|
---|
Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20092H7681995-09-13013 September 1995 Georgia Power Co Fourth Suppl Response to AL Mosbaugh Third Set of Interrogatories & Request for Documents.* Related Correspondence ML20087K3481995-08-17017 August 1995 Gap First Supplemental Response to Intervenor Fifth Interrogatory & Document Request.* Response Suppls Gap Prior Response to Interrogatory 7.W/Certificate of Svc & Svc List. Related Correspondence ML20086H1291995-06-30030 June 1995 Georgia Power Company Supplemental Response to Intervenor Seventh Request for Interrogatories.* W/Certificate of Svc & Svc List.Related Correspondence ML20082L2001995-04-12012 April 1995 Intervenor Supplemental Responses to Georgia Power Company First,Second & Third Requests for Interrogatories & Prior Requests for Documents.* W/Certificate of Svc & Svc List. Related Correspondence ML20080N8401995-02-28028 February 1995 Intervenor Document Request to NRC Staff.* Intervenor Requests That Response Be Submitted within 10 Days as Law Requires.W/Certificate of Svc & Svc List ML20080N9451995-02-28028 February 1995 Intervenor Document Request to MW Horton.* Request Made for Personal Documents Not Previously Produced in Case. W/Certificate of Svc.Related Correspondence ML20080N9311995-02-28028 February 1995 Intervenor Document Request to Ck Mccoy.* Request Made for Personal Documents Not Previously Produced in Case. W/Certificate of Svc.Related Correspondence ML20080N9081995-02-28028 February 1995 Intervenor Document Request to Gr Frederick.* Request Made for Personal Documents Not Previously Produced in Case. W/Certificate of Svc.Related Correspondence ML20080N8971995-02-28028 February 1995 Intervenor Document Request to Tv Greene.* Request Made for Documents Not Previously Produced in Case.W/Certificate of Svc.Related Correspondence ML20080N8901995-02-28028 February 1995 Intervenor Document Request to H Majors.* Requests Made for Personal Documents Not Previously Produced in Case. W/Certificaate of Svc.Related Correspondence ML20080N8771995-02-28028 February 1995 Intervenor Document Request to G Bockhold.* Requests for Personal Documents Not Previously Produced in Case. W/Certificate of Svc.Related Correspondence ML20080N8441995-02-28028 February 1995 Intervenor Document Request to Ga Power Company.* Requests for Personal Documents Not Previously Produced in Case. W/Certificatte of Svc.Related Correspondence ML20072P2231994-08-26026 August 1994 Georgia Power Company Response to Intervenor Document Request.* Util Not to Further Respond to Intervenor Request Since 940801 Deadline Not Met.W/Certificate of Svc & Svc List ML20072L1371994-08-17017 August 1994 Intervenor Document Request to Georgia Power Company.* NRC Advises Util to Identify & Produce All Documents Used in Creation of Georgia Power Company Response to 940731 Nov. W/Certificate of Svc & Svc List.Related Correspondence ML20072A6641994-08-10010 August 1994 Gpc Addl Response to Intervenor Second Request for Admissions.* W/Certificate of Svc.Related Correspondence ML20072A6031994-08-0808 August 1994 Util Response to Intervenor Seventh Request for Interrogatories.* Informs That Util Objects to Instruction D of Seventh Request.W/Certificate of Svc & Svc List.Related Correspondence ML20072A5611994-08-0808 August 1994 Util Third Suppl Response to AL Mosbaugh Third Set of Interrogatories & Request for Documents.* Provides Addl Info Required by Board Memorandum & Order Dtd 940714. W/Certificate of Svc.Related Correspondence ML20072A5851994-08-0808 August 1994 Util Addl Response to Intervenor Fifth Interrogatory & Document Request.* Informs That Response Addresses Document Request 3-5,10,13,14,17 & 18 of Fifth Request.W/Certificate of Svc & Svc List.Related Correspondence ML20071P4021994-07-29029 July 1994 Util Addl Response to Intervenor Fourth Interrogatory & Document Request.