ML20082H424

Intervenor Motion for Issuance of Subpoenas Re Gpc Witnesses.* Intervenor AL Mosbaugh Moves Board to Issue Subpoena to Listed Individuals to Appear & Testify at Illegal License Transfer Hearing.W/Certificate of Svc

ML20082H424
Person / Time
Site:	Vogtle
Issue date:	04/03/1995
From:	Kohn M, Mosbaugh A AFFILIATION NOT ASSIGNED, GEORGIA POWER CO., KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20082H415	List: ML20082H413 ML20082H424
References
CON-#295-16603 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9504170145
Download: ML20082H424 (81)

Text

,.y 'v l 00CKETED April 3, k$hh l UNITED STATES OF AMERICA '95 APR -7 P12 :20 NUCLEAR REGULATORY COMMISSION i ATOMIC SAFETY AND LICENSING BOARD OFFICE Of SECRE TARY DOCKEImG SERVICE

) BRANCH In the Matter of )  ;

) Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY ) 50-425-OLA-3 si 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 MOTION FOR ISSUANCE OF SUBPOENAS REGARDING GPC WITNESSES Pursuant to 10 C.F.R. S2.720 (a) , Intervenor, Allen Mosbaugh moves the Licensing Board to a issue subpoena to each of the individuals identified below to appear and testify at the illegal license transfer hearing during the week of May_17, 1995, at a

place still to be determined by the Board. The areas upon which they will be called to testify are stated below. These issues are related to the final report of the Office of-Investigations-and Georgia Power's safety obligations concerning the diesel 3

generators and are therefore relevant to this proceeding. Egg 1

Memorandum and Order (Scope of Discovery) dated June 2, 1994.

In addition to the areas listed below, these witnesses may also be needed to testify as rebuttal witnesses. l l

, 1. Mark Ajuluni

a. Submission of false statement of reasons why test data in LER 90-006 was inaccurat. as stated in revision 1 to LER 90-006, dated June- 29,.1990.

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9504170145 950403 PDR ADOCK 05000424 p6 0 PDR

2. -John Aufdenkampe

a. Submission of false statement of Vogtle EDG test data.

in LER 90-006, dated 4-19-90.

b. Submission of inaccurate information regarding the participation of the GPC Senior VP of nuclear operations in a late afternoon phone _ call on April 19,

, 1990, in which the wording of'LER 90-006 was revised, (in GPC's 4-1-91 2.206 Petition response).-

c. Providing the NRC and the IIT misleading, incomplete and inaccurate information about the reliability of the vogtle diesel generators as measured by safety system performance indicators (SSPI) and'as related to the rest of the nuclear industry.

d. Providing the NRC OSI team, in august 1990, incomplete-and inaccurate information in written responses (white paper) to NRC questions concerning the origin of the false statements made in.the 4-9-90 oral presentation,

.the-4-9-90 confirmation of action response-letter and the 4-19-90 LER 90-006.

e. Providing false information to the NRC OI, under oath,.

during a June 1993 interview of Pat Mcdonald about the basis of the statement in footnote 3 of GPC's 4-1-91, 2.206 Petition response.

f. Making false statements in GPC's August 1, 1994 response to the demand for information letter for Ken McCoy regarding the lack of knowledge by any corporate representative on 4-19-90 that the 4-9-90. data was-

, incorrect.

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_ Making f alse? statements in ASLB interrogatory: responses ' . L-g.

to NRC staff questions about GPC's definition of the comprehensive test program.

h. Making false statements in ASLB interrogatory response to NRC staff questions about Bockhold's instructions to cash as to the definition of a " successful start".

i. Providing false information to the department of justice about the participants on the 4-19-90 late afternoon phone call.

3. James' Bailey

a. Provluing inaccurate and incomplete vogtle EDG test data in the oral presentation to the NRC on April 9, 1990.

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b. Submission of misleading, inaccurate, and incomplete vogtle EDG test data in the letter of response to the NRC's confirmation of action letter, dated 4-9-90.

c. Submission of false statement of vogtle EDG test data in LER 90-006, dated 4-19-90.

d. Submission of false statement of reasons why test data in LER 90-006 was inaccurate, as stated in revision 1 to LER 90-006, dated june 29, 1990.

e. Submission of false and misleading statements of reason why vogtle EDG test data in April 9, 1990 letter was inaccurate as stated in the GPC clarification letter, dated August 30, 1990.

f. Withholding, on April 9, 1990, knowledge of recent out of tolerance EDG control air dewpoint readings by the VEGP GM. (In his oral presentation)

g. Submission of inaccurate information regarding the participation of the GPC Senior VP of nuclear operations in a late afternoon phone call on April 19, 1990, in which the wording of LER 90-006 was revised, (in GPC's 4-1-91 2.206 Petition response)

h. Providing misleading, incomplete and inaccurate information about the vogtle diesel generator air quality and dewpoints readings in the letter of response to the NRC's confirmation of action letter dated 4-9-90.

i. Providing the NRC OSI team, in August 1990, incomplete and inaccurate information in written responses (white paper) to NRC questions concerning_the origin of,the false statements made in the 4-9-90 oral presentation, the 4-9-90 confirmation of action response letter ard the 4-19-90 LER 90-006.

j. Failing to report to the NRC, pursuant to 50.9, Significant information affecting safety, after realizing that statements in the 4-9-90 oral presentation and the response to the confirmation of action were incorrect.

k. Making false statements in GPC's August 1, 1994 response to the demand for information letter for Ken McCoy regarding the lack of knowledge by any corporate representative on 4-19-90 that the 4-9-90 data was incorrect.

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_ _ _ _ _ _ _ _ ________ __ )

i

4. George bockhold 1

a. Providing inaccurate and incomplete vogtle EDG test )

data in the oral presentation to the NRC on April 9, 1990. ,

i

b. Submission of misleading, inaccurate, and incomplete i vogtle EDG test data in the letter of response to the I NRC's confirmation of action letter, dated 4-9-90.

c. Submission of false statement of vogtle EDG test data in LER 90-006, dated 4-19-90.

d. Submission of false statement of reasons why test' data in LER 90-006 was inaccurate, as stated in revision 1 to LER-90-006, dated June 29, 1990.

e. Submission of false and misleading _ statements of reason why vogtle EDG test data in April 9, 1990 letter was inaccurate as stated in the GPC clarification letter,.

dated August 30, 1990.

f. Withholding, on April 9, 1990, knowledge of recent out of tolerance EDG control air dewpoint readings _by the VEGP GM. (In his oral presentation)

g. Submission of inaccurate information regarding the participation of the GPC Senior VP of nuclear operations in a late afternoon phone call on April 19, 1990, in which the wording of LER 90-006 was revised, (in GPC's 4-1-91 2.206 Petition response)

. h. Providing misleading, incomplete and inaccurate 1

information about the vogtle diesel generator air quality and dewpoints readings _in,the: letter of, y .ca response to the NRC's confirmation _of-action ~ letter ~ -

1. au dated 4-9-90.

i. Providing incomplete and inaccurate information to the NRC's IIT team leader pursuant to his request to provide the IIT with a " table of dewpoint results on unit 1 for the last couple of years" on 4-11-90.

j. W ithholding information from the NRC about the discovery of water in the vogtle diesel air system.

k. Providing the NRC and the IIT misleading, incomplete and inaccurate information about the reliability of the vogtle diesel generators as measured by safety system performance indicators (SSPI) and as related to the rest of the nuclear industry.

~

s I 1. Providing the NRC OSI team, in august 1990, incomplete

and inaccurate information in written responses '(white paper) to NRC questions concerning the origin of the false statements made in the 4-9-90 oral presentation, the 4-9-90 confirmation of action response letter and

, the 4-19-90 LER 90-006,

m. Providing false information to the NRC OI, under oath, during a June 1993 interview of Pat Mcdonald about the

basis of the statement in footnote 3 of GPC's 4-1-91, 2.206 Petition response.

I n. Failing to report to the NRC, pursuant to 50.9, l Significant information affecting safety, after I realizing that statements in the 4-9-90_ oral presentation and the response to the confirmation of action were incorrect.

o. Making false statements in GPC's July 31, 1994 response to the NRC's notice of violation and proposed imposition of civil penalties about " post event measurements" of dewpoints.

p. Making taloe statements in GPC's August 1, 1994 response to the demand for information letter for Ken i McCoy regarding the lack of knowledge by any corporate representative on 4-19-90 that the 4-9-90 data was incorrect.

j q. Making false statements in ASLB interrogatory responses to NRC staff questions about GPC's definition of.the i

comprehensive test program.

r. Mak'ing false statements in ASLB interrogatory response i to NRC staff questions about Bockhold's instructions to cash;as to-the definition of a "su~ccess'fulfst' art". ' -

s. Making false statements in GPC's July 31, 1994 response to the demand for information for George Bockhold

- regarding Cash's understandings of Bockhold's instructions to count diesel starts and Cash's role in

providing that information to Bockhold for his transparency.

t. Making false statements in ASLB interrogatory response about the origin of the 18 &~19 starts in the Bockhold e transparency and the coa response letter.

u. Providing the NRC IIT team misleading, incomplete, and inaccurate information about the root cause of the diesel generator failure during the Vogtle site Area.

Emergency'of 3-20-90.

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v. Failing~to recognize conditions adverse to quality and take appropriate corrective actions for the root cause of the diesel failures during the site area emergency.

w. Operating plant vogtle for over 4 years in an unsafe condition with a design defect as a result of not having properly addressed or taken adequate corrective actions to prevent recurrence of the diesel failures.

x. Providing false information to the department of justice about the participants on the 4-19-90 late

afternoon phone call.

5. Kenneth Burr

a. Providing inaccurate and incomplete vogtle EDG test data in the oral presentation to the NRC on April 9, 1990.

b. Submission of misleading, inaccurate, and incomplete vogtle EDG test data in the letter of response to the NRC's confirmation of action letter, dated 4-9-90.

c. Withholding, on April 9, 1990, knowledge of recent out of tolerance EDG control air dewpoint readings by the VEGP GM. (In his oral presentation)

d. Providing misleading,~ incomplete'and. inaccurate information about the vogtle diesel generator air quality and dewpoints readings in the letter of response to the NRC's confirmation of action letter dated 4-9-90.

e. Withholding information from the NRC about the discovery.of. water _in the vogtle. diesel: air system w _ . w.

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f. Making false statements in GPC's July 31, 1994 response to the NRC's notice of violation and proposed imposition of civil penalties about " post event

measurements" of dewpoints.

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g. Making false statements in GPC's August 1, 1994 l response to the demand for information letter for Ken McCoy regarding the lack of knowledge by any corporate representative on 4-19-90 that the 4-9-90 data was i incorrect.

h. Making false statements in GPC's July 31, 1994 response to the demand for information for George Bockhold regarding cash's understandings of Bockhold's instructions to count diesel starts and Cash's role in 6

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t providing that information to Bockhold for his transparency.

i. Making false statements in ASLB interrogatory response about the origin of the 18 & 19 starts in the Bockhold transparency and the COA response letter.

j. Providing the NRC IIT team misleading, incomplete, and inaccurate information about the root cause of the diesel generator failure during the vogtle site area emergency of 3-20-90.

k. Failing to recognize conditions adverse to quality and take appropriate corrective actions for the root cause of the diesel failures during the' site _ area emergency.

1. Operating plant vogtle for over 4 years in an unsafe condition with a design defect as a result of not having properly addressed or taken adequate corrective actions to prevent recurrence of the diesel failures,

m. Demonstrating a disregard for public safety and

-displaying an unwillingness to reevaluate.the cause of the diesel failures during the 4-9-90 site area emergency after new information'and allegations are brought.to light.

6. Jimmy Paul Cash.

a. Providing inaccurate and incomplete vogtle EDG test data in the oral presentation to the NRC on April 9, 1990.

b. Submission of misleading, inaccurate,'and incomplete

.vogtle EDG test data in_the letter.of. response:to5the. ..c<

'NRC's'~ confirmation of action letter," dated 4-9-90~.

c. Submission of false statement of vogtle EDG test data in LER 90-006, dated 4-19-90.

d. Submission of false and misleading statements.of reason why vogtle EDG test data in April 9, 1990 letter was l inaccurate as stated in the GPC clarification letter, dated August 30, 1990,

e. Making false statements in GPC's August 1, 1994 ,

response to the demand for information letter for Ken McCoy'regarding the lack of knowledge by any corporate representative on 4-19-90 that the 4-9-90 data was incorrect.

