Intervenor Exhibit I-143,consisting of Respondent Response to Complainant Request for Interrogatories & Production of DocumentsML20078G528 |
Person / Time |
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Site: |
Vogtle  |
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Issue date: |
01/11/1995 |
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From: |
Wilson C GEORGIA POWER CO. |
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To: |
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References |
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OLA-3-I-143, NUDOCS 9502030152 |
Download: ML20078G528 (9) |
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Category:EXHIBITS (DOCKETING AND SERVICES BRANCH INFORMATION
MONTHYEARML20100B7601995-10-11011 October 1995 Intervenor Exhibit I-MOSBA-39A,consisting of Case Number 2-90-020R Re List of Exhibits ML20100B7631995-10-11011 October 1995 Intervenor Exhibit I-MOSBA-97,consisting of Case Number 90-ERA58 Transcript Re Deposition of K Mccoy ML20100B7641995-10-11011 October 1995 Intervenor Exhibit I-MOSBA-111,consisting of Procedure Number 00057-C Re 900711 Event Rept Entitled, DG 2A Start Failure ML20100B7651995-10-11011 October 1995 Intervenor Exhibit I-MOSBA-272,consisting of File Number 90-ERA-30 Transcript Re Deposition of LB Glenn ML20099L3881995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-23A,consisting of Transcipt Re Intervenor Exhibit 23A Tape 29 Side B, ML20099L3711995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-8A,consisting of Transcript Re Joint Exhibit 8A Tape 8 Side B, ML20099L3831995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-21A,consisting of Transcript Re Intervenor Exhibit 21 Tape 32-1,dtd 900404,TR 41-44 ML20099L4041995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-153,consisting of Cover Sheet & Page from CRC Handbook of Chemistry & Physics ML20100B6781995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-222,consisting of Cooper Outage Logbook ML20099L4311995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-216,consisting of 900511 Interoffice Memo Re Enterprise Engine S/N 76021 Loss of Offsite Power on 900320 ML20100B6821995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-225,consisting of Correspondence Re Jul 1990 Starting Air Valve Problem ML20099L4291995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-215,consisting of History Re Alnor Dewpointer Model 7200U Serial 24355 Calibr ML20099L4331995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-217,consisting of Handwritten Statement Re Events of 1A DG Loss of Offsite Power ML20099L4081995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-170A,consisting of Transcript Re Intervenor Exhibit II-170A Tape 207,dtd 900717 ML20099L4001995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-94B,consisting of Transcript Re Intervenor Exhibit 94B Tape 32,dtd 900404,TR 46-49 ML20099L3971995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-94A,consisting of Transcript Re Intervenor Exhibit 94A Tape 32,dtd 900404,TR 46-49 ML20100B6801995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-223,consisting of RA Johnston Personal Outage Notes ML20100B6831995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-227,consisting of Correspondence Re Pneumatic Control Component Testing ML20099L3801995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-9A,consisting of Transcript Re Intervenor Exhibit 9 Tape 10,dtd 900323,TR 22-23 ML20099L3891995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-51A,consisting of Transcript Re Joint Exhibit 51 Tape 7,dtd 900322,TR 20-21 ML20099L3691995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-4A,consisting of Transcript Re Intervenor Exhibit 4 Tape 99,dtd 900508,TR 43-53 ML20100B7001995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-237A,consisting of Tape 218 Re 900725 Conversation Between Mosbaugh & Horton ML20099L4031995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-118A,consisting of Transcript Re Intervenor Exhibit 118A Tape 24A,dtd 900330 ML20100B6901995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-232A,consisting of Tape 3,side a of 900223 Conversation Between Bockhold & Mosbaugh ML20099L3041995-10-0606 October 1995 Applicant Exhibit A-181A,consisting of 900404 Tape 34, Beginning of Side B ML20099L4131995-10-0606 October 1995 Intervenor Exhibit I-MOSBA-196,consisting of Nuclear Plant Maint Work Order Re DG 1A That