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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] Category:OTHER LEGAL DOCUMENT
MONTHYEARML20137C2581997-03-18018 March 1997 Summary of Director'S Decision Under 10CFR2.206 of Mb Hobby & AL Mosbaugh, ML20116J8551996-08-0202 August 1996 Joint Notice of Termination.* AL Mosbaugh Voluntarily Withdrew Intervention,Opposition & Contentions in Proceeding.W/Certificate of Svc & Svc List ML20116J8921996-08-0202 August 1996 Withdrawal of AL Mosbaugh.* AL Mosbaugh Voluntarily Withdraws Intervention,Opposition & Contention in Proceedings.W/Certificate of Svc & Svc List ML20092H6881995-09-20020 September 1995 Georgia Power Co Petition for Review of Order to Produce Attorney Notes of Privileged Communications.* Commission Should Provide Opportunity for Oral Argument on Subj Matter ML20087K3621995-08-18018 August 1995 Gap Memorandum of Law on attorney-client Privilege.* Informs That Board Should Determine That attorney-client Privilege Applies to Communications Between Counsel for Gap & M Ajluni.W/Certificate of Svc & Svc List ML20083Q9741995-05-19019 May 1995 Intervenor Preliminary Phase II Witness Schedule.* Advises That List Preliminary & Intervenor Reserves Right to Call Addl Witnesses,As Necessary.W/Certificate of Svc & Svc List. Related Correspondence ML20083Q8901995-05-16016 May 1995 Georgia Power Company List of Addl Exhibits Re DG Statements Hearing.* W/Certificate of Svc & Svc List ML20082L2021995-04-17017 April 1995 Intervenor Statement on Definition of Willfulness & Burden of Proof During Phase Ii.* Informs That Licensee Must Demonstrate That Application Should Be Granted.W/Certificate of Svc & Svc List ML20082L2291995-04-17017 April 1995 Withdrawal of Notice of Appearance of RW Hendrix on Behalf of Nj Stringfellow.* RW Hendrix,Attorney for Nj Stringfellow,Withdraws Notice of Appearance in Hearing Involving Util.W/Certificate of Svc ML20082L2411995-04-17017 April 1995 Intervenor Phase II Exhibit List (Amended).* Intervenor AL Mosbaugh Submits List of Exhibits for Phase II of Licensing Proceeding Re Util.W/Certificate of Svc ML20082L2191995-04-13013 April 1995 Correction to Georgia Power Co List of Exhibits Related to Diesel Generator Reporting Issue.* Forwards Transcript Incorporating Proposed Changes.W/Certificate of Svc & Svc List ML20082B8881995-04-0303 April 1995 Georgia Power Company List of Exhibits Related to DG Reporting Issue.* W/Certificate of Svc & Svc List.Related Correspondence ML20082H5061995-04-0303 April 1995 Intervenor Phase II Exhibit List.* Intervenor Submits List of Exhibits for Phase II of Hearing Involving Util. W/Certificate of Svc ML20082H5191995-04-0303 April 1995 Intervenor Phase II Witness List.* Intervenor Submits List of Witnesses for Phase II of Proceeding Involving Util. W/Certificate of Svc ML20081L6041995-03-22022 March 1995 Intervenor Notice of Deposition of RP Zimmerman & La Reyes.* Requests That Listed Individuals Be Made Available for Deposition by Oral Exam on 950427.W/Certificate of Svc & Svc List.Related Correspondence ML20081L3741995-03-22022 March 1995 Intervenor Notice of Deposition of Jl Milhoan & NRC Representatives.* Requests That Listed Individuals Be Made Available for Disposition by Oral Exam.W/Certificate of Svc. Related Correspondence ML20077P7611995-01-0404 January 1995 Intervenor Schedule for Phase Ii.* Intervenor Responds to Board Request for Submission of Schedule for Phase II Hearing on DG Issues During 941215 Prehearing Conference. W/Certificate of Svc & Svc List ML20080E1171994-12-30030 December 1994 Intervenor Witness Schedule.