ML20080N840

Intervenor Document Request to NRC Staff.* Intervenor Requests That Response Be Submitted within 10 Days as Law Requires.W/Certificate of Svc & Svc List

ML20080N840
Person / Time
Site:	Vogtle
Issue date:	02/28/1995
From:	Wilmouth M AFFILIATION NOT ASSIGNED, KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20080N814	List: ML20080N812 ML20080N840
References
CON-#195-16420 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9503070112
Download: ML20080N840 (11)

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DOCKETED USHRC q February 28, 1995 j l

% WJ? -2 P12 :07 UNITED STATES OF AMERICA I" NUCLEAR REGULATORY COMMISSION - , -

ATOMIC SAFETY AND LICENSING BOARD '[ .

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 al , )

) 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 DOCUMENT REOUEST TO NRC Staff I. INTRODUCTION Pursuant to 10. C.F.R. S2.740b and 5 U.S.C. S552 (Freedom of Information Act), Allen Mosbaugh, Intervenor in the above entitled proceeding, hereby requests that the NRC Staff respond to the following document request by identifying all documents requested herein and by producing all documents requested herein that have not previously been produced. Intervenor request that this request be responded to within ten (10) days as the law requires.

II. INSTRUCTIONS 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:

9503070112 950228 PDR ADOCK 05000424 Q PDR , . .

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1. . Identify the-such information which you' claim is  ;

privileged in the response ~;

2. If'the information is a document or oral ,

communication, identify the document's title or the oral .{

communication.and state the general subject matter of the '

document or oral communication; -

3. If the information is a document or oral communication, state.the date of the document or oral i 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; .j

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 j

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 j

.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

-t approved it; ,

3. The identity of the person who signed it, or over whose name under which it was issued; 2

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4. The identity of the addressee or. addressees;

5. The natureLand substance of the document with '

sufficient particularity to enable the same to be identified;  !

6. The date of the document; and 3

7. The present location of the document and the ,

identity and address of each person who has custody of the 1

document. '

III. DEFINITIONS i

A. The' term "NRC" shall mean every past or present employee of the Nuclear Regulatory Commission, any investigative body, office or subdivision of the Nuclear Regulatory Commission, every past or present Commissioner of the. Nuclear Regulatory Commission.

B. As used-herein, the term " documents" includes any written, recorded or graphic matter, however produced or j 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, appointment book, phone logs, 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, >

transcript, minutes, depositions and all other memorials of any ,

conversations, meetings, and conferences by telephone or i I

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, .otherwise,' including personalinotes,_'and any other writing or recording which'is in the possessioni custody or control of the.

Licensee or any employees, representatives, attorneys, q investigators, or-others acting on his behalf,' including-those ,

-directly involved in the responses to-the Demand for information. ,

C. As.used-herein, the terms "and" and "or" shall each mean 9 and/or.

D.

As used herein, the terms " Licensee", " Georgia Power Company", "The Southern Company", "SONOPCO" (or " Southern Nuclear"), and any other_ derivative therefrom are intended to, ,

4 h and shall, embrace and include any agent or employee of Georgia Power Company, The Southern Company, and/or SONOPCO (or Southern ~  !

Nuclear) , 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 l or may have obtained information for or on behalf of Georgia. f Power Company, The Southern Company, and/or SONOPCO (or' Southern l Nuclear).

E. As used herein, the term "NOV" shall mean the Notice of ,

Violation issued on May 9, 1994; the' Demand for Information issued to the following individuals: C.K.'McCoy, George L Bockhold, Jr., Thomas V. Greene, Georgie R. Frederick, Harry  ;

4 Majors, and Michael W. Horton on May 9, 1994; Georgia Power's i

July 31, 1994 Response to the NOV; Georgia Power's Supplemental Response to the NOV, dated February 1, 1995; the responses of each individual listed above in this paragraph to the individual 4

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Demands for information; the Supplemental Response of George Bockhold, Jr., date February 1, 1995; the NRC's Modified Notice of Violation issued February 13, 1995; and the NRC's Responses to demand for information for each of the individuals listed above in this paragraph.

