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Category:INTERROGATORIES; RESPONSES TO INTERROGATORIES
MONTHYEARML20092H7681995-09-13013 September 1995 Georgia Power Co Fourth Suppl Response to AL Mosbaugh Third Set of Interrogatories & Request for Documents.* Related Correspondence ML20087K3481995-08-17017 August 1995 Gap First Supplemental Response to Intervenor Fifth Interrogatory & Document Request.* Response Suppls Gap Prior Response to Interrogatory 7.W/Certificate of Svc & Svc List. Related Correspondence ML20086H1291995-06-30030 June 1995 Georgia Power Company Supplemental Response to Intervenor Seventh Request for Interrogatories.* W/Certificate of Svc & Svc List.Related Correspondence ML20082L2001995-04-12012 April 1995 Intervenor Supplemental Responses to Georgia Power Company First,Second & Third Requests for Interrogatories & Prior Requests for Documents.* W/Certificate of Svc & Svc List. Related Correspondence ML20080N8401995-02-28028 February 1995 Intervenor Document Request to NRC Staff.* Intervenor Requests That Response Be Submitted within 10 Days as Law Requires.W/Certificate of Svc & Svc List ML20080N9451995-02-28028 February 1995 Intervenor Document Request to MW Horton.* Request Made for Personal Documents Not Previously Produced in Case. W/Certificate of Svc.Related Correspondence ML20080N9311995-02-28028 February 1995 Intervenor Document Request to Ck Mccoy.* Request Made for Personal Documents Not Previously Produced in Case. W/Certificate of Svc.Related Correspondence ML20080N9081995-02-28028 February 1995 Intervenor Document Request to Gr Frederick.* Request Made for Personal Documents Not Previously Produced in Case. W/Certificate of Svc.Related Correspondence ML20080N8971995-02-28028 February 1995 Intervenor Document Request to Tv Greene.* Request Made for Documents Not Previously Produced in Case.W/Certificate of Svc.Related Correspondence ML20080N8901995-02-28028 February 1995 Intervenor Document Request to H Majors.* Requests Made for Personal Documents Not Previously Produced in Case. W/Certificaate of Svc.Related Correspondence ML20080N8771995-02-28028 February 1995 Intervenor Document Request to G Bockhold.* Requests for Personal Documents Not Previously Produced in Case. W/Certificate of Svc.Related Correspondence ML20080N8441995-02-28028 February 1995 Intervenor Document Request to Ga Power Company.* Requests for Personal Documents Not Previously Produced in Case. W/Certificatte of Svc.Related Correspondence ML20072P2231994-08-26026 August 1994 Georgia Power Company Response to Intervenor Document Request.* Util Not to Further Respond to Intervenor Request Since 940801 Deadline Not Met.W/Certificate of Svc & Svc List ML20072L1371994-08-17017 August 1994 Intervenor Document Request to Georgia Power Company.* NRC Advises Util to Identify & Produce All Documents Used in Creation of Georgia Power Company Response to 940731 Nov. W/Certificate of Svc & Svc List.Related Correspondence ML20072A6641994-08-10010 August 1994 Gpc Addl Response to Intervenor Second Request for Admissions.* W/Certificate of Svc.Related Correspondence ML20072A6031994-08-0808 August 1994 Util Response to Intervenor Seventh Request for Interrogatories.* Informs That Util Objects to Instruction D of Seventh Request.W/Certificate of Svc & Svc List.Related Correspondence ML20072A5611994-08-0808 August 1994 Util Third Suppl Response to AL Mosbaugh Third Set of Interrogatories & Request for Documents.* Provides Addl Info Required by Board Memorandum & Order Dtd 940714. W/Certificate of Svc.Related Correspondence ML20072A5851994-08-0808 August 1994 Util Addl Response to Intervenor Fifth Interrogatory & Document Request.