ML20203F137
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| ML20203F137 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 02/23/1998 |
| From: | Curran D HARMON, CURRAN, SPIELBERG & EISENBERG, LLP. |
| To: | Bollwerk J Atomic Safety and Licensing Board Panel |
| References | |
| CON-#198-18832 ISFSI, NUDOCS 9802270215 | |
| Download: ML20203F137 (2) | |
Similar Documents at 07200022 | |
|---|---|
Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217E0661999-10-12012 October 1999
[Table view]Forwards Original Declaration of M Resnikoff in Support of State of Utah Amended Contention V, ,not Available at Time State of UT 991004 Request for Admission of late-filed Amended Utah Contention V.Related Correspondence ML20212G0161999-09-24024 September 1999 Forwards Copy of That NRC Received from Jp Jp Kennedy Re L Bear Representation of Skull Valley Band of Goshute Indians in Connection with ISFSI Proposed to Be Constructed by Pfs Llc.Related Correspondence.Without Encl ML20216F3981999-09-20020 September 1999 Forwards List of Documents Responsive to State Second Discovery Request.Without Encl.Related Correspondence ML20212G0461999-09-20020 September 1999 Forwards Original Signed Reply Declaration of M Resnikoff in Support of State of Utah Second Amended Contention Q, ML20211P6341999-09-0909 September 1999 Forwards Calculation Package List in Re Rev of Submittal Schedule.List of Contents Submitted ML20211Q9251999-09-0808 September 1999 Informs That Author Recently Became Aware of Evidence Which Author Believes Reflects Serious Conflicts with Evidence Presented to & Being Relied Upon by Licensing Board Re Pfs.Related Correspondence ML20211M6741999-09-0303 September 1999 Responds to NRC 990819 Telcon Re Projected Future Growth in Civilian & Military Air Traffic,Use of Flight Termination Systems for Cruise Missiles & Info on Recent Cruise Missile Incident ML20211M1871999-09-0202 September 1999 Forwards Original Signed Documents Which Include Declaration of Jc Pechman Re Contention L,Declaration of M Resnikoff, Re Utah Contention Q & Declaration of M Resnikoff Re Utah Contention R ML20210L9461999-08-0505 August 1999 Forwards Signed Original (Plus Two Copies) of Declaration of J Cooper Verifying Applicant Amended Response to State Second Requests for Discovery (Group I),Inadvertently Excluded from .Related Correspondence ML20210M4411999-08-0404 August 1999 Forwards Signed Original (Plus Two Copies) of Declaration of J Cooper Verifying Applicant Amended Response to State Second Requests for Discovery (Group I) to Replace Facsimile Copy ML20210B3341999-07-20020 July 1999 Informs That on 990628,State of UT Filed Objections & Responses to Applicant Second Set of Discovery Requests with Respect to Group II & III Contentions. Related Correspondence ML20209E4561999-07-12012 July 1999 Forwards Signed Original (Plus Two Copies) of Declaration of Jl Donnell Verifying Applicant Supplemental Response to Ogd First Set of Discovery Requests ML20196K5141999-07-0101 July 1999 Forwards Signed Originals of Declarations & Affidavits to Replace Facsimile Copies,Including Declarations of Davis, Jd Parkyn,E Supko,Verifying Applicant Discovery Responses to State Second Request for Discovery (Group II & III) ML20209A8171999-06-30030 June 1999 Forwards Original Signed Documents Which Had Not Been Available at Time Certain State Pleadings Filed.Related Correspondence ML20196F1571999-06-25025 June 1999 Forwards Declarations & Affidavits to Replace Facsimile Copies of Jl Cole,W Hennessy,D Axt,J Cooper,Dw Lewis, J Donnell & Wj Jacobs Filed on 990604 & W Jacobs,J Cooper, F Davis & C Britton Filed on 990607.Related Correspondence ML20196C4431999-06-21021 June 1999 Confirms 990621 Telcon Re NRC Response to State of Utah First Set of Discovery Requests Directed to NRC, .NRC Agreed That Staff Would Respond to Discovery Requests as Listed.Related Correspondence ML20196A8791999-06-18018 June 1999 Forwards Signed Original Declarations of J Johns & B Brunsdon to Replace Unsigned Copies That Pfs Filed with Motion for Partial Summary Disposition of Contention Utah K, on 990607 ML20196C3691999-06-18018 June 1999 Forwards Original Signed Documents (Plus Two Copies of Each) Which Had Not Been Available at Time Certain State Pleadings Filed.Declaration