ML20084L287
| ML20084L287 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/24/1995 |
| From: | Doris Lewis GEORGIA POWER CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#295-16742 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9506070159 | |
| Download: ML20084L287 (20) | |
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L l(pf 00CKETED USHRC May 24,1995 UNITED STATES OF AMERICA '95 MY 25 P2 :01 NUCLEAR REGULATORY COMMISSION OFFICE OF SECRETARY Dsfore the Atomic Safety and Licensing B_oggCKETggERVICE i
In the Matter of ) Docket Nos. 50-424-OLA-3
) 50-425-OLA-3
- GEORGIA POWER COMPANY, )
et.al. ) Re: License Amendment
) (Transfer to Southern Nuclear)
(Vogtle Electric Generating Plant, )
Units I and 2) ) ASLBP No. 93-671-01-OLA-3 1 i
MOTION BY GEORGI A POWER COMPANY, CilARLES L. COURSEY, MICilAEL L. IlOBBS, AND R.P. MCDONALD ,
TO QUASil TIIE SUBPOENAS OF Cil ARLES L. COUESEY. MICilAEL L. IlOBBS. AND R.P. MCDONALD
- 1. Introduction i
Pursuant to 10 C.F.R. Q 2.720(f), Georgia Power Company (" Georgia Power"), Charles L. Coursey, Michael L. Ilobbs, and R.P. Mcdonald move to quash the subpoenas issued on be- j half ofIntervenor on April 5,1995, for the appearances and testimony of Messrs. Coursey, llobbs, and Mcdonald. These subpoenas should be quashed because they are unreasonable. I They seek the presence of witnesses in order to elicit testimony on matters of which the subpoe-naed individuals have no personal knowledge. They also seek testimony on areas previously ruled to be irrelevant by the Board. In addition, none of the subpoenas have been properly served be-cause no witness fees were incit M.
M Messrs. Coursey, llobbs, and Mcdonald have requested counsel for Georgia Power to submit this Motion on their behalf. Georgia Power also submits this Motion on its own behalf, as an employer and as a party that would l be adversely affected by the unnecessary and immaterial testimony sought by Intenenor. j 9506070159 950524 PDR O
ADOCK 05000424 0) .
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. l Specifically, the subpoena to Mr. Coursey should be quashed because, as far as Geor-gia Power can determine, Intervenor wishes to elicit vague hearsay testimony concerning wa-ter in the diesel air system. Mr. Coursey has no personal knowledge on this topic -- indeed, even his recollection of hearsay statements is vague. Ilis testimony on this subject would therefore have no probative value. The subpoena to Mr. Ilobbs should similarly be quashed because he has no personal knowledge of the pertinent facts of this case. The subpoena to Mr.
Mcdonald should be qutshed because he has little firsthand knowledge of the underlying facts of this case. Any testimony that is sought from Mr. Mcdonald would merely be cumulative of testimony that has been and will be given by other Georgia Power witnesses. Accord-1 ingly, his subpoena should also be quashed.
- 11. The Subpoenas are Unreasonable l
The Commission's Rules of Practice, at 10 C.F.R. Q 2.720(f) authorizes the Licensing l
Iloard to quash any subpoena that is unreasonable, or requires evidence not relevant to any matter in issue. In addition, the lloard also has the power "to limit the number of witnesses whose testimony may be cumulative," and "to strike argumentative, repetitious, cumulative, or irrelevant evidence." 10 C.F.R. Q 2.757(a), (b). SS also 10 C.F.R. Q 2.718; Statement of Policy on Conduct of Licensing Proceedings, CLI-81-8,13 N.R.C. 452 (1981). The Board Chairman has expressed " frustration" that this proceeding has not "run effectively and effi-ciently." lie specifically asked "[ilf the parties can figure [it] out, I would be willing to go with the plan." llearing Tr., May 19,1995, at 4542. This is such an opportunity to bring l
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' discipline to the proceeding. The Board should quash each of the three subpoenas for the rea-sons specified below.
