acceptable.
- 9. Based upon the experimental results for EPR D, the first Sandia report concluded in part that "[fluture EPR cable qualification tests should not employ single conductor test specimens to establish qualification for multiconductors." That conclusion may be questioned on the basis of the results of the first Sandia study itself, since the EPR D cable was the only one of the five multi-conductor cable products for which the multiconductor con-figuration showed significantly greater degradation than the single conductor configuration. More importantly, however, a subsequent Sandia study of cross-linked polyolefin cable, conducted in part for the purpose of
_ .5 _
}
l
' testing this conclusion, showed no'significant differences in deterioration between single conductor and multi-conductor configurations. L.D. Bustard, The Effect of LOCA Simulation Procedures on Cross-Linked Polyolefin Cab _e's Performance, SAND 83-2406, NUREG/CR-3588, April 198', ("the second Sandia report").
- 3. The Study Performed on Conductors Insulated with Cross-Linked Polyoletin Materials.
- 10. The second Sandia report, also authored by Mr.
-Bus:ard, published the results of tests in which three commercially available multiconductor cable assemblies were subjected to simulated LOCA conditions. Similar to the prior study, for two of the cable products tested the tests were performed both on the multiconductor cable products and on single conductors obtained by disassem-bling samples of the multiconductor cables. All three of the multiconductor cable products had cross-linked poly-olefin insulation and thermosetting Hypalon or Neoprene
~ outer jackets.
- 11. As noted above, one of the chief purposes of the second Sandia study was to test experimentally whether qualification testing of-single conductors was more severe, equal to, or less severe than the testing of multiconductor cables. The results obtained demonstrated that the effect of the simulated LOCA conditions upon the cable products tested dic not differ depending upon
- whether a multiconductor configuration or single conductor c'onfiguration was tested. With respect to the two cable products tested in both multiconductor and single con-ductor configurations, the second Sandia report concluded that the electrical properties retained by those cable products following exposure to'LOCA condition ~s'"did'not depend on whether single conductor or multiconductor tes-ing was performed."
- 12. Thus, of the eight multiconductor cable products tested in both Sandia studies, only the multiconductor cab e manufactured by Anaconda Wire and Cable Company that had conductors with EPR insulation and a chlorinated poly-ethylene outer jacket suffered greater degradation in a multiconductor configuration. In fact, two other multi-conductor cables manufactured by Anaconda were tested in the first Sandia study and did not suffer greater degrada-tion in a multiconductor configuration. The results of the second Sandia study further support Bustard's hypothesis that the greater degradation experienced by the EpR D cable in a multiconductor configuration resulted from a jacket-insulation interaction, since other cable products not having the same combination of jacket and insulation have not shown similar degradation.
- 13. My conclusion from these two studies is that only cables having a thermoplastic chlorinated polyethylene jacket are likely to suffer greater degradation when
~
tested in a multiconductor configuration rathe~r than in a single conductor configuration. To determine whether any such electrical cable has been used at VEGP, Bechtel Power Corporation reviewed all purchase orders for electrical cable and questioned all suppliers of safety related equipment for use at VEGP that could be exposed to a harsh -
environment. No such electrical cable was procured for use at VEGP or included in any fabricated equipment pur-chased for VEGP. All electrical cable used at VEGP has either a chlorosulfonated polyethylene (Hypalon) jacket or-a pc lychloropreme (Neoprene) jacket. Multiconductor cables witt. these jacket materials performed as well in multicon-ductor configurations as in single conductor configura-tior.s in the Sandia studies. Considering this, I am confident that multiconductor cables used at VEGP that were environmentally q'ualified by testing single conductor cables or elements of a multiconductor cable are fully
. qualified.
1 3 ~
e M 1 KitchenY 1
Sworn to and subscr' bed '
before me this E day OFFICIAL SEAL of 0Luyt.A , 1985. JOANNE E HENRY NOTARY PUBUC
- CAUFOANIA LOS ANGELES COUNTY
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EXHIBIT A e
J0EL KITCHENS Assistant to the Chief Electrical Engineer Bechtel Power Corporation, Western Power Division PROFESSIONAL QUALIFICATIONS EDUCATION BSEE - University of California, Berkeley - 1948 Business Management Certificate Program, University of California, Berkeley - 1973 EXPERIENCE
SUMMARY
37 years design, supervisory and management positions in power engineering fields.
