ML20070A996

Opposes Belated Request for Further Illegal License Transfer Depositions.Related Correspondence

ML20070A996
Person / Time
Site:	Vogtle
Issue date:	06/22/1994
From:	Lamberski J GEORGIA POWER CO., TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA
To:	Kohn M KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA
References
CON-#294-15259 OLA-3, NUDOCS 9406290231
Download: ML20070A996 (3)

Text

-

/62& e, musconnesecence ROUTMAN SANDERS -

.^ 7. 7,.e.a ta.v..?... ^..L,.r..^ .v. 1g TNM" NArsONS8 ANN PLA2A 600 PE ACHTREE STRE ET N E. SJYE 5200 Aru~m cEOaoa 3030. w. '94 jut! 23 Pd :06 YELE PHONE 404 885 3000 FACSMLE aod 885 3900 JOm LAMBERSou .

r D6 RECT 404 885 3360 0F.r..Lt ,

June 22,1994 DCCrk IIN _ . ,

Michael D. Kohn, 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 Docket Nos. 50-424-OLA-3,50-425-OLA-3; License Amendment fcr Transfer to Southern Nuclear Operating Company

Dear Michael:

Today I received by facsimile your June 22,1994 letter (copy attact'ed) requesting three additional depositions on the illegal license transfer issue, i.e., Messrs. Meier, Peacock and Adams. 'Dtis is inconsistent with the agreement of all parties, approved by the Licensing Board at the May 26 status conference, that your three days of depositions on the illegal license transfer issue would be conducted during the weeks of June 6 and June 13.

Therefc,re, GPC will not agree to arrange such depositions.

During the May 26,1994 status conference in the offices of the Licensing Board, we agreed that Intervenor would be permitted to conduct his final illegal license transfer depositions, if at all, during the weeks of June 6 and June 13 and that the names of the individuals who Intervenor intended to depose would be identified to GPC in a June 1,1994 conference call. Tr. 394-95, 397. On June 1, the list of deponents provided to GPC included Messrs. Williams, Franklin, Scherer, Long, Jobe, Addison, Wallace and Beckham.

In subsequent discussions we further agreed how to keep track of time spent on these depositions during the two week period, with an understanding that the three days worth permitted by the Licensing Board's May 25th Memorandum and Order would correspond to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of questioning.

By Tuesday, June 14,1994 all of these depositions had been completed and the total  ;

running time of these depositions, excluding break time and the time when GPC and the Staff asked questions, was about 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />. At that time, you stated that you may also want to depose Mr. John Meier. I informed you that I would accept requests to schedule further depositions on the illegal license transfer issue during the week of June 13, but I reminded you of our agreement to complete all depositions by June 17. I further informed you that if )

you wanted to depose Mr. Meier by June 17, you needed to advise me as soon as possible. I contacted Mr. Meier to check his schedule and determined that he could travel to Atlanta on 9406290231 94cS22 PDR C

ADOCK 05000424 PDR1 N

l

TROUTMAN SANDERS

w. =u..::=

Michael D. Kohn, Esquire June 22,1994 Page 2 Friday, if you requested his deposition. Wednesday, Thursday and Friday went by and you did not request that I schedule Mr. Meier or anyone else for a deposition.

For these reasons, we oppose your belated request for further illegal license transfer depositions.

Very taily ours, ohn 1.2mbers '

cc: Service List l

l i

1 l

l l

KOHN KOHN. S COLAPINTO P.C. l ATTORNEYS AT LAW 517 FLCACA AVENUE. NW VrAS6 TON DC 20001 18"Jo (207] 23L4563 . F AX (202) 462-4145 N .n :

arm 4.m*Tt:

~

trgdTr . s 0 Skr0 al 3 Lape.73 ... . C 'TTED PsPA

~

vm .m 1 ?%%,. June 22, 1994 yta 1Paesimile John Lamberski, Esq. l TROUTMAN SANDERS Suite 5200  ;

600 Peachtree Street, N.E.

Atlanta, GA 30308-2216 David R. Lewis, Esq.

Shaw, Pittman, Pitts & Trowbridge 2300 N Street, N.W.

Washington, D.C. 20037 Re: Vogtle Electric Generating Plant, Units 1 & 2 License Amendment (Transfer to Southern Nuclear)

ASLBP No. 69 -671-01-01A-3 Rocket Nos. 50-424-OLA-31 50-425-OLA-3

Dear centelman:

Pursuant to the agreement reached and memorialized in Mr.

Levis' June 7, 1994 letter, the parties agreed that Intervenor would have a cumulative total of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to conclude depositions The related to the alianation of control / illegal transfer issue.

parties agree to keep track Basedof theon my time last remaining after conversation each with Mr.

depositin was concluded. remain.

Lamberski, some seven (7) hours of deposition time Intervenor anticipates intends to depose Messrs. John Meier, Tom Peacock and Ferry Adams in the remaining time. This willIntervenor conclude the depositions concerning illegal license transfer.

requests that the parties attempt to reach a mutually convient time to convene the remaining depositions (hopefully all three can be scheduled for the same day and location),

sincerely yours, Michael D. Kohn cc: Charles Barth, Esq.

let.10 TOTR. P.02