ML12334A454
| ML12334A454 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/29/2012 |
| From: | Miras-Wilson R, Post J, Repka D, Tanya Smith Pacific Gas & Electric Co, Winston & Strawn, LLP |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 23804, 50-275-LR, 50-323-LR, ASLBP 10-900-01-LR-BD01 | |
| Download: ML12334A454 (4) | |
Text
November 29, 2012 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )
)
PACIFIC GAS AND ELECTRIC ) Docket No. 50-275-LR COMPANY ) Docket No. 50-323-LR
)
(Diablo Canyon Power Plant, Units 1 and 2) )
MOTION TO MODIFY REVISED SCHEDULING ORDER On November 19, 2012, the Atomic Safety and Licensing Board (Licensing Board) issued a Revised Scheduling Order (Order) related to the license renewal application of Pacific Gas and Electric Company (PG&E) for the Diablo Canyon Nuclear Power Plant.
Pursuant to 10 C.F.R. 2.323(a)(2), and in response to the Licensing Boards invitation to provide feedback,1 PG&E hereby files its motion to modify the Order.
In the Order at 2-3, the Licensing Board revised the monthly mandatory disclosure cut-off date. The Board changed the date from the last day of the preceding month to two weeks immediately prior to the monthly update. PG&E respectfully requests that original monthly cut-off date be restored. Each month PG&Es in-house information technology department works with PG&Es external counsel and its litigation support department to search for, collect, process, and review potentially relevant documents. The search and collection aspects of this endeavor are currently optimized and linked to a regular and consistent cut-off date: the end of each calendar month. However, under the revised Order, the cut-off date for 1
Email from O. Williams, Licensing Board Law Clerk, dated Nov. 19. 2012 (forwarding the Order to the parties and noting that any motion to clarify or change the Order would be due within 10 days).
each month would fluctuate. For example, when the filing deadline (nominally the 15th of each month) is affected by a weekend or holiday the cut-off date would likewise change. Reverting to the last day of the preceding month as the cut-off date would maintain the efficiency of the mandatory disclosure process that has been used successfully throughout this proceeding without prejudicing the other parties (in almost all cases, the requested change would alter the monthly cut-off date by only one to three days). PG&E has discussed this request with the other parties and they have indicated that they have no objection.
Respectfully submitted,
/s/ signed electronically by David A. Repka Tyson R. Smith Rachel Miras-Wilson Winston & Strawn LLP 1700 K Street, NW Washington, DC 20006 Jennifer Post Pacific Gas and Electric Company 77 Beale St., B30A San Francisco, CA 94105 COUNSEL FOR THE PACIFIC GAS AND ELECTRIC COMPANY Dated at Washington, District of Columbia this 29th day of November 2012 2
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )
)
PACIFIC GAS AND ELECTRIC ) Docket No. 50-275-LR COMPANY ) Docket No. 50-323-LR
)
(Diablo Canyon Power Plant, Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of MOTION TO MODIFY REVISED SCHEDULING ORDER in the captioned proceeding have been served via the Electronic Information Exchange (EIE) this 29th day of November 2012, which to the best of my knowledge resulted in transmittal of the foregoing to those on the EIE Service List for the captioned proceeding.
Office of Commission Appellate U.S. Nuclear Regulatory Commission Adjudication Office of the Secretary of the Commission U.S. Nuclear Regulatory Commission Mail Stop O-16C1 Washington, DC 20555-0001 Washington, DC 20555-0001 E-mail: ocaamail@nrc.gov Hearing Docket E-mail: hearingdocket@nrc.gov Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Mail Stop - T-3 F23 Office of the General Counsel U.S. Nuclear Regulatory Commission Mail Stop O-15D21 Washington, DC 20555-0001 Washington, DC 20555-0001 Alex S. Karlin, Chair Susan Uttal, Esq.
Nicholas G. Trikouros Lloyd Subin, Esq.
Paul B. Abramson Maxwell Smith, Esq.
Catherine Kanatas, Esq.
E-mail: Alex.Karlin@nrc.gov E-mail: Nicholas.Trikouros@nrc.gov E-mail: Susan.Utall@nrc.gov E-mail: Paul.Abramson@nrc.gov E-mail: Lloyd.Subin@nrc.gov E-mail: Maxwell.Smith@nrc.gov E-mail: catherine.kanatas@nrc.gov OGC Mail Center : OGCMailCenter@nrc.gov
Diane Curran Harmon, Curran, Spielberg, & Eisenberg, L.L.P.
1726 M St., NW, Suite 600 Washington, DC 20036 E-mail: dcurran@harmoncurran.com Respectfully submitted,
/s/ signed electronically by Rachel Miras-Wilson Winston & Strawn LLP 1700 K Street, NW Washington, DC 20006 COUNSEL FOR THE PACIFIC GAS AND ELECTRIC COMPANY 2