ML19257C434
| ML19257C434 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 01/17/1980 |
| From: | Baxter T SACRAMENTO MUNICIPAL UTILITY DISTRICT, SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | CALIFORNIA, STATE OF |
| Shared Package | |
| ML19257C422 | List: |
| References | |
| NUDOCS 8001290120 | |
| Download: ML19257C434 (1) | |
Text
January 17, 1980 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING E0ARD In the Matter of
)
)
SACRAMENTO MUNICIPAL UTILITY DISTRICT
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Docket No. 50-312
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(Rancho Seco Nuclear Generating Station)
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LICENSEE'S OBJECTIONS TO THE CALIFORNIA ENERGY COMMISSION'S SECOND SET OF INTERR0GATORIES TO THE SACRAMENTO MUNICIPAL UTILITY DISTRICT 19.
INTERROGATORY:
Identify each employment position or class of personnel at Rancho Seco. Provide a description of the management and reporting of these employees, as well as descriptions of the job duties.
Include the following:
A.
Numbers of employees in each position.
B.
Responsibilities and qualifications of each position.
C.
Identity specific individuals who assist or maintain the operation of plant equipment.
D.
Identify all plant personnel (other than licensed operators) who have left employment at Rancho Seco in the last two years, including the reason they left.
OBJECTION:
Licensee has provided, in Set No. 2 of its answers, an answer to this interrogatory with respect to operations, maintenance, engineering, chemistry and health physics personnel at Rancho Seco.
Licensee objects to the interrogatory, to the extent that it applies to other District employees at Rancho Seco, on the ground that it seeks information which is not relevant to the matters in controversy in this 183&290 croceeding.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWERIDGE
/.O.,.
[_
j Thomas A. Baxter 8001290 I,
Counsel for Licensee 1800 M Street, N.W.
Washington, D.C.
20036 (202) 331-4100