ML19257C434
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| 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) | |
Similar Documents at Rancho Seco | |
|---|---|
Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20149E4541994-05-13013 May 1994
[Table view]Licensee First Set of Interrogatories & Request for Production of Documents to Eco.* W/Certificate of Svc. Related Correspondence ML20058P3701993-12-16016 December 1993 Memorandum & Order (Telcon 931209).* Smud Unopposed Motion Granted.W/Certificate of Svc.Served on 931217 ML20058P4161993-12-15015 December 1993 Licensee Petition for Review of Second Prehearing Conference Order & Motion for Directed Certification.* Advises That Commission Accept Review & Grant Directed Certification of Board Rulings.W/Certificate of Svc ML20058E0471993-11-30030 November 1993 Second Prehearing Conference Order (Proposed Contentions; Summary Disposition).* Environmental & Resources Conservation Organization Bases 1,5,11,13,2 & 14 Accepted for Litigation.W/Certificate of Svc.Served on 931201 ML20058E0361993-11-30030 November 1993 Transcript Corrections (Second Prehearing conference,930921- 22).* Board Adopts Listed Corrections.W/Certificate of Svc. Served on 931201 ML20058D6481993-11-19019 November 1993 Exemption from Requirements of 10CFR140.11(a)(4) to Extent That Primary Financial Protection in Stated Amount Shall Be Maintained ML20058E0151993-11-14014 November 1993 Comment Opposing Proposed Rule 10CFR50 Re Exemptions in Accident Insurance for Nuclear Power Plants Prematurely Shut Down ML20057G2181993-10-14014 October 1993 Proposed Transcript Corrections.* Submits Listed Transcript Corrections for 930921 & 22 Prehearing Conference. W/Certificate of Svc ML20058M8951993-10-0505 October 1993 Order (Proposed Transcript Corrections).* Util Submitted Proposed Transcript Corrections for 930921-22 Prehearing Conference.Other Parties May Submit Proposed Corrections by 931015.W/Certificate of Svc.Served on 931005 ML20058M8581993-10-0101 October 1993 Licensee Motion to Correct Transcript of Prehearing Conference.* Requests That Licensing Board Direct Correction of Prehearing Conference Trancript in Manner Described Above.Certification of Svc& Svc List Encl ML20057D1021993-09-27027 September 1993 Eco Answer in Opposition to Smud Motion for Summary Disposition of Eco Original Loop Contention.* Urges Board Either to Deny Motion or to Defer Consideration of Smud Motion to Conclusion of Proceeding.W/Certificate of Svc ML20057D0861993-09-27027 September 1993 NRC Staff Response in Support of Licensee Motion for Summary Disposition of Eco Original Loop Contention.* Summary Disposition Should Be Granted.Certificate of Svc Encl ML20057D1891993-09-27027 September 1993 Exemption from Training rule,10CFR50.120 Requirements to Establish,Implement & Maintain Training Program,Using Sys Approach to Training,For Categories of Personnel Listed in 10CFR50.120.Exemption Effective 931122 ML20057D1351993-09-27027 September 1993 Eco Concise Statement of Material Facts as to Which There Exists Genuine Issue to Be Heard.* Eco Original LOOP Contention Continues to Present Justifiable & Matl Issues Requiring Denial of Smud Motion.Certificate of Svc Encl ML20057D0451993-09-24024 September 1993 Notice of Hearing.* Notifies That Hearing Will Be Conducted in Matter of Proposed Decommissioning of Plant.W/Certificate of Svc.Served on 930924 ML20057D0441993-09-23023 September 1993 Notice of Appearance.* Notice Given That Undersigned Attorney Enters Appearance in Listed Matter & Listed Info Provided.W/Certificate of Svc ML20057C0851993-09-22022 September 1993 Transcript of 930922 Hearing in Bethesda,Md Re Facility.Pp 387-579 ML20057B9611993-09-21021 September 1993 Transcript of 930921 Hearing in Bethesda,Md.Pp 181-386 ML20057B0091993-09-10010 September 1993 Memorandum & Order CLI-93-19.