ML20210T054

Response to Util First Set of Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence

ML20210T054
Person / Time
Site:	Diablo Canyon
Issue date:	10/03/1986
From:	Mcdermott L CONSUMERS ORGANIZED FOR DEFENSE OF ENVIRONMENTAL
To:	PACIFIC GAS & ELECTRIC CO.
Shared Package
ML20210T028	List: ML20210T022 ML20210T054
References
86-523-03-LA, 86-523-3-LA, OLA, OLH, NUDOCS 8610080294
Download: ML20210T054 (4)

Text

<a f

UNITED STATES OF AMERICA 00gEJC NUCLEAR REGULATORY COMMISSION DEFORE THE ATOMIC SAFETY AND LICENSING BOAS 6 0CJ -6 P5 :28

) GFFlCE CF u . M In the Matter of: ) Docket NoE.0Cfgif'g"0LAga

) and 50-323-PACIFIC GAS AND ELECTRIC COMPANY )

) ASLBP No. 86-523-03-LA (Diablo Canyon Nuclear Power Plant, )

Units 1 and 2) ,)

INTERVENOR CONSUMERS ORGANIZED FOR DEFENSE OF ENVIRONMENTAL SAFETY ANSWER TO PACIFIC GAS AND ELECTRIC COMPANY'S FIRST SET OF INTERROGATORIES AND ,

REQUEST FOR PRODUCTION OF DOCUBENTS ANSWER 1. The License Amendment Request Application as per Sect.

182a of the Atomic Energy Act of 1954 as amended states:

l Applications for, and statements made in connection with, lic-enses under section 103 and 104 shall be made under oath or af-firmation.

The only proffered material in this matter which meets the above cri-terion is the Oct 30, 1985 LAR 85-13, Reracking of Spent Fuel Pools.

The official record in this matter is silent in respect to any analy- ,

( sis having been performed.

l ANSWER 2~, 3, 4, 5, 6, 7, 8, 9, 10, 13. See Answer to #1.

The official record in this matter does not provide the informa-tion that is the duty of the regulator and the obligation of the ap-plicant/ licensee to provide for credable evaluation of this License

! Amendment Request. Therefore these questions are premature at this time.

Intervernors in this matter have been cast into an adversarial 8610080294 DR 861003 ADOCK 05000275 PDR

<a 3

t .

position thereby missing a valuable asset of intervention, that is, public review of the Applicant / Licensee Application Request and Sup-plement to the NRC Staff's legal and technical review in this matter.

Intervention provides another dimention and facet to the defense of the public health and safety. If the review process is defective, Radiological Response Planning is the alternative.

Intervention can only be effective if all parties are dealing with the same information. There are indications that this is not so in this matter. PG&E, the applicant / licensee, controlls the information in this application proceeding and is attempting to turn this proce-

~

eding and the intervenor's role inside out by requesting C.O.D.E.S. to provide new information when the burden is on PG&E to correct their deficient application which does not support this proceeding.

For the above reasons, C.O.D.E.S. objects to and cannot answer interrogatories #2, 3, 4, 5, 6, 7, 8, 9, 10 & 13 as propounded.

ANSWER 11, 12. Persons who work with C.O.D.E.S.. in relation to Diablo Canyon Power Plant have found anonymity to be a necessity for a variety of compelling legal, financial and personal safety reasons.

C.O.D.E.S. refers the interrogator to 10CFR2.740(c) protective order and gives notice that this protection is invoked.

REQUEST FOR PRODUCTION OF DOCUMENTS, RESPONSE 1, 2, 3, 4. C.O.D.E.S.

objects to the request for production of documents as being premature in this proceeding. The threshold imperfection in this matter makes it impossible to respond to this request. There is not sufficient documentation in the official record to prepare an adequate evaluation of the License Amendment Request application as submitted.

W

<3 l

INSTRUCTION, RESPONSE #6: C.O.D.E.S. calls attention to

~

10CFR2.740(3) and does NOT agree to such an imposition.

Respectfully submitted Y .Y_____

Laurie McDermott, Co-Ordinator for C.O.D.E.S.

$b Date I do declare and affirm that the above response is true and accu te to the best of my knowledge and ability.

$ Y f. has Y 0bipy f.aA A m E ,

Date County Stat

o; '

(

f UNITED STATES OF AMERICA m m.

N NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 86 (ET -6 P5 :28

)

In the Matter of: ) Docket Nos. 5 -,DQ

/

) and 50-3 @23-0 W AN PACIFIC GAS AND ELECTRIC COMPANY )

) ASLBP No. 86-523-03-LA (Diablo Canyon Nuclear Power Plant, ).

Units 1 and 2) )

CERTIFICATE OF SERYICE I hereby Certify that Copies of "INTERVENOR CONSUMERS ORGANIZED FOR DEFENSE OF ENVIRONMENTAL SAFETY ANSWER TO NRC STAFF INTERROGATORIES ,

AND REQUEST FOR DOCUMENTS REGARDING CONTENTION 14" and INTERVINOR CCN SUMERS ORGANIZED FOR DEFENSE OF ENVIRONMENTAL SAFETY ANSWER TO PACIFIC GAS AND ELECTRIC COMPANY'S FIRST SET OF. INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS" in the above Captioned matter have been served on the following Service List by deposit in the United States mail, first Class this 3rd day of October, 1986. I

"#-72..Lb.kY '.T ----

Abagail K. Town > Pedek B. Paul Cotter. Jr. , Chairman Bruce Norton, Esq. Docketing and Service Section Adminletrative Judge Norton Berry. French Office of the Secretary Atomic Safety and Licensing Board Penel e Perkins. P.C. U.S. Nuclear Regulatory Commiselon U.S. Nuclear Regulatory Cammleolon P.O. Box 10569 Washington. D.C. 20555'

. Washington, D.C. 26555' Phoenix, AZ 85064 Glenn O. Bright. Esq. Nancy Culver Atomic Safety and Licensing Administrative Judge 192 Luneta Street Board Panet Atomic Safety and Licensing Board Penel San Luis obispo. CA 93401 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555' Weehington, D.C. 20555' Mrs. Jacquelin Wheeler Atomic Safety and I.lcensing Dr. Jerry Harbour 2455 Leona Street Appeal Board Penel Administrative Judge San Luis Obispo. CA 93401 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panet Washington. D.C. 20555' U.S. Nuclear Regulatory Commisalon Washington, D.C. 20555' Managing Editor San Luis Obtepo County Richard E. Blankenburg Philip A. Crane, Jr. . Esq. Telegram-Tribune Co-publisher (77 Beale Street. 31st Floor) 1321 Johnson Avenue Wayne A. Soroyen. News Reporter P.o. BOX 7442 P.O. Box 112 Scuth County Publishing Company San Francleco. CA 94120 (94106) San Lula Obispo. CA 93406 P.O. Box 480 Arroyo Grande. CA 93420 Laurie McDermott. Co-ordinator Mn/- d kc Ort (gg ,

Mr. Lee M. Gustafson f3gpeggjeStreet t.o tf *t C d . bW t Pe ifle Oas and Electric Co. Suite #42 San Luis obispo. CA 93401 C.(fgg, g{p(dg, alkr, 1726 M Street. N.W.

Washington, D.C. 20036-4502 Dr. Richard Ferguson Dian M. Gruenetch. Esq.

Edwin F. Lowry gg qbgJ 2gg Grueneich a Lowry Vice-Chairmen 345 Franklin Street Sierra Club San Francleco. CA 94102 Rocky Canyon Star Route Creaton. CA 93432