ML20071M167
| ML20071M167 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/27/1994 |
| From: | Kohn M KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA |
| To: | |
| References | |
| CON-#394-15482 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9408040087 | |
| Download: ML20071M167 (5) | |
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JQ~ CKFT ED nr y3 g 1994 UNITED STATES OF AMERICA
- 2. 5P' NUCLEAR REGULATORY COMMISSION 94 JUL 5 P 3 :54 ATOMIC SAFETY AND LICENSING BOARD
)
0FFICE CF EEWlW In the Matter of
)
DOCSFlM 9 ' k 50-424 DLnCSI 2
)
Docket Nos.
GEORGIA POWER COMPANY
)
50-425-OLA-3 e_t; i,
)
)
Re: License Amendment (Vogtle Electric Generating
)
(transfer to Southern Nuclear)
Plant, Unit 1 and Unit 2)
)
)
ASLBP No. 93-671-01-OLA-3 NOTICE OF DEPOSITION Intervenor, pursuant to 10 C.F.R. 52.740a(a), hereby provides notice that counsel for Intervenor will take the deposition upon oral examination of the following individuals:
Allen Franklin, Ed Crosby, John Meier, a representative (s) of Licensee who can respond to all questions related to licensee verification of dewpoint readings of Plant Vogtle Diesel Generators between 1989 and 1991, and the chairman or acting chairman, as of July 27, 1994, of the Plant Vogtle PRB.
Depositions are to commence during the week of August 8, 1994, at a mutually agreeable time and place.
Each and every of the above identified witnesses are directed to bring to their deposition documents that are or '
anytime were in their immediate control or possession (or in
.e immediate control or possession of their employer or legal counsel to GPC or other counsel retained to represent any individual in the instant matter) which pertain or relate to the following:
(1) all information directly or indirectly relating to the gBO400sy94 Q
ADOCK 05 y
g4 PDR
s.
dewpoint readings of the diesel generators between 1989 and 1991.
(2) all information directly or indirectly relating to the reliability of the Plant Vogtle diesel generators or the air quality of said diesel generators; (3
all personally notes, log books, note books, personal calendars, taped memos, tape recordings or other documentation prepared by the witness or which includes the thoughts or impressions of the witness for the time period of January 1, 1990 through December 31, 1990.
(5) all log books or note books any of the witnesses maintained, reviewed or relied upon when performing any business function related to the start-up of plant Vogtle after the Site Area Emergency.
The deposition of each and every individual identified above shall continue until the witness has fully testified about matters relevant to this proceeding and to matters generally discoverable as background material and relevant to the l
contention.
Intervenor requests that any objection to the production of i
1 documents set out in this notice be transmitted in writing to 1
counsel for Intervenor on or before August 1,
1994.
Respectfully submitted, f(jqu2,f Al}
M Michael D.
Kohn Kohn, Kohn & Colapinto, P.C.
517 Florida Ave.,
N.W.
Washington, D.C.
20001 (202) 234-4663 301\\ notice.mj 2
.A i
UNITED STATES OF AMERICA DDCKETED NUCLEAR REGULATORY COMMISSION USNRC ATOMIC SAFETY AND LICENSING BOARD g
)
'94 JUL % P 3 :54 In the Matter of
)
)
Docket Nos. 50-4 ' g.
g qgggg73gy GEORGIA POWER COMPANY
)
50-4 jfg ggRVICE R i'
)
BR/4NCH l
)
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 Notice of Deposition dated July 27, 1994 has been served this 27th day of July, 1994, by first class mail upon the persons listed in the attached Service List, with the exception that it was served by facsimile as indicated by "*".
By:
h 71[ [
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/
14ary fafe Wiltnoth, Esq."
KOHN,' ROHN & COLAPINTO, P.h.
517 Florida Ave.,
N.W.
Washington, D.C.
20001 (202) 234-4663 t
1
r t
t 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 et al.,
)
)
Re: License Amendment t
(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 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 j
Atomic Safety and Licensing Board U.S.
Nuclear Regulatory Commission I
Washington, D.C.
20555 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, PIT'JMAN, POTTS &
TROWBRIDGE 2300 N Street, N.W.
Washington, D.C.
20037 2
=.. -..
t Office of the Secretary Attn: Docketing and Service U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Office of Commission Appellate Adjudication i
U.S.-Nuclear Regulatory Commission Washington, D.C.
20555 301\\ cert.lis i
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