ML20010E653
| ML20010E653 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/03/1981 |
| From: | Bradley Jones, Olmstead W NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | NRC COMMISSION (OCM) |
| References | |
| ISSUANCES-OL, NUDOCS 8109080103 | |
| Download: ML20010E653 (20) | |
Text
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t UNITED STATES OF AMERICA flVCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of
)
PACIFIC GAS AllD ELECTRIC COMPANY Docket Nos. 50-275 0.L.
)
50-323 0.L.
(Diablo Canyon Nuclear Power
)
Plant, Unit Hos. I ano 2)
)
STAFF RESPONSE Tu AUGUST 14, 1981 NOTION OF J0 INT INTERVEHORS c %g U ll?'if,A 3
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William J. Olmstead t
Deputy Chief Hearing Counsel ~
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s Bradley W. Jones Counsel for NRC Staff September 3, 1981 Go')
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TABLE OF CONTENTS t
PAGE I.
INTRODUCTION.....................
1 II.
DISCUSSION......................
1 A.
Application of the Rule Will Serve Its Intended Purpece 3
B.
No "Special Circumstances" Are Present 5
III. CONCLUSION......................
13 s
A PAGE HRC Cases Kansas Gas and Electric Co. et al. (Wolf Creek Generating Station', Unit 1), ALAB-462, 7 HRC 320, 338 (1978)........
10 Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2), CL1-81-5, 13 NRC (1981)..
10, 11 Vermont Yankee Nuclear Power Corporation (Vermont Yankee Nuclear Power Station), ALAd-138, 6 AEC 520 (1973)........
L STATUTES 5 U.S.C. 9 553 (1976 & Supp. III 1979)..............
9 42 U.S.C. b 2239 (1976 & Supp. III 1979)...........
11, 12
.~
REGULATI0ilS 10 C.F.R. s 2.714......................
10, 11 10 C.F.R. 5 2.758.....................
5, 9, 12 la C.F.R. s 2.758(b).......................
2 10 C.F.R. b 2.762.........................
9 10 C.F.R. s 2.764.................
1, 3-6, 9, 11-13 10 C.F.R. b 2.764(f)(2)(iii)...................
3 10 C.F.R. 9 2.764(f)(2)(iv)...................
3
~
10 C.F.R. 9 2.764(f)t4)(vi)..................
4, 5 10 C.F.R. s 2.785........................
9 10 C. F. R. 9 2. 786........................
5 10 C.F.R. s 2.788.......................
5, 9 10 C. F. R. Q 5 0. 47........................
6 10 C. F. R. 9 50. 47 ( b ).......................
6 10 C. F. R. 9 5 0. 4 7 ( c ).......................
7 10 C.F.R. 6 50.47(c)(1)....................,. 7
i l
h ii i PAGE 4
OTHER a
Statement of Policy:
Further Conuission Guidance for Power Reactor Operating Licenses, CLI-80-42,12 NRC b54(19Q0)......-..................
10 4
45 Fed. Reg. 40101-40103 (1980)..............
8 i
Ab Fed. Reg. 28627 (1981).................
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UNITED STATES OF AMERICA liUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSI014 In the Matter of
)
PACIFIC GAS AND ELECTRIC COMPANY Docket Nos. 50-275 0.L.
50-323 0.L.
(Diablo Canyon Nuclear Power Plant, Unit Hos. 1 and 2 STAFF RESPONSE TO AUGUST 14, 1981 MOTION OF JOINT INTERVENORS 1.
INTRODUCTION On July 17, 1981, the Atomic Safety and Licensing Board in the above proceeding issued a Partial Initial Decision (PID) on the application of PG&E for a fuel load and low power license for the Diablo Canyon Nuclear Facility. That decision authorized issuance of the fuel load and low power operating license upon a favorable ruling by the Appeal Board on certain security issues pending before it.