* Informs That Response Addresses Document Request 3-5,10,13,14,17 & 18 of Fifth Request.W/Certificate of Svc & Svc List.Related Correspondence ML20071P4021994-07-29029 July 1994 Util Addl Response to Intervenor Fourth Interrogatory & Document Request.* Response Addresses Document Request 6-17 & 19 of Fourth Request.W/Certificate of Svc & Svc List. Related Correspondence ML20071P4031994-07-29029 July 1994 Util Response to Intervenor Second Request for Admissions.* Informs That Second Request for Admissions Would Be Done in Two Listed Steps.W/Certificate of Svc.Related Correspondence ML20071M1841994-07-25025 July 1994 Intervenor Seventh Request for Interrogatories to Georgia Power Co.* a Mosbaugh Requests That Georgia Power Co Answer Listed Interrogatories in Writing & Under Oath.W/Certificate of Svc & Svc List.Related Correspondence ML20070H8231994-07-20020 July 1994 Gap Responses to Intervenor Fourth Interrogatory & Document Request.* W/Certificate of Svc & Svc List.Related Correspondence ML20070G9621994-07-18018 July 1994 Gpc Objections to Intervenor 940707 Discovery Requests & Motion for Protective Order.* Gpc Moves Board for Protective Order Providing That Intervenor 940707 Discovery Request Not Be Had.W/Certificate of Svc ML20070H1161994-07-18018 July 1994 Intervenor Response to Georgia Power Co Second Request for Admissions.* Objects to Admissibility by Licensee of Portions of Transcripts &/Or Tape Recordings &/Or Paraphrasing.W/Certificate of Svc.Related Correspondence ML20070E8921994-07-0808 July 1994 Intervenor Fifth Interrogatory & Document Request to Georgia Power Co.* Intervenor a Mosbaugh Requests That Georgia Power Co Answer Listed Interrogatories in Writing.W/Certificate of Svc & Svc List.Related Correspondence ML20070E8551994-07-0808 July 1994 Intervenor Fourth Set of Interrogatories & Request for Documents to Staff of Nrc.* Intervenor a Mosbaugh Requests That Staff of NRC Answer Listed Interrogatories in Writing. W/Certificate of Svc & Svc List.Related Correspondence ML20070E9961994-07-0707 July 1994 Intervenor Second Request for Admissions to NRC Staff.* Requests for NRC to Answer Request for Admissions & Interrogatory & Produce Documents as Required.Certificate of Svc & Svc List Encl.Related Correspondence ML20070F0091994-07-0707 July 1994 Intervenor Fifth Request for Interrogatories & Document Request to Georgia Power Co.* W/Certificate of Svc & Svc List.Related Correspondence ML20070F0541994-07-0707 July 1994 Intervenor'S Third Request for Admissions to Gpc.*Requests Util Answer Request for Admissions & Interrogatories & That Util Provide Required Documentation by 940721.W/Certificate of Svc & Svc List.Related Correspondence ML20071G9511994-07-0707 July 1994 Ga Power Company Response to Intervenor First Request for Admissions.* W/Certificate of Svc & Svc List.Related Correspondence ML20071G9071994-07-0505 July 1994 Georgia Power Co Second Supplemental Response to Am Mosbaugh Third Set of Interrogatories & Request for Documents.* W/Certificate of Svc & Svc List.Related Correspondence ML20071G9421994-07-0101 July 1994 Intervenor Second Request for Admissions to Georgia Power.* Requests That Util Answer Listed Request of Admissions & Deliver Answer on or Before 940715.W/Certificate of Svc & Svc List.Related Correspondence ML20071G8851994-07-0101 July 1994 Ga Power Company Objections to Document Requests in Intervenor Notice of Depositions.* W/Certificate of Svc & Svc List.Related Correspondence ML20070D4901994-06-29029 June 1994 Intervenor Fourth Interrogatory & Document Request to Gpc.* Requests That Responses Be Filed within 14 Days from Svc of Request & All Relevant Documents Be Made Available for Insp. W/Certificate of Svc & Svc List.Related Correspondence ML20070A9051994-06-22022 June 1994 Intervenor Suppl to Licensees Third Set of Interrogatories & Request for Documents.