ML20236L724
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i UNITED STATES OF AMERICA ATOMIC ENF.RGY COMMISSION 1
In the Matter of
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PACIPIC GAS & ELECTRIC COMPANY
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Docket No. 50-32, j
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l (Diablo Canyon Unit 2)
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l MOTION FOR REOPENING O? HEAT 1ING TO PLACS DATA IN THE RECORD OF l
THE DIABLO P30CEEDINGS (1)
In "AEC Regulatory Staff Reply to ' Supplemental Statement by i
Ralph Vrana Concernin6 Testimony of the August 7,1970 Hearing Before the AEC Board in San Luis Obispo, California and 'neply 8
to the September 4,1970 Statement of Mr. Philip Crane, of PG&E by Ralph Vrana,'" Staff Counsel asserts that
" Conference's 'Supplemen-tal statement,' ' Exhibits' and ' Reply' are clearly in the nature of proffered testimony which should not be included as part of the evidentiary record in this proceeding since the evidentiary record has been closed.
If construed as a motion to reopen the record, the AEC regulatory staff (staff) believes that the motion should be 4
denied since the Conference had an adequate opportunity at the l
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reopened hearing to present its case on the matters in issue."
(2)
Conference participated in the reopened hearing under protest I
on grounds partly that adequate opportunity was not afforded for preparation of Jts testimony.
In view of comments by staff above and the necescity of a compete record as the basis for a wise decision affecting the public health, safety, and welfare, Conference
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applies in this motion for a reopened hearing to place these documents in the record and provide the opportunity for cross-examination of witnesses on the subjects raised in these documents.
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This action is proposed only if a reopened hearing is legally
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necessary to place this and subsequent material (See 3 below) on record so that the data are available for review by the Board.
8708100338 070729 PDR FOIA CONNOR87-214 PDR
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Also to be covered by this motion are any drrca in Sc:nic Shoreline's submission of September 16 1970 encloced 1:it'. i^ i s motion.
(4)
Dr. Jahns has mentioned in his i;estitiony and Pacific repeats (Supplemental Proposed Findings of fact and Conclusions of Law l
Submitted by Pacific Gas and Electric Company, September 4,1970, p.6) that " detailed reconnaissance of the entire area was made."
The term " detailed reconnaissance" seems self-contradictory.
In j
any case, Scenic Shoreline has already requested these studies I
and maps and would like nou to repeat this reque.st, These maps should be publicly available as a basis of cross-examination at a reopened hearing.
We requst that your Board require Pacific to l
1 produce these documents.
(5)
Scert Shoreline wishes it to be understood that the request for a reopened hearing on this restr'cted subject area above should not be interpreted as a waiver of our standing request for a full i
hearing on the various issues we listed at the lose Board hearing, We wish to reinstate our request for a hearing on those issues as well.
D MuAr cot
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}rederick Eissler President Scenic Shoreline Preservation Conference, Inc.
Dated at Santa Barbara, California this 16 day of October, 1970
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