ML19257A246
| ML19257A246 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 12/04/1979 |
| From: | Baxter T SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Ellison C CALIFORNIA, STATE OF |
| Shared Package | |
| ML19257A247 | List: |
| References | |
| NUDOCS 8001030251 | |
| Download: ML19257A246 (5) | |
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.,w S haw, PITTM AN, PoTTs & TROWB RIDG E 1800 M STREET.N.W.
WAS HINGTO N. O. C. 20036
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w December 4, 1979 Christopher Ellison, Esquire California Energy Commission 1111 Howe Avenue Sacramento, Calif.ornia 95825 In the Matter of Sacramento Municipal Utility District (Rancho Seco Nuclear Generating Station)
Docket No. 50-312
Dear Mr. Ellison:
Enclosed are Licensee's responses to " California Energy Commission's First Set of Interrogatories to the Sacramento Muni-cipal Utility District," dated November 15, 1979.
Answers to the interrogatories have been grouped into three sets according to author.
A table attached to this letter identifies the location (s) of the response to each interrogatory.
Licensee's objection to one of the interrogatories is contained in a document distinct from the three sets of answers.
In the enclosed answers to Interrogatory 30, Licensee has identified witnesses expected to be called to testify at the hearing in this proceeding.
This identification is preliminary and tentative, and Licensee may well present witnesses other than, or in addition to, those identified.
Licensee will supplement this answer, however, if and when any changes occur in the identity of witnesses expected to testify.
1666 233 2SI 8001030 r,
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SHAW, PITTMAN, POTTS & TROWBRIDGE Christopher Ellison, Esq. December 4, 1979 The provision of answers to interrogatories is r.ot a representation that Licensee considers the information sotght to be relevant to the subject matter of this proceeding.
Where interrogatories seek identical or similar information, we have attempted to provide helpful cross-references to cther interroga-tory responses.
Where Licensee has encountered difficulty in the interpretation of an interrogatory, the language has been construed in the context of the issues raised by California Energy Commission.
As you know, the Nuclear Regulatory Commission's Rules of Practice provide a longer period of time for the service of responses to document production requests than for the service of responses to interrogatories.
Licensee's response to " Calif-ornia Energy Commission's First Request for Production of Documents to the Sacramento Municipal Utility District," dated November 15, 1979, will be filed as soon as the documents have been assembled in an organized fashion.
Because the documents to be produced are, in our view, self-identifying, Licensee
.has not undertaken the unduly burdensome task of identifying all of these documents in the enclosed ansmmm to interrogatories.
This identification informatica may be obtained by California Energy Commission in the course of inspecting the documents.
Licensee, however, will organize the documents in a meaningful way, and any documents identified by Licensee as responsive to the production request, but Mdch are not produced because of some privilege, will be identified in the response.
I encourage you to contact me to discuss the prospect of an accommodation if any dispute arises with respect to the enclosed responses.
Sincerely, A
Thomas A. Baxter Counsel for Licensee Enclosures cc:
per Certificate of Service 1666 234
Location of Interrogatory Resoonses INTERR0GATORY SET NO.
1-4 1
5,6 3
7 - 10 1
11 - 12 2
13 0
14 - 29 2
30 1,2,3 0: Objection 1666 235 e
R UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
SACRAMENTO MUNICIPAL UTILITY DISTRICT
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Docket No. 50-312
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(Rancho Seco Nuclear Generating Stuion))
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing letter to Mr. Christopher Ellison, " Licensee's Answers (Sets Nos. 1, 2 and 3) to the California Energy Commission's First Set of Interrogatories dated November 15, 1979", and "Licen-see 's Objections to the California Energy Commission's First Set of Interrogatories dated November 15, 1979" were served upon the parties identified on the attached Service List by deposit in the United States mail, postage prepaid, this 4th day of December, 1979.
l k.
__romas A.
Baxter 1666 236 e
3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
SACRAMENTO MUNICIPAL UTILITY DISTRICT
)
Docket No. 50-312
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(Rancho Seco Nuclear Generation
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Station)
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SERVICE LIST I
P14?ahath S. Bowers, Esquire Mr. Richard D. Castro Chaiman 2231 K Street Atcmic Safety ani Licensirq Board Sacramento, California 95816 U.S. Nuclear Regulatory remi==im Wa=hington, D.C.
20555 James S. Reed, Esc.{1 ire Michael H. Rsny, Esquire Dr. Richard-F. Cole Reed, Omal & Rehy Ah mic Safety and Licensing Board Panel 717 K Street, Su%te 405 U.S. Miciaa" Regulatory rmmission h t - w, California 95814 Wa=hington, D.C.
20555 Chrisw/s_r F11%=mn, Esquire Mr. Frederick J. Shan Dian Grueneich/ Esquire Atcraic Safety and Licensing Board Panel califmmia Energy en=i== inn.
U.S. Nuclear Regulatory Ccanission 1111 Howe Avera.1e Washington, D.C.
20555 Sacramento, C=14 fnmia 95825 David S. Kaplan, Esquire Herbert H. B.u al, Esquire Secretary and Ganemi Counsel Lawrence Coe' Ianpher, Esquire Sacramento Mmicipal Utility District Hill, Chris*opher and Phillips, P.C.
P.O. Box 15830 1900 M Street, N.W.
Sacramento, califamia 95813 Wa=hingtons D.C.
20036 Stephen H. Lew2.s, Esquire Docketing and Service Section Office of the Executive Iagal Director Office of the Secretary U.S. N'o1aar Regulatory Ccmnission U.S. Nuclear Regulatory Ca mission Washington, D.C.
20555 Wash @ xt, D.C.
20555 Gary Hursh, Esquire Suite 700 520 Capitol Mall Sacramento, Ca dfornia 95814
)bbb 237
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