* Informs That Further Questions of Board Re Effect of Commission Holding in Issues Concerning CLI-93-3 & CLI-93-12 Should Be Certified to NRC, Per 10CFR2.718(i).W/Certificate of Svc.Served on 930910 ML20057B0101993-09-0707 September 1993 Licensee Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard (Environ & Resources Conservation Organization Original Loop Contention).* Advises That Contention No Longer Matl Issue.W/Certificate of Svc ML20057B0051993-09-0707 September 1993 Licensee Motion for Summary Disposition of Environ & Resources Conservation Organization Original Loop Contention.* Advises That Contention Presents No Genuine Issue of Matl Fact to Be Heard & Should Be Dismissed ML20057A1721993-08-31031 August 1993 Notice of Prehearing Conference.* Notifies of 930921 Prehearing Conference in Bethesda,Md to Discuss Proposed Decommissioning of Plant.W/Certificate of Svc.Served on 930901 ML20046C5241993-08-0202 August 1993 NRC Staff Response to Eco Contentions on Staff Ea,Finding of No Significant Impact & Se.* W/Certificate of Svc & Notice of Appearance ML20045G9611993-07-12012 July 1993 Environ & Resources Conservation Organization Contentions on Staff Environ Assessment Findings of No Significant Impact & Safety Evaluation.* Urges ASLB to Admit Foregoing Contention Per 10CFR2.714(b)(2).W/Certificate of Svc ML20044F8041993-05-26026 May 1993 Memorandum & Order CLI-93-12.* Util Motion for Reconsideration of CLI-93-03 Denied.W/Certificate of Svc. Served on 930526 ML20045D1871993-05-10010 May 1993 Erratum.* Informs That Correct Ref for Footnote 34 on Page 22 of Commission Memoranudm & order,CLI-93-03,dtd 930303 Is 57 Fed Reg 20,718 (920514).W/Certificate of Svc.Served on 930610 ML20035G3321993-04-21021 April 1993 NRC Staff Response to Eco Contention Re Loss of Offsite Power.* Advises That Eco Contention & Bases Must Be Rejected in Entirety.W/Certificate of Svc ML20035F5841993-04-13013 April 1993 Licensee Response to Eco Proposed Loop Contentions.* Util Opposes Eco Proposed Contentions on LOOP Because Contentions Vague & Confusing & Lack Factual & Legal Bases.W/Certificate of Svc & Svc List ML20035E0031993-04-12012 April 1993 NRC Staff Response to Eco Contentions Re Funding of Decommissioning.* All Bases Eco Decommissioning Funding Contention & Contention Should Be Rejected.W/Certificate of Svc ML20035B5391993-03-26026 March 1993 NRC Staff Support of Licensee Motion for Reconsideration.* Decommissioning Funding Plan Cannot Be Deemed Adequate Until Listed Issues Resolved.W/Certificate of Svc ML20035B5711993-03-26026 March 1993 Environ & Resources Conservation Organization Answer in Opposition to Licensee Motion for Reconsideration.* W/Certificate of Svc ML20035B5441993-03-22022 March 1993 Environ & Resources Conservation Organization Contention on Licensee Proposed Decommissioning Funding Plan.* Environ & Resources Conservation Organization Contends That Licensee Decommissioning Plan Inadequate.W/Certificate of Svc ML20034H8441993-03-12012 March 1993 NRC Staff Opposition to Environ & Resources Conservation Organization Petition for Reconsideration.* Staff Opposes Petition W/Respect to Reconsideration of Paragraph 2.W/ Certificate of Svc ML20034H7991993-03-12012 March 1993 Order.* Orders That Any Response to Smud Petition,From Either NRC or Environ & Resources Conservation Organization, Shall Be Filed by 930326.W/Certificate of Svc.Served on 930312 ML20034H8661993-03-10010 March 1993 Licensee Motion for Reconsideration.