* W/Certificate of Svc & Svc List. Related Correspondence ML20069P2611994-06-17017 June 1994 Georgia Power Co First Supplemental Response to AL Mosbaugh Third Set of Interrogatories.* Responds to Interrogatories & Document Requests for Persons Listed.W/Certificate of Svc. Related Correspondence ML20069L5641994-06-13013 June 1994 Intervenor Amended Response to Licensee Third Set of Interrogatories & Request for Documents.* W/Certificate of Svc & Svc List ML20069K4091994-06-10010 June 1994 Util Response to AL Mosbaugh Third Set of Interrogatories.* Licensee Objects to Interrogatory as Unduly Burdensome & Duplicative of Preliminary Designation of Anticipated Witnesses.W/Certificate of Svc.Related Correspondence ML20069F2981994-06-0101 June 1994 Intervenor Response to Licensee Third Set of Interrogatories & Request for Documents.* W/Certificate of Svc.Related Correspondence ML20149E4291994-05-18018 May 1994 Intervenors Third Set of Interrogatories & Request for Documents to Util.* W/Certificate of Svc.Related Correspondence ML20149E4421994-05-17017 May 1994 Intervenors Second Set of Interrogatories & Request for Documents to Staff of Usnrc.* W/Certificate of Svc.Related Correspondence ML20029D9281994-05-0606 May 1994 Georgia Power Co Third Set of Interrogatories & Request for Documents to AL Mosbaugh.* Requests That AL Mosbaugh Answer Interrogatories in Writing & Under Oath within 14 Days of Svc.W/Certificate of Svc & Svc List.Related Correspondence ML20065R5831994-05-0303 May 1994 Intervenor Request for Interrogatories Documents to Gpc Related to Illegal Transfer of Control.* Intervenor Requests That Gpc Answer Listed Interrogatories in Writing & Under Oath & Produce Requested Documents.W/Certificate of Svc ML20029D5331994-04-28028 April 1994 Georgia Power Co Second Set of Interrogatories & Third Request for Production of Documents to NRC Staff.* W/ Certificate of Svc.Related Correspondence ML20058P4041993-12-20020 December 1993 Interrogatory Response of NRC Staff to Gap 931008 First Set of Interrogatories & Second Request for Production of Documents.* ML20058P5861993-12-20020 December 1993 Interrogatory Response of Jf Rogge to 931008 Gap First Set of Interrogatories & Second Request for Production of Documents to NRC Staff.W/Certificate of Svc.Related Correspondence ML20058P5201993-12-20020 December 1993 Interrogatory Response of L Trocine to Gap 931008 First Set of Interrogatories & Second Request for Production of Documents to NRC Staff.* ML20058P4391993-12-17017 December 1993 Interrogatory Response of Ae Chaffee to 931008 Gap First Set of Interrogatories & Second Request for Production of Documents to NRC Staff.* ML20058P4301993-12-17017 December 1993 Interrogatory Response of Jf Rogge to 931008 Gap First Set of Interrogatories & Second Request for Production of Documents to NRC Staff.* ML20058P4521993-12-14014 December 1993 Interrogatory Response of SD Ebneter to Gap 931008 First Set of Interrogatories & Second Request for Production of Documents to NRC Staff.* 1995-09-13
[Table view] 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] |
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/S504 4
l D RD00RRESPONDENCE DOCKETED l USNRCJuly 29,1994 1 UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMhilSSIg g q O F S f T i F ij,p y Before the Atomic Safety and LicensineOffidii[{iiNG
~
~ UOcin & S[ WlCE BRis NCli
)
In the Matter of ) Docket Nos. 50-424-OLA-3
) 50-425-OLA-3 GEORGIA POWER COMPANY, )
etal. ) Re: License Amendment
) (Transfer to Southern (Vogtle Electric Generating ) Nuclear) ,
Plant, Units 1 and 2) )
) ASLBP No. 93-671-01-OLA-3 GEORGIA POWER COMPANY'S RESPONSE TO INTERVENOR'S SECOND REOUEST FOR ADMISSIONS I. INTRODUCTION ,
Georgia Power Company ("GPC) hereby responds to Intervenor's Second Request for Admissions to Georgia Power Company, dated July 1,1994 ("Second Request for Admissions").
