ML20072E985
| ML20072E985 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 08/15/1994 |
| From: | Wilmoth M GEORGIA POWER CO., KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#394-15582 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9408230160 | |
| Download: ML20072E985 (24) | |
Text
QUG-iS-19 M 15?44 P.02
/5573 00CKETED USNRC August 15, 1994 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARDFfICE Of Si ':RE TARY 00CKE fiNG c CLRV!Cf:
~~~~ '
)
BRANCH In the Matter of
)
)
Docket Nos. 50-424-OLA-3 GECRGIA POWER COMPANY
)
50-425-OLA-3 at a1
)
)
Re: License Amendment (Vegtle Electric Generating
)
(transfer to Southern Nuclear)
Plant, Unit 1 and Unit 2)
)
)
ASLBP No. 93-671-01-OLA-3
_IN7ERVENOR'S MOTION TO COMPEL GPC TO PRODUCE BILL SHIPMAN COMES NOW, Allen Mosbaugh, Intervenor in the above captioned matter and requests this honorable Board to compel Georgia Power Company, Licensee, to produce Mr. Bill Shipman for the completion of his deposition on or during the week of August 22, 1994.
Additionally, Intervenor requests that if Mr. Shipman is never produced for ine ccmpletion $f his deposition that the appropriate adverse inferencea be invoked against Licensee.
These requests are made for cne following leasons:
I.
BACKGROUND In the course of the August 12, 1994, status conference Licensee indicated that Mr. Shipman would not be available for the continuation of his deposition during the week of August 22, because he is undergoing major surgery on August 24.
Intervenor's counsel, Mr. Stephen M. Kohn, Esq., asserted that this would be only time prior to Mr. Shipman's surgery that Intervenor is able to depose him because Mr. Michael D.
- Konn, will be out of the country during the week of August 15.
Esq.,
'))
9408230160 940815 l
{DR ADOCK 05000424 PDR
1 ouc-is-im is:aa p.o s 1994.
Intervenor's counsel further asserted that there had been an understanding reached between the Board and the parties at the July 28, 1994 status conference that Intervenor would proceed with Mr. Shipman's deposition on August 5, and then reconvene it, 1
if needed, on either August 25 or 26 when Mr. Mosbaugh would be J
available to acsist his counsel.
The Board then directed Intervenor to file this motion explaining his position as to why Mr. Shipman should be compelled to sit for a deposition on August 22.
II.
ARGUMENT Intervenor's counsel has indicated from the beginning of the deposition process that Mr. Shipman's deposition should take precedence over all other noticed depositions.
Intervenor has tirelessly attempted to schedule Mr. Shipman for deposition and has faced counticss roadblocks.
On June 27, 1994, Intervenor noticcd Mr. Sh_p. nan for depugition to take place on July 20.
However, Licenaee failed to inform Intervenor's counsel that Mr.
Shipman was seriously ill until July 1, 1994.
See Exhibit 1 (Letter dated July 1, 1994, from M.
Kohn to D.
Lewis regarding their in-person meeting of July 1).
Upon learning of this illness Intervenor's counsel again requested to schedule Mr.
Shipman to be deposed during the week of July 18.2 Licensee's Intervenor's counsel has repeatedly asked for Licensee 1
te provide an affidavit and/or to communicate in writing regarding Mr. Shipman's health, prognosis, or availability.
Licensee has never accommodated Intervenor in this way.
See Eyhibit 2, infra, and Exhibit 3 (Letter dated July 14, 1994, from M.
Kohn to J. Lamberski page 2 and FN 1).
2
Cat & 15-1994 15!A5 P.04 counsel was at first unresponsive to attempts by Mr. Michael Kohn, to set a firm date for the week of July 18.
Finally, on July 12, Mr. John Lamberski responded that Mr. Shipman would not be available that week because he would be in Houston on the 18th meeting with his doctors.
See Exhibit 2 (Letter dated July 13, 1994, from M.Kchn to ASLB regarding Mr. Shipman's una /ai] ability).
On July 15, Mr. Lamberski also forwarded a letter to Intervenor's counsel from Mr. Shipman's personal counsel, Richard Hendrix, which states that Mr. Shipman would be unavailable because he would be meeting with his doctors on July 15 and 18.
This letter also states that Mr. Shipman would be unavailable the week prior to the close of discovery, July 25 through August 1, because he was on vacation.
See Exhibit 4 (Letter dated July 15, 1994, from J. Lamberski to M.
- Kohn, p.
