ML20028C770

Requests Conference Call to Resolve Time Limit Dispute Re Depositions Prior to Delivery of Thompson & Sholly Testimony

ML20028C770
Person / Time
Site:	Indian Point
Issue date:	12/28/1982
From:	Blum J UNION OF CONCERNED SCIENTISTS
To:	Gleason J, Paris O, Shon F Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8301140084
Download: ML20028C770 (2)

Text

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e n - [ iitG & SEEVICE UgS i BRANCH December 28, 1982 RE:

In the Matter of Consolidated Edison Company of New York and Power Authority of the State of

'New Ycrk Docket Nos. 50-247-SP Mr. James P. Gleason 50-286-SP Mr. Frederick J.

Shon Dr. Oscar H. Paris, j

Administrative Judges, Atomic Safety and Licensing Boari U.S.

Nuclear Regulatory Commission Washington, D.C.

20555

Dear Judges Gleason,

Shon and Paris:

Pursuant to Judge Gleason's order at the conclusion of our conference call this afternoon, we prevailed upon Dr. Thompson and Mr. Sholly to make themselves available for continued deposition at the Consolidated Edison Building in New York for a period of three and one-half hours commencing at 9:00 a.m. on Wednesday, December 29.

Although this caused some strain within the UCS organization,; Dr. Thompson in the end was willing to be available for atis period.

Unfortunately the licensees, represented by Mr. Levin and Mr. Sohinki, were unwilling to accept this offer.

They found the time and location to be suitably convenient, but refused to accept a three and one-half hour (making the entire deposition nine and one-half hours) time limit.

Three and one-half hours is what Judge Gleason had suggested over the phone after informing Mr. Levin that four to six additional hours was excessive uildsp ~the circumstances. "When I asked Mr. Levin and.Mr. S'ohinki what they would propose as a counter-offer to three and one-half hours, 8301140084 821228 PDR ADOCK 05000247 O

PDR 1384 Massachogtts Avenue + Camtmdge, Massachusetts 02238 + Tel. (617) 547-5552 1346 Connectcut Avenue, N W.

• Suite 1105

• Washington, D.C. 20036 + Tel. (202) 296-5600 is

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2 Mr. Levin responded that he tentatively would be willing to accept five hours.

Mr. Sohinki responded for Consolidated Edison that he would accept no time limit, At the conclusion of the conversation

'both attorneys were unwilling to accept any' time limit.

They declared that they were absolutely unwilling to continue the deposition under such conditions.

Dr. Thompson is currently very pressed by three sets of commitments, and cannot be made available indefinitely.

Based upon the foregoing, it is the position of UCS/NYPIRG that we have fully complied with Judge Gleason's order that we make Dr. Thompson and Mr. Sholly available for continued deposition expeditiously and prior to delivery of the Thompson-Sholly testimony.

If the Board believes that this matter merits further exploration, we request that a conference call be arranged with the entire Board at a convenient time.

Thank you for your consideration in this series of annoyances.

Sincerely,

% % d L _ _.

Jeffrey M. Blum Attorney for Union of Concerned Scientists cc:

Mr. Joseph Levin Mr. Steven Schinki (regular service to follow)

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