ML20149E454

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Licensee First Set of Interrogatories & Request for Production of Documents to Eco.* W/Certificate of Svc. Related Correspondence
ML20149E454
Person / Time
Site: Rancho Seco
Issue date: 05/13/1994
From: Doris Lewis
SACRAMENTO MUNICIPAL UTILITY DISTRICT, SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
Atomic Safety and Licensing Board Panel
References
CON-#294-15046 93-677-01-DCOM, 93-677-1-DCOM, DCOM, NUDOCS 9405310111
Download: ML20149E454 (26)
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.n fb RELATED CORRESPONDENCbOCKETED -

USHRC May 13, 1994 UNITED STATES OF AMERICA.og nyt 16 P3:32 NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Lice ing dHnhLa In the Matter of )

) Docket No. 50-312-DCOM SACRAMENTO MUNICIPAL UTILITY )

DISTRICT ) (Decommissioning Plan)

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(Rancho Seco Nuclear ) ASLBP No. 93-677-01-DCOM-R Generating Station) )

LICENSEE'S FIRST SET OF INTERROGATORIES j 1

AND REQUEST FOR PRODUCTION OF DOCUMENTS TO ECO Parsonnt to 10 C.F.R. SS 2.740b and 2.741, the Sacramento Municipal Utility District nereby serves on Environmental and Resources Conservation Organization (ECO) the interrogatories and-requests for production of documents identified below. Under the-Commission's Rules of Practice, ECO must serve its response to these interrogatories within fourteen (14) days of their service, and must serve its response to the request for documents within thirty (30) days of service.

I. DEFINITIONS As used herein, the following terms have the following i meanings:

1. "ECO," "Intervenor," "you," "your," and any synonym thereof or derivative therefrom, refers to and includes Envirc,nmental and Resources Conservation Organization and its employees, agents, 9405310111 940513 D. '

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representatives, members, and any other persons or entities act-ing on ECO's. behalf.

2. The " District," "SMUD," and " Licensee," and any synonym thereof or derivative therefrom, refers-to the Sacramento Munici-pal Utility District.
3. "NRC" or " Commission" refers to the U.S. Nuclear Regulatory Commission.

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4. " Rancho Seco" means the Rancho Seco Nuclear Generating Station.
5. "ISFSI" refers to the Independent Spent Fuel Storage Instal-lation to be built at Rancho Seco.
6. " Document" means any written, recorded, or graphic matter, ~

however produced or reproduced, in the possession,. custody or i control of Intervenor or any employee, agent, representative or member of Intervenor, or person or entity acting on its behalf.

It includes, but is not limited to, all information recorded electronically, chemically or magnetically.

7. " Person" shall mean any individual, partnerrhip, firm, asso-ciation, corporation, agency, or other governmental, legal or business entity. "
8. "Date" shall mean the exact day, month, and year, if ascer- '

tainable, or if not,'the best approximation thereof.

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9. " Decommissioning Funding Plan" refers to the District's Revised Financial Assurance Plan for Decommissioning Rancho Seco Nuclear Generating Station (May 1991) (App. C to Proposed Decom-

!' missioning Plan), and any amendments or revisions thereto.

10. " Rancho Seco Decommissioning Trust Fund" refers to the external trust fund established by the District, pursuant to a trust agreement with Bankers Trust Company of New-York, into I which the District contributes funds for the decommissioning of Rancho Seco.
11. The phrase " Funding Contention Basis" followed by a specific number refers to a paragraph designated by the same number in ECO's Contention on Licensee's Proposed Decommissioning Funding Plan (March 22, 1994), but only to the extent that assertions in such paragraph were admitted for litigation by the Atomic Safety and Licensing Board in its Second Prehearing Conference Order, LBP-93-23 (Nov. 30, 1993). For example, " Funding Contention ;

Basis 1" refers to the first numbered paragraph in ECO's conten- \'

tion on Licensee's Proposed Decommissioning Funding Plan (March 22, 1994), but only to the extent that the assertions in that numbered paragraph were admitted by the Atomic Safety and Licensing Board for litigation in this proceeding. 1

12. " Admitted Funding Contention Bases" means Funding Contention Basis 1, Funding Contention Basis 2, Funding Contention. Basis 4,

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Funding Contention Basis 5, Funding ContentionLBasis 11, and Funding Contention Basis 13, both individually and collectively. '

II. INSTRUCTIONS i

1. Each interrogatory shall be answered separately and fully in-writing under oath or affirmation, unless it is objected to, in which event the reasons for objection shall be stated. The answers shall be signed by the person making them, and the objec-tions shall be signed by the attorney making them.
2. Each request for production of documents.shall also be responded to in writing. Each response shall state, with regard to each item or category of document requested, that.that inspec-tion will be permitted as requested, unless the request is ,

objected to, in which case the reasons'for the objection shall be stated. If objection is made to a part of an item or category, the part shall be specified.