* Response Addresses Document Request 6-17 & 19 of Fourth Request.W/Certificate of Svc & Svc List. Related Correspondence ML20071P4031994-07-29029 July 1994 Util Response to Intervenor Second Request for Admissions.* Informs That Second Request for Admissions Would Be Done in Two Listed Steps.W/Certificate of Svc.Related Correspondence ML20071M1841994-07-25025 July 1994 Intervenor Seventh Request for Interrogatories to Georgia Power Co.* a Mosbaugh Requests That Georgia Power Co Answer Listed Interrogatories in Writing & Under Oath.W/Certificate of Svc & Svc List.Related Correspondence ML20070H8231994-07-20020 July 1994 Gap Responses to Intervenor Fourth Interrogatory & Document Request.* W/Certificate of Svc & Svc List.Related Correspondence ML20070G9621994-07-18018 July 1994 Gpc Objections to Intervenor 940707 Discovery Requests & Motion for Protective Order.* Gpc Moves Board for Protective Order Providing That Intervenor 940707 Discovery Request Not Be Had.W/Certificate of Svc ML20070H1161994-07-18018 July 1994 Intervenor Response to Georgia Power Co Second Request for Admissions.* Objects to Admissibility by Licensee of Portions of Transcripts &/Or Tape Recordings &/Or Paraphrasing.W/Certificate of Svc.Related Correspondence ML20070E8921994-07-0808 July 1994 Intervenor Fifth Interrogatory & Document Request to Georgia Power Co.* Intervenor a Mosbaugh Requests That Georgia Power Co Answer Listed Interrogatories in Writing.W/Certificate of Svc & Svc List.Related Correspondence ML20070E8551994-07-0808 July 1994 Intervenor Fourth Set of Interrogatories & Request for Documents to Staff of Nrc.* Intervenor a Mosbaugh Requests That Staff of NRC Answer Listed Interrogatories in Writing. W/Certificate of Svc & Svc List.Related Correspondence ML20070E9961994-07-0707 July 1994 Intervenor Second Request for Admissions to NRC Staff.* Requests for NRC to Answer Request for Admissions & Interrogatory & Produce Documents as Required.Certificate of Svc & Svc List Encl.Related Correspondence ML20070F0091994-07-0707 July 1994 Intervenor Fifth Request for Interrogatories & Document Request to Georgia Power Co.* W/Certificate of Svc & Svc List.Related Correspondence ML20070F0541994-07-0707 July 1994 Intervenor'S Third Request for Admissions to Gpc.*Requests Util Answer Request for Admissions & Interrogatories & That Util Provide Required Documentation by 940721.W/Certificate of Svc & Svc List.Related Correspondence ML20071G9511994-07-0707 July 1994 Ga Power Company Response to Intervenor First Request for Admissions.* W/Certificate of Svc & Svc List.Related Correspondence ML20071G9071994-07-0505 July 1994 Georgia Power Co Second Supplemental Response to Am Mosbaugh Third Set of Interrogatories & Request for Documents.* W/Certificate of Svc & Svc List.Related Correspondence ML20071G9421994-07-0101 July 1994 Intervenor Second Request for Admissions to Georgia Power.* Requests That Util Answer Listed Request of Admissions & Deliver Answer on or Before 940715.W/Certificate of Svc & Svc List.Related Correspondence ML20071G8851994-07-0101 July 1994 Ga Power Company Objections to Document Requests in Intervenor Notice of Depositions.* W/Certificate of Svc & Svc List.Related Correspondence ML20070D4901994-06-29029 June 1994 Intervenor Fourth Interrogatory & Document Request to Gpc.* Requests That Responses Be Filed within 14 Days from Svc of Request & All Relevant Documents Be Made Available for Insp. W/Certificate of Svc & Svc List.Related Correspondence ML20070A9051994-06-22022 June 1994 Intervenor Suppl to Licensees Third Set of Interrogatories & Request for Documents.* W/Certificate of Svc & Svc List. Related Correspondence ML20069P2611994-06-17017 June 1994 Georgia Power Co First Supplemental Response to AL Mosbaugh Third Set of Interrogatories.* Responds to Interrogatories & Document Requests for Persons Listed.W/Certificate of Svc. Related Correspondence ML20069L5641994-06-13013 June 1994 Intervenor Amended Response to Licensee Third Set of Interrogatories & Request for Documents.