ML20035H619
| ML20035H619 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/26/1993 |
| From: | Culver N SAN LUIS OBISPO MOTHERS FOR PEACE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#293-13919 92-669-03-OLA-2, 92-669-3-OLA-2, OLA-2, NUDOCS 9305060101 | |
| Download: ML20035H619 (4) | |
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SAN LUIS OBISPO MOTHERS FOR PEACE '93 t,m 29 P4 :06 before the ATOMIC SAFETY AND LICENSING BOARD l4 I
In the matter of SL Pacific Gas and Electric Company Docket No. 50-275-OLA-2 Diablo Congon Nuclear Power Plant 50-323-OLA-2 Unit Nos. 1 and 2 ASLBP No. S2-669-03-OLA-2 t
Facility Operating Licenses No. DPR-80 and DPR-82 April 25, 1993 San Luis Obispo Mothers for Peace Motion for Extension of Time to Examine Documents at Diablo Canyon Nuclear Power Plant Although the deadline for discovery ended on April 12, 1993, the Son Luis Obispo Mothers for Peace ("SLOMFF"] finds it necessory to request on extension of time to examine specific documents at the Diablo Canyon Nuclear Power Plant ("DCNPP"J.
SLOMFP needs additional time to view documents that are responsive to its First Set of Uritten Interrogatories and Request for Production of Documents to Pacific Gos and Electric Company
("PG&E"JEFebruary 16, 19933 because the initial opportunity to excmine documents at the plant site on March 16, 1993 was rot sufficient.
Additionally, SLOMFP needs additianol time to view documents that are responsive to its Second and Third Sets of Uritten Interrogatories and Request for Production of Documents to PGSE EMarch 8, 1993).
The Board's Order provided on opportunity to request such on extension for good cause shown.
SLOMFP hos good cause for the reasons stated below.
13 On April 13, 1993, SLONFP received two documents:
PBGE Response to Second Set of Uritten Interrogatories and Requests for the Production of Documents Filed by SLOMFP [ April 12, 1993] and PG&E Response to Third Set of Written Interrogatories and Requests for the Production of Documents Filed by SLOMFP CApril 12, 1993].
PG&E states that SLOMFP may view specific documents at the site prior to April 12. CResponse to Second Set 9305060101 930426 PDR ADOCK 05000275
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y ot 7 and 16.]
PG&E knew that this would be on impossibility, given the fact that SLOMFP would receive the responses to SLOMFP interrogatories and requests for documents ofter the April 12 deadline.
If PG&E chooses to have representatives from SLOMFP go to the site to view documents rather than copy and mail them, PG&E must provide the opportunity.
SLOMFP therefore requests on extension of time to view and copy documents at DCNPP.
23 PERE continues to belittle the SLCHFP for its manner af conducting discovery at the DCNPP.
PG&E's Opposition to Request for Additional Discovery Re Cables CApril 19, 19933 at 11.
Yet PGSE was there and was witness to SLCMFP efforts and PG&E's disorganized, time-consuming and ineffective methods of providing SLOMFP with documents.
For the record, SLOMFP notes that when its three representatives arrived at 9:45 on the morning of March 16, 1993 to view the documents that were noted as being responsive to SLOMFP First Set of Uritten Interrogatories and Requests for Production of Documents (February IB, 1993], no documents were ready or available to examine.
PG&E had the SLOMFP write down specific document requests; SLOMFP then had to wait long periods of time for the documents to be located and then delivered.
Of the five hours that the three SLDMFP representatives spent at the site, opproximately 2 1/2 hours were spent waiting for documents.
Furthermore, at the site, SLCMFP requested all of the NCRs and LERs that were listed as responsive to Interrogatories 12 and 19 and Document Request 22 on Attachment 2 in PGSE's Response to First Set of Interrogotcries and Request for Production of Documents Filed by SLOMFP i
(Re:
Contention 13CMorch 12, 1993].
Of the 93 NCRs listed, PGBE provided the SLOMFP with only B.
Of the 29 LERs listed, PGSE provided SLOMFP with 2
-rc,*
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20.
SLOMFP requested these documents in its Motion to Compel PGSE to Respond to the First Set of Interrogatories and Requests for the Production j
of Documents CRe: Contention I)[ March 29, 19933 at S.
SLOMFP requests
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t either that PG&E provide these and other documents or another opportunity to examine and copy them at the site.