The Commission issued an order on July 22,19d1 indicating that the period for review of the licens-ing decision would not begin to run until the Appeal Board issued its security decision. As of the date of this document no security decision had been issued by the Appeal Board. On August 14, 1981, the Joint Intervenors filed " Joint Intervenors' Request for Waiver of the Immediate Effectiveness Rule". The Staff opposes the Joint Intervenors' motion.
II.
DISCUSSION l
Joint Intervenors urge that the provisions of 10 C.F.R. 9 2.764, which bar the filing of pleadings with the Commission during the low I
power review process provided for in that regulation, be waived in the Diablo Canyon proceeding. The Joint Intervenors argue that application of the rule, due to special circumstances in this proceeding, would not serve the rule's intended purpose. The Joint Intervenors state that the purpose of the rule is to expedite the licensing process by reducing the time between completion of plant construction and a final Commission decision authorizing plant operation.
(Joint Intervenors' Motion at 2).
Indeed, 10 C.F.R. 9 2.758(b) does provide that the sole grounds for a waiver shall be that special circumstances exist such that application of the rule would not serve the purposes for which the rule exists.
Joint Intervenors correctly note that one purpose of the immediate effective-ness rule, as set out in the summary portion of the Statement of Consid-erations on the rule, is to reduce the length of time between a Licensing Board's decision to license plant operation and actual issuance of the license.
(46 Fed. Reg.- 28627, May 28,1981). However, an examination of the entire Statement of Consic'erations reveals that, although perhaps a major purpose of the rule, the purpose identified by the Joint Inter-venors is not the only purpose for the rule.
In addition to noting the desire to eliminate unnecessary delay in licensing, the "sumary" portion l
l of the Statement of Considerations notes that the review process is designed to determine whether effectiveness of a Licensing Board's decision should be delayed pending normal appellate review procedures.
i The " additional information" section of the Statement of Considerations for the rule also indicates that the review process is designed to focus on significant policy issues and it is not intended to involve a review of the entire record established by the Licensing Board.
(Id. at 28628).
l t
Thus, Joint Intervenors' motion to waive 10 C.F.R. s 2.764 must be analyzed to determine; 1) whether there are special circumstances and 2) whether application of the rule in this proceeding would fail to serve the t
purpose of eliminating delay in licensing or the purpose of focusing on significant policy issues.
A.
Application of the Rule Will Serve Its Intended Purpose Treating the second issue first, the question is whether the application of the rule would fail to serve the purposes of the rule.
While the Staff agrees that the fuel load and low power testing program could, as allegeo by Joint Intervenors, conceivably be completed in three months, this does not necessarily mean ' hat application of the rule would not serve the purpose of expediting issuance of a license. The Joint Intervenors allege that an application of the 10 day " deadline" for review of the Licensing Board's decision would not expedite the eventual issuance of a full power operating license.
(Joint Intervenors' Motion at 14). Joint Intervenors' impression that there is such a " deadline" is erroneous. The rule states that "the Commission intends to issue a decision regarding each fuel loading and low power testing license within 10 days of receipt of the Licensing Board's decision..." [ emphasis added]
(10 C.F.R. s 2.764(f)(2)(iv)).
In addition, in 10 C.F.R. s 2.764(f)(2)(iii),
the regulations refer to the schedule in the following paragraph as
" target schedule [sj". This reference to " target schedules" and use of i
l the tenn " intends" rather than a binding term such as "must", indicate that the Comission is not bound by a 10 day limit, and no waiver of the regulation is necessary in order for the Commission to have additional e.,-
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-s time to review the Licensing Board's decision, should they determine that additional time is needed.
In fact, the decision does not become effective until the Commission affirmatively acts.
The other portion of the regulation which Joint Intervenors wish to have waived is the bar on the filing of pleadings with the Connission to assist it in its limited review under 10 C.F.R. 5 2.764 of the Diablo Canyon fuel loading and low power testing authorization by the Licensing Board.
The circumstances surrounding the Joint Intervenors' argument that the purpose of the rule would not be arved, in actuality, demonstrate that the waiver requested would frustrate the purposes of the rule.