3.

If you claim that any information required to be provided by you in response to an interrogatory or request for' production of documents is privileged, identify the specific privilege (s) asserted and state all facts upon which the assertion of the privilege is based.

a. If you assert privilege with respect to a communica-tion, identify the general subject matter of the

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communication,'the date and time of the communication, and all persons present at or party to the communication.

b.

If you assert privilege with respect to'a document, identify the document, its general _ subject matter, and all persons who have received or viewed the original or any copy-of the document.

4.

If you cannot respond to a particular interrogatory or request for production of documents in full, respond to the extent possible and explain your inability to answer the remainder.

5.

In each case where you are asked to identify a document, state:

a. the title of the document;
b. the date of the document; and c.

the person who created or prepared the. document.

6.

In each case where you are asked to identify a person, state:

a. the full name of the person; .

b, the last known business and residential addresses and telephone numbers of the person; and c.

the business affiliation or employment of'the person.

7.

In each case where you are asked to identify a communica-tion, identify:

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a. the date of communication; e
b. the substance of the communication in as much detail as possible; i
c. 'all persons participating in, hearing, or receiving the communication; and
d. all_ documents. relating to the communication.-
8. These interrogatories and request for production of docu-F ments are intended to be continuing in nature, and the answers should be promptly supplemented or amended, as appropriate, pur-suant to 10 C.F.R. 2.740(e), should you obtain any new or differ-ing information responsive to these discovery requests.

III. Interrogatories 1

A. General Interrogatories

1. Identify each member of ECO who has' experience in nuclear power-plant decommissioning and describe such experience. ]
2. Identify each member of ECO who has experience with utility ,

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planning or finance and describe such experience. 1

3. Identify all documents relating to views exprecsed by any I member of ECO concerning: '
a. the-decommissioning of Rancho Seco; 1
b. funding or financing for Rancho Seco's decommissioning;;
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c. the District's financial condition.

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4. Identify all communications between ECO and any member ofL

- ECO concerning:

a. .the decommissioning of Rancho Seco;
b. funding or financing for Rancho Seco's decommissioning;
c. the District's financial condition.
5. Identify all communications, other than filings before the NRC, between ECO and persons other than ECO's members concerning:
a. the decommissioning of Rancho Seco;
b. funding or financing for Rancho Seco's decommissioning; *
c. the District's financial condition.
6. Identify each person known to ECO to have first-hand-knowl- l edge of the facts alleged in and upon whom ECO relied in formu-lating the Admitted Funding Contention' Bases.

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a. With respect to each such person, state those facts of which the person has first hand knowledge and on which'ECO ,

relied; and

b. Identify the specific Funding Contention Basis which ECO contends such facts support.
7. Who drafted ECO's Contention on Licensee's-Proposed Decom-missioning Funding Plan (March 22, 1994)?
8. Identify all persons who reviewed ECO's Contention on Lic- >

ensee's Proposed Decommissioning Funding Plan (March 22, 1994)- '

before it was filed.in.this proceeding.

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9. Identify each person who prepares, or assists in preparing,- e the answers to these general and specific interrogatories. #
10. Identify each person who provides information-upon which ECO relies in answering these general and specific interrogatories,
a. Identify all information which was provided by such person and the specific interrogatory response in which'such.

information is contained.

11. Identify each person whom ECO intends to call as an expert witness in this proceeding. With respect to each such person:
a. Identify the specific Funding Contention Basis on which the person will testify;
b. Identify the subject matter to which such person is expected to testify; l
c. Identify fully all educational and professional experi - =1 I

ence upon which ECO will rely to qualify such person as an- R i

expert, ,]

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12. Identify each person whom ECO intends to call as a fact wit-  ;

u ness in this proceeding. With respect to each such person: )

a. Identify the specific Funding Contention Basis on which the person will testify; and
b. Identify the subject matter to which such person is expected to testify.
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13. Identify all documents, including relevant page citations, which ECO relied upon in' formulating the Admitted Funding'Conten-'

tion Bases. With respect to each such document, identify the l specific Funding Contention Basis to which the document relates.

