ML20237B552
| ML20237B552 | |
| Person / Time | |
|---|---|
| Site: | 07200022 |
| Issue date: | 08/14/1998 |
| From: | Blake E AFFILIATION NOT ASSIGNED, SHAW, PITTMAN, POTTS & TROWBRIDGE, UTAH, STATE OF |
| To: | Bollwerk G, Kline J, Lam P Atomic Safety and Licensing Board Panel |
| References | |
| CON-#398-19421 97-732-02-ISFSI, 97-732-2-ISFSI, ISFSI, NUDOCS 9808190037 | |
| Download: ML20237B552 (4) | |
Text
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- M9M SHAW PITTMAN POTPSeTFOWBFJDGE DOCKETED
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Washmston, D.C. 20037 1128 73 AUG 17 All:57 202.663.8000 Facumule 202.663.8007 ERNEST L Bl.AKE, JR., P.c.
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virginia ernest.blakeeshawpictman.com August 14,1998 ADJUS:
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. Administrative Judge G. Paul Bollwerk, Chairman Administrative Judge Jerry R. Kline Administrative Jadge Peter S. Lam Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of Private Fuel Storage L.L.C.(Private Fuel Storage Facility),
Docket No. 72-22, ASLBP No. 97-732-02-ISFSI, Discovery Status Report
Dear Chairman Bollwerk and Judges Kline and Lam:
In accordance with the Board's June 29,1998 Memorandum and Order (General Schedule for Proceeding and Associated Guidance), the parties hereby file thisjoint report on the status ofinformal discovery. The parties are progressing with informal document discovery; no informal interviews have yet been conducted or requested. The Applicant has made available the bulk ofits documents in Salt Lake City, which lead counsel for the interveners are in the course j
of reviewing, and is continuing to review its documents for completion ofits document i
prrduction. The Applicant has served each of the lead counsel for the interveners with informal discovery requests for relevant documents. The State has supplied the Applicant with copies of documents in response to Applicant's request which the Applicant is reviewing. The Applicant will ' hortly send the State a second informal request for documents based on its initial review of s
the State's documents. The Stete has completed its initial review of the Applicant's files located in Salt Lake City. After reviewing the files, the State requested copies of selected documents and received the copies this week. After the State's experts complete their review of those documents, the State anticipates making an informal request for documents on the Applicant.
OGD and Castle Rock have agreed to supply responsive documents to Applicant's request. The Applicant has agreed to make available for the NRC Staff's review at Shaw Pittman's offices in Washington D.C. a copy of the documents that it has made available to the interveners in Salt Lake City as well as a copy of those documents made available by the interveners in response to Applicant's informal discovery requests which the Appplicant has selected to have copied and sent to its counsel's office in Washington D.C.
Further, the Applicant and the State have entered into a confidentiality agreement which allows the State access to Private Fuel Storage ("PFS") confidential information subject to the terms of the agreement. The State has received a copy of the Applicant's Response to the Staff's l
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SHAW PITTMAN POTTSeTROWBFJDGE m u n w m,e m x m cc,m u m Administrative Judge G. Paul Bollwerk, Chairman Administrative Judge Jerry R. Kline Administrative Judge Peter S. Lam j
August 141998 1
Page 2 Request for Additional Information ("RAl"), which the Applicant claims to be proprietary.
However, the State hc not received access to any other proprietry information. The Applicant has proposed to enter into a similar agreement with Confederated Tribes which would allow the State to share PFS confidential information with Confederated Tribes concerning those contentions on which the Confederated Tribes is involved, subject to the terms of the proposed I
agreement. Additionally, the Applicant has proposed to enter a confidentiality agreement with Castle Rock which would allow for mutual access to each party's confidential information.
Respectfully, f
juELE Ernest L. Blake, Jr.
Counsel for Applicant
.cc: Service List 629391 l
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s UNITED STATES OF AMERICA g3 NUCLEAR REGULATORY COMMISSION
% AUG 17 All :57 Before the Atomic Safety and Licensing Board OFFiG. c o'r RUL E.t l,'
In the Matter of
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ADJUD,. L jpg j
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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 J
I CERTIFICATE OF SERVICE I
I hereby certify that copies of thejoint report on the status ofinformal discovery l
dated August 14,1998, were served on the persons listed below (unless otherwise noted) by e-mail with conforming copies by U.S. mail, first class, postage prepaid, this 14th day of August 1998.
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
- Adjudicatory File 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 Wasidngton, D.C. 20555-0001 e-mail: PSL@nrc. gov Catherine L. Marco, Esq.
- Charles J. Haughney Sherwin E. Turk, Esq.
Acting Director, Spent Fuel Project Office Robert M. Weisman, Esq.
Office of Nuclear Material Safety and Office of the General Counsel Safeguards Mail Stop O-15 B18 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 e-mail: pfscase@nrc. gov
Denise Chancellor, Esq.
Joro Walker, Esq.
Assistant Attomey General Land and Water Fund of the Rockies Utah Attorney General's Office 165 South Main, Suite 1 160 East 300 South,5* Floor Salt Lake City, UT 84111 P.O. Box 140873 e-mail:joro61@inconnect.com Salt Lake City, Utah 84114-0873 e-mail: dchancel@, state.UT.US John Paul Kennedy, Sr., Esq.
Richard E. Condit, Esq.
Confederated Tribes of the Goshute Land and Water Fund of the Rockies Reservation and David Pete 2260 Baseline Road, Suite 200 1385 Yale Avenue Boulder,CO 80302 j
Salt Lake City, Utah 84105 e-mail: rcondit@lawfund.org l
e-mail: john @kennedys.org Clayton J. Parr, Esq.
Danny Quintana, Esq.
Castle Rock, et al.
Skull Valley Band of Goshute Indians Kimball, Parr, Waddoups, Brown & Gee Danny Quintana & Associates, P.C.
185 S. State Street, Suite 1300 50 West Broadway, Fourth Floor P.O. Box 11019 Salt Lake City, Utah 84101 Salt Lake City, Utah 84147-0019 e-mail: quintana @xmission.com e-mail: karenj@pwlaw.com Diane Curran, Esq.
Office of the Secretary Harmon, Curran, Spielberg &
U.S. Nuclear Regulatory Conunission Eisenberg, L.L.P.
Washington, D.C. 20555-0001 2001 S Street, N.W.
Attention: Rulemakings and Adjudications Washington, DC 20009 Staff e-mail: DCurran.HCSE@zzapp.org e-mail: SECY@NRC. GOV (Original and two copies)
- By U.S. mail only
,/
D. Sean 8arnett