ML20073H228

Intervenor Response to Licensee Request for Stipulations Dtd 940228.* Believes That Tape Transcripts Relevant to Proceeding.W/Certificate of Svc.Related Correspondence

ML20073H228
Person / Time
Site:	Vogtle
Issue date:	09/20/1994
From:	Wilmoth M KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA
To:	Atomic Safety and Licensing Board Panel
References
CON-#494-15730 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9410050162
Download: ML20073H228 (8)

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Dated: SeptEbb~hr 20, 1994 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSI'dit W 21 P ' :U) l ATOMIC SAFETY AND LICENSING BOARD

.) i In the Matter of ) >

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) Docket Nos. 50-424-OLA-3 l GEORGIA POWER COMPANY ) 50-425-OLA-3 l 21 al , )  !

) Re: License Amendment '

(Vogtle Electric Generating ) (transfer to Southern Nuclear) l Plant, Unit 1 and Unit 2) )  !

) ASLEP No. 93-671-01-OLA-3 ,

INTERVENOR'S RESPONSE TO LICENSEE'S I REQUEST FOR STIPULATIONS DATED FEBRUARY 28, 1994 l

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I. INTnoDUCTION l At the August 12, 1994 status conference the Licensing Board f i

instructed the parties that when making request for stipulations  ;

i regarding tape transcripts the party's making the request is to l l

certify that the requested tape transcript stipulations are j i

relevant to that party's case. Tr. 597, Tr. 601. Intervenor j requested that Licensee certify that the requested tape transcript stipulations are relevant to the Licensee's case. Sqq  !

letter dated August 15, 1994 from M. Wilmoth to J. Lamberski. i Intervenor never received a response to this request. Therefore, Intervenor objects, on this basis, to responding to the request for st1pulations on the tape transcripts included in Licensee's request which were not exhibits to the OI Report. Intervenor -

takes this pocition because it would be a waste of time and f

resources to stipulate to tape transcripts which the Licensee no  !

i longer believes are relevant to its case and does not plan to t introduce into evidence. l 9410050162 940920 M PDR ADOCK 05000424  !

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Intervenor, however, is willing to respond to the request for stipulations in regard to the portions of the tape transcripts in the requests which were exhibits to the OI Report.

Intervenor believes that the fact these tape transcripts were used in the OI Report makes them relevant to this proceeding.

These requests are the portions of transcripts from Tape Nos. 42, 184, 186, 187, 253, 256, and 267. Intervenor will also respond to the NRC tape recording, IIT #257.

II. TAPE TRANSCRIPT STIPULATIONS Intervenor agrees to stipulate that the above listed tape transcripts portiens are true and accurate with the exception of the following:

Tape 42

p. 1, In 4: The (inaudible) should read dewpoing.

p. 19, in 17: of problem we had.

p. 20, ln 8: The words "that are" should be deleted.

p. 22, ln 24: Not on t that's right the B machine that's right tripped before l

p. 27, in 11: any data then, past the 20th?

p. 28, ln 12-25: Please note that Paul Kochery is the j speaker on these lines.

p. 29, ln 1: The (inaudible) should read statement you know.

p. 29, in 5: And I'll ggi some cop;es.

p. 29, In 16: The (inaudible) should read it went up.

2 The underlino is to indicate words which are to be added to the text of the transcript.

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p. 33, in 23: The (inaudible) should read as it was before correction I hanrd of.

p. 33, in 24. The (inaudible) should read different,

p. 34, 3n 2-3: Between lines 2-3 should be inserted the following--Kochery: Yea, the remaining. Line 3 should read:

ALM: Okay2 all right, maybe I'll get with him.  ;

Tape 184 No corrections. -

Tapo 186 (page 34, line 23 through page 47, line 25)

p. 1, ln 11: He won't sign the LER until we got an audit laying en his desk.

p. 1, ln 13: The Speaker is Odom and it is not a continuation of Fredericks from line 11.

Tape 187 (page 18, line 18 through page 75, line 5)

p. 1, in 12: The (inaudible) should read Georce Fredericks,

p. 1, In 19: The (inaudible) should read any words, i

p. 1, Ins 14, 16, and 18 the Speaker is Tynan. ,

p. 1, in 17: The (inaudible) should read Mr. Hairston writes that last santence.

p. 1, ln 20: The (inaudible) should read Eredericks said.

p. 1, in 22: The (inaudible) should read yeah.

p. 1, In 28: I think it's wrong, but 1 certainly think Mr.

Hairston knows i

p. 6, ln 19: The linaudible) should read Okay, all right.

p. 6, In 31: The (inaudible) should read factored in.