* Lists Intervenor Witnesses & Individual Schedules in Matter of Util Amend to License Re Transfer to Southern Nuclear.W/Svc List ML20077K0641994-12-23023 December 1994 Intervenor List of Exhibits for Phase I Hearing on License Transfer Issues.* W/Certificate of Svc & Svc List ML20078P5781994-12-12012 December 1994 Intervenor Proposed 941214 Agenda.* Requests That Listed Matters Be Discussed at Upcoming Status Meeting. W/Certificate of Svc & Svc List ML20078P6571994-12-12012 December 1994 Intervenor List of Exhibits for Phase I Hearing on License Transfer Issues.* Lists Witnesses for Proceedings Related to Improper Transfer of Control of Util License & False or Misleading Info.Related Correspondence ML20078P6641994-12-12012 December 1994 Intervenor Phase I Witness List.* Informs That Intervenor Intends to Call Listed Witnesses During Phase I Proceedings Re Improper Transfer of Control of Georgia Power Nuclear License.Related Correspondence ML20078P6711994-12-12012 December 1994 Intervenor Prehearing Statement of Issues.* Intervenor Identifies Issues Intended to Be Raised During Upcoming Hearing Scheduled to Commence on 950104.W/Certificate of Svc.Related Correspondence ML20077F9811994-12-0505 December 1994 Intervenor Prefiled Testimony.* Submits Perfiled Testimony Respecting Phase I Hearing.Related Correspondence ML20077C0641994-11-17017 November 1994 Intervenor List of Phase I Issues.* Submits List of Issues Intervenor Plans to Raise at Upcoming Hearing.W/Certificate of Svc & Svc List ML20078H8701994-11-15015 November 1994 Licensee Proposed Agenda.* Lists Agenda Items for Consideration at Status Conference on 941117.W/Certificate of Svc & Service List ML20078H8721994-11-15015 November 1994 Intervenor Proposed 941117 Agenda.* Requests That Listed Matters Be Discussed at Upcoming 941117 Status Conference. W/Certificate of Svc & Svc List ML20076K0731994-10-13013 October 1994 Intervenor Proposed 941017 Agenda.* Lists Matters to Be Discussed at Upcoming Status Conference.W/Certificate of Svc ML20072L2101994-08-23023 August 1994 Certification of AL Mosbaugh.* Certifies That Facts Contained in Intervenor Response to Util Request for Admissions,Filed on 940707,true & Correct.W/Certificate of Svc ML20072A5301994-08-0808 August 1994 Intervenor Proposed Schedule.* Informs of Proposed Schedule for Adjudication of Proceeding.W/Certificate of Svc & Svc List ML20149F7041994-08-0202 August 1994 Gpc Proposed Schedule to Complete Proceeding.* Forwards Util Schedule to Complete Proceeding in Response to ASLB Instructions at 940729 Prehearing Conference.W/Certificate of Svc & Svc List ML20071P4241994-08-0101 August 1994 Intervenor Notice of Deposition of NRC Personnel.* Requests That Executive Director of Operations of NRC Make Available for Depositions by Oral Exam NRC Personnel Listed Below. W/Certificate of Svc & Svc List.Related Correspondence ML20149F6151994-08-0101 August 1994 Notice of Appearance.* Attorney Enters Appearance in Matter Re Georgia Power Co.W/Certificate of Svc ML20071M1641994-07-28028 July 1994 Proposed Agenda for 940729 Status Conference.* Requests That Listed Items Be Included on Agenda for 940729 Status Conference.W/Certificate of Svc & Svc List ML20071M1321994-07-27027 July 1994 Notice of Appearance of Je Joiner on Behalf of Gap.* W/Certificate of Svc & Svc List ML20071M1671994-07-27027 July 1994 Notice of Depositon.