14. Identify all documents, including relevant page citations,.

upon which ECO relies in answering any of the general or specific interrogatories herein. With respect to each such document, identify each interrogatory response to which the document relates.

15. Identify any other source of information, including communi-cations, which is used in answering any of the specific or gen-eral interrogatories herein. With respect to each such source or j

communication, identify each specific interrogatory response to J

which the source or communication relates. 1

16. Identify all documents which ECO intends to offer as exhib- 1 its during this proceeding. With respect to each such document, a.. provide the relevant page citations, and
b. identify each specific Funding Contention Basis to  ;

which the document pertains.

B. Specific Interrogatories  ;

1. Have you reviewed Revision 1 to the Rancho Seco Independent-Spent Fuel Storage Installation License Application and Safety Analysis Report, filed with the NRC on October 27, 1993? .

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2. Do.you still contend that the design of:the District's ISFSI t is unavailable, as alleged in Funding Contention Basis 2?
a. If you still contend that the design of:the Districts ,

ISFSI;is unavailable, identify specifically andfin detail ,

the precise information on ISFSI design that you contend is needed in' order to produce a reliable decommissioning fund-ing estimate.

3. Are you familiar with the NUHOMS design?
4. Do you agree that the NUHOMS design is well established?
5. Do you still contend that contract pricing information-for the proposed ISFSI is unavailable, as alleged in Funding Conten-tion Basis 2?
a. If you still contend that contract pricing information for the ISFSI is unavailable, identify specifically.the pre-cise~ prices or costs that must be specified to produce a reliable decommissioning funding estimate.

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6. Do you maintain that spent fuel storage costs are part of- l decommissioning costs? If so, I
a. state the basis for this. position;  ;
b. identify'all documents that support this position; and H
c. state whether this position is supported by the nuclear industry.

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7. Do you contend that'the cost of an ISFSI using the NUHOMS'

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design cannot be reasonably estimated?

8. Provide your most reasonable estimate of the cost of V

L. ins'talling an ISFSI (using the NUHOMS design) at Rancho Seco.

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9. Identify all' documents that discuss or relate to the cost of installing an ISFSI at Rancho Seco.

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10. Do you contend that that the ISFSI at Rancho Seco cannot be completed by 1998? If you do contend that the ISFSI at Rancho Seco cannot be completed by 1998, j
a. identify each specific fact.that makes such_ completion j impossible; and
b. identify all documents that support your position.
11. Do you contend that the ISFSI at Rancho Seco likely will not be completed by 1998? If you contend that the ISFSI at Rancho Seco likely will not be completed by 1998, H

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a. identify each specific fact that makes such completion by 1998 unlikely, and ] 1
b. identify all documents that support your position. l
12. Do you contend that there is insufficient information to estimate the amount of time it takes to license and construct an ISFSI using the NUHOMS design?

9' 11 3 . How long has it taken to license and' construct an ISFSI.

using the'NUHOMS design at other nuclear power plants?

14. What is your most reasonable estimate of how long it will take to license and construct an ISFSI at Rancho Seco using the NUHOMS design?

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15. Do you contend that the NUHOMS design cannot be licensed for~

fuel storage at Rancho Seco? If so, provide the basis for this l

assertion.

16. What is your most reasonable estimate of how long it will take the NRC to issue a license under 10 C.F.R. Part 72 for an ISFSI using the NUHOMS design at Rancho Seco?
17. State all facts supporting your use of the term " probable" in Funding Contention Basis 14 to describe a 25% increase in'the decommissioning cost estimate due to uncertainty in the licensing and construction of the ISFSI? Do you still contend that this increase is " probable?" If so, identify all documents that sup-port this position.
18. Do you still contend that the District "will not be able to continue its commitment to the Decommissioning Funding Plan," as alleged in Funding Contention Basis 1? If so,
a. identify each specific fact that supports this posi-tion; and
b. identify all documents that support this position.  ;

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19. State all facts and identify all' documents that' support the position, as alleged in Funding Contention Basis 1, _that the Dis-  ;

trict's "long-term debt is incroasing at the rate of'8.8% per  ;

year."

