ML20045G943

Intervenor San Luis Obispo Mothers for Peace (Slomfp) Response to Prehearing Conference Order Re INPO Documents.* Slomfp Cannot Provide Info by Affidavit Due to Lack of Info Re Content of INPO Documents.W/Certificate of Svc

ML20045G943
Person / Time
Site:	Diablo Canyon
Issue date:	07/01/1993
From:	Culver N SAN LUIS OBISPO MOTHERS FOR PEACE
To:	Atomic Safety and Licensing Board Panel
References
CON-#393-14088 92-669-03-OLA-2, 92-669-3-OLA-2, OLA-2, NUDOCS 9307160172
Download: ML20045G943 (3)

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i UNITED STATES OF AMERICA i

NUCLEAR REGULATORY COMMISS@hNdl ~6 F5 Ub i

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ATOMIC SAFETY AND LICENSING BOARD i

j In the Hotter of Pacific Gas and Electric Ccmpany Docket Nos. 50-27S-OLA-2 Diablo Congon Nuclear Power Plant S0-323-OLA-2 Units 1 and 2 ASLEP No. 92-669-03-OLA-2 l

Facility Opercting Licenses No. OPR-80 and DPR-82 July 1,

1993 4

4 Intervenor San Luis Obispo Mothers for Peace i

Response to Preheoring Conference Order l

Re: INPO Documents 1

n its Second Set of Written Interrogatories and Requests for the j

Production of Documents to Pacific Gas and Electric Company C"PG&E"] filed 1

March 8, 1993, Son Luis Obispo Mothers for Peace C"SLONFP"] requested that t

i reports prepared by the Institute for Nuclear Power Operations

(" INFO"]

regarding fire protection and/or maintenance and surveillance programs be q

provided CInterrogatories 12 and 13].

PG&E objected to these requests cs overbroad and as seeking information that is privileged and subject to non-l

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disc 1csure.

During the Prehearing Conference that took place on May 11 and l

12, 1993, SLOHFP narrowed its request to INPO information that is relevant I

only to the evoluotion of the maintenance and surveillance programs at i

j Diablo Canyon Nuclear Power Plant ("DCNPP"].

In its Preheoring Conference 1

Order (June 17, 1993], the Atomic Safety and Licensing Board invited the I

parties to submit responses to information contempleted by 10 CFR l

1 2.790Cb][93-CG).

The SLONFP hereby responds.

SLOMFP understands that there are very few independent and contemporaneous ossessments of nuclear power plant operation.

INPO is one 1

4 such source.

INPO is on important source of information because it is t

independent of PG&E ond the NRC.

It is not " curiosity" that motivates the gp3 1

o

p

SLOMFP to request the opportunity to examine these documents.

SLONFP believes that reports prepared by INFO will contain frank evoluotions of the effectiveness of the maintenance and surveillance programs at DCNPP.

These evoluotions have the potential to provide useful insights and may prove beneficio1 to the hearing process.

SLOMFP does not believe that the evoluotions made by INPO is ovcilable in public sources.

SLOMFP asserts that there should be no secrets on matters relating to the public safety; it is the right of the public to be allowed to become fully informed.

Additianolly, SLOMFP con find no rational basis for withholding any information.

SLOMFP cannot foresee any substantial harm or expense that could come to any party due to disclosure of the INPO evoluotions.

SLOMFP hos made o reasonable and oppropriate request in seeking INPO documents relating to maintenance and surveillance programs at DCNPP.

It is clearly relevant to Contention I and the SLOMFP should be allowed access to this information, i

SLOMFP cannot provide information by offidavit because it has no i

information regarding the content of INPO documents.

Respectfully Submitted, kk A} DIN /

Noncy Cu ser, President Son Luis Obispo Mothers for Peace P.O.

Box 169 Pismo Beach, CA S3998

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4 hr.

Certificate of Service 93 J1 -6 ? ~ vJ I hereby certify that copies cf the foregoing Intervenor San Luis Obispo Mothers for Peace Motion to Compel Pacific Gas.ond Electric. Company to Respond to the Third Set of Supplemental Interrogatories and Requests for the Production of Documents Filed by Son Luis Obispo Nothers for Peace and V

Intervenor San Luis Obispo Mothers for Peace Response to Prehearing Conference Order Re: INPO Documents have been served upcn the following perscns by U.S.

mail, first class.

Office of Commission Appellate Administrative Judge Adjudicotton Charles Bechhoefer, Chairman U.S.

Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, DC 20555 U.S.

Nuclear Regulatory Commission Washington, DC 20555 Administrative Judge Jerry Kline Administrative Judge Atomic Safety and Licensing Ecord Frederick J.

Shen U.S.

Nuclear Regulatory Commission Atomic Safety cnd Licensing Board Washington, DC 20555 U.S.

Nuclear Regulatory Commission Washington, DC 2C555 Edward O'Neill Ann P.

Hodgdon, Esq.

Peter Arth, Jr.

Office of the General Counsel Truman Burns j

U.S. Nuclear Regulatory Commission Robert Kinosion Washington, DC 20555 Peter G.

Fairchild, Esq.

California Public Utilities Commission Joseph B.

Knotts, Jr.,

Esq.

505 Von Ness Avenue Winston & Strown Son Francisco, CA 99102 1900 L Street, N.W.

Washington, DC 20005 Adjudicatory File Secretary of the Commission U.S. Nuclear Regulatory Commission Docketing and Service Branch Washington, DC 20555 U.S.

Nuclear Regulatory Commission

[2 copies]

Washington, DC 20555 C2 copies and originc1]

Robert R. Wellington, Esq.

Diablo Congon Independent Safety Committee 857 Cass Street, Suite D Honterey, CA 93940 Christopher Warner, Esq.

Richard Locke, Esq.

Pacific Gas and Electric Co.

77 Beale Street Son Francisco, CA 99106

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i Dated July 1, 1993, Son Luis Obispo County, CA 9~9-y

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