Indeed, there are at least two valid and readily apparent reasons which convincingly demonstrate the appropriateness of applying the rule to the issues identified by the Joint Intervenors.
First, the issues identified involve detailed analysis of factual and legal disagreements which are not of the "significant policy issue" category which the review process created by the rule is inter.ded to cover.
Sec'ond, the issues raised by Joint Intervenors are of the type which are more appropriately reviewed in the normal appellate review process which is expressly preserved under the regulation.
(10 C.F.R. 9 2.764(f)(2)(vi)). The waiver which Joint Intervenors have requested would result in a detailed review which could result in lengthy delays in licensing. The resolution of the individual concerns of Joint Intervenors would necessarily involve the Coraaission in a review of the lengthy record in this proceeding, in addition to a review of the pleadings the Joint Intervenors wish to file.
w '.. the limited review objectives of These results are incompatibla d
10 C.F.R. 2.764. Thus, rather than deraonstrating that the purposes of
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r the rule will not be served, the Joint Intervenors' arguments demonstrate that the waiver they have requested would frustrate the purposes of that rule.
t B.
No "Special Circumstances" Are Present Joint Intervenors must also, under 10 C.F.R. 9 2.758, demonstrate 1
"special circumstances" showing that the application of 9 2.764 in this proceeding would not serve the purposes for which the rule exists. We have just seen that the application of the rule here would serve its intended purpose. We will now consider whether there are any special circumstances which woula tend to cast doubt on that conclusion. There are none. An examination of each of the categories of "special" circumstances identified by Joint Intervenors reveals that the circum-stances are not, in fact, "special".
The first category of issues raised by Joint Intervenors covers issues which are either seismic or security related.
As Joint Intervenors note in footnote 11 of their motion, the arguments presented in their present motion were also pre-sented in a Petition for Review filed with the Commission on July 6, 1981. A decision on that peWon has not yet been issued. The argu-uents presented by Joint Irce venors are not new, but are simply repeti-tions of arguments c4hich
-' p, asented to the Appeal Board or Licensing l
Board (or both) and which were rejected by those Boards.
(Joint Inter-venors' Proposed Findings of Fact and Conclusions of Law, March 25, 1979,
- p. 23-25; Joint Intervenors' Proposed Findings of Fact and Conclusions of Law, December 15, 1980, p. 47-49). Tnere is no new information or other l
l l
i special circumstances which would indicate that the 10 C.F.R. 5 2.764 revief should be converted into a detailed review of seismic issues.
Joint Intervenors' arguaents are more appropriately considered in connection with their petition for review of the Appeal Board's decision pursuart to 10 C.F.R. 6 2.786.
Thus, in order for Joint Intervenors to bring these issues to the Commission's attention as they have done, a waiver of the rules is not necessary.
In addition,10 C.F.R. 9 2.764(f)(2)(vi) specifically provides that the str.y provisions of 10 C.F.R. 6 2.786 are still applicable to the review process.
If Joint Intervenors can demonstrate circumstances which necessitate delaying issuance of the fuel load and low power license, they could, in compli-ance with 10 C.F.R. 5 2.788, apply to the Commission's Licensing or Appeal boards for a stay. The regulations, therefore, specifically pro-vide mechanisms to address the type of concerns raised by Joint Inter-venors, and there is no reason to try to fashion 10 C.F.R. 9 2.764 to provide such a procedural mechanism, one, as we have shown, it was never designed to provide.
The second set of circunstances raised by Joint Intervenors involves emergency planning. Joint Intervenors raise two issues under this cate-gory. The first issue raised is whether the plant can be licensed for I
fuel load and low power testing without complete compliance with the provisions of 10 C.F.R. 50.47(b). This issue was thoroughly briefed during the low power proceedings before the Licensing Board.