The parties agreed, with the Board's approval, that GPC's response to the Second Request for Admissions would be done in two steps. First, by July 29,1994, GPC would respond to each of the statements of evidence cited in the Vogtle Coordinating Group ("VCG") report, dated February 9,1994.' Second, by August 9,1994, GPC would respond to the conclusions in both the VCG and OI reports.
' This response addresses only those statements of evidence marked with an asterisk in the VCG report. The remaining statements of evidence, according to the VCG report at 1, are the same evidentiary statements that were cited in the NRC's Office of Investigations ("Ol") Report of Investigation (Case No. 2-90-020R), dated December 20, 1993. GPC's response to those evidentiary statements can be found in Georgia Power Company's Response to Intervenor's First Request for Admissions, dated July 7,1994.
1 ,
9408090299 940729 PDR 0
ADOCK 05000424 PDR ) j
II. GENERAL OBJECTIONS.
GPC objects to Intervenor's definition of " documents" in that the definition indicates that GPC must somehow divine what recorded material might be in the " possession, custody, or control of the Intervenor or any employees, representatives, attorneys, investigators, or others acting on his behalf " Second Request for Admissions at 6. GPC has interpreted this definition to apply only to " documents" in GPC's possession.
GPC objects to Instructions E and F of Intervenor's Request which require detailed information concerning every oral communication and person referred to in each of GPC's responses. Compliance with such instructions would be unduly burdensome and oppressive given that most of the responses refer to persons having oral communications. Furthermore, Intervenor is intimately familiar with these communications and the persons involved.
GPC also generally objects to Intervenor's Request to the extent that it requires GPC to )
l identify and produce every document which supports GPC's answer to each request for !
admission. Compliance with this request would be unduly burdensome and oppressive given the number of evidentiary findings. Moreover, Intervenor is well acquainted with the documents relevant to such evidentiary findings and it is unlikely that any such documents have not already been produced to Intervenor among the nearly 60,000 pages of documentation made available to Intervenor in 1993. Nonetheless, without waiving this objection, in connection with any denial of an admission herein, GPC endeavored to identify and produce any documents which it reasonably believes is not among the documents previously produced to Intervenor. No such documents were identified.
Furthermore, GPC generally objects to the identification, or disclosure, of those 2
l l
communications and documents which are subject to the attorney work product doctrine or the )
attorney-client communication privilege. GPC has been defending actions initiated by Intervenor )
I since mid-1990. In addition to this proceeding, such actions include (1) NRC inspections, an l
NRC Office of Investigations ("Ol") investigation, and an NRC enforcement action respecting those allegations lodged by Intervenor in the Hobby /Mosbaugh Petition related to the diesel f
generator reporting issue, (2) three separate actions before the Department of Labor, (3) an ,
investigation by the Department of Justice, and (4) an inquiry by a Congressional Subcommittee.
GPC's legal counsel has been heavily involved in the defense of these actions and, as a result, has generated a large number of documents in preparation of such defenses. It would be oppres-sive and unduly burdensome and expensive for GPC to identify each and every one of such documents which are subject to eithe. or both of (1) the attorney work product doctrine (i.e.,
they were prepared by legal counsel in anticipation oflitigation and their disclosure would reveal the rnental impressions oflegal counsel), or (2) the attorney-client communication privilege (i.e.,
communications from GPC to its legal counsel made in confidence for the purpose of obtaining legal advice and counsel).
III. RESPONSE TO REOUEST FOR ADMISSIONS A. Response to Evidence for Allegation Nos. I and 2
- 1. Admit.