* Licensee Requests Commission Reconsider Grant of Discretionary Intervention to Environmental & Resources Conservation Organization. W/Certificate of Svc ML20034G7151993-03-0909 March 1993 Licensee Response to Eco Petition for Reconsideration.* Eco 930305 Petition Should Be Denied in Toto.Certificate of Svc Encl ML20034G6841993-03-0505 March 1993 Environmental & Resources Conservation Organization Petition for Reconsideration.* Urges Commission to Reconsider & Amend 930303 Decommissioning Order.W/Certificate of Svc ML20128D4951993-01-28028 January 1993 Notice of Appointment of Adjudicatory Employee.* W/Certificate of Svc.Served on 930129 ML20127D5091992-09-11011 September 1992 Environ & Resources Conservation Organization Brief in Support of Appeal from LBP-92-23.* Certificate of Svc Encl ML20127D4711992-09-0808 September 1992 Notice of Appeal.* Gives Notice of Appeal from Order of Board (Served 910821),denying Environ & Resources Conservation Organization Petition for Intervention & Request for Hearings & Termination of Proceedings ML20141M5981992-08-20020 August 1992 Prehearing Conference Order (Terminating Proceeding).* Petition for Leave to Intervene & Request for Prior Hearing of Petitioner, ,denied & Proceeding Terminated. W/Certificate of Svc.Served on 920821 ML20141M5881992-08-17017 August 1992 NRC Staff Response in Support of Licensee Motions to Strike Improper Argument in Environmental & Resources Conservation Organization (Eco) Filings.* Further Argument by Eco Unauthorized.Certificate of Svc Encl ML20029B5991991-03-0404 March 1991 Environ Conservation Organization Reply to 910215 Order.* ASLB Should Limit Any Rulings Based on Current State of Record to Rulings Which Presume That Petitioner & Members Have Standing Under Atomic Energy Act.W/Certificate of Svc ML20029B6701991-02-22022 February 1991 Exemption from 10CFR50-54(q) Requirements Re Offsite Emergency Preparedness That Provides Reactor Shutdown & Changes Long Term Defueled Condition ML20024F8321990-12-0505 December 1990 NRC Staff Response in Opposition to Petition to Intervene Filed by Environmental Conservation Organization on Proposed License Amend.Petition Should Be Denied Based on Listed Reasons.W/Certificate of Svc ML20024F8311990-11-30030 November 1990 Licensee Answer to Environ Conservation Organization Petition.* Organization Seeks to Litigate Issues That Are Beyond NRC Jurisdiction & Scope of Proposed License Amend. Petition Should Be Denied.W/Certificate of Svc ML20024F8301990-11-26026 November 1990 Order.* Motion for Extension of Time for 1 Wk to Respond to Environ Conservation Organization Petition for Leave to Intervene & Request for Hearing,Granted.Util Response Due on 901130.W/Certificate of Svc.Served on 901127 ML20024F9081990-11-16016 November 1990 Licensee Motion for Extension of Time.* Extension of Time of 1 Wk Beyond 901123 Deadline Requested,Based on Length of Petition/Request & Intervening Two Holidays.W/Certificate of Svc ML20024F9051990-11-0808 November 1990 Environ Conservation Organization Comment on Proposed NSHC & Petition for Leave to Intervene & Request for Prior Hearing.* Other Remedies Sought Should Be Granted.Notice of Appearance & Certificate of Svc Encl ML20058G9051990-10-23023 October 1990 Comment on Fr Notice Page 41280 to 41282 Re Smud Possession Only License Amend.Believes Termination of Plant OL Prior to End of Authorized Operating Term Will Have Significant Impact on Environ Sources Needed to Generate Power 1994-05-13 Category:PLEADINGS MONTHYEARML20058P4161993-12-15015 December 1993