(Joint i
Ir.tervenors' Proposed Findings of Fact and Conclusions of Law, June 16, l
l 1981, p. 9-14). The basis for Joint Intervenors' challenge to the l
Licensing Board's determination of this issue is that the Licensing Board l
t was incorrect in finding that SECY 81-188 justified less than full compliance with 10 C.F.R. 9 50.47(b).
(Joint Intervenors' Motion at 7).
The Joint Intervenors misinterpret the Licensing Board's ruling when t
they allege that the Board, based on SECY 81-188, determined that the Cormiission's emergency planning regulations need not be considered in reviewing an application for a license to load fuel and conduct low power tests.
(Joint Intervenors' Motion at 7).
As the Licensing Board was careful to point out with respect to the argument Joint Intervenors now advance, the substance of Section 50.47 is not altered by SECY 81-188.
The SFCY paper only deals with the schedule for implementation of the emergency planning requirements, a subje.ct not specifically dealt with in Section 50.47.
(Partial Initial Decision, July 17, 1981, p. 22-24).
In addition,10 C.F.R. @ 50.47(c)(1) specifically allows the applicant to demonstrate that the deficiencies in the plans are not significant for the plant in question. There is nothing in that provision which prevents the applicant from making a showing of insignificance'on a basis which applies to all the deficiencies. There is no explicit requirement that a deficiency-by-deficiency examination be conducted by the Board.
If the Board has determined, by considering the present state of emergency plan-ning and the low risk during low power operation, that adequate protec-tion exists so that any further deficiencies are insignificant, then the exemption provisions of 10 C.F.R. b 50.47(c) have been met.
Joint Intervenors argue that by determining that the low risk during low power renders the deficiencies in the emergency plan insignificant, the Board, is, in effect, challenging the regulations.
(Joint Inter-venors' Motion at 8).
However, this argument ignores the Board's rationale that emergency planning deficiencies can be rendered insignificant pursuant to Section 50.47(c) because of the low risk assoCidted With low power operation.
Such an analysis can hardly be a challenge to the regulation when its very purpose is to review compliance with the regulation.
For low power authorization a Board is required to make only those findings relevant to the activity to be authorized.
(10 C.F.R.
s 50.57(c)). An analogous situation exists with respect to the con-sideration of accidents for the purposes of conducting an environ-mental review under the Commission's regulations. While the consid-eration of the effect of accidents on the environment assumes that an unlikely accident has occurred, the Comission has specifically noted that it was appropriate to consider the probability of occurrence of the events.
(Comission Statement of Interim Policy, 45 Fed. Reg. 40101, 40103 (1980)). Thus, the fact that some unlikely events are assumed for analysis does not mean that every conceivable event, no matter how unlikely, should be considered.
However, it is not necessary to reach a determination of whether the extremely low probabilities presented during low power testing are so remote as to make their consideration unnecessary.
10 C.F.R. @ 50.47(c) places no restrictions on the reasons which the Licensing Beard may find to demonstrate the insignificance of deficiencies in a particular emer-gency plan.
Unlike the situation in Vermont Yankee liuclear Power Corporation (Vermont Yankee liuclear Power Station), ALAB-138, 6 AEC 520 (1973) which was cited by Joint Intervenors, the Commission's emergency l
l planning regulation allows the Licensing Board to determine whether the
_9.
deficiencies in the emergency plan are insignificant.
Thus, the Licensing Board followed the specific process provided in the regulations.
t The second issue which Joint Intervenors raise with regard to emer-gency planning is whether the Licensing Board adequately considered the effect of an earthquake occurring simultaneously with a radiological emergency at the site.
(Joint Intervenors' Motion at 6). As testified to by Staff witnesses, and as noted by the Board, the effect of earthquakes on the emergency plan is the subject of a study presently beii,G conducted and PG&E will make any modifications indicated by the study as being necessary.
(Sears Testimony at 7; Tr. at,11057-11060, PID at 47). The Licensing Board considered the arguments and made findings on this issue.
