ML20078P657

Intervenor List of Exhibits for Phase I Hearing on License Transfer Issues.* Lists Witnesses for Proceedings Related to Improper Transfer of Control of Util License & False or Misleading Info.Related Correspondence

ML20078P657
Person / Time
Site:	Vogtle
Issue date:	12/12/1994
From:	Kohn M KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20078P652	List: ML20078P649 ML20078P657 ML20078P664 ML20078P671
References
93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9412190155
Download: ML20078P657 (9)

Text

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UNITED STATES OF AMERICA 0FFici nr STCNRny NUCLEAR REGULATORY COMMISSION 00G;F i .,

ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges: .

Peter B. Bloch,' Chair Dr. James H. Carpenter Thomas D.' Murphy' i o

)

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 LIST OF EXHIBITS FOR THE

" PHASE I" HEARING ON LICENSE TRANSFER ISSUES 1

LIST OF EXHIBITS Exhibit 1- Vogtle Project /Vogtle Duty Manager Schedule.

l Exhibit 2- Fourth Quarter 1989 On-Call Project Manager J Telephone List.

l Exhibit 3- Partial Transcript of Mosbaugh tape 259 side A, I 5%. l I

. Exhibit 4- Partial Transcript of Mosbaugh tape 260, side.A '

(Partial-l transcript based on hand written  ;

corrections of Steve Chestnut). ->

Exhibit 5- Partial Transcript of Mosbaugh tape 236, side A,  ;

50%.

Exhibit 6- Partial Transcript of Mosbaugh tape 259, side A, 75%.

Exhibit 7- 1990 PPP Survey, dated April 4, 1990.

Exhibit 8- 1990 Performance Pay Play Survey Optional Comments.

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e Exhibit 9- . Partial Transcript of Mosbaugh tape 236 side A, 25%.

. Exhibit 10- Excerpts from the Deposition of William Shipman deposition taken on 8/5/94, .and continuation thereto.

Exhibit 11- " Synopsis", April 6, 1990, Vol. II, No. 7.

Exhibit'12- ~ Performance Appraisal of Marvin B. Hobby, 1-01-88.

Exhibit 13- December 27, letter from Dahlberg establishing NOCA.

Exhibit 14- Affidavit of Thomas J. McHenry dated 9-16-90.

Exhibit 15- Position Questionnaire of Marvin B. Hobby dated 1-16-89.

Exhibit 16- Personnel Requisition dated 3-2-89.

Exhibit 17- Transcript of NRC proceeding dated March 30, 1989, including hand-written marginalia comments of Dan Smith.

Exhibit 18- Corporate Concern No. 89E0086, prepared for L.B.

Glenn to discuss with H.G. Baker. ,

Exhibit 19- June 8, 1989 letter from Marvin Hobby to Admiral Dennis Wilkinson.

Exhibit 20- Excerpts of October 25, 1989 memo from Bob Edwards to Marvin Hobby regarding Nuclear Operating Agreements.

Exhibit 21- Excerpts from the deposition of H.G. Baker taken on April 8, 1994.

Exhibit 22- Affidavit of Marvin B. Hobby dated October 3, 1994.

Exhibit 23- Excerpts from the deposition of Robert Scherer taken on June 8, 1994.

Exhibit 24- Excerpts from the deposition of Louis Brian Long taken on June 8, 1994.

Exhibit 25- Excerpts from the deposition of Joseph M. Farley taken on April 14, 1994.

.2

Exhibit 26- Excerpts from the deposition H.G. Baker in Hobbv

v. GPC taken on May 23, 1990.

Exhibit 27- Excerpts.from'the deposition of Robert W. Scherer in Fuchko and Yunker v. GPC, DOL Case Nos. 89-ERA 9 and 89-ERA-10 ("Fuchko and Yunker v. GPC") taken on December 21, 1988.

Exhibit 28- Excerpts from the deposition of George Hairston taken on April 13, 1994.

Exhibit 29- Excerpts from William Shipman's notebook.

Exhibit 30- October 7, 1988 SCS Announcement.

Exhibit 31- Addison's appointment calendar for February 14, 1989 and March 6, 1989.

Exhibit 32- Dahlberg's appointment calendar for March 6, 1989.

Exhibit 33- Excerpts of Southern Nuclear Board Meeting Minutes.

Exhibit 34- Hand-written notes of Corporate Secretary taken ducing August 5, 1991 Southern Nuclear Board Meeting.

Exhibit 35- Excerpts of phone log of Marvin Hobby.

Exhibit 36- Excerpts from deposition of R.P. Mcdonald taken on April 14, 1994.

Exhibit 37- March 16, 1988 memo from McHenry to Mcdonald.

Exhibit 38- Motion to Intervene, Comments, and Request for Hearing of Oglethorpe Power Corporation, Ihg Southern comnany et.al. SEC Admin. Proc. No. 70-7530.