20. Do you still contend that the-District's long-term debt is '

increasing at the rate of 8.8% per year?'

21. Do you contend that the District does not or will not have- '

sufficient funds to cover its long-term debt service? If so,

a. identify each specific fact that supports this posi- <

tion; and

b. identify all documents that support this position. ,
22. Do you know to what extent the District's long-term debt is~  !

in the form of revenue bond obligations? If so, identify-specif-- i e

ically the source (s) of such knowledge.

23. Are you familiar with the process for underwriting revenue bonds? If so, identify specifically the source (s).of such familiarity.
24. Explain in detail how revenue bond obligations can affect I the District's ability to make required contributions to the '

Rancho Seco Decommissioning Trust Fund.

25. Do you contend that it is not prudent utility practice to finance capital improvements with long-term bonds?' If so, ,

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a. identify each specific factithat supports this'posi-tion; and
b. identify all documents that' support this position. '
26. Do you contend that the District has issued revenue bonds to -

pay for operating and maintenance expenses, and not to pay for'  ;

capital items? If so,

a. identify each specific fact that supports this posi- -

tion; and

b. identify all documents that support this position.
27. Do you contend that the existence of long-term debt obliga- -

tions does or will interfere with or otherwise affect the Dis-trict's ability to make contributions to'the Rancho Seco Decom-missioning Trust Fund? If so,

a. ' explain in detail how the existence of long-term debt obligations will affect-the District's revenues, from which i revenues the District will make its required contributions to the Rancho Seco Decommissioning Trust Fund;
b. identify each specific fact that supports your answers-to this Interrogatory; and
c. identify all documents that support your answers'to  ;

this Interrogatory.

28. Have you reviewed the covenants in any of the official

-statements relating to the District's revenue bonds?

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29. Do you contend that the existence of long-term debt obliga-tions does or will interfere with or otherwise' affect the Dis-trict's ability or authority to set its rates? If so,
a. identify each specific fact that supports this posi-tion; and
b. identify all documents that support this position.
30. Identify each specific fact and identify all documents that support the position, as alleged in Funding Contention Basis 1, that the District has " avoided" rate increases through the issu-ance of long-term bonds.
31. How many members does ECO have and how many of these members reside or work in the District's service area?
a. Do these members believe that'the District should increase its rates?
b. Identify all ECO members working or residing in the District's service area.
32. Do you contend that the District's' rates are insufficient to cover the District's current operating expenses and debt. service?

If'so,

a. identify each specific fact that supports this posi-tion; and
b. identify all documents that support this position.

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33. Are'you' aware that in connection with the issuance of its revenue bonds, the District has covenanted to establish and main-tain rates which, together with certain items of other income, will yield sufficient revenues to cover, among other things, operating and maintenance costs as'well as its debt service on the revenue bonds? .
34. In light of the covenant referred to.in Interrogatory 33, explain in detail how the District's issuance cf long-term bonds has " avoided" rate increases, as alleged in Funding Contention Basis 1.

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35. Do you contend that the District's partial reliance'on pur-chased power does or will interfere with or otherwise affect'the District's ability to make contributions to the Rancho Seco Decommissioning Trust Fund? If so, i d'
a. explain in detail'how the District's partial reliance s

on purchased power will affect the District's revenues, from which revenues the District will make its required contribu-4 tions to the Rancho Seco Decommissioning Trust Fund; i

b. identify each specific fact that supports your answers '

to this Interrogatory; and

c. identify all documents that support your answers to i this Interrogatory.

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36. Do you contend that the District's partial reliance on pur-chased power does or will interfere with or otherwise affect the District's ability or authority to set its rates? If so,
a. identify each specific fact that supports this posi-tion; and,
b. identify all documents that support this position.
37. Do you still contend, as alleged in Funding ContentionLBasis .

5, that "[a] significant portion of SMUD's plans to provide for savings to pay for the decommissioning funding program is pre-mised on the savings projected to be achieved through SMUD's Con-servation and Load Management Programs"? If so, +

a. identify each specific fact that supports this posi- >

tion; and

b. identify all documents that support this position.
38. Identify, with page and paragraph references, that portion y of the "SMUD 1991 Load Forecast," cited as support for Funding Contention. Basis 5, that supports your contention, as alleged in Funding Contention Basis 5, that "[a)-significant portion of SMUD's plans to provide for savings to pay for the decommission-ing funding program is premised on the savings projected to be achieved through SMUD's Conservation and Load Management-Programs."
39. Explain in detail the relationship, if any, between the Dis-trict's Conservation and Load Management Programs and q

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decommissioning funding, and identify all documents that discuss I such a relationship. .