* W/Certificate of Svc & Svc List ML20069K4091994-06-10010 June 1994 Util Response to AL Mosbaugh Third Set of Interrogatories.* Licensee Objects to Interrogatory as Unduly Burdensome & Duplicative of Preliminary Designation of Anticipated Witnesses.W/Certificate of Svc.Related Correspondence ML20069F2981994-06-0101 June 1994 Intervenor Response to Licensee Third Set of Interrogatories & Request for Documents.* W/Certificate of Svc.Related Correspondence ML20149E4291994-05-18018 May 1994 Intervenors Third Set of Interrogatories & Request for Documents to Util.* W/Certificate of Svc.Related Correspondence ML20149E4421994-05-17017 May 1994 Intervenors Second Set of Interrogatories & Request for Documents to Staff of Usnrc.* W/Certificate of Svc.Related Correspondence ML20029D9281994-05-0606 May 1994 Georgia Power Co Third Set of Interrogatories & Request for Documents to AL Mosbaugh.* Requests That AL Mosbaugh Answer Interrogatories in Writing & Under Oath within 14 Days of Svc.W/Certificate of Svc & Svc List.Related Correspondence ML20065R5831994-05-0303 May 1994 Intervenor Request for Interrogatories Documents to Gpc Related to Illegal Transfer of Control.* Intervenor Requests That Gpc Answer Listed Interrogatories in Writing & Under Oath & Produce Requested Documents.W/Certificate of Svc ML20029D5331994-04-28028 April 1994 Georgia Power Co Second Set of Interrogatories & Third Request for Production of Documents to NRC Staff.* W/ Certificate of Svc.Related Correspondence ML20058P4041993-12-20020 December 1993 Interrogatory Response of NRC Staff to Gap 931008 First Set of Interrogatories & Second Request for Production of Documents.* ML20058P5861993-12-20020 December 1993 Interrogatory Response of Jf Rogge to 931008 Gap First Set of Interrogatories & Second Request for Production of Documents to NRC Staff.W/Certificate of Svc.Related Correspondence ML20058P5201993-12-20020 December 1993 Interrogatory Response of L Trocine to Gap 931008 First Set of Interrogatories & Second Request for Production of Documents to NRC Staff.* ML20058P4391993-12-17017 December 1993 Interrogatory Response of Ae Chaffee to 931008 Gap First Set of Interrogatories & Second Request for Production of Documents to NRC Staff.* ML20058P4301993-12-17017 December 1993 Interrogatory Response of Jf Rogge to 931008 Gap First Set of Interrogatories & Second Request for Production of Documents to NRC Staff.* ML20058P4521993-12-14014 December 1993 Interrogatory Response of SD Ebneter to Gap 931008 First Set of Interrogatories & Second Request for Production of Documents to NRC Staff.* 1995-09-13
[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] |
Text
00 $
MLATED COREGPC*NDENCE Dated: May 3,0%294'IED USHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD 94 MY -6 P 2 :47 Before Administrative Judges:
Peter B. Bloch, Chair 0FFICE OF SECRETARY Dr. James H. Carpenter DOCKEllHG & SERVICE Thomas D. Murphy BRANCH
)
In the Matter of )
) Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY ) 50-425-OLA-3 at 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 REQUEST FOR INTERROGATORIES DOCUMENTS TO GEORGIA POWER COMPANY RELATED TO ILLEGAL TRANSFER OF CONTROL I. INTRODUCTION i Pursuant to 10. C.F.R. 52.740b, Allen Mosbaugh hereby requests that Georgia Power Company (hereinafter referred to as l i
"GPC") answer the following interrogatories in writing and under oath, and produce any documents requested herein that have not already been produced, j II. INSTRUCTIONS A. If you cannot answer a particular interrogatory in full, l after exercising due diligence to secure the information to do so, so state and answer to the extent possible, specifying and explaining you inability to answer the remainder and stating whatever information or knowledge you have concerning the unanswered portion.
