ML20236C170
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.am UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION In the Matter of
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PACIFIC GAS AND ELECTRIC COMPANY
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Docket Nos. 50-275
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50-323 Diablo Canyon Site - Units 1 and 2
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RESPONSE OF PACIFIC GAS AND ELECTRIC COMPANY TO MOTION AND REQUEST OF SCENIC SHORELINE PRESERVATION CONFERENCE, INC.
DATED MAY 10, 1972 Pacific Gas and Electric Company responds to the motion and request filed by Scenic Shoreline Preservation Conference, Inc., dated May 10, 1972, as follows:
1.
Motion to rescind construction oermits.
Clearly, this motion should be denied, PGandE l
will, of course, be bound by the decision of the Commission af ter the Commission reviews the record of the emergency core cooling systems rulemaking proceeding.
Until that record is closed any action regarding the construction permits for the units at Diablo Canyon, or any other construction permits for that matter, would be premature and unwarranted.
2.
Recuest for inclusion of seismic matters.
Once again Conference seeks to inject the seismic design issue into the hearing.
The matter has already been decided, and correctly so, by the Atomic Safety and Licensing Appeal Board in its Memorandum and Order dated August 16, 1971, l
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CONNORB7-214 PDR 1
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and by the Commission itself in its Memorandum and Order dated.
April 21, 1972.
Nothing has developed which should. disturb these decisions.
It is sufficient to note that the Appeal-Board had an opportunity to review the Mendes affidavit prior to issuing its Memorandum and Order dated August 16,-
1971, which is reflected in the Board's decision.
Conference's allegations concerning the proposed Los Angeles Building Code amendments are not relevant to this proceeding for a number of reasons, including the following:
1.
As indicated in the Conference's pleading, the changes are only proposed and have not been adopted.
2.
The Los Angeles Building Code does not apply to the Diablo Canyon Plant.
3.
The proposed amendments indicate one may use an acceleration of other than 0.5 g if.one supplies his own seismic design analysis.
Thus, the 0.5 g requirement is not absolute but is subject to variation based upon the proper analysis.
Respectfully submitted, F. T. SEARLS JOHN C. MORRISSEY PHILIP A. CRANE, JR.
ARTH L. HILLMAN A R.
l Bht' Phili[K. Crane {Jr.
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Attorneys for i
l Pacific Gas-and Electric Company 77 Beale Street San' Francisco, California 94106 415-781-4211 Dated:
May 15, 1972 2'
n UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION In the Matter of
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PACIFIC GAS AND ELECTRIC COMPANY
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Docket Nos. 50-275
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50-323 Diablo Canyon Site - Units 1 and 2
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CERTIFICATE OF SERVICE The foregoing response of Pacific Gas and Electric l
Company dated May 15, 1972 has been served today on the fol-lowing by deposit in the United States mail, properly stamped l
and addressed:
j Mr. Michael Glaser Chairman Atomic Safety and Licensing Board 1150 17th Street,.N.W.
Washington, D.
C.
20036 Dr. Franklin C.
Daiber Department of Biological Sciences University of Delaware Newark, Delaware 19711 l
Dr. M. Stanley Livingston 1005 Calle Largo Santa Fe, New Mexico 87501 i
Atomic Safety and Licensing Board l
Panel j
U. S. Atomic Energy Commission Washington, D. C.
20545 Secretary U.
S. Atomic Energy Commission Washington, D. C.
20545 Attn.:
Chief, Public Proceedings Branch
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.!Or. Joseph Scinto Trial Counsel U. S. Atomic Energy Commission Washington, D.
C. 20545 Mr. Leon Silverstrom Trial Counsel U. S. Atomic-Energy Commission Washington, D. C. 20545 Scenic Shoreline Preservation Conference, Inc.
4623 More Mesa Drive Santa Barbara, California 93105 l
1 Mr. Bruce Sharpe Chern & Sharpe 1
308 North H Street
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Lompoc, California 93436 j
i Mr. Philip W. Marking Henderson, Goodwin, Marking and Horner 3
1033 Santa Barbara Street j
Santa Barbara, California 93101 Y.1
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,s PhiligA.-Crane,Jf.
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A%orney for Pacific Gas and~ Electric. Company Dated:
May 15, 1972
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