ML20005C135
| ML20005C135 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 11/16/1981 |
| From: | Johnson G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | JOINT INTERVENORS - DIABLO CANYON |
| References | |
| ISSUANCES-OL, NUDOCS 8111180440 | |
| Download: ML20005C135 (22) | |
Text
-
O 11/16/81 e
UNITED STATES 0/ AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY Ar,D LICENSING BOARD In the Matter of gg
'CIFIC GAS AND ELECTRIC COMPANY Docket Nos. 50-275
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50-32 (Diablo Canyon Nuclear Power Flant Full Power Proce
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NRC STAFF RESPONSE TO JOINT INTERVEN0RS' THIRD SET OF IN* ERR 0 GAT 0 RIES AND REQUEST 6
FOR PRODU", TION OF DOCUMENTS CuC~@ \\ '
The interrogatories presentec to the Staff by Joint Intervenors quested that each interrogatory be enswered in 4 parts. The Staff has labeled the responses A through D, corresponding to Joint Intervenors' 4
request. The Staff objects to Part D(2) of the interrogatories. Any summary of the witnesses' testimony would be privileged as trial preparatory material. See Kansas Gas and Electric Co. (Wolf Creek Nuclear Generating Station, Unit 1), ALAB-327, 3 NRC 408 (1976).
Further, since at present no such summaries exist, requiring the Staff to compile data and create l
such a summary is objectionable.
See 4A Moore's Federal Practice, $33.20(3).
Therefore, throughout this document Part (2) of Subpart D will not be answered. The Staff further notes that Joint Intervenors will have a complete copy of all Staff testimony prior to any hearing.
The responses of the Staff are set forth below.
INTERR0GATORY 6 For each of the components, systems, or facilities listed below, state Dgg7 3
whether you contend that it has been seismically qualified to withstand and continue to function in the event of a 7.5 magnitude earthquake on the r
Hosgri Fault, and state each and every fact upon which your response is hbft k!
O!bb0 DESIGNATED ORIGINAL 5
Cert 191M Byh'& _
based.
Include in your response a description of all qualification tests performed, the da.e of such tests, the persons or entities con-ducting the tests, and any modifications to the component, system, or facility tested which were made as a result of such testing.
(a)
Early Warning System sirens (and related compressors and compressor platforms) located within the Diablo Canyon plume exposure pathway EPZ; (b)
PGandE telecommunications equipment racks, battery racks, antennae, and supports; (c) mountaintop PGandE Private Microwave System repeaters; (d) mountaintop UHF and VHF Radio System repeaters located at Davis Peak. Tepusquet Peak, and Tassajera Peak; (e)
Emergency Broadcast System radio transmission towers; (f)
Early Warning System transmitters (located at Davis Peak, l
Rocky Butte, Cuesta Peak, Morro Bay, San Luis Obispo, and Pismo Beach) and encoders (located at 'he San Luis Sheriff's Office and the California Department of Forestry);
i (g) offsite Emergency Operations Facility and associated cables, wiring, and equipment; l
(h)
San Luis Obispo County Emergency Operitions Center and associa-ted cables, wiring, and equipment; (1) onsite Technical Support Center and associated cables, wiring and equipment; (j) radiological monitoring stations; (k) PGandE onsite meteorological tower and associated cables, wiring, i
and equipment; (1) UDAC and associated cables, wiring, and equipment.
Response
j A.
The NRC Staff is not aware of qualification tests to demonstrate the seismic qualification of items a through 1.
The onsite Technical i
Support Center, item 1, has been designed to seismic Class I criteria.
B.
See Applicant's Emergency Plan, Rev. 3, Para. 7.1.4.1.
C.
The Sta'f and/or independent contractor are not presently engaged in or intend to engage in further research or work which may bear on the issues covered in the interrogatory other than the normal Staff review.
l D.
(1) John R. Sears and Dean Kunihiro are the experts whom the Staff intends to have testify on the subject matter covered in the interrogatory.