* Requests That Any Objection to Production of Documents Set Out in Notice Be Transmitted in Writing to Counsel for Intervenor on or Before 940801. W/Certificate of Svc.Related Correspondence ML20070F0371994-07-12012 July 1994 Intervenor Notice of Correction.* Heading on Interrogatories Served Upon Georgia Power Co on 940708,dtd 940708,should Have Read Intervenor Sixth Request for Interrogatories.... W/Certificate of Svc & Svc List.Related Correspondence ML20070E8451994-07-0707 July 1994 Notice of Appearance of SA Westby on Behalf of Jp Cash.* W/Certificate of Svc ML20069P3981994-06-22022 June 1994 Intervenor Proposed Agenda for 940623 Status Conference.* Intervenor Requests Items Listed Be Included in Conference Agenda.W/Certificate of Svc & Svc List ML20070B0281994-06-22022 June 1994 Notice of Appearance of Mj Wilmoth.* Enters Appearance as Counsel on Behalf of AL Mosbaugh in Listed Proceeding. W/Certificate of Svc ML20069P1601994-06-13013 June 1994 Notice of Appearance of SA Westby on Behalf of MW Horton.* Enters Apparence as Counsel on Behalf of MW Horton in Proceedings Re Listed Matter.W/Certificate of Svc ML20069J9441994-06-0505 June 1994 Intervenor Notice of Deposition of E Allison,Aw Dahlberg, T Beckham & J Wallace.* W/Certificate of Svc.Related Correspondence ML20069K0081994-06-0303 June 1994 Notice of Appearance of RW Hendrix on Behalf of Nj Stringfellow.* W/Certificate of Svc ML20069D0071994-05-25025 May 1994 Intervenor Proposed Agenda for 940526 Status Conference.* Requests That Issue of Whether or Not NRC Staff Has Released All of Mosbaugh Tapes & OI Rept Exhibits to Intervenor,In Agenda ML20073S6101994-05-24024 May 1994 Notice of Appearance of Bh Morris on Behalf of Gr Frederick.* W/Certificate of Svc ML20069C7581994-05-20020 May 1994 Notice of Deposition by Written Interrogatories & Oral Exam & Request for Documents.* Informs That AL Mosbaugh Gives Notice of Deposition.W/Certificate of Svc.Related Correspondence ML20149E4601994-05-17017 May 1994 Intervenors First Request for Admissions to NRC Staff.* W/ Certificate of Svc.Related Correspondence ML20149E4781994-05-17017 May 1994 Intervenors First Request for Admissions to Ga Power.* W/ Certificate of Svc.Related Correspondence ML20149E3911994-05-13013 May 1994 Intervenor Notice of Deposition of K Burr.* Provides Notice That Commencing on 940524,counsel for Intervenor Will Take Deposition Upon Oral Exam of K Burr,Believed to Be Employee of Southern Nuclear Operating Co ML20149E5101994-05-13013 May 1994 Intervenor First Tentative Witness List Re Character & Competence.* Submits Preliminary List of Witnesses Re Character & Competence.W/Certificate of Svc.Related Correspondence 1997-03-18
[Table view] |
Text
- . . _ _ - _ _ _ _ _ _ _ _ _ - _ _
.:=. .;
lb E? h 5' 00CXETED
" UNITED STATES OF AMERICA USNRC i NUCLEAR REGULATORY COMMISSION 4 ATOMIC SAFETY AND LICENSING BOARD
'94 JM 22 P3 :28
- )
In the Matter of )
d
) Docket Nos. 50-42Mf6dM-Gi $P 'r grqy GEORGIA POWER COMPANY ) 50-42NdhJ3/G i J hmr '
at al., ) -!WP
.. ) Re: License Amendment (Vogtle Electric Generating ~ ) (transfer to Southern Nuclear)
Plant, Unit 1 and. Unit 2) )
) ASLBP No. 93-671-01-OLA-3 INTERVENOR'S PROPOSED AGENDA f FOR JUNE 23, 1994 STATUS CONFERENCE i Intervenor.hereby respectfully request the following items 4
! he included on the agenda for the June 23, 1994 status conference:
- 1. Whether Licensee's response to Intervonor's third set J
of interrogatories are evasive and non-responsive (Sgg j 0 Intervenor's Motion to compel Licensee's Responses to I Interrogatory questions,(to be' filed by close of business, June 22, 1994');
