ML20081L604
| ML20081L604 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/22/1995 |
| From: | Kohn M KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA |
| To: | |
| References | |
| CON-#195-16530 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9503300262 | |
| Download: ML20081L604 (4) | |
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~ RELATED CORRESPONDENCE 00CMETED MarchU2MfC1995 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 95 tm 24 N1:39 ATOMIC SAFETY AND LICENSING BOARD i ) 0FFiCE Oc 55fIM! SA In the Matter of ) DOCKEI)]Ij ) Docket Nos. 50-424-OLA'-3 GEORGIA POWER COMPANY ) 50-425-OLA-3 l gt;, 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 NOTICE OF DEPOSITION OF ROY P. ZIMMERMAN AND LUIS A. REYES Intervenor, pursuant to 10 C.F.R. S2. 720 (h) (2) (i), hereby i request that the Executive Dirbctor of Operations of the NRC make available for depositions by oral examination Roy P. Zimmerman and Luis A. Reyes on April 27, 1995 at 10:00 am and continuing every working day thereafter until the deposition of each person is completed. These depositions are to be conducted'at the offices of Kohn, Kohn and Colapinto, P.C., 517 Florida Ave., N.W., Washington, D.C. These witnesses are identified as the " management panel" NRC Staff plans to present during the Phase II hearing in the above-captioned matter. Intervenor asserts that deposing these individuals is necessary because they possess and have had access to the following information on matters relevant to this proceeding which is not available from any other party or persons outside of NRC Staff, including information concerning the factual basis and reasoning employed by NRC Staff concerning "the character and 9503300262 950322 PDR ADOCK 05000424 W S$?) Q
.~ ~ 3:.: % Lintegrity of the corporations involved as it relates to.the admitted contention regarding prbposed transfer." The witnesses identified above are requested to bring with them all materials in their immediate control or possession (or in the immediate' control or possession of the agency) which concern or relate _to the following: j All' documents they have created or reviewed that' relate' to the. character and integrity of the corporations involved in the proposed transfer of the license or for which the-witness bases any statement of fact or opinion in any draft or pre-filed testimony or other i documents related to the position of the Agency concerning the character and competence.of the licensee; Southern Nuclear or any employee'or former employee thereof. The depositions identified above shall' continue until the witness has fully testified to all matters pertaining the issues for which the witnesses was called to testify; with respect to the documents produced by the witnesses; and with respect to all I matters generally discoverable as background material. Respectfully submitted, A #~ ( Michael D. Kohn Mary Jane Wilmoth Kohn, Kohn & Colapinto, P.C. 517 Florida Ave., N.W. Washington, D.C. 20001 J (202) 234-4663 l CVILES\\301WRCNOTIC.1 l l J 2 i I
~ DOCMETFD MEc3C22, 1995 UNITEDSTAThSOFAMERICA 95 tiAR 24 A11 :39 NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD OFT il t - .' "f i/ RY I DOCMET6h' ' d E 4 't F In the Matter of ) q,,,;.., ) Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY ) 50-425-OLA-3 s t, 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: 1) INTERVENOR'S MOTION tPO COMPLETE DISCOVERY AGAISNT NRC STAFF; 2) INTERVENOR'S NOTICE OF DEPOSITION OF JAMES L. MILHOAN AND NRC REPR, 'ENTATIVES; and 3) INTERVENOR'! !.OTICE OF DEPOSITION OF ROY P. ZIMMERMAN AND LUIS A. REYES was served via hand-delivery on March 23, 1995 upon the persons listed in the attached Service List. By: ' //A // / M ne W11 moth C:\\ FILES \\301\\NRCNOTIC.CRT
L .a' i ,4.. i UNITED STATES OF AMERICA NUCLEAR REGUIITORY COMMISSION [ ATOMIC SAFETY AND LICENSING BOARD i ) i In the Matter of ) ) Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY ) 50-425-OLA ! - 11 A L., ) ) Re: License Amendment l (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 di(& OKS5 I Peter B. Bloch, Chair James H. Carpenter md } r Atomic Safety and Licensing Bqprd 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 l U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ~ Washington, D.C. 20555 I Ernest L. Blake, Jr. Office of the Secretary David R. Lewis l Attn: Docketing and Service SHAW, PITTMAN, POTTS & U.S. Nuclear Regulatory Commission TROWBRIDGE Washington, D.C. 20555 2300 N Street, N.W. Oftice of Commission Appellate Adjudication U.S. Nuclear Regulatory Commission Washington, D.C. 20555 4 ? e C:\\ FILES \\301\\ CERT.LIS i i -- -, --}}