ML17083A468
| ML17083A468 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/13/1980 |
| From: | Brown H, Georgiou B, Lanpher L CALIFORNIA, STATE OF, HILL, CHRISTOPHER & PHILLIPS |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| Shared Package | |
| ML17083A469 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8008150364 | |
| Download: ML17083A468 (40) | |
Text
UNITED STATES OF AFRICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APP E
9'n the Matter of PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Nuclear Power Plant, Units 1 and 2)
)
)
)
Docket Nos. 5
)
0-32 O. L.
)
)
)
)
MOTION OF GOVERNOR EDMUND G.
BROWN, JR.
FOR REVISION OF NON-DISCLOSURE AFFIDAVIT AND FOR REVISION OF THE PREHEARING SCHEDULE Governor Edmund G. Brown, Jr. hereby moves this Board to revise the schedule established in the Board's Fourth Prehearing Conference Order
("Order" ), dated August 8,
- 1980, and to modify certain provisions in the non-disclosure affidavit, all as set forth below.
1.
The Board's Order required us to review the security plan and to submit, by August 25, specific issues of concern.
We
- assumed, as apparently did the Board, that PG&E would make its entire security plan available to us.
- However, PG&E has not done so.
We have not been given access to either the safeguards con-tingency plan recuired by Part 73 (particularly Sections 73.40 and 73.55(h)), or to a critical chapter of the security plan.
From our point of view, these are among the most
'mpo tant aspects of PG&E's security system.
Thus, i" is essential that we rev ew them.
0 e
8008160
On August ll, we requested the NRC Staff to provide us access to the contingency plan and Chapter 8.
Staff counsel, who declined our request pending his consultation with PG&E, has not yet given us such access.
Accordingly, since we still have not been per-mitted to review the entire plan, we request an extension of the August 25 filing date on a day-to-day basis; that is, an extension of one "business day" for each business day of delay in providing us the plan.
{We require "business day" extensions because the Staff prefers tnat we view the plan only during the NRC's normal business hours..)
2.
We request that the Board modify certain procedures required by the Board's Protective Order and the Affidavit of Non-Disclosure.
We signed the affidavit in good faith, and on August ll and 12 worked under the prescribed restrictions.
- Now, with the benefit of such actual working experience, we bring to the Board's attention the fact that these restrictions are unworkable.
Aside from the unnecessary inconvenience, it is now clear that being precluded from taking our notes from the NRC's or PGGE's office cripples our efforts to analyze necessary materials, to discuss these materials among co-counsel and our expert witnesses and to develop, draft and review required and anticipated pleadings and testimony.
- Indeed, the restrictions impose burdens on us wh'h are inconsistent with our ethical obligations to represent our client zealously within the bounds of the law.
See Code of Pro-fessional Responsibility, Canon 7 and EC 7-39.
Accordingly, we suggest-several procedural modifications which we urge the Board to adopt.
a.
We request authorization to take our notes from the NRC's or PG&E's offices on the condition that such notes and materials developed from such notes shall be kept in a safe in our office at all times other than when in our personal possession.
The Staff and PG&E may verify the security of our office and safe.
(While we would prefer to have the security plan itself at our office, we are prepared to continue, the inconvenience of reviewing the plan at the NRC or at PG&E. lt is our hope that this provides a mean-ingful basis of compromise tha" will be agreeable to PG&E.)
b.
We request tnat our personal secretaries, each of whom has executed non-disclosure affidavits (the affidavits and resumes are enclosed herewith),
be permitted to type our pleadings and other materials-at our office rather than at the NRC.
This request, of course, naturally flows from our first request to be able to use notes and prepare materials in our offices.
c.
We request. that. our expert consultants/witnesses be permitted to take their notes from PG&E's offices and to keep them in a safe at all times that such materials are not in their per-sonal possession.
This is essential if these witnesses are to confer with us and to prepare testimony for this proceeding.
The NRC and PG&E may verify the security arrangements for each witness.
3.
We request the Board to fix, after conferring with all participants at a prehearing conference, the necessary schedule to allow'prehearing discovery.
From our review of the por'-'on of PG&E' plan already available to us, it has become clear that additional information will be required in order to assess the
adequacy of PG&E's plan.
