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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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%5 31.18 A10:10 UNITEDREGULATORY NUCLEAR STATES OF AMERICA rrF'CE 0r ,ECPtLIM'-
COMMISSIQNerg S
, 2.c BRuCH BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
GEORGIA POWER COMPANY, ~et al.
~ --
) Docket Nos. 50-424 (OL)
) 50-425 (OL)
(Vogtle Electric Generating Plant, )
Units 1 and 2) )
Affidavit of D. S. Jagannathan, Stephen J. Cereghino, and Mark L. Mayer County of Los Angeles )
) ss.
State of California )
We, D. S. Jagannathan, Stephen J. Cereghino, and Mark L. Mayer, being duly sworn according to law, depose and say as follows:
- 1. We are employed by Bechtel Power Corporation. Our business address is Bechtel Power Corporation, 12440 East Impe-rial Highway, Norwalk, California, 90650. Summaries of our professional qualifications and experience are attached hereto as Exhibits A, B, and C.
- 2. The purpose of this affidavit is to support Appli-cants' Motion for Summary Disposition of Joint Intervenors' Contention 7. The affidavit describes the design features at i
l l 850719 4 850715 PDR A K 05000424 l 9 PDR j
VEGP that prevent a significant accidental release of radioac-tive liquid to the ground-water. The affidavit also describes the extremely conservative assumptions that are implicit in Ap-plicants' accidental spill analyses. We have personal knowl-edge of the matters stated herein and believe them to be true and correct.
I. Design of Tanks and Systems Outside Containment that could Contain Radioactive Liquid
- 3. The operation of a nuclear power plant results in the production of radioactive materials which are almost entirely contained within the fuel elements of the reactor vessel.
These radioactive materials are either direct products of the fission process or are materials activated in or near the reac-tor core. Radioactive materials originating from the fuel and those materials activated within the reactor core are contained within the closed loop reactor coolant system. Liquid radioac-tive materials are removed from the reactor coolant system under controlled conditions. The chemical and volume control system, boron recycle system and the liquid waste processing system are designed to contain and process liquid radioactive wastes and to maintain releases of liquid radioactive effluents to the environment below 10 C.F.R. Part 20 limits and "as low as reasonably achievable" under normal operating conditions.
I e
- 4. Tanks and related piping containing radioactive lig-uids at Plant Vogtle are designed and constructed to stringent standards.. Safety-related tanks and related piping are de-signed and constructed in accordance with Regulatory Guide 1.26, " Quality Group classifications and Standards for Water ,
Steam , and Radioactive-Waste-Containing Components of Nuclear Power Plants" (Rev. 3 1976). Non-safety related tanks and re-lated piping are designed and constructed in accordance with Regulatory Guide 1.143, " Design Guidance For Radioactive Waste Management Systems, Structures, and Components Installed in Light-Water-Cooled Nuclear Power Plants" (Rev. 1 1979).
- 5. With the exception of the refueling water and reactor makeup water tanks, tanks containing radioactive liquids are located in containment, the auxiliary building, the radwaste transfer building, and the radwaste solidification building.
The containment building is designed to withstand a major acci-dent, and its failure is not considered credible.
- 6. The tanks in the auxiliary building, the radwaste transfer building, and the radwaste solidification building are located in rooms that have, as a minimum, 2-foot thick concrete walls; and the rooms either have curbs or watertight doors, or are entombed. The tanks are of stainless steel or Inconel con-struction. A leak detecting drain system in these buildings alarms to alert the control room operator of a leak in the various rooms. The drains are routed to the liquid waste.
processing system.. Flood retaining rooms also have a wall-mounted level switch which would notify the control room operator of a tank rupture.
- 7. The. auxiliary building is a seismic Category 1, rein-forced concrete structure designed and constructed in accor-dance.with Regulatory Guide.l.29, " Seismic Design Classifica-tion" (Rev. 3 1978) (i.e. it is designed to withstand the' safe shutdown earthquake without fracture of the walls or basemat).
The auxiliary building has a reinforced concrete slab (basemat). The basemat is 10 feet-thick. The boron recycle holdup tank (RHT) is located directly on top of the ten foot y thick basemat at elevation 119 (feet above mean sea. level).
The outside wall of the auxiliary building at'this elevation consists of approximately 6-foot thick reinforced concrete.
The auxiliary building's outside walls at elevation 196, where the waste evaporator concentrates holdup tank (WECHT) is locat- j ed, consist of approximately 4-foot thick reinforced concrete.
The prevention of ground-water seepage into the building and leakages out of the building is assured by the thick exterior concrete walls and basemat.
- 8. The radwaste transfer building and radwaste solidifi-cation building are designed for the operating basis earthquake conditions in accordance with Regulatory Guide 1.143. In
9 addition, the radwaste transfer building is designed to with-stand the safe shutdown earthquake due to its close proximity to the auxiliary building, a seismic Category 1 structure.