- 2. Whether NRC Staff should respond to the outstanding interrogatory questions and document request filed by Intervenor (See Intervonor's Motion to Compel NRC Staff Response to Interrogatory Questions and Documents (filed on June 22, 1994);
- 3. Whether Licensee's request for and NRC Staff's granting a 60 day continuance to Licensee to response to the May 9, 1994 Notice of Violation ("NOV") and Demands for Information wan l inconsistent with discovery (Sligationa pending before the ASLD I
as set forth during the last status conference held before the Board on May 26, 1994. A copy of NRC Staff's letter approving the extension is attached (see June 2, 1994 letter from NRC to 9406240182 940622
{DR ADOCK 05000424 PDR
])$d
s -... . ~ . .. . .
_s l
I ,
Georgia Power Company -- a copy of which was not served upon Intervenor until June 16, 11994 when its existence was learned during the course of a deposition). )
- 4. Whether Licensee should be compelled to produce Mr.
George Frederick to answer questions objected to by counsel to licensee during thn course of the deposition of Mr. Frederick. l This line of questioning concerns communications between the NRC l Augmented Inspection Team and Plant Vogtle management and whether Plant Vogtle management intentionally deceived the Augmented Inspection Team about safety precautions that had to be followed I
in response to the Site Area Emergency. In particular, the ,
l questioning concerned whether NRC's Augmented Inspection Team on or about March 20, 1990 instructed Plant Vogtle management that i the Plant Vogtle Unit 1 containment hatch could not be opened !
until such time as-one diesel generator was declared operable, l and that after committing to the NRC Augmented Inspection Team that the hatch would*not be opened until such time as at least one diesel generator was declared operable, Plant Vogtle management intentlonally violated that commitment to the l
Inspection Team and opened the containment hatch fully cognizant 1
of the fact that both diesel generator 1A and 1B were declared i inoperable and that a "LCO" (" Limiting Condition of Operation")
had been recorded in the control room log book with respect to both diesels. See Intervenor Deposition Exhibit 39 (Transcript of NRC Tape No. 25, Side B, shown to Mr. Frederick during the course of his deposition) (attached) . Intervenor is particularly l 2 i
l l
l
.. .. .=. .. . ~ .: .
l i
1
\
I troubled by the fact that Licensee had agreed to allow 1
questioning to commence and then abruptly terminated questioning l once the tape segment was identified and played for the witness. j Intervonor advised counsel to Licensee that cutting off the questioning at this juncture would prejudice.Intervonor's ability to effectively examine the witness about this important incident.
Intervenor argued that the questioning war clearly within the scope of the Board's June 2, 1994 Memorandum and Order (Scope of Discovery). To wit, Intervenor advised counsel to Licensee on the record that the June 2, 1994 Order specifically provides that
" questions related to whether the representations to the NRC were the whole truth may be raised in this proceeding," including 1
questions concerning "how Georgia Power has attempted to fulfill l l
its safety obligations with respect to diesel generators," and what " Georgia Power's safety obligations were." San June 2, 1994 Memorandum, Section 2, QupRtions About the Site Area Emercency or violations of Technical Specifications, at pp. 2-3.
m l Respectfully submitted, h
Michael D. Kohn Stephen M. Kohn David K. Colapinto Kohn, Kohn & Colapinto, P.C.
