ML20041E244
| ML20041E244 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/01/1982 |
| From: | Mcclung C CITIZENS FOR ALTERNATIVES TO RADIOACTIVE DUMPING, FLEMMING, ANDERSON, MCCLUNG & FINCH, GUARD |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| ISSUANCES-OL, NUDOCS 8203100286 | |
| Download: ML20041E244 (16) | |
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PHYLLIS GALLAGHER, Esq.
2 1695 West Crescent, Suite 222 '
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Anaheim, CA 92801 3 CHARLES E. McCLUNG, JR., Esq. p g Fle~ ming, Anderson, McClung & Finch i
4 24012 Calle de la Plata, Suite 330 O N l
Laguna Hills, CA 92653 g RECsVED 4
- MAR 09 igggw !
6 Attorneys for Intervenors ~
7 Guard, Carstens, et al. {. saam%y Nm g mc ,
b 8 UNITED STATES OF AMERICA on 9 NUCLEAR REGULATORY COMMISSION 10 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL 11 BOARD 12 In the Matter of ) Docket Nos. 50-361 OL
) 50-362 OL 13 SOUTHERN CALIFORNIA )
EDISON COMPANY, et al., ) INTERVENORS' BRIEF IN SUPPCRT 14 OF EXCEPTIONS TO PARTIAL
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(San Onofre Nuclear Generating ) INITIAL DECISION WITH RESPECT 15 Station, Units 2 and 3) ) TO THE LOW POWER MOTION
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18 INTRODUCTION 19 The Intervenors respectfully submit that the Atomic Safety
.and Licensing Board ("ASLB") erred whe It lie ~ld'Inits Partial
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21 Initial Decision dated January ll, 1982 that th' eke' exists's'uffi-r o :s . ..w 22 cient emergency preparedness surrounding the SaMon'olre'Nu' clear -
23 Generating Station (SONGS) to protect public hea t and safety
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24 during a. low power operation at Unit 2'.- Ex.-8.- Neither'the Ap-plicants nor the NRC staff presented any evidence as to actual 26 1 ~
27 References to Intervenors' Exceptions and the Partial Initia1 De-cision will be cited "Ex. 1." and "PID at " respectively.
8203100286 820301 I (0
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I risk of the low power operation of Unit 2. The only evidenc'e pre-2 sented in this proceeding has been what the relative risk of 3 operating a pressurized water reactor ("PWR") like San Onofre Unit 4 2 would be at low power as compared to its operation at full power.
5 The evidence shows that absolutely no consideration was made of 6 any factors pertaining to the actual operation of Unit 2 at the 7 site. Intervenors submit that evidence must be presen'ted which 8 will demonstrate that the actual risk of operation of Unit 2 9 during low power testing will be low enough to justify the delayed 10 implementation of the emergency planning standards aet forth in 11 10 CPR Section 50.47 (b) (1) through (16). This has not been done 12 and therefore the alternative license for fuel loading and low 13 power testing should be denied.
14 ARGUMENT -
15 1 16 IN, ORDER TO JUSTIFY REDUCED EMERGENCY PLANNING 17 THE RECORD MUST DEMONSTRATE THAT THE ACTUAL 18 OPERATION OF THE SAN ONOFRE UNIT 2 AT LOW P WER 19 GIVEN SITE SPECIFIC FACTORS SUCH AS A CONTINUED 20 OPERATION OF UNIT 1 AND CONTINUED CONSTRUCTION 21 AT UNIT 3 WILL ACTUALLY BE OF LOW RISK TO TH'E 22 SURROUNDING COMMUNITY.
23 The issue posed in the low power portion of this proceeding 24 is a simple one. It is wheth.er or not there exists sufficient 25 emergency preparedness to protect the public health and safety 2
26 during fuel loading and low power testing at SONGS Unit 2. What 27 standard is to be applied to determine what sort of emergency 28 preparedness is necessary? Three standards have been proposed.
1 The first standard was proposed by the Applicants. Their 2 standard is emergency preparedness under low power operation of 3 any PWR would require an operational on-site emergency plan plus 4 the ability to communicate with the off-site surrounding juris-3 5 dictions. Pilmer at 7.
