ML20196C384
| ML20196C384 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 06/18/1999 |
| From: | Braxton J UTAH, STATE OF |
| To: | Julian E NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20196C389 | List: |
| References | |
| CON-#299-20556 ISFSI, NUDOCS 9906240015 | |
| Download: ML20196C384 (5) | |
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Mtim!D00RRESPONDENCE O 5 65; STATE OF UTAH OFFICE OF Tile ATTORN E Y G EN Ek A L 00i:MFICD
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.I A N GRAHAM ii ATToRNE Y GENER AL A[.V JAMES R. SOPER HEEo RicHAR0s some Gene <ai PALMER DEPAuus chief Deputy Anomey General Owector of PuNc Pdcy & Communcaons June 18,1999 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 l
Mail Stop: 016G15 Washington, D.C. 20555 Re:In the Matter of Private Fuel Storage, LLC, Docket 72-22 W D 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:
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Declaration of David Larsen, dated April 29,1999, the faxed version of which was filed with the State of Utah's Amended Responses to Applicant's First Set of Formal Disco Requests, dated Ap ". 29,1999; 2.
Declaration of Dr. Marvin Resnikoff, the faxed version of which was filed with the State 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; Signature page with Brent Bradford's signature, the faxed version of which was filed with 3.
the State of Utah's Second Set of Discovery Requests Directed to the Applicant, dat 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; l
9906240015 990618 PDR ADOCK 07200022 C
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160 East 300 South. 5th Floor, P.o. Box 140873 Salt Lake City, Utah 84114 0873 Telephone: (801) 366 0290 Facsimbe: (801) 366 0292
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June 18.1999 letter to Emile L.Julian. page 2
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Signature page with Brent Bradford's signature, the faxed version of which was filed with 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 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 i
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.
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. Hawle the State of Utah's Response to Applicant's Second and Third Sets of Discovery Requests with Respect to Group I Content;ons, datedJune 4,1999.
Please contact me with any questions at (801) 366-0287.
Thank you.
Yours truly, W
gear raxto Legal Assistant
Enclosures:
as stated cc: Service List, with documents # 6, without documents # 1-5.
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DECLARATION I, David Larsen, hereby declare under penalty of perjury and pursuant to 28 U.S.C. 51746,
. that the statements contained in State of Utah's 1999, Amended Responses to Applicant's First Set'of Formal Discovery Requests, with respect to Utah Contention K (Inadequate Consideration of Credible Accidents, specifically State's Response to Request for Admission No.
26, and State's Response to Request for Admissions No.14, No.15, and No.16) are true and correct to the best of my knowledge, information and belief.
h day of
,1999.
Dated this By:
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David Larsen Environmental Scientist, Geologist Division of Solid and Hazardous Waste Utah Department of Environmental Quality l
r DATED this 13th day of May,1999.
L Respectfully submitted, STATE OF UTAH
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W aW Brent Bradford
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Deputy Director Utah Department of Environmental Quality l
Denise Chancellor, Assistant Attorney General Fred G Nelson, Assistant Attorney General Diane Curran, Special Assistant Attorney General Connie Nakahara, Special Assistant Attorney General Attorneys for State of Utah Utah Attorney General's Office 160 East 300 South,5th Floor, P.O. Box 140873 Salt Lake City, UT 84114-0873 Telephone: (801) 366-0286, Fax: (801) 366-0292 J
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DATED this 18th day of May,1999.
Respectfully submitted, STATE OF '
._N)f l-Brent Bradford
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Deputy Director Utah Department of Environmental Quality Denise Chancellor, Assistant Attorney General Fred G Nelson, Assistant Attorney General Diane Curran, Special Assistant Attorney General Connie Nakahara, Special Assistant Attorney General Attorneys for State of Utah Utah Attorney General's Office 160 East 300 South,5th Floor, P.O. Box 140873 Salt Lake City, UT 84114-0873 Telephone: (801) 366-0286, Fax: (801) 366-0292 l
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