ML20148D934

Second Discovery & Status Rept of Applicants Southern CA Edison & San Diego Gas & Elec.Submitted in Response to Memorandum & Order of 781002 Requiring Each Party to Rept by 781020.Expects to Issue SER by 790501.W/Cert of Svc

ML20148D934
Person / Time
Site:	San Onofre
Issue date:	10/20/1978
From:	Casey S, Kocher C, Pigott D CHICKERING & GREGORY, SOUTHERN CALIFORNIA EDISON CO.
To:
References
NUDOCS 7811060050
Download: ML20148D934 (5)

Text

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m- - <pbr-I DAVID R. PIGOTT

' SAMUEL B. CASEY 2 CHICKERING & GREGORY gg Three Embarcadero Center 3 Twenty-Third Floor  :

San Francisco, California 94111 T '

4 Telephone: (415) 393-9000 m

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5 CHARLES R. KOCHER t - 4 -

JAMES A. BEOLETTO \h h N 6 SOUTHERN CALIFORNIA EDISON COMPANY V D P. O. Box 800 0: J 7

2244 Walnut Grove Avenue N 3

Rosemead, California 91770 8

Telephone: (213) 572-1900 9

Attorneys for Applicants, Southern California Edison Company 10 and San Diego Gas & Electric Company 11 12 UNITED STATES OF AMERICA 13 NUCLEAR REGULATORY COMMISSION 14 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 15 16 In the Matter of ) Docket Nos. 50-361 OL

) 50-362 OL 17 SOUTHERN CALIFORNIA )

EDISON COMPANY, et al.,) SECOND DISCOVERY AND l 18

) STATUS REPORT OF APPLICANTS l

(San Onofre Nuclear Generating ) SOUTHERN CALIFORNIA EDISON

! 19 Station, Units 2 and 3) ) COMPANY AND SAN DIEGO GAS &

) ELECTRIC COMPANY

)

20 S uthern California Edison Company and San Diego Gas &

21 22 Electric Company (hereinaf ter " Applicants") submit this report in 23 response to the Memorandum and Order of October 2, 1978, requiring 24 each party in the above-captioned proceeding to report on or before October 20, 1978, the status of its discovery and its 25 26 estimates for hearing dates.

As of the date of this filing, Applicants have responded 27 to interrogatories submitted by FOE, et al. Applicants have not -

28 N 17;.0600f D

I received a discovery request from GUARD.

2 Applicants are now preparing their case for issuance 3 of operating licenses for San Onofre Generating Station, Units 2 4 and 3. The preparation of Applicants ' direct case does not re-5 quire discovery from any other party at this time.

6 On June 28, 1978, as a part of its overall preparation 7 for hearing, Applicants served a first set of interrogatories on 8 FOE, et al. and GUARD, the intervenors in this proceeding. The 9 primary purpose of these interrogatories was to elicit a specific 10 articulation of the precise bases for each of the intervenors' 11 contentions, and to discover the documents and witnesses each 12 intervenor will rely on at hearing. FOE, et al. and GUARD have 13 separately responded to Applicants' first set of interrogatories.

14 Applicants may engage in additional discovery to further clarify 15 the intervenors' positions and to examine prospective intervenor 16 witnesses as they are identified pursuant to 10 C.F.R. S2.740(e).

17 Applicants are aware of the possibility of summary 18 disposition of contentions in nuclear licensing proceedings. In 19 order to facilitate this licensing proceeding, Applicants may

! 20 move for summary disposition well before the hearings in this l

21 matter if it appears that as to a particular contention there is 22 no genuine issue as to a material fact and that Applicants are 23 entitled to a decision on that contention as a matter of law.

