ML20070D490
| ML20070D490 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/29/1994 |
| From: | Kohn M AFFILIATION NOT ASSIGNED, KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA |
| To: | GEORGIA POWER CO. |
| References | |
| CON-#394-15299 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9407080122 | |
| Download: ML20070D490 (22) | |
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,7 ATOMIC SAFETY AND LICENSING BOARD '94 JUN -30 P4 :05 i
Before Administrative Judges: j g SECRERRY Peter B. Bloch, Chair Dr. James H. Carpenter CMMU b [pv;cE l D:M M C H Thomas D. Murphy
)
In the Matter of )
) Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY ) 50-425-OLA-3 el. al., )
) Re: License Amendment (Vogtle Electric Generating ) (transfer to Southern Nuclear)
Plant, Unit 1 and Unit 2) )
) ASLBP No. 93-671-01-OLA-3 INTERVENOR'S FOURTH INTERROGATORY AND DOCUMENT REQUEST TO GEORGIA POWER COMPANY l
I. INTRODUCTION Pursuant to 10. C.F.R. S2. 74 0 (b) and S2.741, Intervenor Allen Mosbaugh hereby requests that Georgia Power Company (hereinafter referred to as "GPC") answer the following interrogatories in writing and under oath and produce documents < identified in response to the below identified interrogatory questions. Intervenor requests that responses be filed within 14 days from the service of this request and that all relevant documents be made available for inspection and copying within 14 days. Intervenor requests that these document be produced within 30 days from_the service of this request. II. INSTRUCTIONS A. If you cannot answer a particular interrogatory in full, after exercising due diligence to secure the information to do so, so state and answer to the extent possible, specifying and lpdu -
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((yy 4.p* _ DC-explaining you inability to answer the remainder and stating whatever information or knowledge you have concerning the unanswered portion. B. Each interrogatory is a continuing one, and should be supplemented as required by 10 C.F.R. 52.740(e). C. If you claim that any information which is required to be provided by you in your response to any of these interrogatories is privileged or immune from discovery:
- 1. Identify the portion of the interrogatory to which such information is otherwise the response;
- 2. If the information is a document or oral communication, identify the document's title or the oral communication and state the general subject matter of the document or oral communication;
- 3. If the information is a document or oral communication, state the date of the document or oral communication.
- 4. If a document, identify its author (s) and the person (s) for whom it was prepared or to whom it was sent, including all persons who received copies;
- 5. If an oral communication, identify all persons i
present at the time of the oral communication;
- 6. State the nature of the privilege or immunity claimed; and
- 7. State in detail each and every fact upon which you base your claim of privilege or immunity from discovery.
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M' D. In each case where you are asked to identify or to state the identity of a document or where the answer to the interrogatory refers to a document, state with respect to each such document:
- 1. The identify of the person who prepared it;
- 2. The identity of all persons who reviewed or approved it;
- 3. The identity of the person who signed it, or over whose name it was issued;
- 4. The identity of the addressee or addressees;
- 5. The nature and substance of the document with i sufficient particularity to enable the same to be identified; ,
- 6. The date of the document; and
- 7. The present location of the document and the identity and address of each person who has custody of the document.
E. In each case where you are required to identify an oral communication, or where the answer to the interrogatory refers to an oral communication, state with respect thereto:
- 1. The date and place thereof; 1
- 2. The identity of each person who participated in or heard any part of the communication; 3.
}fthecommunicationwasbytelephone, so indicate and state who initiated the telephone call; 3 3 i < l f x+a
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- 4. The substance of what'was said by each' person who participated in the communication; and
- 5. The location and the identity and address of the -
custodian of any document (including any mechanical, magnetic, electrical or electronic recording) that recorded, summarized, reported or confirmed the oral communication. F. In each instance where you are asked to identify or state the identity of a person, or where the answer to an interrogatory refers to a person, state with respect to each such person: , i
- 1. His/her name;
- 2. His/her last known business and residence addresses and telephone numbers;
- 3. If an individual, his/her business affiliation or employment at the date of the transaction, event or matter referred to; and
- 4. If a corporation or association, the business or !
activity in which it was engaged at the date of the j transaction, event or matter referred to. III. DEFINITIONS
- 1. The term "NRC" shall mean every past or present employee of the Nuclear Regulatory Commission, any investigative body, office or subdivision of the Nuclear Regulatory Commission, every past or present Commissioner of the Nuclear Regulatory Commission.