517 Florida Ave., N.W.
Washington, D.C. 20001 (202) 234-4663 301\s':hord3 3
- sutr a -12 4 m r.a
- . mw w u.. ci. - . ,m ss~. .
4p ng i, ~
( j*/
NUCLEAR REGULATORY COMMISSION
- l. WASHINGTON. O.C. 2066M001
- +....
M0219%
- Docket No. 50-424 j EAs93-304, 94-036,94-037, and j 94-052 1
- Georgia-Power Company .
W. G. Hairston, III i 40 Inverness Center' Parkway
- Post Office Box 1295 i
Birmingham, Alabama 35201
Dear Mr. Hairston:
i
) -
SUBJECT:
REQUEST FOR EXTENSION OF TIME FOR RESPONSE 4
?
$ I have received you letter of May 27, 1994, in which you request a sixty day extension .for Georgia Power Capany's (GPC) response to the May 9,1994 ,
Notice of Violation and Proposed Imposition of Civil Penalties and responses l
i to three Demands for Information. This is to advise that, after due l consideration and consultation with the NRC staff. I have decided .o grant your request for a ' sixty day extenlon. Accordingl'y, responses on these matters are due no later than August 8, 1994. I would urge you to provide GPC's responses as far in~ advance o'f that date as ppssible.
Sincerely, j Lib -
! ames Lieberman, Director l ffice of Enforcement
.l .ce: Mr. J. D. Woodward j Senior Vice President
- Georgia Power Company Nuclear Operations 1 P. O. Box 1295 i Birmingham, AL 35201 J. B. Beasley General Manager. Plant Vogt'le Georgia Power Company P. O. Box 1600
- Waynesboro, GA 30830 Pw v,.s i
P.Qg
/ igera d 3% l810
. :m . .
TAPE #25 Side B Frederick : I haven't figured out yet how, what the justi'ication was.
' Mosbaugh: Well Frederick : Though I've had it explained to me twice that
,s , managt nent knew about it.
Mosbaugh:. . L.ackey and Beasley told you that they weren't going io-
- They actually told- 1 just-That was just an impression that I had but they actually told you they weren't going to put the hatch on.
Frederick :
Because I was arguaing- I walked-What happened,. v was, I walked into the War Room, uh, the afternoon of the event and uh , the evenino of the event and it was late that that day and Mike was dimmsinkwith %
oeoore the'feihova} of the hatch.' And I 'sdid "How $an you disduss the removing the hatch? We need to keep our barriers.", and he recognised that I had a concern and so he went and got Barney and then I (g1 g
think Skip mentioned it to me, slightly. And then we had the big brief with the NRC.
Mosbaugh: Um huh. ;
" Frederick' : And basically, at the meeting I thought that the final discussion that I got from George and Skip, because they said it 4 times for clarification, I rememberit had
' to be said 4 times before everybody understood, that we wouldn't reopen the hatch until we hasthe
~
diesel and thi RAT. And we neyer got the dieseC That night they wrote an LCO00 it.
Mosbaugh :
Yeah. The diesel was just declared operable 2 days ago.
Frederick : But they wroto an LCO that night, I mean an actual LCO saying that it was inoperable and B was torn apart.
Mosbaugh : Yeah.
Frederick :
So there was no way that they could say that they had the diesel, and the next mornino when I canwirfaru: .
found out that the hatch was open. Uh, I ask those*
questions again and uh, Mike, uh, I said how could you all do that, management briefed the NRC. He said, "No, management said we could go ahead".
Mosbaugh : I ask the-
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Frederick : That's not what I heard.
Mosbaugh : 1, I,1 voiced the same concems in the morning. When I found that the hatch was open in the morning i voiced the same concern.
Frederick : I remember, because you didn't know. You said-Mosbaugh : I didn't know because, I was the duty manager.
Frederick : Said we breached it in the opposite way and they had to go rebreach it.
Mosbaugh : That's right.