40. Are you aware of the difference between a " goal" and a " pre- ,

l diction"? If so, explain that difference, and explain why, in Funding Contention Basis 5, you referred to a District "predic-tion" of 1991 peak load when the referenced document refers to a District " goal" for 1991 peak load.

41. Do you still contend, as alleged in Funding Contention Basis 5, that the Commission can have no " confidence" in the District's  ;

long-term estimates of savings the District can achieve in "other areas"? If so,

a. identify the "other areas" you are referring to;
b. explain in detail why the District's planned periodic review of decommissioning funding would not be sufficient:to address any variances between its long-term estimates and ..

actual experience;

c. identify each specific fact that supports your answers to this Interrogatory; and i
d. identify all documents that support your answers to  !

this Interrogatory.

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42. Do you still' contend, as alleged in Funding Contention Basis 11, that a[t]here can be no confidence in the SMUD Decommission-ing Funding Plan because SMUD has failed to provide a.long-term q Utility District overall financing plan"? If so, 1

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  • E a. identify each specific fact that supports this posi-tion; and p b. identify all facts that support this position..

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43. Explain what is meant by a "long-term . . . overall financ-ing plan," as alleged in Funding Contention Basis 11. In partic-l ular, and without limiting the generality of the foregoing, iden-tify specifically and in detail the precise information that must or should be included in a "long-term . . . overall financing plan."
44. Does the NRC require the submission of the type of "long-term . . . overall financing plan" described in Funding Conten-tion Basis 11 in order to review and assess a decommissioning funding plan? If so,
a. identify each specific fact that supports this posi- g tion; and
b. identify all documents that support this position.
45. Do you contend that, in the absence of the type.of "long-a term ... . overall financing plan" described in Funding Conten- )

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tion Basis 11, a decommissioning funding plan is inadequate to l 1

allow the Commission to determine whether a licensee has provided  !,

reasonable assurance of funds for decommissioning? If so,

a. identify specifically and in detail the. precise infor-mation relating to decommissioning. funding that you contend is necessary to allow'the Commission to determine whether a

licensee has provided reasonable assurance of funds for decommissioning, and explain in detail why such information is necessary;

b. identify each specific fact that supports your answers ,

to this Interrogatory; and

c. identify all documents that support your answers to this Interrogatory.
46. Do you contend that the District's bond ratings are not an adequate indicator of the District's long-term credit-worthiness and financial performance? If so,
a. identify each specific fact that supports this posi-tion; and
b. identify all documents that support this' position.
47. Do you contend that the bond rating agencies are unqualified to rate the District's credit-worthiness? If so,
a. identify each specific fact that supports this posi-tion; and
b. identify all documents that support this position.
48. Do you disagree with the District's current bond ratings?

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a. identify each specific fact that supports this posi-tion; and
b. identify all documents ch t support this position.

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49. Do you still contend, as e.lleged in Funding Contention Basis 13, that the Decommissioning Funding Plan was premised "on growth through interest earnings that are now' unrealistically high"?. If so,
a. identify each specific fact that supports this posi-tion; and
b. identify all documents that support this position.
50. Do you contend that the District's planned periodic review of its rate of return on decommissioning trust funds would not be sufficient to address any variances between its expected rate of return and actual experience? If so,
a. identify each specific fact that supports this posi-tion; and
b. identify all documents that support this position.
51. Do you still contend, as alleged in Funding Contention Basis 4, that the District should prepare and file with the Commission-a " semi-annual" report on decommissioning funding? .If so,
a. explain in detail why a requirement.for a semi-annual report is necessary to allow the.commissica to determine ,

whether the District has provided reasonable assurance of funds for decommissioning; '

b. explain in detail why the District's plan to perform '

periodic reviews of matters affecting decommissioning fund-  ;

ing is not adequate to allow the Commission to determine ,

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whether the District has provided reasonable assurance of 1

ful-J for decommissioning;

c. identify specifically and in detail the precise matters that you contend should be discussed in the semi-annual report and how those matters relate to decommissioning funding;
d. identify each specific fact that support your answers to this Interrogatory; and
e. identify all documents that support your' answers.to r this Interrogatory.

