ML20080N844

Intervenor Document Request to Ga Power Company.* Requests for Personal Documents Not Previously Produced in Case. W/Certificatte of Svc.Related Correspondence

ML20080N844
Person / Time
Site:	Vogtle
Issue date:	02/28/1995
From:	Wilmouth M AFFILIATION NOT ASSIGNED, KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA
To:	GEORGIA POWER CO.
Shared Package
ML20080N805	List: ML20080N801 ML20080N844 ML20080N877 ML20080N890 ML20080N897 ML20080N908 ML20080N931 ML20080N945
References
93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9503070113
Download: ML20080N844 (12)

Text

. . . . . .

t c .

t RELATED CORRESPONDENCE DOCKEIED USHRC February.28, 1995  ;

UNITED STATES OF AMERICA '95 MM -2 P12 :04 .

NUCLEAR REGULATORY COMMISSION  ;

ATOMIC SAFETY AND LICENSING BOARD  ;

0FFICE OF SECRETARY Before Administrative Judges: 00CXtitNG & CETW!CE i Peter B. Bloch, Chair BRANCH f Dr. James H. Carpenter  !

Thomas D. Murphy [

)

In the Matter of ) j

) Docket Nos. 50-424-OLA-2 i 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 ,

INTERVENOR'S DOCUMENT REOUEST TO GEORGIA POWER COMPANY i l

I. INTRODUCTION i Pursuant to 10. C.F.R. 52.740b, Allen Mosbaugh, Intervenor I in the above entitled proceeding, hereby requests that Georgia l Power Company (hereinafter referred to as "GPC") respond to the i

following document request by identifying all documents requested l i

herein and by producing all documents requested herein that have not previously been produced. Intervenor requests a response within ten (10) days or at another mutually agreeable time.  !

II. INSTRUCTIONS j A. If you claim that any information which is required to be provided by you in your response to this document request is. f

'l privileged or immune from discovery:  ;

1. Identify the such information which you claim is l f

privileged in the response;

?

9503070113 950228 ADOCK O 44 p)

{DR

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' l document or oral communication; I

3. If the information is a document or oral ,

communication, state the date of the document or oral  ;

communication.

4. If a document, identify its author (s) and the  !

6 person (s) for whom it-was prepared and/or to whom it was  !

sent, including all persons who received copies; ,

5. If an oral communication, identify all persons- i 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 i'

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  :

1 document:

1. The identify of the person who prepared it;

2. The idencity 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; 2

i

5. The nature and substance of the document with sufficient particularity to enable the same to be t

identified;

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 (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 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, appointment book, phone logs, pamphlet, periodical, work sheet, 3

h i!

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  ;

otherwise, including personal notes, and any other writing or recording which is in the possession, custody or. control of the Licensee or any employees, representatives, attorneys, investigators, or others acting on his behalf, including those i

directly involved in the responses to the Demand for information.

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

D. As used herein, the term "NRC" shall mean the U.S.

Nuclear Regulatory Commission, an agency of the Federal l Government, and any and all offices within the Nuclear Regulatory .

Commission, including NRC Staff, NRC Office of Investigations, and all their respective attorneys, agents, servants, associates, employees, representatives, investigators. j 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 Bockhold, Jr., Thomas V. Greene, Georgie R. Frederick, Harry Majors, and Michael W. Horton on May 9, 1994; Georgia Power's 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  !

I

s. .

i 2

. - i Demands for information; the Supplemental Response of George ,

Bockhold, Jr., date February 1, 1995; the NRC's Modified Notice f of Violation issued February 13, 1995; and the NRC's Responses to - j demand for information for each of the individuals listed above i 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" chall mean any process by which a record is made of a meeting, event, i 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. l IV. DOCUMENT REOUEST

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

2. Identify and produce all' correspondence between Georgia- ,

Power and any person directly or indirectly related to the NOV.

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

4. Identify and produce all correspondence between Georgia Power and/or its council and the selected individuals and/or their individual council, directly or indirectly related to the NOV.

5

.= . i l

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

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

7. 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.

8. 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.

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

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

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

12. Identify the manner in which the discussions or meetings identified in numbers 10 and 11 above were recorded and the person (s) or company who recorded them.

6

13. Identify and produce the recordings and/or transcripts of the discussions or meetings identified in numbers 10 and 11 above.

14. Identify and produce any notes, minutes, and/or phone logs of the discussions or meetings identified in numbers 10 and 11 above.

