ML20149E391

Intervenor Notice of Deposition of K Burr.* Provides Notice That Commencing on 940524,counsel for Intervenor Will Take Deposition Upon Oral Exam of K Burr,Believed to Be Employee of Southern Nuclear Operating Co

ML20149E391
Person / Time
Site:	Vogtle
Issue date:	05/13/1994
From:	Kohn M KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA
To:
Shared Package
ML20149E366	List: ML20149E362 ML20149E369 ML20149E391 ML20149E400
References
93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9405310077
Download: ML20149E391 (2)

Text

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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 at alt, )

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

Plant, Unit 1 and Unit 2) )

) ASLBP No. 93-671-01-OLA-3 INTERVENOR'S NOTICE OF DEPOSITION OF KEN BURR Intervenor, pursuant to 10 C.F.R. 52.740a(a), hereby provides notice that commencing at 10:00 AM, on May 24, 1994, counsel for Intervenor will take the deposition upon oral examination of KEN BURR, who is believed to be an employee of Southern Nuclear Operating Company. The location of the deposition shall be the law offices of KOHN, KOHN & COLAPINTO, P.C., located at 517 Florida Ave., N.W., Washington, D.C.

The witness is directed to bring with him all materials in his inmediate control or possession (or in the immediate control or possession of his employer or counsel) that (1) contain the hand writing, thoughts or impressions of the witness that in any way relate to the Site Area Emergency which occurred at Plant Vogtle on March 20, 1990 or the response to that event, including all materials concerning any drafts of letters _or other door .s that relate in any way to facts set out in the May 9, 1994 Nuuice of Violation issued by the Nuclear Regulatory Commission to-Georgia Power Company; (2) all information directly or indirectly relating to the reliability of the Plant Vogtle diesel generators, and information transmitted between Birmingham 9405310077 940513 PDR 0 ADOCK 05000424 PDR

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corporate offices that in any way concerns the diesel generators or site area emergency or information transmitted to the NRC concerning the diesel generators or site area emergency; and (3) all personally notes, log books, note books, personal calendars, tape memos, tape recordings or other documentation prepared by the witness or which includes the thoughts or impressions of the witness for the time period of March 20, 1990 and December 31, 1990.

This deposition shall continue until the witness has fully testified to the matters pertaining to the admitted' contentions (excluding license transfett in this proceeding and to matters generally discoverable as background material and relevant to

.said contentions.

Pursuant to 10 C.F.R. $2.70a(h), Intervenor will transmit to the witness at the time of his appearance all required fees ($40 witness fee and $328 travel allowance -- which assumes that Mr.

Burr will be traveling between Birmingham, Alabama and Washington, D.C.).

Intervenor requests that any objection to the production of documents set out in this notice be transmitted in writing to counsel for Intervenor by May 20, 1994.

Respectfully submitted, W /

Michael D. Kahn Kohn, Kohn & Colapinto, P.C.

517 Florida Ave., N.W.

Washington, D.C. 20001 (202) 234-4663 301\ notice.KB 2

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