ML20058P404

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Interrogatory Response of NRC Staff to Gap 931008 First Set of Interrogatories & Second Request for Production of Documents.*
ML20058P404
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 12/20/1993
From: Barth C
NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
GEORGIA POWER CO.
Shared Package
ML20058P407 List:
References
CON-#493-14544 OLA-3, NUDOCS 9312270117
Download: ML20058P404 (2)


Text

h WWD CORRESPONDENCE December 2.0,1993

,  ?' . l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 93 Er 20 P / :1 B BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) <

) Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY, et al. ) 50-425-OLA-3

)

(Vogtle Electric Generating Plant ) Re: Licensee Amendment Units 1 and 2) ) (Transfer toSouthern Nuclear)

)

INTERROGATORY RESPONSE OF THE NRC STAFF TO GEORGIA POWER COMPANY'S OCTOBER 8,1993, FIRST SET OF INTERROGATORIES AND SECOND REOUEST FOR PRODUCTION OF DOCUMENTS On October 8,1993, the Georgia Power Company (GPC) served Interrogatories upon the Staff, designating named persons to disclose information known to them regarding possible issues in this proceeding. Without waiving any of its rights under 10 C.F.R. Part 2, the Staff has responded to the GPC interrogatories. Attached hereto and made a part herein are sworn responses by Alfred E. Chaffee, Stewart D. Ebneter, Milton D. Hunt, Peter A. Taylor, Alan R. Herdt,12igh Trocine, Ronald Aiello, Douglas Starkey, and John Rogge. The response of Kenneth E. Brockman is not attached as Mr. Brockman's extensive official travel and other NRC duties have delayed his response, which we anticipate will be filed within one week, i.e., by December 27,1993.

The Staff objects to Interrogatory 9 which asks "the NRC staff's current opinions

. . . regarding the character . . ." of named GPC present and former employees. The NRC as a collective whole does not in the normal course of business formulate an opinion as to the integrity of named persons whose work is subject to the Atomic Energy 9312270117 931220 PDR ADOCK 05000424 G PDR D7 kL  ;

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Act. Funher, the issue here is not the character of particular individuals, but whether  ;

the proposed transferee organization has the necessary attributes to receive a license.

The Staff objects to Interrogatory 10 as it calls for premature disclosure of information gathered by the Office of Investigations during the course of an investigation.

Respectfully submitted, eb/h i Charles A. Barth  ;

Counsel for NRC Staff Attachments: As indicated i i

1 Dated at Rockville, Maryland this 20th day of December 1993 6

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