ML110450622

San Luis Obispo Mothers for Peace'S Comments Regarding Planned Protective Order

ML110450622
Person / Time
Site:	Diablo Canyon
Issue date:	02/14/2011
From:	Curran D Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP, San Luis Obispo Mothers for Peace
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
50-275-LR, 50-323-LR, ASLBP 10-900-01-LR-BD01, RAS 19582
Download: ML110450622 (3)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of Pacific Gas and Electric Company Docket Nos. 50-275-LR Diablo Canyon Nuclear Power Plant 50-323-LR Units 1 and 2 SAN LUIS OBISPO MOTHERS FOR PEACES COMMENTS REGARDING PLANNED PROTECTIVE ORDER Pursuant to the Atomic Safety and Licensing Boards (ASLBs) Notice of Planned Protective Order (February 3, 2011), San Luis Obispo Mothers for Peace (SLOMFP) hereby comments on the protective order and non-disclosure agreement that were attached to the Notice. SLOMFP proposes only one change to the protective order circulated by the ASLB: to add the contents of paragraph T of the proposed protective order that the parties submitted on November 9, 2010: Nothing in this protective order shall prevent any party from seeking public disclosure of information designated as Protected Information, in accordance with NRC regulatory procedures or other applicable law. That language would clarify that SLOMFP is permitted to seek Protected Information by submitting a Freedom of Information Act request under 10 C.F.R. Part 9, in addition to seeking it through discovery in other proceedings as provided in paragraph Z of the ASLBs planned protective order.

In all other respects, SLOMFP believes that the planned protective order and nondisclosure agreement issued by the ASLB are comprehensive and fully protective of all parties interests in this proceeding.

Respectfully submitted, Electronically signed by Diane Curran Harmon, Curran, Spielberg, & Eisenberg, L.L.P.

1726 M Street N.W., Suite 600 Washington, D.C. 20036 202/328-3500 FAX 202/328-6918 dcurran@harmoncurran.com February 14, 2010

CERTIFICATE OF SERVICE I certify that on February 14, 2011, I posted San Luis Obispo Mothers for Peaces Comments Regarding Planned Protective Order on the NRCs Electronic Information Exchange. It is my understanding that as a result, the following persons were served:

Office of the Secretary David A. Repka, Esq.

Rules and Adjudications Branch Tyson R. Smith, Esq.

U.S. Nuclear Regulatory Commission Winston & Strawn, LLP 11555 Rockville Pike 1700 K Street N.W.

Rockville, MD 20852 Washington, D.C. 20006-3817 hearingdocket@nrc.gov drepka@winston.com, trsmith@winston.com Susan Uttal, Esq. E. Roy Hawkens Lloyd Subin, Esq. Chief Administrative Judge Office of General Counsel Atomic Safety and Licensing Board Mail Stop O-15D21 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Roy.Hawkens@nrc.gov Susan.Uttal@nrc.gov Lloyd.Subin@nrc.gov Electronically signed by Diane Curran