ML110450622: Difference between revisions

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{{#Wiki_filter:UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD  In the matter of        Pacific Gas and Electric Company  Docket Nos. 50-275-LR Diablo Canyon Nuclear Power Plant            50-323-LR
Units 1 and 2 SAN LUIS OBISPO MOTHERS FOR PEACE'S COMMENTS REGARDING PLANNED PROTECTIVE ORDER    Pursuant to the Atomic Safety and Licensing Board's ("ASLB's") Notice of Planned Protective Order (February 3, 2011), San Luis Obispo Mothers for Peace
("SLOMFP") hereby comments on the protective order and non-disclosure agreement that were attached to the Notice. SLOMFP proposes only one change to the protective order circulated by the ASLB:  to add the contents of paragraph T of the proposed protective order that the parties submitted on November 9, 2010:  "Nothing in this protective order shall prevent any party from seeking public disclosure of information designated as Protected Information, in accordance with NRC regulatory procedures or other applicable law."  That language would clarify that SLOMFP is permitted to seek Protected Information by submitting a Freedom of Information Act request under 10 C.F.R. Part 9, in addition to seeking it through discovery in other proceedings as provided
in paragraph Z of the ASLB's planned protective order.
In all other respects, SLOMFP believes that the planned protective order and nondisclosure agreement issued by the ASLB are comprehensive and fully protective of all parties' interests in this proceeding.
Respectfully submitted, Electronically signed by Diane Curran Harmon, Curran, Spielberg, & Eisenberg, L.L.P.
1726 M Street N.W., Suite 600
Washington, D.C. 20036
202/328-3500
FAX 202/328-6918 dcurran@harmoncurran.com February 14, 2010 CERTIFICATE OF SERVICE I certify that on February 14, 2011, I posted San Luis Obispo Mothers for Peace's Comments Regarding Planned Protective Order on the NRC's Electronic Information Exchange. It is my understanding that as a result, the following persons were served:
Office of the Secretary Rules and Adjudications Branch
U.S. Nuclear Regulatory Commission
11555 Rockville Pike
Rockville, MD  20852
hearingdocket@nrc.gov David A. Repka, Esq.
Tyson R. Smith, Esq.
Winston & Strawn, LLP 1700 K Street N.W.
Washington, D.C. 20006-3817
drepka@winston.com
,trsmith@winston.com Susan Uttal, Esq.
Lloyd Subin, Esq.
Office of General Counsel
Mail Stop O-15D21
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555
Susan.Uttal@nrc.gov Lloyd.Subin@nrc.gov E. Roy Hawkens Chief Administrative Judge Atomic Safety and Licensing Board
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555 Roy.Hawkens@nrc.govElectronically signed by Diane Curran}}

Revision as of 08:18, 14 August 2018

San Luis Obispo Mothers for Peace'S Comments Regarding Planned Protective Order
ML110450622
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 02/14/2011
From: Curran D
Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP, San Luis Obispo Mothers for Peace
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
50-275-LR, 50-323-LR, ASLBP 10-900-01-LR-BD01, RAS 19582
Download: ML110450622 (3)
v • d • e


Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of Pacific Gas and Electric Company Docket Nos. 50-275-LR Diablo Canyon Nuclear Power Plant 50-323-LR

Units 1 and 2 SAN LUIS OBISPO MOTHERS FOR PEACE'S COMMENTS REGARDING PLANNED PROTECTIVE ORDER Pursuant to the Atomic Safety and Licensing Board's ("ASLB's") Notice of Planned Protective Order (February 3, 2011), San Luis Obispo Mothers for Peace

("SLOMFP") hereby comments on the protective order and non-disclosure agreement that were attached to the Notice. SLOMFP proposes only one change to the protective order circulated by the ASLB: to add the contents of paragraph T of the proposed protective order that the parties submitted on November 9, 2010: "Nothing in this protective order shall prevent any party from seeking public disclosure of information designated as Protected Information, in accordance with NRC regulatory procedures or other applicable law." That language would clarify that SLOMFP is permitted to seek Protected Information by submitting a Freedom of Information Act request under 10 C.F.R. Part 9, in addition to seeking it through discovery in other proceedings as provided

in paragraph Z of the ASLB's planned protective order.

In all other respects, SLOMFP believes that the planned protective order and nondisclosure agreement issued by the ASLB are comprehensive and fully protective of all parties' interests in this proceeding.

Respectfully submitted, Electronically signed by Diane Curran Harmon, Curran, Spielberg, & Eisenberg, L.L.P.

1726 M Street N.W., Suite 600

Washington, D.C. 20036

202/328-3500

FAX 202/328-6918 dcurran@harmoncurran.com February 14, 2010 CERTIFICATE OF SERVICE I certify that on February 14, 2011, I posted San Luis Obispo Mothers for Peace's Comments Regarding Planned Protective Order on the NRC's Electronic Information Exchange. It is my understanding that as a result, the following persons were served:

Office of the Secretary Rules and Adjudications Branch

U.S. Nuclear Regulatory Commission

11555 Rockville Pike

Rockville, MD 20852

hearingdocket@nrc.gov David A. Repka, Esq.

Tyson R. Smith, Esq.

Winston & Strawn, LLP 1700 K Street N.W.

Washington, D.C. 20006-3817

drepka@winston.com

,trsmith@winston.com Susan Uttal, Esq.

Lloyd Subin, Esq.

Office of General Counsel

Mail Stop O-15D21

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555

Susan.Uttal@nrc.gov Lloyd.Subin@nrc.gov E. Roy Hawkens Chief Administrative Judge Atomic Safety and Licensing Board

U.S. Nuclear Regulatory Commission

Washington, D.C. 20555 Roy.Hawkens@nrc.govElectronically signed by Diane Curran

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