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af IN:52 2. " Document" shall mean every instrument or device by I which, through which or on which information has been recorded including those reflecting meetings, discussions or conversations; notes; letters; drawings; files; graphs; charts; maps; photographs; deeds; studies; data sheets; notebooks; books; appointment calendars; telephone bills; telephone messages; receipts; vouchers; minutes of meetings; pamphlets; computations; calculations; accounting (s) ; financial statements; voice recordings; computer printouts; and device or media on which or through which information of any type is transmitted, recorded or preserved. The term " document" also means every copy of a document when such copy is not an identical duplicate of the original.
- 3. " Contact" means any and all communication by any means whatsoever that involved a transfer of information, whether written, oral or in any other form, including discussions, letters, memoranda, telephone calls, or telegrams.
- 4. The term " identify" means:
- a. As to conversations, stating the parties of the conversation, the date of the conversation, the subject matter of the conversation, and the portions of the conversation responsive to the particular interrogatory;
- b. As to the individuals, stating their name, business address, position or job, their relation, if any, to the f
parties in this proceeding, and their present or former affiliation or_ contact with Respondent; 5 e ', . (( .& . m -
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- c. As to meetings and contacts, statling the date of each such meeting or contact, the participants and the titles of those participants, and the substance thereof. Identify all documents written during, or as a result of, such meeting or contact. Identify all communications preceding, during, and subsequent to such meeting or contact.
- 6. As used herein the term " Notice of Violation" or "NOV" shall refer to the Notice of Violation and Proposed Imposition of Civil Penalties, Docket # 50-424, issued on May 9, 1994.
- 7. As used herein the term " Demand for Information" shall refer to the Demands for Information which were issued in conjunction with the Notice of Violation on May 9, 1994 to the following persons:
- a. Thomas V. Greene
- b. Georgie R. Frederick
- c. Harry W. Majors
- d. Michael W. Horton
- e. C. Kenneth McCoy
- f. George Bockhold, Jr.
- 8. As used herein, the terms " Licensee", " Georgia Power Company", "The Southern Company", "SONOPCO", and any other derivative therefrom are intended to, and shall, embrace and 1
include any agent or employee of Georgia Power Company, The l Southern Company, and/or SONOPCO, past or present, their counsel and all their respective agents, servants, associates, employees, r.epresentatives, private investigators, and others who are or 1 6 l vn, w l 4.y.w; sg;ma .u - . ,. l h . 21;kkb j<
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y., , . R j, gE . " - % ll - l bI ~ t [+ have been in possession of or may have obtained information for t-or on behalf of Georgia Power Company, The Southern Company, and/or SONOPCO.
- 9. As used herein, the terms "you" and "your" refers to the following persons:
- a. all persons listed in Part III, definition No. 7.
- b. the representatives of all persons listed in Part III, definition No. 7.
- c. all directors and officers of Georgia Power company.
- d. any person representing Georgia Power Company in this licensing proceeding.
- e. any person with the authority to act as an official representative of Georgia Power Company.
IV. INTERROGATORIES AND DOCUMENT REOUESTS
- 1. Identify all contacts you or any person acting on your behalf, has had with the NRC, directly or indirectly related to the Notice of Violation of May 9, 1994 and/or the Demands for Information which were included with it, since May 9, 1994.
- 2. Identify and produce all documents, internal and external, which were produced as a result of any of the contacts ;
referred to in your response to Interrogatory No. 1. !