Exhibit 39- Reply to the Southern Company's Response to Oglethorpe Power Company's Motion to Intervene, Comments and Request for Hearing, The Southern Comnany et.al. SEC Admin. Proc. No. 70-7530.

Exhibit 40- The Southern Company's 10-K Report for fiscal year ended December 31, 1993, p. I-13, III-4 to III-6.

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' Exhibit 41- Partial transcript of Mosbaugh Audio Tape No.~260, Side A with handwritten corrections made by Steve Chestnut.

Exhibit 42- Excerpts from the deposition of R.P. Mcdonald in Fuchko and Yunker v. GEC, Dept. of Labor Case Nos.

89-ERA-9 and 89-ERA-10 taken on December 23, 1988.

Exhibit 43- Excerpts from the deposition of Gerald Johnson in Hobbv v. GPC taken on October 2, 1990.

Exhibit 44- Excerpts from the deposition of Dan Smith taken on April 12, 1994.

Exhibit 45- Excerpts from the trial testimony in Hobbv v. GPC.

Exhibit 46- Memos from M.T. Brown to Farley, et al, dated September 19, 1989 and September 15, 1989.

Exhibit 4 ', -- Joint Stipulation (including all attached exhibits).

Exhibit 48- GPC's April 1, 1991 response to Intervenor's 2.206 Petition (including attachments).

Exhibit 49- Request for Proceedings and Imposition of Civil Penalties for Improperly Transferring Control of Georgia Power Company's Licenses to the SONOPCO Project and for the Unsafe and Improper Operation of Georgia Power Company Licensed Facilities, dated September 11, 1990, pp 2-8 and 13-16.

Exhibit 50- Intervenor's October 1, 1990 supplement to the 2.206 petition.

Exhibit 51- September 11, 1989 memo from Townley to Whitney, Re: Nuclear Cost Comparison.

Exhibit 52- Excerpts from the hearing testimony in Fuchko and Yunker v. GPC, . Dept. of Labor Case Nos. 89-ERA-9 and 89-ERA-10.

Exhibit 53- Deposition of Edward L. Addison taken on June 9, 1994.

l Exhibit 54- Deposition of A.W. Dahlberg taken on April 6, i 1994.

Exhibit 55- Deposition of A.W. Dahlberg taken on June 10, 1994.

4

1 Exhibit 56- Deposition of Charles K. McCoy taken on April 6, 1994.

1 Exhibit' 57- Deposition of Jeff Wallace taken on June 13, 1994. l Exhibit 58- Deposition of H.G. Baker in Hobby, taken on May 23, 1990.

Exhibit 59- Deposition of William R. Evans in Hobby, taken on August 23, 1990.

Exhibit 60- Deposition of Lee B. Glenn in Hobby, taken on August 23, 1990.

I Exhibit 61- Deposition of A.W. Dahlberg in Hobby, taken May 8, l 1990.  !

Exhibit 62- Deposition of R.P. Mcdonald in Hobby, taken on May 7, 1990.

Exhibit 63- Deposition of R.P. Mcdonald in Hobby, taken on August 23, 1990.

Exhibit 64- Deposition of A.W. Dahlberg taken July 1994.

Exhibit 65- Deposition of Joseph Farley taken on July 25, 1994.

Exhibit 66- Affidavit of Joseph Farley.

Exhibit 67- 11/20/90 memo from C.E. Crosby to Farley, et al.,

and attachments thereto.

Exhibit 68- March 30, 1994 letter from Lamberski to Barth '_

(with attachments).

Exhibit 69- April 24, 1989 letter from Mcdonald to Franklin.

Exhibit 70- Deposition of Fred D. Williams in Hpbby.

Exhibit 71- Hobbv proceeding record, including recommended decision.

Exhibit 72- Deposition of Carey Don Proctor in Hobby, taken on October 2, 1990.

Exhibit 73- Deposition testimony of Jesse Schaudies in Hobby, taken on August 23, 1990.

Exhibit 74- Deposition of George Hairston taken in July, 1994.

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Exhibit 75- Deposition of C. K McCoy taken on July 26, 1994.

I. Exhibit 76- Deposition of R. P. Mcdonald taken on July 25, 1994.

p Exhibit 77- Deposition of James Bailey.

l Exhibit 78- Deposition of Paul Rushton taken on July 20, 1994.

Exhibit 79- October 3, 1991 Georgia Power supplement to its 2.206 Petition response.

Exhibit 80- December 10, 1991 Georgia Power supplement to its 2.206 Petition response.

Exhibit 81- July 7, 1993 letter from Addison to Sen. Bob Graham.

Exhibit 82- 1/12/88 draft of SONOPCO president responsibility statement.

Exhibit 83- May 3, 1988 memo from McHenry to Mcdonald.

Exhibit 84- Duty Manager Phone Numbers, On call Project Managers.