[Table view]Licensee Petition for Review of Second Prehearing Conference Order & Motion for Directed Certification.* Advises That Commission Accept Review & Grant Directed Certification of Board Rulings.W/Certificate of Svc ML20058M8581993-10-0101 October 1993 Licensee Motion to Correct Transcript of Prehearing Conference.* Requests That Licensing Board Direct Correction of Prehearing Conference Trancript in Manner Described Above.Certification of Svc& Svc List Encl ML20057D1021993-09-27027 September 1993 Eco Answer in Opposition to Smud Motion for Summary Disposition of Eco Original Loop Contention.* Urges Board Either to Deny Motion or to Defer Consideration of Smud Motion to Conclusion of Proceeding.W/Certificate of Svc ML20057D1351993-09-27027 September 1993 Eco Concise Statement of Material Facts as to Which There Exists Genuine Issue to Be Heard.* Eco Original LOOP Contention Continues to Present Justifiable & Matl Issues Requiring Denial of Smud Motion.Certificate of Svc Encl ML20057D0861993-09-27027 September 1993 NRC Staff Response in Support of Licensee Motion for Summary Disposition of Eco Original Loop Contention.* Summary Disposition Should Be Granted.Certificate of Svc Encl ML20057B0101993-09-0707 September 1993 Licensee Statement of Matl Facts as to Which There Is No Genuine Issue to Be Heard (Environ & Resources Conservation Organization Original Loop Contention).* Advises That Contention No Longer Matl Issue.W/Certificate of Svc ML20057B0051993-09-0707 September 1993 Licensee Motion for Summary Disposition of Environ & Resources Conservation Organization Original Loop Contention.* Advises That Contention Presents No Genuine Issue of Matl Fact to Be Heard & Should Be Dismissed ML20035E0031993-04-12012 April 1993 NRC Staff Response to Eco Contentions Re Funding of Decommissioning.* All Bases Eco Decommissioning Funding Contention & Contention Should Be Rejected.W/Certificate of Svc ML20035B5391993-03-26026 March 1993 NRC Staff Support of Licensee Motion for Reconsideration.* Decommissioning Funding Plan Cannot Be Deemed Adequate Until Listed Issues Resolved.W/Certificate of Svc ML20035B5711993-03-26026 March 1993 Environ & Resources Conservation Organization Answer in Opposition to Licensee Motion for Reconsideration.* W/Certificate of Svc ML20034H8441993-03-12012 March 1993 NRC Staff Opposition to Environ & Resources Conservation Organization Petition for Reconsideration.* Staff Opposes Petition W/Respect to Reconsideration of Paragraph 2.W/ Certificate of Svc ML20034H8661993-03-10010 March 1993 Licensee Motion for Reconsideration.* Licensee Requests Commission Reconsider Grant of Discretionary Intervention to Environmental & Resources Conservation Organization. W/Certificate of Svc ML20034G7151993-03-0909 March 1993 Licensee Response to Eco Petition for Reconsideration.* Eco 930305 Petition Should Be Denied in Toto.Certificate of Svc Encl ML20034G6841993-03-0505 March 1993 Environmental & Resources Conservation Organization Petition for Reconsideration.* Urges Commission to Reconsider & Amend 930303 Decommissioning Order.W/Certificate of Svc ML20141M5881992-08-17017 August 1992 NRC Staff Response in Support of Licensee Motions to Strike Improper Argument in Environmental & Resources Conservation Organization (Eco) Filings.* Further Argument by Eco Unauthorized.Certificate of Svc Encl ML20029B5991991-03-0404 March 1991 Environ Conservation Organization Reply to 910215 Order.* ASLB Should Limit Any Rulings Based on Current State of Record to Rulings Which Presume That Petitioner & Members Have Standing Under Atomic Energy Act.W/Certificate of Svc ML20024F8311990-11-30030 November 1990 Licensee Answer to Environ Conservation Organization Petition.* Organization Seeks to Litigate Issues That Are Beyond NRC Jurisdiction & Scope of Proposed License Amend. Petition Should Be Denied.W/Certificate of Svc ML20024F9081990-11-16016 November 1990 Licensee Motion for Extension of Time.