ML15110A477

Foe Reply in Support of Motion to Supplement Ex.2

ML15110A477
Person / Time
Site:	Diablo Canyon
Issue date:	04/17/2015
From:	Ayres Law Group, Friends of the Earth, Pacific Gas & Electric Co
To:	NRC/OGC, US Federal Judiciary, US Court of Appeals for the District of Columbia Circuit
Creedon, Meghan
Shared Package
ML15110A474	List: ML15110A475 ML15110A476 ML15110A477
References
14-1213, DPO-2013-002
Download: ML15110A477 (2)

Text

USCA Case #14-1213 Document #1547998 Filed: 04/17/2015 Page 1 of 2 EXHIBIT 2 PETITIONERS REPLY TO RESPONDENTS AND INTERVENORS RESPONSES TO PETITIONERS MOTION TO SUPPLEMENT THE CERTIFIED INDEX OF THE RECORD No. 14-1213 (D.C. Cir.)

Email from Richard E. Ayres to Charles Mullins March 22, 2015, 6:33pm

USCA Case #14-1213 Document #1547998 Filed: 04/17/2015 Page 2 of 2 From: Richard E. Ayres ayresr@ayreslawgroup.com

Subject:

Request to Defer Filing Motion to Supplement the Record Date: March 22, 2015 at 6:33 PM To: Mullins, Charles Charles.Mullins@nrc.gov Chuck In the interest of reaching an agreement if possible, I want to make absolutely sure that we are both talking about the same thing.

What we would like to have included in the record is only the portion of the change package that deals with seismic issues Chapter 2.5.

If that changes the agencys position, please let me know as soon as possible. I am attaching a copy of the part of the package we wish to have in the record.

Given the NRCs earlier motion to defer briefing, your somewhat leisurely response to my request to include the material from the change package in the record, and your current request that we defer filing a motion to supplement the record for 10 days, I must admit I am becoming concerned that delay may be the NRC strategy in this matter. I have to note that a more timely response to my request to include the material in the record might have avoided the scheduling problem you describe in your e-mail earlier today.

For this reason, I am not inclined to agree to defer filing our Motion to Supplement for 10 days. Our plan is to file the Motion on Tuesday, unless we hear from you by COB Monday that the NRC will agree to include the material we are requesting in the record.

Dick Richard Ayres Ayres Law Group LLP 1707 L Street, N.W., Suite 850 Washington, D.C. 20036 202-452-9200 AyresR@AyresLawGroup.com