ML20070F009

Intervenor Fifth Request for Interrogatories & Document Request to Georgia Power Co.* W/Certificate of Svc & Svc List.Related Correspondence

ML20070F009
Person / Time
Site:	Vogtle
Issue date:	07/07/1994
From:	Wilmoth M AFFILIATION NOT ASSIGNED, KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA
To:	GEORGIA POWER CO.
References
CON-#394-15383 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9407180124
Download: ML20070F009 (13)

Text

v RE1ATED CORRESPONDENCE DOCKETED USt!RC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD 94 JL 11 P6:22  :

Before Administrative Judges: ec r"~'"

Peter B. Bloch, Chair [g ;, ,4 1 '

Dr. James H. Carpenter '

Thomas D. Murphy

)

In the Matter of )

) Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY )

et al., 50-425-OLA-3

)

) Re: License Amendment (Vogtle Electric Generating )

Plant, Unit 1 and Unit 2) )

(transfer to Southern Nuclear)

) ASLBP No. 93-671-01-OLA-3 INTERVENOR'S FIFTH REQUEST FOR INTERROGATORIES AND DOCUMENT REQUEST TO GEORGIA POWER COMPANY I. INTRODUCTION Pursuant to 10. C.F.R. S2.740b, Allen Mosbaugh hereby requests that Georgia Power Company (hereinafter referred to as "GPC")

answer the following interrogatories in writing and under oath, and produce any documents requested herein that have not already been produced.

II. INSTRUCTIONS A.

When responding to these Interrogatories refer to each tape by its NRC tape number (i.e. Response 1(a) (1) : NRC Tape No. '

001.

B. If you cannot answer a particular interrogatory in full, after exercising due dJligence 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 DR DOK0$ bob 424 Q PDR

})b0 )

}

l l

l whatever information or knowledge you have concerning the l i

unanswered portion.  !

C. Each interrogatory is a continuing one, and should be supplemented as required by 10 C.F.R. S2.740(e).

D. If you claim that any information which is required to I be provided by you in your response to any of these i interrogatories is privileged or immune from discovery:

i

1. Identify the portion of the interrogatory to which such information is otherwise the response; l

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; ,

t

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.

2 7

i.",

l 1

I l

E. In each case where you are asked to identify or to state the identify of a document or where the answer to the interrogatory refers to a document, state with respect to each such document:

1. The identify of the person who prepared it;

)

2. The identity of all persons who reviewed or <

approved it;

3. The identity of the person who signed it, or over whose name it was issued;

4. The identity of the addressee or addressees;

5. The nature and substance of the document with sufficient particularity to enable the same to be identified; 1

l

6. The date of the document; and i l

7. The present location of the document and the  !

identity and address of each person who has custody of the-1 document. I F. In each case where you are required to identify an oral l

communication, or where the answer to the interrogatory refers to )

l an oral communication, state with respect thereto:

l

1. The date and place thereof;

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 I

and state who initiated the telephone call; l

!. j 3

1 a- .

I l

4. The substance of what was said by each person who participated in the communication; and

5. The location and the identity and address of the j custodian of any document (including any mechanical, magnetic, electrical or electronic recording) that recorded, i 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 i

interrogatory refers to a person, state with respect to each such ,

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 transaction, event or matter referred to.

III. DEFINITIONS A. As used herein, the terms " Licensee", " Georgia Power Company", "The Southern Company", "SONOPCO", "you", or "Your" and any synonym thereof and derivative therefrom are intended to, and shall, embrace and include every agent or employee of Georgia  !

Power Company, The Southern Company, and/or SONOPCO, past or present, their counsel and all their respective agents, servants, 2 4

l 1

l l

l

associates, employees, repreecutatives, private investigators, and others who are or have been in possession of or may have obtained information for or on behalf of each person listed in any manner with respect to any matter referred to in these request for admissions.

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, interof fice comtauuication, 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, tape recordings made by Intervenor, 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 Licensee 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.

D. As used herein, the " Allen Mosbaugh" and the term

" petitioner" or "intervenor" shall mean Allen Mosbaugh, the Intervenor in this proceeding.

5

E. As used herein, the term "date" shall mean the exact day, month, and year, if ascertainable, or if not, the best approximation thereof, including relationship to other events.

F. As used herein, thr. term " person" shall mean any individual, partnership, firm, association, corporation or other government, legal or business entity.

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 H. As used herein, the term "NRC" shall mean the U.S.

Nuclear Regulatory Commission, an agency of the Federal Government, and any and all offices within the Nuclear Regulatory Commission, including NRC Staff, NRC Office of Investigations, and all their respective attorneys, agents, servants, associates, employees, representatives, investigators.

I. As used herein, the term "Mosbaugh Tapes" shall mean the tape recordings made by Allen L. Mosbaugh which have been numbered 1-277 by the NRC for identification purposes.

IV. INTERROGATORIES AND DOCUMENT REOUESTS

1. Please respond to the following interrogatories for each of the Mosbaugh tapes listed below:

a. Identify every person whose voice is on the tape.