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p. 14, in 8: The Speaker is odom and not Webb.

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p. 14, in 14: The LEF's then changed 1 I haven't heard that.the cover

p. 15, ln 10: That's how we oct to 19 in Atlanta.

p. 16, in 8: The (inaudible) should read cettinc sheets,

p. 17, In 31: The (inaudible) should read our cractices.

p. 22, in 22-26: submittal of the LER. It also . appears that confusion about the specific point at which the test program exiat. And they start that paragraph out by saying no specific cause for the error in the LER 18 starts was 4dentified.

p. 22, ln 31: The (inaudible) should read is consistent.

p. 23, ln 31: The (inaudible) should read thgs.

p. 24, ln 3: How about changina the word to difference, and let me find out. '

p. 24, ln 25: that word, though if you would.

p. 25, in 4: PRB members are getting tired of this p_gyticular LER. We

p. 25, in 30-31: We argued and argued over it until this time o# day on April 19th finally corporate said "We believe what we said on Anril 9 is okay we are coing to cut that in the LEP.a

p. 26, ln 7: Yes, sure. dafinitely, the information was all available, okay.

Tape 253 (page 5, line 3 through page 21, line 21)

Insert 1, In 4: and who acproved them?

Insert 1, ln 11: three of us worked on it at the time. I might have put the Insert 1, ln 12: bullets down and 121 Ken Eurr to make sure 4

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Tape 258 (page 22, line 15 through page 39, line 12) .

p. 1, in 14: The (inaudible) should read draft.

p. 8, in 13: different things going on that I'll work 1g e;xnlain with George.

p. 8, in 38: The second (inaudible) should read had a mistake in it.

Insert 1, ln 14: The (inaudible) should read when we wrote the revision Insert 1, ln 17: The (inaudible) should read He had done his audit. Wa completed the audit.

p. 9, In 10: Which meant we changed the type of starts we were counting (inaudible) successful La valid and

p. 9, In 17: The Speaker is Aufdenkampe. The (inaudible) should read by the name time frame,

p. 9, in 19: The Speaker is Bockhold.

p. 9, ln 26: The (inaudible) should read Tom took.

p. 9, In 27-28: or correct the first LER. One was valid starts (nause) there were eo many revisions on it__.

p. 10, in 11: is that -- what they focused on and come to the

p. 10, in 32: The (inaudible) should read reactionary.

Tape 267 (Side B, page 41, line 9 through page 4 7, line 9)

Intervenor request that page 40 also be attached to put this passage into the proper context.

1 p- 1, in 4 : The (inaudible) should read cet our butts kicked l

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p. 1, In 9: something they know is wrong. If we. we lie to them...

p. 2, In 27: Where it tripped.

p. 2, ln 36: We missed those and that's what cut us down to 11 IIT Tape #257 No corrections.

Respectfully submitted, I ~

b'1 , $')$'h!'$ ',$'ilf j Michaep:0. Kohn '

Mary Ja'ne Wilmoth Kohn, Kohn & Colapinto, P.C.

517 Florida Ave., N.W.

Washington, D.C. 20001 (202) 234-4663 DATED: September 20, 1994 301\tapestip i

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DJ' ,I' Augbst'23, 1994 UNITED STATES OF AMERICA .g' 7p g p; :tj3 NUCLEAR REGULATORY COMMISSION ' --

, ATOMIC SAFETY AND LICENSING BOARD

)

Cr In the Matter of )

DNF

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

) 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 Response to Licensee's Regreat for Stipul;tions Dated February 28, 1994 has been served this 20th day of Septettber 1994, by facsimile persons listed in the attached Service List, with the exception that it was served by first class mail as indicated by "*"

By: I hA.h $1\b !I)k 7/ - ,

Mary Janer/Wilmoth l KOHN, 1/OHN & COLAPINTO, P.C.

l 517 F16rida Ave., N.W.

Washington, D.C. 20001 (202) 234-4663 1 l 1

.s-sa,. --'  !

o UNITED STATES OF AMERICA NUCLEAR REGU!ATORY COMMISSICN ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

) Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY ) 50-425-OLA-3 gr - 1 , 1

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

Plant, Unit 1 and Unit 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 913 Green Point Drive U.S. Nuclear Regulatory Commission Oyster Point Washington, D.C. 20555 Sunset Beach, NC 28468 l

l Admtnistrative 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 i Cffice of the Secretary l Attn: Docketing and Service l U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Of fice of Commission Ap-f ellate Adjudication U.S. Nuclear Regulatory Commission Washington, D.C. 205S5 301\ cert.lis 2

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