ML20072A585

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

ML20072A585
Person / Time
Site:	Vogtle
Issue date:	08/08/1994
From:	Joiner J GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE, TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA
To:	AFFILIATION NOT ASSIGNED
References
CON-#394-15549 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9408150101
Download: ML20072A585 (6)

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00 M DCORRESPONDENCE PC 0 Nugust 8,1994 UNITED STATES OF AMERICA '94 E -9 P2 35 NUCLEAR REGULATORY COMMISSIOgg;; y g gg rg(y DOCKEIU 7'E Before the Atomic Safety and Licensine Board '

)

In the Matter of ) Docket Nos. 50-424-OLA-3 l

) 50-425-0LA-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 i l

GEORGIA POWER COMPANY'S ADDITIONAL RESPONSE TO INTERVENOR'S l FIFTH INTERROGATORY AND DOCUMENT REOUEST i 1

I I. INTRODUCTION j Georgia Power Company ("GPC") hereby provides an additional response to l

1 Intervenor's Fifth Interrogatory and Document Request to Georgia Power Company, dated l July 8,1994 (the "Fifth Request"). This response addresses document request nos. 3-5,10, 13,14,17, and 18 of the Fifth Request.'

A number of the document requests in the Fifth Request are objectionable as overbroad in that Intervenor seeks information beyond the scope of discovery established by the Board's Memorandum and Order (Scope of Discovery), dated June 2,1994. GPC has endeavored to identify and make available those documents which, based on a reasonable

" GPC previously provided its response to the interrogatories in Intervenor's Fifth Request. Eeg Georgia Power Company's Responses to Intervenor's Fifth Interrogatory and Document Request, dated July 22,1994.

9408150101 940808 PDR ADOCK 05000424 G PDR

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inquiry, appear relevant to the diesel statements at issue in this proceeding or may lead to the discovery of admissible evidence. In addition, GPC incorporates herein each of the General Objections stated in Georgia Power Company's Responses to Intervenor's Fifth Interrogatory and Document Request (July 22,1994), at 1-3.

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11. RESPONSES TO DOCUMENT REOUESTS  !

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3. GPC objects to this document request to the extent it seeks volummous  !

l documents from 1989 to present on the grounds that it is unduly burdensome and overbroad j l

as seeking information which is outside the scope of this proceeding. Without waiving such l l

objections, the Outside Areas Operator Rounds Sheets for 1989 and 1990 are available to l Intervenor for inspection and copying in the Atlanta offices of GPC's counsel except for the j I

following dates (these sheets are missing from the Vogtle Document Control Center): Unit 1 l

- June 25 and 26,1990; Unit 2 -- January 1 - 20, 1989, October 11 - 20,1989, and  ;

I December 12 - 16, 1989.

4. GPC objects to this document request to the extent it seeks documents from '

l March 20,1990 to present on the grounds that it is unduly burdensome and overbroad as I seeking information which is outside the scope of this proceeding. Without waiving such objections, GPC has already produced the maintenance work order package documenting the April 6,1990 inspection of the EDG 1 A air receiver. See Georgia Power Company's Additional Response to Intervenor's Fourth Interrogatory and Document Request, dated July 29,1994, at 5 (Bates Nos. 065977 - 065981). No other air receiver inspections were identified for 1990.

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5. GPC objects to this document request to the extent it seeks documents from  !

i 1989 to present on the grounds that it is unduly burdensome and overbroad as seeking i

information which is outside the scope of this proceeding. Without waiving these objections,  !

GPC has already produced over 60,000 pages of documentation related to the Vogtle diesel  ;

generators and is unaware of any other documentation responsive to this request.  ;

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10. GPC objects to this document request to the extent it seeks all documents  ;

l contained in " BASE SYSTEM" files on the grounds that it is unduly burdensome and I

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oppressive and overbroad as seeking information which is outside the scope of this l proceeding. Without waiving such objections, GPC believes it has already produced all l

relevant documents responsive to this request. See Georgia Power Company's Responses to Intervenor's Fifth Interrogatory and Document Request, dated July 22,1994, at 4 (response i

l to interrogatory no.12).  ;

13. See GPC's response to Document Request No.10 above.

14. GPC objects to this document request to the extent it seeks documents unrelated to the diesel generator reporting matter at issue in this proceeding on the grounds that it is unduly burdensome and overbroad as seeking information which is outside the scope of this proceeding. Without waiving such objections, GPC is not aware of any relevant documents responsive to this request that have not been produced and are not available in the i

NRC's Public Document Room.