Copies of their professional qualifications are in attachments A and B respectively.
(2) See paragraph prior to Interrogatory 69.
(3) John R. Sears has testified:
(a) on emergency planning security in Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2), Docket Nos.
50-275, 50-323; (b) on emergency planning and security in Southern California Edison Company (San Onofre, Units 2 and 3), Docket Nos. 50-361, 50-360 OL; (c) on emergency planning in a proceeding culminating in l
Commonwealth Edison Company (Zion Station, Units 1 and 2), LBP-80-7,11 I
NRC 245 (1980);
(d) on emergency planning in Boston Edison Company (Pilgrim i
Nuclear Generating Station, Unit 2), Docket No. 50-471; (e) on emergency planning in Long Island Lighting Company l
(Jamesport Nuclear Power Station, Units 1 and 2), Docket Nos. 50-516, I
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50-517; and (f) on implementation of plant operations in Yankee Atomic Electric Company (Yankee Nuclear Power Station), Docket No. 50-209.
Dean Kunihiro has testified:
(a) on security matters in Commonwealth Edison Company (Zion Station, Units 1 and 2), Docket Nos. 50-295, 50-304.
INTERROGATORY 70 With respect to each of the components, systems, or facilities listed in Interrogatory No. 69, state whether you contend that s'.ch component, system, or facility need not be seismically qualified to withstand and continue to function in the event of a 7.5 magnitude earthquake on the Hosgri Fault, and state each and every fact upon which your response is based.
Response
A.
NRC does not require items a-1 of Interrogatory 69 to be seismic-ally qualified; e.g., NUREG-0696, Functional Criteria for Emergency Response Facilities, February 1981, states "The TSC (Technical Support Center) need not meet seismic Category I criteria or be qualified as an engineered safety feature (ESF)." Following an earthquake, accident assessment and dose projection would continue to be done at the plant.
Due to the diversity and redundancy of communications systems and equip-ment, the NRC Staff considers it to be highly unlikely that all means of communications would be unavailable at the same time. Radio and TV stations outside the seismically affected z]ne could still broadcast alerting information to the emergency planning zone.
1 5-B.
C.
See response to Interrogatory 69.C.
D.
See response to Interrogato
- 59.D.
INTERROGATORY 71 List each and every agreement and/or contract between PGandE and any third party for the provision by such third party of services, assistance, workers, equipment, and/or vehicles for the repair of damage resulting l
from an earthquake on the Hosgri Fault which accompanies a radiological i
j emergency at Diablo Canyon, and specify precisely:
(a) whether the agreement and/or contract is formal or informal; I
(b) the party or entity committing to provide such services, assistance, workers, equipment, or vehicles; (c) the substance-of such agreement and/or contract; (d) the type and number of services, assistcnce, workers, equipment, or vehicles agreed to be provided;
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(e) whether such agreement and/or contract specifically pro-l l
vides for the provision of such services, assistance, workers, equipment, or vehicles when there is a risk of radiation exposure to such workers, i
equipment, or vehicles; (f) the address of the party or entity committing to provide i
services, assistance, workers, equipment, or vehicles and the location of such equipment or vehicles.
l
Response
A.
This interrogatory assumes " damage resulting from an earthquake on i
the Hosgri fault which accompanies a radiological emergency at Diablo i
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Canyon." The NRC judgment is that an carthquake less than the SSE would result in the reactor shutting down safely, with no radioactive release.
However, there might be a potential for radioactive rclease from non-seismically qualified equipment. Such a release would require minimun protective actions.
The PG&E Emergency Plan lists agreements for assistance during emergencies.
San Luis Obispo County would have available state and Federal resources which do not require formal contracts. Joint Inter-venors have as ready access to the documents as does the Staff. There is no requirement, therefore, that the Staff compile this information to answer this interrogatory.
See 4A Moore's Federal Practice, 5 33.20(3).
B.
None.
C.
See response to Interrogatory 69.C.
D.
See response to Interrogatory 69.D.
