ML20069P261
| ML20069P261 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/17/1994 |
| From: | Lamberski J GEORGIA POWER CO., TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA |
| To: | Mosbaugh A AFFILIATION NOT ASSIGNED |
| References | |
| CON-#294-15231 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9406240123 | |
| Download: ML20069P261 (6) | |
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RELATE 000RRESPONDENCE 00CKETED 4
USNPfane 17, 1994 UNITED STATES OF AMERICA 94 JUN 21 N0 :56 NUCLEAR REGULATORY COMMISSION OFFICE OF SECPa.IARl(
BEFORE THE ATOMIC SAFETY AND LICENSI ENbkkb!f *
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l In the Matter of GEORGIA POWER COMPANY, Docket Nos. 50-424-OLA-3 c1al.
50-425-OLA-3 (Vogtle Electric Re: License Amendment Generating Plant, (Transfer to Southern Units 1 and 2)
Nuclear)
ASLBP No. 93-671-01-OLA-3 l
l l
GEORGIA POWER COMPANY'S FIRST SUPPLEMENTAL. RESPONSE TO ALLEN L. MOSBAUGH'S THIRD SET OF INTERROGATORIES l
I.
Introduction Georgia Power Company ("GPC") hereby provides a supplemental response to l
Allen L. Mosbaugh's Third Set of Interrogatories, dated May 17, 1994. In providing this supplemental response, GPC incorporates each of the objections previously asserted in Georgia Power Company's Response to Allen L. Mosbaugh's Third Set of Interrogatories, dated June 10, 1994.
II.
Supplemental Response to Interrogatories and Document Requests for Persons Listed Several of the individual respondents indicated that they participated in an NRC 5'"MG M88%
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inspection conducted by the NRC Region II on May 9 through May 20, 1994. The inspection focussed on the effectiveness of GPC's corrective actions associated with the Vogtle Unit I diesel generators following the March 20, 1990 Site Area Emergency.
The inspection team issued its inspection report on June 9,1994 (NRC Inspection Report Nos. 50-424/94-12 and 50-425/94-12). GPC did not keep an index of the documents the NRC copied or reviewed in this inspection, nor did GPC retain a copy of such documents other than a document entitled "Calcon Sensor Failures" and a document listing maintenance work orders from 1990 to the date of the inspection related to air dryer problems. These two documents will be made available for Intervenor's inspection.
5.
(Mr. Mark Briney) Mr. Briney had contacts with members of the j
Augmented Inspection Team and Incident Investigation Team following the March 20,1990 event. He left the employ of GPC in September 1991. He does not recall any other contacts responsive to this request.
11.
(Mr. Bill Chenault) Mr. Chenault had contacts with members of the Augmented Inspection Team and Incident Investigation Team following the March 20,1990 event.
He does not recall any other contacts responsive to this request.
27.
(Mr. Patrick Mcdonald) On September 5,1990, Mr. Mcdonald attended an NRC Enforcement Conference in Atlanta, Georgia where matters related to the current Notice of Violation were discussed. Documentation concerning this enforcement conference has been previously produced.
2
N Mr. Mcdonald also participated in an exit meeting with the NRC's Operational Safety Inspection Team in August,1990. He was interviewed by the NRC's Office of Investigations on July 1,1993.
l t
l Dated:
June 17,1994 i
i
/k A
ohn lamberski
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/ TROUTMAN SANDERS Suite 5200 600 Peachtree Street, N.E.
Atlanta, GA 30308-2216 i
(404) 885-3360 Ernest L. Blake David R. Iewis l
- SHAW, PITTM AN, POTTS TROWBRIDGE 2300 N Street, N.W.
l Washington, D.C. 20337 (202) 663-8084 i
Counsel for Georgia Power Company 3
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l' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD i
In the Matter of GEORGIA POWER COMPANY, Docket Nos. 50-424-OLA-3 at al.
50-425-OLA-3 (Vogtle Electric Re: License Amendment Generating Plant, (Transfer to Southern Units 1 and 2)
Nuclear)
ASLBP No. 93-671-01-OLA-3 AFFIDAVIT OF THOMAS L.
PENLAND, JR.
I, Thomas L. Penland, Jr., being duly sworn, state as follows:
1.
I am an associate in the law firm of Troutman Sanders, where I have practiced law since being admitted to the State Bar of Georgia in 1993.
2.
I am duly authorized to verify Georgia Power Company's First Supplemental Response to Allen L. Mosbaugh's Third Set of Interrogatories; specifically,Section II " Supplemental Response to Interrogatories and Document Requests for Persons Listed."
I hereby certify that the statements and opinions in such l
responses are true and correct representation of the responses provided by the named individuals to the best of my personal knowledge and belief.
Idi)
AM Thomas L.' Pehland, Jf. // '
Sworn to and sub bed
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before me this,/
ay offJune, 1994 Ch8tGN kf f1A'
' Notary Publict 7
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,Ny commission expires:
Notary Pucac. Cobb Consit/, Georgia.
My Commlesson Empires January 12,1906.
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4 DOCKETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION OFFICE OF SECRETARY
)
00CKETiHG & SERVICE In the Matter of
)
Docket Nos. 50-424 MLADi
)
50-425-OLA-3 GEORGIA POWER COMPANY,
)
et al.
)
Re: License Amendment
)
(Transfer to Southern (Vogtle Electric Generating
)
Nuclear)
Plant, Units 1 and 2)
)
)
ASLBP No. 93-671-01-OLA-3 CERTIFICATE OF SERVICE I hereby certify that copies of " Georgia Power Company's First Supplemental
Response
to Allen L.
Mosbaugh's Third Set of i
Interrogatories" was served by_ express mail upon the persons listed on the attached service list, this 17th day of June, 1994.
4*
I
.z J
n Lhmberski *
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4 i
UNITED STATES OF AMERICA i
NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD i
In the Matter of GEORGIA POWER COMPANY, Docket Nos. 50-424-OLA-3' 1
at al.
50-425-OLA-3 i
(Vogtle Electric Re: License Amendment Generating Plant, (Transfer to Southern i
Units 1 and 2)
Nuclear) j ASLBP No. 93-671-01-OLA-3 SERVICE LIST Administrative Judge Stewart D.
Ebneter i
Peter B.
Bloch, Chairman Regional Administrator i
i Atomic Safety and Licensing USNRC, Region II 2
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 j
i James H. Carpenter Commission Atomic Safety and Licensing Washington, D.
C.
20555 i
Board ATTN:
Docketing and 933 Green Point Drive Services Branch Oyster Point Sunset Beach, NC 28468 Charles Barth, Esq.
4 Office of General Counsel I
Administrative Judge One White Flint North Thomas D. Murphy Stop 15B18 i
Atomic Safety and Licensing U.S. Nuclear Regulatory Board Commission l
U.S.
Nuclear Regulatory Washington, D.
C.
20555
)
l Commission i
Washington, D.C.
20555
- Director, Environmental Protection Michael D. Kohn, Esq.
Division 4
j Kohn, Kohn & Colapinto, P.C.
Department of Natural 517 Florida Avenue, N.W.
Resources l
Washington, D.C. 20001 205 Butler Street, S.E.
i Suite 1252 i
Office of Commission Appellate Atlanta, Georgia 30334 i'
Adjudication-One White Flint North 11555 Rockville Pike l
Rockville, MD 20852 k
i i
I 4
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