(Tr. at 11283-11289, PID at 47). The Joint Intervenors have not presented any information additional to that already considered by the Licensing Board which might be considered as raising specia' circumstances. As with the seismic and security issues, the reargument of these positions is appropriately handled through the appeal provisions of 10 C.F.R. 9 2.762 and 9 2.785, and through the stay provisions of 10 C.F.R.
b 2.788. The Joint Intervenors have not presented anything special about their arguments other than the fact that they were rejected by the Licensing Board. This is not a case where the Licensing Board has ruled on the basis of some new theory or position which Joint Intervenors were not previously allowed to address.
If such an adverse ruling were to constitute "special circumstances" under 10 C.F.R. s 2.758, the exceptions to 10 C.F.R. 9 2.764 would swallow the rule.
_ _ _ _. _ - - _ _ _. _ _ _ _ _ _ _ _ _ _. _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. - _ _ - _. _ _ _ _ _ _ _ _.. _ _ _ _ _ _ _ _ _ _ _., _ _ _ _ _ _ _ ~. _. - _ _ _ _ _ _ _
- The third category of issues Joint Intervenors uaintain establish "special circumstances" justifying a waiver of 10 C.F.R. 9 2.764, is the rejection by the Licensing Board of certain contentions proposed by Joint Interven' ors. Joinc intervenors argue that the Licensing Board's treat-ment of flVREG-0737 elevated that document to the itatus of a rule without the public notice and comment requirements of the Administrative Proce-dyre Act of 1946 being net.
(Joint Intervenors' 110 tion at 12; 5 U.S.C.
9 553 (1976 &. pp. III 1979)). An examination of the Licensing Board's Prehearing Ccnference Order of February 13, 1981, and the Comission's clarification of the Revised Policy Statement on NUREG-0737 show that interpretation to be groundless.
In Pacific Gas and Electric Company (Diablo Canyon liuclear Power Plant, Units 14:a 2), CLI-81-5,13 NRC (1981), the Commision pro-vided guidance on the proper application of the Revised Statement of Policy, CLI-80-42, 12 t4RC 654 (1980), and flVREG-07W to contentions sub-mitted in proceedings where the record has been closed'. That order made it clear that the requirements of 10 C.F.R. 9 2.714 on late filt.d conten-tions, and the requirements for reopening a closed record i: Kansas Gas and Electric Co. et. al. (Wolf Creek Generating Station, Unit 1),
ALAB-462, 7 HRC 320, 338 (1978), apply to late filed contentions which relate to tiUREG-0737.
(CLI-81-5 at 5-6).
The Commission did note that NUREG-0737 coulu satisfy the requirement for sign ficant new information i
necessary to reopen a closed record under the, Wolf Creek standard, tiewever, the Comission also noted that it must still be demonstrated that the information would have changed the initial result in order to justify reopening the record.
(CLI-81-5at6). Thus, the Comission was not establishing flUREG-0737 as a rule by its treatment of the con-tentions, but was uerely making a determination of whether the informa-tion in,ltVREG-0737 satisfied the Commission's regulations for late filing of contentions and reopening closed records.
An examination of the Licensing Board's treatment of the contentions reveals that the Licensing Board, similarly, did not treat the 140 REG-0737 as a rule, but simply made a determination of whether the Cormiission's rules for late filing of contentions and reopening a closed record were satisfied.
The Licensing Board stated in the February 13, 1981 Prehearing Conference Order that the Joint Intervenors had not at that time attempted to demonstrate good cause for late filing of contentions and reopeiiing a closed record.
(Prehearing Conference Order at 8).
- However, rather than rejecting all of the Joint Intervenors' contentions, the Licensing Board found that NUREG-0737 would constitute good cause for ooth reopening the record and for late filing of contentions.
(Id.at 12).