Subpoena to Charles L. Coursey
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Mr. Coursey was apparently subpoenaed by Intervenor to testify on alleged moisture m j the Vogtle diesel air system.F We surmise that intervenor seeks to introduce Mr. Coursey's testimony that he heard "there was some moisture drained out of one of the lines." Deposition of Charles L Coursey, July 20,1994, at 9. As can be seen from the transcript of his July 20,1994 deposition, Mr. Coursey's testimony on alleged findings of moisture in air lines is hardly probative of the issues in this case.E Mr. Coursey could not identify when the alleged moisture drainage occurred, or even ;
i how he heard about it, lie also testified that he had no personal knowledge concerning ajar of I fluid collected from a trip line. Id. at 10. Mr. Coursey's testimony concerning alleged mois-ture drainage is not based on personal knowledge. See Fed. R. Evid. 602 ("A witness may not testify to a matter unless evidence is introduced sufficient to support a finding that the wit- ,
ness has perwnal knowledge of the matter"). This testimony has no probative value, and is j unreliable because it is based on unidentified hearsay, which the Board has already ruled Hintervenor's Motion for issuance of Subpoenas Regarding GPC Witnesses, Apr. 3,1995 at 8 (Coursey items a0 L'Pages 910 of the Coursey Deposition are attached hereto (Attachment 1). This deposition transcript has not been reviewed by the witness for its accuracy; indeed. Intervenor failed to produce the transcript in time for its use during this hearing. Georgia Power submits this portion of the transcript only to illustrate the lack of proba-tive value that would be provided by Mr. Coursey's testimony.
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4 discipline to the proceeding. The Board should quash each of the three subpoenas for the rea-sons speciDed below.
Subpoena to Charles L. Coursey l
Mr. Coursey was apparently subpoenaed by Intervenor to testify on alleged moisture in the Vogtle dicsci air system.7' We surmise that Intervenor seeks to introduce Mr. Coursey's ,
testimony that he heard "there was some moisture drained out of one of the lines." Deposition -
of Charles L. Coursey, July 20,1994, at 9. As can be seen from the transcript of his July '
20,1994 deposition, Mr. Coursey's testimony on alleged findings of moisture in air lines is hardly probative of the issues in this case.
Mr. Coursey could not identify when the alleged moisture drainage occurred, or even how he heard about it. lie also testified that he had no personal knowledge concerning a jar of i
fluid collected from a trip line. Id. at 10. Mr. Coursey's testimony concerning alleged mois-ture drainage is not based on personal knowledge. See Fed. R. Evid. 602 ("A witness may not testify to a matter unless evidence is introduced sufficient to support a Onding that the wit-ness has personal knowledge of the matter"). This testimony has no probative value, and is unreliable because it is based on unidentified hearsay, which the Board has already ruled E intervenor's Motion for issuance of Subpoenas Regarding GPC Witnesses, Apr. 3,1995 at 8 (Coursey items a f).
E Pages 910 of the Coursey Deposition are attached hereto (Attcchment 1). This deposition transcript has not been reviewed by the witness for its accuracy; indeed. Intervener failed to produce the transcript in time for its use during this hearing. Georgia Power submits this portion of the transcript only te illustrate the lack of proba-tive value that would be provided by Mr. Coursey's testimony.
inadmissible.E See Tennessee Valley Authority (llartsville Nuclear Plant, Units I A,2A, IB, 28), ALAB-367,5 NRC 92,121 (1977) (hearsay evidence must be reliable); see also Com-monwealth Edison Co. (Braidwood Nuclear Power Station, Units 1 aad 2), LBP-86-12,23 NRC 414, 419 (1986).
Intervenor also states that be wishes to question Mr. Coursey, as well as Mr. Ilobbs, on alleged false statements in the Georgia Power July 31,1994 response to the NRC's Notice of Violation. Intervenor's Motion for Subpoenas at 8,13. This assertion is vague to the point of being meaningless. Based on Intervenors' deposition of Mr. Coursey, Georgia Power is unaware of any topic other than air quality that Mr. Coursey can provide testimony on.
There is no evidence that either Mr. Coursey or Mr. Ilobbs had any role in preparation of the July 31,1994 response to the NOV. There is no reason for their testimony on this issue, which would lack personal knowledge and merely cause delay in the proceeding.
In addition, Intervenor seeks to question Mr. Coursey on "[ flailing to recognize condi-tions adverse to quality and take appropriate corrective actions for the root cause of the diesel failures during the site area emergency." Intervenor's Motion for Subpoenas at 8 (emphasis added). Intervenor's request to admit root cause testimony was rejected by the Board.
