ML20030C177
| ML20030C177 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/18/1981 |
| From: | Norton B NORTON, BURKE, BERRY & FRENCH, PACIFIC GAS & ELECTRIC CO. |
| To: | Ellen Brown CALIFORNIA, STATE OF |
| References | |
| ISSUANCES-OL, NUDOCS 8108250471 | |
| Download: ML20030C177 (6) | |
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UNITED STATES OF AMERICA C
fldG31190k'f NUCLEAR REGULATORY COM!!ISSION
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BEFORE THE ATOMIC SAFETY AND LICENSING BOAR E'
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Docket Nos. 50-27'5'O L.
PACIFIC GAS AND ELECTRIC COMPANY
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50-323 0.L.
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(Diablo Canyon Nuclear Power
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Plant, Units No. 1 and 2)
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N APPLICANT PACIFIC GAS AND ELECTRIC COMPANY'D NC 2 <J Jgg REQUEST FOR PRODUCTION OF DOCUMENTS J E4 A
FROM GOVERNOI EDMUND G.
BROWN Q
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Pursuant to 10 C.F.R.
S2.741 and the Licensing Boar Ilp i
Order of August 4, 1981, Applicant PACIFIC GAS AND ELECTRIC COMPANY requests GOVERNOR EDMUND G. BROWN, as a representative of an interested state, to produce for inspection and copying the documents described herein.
Governor Brown is requested to produce these documents at the offices of Pacific Gas and Electric Company, located at 925 L Street, Suite 890, Sacramento, California, at 10:00 a.m. on September 23, 1981, unless another prior time or location is agreed l
upon among the partles.
l As used herein, " documents" includes, but is not limited to, papers, photographs, recordings, memoranda, books, records, writings, letters, telegrams, mailgrams, correspondence, notes and/or minutes of meetings or conversations or of telephone calls, inter-office or intra-office memoranda or written communications of any nature, intra-agency memoranda or written communications of any nature, recordings of conversations either in writing or upon any c
.nechanical or electronic or electrical recording devices, notes, 1
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8108250471 810818 PDR ADOCK 05000275 L
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4 exhibits, appraisals, work papers, reports, studies, opinions, analyses, assessments, surveys, evaluations, projections, hypotheses, formulas, designs, drawings, manuals, notebooks, worksheets, l
l contracts, agreements, letter agreements, diaries, desk calendars, i
charts, schedules, appointment books, punchcards and computer printout sheets, computer data, telecopier transmissions, directives, proposals, and all drafts, revisions, and differing versions (wheIther formal or informal) of any of the foregoing, and also, all copies of any of the foregoing which differ in any way (including handwritten notations or other written or printed matter of any nature) from the original.
As stated above, this request for production is directed to i
Governor Brown as a representative of an interested state.
As such, the request is directed at the State of California and all of its agencies, organizations, and/or subdivisions of any kind whatsoever, including, but not limited to, the California Conservation Corps.,
l Department of Corrections, Department of Fish and Game, Department of Forestry, Department of Youth Authority, State Fire Marshal, Military Department, California Highway Patrol, Department of General Services, Department of Justice, Department of Transportation, Air Resources Board, Department of Food and Agriculture, Department of Aging, Department of Motor Vehicles, Department of Parks and 1
I Recreation, Department of Rehabilitation ~, Department of Veteran's Affairs, Department of Conservation, Department of Education, Department of Finance, Department of Industrial Relations, Department of Water Resources, Energy Resources Conservation and Development,
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Commission, Public Utilities Commission, Office of Emergency Services, and the State Personnel Board.
All documents in the possession of the State of California are to be produced, whether they be located in headquarter offices, regional offices, or local offices or any suodivision thereof.
Request No. 1:
All documents in possession, custody or control of the State of California (including the possession, custody or control of any agency or organization of the State or of any contractor, employee, consultant, or agent of the State, past or present) which relate in any way to radiological emergency planning (at Diablo Canyon or any other-nuclear facility) or earthquake response or emergency planning (at Diablo Canyon or any other critical facility (nuclear, medical or otherwise)).