2) anc Exdibit 5 (Letter dated July 12, 1994 from R.
Hendrix to J.
Lambe:cki).
This letter alet. states that Mr. Shipman would not be available until possibly the week of August 8.2 Mr. Michae). Kohn was told that the first date Mr. Shipman would be available for deposition was August 5, 1994.
Mr.
Shipman was produced for deposition on that day for four hours during which Licensee initiated conference calls to the Board which eroded the time available.
Licensee would only allow the The original date for the end of discovery was August 2
1.
Therefore, Mr. Mosbaugh scheduled his family vacation to begin at this time.
However, the discovery period was extended due to the fact that Licensee requested and received an extension in replying to written discovery from the Intervenor.
Thus, Mr.
Mosbaugh was unable to be present during the August 5 deposition to assist his counsel.
3
QuG-15-1994 15*45 P.05 deposition to commence at 1 p.m. CST and insisted that it end by 5:30.
Yet, the sign-in log demonstrated that counsel to Licensee arrived in or about 9:00 a.m
- apparently to meet with the witness and prepare him for his deposition.
Had this time been made available to Intervenor, Mr. Shipman's deposition could have been completed however it wan not.
Several areas of inquiry on significant issues remained untouched.
Moreover, Mr Shipman's counsel stated that Mr. Shipman may be scheduled for surgery on August 25th or 26th and that he might travel on the 24th and that the final date has not been scheduled.
Intervenor suggested, given these plans, that Mr.
Shipman's deposition reconvene on August 22nd.
Nonetheless, Licensee did not inform Intervenor's counsel about his availability.
Additionally, and most disturbing, is Mr. Shipman's testire,any duriag his deposit.jpn that he had returned to Work for nine days during uhe last month.
Licensee had to be aware of Mr.
Shipman's return to work (he continues to serve as a GPC General Manager), yet choose to keep Intervenor's counsel in the dark.
Finally, at the July 28, 1994 Status conference, this Board indicated that it would allow Intervenor to recommence Mr.
Shipman's deposition at a point in time when Mr. Mosbaugh would be available to attend and August 25th and 26th was proposed.3 On August loth and again on August lith, Mr. Michael Kohn spoke Every date Intervenor noticed Mr. Shipman for 3
deposition has been rejected to accommodate Mr. Shipman's scheduling to meet with his doctors.
4 m
ouc-is-io9a is ac p.oc 4
with Messrs. Lamberski and/or Joiner and they indicated that they would advise him hafore the August 12, 1994, status conference about Mr. Shipman's availability on August 22nd.
Counsel to Licensee failed to do so.
In the interim and under the understanding that Mr. Shipman would be made available during the week cf August 22, Mr. Michael Kohn made arrangements to be out i
of che country from August 14 through August 20.
Mr. Michael Kohn has conducted all of the depositions for Intervenor in this proceeding and he has in depth knowledge of the diesel generator issues.
Intervenor considers Mr. Shipman to be a very critical witness to this proceeding.4 Therefore, it would put Intervenor at a unfair disadvantage for this critical deposition to be completed by anyone other than Michael Kohn.
If Mr. Shipman is not compelled by this Board to appear for
~
deposition on or duri19 the week of August 22, and is thereafter not available_through the rec.e.inder of this proceeding, Intervenor requesta that the appropriate adverse inferences be invoked against Licensee.
Intervenor's counsel was affirmatively led to the impression Mr. Shipman would be available, yet he has i
Mr. Shipman was the General Manager over licensing with whom Mr. Mosbaugh spoke on April 19, 1990 to advise him that the April 9, 1990 Corrective Action Response letter transmitted by GPC and the draft of Site Area Emergency Licensing Event Report (LER 90-006) contained materially false statements.
Mr. Shipman also states on Tape 57 that he was going to meet with Mr.
Hatraton and advise him of this matter.
On a later afternoon telephone conference, in response to a question by Mr. Hairston as to whether there were trips on the diesels, Mr. Shipman is alleged to have responded that management should just " disavow" knowledge of any trips.
5
CLC-15-19)A LS*AG p,gy not been.
Intervenor's case will be significantly injured if Mr.
Shipman is never produced for the completion of his deposition.
III. CONCLUSION For the foregoing reasons, Intervenor requests that Mr.
Shipman be made available for deposition on August 22, 1994, or during that week.
Intervenor also requests that if Mr. Shipman is never produced for deposition then the appropriate adverse inferences be applied to Licensee.