These data, particularly PG&E's pro-cedures implementing the plan and analyses underlying certain con-clusions set forth in the plan, can be most expeditiously obtained through discovery, rather than time-consuming subpoenas at the hearing itself.
We are prepared to submit initial discovery requests immediately in an effort to move this proceeding
- forward, but are barred by Section 2.740(b)(l) until this Board first has ruled on contentions and issues.
Accordingly, we ask the Board to permit us immediately to commence discovery.
We have served all parties either by hand delivery or'y Federal Express.
We respectfully request an early ruling on these matters.
Respectfully submitte'd, Herbert H. Brown Lawrence Coe Lanpher HILL~ CHRISTOPHER A~LD PHILLIPS~
P CD 1900 M Street, N.W.
Washington, D.C.
20036 Byron S. Georgiou Deputy Legal Affairs Secretary Attorneys for Governor Edmund,G.
Brown,Jr
h UNITED STAT S
OF ZdlZRICA NUCLEAR REGULATORY CO?QCISSION ATOMIC SA" ETY AND LICENSING APPEAL BOARD In the Matter of PACIFIC GAS AND ELECTRIC COMPANY (Diabl'Canvon Nuclear Power Plant, Units l and 2)
)
)
)
)
Docket Nos.
50-275
)
50-323
)
)
)
~
A'""NDED 3"FIDAVIT OF NON-DISCLOSUR-
, being duly sworn, state:
l.
As used in this Affidavit oz Non-Disclosure(
(a)
Protected information" is (l) any form of the physical security plan zor the licensee's Diablo Canyon Nuclear Power Plant, Units l and 2; or (2) any information ob ained by virtue of these 'pro-ceo'dings.which. xs not othe'reise
'a matter' public rec'ord.and whi'ch: 'deals with.'or'escribes details of the secu'rity plan.
(b)
An authorized pe son" is (l) an employee oz the Nuclear Regulatory Commission entitled to access to protected information; (2) a person who, at the 'vi-tation of tne Atomi'c Safety and Licensing Appeal Board
("Aaoeal Board" )( ha,s executed a coav of this affidavit; or (3)
- a. person e~<<,'ploved bv Pacific Gas and Eleciric
- Company, the licensee, and authorized by it in accordance with Commission regulations to nave access to protected information.
2.
Z shall not disclose protected information to anyone excep an authorized
- person, unless that information has previously been disclosed in the public record of this pro-ceeding.
I will sazeguard protected inzormation in written form (including any portions o
~ transcripts of 'n camera
- hearings, filed testimony or any other documents tha.i contain II such info~iation), so that it remains at all times unde~ the control of an authorized person and is not disclosed to anyone else.
3.
I will not reproduce any protected in ormation by any means without tne Appeal Board's express approval or direction.
So long as l possess protected inzormation, I shall continue to take these precautions un il further order o
tne Appeal Board.
4.
I shall simi arly safeguard and hold i;n confidence any data,
- notes, or copies of protected
'nformation and all other papers which contain any protected information by means oz the following:
(a) my use of the protected information will be made a
a facial 'ty in San.=rancisco to be mace ava'lable by=acific
Gas and Elect
~c Company.
(b) l w'll keep and safeguard all such material in a safe to be obta.ined by intervenors at, Pacific Gas ana Electr ic Company '
- expense, after consultation wiih abaci~'c Gas and Electric Company and to be located ai all times at the above designated locat'on.
(c)
An'y secretarial work perzormed at my reauest or under mv supervision will be pe formed at the above location bv one secretary oz my designation.
shall furnish Pacific Gas and Electric Company, the Board and Staff an appropriate resume of tne secretary's background and experience.
ent will (d)
Necessary typing and reoroauctzon ecruipment w'e furnished by Pac'fic Gas and Electr'c Company.
(e)
All mailings by me involving protected xnformatz.on shall be made from the facility furnished by Pacxsxc Gas and Electric Co.
5 Z=
Z preoare savers containing protectec.
z.nzormat~on z
in orde to participate in further proceeaxngs
~n this case, Z will assure that any secretary or othez individual who must receive protecied in=ormation 'n order to help me prepa e those
~
~
oapers has executed an azfidavit like tnxs one and nas agreea p
C to abide by its terms.
Copies o~ any such az fidav' will be 1 ed witn tne 9 'speal Board before Z -eveal any protecte
'nfo=mation io any sucn p>~son.
