ML20069D007

Intervenor Proposed Agenda for 940526 Status Conference.* Requests That Issue of Whether or Not NRC Staff Has Released All of Mosbaugh Tapes & OI Rept Exhibits to Intervenor,In Agenda

ML20069D007
Person / Time
Site:	Vogtle
Issue date:	05/25/1994
From:	Kohn M KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA
To:
Shared Package
ML20069D011	List: ML20069D007 ML20069D026 ML20069D042
References
CON-#294-15102 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9406020185
Download: ML20069D007 (4)

Text

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l 00CKETED UNITED STATES OF AMERICA l' NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD 94 MY 25 P3 :35

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In the Matter of ) FFICE OF SECRETARY

) Docket Nos. 50-424-OLA OCKETIE & SERVICE, GEORGIA POWER COMPANY ) 50-425-OLA-3 BRANCH l gi gl,_, )

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

Plant, Unit 1 and Unit 2) ) j

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

INTERVENOR'S PROPOSED AGENDA I FOR MAY 26, 1994 STATUS CONFERENCE In response to the Atomic Safety and Licensing Board's order of May 16, 1994, Intervenor hereby respectfully request the following items be included on the agenda for the May-26, 1994 status conference:

1. The issue of whether or not NRC Staff.has, in fact, released all of the Mosbaugh tapes and OI Report Exhibits to Intervenor. See exhibits A, B, and C.

2. Georgia Power Company's filing of the transcripts for tapes No. 57 and 58 to the ASLB.

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3. The date for completion of Phase II discovery. i l

4. The need to move documents produced by Georgia. Power Company maintained in Atlanta to Washington, D.C. Intervenor does not have reasonable access to these documents. Intervenor

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requested Licensee to relocate these documents to its Washington, 1 D.C. counsel's office and Licensee refused. Intervenor seeks te l 9406020185 940525 PDR ADOCK 05000424 g

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l have these documents transferred to Washington, D.C. See exhibits D and E. )

i Respe . fully submitted, Michael.D. Kohn i Stephen M.- Kohn David K. Colapinto Kohn, Kohn'& Colapinto,'P.C.

517 Florida Ave., N.W..

Washington, D.C. 20001 (202) 234-4663 301\schord2 t

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KOHN, KOHN, S COLAPINTO, P.C.

ATTORNEYS AT law 517 FLORCA AVENUE, NW WASHINGTON, OC 200o1-1850 (202) 234-4663 e FAX (202] 462-4145  !

MCNAEL 0 KOHN ... . AcuTTED W CC

. AOMTTED N HA STEPHEN M KOHN ...

Ocyto g. Coi,APiNTO . .. . ACMTTED W MA l

. AOMTTto N NJ l OF COUNSEL.

. ACM TTED W PA E= A07 l cucEt i osHTay ...

May 18, 1994 Charles A. Barth, Esq.

Office of the General Counsel One White Flint North Stop 15B18 U.S. Nuclear Regulatory Commission ,

Washington, D.C. 20555 l RE: License Amendment (transfer to Southern Nuclear)

Docket Nos. 50-424-OLA-3; 50-425-OLA-3'

Dear Mr. Barth,

I am writing in regard to the exhibits mentioned in the body of the OI Report. After careful review of both the OI Report and the exhibits previously made available to Intervenor, it appears thz.c a number of the exhibits mentioned in the OI Report were not made available to Intervenor. I look forward to your making all of the exhibits available to us immediately. Because we still do not have the complete OI Report, we urge you to expeditiously make the remaining exhibits available so that the 50 day discovery window from receipt of the OI Report and exhibits will not remain open for longer than necessary.

Yours truly, Stephen M. Kohn cc: Service List 301\3181et l

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, o 288u9 k UNITED STATES

} NUCLEAR REGULATORY COMMISSION

• . WASHINGTON, D.C. sNEE 0001 May 20, 1994 l

Stephen Kohn Kohn, Kohn and Colapinto, P.C.  ;

517 Florida Avenue, N. W. l

. Washington, D. C. 20001 In the Matter of GEORGIA POWER COMPANY, et al.

(Vogtle Electric Generating Plant, Units 1 and 2)

Docket Nos. 50-424-OLA-3, 50-425-OLA=3

Dear Mr. Kohn:

I have your letter' dated May 18, 1994,- wherein you allege that you do not haveLa complete copy of:OI Report Case No. 2-90-020R and that you do not have a complete set of exhibits to that report. To the best of our knowledge, a complete report with the exhibiti was provided to you. If you will please identify what exhibits that you believe are missing, and the reference in the OI report to thesa_ exhibits, we shall provide copies.of anything that may be missing to you for inspection and copying in compliance with the-Commission's Order in CLI 94-05.

I also have Mr. Michael Kohn's letter to Mr. David Lewis discussing scheduling depositions of Messrs Fredericks, Burr and Majors. In light of the confusion with respect to .the transcription of depositions in the past, please advise me well in advance of any such depositions, if you do not plan to have transcripts made of those, or any other depositions. This-is in accordance with Green V. Williams, 90-FRD 440, 441 (ED Tenn. 1981), and as a matter of courtesy, sincerely, Charles A. Barth Counsel for NRC Staff CC: service List Telefax:

8. Kohn J. Lamberski P. Bloch klO'e 0 M I N Qbet b

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