ML20196C369
| ML20196C369 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 06/18/1999 |
| From: | Braxton J UTAH, STATE OF |
| To: | Julian E NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| CON-#299-20555 ISFSI, NUDOCS 9906240011 | |
| Download: ML20196C369 (3) | |
Text
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STATE OF UTAH g 05S5 i
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1 ATTORNEY GENERAL ADJr' JAMES R. SOPER REED RicHARDS soscnor Generai PALMER DEPAuus cruit oeputy Anomey Gwwal Dir.ctor of Pubic Polcy & Communcations 4
i June 18,1999 i
Emile L.Julian, Assistant for Rulemakings and Adjudications Rulemakings and Adjudications Staff Office of the Secretary U.S. Nuclear Regulatory Commission 11555 Rockville Pike, One White Flint North Mail Stop: 016G15 Washington, D.C. 20555 i
Re: In the Matter of Private Fuel Storage, LLC, Docket 72-22 -5 3 F #
Dear Mr.Julian; Enclosed are original signed documents (plus two copies of each) which had not been available at the time certain State's pleadings were filed. They are:
Declaration of David Larsen, dated April 29,1999, the faxed version of which was filed 1.
with the State of Utah's Amended Responses to Applicant's First Set of Formal Discovery Requests, dated April 29,1999; 2.
Declaration of Dr. Marvin Resnikoff, the faxed version of which was filed with the Stat, of Utah's Motion to Compel Applicant to Respond to State's First Set of Discovery Requests, dated April 30,1999. There are two Declarations, one to file with the proprietary version of the pleading and one to file with the redacted version; 3.
Signature page with Brent Bradford's signature, the faxed version of which was filed with the State of Utah's Second Set of Discovery Requests Directed to the Applicant, dated May 13,1999. There are two signature pages, one to file with the proprietary version of the pleading and one to file with the redacted version; 9906240011 990618 PDR ADOCK 07200022 c
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}60 160 East 300 South,5th Floor, P.o. Box 140873, Salt Lake City, Utah 84114 0873 Telephone: (801) 366 0290 Facsimile: (801) 366 0292
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g' lune 18.1999 letter to Emile L. Tulian page 2
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Signature page with Brent Bradford's signature, the faxed version of which was filed with 4.
the State of Utah's Third Set of Discovery Requests Directed to the Applicant, dated May 18,1999. There are two signature pages, one to file with the proprietary version of the 1
pleading and one to file with the redacted version; 5.
' Declaration of Neil Taylor, the faxed version of which was filed with the State of Utah's Response to Applicant's Second and Third Sets of Discovery Requests with Respect to Group I Contentions, dated June 4,1999; and 6.
Declarations of David B. Cole, David Larsen, and Bronson W. Hawley, who.were not available to sign their Declarations at the time the State of Utah's Response to Applicant's Second and Third Sets of Discovery Requests with Respect to Group I Contentions, dated June 4,1999, was filed.
i Please replace the faxed version of these documents with the enclosed original signed
. documents, and add the Declarations of David B. Cole, David Larsen, and Bronson W. Hawley the State of Utah's Response to Applicant's Second and Third Sets of Discovery Requests with Respect to Group I Contentions, dated June 4,1999.
i Please contact me with any questions at (801) 366-0287.
Thank you.
j i
Yours truly, V
'catyhaxto Legal Assistant
Enclosures:
as stated cc: Service List, with documents # 6, without documents # 1-5.
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f CONCLUSION
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f For the foregoing reasons, the Applicant's objections to the Sts'.e's first set of discovery requests on Contention C are without merit. Therefort, PFS shouki be ordered to answer the discovery.
DATED this 30* day of April,1999, Respectfully submitted, Denise Chancellor, Assistant Attorney General j
Fred G Nelson, Assistant Actorney General Diane Curran, Special Assistant Attorney General Connie Nakahara, Specid Assistant Attorney General Attorneys for State of Utah Utah Attorney General's Office 160 East 300 South,5th Ploor, P.O. Box 140873 Salt Lake City, UT 84114 0873 Telephone: (sC1) 3M286, Fax: (801) 366 0292 i
DECLARATION OF DR.MARVIN RESNIKOFF Under penalty of perjury, I, Dr. Marvin Resnikoff, declare that I am the State's qualified expert with respect to Contention C, that the foregoing factual sacertions regarding the nature of and bases for Contention C are true and correct to the best of my knowledge and belief, and that th forego
- g statements regarding relevance of the requestad discovery tent"pnC professional judgment, o
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/ r. Marvin Resnikoff
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