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f. Making false statements in ASLB interrogatory response to NRC staff questions about Bockhold's instructions to Cash as to the definition of a " successful start".

g. Making false statements in GPC's July 31, 1994 response to the demand for information for George Bockhold regarding cash's understandings of Bockhold's instructions to count diesel starts and Cash's role in providing that information to Bockhold for his transparency.

h. Making false statements in ASLB interrogatory response about the origin of the 18 & 19 starts in the Bockhold transparency and the coa response letter.

7. Charles Coursey

a. Withholding, on April 9, 1990, knowledge of recent out of tolerance EDG control air dewpoint readings by.the VEGP GM. (In his oral presentation)

b. Providing misleading, incomplete and inaccurate information about the vogtle diesel generator air quality and dewpoints readings in the letter of response to the NRC's confirmation of action letter dated 4-9-90.

c. Providing incomplete and inaccurate information to the NRC's IIT team leader pursuant to his request to provide the IIT with a " table of dewpoint results on Unit 1 for the last couple of years" on 4-11-90.

d. Withholding information from the NRC about the discovery of water in the vogtle diesel air system.

e. Making false statements in GPC's' July 31, 1994 response to the NRC's notice of violation and proposed imposition of civil penalties about " post event measurements" of dewpoints.

f. Failing to recognize conditions adverse to quality and take appropriate corrective actions for the root cause of the diesel failures during the site area emergency.

8. Ester Dixon

a. Providing inaccurate and incomplete vogtle EDG test data in the oral presentation to the NRC on April 9, 1990.

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b. Making false statements in ASLB interrogatory response about the origin of the 18 & 19 starts in the Bockhold transparency and the COA response letter.

9. Michael Duncan

a. Withholding, on April 9, 1990, knowledge of recent out of tolerance EDG control air dewpoint readings by the VEGP GM. (In his oral presentation)

b. Providing misleading, incomplete and inaccurate information about the vogtle diesel generator air quality and dewpoints readings in the letter of response to the NRC's confirmation of action letter dated 4-9-90.

c.. Providing incomplete and inaccurate information to the NRC's IIT team leader pursuant to his requeot to provide the IIT with a " table of dewpoint results on unit 1 for the last couple of. years" on 4-11-90.

d. Withholding information from the NRC about the discovery of water in the vogtle diesel air system.

e. Making false statements in GPC's July 31, 1994. response to the NRC's notice of violation and proposed imposition of civil penalties about " post event measurements" of dewpoints.

10. Allen Franklin

a. Making false statements in GPC's July 31, 1994 response-to the NRC's notice of violation about GPC's calls to the NRC informing them of the errors in the LER.

b. Making false statements in GPC's July:31~,11994Cresponse -

to the NRC's notice of violation and proposed imposition of civil penalties about " post event measurements" of dewpoints.

c. Operating plant vogtle for over 4 years in an unsafe condition with a design defect as a result of not l having properly addressed or taken adequate corrective i actions-to prevent recurrence of the diesel failures.

d. Demonstrating a disregard for public safety and' displaying an unwillingness to reevaluate the cause'of the diesel failures during the 4-9-90 site area emergency after new information and allegations are.

brought to light.

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! e. The failure of GPC to properly identify and correct the false, misleading, inaccurate and non-candid statements made to the NRC regarding the diesel failures, the findings of the OI and other matters relevant to this proceeding.

11. Georgie Frederick 4

a. Providing inaccurate and incomplete vogtle EDG test data in the oral presentation to the NRC on April 9, 1990.

b. Submission of false statement of reasons why test data in LER 90-006 was inaccurate, as stated in revision 1 to LER 90-006, dated June 29, 1990.

. c. Submission of false and misleading statements of reason why vogtle EDG test data in April 9, 1990 letter was inaccurate as stated in the GPC clarification letter, dated August 30, 1990,

d. Submission of inaccurate information regarding the participation of the GPC senior VP of nuclear operations in a late afternoon phone call on April 19, 1990, in which the wording of LER 90-006 was revised, (in GPC's 4-1-91 2.206 Petition response)

e. Providing the NRC OSI team, in August 1990, incomplete and inaccurate information in written responses (white paper) to NRC questions concerning the origin of the false statements made in the 4-9-90 oral presentation, the 4-9-90 confirmation of action response letter and the 4-19-90 LER 90-006.

f. Making false statements in ASLB interrogatory responses to NRC staff questions about GPC's definition.of the.

~

comprehensive test program. ^L W

g. Providing the NRC IIT team misleading, incomplete, and inaccurate information about the root cause of the diesel generator failure during the vogtle site area emergency of 3-20-90.

h. Failing to recognize conditions adverse to quality and take appropriate corrective _ actions for the root cause of the diesel failures during the site area emergency. i l

1. Operating plant vogtle for over 4 years in an unsafe j condition with a design defect as a result of not having properly addressed or taken adequate corrective actions to prevent recurrence of the diesel failures.

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12. George Hairston l

a. Providing inaccurate and incomplete vogtle EDG test data in the oral presentation to the NRC on April 9, 1990.

b. Submission of misleading, inaccurate, and incomplete l vogtle EDG test data in the letter of response to the  !

NRC's confirmation of action letter, dated 4-9-90.

c. Submission of false statement of vogtle EDG test data i in LER 90-006, dated 4-19-90. '

l

d. Submission of false statement of reasons why test data l in LER 90-006 was inaccurate, as stated in revision 1 to LER 90-006, dated June 29, 1990.

e. Withholding, on April 9, 1990, knowledge of recent out of tolerance EDG control air dewpoint readings by the VEGP GM. (In his oral presentation)

f. Submission of inaccurate information regarding the participation of the GPC senior VP of nuclear operations in a late afternoon phone call on April 19, i 1990, in which the wording of LER 90-006 was revised, (in GPC's 4-1-91 2.206 Petition response)

g. Providing misleading, incomplete and inaccurate information about the vogtle diesel generator air quality and dewpoints readings in the letter of response to the NRC's confirmation of action letter dated 4-9-90.

h. Providing the NRC OSI team, in August 1990, incomplete and inaccurate information in written responsesq(white: s +

paper) to NRC questions concerning the origin of the-false statements made in the 4-9-90 oral presentation, the 4-9-90 confirmation of action response letter and the 4-19-90 LER 90-006.

i. Providing false information to the NRC OI, under oath, l during a June 1993 interview of Pat Mcdonald about the ,

basis of the statement in footnote 3 of GPC's 4-1-91, I 2.206 Petition response. l l

j. Failing to report to the NRC, pursuant to 50.9, l Significant information affecting safety, after  ;

realizing that statements in HM 4-9-90 oral l

! presentation and the response us the confirmation of l action were incorrect.

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k. -Providing misleading incomplete and inaccurate.

information to the NRC in GPC's 2.206' Petition response

'on 4-1-91'about GPC's calls to the NRC' informing them of the errors in the LER.

' l. Making false statements in GPC's July 31, - 1994 L response

.to the NRC's notice.of violation about GPC's calls-to '

the.NRC informing them of the errors in the.LER.

I m. Making false statements in GPC's July 31,~1994 response  ;

! to the NRC's' notice of" violation and' proposed imposition of civil penalties.about " post. event i measurements" of dewpoints. '

4- n. Making false statements in GPC's August 1,-1994 I response to the' demand for information' letter'for Ken- -

McCoy regarding the lack of-knowledge by any corporate representative on'4-19-90 that.the 4-9-90' data ~was incorrect.

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o. Making false statements in ASLB interrogatory responses to NRC staff questions about GPC's definition of the comprehensive teet program.

! p. Making false statements in ASLB interrogatory response to NRC staff questions about Bockhold's-instructions to cash.as to the definition of a " successful start".

q. Making false statements in.GPC's July. 31,.1994 response to the demand for information for George Bockhold L regarding cash's understandings of Bockhold's instructions to count diesel starts and Cash's role in.

providing that information to Bockhold for-his

transparency. ,

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1 Making"fal'se' statements 'in ASLB interro<jatory Tresponse

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about the origin of the 18 & 19 starts in the Bockhold transparency and the COA response letter.

s. Providing the NRC IIT team misleading, incomplete, and inaccurate information about the root cause of the diesel generator failure during the vogtle site area emergency of 3-20-90.,

., t. Failing to recognize conditions adverse to quality.and take appropriate corrective actions for the root cause of the diesel failures during the site area emergency.

u. Operating plant vogtle for over 4 years in an unsafe

~

condition with a design defect as a result of not ~

having properly addressed or taken. adequate corrective actions to prevent recurrence of the diesel failures.

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v. Demonstrating a disregard for public safety and displaying an unwillingness to reevaluate the cause of the diesel failures during the 4-9-90 site area emergency after new information and allegations are brought to light.

w. The failure of GPC to properly identify and correct the false, misleading, inaccurate and non-candid statements made to the NRC regarding the diesel failures, the findings of the OI and other matters relevant to this proceeding.

13. Michael Hobbs

a. Withholding, on April 9, 1990, knowledge of recent out of tolerance EDG control air dewpoint readings by the VEGP GM. (In his' oral-presentation) b Providing misleading, incomplete and inaccurate information about the vogtle diesel generator air quality and dewpoints readings in the letter of response to the NRC's confirmation of action letter dated 4-9-90.

c. Providing incomplete and inaccurate information to the NRC's IIT team leader pursuant to his request to provide the IIT with a " table of dewpoint results on unit 1 for the last couple of years" on 4-11-90.

d. Withholding information from the NRC about the discovery of water in the vogtle diesel air system.

e. Making false statements in GPC's July 31, 1994 response to the NRC's notice of violation and proposed

-imposition of' civil. penalties about " post event' measurements" of'dewpoints.

14. Kenneth Holms

a. Withholding, on April 9, 1990, knowledge of recent out of tolerance EDG control air dewpoint readings by the VEGP GM. (In his oral presentation)

b. Providing misleading, incomplete and inaccurate information about the vogtle diesel generator air quality and dewpoints readings in the letter of response to the NRC's confirmation of action letter dated 4-9-90.

c. Withholding information from the NRC about the discovery of water in the vogtle diesel air system.

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'd. Making false. statements in:GPC's1 July 31 fl994 response. ,

to the NRC's notice of violation'and proposed 4 imposition of civil. penalties about " post event  !

measurements" of dewpoints.

i

e. Providing-the NRC IITfteam misleading, incomplete,s and, l inaccurate information about the root.cause~of the-diesel' generator failure during.the vogtle site area ~

' ~

emergency of?3-20-90.

f.- Failing.to! recognize. conditions adverse to qualityjand take appropriate l corrective actions;for the, root.cause of.the< diesel failures during'the site area. emergency.  ;

g. . operating. plant vogtle for over 4 years in an1 unsafe condition- with-a design defect as a result of not having properly. addressed or taken-adequate corrective -!

actions.to prevent; recurrence ofEthe. diesel failures. .

15. 'MichaelHHorton~ ,

a.. Submission of false and misleading: statements lof reason. i why vogtle EDG test' data in April 9,L1990-letter.was j

' inaccurate as stated in the. GPC clarification letterc r dated August- 30, 1990,

b. ' Withholding,'on April'9, 1990,1 knowledge.of recentLout I of tolerance EDG-control air. dewpoint; readings:by'the. ~

VEGP GM. (In his. oral _presentationk

c. Providing misleading, incomplete.and inaccurate information about the vogtle diesel generator air ~

quality and, dewpoints readings fin . the letter' of:  ;

response to the NRC's confirmation of action letter  !

' dated'4-9-90.

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. se l d. Withholding information from the NRC'about the discovery.of water in the vogtle diesel air system.

e. Making false statements in GPC's July 31, 1994: response to the NRC's notice of violation and' proposed imposition of civil penalties about " post event measurements" of dewpoints. [

f. Providing the NRC IIT.teamimisleading, incomplete,s and j i

inaccurate information about the root cause of-the

. J

diesel generator failure during the'vogtle site area l

emergency of 3-20-90. i

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g. Failing to;recognizeLconditions adverse lto quality and' ]

take appropriate corrective actions for the root cause of the diesel failures during/the site area emergency.