INTERROGATORY 72 At section 6 of the TERA Corporation Report entitled " Earthquake Emergency Planning at Diablo Canyon," a number of "special tasks that might have to be performed following a major earthquake and radiological emergency" are identified.
Included among these tasks are:
(a) damage reconnaissance; (b) emergency repair and/or restoration of key transportation routes; (c) clearing debris from key transportation routes; (d) coordination with law enforcement agencies for barricading of certain areas;
(e) procurement and allocation of transportation resources; (f) traffic control; and (g) evaluation and determination of protective actions to be I
t&r by nonessential PGandE employees and by the public.
As to each of these individdal tasks in the event of a 7.5 magnitude earthquake on the Hosgri Fault, state precisely:
(1) how many persons would be needed to perform the specified task; (2) how many PGandE employees would be available to perform the specified task; (3) how many County or State personnel would be available to per-fom the specified task; i
(4) how many other persons would be available to perform the specified i
task; (5) a list of any tr,d all agreements and/or centracts in which specific commitments have been made to supply personnel; i
(6) every fact upon which your responses to subparts (1) through (5) of this interrogatory are based.
Response
i i
A.
As stated in response to Interrogatory 71, the NRC judgment is that i
offsite protective actiors due to a radiological release following an earthquake of 7.5 magnitude on the Hosgri fault would require a minimum response due to radioactivity. Offsite response to an earthquake is the-responsibility of governmental agencies and is described in their earth-quake response plans. To the extent this interrogatory is capable of being answered, such answers may be sought from documents made available by the Applicant, County and Governor Brown in this proceeding. See Response 71. A., above.
B.
'None.
C.
See response to Interrogatory 69.C.
D.
See response to Interrogatory 69.D.
INTERROGATORY 73 State whether you contend that the TERA Corporation Report cited supra satisfies the NRC Staff's December 16, 1980 request that PGandE provide analyses of the complicating effects of eartnquakes on the Diablo Canyon emergency plans, and state each fact upon which your response is based.
Response
A.
Yes.
The report describes the possible complicatir.g effects on communicationt and on transportation.
B.
None.
C.
See response to Interrogatory 69.C.
D.
See response to Interrogatory 69.D.
IdTERR0GATORY 74 Describe in detail the specific changes which will be made in the relevant applicant, state and local emergency plans based on the infor-mation, findings, and recommendations contained in the TERA '
oration Report cited supra.
Response
A.
The Staff judges that no changes are necessary in the Applicant's plans.
Information as to Applicant's response to the report should be sought from Applicant. The TERA report has been transmitted to govern-
me. ital agencies so they can judge whether changes are indicated in their plans.
B.
None.
C.
See response to Interrogatory 69.C.
D.
See response to Interrogatory _69.D.
INTERR0GATORY 75 Do you contend that sheltering will, under certain circumstances, be a preferable protective action alternative to evacuatian? If so, state what those circumstances are and each and every fact upon which your response is based. List each and every study, report, and/or analysis which supports your conclusion.
Response
A.
ies. NUREG-0654, Appendix 1, pages 16 and 17 give specific guidanca for state and local authorities for both shelter and evacua-tion.
Documents which support the NRC Staff conclusion are:
1.
Manua! of Protective Action Guides and Protective Actions for Nuclear Incidents.
U.S. Environmental Protection Agency (EPA-520/1-75-001).
2.
Examination of Offsite Radiological Emergency Measures for Nuclear Reactor Accidents Involving Core Melt. Sandia Laboratory (SAND 78-0454).
3.
Planning Basis for the Development of State and Local Govern-ment Radiological Emergency Response Plans in Support of Light Water Nuclear Power Plants.
NUREG-0396, EPA 520/1-78-016.
U.S. Nuclear Regulatory Commission, U.S. Environmental Protection Agency.
B.
See Response 75.A.
C.
See response to Interrogatory 69.C.
D.
See response to Interrogatory 69.D.