* Extension of Time of 1 Wk Beyond 901123 Deadline Requested,Based on Length of Petition/Request & Intervening Two Holidays.W/Certificate of Svc ML20024F8281990-10-0202 October 1990 Licensee Answer to Possible Request for Hearing Filed by Environ Conservation Organization.* Organization Has Not Shown Requisite Interest in Possession Only License Amend Proceeding.W/Certificate of Svc ML20215D6741987-06-12012 June 1987 Suppl 4 to Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W.Ucs Reply to Responses from NRC & B&W Owners Group.* Certificate of Svc Encl ML20210C4191987-04-0606 April 1987 Principal Response of B&W Owners Group to Petition Filed Under 10CFR2.206 by Ucs.* Petition Should Be Denied ML20205F2911987-03-23023 March 1987 Suppl 3 to Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W.* Requests That Listed Names Be Added to List in Paragraph 1 of 870210 Petition ML20210C2691987-03-0606 March 1987 Initial Response of B&W Owners Group to Petition Filed Under 10CFR2.206 by Ucs.* Request for Immediate Suspension Should Be Summarily Denied.W/Certificate of Svc ML20211F5091987-02-20020 February 1987 Suppl 2 to Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W.* Lists Names to Be Added to 870210 Petition & Corrects Address for Save Our State from Radwaste ML20210N4861987-02-10010 February 1987 Petition for Immediate Action to Relieve Undue Risk Posed by Nuclear Power Plants Designed by B&W Co.* OLs & CPs for Facilities Should Be Suspended Until Listed NRC Actions Taken ML20137L5911985-09-10010 September 1985 Response Opposing Jf Doherty 850611 Petition for Show Cause Order Requesting NRC to Institute Consolidated Proceeding Per 10CFR2.202.Certificate of Svc Encl ML20126A3531985-06-11011 June 1985 Petition/Request for Order to Show Cause Why Plants Should Not Be Shut Down Until CRD Mechanisms Inspected ML20032C2861981-11-0303 November 1981 Motion for Extension of Time Until 811211 to File Info Requested by ASLB 811007 Memorandum & Order.Licensee Counsel Has Unavoidable Schedule Conflicts.Nrc & CA Energy Commission Do Not Oppose Motion.Certificate of Svc Encl ML19350B7541981-03-12012 March 1981 Request for Order Compelling NRC Answers to Util 801112 Interrogatories 13-16.NRC Should Have Tabulated Acceptance Criteria & Has Obligation to Do So Now.Certificate of Svc Encl.Related Correspondence ML20003D2261981-03-0909 March 1981 Memorandum of Law That St Lucie decision,ALAB-603,should Not Be Applied to Require Quantitative Assessment of Probability of Failure of TMI-1 Decay Heat Removal Sys Since No Special Circumstances Exist ML19331E3001980-09-0505 September 1980 Memorandum of Law in Support of Encl Findings of Fact & Conclusions of Law Filed in Response to CA Energy Commission 800804 Findings.Urges Issuance of Order to Show Cause If Revision of Commission 800507 Order Warranted ML19330C5551980-08-0404 August 1980 Statement of CA Energy Commission in Support of Proposed Findings of Fact & Conclusions of Law.Urges Issuance of Order Requiring Prompt Commencement of Addl Improvements to Upgrade Safety & Reliability ML19323H6811980-06-0404 June 1980 Motion by CA Energy Commission for Extension Until 800801 to File Proposed Findings of Fact & Conclusions of Law. Suggests 800711 for Licensee findings,800822 for NRC Findings & 800905 for Licensee Reply.W/Proof of Svc ML19296C0971980-02-22022 February 1980 Motion for Extension Until 800304 for Filing Testimony Re CA Energy Commission Issue 5-2.Extension Will Apply to All Parties & Will Not Impact Hearing Schedule.Certificate of Svc Encl ML19294B5351980-02-21021 February 1980 Response by CA Energy Commission in Opposition to Licensee Objection to ASLB Prehearing Conference Order,Part Ii.Urges Denial of Alternative Request Seeking