ML20136J436

Second Supplemental Response to Joint Intervenors 841025 First Set of Interrogatories & Requests to Produce Re Interrogatory A-1 Concerning Identification of Expert Witnesses.W/Certificate of Svc.Related Correspondence

ML20136J436
Person / Time
Site:	Vogtle
Issue date:	01/08/1986
From:	Doris Lewis GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	JOINT INTERVENORS - VOGTLE
References
CON-#186-702 OL, NUDOCS 8601130375
Download: ML20136J436 (11)

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UNITED STATES OF AMERICA '86 NUCLEAR REGULATORY COMMISSION 10 49;33 f-

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up Lev BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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GEORGIA POWER COMPANY, et al.

) Docket Nos. 50-424 (OL)

) 50-425 (OL)

(Vogtle Electric Generating )

Plant, Units 1 and 2) )

APPLICANTS' SECOND SUPPLEMENTAL RESPONSE TO JOINT INTERVENORS' FIRST SET OF INTERROGATORIES AND REQUESTS TO PRODUCE In accordance with 10 C.F.R. 5 2.740(e)(1), Applicants provide the following supplemental response to general inter-rogatory A-1(b) of Joint Intervenors' "First Set of Interroga-tories and Requests to Produce" (Oct. 25, 1984).

INTERROGATORY A-1: Please identify (by name, business, address, occupation and employer) . . . b) each person you ex-pect to call as an expert witness in this proceeding as well as a brief description of the subject matter on which that person is expected to testify and the substance of that testimony, the witness's educational and professional background, and the identity of any previous proceedings in which that person has testified.

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i SUPPLEMENTAL RESPONSE: Applicants presently expect to call Thomas W. Crosby, Clifford R. Farrell and Lewis R. West as wit-nesses on Contention 7 in this proceeding. Mssrs. Crosby, Farrell and West are geologists employed by Bechtel Civil and Minerals Inc., P.O. Box 3695, San Francisco, California 94119.

Applicants also expect to call,Dr. Stavros S. Papadopulos as a witness on Contention 7. Dr. Papadopulos is a ground-water hydrologist and a member yof S.S. Papadopulos & Associates, 12250 Rockville Pike, Suite 290, Rockville, Maryland 20852.

Applicants expect these witnesses to testify to the adequacy of the geological / hydrological exploration at VEGP, the adequacy of data on marl thickness and permeability, the adequacy of data on marl continuity, the. direction of groundwater flow, and

. groundwater travel time. Apolicants expect that the substance of these witnesses' testimony will be similar to the averments in the previously submitted Affidavit of T. Crosby, C. Farrell, and L. West (July 8, 1985), but the substance has not yet been completely or precisely determined.

Summaries of the educational and professional background of Mssrs. Crosby, Farroll and West were previously provided with " Applicants' Motion for Summary Disposition of Joint Intervenors' Contention 7 (Ground-water)," dated July 15, 1985.

A summary of Dr. Papadopulos' qualifications is attached hereto.

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.6 Mr. Crosby has previously testified in the Skagit con-struction' permit. proceeding. Mssrs. West and Farrell and Dr. Papadopulos have not previously testified in an NRC adjudi-catory proceeding.

Respectfully submitted, e

George F. Trowbridge, P.C.

Bruce W. Churchill, P.C.

David R. Lewis SHAW, PITTMAN, POTTS & TROWBRIDGE James E. Joiner, P.C.

Charles W. Whitney Kevin C. Greene .

Hugh'M. Davenport TROUTMAN SANDERS, LOCKERMAN

& ASHMORE Counsel for Applicants Dated: January 8, 1986

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STAVROS S. PAPAD0PULOS Ground-Water Hydrologist Date and Place September 21, 1936 of Birth: Istanbul, Turkey Citizenship: U.S.A. (naturalized November 1969; first name corrected to "Stavros" from "Istavros")

Education: Doctor of Philosophy in Civil Engineering, 1964, Princeton University, Princeton, New ' Jersey.