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h. Operating-plant vogtle for over'4 years in an unsafe condition with a design defect as a result of not ,

having properly addressed or taken adequate corrective

, actions to prevent recurrence of the diesel failures' .

16. Skip Kitchens

a. Withholding, on April 9, 1990, knowledge of'recent out of_talerance EDG control air dewpoint-readings by the VEGP GM. (In his oral presentation) l b. Providing misleading, incomplete and inaccurate l 'information about-the vogtle diesel generator air j quality and'dewpoints readings in the letter of response to the NRC's confirmation of. action letter i dated 4-9-90.

c. Providing incomplete and inaccurate information.to the NRC's IIT team-leader pursuant to'his request to-e provide the IIT with a " table of. dewpoint results on unit 1.for the last couple of years" on 4-11-90.

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d. Making false statements in GPC's July 31, 1994 response to the NRC's notice of violation-and~ proposed _ ]

i imposition of civil penalties about-" post event  :

measurements" of dewpoints. I 1

j -e. Demonstrating a disregard for publicfsafety and displaying an unwillingness to-reevaluate the cause of the diesel failures during the.4-9-90 site area emergency after new information and allegations are i brought to light.

17. Paul Kochery ^

~ ' '

a. Withholding, on April 9, 1990, knowledge of recent out ~

of tolerance EDG control. air dewpoint. readings by the VEGP GM. (In his oral presentation)

b. Providing misleading, incomplete and inaccurate information about the vogtle diesel generator air l quality and dewpoints readings in the letter of l response to the NRC's confirmation of action letter dated 4-9-90. l l

c. Withholding information from the NRC about the discovery of water in the vogtle diesel air system.

d. _Failing to recognize conditions adverse to quality and take appropriate corrective actions.for the root cause of the diesel failures during the site area emergency.

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18. Kenneth McCoy

a. Providing inaccurate and incomplete vogtle EDG test I data in the oral presentation to the NRC on April 9, 1990.

b. Submission of misleading, inaccurate, and incomplete vogtle EDG test data in the letter of response to the NRC's confirmation of action letter, dated 4-9-90. {

c. Submission of false statement of vogtle EDG test data in LER 90-006, dated 4-19-90.

d. Submission of false statement of reasons why test data in LER 90-006 was inaccurate, as stated in revision 1 to LER 90-006, dated June 29, 1990.

e. Submission of false and misleading statements of reason why vogtle EDG test data in April 9, 1990 letter was inaccurate as stated in the GPC clarification letter, dated August 30, 1990.

f. Withholding, on April 9, 1990, knowledge of recent out of tolerance EDG control air dewpoint readings by the VEGP GM. (In his oral presentation)

g. Submission of inaccurate information regarding the participation of the GPC Senior VP of nuclear operations in a late afternoon phone call on April 19, 1990, in which the wording of LER 90-006 was revised, (in GPC's 4-1-91 2.206 Petition response)

. h. Providing misleading, incomplete and inaccurate information about the vogtle diesel generator air quality and dewpoints readings in'the letter of' - ~

response to the NRC's confirmation of action letter dated 4-9-90.

i. Providing the NRC OSI team, in august 1990, incomplete j and inaccurate information in written responses (white paper) to NRC questions concerning the origin of the false statements made in the 4-9-90 oral presentation, I the 4-9-90 confirmation of action response letter and  !

the 4-19-90 LER 90-006.  ?

j. Providing incomplete and inaccurate information about i the role of GPC executive, Ken McCoy, in the preparation and review of LER 90-006, in a section 210 ,

department of labor proceeding. I

k. Failing to report to the NRC, pursuant to 50.9, Significant information affecting safety, after 16 l

l

)

4 realizing that statements in the 4-9-90 oral presentation and the response to the confirmation of action were incorrect.

1. Providing misleading incomplete and inaccurate information to the NRC in GPC's 2.206 Petition response on 4-1-91 about GPC's calls to the NRC informing them of the errors in the LER.

a

m. Making false statements in GPC's July 31, 1994 response to the NRC's notice of violation about GPC's calls to the NRC informing them of the errors in the LER.

n. Making false statements in GPC's July 31, 1994 response to the NRC's notice of violation and proposed imposition of civil penalties about " post event measurements" of dewpoints.

o. Making false statements in GPC's August 1, 1994 response to the demand for information letter for Ken McCoy regarding the lack of knowledge by any corporate representative on 4-19-90 that the 4-9-90 data was incorrect.

p. Making false statements in ASLB interrogatory responses to NRC staff questions about GPC's definition of the i comprehensive test program.

q. Making false statements in ASLB interrogatory response to NRC staff questions about Bockhold's instructions to Cash as to the definition of a " successful start".

r. Making false statements in GPC's July 31, 1994 response to the demand for information for George Bockhold regarding Cash's understandings of.Bockhold's -

instructions'to count diesel starts and/ Cash's role'in i

providing that information to Bockhold for his transparency.

s. Making false statements in ASLB interrogatory response about the origin of the 18 & 19 starts in the Bockhold transparency and the COA response letter.

t. Providing the NRC IIT team misleading, incomplete, and inaccurate information about the root cause of the diesel generator failure during the vogtle site area emergency of 3-20-90.

u. Failing to recognize conditions adverse to quality and take appropriate corrective actions for the root cause of the diesel failures during the site area emergency.

17

v. Operating plant vogtle for over 4_ years in-an unsafe condition with a design defect as a result of not having properly addressed or taken_ adequate corrective actions to prevent recurrence of the diesel failures.

w. Demonstrating a disregard for public safety and displaying an unwillingness to reevaluate the cause of the diesel failures during the 4-9-90 site area i

emergency after new information-and allegations are brought to light.

19. Patrick Mcdonald

a. Providing inaccurate and incomplete vogtle EDG. test-dataLin the oral presentation to the~NRC on April-9, 1990.

b '. Submission of misleading, inaccurate, and incomplete vogtle EDG test data in the-letter of. response to the NRC's confirmation of action letter, dated-4-9-90.

~

c. Submission of false statement of vogtle EDG test data in LER'90-006, dated 4-19-90.

d. Submission of' inaccurate information regarding the participation of the GPC senior VP of nuclear; operations in a late afternoon. phone ~ call.on April 19, 1990, in which the wording of LER 90'006Lwas revised, (in GPC's 4-1-91'2.206 Petition response);

e. Providing misleading,-incomplete and inaccurate.

information about the vogtle diesel generator air ,

quality and dewpoints readings in the;1etter of response to the NRC's confirmation of action' letter

. dated-4-9-90.m -

* * "+- 'A'

• w .n .

f. Withholding information from the NRC about the discovery of water in the vogtle diesel' air system. ,

I

g. Providing the NRC OSI team, in August 1990, incomplete and inaccurate information in written responses (white paper) to NRC questions concerning the origin of the false statements made in the 4-9-90 oral presentation, .

the 4-9-90 confirmation of action response letter and I the 4-19-90 LER 90-006. )

l

h. Providing false information to the NRC OI, under cath, during a June 1993 interview of Pat Mcdonald about the '

basis of the statement in footnote 3 of'GPC's 4-1-91, 2.206 Petition response.

l l

18 u __ __ _

i. Providing incomplete and inaccurate information about the role of GPC executive, Pat Mcdonald, in the preparation and review of LER 90-006, in a section 210 department of labor proceeding.

j. Failing to report to the NRC, pursuant to 50.9, Significant information affecting safety, after realizing that statements in the 4-9-90 oral presentation and the response to the confirmation of-action were incorrect.

k. Providing misleading incomplete and inaccurate information to.the NRC in GPC's 2.206 Petition response on 4-1-91 about GPC's calls to the NRC informing them of the errors in the LER.

1. Making false statements in GPC's August 1, 1994 response to the demand for information letter for Ken McCoy regarding the lack of knowledge by any corporate representative on 4-19-90 that the 4-9-90 data was incorrect.

m. Providing the NRC IIT team misleading, incomplete, and inaccurate information about.the root cause of the diesel generator failure during the vogtle site area emergency of 3-20-90.

n. Failing to recognize conditions adverse to quality and take appropriate corrective actions for the root cause of the diesel failures during the site area emergency.

o. Operating plant vogtle for over 4' years in an unsafe condition with a design' defect as a result of not having properly addressed or taken adequate corrective '

actions to: prevent recurrence of"the' diesel (failu'res.

p. Demonstrating a disregard for public safety and displaying an unwillingness to reevaluate the cause of the diesel. failures during the 4-9-90 site area emergency after new information and allegations are brought to light.

20. Harry Majors

a. Submission of false statement of reasons why test data in LER 90-006 was inaccurate, as stated in revision 1 to LER 90-006, dated June :29, 1990.

i

21. Paul Rushton

a. Submission of false statement of vogtle EDG test data )

in LER 90-006, dated 4-19-90. j 19 i

b. Submission of false statement of reasons why test data in LER 90-006 was inaccurate, as stated in revision 1 to LER 90-006, dated June 29, 1990.

l

c. Submission of inaccurate information regarding the l participation of the GPC senior VP of nuclear- )

operations in a late afternoon phone-call on April 19, 1 1990, in which the wording of LER 90-006 was revised, (in GPC's 4-1-91 2.206 Petition response) ,

d. Providing the NRC OSI team, in August 1990,. incomplete and inaccurate information in written responses-(white paper) to NRC questions concerning the origin of the false statements made in the 4-9-90 oral presentation, the 4-9-90 confirmation of action response letter and the 4-19-90 LER 90-006,

e. Failing to report to the 1000, pursuant'to 50.9, Significant information'affecting safety, after realizing that statements in'the 4-9-90 oral presentation and the. response to the confirmation of action were incorrect.

22. William Shipman

a. Providing inaccurate and incomplete vogtle EDG test data in the oral presentation to the NRC on' April 9, 1990.

b. Submission of misleading, inaccurate, and incomplete vogtle EDG test data in the-letter of response to the NRC's confirmation of action 11etter,. dated 4-9-90.

c. Submission of false statement of vogtle EDG, test data'

~

,.s

'",*7",,

in"LER 90-006,' dated 4-19-90.

d. Submission of false statement of reasons why test data in LER 90-006 was inaccurate, as stated in revision 1 to LER 90-006, dated June 29, 1990.

e. Withholding, on April 9, 1990, knowledge of recent out of tolerance EDG control air dewpoint readings by the VEGP GM. (In his oral presentation)

f. Submission of inaccurate information regarding the participation of the GPC Senior VP of nuclear operations in a late afternoon phone call on April 19, 1990, in which the wording of LER 90-006 was revised, (in GPC's 4-1-91 2.206 Petition response) 1 20

l

g. Providing misleading, incomplete and inaccurate  !

.information about the vogtle diesel generator air' l quality and dewpoints readings in the letter of response to the NRC's confirmation of action letter dated 4-9-90.

h. Providing the NRC OSI team, in. august 1990, incomplete and inaccurate information in written responses (white paper) to NRC questions concerning the origin of the false statements made in the 4-9-90 oral presentation, the 4-9-90 confirmation of action response letter and the 4-19-90 LER'90-006.

i. Providing false information to the NRC OI, under oath, during a June 1993 interview of Pat Mcdonald about the basis of the statement in footnote 3 of GPC's 4-1-91, 2.206 Petition response.

j. Failing to report to the NRC, pursuant to 50.9, significant information affecting safety, after realizing ^that statements in the 4-9-90 oral presentation and the response to the confirmation of action were incorrect.

k. Providing misleading incomplete and inaccurate information to the NRC in GPC's 2.206 Petition response on 4-1-91 about GPC's calls to the NRC informing them of the errors in the LER.

1. Making false statements in GPC's July 31, 1994 response to the NRC's notice of violation and proposed imposition of civil penalties about " post event measurements" of dewpoints.