- 2. Admit.
- 3. Admit.
- 4. Admit.
- 7. Admit.
3
\
- 8. Admit.
- 9. Deny. Although this statement accurately reflects Mr. Cash's OI interview testimony, the actual intent of the start count information was 1
to show that the diesels had been started a number of times with no i significant problems. See GPC's Response to the NRC Staff's First Set of Interrogatories, dated August 9,1993, at 12; Exhibit 12 at 12.
- 11. Admit.
- 12. Admit with the clarification that GPC believes Mr. Cash in fact included diesel starts in his count that occurred before the sensor calibration and l
logic testing were completed.
- 13. Admit with the clarification that the actual count referred to by Mr.
Bockhold on April 19, 1990, included starts which occurred before ;
t completion of sensor calibration and logic testing. See Exhibit 11.
i
- 14. Admit.
- 15. Admit.
- 16. Admit with the clarification that GPC's basis also included all of the troubleshooting and control system functional testing described in NUREG-1410, Appendix J. ;
- 18. Admit.
- 20. Deny. This statement mischaracterizes the testimony of Mr. Bockhold in that it omits relevant informction which supplies the context of the statement. Both Messrs. Bockhold and Cash understood that Mr. Cash 4
was to count the number of successful starts without significant problems.
Ses Exhibit 12, Tr. 4-5 and GPC's Response to the NRC Staff's First Set of Interrogatories, dated August 9,1993, at 12. i
- 21. Admit.
- 41. Admit.
I
- 42. Deny. GPC admits that Mr. Cash does say that he gave Mr. Bockhold "every start that we have done." However, Mr. Cash's typed diesel start !
list, reDecting the results of his review, shows Mr. Cash included on the list (a) starts which were performed before the March 20,1990 event, and (b) more starts than Mr. Cash reported to Mr. Bockhold as being .
successful starts. See Exhibit 36, Tr. 35 and Exhibit 11. In addition, ;
GPC notes that Mr. Cash's statement was "I'm not sure if I found the I failures or not." Tape 58. j l
- 59. Admit. I
- 64. Neither admit nor deny. The interview notes of the 01 investigator are an insufficient basis for GPC to determine either the accuracy or the l
truthfulness of this evidentiary finding.
- 65. Admit with the clarification that the evidentiary statement is based on the dennition of successful starts provided in the August 30,1990 letter.
- 66. Neither admit nor deny. GPC lacks sufficient information to confirm the truthfulness of this statement.
5 l l
l
l l
I B. Responses to Evidence for Allegation No. 3.
- 1. Admit with the clarification that the date of LER 90-06 should be April 19, 1990.
- 7. Admit.
- 9. Admit. ,
- 16. Admit. ,
- 18. Admit.
- 19. Deny. The number of " consecutive successful starts subsequent to the completion of the CTP" as that term was defined by Mr. Bockhold on April 19,1990, and conveyed to Shipman and Aufdenkampe, does not correlate with the diesel start numbers 10 and 12 cited in the June 29, 1990 cover letter. See Exhibit 36, Tr. 20-26.
- 20. Admit.
- 21. Admit.
- 22. Deny. GPC admits that the statement accurately summarizes Mr.
Shipman's statements as recorded on Tape 58. However, GPC denies that the starts referred to in the April 9,1990 letter actually included only those starts after instrument recalibration. Src Exhibit 11.
- 23. Neither admit nor deny. GPC lacks sufHcient information to determine the truthfulness of this statement.
- 24. Admit with the clarification that while Messrs. Shipman and Aufdenkampe ,
did not know the exact starting point for Mr. Bockhold's count, they were 6
informed it was after instrument recalibration. See Exhibit 36, Tr. 20-26.
- 25. Admit.
- 26. Admit.
- 27. Admit.
- 28. Admit.
- 29. Admit.
- 30. Deny. In the referenced portion of Tape 58, Mr. Cash indicates that he began his count for EDG 1 A with starts performed on March 20, 1990.
