ML20035D988
| ML20035D988 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/08/1993 |
| From: | Zamek J SAN LUIS OBISPO MOTHERS FOR PEACE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#293-13872 92-669-03-OLA-2, 92-669-3-OLA-2, OLA-2, NUDOCS 9304140161 | |
| Download: ML20035D988 (14) | |
Text
i l
9.
W f$
l-d Lou'LiLD U.;fiHC UNITED STATES OF AMERICA i
NUCLEAR REGULATORY COMMISSION
'93 APR 12 PS 25 ATOMIC SAFETY AND LICENSING BOARD l
Before Administrative Judges:
Charles Bechhoefer, Chairman Jerry R.
Kline Frederick J. Shon In the Motter of Pacific Gas and Electric Company Docket Nos. S0-27S-OLA-2 Diablo Canyon Nuclear Power Plant S0-323-OLA-2 Units 1 and 2 ASLBP No. 92-669-03-OLA-2 Focility Operating Licenses No. DPR-80 and DPR-82 April 8, 1993 Son Luis Obispo Mothers for Psoce Response to Second Set of Interrogatories and Request for Production of Documents Filed by Pacific Gas and Elsetric Company and Motion for Protective Order Son Luis Obispo Mothers for Peace ["SLOMFP"] herein responds to Pacific Gas and Electric Company's ["PG&E"3 Second Set of Interrogatories and Request for Production of Documents filed March 4, 1993.
l Answers to Interrogatories for Contention I l
Interrogatory B-1:
In its Preheoring Conference Order, the Licensing Board I
did not strictly limit NFP "to the specific incidents relied upon to admit its contention."
Prehearing Conference Order, at 2S.
" Incidents such as those that MFP ottempted to read into the record at the preheoring conference may be acceptable, os long as they are material to the implementation of maintenance and surveillonce programs." Jda B-1.1 Does MFP intend to identify additional " incidents" other than those set forth in its " Supplement to Petition to Intervene"
[ Supplemental Petition"J?
B-1.2 If so, identify all of the incidents, other than those set forth in the Supplemental Petition, on which MFP intends to rely in support of Contention I.
Explain why they support Contention I.
B-1.3 Provide any and all documentation relevant to the incidents identified in response to B-1.2.
Include any documentation originally prepored for, and intended to be submitted at, the Preheoring Conference.
B-1.4 PG&E emphasized the continuing nature of B-1 and directs MFP to review instruction L obove.
I 9304140161 930408 3
PDR ADOCK 05000275 KD g
~.1 c.-
Answer:
SLOMFP does intend to identify additional incidents.
- However, SLOMFP hos not yet determined which incidents will be used in testimony because SLOMFP hos not yet received all of PGSE's responses to SLDMFP discovery requests nor hos it had the opportunity to evoluote all of its gathered documents.
SLOMFP notes the continuing nature of B-1 and intends to provide this information to PG&E in a timely fashion.
l Interrogatory B-2:
Describe the qualifications and experience of MFP members and their consultants in this proceeding, pertinent to the l
nature, scope, purpose of, and/or porticipation in:
B-2.1 maintenance and surveillance practices and activities at DCPP or other commercial nuclear power plants; l
B-2.2 predictive, preventive, and corrective maintenance practices employed generally throughout the nuclear industry as well as at DCPP.
Answer:
SLOMFP will provide the qualifications and experience of its witnesses when SLOMFP hos determined who those will be.
SLOMFP objects to the portion of this interrogatory that requests qualifications and experience of individual members of SLOMFP -
who will not be colled as witnesses - ond requests the issuonce of a protective order.
SLDMFP relies on Rule 26Cb]C9] which differentiates between experts whom the party expects to call os witnesses and those who have been retained or specicily employed by the party in preparation for trial.
Discovery of expert witnesses is necessory to narrow the issues and eliminate surprise, but that purpose is not furthered by discovery of non uitness experts.
This opplication of Rule 26Cb]C9] was upheld in Public Service Co. of New A
Hampshire (Seabrook Station. Units 1 and 23, LSP083-17, 17 NRC ot 997 (1983].
8nterrogatory B-3:
Identify and provide copies of all reports, prepored by
)
or at the direction of MFP and/or any of its consultants, either in this proceeding or otherwise, oddressing or reviewing maintenance and surve111once practices at DCPP or at any other commercial nuclear power plant.
s.
i l-i I
l B-3.1 State whether MFP intends to use information identified in response to B-3, to support Contention I.