9405120040 940503 N PDR ADDCK 05000424 y f>9 3-0 PDR
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 j
such informa' ion 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 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.
D. In each case where you are asked to identify or to state l the identify of a document or where the answer to the l
2
I
! interrogatory refers to a document, state with respect to each i
such document:
!' 1. The identify of the person who prepared it; i
! 2. The identity of all persons who reviewed or i
i approved it;
! 3. The identity of the person who signed it, or over 1 whose name it was issued; 4
- 4. The identity of the addressee or addressees; j l 5. The nature and substance of the document with I sufficient particularity to enable the same to be i identified;
- 6. The date of the document; and
- 7. The present location of the document and the 1
l.
identity and address of each person who has custody of the I document.
l 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:
j 1. The date and place thereof; j
- 2. The identity of each person who participated in or heard any part of the communication;
- 3. If the communication was by telephone, so indicate t
and state who initiated the telephone call;
- 4. The substance of what was said by each person who )
1 participated in the communication; and i
3 j
i 4
- - - - - - - , . _ _ , . - , - _ , . - - , , . . - . - . i
- 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 i person:
- 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 i transaction, event or matter referred to.
G. As used herein, the term " detail" and the phrases " state in detail" and " describe in detail" shall mean that you are requested to state, with specificity, each and every fact, ultimate fact, circumstance, incident, act, omission, event and
- date, relating to or otherwise pertaining to the matters inquired of in said interrogatory.
III. DEFINITIONS A. As used herein, the terms "NRC," "you," or "your" and any synonym thereof and derivative therefrom are intended to, and 4
shall, embrace and include any and all offices within the Nuclear Regulatory Commission, including NRC Staff, NRC Office of Investigations, and all their respective attorneys, agents, se rvants , associates, employees, representatives, investigators, and others who are or have been in possession of or may have obtained information for or on behalf of the NRC in any manner with respect to any matter pertaining to information responsive to any interrogatory question set out below as well as any and
- document requested below.
I B. As used herein, the term " documents" includes any written, recorded or graphic matter, however produced or reproduced, of every kind and regardless of where located, including but not limited to any summary, schedule, memorandum, note , statement, letter, telegram, interoffice communication, report, diary, desk or pocket calendar or notebook, daybook, appointment book, pamphlet, periodical, work sheet, cost sheet, list, graph, chart, index, tape, record, partial or complete report of telephone or oral conversation, compilation, tabulation, study, analysis, transcript, minutes, and all other memorials of any conversations, meetings, and conferences by telephone or otherwise, and any other writing or recording which is in the possession, custody or control of the Intervenor or any employees, representatives, attorneys, investigators, or others acting on his behalf.
C. As used herein, the terms "and" and "or" shall each mean and/or.
5
1 l
D. As used herein, the " Allen Mosbaugh" and the term
" petitioner" or "intervonor" shall mean Allen Mosbaugh, the Intervenor in this proceeding.
E. As used herein, the term "SONOPCO," " Southern Nuclear" and " Southern Nuclear Operating Company, Inc.," shall include an entity formerly known as the "SONOPCO project" as well as a the current corporate entity now generally referred to as " Southern Nuclear."
F. As used herein, the term "date" shall mean the exact 1
day, month, and year, if ascertainable, or if not, the best l 1
I approximation thereof, including relationship to other events.
G. As used herein, the term " person" shall mean any l individual, partnership, firm, association, corporation or other :
government, legal or business entity.
l 1
H. As used herein, the term " detail" and the phrases " state in detail" and " describe in detail" shall mean that you are requested to state, with specificity, each and every fact, ultimate fact, circumstance, incident, act, omission, event and date, relating to or otherwise pertaining to the matters inquired l
of in said interrogatory, j I. As used herein, the term " COA" shall refer to a confirmation of action letter sent by or on behalf of Georgia Power Company to the NRC in response to the March 20, 1990 Site Area Emergency.