- 3. State whether GPC provided to the NRC or any of its personnel in the time frame between 3-20-90 and 4-14-90 a table
-p of Safety System Performance indicators (SSPI) data for the l l
Vogtle Emergengy_AC power system, identical or substantially 7 n r~ N pt J.
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- 4. State the daily high and low outdoor temperatures of +
each day between March 1, 1990 and June 30, 1990 at the plant Vogtle site as recorded by the meteorological station located at plant Vogtle.
- 5. Produce all correspondence between you or any person acting on your behalf and the NRC directly or indirectly related to the NOV and/or the Demands for Information for the period from May 9, 1994 to present.
- 6. Intervenor request all performance appraisals for the time period from 1988 to present for the following persons:
- a. Thomas Beckham
- b. Joseph Farley
- c. George Hairston
- d. Louis Long
- e. Patrick Mcdonald
- f. Charles McCrary
- g. Ken McCoy ,
- h. John Meyer
- 1. Jack Woodward
- 7. Produce the Plant Vogtle " Duty Engineer Daily Log" for the years 1989 and 1990.
- 8. Produce all " Deficiency Cards" for Vogtle Units 1, 2, or common, that relate to emergency diesel generators, diesel generator sub-systems, diesel generator support systems, diesel 8
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generator components, diesel generator startihg problems or failures, dienel generator running problems and failures, diesel generator trips, diesel generator air quality, diesel generator control air humidity or dewpoints. Include copies of both front and back of the deficiency card and copies on any attachments including Root Cause and Corrective Action sheets.
- 9. Produce all completed Preventative Maintenance (PM) checklist, SCL-166, for Vogtle diesel 1A, 1B, 2A, and 2B, for the years 1989 to the present. These PM checklists pertain to the measu: ents of control air dewpoints for the EDG's.
- 10. Produce copies of the following Deficiency Cards (include both front and back as well as attachments):
- a. DC 1-90-186
- b. DC 1-89-1316
- c. DC 1-89-1317
- 11. Produce copies of the following Maintenance Work Orders and all documents contained in the entire work order package created in response to the maintenance work performed with respect to Work Order Nos:
- a. MWO 1-90-01513
- b. MWO 1-90-00899
- c. MWO 2-90-01136
- d. MWO 2-90-00964 i l
- e. MWO 1-88-07746 i
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- f. MWO 1-90-01514 y g. EWO 1-88-02991
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- 12. Produce a copy of the " table or dewpoint results for:
Unit 1 for the last couple of years" that was requested by Al - Chaffee on 4-9-90 to be provided to the NRC during a conference call with GPC personnel. Participating on that call from GPC were skip Kitchens, Paul Kochery, Herb Beacher, and Louis Ward.
- 13. Pc oduce the portions of Bill Shipman's daily spiral notebook for 1990 that were not included in previous versions, i.e., the missing pages from the period 3-20-90 to the end of 1990 and in the months of January, February and March 1990.
- 14. Produce the portions of Bill Shipman's daily spiral notebook for 1990 that were not included in previous versions, i.e., the missing pages from the period 3-20-90 to the end of 1990 and in the months of January, February and March 1990.
- 15. Produce any Maintenance work order and similar maintenance work documentation from 1990 associated with the inspection or cleaning of the air receiver tanks associated with the diesel starting and control air systems for Vogtle diesels 1A, 1B, 2A, or 2B.
- 16. Produce the complete 80 sheet notebook of Kenneth McCoy for the period of June 25 to September 28, 1990 and produce the other notebooks and similar such notebooks / records maintained by Mr. McCoy between January and December of 1990. This can be identified by Bates numbers 024324-024336.