Master of Arts in Civil Engineering, 1963, Princeton University, Princeton, New Jersey.

Master of Science in Ground-Water Hydrology, 1962, New Mexico Institute of Mining and Technology, Socorro, New Mexico.

Bachelor of Science in Civil Engineering, 1959, Robert College, Istanbul, Turkey.

Languages: English, French, Greek, Turkish, knowledge of Spanish.

Professional Registration: District of Columbia.

Professional Societies: American Society of Civil Engineers (Hydraulic Division, Comiittee on Ground-Water Hydrology, Member 1975-79; Corresponding Member 1980-81)

American Geophysical Union National Water Well Association International Association of Hydrogeologists (Member, U.S.

National Committee, 1981-84)

Sigma Xi Awards & Honors: U.S. Department of Interior Meritrocious Service Award, May 1977.

U.S. Geological Survey Special Achievement Award, September 1977.

Medal of the City of Montpellier, presented at the International Symposium on the Implications of Hydrogeology on Earth Sciences, Montpellier, France, September 11-16, 1978.

Publications: List of publications attached.

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STAVROS S. PAPAD0PULOS Ground-Water Hydrologist Professional Experience:

October 1979 to present S. S. Papadopulos & Associates, Inc., Consulting Ground-Water Hydrologisi s, Rockville, Maryland. President. As the senior executive officer of the company, manages the business aff drs of the company and provides quality control for technical services. Directs and conducts studies on all aspects of quantitative ground-water hydrology. Areas of expertise include formulation of ground-water projects, evaluation of ground-water resources through use of mathematical and digital models, design and analysis of aquifer tests, saltwater intrusion in coastal aquifers, movement of contaminants and storage of heat in aquifers, and other problems involving ground-water flow and transport of solutes and of thermal energy in hydrogeologic systems. Some recently completed or current activities for which he carries primary responsibility are listed below:

a) Serves with Prof. Pinder of Princeton University, Prof.

Cherry of the University of Waterloo and Prof. Freeze of the University of British Columbia on a committee reviewing and di,recting remedial investigations conducted by other consultants at Ciba-Geigy's Toms River Plant in New Jersey.

b) Designs hydrogeologic testing plans for Battelle Memorial Institute of Columbus, Ohio, which will be used to guide the conduct of hydrogeologic tests in monitoring and test wells associated with the Exploratory Shaft Facilities at potential high-level radioactive waste repository site in Deaf Smith County, Texas.

c) Directed supplemental hydrogeologic investigations conducted on behalf of PRPs at the Chem Dyne Site, Hamilton, Ohio, and participated in negotiations

[ leading to a Consent Decree. Currently, he is

directing additional data collection to finalize the design of an extraction / injection system for ground-l water remediation as agreed upon in the Consent Decree, d) Assisted potentially responsible parties (PRPs) in the review of investigations conducted by U.S. Envi ron-mental Protection Agency contractors and in the l

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STAVROS S. PAPADOPULOS Ground-Water Hydrologist preparation of an alternative remedial plan for the Lone Pine Landfill in Freehold, New Jersey. Currently, he serves as the Technical Coordinator for supplemental remedial investigations conducted on behalf of the PRPs.

e) Evaluated the ground-water monitoring program at the Oaks Sanitary Landfill in Montgomery County, Maryland, and designed a monitoring network that combined monitoring wells with a geophysical monitoring system.