If so, identify the information and explain how it supports o particular ospect[s] of the contention.
Answer: No such documents exist.
Interrogatory B-4:
Identify and provide copies of all reports of which MFP or its consultant is owcre, and on which it intends to rely in this proceeding, relevant to the implementation of maintenance and surveillance programs at commercial nuclear power plants located in the United States.
1 B-9.1 Provide copies of any and all documents relevant to the information identified in response to B-9.
Answer: SLOMFP objects to this interrogatory to the extent that it requests identification of all documents that SLOMFP or its consultants are aware.
This request is overly brood and burdensome; SLOMFP requests the issuance of a protective order.
The SLOMFP will identify documents that its witnesses will rely on in the cose when this information is known.
fnterrogatory B-S:
Describe your understanding of the nature and purpose of the NRC's Systematic Evoluotion of Licensee Performance ["SALP"]
program.
Include in your response answers to the following questions.
B-S.1 Uhot is the significance of a SALP Category 1 score?
B-S.2 Hos any member of MFP or its consulting team porticipated in the SALP process in any copocity?
If so, in what matter, and when.
Identify any other persons involved.
Answer:
The " Introduction" to the SALP report for DCNPP from 1/1/90-6/30/92 stctes that the SALP "is on integrated NRC stcff effort to collect ovc11chle observations and dato on a periodic basis and to evoluote licensee performance on the basis of this information.
The program is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations."
According to the "Criterio" section of the SALP report for DCNPP from 8/1/88-12/31/88, the definition of Category 1 is os follows: "L:censee management ottention ond involvement ore reodily evident and place emphasis on superior performance of nuclear safety or
.t sofeguards activities, with the resulting performance substontially exceeding regulatory requirements.
Licensee resources are ample and l
effectively used so that a high level of plant and personnel performance is l
l being ochieved.
Reduced NRC attention may be appropriate."
l SLOMFP will provide the information regarding the experiences of its t
expert witnesses when its witnesses have been selected.
But SLOMFP ogain objects to inquiries regarding individual members of SLOMFP or other persons that are not witnesses in this proceeding.
SLOMFP ogoin relies on Rule 2SCb]C4] and requests the issuance of a protective order.
Interrogatory B-6:
Describe your understanding of the purpose and nature of a Licensee Event Report ( *'LER " J.
Answer:
Refer to 10 CFR S0.72 and 50.73.
Interrogatory B-7:
Describe your understanding of the purpose and nature of NRC inspection and enforcement activities.
B-7.1 Hos any member of MFP or its consulting team porticipated, in ony capacity, in enforcement ond/or inspection activities at DCPP or any other commercial nuclear power plant?
Answer:
Refer to 10 CFR Port 21 for the purpose and nature of NRC inspection and enforcement activities.
In response to B-7.1, SLOMFP ogain ogrees to supply information regarding the experiences of its witnesses when they have been identified.
Yet, SLONFP objects to inquiries regarding individual members of SLOMFP or other persons that are not witnesses in this proceeding.
SLOMFP relles on Rule 26Cb][9] and requests the issuance of a protective order.
Interrogatory B-8:
Identify any and all information, of which MFP or its consultant is aware, regarding:
B-8.1 the maintenance rule and its implementotion ot DCPFi B-8.2 maintenance and surveillance activities at DCPP; and/or B-B.3 oging, oging management, ond/or the effectiveness of programs to monoge oge-related degrodotion at DCPP.
B-B.9 Does MFP intend to use any of the information identified in response to B-8.1
.3 in support of Contention I?
If so, explain the intended use of any such information.
l-3 r
l B-8.5 Provide copies of any documentation identified in response to B-8.1
.3 which is not already available to PG&E.
l Answer:
SLOMFP objects to the portion of this interrogatory that requests
]
c11 information that SLOMFP or its consultonts is aware.
This request is l
overly brood and burdensome; SLOMFP requests the issuance of a protective order.
The SLOMFP intends to identify all documents to be used in l
testimony in support of Contention I; however, o complete response from PG&E of discovery requests regarding this Contention hos not yet been i
l received.
l Interrogatory B-9:
How, and in accordance with what stondord, does MFP and its consultant define o "sufficiently effective and comprehensive surveillance and maintenance progrom?"
