ML20080A341

Forwards Intervenor Motion to Postpone Deposition of NRC Personnel Until Conclusion of License Transfer Hearing, Submitted in Place of 941013 Motion

ML20080A341
Person / Time
Site:	Vogtle
Issue date:	10/17/1994
From:	Kohn M GEORGIA POWER CO., KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA
To:	Bloch P, Carpenter J, Murphy T Atomic Safety and Licensing Board Panel
Shared Package
ML20080A344	List: ML20080A341 ML20080A365
References
CON-#494-15826 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9411010029
Download: ML20080A341 (2)

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• 4N![L i CS *H *e October 17, 1994 Via facsimile Hon. Peter B. Bloch, Chair Hon. Thomas D. Murphy Hon. James H. Carpenter Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re

  In the Matter of Georgia Power Company, et.al. (Vogtle Electric Generating Plant, Unite 1 and 2) Docket Nos.

50-424-OLA-3 & 50-425-OLA-3, ASLBP No. 93-671-01-OLA-3

Dear Sirs:

Please find enclosed "Intervenor's Motion to Postpone Deposition of NRC Personnel Until Conclusion of License Transfer Hearing," which Intervenor's counsel submits in place of the earlier motion filed on October 13, 1994. The substitute motion alters numbered paragraphs 3 and 4 and provides an additional citation in paragraph 6. These changes provide additional support for Intervenor's motion.

With respect to paragraph 3, the transcript of the last ASLB hearing rather demonstrates that the parties agreed to a January 4

- 13, 1994 schedule to conduct NRC witnesses depositions. This fact would appear to be dispositive support of Intervenor's request. Paragraph 4 indicates that Intervenor's counsel "was not consulted" about changes in the schedule of NRC Staff depositions.

NRC Staff wrote counsel on October f, 1994 asking them to respond to a proposed schedule. This letter was transmitted during the time period Intervenor had to respond to GPC's request for summary decision and both NRC and GPC's counsel never received any communication from Intervenor nor did they contact Intervenor's counsel to participate in their discussions that occurred after October 5, 1994. Intervenor was not consulted about the final schedule, but did receive a letter requesting Intervenor to respond to suggested schedule proposed by NRC's counsel.

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Page 2 October 17, 1994 Kohn to ASLB

-Intervenor's counsel hopes this additional information is useful to the Board. Thank you for your consideration of this matter.

Sincerely, p_

Michael D. Kohn Attorney for Intervenor cc: Service List C:\ FILES \301\BLOCH2.LET J

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