F. As used herein, the term " selected individual" shall mean the following individuals to whom a Demand for Information was issued: C.K. McCoy, George Bockhold, Jr., Thomas V. Greene, Georgie R. Frederick, Harry Majors, and Michael W. Horton.

G. As used herein, the term " recorded" shall mean any process by which a record is made of a meeting, event, conversation or correspondence, including but not limited to audio tape, minutes, court reporter notes, video tape, phone logs, hand written notes and any transcriptions thereof.

IV. DOCUMENT REOUEST

1. Identify and produce any documents used in response to or generated as a result of the Response to Demand for Information Regarding Thomas V. Greene, dattd August 9, 1994.

2. Identify and produce any documents used in response to I or generated as a result of the Response to Demand for Information Regarding Georgie R. Frederick, dated July 28, 1994.

3. Identify and produce any documents used in response to or generated as a result of the Response to Demand for Information Regarding Harry Majors, dated August 5, 1994.

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-4.- Identify and produce any documents used in response to .l or. generated as a. result of the-Response to Demand _for Information Regarding Michael W. Horton, dated July. 29,.1994.

=5. Identify and produce any documents used in response to

. j or generated'as a result of the Response to Demand for.

f Information Regarding.C. K. McCoy, dated August 5, 1994.  !

6. Identify and produce any documents.used in response to or generated as a result of the Response to Demand for  !

Information Regarding George Bockhold, Jr., dated August 5, 1994. .

7. Identify and produce all documents used in the creation -

I of the Notice of Violation issued May 9, 1994 and the Modified l Notice of Violation issued February 13, 1995.  :

8. Identify and produce all documents used in the creation l of the letter to C. K. McCoy, issued February 13, 1995 regarding his response to the NRC Demand for Information Regarding C.  !

Kenneth McCoy, dated August 1, 1994. ,

9. Identify and produce all documents used in.the creation i of the letter to George Bockhold, Jr., issued February'13, 1995  ;

regarding his response to the NRC Demand for Information ]

Regarding George Bockhold, Jr., dated July 31, 1994. .[

10. Identify and produce all documents used in the creation  !

of the letters, issued February 13, 1995, to Thomas V. Greene, l Georgie R. Frederick, Harry Majors and Michael W. Horton, j i

regarding their individual responses to the NRC's Demand for Information Regarding Thomas V. Greene, Georgie R. Frederick, ,

Harry Majors, and Michael W. Horton. l t

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11. Identify and produce any documents used in response to or generated as a result of the NRC's Modified Notice of

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Violation and Proposed Imposition of Civil Penalties, dated February 13, 1995, by NRC personnel.

12. Identify and produce all correspondence between Georgia Power and the NRC directly or indirectly related to the NOV.

13. Identify and produce all correspondence between the selected individuals and/or their individual counsel and the NRC directly or indirectly related to the NOV.

14. Identify and produce all documents created by non Georgia Power employees directly or indirectly related to the NOV.

15. Identify and produce all documents directly or indirectly related to the any settlement and settlement negotiations between Georgia Power, its counsel and the NRC regarding the NOV.

16. Identify and produce all documents directly and indirectly related to the any settlement and settlement negotiations between the selected individuals, their individual

. counsel and the NRC regarding the NOV.

17. Identify and produce all hand written notes directly or indirectly related to the NOV and Demands for information.

18. Identify any discussions or meetings between Georgia Power, its counsel and the NRC, directly or indirectly related to the NOV that were recorded, )

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19. Identify any discussions or meetings, between the selected individuals and the NRC, directly or indirectly related to the NOV that were recorded.

20. Identify the manner in which the discussions or meetings identified in numbers 18 and 19 above were recorded and the person (s) or company who recorded them.

21. Identify and produce the recordings and/or transcripts of the discussions or meetings identified in numbers 18 and 19 above.

22. Identify and produce any notes, minutes, and/or phone logs of the discussions or meetings identified in numbers 18 and 19 above.

