ML20091H825
| ML20091H825 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/19/1995 |
| From: | LABOR, DEPT. OF |
| To: | |
| References | |
| OLA-3-A-130, NUDOCS 9508140234 | |
| Download: ML20091H825 (4) | |
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DOCKETED USNRC Page 236 95 JUL 27 P4 :42 BEFORE THE UNITED STATES DEPARTMENT OF0f5&6R0F SECRETARY 00CKEllHG & SERVICE BRANCH ALLEN L. MOSBAUGH, a
VOLUME 11 Complainant, a
Case Nos. 91-ERA-01 vs.
91-ERA-11
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GEORGIA POWER COMPANY, a
Respondent.
Hearing Room A, Suite 2400, 101 Marietta Tower, 101 Marietta Street, N.W.,
Atlanta, Georgia Wednesday, March 11, 1992 7
The above-entitled matter came on for hearing, pursuant to Adjournment, at 9:00 a.m.
BEFORE:
HON. ROBERT M. GLENNON, Administrative Law Judge APPEARANCES:
Qn behalf 91 the comolainant:
MICHAEL D. KOHN, Attorney, STEPHEN M. KOHN, Attorney, Kohn, Kohn & Colapinto, 517 Florida Avenue, N.W.,
Washington, D.C.
20001 SANDRA MICHAELS, Attorney, 142 Mitchell Street, S.W.,
Suite 300, Atlanta, Georgia 30303 NUCLEAR REGULATORY COMMISSI'ON Cf(
E-130 Docket No. 50-4?4/425-OLA-3 EXHIBIT NO.
in the matter of Geornia Power Co. et al.. Vontle Units ' & 2 g identifi[ed
^PP cant O lntervenor D Other li QStaff 9508140234 950719 QQ Received O Rejected Reporter KHQ PDR ADOCK 05000424 PDR Date 7 l l') l') f witness
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Page 287 I
1 of Georgia Power management that I wanted confidential 1
2 treatment.
3 Q.
And after when you saw --
What was your 4
relationship with Mr. Robinson in terms of contact and 5
communications?
And I'm not looking for the substance of i
6 what was said, but just in terms of their number after this 7
document was signed.
?
8 A.
It seems like over the summer, something like June 4
9 on, I believe I met with Mr. Robinson in the evening for i
10 periods of four or five hours on four different occasions, 11 and two of those occasions there was sworn testimony i
l 22 involved.
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13 And then I had telephone contacts with Mr. Robinson 14 probably averaging one or two a week over the summer.
l 1E MR. STEPHEN KOHN:
Your Honor, could we have a 16 short recess?
j 17 JUDGE GLENNON:
How long?
18 MR. STEPHEN KOHN:
Just five minutes.
4 19 JUDGE GLENNON:
We'll take a short recess, about 20 five minutes.
F@
M 21 (A brief recess.)
N i
22 JUDGE GLENNON:
Let's resume the hearing.
23 BY MR. STEPHEN KOHN:
24 Q.
Calling your attention again to Complainant's 25 Exhibit 45, I notice that it's signed and dated on June 14th,
l
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.Page 288-1 1990.
When did you --
Did you meet with Mr. Robinson in or i
j 2
about that time?
l-3 A.
Yes, I did.
I 4'
Q.
On what date?
l l
5 A.
It seems like I remember meeting with him on like 6
the evening of the 13th and the 14th of June, two days I l
i 7
think.
8 Q.
When you met with Mr. Robinson in that time period i
l 9
did you give him anything?
i l
10 A.
Yeah.
I brought a number of detailed written 1
l 11 allegations to him.
12 I made reference earlier I think that after I had 13 found the information' submitted in the LER to be false I j
14 think I mentioned earlier that I had started drafting an 15 allegation.
I 16-I brought to Mr. Robinson a number of very detailed
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i 17 written allegations, and I believe with the execution of that i
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18 confidentiality agreement, you know, I provided all those 1
j 19 written allegations to Mr. Robinson.
j 20 Q.
Did you use anything to help you when you were i
j 21 drafting those written allegations?
i j
22 A.
I guess I'd like to'say about the allegations, you j
23 know, this was the most serious, you know, I think of all the i
24
-allegations, and I gave them to him at this time, and I had 25 started preparing that back in the late April time frame, i
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i Page 289 1
and, yeah, I spent a lot of time, I took a lot of work trying 2
to, you know, get it in the sequence of events and the things i
3 that happened to be extremely accurate.
4 I reviewed a lot of documentation, I used my tape j
5 recordings, I would relisten to segments of the tape 6
recordings to make sure that my recollection was exactly true l
7 and so that I could write a factual allegation that would be, l
8 you know, perfectly accurate and true, and then I gave those 9
to Mr. Robinson.
t l
10 Q.
At this time did you tell Mr. Robinson that you had i
11 utilized tape recordings to prepare this documentation?
f 12 A.
No.
The documents -- the documents were very high 4
i i
13 quality and very detailed, and because of the way they had l
14 been prepared they were certainly as much as I felt -- you j
15 know, I felt, you know, that they spoke for themselves, they 16 were an accurate reflection of what had happened.
l 17 Q.
Did you tell Mr. Robinson that you had tape 18 recordings?
19 A.
No, I didn't.
20 Q.
Why not?
21 A.
Well, I guess I felt that I had what seemed to me 22 to be a bad experience initially, I felt I had been found out l
23 on the dilution valves allegation that I had sent in, and I didn't expect anybody to recognize that it might have been me 24 i
25 despite all the preparations I had made, and at this point 1
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