Supplemental Petition, at 5.
B-9.1 State whether MFP or its consultant perceives any correlation between SALP scores and the existence of a "sufficiently effective and comprehensive surveillance and maintenance program."
Explain.
l B-S.2 Do you believe that ongoing NRC inspection and enforcement i
ottivities, in conjunction with general regulatory oversight, ensure the existence of "sufficiently effective and comprehensive surveillance and maintenance program [s]" at operating commercial nuclear power plants?
If not, explain why not.
Answer:
A sufficiently effective and comprehensive surveillance and maintenance program must be odequate to detect degradotion or malfunctioning in o piece of equipment before that degradotion or malfunctioning falls to meet the NRC requirements for quality, reliability l
l and copobility.
The maintenance and surveillonce program should cover all I
equipment that is safety-related, important-to-sofety or non-sofety equipment whose failure could effect important-to-sofety equipment.
The SALP report is based on limited information.
Additionally, on overage " grade" is provided for limited ospects of operation Cusing limited information) over o long period of time.
It is on expressed opinion of operation, not a comprehensive onclysis of a plant's maintenance and surveillance program.
NRC inspection and enforcement activities, os well, l
i
s f
take representative activities to observe and inspect.
These are not comprehensive reviews.
The NRC inspection process hos been known to overlock deficiencies and non-conformances.
The current issue of degraded safety-related cables at DCNPP is on example of a problem that was not detected through NRC inspection and enforcement octivities, nor through general regulatory oversight.
A Licensing Review is o much more thorough and critical evoluotion.
Interrogatory B-10:
What mechanisms, other than the maintenance and surveillance program, should licensees employ to "guarontee that failure of aging systems, structures, and components will not cause safety problems?"
Supplemental Petition, at 5.
B-10.1 What mechanisms, among those identified in response to B-10, do you believe PGBE has foiled to implement at DCPP?
B-10.2 Provide copies of any and all documents supporting your response to B-10.1.
Answer:
SLOMFP objects to this interrogatory.
It is not the place of SLOMFP to identify mechanisms that the licensee should employ to improve its maintenance and surveillance program.
The issue in this proceeding is to identify PGSE failures despite these already-established "mechonisms."
SLOMFP requests the issuonce of a protective order.
Interrogatory B-11:
MFP contends that "the NRC has repeatedly cited PGSE for its slow response to correct maintenance problems."
Supplemental Petition, at 7.
Identify and provide supporting documentation for all such incidents, other than those listed in the Supplemental Petition in support of Contention I.
Answer:
SLOMFP is not prepared to answer this request at this time because SLOMFP has not yet received all of its discovery requests from PGSE.
SLOMFP intends to provide this information to PGSE in a timely fashion.
Interrogatory B-12:
What is the relctionship between Inspection Report I"IR"3 S2-19 and mcIntenance and surveillance activities at DCPP?
Supplemental Petition, at 11.
Answer:
In IR S2-14, the NRC calls to PGSE's attention its failure to provide written instructions for the ossembly of on important piece of
s equipment. Inadequate instructions to technical personnel is a maintenance issue.
Interrogatory B-13:
How many commercial nuclear power plants, located in the United States, are "oging plant [s]"?
Supplemental Petition, at 13.
B-13.1 How do you define "oging" in the context of this proceeding?
l B-13.2 Uhen does "oging," in the context of this proceeding, commence?
l B-13.3 Uhot is the basis for the ossertion that on "oging" plant
" consequently needs more repairs and more maintenance than a new l
plant?"
Supplemental Petition, at 13.
Document and explain, on o comparotive basis, the differences in the quantity and type of repairs-and maintenance required by a new versus on "oging" plant.
B-13.4 Con maintenance and surveillance programs effectively identify i
and manage the effects of "oging?"
Explain.
Answer:
All nuclear power plants begin oging when the components, systems and structures are produced and continue to age throughout service.
NUREG-1199, Rev. 1 Nuclear Plant Aging Research CNPARJ Progrom Plon:
Components, Systems, and Structures [NRC: 1S87).
The NRC defines oging as the cumulative degrodotion of structures, systems and components that occurs over time.
Factors that contribute to the aging process include normal wear and vibrotion, improper installotion, use or maintenance, excessive testing, and conditions such as radiction or the external environment under which the systems or components have operated.
