ML20236B793

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Reply of PG&E to Scenic Shoreline Preservation Conference, Inc Motion.* Util Believes That NRC Responsible to Determine Extent That Check of Util Design Necessary.Certificate of Svc Encl
ML20236B793
Person / Time
Site: Diablo Canyon, 05000000
Issue date: 04/09/1976
From: Crane P
PACIFIC GAS & ELECTRIC CO.
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20236A877 List: ... further results
References
FOIA-87-214 NUDOCS 8707290235
Download: ML20236B793 (4)


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s UNITED STATES OF AMERIL.

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARQ 7u L/

In the Matter of )

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PACIFIC GAS AND ELECTRIC COMPANY ) Dockets 50-275-g /

) 50-323-OL Units 1 and 2 )

)

Diablo Canyon Site )

)

REPLY OF PACIFIC GAS AND ELECTRIC COMPANY TO SCENIC SHORELINE PRESERVATION CONFERENCE, INC. MOTION Pacific Gas and Electric Company hereby replies to the Scenic Shoreline Preservation Conference, Inc. undated Motion received March 31, 1976 as follows:

1. All PGandE knows about the meeting in San Francisco referred to in paragraph 1 of the motion is what it read about it in the newspapers. PGandE was neither invited nor did it attend l any such meeting. In any event, the Board has previously ruled l

that ex parte meetings between PGandE and the NRC Staff are proper (Order dated March 12, 1975). Whatever develops from such meetings is, of course, subject to examination at the public hearing.

2. PGandE is not the proper party to reply to the allega-tions concerning Dr. Newmark. As we understand it, he is a consultant to NRC but not an " arbiter of differences between agencies." PGandE sees no need for appointment of an " independent five-person committee" and submits that the testimony of its consultants and the NRC Staff's consultants at the operating license public hearing will be sufficient to consider adequately the issues in contention among the parties.

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8707290235 070721 i PDR FOIA A C PLR u.ONNORO7-214 L__________ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ .


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3. PGandE subl..its that it is up to the NRC to decide how much of a check of PGandE's design is necessary. In any event, a considerable amount of auditing and design review has been conducted since the statement by Mr. Shao in February 1975.

Respectfully submitted, JOHN C. MORRISSEY PHILIP A. CRANE, JR.

DENNIS C. SULLIVAN BRUCE R. WORTHINGTON By' h ,

Phipfp A. Crane, 'Jr.

Attorneys for Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 (415) 781-4211 Dated: April 9, 1976 i

~, ) UNITED STATEq OF AMERIC.

NUCLEAR REGULhTORY COMMISSION In the Matter of )

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

) 50-323-OL Units 1 and 2 )  !

)

Diablo Canyon Site )

)

CERTIFICATE OF SERVICE The foregoing document 09) of Pacific Gas and Electric Company has Mkaxxd been served today on the following by deposit in the United States mail, properly stamped and addressed:

Mrs. Elizabeth E. Apfelberg Mr. John J. Forster 1415 Cazadero C/o Mr. Gordon Silver q Saa Luis Obispo, California 93401 5055 Radford Avenue North Hollywood, California 91607  :

James R. Tourtellotte, Esq.  !

Office of Executive Legal Director Director BETH 042' Division of Reactor Licensing.

U. S. Nuclear _ Regulatory Commission U. S. Nuclear Regulatory Commission i Washington, D. C. 20555 Washington, D. C. 20555 Elizabeth S. Bowers, Esq. Nathaniel H. Goodrich, Esq.

Chairman Chairman Atomic Safety and Licensing Board Atomic Safety and Licensing U. S. Nuclear Regulatory Commission Board Panel Landow Building - Room 1209 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Landow Building - Room 1209 Washington, D. C. 20555 Mr. Glenn O. Bright Atomic Safety and Licensing Board Dr. William E. Martin U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Landow Building - Roor 1209 Senior Ecologist Washington, D. C. 20555 Battelle Memorial Institute Columbus, Ohio 43201 Mr. William P. Cornwell P.O. Box 453 Alan S. Rosenthal, Esq.

Morro Bay, California 93442 Chairman Atomic Safety and Licensing Mr. Frederick Eissler Appeal Panel Scenic Shoreline Preservation U. S. Nuclear Regulatory Commission Conference, Inc. Landow Building - Room 1209 4623 More Mesa Drive Washington, D. C. 20555 Santa Barbara, California 93110 Secretary Ms. Raye Fleming U. S. Nuclear Regulatory Commission 1746 Chorro Street Washington, D. C. 20555 San Luis Obispo, California 93401 Attn.: Docketing and Service Section

.,k Mrs. Sandra A. Silver l 5055 Radfcrd Avenue '

North Hollywood, California 91607 1 Andrew Skaff, Esq.

Counsel Public Utilities Commission of the State of California 5066 State Building San Francisco, California 94102 bA M P%ip A. ' Crand, " Jr. /

, Attorney l Pacific Gas and Electric Company l Dated: April 9, 1.976 l

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