6 The Federal Em'e,rgency Management Agency (FEMA) testifying 7 as part of the Staff's case proposed a second standard. The 8 standard of FEMA is simply that the state in which the nuclear 9 power plant exists has an emergency plan which has received con-10 currence under the voluntary program where the Nuclear Regulatory 11 Commission (NRC) reviewed the state plans prior to the Three Mile 12 Island (TMI) accident and prior to the upgraded emergency planning 13 requirements. The on-site plan must also meet the pre-TMI require-14 ments. Tr. 11,310 (Nauman) 15 The third standard was that proposed by the Staff in the 16 testimony of Mr. Lauben and Dr. O'Reilly. That standard is essen-17 tially that no off-site plans are necessary at all so long as the 18 on-site capability to respond to emergency meets the pre-TMI plan-19 ning standards. Lauben at 9. These standards are similar.in that 20 .none requires any emergency preplanning by off-site jurisdictions 21 during low power operation. The ASLB adopted this view. Ex. 7.
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23 2 The issue reads:
"Whether there is reasonable assurance of adequate protection 24 to the h.ealth and safety of the public during fuel loading and low p wer testing, considering the risk to the public presented by 25 those activities and the level of emergency preparedness during those activities." PID at 217.
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27 Written testimony will be cited " Sears at , " "Nauman at
.28 , " etc. oral testimony will be cited to the tran-script with the notation of the person making the statement.
1 None of these standards (" low power standards") proposed by 2 the Applicants and FFFUL and the Staff and accepted by the ASLB 3 for determining what sort of emergency planning is necessary in 4 the low power situation require that the applicant demonstrate- ,
5 compliance with 10 CFR Section 50.47 (b) (1) through (16), the j 6 upgraded emergency planning regulations which arose out of the 6
7 TMI incident (the "New Rules"). The' assumption which underlies 8 the low power standards is that the New Rules of emergency pre- '
i during 9 paredness are not required under low power operation because/ low 10 power operation there is a substantial reduction in the risk of 11 accidents and the consequences of any accidents that might occur.
12 It is argued that emergency plans will have to meet the New 13 Rules before full power operation of a plant is allowed bu.t.it is 14 not necessary that upgraded emergency plans be in place at the 15 time of the low power operation of the plant. Thus, the plans 16 must meet'the New Rules but the New Rules are timed to take effect 17 before full power operation and not before. The decreased risk 18 of low power operation is said to justify the delay in the timing 19 of the application of the New Rules, i 20 No separate standard for the emergency planning required at 21 low power operation is set forth in the regulations. Therefore, 22 the low power standards proposed by Applicant, FEMA and the Staff 23 and accepted by the ASLB must arise out of the flexible section 24 10 CFR Section 50.47 (c) (1) . See In the Matter of Pacific Gas &
25 Electric (Diablo Canyon Nuclear Power Plant' Units 1 and 2) CLI 26 22, September 21, 1981 (Additional Views of Commissioner Ahearne.
27 at 2). Section 50.47 (c) (1)' provides that an applicant need not 28 meet the planning standards set forth in 10 CFR Section 50.47 (b) l _4_ ,
1 (1) through (16) if it can demonstrate "to the satisfaction of the 2 Commission that deficiencies in the plans are not significant for 3 the plant in question, that adequate interim compensating actions 4 have been or will be taken promptly, or that there are other com-5 pelling reasons to permit plant oteration." The low power opera-6 tion of a plant presents an obvious case where deficiencies in the 7 plans might not be "significant" as'provided in this section be-8 cause the risks of accidents may be reduced. It must be shown, 9 however, that the risk is actually low for the plant in question.
10 It is long settled NRC law that there is an evidentiary bur '
11 den en the Applicants to prove their case for any such exemption 12 by "prepon'derance of the evidence". See e.g. Consolidated Edison 13 Company of New York (Indian Point Nuclear Generating Station, Unit 14 3), CCH Nuc Reg Rptr. Page 30,027 (NRC 1975); Duke Power Company, 15 (Catawba Nuclear Stations, Units 1 and 2), ALAB-355, CCH Nuc Reg 16 Rptr Page 30,116 (1976); Consumers Power Company (Midland Plant, 17 Units 1 and 2), ALAB-315, 3 NRC 101 (1976). The magnitude of 18 this burden is influenced by the gravity of the matter in contro-19 versy. Virginia Electric and Power Company, (North Anna Power 20 Statio'n, Units 1 - 4), ALAB-256, 1 NRC 101 (1975). In this pro' .