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- 17. With respect to the following individuals:
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'a ) KEN HOLMES; b) PAUL KOCHERY; c) KENNETH STOKES; d) TOM" l
WEBB; e) RICK ODOM; f) SKIP KITCHENS; g) GUSS WILLIAMS; h) GEORGE BOCKHOLD; i) JAMES BAILEY; j) WILLIAM SHIPMAN; k) PAUL RUSHTON; 1) LOUIS WARD; m) CLIFF MILLER; n) MARK AJULUNI; o) DAVID LISENBY; p) C. K. MCCOY; q) GEORGE HARISTON; r) R.P. MCDONALD; s) JOSEPH FARLEY; t) A.W. DAHLBERG; u) JOHN AUFDENKAMPE; v) MICHAEL HORTON; w) GEORGIE FREDERICK; x) JACK STRINGFELLOW and y) TOM GREENE; Produce documents responsive to the following: (1) documents which contain the hand writing, thoughts or impressions of the witness with respect to: a) L3F. 90-006, b) the April 9, 1990 presentation to the NRC; c) the April 9, 1990 corrective action response filed by GPC; d) any issues identified in NRC OI Report 2-90-020R or the May 9, 1994 Notice of Violation issued by the NRC to Georgia Power Company; (2) documents that contain information which directly or indirectly relates to the reliability of the Plant Vogtle diesel generators or the air quality of said diesel generators with respect to air quality or reliability problems occurring between 1989 and present; (3) documents transmitted between the plant Vogtle site and/or the SONOPCO/GPC Birmingham corporate offices that in t S1 -
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t - is oi ~ M<- . any way concerns the diesel generators or site area emergency; (4) all personal notes, log books, note books, personal calendars, taped memos, tape recordings or other documentation prepared by the witness or which includes the thoughts or impressions of the witness for the time period of January 1, 1990 through December 31, 1990; i (5) all log books or note books any of the witnesses maintained, reviewed or relied upon when performing any business function related to the start-up of plant Vogtle after the Site Area Emergency. l
- 18. Identify when language reflecting that: 1) the diesel l generators had been started 18 and 19 times each without problems or failures ; and 2) the wording related to air quality of the D/G air system including dewpoint control; and 3) wording related to the determination that dew points were higher than expected due to faulty instrumentation, appeared in any and every draft or final version of the April 9, 1990 Confirmation of Action response. In addition:
- a. state each and every person who helped design or craft this language. For each and every person identified, state:
- 1) the date and time of their involvement; ii) the sum and substance of their involvement with respect to any portion of the wording they worked l i
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- 19. Identify each and every document submitted to the NRC -
or any employee thereof that demonstrated a failure of any diesel generator after March 20, 1990.
- a. For each and every such document state:
i) its author; ii) the time, date, method of delivery; iii) to whom it was delivered and/or addressed,
- b. Produce all documents identified together with any document demonstrating the date, time or method of delivery to NRC.
- 20. With respect to the following phrase contained in GPC's April 1, 1991 response to Intervenor's 2.206 Petition:
The wording was reviewed by corporate and site representatives in a telephone conference call late on April 19, 1990. Although Mr. Hairston was not a participant on this call, he had every reason to believe the final draft LER presented to him after the call was accurate and complete.
- a. State each and every fact know to Licensee / Southern Nuclear at the time determine that the above statement represented the whole truth and/or was not misleading and/or false;
- b. State whether any affidavits obtained by counsel to Licensee and/or Southern Nuclear utilized in any form statements contained therein to determine that the information portrayed was correct; w_
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- c. Identify each and every person (including lbgal counsel) who helped draft or reviewed the-phrase:
i) For each such person identified, state what fact or facts were relied upon to verify this statement. 4
- 21. Identify the specific segment or segments of any portion of any call contained on tape No. 58 which resulted in the revision of any portion of the following-phrase:
After the 3-20-90 event, the control systems of both engines have been subjected to a comprehensive test program. Subsequent to this test program, DG1A and DG1B have been started at least 18 times each and no failures or problems have occurred during any of these starts. Please identify the specific tape segment (s) by way of citing to a dated version of the Tape 58 Transcript recently prepared by GPC and identify the page number (s) and line numbers responsive to this request.
