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, 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 In the Matter of: ))
) Docket No. 50-423-LA-3 Dominion Nuclear Connecticut, Inc. )
) ASLBP No. 00-771-01-LA-R (Millstone Nuclear Power Station, )
Unit No. 3)
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.
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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: )
)
) Docket No. 50-423-LA-3 Dominion Nuclear Connecticut, Inc.
)
) ASLBP No. 00-771-01-LA-R (Millstone Nuclear Power Station, Unit No. 3) )
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 Dr. Richard F. Cole Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 (e-mail: cxb2@nrc.gov) (e-mail: rfcl @nrc.gov)
Dr. Charles N. Kelber Office of the Secretary Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, DC 20555 U.S. Nuclear Regulatory Commission Attn: Rulemakings and Adjudications Staff Washington, DC 20555-0001 (original + two copies)
(e-mail: cnk@nrc.gov) (e-mail: HEARINGDOCKET@nrc.gov)
Office of Commission Appellate Adjudicatory File Adjudication Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555
Ann P. Hodgdon, Esq.* Nancy Burton, Esq.
Office of the General Counsel 147 Cross Highway U.S. Nuclear Regulatory Commission Redding Ridge, CT 06876 Washington, DC 20555 (e-mail: nancyburtonesq@hotmail.com)
(e-mail: aph@nrc.gov)
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.