ML20072L104
| ML20072L104 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 08/17/1994 |
| From: | Lamberski J TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA |
| To: | Bloch P, Carpenter J, Murphy T Atomic Safety and Licensing Board Panel |
| References | |
| CON-#394-15609 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9408310081 | |
| Download: ML20072L104 (5) | |
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l August 17, 1994 Administrative Judge Pe'er B. Bloch, Chairman Administrative Judge James H. Carpenter Administrative Judge Thomas D. Murphy Atomic Safety and Licensing Board (Georgia Power)
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Rc:
Vogtle Electric Generating Plant, Units 1 and 2 License Amendment (Transfer to Southern Nuclear) ASLBP No. 93-671-01-OLA-3.
Dear Sirs:
Yesterday, I provided to you Georgia Power Company's Response to Intervenor's Motion to Compel GPC to Produce Bill Shipman ( August 16, 1994). Two letters should have been attached to that filing but were inadvenently omitted. Those two letters, one from M. Kohn to E. Blake, dated July 12, 1994, an; another from J. Lamberski to M. Kolm, dated July 14, 1994, are attached to this lettcr. I apologize for any inconvenience this may have caused.
Very t y yours A~
John Lamberski ec:
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July 12, 1994 Via Faceimile Ernest L.
- Blake, Jr.,
Esq.
f David R.
Lewis, Esq.
Shaw, Pittman, Pitts & Trowbridge 2300 N Street, N.W.
Washington, D.C.
20037 Units 1 &2 Vogtle Electric Generating Plant, Re:
License Amendrent (Transf er Oc Southern Nuclear)
Oceket Nes. 50-424-CLA-37 50-425-OLA-3 Oear Ernest:
Intervenor requests that the following individuals be made dvailable for deposition as fo11cws:
1.
Miller 7/10 10:00 a.m.
2.
Lisenby 7/18 12:30 p.m.
3.
Ajluni 7/18 2:00 p.m.
4.
- Bailey 7/19 10:00 a.m.1 5.
Ward 7/20 10:00 a,s.
5.
- Rushton 7/20 10:00 p.m.
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7.
Kitchens 7/20 2:00 p.m.
8.
- Bockhold 7/2*.
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*" indicates that the same date and time appears as was 1
preposed in an earlier schedule for cral examination transmitted to Intervenor by counsel to Licensee.
1
E 2-1994 11:45 2.03 9.
Shipman 7/22 1:30 p.:7. 2 10.
McCoy 7/25 10:00 a.m.
- 11. *v.cDonald 7/26 10:00 a.m.
- 12. *Hairsten 7/27 10:00 a.m.
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Par 2.ey 7/M 10 :U:T a_m.t -
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- 14. *Dahlberg 7/28 3:00 p.m.
The above schedule represents Intervenor's best effort to attempt to work with an earlier proposed schedule each party has previcusly i
Sincerely, fllL U.
Michael D.
KobJ1 3 0 '.\\ le t 1. eb i
2 If Licensee believes that Mr.
Shipman will not be available on this date due te health considerations, Intervenor requests that an affidavit be submitted stating Mr. Shipman's health status (including any reason to believe his health would improve at a later date and why a delay in taking his deposition is necessary).
Intervenor also would like to know whether Licensee anticipates whether Mr. Shipman will be available when the hearing in this matter convenes or whether the parties should consider taking his testimony Out of time.
TOTAt. P.03-
TROUTMAN SANDERS
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NAfiONSBANM PLAZA eco PE ACMTREE STREET N E SutTE 5200 ATL ANTA GEORGIA 30308 2216 TELEPHONE 404 885 3000 FACSMLE 404 885 3900 JOHN LAMBE ASK' OiAECT 404 885 3360 July 14,1994 VIA FACSIMILE 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, 50425-OLA-3; License Amendment for Transfer to Southern Nuclear Operating Company
Dear Michael:
Ernie Blake and I telephoned you ;csterday to discuss the deposition schedule. We left a message for you to call us but did not receive a call back. 7he following is our latest schedule for depositions for the weeks of July 18 and July 25:
July 18: 10:00 a.m. - Miller; 12:30 p.m. - Lisenby; 2:00 p.m. - Ajiuni' July 19: 10:00 a.m. - Bailey; 1:00 p.m. Ward July 20: 10:00 a.m. - Rushton; 2:00 p.m. Dixon July 21: 10:00 a.m. - Bockhold July 22: 10:00 a.m. - Mosbaugh 2
July 25: 11:00 a.m. - Farley; 2:00 p.m. - Mcdonald July 26: 10:00 a.m. - McCoy July 27: 10:00 a.m. - Hairston July 28: 3:00 p.m. - Dahlberg 5
July 29: 2:00 p.m. - STATUS CONFERENCE
' I have not been able to confirm this with Ajtuni, who is on vacation.
Mr. Mcdonald will be returning from Pensacola this day and will confirm, or propose 2
a change to, the start time for this deposi ion within the next day or two.
t
' Ernie informed the Board yesterday of the panies' desire to shift the status conference from the 22nd to the 29th; the Licensing Board will determine the time and location for the
I TROUTMAN SANDERS n.: :.;:.L~.J.:J, ; ta.::
Michael D. Kohn, Esquire July 14,1994 Pare 2 All depositions will take place in the offices of Troutman Sanders, with the exception of Mr. Dahlberg's deposition which will take place in the Southern Co.?pany offices.
Intervenor is responsible to arrange for a court reporter for all depositions erept for Mr.
Mosbaugh.
In response to your request to depose Mr. Shipman, As I told you on July 12, it is my understanding from discussions I have had with Richard Hendrix, Mr. Shipman's attorney, that Mr. Shipman is meeting with his surgeons in Houston on July 15 and 18 to determine whether he will undergo surgery. We will not know whether Mr. Shipman will be ab!c to attend any deposition until he returns from Houston. This will be July 19, assuming he does not undergo surgery. Your July 13 letter to the Board incorrectly reports these dates. You may want to submit a letter to the Board correcting your July 13 letter.
We have also discussed a possible deposition date for Mr. Kitchens. To confirm, if you would like u> depose Mr. Kitchens on July 20, you must do so in the vicinity of Plant Vogtle since Mr. Kitchens must remain close to the plant that day. You have indicated that you would like to depose him at a later date. August 2,1994 to depose Mr. Kitchens in Atlanta remains acceptable, but you should let me know by July 22nd if you would like to depose him then.
Very ly yours John Lamberski cc:
Charles A. Barth, Esq.
status conference.
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