of M Resnikoff Encl ML20196C3841999-06-18018 June 1999 Forwards Original Signed Documents (Plus Two Copies of Each) Which Had Not Been Available at Time Certain State Pleadings Filed.Declaration of D Larsen,B Brandford,N Taylor & DB Cole Encl.Related Correspondence ML20195H3711999-06-0909 June 1999 Discusses Statement Specifying What Portions of Licensee 990527 Motion to Compel No Longer Require Board Action ML20195D7171999-06-0808 June 1999 Forwards Figure Entitled, Comparative Single-Engine Fighter/Attack Class a Flight Mishap Rates, That Should Have Been Included in Rept of Jl Cole.Figure Should Be Inserted in Rept After Page 13 ML20207G1491999-06-0808 June 1999 Forwards Rev 2 to Private Fuel Storage,Llc Physical Protection Plan & Rev 1 to Contingency Plan & Training & Qualification Plan.Plans Withheld from Public Disclosure Per 10CFR73.21 ML20195D6531999-06-0707 June 1999 Forwards Exhibit 1 to Applicant Opposition to Ogd Motion to Extend Discovery & Motion to Quash Ogd Notice of Deposition of L Bear.Exhibit Inadvertently Omitted from Opposition When Filed ML20207E3351999-06-0101 June 1999 Forwards Affidavit of W Lewis Filed in Support of Applicant Partial Motion for Summary Disposition with Respect to Utah H & Affidavits of J Donnell & J Cooper to Applicant Objections & Answers to Suwa First Discovery Request ML20207E3471999-05-28028 May 1999 Forwards Check in Listed Amount to Cover Witness & Mileage Fees for Ld Bear.Motion Filed to Extend Discovery Period & Notice of Deposition for Ld Bear.Without Encl.Related Correspondence ML20207A5601999-05-20020 May 1999 Provides Board with Background Re Footnote 2 Which Appeared in Board 990511 Order Ruling on Applicant 990422 Motion to Compel in Which Listed Info Was Stated ML20206R9461999-05-19019 May 1999 Submits Motion for Partial Summary Disposition of Contention Utah H.Affidavit of I Rampall & Some of Related Exhibits Filed with Pfs Motion,Contain Holtec Intl Proprietary Info & Ask That Affidavit & Exhibits Be Maintained as Confidential ML20206R8871999-05-14014 May 1999 Submits Amended Proprietary Response to State of Utah First Set of Discovery Requests,Specifically Responses to Interrogatories 1-3 for Utah Contention H & Forwards Affidavits of Ai Soler & I Rampall ML20206H8181999-05-0505 May 1999 Forwards Affidavits Verifying Private Fuel Storage Answers to Interrogatories & Requests for Admissions Filed by Pfs on 990421,in Response to State of Utah First Set of Discovery Requests.Related Correspondence ML20206H8721999-05-0505 May 1999 Forwards State Comments on Proposed Rulemaking Re Changes to Requirements for Environ Review for Renewal of NPP Operating License, & Errata Ltr ML20205S0301999-04-21021 April 1999 Informs That Pfs Submitted non-proprietary Response & Proprietary Response to State of UT First Set of Discovery Request.Proprietary Response Contains Matl from Holtec Rept HI-992134.Related Correspondence ML20206B6701999-04-21021 April 1999 Forwards Original Affidavit & Verification of Jd Parkyn Filed in Conjunction with Applicant Objections & Responses to State of Utah First Set of Discovery Requests & Affidavit of W Hennessy Filed in Support of Applicant Motion ML20204D0671999-03-19019 March 1999 Clarifies Inaccuracy in Record of 990216 Appeal Filed by Pfs,Llc Appealing ASLB 990203 Memo & order,LBP-99-3. Believes That 500 Foot Corridor for Rail Line Insignificant to Arguments Made on Appeal.With Certificate of Svc ML20207A2091999-02-10010 February 1999 Informs That Private Fuel Storage Encl Security Plan Has Been re-titled, Physical Protection Plan, to Be Consistent with Terminology of New Regulations.Without Encl ML20198J0501998-12-21021 December 1998 Submits Notice of Withdrawal from Proceeding of Castle Rock Land & Livestock,Lc & Skull Valley Co,Ltd.Requests That Board Promptly Accept & Approve Notice of Withdrawal ML20196B2751998-11-24024 November 1998 Submits Rept on Status of Informal Discovery Re Private Fuel Storage,Iaw Board 981029 Order.Parties Have Initiated Informal Interview Process ML20196B1851998-11-23023 November 1998 Requests on Behalf of Castle Rock That State of Utah Take Over as Lead Party on Consolidated Contentions AA & 13 ML20155J1041998-11-0909 November 1998 Ack Receipt of Requesting Broad Range of Info from NRC Staff Re Safety Record & Funding of Commerical Nuclear Power Reactor & Other Fuel Storage Proposal Pending Before Commission.Related Correspondence ML20155A3981998-10-23023 October 1998 Files Joint Rept on Status of Informal Discovery IAW Board Memorandum & Order of 981001 1999-09-09 Category:INCOMING CORRESPONDENCE MONTHYEARML20217E0661999-10-12012 October 1999