. Frederick : Right. I'thidk we're going to-1 think @*gt when they get
'~a i6unis tb'theTvent I th?nk thst's aViis'take_. ~ ' ' e '
.Mosbaugh: Yep, and I would say deliberately, I mean you know the pressurizer hatch SNAFU bere uh I think was, is a very bad you know situation done out of the chain of.
command and all that, but I don't think that it was done deliberately.
Frederick : Right.
Mosbaugh : No body deliberately put that hatch on to put the Plant in a less safe condition.
Frederick : Right Mosbaugh : Okay, it was done out of the chain of command it was a major SNAFU. But, but the hatch really puts the Plant in a less safe the containment hatch puts the Plant in a less safe condition and we did it on curraose.
- Frederick : Yeah, I'm of tile opinion that the hatch should still be shut richt ncE never have bee,n reopened, they could
- have cone then, well they might have had a little dificultity with leak rate-Mosbaugh
- The hatch, in my opinion the hatch could have only, to be safe, should have only be recoened once the diesel was operable.
[
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! a DOCKETED i I
l UNITED STATES OF AMERICA USNCI NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
' '94 JUN 22 P ? 28
)
In the Matter of )
) Docket Nos. 50-424gpF4 tai a JFii.,RY i
) 50-42509 W 3 C r
- it ' U l GEORGIA POWER COMPANY > , 4 'i' h et 31,., ) _
) Re: License Amendment (transfer to Southern Nuclear) j (Vogtle Electric. Generating )
Plant, Unit 1 and. Unit 2) )
) ASLBP No. 93-671-01-OLA-3 CERTIFICATE OF SERVICE I hereby certify that Intervenor's Proposed Agenda and l
l Intervenor's Mot. ion to Compel Responses to Interrogatories From NRC have been served this 22nd day of June, 1994, by first class mail upon the persons listed in the attached Service List (additional service by facsimile indicated by "*").
l i
By: [ b 84W 4fi) /
'Ma'ry Jfr)6 Wilmoth,' Esq.
KOHN, KOmi & COLAPINTO, P.C.
317 Florida Ave., N.W.
! Washingtor., D.C. 20001
~
(202) 234-4663 I
I w
T.
1 I
v . . _-
l w.=.=, ... .. l
~
DOCKETED UNITED STATES OF AMERICA USNPC NdCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
'94 JUN 22 P 3 :28 ,
) I In the Matter of )
i GEORGIA POWER COMPANY eg p_1_ ,
)
)
)
Docket Nos. 50-4 2 4 -OLJ 50-425-OL) 3f"__7 p'
',y',"
d'7
,='
f l
. ) Re: License Amendment (Vogtlo Electric Generating ) (transfer to Southern Nuclear) i l
P.1.a n t , Unit 1 and. Unit 2) ) l
____) ASLBP No. 93-671-01-OLA-3 i
l SERVICE LIST
- Administrative. Judge Peter B. Bloch, Chair Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission )
i Washington, D.C. 20555 Administrative Judge James H. Carpenter 933 Green Point Drive Oyster Point Sunset Beach, NC 28468 i
- Administrative Judge l Thomas D. Murphy l Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Charlec A. Barth, Esq. _"
Office of General ~Councel "
l U.S. Nuclear Regulatory Commission
- Washington, D.C. 20555 John Lamberski, Esq.
I Troutman Sanders Suite 5200 600 Peachtree Street, N.E.
Atlanta, GA 30308-2216
David R. Lewis SHAW, PITTMAN, POTTS %
TROWBRIDGE 2300 N Street, N.W.
Washington, D.C. 20037 2
l l
l
Ju 4-22-l u i 11:c5 ...
- office of the Secretary Attn: Docketing and Service U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Office of Commission Appellate Adjudication U.S. Nuclear Regulatory Commission Washington, D.C. 20555 301\ cert.'lis l
I l
4 l
3 l
TOTAL P.13 l