Exhibit 85- SONOPCO Project Detail Telephone Billing Report.

]

Exhibit 86- April 20, 1989 memo from Gilbert to Beckham, Long, McCoy, Woodard, Meggs.

]

Exhibit 87- " Synopsis", December 1988.

Exhibit 88- " Synopsis", March 7, 1989 Vol. I, No. 4.

Exhibit 89- " Synopsis", March 30, 1989 Vol. I, No. 6.

Exhibit 90- " Synopsis", Dec. 11, 1989 Vol. I, No. 22.

Exhibit 91- " Synopsis", January 1991 Vol. III, No. 1.

Exhibit 92- "This Week Georgia Power", May 19, 1988.

Exhibit 93- "This Week Georgia Power", September 22, 1988.

Exhibit 94- "This Week Georgia Power", October 13, 1988.

Exhibit 95- "This Week Georgia Power", November 3, 1988. l I

Exhibit 96- "This Week Georgia Power", April 27, 1989, p. 1.

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. . l Exhibit 97- "This Week Georgia Power", January 5, 1990.

Exhibit 98- " News", May 18, 1988.*

Exhibit 99- " News", December 18, 1990.

Exhibit 100- December 17, 1990 announcement entitled " Southern Nuclear Incorporates".

Exhibit 101- December 19, 1990 announcement entitled " Southern-1 Nuclear board elects officers".

Exhibit 102- June 3, 1991 announcement entitled " Company: l Three-phased transition under way". l Exhibit 103- Speech outline for administrative services VP I Charles McCrary for use at other system companies.

Exhibit 104- All purpose speech for external audiences 1989.

Exhibit 105- Agenda for NRC Management Meetings. Identified as 92 Project 072114-072118.

Exhibit 106- Agenda for NRC Management Meetings (copy faxed to SCS Fuel Services February 12, 1988). Identified as 92 Project 072119-072121.

Exhibit 107- Technical Qualifications of SONOPCO.

Exhibit 108- March 2, 1988 to NRC from L.T. Gucwa, Manager of Nuclear Safety regarding changes to GPC's Nuclear Operations organization.

Exhibit 109- March 4, 1988 Intracompany Correspondence to file from L.B. Long regarding March 2, 1988 meeting with NRC.

Exhibit 110- March 15, 1988 Intracompany Correspondence from L.B. Long regarding upcoming meeting with-NRC.

Exhibit lil- March 21, 1988 Intracompany Correspondence form L.B. Long regarding March 18, 1988 meeting with NRC (with exhibits).

Exhibit 112- " Nucleonics Week", March 24, 1988 p. 13.

Exhibit 113- March 30, 1988 letter to NRC from P.D. Rice. l (Enclosures) l I

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" News" is a Southern Company publication.

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-- y Exhibit 114- May 5, 1988 letter to H.G. Baker from R.P.

Mcdonald.

Exhibit 115- June 1, 1988 letter to NRC from R.P. Mcdonald.

Exhibit'116- June 15, 1988 letter to file from John Meier.

Exhibit 117- August 12, 1988 letter to NRC from Hairston.

' Exhibit 118- May 3, 1990 Memo for File from R.P. Mcdonald.

Exhibit 119- APPLICATION TO AMEND FACILITY OPERATING LICENSE NOS. NPF-68 AND NPF-81, dated September 4, 1992.

Exhibit 120- May 1, 1989 letter from Hairston to NRC correcting Full Power License Hearing Transcript.

Exhibit 121- Excerpts of Michael Barker Day Timer.

Exhibit 123- Organizational chart which depicts the actual organization structure.

Exhibit 124- Licensee's response to 2.206 petition including all amendments, supplements, attachments and exhibits.

Exhibit 125- Vogtle Emergency Plan Implementing Procedure DNS-EP-04 rev 0-present duties of the on-call project manager.

Exhibit 126- Corporate Emergency Telephone Directory Vogtle Project all rev 1988-present.

Exhibit 127- VEGP Administrative Procedure 00007-C rev 0-present, Vogtle Duty Manager / Response Team.

Exhibit 128- VEGP Emergency Plan all rev 88-present, including all appendices and attachments.

Exhibit 129- 8-30-94 letter from Hairston to Russell Exhibit 130- 9-2-94 letter From Lamberski to Barth.

Exhibit 131- Vogtle Project / Duty Manager Schedule 1-9-90.

Exhibit 132- Crisis Management plan September 1992.

Exhibit 133- Corporate Emergency Organization Notification Tree, Figure C-1.

[ Signature on next page]

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Respectfully submitted, W #

Michael D. Kohn KOHN, KOHN AND COLAPINTO, P.C. ,

517 Florida Ave., N.W.

Washington, D.C. 20001 (202) 234-4663 Attorneys for the Intervenor 6

Dated: December 12, 1994 C:\ FILES \301\ EXHIBIT.LST i

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