ML20206R967
| ML20206R967 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 05/18/1999 |
| From: | Gaukler P AFFILIATION NOT ASSIGNED, SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | AFFILIATION NOT ASSIGNED |
| References | |
| CON-#299-20408 97-732-02-ISFSI, 97-732-2-ISFSI, ISFSI, NUDOCS 9905210020 | |
| Download: ML20206R967 (6) | |
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I 2 OYO Ra.MED COMESPGMfot2 00CKETED UP3RC May 18,1999 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Abi 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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e Docket No. 72-22
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(Private Fuel Storage Facility)
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ASLBP No. 97-732-02-ISFSI APPLICANT'S FIRST SET OF INTERROGATORIES TO INTERVENOR SUWA Applicant Private Fuel Storage L.L.C. (" Applicant" or "PFS") hereby propounds the following interrogatories to intervenor SUWA.
General Definitions and Instructions 1.
"SUWA" means the Southern Utah Wilderness Alliance, any ofits officials, directors, agents, employees, representatives, and attorneys.
2.
" Consultant" means any person who provides professional or technical input, advice and/or opinion to SUWA whether that person is employed specifically for this case or is a regular SUWA employee or official.
3.
The " Low Corridor rail line" means the rail line that PFS has proposed in its License Amendment of August 28,1998 to construct and operate a rail line running 9905210020 990518 PDR ADOCK 07200022 C
PDR 3 563
I from Low, Utah (on the main Union Pacific rail line near Interstate 80) to the PFS site on the Skull Valley reservation.
INTERROGATORY NO.1. State the name, business address, and job title of each person who was consulted and/or who supplied information for responding to interrogatories, requests for ' admissions and requests for the production of documents.
Specifically note for which interrogatories, requegts for admissions and requests for production each such person was consulted and/or supplied information.
If the information or opinions of anyone who was consulted in connection with your response to an interrogatory or request for admission differs from your written answer to the discovery request, please describe in detail the differing information or opinions, and indicate why such differing information or opinions are not your official position as expressed in your written answer to the request.
INTERROGATORY NO. 2. Please provide the name, address, profession, employer, area of professional expertise, and educational and scientific experience of each person whom SUWA expects to call as a witness or expert witness at the hearing and the subject matter about which each witness or expert witness will testify. For each expert witness please include a list of all publications authored by the witness within the preceding ten years and a listing of any other cases in which the witness has testified as an expert at a trial, hearing or by deposition within the preceding four years. Please describe the subject matter on which each of the witnesses is expected to testify at the 2
i hearing by detailing the facts and opinions to which each witness is expected to testify, including a summary of the grounds for each opinion, and identify the documents (including all pertinent pages or parts thereof), data or other information which each witness has reviewed and considered, or is expected to consider or to rely on for his or i
her testimony.
INTERROGATORY NO. 3. Identify and, fully describe each alternative to the proposed alignment of the Low Corridor rail line that SUWA asserts would have fewer or less severe environmental impacts than the alignment now proposed by PFS, including the precise alignment of each proposed alternative, and the scientific and technical bases for SUWA's position.
INTERROGATORY NO. 4. For each alternative identified by SUWA, identify and fully describe each environmental impact that SUWA asserts PFS's proposed rail alignment would have that SUWA's rail alignment alternative would not have, the specific environmental impacts associated with SUWA's alternative that PFS's proposed rail alignment would not have, and the scientific and technical bases therefor.
INTERROGATORY NO. 5. Identify and fully describe the feasibility of building and using, for the shipment of spent fuel transportation casks, each of the rail line alignment alternatives identified by SUWA in Interrogatory No. 3, and the scientific, technical and engineering bases therefor.
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i INTERROGATORY NO. 6. Identify and fully describe the cost to build and maintain each of the rail line alignment alternatives identified by SUWA in Interrogatory No. 3, along with the factual and any other bases supporting SUWA's estimates of those i
costs.
1 Respectfully submitted, V
bb Jay E. Silberg Ernest L. Blake, Jr.
Paul A. Gaukler SHAW, PITTMAN, POTTS & TROWBRIDGE 2300 N Street, N.W.
Washington,DC 20037 (202) 663-8000 Dated: May 18,1999 Counsel for Private Fuel Storage L.L.C.
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DOCKElED
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USHPC UNITED STATES OF AMERICA 99 MAY 20 P 3 :24 j
NUCLEAR REGULATORY COMMISSION Oi n..
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Before the Atomic Safety and Licensing Board ADJO 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 i
CERTIFICATE OF SERVICE i
I hereby certify that copies of the " Applicant's First Set ofInterrogatories to Intervenor SUWA" were served on the persons listed below (unless otherwise noted) by i
e-mail with conforming copies by U.S. mail, first class, postage prepaid, this 18th 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 and kjerry@.erols.com Dr. Peter S. Lam
- Susan F. Shankman Administrative Judge Deputy Director, Licensing & Inspection Atomic Safety and Licensing Board Panel Directorate, Spent Fuel Project Ollice U.S. Nuclear Regulatory Commission Oflice of Nuclear Material Safety &
Washington, D.C. 20555-0001 Safeguards e-mail: PSL@nrc. gov U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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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 Staff e-mail: hearingdocket@nrc. gov (Original and two copies)
Catherine L. Marco, Esq.
Denise Chancellor, Esq.
Sherwin E. Turk, Esq.
Assistant Attorney General Office of the General Counsel Utah Attorney General's Ollice P.O. East 300 South,5th 160 bloor Mail Stop O-15 Bl8 l
U.S. Nuclear Regulatory Commission Box 140873 Washington, D.C. 20555 Salt Lake City, Utah 84114-0873 e-mail: pfscase@nrc. gov e-mail: dchancel@ state.UT.US l
John Paul Kennedy, Sr., Esq.
Joro Walker, Esq.
Confederated Tribes of the Goshute Land and Water Fund of the Rockies Reservation and David Pete 165 South Main, Suite 1 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 Washington, D.C. 20009 Salt Lake City, Utah 84101 e-mail:DCurran.HCSE@zzapp.org e-mail: quintana @xmission.com i
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- By U.S. mail only b IJ ITul A.GaukIer ~
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Document #: 747720 v.1 l
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