Memorandum and Order (Motion to Strike Mosbaugh Testimony), May 11,1995 at 21-22.
Accordingly, Intervenor should not now be p ..uited to seek additional testimony on root
. cause issues.
Ehlemorandum and Order (h10 tion to Strike hiosbaugh Testimony), h1ay 11.1995, at 14 ("If the identity of the speaker is not revealed it is not subject to appropriate cross-examination").
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Subpoena to Michael L. Ilobbs l
Like Mr. Coursey, Mr. Ilobbs lacks personal knowledge of the pertinent facts at issue '
in this proceeding. For example, he testified in his deposition that he was not involved in looking at diesel generators after the site area emergency; he could not recall whether there was an increase in frequency of dew point readings after the SAE; he could not recall any communications with Mr.130ckhold after the SAE concerning higher than expected dewpoint readings; and could not recall any problems with dewpoint test equipment. Deposition of Mi-chael llobbs, Aug. 4,1994, at 4-5,18,27." Even this last poimsi.. h,iowledge of problems l
I with test equipment) has no probative value, because Mr. Ilobbs was on temporary assignment during the 1990 outage at Plant Vogtle and was not involved in any dewpoint measurement at that time." Mr. Ilobbs' testimony is not probative of any issue in this proceeding.
Subpoena to R.P. Mcdonald l
The subpoena to Mr. Mcdonald, a retired Georgia Power executive, should be quashed because he has little personal knowledge of the facts at issue in this proceeding, and any testi-mony provided by Mr. Mcdonald would be cumulative and repetitive of testimony provided by other Georgia Power witnesses. For example, Intervenor seeks Mr. Mcdonald's M Pages 4-5,18, and 27 of the llobbs Dehsition are attached hereto ( Attachment 2). Like the Coursey deposi-tion transcript, this deposition transcript has not been reviewed by the witness for its accuracy because Interve-nor failed to produce the transcript in time for its use during this hearing. Georgia Power submits the portions of this transcript only to illustrate the lack of probative value that would be provided by Mr. Ilobbs' testimony.
U Se_e Georgia Power Company's Third Supplemental Response to Allen L. Mosbaugh's Third Set ofInterroga-tories and Request for Documents, Aug. 8,1994 at 2 n.3 ("Mr. Ilobbs, who was the Vogtle !BC Superinten-dent, assumed a temporary role within another Maintenance Department group from February 1990 through the J end of 1990. Mr. Mark Briney, who is no longer a GPC employee, acted as the I&C Superintendent during this I period").
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testimony on the April 9,1990 presentation to the NRC and on the April 9,1990 letter to the NRC. Intervenor's Motion for Subpoenas at 18 items a-b, e. Mr. Mcdonald was not in-volved in "her activity. Ilis involvement in the April 19,1990 LER was minimal, and did l
not include any involvement in the diesel start issue.
Mr. Mcdonald also has little personal knowledge of the real events at issue in this pro-ceeding. While he signed the 2.206 response letter, he did so on the basis of representations by Georgia Power officials that the information therein was correct, not on the basis of per-I sonal knowledge. The root cause testimony sought from Mr. Mcdonald (Intervenor's Motion for Subpoenas at 19 items n and p) were previously ruled by the Board to be inadmissible in this proceeding. Memorandum and Order (Motion to Strike Mosbaugh Testimony), May 11, 1995 at 21-22. The testimony sought from Mr. Mcdonald concerning information provided ;
in a Section 211 Department of Labor proceeding (Intervenor's Motion for Subpoena at 19 item i) is irrelevant to this proceeding. Sg Memorandum and Order (Motion to Strike) at 10 (striking testimony related to Section 211 Department of Labor proceeding). l l
l With respect to the other subjects on which Intervenor seeks testimony, other Georgia l Power witnesses with personal knowledge of the facts have already testified or will testify on -
these matters. Such topics include LER 90-006, and responses to OSI. Mr. Mcdonald's testi-P mony on these matters will be repetitious and cumulative. It is difficult to imagine the need for four hours of testimony from Mr. McDonaldU given his lack of knowledge of the facts at issue in this proceeding. The subpoena to Mr. Mcdonald should be quashed.
Hintervenor's Preliminary Phase 11 Witness Schedule, May 19,1995. at 1.