- 22. State whether anyone in the Birmingham offices ever contemplated using the phrase " comprehensive test program" (or any equivalent such phrase) in a draft or final version of LER 90-006. If the answer is yes state:
- a. The sum and substance of all discussions not included in tape No. 58 that relates to the contemplated use of the phrase;
- b. the date and time of any such discussion.
If the exact date or time cannot be recalled, identify whether.it w occurred before or after Tape No. 58 or between any jeg_ segm,ent recorded on this tape.
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- 23. State the identify of each and every individual in the Birmingham offices at the time LER 90-006 was signed out by Mr.
Hairston who knew the definition of the phrase " comprehensive test program" contained in the LER. For each such person identified, state:
- a. What source (s) of information or statement (s) from any individual were relied upon to form the basis for their definition together with a summary of the information provided;
- b. The start number for each diesel generator which corresponds to the individual (s) definition;
- c. How the source of information was verified and by whom it was verified.
- 24. State whether any individual in the Birmingham offices learned at any time on or before April 19, 1990 that wording contained in the April 9, 1990 COA response related to the number of starts of the diesel generator could or did constitute a material false statement. If the answer is yes:
- a. identify each and every person who learned of this;
- b. identify the source of their knowledge;
- c. identify each and every person who received second-hand information from either Mr. Stringfellow of Mr. Shipman or any other individual who became aware that the COA response could or did contain a material false
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- 25. Identify all steps taken by anyone in Birmingham between April 9-30, 1990 to determine whether a material false statement was contained in the April 9, 1990 COA response.
- 26. State whether anyone in Birmi'gham intended to take any action to correct the April 9, 1990 COA response before Allen Mosbaugh requested such action in an April 30, 1990 memor'ndum a he presented to G. Bockhold.
- 27. State the identify of each and every manager stationed in Birmingham who was aware that Mr. Mosbaugh had submitted his April 30,*1990 memorandum to G. Bockhold (identified in GPC's request for stipulation as Exhibit 33).
28.1 State whether Licensee believes that, pursuant to 10 C.F.R. 50.9, a licensee would be required to notify the appropriate regional administrator of the NRC of any significant information contained in a COA response letter transmitted by a licensee to the NRC that was either false, misleading or materially incorrect within two (2) working days. If the answer is yes, state:
- a. Whether SONOPCO/GPC ever notified the Region II administrator of any misleadin,g, false or materially incorrect information contained in either the April 9, 1990 CCA Response within two working days.
28.2 State whether any managers at the Birmingham corporate offices discussed whether 10 C.F.R. 50.9 applied to filing corrections t the COA response letter.
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- 29. With respect to responses to questions numbered 3 and 5 set out in the document entitled Response to NRC Question Concerning Diesel Starts Reported on April 9, 1990 and in LER 90-06, Revisions 0 and 1 (NRC-OI Report Exhibit No. 44), state the following:
- a. the entire process used to gather information to respond to these questions;
- b. whether any earlier draft or document used, when preparing any earlier draft or the final document identified Mr. McCoy as a participant and, if so, who decided to delete Mr. McCoy's name, the basis for deleting Mr. McCoy's name.
