ML20081L410

Responds to Intervenor Re List of Tape Segments & License Amend for Transfers.Util Ack Receipt of Intervenor Request for Agreement on Certain Tape Segments, & Will Review Tape Segments by 950323.Related Correspondence

ML20081L410
Person / Time
Site:	Vogtle
Issue date:	03/14/1995
From:	Lamberski J GEORGIA POWER CO., TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA
To:	Wilmoth M KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA
References
CON-#195-16498 OLA-3, NUDOCS 9503300186
Download: ML20081L410 (2)

Text

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LTROOTMANSANDERSL DOCKETED

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j TELE PHONE 404-885-3000 -

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' JOHN LAMBERSXi 0FFICE OF 3ECF6MWfth ass saco ~ .f DOCKETI% & URyICE t Marc h 14,1995 BRAEH ,

4 Mary Jane Wilmoth, Esquire Kohn, Kohn & Colapinto, P.C. '

,< 517 Florida Avenue, N.W.  ;

-Washington, D.C. 20001  :

Re: Georgia Power Company (Vogtle Electric Generating Plant, Units 1 and 2) NRC l Docket Nos. 50-424-OLA-3, 50-425-OLA-3; License Amendment for Transfer  !

to Southern Nuclear Operating Company  :

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Dear Ms. Wilmoth:

t Georgia Power Company (" Georgia Power") hereby responds to Intervenor's letter dated .

February 28, 1995, regarding Intervenor's List of Tape Segments. The letter purports to- ,

identify tape segments Intervenor plans to introduce at the upcoming hearing. As you know, the j

' Board's schedule for Phase II calls for the parties to complete agreements on the transcripts by March 23,1995. Memorandum and Order (Schedule for Phase II), January 18, 1995.  ;

Georgia Power is having difficulty understanding the purpose of your February 28 letter.  ;

If Intervenor wants the parties to agree to the tape transcript segments identified, the Board has stated that his counsel should specify in the request that the segments are relevant to his case and .

submit a proposed transcript for the other parties to review. Tr. 601. - Since your. letter did not i include any transcripts for the parties to review, Georgia Power will not treat Intervenor's letter i as a request for agreement on the tape segments identified.

Further, Georgia Power notes a number of inaccuracies in your February 28 letter. For  ;

example, under the heading of " Transcripts of tapes used in the OI Report," Intervenor lists tapes 11,19, and 40. While these langs were listed as exhibits to the OI Report (Exhibits 99, .;

108, and 109, respectively), OI did not provide a transcriot for these tapes. Under the heading ,

of " Tapes not used in the OI Report," Intervenor identifies Tape No.' 267. This tape and its i associated transcript were 01 Exhibits 91 and 92, respectively. Also, under this same heading, l Intervenor identifies a tape segment as " Tape dated June 8,1990, p. 8." Georgia Power does j not know with certainty what tape this identifies. Finally, under the heading of " Tape transcripts j already stipulated," the only information Georgia Power understands to be correct is _that i transcripts for Tapes 57 and 58 have been agreed to by the parties, with specific exceptions j noted in the transcripts prepared by Georgia Power. Georgia Power does not understand the  ;

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-TROUTMAN SANDERS

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Ms. Wilmoth -

March 14,1995 Page other information listed.  !

Georgia Power also reminds Intervenor that his September 20, 1994 letter, styled ['

"Intervenor's Response to Licensee's Request for Stipulations Dated February 28, 1994,"

stipulated to certain portions of Tape Nos. 42,184,186,187, 253, 258, and 267, as well as IIT Document No. 257. Further, Georgia Power submitted additional requests for tape transcript stipulations on October 20, 1994 and November 11, 1994 for which it continues to await i Intervenor's response.

Finally, Georgia Power acknowledges receipt of Intervenor's request for agreement on certain tape segments, dated March 13,1995. Georgia Power will endeavor to review and agree on these tape segments before March 23. However, Georgia Power does not believe it will be able to review any other transcripts for possible agreement by the March 23rd deadline unless it receives such proposed transcripts by March 16.

Very truly yours, h t ohn 12mberski i

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