~ ~

~ Making false s'tatements in GPC's August'11 1994

m. -

response to the~ demand for information'1etter for Ken McCoy regarding the lack of knowledge by any corporate representative on 4-19-90 that the 4-9-90 data was incorrect.

n. Failing to recognize conditions adverse to quality and take appropriate corrective actions for the root cause of the diesel failures during the site area emergency.

o. Operating plant vogtle for over 4 years in an unsafe condition with a design defect as a result of not ,

having properly addressed or taken adequate corrective l actions to prevent recurrence of the diesel failures. i

p. Demonstrating a disregard for public safety and I displaying an unwillingness to reevaluate the cause of l the diesel failures during the 4-9-90 site area l 21 l

l c

emergency after new information and allegations are brought to light.

23. Jackson Stringfellow

a. Providing inaccurate and incomplete vogtle EDG test data in the oral presentation to the NRC on April 9, 1990,

b. Submission of misleading, inaccurate, and incomplete vogtle EDG test data in the letter of response to the NRC's confirmation of action letter, dated 4-9-90.

c. Submission of false statement of vogtle EDG test data in LER 90-006, dated 4-19-90.

d. Submission of false statement of reasons why test data in LER 90-006 was inaccurate, as stated in revision 1 to LER 90-006, dated June 29, 1990,

e. Submission of inaccurate information regarding the participation of the GPC Senior VP of nuclear operations in a late afternoon phone call on April 19, 1990, in which the wording of LER 90-006 was revised, (in GPC's 4-1-91 2.206 Petition response)

f. Providing the NRC OSI team, in august 1990, incomplete and inaccurate information in written responses (white paper) to NRC questions concerning the origin of the false statements made in the 4-9-90 oral presentation, the 4-9-90 confirmation of action response letter and the 4-19-90 LER 90-006.

g. Providing false ninformation to the NRC.OI, under oath, ,

during a' June'1993' interview of Pat Mcdonald about the.. 7-basis'of'the" statement in footnote 3 of'GPC's"4'-1-91, 2.206 Petition response,

h. Failing to report to the NRC, pursuant to 50.9, Significant information affecting safety, after I realizing that statements in the 4-9-90 oral '

presentation and the response to the confirmation of action were incorrect.

i. Making false statements in GPC's August 1, 1994 l response to the demand for information letter for Ken McCoy regarding the lack of knowledge by any corporate representative on 4-19-90 that the 4-9-90 data was i I

incorrect.

22

l

24. Kenneth Stokes l l

a. Withholding, on April 9, 1990, knowledge of recent out of tolerance EDG control air dewpoint readings by the j VEGP GM. (In his oral presentation) l

b. Providing misleading, incomplete and inaccurate information about the vogtle diesel generator air i quality and dewpoints readings in the letter of response to the NRC's confirmation of action letter ;

dated 4-9-90. '

c. Withholding information from the NRC about the

discovery of water in the vogtle diesel air system.

i

d. Making false statements in GPC's July 31, 1994 response to the NRC's notice of violation and proposed imposition of civil penalties about " post event measurements" of dewpoints.

} e. Providing the NRC IIT team misleading, incomplete, and inaccurate information about-the root cause of the diesel generator failure during the vogtle site area emergency of 3-20-90.

I

f. Failing to recognize conditions adverse to quality and take appropriate corrective actions for-the' root cause of the diesel failures during the site area emergency.

, g. Operating . plant vogtle for over 4 years in an unsafe condition with.a design defect as a result.of not having properly addressed or taken adequate corrective actions to. prevent recurrence of the diesel failures.

25. Louis Ward

a. Submission of false statement of vogtle EDG test data ,

in LER 90-006, dated 4-19-90. l l

b. Withholding, on April 9, 1990, knowledge of recent out '

of tolerance EDG control air dewpoint readings by the l VEGP GM. (In his oral presentation) i 1

I

c. Submission of inaccurate information regarding the participation of the GPC senior VP of nuclear operations in a late afternoon phone call on April 19, 1990, in which the wording of LER 90-006 was revised, (in GPC's 4-1-91 2.206 Petition response)

d. Providing misleading, incomplete and inaccurate l information about the vogtle diesel generator ~ air quality and dewpoints readings in the letter of 23 l

1 l

response to the NRC's confirmation of action letter dated 4-9-90.

f. Providing incomplete and inaccurate information to the NRC's IIT team leader pursuant to his request to provide the IIT with'a " table of dewpoint results on unit i for the last couple of years" on 4-11-90.

g. Withholding information from the NRC about the discovery of water in the vogtle diesel air system. .

h. Providing the NRC OSI team, in August 1990, incomplete and inaccurate information in written responses (white i paper) to NRC questions concerning the origin of the false statements made in the 4-9-90 oral presentation, the 4-9-90 confirmation of action response letter and the 4-19-90 LER 90-006.

i. Making false statements in GPC's July 31, 1994 response '

to the NRC's notice of violation and proposed imposition of civil penalties about " post event measurements" of dewpoints.

j. Making false statements in GPC's August 1, 1994 response to the demand for information letter for Ken McCoy regarding the lack of knowledge by any corporate representative on 4-19-90 that the 4-9-90 data was incorrect.

k. Providing the NRC IIT team misleading, incomplete, and inaccurate information about the. root,cause.of. t.he.. . _~ '__ ; .

diesel generator failure during the vogtle site area ~

emergency of 3-20-90,

1. Failing to recognize conditions adverse to quality and take" appropriate ~ corrective actions'for'th~e' root"canse' ~ *7 ^

of the diesel failures during the site area emergency.

m. Operating plant vogtle for over 4 years in an unsafe condition with a design defect as a result of not having properly addressed or taken adequate corrective actions to prevent recurrence of the diesel failures.

26. Thomas Webb

a. Submission of false statement of vogtle EDG test data in LER 90-006, dated 4-19-90.

b. Submission of false statement of reasons why test data in LER 90-006 was inaccurate, as stated in revision 1 to LER 90-006, dated June 29, 1990.

24

27. Guss Williams

a. Providing the NRC and the IIT misleading, incomplete and inaccurate information about the reliability of the vogtle diesel generators as measured by safety system performance indicators (SSPI) and as related to the rest of the nuclear industry.

The relavance of each of these witness' testimony cannot be seriously disputed. The necessary factual predicate requiring the issuance of the subpoenas has been set forth in Mr.

Mosbaugh's pre-filed testimony.

These individuals are past or present employees or agents of the Licensee and have been identified as being in the control of Licensee, Georgia Power Company, and/or its counsel. Intervenor requests that the subpoenas for the above-identified individuals be served on John Lamberski, Esq., Troutman Sanders, 600 Peachtree Street, N.E., Suite 5200, Atlanta, Georgia, 30308-2216.1 Each of the witnesses is to bring any and all. documents, in their custody, control and/or possession, related to the subject area to which the witness is to testify. These documents shall include but are not limiced to written, recorded or graphic.

l 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, 2

If any of these individuals are no longer in the control of the Licensee, then Licensee must indicate such so that Intervenor may subpoena them elsewhere.

25

5 I

1

periodical,. work sheet, cost sheet, list, graph, chart,~index, tape, record, partial or complete report of telephone or oral'

conversation, tabulation, study, analysis, transcript, minutes, depositions and all memorials of any conversations, meetings, and conferences by telephone or otherwise, including personal notes, j.

and any other writing or: recording.

l The~date~and time that each of'the witnesses is'expectedito

testify is set forth in the accompanying subpoenas' bearing1 the

name of.the witness.

WHEREFORE, Intervenor requests-that the Board issue a.

4 subpoena for each of the above-identified individuals to appear

].

at the date and time indicated.in the accompanying subpoena.

j ' Respectfully-submitted, i

h Michael D. Kohn-l 1 Mary Jane.Wilmoth i KOHN, KOHN!& COLAPINTO, P.C.

[

517 Florida Ave., N.W.

o Washington,"D.C.-20001l - -

l (202) '234-4663 I

~

l CERTIFICATE OF SERVICE

! (/ I hereby certify that the above motion was served on April

i, 1995 by hand delivery upon the persons listed in the attached service list (except that it was delivered by first class mail as 4 indicated by "*"). =

A Y !s a 1

Mary Uan j

/$11 moth 4

ji 26 4

.- . - .. . .-.- . .-- .~ -- . . - - -

H UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

' ATOMIC S7?ETY AND LICENSING BOARD

)

, In the Matter of. )

) Docket Nos. 50-424-OLA-3

GEORGIA POWER COMPANY ) 50-425-OLA-3 31 gL., )

) Re: License Amendment ,

(Vogtle Electric Generating ) (transfer to Southern Nuclear) l

! Plant, Unit 1 and Unit 2) ) i

^

) ASLBP'No.^93-671-01-OLA-3  !

\

i

'l l l SUBPOENA OF JOHN AUFDENKAMPE l

'l

'In accordance with section 161(c) of the Atomic Energy Act, l

42 U.S.C. S 2201 (c) and 10 C.F.R. 52;720, John Aufdenkampe is, l 1

hereby ordered to appear.and testify before.the Atomic Safety'and'

'l Licensing Board concerning the Phase II diesel generator' issues l in the above captioned proceeding. You are to appear on May-17, 1995 at'9:00 a.m. or at another specified1 time duringx that orithe following week, at a place yet to be' determined by the Board.

You are.to bring with you'all documents.which' fit the-following description:

'all' documents, in your custody, control and/or possession, related to the subject area to which'you.have been called to

. testify asLset forth in Intervenor's' Motion'for the1 Issuance of. Subpoenas ~. These documents shall include:butLare not' limited to written, recorded or. graphic matter, however L

l l

)

1 produced:or reproduced, of every kind and regardless of where located, including but not limited to_any summary, schedule, memorandum, note, statement, letter, . telegram, i interoffice communication, report, diary, desk or pocket-calendar or notebook, daybook, appointment book, phone logs,

~

J pamphlet, periodical, work sheet, cost sheet, list, graph, chart,.index, tape, record, partial or complete report of telephone or oral conversation, tabulation, study, analysis, transcript, minutes, depositions and all memorials of any conversations, meetings, and conferences by telephone or

'otherwise, including personal notes, and any other writing or recording.

On motion made promptly, and in any event received on or

) before May 17, 1995, and on notice delivered to Intervenor's counsel on or before that date, this Atomic Safety and' Licensing i

i Board (or if the Licensing Board is unavailable, the Commission):

, may (1) quash or modify the subpoena if it is unreasonable or I

requires evidence not relevant to any matter or issue, or.(2) condition denial of the motion on just and reasonable terms.

J- IT IS SO ORDERED.

i I

Peter B. Bloch, Chair

', Dated at Rockville, Maryland this day of ,~1995.

i I

4 i

1 s

l i

l l

1 l

l l

I UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION I ATCMIC SAFETY AND LICENSING BOARD

)  ;

In the Matter of )

) Docket Nos. 50-424-OLA-3 l GEORGIA POWER COMPANY ) 50-425-OLA-3 l

91. i , )

) Re: License Amendment (Vogtle Electric Generating ) (transfer to Southern Nuclear) l Plant, Unit 1 and Unit 2) ) l

) ASLBP.No. 93-671-01-OLA-3. I l

. SUBPOENA OF GEORGE BOCKHOLD 4

l In accordance with section 161(c) of the Atomic Energy Act, 42 U.S.C. S2201(c) and 10 C.F.R. S2.720, George Bockhold is l

! hereby ordered to appear and testify before the Atomic Safety and I

Licensing Board concerning the Phase II diesel generator issues in the above captioned proceeding. You are to appear on May 17, 1995 at 9:00 a.m. or at another specified time during that or the following week, at a place yet to be determined by the Board.

You are to bring with you all documents which fit the following description:

all documents, in your custody,. control and/or possession, related to the subject area to which you have been called to testify as set forth in Intervenor's Motion for the Issuance of Subpoenas. These documents shall include but are not limited to written, recorded or graphic matter, however

~ ,

p produced or reproduced, of.every' kind and regardless of where located, including but not limited to any summary, 4

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, tabulation, study, analysis, transcript, minutes, depositions and all memorials of any conversations, meetings, and conferences by telephone or otherwise, including personal notes,.and any other writing or recording.-

On motion made promptly, and in 'any event received on or before May 17, 1995, and on notice delivered to Intervenor's counsel on or before that date, this Atomic Safety and Licensing

- Board (or'if the-Licensing Board is unavailable, the Commission) l may (1) quash or modify the subpoena if it is unreasonable or.