September 1970 to October 1979 .U.S. Geological Survey, Water Resources Division, Northeastern Region, Reston, Virginia. Research Hydrologist GS-14 (9/70-11/74), Hydrologist GS-15 (11/74-9/79). Originated, planned and conducted, or directed, particularly complex research projects in the analysis of ground-water systems. Developed new, and improved existing methods for aquifer test analyses and for the evaluation of ground-water resources. Served as Research Advisor -

'l ound-Water Physics to the Assistant Division Chief ' for Research and Technical Coordination and to his Deputy- for Research, and assisted in periodically evaluating the Division's research pro gram. Frequently acted for the Deputy Assistant Chief Hydrologist for Research, and for the Regional Research ' Hydrologist. Made field trips to district offices to provide technical assistance to project chiefs engaged in ground-water investigations, and informed the Regional Hydrologist on progress and problems in the project. Participated and represented the U.S. Geological Survey in national and international conferences. Lectured in training schools and in advanced seminars held for Survey and developing country agency personnel. Conducted a variety of ground-water studies of national and regional interest, including the assessment of the energy potential of the Gulf Coast geopressured zones, the feasibility of aquifer thermal energy storage and the evaluation of shallow land burial sites for low-level radioactive wastes, and undertook assignments in Saudi Arabia and Portugal on detail to other U.S. agencies and to UNESCO.

September 1969 to September 1970 University of Illinois at Chicago Circle, Department of Geological Sciences, Chicago, Illinois. Associate Pro fesso r. Taught courses in ground-water hydrolo gy, engineering and structural geology, and advised graduate students majoring in ground-water hydrology. Conducted 3

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STAVROS S. PAPAD0PULOS Ground-Water Hydrologist research on the application of digital computer techniques to well hydraulics and aquifer evaluation studies. Served on the Executive Committee of the department and on various other departmental and university connittees.

Harza Engineering Company, Chicago , Illinois. Chief Ground-Water Hydrologist. Served on the staff of the company as consultant on ground-water studies for water and land resources development projects. In this capacity, participated in ground-water studies for the Lake Minnetonka Project, initiated reconnaissance studies of the potential of ground water in Northern Guatemala, and served as leader of a Harza team of experts in Indonesia for the formulation of a ground-water exploration program designed to assess the technical feasibility of developing ground-water for irrigation in several areas in Java and to identify within these areas pilot irrigation projects which will provide data for subsequent large scale development of irrigation projects making conjunctive use of surface and ground-water supplies.

June 1967 to September 1969 Harza Engineering Company, Chicago, Illinois. Ground-Water Specialist, Planning Division (6/67-10/67), Head of Hydrology ' Department, Water Resources Division (10/76-9/69). Supervised engineers engaged in hydrologic and ground-water investigations and in preparation of planning repo rts . Conducted continuous broad view and direction of all aspects of planning involving ground-water resources, including preliminary and detailed exploration programs, pumping tests, resource evaluation, aquifer projection studies and definite project formulation. Responsible for development of standards and procedures for all ground-water related activities. Major assignments included ground-water studies for the Chicago Deep Tunnel Project, the Irrigation Rehabilitation Project in Indonesia, and the Ullum Project in Argentira.

University of Illinois at Chicago Circle, Department of Geology , Visiting Associate Professor. Taught evening courses in ground-water hydrology.

September 1966 to June 1967 University of Minnesota. Department of Geology and Geophysics, Minneapolis, Minnesota. Associate Professor.

Conducted research in well hydraulics and aquifer evaluation methods and taught courses in ground-water 4

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STAVROS S. PAPADOPULOS Ground-Water Hydrologist hydrology. Served on the Graduate Admissions Committee of the department.

September 1963 to September 1966 U.S. Geological Survey, Water Resources Division, Arlington, Virginia. Hydraulic Engineer GS-9 (9/63-2/64),

Research Engineer GS-11 (2/64-3/65), and Research Hydrologist G-12 (3/65-9/66). Conducted basic and applied research in the mechanics of ground-water flow.

Served as consultant to District offices on special problems such as seepage estimates for Cedar Lake in Washington, analyses of limited pumping-test data in Puerto Rico, the Virgin Islands, North Carolina and Florida, and tracer studies in Colorado. Lectured on aquifer test methods in training conferences for Survey personnel.