These buildings are reinforced concrete structures consisting of 1-foot six-inch thick exterior walls (minimum).
- 9. There are two radioactive tanks per unit located out-side of buildings -- the refueling water and reactor makeup water tanks. The tanks are designed for seismic Category 1 l
conditions and are constructed of cylindrical, reinforced con-crete shells that are 2-foot thick (minimum). Each tank is lined with a continuous stainless steel liner plate to ensure leaktight integrity. These tanks have concrete perimeter dikes I
to control runoff in the event of a tank overflow. Alarms are provided in the control room to alert the operator of a poten-tial overflow condition. Provisions have been incorporated to sample collected water in the 61kes and to transfer potentially contaminated water to the liquid waste processing system.
Piping running between these tanks and the auxiliary building is enclosed in Seismic Category 1 tunnels.
- 10. For the purpose of analyzing a postulated spill, the RHT is the most critical tank containing radioactive liquid be-cause it has a large volume (112,000 gallons) and has poten-tially the largest overall isotopic activity. The RHT is de-signed and constructed in accordance with Regulatory Guide 1.26. It is an atmospheric tank' constructed of 1/4 inch (mini-mum) thick stainless steel. The RHT is located in the auxilia-ry building, below grade, in a flood retaining room. This room is equipped with a leak detecting drain system that provides a high level alarm to alert the control room operator of a leak.
The drains are routed via a locked-closed valve to the liquid waste processing system. A wall mounted level switch would also notify the control room operator of a potential tank rup-ture.
- 11. The major contribution to the radioactive isotope in-ventory in the RHT is the reactor coolant system chemistry con- I trol bleed off. The activity of this process stream is essen-l tially that of the reactor coolant system. For the purposes of I analysis, it has been assumed that the activity released in the rupture of the RHT is that of the reactor coolant system for the expected failed fuel levels prescribed by ANSI N-237-1976,
" Source Term Specification."
- 12. The WECHT has a specific isotopic activity comparable to that of the RHT and is therefore also of interest. The l WECHT, however, has a much smaller volume (2,800 gallons) than the RHT. The WECHT is designed and constructed in accordance with Regulatory Guide 1.143. It is an atmospheric tank con-structed of 3/16 inch (minimum) thick stainless steel. The WECHT is also located in the auxiliary building, below grade, entombed in a room equipped with a leak detecting drain system.
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II. Assumptions for Spill Analysis
- 13. Of the several radionuclides present in the RHT and WECHT, thrge are critical because of relatively long half-lives. These are tritium (H-3), strontium-90 (Sr-90), and cesium-137 (Cs-137). The isotopic activity assumed for analy-sis of the rupture of either the RHT or WECHT are as follows:
Initial Activity Initial Activity in RHT in WECHT Radionuclide (uCi/cm3) (uci/cm3)
H-3 1.0E-0 1.0E-0 Sr-90 1.0E-5 8.9E-6 Cs-137 1.9E-2 1.7E-2
'14. To evaluate the worst consequences of a rupture of i either the RHT or the WECHT, one must postulate not only total tank-failure, but also failure of the auxiliary building hous-ing these tanks. The simultaneous failure of either tank and
[
I of the auxiliary building, however, is highly unlikely. As l previously stated, the RHT is constructed of 1/4 inch thick stainless steel (minimum), the WECHT is constructed of 3/16 inch thick stainless steel (minimum), and the auxiliary build-l ing is a seismic Category 1 structure designed not to fracture l
when subjected to the safe shutdown earthquake.
- 15. Assuming that a catastrophic event occurred which caused. fracturing of the auxiliary building walls, the frac-tures would likely not be continuous from the inside wall to the outside, due to the reinforcing bars which are ductile in l
1 1
...r .- - . . .
s nature. Moreover, even if a fracture did traverse the entire thickness of the auxiliary building wall, flow through such a fracture would not necessarily be outwards. For example, be-cause the RHT is at elevation 119 feet and the top of the water table aquifer is at approximately elevation 165 feet, the head differential would cause the fluid flow, if any, to be into the RHT room. The room would have to fill up with water before any outward leakage could occur.
- 16. The formation of a large fracture that would allow free flow of liquid from either the RHT or WECHT room to the ground is extremely small. Nonetheless, the sna. lysis conserva-tively assumes that the entire tank is instantaneously intro-duced to the water table aquifer. No credit is taken for structural design capability of the tanks or the building to contain the fluid within the confines of the plant.