Respectfully submitted, f
[db Md Michael Kohn Mary Jane Wilmoth Kohn, Kohn & Colapinto, P.C.
517 Florida Ave.,
N.W.
Washington, D.C.
20001 (202) 234-4663 Attorneys for Intervenor
~.
Dated; August 15, 1994 301\\motship l
6 ee
.e_
QUG 19 M 15t47 p gg 1
l Exhibit 1
l
CUG-15-1994 15!A7 P.C9 KOHN. KOHN, S COLAPINTO, PC ATTORNEYS AT law 517 FLORea AVENLE. NW WASHNGTON. 00 2OOCS1950 (202; 234-4663. FAX (202,' 462 4* 45 US 4.
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July 1, 1994 Vi: Fhesini1+
David R.
Lewis, Esq.
Shaw, Pittman, Pitts & Trowbridge 2300 N Street, N.W.
Washington, D.C.
20037 Re:
Vogtle Electric Generating Plant, Units 1 &2 License Amendment (Transfer to Southern Nuclear)
ASLBP No. 69-671-01-OLA-3 l
Docket Nos. 50-424-OLA 50-425-OLA-3 Mr Lewis:
I write you with respect to our in-person meeting today with r e spe <-
- to, im er alia, the notices of depositions transmitted to l
Licensee on t..ae 27, 1994. ~~ With respect to these depositions, l
please be advis.2d of the following:
1)
The firs-witness I.oticed, Mr. Stokes, must commence as l
noticed, ca July v,
1994 at 30 a.m.
He is an important witness who cannet be deposed at a later date without l
harm resulting to Intervenor's case.
Intervenor objects to going forward with any depositions until Mr. Stokes is produced.
2)
I advised you that I was making travel plans and needed to know if the first week of noticed depositions (everyone noticed for this week was believed to be physically stationed in Augusta) would commence in Augusta or elsewhere.
You indicated to me that Licensee would agree to make everyone available in Atlanta as this would best suit your client's needs.
I agreed to this arrangement.
At the last minute you are changing the deposition location to Augusta -- af ter I have booked my airline tickets and made lodging arrangements.
I request that you abide by your earlier commitments.
ca-('
QUG-15-IGM 15:47 P.10 Page 2 Kohn to Lewis July 1, 1994 3)
You indicated to me that Mr. Shipman now suffers from life -thr eatening health problems.
I extend my condolences and sincerely wish him the best.
I will, of
- course, reschedule his deposition to accommodate his condition.
Unfortunately, his condition makes it imperative that Mr. Shipman's deposition commence as soon as possible.
I request that you attempt to schedule him for deposition during the week of July 18th.
Sincerely,
,/fs Michael D.
Kohn cc:
Charles Bcrth, Esq.
301\\let.dl 1
1
(CG-15-1994 15:48 P.11 Exhibit 2
CetE-15-19M 15:49 p.12 KOHN. KOHN 6, COLAPINTO, PC.
ATTORNEYS AT LAW
$17 FLCFOA AVENJE. NW WAS-NGTCN 2C 20001 1850 (202)2:44-4653. F A X '202) 462-4145 Ac o-Tec s oc v o< art 3 o'..* *
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- C'*'V/ft'*Fa g imile July 13, 1994 Hon. Peter B.
isloch, Chair Ato nic Safety and Licensing Board U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Hon. James H.
Carpenter 933 Green Point Drive Oyster Point Sunset Beach, NC 28468 Hon. Thomas D.
Murphy Atomic Safety and Licensing Board U.S.
Nuclear Regulatory Commission
~
Wasnington, D.C.
20555 Re:
In the Matter of Georgia Power Company, ot.al.
(Vogtle Electric Generating
- Plant, Unita 1 and 2) Dockets Nos. 50-424-OLA-3 & 50-425-OLA-3, ASLDP No. 93-671-01-OLA-3
Dear Honorable Judges:
Below-signed ccunsel wishes to place the Board on notice of a conversation held yestcrda; concerning the availability of an essential witness to this proceeding, Mr. William Shipman.1 Mr.
John Lamberski advised below-signed counsel that Mr. Shipman has scheduled a meeting with his surgeon for July 19, 1994 and that, based on this consultation, Mr.
Shipman may undergo radical surgery.
1 Mr. Shipman was the General Manager over licensing with whom Mr. Mosbaugh spoke Tn April 19, 1990 to advise him that the April 9, 1990 Corrective Action Response letter transmitted by GPC and the draft of Site Area Emergency Licensing Event Report (LER 90-006) contained materially false statements.