INTERROGATORY 76 State where, if at all, '
the evacuation times assessment prepared for Diablo Canyon and submitted by PGandE the estimates are adjusted for delays likely to result from " spontaneous evacuation" by persons ather than those within a specified evacuation area.
Response
A.
The evacuation times assessment include total evacuation times which cover everyone in the entire area. Consequently, spontaneous evacuation is a part of the total.
B.
None.
C.
See response to Interrogatory 69.C.
D.
See response to Interrogatory 69.D.
INTERR0GATORY 77 On p. 4 of the Staff's response to Joint Intervenors' first set of interrogatories (" Staff Response"), you state that an upgraded meteoro-logical program, an alert system, and a public information-system "are now being implemented." Describe in detail the basis for that statement.
Response
A.
The applicant has installed onsite a back-up meteorological tower.
I The sirens for the early warning system have been installed.
Implementation of the public information program is as follows:
a)
Notification to residents-in the LPZ is canplete.
b)
The booklet on emergency planning is under revision and is now scheduled for distribution within the EPZ in February 1982.
c)
Signs for posting in park areas are awaiting government approval.
c)
The emergency page for the phone book has been submitted for the next edition of the phone book.
B.
None.
C.
See response to Interrogacory 69.C.
D.
See response to Interrogatory 69.D.
INTERROGATORY 78 On p.12 of the Staff Response, you state that the "offsite plans do not specifically address the effect of a major earthquake which occurs simultaneously with a radiological emergency at Diablo Canyon."
(a) State whether you contend that such offsite plans need not consider the complicating factors which might be caused by earthquakes in the developmen, of emergency plans for a nuclear power plant, and, if not, state each and every fact upon which your response is based.
(b) With respect to the San Luis Obispo County plans and the State of California plan, state how such complicating effects are addressed, f
if at all.
Response
A.
a)
NUREG-0654, Para. II.J.10., requires offsite plans to consider a variety of measures -- including several relating to communication and transportation under various conditions. The position of the NRC Staff i
is addressed in the Novenber 3,1981 memorandum from Brian K. Grimes, i
l,-
1 NRR, to John licConnell, FEMA, which has already been provided to all parties.
b)
As stated in response to Interrogatory 74, the TERA report has been submitted to governmental agencies so they can judge whether changes are indicated in their emergency plans as a result of the complicating factors which might be caused by earthquakes. To the extent this i
interrogatory relates to current plans, these are as availab'.e to Joint Intervenors as to Staff.
See Response 71.A.
B.
See Response 78. A., above.
C.
See response to Interrogatory 69.C.
D.
See response to Interrogatory 69.D.
4 INTERROGATORY 79 On p.13 of the Staff Response, you state that "this [ communications]
equipment is considered to be adequate for communications following an earthquake." Describe in detail the basis for that conclusion and cite each and every study, analysis or test prepared, conducted, or reviewed by you in reaching the conclusion.
Response
l A.
The communications equipment is redundant and diverse, e.g., there 1
I are two telephone cables south from the plant toward Avila Beach, one l
on each side of the road, and also two cables north from the plant r
toward Morro Bay. There are two microwave systems which use different l
l equipment, on up the Coast Valley, and the other north via the West l
Valley system. The radio systems back up the telephone system.
The NRC Staff conclusion is that, while it h conceivable that some communi-(
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l cations equipment may be rendered inoperable following an earthquake, it is hignly unlikely that nothing would be available.
B.
Nor.e.
C.
See response to Interrogatory 69.C.
D.
See response to Interrogatory 69.D.
INTERR0GATORY 80 On p.13 of the Staff Response, you cite a contract with a heli-copter company "to furnish transportation to and from the plant follow-ing an earthquake if all other means of transportation are inoperative."
State precisely:
(a) the factual basis for your conclusion that such a contract j
will provide an adequate means of transportation to and from the plant; (b) the number of helicopters to be provided under the contract on an eme,gency basis; (c) the number of persons which the helicopter (s) in question can I
transport at one time; (d) a description of any and all drills or exercises of which you are aware which support the statement quoted.