15. Identify and produce all documents used in the creatien of Georgia Power Company's February 1, 1995 Supplement to Georgia Power Company's Response to the Notice of Violation (NOV) dated July 31, 1994.

16. Identify and produce all documents used in the creation of the February 1, 1995 letter from Mr. George Bockhold, Jr. to Mr. James Lieberman that supplements his August 5, 1994 Response to the NRC Demand for Information Regarding George Bockhold, Jr.

(EA 94-037).

17. Identify and produce all documents used or created as a result of the meetings between George Bockhold, Jr. and the Senior Vice President of Georgia Power and his immediate supervisor at Southern Nuclear, that were generally identified in

_Mr. Bockhold's February 1, 1995 letter.  !

18. Identify all persons whom attended each of the meetings identified in response to number 17 above.

19. Identify the immediate supervisors, at both Georgia Power and Southern Nuclear, of George Bockhold, Jr.

l 20 Produce the personnel file of George Bockhold, Jr. from May 1, 1994 to present. l 7

1

21. Identify and produce all documents upon which Georgia Power relied when coming to the understanding that it's July 31, 1994 response to the NOV had not persuaded the Staff of the appropriateness of the actions of George Bockhold.

22. Identify and produce any documents used in response to or generated as a result of the NRC's letter regarding the individual responses to the NRC's Deman'_ lor Information Regarding Thomas V. Greene, Georgie R. Frederick, Harry Majors, and Michael W. Horton, issued February 13, 1995.

23. Identify and produce any documents used in response to or generated as a result of the NRC's letter regarding the Response to the Demand for Information Regarding Kenneth McCoy, issued February 13, 1995.

24. Identify and produce any documents used in response to or generated as a result of the NRC's letter regarding the response to the Demand for Information Regarding George Bockhold, Jr., issued February 13, 1995.

25. Identify and produce any documents used in response to or generated as a result of the NRC's Modified Notice of Violation and Proposed Imposition of Civil Penalties, issued February 13, 1995, by Georgia Power Personnel.

26. Identify and produce any depositions relied upon in creating Georgia Power's responses to the NOV or Demand for Information.

8

i i

l 1

27. Identify and produce any depositions relied upon in  !

creating the responses of the selected individuals to the NOV or Demand for Information, j

28. The information and documents that are to be identified and/or produced in numbers 1-27 above, should include but are not limited to all documents, including handwritten personal notes, used in response to or created as a result of numbers 1-27 above by the following individuals:

a. Thomas V. Greene

b. Georgie R. Frederick

c. Harry Majors

d. Michael W. Horton

e. C. K. McCoy

f. George Bockhold

g. J. Beasley, Jr.

h. M. Sheibani

i. H. A. Franklin

j. W. G. Hairston, III

k. J. D. Woodard

1. L. B. Long

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

9

^

l i

29. Identify and produce all documents created since  :

i responded to the previous request for documents by Intervenor.

30. Identify and produce all documents that may be responsive to any of the document requests set out in j Intervenor's Document Request to NRC Staff, dated February 28, 1995.

Respectfully submitted, Ma e Wilmoth i Steph M. 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.GPC t

f e

10 l

~ _ _ __

• • 6 DOCKETED February 2d!Slill95 UNITED STATES OF-AMERICA NUCLEAR REGULATORY COMMISSION E EM ~2 R2 M l ATOMIC SAFETY AND LICENSING BOARD  ;

0FFICE OF SECRETARY I

DOCKEi!NG & 2RVICE

- In the Matter of ) ggApcg

) 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): l Plant,- Unit 1 and Unit 2) )

) ASLBP No. 93-671-01-OLA-3 l CERTIFICATE OF SERVICE I hereby certify that the tcilowing documents entitled  ;

Intervenor's Document Request to NRC Staff, 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, i Intervenor's Document Request to Georgie R. Frederick, ,

Intervenor's Document Request to Harry Majors, and Intervenor's Document Request to Michael W. Horton have been served this February 28, 1995, by first class mail on the persons listed in ,

the attached. service list.

/$44All$$/7$Y/) / ~

' Mary J e Wilino'th KOHN, OHN & COLAPINTO, P.C. '

517 F orida Ave., N.W.

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

L P

t

... ..~

6 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 g1 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 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 1 Attn: Docketing and Service j U.S. Nuclear Regulatory Commission j Washington, D.C. 20555 Office of Commission Appellate Adjudication U.S. Nuclear Regulatory Commission Washington, D.C. 20555 1

C:\ FILES \301\ CERT.LIS