/

requires evidence not relevant to any matter or issue, or (2) l condition denial of the motion on just and reasonable terms.

l IT IS SO ORDERED.

l I

Peter B. Bloch, Chair l Dated at Rockville, Maryland this day of , 1995.

. . - . . . . . . _. . . . _. .. . _ . _ _ . _ . . . . _ . . ~_ _. . _

'~

i 4

j~

UNITED STATES OF' AMERICA NUCLEAR REGULATORY' COMMISSION ATOMIC SAFETY AND LICENSING BOARD L )

.In the Matter of )

i ) Docket Nos. 50-424-OLA-3 c . GEORGIA POWER COMPANY )' 50-425-OLA-3 31 AL., )

) Re: License Amendment j (Vogtle-Electric Generating ) (transfer to Southern Nuclear)

Plant, Unit 1 and Unit 2) )

4 ) ASLBP No. 93-671201-OLA-3 i SUBPOENA OF KENNETH BURR

In accordance with section 161(c) of'the At'omic Energy Act, l .

42 U.S.C. S 2201 (c) and 10 C.F.R. S2'.720, Kenneth Burr is hereby ,

i 1 ordered to appear and testify before the Atomic Safety.and l Licensing Board concerning the Phase II diesel generator issues l l

in the above captioned proceeding. You are'to appear on May 17, 1.

1995 at 9:00 a.m. or at another specified time during that or the l following week, at a place.yet to be determined by the Board.

You are'to bring with you all documents which fit the a

following description:

all documents, in your custody,' control and/or posses ~sion, related to the subject arealto which you have been called-to 4' testify as set forth in 'Intervenor's Motion for the Issuance of Subpoenas. These documents shall include but are not.

limited to 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, cost sheet, list, graph, chart, index, tape, record, partial or complete report of telephone or oral conversation, tabulation, study, analysis, i transcript, minutes, depositions and all memorials of any conversations, meetings, and conferences by telephone or otherwise, including personal notes, and any other writing or recording.

On motion made promptly, and in any event received on or before May 17, 1995, and on notice delivered to Intervenor's counsel on or before that date, this Atomic Safety and Licensing Board (or if the Licensing Board is unavailable, the Commission) may (1) quash or modify the subpoena if it is unreasonable or l requires evidence not relevant to any matter or issue, or (2) condition denial of the motion on just and reasonable terms.

IT IS SO ORDERED.

Peter B. Bloch, Chair Dated at Rockville, Maryland this day of , 1995.

i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD  ;

)

In the Matter of ) J

) Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY ) 50-425-OLA-3 31 gL., )

) Re: Lic'ense Amendment  ;

(Vogtle Electric Generating ) (transfer to Southern Nuclear) l Plant, Unit 1 and Unit-2) )  !

) ;ASLBP No. 93-671-01-OLA  !

SUBPOENA OF JAMES BAILEY In accordance with section 161(c) of the Atomic Energy Act, 42 U.S.C. 52201(c) and 10 C.F.R. S2.720, James Bailey is hereby ordered to appear and testify before the Atomic Safety and-  ;

i Licensing Board concerning the Phase II diesel generator issues l 1

in the above captioned proceeding. You are to appear on May 17, 1995 at 9:00 a.m. or at another specified time during that or the following. week, at a place.yet to be determined by the Board.

You are to bring with you all documents which fit the i following description:

i all documents, in your custody, control and/or possession, l related to the subject area to which you have been called to i d

testify as set forth in Intervenor's Motf.on for the Issuance of Subpoenas. These documents shall include but are not limited to written, recorded or graphic matter, however s

produced or reproduced, of everyLkind and regardless of where located,. including but not limited to any summary,-  ;

schedule, memorandum, note'1 statement, letter,; telegram,.

, l interoffice communication, report,_ diary," desk'or pocket l calendar orLnotebook,. daybook,' appointment book,. phone logs, I pamphlet, periodical, work sheet, cost sheet, list,, graph, R F chart, index tape, record, partial cnr complete report of telephone or oral conversation, tabulation, study, analysis, - i transcript, minutes, depositions and all memorials of any;  !

conversations, meetings, and conferences by telephone or otherwise,.-including personal notes, and any other writing i or recording. )

on motion'madeLpromptly, and in any event. received on or

. before May 17, 1995, and on notice delivered to Intervenor's ,

counsel on or before that date, this Atomic Safety and Licensing 1 l .

Board (or.if the Licensing Board is unavailable, the1 Commission). l l may (1) quash or modify.the subpoena if it is unreasonable.or requires evidence not relevant to'any matter or' issue, or'(2)

I condition denial of the motion on just and reasonable terms.

IT IS SO ORDERED.

Peter B. Bloch, Chair Dated'at Rockville, Maryland  :

this day of , 1995. l

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_______.__m.._m.___.____._________.__.___ _ . _ _ _w. - _ , . ._ _, __ . . , _ . , y r 3 y., y _p ._

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

.e1 AL., )

) Re: License Amendment (Vogtle Electric Generating ) (transfer to Southern Nuclear)

Plant, Unit 1 and Unit 2) )

) ASLBP No. 93-671-01-OLA-3 SUBPOENA OF JIMMY PAUL CASH In accordance with section 161(c) of the Atomic Energy Act, 42 U.S.C. S2201(c) and 10 C.F.R. S2.720, Jimmy Paul Cash is i 1

hereby ordered to appear and testify before the Atomic Safety and l l

Licensing Board concerning the Phase II diesel generator issues in the above captioned proceeding. You are to appear on May 17, 1995 at 9:00 a.m. or at another specified time during that or the following week, at a place yet to be determined by the Board.

You are to bring with you all documents which fit the following description:

all documents, in your custody, control and/or possession, related to the subject area to which you have been called to testify as set forth in Intervenor's Motion for the Issuance of subpoenas. These documents shall include but are not limited to written, recorded or graphic matter, however

- - -. ~ .. .- -. - .. - - .- - _- . - . . _ . . .- - -_

l l

4

~l produced cnc 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,udeek or pocket  !

calendar or. notebook, daybook,-appointment book, phone logs, l pamphlet, periodical, work sheet, cost-sheet, list, graph, chart, index,. tape, record, partial'or complete report'of telephone or oral conversation, tabulation, study, analysis,s j transcript,-minutes, depositions and all memorials of any; e fconversations, meetings, and conferences;byJtelephone or' .

otherwise, including personal notes, and any other writing I or recording.

1 on' motion made promptly, and in any event received on or before May 17, 1995, and on notice delivered to Intervenor's counsel on or before that date, this Atomic Safety.and Licensing i Board (or if the Licensing Board is unavailablei the commission)-

i may (1) quash or modify the subpoena if itEis unreasonable or j requires evidence:not relevant to any matter or issue,;or'(2).

condition denial of the motion on just and reasonable terms.

IT IS SO ORDERED.

Peter B' . Bloch,. Chair Dated at Rockville, Maryland this day of __, 1995.

I J

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4 3

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION' ATOMIC SAFETY AND LICENSING BOARD

-)

In the Matter of ) ,

) Docket Nos. 50-424-OLA l I

1 ' GEORGIA POWER' COMPANY ) 50-425-OLA-3 et AL., ) i

)i ) Re: License Amendment I i (Vogtle Electric Generating ) (transfer to Southern Nuclear) n Plant, Unit 1 and Unit 2). )

1 ) ASLBP No. 93-671-01-OLA-3 SUBPOENA OF CHARLES COURSEY In accordance with section 161(c)'of'the Atomic. Energy'Act, 42 U.S.C. 52201(c) and.10 C.F.R. 52.720, Charles Coursey is hereby ordered to appear and testify before the Atomic Safety and Licensing Board concerning the Phase II diesel generator issues in the above captioned proceeding. You are to app *.ar on May 17, 1995 at 9:00 a.m..or at another specified time during that or the following week, at a place yet to be' determined by the Board.

You are to bring with you all documents which fit the fol!.owing description:

s11 documents, in your custody, control and/or possession, related to the subject area'to.which you.have been called to testify as set forth in Intervenor's Motion for.the Issuance .

of Subpoenas. These documents shall include but are not limited to written, recorded or graphic matter, however 1

, , , . - ,. .. _ , , , . -. ,,..M ,-,r,..

6 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, cost sheet, list, graph, chart, index, tape, record, partial or complete report of telephone or-oral conversation, tabulation, study, analysis, transcript, minutes, depositions and all memorials of any conversations, meetings, and conferences by telephone or otherwise, including personal notes, and any other writing or recording.

On motion made promptly, and in any event received on or

before May 17, 1995, and on notice delivered to Intervenor's counsel on or before that date, this Atomic Safety and Licensing Board (or if the Licensing Board is unavailable, the Commission) 1

! may (1) quash or modify the subpoena if it is unreasonable or i

requires evidence not relevant to any matter or issue, or (2) condition _ denial of the motion on just and reasonable terms.

i IT IS SO ORDERED.

l l

Peter B. Bloch, Chair

. Dated at Rockville, Maryland i

this day of , 1995.

A 1

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'h j UNITED STATES OF. AMERICA j NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD.

4 i .)

s In the Matter of )

) Docket Nos. 150-424-OLA-3 GEORGIA POWER COMPANY ) 50-425-OLA-3 31 AL., )

Re: License Amendment

)

l (Vogtle Electric Generating ) (transfer to Southern Nuclear)

! Plant, Unit 1 and Unit 2) )

l ) ASLBP No. 93-671-01-OLA-3 1

j SUBPOENA OF GEORGIE FREDRICKS 4

p In accordance with section 161(c) of the Atomic Energy Act, i

j 42 U.S.C. 52201 (c) and 10 C.F.R. S2.720, Georgie Fredricks is i hereby ordered to appear and testify before the Atomic Safety and Licensing Board concerning the Phase II diesel generator issues in the above. captioned proceeding. You are to appear on May 17, 1995 at 9:00 a.m. or at another specified time during that or the 3 following week, at a place yet to be determined by the Board.

j .You are to bring with you all documents:which fit the a

following description:

all documents, in your custody, control and/or possession, related to. the subject area to which _ you ' have been called tx) testify as set forth in Intervenor's Motion for the Issuance of Subpoenas. These documents shall include but are not limited to written, recorded or graphic matter, however-Y -

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. 1 produced or reproduced, of every kind and regardless of where located, including but not limited to any summary, i schedule, memorandum, note, statement, letter, telegram, I 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 reportlof telephone or oral conversation, tabulation, study, analysis, transcript, minutes,' depositions and all memorials of any conversations, meetings, and conferences by telephone or otherwise, including personal notes, and any other. writing l or recording.

On motion made promptly, and in'any event received on or before.May-17, 1995,'and on notice delivered to Intervenor's ,

I counsel on or before that date, this Atomic Safety and Licensing l

, J 4 Board (or if the Licensing Board is unavailable, the Commission) may (1) quash or modify the subpoena if it is unreasonable.or requires evidence not relevant to any matter or issue, or (2) 4 _

! condition denial of the motion on'just and reasonable terms. l l

IT IS SO ORDERED.

l Peter.B. Bloch, Chair Dated at Rockville, Maryland

. this day of , 1995.

1 a

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

)

In the Matter of )

) Docket Nos. 50-424-OLA-3  !

GEORGIA POWER COMPANY ) 50-425-OLA-3 )

at alm, ) )

) Re: License Amendment ,

l (Vogtle Electric Generating ) (transfer to Southern Nuclear) l Plant, Unit 1 and Unit 2) ) j

) ASLBP No. 93-671-01-OLA-3 1 SUBPOENA OF GEORGE HAIRSTON l

1 In accordance with section 161(c) of the Atomic Energy Act, 42 U.S.C. S2201(c) and 10 C.F.R. 52.720, George Hairston is hereby ordered to appear and testify before the Atomic Safety and Licensing Board concerning the Phase II diesel generator issues in the above captioned proceeding. You are to appear on May 17, 1995 at 9:00 a.m. or at another specified time during that or the following week, at a place yet to be determined by the Board.

