ML20036A671
| ML20036A671 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon |
| Issue date: | 05/06/1993 |
| From: | Culver N SAN LUIS OBISPO MOTHERS FOR PEACE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#293-13948 92-669-03-OLA-2, 92-669-3-OLA-2, OLA-2, NUDOCS 9305130060 | |
| Download: ML20036A671 (2) | |
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%f&C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 93 M Y 10 P3 :26 ATOMIC SAFETY AND LICENSING BOARD m n ; E 41;,c '
In the matter of DUChi %G A ' > VifT Pacific Gas and Electric Company Docket Nos. 5dah75-OLA-2 Diablo Congon Nuclear Power Plant SD-323-OLA-2 Units 1 ond 2 ASLBP No. 92-GES-03-OLA-2 Focility Operating Licenses No. DPR-80 ond DPR-82 May 6, 1993 Intervenor Son Luis Obispo Mothers for Peace Repig to Pacific Gas and Electric-Company's Motion to Impose Duty on MFP to Supplement Responses to Interrogatories and Requests for Production of Documents On April 23, 1993, Pacific Gas and Electric Company C"PG&E"3 filed a Motion to Impose Duty on MFP to Supplement Responses to Interrogotories and Requests for Production of Documents.
PG&E expresses its frustrations with the Son Luis Obispo Mothers for Pecce C"SLOMFP"] responses to PG&E's Second Set of Interrogatories and Requests for Production of Documents.
SLOMFP hereby responds to PG&E.
SLOMFP is owere of its duty to supplement its answers to discovery requests, yet SLOMFP connot answer what it does not know.
Working;within the compressed time schedule of the' discovery period, working with limited resources, and busy with the issues that have come up in the course of discovery, SLOMFP hos not had the opportunity to evoluote the cose.
Furthermore, SLOMFP hos not yet received all of the information and documents requested of PGBE.
SLOMFP would hope to be'ollowed the time to evoluote its cose.
SLOMFP is working with its consultants and would expect to be able to identify its expert witnesses prior to summary disposition.
Respectfully Submitted, Noney Culver, President Son Luis Obispo Mothers for Peace 3
930513006o 93o506 ^
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~93 MAY 10 P 3 :27 Certificate of Service I hereby certify that copies of the foregoing Intervenor;. Son,Luis Obispo Mothers for Peace Reply to Pacific Gas and ElectricuCompany's! Motion to Impose Duty on MFP to Supplement Responses to InterrogatoFies and Requests for Production of Documents have been served upon the following persons by U.S. mail, first class.
Office of Commission Appellore Administrative Judge Adjudication Charles Bechhoefer, Chairman U.S.
Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, DC 20555 U.S.
Nuclear Regulatory Commission Washington, DC 20555 Administrative Judge Jerry Kline Administrative Judge Atomic Screty and Licensing Board Frederick J.
Shon U.S. Nuclear Regulatory Commission Atomic Sofety and Licensing Board Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Edward O'Neill Ann P. Hodgdon, Esq.
Peter Arth, Jr.
Office of the General Counsel Truman Burns U.S. Nuclear Regulatory Commission Robert Kinosion Washington, DC 20555 Peter G. Fairchild, Esq.
California Public Utilities Commission Joseph B. Knotts, Jr.,
Esq.
505 Uon Ness Avenue Winston & Strown Son Francisco, CA 94102 1900 L Street, N.W.
Washington, DC 20005 Adjudicatory File Secretary of the Commission U.S. Nuclear Regulatory Commission Docketing and Service Bronch Washington, DC 20555 U.S.
Nuclear Regulatory Commission Ucshington, DC 20555 Robert R. Wellington, Esq.
Diablo Congon Independent Safety Committee 357 Cass Street,-Suite D Monterey, CA S3940 Christopher Warner, Esq.
Richard Locke, Esq.
Pacific Gas and Electric Co.
77 Beale Street San Francisco, CA 94105 Jill ZomEk Dated May 8, 1993, Son Luis Obispo County, CA
.