21 ceeding where the matter in controversy is'the readiness of ef-22 fective emergency response action to protect public health and ,
23 . safety the applicants have the burden of making the most conclu-24 sive showing for an exemption from .the regulation. There is a 25 burden on the applicant to demonstrate by preponderance of evidence 26 that an exemption is warranted and there is a mandate for the 27 ASLB to deny the A'pplicants' requested license unless the letter 28 and spirit of the law are met. See, Vermont Yankee Nuclear Power i
1 Corporation (Vermont Yankee Nuclear Power Station) ALAB-l'38 .(197 3) 2 (" reactors may not be licensed unless they comply with all appli-3 cable standards").
4 The basis for the low power standards accepted by the ASLB 5 in this case is a generic study of the risk of low power operation 6 of any given plant versus the risk at full power. Accordingly, 7 the NRC staff and the Applicants in'this proceeding have put on 8 expert testimony to show why in a generic sense operation of'a 9 PWR at low power will have less risk than operating a PWR at full 10 powe'r. Intervenors submit.that this relative risk assessment, 11 while important, is not sufficient to guarantee the public health 12 and safety is protected around a given plant. Ex. 5. In addition 13 to this relative risk assessment an analysis must be made of the 14 site in question to decide actual risks. A dete,rmination must'be 15 made whether or not there are other factors which might increase 16 the risk 'such that the New Rules should come into effect. The 17 Intervenors believe that this requires a review of not only the 18 plant in question, but the site in question.to see whether the 19 delayed timing of new standards makes sense from a regulatory point ,
20 of view in any given case.
21 SONGS Unit 2 is surrounded by two other plants, Unit 1 22 which is a licensed reactor which has been operating since the 23 early 70's, and Unit 3 which is as yet unlicensed and which is 24 still under construction. Staff Exhibit 1 at 2-1. The Inter-25 venors assert that any study of the risk of operation of Unit 2 26 at low power must address whether or not those risks would be 27 increased by (1) the continued construction of Unit 3 and (2) the 28 ongoing operation of Unit 1.
l 1 It is clear that there are certain interrelationships between 2 Unit 1 and Unit 2 which could multiply the risk of operation of 3 Unit 2 at low power. This Board can take jbdicial notice of the
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4 fact that Unit 1 is on the same site as Unit 3 and that in fact i 5 the same fire water system and switching system are used for both ,
t 6 plants. In addition the testimony'of Mr. David F. Pilmer demon-7 strates that Unit 1 and Unit 2 have~ essentially the same emergency 8 plan. Indeed the exhibit attached to Mr. Pilmer's testimony which 9 is found after Transcript Page 11,243 is an NRC review of the Unit 10 1 emergency plan which is taken as evidence that Unit 2 emergency 11 plan on-site meets NRC criteria. In addition the emergency per-12 sonnel and' operating personnel for the two Units are the same.
13 Tr. 11,256 (Pilmer) . The overlapping geography and personnel 14 between Unit 1 and Unit 2 provide a narrowed margin of safety in ,
15 that the possibilities for dealing with any complications that'were i 16 to arise at Unit 2 during low power would be limited because of the f 17 ongoing operation of Unit 1. This might well entail shutting down l 18 ait 1 and other matters. Tr. 11,256 (Pilmer) .
19 The Board can take judicial notice of the fact that con-f 20
,struction of Unit 3 is ongoing. Indeed there are numerous inter'- ]
21 connected systems including control room between Unit 2 and Unit 22
- 3. Ex. 4. It is therefore clear that the issue of whether or not ,
23 .the. ongoing construction or unfinished character of Unit 3 could 24 increase the risk of an accident at Unit 2 during the low power 25 operation thereof must be addressed in order to provide reasonable 26 assurance of public safety.
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2 THERE IS NO EVIDENCE IN THIS PROCEEDING TO l
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. 3 DEMONSTRATE THAT THE OPERATION OF UNIT 2 i 4
AT LOW POWER IS ACTUALLY LOW RISK. S;[TE 5 SPECIFIC FACTORS WHICH MIGHT MULTIPLY THAT-6 RISK WERE NOT CONSIDERED. ACCORDINGLY THE 1
7 APPEAL' BOARD SHOULD REVERSE THE FINDING BY THE 8 ASLP THAT THE PUBLIC HEALTH AND SAFETY WILL BE l 9 PROTECTED DURING THE OPERATION AT LOW POWER OF - ,
4 10 UNIT 2. ,
11 An analysis of the record in this case indicates that f 12 neither the Applicants, FEMA nor the NRC sta5f addressed any site '
13 specific factors which may have increased.either the risk,of an 14 accident during the low power operation of Unit ,2 or the possible consequences of any s'uch accident. In some cases the ASLB did not i 15 16 illow questions into these issues. In retrospect-these were errors 17 which must be rectified in order to issue a license as requested
}g by the Applicants in this alternative proceeding. Ihtervenorse l
19 were concerned that because of the ongoing operation of Unit 1 at !
l 20 the si~te during the low power operation of Unit.2 there'might be.
