ML20045D795

Forwards Exhibit a to Ga Power Co Motion to Compel Intervenor Production of Documents & Responses to Certain Interrogatories Which Were Inadvertantly Omitted from 930617 Motion to Compel.W/Certificate of Svc & Svc List

ML20045D795
Person / Time
Site:	Vogtle
Issue date:	06/22/1993
From:	Lamberski J GEORGIA POWER CO., TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA
To:	Bloch P, Carpenter J, Murphy T Atomic Safety and Licensing Board Panel
References
CON-#293-14064 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9306300068
Download: ML20045D795 (4)

Text

TROUTMAN SANDERS a

• • m-ta t nu

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=a com om o s NATIONSBANK PL.AZA 600 PE ACHTRE E STREE T. N E. - SUITE 5200

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ATLANTA, GEORGIA 30308-2216 L 4 TELEPHONE: 404-885 3000 F ACSIMIL E. 404 885 3900

OHN LAMBERSKI DIRECT. 404 885 3360 June 22,1993 l

1 Peter B. Bloch, Esq., Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. James H. Carpenter Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Thomas D. Murphy Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Mattar of Georgia Power Conipany et al.

(Vogtle Electric Generating Plant, Units 1 and 2)

Docket Nos. 50-424-OLA-3 & 50-425-OLA-3 ASLBP No. 93-671-01-OLA-3

Dear Sirs:

I attach Exhibit A to Georgia Power Company's Motion to Compel Intervenor's Production of Documents and Responses to Certain Interrogatories which was inadvertently omitted from the Motion to Compel when it was filed on June 17, 1993.

Very truly yours, l

0 John Lamberski l

JL:svb Enclosure o

350

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CONF 10Eh11ALITY AGREEMENT l have infomation that I wish to provide in confidence to the U.S. Nuclear I request an express pledge of confidentiality Regulatory Comission (NRC).

as a condition of providing this inforestion to the NRC.

It is ry understanding that, consistent with its legal obligationi the NRC, by agreeing to this confidentiality, will adhere to the folleving conditions.

During the course of an inquiry or investigation, the NRC will make its (1) best effert to avoid actions which would clearly be expected to result in dis-closure of my identity to persons subsequently coming in contact with the NRC.

Except as necessary to assure public health and safety and ucept as (2) necessary to infom Congress or State or Federal agencies in furtherance of their responsibilities under law or public trust, the NRC will not identify me by nane or personal identifier in any conversation, ccreunication or The NRC will use its best NRC initiated document released outside the NRC.

effort to minimize any disclosures made outside of the NRC.

The NRC will disclose ray identity inside the NRC only on 4 need-to-know (3) basis to the extent required for the conduct of HRC related activities.

Consequently, I acknowledge that if I have further contacts with NRC person.

nei,1 cannot expect that those people will be cognizant of this Confidentiality Agreement anc it util be my responsibility to bring that point to their attention if I desire similar treatment for the infomation provided to them.

Even though the NRC will make its best effort to protect my identity, eJ (4) identification could te ccepelled by orders or subpoenas issued by courts of In rearirg boards, Administrative '.aw Judges, or similar legal entities.

law, such cases, the basis for granting this promise of confidentiality and any cther relevant f acts will be comunicated by the NRC to tne authority ordering the disclosure in an ef fort to maintain my confidentiality.

1 also understand that the NRC will consider ce to have waived my right to cenfidentiality if I take, or have taker), any action so inconsistent with the grant of confidentiality that the action overrides the purpose behind the conficentiality such as (1) disclosino publicly infomation which reveals my status as a confidential source or (2} intentionally providing f alse informa.

The NRC will attempt to notify tr,e of its intent to revoke tion to HRC.

confidentiality and provide me an opportunity to explain why such action should not be taken.

/7/E /Wex' warred /A/#4

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Other Conditions: (if any)

NO/ct kc'A'N, CN Anf f5 mfd H 4.jssueli

ftMXCL, b40Y / Ar,9//..wa dY Ny 7?/E fenrENrr er if y infAkfME frN/LCASA/7w wirff MC7EC AND ON wkt /f /WO Acf 77 ea['an Nehtand the contents of this agreenent. 1 agree with I

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//A$ l2!%f its provisions.

G-l1 1C Kakh /+n L. Hisba o Date; Address: /70tAq's

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kvelow ry Comissio, a JoTI)

Agreed to on behalf of the U.S. Nuclear Regu16 sdwa M, /9fD

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LBgnaturt:LALAY L. AYa/w/C'A-l Date:

Name:

Tit 1e: zwwsmarc,e Morf ste wMsY7M'M3 p

EXHlBII ElG8 I OF l

i 1

N

4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of GEORGIA POWER COMPANY, Docket Nos. 50-424-OLA-3 l

et al.

50-425-OLA-3 l

Re: License Amendment (Vogtle Electric (Transfer to Southern Generating Plant, Units 1 and 2)

Nuclear)

ASLBP No. 93-671-01-OLA-3 i

CERTIFICATE OF SERVICE This is to certify that copies of the within and foregoing 1

" Exhibit A" to Georgia Power Comoany's Motion to Compel Intervenor's Production of. Documents and Responses to Certain Interrogatories were served on all those listed on the attached service list by depositing same with an overnight express mail j

delivery service.

This is the 22nd day of June, 1993.

o n Lamberski ROUTMAN SANDERS i

Suite 5200 600 Peachtree Street, N.E.

Atlanta, GA 30308-2216 (404) 885-3360 i

.-,,.,.,,,,,,-m

,......,.... -.. -. ~ _. _,,,,...

1 UNITED STATES OF AMERICA i

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of GEORGIA POWER COMPANY, Docket Nos. 50-424-OLA-3 et al.

50-425-OLA-3 Re: License Amendment (Vogtle Electric (Transfer to Southern Generating Plant, Nuclear)

Units 1 and 2) f ASLBP No. 93-671-01-OLA-3 8

_ SERVICE LIST Administrative Judge Stewart D.

Ebneter Peter B.

Block, Chairman Regional Administrator Atomic Safety and Licensing USNRC, Region II Board 101 Marietta Street, NW U.S.

Nuclear Regulatory Suite 2900 Commission Atlanta, Georgia 30303 Washington, D.C.

20555 Office of the Secretary Administrative Judge U.S.

Nuclear Regulatory James H.

Carpenter Commission Atomic Safety and Licensing Washington, D.

C.

20555 Board ATTN:

Docketing and U.S.

Nuclear Regulatory Services Branch Commission Washington, D.C.

20555.

Charles Barth, Esq.

Office of General Counsel Administrative Judge One White Flint North Thomas D. Murphy Stop 15B18 Atomic Safety and Licensing U.S. Nuclear Regulatory Board Commission U.S.

Nuclear Regulatory Washington, D.

C.

20555 Commission Washington, D.C.

20555

Director, Environmental Protection Michael D.

Kohn, Esq.

Division Kohn, Kohn & Colapinto, P.C.

Department of Natural 517 Florida Avenue, N.W.

Resources Washington, D.C.

20001 205 Butler Street, S.E.

Suite 1252 Office of Commission Appellate Atlanta, Georgia 30334 i

Adjudication i

One White Flint North 11555 Rockville Pike Rockville, MD 20852 ATTENTION:

Docketing and Service Branch

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