An especially corrosive condition experienced at DCNPP is the continued exposure to solt air and water.
The increased risks associated with oging cannot be dismissed by relying on maintenance and surveillance programs.
First, too little is known about the aging process to state confidently that it con be controlled by current methods.
The NRC hos conceded that " mony age-related uncertainties exist because neither [NRCJ nor the industry
s i
completely understand the nature and effects of oging on the plants."
GAD /RCED-89-90, License Renewal Questions for Nuclear Plants Need to Be Resolved [ GAD: April 19893 at 16-17.
Additionolly, in some cases the technology for detecting oging effects simply does not exist.
NUREG-1377, Rev. 2, NRC Research Progrom on Plant Aging: Listing and Summaries of i
Reports Issued Through June 1991 CNRC: July 1991) at 15.
The bosis for the assertion that on "oging" plant requires more repairs than a new plant con be found in PG&E's own admission of the odditional " risks" of on oging Dicblo Congon Nuclear Power Plant:
"The I
risk of unscheduled autoges os the plant gets older; the risk of higher than expected maintenance and capitol costs as major plant equipment, such as steam generators, is repaired or replaced; and the risk of reduced plant performance or higher costs..."
Protest of PGGE to Petition By l
I Toward Utility Rote Normolization to Modify Decision 88-12-083 CDetober 16, 19923 at 10.
I Interrogatory B-14:
Does the sofe operation of all, or only " cider,"
commerciol nuclear power plants require "o sound surveillonce progrom?" Supplemental Petition, at 13.
If not, what is the basis for the distinction?
t Answer:
Certainly, all nuclect power plants require a sound surveillonce program.
As the plants age, however, o sound maintenance and surveillance progrom ecy not be enough to detect problems.
Refer to answer to Interrogatory B-13 ond documents noted therein.
Interrogatory B-15:
How do you define and measure " margin of safety?"
Supplemental Petition, at 13, i
Answer:
The concept of "morgin of safety" hos been expressed in the Federol Register in this cose. Federal Register, Ucl. 57, No. 191 EJuly 22, 1992).
It is the understanding of the SLOMFP that when a nuclear power plant compiles with NRC requirements, the morgan of safety that is
l.
considered reasonoble to protect the health and safety of the public is l
l odequate.
But as o plant ages, both safety components and non-sofety components that could effect the safe operation of the plant increasingly falls out of compliance.
The margin of safety is then reduced.
SLONFP has not quantified this reduction, but it is not necessary to quantify this reduction.
The Commission hos already established that compliance with its safety regulations constitutes the measure of what is required to maintain on adequate margin of safety.
Interrogatory B-16:
Provide on explanation and documentation in support of the ossertion that "the continued operation of CDCPPJ beyond the date for which operation was originally opproved would significantly reduce the plant's margin of safety."
Supplemental Petition, at 13.
B-16.1 Quontify, explain, and document the purported reduction in the plant's "morgin of sofety."
1 Answer:
Refer to answer to Interrogatory B-15.
For additional
(
information, refer to answer to Interrogatory B-13 and to the documents noted therein.
Answers to Interrogotories for Contention U Interrogatory B-17:
In support of the admissible portion of Contention U l
pertinent to the implementation of interim compensatory fire-protection measures at DCPP, MFP cites five incidents based on two NRC inspection reports and three LERs.
Preheoring Conference Order, at 35.
B-17.1 Uhat, if ony, other incidents does MFP or its consultant intend to rely upon in support of Contentien V, as admitted by the Licensing Ecord, which regards inplementation of Thermo-Log compensatory measures at DCPP?
B-17.5 Provide any and all documentation relevant to the incidents identified in response to B-17.1.
B-17.3 PG&E reiterates the continuing noture of this request and 1
directs MFP and its consultant to review instruction L obove, j
Answer-SLOMFP has not yet received all documents requested from PGEE 1
regarding this Contention and is therefore currently unable to provide this information.
SLCMFP notes the continuing nature of this request.
t i
d Interrogatory B-18:
Explain NFP's knowledge of the interim compenectory measures in effect at DCPP.
State, in porticular, whether MFP or its consultant knows what these compensatory measures are in each Thermo-Log fire creo.
Answer:
Refer to FG&E's Response to Supplement 1 of NRC Bulletin 92-01, September 28, 1992. CDCL-92-208 & HBL-92-060).