1
Response
A.
(a)-(d)
The operating crew at the reactor has been trained, and i
is qualified, to assess and to cope with, an accident; to cla3sify the accident; to project potential offsite doses; to notify offsite author-ities.
The personnel essential to continue to perform these functions consist of a replacement crew. The replacement crew could be airlifted to the site from the offsite EOF in shuttle trips of a 4-seat helicopter.
the guidance in Table B-1 of NUREG-0654 specifies that the on shift crew
should be augmented by addition of 24 personnel at the site.
They could also be airlifted to the site in shuttle trips.
No specific drills have been performed to denonstrate this capability.
B.
See Response 80.A., above.
C.
See response to Interrogatory 69.C.
D.
See response to Interrogatory 69.D.
INTERR0GATORY 81 Do you contend that the letters of agreement contained in Draf t 3 of PGandE's onsite plan comply with all applicable NUREG-0654 criteria and, if so, what is the basis for your conclusion that they satisfy criterion II.A.3? Do you contend that any other agreements are necessary?
Response
A.
Professional judgment and experience are the basis for the conclu-sion that the letters of agreement contained in Draf t 3 of the Applicant's Emergency Plan satisfy NUREG-0654. The NRC Staff judges that other agreements are not required.
B.
None.
C.
See response to Interrogatory 69.C.
D.
See response to Interrogatory 69.D.
INTERROGATORY 82 On p.18 of the Staff Response, you cite various methods of public notification. What is the basis for your conclusion that any of the methods cited can be implemented and, if implemented, will be successful ir. actifying all members of the public? Describe any and all studies
. ucon which you rely in concluding that the area-wide siren system will successfully cover the plume exposure EPZ.
Response
-A.
The primary method of alerting people within the EPZ ts via the siren system. The siren system has been designed to produce an alerting signal approximately 10 db above ambient noise levels within the EPZ.
The level of perception of a dissonant sound is approximately 10 db below ambient.
Consequently, the NRC Staff juages that the siren system complies with the guidance in Appendix 3 of NUREG-0654 and is capable of alerting the public in the EPZ.
Documents which support the NRC conclusion include:
Balt, Beronek, Newman, Inc., Outdoor Warning Systems Guide (FEMA CPG-1-17).
B.
See Response 82. A., above.
C.
See response to Interrogatory 69.C.
D.
See response to Interrogatory 69.D.
INTERROGATORY 83 On p. 21 of the Staff Response, you describe the PGandE public information program.
(a) Describe the proposed implementation schedule for the program.
(b) What, if anything, has been or will be done to inform visitors to the beaches and parks (including Pismo, Cayucos, Morro Strand, and Atascadaero) as required by 10 C.F.R. 9 50.47(b)(7)?
Response
A.
(a) The implementation schedule for the more significant items in the public information program is described in answer to Interrogato y 77.
(b)
It is proposed that signs will be posted in beach and park areas within the EPZ.
B.-
None.
C.
See response to Interrogatory 69.C.
D.
See response to Interrogatory 69.D.
INTERR0GATORY 84 On p. 23 of the Staff Response, you refer to the plant conditions l
listed in Section 4 of the Diablo Canyon onsite plan and the guidance of Appendix 1 to NUREG-0654. Describe any and all training received by i
PGandE personnel and County personnel in the application of that guid-i ance to determine what protective actions to recommend or order.
Response
A.
All PG&E shift foremen have been trained to operate via written, approved procedures.
Emergency Procedure G 1, Accident Classification and Emergency Plan Activation, gives specific guidance to the Emergency
)
Coordinator on shift to classify the accident and to notify offsite authorities promptly.
Emergency Procedure RB-10 describes the mechanism l
for recommending protective actions to offsite authorities and includes l
the bases for the choice of the recommendation.
Understanding of these i
topics by offsite authorities as a result of previous coordination with PG&E was demonstrated during the full scale exerci:e of August 1981.
B.
I&E Inspection Report on August 19, 1981 exercise, which has been provided to all parties.
