ML20035H624
| ML20035H624 | |
| 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-#293-13920 92-669-03-OLA-2, 92-669-3-OLA-2, OLA-2, NUDOCS 9305060109 | |
| Download: ML20035H624 (3) | |
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i 93 ffR 29 P416 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the t'
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I ATOMIC SAFETY AND LICENSING BOARD NLE [. } m'. : '
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In the matter of l
Pacific Gas and Electric Company Docket Nos. 50-275-OLA-2 Diablo Congon Nuclear Power Plant 50-323-OLA-2 Units 1 and 2 ASLBP No. 92-SSS-03-OLA-2 Focility Operating Licenses No. DPR-BO ond DPR-82 April 26, 1993 i
Intervenor Son Luis Obispo Mothers for Peace Motion to Compel the NRC Stoff to Respond to the First Set of Interrogatories and Request for the Production of Documents Filed by Son Luis Obispo Mothers for Peace On March 8, 1993, the Son Luis Obispo Mothers for Peace ["SLOMFP"3 filed its First Set of Written Interrogatories and Requests for the Production of Documents to the NRC Stoff.
The NRC Stoff filed its response i
on April 12, 1993:
NRC Staff's Response to SLOMFP's First Set of Interrogotories and Request for the Production of Documents.
In this I
document, the NRC Staff objects to some requests or provides insufficient onswers.
For reasons provided below, SLOMFP moves that the Atomic Safety and Licensing Board enter on Order compelling the NRC Stoff to answer certain of SLOMFP's interrogatories and requests for documents.
9305060109 930426 PDR ADOCK 05000275 O
PDR Interrogatory 9:
Stunty requests information on the reliability of fire watch personnel.
The NRC Stoff objects to this request as being overly 1
brood, unduly burdensome and unnecessary because this information is l
publicolly available.
But SLOMFP believes that this is on extremely I
reasonable request and should be answered.
This information is not reasonobly obtainoble through other means Furthermore, this information is highly relevant to the proceeding because the utility is relying on fire watches to compensate for o faulty fire barrier material.
36M
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i Interrogatory S:
SLOMTP requests NRC stoff inspectiot.s and/or evoluotions f
of the fire watch program implemented by Pacific Gas and Electric Company t
C"PG&E"3 at Diablo Congon Nuclear Power Plant ("DCNPP").
The NRC Stoff i
finds it unduly burdensome to list all inspection reports from the time the plant began operation.
So, SLOMFP hos been provided with six inspection i
report numbers and dotes which dated back to July 1991.
This portial list is insufficient.
The SLOMFP believes this to be o reasonable request.
SLOMFP expects that this information is organ 2 zed in such a fashion that 1
this request is not burdensome - especially since the plant has only been in operation since 1S89.
I 1
Interrogatory 7:
The NRC Stoff objects to SLOMFP's request for summaries of NRC Stoff position on the contentions admitted by the Board in this proceeding.
The NRC Staff claims that this information is available in pleadings and public documents.
But these documents were written before the contentions were admitted.
Now that these contentions have been admitted, SLOMFP requests knowledge of the NRC Stoff position of these i
contentions based on their merits.
SLOMFP believes this to be o reasonable request.
i Respectfully Submitted, Nancy Culver, President Son Luis Obispo Mothers for Peace P.O. Box 169 l
Pismo Beach, CA S3998
93 TJ7 29 P4 :09 Certificate of Service 1 hereby certify that copies of the f oregoing Son Luis Obispo'. Mothers! for Peace ("SLOMFF"] Motion for Extension of Time to Examine Documents at Diablo Canyon Nuclear Power Plant and Intervenor SLOMFP Reply to Pacific Gas and Electric Company's ["PG&E"3 Motion to Strike in Port SLOMFP Filing Regarding Addendum to FES cnd Intervenor SLOMFP Motion to Compel PGRE to Respond to the Second and Third Sets of Interrogatories and Requests for Production of Documents Filed by SLOMFP ond Intervenor SLOMFP Motion to Compel the NRC Stoff to Respond to the First Set of interrogatories and Request for the Production of Documents Filed by SLOMFP cnd SLOMFP Motion for Leave to Reply to PGSE's Opposition to Additional Discovery Re: Cables have been served upon the following persons by U.S.
mcil, first class.
Cffice cf Ccmmission Appellcte Administrative J;dge cdjudicction Charles Dechhcefer, Chairman U.S.
Nuclear Regulatcry Commissicn Atcmic Sofety and Licensing Board Ucshirgton, DC 20555 U.S.
Nuclear Regulatory Commission Ucshington, DC 20555 Administrative Judge Jerry Kline Administrctive Judge Atomic Screty and Licensing Bocrd Frederick J.
Shcn U.S.
Nuclear Regulatory Ccmmission Atomic Sofety cnd Licensing Board Ucshingtcn, DC 20S55 U.S.
Nuclecr Regulatory Commission Ucshington, DC EC555 Edwced O'Neill Ann P.
Mcdgdon, Esq.
Peter Arth, Jr.
Office of the General Counsel Trumon Burns U.S.
'Lclecr Pegulctory Ccmmission Robert Kinesian i
Ucshington, DC 20555 Peter G.
Fairchild, Esq.
Californio Public Utilities Commission Jcseph E.
- Knotts, Jr.,
Esq.
ECS Ucn Ness Avenue U1nston S Strcun San Frcncisco. CA 94102 1900 L Street, N.U.
Unshirgton, DC 20C05 Adjudicatcry File Secretary cf the :cmmission U.S.
utlear Pegulatory Commission OccLeting and Seru1ce Eronch Ucshirgton, DC 20555 U.S.
Nuclear Rcgulatory Commission Ucshington, DC 2:555
?cbert F Lellirgian, Esq.
Dicbic Canyon Independent Safet Ecmmittee a
E57 Cass Street, Euite D M ntercy, CA 93SMO Christcpher Ucr er Esq.
Richard Locke, Esq.
/
Pccif c 30s and Electric Co.
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