Mr. Shipman also atttes on Tape 57 that he was going to meet with Mr. Hairston and advise him of this matter.
On a later afternoon telephone
)
l conference, in response to a question by Mr. Hairston as to whether l
thcre were trips on the diesels, Mr. Shipman is alleged to have l
responded that management should just " disavow" knowledge of any trips.
t (l
o-
LUG-15-1994 is!49 P.13 Page 2 July 13, 1994 Letter to ASLB This Honorable Board should take note that on June 27, 1994,-
Intervenor's counsel requested that Mr. Shipman be made available for dep?sition on July 20, 1994.
Sae Intervenor's June 27, 1994 Notice of Deposition of various individuals.
It was not until July 1, 1994, that Licensee's counsel, Mr. David Lewis, advised me that it was his understanding that Mr.
Shipman was terminally ill.
After our conversation on July 1, 1994, I transmitted a letter to Mr, Lewis which states in relevant part:
You indicated to me that Mr.
Shipman now suf fers f rom lif e-threatening health problems.
I extend my condolences and sincerely wish him the best.
I will, of course, reschedule his deposition to accommodate his condition.
Unfortunately, his condition makes it imperative that Mr.
Shipman's deposition commence as soon as possible.
I request that you attempt to schedule him for depositicn during the week of July 18th.
To this day, Licensee's counsel remains unrarponsive to Intervedor's request to schedule Mr. Shipman for deposition on the first available cate (Intervencr's counsel renewed this request on more than one occasion oral.ly to counsel to Licensee).
On July 12, in respoLac to a renewec request to schedule Mr. Shipman for
~
- 1994, Mr. Lamberski responded deposition during the week of July 18th,2 orally that it is his understanding that Mr. Shipman will not be made available for deposition because he plans to travel to Houston, Texas to meet with h;.s surgeon, 2
On July 12, 1994, counsel to Intervenor requested that Licensee submit an af fidavit indicating Mr. Shipman's health status and to supply information as to why Mr. Shipman's health status would improve at a later date and why a delay in taking his Intervenor further sought to know whether deposition is necessary.
Licensee anticipates that Mr.
Shipman's health condition will prohibit him form testifying at the hearing.
e m
m
AUG-15-1994 15:49 P.14 Page 3 July 13, 1994 Letter to ASLB Intervenor believec his case will be significantly impaired be able to depose Mr. Shipman and to otherwise take should be not testimony from Mr. Shipman in lieu of his appearing at the hearing itself.
Intervenor believes that he should be entitled to appropriate adverse inferences should Mr.
Shipman never be produced for deposition. Intervenor requests guidance from the Board on this matter.
Respectfully, hj &
Michael D.
Kohn Attorney for Intervenor cc:
John Lamberski, Esq.
Charica Barth, Esq.
files \\001\\LET1' Jb I
. _ _ _. _ _. _. _ _.. _ - ~ _... _ _ _.. _..,. _... _ _
OJG-15-19 M 15:49 P.15 I
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QUG-15-1994 15'50 P.iG l
KOHN, KOHN, & COLAPINTO, PC.
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July 14, 1994 Via ;'ac s imil e John Lair.berski, Esq.
TROUINAN SANDERS Suite 5200 600 Peachtree Street, N.E.
Atlanta, GA 30308-2216 RE:
Vogtle Electric Generating Plant, Units 1 &2 i
License Amendment (Transfer to Southern Nuclear)
Docket Non. 60-424-OLA-3: 50-425-OLA-3
Dear Mr. Lamberski:
I am in receipt of your facsimile transmission of today setting Torth the latest deposition schedule for the weeks of July
'icur let er accurately sets forth the schedule as leth ar.a 25th.
we last discussea it.
Nonetheless, I request that we discuss the f ollowj ng thret-things tomorrde:
Add to the afternoon of July 20th the following persons:
1.
I anticipate that Michael Duncan and Charles Coursey.
Messrs. Duncan'a c.c. : Coursey's depositions should last approximately half an hour each.
advise whether Mr. Kitchens' schedule will make Please 2.
him available for deposition in Atlanta on the morning of July 28th.
conflict in my schedule may make it 3.
A developing difficult for me to complete Mr. Dahlberg's deposition if we begin it at 3 p.m. on July 28th.
Assuming this is the
- case, there may be a need to move Mr.
Dahlberg's dy ;sition to 1 p.m.,
or else we may have to agree on a different date and time convenient to Mr. Dahlberg.