You are to bring with you all documents which fit the following description:

all documents, in your custody, control and/or possession, related to the subject area to which you have been called to testify as set forth in Intervenor's Pot'.on for the Issuance of Subpoenas. These documents shall include but are not limited to written, recorded or graphic matter, however

l l

produced or reproduced, of every kind and regardless of l 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, 5

chart, index, tape, record, partial or complete report of i telephone or oral conversation, tabulation, study, analysis, transcript, minutes,- depositions and all memorials of any I j conversations, meetings, and conferences by telephone or l otherwise, including personal notes, and any.other writing or recording.

. 1 on motion made promptly, and in any event received on or' J j before May 17, 1995, and on notice delivered to Intervenor's counsel on or before that date, this Atomic Safety and Licensing Board (or if the Licensing Board is unavailable,.the Commission) may (1) quash or modify the subpoena ^if it is unreasonable or 4

i requires evidence not relevant to any matter or issue, or (2)

! condition denial of the motion on just and reasonable terms.

IT IS SO ORDERED.

1 i Peter B. Bloch, Chair 4

Dated at Rockville, Maryland this day of , 1995.

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4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD i )

. In the Matter of )

I ) Docket Nos. 50-424-OLA-3 i GEORGIA POWER COMPANY ) 50-425-OLA-3

! 31 3,L , )

) Re: License Amendment-(Vogtle Electric Generating ) (transfer to Southern Nuclear)

Plant, Unit 1 and Unit 2) .)

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

1 i SUBPOENA OF KENNETH HOLMS I

In accordance with section 161(c) of the Atomic Energy Act,

42 U.S.C. S 2201 (c) and 10 C.F.R. 52.720, Kenneth Holms is hereby l ordered to appear and testify before'the Atomic Safety and Licensing Board concerning the Phase II diesel generator issues in the above captioned proceeding. You are to appear on May 17, t

l 1995 at 9:00 a.m. or at another specified. time during that or the -

I following week, at a place yet to be determined by the Board.

i You are to bring with you all documents which fit the i

following description:

all documents, in your custody, control and/or possession, related-to the subject area to which you have been called to testify as set forth in Intervenor's Motion for the Issuance of Subpoenas. These documents shall include but are not 4 limited to written, recorded or graphic matter, however

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s I

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, cost sheet, list, graph,  ;

chart, index, tape, record, partial or complete report of telephone or oral. conversation, tabulation, study, analysis, transcript,. minutes, depositions and all memorials of any a conversations, meetings, and conferences by telephone or otherwise, including personal notes, and any other writing or recording.

On motion made promptly, and in any event received on or before May 17, 1995, and on. notice delivered to Intervenor's councel on or before that date, H this' Atomic Safety and' Licensing-Board (or if the Licensing Board is unavailable, the Commission) may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter or issue, or (2) condition denial of the motion on just and reasonable terms.

IT IS SO ORDERED.

Peter B. Bloch, Chair Dated at Rockville, Maryland this day of , 1995.

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

.e l a L ., )

) Re: License Amendment (Vogtle Electric Generating ) (transfer to Southern Nuclear)

Plant, Unit 1 and Unit 2) )

) ASLBP No. 93-671-01-OLA-3 SUBPOENA OF MICHAEL HORTON In accordance with section 161(c) of the Atomic Energy Act, 42 U.S.C. 52201(c) and 10 C.F.R. S2.720, Michael Horton is hereby ordered to appear and testify before the Atomic Safety and Licensing Board concerning the Phase II diesel generator issues in the above captioned proceeding. You are to appear on May-17, 1995 at 9:00 a.m. or at another specified time during that or the following week, at a place yet to be determined by the_ Board.

You are to bring with you all documents which fit the following description:

all documents, in your custody, control and/or possession, related to.the subject area to which you have been called to testify as setfforth in Intervenor's Motion for the Issuance of subpoenas. These documents shall include but are not limited to written, recorded or graphic matter, however

l 1 l l produced or reproduced, of every kind.and regardless of j 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, I

pamphlet, periodical, work sheet, cost sheet, list, graph, i

chart, index, tape, record, partial oricomplete report of-telephone or oral conversation, tabulation, study, analysis, transcript,. minutes, depositions and all memorials of any '

conversations, meetings, and conferences by telephone or

< otherwise, including personal notes, and any other writing or recording.

On motion made promptly,-and in any event received-on or:

j before May 17, 1995, and on notice delivered to Intervenor's

) counsel on or before that date, this Atomic Safety and Licensing 1

Board (or if the Licensing Board is unavailable, the commission) may (1) quash or modify the subpoena if it is unreasonable.or requires evidence not relevant to any matter or_ issue,.or (2) j condition denial of-the motion on just and reasonable terms.

i

$ IT IS SO ORDERED.

i 4 I Peter B. Bloch, Chair

! Dated at Rockville, Maryland this day of , 1995.

i j

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4 l

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UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION l ATOMIC SAFETY AND LICENSING BOARD i ) l l In the Matter of )

( ) Docket Nos. 50-424-OLA-3 l GEORGIA POWER COMPANY ) 50-425-OLA-3 l A C. A 1.s., )

) Re: License Amendment i

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

Plant, Unit 1 and Unit 2) ) .

l

) ASLBP No. 93-671-01-OLA-3 SUBPOENA OF SKIP KITCHENS I l

In accordance with section 161(c) of the Atomic Energy Act,  !

42 U.S.C. S2201(c) and 10 C.F.R. 52.720, Skip Kitchens is hereby ordered to appear and testify before the Atomic Safety and Licensing Board concerning the Phase II diesel generator issues in the above captioned proceeding. You are to appear on May 17, 1995 at 9:00 a.m. or at another specified time:during that or the following week, at a place yet to be determined by the Board.

-You are to bring with you all documents which fit the following descriptica:

all documents, in your custody, control and/or possession, related to the subject area to which.you have been called to testify as set forth in Intervenor's Motion for the Issuance of Subpoenas. These documents shall include but are not limited to 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, cost sheet, list, graph, chart, index, tape, record, partial or complete report of telephone or oral conversation, tabulation, study, analysis, transcript, minutes, depositions and all memorials of any conversations, meetings, and conferences by telephone or otherwise, including personal notes, and any other writing or recording.

On motion made promptly, and in any event received on or before May 17, 1995, and on notice delivered 86XEntervenor's counsel on or before that date, this Atomic Safety and Licensing Board (or if the Licensing Board is unavailable, the Commission) may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter or issue, or (2) condition denial of the motion on just and reasonable terms.

IT IS SO ORDERED.

Peter B. Bloch, Chair Dated at Rockville, Maryland this day of , 1995.

1 i

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 at;. gL., )

) Re: License Amendment (Vogtle Electric Generating ) (transfer to Southern Nuclear)

Plant, Unit l'and Unit 2) )

) ASLBP No. 93-671-01-OLA l SUBPOENA OF PAUL KOCHERY In accordance with section 161(c) of the Atomic 1 Energy Act,

)

42 U.S.C. S2201(c) and 10 C.F.R. S2.720, Paul Kochery is hereby ordered to appear and testify before the Atomic Safety and--

Licensing Board concerning the Phase II diesel generator-issues in the above captioned proceeding. You are to appear on May 17, 1995 at 9:00 a.m. or-at another specified time during that or the following week, at a place' yet to be determined by the Board.

You are to bring with you all documents which fit the following description:

all documents, in your custody, control and/or possession, related to the subject area to which you have been called to testify as set forth in Intervenor's Motion for the Issuance of Subpoenas. These documents shall include but are not-limited to written, recorded or' graphic matter, however

- . - . - . - ~ . , - . . . -

produced or reproduced, of every kind and regardless of )

. where located, including but not limited to any summary, i schedule, memorandum, note, statement, letter, telegram, I l 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, tabulation, study, analysis, I transcript, minutes, depositions and all memorials of any  !

j conversations, meetings, and conferences by telephone or i

, otherwise, including personal notes, and any other writing i L or recording.  !

On motion made promptly, and in any event received on or i

before May 17, 1995, and on notice delivered to Intervenor's l counsel on or before that date, this Atomic Safety and Licensing I

i Board (or if the Licensing Board.is unavailable, the Commission) may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter or issue, or (2) condition denial of the motion on just and reasonable terms.

IT IS SO ORDERED.

l l

Peter B. Bloch, Chair l l

i Dated at Rockville, Maryland this day of , 1995.

l 1

--7 c7

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 31 aL., )

) Re: License Amendment J (Vogtle Electric Generating ) (transfer to Southern Nuclear)

Plant, Unit 1 and Unit 2) )

) ASLBP No. 93-671-01-OLA-3 j SUBPOENA OF HARRY MAJORS In accordance with section 161(c) of the Atomic Energy Act, 42 U.S.C. S2201(c) and 10 C.F.R. 52.720, Harry Majors is hereby ordered to appear and tes,1fy before the Atomic Safety and Licensing Board concerning the Phase II diesel generator issues in the above captioned proceeding. You are to appear on May 17,

.1995 at 9:00 a.m. or at another specified time during that or the following week, at a place yet to be determined by the Board.

You are to bring with you'all documents which fit the following description:

all documents, in your custody, control and/or possession, related to the subject area to which you have been called to testify as set forth in Intervenor's Motion for the Issuance of Subpoenas. These documents shall include but are not limited to written, recorded or-graphic matter, however

l 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, cost sheet, list, graph, chart, index, tape, record, partial or complete report of telephone or oral conversation, tabulation, study, analysis, transcript, minutes, depositions and all memorials of any conversations, meetings, and conferences by telephone or otherwise, including personal notes,-and any other writing or recording.

On motion made promptly, and in any event received on or before May 17, 1995, and on notice delivered to Intervenor's counsel on or before that date, this Atomic Safety and Licensing Board (or if the Licensing Board is unavailable, the Commission) may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter or issue, or (2) condition denial of the motion on just and reasonable terms.

IT IS SO ORDERED.

Peter B. Bloch, Chair Dated at Rockville, Maryland this day of , 1995.

S 4

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1 1

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1 I

i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION v ATOMIC SAFETY AND LICENSING BOARD J

)

In the Matter of )

) Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY ) 50-425-OLA-3 i r1 AL., )

) Re: License Amendment (Vogtle Electric Generating ) (transfer to Southern Nuclear) l Plant, Unit 1 and Unit 2) )

l ) ASLBP No. 93-671-01-OLA-3 I l SUBPOENA.0F KENNETH MCCOY b

[ In accordance with section 161(c) of the Atomic Energy Act, s

j 42 U.S.C. S2201(c) and 10 C.F.R. 52.720, Kenneth McCoy is hereby order to appear and testify before the Atomic Safety and i

{ Licensing Board concerning the Phase II diesel generator issues l in the above captioned proceeding. You are to appear on May 17, l_ 1995 at 9:00 a.m. or at another specified time during that or the following week, at a place yet to be determined by the Board.

You are to bring with you all documents which fit the following description:

all documents, in your custody, control and/or possession, l related to the subject area to which you have been called to

, testify as set forth in Intervenor's Motion for the Issuance of Subpoenas. These documents shall include-but are not i limited to written, recorded or graphic matter, however 4

4 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, cost sheet,' list, graph, chart, index, tape, record, partial or complete report of telephone or oral conversation,. tabulation, study, analysis, transcript, minutes, depositions and all memorials of any ,

conversations, meetings, and conferences by telephone or  ;

otherwise, including personal notes, and any other writing

-or recording. ,

On motion made promptly, and in any event received on or before May 17, 1995, and on notice delivered to Intervenor's j counsel on or before that date, this Atomic Safety and Licensing  ;

Board 2 (or if the Licensing BoardL is unavailable, the Commission) '

may (1) quash or modify the subpoena if it is-unreasonable or requires evidence not relevant to any matter or issue, or (2) i condition denial of the motion on just and reasonable terms.

l IT IS SO ORDERED. l 2

Peter B. Bloch, Chair Dated at Rockville, Maryland this day of , 1995.

'l l -

i I

i I

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

I . )

] In the Matter of )  !