J. As used herein, the term "LER" or "LER 90-006" shall refer to any draft or actual licensee event report, or revision 6
l l
to any such report received or known to have existed by NRC that in any way pertains to the March 20, 1990_ Site Area Emergency.
IV. INTERROGATORIES AND DOCUMENT REOUESTS Below petitioner sets forth interrogatory questions and requests for documents.
- 1. Identify all committees or other entities established within the Southern System to study the creation of "SONOPCO" as i well as all committees and entities within the Southern System i who reviewed and/or approved the creation of SONOPCO between 1986 up until Southern Nuclear was incorporation.1
- a. For each entity identified, specify evTry person who served on any such committee; l
- b. Produce every document prepared or used as a I
briefing paper by any such entity and produce all draft and final documents prepared by any such entity.
- c. State the purpose of creating the entity; the role l that entity played. l
- d. Provided a chronology of action each entity took with respect to the creation of SONOPCO and produce all meeting minutes, drafts or final materials relied upon by any such entity to accomplish all of the activities set out in the chronology.
- 2. Provided a listing of all titles held by Joseph Farley with respect to any formal or informal position he held within i
the Southern System between 1986 and present, including all 1
Information contained in Licnesee's request for admissions need not be included when responding to this I interrogatory.
7
l Boards of Directorships, Ex Officio positions, all pay tiles, all job descriptions ever prepared (including unofficial descriptions),
- a. Produce all minutes and other corporate information documenting all t.tles and sources of pay provided to Mr. Farley.
- 3. Produce all materials Mr. Farley provided to Mr.
Addison or that Mr. Addison providad to Mr. Farley about the formation of SONOPCO between 1986 until 1991.
- 4. Produce all documents, drafts and otherwise, received by any and all members of GPC's Board of Directors and/or its l
l Management Council which mentions or concerns the formation of 1
l SONOPCO between 1986 and 1991.
- 5. Produce all documents, drafts and otherwise, received by any and all members of Southern Company's Board of Directors or created by the Board concerning the. formation of SONOPCO between 1986 and 1991.
- 6. Please provide a description of the process that occurred in filling the position being vacated by Mr. Vogtle as President of the Southern Company. Please:
- a. Produce all documents relating to the election of Mr. Addison as the President of the Southern Company, including:
i) All newspaper articles contained in GPC's or Southern Company's " clippings file";
8
.__ . _ .a
. 1 i l I
l
- 11) All paperwork created in anticipation of or
< during any vote (s) or nomination process; l l
iii) All documentation related to any l l
i i
4 " politicking" going on within the Southern l
i l System; l
\
- iv) All documentatica circulated to any outside i s
or inside Board of Directors on the Southern Company board that related in any way to any individual seeking nomination, selection or
{
l confirmation as president of the Southern Company prior to or at the time Mr. Addison f
! was selected.
i l v) Any documentation of any kind in the i
possession of any GPC Board member (or former i
i Board member) that relates to the selection of or matters pertaining to the selection of f
i
- a president of the Southern Company.
- b. Identify how many votes were taken by the Board of i
l Directors (including informal and straw votes) before i
- Mr. Addison was selected, and supply a summary of each vote taken and the date of the vote.
[ c. Identify how each Director voted in each vote leading
! to the selection of Mr. Addison to succeed Mr. Vogtle.
l i) For each Director, identify their affiliation with any Board of Directors or officer positions within i
9 4
i
i i
the Southern System at the time any vote was
}
- taken.
I i 7. Produce a copy of all memorandum prepared by Mr.
f Mcdonald concerning contact he or Mr. Farley had with the I Commission concerning the formation of SONOPCO.
J 8. Produce the " chronology" reviewed by Messrs. Farley, i
- Mcdonald and Dahlberg prior to their depositions.
- 9. State the date and the specifics of how the minority i owners of Plant Vogtle learned of Southern Company's U-1 filing 4
- with the SEC to create SONOPCO.
