ML20081L334
| ML20081L334 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/13/1995 |
| From: | Wilmoth M AFFILIATION NOT ASSIGNED, KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA |
| To: | Barth C NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| References | |
| CON-#195-16497 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9503300160 | |
| Download: ML20081L334 (2) | |
Text
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,yg, y KOHN, KOHN, & COLAPINTO, PC.
o ATTORNEYS AT LAW p~
DOCKETED-517 FLORIDA AVENUE. NW ggg WASHINGTON. DC 20001 1850 y
(202) 234-4663 e FAX (202) 462 4145
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March 13, 1995 Via Facsimile Charles Barth, Esq.
Office of the General Counsel One White Flint North Stop 15B18 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Re:
In the Matter of Georgia Power Company,
~
et.al. (Vogtle Electric Generating Plant, Units 1 and 2) Dockets Nos. 50-424-OLA-3 &
50-425-OLA-3, ASLBP No. 93-671-01-OLA-3
Dear Charles:
I am writing in regard to^your letter of March 10, 1995, which addresses the recent discovery request by Intervenor.
There are a few points from your letter that I would like to address.
First, it was clearly an oversight that allowed the request to the Staff to be issued pursuant to 10 C.F.R. 52.740.
I hereby request that the request be amended as being issued pursuant to 10 C.F.R. 52.744.
However, I believe that the request contains the required specificity (e.g. request IV.7, at page 6, means exactly what it states and can be no more specific).
In addition, Intervenor is aware that diacovery on diesel generator issues is closed.
However, Intervenor believes the recent negotiations, agreements, and findings of the NRC regarding the Notice of Violation and the Demands for Information give Intervenor good cause for additional discovery.
Intervenor had hoped to resolve this issue among the parties but is perfectly willing to involve the Board.
The next point I would like to address is your complaint j
that Intervenor's request covers material previously provided to 1
ZIntervenor.
I would like to call your attention to the first page of the request where Intervenor states that the request does not include information that has been previously provided to him.
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Wilmoth/Barth March 13, 1995 Page 2 However, documents relating to Intervenor's request that are in the Public Document Room should nonetheless be identified.
Finally, the law firm of Kohn, Kohn, and Colapinto, P.C.
has not made the FOIA request specified in your letter concerning plant Vogtle.
Recently the National Whistleblower Center has made requests under FOIA in an attempt to acquire information to disseminate to the public to thereby kenp the public informed as to the issues in this proceeding.
In closing, Intervenor accepts your letter of March 10, 1995 as a refusal of Intervenor's document request and will file the appropriate motion.
Thank you for your attention to this matter.
Sincerely, 6M'MNLY M ry e'W11 mot cc:
Service List C:\\ FILES \\301\\LET2C8
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