ML19290C063
| ML19290C063 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 12/17/1979 |
| From: | Remy M FRIENDS OF THE EARTH, REED, SAMUEL & REMY |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19290C052 | List: |
| References | |
| NUDOCS 8001090110 | |
| Download: ML19290C063 (2) | |
Text
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UNITED STATES OF AMERICA M
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NUCLEAR REGULATORY COMMISSION r
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In the Matter of
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SACRAMENTO MUNICIPAL UTILITY
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Docket No. 50-312 DISTRICT
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(Rancho Seco Nuclear Generating
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' FRIENDS OF THE EARTH'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO THE SACRAMENTO MUNICIPAL UTILITY DISTRICT Pursuant to the Nuclear Regulatory Commission's rules of practice, particularly 10 C.F.R.
section 2.744, Friends of the Earth hereby requests that the Sacramento Municipal Utility District
("SMUD") produce at the Friends of the Earth offices, 717 "K"
- Street, Suite 405, Sacramento, California, within 30 days of the date of service hereof, certain documents described below for inspection and copying by Friends of the Earth.
Definition The term " document" shall include, by the way of illustration only and not by way of limitation, the following, whether printed or reproduced by any process, or written, and/or produced by hand, and whether or not claimed to be privileged or otherwise excludable from discovery, namely; studies, analyses notes, correspondence, communications of any nature, telegrams, memoranda, notebooks of any character, summaries or records of personal conversations, checkbooks, checkbook stubs, passbooks, cancelled checks, bills, paid and unpaid, diaries, reports, publications, photographs, minutes or records of meetings, transcripts of oral testimony or statements, reports and/or 1730 036 8 0 0 1 o 9 0,i o summaries of investigations, agreements and contracts,, including all modifications and/or revisions thereof, reports and/or sum-maries of negotiations, court papers, brochures, pamphlets, tape recordings, records and dictation belts.
Any document bearing on any sheet or side thereof, any marks, including, by way of illustration only and not by way of limitation, initials, stamped indicia, any comment or any notation of any character and not a part of the original text, or any reproduction thereof, is to be considered a separate document for purposes of this request.
REQUESTED DOCUMENTS All documents identified by the SMUD in its response to the"Friencs of the Earth First Set of Interrogatories to the Sacramento Municipal Utility District," dated December 17, 1979.
Each interrogatory propounded by the Friends of the Earth relates directly to issues subject to adjudication in this proceeding and, accordingly, each document requested herein is relevant under the NRC's rules of practice.
If any document identified by SMUD and therefore requested herein has been placed in the SMUD Public Document Room, please so indicate.
DATED:
December 17, 1979 Respectfully Submitted, k
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/MICHAELH.
REMY Attorney for Friends of the Earth 1730 037
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