Interrogotory B-19:
Hos MFP or its consultant ever porticipated in or observed a fire watch at DCPP or any other commercial nuclear power reactor?
Answer: SLOMFP hos not yet determined its witnesses, but will provide information on their background and experiences when they are identified.
SLOMFP objects to the portion of the interrogatory that inquires into the experiences of individual members of SLOMFP or other non-witness persons.
SLOMFP requests on issuance of a protective order, relying on Rule 26[b3[43.
Interrogatory B-20:
Identify all instances, known to MFP, in which fire watches have been missed at DCPP since implementation of the interim compensatory measures at issue.
Answer:
SLOMFP hos not received all documents requested from PG&E regarding this issue and is unable to respond to this interrogotory at this time.
Interrogotory B-21:
Identify all studies, reports, and information, within the knowledge or possession of NFP or its consultants, pertaining to l
the implementation of interim compensatory measures at DCPP and/or any i
commercial nuclear power plant.
j B-21.1 Is any of the information identified in response to B-21 comparative in noture; e.g.,
does it compare the implementation of interim compensatory measures at various commercici nuclear power plants?
B-21.2 Upon which of the items identified in response to B-21 does l
MFP and its consultant intend to rely in support of Contention U7 j
Explain how.
B-21.3 If NFP and its consultant do not intend to rely upon certoln of the items identified in response to item B-21, explain why for each study, report, or source of information.
l i
{
l B-21.4 Provide any and all documentation relevant to the items l
I identified in response to B-21.
l Answer:
SLOMFP objects to the portion of this interrogatory that requests identification of all studies, reports and information within the knowledge or possession of SLOMFP or its consultants.
SLOMFP additianolly L
objects to PG&E's request to explain why certain information will not be used in the cose.
This information will obviously be irrelevant to the
(
cose and will not assist PGSE in the preparation of its cose.
These requests are overly brood and burdensome; SLOMFP requests the issuance of a protective order.
Regarding the other portions of the request, SLOMFP has l
not received all documents requested from PG&E regarding this issue.
Nor hos the SLOMFP determined which items will be relied upon in the cose.
SLOMFP will provide this information to PG&E in a timely fashion.
Interrogatory B-22:
Identify all documents and all sources of information avoilable to MFP or its consultants pertaining to missed fire watches within the commercial nuclear power industry and/or at DCPP.
l B-22.1 Does MFP intend to rely upon any of this information to l
support Contention U?
If so, in each cose explain how.
l B-22.2 If MFP does not intend to rely upon certain of the information identified in response to B-22, explain why for each document, report, or source of information.
B-22.3 Provide any and all documentation relevant to the information provided in response B-22.
Answer:
Refer to answer to Interrcgatory B-21.
Interrogatory B-23:
MFP asserts that " human observers are not completely reliable.
They make mistakes."
Supplemental Petition, at 29.
E-23.1 Explain the factors, events, and conditions which leod to the osserted "unrellobility" cf human observers.
B-23.2 Uhot kinds of "mistokes" do human observers make?
Explain the factors, events, and conditions which lead to these 'mistokes?"
B-23.3 Identify and provide copies of any and all reports, documents, and sources of information which indicate that "mistokes" of this type have in fact occurred at DCPP.
Explain why they support Contention U.
i l
l
l l
l s
Answer:
" Personnel error" is the common " root cause" of missed fire l
l watches and the failure to establish fire watches when needed due to
)
l inoperable fire protection equipment or degraded barriers.
Often these I
l l
personnel errors are o result of inodequate instructions.
SLOMFP hos not
)
yet received all of PG&E's discovery responses and has, therefore, yet to ottoin all information that indicates these types of situations.
SLOMFP I
l will identify the incidents that it intends to use in testimony when that has been determined.
Interrogatory 24:
What consequences do open fire dnors have on the implementation of interim compensatory fire protection measures ut DCPP?
In what way do they support Contention U?
Answer:
An open fire door creates o non-functional fire barrier.
Open fire doors therefore have consequences for both general and compensatory fire protection measures at DCNPP.
Situations involving fire protection f
measures in which the personnel exhibit carelessness or inadequate training support Contention U.
Interrogatory 25:
What consequences do unlotched fire doors have on the implementation of interim compensotory fire protection measures at DCPP?