Have you reviewed Resolution 91-6-9, adopted by the Dis-52.

trict's Board of Directors on June 4, 1991, which commits the District to collect for decommissioning through rates?

IV. Request for Production of Documents  ;

33 Licensee requests ECO to produce for inspection and copying at ECO's offices or at the offices'of ECO's counsel, within , -;

i thirty (30) days after service hereof, the following: l l

1. All documents identified in your answers to the foregoing  ;

'l Interrogatories. ,

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2. All documents that-refer, reflect.or relate to ECO's forma- ..

tion and/or chartering.

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All documents that refer, reflect or relate to ECO's current membership.

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4. .All documents that refer, reflect or relate to any communi- ,

cation identified in your answer to General Interrogatory 4.

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5. All documents that refer, reflect or relate to any communi-

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cation identified in your answer to General Interrogatory 5.

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6. All documents that refer, reflect or relate to each person identified in your answer to General Interrogatory 11, including, without limitation, all documents that refer, reflect or relate to either the subject matter to which the person is expected to

-testify, and/or the educational and professional experience upon which ECO will rely to qualify such person as an expert, I

7. All documents that refer, reflect or relate to each person ,

identified in your answer to General Interrogatory 12, including, without limitation, all documents that refer, reflect or relate to the subject matter to which the person is expected to testify.

8. All documents that refer, reflect or relate to any source of information, including communications, identified in-your answer to General Interrogatory 15. .
9. All' documents, other than those authored by the District.or

-its representatives or the NRC, relating to the decommissioning. 1 of Rancho Seco. 1

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All documents, other than those authored by the District or

'its representatives or the NRC, relating to-a.

funding or financing for Rancho Seco's decommissioning; b.

the District's financial condition.

Respectfully submitted, O

Thomas A. Baxter, P.C.

David R. Lewis Vincent J. Colatriano SHAW, PITTMAN, POTTS & TROWBkIDGE 2300 N Street, N.W.

Washington, D.C. 20037 (202) 663-8000 Dana S. Appling, Esq.

General Counsel SACRAMENTO MUNICIPAL UTILITY DISTRICT P. O. Box 15830 Sacramento, California 95813 (916) 732-6123 Counsel for Licensee Dated: May 13, 1994 i

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RELATED CORRESPONDENCE l l

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

.) Docket No. 50-312-DCOM SACRAMENTO MUNICIPAL UTILITY )

DISTRICT ) (Decommissioning Plan)

)

(Rancho Seco Nuclear Generating ) ASLBP No. 93-677-01-DCOM-R Station) )

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CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing " Licensee's  :

First Set of Interrogatories and Request for Production of Docu-ments to ECO," dated May 13, 1994, are being served upon the per- ,

sons on the attached Service List by deposit,in the United States mail, first class, postage prepaid, this 13th day of May,_1994. ,

t David R. Lewis 4

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9 DOCKETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION L Before the Atomic Safety and Licensing BoNdMM' 16 P3 :32 In the Matter of Docket No.hFFICE OF SECRETARY

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)  % EVICE SACRAMENTO MUNICIPAL UTILITY )

DISTRICT ) (Decommissioning Plan)

)

(Rancho Seco Nuclear Generating ) 'ASLBP No. 93-677-01-DCOM-R Station) )

SERVICE LIST Administrative Judge office of the Secretary Charles Bechhoefer, Esq., Chairman Attn: Docketing and Service Branch Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Adjudicatory File Administrative Judge Atomic Safety and Licensing Board j Dr. Richard F. Cole U.S. Nuclear Regulatory Commission ,

Atomic Safety and Licensing Board Washington, D.C. 20555 l U.S. Nuclear Regulatory Commission Washington, D.C. 20555 office of Commission Appellate Adjudication Administrative Judge- U.S. Nuclear Regulatory Commission Mr. Thomas D. Murphy Washington, D.C. 20555' Atomic Safety and Licensing Board i U.S. Nuclear Regulatory Commission James P. McGranery, Jr., Esq.

Washington, D.C. 20555 1255 - 23rd Street, N.W.

Suite 750 Mitzi A. Young, Esq. _ Washington, D.C. 20037 Lisa Clark, Esq.

office of the General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dana S. Appling, Esq.

General Counsel' .j Sacramento Municipal Utility -I District P.o. Box 15830 1 Sacramento, CA 95813 I o '

0329:033DRL.94 i

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