I Produce all documents sent to the co-owners prior
- a.
l to the U-1 filing; l
- b. Identify all documents pertaining to any briefings l
! concerning the u-1 filing that reflect any a
I communication (s) with the co-owners. !
- c. Produce all documentation received from the co- )
owners concerning acknowledgment of the U-1 filing j as well as with respect to any agreement or i
l disagreement any co-owner may have had with the
) initial U-1 filing or in anticipation of said 1
filing.
- 11. State whether, at any time during the formation of j 1
i j SONOPCO or the SONOPCO project, the co-owners objected to the
} timing or content of the U-1 filing or any other document or ,
i matters related to the formation of SONOPCO.
i 10 I
1 4
. , , , .-,.,y,,, ,. m .m.- r- 31-,,., y,.--rv.-%,
i 1
- a. If the answer is yes, identify the sum and
=
i substance of the objection, who the objecting l party was, the date of the dispute and the resolution (if applicable).
i
, 12. Produce all minutes, meeting notes, briefing papers and i materials pertaining to the formation of SONOPCO, or which
. pertain to the nuclear budget of plant Vogtle, that was reviewed by, created by or relied upon by Southern Company's Board of Directors.
- 13. Produce all minutes, meeting notes, briefing papers and I
i me.terials pertaining to the formation of SONOPCO, or which pertain to the nuclear budget of plant Vogtle, that was reviewed l, l
' by, created by or relied upon by GPC's Board of Directors.
- 14. Produce all materials and notes relating to the 1990 nuclear budget of plant Vogtle (including notes taken during the meeting or which reflect the results of the meeting) that was held in Birmingham, Alabama in 1990. ]
i i
- a. Identify the participants to said meeting
- b. State whether any minutes or other materials were ever prepared.
- 15. Provide a chronological description (including dates) l and the sum and substance of the budgeting process used to prepare and finalize GPC's 1990 nuclear budget (including "O&M").
Specifically identify the role and involvement of:
- a. GPC's Management Council;
- b. GPC's Board of Director's; 11 i
! . , i 1
l l
! c. Southern Company Board or standing committees;
- d. Southern Company's Executive Vice President -
Nuclear's role; l e. Southern Company's Management Council.
i 16. Provide a chronological description (including dates) and the sum and substance of the budgeting process used to
{
} prepare and finalize GPC's 1990 n9D-nuclear budget (including ,
1 "O&M"). Specifically identify the role and involvement of:
l a. GPC's Management Council;
- b. GPC's Board of Director's; t l
! c. Southern Company Board or standing committees; f d. Southern Company's Executive Vice President -
1 Nuclear's role; l
- e. Southern Company's Management Council.
- 17. Identify whether and/or when GPC's non-nuclear 1990
) budget was apptoved by GPC's Man,agement Council. l l !
! a. Produce all documents related to the vote and/or '
! J
- review by the Management Council. j 4
- 18. Identify whether and/or when GPC's non-nuclear 1990 i
! budget was approved by GPC's Board of Directors.
{
- a. Produce all documents related to the vote and/or review by the Board of Directors.
- 19. Identify whether and/or when GPC's nuclear 1990 budget l,
4 was approved by GPC's Management Council. ,
1 l 1 i l a. Produce all documents related to the vote and/or review by the Management Council.
12 I
I i
i 0
I
- 20. Identify whether and/or when GPC's nuclear 1990 budget was approved by GPC's Board of Directors.
- a. Produce all documents related to the vote and/or review by the Board of Directors.
- 21. Did the 1990 non-nuclear budget for GPC require the approval of the Southern Management Council?
S
- 22. Did the 1990 non-nuclear budget for GPC require the approval of the Southern Board of Directors?
- 23. Did the 1990 non-nuclear budget for GPC require the
- approval of any group within the Southern System that is not controlled by GPC?
. a. If yes, please identify the group and the l
reason (s) why the approval was/is needed.
- 24. Did the 1990 nuclear budget for GPC require the approval of any group within the Southern System that is not controlled by GPC?