0
6.
shall use protected inzormation or. y zor -'he purpose of oreparation for'his oroceeaing or any urtner proceeaings in this case aealing with security plan 'ssues, and for no other purpose.
7.
Z shall keep a record oz all protected information in my possession, including any cooies of that information made by or for me.
At the conclusion of this proceeding, I shall account to the Appeal Board or to a Commission employee desig-nated bv that Boa d =or all the papers or otne materials containing protected.
inzormation in my oossession and delive tnem as provided herein.
Rien l have finishea using the pro-tected in ormaiion they contain, bu in no event later than the conclusion of this proceeding, l shall deliver those paoers and materials to the Appeal Board (or to a Commission employee aesignated by, the Board), togethe-with all notes and data which contain protected information for sazekeeping during the lifetime oz the plant.
8.
Z make this agreement with the following understandings:
(a) I ao not waive any objections that any otner person may have to executing an affiaavit such as this one; (b) I will not corroborate the accuracv or inaccuracy of informatior obtained outsiae this proceeaing hy. using protected th ougn the, hearing process.
information aained <
7 Suiscr" bed anc sw rn,to before me is j-'+aav of,liSO.
l N~ 0ic.rv P UDl2. c gZ Co~en Zr"i[os "robnxc~
14, 19SS
GEORGI<NA S.
THURiLVB POSITION DESIRED:
Speed:
Secretary or Administrative Assistant Shorthand 80 wpm; Typing 80 wpm ADDRESS:
1672 Chimney House Road Reston, Virginia 22090 TELEPHONE:
CIVIL STATUS:
H>4LTH:
CITIZENSHIP:
(703) 437-8205
- Married, 2 grown children Excellent U.S.A.
POREIGN LANGUAGE:
- Spanisn, Excellent written
& spoken; Excellent Engl'sh language skills EDUCATION:
Sept.
1929
June 1935 (Skipped 2 yrs.)
St.
Thomas Aquinas School San Juan, Puerto Rico Sept.
1935
June 1939 Central High School San Juan, Puerto Rico Sep t.
1939
June 1941 Ramirez Business College San Juan, Puerto Rico EXPERIENCE:
June 1941
Feb.
1944 United States bar Department Puerto Rico District San Juan, Puerto Rico
Title:
Assistant
- Head, Correspondence, Mail & Records Section Irmediate Supervisor:
B. J.
Jane Duties
& Responsibilities:
Assisted Head of Section in supervising the work of 35 employees engaged in handling of incoming and outgoing mail, including classifying and inoexing the correspondence; preparation of mail,concerning correspondence procedure; assisting in supervising the messenger service; assisting in supervising the file section.
The Correspondence, Mail & Records Section served a central office of over 600 persons.
Reason for leaving:
To move to the U.
S.
Feb.
1944
F'eb.
1947 Consulate General of Colombia 444 Madison Avenue New York, N. Y. 10022 Sec eta
> to tne Consul Gen<era
~
and to two Auxiliary Con-u s 0=sera'
r
Immediate Supervisor Simon Arboleda Bernardo Santa Coloma Eduardo Anjel Duties
& Responsibilities:
Composed letters in Engl'sh and in Spanish for the Consul's signature.
Received visitors to the Consul's office.
Received purchase orders from the various ministries in Colombia, translated
- them, selected tne names of manufacturers in the U.
S.
from the Thomas
- Guide, requested bids, placed orders, and wrote letters as required to 'the manufac-turers and to the ministries in Colombia regarding these orders.
In order that the degree of my responsibility may be appreciated, it i-pointed out that the men whom I served lacked a working knowledge of the English language and so the responsibility for dealing and corresponding with U.
S. manufac-turers rested solely with me.
R ason for leaving:,
To go to Greece under contract with the U.
S. Department of the Army.
Harch 1947
July 1949 American Hission for Aid to Greece U.
S. Department of the Army
- Athens, Greece T'ie:
Secretary to Head, Personnel Division Immediate Supervisor:
Jack Blzsor Duties
& Responsibilities:
Took dictation of and transcribed letters, memos and endorsenents to the Head of Hission,
'Washington, and to other districts; assisted my supervisor in the classification of positions for American personnel and in obtain'ng job descriptions for Greek employees where appoint-ments, tr nsfers or promotions were concerned.