Rather than applying NUREG-0737 as a rigid rule which prevents the admission of Joint Intervenors' contentions, the Licensing Board was giving more benefit to the Joint Intervenors on the basis of NUREG-0737 then was necessary under the Commission's guiaance in CLI-81-5. Since l~
the Licensing Board was simply using NUREG-0737 as information which might meet the provisions of 10 C.F.R. s 2.714 and which might satisfy the requirement for reopening a closed record, NUREG-0737 would not be the equivalent of a rule requiring notice and comment as alleged by Joint i
Intervenors. The Licensing Board's method of using NUREG-0737, there-i fore, does not constitute special circumstances justifying a waiver of i
10 C.F.R. S 2.7C4.
Rather, what 1s involved is the application of I
well established Comission rules for late filing of contentions and reopening of closed records.
The Joint Intervenors further allege that by limiting the scope of contentions, the Licensing Board denied Joint Intervenors their right to a hearing under Section 189(a) of the Atomic Energy Act of 1954 (as amended).
(Joint Intervenors' Motion at 12; 42 U.S.C. 9 2239 (1976 &
Supp. III 1979)). This argument is specious at best.
Joint Intervenors have, in fact had a hearing of great length on this application.
In addition, the record was reopened to further consider THI-related low power contentions. The latter reopened hearing lasted from May 19-22, 1981. The opportunity for hearing whictt Section 189(a) affords does not necessarily mean that an interested party, such as Joint Intervenors, has the right to litigate in that nearing all of the contentions which they allege.
Tne Joint Intervenors have presented their contentions to the Licensing Board and were given an opportunity to present e guments in support of them. As demonstrated above, that Board gave them generous treatment in setting the issues for hearing. As far as the consideration of contentions is concerned, Section 189(a) does not require anything more. Thus, the rejection of Joint Intervenors' contentions does not raise special circumstances which would justify the waiver of 10 C.F.R. 9 2.764 so that it would be changed from a limited review, for specific purposes, of significant policy issues by the Commission into a detailed review of the Licensing Board's acceptance or rejection of some con-tentions.
A detailed review of such rulings, while the antithesis of the 10 C.F.R. 9 2.764 Comission review, is a typical ingredient for the regular uppellate process for the review of ASLB decisions.
As far as i
. 10 C.F.R. s 2.764 is concerned, Joint Intervenors are in no different position than any person who participates in a proceeding and has some contenti,ons rejected and some accepted.
III. CONCLUSION A waiver of a rule is appropriate under 10 C.F.R. 4 2.758 if special circumstances exist such that the purposes of the rule would not be served by applying it to the proceeding in question. As [as been demon-
~
strated above, the waiver requested by Joint Intervenors does not present cpecial circumstances, but rather presents the panoply of positions and issues which are expected in any adversarial proceeding where a ruling is unfavorabl'e to one of the parties.
Joint Intervenors have shown no special circumstances which would warrant the waiver of 10 C.F.R. 9 2.764.
That section serves the limited purpose of providing the Commission, without unnecessary delay, with an opportunity to review significant questions of policy before allowing a ASLB decision to become effective.
This limited review procedure is not, however, in lieu of, and, indeed, has no affect on the normal appellate procedures which remain available to the Joint Intervenors.
Respectfully submitted,
/,
William J.
lastead Deputy Chief Hearing Counsel Y
f@
c Bradley W.
s Counsel for NRC Staff Dated at Bethesda, liaryland this 3rd day of September, 1981.
UNITED STATES OF AMERICA NUCLEAR REGULATORY C0t@flSSION BEFORE THE C0f411SSION
.~
IntheMagterof PACIFIC GAS AND ELECTRIC COMPANY Docket Nos. 50-275 0.L.
50-323 0.L.
(Diablo Canyon Nuclear Power Plant Unit Nos. I and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies.of STAFF P9P0NSE TO AUGUST 14, 1981. MOTION OF JOINT INTERVENORS in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 3rd day of September,19811
- Mr. Thomas S. Moore, Member
- Mr. Samuel J. Chilk Atomic Safety and Licensing Appeal Board Office of the Secretary U.S. Nuclear Regulatory Commission of the Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 John F. Wolf, Esq., Chairman
- Leonard Bickwit, Esq.