4
- a. If yes, please identify the group and the !
i reason (s) why the approval was/is needed. l 1
4 25. Did the approval of the 1990 non-nuclear budget by j GPC's Management Council represent the approval of the CEO of GPC. If not, why not. i
- 26. Did the approval of the 1990 nuclear budget by GPC's Management Council represent the approval of the CEO of GPC. If not, why not. ;
- 27. Does the CEO of the Southern Company have the power to
" veto" or object to GPC's budget?
13 s
? . .
- 28. When did GPC notify the plant Vogtle joint owners that the non-nuclear power generation budget for 1990 had been approved.
- a. Provide all documentation concerning any written or verbal. communication concerning any joint owners' notification, including any cover letter accompanying the transmission of budgetary l
information.
l 29. When did GPC notify the plant Vogtle joint owners that ;
the nuclear power generation budget for 1990 had been approved.
- a. Provide all documentation concerning any written or verbal communication concerning any joint l owners' notification, including any cover letter accompanying the transmission of budgetary 1 i
information.
- 30. Identify every visit Mr. Farley.made to plant Vogtle ;
and/or Hatch and state the date and purpose of the visit. !
- a. With respect to the visit relating to administrative matters, including but not limited to pay and/or future evaluations of employees, produce any and all notes created by any of the participants to such meetings as well as any agenda (s) or other documentation prepared in l anticipation of the meetings.
- 31. State whether Mr. Farley held " staff meetings" while he was stationed in 40 Inverness Place.
I 14 l
- a. If the answer is yes, produce all meeting notes, briefing books, agendas, calendars and notebooks l
that in any way reflect what was discussed during the briefings.
- b. Identify the normal participants to such briefing sessions.
- c. Identify the date and attendees of each such briefing session.
- 32. Between 1983 and 1994, state whether the NRC was I
l notified as to the identity of the person (or title) ultimately responsible for the construction, design and operation of GPC's nuclear power plants.
- a. If the answer is yes, produce the document (s) identifying the individual (s).
- 33. Identify all documents (including SEC filings and any I
and all Board minutes, resolutions, memorandum, decisions of standing committees, and Charters) that set out or in any way l modify the inter-relationship or define the relationship of the Southern Company's authority to own, control, appoint Board Members, approve standing committees, elect officers, approve funding, approve budgets and set company policy or directives or i
otherwise control or modify GPC's corporate existence.
- a. To the extent any document is not self-l explanatory, explain its the sum and substance and l its effect on the relationship between GPC and the 1
Southern Company.
[ signature on next page]
15 l
l l
l l
Respectfully submitted, j 1
,.- ~
Michael D. Kohn j KOHN, KOHN AND COLAPINTO, P.C. 1 517 Florida Avenue, N.W. j Washington, D.C. 20001-1850 l (202) 234-4663 i Attorney for Intervenor Dated: May 3, 1994 j CERTIFICATE OF BERVICE I hereby certify that a copy of the foregoing has been served on May 3, 1994 by hand service ("*" indicates additional service via facsimile on May 2, 1994)
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 l
l 1
(Continued on Next Page) i 16 l
l
l 1
i k
. Troutman Sanders Suite 5200 I 600 Peachtree Street, N.E.
j Atlanta, GA 30308-2216 i
David R. Lewis
- SHAW, PITTMAN, POTTS &
i TROWBRIDGE i 2300 N Street, N.W.
Washington, D.C. 20037
- and by first class mail on May 2, 1994 upon the following:
! 1 I
Office of the Secretary j Attn: Docketing and Service i U.S. Nuclear Regulatory Commission i Washington, D.C. 20555 i
4 office of Commission Appellate 3
Adjudication i U.S. Nuclear Regulatory Commission Washington, D.C. 20555 By:
j Michael D. Kohn
{
KOHN, KOHN AND COLAPINTO, P.C.
- 517 Florida Avenue, N.W.
I Washington, D.C. 20001-1850 l l (202) 234-4663 4
301\ inter 3.gpc
?
1 i
I 4
j 17 a
)
i i
i . -- ._. _ ,_ . ._,