Reason for leaving:
Completion of contract Aug.
1949
Aug. 1951 Standard Oil Company (N. J.)
30 Rockefeller Plaza New York, N. Y. 10022
Title:
Secretary to the Assistant
'Hanager, Publ'c Relations Department Immediate Supervisor:
Hilliam B. B"own Duties
& Responsibilities:
Took dictation, typed letters and memos.
Composed some of the corresponde'nce for Assistant Hanager's signature.
Translated ne:spaper articles in Spanish from Latin American af"iliate puo ications into Eng'ish, and articles in English from the parent co. pany house organ, into Spa..ish, fo" publ'cat on in Latin American affil'te publications, Actec as interpreter and hostess when representatives rom gratin American a fil'ate o fices v'sited the parent company in New York.
R son'for leavin~:
To go to.'morocco under con-=act with the U.
S. Department ox me Ar=y.
Sep t.
1951
Feb.
1953 Army Corps of Engin rs U.
S. Department of the Army Nouasseur Air Force
- Base,
!forocco
Title:
Secretary to Head, Personnel Division Immediate Supervisor:
Bernadine H. Wilson Duties
& Responsibil'ties:
Took dictation, typed letters, me. os and endorsements; composed some of the correspondence for Head o-Division's signature; reviewed job applications and interviewed "local hire" Pmerican and French personnel for possible employment; traveled to Par'is with Assistant
- Head, Personnel Division to interview applicants and to hire more than 100 of them for work in Horocco in professional and non-professional capacities; reviewed U.
S.
Government job description sheets.
Reason for leaving:
To have my first child, having married in 1952.
1953 1964 Upon return to the U.S. in 1953, I dedicated myself primarily to child rearing, homemaking, Scout and churcn activities.
In addition, I managed all family business affairs and acted as my husband's secretary at home.
He is an architect and during tnose years used to "moonlight" regularly.
I typed all his specifications, letters and contracts.
1964 1965 Sutton Researcn Cor~:oration Santa Monica, California
Title:
Secretary to the President l
Immediate Supervisor:
Theodore;Briskin, President Duties
& Responsib lit'es:
On this job I was entrusted with the running of a snail office that served a chemical laboratory engaged essent ally in the pro-duction of a non-carcinogenic cigarette.
I wrote lette s for the President's signature; reviewed invoices and checked them against receipt o
materials and supplies; wrote cnecks or the President's signature; did the weekly payroll; prepared quarterly ta.. reports to the U.
S.
Governmen
- took dictation of President's personal correspondence and paid his bills.
Reason for leaving:
To join my husoand in Hawaii 1966.
Did not work
4 ~
1967
~-
Philco-Ford Corpora~ion'esearch
& Development Program Bangkok, Thailand
Title:
1)
Secretary to Program Director, then promoted to 2)
- Head, Typing/Messenger Pool Immediate Supervisors:
Dr. Wilfred J.
Smith Paul J.
Maynard Duties
& Responsibilities:
As Secretary to the Program Director I composed letters for his signature; took dictation of and transcribed letters and montnly reports to the Home Office; kept files; was recording secretary at staff meetings and conferences.
As Head of the Typing/Messenger Pool I allotted and supervised the work of six to eignt American and Thai typists and of three to four messengers.
Reason fo" leaving:
To join my husband in Iran 1969 Traveled abroad, returned to the States, did not. work.
1970 1971 Michael S. Horwatt, Attorney at Law Reston International Center Reston, Virginia 22090
Title:
Secretary Immediate Supervisor:
Michael S. Horwatt Duties
& Responsibilities:
As my children were still in school, I worked only part time ror Michae S. Horwatt, wno was then just starting his law practice.
As his business grew and he acquired more partners, he required the services of= a full time secretary and, after trying it for a while, I decided I did not want to continue working full time, so in 1971 I resigned.
Reason for leav'ng:
Was not willing to work full time at the time and wished to open my own secretarial business at home.
1971 1977
Title:
Ezecutive Secretary Self-employed, at home (off and on)
Du 'es
& Responsibilit es:
Typing o" speci ications, reports, proposals, lette s, etc., for architects",
engine rs, consultants, attorneys, h'storians, etc.
November 1977 to Present Hill, Christopher and Phillips, P.