However, Mr. Cash actually performed his review of the control room logs for successful starts by reviewing entries beginning before the March >
20,1990 event, and ending sometime shortly before April 9,1990. See Exhibit 36, Tr. 35-36 and Exhibit i1.
- 31. Deny. GPC admits that Mr. Cash does say that he gave Mr. Bockhold "every start that we have done." However, Mr. Cash's typed diesel start list, reflecting the results of his review, shows Mr. Cash included on the list (a) starts which were performed before the March 20,1990 event, and (b) more starts than Mr. Cash reported to Mr. Bockhold as being successful starts. See Exhibit 36, Tr. 35 and Exhibit 11. In addition, GPC notes that Mr. Cash's statement was "I'm not sure if I found the failures or not." Tape 58.
- 32. Deny. Aufdenkampe's statement, as recorded on Tape 58, was that Mr.
Bockhold in fact told Mr. Shipman that the diesel start count for EDG 1B 7
" started after the third failure." Tape 58.
- 33. Neither admit nor deny. GPC lacks sufficient information to determine -
the truth of this statement. However, GPC notes that it is aware of only one LER draft where hir. hiosbaugh expressed concern regarding its accuracy.
- 39. Admit with the clarification that hir. Hairston had requested verification of the EDG start data and assumed it was performed. Exhibit 31, Tr. 46-
$1.
C. Responses to Evidence for Allegation No. 4.
- 1. Admit.
- 2. Admit.
- 3. Admit.
- 5. Admit.
- 6. Admit with the clarification that GPC has not reviewed the VCG's version of this transcript.
- 7. Admit.
- 11. Admit with the clarification that hir. Frederick was also out of the office when Hairston placed this call. The call was received by the another SAER representative on-site.
- 15. Admit.
- 16. Admit.
- 17. Admit.
8
l
- 18. Admit with the clarification that the context of the evidentiary statements is lost due to the omission of other material information contained in the SAER report.
- 20. Admit with the clarification that hiessrs. Bockhold and Cash believe they were in fact contacted during the course of the SAER audit.
- 21. Admit.
- 22. Admit.
- 25. Deny. The referenced draft cover letters to the June 29,1990 revision to the LER do refer to the April 9,1990 letter, contrary to this finding. See GPC's Section 2.206 Petition Response, dated April 1,1991, Attachment 3, Exhibits 16-20.
- 26. Admit.
- 30. Admit. ;
- 34. Admit.
- 35. Deny. GPC agrees that hir. hiosbaugh did express this viewpoint.
1 However, GPC denies the truth of the statement because adequate information was not avaibble to those counting diesel starts on April 19, 1990, and just prior to April 9,1990, such that they were able to compile '
an accurate count. See Tape 57 and Exhibit 11.
- 36. Deny. GPC admits that hir. hiosbaugh did express this viewpoint.
However, GPC denies that personnel acted with either carelessness or negligence.
9
- 37. Deny. GPC admits that Mr. Mosbaugh did express this viewpoint.
However, GPC denies the truth of the statement because it does not explain the reason the LER statement was incorrect. Tapes 57 and 58.
- 38. Admit.
- 39. Admit.
- 41. Deny. This statement fails to distinguish between Mr. Horton's initial response and his ultimate opinion. Exhibit 57, Tr.19-30.
- 42. Admit.
- 43. Deny. GPC denies the truth of the statement because the information provided to Mr. Greene on June 29,1990, by Mr. Mosbaugh conflicted with information provided by other knowledgeable participants such that it was not clear to Mr. Greene that the cover letter was deficient. Exhibit 57, Tr. 32-69.
- 44. Admit.
- 45. Admit.
D. Responses to Evidence for Allegation No. 5.
- 1. Admit.
- 3. Admit.
- 5. Admit.
- 21. Admit.
- 22. Admit.
- 24. Admit.
10
- 25. Admit with the clarification that Bockhold's statements, when reviewed in context, indicate that the particular reorganization of the August 30 letter under discussion by the PRB would not, in his opinion, improve upon the accuracy of the letter.