! 24 Applicants anticipate being ready to begin safety or environmental hearings in this matter within thirty (30) days of 25 26 receipt of the Safety Evaluation Report (including all supplements 27 thereto) or the Final Environmental Impact Statement, as the case 28 may be. Based on correspondence with the NRC Staff, Applicants l

e 1 presently estimate that the Staff will complete its review and 2 issue its Safety Evaluation Report on or before May 1, 1979; and 3 its Final Environmental Impact Statement on or beTere April 1, 4 1979.

5 Applicants presently plan initial fuel load of Unit 2 6 .in February, 1980; and of Unit 3 in May, 1981. This being the 7 case Applicants are hopeful that all hearings in this matter 8 will be completed by September, 1979 so that the initial decision 9 and the operating license for each Unit can issue without 10 adversely affecting the initial load date for either Unit 2 or 3.

13 DATED: Octcher 20 , 1978.

12 13 Respectfully submitted, 14 DAVID R. PIGOTT SAMUEL B. CASEY 15 CHICKERING & GREGORY 16 CHARLES R. KOCHER J AMES A . BEOLETTO 17 SOUTHERN CALIFORNIA EDISON COMPANY 18

/s/ David R. Pigott DAVID R. PIGOTT 20 One of Counsel for Applicants Southern California Edison Company 21 and San Diego Gas & Electric Company 22 23 24 25 26 27 28 1

CERTIFICATE OF SERVICE I hereby certify that on the bhdayofOctober, 1978, 3

a copy of the foregoing SECOND DISCOVERY AND STATUS REPORT OF 4

APPLICANTS SOUTHERN CALIFORNIA EDISON COMPANY AND SAN DIEGO GAS &

5 ELECTRIC COMPANY was served upon each of the following by deposit 6

in the United States mail, first-class postage prepaid, addressed 7

as follows:

8 Ivan W. Smi ch , Esq . , Chairman 9 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission .

C 10 Washington, D. C. 20555 11 Dr. Cadet H. Hand Jr., Member Director, Bodega Marine Laboratory 12 University of California P.O. Box 247 13 Bodega Bay, California 94923 14 Mr. Lester Kornblith Jr., Member Atomic Safety and Licensing Board 15 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 16 Lawrence J. Chandler, Esq. l 17 Office of the Executive Legal Director l U. S. Nuclear Regulatory Commission l 18 Washington, D. C. 20555 19 Janice E. Kerr, Esq.

J. Calvin Simpson, Esq.

20 Lawrence Q.'Garcia, Esq.

California Public Utilities Commission 5066 State Building j 21 San Francisco, California 94102 22 David W. Gilman 23 Robert G. Lacy San Diego Gas & Electric Company 24 P. O. Box 1831 San Diego, California 92112 25 James H. Drake, Vice President 26 Southern California Edison Company P. O. Box 800 27 2244 Walnut Grove Avenue Rosemead, California 91770 28

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a . O 1 John R. Bury, General Counsel Charles R. Kocher, Esq.

2 James A. Beoletto, Esq.

Southern California Edison Company 3 P. O. Box 800 2244 Walnut Grove Avenue 4 Rosemead, California 91770 5 Alan R. Watts, Esq.

Rourke & Woodruff 6 California First Bank Building 10555 North Main Street, Suite 1020 7 Santa Ana, California 92701 8 Richard J. Wharton, Esq.

4655 Cass Street 9 San Diego, California 92109 10 Phyllis M. Gallagher, Esq.

615 Civic Center Drive, West 11 Suite 220 Santa Ana, California 92701 12 -

Mrs. Lyn Harris Hicks 13 GUARD 3908 Calle Ariana 14 San Clemente, California 92672 15 Mr. Lloyd von Haden 2089 Foothill Drive 16 Vista, California 92083 17 Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission 18 washington, D. C. 20555 l 19 Docketing and Service Section Office of the Secretary l 20 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 21 l

22 .

- < l 23 + W AY SAMUEL B. CASEY One of Counsel for Applicahts 25 Southern California Edison  !

Company and San Diego Gas & I 26 Electric Company 27 )

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