Request No. 2:
All documents in the possession, custody or control of the State of California (including the possession, custody or control of any agency or organization of the State, or of any contractor, employee, consultant or agent of the State, past or present) which l
relate in any way to State, local, Federal, or utility emergency response plans within the State of California.
Respe$tfully submitted, MALCOLM H.
FURBUSH PHILIP A.
CRANE, JR.
Pacific Gas and Electric Company 77 Bealo Street San Francisco, California 94106 (415)781-4211
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1 ARTHUR C. GEHR Snell & Wilmer 3100 Valley Center Phoenix, Arizona 85073 (602)257-7288 l
BRUCE NORTON Norton, Burke, Berry & Junck, P.C.
3216 N.
Third Street l
Suite 300 l
Phoenix, Arizona 85012 l
(602)264-0033 Attorneys for
- l Pacific Gas and Electric Company By E'ruce Norton DATED
August 18, 1981.
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UNITED STATES OF AMERICA g
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NUCLEAP REGULATORY COMMISSION c'
BEFORE THE ATOMIC SAFETY AND LICENSING BOA NN
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'Chliltb In ebn Matter of
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Docket Nos. 50-275 0.L.
PACIFIC GAS AND ELECTRIC COMPANY
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50-323 0.L.
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(Diablo Canyon Nuclear Power
)
Plant, Units No. 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " APPLICANT PACIFIC GAS AND ELECTRIC COMPANY'S REQUEST FOR PRODUCTION OF DOCUMENTS FROM GOVERNOR EDMUND G. BROWN," dated August 18, 1981, have been served on the following by deposit in the United States mail, postage prepaid, this 18th day of August, 1981:
The Hon. John F. Wolf, Chairman Gordon Silver Atomic Safety and Licensing Board 1760 Alisal Street Mail Drop East West 450 San Luis Obispo, CA 93401 U.
S. Nuclear Regulatory Comm'n War.ington, D.C.
20555 Sandra A.
Silver 1760 Alisal Street The Hon. Glenn O.
Bright San Luis Obispo, CA 93401 Atomic Safety and Licensing Board Mail Drop East West 450 Harry W. Willis, Esq.
U.
S. Nuclear Regulatory Comm'n W. Andrew Baldwin, Esq.
Wa shing ton, D.C.
20555 601 California Street Suite 2100 The Hon. Jerry R.
Kline San Francisco, CA 94108 Atomic Saf.ety and Licensing Board Mail Drop East West 450 U.
S.
Nuclear Regulatory Comm'n Washington, D.C.
20555 Mrs. Elizabeth Apfelberg Joh-R.
Phillips, Esq.
c/o Nancy Culver Center for Law in the 182 Luneta Drive Public Interest San Luis Obispo, CA 93401 10203 Santa Monica Blvd.
Los Angeles, CA 90067 David F.
Fleischaker, Esq.
..Mrs. Raye Fleming 1735 Eye Street N.W.
1920 Mattie Road Washington, D.C.
20006 Shell Beach, CA 93449 l
Mr. Frederick Eissler Scenic Shoreline Preservation Conference, Inc.
4623 More Mesa Drive Santa Barbara, CA 93105
William J. Olmstead, Esq.
Carl Neiburger Lucy Swartz, Esq.
P. O.
Box 112 Edward G.
Ketchen, Esq.
San Luis Obispo, CA 93402 Office of Executive Legal Director BETH 042 U.
S. Nuclear Regulatory Comm'n Washington, D.C.
20555 J.
Anthony Kline, Esq.
Byron S.
Georgiou, Esq.
Legal Af f rirs Secretary Atomic Safety and Licensing Board to the Governor Panel State of California U.
S.
Nuclear Regulatory Comm'n State Capitol Building Washington, D.C.
20555 Sacramento, CA 95814 Herbert H.
Brown, Esq.
Docketing and Service Section Lawrence Coe Lanpher, Esq.
Office of the Secretary Hill, Christopher & Phillips U.
S.
Nuclear Regulatory Comm'n 1900 M Street, N.W.
Washington, D.C.
20555 Washington, D.C.
20036 Janice E.
Kerr, Esq.
Lawrence Q. Garcia, Esq.
350 McAllister Street San Francisco, CA 94102 T
l Bruce Norton
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