Ill. The Subpoenas llave Not Been Properly Served The subpoenas should also be quashed because they have not been properly served.
Under 10 C.F.R. Q 2.720(c), service of a subpoena must be made by tendering the fees for one days attendance and mileage. None of interver.or's subpoenas have been properly served because Intervenor failed to tender the requisite fees,"in direct contravention of 10 C.F.R. Q 2.720(c). This provision is taken verbatim from Fed. R. Civ. o. 45(b)(1), which has also been construed as requiring the simultaneous tendering of the fees. Subpoenas tendered with-out such fees are invalid. CF&l Steel Corp. v. Mitsui & Co., Inc.,713 F.2d 494,496 (9th Cir.1983); lxng v. United States,1990 U.S. Dist. LEXIS 4180 (D. Colo. April 5,1990); 5A Moore's Federal Practice Digest, 145.06[1] (2d ed.1994); 9 C. Wright & A. Miller, Federal Practice and Procedure Q 2461 (1971).
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?!Georgia Power's counsel have discussed this topic with hit. hiosbaugh's counsel a number of times. As of hionday, hiay 22, counsel for hir. hiosbaugh confirmed that he would provide witness fees. Counsel for Geor- ,
gia Power agreed not to seguire inileage fees until mileages have actually been established. No checks have l been received. l 1
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1 IV. Conclusion For all of the reasons stated above, the subpoenas for Charles L. Coursey, Michael L.
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Ilobbs, and R.P. Mcdonald should be quashed.
Respectfully submitted, i
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w Ernest L. Blake, Jr.
Q l David R. Lewis SilAW, PITTMAN,POTFS & TROWBRIDGE 2300 N Street, N.W.
Washington, D.C. 20037 (202) 663-8000 James joiner John Lamberski TROUTMAN SANDERS Suite 5200 600 Peachtree Street, N.E.
Atlanta, Georgia 30308 2216 ,
l (404) 885-3360 Dated: May 24,1995 l
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11.1666 01 / t*C5trl l
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Attachment 1 1
UNITED STATES OF AMERICA ATOMIC SAFETY & LICENSING BOARD In the Matter of: l 1
GEORGIA POWER COMPANY l DOCKET NOS.:
l 50-424-OLA-3 l 50-425-OLA-3 Wednesday, July 20, 1994 Deposition of CMARLES IAUIS COURSEY called for examination and testified as follows:
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(TRANSCRIPTION FROM STENOGRAPHIC NOTES PROVIDED BY THE CLIENT.]
NEAL R'. GROSS COURT REPORTERS ANO TRAN8CrueERS
- 1323 RH00E ISt.AND AVENUE. N.W.
9 e 1 A. No, sir.
2 Q. Or after the March 12th incident?
3 A. No, sir.
Did you ever hear, or know, that fluid had t
4 Q.
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. 5 been drained out of one of the trip lines of the diesel?
6 A. Yes, there was some moisture drained out of 7 one of the lines.
8 Q. Do you recall when that occurred?
9 A. No, sir.
10 Q. Do you recall how you heard about it?
11 A. No, sir. I just don't know that date or who 12 told me or what occurred, but I remember we found 13' moisture giroblems in some of the air lines.
14 Q. Are you referring to the trip lines?
15 A. Yes.
16 Q. Did you also hear of any moisture problems 17 with the air start system?
,' 18 A. Yes.
19 Q. And that's not in relation to March 12th; 20 that's in the last nine (phonetic) years? Do you recall 21 whether this was in the March 12th report or not?
i 22 Do you remember an air start moisture problem 8 .
NEAL R. GROSS COURT REPORTERS AND TRANSCRWERs 1323 RHODE ISLAND AVENUE, N.W. -
pae exuss WASHINGTON, O C. 20006 (20M 2?44s3
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10 1 with respect to the air start celnoid having a flaw?
2 A. No, sir. I don't remember that.
3 Q. Did you, on occasion, ever happen to observe a 4 jar of water, or fluid, from a trip line having been 5 collected?
6 A. No, sir.
7 (Off the record discussion.)
8 (A short break was taken.)
9 MR. KOHN: No further questions from me.
10 (The deposition ended at 4:10 p.m.)
i 11 4
' 12 13 14 i
15 16 17 18 19 20 21 22 NEAL N. GROSS
. 1323 RHOOE ISLAND AVENUE. N.W.