C.
1900 2 Street, N. V.
Washington, D.
C.
20036
Title:
Secretary Immediate Supervisor:
Herbert H.
Brown Duties 6 Responsibilities:
General secretarial duties.
REFERENCES:
Kurt N. Pronske Civil Engineer 1414 Aldennam Lane
- Reston, Va.
22090 437-3606 Dexter NacBride Executive Vice President American Society of Appraiser.
11800 Sunrise Valley Dr.
Reston International Center
- Reston, Va.
22070 620-3838 Jack Williamson Architect/
Planner 1274 Kay Drive E.
Cherry Hill, N. J.
08034 (609) 795-1388
UNZTED STATES 0 A~L"RZCA NUCLEAR H"GULATORY COMYiZSSZON ATQMZC SAFETY AND LZCENSZNG APPEAL BOME Zn the Matter of PACZPZC GAS AND ELECTRZC COMPANY
'(Diablo Canyon Nuclear Power Plant, Units 1 and 2)
)
)
)
)
Docket Nos.
50-275
)
50-323
)
)
)
~
ZI P~NDED P>PZDAVZT OP NON-DZSCLOSURE I
j
/j
/
.l ('~;,Ljc.I /7!:~/
,hein.g auly swo-n, state:
l.
As used in this Affidavit o Non-Disclosure, (a)
"Protected inzormation" is (1) any form of the
.physical security plan for the licensee's Diablo Canyon Nuclear Power Plant, Units 1 and 2; or (2) any information obtained by vir. ue of these pro-cd'dingus which 's not otM'rw"se a matte-'f public 1 1 rec'ord.and whi'ch dea'ls with'or'escribes details of ihe secu'riiy. pla.n.
(b)
An "authorized pezson" is (1) an employee oz he Nuclear Regulatory Commission entitled to.access to protected information; (2) a pe son who, at -'he invi-ta. ion oz he Atomic Sa, ety and Licensing Appeal Board
("Appeal Board" ), has executed a copy of this aff'dav'i; or (3)
- a. person, emoloved by Pacific Gas and lec-'ric
r>>
- Comoany, tne licensee, ana authorized by '" in accoraance with Commission regulations to have access to protected information.
2.
I shall not disclose protected
'nzormation to anyone except an authorizea
- person, unless that inzormation has previouslv been disclosed in the public record of this oro-ceeaing.
I will sazeguard protectea
'nformation in wri ten zorm (incluainc anv oortions of transcripts of in camera hearings, filed testimony or any other aocuments ha" con a:in such information),
so that it remains at all times unae the control of ar. author'ea pe son and is not. disclosed to anyone else.
3.
I will not reproduce any protected infor<<mation by any means w'thout the Appeal Board's express aporoval or airection.
So long as I possess protected information, I shall continue to take these precautions until further oraer of the Appeal Board.
4.
I shall similarly safeguard and hold in confidence any data,
- notes, or copies of orotec ed information and all other papers whicn contain any protectea information by, means of the followinc:
(a) mv use of the orotected 'nformation will be made a fac zl:tv ~~l Sa 1 "ranchsco co 5e maae ava J.22 J.
Dv ac-'z c
$;" 1 Gas and Electric Company.
(b)
Z will keeo and safeguard all such material in a,
~
~
safe to be obtained by intervenors at Paczzxc Gas and Elect ric Company '
- expense, afier consultation with Pacizic Gas and Electric Company and to be located at all iimes at the above designated location.
(c)
Anv secretarial work pe zozmed at my recruest o-under my sup rv pervision w'll be perzormed at the above location by one secretary of my designation.
I shall furnish Pacific Gas and Electric Company, c ~he the Board and Staff an appropriate esume o~
he secretary's background and experience.
(d)
Necessary typ'ng and reproduction ecru~pment we'll be zurnished by Pacific Gas and Electric Company.
~
~
(e)
A3.3. mailings by me involving protected xnzormat~on
~ g
~
shall be made from the facility furnished by Pacx.
zc Gas and Electzic Co.
5.
Zf Z prepare papers containing protects.