- 26. Admit.
- 27. Admit.
- 28. Admit.
E. Responses to Evidence for Allegation No. 6.
- 2. Admit.
- 3. Admit with the clarification that the inspection report was based on an ;
historic view of air quality.
- 4. Admit. l l
- 6. Admit.
- 8. Admit.
- 9. Neither admit nor deny, GPC lacks sufficient information to determine the truth of the statement. ,
F. Responses to Evidence for Allecation No. 7.
- 1. Admit.
- 2. Admit.
- 3. Neither admit nor deny. GPC lacks sufficient information to determine 1 l
the truth of the statement.
- 4. Admit.
11
Dated: July 29,1994
) 1 i
/ ,
~-
w 11 t
/ John Lambetski '
TROUTMAN SANDERS Suite 5200 600 Peachtree Street, N.E.
Atlanta, GA 30308-2216 (404) 885-3360 Ernest L. Blake David R. Lewis SHAW, PITTMAN, POTTS & TROWBRIDGE 2300 N Street, N.W.
Washington, D.C. 20337 (202) 663-8084 Counsel for Georgia Power Company 12
n 2c. '94 FF 1 14:57 ID:t%1tJENANCE-SU FCRT FAX NO:1 205 BSE 5465 C6EO F02 SENT BY:tPC 50/0 'l-26-94 : 3:02PM t TROUTNAN SAN 0ER5*NAINTENANCE-SUPPORT ;# 8 UNITED STATES OF AMERICA NUCIE.4JL REGULATORY COMMISSION unpour far ATOMIC RAFETY AND UCPNENG BOARD In: the Matter of
- Docket Nos. 80 424OLA-3 GEORGIA POWER COMPANY, a al :
SM25-OLA-3
- Re: 1.lcease Am== Amend (V$le M Gepsrathig Phaa.3 : (Treaufer to Unles 1 and 2) : Southern Nuclear)
- ASLEF NO. 93471 OLA-3 ArrmAVrr OF MANE J. AlfENT t
J. Mark J. Ajtuni, being dWy swom, state as fo!!cws:
1.
I arn currently ornployed by Southern Nuclear Opersdng Company as Senior Project Engineer, VogGe Project.
2.
I have been exprenly authorized to verify Georgia Power Company's Response to Intervenor's Second Request for Admissions. Speciflgally I am duly authtrite "
to respond on behalf on the Company to the W Request for Admissions for statertents of evidence contained in the Nuclear Regulatory Commission's Vogtle Cocedinat Report, dated Petguary 9,1994, which deny, admit with clarification, or neither admit nor deny requested Admissions not otherwise addresseo by individua> atsostatips.
I hereby certify that the statements and opinions in such responses are true and correct to the best of my personal knowledge and belief.
I hN '
, ,,,,,, , ,, .,,g wa* >. +> e befos me thid y of July,1994 ,
AhA4 Noiary poi.
My commission aspires:
4 nu G. I996'
( .
UNITED STATES OF Ah1 ERICA NUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICENSING 130ARD l
In the Matter of :
- Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY, El al. : 50-425-OLA-3
- Re: License Amendment (Vogtle Electric Generating Plant, : (Transfer to Units 1 and 2) : Southern Nuclear)
- ASLBP NO. 93-671-OLA-3 i
AFFIDAVIT OF G. R. FREDERICK I, G. R. Frederick, being duly sworn, state as follows: i
- 1. I am currently employed by Georgia Power Company as Manager, Maintenance, Vogtle Electric Generating Plant.
- 2. I am duly authorized to verify Georgia Power Company's Response to Intervenor's Second Request for Admissions, specifically the responses to statements of evidence contained in the Vogtle Coordinating Group Report, dated February 9,1994, which .;
deny, admit with clarification, or neither admit nor deny as follows: ;
Allegation No. 4: Nos. I1,18 I hereby certify that the statements and opinions in such response are true and correct to the best of my personal kocwledge and belief.
r . X, A G. R. Frederick Sworn to and subscrjbed l
before me this d' day of July,1994.