Tripped Twice Following Two Actual Loss of Offsite Start Conditions ML20099L3821995-09-28028 September 1995 Intervenor Exhibit I-MOSBA-19A,consisting of Transcript Re Intervenor Exhibit 19 Tape 25,dtd 900330,TR 2 ML20099L3861995-09-28028 September 1995 Intervenor Exhibit I-MOSBA-22B-1,consisting of Transcript Re Intervenor Exhibit 22B Tape 89 Side A,50%,dtd 900502 ML20099L2111995-09-28028 September 1995 Applicant Exhibit A-120A,consisting of Transcript of Audiotape 72 ML20099L2121995-09-28028 September 1995 Applicant Exhibit A-133A,consisting of Transcript of Audiotape 69 ML20099L3581995-09-27027 September 1995 Applicant Exhibit A-202,consisting of Re Licensee Suppl Reply to NOV & Proposed Imposition of Civil Penalties ML20099L3601995-09-27027 September 1995 Applicant Exhibit A-203,consisting of Licensee on NRC Demand for Info Re G Bockhold ML20100B7541995-09-26026 September 1995 Intervenor Exhibit I-MOSBA-270,consisting of M&TE Traveler Re Alnor Derpointer W/Last Calibr Date of 890907 & Next Calibr Date of 900307,extended to 900407 ML20099L4111995-09-26026 September 1995 Intervenor Exhibit I-MOSBA-183A,consisting of Transcript Re Intervenor Exhibit II-183A (Joint Version) Tape 99 Side a, ML20099L4021995-09-22022 September 1995 Intervenor Exhibit I-MOSBA-95,consisting of 900823 Interoffice Correspondence Re NRC Areas of Concern, Log:SRBS-00044 Security Code:Nc ML20100B6991995-09-22022 September 1995 Intervenor Exhibit I-MOSBA-237,consisting of Tape 218,side B at 70% Re 900725 Conversation Between M Horton & Mosbaugh ML20099L1411995-09-22022 September 1995 Board Exhibit Bd-10,consisting of Drawing W/Related Info ML20099L4051995-09-21021 September 1995 Intervenor Exhibit I-MOSBA-169,consisting of Demonstrative Aid 4 (Rev 950713) Re Dew Point Data,Diesel Air Sys ML20100B6971995-09-21021 September 1995 Intervenor Exhibit I-MOSBA-235 Sup,Consisting of Transcript of Pages 83 & 84 Re OI Investigation ML20100B7501995-09-21021 September 1995 Intervenor Exhibit I-MOSBA-266,consisting of Final Rept, Enhancement on On-Site Emergency DG Reliability ML20100B6921995-09-21021 September 1995 Intervenor Exhibit I-MOSBA-233 Sup,Consisting of Transcript Re Page 689 ML20099L3541995-09-21021 September 1995 Applicant Exhibit A-199,consisting of Affidavit of Ja Bailey Re Vogtle Project ML20100B7431995-09-19019 September 1995 Intervenor Exhibit I-MOSBA-262,consisting of Amount of Water in Humid Air at Any Pressure ML20100B7411995-09-19019 September 1995 Intervenor Exhibit I-MOSBA-260,consisting of to NRC Document Control Desk Re Plant Special Rept Invalid DG Failure ML20100B7421995-09-19019 September 1995 Intervenor Exhibit I-MOSBA-261,consisting of Estimate of DG Daily Air Leakage ML20099L3461995-09-19019 September 1995 Applicant Exhibit A-195,consisting of Professional Resume Re Ht Hill ML20099L3481995-09-19019 September 1995 Applicant Exhibit A-196,consisting of Paper Re Vogtle Experience W/Calcon Sensors in DG Trip Circuits ML20099L3511995-09-19019 September 1995 Applicant Exhibit A-198,consisting of Rept Re Plant DGs Airstart Cap Evaluation,Log 95-MT 039 ML20100B7471995-09-19019 September 1995 Intervenor Exhibit I-MOSBA-264,consisting of Water Formation in Control Air Supply Typical Conditions (Early Apr 1990) ML20100B7461995-09-19019 September 1995 Intervenor Exhibit I-MOSBA-263,consisting of Amount of Water in Humid Air at 240 PSIG (17.3 Atm) 1995-09-28
[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 ML20216B0731998-03-0505 March 1998 Exemption from Certain Requirements of 10CFR50.71(e)(4) Re Submittal of Revs to FSAR for Facility Changes Made Under 10CFR50.59 for Vogtle Electric Generating Plant,Units 1 & 2 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 Directors Decision Under 10CFR2.206 of Mb Hobby & AL Mosbaugh, ML20137C4261997-03-18018 March 1997 Directors 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 ML20137B3111997-03-17017 March 1997 Order Approving Southern Nuclear Operating Co,Inc.,As Exclusive Operator Vogtle Licenses 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 ML20129H7371996-05-0707 May 1996 Transcript of 920507 Interview of Jd Davis in Waynesboro, Ga.Pp 1-44 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 1999-06-28
[Table view] |
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RESPONDENT'S RESPONSE TO COMPLAI6dT'S REQUEST FOR INTERROGATORIES AND PRODUCTION OF DOCTIMENTS
)
Comes now Respondent Georgia Power Company and, pursuant to 29 C.F.R.
