ML020320013
| ML020320013 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/07/2002 |
| From: | Repka D Dominion Nuclear Connecticut, Winston & Strawn |
| To: | Connecticut Coalition Against Millstone, Long Island Coalition Against Millstone, Office of Nuclear Reactor Regulation |
| Byrdsong A | |
| References | |
| +adjud/rulemjr200506, 50-423-LA-3, ASLBP 00-771-01-LA-R, RAS 3846 | |
| Download: ML020320013 (5) | |
Text
38tU, In the Matter of:
Dominion Nuclear Connecticut, Inc.
(Millstone Nuclear Power Station, Unit No. 3)
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Docket No.
50-423-LA-3 ASLBP No. 00-771-01-LA-R NOTICE OF DOMINION NUCLEAR CONNECTICUT, INC.'S SECOND PRODUCTION OF DOCUMENTS TO INTERVENORS I.
Introduction In accordance with the directives of the Atomic Safety and Licensing Board
("Licensing Board") in its November 5, 2001, Memorandum and Order (Telephone Conference Call, 10/31/01; Schedules for Proceeding), and the rules and procedures of 10 C.F.R. Part 2, Dominion Nuclear Connecticut, Inc. ("DNC") hereby produces, in response to Intervenor's Second Set of Interrogatories and Request for Production in the Reopened Proceedings, the requested document as stated below.
II.
General Objections DNC's production of documents is subject to the general objections stated in DNC's Response to Intervenors' First Set of Interrogatories and Request for Production in the Reopened Proceedings, filed November 21, 2001, and in DNC's Response to Intervenors' Second Set of Interrogatories and Request for Production in the Reopened Proceedings, filed December 20, 2001. e mrpdfe siC/05~6~-o RELATED 0OiE,,ODEE DOCKETED USNRC JarYJ22y 2 AM 10: 52 OFFICE
>"A E"RETARY UNITED STATES OF AMERICA RULi,-AKiINGS AND NUCLEAR REGULATORY COMMISSION ADJUDICAIlONS STAFF BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
,Xc'sF V- 09
III.
Reauests for Production Subject to the aforementioned objectives, DNC hereby responds as follows to Intervenors' specific document requests:
- 1.
Please produce the last report prepared by the licensee and filed with the NRC in 1980 inventorying the missing spent fuel rods..
Response
This document is produced as L013745 - L013749.
- 2.
Please provide a complete list of low-level radioactive waste contractors and their business addresses used by Northeast Nuclear Energy Company from 1972 to the present time.
Response
As noted in DNC's Response to Intervenors' Second Set of Interrogatories and Request for Production in the Reopened Proceedings, dated December 20, 2001 ("DNC's Response to Intervenors' Second Discovery Request"),
DNC objects to this discovery request on the grounds that the information sought is irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence.
- 3.
Please produce all documents substantiating the responses to Interrogatory 1, a through n.
Response
As noted in DNC's Response to Intervenors' Second Discovery Request, DNC objects to this discovery request on the grounds that the information sought is irrelevant, immaterial, and not reasonably calculated to lead to the discovery of admissible evidence.
Rý_ectfully submitted, David A. Repka Robert M. Rader Donald P. Ferraro WINSTON & STRAWN 1400 L Street, NW Washington, D.C. 20005-3502 Lillian M. Cuoco DOMINION NUCLEAR CONNECTICUT, INC.
Millstone Power Station Building 475/5 Rope Ferry Road (Route 156)
Waterford, CT 06385 Counsel for Dominion Nuclear Connecticut, Inc.
Dated in Washington, D.C.
this 7 th day of January 2002 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
Dominion Nuclear Connecticut, Inc.
(Millstone Nuclear Power Station, Unit No. 3)
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Docket No.
50-423-LA-3 ASLBP No. 00-771-01-LA-R CERTIFICATE OF SERVICE I hereby certify that copies of "Notice of Dominion Nuclear Connecticut, Inc.'s Second Production of Documents to Intervenors' in the Reopened Proceedings" and documents produced pursuant thereto in the captioned proceeding have been served on the following by overnight delivery this 7 th day of January 2002. Additional e-mail service of the Notice has been made this same day as shown below.
Charles Bechhoefer, Chairman Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 (e-mail: cxb2@nrc.gov)
Dr. Charles N. Kelber Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 (e-mail: cnk@nrc.gov)
Office of Commission Appellate Adjudication U.S. Nuclear Regulatory Commission Washington, DC 20555 Dr. Richard F. Cole Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 (e-mail: rfcl @nrc.gov)
Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Rulemakings and Adjudications Staff (original + two copies)
(e-mail: HEARINGDOCKET@nrc.gov)
Adjudicatory File Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555
Ann P. Hodgdon, Esq.*
Office of the General Counsel U.S. Nuclear Regulatory Commission Washington, DC 20555 (e-mail: aph@nrc.gov)
Nancy Burton, Esq.
147 Cross Highway Redding Ridge, CT 06876 (e-mail: nancyburtonesq@hotmail.com)
Diane Curran Harmon, Curran, Spielberg & Eisenberg, L.L.P.
1726 M Street, N.W.
Suite 600 Washington, DC 20036 (e-mail: dcurran@harmoncurran.com)
- The NRC Staff has requested-that it be served with only those documents produced to Intervenors that it specifically requests.
Donald P. Ferraro Counsel for DNC, Inc.