EMPLOYMENT HISTORY -
1966 to present: Bechtel Group - various locations 1956 to 1966: Anaconda Company - Wire and Cable Division New York and San Francisco 1948 to 1956: Pacific Gas and Electric Company San Francisco PROFESSIONAL AFFILIATIONS:
Fellow, Institute for the Advancement of Engineering Senior Member, Institute of Electrical and Electronic Engineers Member, IEEE Insulated Conductors Committee Member, Project fianagement Institute Registered Professional Engineer, Arizona and California SPECIFIC QUALIFICATIONS IN THE INSULATED CABLE FIELD Ten years with the Anaconda Company, Wire and Cable Division. These years included the following positions held and duties performed:
o 31/2 years as' a Cable Engineer doing cable design, specification writing, inspection and manufacturing engineering.
o 2 years as a Regional Engineer doing application engineering and providing technical assistance for sale personnel and clients, o 2 1/2 years a Chief Cable Engineer with full responsibility for design, specifications and quality for the company's insulated products in the low voltage and medium voltage field. i o 2 years as General Manager of the Cable Accessories Division in charge of design, manufacture and marketing of the accessories product line.
During 19 years with the Bechtel Group of Companies, have been a Cable Specialist with responsibility for insulated cable master specifications for all voltages and applications. Have been a member of the IEEE Power Engineering Society Insulated Conductors Committee and have represented Bechtel on this committee for this full time. Have actively participated on subcommittees and working groups responsible for maintaining and revising, as necessary, cable industry qualification standards such as IEEE Standard 383.
1 1
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OCldETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'85 Ji -3 N0 :05 BEFORE THE ATOMIC SAFETY AND LICENSING BOARDrgggggg .,
~
00CKET#NG & SEsvlb BRANCH In the Matter of :
GEORGIA POWER COMPANY, et al. : Docket Nos. 50-424
- 50-425 (Vogtle Electric Generating :
Plant, Units 1 and 2) :
CERTIFICATE OF SERVICE I hereby certify that copies of the Affidavit of Joel Kitchens, dated June 27, 1985, were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, or where indicated by an asterisk (*) by hand delivery, this 1st day of July, 1985. ;
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f/ !" l Jhmes E. Joiner Attorney for Applicants Dated: July 1, 1985
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)
o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
.) -
GEORGIA POWER COMPANY, et al. -- --
) Docket Nos. 50-424
) 50-425 (Vogele Electric Generating Plant, )
Units 1 and 2) )
SERVICE LIST Morton B. Margulies, Chairman
- Douglas C. Teper Atomic Safety and Licensing Board 1253 Lenox Circle U. S. Nuclear Regulatory Commission Atlanta, Georgia 30306 Washington, D. C. 20555
- Laurie Fowler Mr. Gustave A. Linenberger Legal Environmental Assistance Atomic Safety and Licensing Board -
Foundation U. S. Nuclear Regulatory Commission 218 Flora Avenue, N. E.
Washington, D. C. 20555 Atlanta, Georgia 30307 ,
Dr. Oscar H. Paris
- Tim Johnson Atomic Safety and Licensing Board Campaign for a Prosperous Georgia
-U. S. Nuclear Regulatory Commission 175 Trinity Avenue, S. W.
Washington, D. C. 20555 Atlanta, Georgia 30303 Bernard M. Bordenick, Esquire Docketing and Service Section Office of Executive Legal Director Office of the Secretary U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory l Washington, D. C. 20555 Commission Washington, D. C. 20555 Atomic Safety and Licensing Board Panel Bradley Jones, Esquire U. S. Nuclear Regulatory Commission Regional Counsel Washington, D. C. 20555 U. S. Nuclear Regulatory
, Commission
- Atomic Safety and Licensing Suite 3100 ,
Appeal Board Panel 101 Marietta Street U. S. Nuclear Regulatory Commission Atlanta, Georgia 30303 Washington, D. C. 20555
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