5518.18, 18.19 ano 18.20 and Rules 26, 33 and 34 of the Federal Rules of Civil Procedure, hereby responds to Complainant's Request for Interrogatories and Production of Documents as follows:
GENERAL OBJECTIONS Respondent objects to the interrogatories and request for production of documents to the extent that they seek documents protected by the attorney / client privilege; documents prepared in anticipation of litigation or within the protection of Rule 26(b)
(3) of the Federal Rules of Civil Procedure; documents protected by the work-product privilege or any other privilege; or documents containing proprietary or confidential information.
Respondent furth r objects to the requirement of several requests that information or documents be provided which relate
" indirectly" to the subject specified.
Such a requirement is so 9502030152 950111 Exhibit g L/3,page / _ oj PDR ADOCK 05000424 Q
PDR
2.
overbroad and ambiguous as to be meaningless in the context of these discovery requests.
SEECIFIC RESPONSES TO INTERROGATORIES Interroaatory No. las For the Respondents state whether there is a personnel manual procedure guide, or any other work-rule docu-ment setting forth personnel policy, organizational information, work rules, attendance rules, etc. which cover the areas or departments in which Complainant was employed while working for Respondents.
Responsg:
Georgia Power Company does have a Corporate Guidelines Manual setting forth general parsonnel policies and other related information.
Other than the general Corporate Guidelines Manual there are no specific departmental rules or guidelines responsive to this request.
Interrocatorv No. Ib:
If so, produce each such document:
1
Response
The document referred to above will be produced.
Interrocatorv No. 2:
Identify all persons who participated in i
the decision to terminate, lay off and/or discipline Complainant i
by stating:
a.
His or her name; b.
Job title; 0 Exhibit M,page ofJ__
~
c.
.. Length of experience with the enmpany; d..
The action (s) each took which led to any decision concerning Complainant.
Response
I i
Respondent objects to Interrogatory No. 2 because it
'mischaracterizes Respondent's actions in relation to Complainant.
j
~
Georgia Power Company did not te'minate, lay off or discipline r
i Complainant.
As part of the Company's reorganization in recognition of'SONOPCO's failure to become a separate and distinct corporation, Complainant's position was identified as-being unnecessary and was eliminated.
The following people participated or were peripherally involved in the decision to eliminate Complainant's position:
- MI. Fred Williams, Vice President, Bulk Power Markets for past 5 years, 20 years of service with GPC.
i
- K.E. Adams, Sr. Vice President - Fossil & Hydro Power for past year, 27 years of service'with GPC.
t
- H.G.
Baker, Jr., Sr Exec. Vice President for past 6 years, 39 years cf service with GPC.
i
- T.G.
Boren, Sr. Vice President - Administrative Services for past year, 21 years of service with GPC.
- W.T. Dahlke, Sr. Vice President - Marketing for past year, 24 years of service with GPC.
- D.H.
Evans, Exec. Vice President for past year, 19 years df service with GPC.
- J.C. Hemby, Jr., Exec. Vice President for past year, 39 years of service with GPC.
- G.R. Hodges, Sr. Vice President - Division Operations for past throa years, 26 years of service with GPC.
- W.Y.
Jobe, Executive Vice President'and Chief Financial l
Officer for past six years, 19 years of service with GPC.
. L Exhibitb,Pa9e-S-Of_T__
i i
s A
- A.W.
Dahlberg, President and Chief Executive Officer for past two years, 29 years of service with GPC.
Thb recommendation to reorganize and eliminate Complainant's position was that of Mr. Williams.
This recoramendation was developed after a careful review of the interface needs of the Company and the SONOPCO Project (hereinafter sometimes
" Project").
The review took the form of discussions between Mr.
Williams and representatives from around the Company and the SONOPCO Project and included discussions with Complainant and his staff.
The discussions were informal in nature and, in the majority of instances, no reference was cade that the results_of the conversation would be used in making the organizational decision.- The discussions were designed to provide input to Mr.
Williams in order that he could assess the Company's needs for interface with the SONOPCO Project.
After conducting his review, Mr. Williams determined that the Nuclear Operations Contract Acministration Group should be reorganized to reflect the fact that SOFOPCO, as a stand-alone entity, had not materialized and there was no contract to administer.
In addition, the performance of the Project group was such that Project members were able to provide more of the relevant data to meet Company needs than had originally been envisioned.
Further, as other groups were reorganized within the Company (System Planning, Engineering, etc.) it became appcrent that the primary benefits of centralization could not be realized if a separate group was going to exist to provide information and )
V f
Exhibit
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perform functions that could be performed by the Project.
It j
also became apparent that a level 20 position, one of the highest non-officer positions in the Company, was no longer needed for the remaining tasks to be performed.
Finally, it was acknowledged that the Bulk Power Markets Organization, already l
responsible for administering Participant Contracts, Interchange Contracts and various tariffs, had contacts and communication channels established and that the contract under negotiation would be similar in nature from an administrative perspective.