, ,yf - /
yll Notary Public ; .,
My commission expires:
_ w-~ ~ r - ,.m .
W h Fagidros vem$s,ry 12.Essi
~" 7 7J 29 a9a rR: 14:50 ID : t%!H'D GrCE-3PFCR' rM to:1 205 CCG 5455 mEOE 02 - --
SENT SY:47th tvP : 7-as-64 til icAR i l 4040653388* 1 205 077 7665:a 3 l
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i wwons Tn Amurc rAFFTY AND WCNENG BOADg In tha Matter of :
- Docket Nos. 30434 OLA-3 GEORGIA DOWER COMPANY, e al.
2425-OIA-3 t
t Re IJcense Amendment (Vogtle Ehetric Generattag Maat, t (Treaufer to Untss 1 and 2) : Southern Nuclear)
I
- ASLRP NO. 95471 OLA-3 JJFmAVrr OF MICF AET. W. HORTON 1, Michael W. Horton, being duly swe., stat 6 as Miowx 1.
I am curantly employed by Southern Nudear Operating Company as Project Manager - Nuclear Technice! $cryices. '
2.
I am duly authorland to verify Georgia Power Company's **pw to Intervenor's Second Request for Admissions, speci6cally the responses to stataments of evidence contained in the Vogtle Coordinating Group Report, dated February 9,1994, which deny, admit with cJartftcation, or neither admit nor deny as follows:
I Allegation No. 4: No.41 I hereby certify that the sentements and opinions in such response are true and cornet to the best of my personal knowledge and belief.
Sxn -
0 Michael W. Rorton sworn to and h:d befbro Ine this of July,1994.
CAL 4 k 7
e N6NM U )
# e &
, 1
. 00CKETED USHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '94 f5 -l P3:19 Before the Atomic Safety and Licensina Board ut r 4GE OF SECPE TARY DOCKEilNG s 'if RVICE
) BRANCH In the Matter of ) Docket Nos. 50-424-OLA-3
) 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 Response to Intervenor's Second Request for Admissions, dated July 29, 1994, were served by express mail service, upon the persons listed on the attached service list, this 29th day of July, 1994.
k 7Mid -
1 2 )? '
Thomas L. Penland, Jr.
Dated: July 29, 1994 l
4 13 l
l i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of GEOP.GIA POWER COMPANY,
- Docket Nos. 50-424-OLA-3 et al.
- 50-425-OLA-3 (Vogtle Electric
- Re: License Amendment Generating Plant, *
(Transfer to Southern 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 Atomic Safety and Licensing Commission Board Washington, D. C. 20555 U.S. Nuclear Regulatory ATTN: Doeketing and Commission Services Branch Washington, D.C. 20555 C..arles Barth, Esq.
Administrative Judge Office of General Counsel James H. Carpenter One White Flint North Atomic Safety and Licensing Stop 15B18 Board U.S. Nuclear Regulatory 933 Green Point Drive Commission Oyster Point Washington, D. C. 20555 Sunset Beach, NC 28468 Director, Administrative Judge Environmental Protection Thomas D. Murphy Division Atomic Safety and Licensing Department of Natural Board Resources U.S. Nuclear Regulatory 205 Butler Street, S.E.
Commission Suite 1252 Washington, D.C. 20555 Atlanta, Georgia 30334 [
Michael D. Kohn, Esq.
Kohn, Kohn & Colapinto, P.C.
517 Florida Avenue, N.W.
Washington, D.C. 20001 Office of Commission Appellate Adjudication 1 One White Flint North 11555 Rockville Pike l
Rockville, MD 20852 l
Stewart D. Ebneter Regional Administrator USNRC, Region II 101 Marietta Street, NW Suite 2900 Atlanta, Georgia 30303 I
- - ,~. .