[Table view]Forwards Original Declaration of M Resnikoff in Support of State of Utah Amended Contention V, ,not Available at Time State of UT 991004 Request for Admission of late-filed Amended Utah Contention V.Related Correspondence ML20212G0461999-09-20020 September 1999 Forwards Original Signed Reply Declaration of M Resnikoff in Support of State of Utah Second Amended Contention Q, ML20211P6341999-09-0909 September 1999 Forwards Calculation Package List in Re Rev of Submittal Schedule.List of Contents Submitted ML20211Q9251999-09-0808 September 1999 Informs That Author Recently Became Aware of Evidence Which Author Believes Reflects Serious Conflicts with Evidence Presented to & Being Relied Upon by Licensing Board Re Pfs.Related Correspondence ML20211M6741999-09-0303 September 1999 Responds to NRC 990819 Telcon Re Projected Future Growth in Civilian & Military Air Traffic,Use of Flight Termination Systems for Cruise Missiles & Info on Recent Cruise Missile Incident ML20211M1871999-09-0202 September 1999 Forwards Original Signed Documents Which Include Declaration of Jc Pechman Re Contention L,Declaration of M Resnikoff, Re Utah Contention Q & Declaration of M Resnikoff Re Utah Contention R ML20210L9461999-08-0505 August 1999 Forwards Signed Original (Plus Two Copies) of Declaration of J Cooper Verifying Applicant Amended Response to State Second Requests for Discovery (Group I),Inadvertently Excluded from .Related Correspondence ML20210M4411999-08-0404 August 1999 Forwards Signed Original (Plus Two Copies) of Declaration of J Cooper Verifying Applicant Amended Response to State Second Requests for Discovery (Group I) to Replace Facsimile Copy ML20210B3341999-07-20020 July 1999 Informs That on 990628,State of UT Filed Objections & Responses to Applicant Second Set of Discovery Requests with Respect to Group II & III Contentions. Related Correspondence ML20209E4561999-07-12012 July 1999 Forwards Signed Original (Plus Two Copies) of Declaration of Jl Donnell Verifying Applicant Supplemental Response to Ogd First Set of Discovery Requests ML20196K5141999-07-0101 July 1999 Forwards Signed Originals of Declarations & Affidavits to Replace Facsimile Copies,Including Declarations of Davis, Jd Parkyn,E Supko,Verifying Applicant Discovery Responses to State Second Request for Discovery (Group II & III) ML20209A8171999-06-30030 June 1999 Forwards Original Signed Documents Which Had Not Been Available at Time Certain State Pleadings Filed.Related Correspondence ML20196F1571999-06-25025 June 1999 Forwards Declarations & Affidavits to Replace Facsimile Copies of Jl Cole,W Hennessy,D Axt,J Cooper,Dw Lewis, J Donnell & Wj Jacobs Filed on 990604 & W Jacobs,J Cooper, F Davis & C Britton Filed on 990607.Related Correspondence ML20196C3841999-06-18018 June 1999 Forwards Original Signed Documents (Plus Two Copies of Each) Which Had Not Been Available at Time Certain State Pleadings Filed.Declaration of D Larsen,B Brandford,N Taylor & DB Cole Encl.Related Correspondence ML20196C3691999-06-18018 June 1999 Forwards Original Signed Documents (Plus Two Copies of Each) Which Had Not Been Available at Time Certain State Pleadings Filed.Declaration of M Resnikoff Encl ML20196A8791999-06-18018 June 1999 Forwards Signed Original Declarations of J Johns & B Brunsdon to Replace Unsigned Copies That Pfs Filed with Motion for Partial Summary Disposition of Contention Utah K, on 990607 ML20195H3711999-06-0909 June 1999 Discusses Statement Specifying What Portions of Licensee 990527 Motion to Compel No Longer Require Board Action ML20207G1491999-06-0808 June 1999 Forwards Rev 2 to Private Fuel Storage,Llc Physical Protection Plan & Rev 1 to Contingency Plan & Training & Qualification Plan.Plans Withheld from Public Disclosure Per 10CFR73.21 ML20195D7171999-06-0808 June 1999 Forwards Figure Entitled, Comparative Single-Engine Fighter/Attack Class a Flight Mishap Rates, That Should Have