ML20072L137

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

ML20072L137
Person / Time
Site:	Vogtle
Issue date:	08/17/1994
From:	Wilmoth M AFFILIATION NOT ASSIGNED, KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA
To:	GEORGIA POWER CO.
References
CON-#394-15610 94-671-01-OLA-3, 94-671-1-OLA-3, OLA-3, NUDOCS 9408310095
Download: ML20072L137 (7)

Text

.

/5&o DOCKETED WTED CORRESPOtGE)CE USHRC August 17, 1994 T4 ALS 22 N1 :47 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD r j~{' '

Before Administrative Judges:

Peter B. Bloch, Chair Dr. James H. Carpenter Thomas D. Murphy

)

In the Matter of )

) Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY ) 50-425-OLA-3 21 El., )

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

Plant, Unit 1 and Unit 2) )

, ASLBP No. 93-671-01-OLA-3 INTERVENOR'S DOCUIiENT 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") respond to the following document request by producing any documents requested herein that have not previously been produced.

II. INSTRUCTIONS i

A. If you claim that any information which is required to be provided by you in your response to this document request is privileged or immune from discovery:

1. Identify the such information which you claim is i privileged in the response;

2. If the information is a document or oral communication, identify the document's title or the oral b

9408310095 940817 l PDR ADOCK 05000424  !

O PDR l L I

communication and state cPe general subject matter of the document or oral communication;

3. If the information is a document or oral communication, state the cate 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;

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.

B. In each case where you are asked to identify or to state -

the identify of 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 under which 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; 2

L

6. The date of the document; and

7. The present location of the document and the identity and address of each person who has custody of the document.

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, associates, employees, representatives, 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 interrogatories.

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, interoffice communication, report, diary, desk or pocket calendar or notebook, daybook, i 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, 3

l l

I

1 1

l 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, l

representatives, attorneys, investigators, or others acting on his behalf.

C. As used herein, the terms "and" and "or" shall each mean and/or. l D. 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, 1

and all their respective attorneys, agents, servants, associates, employees, representatives, investigators.

IV. DOCUMENT REOUEST

1. Identify and produce all documents used in the creation of Georgia Power Company's response to the Notice of Violation (NOV) dated July 31, 1994.

2. Identify and produce all documents used in the creation of the response to the NRC Demand for Information Regarding C.

Kenneth McCoy, dated August 1, 1994.

3. Identify and produce all documents used in the creation of the response to the NRC Demand for Information RegardingGeorge Bockhold, Jr., dated July 31, 1994.

4. Identify and produce all documents used in the creation of the response to the NRC Demand for Information Regarding 4

Thomas V. Greene, Georgie R. Frederick, Harry Majors, and Michael W. Horton, dated July 31, 1994.

5. Identify and produce all documents, directly or indirectly related to the responses to the NOV and Demands for Infromation identified in 1-4 above.

Respectfully submitted, bq ' OW f' Mary Jan#W'imoth M

KOHN, KOHN' COLAPINTO, P.C.

517 Florida Ave., N.W.

Washington, D.C. 20001-1850 (202)234-4663 Attorney for Intervenor DATED: August 17, 1994 doc.gpc 5

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 ga al., )

) Re: License Amendment (Vogtle Electric Gen 2 rating ) (transfer to Southern Nuclear)

Plant, Unit 1 and Unit 2) ) i

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

CERTIFICATE OF SERVICE  !

I hereby certify that Intervenor's Document Request from Georgia Power Company has been served this 17th day of August 1994, by first class mail upon the persons listed in the attached Service List.

n, *1 By: ,

dW. d/l8 f/),(/dO'Q '

Mary Ja;tV ilinoth KOHN, KJ 4 & COLAPINTO, P.C.

517 Florida Ave., N.W.

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

l I

i 1

l I

c. .

- _ _ _ J

)

. .- i I

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

)

In the Matter of )

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

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

Plant, Unit 1 and Ur.it 2) )

) ASLBP No. 93-671-01-OLA-3 SERVICE LIST Administrative Judge Administrative Judge Peter B. Bloch, Chair James H. Carpenter Atomic Safety and Licensing Board 933 Green Point Drive U.S. Nuclear Regulatory Commission Oyster Point Washington, D.C. 20555 Sunset Beach, NC 28468 Administrative Judge Charles A. Barth, Esq.

Thomas D. Murphy Office of General Counsel Atomic Safety and Licensing Board U.S. N.R.C U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 John Lamberski, Esq. Ernest L. Blake, Jr.

Troutman Sanders David R. Lewis Suite 5200 SHAW, PITTMAN, POTTS &

600 Peachtree Street, N.E. TROWBRIDGE Atlanta, GA 30308-2216 2300 N Street, N.W.

Washington, D.C. 20037 Office 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.lis 2

_ _ _ .______ ___ __.