W ASHINGTON, O C. 20005 (202) 2344433 (200 234-4433 ,
Attachment 2 ,
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY ,
+++++
ATOMIC SAFETY.AND LICENSING BOARD PANEL f DEPOSITION t
IN THE MATTER OF: ll Docket No.
ll GEORGIA POWER COMPANY ll 50-424-OLA-3 ;
ll 50-425-OLA-3 $
Vogtle Electric Generating ll ll Plant, Unit 1 and Unit 2 ll ll
__ u Friday August 4, 1994 DEPOSITION OF: j MICHAEL HOBBS i l
i NEAL R'. GROSS COURT REPORTERS ANO TRANSCRitERS 1323 RHOOE ISLAND AVENUE. N W.
, (202) 234M33 WASHINGTON. O C. 20006 (20 0 234-4433 l
4 1 Q. Does that (PROER) (process?) have'a plant 2 dock number? Do you know what I am referring to?
3 A. You have the WOFA (standards) standards l
4 checklist number. And I don't recall that number. I 5 Q. An who would you fill out the checklist?
6 A. The technician performing the task.
7 Q. And those technicians would then be 8 reporting to you?
9 A. Uh-huh (phonetic). .
10 Q. Did all the I and CH (phonetic) 11 technicians report to you?
12 A. Yes.
13 Q. There was any increase in the frequency 14 of dew point readings after the site air emergency? i 15 A. I don't recall.
16 Q. Were you involved with looking at diesel ,
i 17 generators after the site air emergency?
18 A. No, not to my recollection.
19 Q. Did the I and CH (phonetic) technicians t
20 perform additional dew point readings after the l l
21 site air emergency?
l 22 A. I don't recall. In addition to what? l NEAL R'. GROSS COURT REPORTER $ AND THAN8CRSERS 1323 RHODE ISLAND AYENUE N W.
(202) 234 4433 WASHINGTON. O C. 20005 (202) 234-4433
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5 1 Q. To the normal PM program.
2 A. I don't recall.
3 -Q. Now, if a high dew point was obtained, 4 was there a process you would use to determine 5 whether the reading was accurate?
6 GEORGIA POWER: Is this now before or 7 after or any time?
8 MR. KOHN: Well,.let's start with before 9 the site air emergency.
10 THE WITNESS: Restate your question. .
11 BY MR.KOHN:
12 Q. Okay. Is the dew point requirement that 13 the air receivers have 50 degrees or lower degrees l 14 Fahrenheit dew point? Are you aware of that?
1 15 A. Uh-huh (phonetic).
16 Q. Okay. If a dew point reading was above l
17 50 degrees out of specification, what steps would .
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18 do to determined that the test dew point was valid?
19 A. (No response.)
20 Q. If there are additional steps that you l
21 take. I don't mean to imply that you are --
22 A. There are no additional steps to take to NEAL R'. GROSS COURT REPORTERS AND TRANSCRISERS 1323 RHODE ISLAND AVENUE. N.W.
(202) 234 4433 WASHiNOTON, O C 20006 (202) 234 4433
18 1 Q. So if I understand it then, you would 2 l' earn about a higher.than expected dew' point t
3 reading from your technicians directly?
4 A. Uh-huh (phonetic).
5 Q. And then Mr. Stokes would also. learn from 6 the same technician?
7 A. That's the way the program was intended.
8 Q. ,0kay. And you have no recollection of 1
9 any communications with Mr. Bokhold (phonetic) 10 after the site air emergency concerning higher than 11 expected dew point readings? i i
12 A. I don't have any recollection of that, -
1 13 no.
14 Q. Do you heve a recollection of any 15 conversations with anyone in -- after the site air 16 emergency, within a month or two after the site air 17 emergency of any conversations with anyone about 18 higher than expected dew point readings other than 19 your technician?
20 A. Yes.
21 Q. Who was that?
22 A. Ken Stokes. I believe it was Ken.
NEAL R'. GROSS COURT REPORTERS AND TRANSCReERS 132s RHODE ISLAND AVENUE, N.W.
pon 2s4-44s3 wAssmotoN, O c. secos (202) 234=33 )
27 1
1 BY MR. KORN- l 2 Q. Mr. Hobbs, can you tell me if a piece of i
3 one of the dew point pieces of test equipment were 4 considered or determined to be defective, what 5 (PROERS) (process?) would be taken? ,
6 A. For a defective piece EMTE (phonetic),
7 typically we would remove it from the program; put 8 a hold tag on it.