23. Identify and produce any depositions relied upon, reviewed by or in the possession of any NRC employee at any time, who had any input in creating the NOV, (see definition E above).

24. Identify and produce any depositions relied upon, ,

reviewed by or in the possession of any NRC employee at any time, who nad any input in creating the individual Demands for Information, (see definition E above).

25. Identify and produce all documents directly or indirectly related to the NOV.

26 The documents that are to be identified and produced in items 1-25 above, should include but are not limited to all documents used or created in response to or as a result of items j

1-25 above by the following individuals:

a. James Lieberman

b. Stewart Ebneter 8

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c. Darl Hood

d. B. R. Bonser

e. James L. Milhoan

f. Larry Robinson

g. Office of Investigations ,

h. any other individual who was directly or indirectly involved with the above items.

27. Identify and produce all documents created since responded to the previous request for documents by.Intervenor.

28. Identify and produce all documents that may be responsive to any of the request set out in Intervenor's Document Request to Georgia Power Company, Intervenor's Document Request to C.K. McCoy, Intervenor's Document Request to George Bockhold, Jr., Intervenor's Document Request to Thomas V. Greene, Intervenor's Document Request to Georgie R. Frederick, Intervenor's Document Request to Harry Maj ors, and Intervenor's Document Request to Michael W. Horton, all dated February 28, 1995.

R ectfully submitted,,

M Stephen Yfa

. Kohn KOHN, KOHN & COLAPINTO, P.C.

517 Florida Ave., N.W.

Washington, D.C. 20001-1850 (202)234-4663 Attorneys for Intervenor DATED: February 28, 1995 C:\ FILES \301\ DOC 2.NRC 9

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, y DOCKETED a j

FebruarYdif$C 1995 t

UNITED STATES'OF AMERICA '!

NUCLEAR REGULATORY COMMISSION w mR -2 Pi2:07 i ATOMIC SAFETY AND LICENSING. BOARD j

) OFFICE OF SECRE mRY . ~

DOCKETING 1 EERVICE  :

In the Matter of ) up /gH  !

) Docket Nos. 50-424-DLA-3 ti GEORGIA POWER COMPANY. ) 50-425-OLA-3' i

'st AL., ) l

) 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 .j I hereby certify that the following documents. entitled' l l

Intervenor's' Document Request to NRC. Staff, Intervenor's. Document l l

Request to Georgia Power Company, Intervenor's Document Request {

to C.K. McCoy, Intervenor's Document Request to George Bockhold, Jr., Intervenor's Document Request to Thomas V. Greene, l

Intervenor's Document ~ Request to Georgie R. Frederick,  !

Intervenor's Document Request to Harry Majors, and Intervenor's j i

Document Request to Michael W. Horton have been served this  !

February 28, 1995, by first class mail on the persons listed in l the attached service list.

t Yibd1mMn6/AAs l Mdrp Ja Wilmoth ~/ ';

KOHN, & COLAPINTO, P.C. i 517 F1 rida Ave., N.W.  !

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

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

i

) i In the Matter of )-  ;

)- Docket Nos.'50-424-OLA-3~ -i

. GEORGIA POWER COMPANY ) 50-425-OLA .!

31 ' AL,', ) .

) Re: License Amendment .

(Vogtle Electric. Generating ) (transfer to Southern Nuclear)  !

Plant, Unit 1 and Unit 2) ). -

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

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 l l

Administrative Judge Charles A. Barth, Esq.

Thomas D. Murphy Office of General Counsel 1 Atomic Safety and Licensing Board U.S. N.R~.C t U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i Washington, D.C. 20555 ,

John Lamberski, Esq. Ernest'L. Blake, Jr.

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

, 600 Peachtree Street, N.E. TROWBRIDGE I 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 i Washington, D.C. 20555 .

Office of Commission Appellate Adjudication U.S. Nuclear Regulatory Commission Washington, D.C. 20555  !

c h C2\ FILES \301\ CERT.LIS I

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