Administrative Judge Atomic Safety and Licensing Board General Counsel Office of the General Counsel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Washington, D.C.
20555 Mr. Glenn 0.. Bright Administrative Judge Atomic Safety and Licensing Board f.
U.S. Nuclear Regulatory Commission l
Washington, D.C.
20555
- l l>
Dr. Jerry Kline
- Dr. John H. Buck Atomic Safety and Licensing Appeal Board Administrative Judge U.S. Nuclear Regulatory Comission Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission l
Washington, D.C.
20555 Washington, D.C.
20555 i
- Dr. W. Reed Johnson Atomic Safety and Licensing Appeal Board Elizabeth Apfelberg l
l U.S. Nuclear Regulatory Comission 1415 Cozadero San Luis Obispo, California 93401 l
Washington, D.C.
20555 1
4 l
Philip A. Crane, Jr., Esq.
Janice E. Kerr, Esq.
Pacific Gas and Electric Company Lawrence Q. Garcia, Esq.
350 McAllister Street P.O. Box 7442 San Francisco, California 94102 San Francisco, CA 94120 Mr. James 0. Schuyler Mr. Frederick Eissler Nuclear Projects Engineer Scenic Shoreline Preservation Pacific Gas & Electric Company 77 Beale Street Conference, Inc..
4623 More Mesa Drive San Francisco, California 94106 Santa Barbara, California 93105 Bruce Norton, Esq.
Mrs. Raye Fleming 3216 North 3rd Striet Suitw 202 1920 Mattie Road Shall Beach, California 93449 Phoenix, Arizona 85102 Richard E. Blankenburg, Co-publisher David S. Fleischaker, Esq.
Wayne A. Soroyan, News Reporter P.O. Box 1178 South County Publishing Company Oklahoma City, Oklanoma 73101 P. O.
Box 460 Arroyo Grande, California 93420 Mrs. Sandra A. Silver 1760 Alisal Street
- Ms. Majorie Nordlinger San Luis Obispo, California 93401 Office c' General Counsel U.S. Nuclear Regulatory Commission Mr. Richard B. Hubbard Washington, D.C.
20555 MHB Technical Associates 1723 Hamilton Avenue - Suite K Mr. Gordon Silver San Jose, California 95125 1760 Alisal Street San Luis Obispo, California 93401 Mr. John Marrs John R. Phillips, Esq.
Managing Editor San Luis Obispo County Simon Klevansky, Esq.
Margaret Blodgett, Esq.
Telegram-Tribune Marion P. Johnston, Esq.
1321 Johnson Avent:e Center for Law in the Public P. O.
Box 112 San Luis Obispo, California 93406 Interest 10203 Santa Monica Boulevard Los Angeles, California 90067 Andrew Baldwin, Esq.
124 Spear Street San Francisco, California 94105 Arthur C. Gehr, Esq.
Snell & Wilmer Mr. Herbert H. Brown 3100 Valley Center Hill, Christopher & Phillips, P.C.
Phoenix, Arizona 85073 1900 M Street, N.W.
Paul C. Valentine, Esq.
Washington, D.C.
20036 321 Lytton Avenue Palo Alto, California 94302 Byron S. Georgiou Legal Affairs Secretary Governor's Office Harry M. Willis State Capitol Seymour & Willis Sacramento, California 95814 601 California St., Suite 2100 San Francisco, California 94108
.g.
_ ?'
,
- Atomic Safety and Licensing Mark Gottlieb California Energy Commission Board Panel U.S, !!uclear Regulatory Comission MS-18 Washington, D.C.
20555 11111(owe Avenue Sacramento, California. 95825
- Atomic Safety and Licensing Appeal Board Panel U.S. !!ucidir Regulatory Commission Washington, D.C.
20555
- Docketing and Service Section U.S. !!uclear Regulatory Commission Washington, D.C.
20555 N
<1 Bradley W. Jones Counsel for NRC Staff I
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,