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OFFICIAL SEAL Subscribed and sworn to before JOANNE E HENRY me this M day of July, 1985 My Commission expires: 8 Jf.lt ((
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EXHIBIT A D. S. JAGANNATHAN VOGTLE PROJECT CIVIL-STRUCTURAL LICENSING C0bdDINATOR Bechtel Power Corporation, Western Power Division EDUCATION B.E. (Civil) - University of Madras, India - 1963 H. SC. Engg. (Structural) - University of Madras, India - 1967 Ph.D. (Structural Engg.) - University of Minnesota - 1974 EXPERIENCE
SUMMARY
Twenty years teaching, analysis, design, construction coordination and supervisory experience in the field of Civil-Structural Engineering EMPLOYMENT HISTORY 1974 to present: Bechtel Power Corporation, Norwalk, California 1968 to 1974: Part time at Wheeler and Tillitt, University of Minnesota, ESI, and Setter, Leach and Lindstrom, Minneapolis, Minnesota 1967 to 1968: P.S.G. College of_ Technology, India 1963 to 1965: Madras Public Works Department, India PROFESSIONAL AFFILIATIONS Registered Professional Engineer, California Registered Structural Engineer, California SPECIAL QUALIFICATIONS IN NUCLEAR POWER PLANT DESIGN Eleven years with Bechtel Power Corporation, Norwalk, California.
-These years included the following positions held and duties perfo rmed.
o 3 years as a senior engineer performing seismic analysis and design of nuclear power plant structures, which included special assingments on Mark I Containment Study and review of seismic. qualification of equipment. Last one year on seismic analysis in Vogtle Project.
o 2 years as a seismic group leader on the Vogtle project with the responsibility for the seismic analysis of all safety-realted structures.
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s o 3 years as an engineering group leader on the Vogtle project Civil-Structural discipline, responsible for all the design engineering work and construction coordination, for contain-ment building for a brief period and following that for the auxiliary building, fuel handling building and diesel genera-tor building.
o 3 years as a special assistant to the Vogtle project Civil-Structural engineering group supervisor, performing the functions of the licensing coordinator with responsibility for the coordination of all civil-structural engineering licensing activities with project licensing engineer.
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e EXHIBIT B STEPHEN J. CEREGHINO EDUCATION: B.S., United States Naval Academy Naval Nuclear Power School Naval Nuclear Power Training Unit MBA, Business Administration, Whittier College
SUMMARY
- 7 Years: Bechtel engineering responsibilities in licensing and systems integration on the Vogtle project.
, 6 Years: Various training, operational and maintenance responsi-bilities associated with the naval nuclear propulsion program.
EXPERIENCE: Mr. Cereghino is Project Vogtle's Nuclear Group Supervisor.
In this capacity, he provides technical guidance and assistance in the licensing and design of Plant Vogtle. As licensing engineer, he coordinates the inter-discipline activities of project personnel and coordinates with the client, NSSS and NRC personnel to ensure consistent application of licensing commitments. Mr. Cereghino supervises the administration of the NSSS contract, including such activities as: NSSS vendor.
data review, evaluation of NSSS proposals, and coordination of A/E-NSSS interface activities. In the systems. integration area, Mr. Cereghino is responsible for the analytical evalua-tion of potential plant hazards, such as: radiation, pressure, temperature, flooding, internal missiles and seismic inter-actions.
Prior to joining Bechtel, Mr. Cereghino was an officer in the United States Navy. His shipboard engineering assignments were as Reactor Controls Officer and Main Propulsion Assistant. He routinely supervised the operation of the reactor plant during all modes of operation, and directed the chemistry control and radiation protection programs for ships' company. Mr. Cereghino's last assignment with the Navy was as a Division Director at the Naval Nuclear Power School; as such, he coordinated the instruction of Reactor Principles to enlisted plant operators. Before leaving the Navy, Mr. Cereghino successfully qualified to assume the responsibilities of Chief Engineer of a naval nuclear pro-pulsion plant.
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PROFESSIONAL AFFILIATIONS:
Professional Registration: Mechanical Engineering, State of California
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EXHIBIT C MARK L. MAYER ENGINEER Bechtel Power Corporation, Western Power Division PROFESSIONAL QUALIFICATIONS EDUCATION BS, Nuclear Engineering, Massachusetts Institute of Technology-1981 EXPERIENCE
SUMMARY
4 years as a nuclear engineer EMPLOYMENT HISTORY 1981 to present: Bechtel Power Corporation, Western Power Division PROFESSIONAL AFFILIATIONS:
Registered Professional Engineer, California SPECIFIC QUALIFICATIONS IN THE RADIATION ANALYSIS FIELD Four years with the VEGP nuclear engineering group.
Responsibilities and duties have included:
o Input to, and review of, project radiation shielding calculations. These duties required the review and understanding of the plant layout, operation and radiation sources.
o Input to, generation of, and review of, project equipment radiation dose calculations. These duties required a review of radiation sources and accident scenarios to identify qualification doses.
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