I hope we can reach arrangement with respect to paragraphs 1 and 2 above by early afterncon tomorrow.
C/JG-15-1994 15!TO P.17 1
Page 2 July 14, 1994 Kahn to Lamberski to your observation about my correspondence with With respect the Board dated July 12, 1994 my letter accurately sets forth my understanding.
I do not suggest the information set out in your lettar today is inaccurate; enly that I do not recall any mention of a July 15th scheduled meeting between Mr.
Shipman and his (my recollection is that our discussions only focused on l
surgeon events occurring on or af ter July 18th).
To the extent you have additional information not contained in your letter of today about or availability, please Mr.
Shipman'c
- health, prognosis, communicate this information to me in writing to avoid further confusion on this matter.1 Sincerely,
/ft s
/
1 Michael D.
Kohn 301\\lamlet.10 11 disclosure about Mr. Shipman's condition would allow 1
F:
situation.
Depending Intervenor to adequately assess the currentIntervenor may wish to take his on Mr. Shipman's actual condition, deposition in Houston prior to his surgery.
I note that I requented in my 7-12 letter to Mr. Blake (which I faxed to you) that you submit an affidavit concerning Mr.
Shipman's health status.
I again request that such an affidavit be provided before Mr. Shipman undergoes any risky surgery.
AUG-15-1934 15:51 P.18 W
-w Exhibit 4
15-1934 15:51 P.19 S
_..ROUTMAN ANDERS _
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missaam staz.A wepseMastsme.v.ms, SwacoO ATLANTA.QE04GIA JCuGB Ftte flkaPHONE due $46 3300 secaste41:40s GAS-Jt00 DIRfCT. dos ens-3300 f.pm LAMUUtSK1 July 15,1994 m Tr'KOPY Michael D. Kohn, !bquire Koha, Kc4m & Colapirno, P.C.
517 Florida Avenue, N.W.
Washington, D.C. 20301 Gecrgia Power Company (Vogtle Bectric Re:
to Southern Nuclear Operating Company
Dear Michael:
Pursuant to our agreement of July 12, the foUowing is GPC's p Georgia Interrogatory No. 3 of Intervenor's Fourth laterrogatory and Docume Pr,wer Company, dated Jure 29.1994:
GPC believe:; tnt a d cument, w:dch is substantiaHy similar to 14,1994, was as Exhibit D during the tieposition of John Aufdenkampe on June h
provided biGPC to tbc NRC Incment Investigation Tea 20,1990 through April 14,1990.
document does as irr #143 in the bibliography of docurnents Company's GPC's fmal response k this intanogatory wil d
July 20, 1994, On July 12, t994 I asked you to provide to GPC an affidavit i d hat Response to Licensec's Request for Admissions, dated July 18, 1994.
affidavit and request that you serve it by facsimile by C.O.B. Monday, 8 A copy of de IIT #143 document is attached hereto.
C4JG-15-19 M 15:51 P.20 p ws e
eco TgXTTMAN SANM.RS
,-w ::.s,u.am Michad D. Kohn, F4uire July 15,1994 E=ve 2 in response to your July 14 neuer, which was faxed to my office to your requested changes to the WJtion schedule. With those ch is as fo!30ws:
2:00 p.m. - Ajtuni July 18: 10 00 a.m. - Miller; 12:30 p.m. - Lit.enby:
10:00 a.m. - B:uley; I:00 p.m. - Ward 00 p.m.-Duncan; 4:30 p.m.-Coursey July 19:
July 20: 10:00 a.m. - Rushttm; 2:00 p.m.- Dixon; 4:
July 21: 10:00 a.m. - Bockhold July 22: 10:00 a.m.
Mosbaugh July 25: 11:00 a.m. - Farley; 2:00 p.m. - Mcdonald 2 July 26: 10:00 a.m. - McCoy July 27: 10.00 a.m. - Hairston
' July 28: 10:00 a.m. - Ki:chens; 1:00 p.m. - Dahlberg July 29: 2:00 p.m. - 5TATUS CONFERENCE YoutJuly 1416.tcr t.lso 2*ed that I provide you with an affviavit concerni of Mr. Shipman. In resxese to this request, I attach a letter from Mr. Shipm Richard Henddx, which sets fath ev-rythmg I know about Mr. Shipman's status Very trul yours, AAn Lamberski Chatica A. Barth, Esq.
cc:
Carolyn Evans, Esq.
2 Mr. McDoruld will be returning from Pensacola on July 25 and will confinn a change to, the start time for this deposition within the next day or two.
