ML20155A398
| ML20155A398 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 10/23/1998 |
| From: | Gaukler P AFFILIATION NOT ASSIGNED, SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Bollwerk G, Kline J, Lam P Atomic Safety and Licensing Board Panel |
| References | |
| CON-#498-19668 97-732-02-ISFSI, 97-732-2-ISFSI, ISFSI, NUDOCS 9810290019 | |
| Download: ML20155A398 (2) | |
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October 23,1998 Administrative Judge G. Paul Bollwerk, Chairman Administrative Judge Jerry R. Kline Administrative Judg:: Peter S. Lam Atomic Safety and Licensing Board (J.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of Private Fuel Storage L.L.C.(Private Fuel Storage Facility), Docket No. 72-22, ASLBP No. 97-732-02-ISFSI, Joint Status Report on Informal Discovery
Dear Chairman Bollwerk and Judges Kline and Lam:
In accordance with the Board's Memorandum and Order of October 1,1998, the parties hereby file this joint report on the status ofinformal discovery.
The parties have been continuing with the informal document discovery process. The State has been copying and sending to the Applicant the documents requested by the Applicant (approximately 10,000 pages) in its review of State documents in late September.
The State will complete that process by early next week. The Applicant is reviewing these documents both to identify follow-up requests and to prepare for informal interviews. The State has completed its review of the documents produced by the Applicant in Salt Lake City (except for two files of vendor proprietary documents for which consent from the vendor is being sought), requesting about 6000 pages of documents which have been copied and sent to the State. The State has sent to the Applicant this week a follow up request for additional documents which the Applicant is currently reviewing. Both the State and the Applicant are in the process of preparing logs of privileged documents that were not produced and that process should be completed and the logs exchanged in the next couple of weeks.
OGD intends to review in the near future the documents made available by the Applicant in Salt Lake City. OGD has also sent informal requests to the Applicant and the Skull Valley Band for information and documents to which the Applicant, as lead counsel, will reply to shortly on behalf of both it and the Band. OGD has also sent an informal request to the State to which the State is responding. Castle Rock has previously reviewed the initial group of documents made available by the Applicant in Salt Lake City and, over 9810290019 981023 PDR ADOCK 07200022 O}
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POTI5eTBOWBPJDGE A PAAThtBS,cf FNCMICING PLCFRSONAL(C%A4ATILWB Atomic Safety and Licensing Board October 23,1998 Page 2 the next several weeks, expects to review the remaining documents as well as make available documents to the Applicant.
The NRC Staff has reviewed in the offices of Shaw Pittman the Applicant's documents made available to other parties in Salt Lake City and the initial documents produced by State in August as well as the documents produced by OGD in response to requests from the Applicant. The NRC Staffintends to review next week at Shaw Pittman's offices the documents requested by the Applicant in its review of State documents in late September.
In preparation for informal interviews, the parties (other than the Staff) have agreed to exchange by today, October 23,1998, lists of knowledgeable persons for each of the contentions, which in accordance with the Board's April 22 Memorandum and Order (pages 161-162) are those persons for each party that have information relevant to the admitted contention and their supporting bases. These lists will include, but will not be limited to, those individuals that a party has so far to date determined will be hearing witnesses. After,
reviewing the lists, the Applicant and the State intend to confer next week to schedule the first informal interviews which would be conducted by the Applicant in the first part of November. The Applicant intends at that time to travel to Utah in order to conduct informal interviews as well as to review additional State documents that it did not have time to review in late September. The State intends to begin conducting informal interviews in late November. The Staff does not currently expect to schedule informal interviews on its own but intends to participate in those conducted by the other parties. The parties expect informal interviews as well as additional document discovery to continue throughout the remainder of the informal discovery period.
Sincerely, Paul A. Gaukler
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