6

l l

b. For every person identified in 1(a) above, please ,

list every statement of that person which is on the tape. l l

c. State whether you believe each and every  ;

1 statement identified in 1(b) above, to be true and accurate, and I i

identify each and every statement you deny is true and accurate. l i

d. For each and every statement you identified in l I

1(c) above as not being true and accurate, explain in detail the l l

reason (s) for denying each of the identified statements is true j and accurate.

l

e. If a transcript exists for any of the Mosbaugh tapes listed below, produce a copy of such.

f. Identify all inaudible sections of each and every tape listed below.

NRC Tape NO. NRC Tane NO.

1. 001 13. 033  !

2. 002 14. 036

3. 003 15. 035

4. 004 16. 036 -

5. 005 17. 037

6. 006 18. 038

7. 015 19. 044

8. 016 20. 046

9. 022 21. 051

10. 023 22. 052

.11. 025 23. 054

12. 026 24. 055 J 7

t

25. 056 51. 108 .

26. 059 52. 109

27. 060 53. 110 i

28. 061 54. 111  ;

i 062 112

29. 55.

30. 063 56. 113 .

31. 064 57. 114 i

32. 065 58. 115 ,

t

33. 067 59. 116 i 52 068 60. 117

35. 070 61. 118

36. 072 63. 119  !

l

37. 077 63. 120 i

38. 078 64. 121 l

39. 080 65. 123 I

40. 082 66. 124 l

41. 084 67. 125 i

42 085 68. 129 ,

43. 088 69. 130 g I

131

44. 091 70.

45. 092 71. 132 ,

46. 093 72. 133 )

l

47. 094 73. 134 '

48. 097 74. 135

49. 104 75. 136

50. 105 76. 137 8

I

.. . . l

77. 138 103. 180

78. 139 104. 181

79. 140 105. 189 -

i

80. 141 106. 190

81. 142 107. 191

82. 144 108. 192 ,

83. 145 109. 193

84. 146 110. 194 '

85. 147 111. 195

86. 148 112. 196

87. 149 113. 197

88. 150 114. 198 i

89. 151 115. 202 1

90. 152 116. 203

91. 153 117. 206 .i 1

92. 154 118. 207

93. 163 119. 208

94. 164 120. 209 I

95. 170 121. 210 1

96. 171 122. 211 i i

i

97. 173 123. 218 j 1

98. 174 124. 221 i

99. 176 125. 228 100. 177 126. 229 101. 178 127. 232 i i

102. 179 128. 233 9 j

129. 235 139. 263 130. 236 140. 265 131. 237 141. 270 132. 238 142. 271 133. 239 143. 272 134. 240 144. 273 135. 241 145. 274 136. 242 146. 275 137. 243 147. 276 138. 244 148. 277 C 2.

Produce all documents used in or created by answering '

the above interrogatories.

Respectfully submitted, f flb& O /}Vfh ?k Mary J 4 Wilmoth KOHN, kOHN & COLAPINTO, P.C.

517 Florida Ave., N.W.

Washington, D.C. 20001-1850 .

(202)234-4663 I Attorney for Intervenor l

DATED this 7th day of July 1994.

inter 6.gpc I

)

10 I

']

UUE 'r;[9 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD 94 J'1 11 P6 < 3

)

In ehe Matter of ) g - -

) Docket Nos. 50-424-OLqhj' ,

GEORGIA POWER COMPANY ) 50-425-OLA-3 en al., )

) Re: License Amendment (Vogtle Electric Generating ) (transfer to Southern Nuclear)

Plant, Unit 1 and Unit 2) )

) ASLBP No. 93-671-01-OLA-3 CERTIFICATE OF SERVICE I hereby certify that Intervenor's Second Request for Admissions to NRC Staff, Intervenor's Sixth Request ror Interrogatories and Document Request to Georgia Power Company, and Intervenor's Thir' Recuest for Admissions to Georgia Power Company have been served this 7th day of July, 1994, by first class mail upon the persons listed in the attached Service List, with the exception that they were hand delivered to the Office of General Counsel, and Licensee's Washington counsel as indicated by "*"

By: D(y h j>r,:M.I %' /

~-

Mary Jpe' Wilmoth, Esq.

KOHN, KOHN & COLAPINTO, P.C.

517 Florida Ave., N.W.

Washington, D.C. 20001 (202) 234-4663 1

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

) Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY ) 50-425-OLA-3 p1 al., )

) Re: License Amendment (Vogtle Electric Generating ) (transfer to Southern Nuclear)

Plant, Unit 1 and Unit 2) )

) ASLBP No. 93-671-01-OLA-3 SERVICE LIST Administrative Judge Peter B. Bloch, Chair Atomic Safety and Licensing Board ,

l 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 l Washington, D.C. 20555 j

• Charles A. Barth, Esq.

Office of General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 John Lamberski, Esq.

Troutman Sanders Suite 5200 600 Peachtree Street, N.E.

Atlanta, GA 30308-2216

• Ernest L. Blake, Jr.

' David R. Lewis SHAW, PITTMAN, POTTS &

-TROWBRIDGE 2300 N Street, N.W.

Washington, D.C. 20037 2

't

o. ,

l l

Office of the Secretary Attn: Docketing and Service U.S. Nuclear Regulatory Commission 3 i

Washington, D.C. 20555 Office of Commisei'an Appellate Adjudication U.S. Nuclear Regulatory Commission '

Washington, D.C. 20555 301\ cert.lis i 1

O a

i

}

b 3- .

_. .