=mi r?
v-
AUG-15-1994 15:52 P.21 4
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Mr. John Lamberski Troutman Sandora NationsBank Plata 600 Peachtree.treet, N.E.
9 Suite 5200 Atlanta, GA 30308-2216 no:
giM_niman
Dear Joiin:
date of I'm writing with respect to the proposed depositionUnfortunately, this date for unr.11ent, Bill Shipman.
I good for Bill and we will need tc cancel the deposition.
7/29/94 that he is scheduled spoke to Bill this morning and he advises meand 18 at the MD Anderson not on July 15 to saeet with his doctorsknow un*.il after meeting with his surgeonsl of his stomach He wi.L1 not whether he in going to undergo surgery for remova Center.
As I'm sure you are aware, he has cancer not only ofU and pancreas.
the atomach, but also the liver. surgery to the stomach may be successful, be discussed All of these complexities will his liver are ht to contraindicated.between Mr. Shipman and his physicians on the 18th an In the meantime, time will Mr. Shipman know what his schedule is.
Ln order to in the event he does not undergo inanediate surgery, i
ld recuperate fross all he has recently been through, MEJJtgn_}avacatiQ to resLand abe o it is cimar thatTe Rl.a_gn,edthrough AUg_us M. Tpeaking with Mr. Shipman, fii not currently able to give a deposition, either physically or anticipate that he will be available for Of courne, with his current situation, do not mentally, and I deposition before August S.
For the time being, however, this is things could change daily.
the best infonsation I have.
~~
~ ~ - - - - - - _ _ _ _ _ _ _ _ _ _ _ _
4JG-15-1994 15:53 P,23 Mr. John Lamberski July 12, 1994 Page Tiro If you wish to discuss th9 matter with Mr. Kohn, I would suggest that you block off some dates during the week of A try tc,make him availsble.
Gincerely, PI
, McCRANIE, BROWN & THRASH
.c Richard W. Hendrix RWH/in e.\\m ee. amin--
m -
4
QUG-15-19 M 15?53 P. 2-1 00CKETED UNITED STATES OF AMERICA U3NRC NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD W E 16 P4 31
)
In the Matter of
)
Docket Dos. 50-gp4gQLA-3,.
50-gd5gp}h3f i
GEOPGIA POWER COMPANY 1
DRANt:H C L AL,
)
Re: License Amendment (transfer to Southern Nuclear)
(vogtle Electric Generating i
Plant, Unit 1 and Unit 2)
)
)
ASLBP No. 93-671-01-OLA-3 CERTIFICATE OF SERVICE I hereby certify that Intervenor's Motion to Compel GPC to Produce Bill Shipman has been served this 15th day of August by facsimile upon the persons listed in the attached
- 1994, Service List, with the exception that it was served by first class mail as indicated by "*".
k[htvl4d%6b/NMiG By:
Mary Jaye/Wilmoth KOHN, KOHN & COLAPINTO, P.C.
517 Florida Ave., N.W.
Washington, D.C.
20001 (202) 234-4663 1
Ai
GUG-15+ 19 M 15f53 P.25 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING DOARD
)
In the Matter of
)
)
Docket Nos. 50-424-OLA-3 GEORGIA POWER CCi4PANY 50-425-OLA-3 I
Lt. LL.,
)
Re: License Amendment (Vogtle Electris, Generating 1
(transfe.r to Southern Nuclear)
Plant, Unit 1 and Unit 2)
)
)
ASLBP No. 93-671-01-OLA-3 S E R,,V_I C E L T S I
% Administrative Judge Admtnictrative Judge Peter B.
Bloch, Chair James H.
Carpenter Ato aic Satety and Licensing Leard 933 Green Point Drive U.S. Nuclear Regulatory Commission Oyster Point Washington, D.C.
20555 Sunset Beach, NC 28468 Charles A.
Barth, Esq.
Administrative Judge Office of General Counsel Themaa D. Murphy Atcmic Safety and Licensing Board U.S. N.R.C U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washinaton, D.C.
20$55 Ernest L.
Blake, Jr.
John Lamberski, Esq.
David R.
Lewis Troutt.un Sandeis Suite 5200
- ' ~
SRAW, PITTMAN, POTTS &
600 Peachtree street, N.E.
TROWBRIDGE Atlanta, GA 30300-2216 2300 N Street, N.W.
Washington,-D.C.
20037 Of fice 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.lio 2
TOTAL P.25