9 And it would remain on hold until 10 corrective action had been taken and I had a 11 subsequent successful calibration record on that 12 piece of equipment. ,
13 Q. And since you have no recollection of 14 that occurring with any piece of dew point test 15 equipment?
I 16 A. From the 1990 time frame period?
17 Q. Yes.
18 A. No, sir. I don't recall.
1 19 MR. KOHN: No further questions.
20 BY GEORGIA POWER:
Mr. Hobbs, just a few questions to follow 21 Q.
I 22 up Mr. Cone. I believe that Mr. Kohn testified NEAL R. GROSS COURT REPORTERS AND TRANSCRSERS f 1323 RMODE ISLAND AVENUE, N W.
(202) 2344433 WASHINGTON, D C. 20006 (202) 2344433
t 00CKETED' US$h24,1995 UNITED STATES OF AMERICA % MY 25 P2 :01 NUCLEAR REGULATORY COMMISSION OFFICE OF SECRETARY Before the Atomic Safety and Licensing BoaGDCKETING & SERVICE i BRANCH i
In the Matter of ) Docket Nos. 50-424-OLA-3
) 50-425-OLA-3 !
GEORGIA POWER COMPANY, )
etal. ) Re: License Amendment
) (Transfer to Southern Nuclear)
(Vogtle Electric Generating Plant, )
Units I and 2) ) ASLBP No. 93-671-01-OLA-3 i
CEILIlllCATTLOF SERVICE I hereby certify that copies of " Motion by Georgia Power Company, Charles L.
Coursey, Michael L. Ilobbs, and R.P. Mcdonald to Quash the Subpoenas of Charles L.
Coursey, Michael L. Ilobbs, and R.P. Mcdonald," dated May 24,1995, were served upon the persons listed on the attached service list by deposit in the U.S. Mail, first class, postage prepaid, or where indicated by an asterisk by hand delivery, this 24th day of May,1995.
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David R. Lewis ,
Counsel for Georgia Power Company
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4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Boan!
In the Matter of ) Docket Nos. 50-424-OLA-3
) 50-425-OLA-3 GEORGIA POWER COMPANY, )
et al. ) Re: License Amendment
) (Transfer to Southern Nuclear)
(Vogtle Electric Generating Plant, ) l Units I and 2) ) ASLBP No. 93-671-01-OLA-3 !
SERVICE LIST l
Administrative Judge Administrative Judge
- Peter B. Bloch, Chairman
- James H. Carpenter Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission 933 Green Point Drive Washington, D.C. 20555 Oyster Point Sunset Beach, N.C. 28468 l
\
Administrative Judge Stewart D. Ebneter j
- James II. Carpenter Regional Administrator, Region 11 '
Atomic Safety and Licensing Boaril U.S. Nuclear Regulatory Commission l U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W., Suite 2900 Washington, D.C. 20555 Atlanta, Georgia 30303 Administrative Judge Office of the Secretary
- Thomas D. Murphy Att'n: Docketing and Service Branch Atomic Safety and Licensing Board U.S. U.S. Nuclear Regulatory Commission Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555
- Michael D. Kohn, Esq. Office of Commission Appellate Adjudication Kohn, Kohn & Colapinto U.S. Nuclear Regulatory Commission 517 Florida Avenue, N.W. Washington, D.C. 20555 Washington, D.C. 20001
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- Mitzi A. Young, Esq. Carolyn F. Evans, Esq.
- Charles Barth, Esq. U.S. Nuclear Regulatory Commission i
- John T. Hull, Esq. 101 Marietta Street, N.W., Suite 2900 U.S. Nuclear Regulatory Commission Atlanta, Georgia 30323-0199 :
Office of the General Counsel '
One White Flint North, Stop 15B18 11545 Rockville Pike Rockville, MD 20852 Director, Adjudicatory File Environmental Protection Division
' Atomic Safety and Licensing Board Department of Natural Resources U.S. Nuclear Regulatory Commission 205 Butler Street, S.E., Suite 1252 Washington, D.C. 20555 Atlanta, Georgia 30334 99619-0% / iwW'S W1 i
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