21 significant enough risk so that the NRC should require that the 22 New Rules be complied with. It did not seem to. make. sense to 23 apply a standard of decreased emergency planning in a situation 24 where a nuclear plant already existed at the site. If the new ,
25 plant to be operated at low power is the only plant at the site, 26 then perhaps the delayed' implementation of the emergency planning 27 New Rules would make sense. This is not the case at San Onofre. ;
i 28 Unit 1 is.and has been an operating nuclear plant for over ten ;
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1 years. Intervenors submit that the Applicants should be required 2 to comply with emergency planning regulations currently in effect 3 before they are allowed to put a new plant on line at the site.
4 It is for this reason that the Intervenors submitted their proposed 5 contention in the low power hearing-
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6 "Whether Applicants have sufficiently demonstrated that a 7 radiological emergency at SONGS 2 and 3 could not cause a radio-8 logical emergency at SONGS 1". PID at 218. This contention was 9 rejected by the Board essentially on the grounds that it lacks 10 specificity. But the issue was clear, simply does the low power 11 operation of the Unit 2 increase the risk of operation of Unit 1 12 and conversely does the operation of Unit 1-increase the risk 13 during low power operation of Unit 2. All involved in the hearing 14 understood the questions being posed by the Intervenors. Feighed 15 ignorance of the' Intervenors' intent allowed the ASLB to dismiss 16 the contention as vague. This was error. Ex. 1. This error was 17 continued throughout the nearing process as the ASLB excluded 18 questions which seemed to relate to the Intervenors' concern with 19 respect to the ongoing construction of Unit 3 and the ongoing
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20 operation of Unit 1.
21 Intervenors first addressed the issue of whether or not the 22 ongoing construction at Unit 3 would increase the risk of an acci- ,
23 . dent at Unit 2 during low power. This guestion was put by Mr.
24 McClung to the Applicants' witness,.Mr. Buttemer, at Transcript 25 page 11,213. This line of questions was objected to by the Appli-26 cants and the objection was sustained on the basis that it was 27 beyond the scope of the issue. The issue was whether there was 28 reasonable assurance that there would be adequate protection to the
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b 1 health and safety of the public during fuel loading and low 2 power testing. The question o f whether or not the ongoing con-struction at Unit 3 would increase the risk was properly within
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3 4 this issue. It was foreclosed because it was confused with the 5 Intervenors' contention which was rejected earlier. Intervenors 6 feel that this question must be addressed in order'to determine 7 the actual risk of operation of Unit 2 at low power. Ex. 2.
i 8 Mr. Grimes testifying for the Staff indicated (Tr. 11,343) g that the NRC position was essentially a generic comparison of,the 10 risk' of low power operation of a plant versus the risk at full 11 power. Intervenors attempted to question whether Mr. Grimes thought I 12 it would be necessary to consider the additional risks which 13 might be posed by the operation of an operating reactor at .the 14 same site as the low power testing of Unit 2. Tr. 11,345. That 15 line of questioning was objected to by the staff and the Appli-16 cants and the objection was sustained on the basis that it was 17 beyond the scope of the issue. Tr. 11,346. Ex. 3.
18 With respect to the' consideration of other site specific i 19 factors, including the ongoing operation of Unit 1, none of the 20 witnesses made any study of either the possible increase in pro-21 bability of accident or the possible increase of consequ'ences 22 which may be caused by the ongoing operation of Unit 1 during the 23 low power testing of Unit 2.
24 Mr. Buttemer, Applicants' expert witness on the risk of low .
25 power operation, indicated that he made no ' site specific analysis 26 of the' probability of accidents at San Onofre plant (Tr. 11,208) 27 and he made no site specific analysis of the consequences of any 28 particular sequence which might be postulated for the plant
e 1
(Tr . 11,215 (Buttemer).
