ML20206R332
| ML20206R332 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 05/13/1999 |
| From: | Gaukler P AFFILIATION NOT ASSIGNED, SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | SOUTHERN UTAH WILDERNESS ALLIANCE |
| References | |
| CON-#299-20397 97-732-02-ISFSI, 97-732-2-ISFSI, ISFSI, NUDOCS 9905200085 | |
| Download: ML20206R332 (6) | |
Text
u' 20397
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i 00CKETED RELATED CORRESPONDDM MC
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i NUCLEAR REGULATORY COMMISSib'N Before the Atomic Safety and Licensing Board In the Matter of
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l PRIVATE FUEL STORAGE L.L.C.
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Docket No. 72-22 i
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(Private Fuel Storage Facility)
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ASLBP No. 97-732-02-ISFSI APPLICANT'S FIRST SET OF DOCUMENT REQUESTS TO INTERVENOR SUWA Applicant Private Fuel Storage L.L.C. (" Applicant" or "PFS") hereby makes the following formal document requests of SUWA.
General Definitions and Instructions 1.
The term " document" means the complete original or a true, correct, and I
complete copy and any non-identical copies, whether different by reason of any notation or otherwise, of any written or graphic matter of any kind, no matter how produced, recorded, stored, or reproduced (including electronic, mechanical or electrical records or representation of any kind) including, but not limited to, any writing, letter, telegram, meeting minute or note, memorandum, statement, book, record, survey, map, study, handwritten note, working paper, chart, tabulation, graph, tape, data sheet, data processing card, printout, microfilm or microfiche, index, diary entry, note of interview 9905200085 990513 PDR ADOCK 07200022 C
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o or communication, or any data compilation including all drafts of all such documents.
The phrase " data compilation" includes, but is not limited to, any material stored on or accessible through a computer or other information storage or retrieval system, including videotapes and tape recordings.
2.
"SUWA" means the Southem Utah Wildemess Alliance, any ofits ollicials, directors, agents, employees, representatives, and its attorneys.
3.
" Consultant" means any person who provides professional or technical input, advice and/or opinion to SUWA whether that person is employed specifically for 1
this case or is a regular SUWA employee or official.
1 4.
The " Low Corridor rail line" means the rail line that PFS has proposed in i
its License Amendment of August 28,1998 to construct and operate a rail line running i
from Low, Utah (on the main Union Pacific rail line near Interstate 80) to the PFS site on the Skull Valley reservation.
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Contention SUWA B Alignment Alternatives to the Low Junction Rail Line A.
Document Requests-SUWA B The Applicant requests SUWA to produce the following documents directly or indirectly within its possession, custody or control:
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All documents related to the claims raised by SUWA in Contention SUWA B, as admitted by the Board.
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All documents, data or other information generated, reviewed, considered or relied upon by any expert or consultant assisting SUWA with respect to SUWA j
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All calculations, studies, evaluations, analyses or other documents relating to the environmental impacts of the Low Corridor rail line in its alignment as proposed by PFS.
4.
All documents identifying any attematives proposed or endorsed by SUWA to PFS's proposed alignment of the Low Corridor rail line.
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All documents identifying the ownership of the land that would be traversed J
by the alternatives proposed or endorsed by SUWA to PFS's proposed alignment of the Low Conidor rail line.
6.
All calculations, studies, evaluations, analyses or other documents relating to the environmental impacts of any potential alignment of the Low Corridor rail line other than that proposed by PFS.
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All documents relating to the environmental impacts of any attematives to PFS's proposed alignment of the Low Conidor rail line that SUWA asserts would have fewer or less severe environmental impacts than the alignment now proposed l
' by PFS.
8.
All documents concerning the scientific, technical, or engineering feasibility of building and using, for the shipment of spent fuel transportation casks, each of 3
the alternative rail line alignments for the Low Corridor rail line that SUWA 1
asserts would have fewer or less severe environmental impacts than the alignment now proposed by PFS.
9.
All documents conceming the cost to build and maintain each of the alternative alignments for the Low Corridor rail line that SUWA asserts would have fewer or less severe environmental impacts than the alignment now proposed by PFS, including those documents providing the factual basis supporting SUWA's estimates of those costs.
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I Respectfully submitted, Jf [ Nth n
Jay E. Silberg Ernest L. Blake, Jr.
Paul A.Gaukler SHAW, PITfMAN, POTTS & TROWBRIDGE 2300 N Street, N.W.
Washington, DC 20037 (202) 663-8000 Dated: May 13,1999 Counsel for Private Fuel Storage L.L.C.
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00CKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Obi i IW g)A a
Before the Atomic Safety and Licensing Board In the Matter of
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PRIVATE FUEL STORAGE L.L.C.
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Docket No. 72-22
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(Private Fuel Storage Facility)
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ASLBP No. 97-732-02-ISFSI 1
i CERTIFICATE OF SERVICE I hereby certify that copies of the " Applicant's First Set of Document Requests to Intervenor SUWA" were served on the persons listed below (unless othenvise noted) by l
e-mail with conforming copies by U.S. mail, first class, postage prepaid, this 13th day of May 1999.
G. Paul Bollwerk III, Esq., Chairman Dr. Jerry R. Kline Administrative Judge Administrative Judge Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 e-mail: GPB@nrc. gov e-mail: JRK2@nrc. gov Dr. Peter S. Lam
- Susan F. Shankman j
Administrative Judge Deputy Director, Licensing & Inspection Atomic Safety and Licensing Board Panel Directorate, Spent Fuel Project Office U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety &
Washington, D.C. 20555-0001 Safeguards e-mail: PSL@nrc. gov U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i
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Office of the Secretary
- Adjudicatory File U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Washington, D.C. 20555-0001 U.S. Nuclear Regulatory Commission Attention: Rulemakings and Adjudications Washington. D.C. 20555-0001
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e mail: hearingdocket@nre. gov (Original and two copies)
Catherine L. Marco, Esq.
Denise Chancellor, Esq.
Sherwin E. Turk, Esq.
Assistant Attomey General Office of the General Counsel Utah Attorney General's Office Mail Stop O-15 B18 160 East 300 South,5* Floor U.S. Nuclear Regulatory Commission P.O. Box 140873 Washington, D.C. 20555 Salt Lake City, Utah 84114-0873 e-mail: pfscase@nrc. gov e-mail: dchancel@ state.UT.US John Paul Kennedy, Sr., Esq.
kro Walker, Esq.
j Confederated Tribes of the Goshute Land and Water Fund of the Rockies Reservation and David Pete 165 South Main, Suite 1
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1385 Yale Avenue Salt Lake City, UT 84111 Salt Lake City, Utah 84105 e mail: joro61@inconnect.com e-mail: john @kennedys.org Diane Curran Esq.
Danny Quintana, Esq.
Harmon, Curran, Spielberg &
Skull Valley Band of Goshute Indians Eisenberg, L.L.P.
Danny Quintana & Associates, P.C.
2001 S Street, N.W.
50 West Broadway, Fourth Floor l
Washington, D.C. 20009 Salt Lake City, Utah 84101 e-mail:DCurran.HCSE@zzapp.org e-mail: quintana @xmission.com
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- By U.S. mail only
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k Paul A. Gaukler "
Document #: 761443 v.!
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