[
As a result of the foregoing observations, Mr. Williams' r.ecommendation to eliminate the General Manager position was presented to Mr. Evans and Mr. Boren and then to the' Management Council.
{
Interrocatory No. 3:
State whether Respondents received any written or oral requests from the complainant concerning his i
safety and/or quality control / quality assurance allegations or complaints.
[For purposes of these interrogatory questions, "quslity control / quality assurani:e" include the concerns raised by Mr. Hobby in his April 27, 1990 confidential memorandum to F.
W. Williams.)
If so, identify each complaint by stating:
a.
Its date; b.
Its contents c.
Its disposit. ion.
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Interroaatory No. 26:
Are any of the allegations or concerns raised in the April 27, 1990 Confidential Memorandum to F. W.
Williams from M. Hobby incorrect or not completely correct?
For each such allegation or concern which Respondent does not concede is correct, please:
a.
Identify the concern / allegation; b.
State in full, exactly why the concern / allegation is not correct; c.
Produce all focuments which support your position as to i
why tire ~ allogat. ion /cgnaern.is gt cc.sple'.ely correct.
Response
Respondent objects to this interrogatory on the grounds that it is overbroad and seeks information irrelevant to the subject matter of this action, in that the April 27th memo addresses matters which are not even alleged to be protected activity by the Complainant himself.
Upon confirmation by Complainant or his counsel as to which statemene. contained in the April 27th memo allegedly constitute protected activity,- Respondent will endeavor to note whether such statements are incorrect or incomplete.
Interrocatorv No.27:
Separately for each response given to every one of the Interrogatories, identify the person other than counsel, responsible for providing the information or, or formulating such response and identify each document relied on in formulating each response. Exhibit MO, page b of1 a
T'k Responses Respondent objects to this Interrogatory on the grounds that it would be overly burdensome and oppressive to provide the information requested, and on the further grounds that disclosure i
of the requested information would reveal the mental impressions, conclusions, and legal theories of Respondent and its counsel.
.~
Subject to and without waiving these or any other objections, Respondent states that all of the persons identified in response to Interrogatory No. 2 provided information used in responding to Eh'ese interrogatories, and all non-privQ.eged documents relied upon in answering these interrogatories either have been or will be produced.
In addition to the persons listed in the response to Interrogatory No.
2, the following people assisted counsel in preparing answers to these interrogatories:
(1)
Clifton Douglas Wilson - Assistant to the Executive Vice President of Finance; (2)
Leonard Owens -
Supervisor, Pensions; (3)
Joseph M. Farley - Executive Vice President - Nuclear, Southern Company; (4)
R.P. Mcdonald - Executive Vice President Nuclear, Georgia Power Co. and Executive Vice President Nuclear, Alabama Power; and (5)
Robert Hughes - Manager, Regulatory Affairs
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. xhibitl%C3,page of ~.-
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that it requests information which is neither relevant to this litigation nor likely to lead to the discovery of admissible evidence.
Without waiving this objection, but subject thereto Respondent will produce all documents responsive to this request that are related to the subject matter of this action.
1 Beauest No. 9:
Copies of 1989 calendar, appointment books or schedules of:
a.
A. W.
Dahlberg; i
b.
J. M. Farley; c.
R.
D. Mcdonald; d.
E.
L. Addison; e.
H. A.
Franklin; f.
J. A. Melers; g.
F.
W.
Williams Resoonse:
Respondent objects to Request No. 9 on the basis that it is overbroad, burdensome and harassive and on the additional ground that it requests information which is neither relevant to this litigation nor likely to lead to the discovery of admissible evidence.
Without waiving this objection, but subject thereto, Respondent will produce all calendar information for the above listed persons which evidences or relates to meetings involving i
or concerning Complainant.
Reauest No. 10:
Approved Job Description for Exhibit
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4 STATE OF GEORGIA COUNTY OF FULTON VERIFICATION IN PERSON, before the undersigned officer, duly authorized tocadminister oaths, appeared Clifton Douglas Wilson, Assistant i
to the Executive Vice President of Finance of RESPONDENT GEORGIA POWER COMPANY, who first being duly sworn, states that to the bestofhisknowledgethestatementssetforthinthe(rithinand foregoing RESPONDENT'S RESPONSE TO COMPLAINANT'S REQUEST FOR INTT:RROGATORIES AND PRODUCTION OF DOCUMENTS are true and correct.
The responses as written are not based solely on the knowledge of the executing party, but include information obtained by and through GEORGIA POWER COMPANY'S agents, representatives, and attorneys.
This /7
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Clifton Douflas Wilson j
me this / 7 g subscribed before Sworn to an day of August, 1990
~ Notary Public Noterr PuWic, Cobb County by Commisskri Espires Mar.% -
21.1993 hNbit
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