Additionally, SLOMFP requests that I
i these documents be ready and avoilable for viewing when representatives l
t from SLOMFP orrive at the plant site.
SLOMFP intends to provide PG&E with I
o list of requested documents prior to the visit.
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d 3)
The proposed license omendment in question would not become i
i effective until the year 2008.
SLOMFP does not understond the l
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extraordinary hurry to get through the discovery phase of this proceeding.
Discovery was very short.
And during that time, o lot had been required; i
SLOMFP was working on discovery requests, various motions and three late-filed contentions.
Given the circumstances, SLOMFP requests odditional time to continue to examine documents at the plant site.
SLOMFP is agreeable to viewing these documents at the site or at PG&E's office in Son Luis Obispo.
SLOMFP would also agree to provide o i
list of document requests; PG&E con then copy and mail them to SLOMFP.
If PGSE chooses to have SLOMFP examine documents at the site or at its office
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rather than copy and mail them, SLOMFP proposes May 9, S and/or 6, 1993 os
-dotes to do so.
SLOMFP reiterates that it will provide o list of document l
i requests to PG&E prior to May 9 and. expects that these documents will be l
i ready and avoilable to the SLOMFP representatives when they arrive.
j Respectfully submitted, 2
1 l
Noney. Culver, President y
Son Luis Obispo Mothers for Peace P.O.
Box 169
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Pismo Beach, CA 93998 l
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'93 TK 29 Pi :09 j
Certificate of Service i
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I hereby certify that copies of the foregoirg Son Luis Obispo'yMothers for Peace ("SLOMFF"3 Motion for Extension of Time to Examine Document's at Diablo Congon Nuclear Power Plant and Intervenor SLOMFP Reply to Pacific Gas and Electric Company's C"PGSE"3 Motion to Strike in Port SLOMFP Filing Regarding Addendum to FES and Intervenor SLOMFP notion to Compel PGSE to Respond to the Second and Third Sets of Interrogatories and Requests for Production of Documents Filed by SLOMFP and Intervenor SLOMFP Motion to l
Compel the NRC Stoff to Respond to the First Set of Interrogatories and Request for the Production of Documents Filed by SLOMFP and SLOMFP Motion j
for Leove to Reply to PGSE's Opposition to Additianol Discovery Re: Cables have been served upon the followirg persons by U.S.
mail, first c1 css.
j Cffice of Ccenissico Appel1cte Administrative Judge l
Adjudication Charles Bechhcefer, Chairman U.S.
Nuclecr Regulctcry Commissicn Atcmic Sofety and Licensing Eco-d Ucshington, CC 20555 U.S.
Nuclear Pegulatory Commission j
Ucshingtcn, DC 20555 l
Administrative Judge Jerry Kline Administrative Judge Atomic Screty and Licensing Ecord Frederick J.
Shan l
U.S.
Nuclect Regulatcry Ecmmission Atomic Screty and Licensing Eccrd Ucshington, DC 20555 U.S.
Nuclear Regulatory Commissacn j
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Educrd O'Neill i
Ann P. Hodgdon, Esq.
Peter Arth, Jr.
i Office cf the General Counsel Truman Burns i
r U.S.
Nuclecr Regulctory Commission
?cbert Kinasion Ucshington, DC 20555 Peter G.
Fairchild, Esq.
i Californic Public Utilities Commission Jcseph E.
- Knotts, Jr.,
Esq.
505 Ucn Ness Avenue j
U1nston & Stroun Son Francisco, CA 99102 1400 L Street, N.U.
Ucshington, CC ECCCE
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Adjudicatcry File Secretcry cf the Ecmmission U.S.
Nuclecr Pegulctcry Commission Occi.eting and Service Eranch Ucshington, CC EC555 U.S.
Nuclecr Regulatory Ccmmissicn Ucsringtcn. CC EC555
? chert ?.
Uellingtcr Esq.
Dicb1c Ccnycn Independent Scfety Ccmmattee 057 Ccss Street. Suite D Monterey, CA 53590 Chr:stopher Untrer, Esq.
t 31 chord '.cche, Esq.
?ccific Ecs cnd Electric Cc.
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~~ Eecle Street con Francisec, CC es1Cs i
~ 111 ZamEk i
Octed cpri. 25, 15S5. San L ls Cbispc Cc_nty, CA 1
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