I

). Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY ) 50-425-OLA-3 i g_t aL., )

! ) Re: . License Amendment

} (Vogtle Electric Generating ) (transfer to Southern Nuclear)

Plant, Unit 1 and Unit 2) )

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

SUBPOENA OF PATRICK MCDONALD ,

1 4

j In accordance with section_161(c) of the Atomic Energy Act,

l

] 42 U.S.C. 52201 (c) and 10 C.F.R. 52.720, Patrick Mcdonald is j

! hereby ordered to appear and testify before the Atomic Safety and j Licensing Board concerning the Phase II diesel generator issues

in the above captioned proceeding. You are to appear on May 17, 1995 at 9

00 a.m. or at another specified time during that.or the i

following week, at a place yet to be determined by the Board.

You are to bring with.you all documents which' fit the following description:

i all documents, in your custody, control.and/or possession, related to the subject area to which you have been called to testify as set forth in Intervenor's Motion for the Issuance

- of Subpoenas. These documents shall_ include but are not limited to written, recorded or graphic matter, however 4

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, cost sheet, list, graph, chart, index, tape, record, partial or complete report of telephone or oral conversation, tabulation, study, analysis, transcript, minutes, depositions and all memorials of any conversations, meetings, and conferences by telephone or otherwise, including personal notes, and any other writing or recording.

On motion made promptly, and in any_ event received on or before May 17, 1995, and on notice delivered to Intervenor's counsel on or before that date, this Atomic Safety and Licensing Board (or if the Licensing Board is unavailable, the Commission) may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter or issue, or (2) condition denial of the motion on just and reasonable terms.

l IT IS SO ORDERED.

Peter B. Bloch, Chair

Dated at Rockville, Maryland this day of , 1995.

i l

L I

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4 1

l 1

l j UNITED STATES OF AMERICA 1 1 NUCLEAR REGULATORY COMMISSION L ATOMIC SAFETY AND. LICENSING' BOARD.

i

)

! In the Matter of )

l ) Docket Nos. 50-424-OLA-3 I -GEORGIA POWER COMPANY ) 50-425-OLA-3 L 31 AL., - ) .

l- .

) .Re: License' Amendment

}- '(Vogtle Electric Generating ) (transfer to Southern Nuclear) j Plant, Unit 1 and Unit 2) -) )

j ) 'ASLBP No. 93-671-01-OLA-3 i 4

4 i

SUBPOENA OF PAUL RUSHTON l

i l

1 In accordance with section 161(c) of the Atomic Energy.Act, 42 U.S.C. S2201(c) and 10 C.F.R. 52.720, Paul Rushton is hereby 1

i ordered to appear and testify before the Atomic Safety and.

Licensing Board concerning the Phase II diesel generator issues i

j' in the above captioned proceeding. You are to appear on May 17,

l. ~

.- 1995 at 9:00 a.m. or at another specified time duringithat or the l

following week, at a place yet to'be determined by the Board' .

]

. You are to bring with,you all documents:which fit the-i l following description:-

i-

[ all documents, in your custody, control.and/or_ possession, l related to the subject area to which you have been calledito L testify as set forth in Intervenor's Mat;on for the Issuance -

j- of subpoenas. These' documents shall include but.are nott j limited,to written, recorded or graphic matter, however i

5-l

. . . . . . -. ..-.._.m.-._.,_,.

1 D

1 1

produced or reproduced, of every kind and regardless of -)

where located,_ including but not limited t'o.any summary, i Schedule, memorandum, note, statement, letter, telegram, interoffice communication, report, diary,. desk.or pocket ,

calendar or notebook, daybook,Lappointment' book, phone logs, '

pamphlet, periodical,_ work sheet, cost sheet, list,_ graph, '

chart, index,- tape, record, partial or complete report of-

-telephone or oral conversation,Ltabulation, study, analysis,  !

transcript, minutes, depositions.and all memorials of any H conversations, meetings, andEconferences by, telephone ~or otherwise- including personal notes, and any other writing.

or recording.

On motion made.promptly, and in'any event' received on~or before May 17,.1995, and on notice delivered to Intervenor's _

counsel on or before'that.date, this Atomic Safety and Licensing ,

Board (or if the Licensing' Board is unavailable, .the ' Commission)

- may (1) qpash or modify the subpoena.if it.is. unreasonable or requires evidence not relevant to any matter.or_ issue, or (2) condition denial of the motion on'just and reasonable terms.

IT IS SO ORDERED.

Peter B. Bloch, Chair Dated at Rockville, Maryland this day of ,-1995.

4

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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 ga AL., )

) Re: License Amendment (Vogtle Electric Generating ) (transfer' to Southern . Nuclear)

Plant, Unit 1 and Unit 2) )

) ASLBP No. 93-671-01-OLA-3 SUBPOENA OF JACKSON STRINGFELLOW In accordance with section 161(c) of the, Atomic Energy Act, 42 U.S.C. 52201 (c) and 10 C.F.R. 52.720, Jackson Stringfellow is hereby ordered to appear and testify before the Atomic Safety and Licensing Board concerning the Phase II diesel generator issues in the above captioned proceeding. You are to appear on'May 17, 1995 at 9:00 a.m. or at another specified time during that or the following week, at a place yet to be determined by the Board.

You are to bring with you all documents which fit the following description:

all documents, in your custody, control and/or possession, related to the subject area to which you have been called to testify as set forth in Intervenor's Motion for the Issuance of Subpoenas. These documents shall. include but are not limited to written, recorded or graphic matter, however l

1 .

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, 1 pamphlet, periodical, work sheet, cost sheet, list, graph, l

chart, index, tape, record, partial or complete report of I telephone or oral conversation, tabulation, study, analysis, transcript, minutes, depositions and all memorials of any conversations,-meetings, and conferences by telephone or

otherwise, including personal notes, and'any other writing i

or recording.

l j On motion made-promptly, and in any event received on or 1

i. i before May 17, 1995, and on notice delivered to Intervenor's t

counsel on or before that date, this Atomic Safety and Licensing l

j Board (or if the Licensing Board is unavailable, the Commission) l may (1) quash or modify the subpoena if it .is unreasonable or j requires evidence not relevant' to any matter or issue, or (2)

{ condition denial of the motion on'just and reasonable terms.

i i

IT IS SO ORDERED.

A Peter B. Bloch, Chair Dated at Rockville, Maryland i this day of __ , 1995.

].

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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,

ATOMIC SAFETY AND LICENSING BOARD  !

j )

In the Matter of )

I; . ) Docket Nos. 50-424-OLA-3 l- 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) )

j ) ASLBP No. 93-671-01-OLA-3 a??S SUBPOENA OF WILLIAM SHIPMAN i

f In accordance with section 161(c) of the Atomic Energy Act, 42 U.S.C. 52201(c) and 10 C.F.R. 52.720, William Shipman is

}. hereby ordered to appear and testify before the Atomic Safety and i

Licensing Board concerning the Phase-II diesel generator issues

in the above captioned proceeding. You are to appear on May 17, 1995 at 9

00-a.m. or at another specified time during that'or'the f following week, at a place yet to be determined by the Board.

You are to bring with you all documents which fit the I

following description:

i all documents, in your custody, control and/or possession,

.related to the subject area to which you have been called to testify as set forth in Intervenor's Motion.for the Issuance of Subpoenas. These documents shall include but are not-limited to 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, cost' sheet, list, graph, chart, index, tape, record, partial or complete report of telephone or oral conversation, tabulation, study, analysis, transcript, minutes, depositions and all memorials of any conversations, meetings, and conferences by telephone or otherwise, including personal notes, and any other writing or recording.

On motion made promptly, and in any event received on or before May 17, 1995, and on notice delivered to Intervenor's counsel on or before that date, this Atomic Safety and Licensing Board (or if the Licensing Board is unavailable, the Commission) may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter or issue, or (2) condition denial of the motion on just and reasonable terms.

IT IS SO ORDERED.

Peter B. Bloch, Chair Dated at Rockville, Maryland this day of , 1995.

l

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 91 ab., )

) Re: License Amendment (Vogtle Electric Generating ) (transfer to Southern Nuclear)

Plant, Unit 1 and Unit 2) )

) ASLBP No. 93-671-01-OLA-3 SUBPOENA OF KENNETH STOKES In accordance with section 161(c) of the Atomic Energy Act, 42 U.S.C. S2201(c) and 10 C.F.R. S2.720, Kenneth Stokes is hereby ordered to appear and testify before the Atomic Safety and Licensing Board concerning the Phase II diesel generator issues in the above captioned proceeding. You are to appear on May 17, 1995 at 9:00 a.m. or at another specified time during that or the following week, at a place yet to be determined by the Board.

You are to bring with you all documents which fit the following description:

all documents, in your custody, control and/or possession, related to the subject area to which you have been called to testify as set forth in Intervenor's Motion for the Issuance of Subpoenas. These documents shall include but are not limited to 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, 1 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, tabulation, study, analysis, transcript, minutes, depositions and all memorials of any conversations, meetings, and conferences by telephone or otherwise, including personal notes, and any other writing or recording.

On motion made promptly, and in any event received on or before May 17, 1995, and on notice delivered to Intervenor's

< counsel on or before that date, this Atomic Safety and Licensing Board (or if the Licensing Board is unavailable, the Commission) may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter or issue, or (2) condition denial of the motion on just and reasonable terms.

IT IS SO ORDERED.

4 Peter B. Bloch, Chair l

Dated at Rockville, Maryland this day of , 1995. l 4

=

b l

l l

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 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 I

SUBPOENA OF THOMAS WEBJ In accordance with section 161(c) of the Atomic Energy Act, 42 U.S.C. S2201(c) and 10 C.F.R. S2.720, Thomas Webb is hereby ordered to appear and testify before the Atomic Safety and Licensing Board concerning the Phase II diesel generator issues in the above captioned proceeding. You are to appear on May 17, 1995 at 9:00 a.m. or at another specified time during that or the following week, at'a place yet to be determined by the Board.

You are to bring with you all' documents which fit the=

following description:

all documents, in your custody, control and/or possession, related to the subject area-to which you have been called to testify as set forth in Intervenor's Mot.on for the Issuance of Subpoenas. These documents shall include but are not limited to written, recorded or graphic matter, however

. _ . - . ... . --_ -.. - _- .= - .__ _. . -

1 l

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, cost sheet, list, graph, chart, index, tape, record, partial or complete report of telephone or oral. conversation, tabulation, study, analysis, transcript, minutes, depositions and all memorials of any conversations, meetings, and conferences by telephone or otherwise, including personal notes, and any other writing or recording. j On motion made promptly, and in any event received on'or before May 17, 1995, and on notice delivered to Intervenor's counsel on or before that date, this Atomic Safety and Licensing Board (or if the Licensing Board is unavailable, the Commission) may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter or issue, or (2) condition denial of the motion on just and reasonable terms.

IT IS SO ORDERED.

l 1

Peter B. Bloch, Chair l Dated at Rockville, Maryland this day of , 1995.

l 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 ) 425-OLA-3

.gJ; gb, )

) Re: License--Amendment (Vogtle Electric Generating ) (transfer to Southern Nuclear)

Plant, Unit 1 and Unit 2) )

) ASLBP No. 93-671-01-OLA i SUBPOENA OF LOUIS WARD In accordance with section 161(c) of the Atomic Energy Act, 1

42 U.S.C. S2201 (c) and 10 C.F.R. S2.720, Louis Ward is hereby ordered to appear and testify before the Atomic Safety and Licensing Board concerning the Phase II diesel' generator issues in the above captioned proceeding. You are to appear on May 17,

} 1995 at 9:00 a.m. or at another specified time during that or the following week, at a place yet to be determined by the Board.

i You are to bring with you all documents which fit the following description:

all documents, in your custody, control and/or possession, related to the subject area to which you have been called to tectify as set forth in Intervenor's Motion for the Issuance of Subpoenas. These documents shall include but are not~

limited to written,' recorded or graphic matter, however I

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t 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, cost sheet, list, graph, chart, index, tape, record, partial lor complete report of telephone or oral' conversation, tabulation, study, analysis, transcript, minutes, depositions and all memorials of any conversations, meetings, and conferences by telephone or otherwise, including personal notes, and any.other writing or recording.