In what way do they support Contention U?
Answer:
The lotch on a fire door is port of the tested, fire rated door r
assembly.
An unlotched fire door creates o non-functional fire barrier.
Unlotched fire decrs therefore have consequences for both general and j
compensatory fire protection measures at DCNPP.
Situations involving fire-protection measures in which the personnel exhibit corelessness or inadequate training support Contention U.
i l
i i
I
UNITED STATES OF AMERICA j
NUCLEAR REGULATORY COMMISSION i
ATOMIC SAFETY AND LICENSING BOARD In the Matter of Pacific Gas and Electric Company Docket Nos. 50-275-OLA-2 Diablo Congon Nuclear Power Plant 50-323-OLA-2 i
Units 1 and 2 ASLBP No. 92-EB9-03-OLA-2 Facility Operating Licenses No. DPR-80 and DPR-82 April 8, 1993 AFFIDAVIT I,
Jill K.
ZomEk, the Treasurer on the Doord for Son Luis Obispo i
Mothers for Peace, have provided the information for the " Son Luis Obispo l
Mothers for Peace Response to Second Set of Interrogatories and Request for l
Production of Documents Filed by Pacific Gas and Electric Company."
The information contained in the referenced interrogatory answers and i
responses to requests for documents is true and correct to the best of my knowledge and belief.
l l
Ji 1 K.
Zamf '
Scte of California County of Son Luis Obispo Sworn and subscribed to before me this [_ _ dog of April, 1993
^'"
^ ^ ' " ^ " ' ^
Gg--
hu~'lic~~~
"{,;t PATSY JEN4 CHM 4CEY h d
COMM. #967529
'. [ff simusocnrocotmY tomy rusuc.cautomrA 8 o %{ ger~ My comm. Expres June 17.199ff r
-- h-'/) - [-(p- ----
i4
s r
My commission expires
m
't r t 4
'93 AFP12 P5 15 Certificate of Service I hereby certify that copies of the foregoing Son Luis Obispo f1others for Peace Response to Second Set of Interrogatories and Request fcr Production of Documents Filed by Pacific Gas and Electric Company and riotion for Protective Order and Intervenor Son Luis Obispo flothers for Peace Response to flemorandum and Order [ Addendum to FES) have been served upon the following persons by U.S.
mail, first class.
Office of Commission Appellate Administrative Judge Adjudicotlon Charles Dechhoefer, Chairman U.S.
fluclear Regulatory Commissaan Atomic Safety and Licensing Board Uoshington, DC 20555 U.S.
fJuclear Regulatory Commission Uushir.gton, DC 20555 Administrative Judge Jerry Kline Administrative Judge Atomic Safety and Licensing Doord Frederick J.
Shon U.S.
fJuclear Regulatory Commission Atomic Screty and Licensing Board Uoshington, DC 20555 U.S.
fJuclear Regulatory Commission Ucshington, DC 20555 Edward O'fJelll l
Ann P.
Hodgdon, Esq.
Peter nrth, Jr.
l Office of the General Counsel Truman Curns U.S.
Nuclear Regulatory Commission Robert Kinosion Uoshington, DC 20555 Peter G.
fairchild, Esq.
California Public Utilities Commassion Joseph B.
Knotts, Jr, Esq.
505 Uon fJess Avenue Winston & S t r a tu n Son Francisco, CA S9102 1900 L Street, fJ. W.
Washington, DC 20005 Adjudicatory File Secretary of the Commission U.S.
!Juclear Regulatory Commissann Docketing und Service Cranch Unshington, DC 20555 U.S.
fjuclear Regulatory Commissaan l
Uoshington, DC 20555 Pobert R.
Cellington, Esq.
Diablo Ecnyon Independent Screty Committee B57 Coss Street, Suite D l
f1onterey, CA 93990 i
Chr2stopher Ucrner, Esq.
l Pichord Loc) e, Esq.
l Pacific Eus and Electric Co.
77 Eeole Street Son Franc 2sco, CA S9106
- A focsimile of Intervenor Son Luis Obispo flothers for Peace Response to I1emorandum and Order CAddendum to FES] was sent to Ann Hodgdom os requested by Judge Dechhoefer and communicated by telephone on April 6,
3903.
Dated April 6,
1993, Son Luis Obispo County, En Ji21 ZomEk f$D d