- c. whether any earlier draft or document used when preparing any earlier draft or the final document identified other participants not listed in the response to questions 3 or 5. If the answer is yes, state who decided to delete the identity of the other participant (s) and the basis for the decision to delete these names;
- d. who was given overall responsibility to verify the information;
- e. The exact role Mr. Frederick played in responding to these questions;
- f. The exact role each and every attorney involved in preparing these responses played in verifying and/or
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- g. Whether Mr. McCoy was specifically asked whether he participated in a phonecon between site management and corporate management and his response to this question;
- h. Whether Mr. Hairston was specifically asked whether he 1
participated in a phonecon between site management and l corporate management and his response to this question. ) 1
- 30. With respect to responses to questions number 1 set out I in the document entitled Response to NRC Question Concerning Diesel Starts Reported on April 9, 1990 and in LER 90-06, Revisions 0 and 1 (NRC-OI Report Exhibit No. 44), state whether it accurately portrays that Mr. Burr worked on the slide presentation. Additionally state:
a, the entire process used to gather information to respond to this question;
- c. whether any earlier draft or document used when preparing any earlier draft or the final document identified or had deleted any other participants not listed in the response to question 1. If the answer is yes, state who decided to delete or any name and the basis for the decision to delete or add the name;
- d. who was given overall responsibility to verify the information;
- e. The exact role Mr. Frederick played in responding to this question;
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- f. The exact role each and every attorney involved in preparing these responses played in verifying and/or drafting the response;
- g. Whether Mr. Burr was specifically asked whether he should be identified in the answer to question 1.
- 31. With respect to responses to question Nos. 3 and 5 to NRC OI Exhibit No. 44, state whether Southern Nuclear personnel ever learned that the response to question Nos. 3 or 5 were false, incomplete or misleading. If the answer is yes:
- a. State the date and time Southern Nuclear personnel first learned of this;
- a. State whether 10 C.F.R. 50.9 requires timely notification (within 2 working days) of false, misleading or incomplete response. If the answer is no, please explain your response in detail; If the answer is yes, state whether 10 C.F.R. 50.9 requirements were complied with inasmuch as no timely notification occurred with ted to the NRC.
- 32. With respect to page 73, paragraph 177 of the NRC OI Report 2-90-020R, identify who "everybody" refers with respect to i Mr. Hariston's statement referenced in this paragraph.
Additionally, state: l 1
- a. how Hairston determined that everyone agreed;
- b. from whom Hairston learned that everyone agreed;
- c. when and from whom Hairston learned for the first
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C time that not everyone agreed.
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9 1 Respectfully submitted, 1 l Michael D. Kohn l Mary Jane Wilmoth ! KOHN, KOHN AND COLAPINTO 517 Florida Avenue, N.W. Washington, D.C. 20001-1850 (202) 234-4663 Attorneys for Intervenor Dated: June 29, 1994 CERTIFICATE OF SERVICE I hereby certify that a copy of Intervenor's Fourth Interrogatory and Document Request to Georgia Power Company was served this 29th day of June, 1994 by hand-delivery upon counsel to Licensee, David R. Lewis, Esq., located at Shaw, Pittman, Pitts & Trowbridge, 2300 N Street, N.W., Washington, D.C., and by first class mail upon the persons listed in the attached Service List. By: b+[fN# fa Mary Jahe Wilmoth, Esq. KOHN, KOHN & COLAPINTO, P.C. 517 Florida Ave., N.W. Washington, D.C. 20001 (202) 234-4663 w '%k 20 e
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00CKETED UNITED STATES OF AMERICA ~ USHRC NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
'94 JN 30 P4 :05
)
In the Matter of )
) Docket Nos. 50-424-OLaFBICE 0' ELRETARY GEORGIA POWER COMPANY ) 50-425-OLA90KETDd3 CEFVICE gt al., ) BHisHCH
) Re: License Amendment (Vogtle Electric Generating ) (transfer to Southern Nuclear)
Plant, Unit 1 and Unit 2) )
) ASLBP No. 93-671-01-OLA-3 SERVICE LIST Administrative Judge Peter B. Bloch, Chair Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Administrative Judge James H. Carpenter 933 Green Point Drive Oyster Point Sunset Beach, NC 28468 Administrative Judge Thomas D. Murphy Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Charles A. Barth, Esq.
Office of General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 John Lamberski, Esq. Troutman Sanders Suite 5200 600 Peachtree Street, N.E. Atlanta, GA 30308-2216 nk di - E~
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. . s Office of the Secretary Attn: Docketing and Service U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Office of Commission Appellate Adjudication U.S. Nuclear Regulatory Commission Washington, D.C. 20555 301\ cert.lis i
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