2 The Applicants' witness, Mr. pilmer, who was to testify about 3
the need for emergency planning during low power also did not 4 make any site specific analysis of the' probability of accidents at 5 the plant. Tr. 11,249 (Pilmer). Although Mr. Pilmer indicates 6 in his testimony that he did think about the'possible site specific 7 consequences of accident' sequences he did not take into considera-8 tion the possible fision releases at Unit 1. Tr. 11,264, 11,273 9 (Pilmer).
10 The staff witnesses also did not take into account these 11 considerations. Mr. Nauman from FEMA testifying as part of the staff's ca'e s indicated that the FEMA review consisted simply of 12 13 determining whether or not there was a State of California plan 14 which had received NRC concurrence. He indicated that this was essentially a file checking procedure. Tr. 11,311 (Nauman) ;
15 16 see also Tr. 11,356 (Grimes).
17 The NRC's expert witnesses in risk analysis, Mr'. Lauben and 18 Dr. O'Reilly,indicatedthat they did not consider any site specific 19 aspects with respect to their assessment of the risk, (b~oth pro-bability wise and consequence wise) of the low power operation of 20 21 Unit 2. Tr. 11,326. They testified additionally that they did 22 not consider the operation of Unit 1. Id. The NRC team indicated .
23 .they just performed a relative risk analysis and that it was not 24 necessary to do any site specific analysis *because they were not
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25 looking for actual risks. Tr. .1,327 (Lauben).
26 It is clear from a record in this proceeding that the various 27 expert witnesses for the Applicants, the NRC staff and FEMA did 28 not consider any site sper'fic aspects which would cither increase O
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I the risk of an accident at San Onofre Unit 2 during low power or l 2 which might increase the consequences of an accident at. San Onofre 3 Unit 2 during low power operation. Intervenors' questions in this l lI 4 regard were wrongfully excluded by the Board. Intervenors would 5 therefore submit that it is impossible for this Board to make a 6 finding that there is, reasonable assurance that the public health I
7 and safety will be adequately protected at San Onofre'and sur- !
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8 rounding San-Onofre site. Ex. 8. !
9 III 10 THE EMERGENCY PREPAREDNESS SURROUNDING THE 11 SAN ONOFRE NUCLEAR GENERATING STATIONS DOES (
12 NOT MEET THE STANDARDS SET FORTH IN 10 CFR f 13 50.47 (a) . THERE IS NOT REASONABLE ASSURANCE 14 THAT THE PUBLIC HEALTH AND SAFETY WILL BE PRO-15 TECTED IN THE EVENT OF A RADIOLOGICAL RELEASE [
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'WITH OFF-SITE CONSEQUENCES.
17 The ASLB did not consider the status of the off-site emer-
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18 gency preparedross pursuant to the low power motion becaus'e it 19 was deemed unn.cessary. Ex. 7. Intervenors will therefore only
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20 briefly point out that at the present time the status of emergency ,
21 preparedness off-site does not meet the standards of the New Rules.
22 As determined by the FEMA findings (URC Staff Exhibit 11), the 23 status of off-site emergency preparedness is not capable of being 24 implemented. The Applicants have proposed an action _ plan to 25 remedy these deficiencies but that action plan has not been com-26 1 pleted in significant respects. Intervenors are particularly con-27 cerned about the capability of off-site agencies to monitor radio-28 active release and to assess the consequences thereof and to take
I coordinated and effective protective action response. This capa-2 bility has not yet been demonstrated and it is crucial to effective 3 cmergency planning. See Updated FEMA evaluation added to the 4 record by motion of the Staff, December 2, 1981, IV A.F.,G,H. b 5 Indeed the Applicants admit this on the record by proposing to meet 6 these standards through the exemption provided in 10 CFR 50.47 (c) 7 (1). Tr. 11,039. They have attempted to show in thsir brief and 8 findings of fact in the full power case that these regulatory 9 standards are satisfied by the on-site capacility (Applicants' 10 Findings, 213-214). Intervenors submit that this has not been 11 done and thus there are significant deficiebcies in the plans 12 which impact upon the public health and safety such that the ASLB 13 erred when it made a finding of adequacy at this time. Ex. 8.
