ML20039C696

Submits Documents Described in Attachment Per ASLB 811216 Prehearing Conference Request to Submit Documents for in Camera Insp Withheld Under Claim of Privilege.W/O Documents

ML20039C696
Person / Time
Site:	Diablo Canyon
Issue date:	12/23/1981
From:	Lanpher L CALIFORNIA, STATE OF, KIRKPATRICK & LOCKHART
To:	Wolfe S Atomic Safety and Licensing Board Panel
References
ISSUANCES-OL, NUDOCS 8112300052
Download: ML20039C696 (3)

Text

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KrnnATRICE, LOCKHART, HrII. CnntsropuuR Sc,Rivrr.trys A Paarrname=se IncLunare A PmorsessanAL Composursos Lyy[;5? 4 ?

1900 M Srazzr, N. W.

WASHINGTON, D. C. 20000 TRLEFNONE (dos) 489 7000 ' ; }Z - [(,[IN'PETTesCBOE CABLE: HIFMI ~

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202/452-7011 Honorable Sheldon J. Wolfe A f jg. . J Atomic Safety and Licensing Board  % N 4'5(y United States Nuclear Regulatory C OEC Commission 9 %. O 798pm LIO Washington, D.C. 20555 Q

'L'y A !$ ij' f 9 !: !f

• If Re: Diablo Canyon Nuclear Power Plant, Units 1 and 2; Docket Nos. Oy//g"u . -@

50-275 0.L. and 50-323 0.L.

Dear Judge Wolfe:

During the Prehearing Conference in Bethesia, Maryland, on December 16, 1981, you requested counsel t<., submit for in camera inspection those documents which counsel have Ethheld from production under claim of privilege. Tr.

11,489, 11,497-98. In accordance with that request, counsel submits the documents described on the attachment here co.

Sincerely yours, fl--

Lawrence Coe Lanpher Attorney for Edmund G. Brown Jr., Governor of the State of California LCL/dk Enclosures cc: With attachment, but without documents:

3 Service List Dbs

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81123000S2 011223 PDR ADOCK 05000 G

INDEX OF DOCUMENTS WITilllELD FROM PRODUCTION ,

i DOCUMENT -

NUMBER DOCUMENT DESCRIPTION STATUS / REASON PRODUCTION NOT REQUIRED

• 1 October 6,1981 Menorandtm reflecting conversation 'Ihis docment was inadvertently produced in anong counsel and client sployees re review of discovery. No ruling necessary.

Tera Report. Confidential ocumunications between client and attorney.

2 tbtes frcm Philip Greenberg, Assistant to Governor 1) Protected by attorney / client privilege.

Brown for Energy and Environnent, reflecting infornation fmn and conversations with client 2) Does not relate to mergency planning at October 6 neeting referred to in Doctment No.1. contention.

3 George Young outline of conceptual steps necessary 1) Attorney / client privilege, in earthqtake/energency planning review. Prepared 2) Work product protection.

at request of counsel. 3) Not relevant to menjency planning contention as revised by Doard at prehearing conference.

4 tbtes of Ann Flook, State OES, re October 6 nceting 1) Attorney / client privilege.

referred to in Ibetment No.1. 2) tbt relevant to enenjency planning conten-tion as revised by Board at prehearing conference.

5 Letter fmn Phillip Greenberg to II. Brown and 1) Attorney / client privilege L. Lanpher, April 21, 1981, re FEMA review of 2) tbt relevant since 1976 plans are not 1976 (bunty plans. part of full power proceeding.

6 Menorandtm, Iarry Lanpher to Wade Ibse (Assistant 1) Attorney / client privilege. -

to Phillip Greenberg), dated June 12, 1981 re 2) Work product protection.

Mr. Sears' testinony in low power hearing. 3) tbt relevant in full power hearing.

7 Notes of Phillip Greenberg re Document No. 6. 1) Attorney / client privilege.

2) Not relevant in full power hearing.

8 Intter frcm Iitr:.y Ianpher to Wade Ibse, dated 1) Attorney / client privilege.

June 8,1981, re Mr. Sears' testinony in low 2) Work product doctrine.

power hearing. 3) Not relevant in full power hearing.

\

', I DOCUMENT NUMBER DOCUMENT DESCRIPTION STATUS / REASON PRODUCTION NOT REQUIRED 9 Ictter fran Iarry Ianpher to Richard Pelty, 1) Attorney / client privilege dated July 15,.1981, re his affidavit concerning 2) Work product doctrine.

use of helicopters to alert persons in Montana de Oro State Park.

10 Letter fran Iarry Ianpher to Ricinrd Minor, 1) Work product doctrine dated April 3, 1981, re his possibly supply- 2) Not relevant in full power hearing.

ing an affidavit'in low power proceeding.

11 Intter fran Iarry Ianpher to Wade Ibse, dated 1) Attorney / client privilege.

May 29, 1981, re Mr. Sears' testinony in low ' 2) Work product doctrine.

power hearing. 3) Not relevant in full power hearing.

12 Caltrans Report called for in Doctanent No.1. 'Ihis ch7 tenent was inadvertently provided to

• PGLE. No ruling necessani.

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