Been Included in Rept of Jl Cole.Figure Should Be Inserted in Rept After Page 13 ML20195D6531999-06-0707 June 1999 Forwards Exhibit 1 to Applicant Opposition to Ogd Motion to Extend Discovery & Motion to Quash Ogd Notice of Deposition of L Bear.Exhibit Inadvertently Omitted from Opposition When Filed ML20207E3351999-06-0101 June 1999 Forwards Affidavit of W Lewis Filed in Support of Applicant Partial Motion for Summary Disposition with Respect to Utah H & Affidavits of J Donnell & J Cooper to Applicant Objections & Answers to Suwa First Discovery Request ML20207A5601999-05-20020 May 1999 Provides Board with Background Re Footnote 2 Which Appeared in Board 990511 Order Ruling on Applicant 990422 Motion to Compel in Which Listed Info Was Stated ML20206R9461999-05-19019 May 1999 Submits Motion for Partial Summary Disposition of Contention Utah H.Affidavit of I Rampall & Some of Related Exhibits Filed with Pfs Motion,Contain Holtec Intl Proprietary Info & Ask That Affidavit & Exhibits Be Maintained as Confidential ML20206R8871999-05-14014 May 1999 Submits Amended Proprietary Response to State of Utah First Set of Discovery Requests,Specifically Responses to Interrogatories 1-3 for Utah Contention H & Forwards Affidavits of Ai Soler & I Rampall ML20206H8721999-05-0505 May 1999 Forwards State Comments on Proposed Rulemaking Re Changes to Requirements for Environ Review for Renewal of NPP Operating License, & Errata Ltr ML20206H8181999-05-0505 May 1999 Forwards Affidavits Verifying Private Fuel Storage Answers to Interrogatories & Requests for Admissions Filed by Pfs on 990421,in Response to State of Utah First Set of Discovery Requests.Related Correspondence ML20206B6701999-04-21021 April 1999 Forwards Original Affidavit & Verification of Jd Parkyn Filed in Conjunction with Applicant Objections & Responses to State of Utah First Set of Discovery Requests & Affidavit of W Hennessy Filed in Support of Applicant Motion ML20205S0301999-04-21021 April 1999 Informs That Pfs Submitted non-proprietary Response & Proprietary Response to State of UT First Set of Discovery Request.Proprietary Response Contains Matl from Holtec Rept HI-992134.Related Correspondence ML20204D0671999-03-19019 March 1999 Clarifies Inaccuracy in Record of 990216 Appeal Filed by Pfs,Llc Appealing ASLB 990203 Memo & order,LBP-99-3. Believes That 500 Foot Corridor for Rail Line Insignificant to Arguments Made on Appeal.With Certificate of Svc ML20207A2091999-02-10010 February 1999 Informs That Private Fuel Storage Encl Security Plan Has Been re-titled, Physical Protection Plan, to Be Consistent with Terminology of New Regulations.Without Encl ML20198J0501998-12-21021 December 1998 Submits Notice of Withdrawal from Proceeding of Castle Rock Land & Livestock,Lc & Skull Valley Co,Ltd.Requests That Board Promptly Accept & Approve Notice of Withdrawal ML20196B2751998-11-24024 November 1998 Submits Rept on Status of Informal Discovery Re Private Fuel Storage,Iaw Board 981029 Order.Parties Have Initiated Informal Interview Process ML20196B1851998-11-23023 November 1998 Requests on Behalf of Castle Rock That State of Utah Take Over as Lead Party on Consolidated Contentions AA & 13 ML20155A3981998-10-23023 October 1998 Files Joint Rept on Status of Informal Discovery IAW Board Memorandum & Order of 981001 ML20154H2501998-10-0505 October 1998 Forwards M Resnikoff Original Declaration,Which Had Not Been Available at Time of Filing of State of UT Contentions Relating to Low Pail Transportation License Amend, ML20154B8741998-10-0101 October 1998 Forwards Pleading, Correction to State of UT Contentions Re Low Rail Transportation License Amend, That Was Not Mailed on 980930,as Stated on Certificate of Svc,Due to Miscommunication ML20237F0541998-08-28028 August 1998 Informs That,In Response to Board 980820 Order Re Proposed Telcon Scheduled for 981001 or 02,no Attorneys for Utah Attorney General Ofc Will Be Available Due to Ofc Mandatory Cle Training/Retreat to Be Held.W/Certificate of Svc ML20237B5521998-08-14014 August 1998 Files Joint Rept on Status of Informal Discovery in Accordance W/Board 980629 Memorandum & Order (General Schedule for Proceeding & Associated Guidance).W/Certificate of Svc 1999-09-09 |
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