ML20062K464
| ML20062K464 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/11/1982 |
| From: | Crane P PACIFIC GAS & ELECTRIC CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ALAB-653, ISSUANCES-OL, NUDOCS 8208170211 | |
| Download: ML20062K464 (4) | |
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NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD.FFICE OF EEC C
'000KETING & SERVIC-Before Administrative Judges:
BRANCH-Lawrence Brenner, Chairman Dr. James H. Carpenter Dr. Peter A. Morris
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In the Matter of
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Docket No. 50-322 0.L.
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LONG ISLAND LIGHTING COMPANY
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(Security Proceeding)
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(Shoreham Nuclear Power Station,
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Unit 1)
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As permitted by the Commission's order dated July 30, 1982 (CLI-82-17) Pacific Gas and Electric Company (PGandE) makes this special appearance to oppose the request of counsel for intervenor Suffolk County for access by its consultants to portions of the Appeal Board decision on the Diablo Canyon Security Plan (ALAB-653).
Further, for the reasons set forth below PGandE will oppose any similar requests made in the future.
PGandE submits that there is no need for the Suffolk County consultants to have this information.
Their mission is to analyze the Shoreham security plan, not Diablo Canyon's.
Furthermore, in another order dated July 30, 1982 (CLI-82-19) the Commission released a sanitized version of ALAB-653.
This should give the
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Suffolk County consultants sufficient information for their purposes.
8208170211 820811 PDR ADOCK 05000322 O
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'PGandE has. expressed many times its continuing reluctance to permit outsiders to review its security plan because of the risk of unauthorized release of the details of the plan.
PGandE was agreeable to having certain lawyers look at selected portions of the Diablo Canyon ALAB decision to offset what it perceived to be the advantage Suffolk County counsel otherwise would have had due to their participation in the Diablo Canyon proceeding.
Now, it is requested that security plan information be given to consultants for that intervenor, and a similar request for other consultants can be expected.
PGandE submits that release of protected information to an ever expanding group of persons violates the spirit at least, if not the letter, of the principle of limiting access to security plan details strictly followed by the Appeal Board in the Diablo Canyon proceeding.
(See Appeal Board order dated October 17, 1980 reluctantly permitting an additional lawyer for Governor Brown to have access to the
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security plan.
See also ALAB-410, (5 NRC 1398) and CLI 77-23, (6 NRC 455.)
Respectfully submitted, Dated:
August 11, 1982 MALCOLM H. FURBUSH PHILIP A. CRANE, JR.
RICHARD F. LOCKE l
Pacific Gas and Electric Company Post Office Box 7442 l
San Francisco, CA 94120 (415) 781-4211 l
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ARTHUR C. GEHR Snell & Wilmer 3100 Valley Center Phoenix, Arizona 85073 (602) 257-7288 BRUCE NORTON Norton, Burke, Berry & French, P.C.
3216 N. Third Street Suite 300 Phoenix, Arizona 85012 (602) 264-0033 Attorneys for Pacific Gas and Electric Company
' Philip Crane Jr.
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In the Matter of DOCKETED LONG ISLAND LIGHTING COMPANY USNRC (Shoreham Nuclear Power Station, Unit 1)
Decket No. 50-322 (OL) 52 AW 16 N0:08 CERTIFICATE OF SERVICE GFFICE OF SECRETAnv 7 The foregoing document of Pacific Gas and ElectCdAEtasmastyVICE has been served today on the following by deposit in the NMEE%d States mail, properly stamped and addressed:
Lawrence Brenner, Esq.
Bernard M. Bordenick, Esq.
Administrative Judge U.S. Nuclear. Regulatory Atomic Safety and Licensing Commission Board Panel Washington, DC 20555 U.S. Nuclear Regulatory Commission Anthony F.
Earley, Jr., Esq.
Washington, DC 20555 Hunton & Williams
.P. O. Box 1535 Dr. Petcr A. Morris Richmond, Virginia 23212 Administrative Judge Atomic Safety and Licensing Chief, Records Service Branch Board Panel Division of Technical Information U.S. Nuclear Regulatory and Document Control Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. James H. Carpenter Bruce Norton, Esq.
Administrative Judge Norton, Burke, Berry & French, P.C.
Atomic Safety and Licensing 3216 N. Third Street Board Panel Suite 300 U.S. Nuclear Regulatory Phoenix, Arizona 85012 Commission Washington, DC 20555.
Michael S. Miller Kirkpatrick, Lockhart, Hill, Christopher & Phillips 1900 M Street N.W.
l Washington, DC 20036 l
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. h-v Philip ~/ ' Crane, J Attorne Dated:
August 11, 1982 Pacific Gas and El ctric Company l
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