ML050270133
| ML050270133 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 01/14/2005 |
| From: | Hofmann S State of VT, Dept of Public Service |
| To: | Anthony Baratta, Carlin A, Rubenstein L Atomic Safety and Licensing Board Panel |
| Byrdsong A T | |
| References | |
| 50-271-OLA, ASLBP 04-832-02-OLA, RAS 9218 | |
| Download: ML050270133 (6) | |
Text
. WAS 92jg G03COMPONDM 112 STATE STREET il jA FAX: (802) 828-2342 DRAWER 20 . SIL TTY (VT): 1-800-734-8390 MONTPELIER VT 05620-2601 e-mail: vtdps@psd.state.vt.us TEL: (802) 828-2811 Internet: htp://www.state.vt.us/psd STATE OF VERMONT DEPARTMENT OF PUBLIC SERVICE DOCKETED USNRC January 14, 2005 January 24, 2005 (3:35 pm)
OFFICE OF SECRETARY Administrative Judge Alex S. Carlin, Chair RULEMAKINGS AND Atomic Safety and Licensing Board Panel ADJUDICATIONS STAFF U.S. Nuclear Regulatory Commission Mail Stop T-3F23 Washington, DC 20555-0001 Administrative Judge Anthony J. Baratta Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Mail Stop T-3F23 Washington, DC 20555-0001 Administrative Judge Lester S. Rubenstein Atomic Safety and Licensing Board Panel 4270 E. Country Villa Drive Tuscon, AZ 85718 Re: Docket No. 50-271-OLA/ASLB No. 04-832-02-OLA
Dear Administrative Judges:
This letter is to confirm to the Atomic Safety and Licensing Board Panel for this proceeding, that the Vermont Department of Public Service has complied with 10 CFR § 2.336 regarding our general discovery obligations. Please find attached a copy of the Department's Certificate of Disclosure and transmittal letter to the parties.
These disclosures have been made to all parties, whether the party has taken or not taken a position on any of the Department's admitted contentions.
Respectfully submitt Sarah Hofmn Special Counsel
-re4Vn/fea'esac Y-O35 -.b-cy-c2g-
JanuaTy 14, 2005 cc: Anthony Z. Roisman, Esq.
Jonathan J. Block, Esq.
John M. Fulton, Esq.
Marisa Higgins, Esq.
Brooke Poole, Esq.
Douglas J. Rosinski, Esq.
Raymond Shadis Jay E. Silberg, Esq.
Robert Weisman, Esq.
OCAA Office of the Secretary
January 14, 2005 At this time, Mr. Sherman expects to rely upon the information in his possession included in the attached Disclosures as the bases for his opinions. As further relevant information comes into our possession, it will be disclosed as required by 10 CFR § 2.336.
As of today, Protective Agreements have not been worked out among the parties.
Accordingly, at this point we are sending the lists of all documents not being produced in hard copy to all parties, the hard copies of all non-proprietary documents to all parties, and two CDs, provided to us by Entergy in November 2004, that contain proprietary material, only to Entergy. Our Disclosure list of documents indicates which documents are claimed to be proprietary by Entergy. There are no documents generated by Department for which a proprietary claim is being made. If after looking at the lists, any of the other parties would like any of the non-proprietary material from the list, and it wasn't provided in Entergy's disclosure, please let me know and I will have copies of the material made for you.
Additionally, the Department does have in its possession documents (primarily e-mails) that are privileged attomey-client material. The Department has reached an agreement with Entergy and the NRC Staff that this material is not subject to disclosure and that a privilege log for this material was not necessary.
If a party upon whom this disclosure is required, would like to come and view some of the disclosed materials as kept in the Department's files, please call me so we can arrange a mutually convenient time during normal business hours for that to occur.
Finally, please call me if you have trouble accessing any of the information that is described as to location, and I will provide whatever assistance I can to ensure your access to the information.
Very truly yours, C-Sarah Hohnf Special Cou cc: Administrative Judge Alex S. Karlin Administrative Judge Anthony J. Baratta Administrative Judge Lester S. Rubenstein
January 14, 2005 Office of the Secretary OCAA John M. Fulton, Esq.
. I . .
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
) DocketNo. 50-271 ENTERGY NUCLEAR VERMONT YANKEE LLC AND ENTERGY NUCLEAR ) ASLBP No. 04-832-02-OLA OPERATIONS, INC.
(Vermont Yankee Nuclear Power Station)
CERTIFICATE OF DISCLOSURE My name is William K. Sherman: I am employed by the Vermont Public Service Department ("Department") in the position of State Nuclear Engineer. I have held this position since November, 1988. My duties include ongoing State regulatory oversight of the Vermont Yankee Nuclear Power Station ("Vermont Yankee"), as well as advising the Department and other State agencies on issues related to Vermont Yankee and nuclear power.
- 2. All materials relevant to the contentions of Department which have been accepted in the above-identified docket have been disclosed pursuant to 1O C.F.R. § 2.336, and the disclosures are accurate and complete to the best of my knowledge as of the date of this certification.
William K. Sherman State Nuclear Engineei Subscribed and sworn to before me this 14th day of January, 2005.
Susan Pittsley LI)
Notary Public My commission expires February 10, 2007
112 STATE STREET 1 FAX: (802) 828-2342 DRAWER 20 'ETY (VT): 1-800-734-8390 MONTPELIER VT 05620-2601 e-mail: vtdpsppsd.state.vt.us TEL: (802) 828-2811 Internet: http:/Avww.state.vt.us/psd STATE OF VERMONT DEPARTMENT OF PUBLIC SERVICE January 14, 2005 Jay E. Silberg, Esq.
Matias Travieso-Diaz, Esq.
Shaw Pittman, LLP 2300 N St., NW Washington, DC 20037-1128 Brooke Poole, Esq.
Robert Weisman, Esq.
Marisa Higgins, Esq.
Office of the General Counsel Mail Stop 0-15 D21
'U.S. 7Iuideai lau~toi-emssin Washington, D.C. 20555-0001 Jonathan M. Block, Esq.
94 Main Street P.O. Box 566 Putney, VT 05346 Re: Docket No. 50-271-OLA/ASLBP No. 04-832-02-OLA
Dear Ladies and Gentlemen:
Please find enclosed the Department's disclosures pursuant to 10 CFR § 2.336 as well as a Certificate of Disclosure, Certificate of Service, and a copy of a letter to the Board indicating our compliance.
Pursuant to 10 CFR § 2.336(a)(1), at this time the person "upon whose opinion the party [Department) bases its claims and contentions and may rely upon as a witness,"
is State Nuclear Engineer, William K. Sherman. Mr. Sherman's telephone number and address are:
Vermont Department of Public Service 112 State Street - Drawer 20 Montpelier, VT 05620-2601 802-828-3349