Postponement of Testimony,Due to Agreed Upon Schedule.W/Certificate of Svc ML19296D2171980-02-19019 February 1980 Response in Opposition to Part II of ASLB 800214 Prehearing Conference Order Denying Licensee 800124 Motion for Summary Disposition Re CA Energy Commission Contention 5-2.If Affirmed,Urges Deferral of Testimony.W/Certificate of Svc ML20126A8441980-02-0404 February 1980 Response by CA Energy Commission (CEC) in Opposition to Licensee 800124 Motion for Summary Disposition Re CEC Issue 5-2.General Design Criteria 16 & 50 Established in 10CFR50, App A,Does Not Prohibit Controlled Filtered Venting ML20126A8391980-02-0404 February 1980 Statement of Matl Facts by CA Energy Commission (CEC) in Support of CEC Response to Licensee Motion for Summary Disposition of CEC Issue 5-2.Disputes Licensee Facts Re Commercial Availability of Filtered Sys.Proof of Svc Encl ML20126A8321980-02-0404 February 1980 Response by CA Energy Commission to Licensee Motion for Summary Disposition Re G Hursh & R Castro Contentions. Contention Closely Relates to ASLB Questions.Motion Should Be Denied to Avoid Confusion ML19260D7921980-02-0404 February 1980 Response to Licensee 800124 Motions for Summary Disposition. Opposes Blanket Motion & Disposition of Castro & Hursh Remaining Contentions ML19257C3791980-01-24024 January 1980 Response to Friends of the Earth First Request for Production of Documents & First Set of Interrogatories.Urges Issuance of Protective Order Re Interrogatories Objected to by Nrc.Affidavits & Certificate of Svc Encl ML19257D5821980-01-24024 January 1980 Brief in Support of Motion for Summary Disposition Re CA Energy Commission Contention 5-2.Proposed Controlled Filtered Venting Sys Constitutes Challenge to Design Basis Established by Regulations ML19257D5811980-01-24024 January 1980 Statement of Matl Facts Upon Which There Is No Issue to Be Heard Re CA Energy Commission Contention 5-2.Proposed Controlled Filtered Venting Sys Has Not Been Developed Technically & Is Not Available Commercially ML19257D2171980-01-24024 January 1980 Brief in Support of Motion for Summary Disposition of G Hursh & R Castro Contentions.Mere Allegations W/O Proper Form of Matl or Substantial Facts Are Not Sufficient to Establish Issues,Per 10CFR2.749(b) ML19257D5691980-01-24024 January 1980 Motion for Summary Disposition of CA Energy Commission Contention 5-2 Per Encl Statement of Matl Facts Upon Which There Is No Genuine Issue to Be Heard ML19257D2161980-01-24024 January 1980 Statement of Matl Facts as to Which There Is No Geniune Issue to Be Heard Re G Hursh & R Castro Contentions. Intervenors 791205,800107 & 14 Responses to NRC & Licensee Interrogatories Admitted Absence of Bases for Allegations ML19257D2101980-01-24024 January 1980 Motion for Summary Disposition of Intervenors G Hursh & R Castro Contentions,Per Encl Statement of Matl Facts ML19262C0461980-01-18018 January 1980 Response to CA Energy Commission Motion to Terminate Action Re Emergency Planning Referral to Aslab.Nrc Has No Objection to Granting of Motion.Certificate of Svc Encl ML19257C4571980-01-17017 January 1980 Response to CA Energy Commission Second Request for Production of Documents.Requested Info Will Be Available for Insp & Copying in Sacramanto,Ca at Mutually Covenient Times ML19257C4341980-01-17017 January 1980 Objection to CA Energy Commission Interrogatory 19 of Second Set of Interrogatories.Description of Smud Mgt Is Irrelevant 1993-09-07 |
Text
January 17, 1980 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING E0ARD In the Matter of
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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
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