ML20069K022

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Summarizes Several Agreements Between Parties Relating to Discovery Re Matter of Ga Power Co.W/Svc List
ML20069K022
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 06/07/1994
From: Doris Lewis
GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To: Bloch P, Carpenter J, Murphy T
Atomic Safety and Licensing Board Panel
References
CON-#294-15157 OLA-3, NUDOCS 9406150216
Download: ML20069K022 (3)


Text

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Bld i June 7,1994 Peter B. Bloch, Esq., Chairman Dr. James H. Carpenter Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission 933 Green Point Drive Washington, D.C. 20553 Oyster Point Sunset Beach, N.C. 28468 Mr. Thomas D. Murphy Administrative Judge Atomic Safety and licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20553 In the Matter of Georgia Power Company (Vogtle Electric Generating Plant, Units 1 & 2)

Docket Nos. 50-424-OLA-3,50-425-OLA-3 Gentlemen:

I am writing to summarize several agreements between th: parties relating to discovery.

First, Intervenor has agreed to supplement by June 10 its response to Georgia Power Company's Third Set of Interrogatories and Request for Documents to Allen L.

Mosbaugh. The parties have further agreed that the period in which Georgia Power might file a motion to compel will not commence until then.

Second, Intervenor requested and the parties agreed to substitute Mr. Stringfellow for Mr. Green as one of the individuals who may be deposed on the diesel generator issues during the next two weeks.

Third, Intervenor and Georgia Power Company agreed that Intervenor's Notice of Deposition Upon Written Interrogatories will be answered only by those individuals named in the notice who are Directors of Southern Nuclear. We also agreed that interrogatories asking about the " Site Area Emergency" will be construed as askmg about " diesel generator reliability and performance during the site area emergency and communications to the NRC related thereto." Similarly, mterrogatories asking about "any of the allegations against Georgia Power Company by Mr. Mosbaugh," or similar words to that effect, will be construed as asking about the allegations discussed in OI report.

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s SHAW. PITTMAN, POTTs & TROWBRIDGE A PA RT hE P $4eir shCt hD ahG PM Of f $ $ tOh AL C OMPOR ATichS Atomic Safety & Licensing Board June 7,1994 Page Two Fourth, the parties have agreed that Intervenor will have a cumulative total of twenty-four hours (equivalent to three eight-hour days) to depose designated individuals, other than Mr. Dahlberg, on the license transfer issue. The parties will keep track of the duration of Intervenor's questioniong during each of these depositions. Lunch breaks, other breaks taken by a party other than Intervenor, and questioning by parties other than Intenenor, will not be counted.

Finally, the parties have agreed to meet on Friday, June 17, to attempt to reach a final a reement on the license transfer stipulations and on acceptable transcriptions of tapes 7 and 58 (related to the April 19,1990 calls)

Sincerely, David R. Lewis Counsel for Licensee cc:

Senrice List

e i

UNrrED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board

)

In the Matter of

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Docket Nos. 50-424-OLA-3

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50-425-OLA-3 GEORGIA POWER COMPANY,

)

et al.

)

Re: License Amendment

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(Transfer to Southern (Vogtle Electric Generating

)

Nuclear)

Plant, Units 1 and 2)

)

)

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

?

SERVICE LIST Administrative Judge Office of the Secretary Peter B.

Bloch, Chairman U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Board Washington, D.C.

20555 t

U.S. Nuclear Regulatory Commission ATTN: Docketing and Services Branch Washington, D.C.

20555 Mitzi A.

Young, Esq.

Administrative Judge Charles Barth, Esq.

Dr. James H.

Carpenter Office of General Counsel Atomic Safety & Licensing Board One White Flint North 933 Green Point Drive Stop 15B18 Oyster Point U.S. Nuclear Regulatory Commission f

Sunset Beach, N.C.

28468 Washington, D.C.

20555 Administrative Judge

Director, Thomas D. Murphy Environmental Protection Division Atomic Safety & Licensing Board Department of Natural Resources U.S.

Nuclear Regulatory Commission 205 Butler Street, S.E.

Washington, D.C.

20555 Suite 1252 i

Atlanta, Georgia 30334 Michael D.

Kohn, Esq.

Kohn, Kohn & Colapinto, P.C.

Office of Commission Appellate 517 Florida Avenue, N.W.

Adjudication Washington, D.C.

20001 U.S. Nuclear Regulatory Commission l

Washington, D.C.

20555 Stewart D.

Ebneter i

Regional Administrator Adjudicatory File i

USNRC, Region II Atomic Safety and Licensing Board 101 Marietta-Street, N.W.

U.S. Nuclear Regulatory Commission l

Suite 2900 Washington, D.C.

20555 i

Atlanta, Georgia 30303

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