~ nzozma~xon in order to pariic'p'pate in =u~ther proceedings in a~s
- case, I will assure tnai a y any secre-'ary or other individual wno must receive protected information in order to help me prepa"e those p
savers nas executed an affidavit like th~s one ana nas agre
~1 to aoice hy its i La h 'e r s Cop~es o
anv such a
'dam w
1
"~ ~ ed 'e
-seal Board he. ore Z reveal anv arotec
'nfo mation io any suer p~=son.
J A
t 6.
I snail use protectea information only for the purpose of preparation for tnis proceeaing or any further proceedings in this case dealing wiih security plan issues, and for no o"her purpose.
7.
I shall keep a record of all protected information in my possession, incluaing any copies of Rat information made by or for me.
At the conclusion oz this proceeaing, I shall account to the Appeal Board or to a Commission employee desig-na ed bv ihat Boara =or all tho papers or other materials containing protec ed in ormation in my possession and aeliver them as proviaed herein.
Rien I have finishea using the pro-tected in ormation they contain, but in no even" later than the conclusion o
this proceeding, I shall deliver Dose papers ana materials to the Appeal Boara (or to a Commission employee designated by the Board), together with all notes ana aata which coniain proiected informaiion for sazekeeping during the lifetime o tne plant.
8.
I make tnis agreement with the following unaerstandings:
(a) I ao not waive any objections'hat any other person may have to executing an affidavit such as th's one; (b) I will not corroborate the accuracy or inaccuracy oz inzormation obtainea ou"siae this proceeding hy using protected information gained through the hearinc process.
s j/
g /
S~~"'scribed and his
/3+-'.ay o
sworn to before me
-" ~c:c C
.19-80
~~
J/
L.c.
t~otarv 'cubi i c RZ Co~Le" ~=i:es ~ebmc;g 14, l985
~
II
4 E
1
~ a Ci PAUL'"TTE 1!r"lILTQN 693 Arlington Drive, =,'20~
Alexandria, Virginia 223M 703-765-5270 EDUCATION:
Henderson Institute Henderson, North Carolina 27536 Graduated June 1967 North Carolina Agricultural
& Technical Univers'ty Greensboro, North Carolina 27411 Graduated June 1971-B.S. Office Administration Hunter College New York City, New York 1973 to 1974 masters program in business education Ei~lP LOYiiCNT HISTORY:
Painzer Minion Co., Inc.
437 Fifth Avenue New Yo k, New York Administrative Secretary 1971 to 1975 Superior Career Institute 116 Nest 14th Street New York City, New York Administrative Assistant 1975 to 1979 Hill, Cnristopher
& Phillips, PIC.
1900 M Street, N.N.
Nasnington, D.C.
20036 Legal Secretary Presently employed with this law CL"RICAL SKILLS:
-Typing Speed 85/90
-Shortnand Speed 90/100
-Experienced in Litigation
-Interviewing of clerical applicants for jobs
-Dictaphone skills
-Able to do own correspondence
'-Some bookkeeping skills Energy law and crim'nal law PERSONAL R" "
RENCES CAN B SUBHITT>D UPON YOUR REQUEST.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD Zn the Matter of PACIFIC GAS AND ELECTRIC COMPANY (Diablo Canyon Nuclear Power Plant, Units 1 and 2)
)
)
)
)
Docket Nos.
50-275 O.L.
)
50-323 O.L.
)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the MOTION OF GOVERNOR EDMUND G.
BROWN, JR.
FOR REVISION OF NON-DISCLOSURE AFFIDAVIT AND FOR REVISION OF THE PREHEARING SCHEDULE" in the above-captioned proceeding have been served on the following in the manner and on the date indicated below.
Richard S.
- Salzman, Esq.,
Chairman Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Dr.
W. Reed Johnson Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington,
.D. C.
20555 Mr. Thomas S. Moore, Member
- Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C.
20555 William J. Olmstead, Fsq.
Executive Legal Director's Office Nuclear Regulatory Commission Washington, D.
C.. 20555 Andrew Baldwin, Esq. **
601 California Street Suite 2100 San Franci.'sco, CA 94108 Harry M. Willis **
601 California Street, Suite 2100 San Francisco, CA 94108
2.
Herbert H. Brown Lawrence Coe Lanpher HILL, CHRISTOPHER AND PHILLIPS, P.
C.
1900 N Street, N.
W.
Washington, D. C.
20035 August 13, 1980 By hand on August 13, 1980 By Federal Evpress on August 13, 1980