C.
See response to Interrogatory 69.C.
i D.
See response to Interrogatory 69.D.
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INTERR0GATORY 8_S_
1 De p. 26 of the Staff Response, au note that San Luis Obispo County has prepared certain emergency plans. What efforts have been made specifically to coordinate PGandE's emergency response organization with all officials responsible for local emergency preparedness and response in the jurisdictions cited in Joint Intervenors' Interrogatory No. 25?
Response
A.
The culmination of the efforts to coordinate PG&E's and local officials' emergency response occurred in the August,1981 full-scale 1
^
exercise. Critiques following the exercise pointed out areas for improvement, but there was agreement that the coordination between the organizations involved was well above the satisfactory level.
B.
See Response 94.B., abs e.
C.
See response to Interrogatory 69.C.
I D.
See response to interrogatory 69.D.
INTERR0GATORY 86 l
j With respect to the TERA Corporation Report entitled " Earthquake l
l Emergency Planning at Diablo Canyon," state whether you contend that the traximum acceleration at the plant postulated for purposes of that report is properly calculated as less than the.75g acceleration postulated i
for the SSE in the Diablo Canyon seismic proceeding, and, if so, state each and every fact upon which your response is based.
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Response
l A.
.759 acceleration is the design value for systems and components of i
the reactor judged by the NRC to be essential to safe operation and I
shutdown of the reactor.
The NRC Staff judges that the assumptions in the TERA report are responsive to the request by the NRC that the Applicant consider the complicaong factors that might result from an earthquake.
B.
November 3,1980 letter from Brian K. Grimes, NRR, to John McConnell.
FEMA, which has already been provided to all parties.
C.
See response to Interrogatory 69.C.
a D.
See response to Interrogatory 69.D.
1 1
Request for Production of Documents 1.
All documents identified in, relied upon, or relevant to the j
responses to Interrogatory Nos. 69-86 supra.
Response
All documents responsive to this request have already been provided l
to the parties in this 'groceeding, or are available to members of the public.
l Respectfully submitted, George E. Johnson Counsel for NRC Staff Dated at Bethesda, Maryland i
this 16th day of November, 1981.
I i
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4 U?ilTED STATES OF NIERICA NUCLEAR REGULATORY C0i'illSSION
_BEFORE THE ATOMIC SAFETY NID LICE *lSit!G BOARD In the flatter of
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PACIFIC GAS ATID ELECTRIC COMPANY
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Docket Nos. 50-275 0.L.
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50-323 0.L.
(Diablo Canyon tiuclear Power Plant
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Unit flos. 1 and 2)
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AFFIDAVITOFJOHNR. SEAR I, John R. Sears, being duly sworn, state as follows:
1.
I am employed by the U.S. Nuclear Regulatory Connission as a Senior Reactor Safety Engineer, Emergency Preparedness, Office of Inspection and Enforcement.
2.
I am duly authorized to participate in answering Interrogatories 69 through 86 and I hereby certify that the answers given are true to the best of my knowledge.
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- o Jyo R. Sears Subscribed and sworn to before me 1
this V'!'
day of November,1981
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a My Cczaission Expires:.)j. /, c/[ p-J
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE TH E__ _ A T OM I C SAFETY AND_LICENSINC_EUARD In the Matter of PACIFIC CAS AND ELECTRIC COMPANY Decket Num. 50-173 0.L.
50 0.L.
(Dinblo Canyon Nuc1 car Pnwcr Plant Unita Nos. 1 and 2)
AFFIDAVIT OF DEAN M.
KUNIHIRO I, Dean M.
Kunihiro, being duly sworn, state as follows:
1.
T am employed by the U.S. Nuclear Regulatory Commisalon as Reginnal State f.iaison Officer. Office of Inspection and Enforcement.
2.
I am duly authorized to participate in answering Interrogatories 69 through 86 and I hereby certify that the answer,given in true to the best of my knowledge.