17. GPC objects to this document request on the grounds that it is overbroad and unreasonably cumulative and duplicative. GPC has responded to all of Intervenor's 3

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1 document requests. GPC incorporates herein its prior responses, including all general and specific objections to such document requests.

18. GPC objects to this document request to the extent that it seeks documents that are privileged attorney-client communications or subject to the attorney work product doctrine. Otherwise, GPC is unaware of documents responsive to this request that have not been produced.

Dated: August 8,1994

/ .

ames E. Joiner '

John Lamberski TROUTMAN SANDERS Suite 5200 600 Peachtree Street, N.E.

Atlanta, GA 30308-2216 (404) 885-3360 Ernest L. Blake David R. Lewis l SHAW, PITTMAN, POTTS & TROWBRIDGE i 2300 N Street, N.W.

Washington, D.C. 20337 (202) 663-8084 Counsel for Georgia Power Company 4

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DOCKETED USNRC 1

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 94 AUG -9 P2 :55 Before the Atomic Safety and Licensine Board 0FFICE OF SECRETARY

~

DOCKETING & SERVtCE BRANCH

)

In the Matter of ) Docket Nos. 50-424-OLA-3

) 50-425-OLA-3 GEORGIA POWER COMPANY, ) l etal. ) Re: License Amendment i

) (Transfer to Southern (Vogtle Electric Generating ) Nuclear)

Plant, Units 1 and 2) )

) ASLBP No. 93-671-01-OLA-3 l

l CERTIFICATE OF SERVICE I hereby certify that copies of Georgia Power Company's Additional Response to Intervenor's Fifth Interrogatory and Document Request, dated August 8,1994, were served by express mail upon the persons listed on the attached service list this 8th day of August, l 1994.

1 N M d.1 .

+1 4'Pl Thomas L. Penland, Jr.

TROUTMAN SANDERS Suite 5200 600 Peachtree Street, N.E.

Atlanta, GA 30308-2216 (404) 885-3471 I

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Q UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l In the Matter of GEORGIA POWER COMPANY,

• Docket Nos. 50-424-OLA-3 9.1 Al.

• 50-425-OLA-3 (Vogtle Electric

• Re: License Amendment Generating Plant, *

(Transfer to Southern Units 1 and 2)

• Nuclear)

• ASLBP No. 93-671-01-OLA-3 I

SERVICE LIST Administrative Judge Stewart D. Ebneter Peter B. Bloch, Chairman Regional Administrator Atomic Safety and Licensing USNRC, Region II Board 101 Marietta Street, NW U.S. Nuclear Regulatory Suite 2900 Commission Atlanta, Georgia 30303 Two White Flint North 11545 Rockville Pike Office of the Secretary Rockville, MD 20852 U.S. Nuclear Regulatory Commission l Administrative Judge Washington, D. C. 20555 '

James H. Carpenter ATTN: Docketing and Atomic Safety and Licensing Services Branch Board 933 Green Point Drive Charles Barth, Esq.

Oyster Point Office of General Counsel Sunset Beach, NC 28468 One White Flint North Stop 15B18 Administrative Judge U.S. Nuclear Regulatory Thomas D. Murphy Commission Atomic Safety and Licensing Washington, D. C. 20555 Board U.S. Nuclear Regulatory Director, Commission Environmental Protection Two White Flint North Division 11545 Rockville Pike Department of Natural Rockville, MD 20852 Resources 205 Butler Street, S.E.

Michael D. Kohn, Esq. Suite 1252 Kohn, Kohn & Colapinto, P.C. Atlanta, Georgia 30334 517 Florida Avenue, N.W.

Washington, D.C. 20001 office of Commission Appellate Adjudication One White Flint North 11555 Rockville Pike Rockville, MD 20852