Prepared and reviewed technical papers.

The George Washington University, School of Engineering an'd Applied Science, Washington, D.C. Part-time Associate Professorial Lecturer (9/65-5/66). Taught evening courses in hydrology, hydraulic engineering and soil mechanics.

September 1961 to September 1963 Princeton University, Department of Geological Engineering, Princeton, New Jersey. Graduate Assistant (9/61-6/62) and 9/62-6/63). Conducted research in flow through porous media and taught a course in the theory of ground-water motion.

U.S. Geologic Survey, Water Resources Division, Ground-Water Branch, Denver, Colorado. Hydraulic Engineer GS-9 (6/62-9/62). Prepared type-curves for the evaluation of wedge-shaped aquifers in the Little Plover Basin, Wisconsin.

New Mexico Institute of Mining and Technology, Socorro, New Mexico. Research Assistant (6/63-9/63), and U.S.

Geological Survey, Water Resources Division, Ground-Water Branch, Trenton, New Jersey. Hydraulic Engineer GS-9 (3/63-9/63). Conducted research on the non-steady flow to multiaquifer wells (project was supported by the Survey and used as a Ph.D. thesis).

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STAVROS S. PAPAD0PULOS Ground-Water Hydrologist September 1959 to September 1961 New Mexico Institute of Mining and Technology, Socorro, New Mexico. Graduate Research Assistant. Conducted research in problems related to ground-water flow.

June 1958 to September 1959 The U.S. Army Corps of Engineers (TUSEC), Trabzon (6/58-9/ 58 ) and Sinop (6/59-9/59), Turkey. Assistant Engineer LGS-7. Inspected general construction work and assisted in preparing revisions to design and specifications to fit local field conditions.

Expert Testimony: U.S. District Court, Western District of Tennessee, Eastern Division: Woodrow Sterling et al. vs. Velsicol Chemical Corporation (July 1982).

December 1985 6

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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 (OL)

) 50-425 (OL)

.(Vogtle Electric Generating )

Plant,. Units 1 and 2)- )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Second Sup-

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_plemental Response to Joint Intervenors' First Set of Interrog-atories and Requests to Produce," dated January 8, 1986, were served t aon' those persons on the attached Service List by de-posit in the United States' mail, postage prepaid, this 8th day of January, 1986.

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David R.. Lewis Dated: January 8, 1986

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.h UNITED STATES OF AMERICA

-NUCLEAR REGULATORY COMMISSION Before the Atomic' Safety and Licensina Board

'In the-Matter of- )

)

-GEORGIA POWER. COMPANY, -- -~et al. ) Docket No.~50-424

) 50-425 (Vogtle 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, GA 30306

Washington, D.C. 20555 Mr. Gustave A. Linenberger Laurie Fowler

-Atomic Safety and. Licensing Board 218~ Flora Avenue, N.E.

U.S. Nuclear Regulatory Commission Atlanta, GA 30307

Washington, D.C. 20555 l

Dr.' Oscar H. Paris' Tim Johnson Atomic Safety and Licensing Board Campaign for a Prosperous U.S. Nuclear Regulatory' Commission Georgia Washington, D.C. ~20555 1083 Austin Avenue, N.E.

Atlanta, GA 30307 Bernard M. Bordenick, Esq.

-Office of Executive Legal Director Docketing and Service Section U.S. Nuclear. Regulatory Commission Office of the Secretary Washington,.D.C. 20555 U.S. Nuclear Regulatory Commission Atomic. Safety and Licensing Washington, D.C. 20555 Board Panel U.S. Nuclear Regulatory Commission Bradley Jones, Esquire Washington,.D.C. 20555 Regional Counsel U.S. Nuclear Regulatory

.romic Safety'and' Licensing Commission Appeal Board Panel Suite 3100 U.S. Nuclear Regulatory Commission 101 Marietta Street Washington,'D.C. 20555 Atlanta, GA 30303

.