On motion made promptly, and in any~ event received on or before May 17,.1995, and on notice delivered to Intervenor's counsel on or before that date, this_ Atomic Safety and Licensing Board (or if the Licensing Board is unavailable, the Commission) may (1) quash or modify the subpoena if it:is unreasonable or requires evidence-not relevant to any matter or issue, or (2) condition denial of the motion on just and reasonable terms.

l IT IS SO ORDERED.

Peter B. Bloch, Chair Dated at Rockville, Maryland this day of , 1995.

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

)

In the Matter of )

) Docket Nos. 50-424-OLA-3 l GEORGIA POWER COMPANY ) 50-425-OLA-3 31 aL., )

) Re: License Amendment (Vogtle Electric Generating ) (transfer' to Southern Nuclear) l Plant, Unit'l and Unit 2) ~ ) _ ,

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

i SUBPOENA OF GUSS WILLIAMS l

In accordance with section 161(c) of the Atomi Energy Act, i l

42 U.S.C. S 2201 (c) and 10 C.F.R. 52.720, Guss Williams is hereby i ordered to appear and testify before the Atomic Safety and l Licensing Board concerning the Phase II diesel generator issues in the above captioned proceeding. You are to appear on May 17, 1995 at 9:00 a.m. or at another specified time during that or the following week, at a place.yet to be determined by the Board.

You are to bring with you all documents which fit the following description:

all documents, in your. custody, control and/or possession, related to the subject area to which you have been called to tescify as set forth_in Intervenor's Motion for the Issuance of Subpoenas. These documents shall include but are not limited to written, recorded or graphic matter, however

produced or reproduced, of every kind and regardless of l where located, including but not limited to any summary, schedule, memorandem, note, statement, letter, telegram, l interoffice communication, report, diary, desk or pocket calendar or notebook, daybook, appointment book, phone logs, pamphlet, periodical, work sheet, cost sheet, list, graph, l chart, index, tape, record, partial or complete report of l telephone or oral conversation, tabulation, study, analysis, transcript, minutes, depositions and all memorials of any conversations, meetings, and conferences by telephone or otherwise, including personal notes, and any other writing or recording.

On motion made promptly, and in any event received on or before May 17, 1995, and on notice delivered to Intervenor's counsel on or before that date, this Atomic Safety and Licensing Board (or if the Licensing Board is unavailable, the Commission) may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter or issue, or (2) condition denial of the motion on just and reasonable terms.

IT IS SO ORDERED.

Peter B. Bloch, Chair Dated at Rockville, Maryland this day of , 1995.

f

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l 1

i UNITED STATES OF AMERICA

. NUCLEAR REGULATORY COMMISSION J ATOMIC SAFETY AND LICENSING BOARD' -

1 I

! ) l 1 l In the Matter of )

. ) Docket Nos. 50-424-OLA-3

GEORGIA POWER COMPANY ) 50-425-OLA-3 l

} 31 aL., ) '!

). Re: License Amendment l (Vogtle Electric Generating ) (transfer to Southern Nuclear) l j Plant, Unit 1 and Unit 2) ) l t ) ASLBP No. 93-671-01-OLA-3 I i

l i

SUBPOENA OF ALLEN FRANKLIN l

i j

i l In accordance with section 161(c) of the Atomic Energy Act, 42 U.S.C. 52201(c) and 10 C.F.R. S2.720, Allen Franklin is hereby

., i j ordered to appear and testify before the Atomic Safety and l Licensing Board concerning the Phase II diesel generator issues in the above captioned proceeding. You are to appear on May 17, 1995 at 9:00 a.m. or at another specified time during that or the i

i following week, at a place yet to be determined by the Board.

~

You are to bring with you all documents which fit the following description:

, all documents, in your custody, control and/or possession, related to the subject area to which you have been called to

, testify as set forth in Intervenor's Motion for the Issuance-1 of Subpoenas. These documents shall include but are.not limited to written, recorded or graphic matter, however 4

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l

, l 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,  :

l pamphlet, periodical, work sheet, cost sheet, list, graph, chart, index, tape, record, partial or complete report of

telephone or oral conversation, tabulation, study, analysis, .

transcript, minutes, depositions and all memorials of any i 1

conversations, meetings, and conferences by telephonelor j otherwise, including personal notes, and any other writing

or recording.

1

on motion made promptly, and in any event received on or.

. before May 17,.1995, and on notice delivered to Intervenor's J. counsel on or before that date, this Atomic Safety and Licensing j

Board (or if the Licensing Board-is unavailable, the Commission) ]

may (1) quash or modify the subpoena if it is unreasonable or-

! l

) requires evidence not relevant to any matter or issue, or (2) condition denial of the motion on just and reasonable terms.

i IT IS SO ORDERED. 1 1

i i Peter B. Bloch, Chair- j i

j Dated at Rockville, Maryland-1 this day of , 1995.

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l 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 l 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 l

l 1

SUBPOENA OF ESTER DIXON 1

In accordance with section 161(c) of the Atomic Energy Act, 42 U.S.C. S2201(c) and 10 C.F.R. 52.720, Ester'Dixon is hereby ordered to appear and testify before the Atomic Safety and Licensing Board concerning the Phase II diesel generator issues in the above captioned proceeding. You are to appear on May 17, 1995 at 9:00 a.m. or at another specified time during that or the following week, at a place yet to be determined by the Board.

You are to bring with you all documents which fit the following description:

all documents, in your custody, control and/or possession, related to the subject area tx) which you have been called to testify as set forth in-Intervenor's Motion for the Issuance of Subpoenas. These documents shall include.but are not limited to written, recorded or graphic matter, however

1 e

~

! produced orL reproduced, of every kind' and regardless of--

, where located, including but not limited to.any summary, I

schedule , -' memorandum, note, statement, letter,: telegram,.

interoffice communication, report,. diary, desk.or pocket j calendar.or notebook, daybook, appointment book,;phoneLlogs, .

i pamphlet, periodical,. work sheet, cost ~ sheet, list,:-graph, '

j chart,1index, tape, record, partial or complete-report of.

it telephone or' oral conversation, tabulation, study,. analysis, i transcript, minutes,Jdepositions'and all memorials.of-any.

{; conversationsi meetings, .and conferences by telephone ~ cur 4- otherwise, including personal notes, and any other. writing or recording.

~

on motion made promptly,Jand in any event received-onlor

[

! before May 17, 1995, and on' notice delivered to Intervenor's

counsel on or before that-date, this Atomic Safety and Licensing-1

Board (or.if the Licensing.Boardlis unavailable, .the Commission) j may (1)f quash-or modify the subpoena if it is unreasonable-.or i requires evidence not relevant to any matter or issue, or (2) 1 4

l condition denial of the motion.on just:and reasonable terms. l r  ;

i

!- )

[

3 IT IS SO ORDERED. I l

l li - Peter B. Bloch, Chair i

1 1

Dated at Rockville, Maryland .

I i this day of , 1995. l i

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I 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 31 gL., )

) Re: License Amendment (Vogtle Electric Generating ) (transfer to Southern Nuclear)-

Plant, Unit 1 and Unit 2) )

) ASLBP No. 93-671-01-OLA-3 SUBPOENA OF MICHAEL DUNCAN In accordance with section 161(c) of the Atomic Energy Act, 42 U.S.C. S2201(c) and 10 C.F.R. 52.720, Michael Duncan is hereby ordered to appear and testify before the Atomic Safety and i Licensing Board concerning the Phase II diesel generator issues l

in the above captioned proceeding. You are to appear on May 17, j l

1995 at 9:00 a.m. or at another specified time during that or the following week, at a place yet to be determined by the Board.

You are to bring with you all documents which fit the following description:

all documents, in your custody, control and/or possession, related to the subject area to which you have been called to-testify as set'forth in Intervenor's Motion for the Issuance of Subpoenas. These documents shall include but are not limited to written, recorded or graphic matter, however 1

produced or reproduced, of every kind'and regardless of where located, including but not limited to any summary, I 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  ;

te?ephone or oral conversation, tabulation, study, analysis, transcript, minutes, depositions and all memorials of any conversations, meetings, and conferences by telephone or otherwise, including personal notes, and any other writing or recording. I on motion made promptly, and in any event received on or i before May 17, 1995, and on notice delivered to Intervenor's counsel on or before that date, this Atomic Safety and Licensing Board (or if the Licensing Board is unavailable, the Commission) ,

1 may (1). quash or modify the subpoena if it is unreasonable or l

~

l requires evidence not relevant to any matter or issue, or.(2) I condition denial of the motion on just and reasonable ~ terms.

l l

IT IS SO ORDERED.

J Peter B. Bloch, Chair' Dated at Rockville, Maryland this day of ,-1995.

l l

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! I 1

l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD j

)

In the Matter of )

) Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY ) 50-425-OLA-3' l SL AL., )

, ) Re: License Amendment

, (Vogtle Electric Generating ) (transfer to- Southern Nuclear)

Plant, Unit 1 and Unit 2) )

, ) ASLBP No. 93-671-01-OLA-3 l I

SUBPOENA OF MICHAEL HOBBS In accordance with section 161(c) of the Atomic Energy Act, 42 U.S.C. S2201(c) and 10 C.F.R. S2.720, Michael.Hobbs is hereby i ordered to appear and testify before the Atomic Sa'etyf and Licensing Board concerning the Phase II diesel generator issues in the above captioned proceeding. You are to appear on May 17, 1995 at 9:00 a.m. or at another specified time during that.or the following week, at a place yet to be determined by the Board.

You are to bring with you all documents which fit the following description:

i all documents, in your custody, control and/or possession, related to the subject area to which you have been called to testify as set forth in Intervenor's Motion for the Issuance 4 of Subpoenas. These documents shall include but are not limited to written, recorded or graphic matter, however h

4 5

I T 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,1 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, tabulation,1 study, analysis, transcript, minutes, depositions and all memorialslaf any )

conversations, meetings, and conferences by-telephone or- 1 otherwise, including personal notes,-and any'other writing or recording.

On motion made promptly, and in any event received on or before May 17, 1995, and on notice delivered to Intervenor's counsel on or before that date, this Atomic Safety and Licensing Board (or if the Licensing Board is unavailable, the commission) may (1) quash or modify the subpoena if it is unreasonable or requires evidence not relevant to any matter or issue, or (2) condition denial of the motion on just and reasonable terms.

l IT IS SO ORDERED. {

l Peter B. Bloch, Chair

)

i Dated at Rockville, Maryland j this day of , 1995. 1 l

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 e.t A L ., )

) Re: License Amendment (Vogtle Electric Generating ) (transfer to Southern Nuclear)

Plant, Unit 1 and Unit 2) )

) ASLBP No. 93-671-01-OLA-3 SUBPOENA OF MARK AJULUNI In accordance with section 161(c) of the Atomic Energy Act, 42 U.S.C. S2201(c) and 10 C.F.R. S2.720, Mark Ajuluni is hereby ordered to appear and testify before the Atomic Safety and Licensing Board concerning the Phase II diesel generator issues l in the above captioned proceeding. You are to appear on May 17, 1995 at 9:00 a.m. or at another specified time during that or the l following week, at a place yet to be determined by the Board.

You are to bring with you all documents which fit the following description:

all documents, in your custody, control and/or possession, related to the subject area to which you have been called to testify as set forth in Intervenor's Motion for the Issuance of Subpoenas. These documents shall include but are not limited to written, recorded or graphic matter, however

4

-produced or reproduced, of'every kind and regardless of where located, including but not limited to any summary, l 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,-tabulation, study, analysis,

< transcript, minutes,-depositions-and all memorials of any

. conversations, meetings,-and. conferences by telephone'or otherwise,nincluding personal notes,'and any other writing _

or recording.

On motion made promptly, and in any event received on or-i . ..

i before May 17, 1995, and on notice delivered to Intervenor's counsel on-or before that date, this Atomic safety..and Licensing j Board (or if the Licensing Board is unavailable, the commission) may z (1) quash or modify the subpoena if it is unreasonable or' requires evidence not relevant to any_ matter or issue,.or'(2).

condition denial'of.the motion'on:just and reasonable terms.

2 IT IS SO ORDERED.

f 2

Peter B. .Bloch, Chair 1

1 I

Dated at Rockville, Maryland this day of , 1995.

l 1-

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