ML20076G903

Motion for Extension Until 830827 to File Supplemental Response to Util First Request for Production of Documents. Related Correspondence

ML20076G903
Person / Time
Site:	Diablo Canyon
Issue date:	08/27/1983
From:	Reynolds J CENTER FOR LAW IN THE PUBLIC INTEREST, JOINT INTERVENORS - DIABLO CANYON
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
Shared Package
ML20076G906	List: ML20076G903 ML20076G908
References
ISSUANCES-OL, NUDOCS 8309010184
Download: ML20076G903 (4)

Text

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COftniLWONDENCE 88CKETED USNRC UNITED STATES OF AMERICA ,

NUCLEAR REGULATORY COMMISSION -

• BEFORE THE ATOMI'C SAFETY AND LICENSING. APPEAL ~ BOMB"E,CF SECy rf.&

.irm , - . ;;a vc ,,

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In the Matter of _

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)

PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 0.L.

' ) 50-323 0.L.

(Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) ) (Reopened Hearing --

) Design Quality

_ ) Assurance) i JOINT INTERVENORS' MOTION FOR ONE-DAY EXTENSION OF TIME TO FILE SUPPLEMENTAL RESPONSE TO PACIFIC GAS AND ELECTRIC COMPANY'S FIRST

REQUEST FOR PRODUCTION OF DOCUMENTS Pursuant to 10 C.F.R. S 2.711, the Joint Intervenors hereby respectfully move the Atomic Safety and Licensing Appeal Board (" Appeal Board") for an order extending the time in which to file a supplemental response to Pacific Gas and Electric Company's ("PGandE") First Request for Production of Documents.

By order dated August 16, 1983, the Appeal Board ordered the j Joint Intervenors to provide a further response to PGandE's document production request by August 26, 1983. A one-day extension of time in which to file the attached supplemental i

response until and including August 27, 1983 is requested by this motion.

The motion is necessitated by th? extensive activity in this proceeding during the past several weeks. In particular, the prehearing conference in Bethesda, Maryland and l

two days of depositions in San Francisco, California during the l 8309010184 830827 PDR C

ADOCK 05000275 /

PDR G)h)2 s/ - ,

o past five days has allowed counsel insufficient time to prepare a proper response to the document request by the date ordered.

For the foregoing reason, and for those reasons which appear in the attached Declaration of Counsel, the Joint Intervenors request that their motion for a one-day extension of time be granted.

DATED: August 27, 1983 Respectfully submitted, JOEL R. REYNOLDS, ESQ.

JOHN R. PHILLIPS, ESQ.

ERIC HAVIAN, ESQ.

j Center for Law in the Public Interest 10951 W. Pico Boulevard Los Angeles, CA 90064 (213)470-3000 DAVID S. FLEISCHAKER, ESQ.

1 P. O. Box 1178 oklahoma City, OK 73101 By N -

JOEL REYNOLDS Attorneys for Joint Intervenors SAN LUIS OBISPO MOTHERS FOR PEACE SCENIC SHORELINE PRESERVATION CONFERENCE, INC.

ECOLOGY ACTION CLUB SANDRA SILVER ELIZABETH APPELBERG JOHN J. FORSTER J

C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD

)

In the Matter of )

)

PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 0.L.

) 50-323 0.L.

(Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) ) (Reopened Hearing --

) Design Quality

) Assurance)

DECLARATION OF JOEL R. REYNOLDS I, Joel R. Reynolds, declare and say:

1. I am one of the attorneys for the Joint Intervenors in this proceeding.

2. On August 16, 1983, the Atomic Safety and Licensing Appeal Board ordered the Joint Intervenors to file a supplemental response to Pacific Gas and Electric Company's First Request for Production of Documents by August 26, 1983.

3. Due to the extensive level of activity in this l

l proceeding during the past several weeks, a one-day extension of time is necessary to prepare an adequate response. In particular, this extension is necessitated by the prehearing conference in Bethesda, Maryland and two days of depositions in San Francisco, California, all held within the past five days.

4. Because I was absent from my office for this period, I was unable to complete the document analysis requested by the Board, and, consequently, processing of the Joint i

Intervenors' response was postponed until my return.

l i J

5. The Joint Intervenors request that the Appeal Board exercise its authority pursuant to 10 C.F.R. S 2.711 and that the attached motion for a deadline extension of one day be granted.

I declare under penalty of perjury that the foregoing is true and correct.

Executed this 27th day of August, 1983, at Los Angeles, California.

) I _

Goel R. gg'yr161ds I

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