ML20078P578

Intervenor Proposed 941214 Agenda.* Requests That Listed Matters Be Discussed at Upcoming Status Meeting. W/Certificate of Svc & Svc List

ML20078P578
Person / Time
Site:	Vogtle
Issue date:	12/12/1994
From:	Wilmoth M AFFILIATION NOT ASSIGNED, KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA
To:
References
CON-#494-16089 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9412190070
Download: ML20078P578 (5)

Text

'

/9 29 Dc 2, 1994 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 9A DEC 13 P4 :C ATOMIC SAFETY AND LICENSING BOAE Before Administrative Judgesg FM (1~ . N Il ~; '

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

)

In the Matter of )

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

.CL 13L., )

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

Plant, Unit 1 and Unit 2) )

) ASLBP No. 93-671-01-OLA-3 INTERVENOR'S PROPOSED DECEMBER 14, 1994 AGENDA Intervenor requests that the following matters be discussed at the upcoming December 14, 1994 status conference:

1. Licensee's December 6, 1994 production of documents.

2. Subpoenas of witnesses and documents.

3. Schedule for Phase II of proceeding.

Intervenor believes that it would be more productive to finalize the schedule for the diesel generator " Phase II" portion of the proceeding after the conclusion of the license transfer

" Phase I" hearing. Nonetheless, Intervenor's proposed schedule for Phase II of the proceeding concerning diesel generator issues is set out below. It is significant to note that neither the schedule for Phase I nor the schedule for Phase II allots time for the filing of post-hearing findings of fact. Such findings of fact would assist the Board in making its final determination and Intervenor believes that such time should be allotted.

jjj219007o941212 -

g ADOCK 05000424 enn 3? 503

SCHEDULE FOR PHASE II January 18 -

February 1 Depositions of NRC personnel.

February 3 Prehearing Conference.

February 6-10 The parties convene in Washington, D.C. for the following:

a) identification of any and all tapes that have not been transcribed by any party, and with respect thereto, develop a method to proceed on tapes for which no transcription exists; b) each party shall identify existing transcripts (or portions of a transcript) which that party believes it may use during the hearing process; c) each party shall, to the fullest extent possible, attempt to resolve the accuracy of any transcript identified in (b) above (this process would include the playing of controverted tape segments with the expectation that each party will have a representative available to resolve disputes, as necessary). For any transcript segment for which an agreement cannot be reached, each party will submit by February 6, 1994, a written alternative to the content of the contested portion of the transcript. The parties will attempt to continue to resolve differences in transcriptions, as outlined in the february 20-24 paragraphs below.2 February 20 Parties exchange all written alternatives and otherwise corrected or commented on versions of all tape transcripts that each party had identified as potentially relevant in the february 6-10 conference.

2 This process will only include tapes which are relevant to the proceeding. The attorney requesting this process for a tape must certify that it is relevant to that attorney's case pursuant to a prior order by the Board.

2

a. .

February 20-24 Parties attend conference in Washington, D.C.

to reach stipulations as to the content of a tape transcript and designate any contested portions of a tape. The parties shall:

a) Identify all portions of transcripts for which all three parties are in agreement as to their contents; b) Attempt to reach an agreement as to the contents of tapes for which a

. disagreement exists; c) Specifically identify those portions of transcripts for which no agreement can be reached.

March 1 Parties are to jointly submit stipulated tape transcripts. With respect to any disagreement concerning transcript language, each party will submit their proposed version of a disputed section. All proposed versions will be included in the transcript.

March 8 Intervenor's identification of issues for hearing.

March 15 Prefiled testimony.

April 3 Prefiled findings.

April 7 Prehearing conference.

April 17 Hearing on diesel generator issues commences.

Respectfully submitted, feb8M lA fe b Mibhag D. Kohn '

Mary /4ane Wilmoth KOHN, KOHN, AND COLAPINTO, P.C.

517 Florida Ave., N.W.

Washington, D.C. 20001 (202) 234-4663 Attorneys for Intervenor C: \F IL E S\301\ AGENDA.2 3

I Decembe 4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD 94 der.13 P4 'f7

) 0FFICE [o sicREiARY In the Matter of ) 00CKE IING ' U"l((

) Docket Nos. 50-424 -OBA13 LH GEORGIA POWER COMPANY ) 50-425-OLA-3 91 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 PROPOSED DECEMBER 14, 1994 AGENDA has been served via facsimile, this December 12, 1994, upon the persons listed in the attached Service List, with the exception it was served by first-class mail as indicated by "*".

By: hMs k/l d Y (1 Ma'ry 'JdQ Wilmoth KOHN, KOHN & COLAPINTO, P.C.

517 Florida Ave., N.W.

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

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 at AL., )

) 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 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 ti . 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 (also served by fax)

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 C:\ FILES \301\ CERT.Ll$

- .