14 CONCLUSION 15 In conclusion the Intervenors respectfully submit that the 16 rationale which underlies postponing of the timing of the com-17 pliance with the upgraded emergency planning standard's contained 18 in the regulations 10 CFR Section 50.47 et seq. from the low 19 power stage to the full power licensing stage does not apply in 20 the San Onofre case because there is an existing and ongoing 21 reactor at the site. Accordingly, it is clear that the upgraded 22 emergency standards should be complied with before a new reactor 23 is licensed at this particular site. The Applicants and the ASLB 24 have not even attempted to demonstrate such compliance. The ASLB 25
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i 1 order granting the low power license should therefore be reversed.
2 3 Respectfully submitted, 4 PHYLLIS M. GALLAGHER, Esq.
CHARLES E. McCLUNG, JR. of 5 Fleming, Anderson, McClung &. Finch
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'82 12R -5 A10 :34
~ UNITED STATES OF AMERICA O
NUCLEAR REGULATORY COMMISSJON LT -
.a. z.
BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD ,
~ "
In the Matter of )
) Docket Nos. 50-361 OL SOUTHERN CALIFORNIA EDISON COMPANY, ) 50-362 OL ET AL. ) ,
)
(San Onofre Nuclear Generating Station,)
Units 2 and 3) )
CERTIFICATE OF SERVICE I hereby ce'rtify that copies of the'INTERVENORS BRIEF IN SUPPORT OF EXCEPTIONS TO PARTIAL INITIAL DECISION WITH RESPECT TO THE LOW POWER MOTION dated February 26, 1982 in the above captioned proceedings were served on the following parties by deposit.in .
the United States Mail on March 1, 1982.
- Stephen F . Eilperin, Esq. .
Chairman, Atomic Safety and Licensing Appeal Boeard U.S. Nuclear Regulatory Commission Washington, D .,C . 20555 James L4 'Kelley, Esq., Chairman David,R. Pigott, Esq.
Administrative Judge Samuel B. Casey, Esq.
Atomic Safety and Licensing Board John A. Mendez, Esq.
U.S. Nuclear Regulatory Commission Edward B. Rogin, Esq.
Washington, D.C. 20555 of Orrick, Herrington & Sutcliffh
. A Professional Corporation Dr. Cadet H. Hand, Jr., 600 Montgomery Street Administrative Judge San Francisco, California 94111 c/o Bodega Marine Laboratory University of California Alan R. Watts, E q.
P.O. Box 247 Daniel K. Spradlin Bodega Bay, California 94923 Rourke & Woodruff l 1055 North Main Street, #1020
- Dr. Reginald L. Gotchy Santa Ana, California 92701 l j
Atomic Safety and Licensing *
. Appeal Board
- Dr. W. Reed Johnson U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board i U.S. Nucl' ear Regulatory Commissid
. . Washington, D'.C. 20555- -
,Mrs. Elizabeth B. Johnson, Richard J. Wharton, Esq.
Administrative Judge .
University of San Diego Oak Ridge National Laboratory School of Law Alcala P. ark P. O. Box X, Building 3500 San Diego, California 92110 Oak Ridge, Tennessee 37830 -
Mrs. Lyn Harris Ficks Janice E. Kerr, Esq. GUARD J. Calvin Simpson, Esq. 3908 Calle Ariana .
Lawrence O. Garcia, ESg. .
San Clemente, California 92672 7
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California Utilities Commission 5066 State Building , A. S. Carstens San Francisco, California 94102 2071 Caminito Circulo Norte Mt. La Jolla, California 92037 Charles R. Kocher, Esq.
James A. Beoletto, Esq. ,
Southern California Fdison Company Lawrence J.' Chandler, Esq.
4244 Walnut Grove Avenue Donald Hassel, Esq. -
Rosemead, California 91770 U. S. Nuclear Regulatory Commission David W. Gilman ,0ffice of the Fxecutive Robert G. Lacy Legal Director San Diego Gas & Electric Company Washington, D.~C. 20555 P. O. Box 1831 .
San Diego, California 92112 Atomic Safety and Licensing l Appeal Board Panel '
Phyllis'M. Gallagher, Esq. U. S. Nuclear Reculatory 1695 West Crescent Avenue Commission I Suite 222 ,
Washincton D. C.
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20555 Anaheim, California _92701 Secretary ,
Robert Dietch, Vice President U. S. Nuclear Regulatory Comm.
Southern Edison California Company Attn: Chief, Docketing.&.
P. O. Box 800 Service Branch 2244 Walnut Grove Avenue Washington, D. C. 20555 Rosemead, California 91770 M &
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