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NUCLEAR REGULATORY COMMISSION BEF0RE THE ATOMIC SAFETY AND LICEPSIfiG BOARD In the Matter of
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PACIFIC GAS AND ELECTRIC COMPANY Docket Nos. 50-275 0.L.
50-323 0.L.
(Diablo Cinyon Nuclear Po,<er Plant Unit Nos. 1 and 2 CERTIFICATE OF SERVICE I hereby cert.(y that copies of NRC STAFF RESPONSE TO JOINT INTERVEN0RS' THIRD SET OF INTERUMTORIES AND REQUEST.FOR PRODUCTION OF DCCUMENTS in the above-captioned proceeding have been served on the following by deposit in the i
United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 16th j
day of November, 1981.
John F. Wolf, Eng., Chairman Richard E. Blankenburg Administrative Judge Co-publisher Atomic Safety and Licensing Board Wayne A. Soroyan, News Reporter O.S. Nuclear Regulatory Commission South County Publishing Company Washington, D.C. -20555 P.O. Box 460 Arroyo Grande, California 93420 Glenn 0. Bright, Esq.
Administrativa Judge Atomic Safety and Licensing Board i
U.S. h clear Regulatory Comission Washingcon, D.C.
20555
- Dr. Jerry Kline Mr. Gordon Silver Administrative Judge Mrs. Sandra A. Silver Atomic Safety and Licensing Board 1760 Alisal Street U.S. Nuclear Regulatory Commission San Luis Obispo, California 93401 Washington, D.C.
20555 i
Arthur C. Gehr, Esq.
Elizabeth Apfelberg Snell & Wilmer i
1415 Coradero 3100 Valley Center j
San Luis Obispo, California 93401 Phoenix, Arizona 95073 Philip A. Crane, Jr., Esq.
Paul C. Valentine, Esq.
i Pacific Gas and Electric Company 321 Lytton Avenue r
P.O. Box 7442 Palo Alto, California 94302 San Francisco, California 94120 Bruce Norton, Esq.
l Mr. Frederick Eissler
~,216 North 3rd Street Scenic Shoreline Preservation Suite 202 Conference, Inc..
Phoenix, Arizona 85012 4623 More Mesa Drive Santa Barbara, California 93105 Andrew Baldwin, Esq.
124 Spear Street Mrs. Raye Fleming San Francisco, California 94105 1920 Mattie Road Shell Beach, California 93449 o
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Atomic Safety and Licensing Appeal Panel Joel R. Reynolds, Esq.
U.S. Nuclear Regulatory Commission John R. Phillips, Esq.
Washington, D.C.
20555
- j Center for Law in the Public Interest Atomic Safety and Licensing Board 10951 West Pico Boulevard Panel 3
Third Floor U.S. Nuclear Regulatory Commission Los Angeles, CA 90064 Washington, D.C.
20555
- Byron S. Georgiou Docketing and Service Section legal Affairs Secretary U.S. Nuclear Regulatory Commission Governor's Office Washington, D.C.
20555 *
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State Capitol Sacramento, California 95814 Mark Gottlieb California Energy Connission l
David S. Fleischaker, Esq.
MS-18 P.O. Box 1178 1111 Howe Avenue Oklahoma City, Oklahoma 73101 Sacramento, California 95825 4
Richard B. Hubbard MHB Technical Associates 1723 Hamilton Avenue - Suite K San Jose, California 95125 John Marrs, Managing Editor San Luis Obispo County Telegram-Tribune 1321 Johnson Avenue P.O. Box 112 San Luis Obispo, California 93406 I
Herbert H. Brown Hill, Christopher & Phillips, P.C.
i 1900 M Street, N.W.
Washington, D.C.
20036 Harry M. Willis Seymour & Willis l
601 California St., Suite 2100 San Francisco, California 94108
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Janice E. Kerr, Esq.
Lawrence Q. Carcia, Esq.
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. M nson 350 McAllister Street Counsel San Francisco, California 94102 Mr. James 0. Schuyler Nuclear Projects Engineer i
Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 4