ML20081L429
| ML20081L429 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/27/1995 |
| From: | Lamberski J GEORGIA POWER CO., TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA |
| To: | Wilmoth M KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA |
| References | |
| CON-#195-16540 OLA-3, NUDOCS 9503300197 | |
| Download: ML20081L429 (3) | |
Text
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'95 M? 28 A10:49 ATLANTA. GEORGIA 30308-2216 TELE PHONE. 404 885<3000 FACS MLE 404 885 3900 maernso QQ[I DOCKt m o 'm+i u CE BRMi March 27,1995 VIA FEDERAL EXPRESS Mary Jane Wilmoth, Ecquire Kohn, Kohn & Colapinto, P.C.
517 Florida Avenue, N.W.
Washington, D.C. 20001 Re:
Georgia Power Company (Vogtle Electric Generating Plant, Units 1 and 2) NRC Docket Nos. 50-424-OLA-3, 50-425-OLA-3; License Amendment for Transfer to Southern Nuclear Operating Company
Dear Ms. Wilmoth:
Georgia Power Company (" Georgia Power") hereby responds to Intervenor's letter dated March 22,1995, regarding Intervenor's stipulation proposals for tape transcripts ("Intervenor's March 22nd Letter").I' The letter summarizes Intervenor's eleventh-hour actions to reach agreement on tape transcripts he plans to introduce at the hearing. Georgia Power agrees with Intervenor that "this process is important and that the parties should reach as many stipulations as possible before the hearing." Intervenor's March 22nd Ietter at 4. That is precisely why Georgia Power, beginning over a year ago, submitted proposals for tape transcript agreement on February 28,1994, October 20,1994 and November 11, 1994. In contrast, as Intervenor's March 22nd Letter chronicles, Intervenor's first proffer of tape transcripts for agreement was March 13,1995, only ten days before the deadline set by the. Board for the tape agreement process to conclude. Intervenor's March 22nd Letter also enclosed several additional transcripts for agreement by the parties that was not received by Georgia Power until today.
Georgia Power will make every effort to accommodate Intervenor's'last minute entry into the tape transcript agreement process by responding to all of the tape transcript excerpts' proposed to date. Georgia Power would appreciate Intervenor's reciprocal cooperation by responding to its proposal for tape transcript agreement dated November 11, 1994. As an' aid to Intervenor in this process, Georgia Power summarizes below the status of Georgia Power's requests.
l' Sec Intervenor's letter from M. Wilmoth to M. Young, et al., and J. Lamberski, et al.,
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dated March 22, 1994.
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.u,uu=,J,,.a.:x Ms. Wilmoth March 27,1995 Page Georgia Power first proposed transcripts to the parties for agreement on February 28, 1994.2/ Intervenor partially responded to this request on September 20, 1994, by providing comments on those transcripts that had also been used by the NRC's Office of Investigations as exhibits to its report for Case No. 2-90-020R, as well as agreeing to the partial copy of the IIT Document #257 transcript.2' Following the Board's ruling regarding the appropriate process for proffering tape transcripts for agreement,i' Georgia Power submitted another letter to the parties, on October 20,1994, seeking agreement on partial transcripts for Tapes 42,184,186,253, 258, and 267.1' These transcripts were among those previously proffered by Georgia Power in its February 28, 1994 letter. Georgia Power also incorporated Intervenor's comments, received in his September 20,1994 response, except as detailed by Georgia Power in the letter. Intervenor, for the first time, responded to Georgia Power's October 20, 1994 proposal in Intervenor's March 22nd Letter. Intervenor agreed to partial transcripts for Tape 1846' and Tape 253. Intervenor's March 22nd Letter at 4. Intervenor further agreed to stipulate to the partial transcripts for Tapes 42,186, 258 and 267 upon the condition that the exceptions to these transcripts noted in Intervenor's September 20,1994 letter continue to be considered " disputed" by the parties.
2' Sr.c Georgia Power's letter from J. Lamberski to C. Barth and M. Kohn, dated February 28,1994.
See Intervenor's Response to Licensee's Request for Stipulations Dated February 28, 2'
1994, dated September 20, 1994. Georgia Power notes that it continues to believe that IIT Document #257 is relevant to its case and plans to use the transcript as agreed to by Intervenor in his response.
i' See August 12, 1994 status conference transcript, Tr. 597, 601-02.
l l' Sec Georgia Power's letter from J. Joiner to C. Barth and M. Kohn dated October 20, 1994.
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Intervenor's Letter states that it stipulates to the Tape 184 transcript proffered on February 28,1994. This is the same transcript proffered on October 20,1994 except that the first page of the transcript was deleted (because it is not relevant) in the October 20 proposal other than the information identifying the transcript as Tape 184, Side 1.
Georgia Power assumes that Intervenor did not want to include this irrelevant information.
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L TaoUTMAN SANDERS
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Ms. Wilmoth March 27,1995 Page Georgia Power also submitted another tape agreement proposal on November 11, 1994 to which Intervenor has not responded.2' Georgia Power's outstanding proposal seeks agreement on partial transcripts for Tapes 11, 17, 19, 21, 27, 29, 32, 34, 35, 37, 38, 39, 40, 53, 69, 71, 74, 75, 76, 79, 89, 90, 98,143,157,161,167,172, and 187.!' Georgia Power again requests that Intervenor review and respond to the November 11, 1994 proposal.
Very truly yours, John Lamberski i
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I' Georgia Power included a reminder of this outstanding tape stipulation request in its March 14,1995 letter to Intervenor (from J. Lamberski to M. Wilmoth) but no mention of the outstanding request was included in Intervenor's March 22nd Letter, l' Georgia Power notes that some of these transcripts (e.g., Tapes 40 and 89) include tape transcript excerpts that overlap transcript excerpts for which Intervenor seeks agreement. It seems that Intervenor could have simply stipulated to these transcripts, conditioned upon his proposed changes, rather than submitting a new proposal to the parties.