ML20053D081
| ML20053D081 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/26/1982 |
| From: | Pigott D ORRICK, HERRINGTON & SUTCLIFFE, SAN DIEGO GAS & ELECTRIC CO., SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC COMMISSION (OCM) |
| References | |
| ISSUANCES-OL, NUDOCS 8206040042 | |
| Download: ML20053D081 (14) | |
Text
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_4 DAVID R. PIGOTT EDWARD B. ROGIN
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Aj:43 SAMUEL B. CASEY U"
JOHN A. MENDEZ Of ORRICK, HERRINGTON & SUTCLIFFE A Professional Corporation n
600 Montgomery Street
?1 San Francisco, California 94111 Telephone: (415) 392-1122 CHARLES R. KOCHER JAMES A.
BEOLETTO SOUTHERN CALIFORNIA EDISON COMPANY P.O.
Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Telephone: (213) 572-1212 Attorneys for Applicants Southern California Edison Company, San Diego Gas & Electric Company, City of Anaheim, California and City of Riverside, California UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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SOUTHERN CALIFORNIA EDISON
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DOCKET NOS. 50-361 OL COMPANY, et al.
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50-362 OL
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(San Onofre Nuclear Generating
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Station, Units 2 and 3).
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APPLICANTS' OPPOSITION TO CARSTENS,.
ET AL. APPLICATION FOR STAY OF LOW POWER LICENSE (10 C.F.R.
$ 2.788) AND APPEAL FROM DENIAL OF STAY MOTION BY THE ASALB.
Dated:
May 26, 1982.
s206040042 e20526 PDR ADOCK 05000361 3
G PDP j
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STATEMENT OF CONTESTED ISSUES 1.
Whether as the result of ground motion analysis techniques developed subsequent to issuance of the construction permit or data gathered from earthquakes which occurred subsequent to issuance of the construction permit, the seismic design basis for SONGS 2 & 3 is inadequate to protect the public health and safety.
2.
Whether characterization of certain offshore geologic features as a zone of deformation, I
referred to as the Christianitos Zone of l
Deformation (CZD), or whether any additional l
information about the CZD which became available subsequent to issuance of the construction pernic render the seismic design basis for SONGS 2 & 3 l
inadequate to protect the public health and safety.
l 3.
Whether the seismic design basis for SONGS 2 & 3 is inadequate to protect the public health and safety as a result of discoveries subsequent to issuance i
of the construction permit of the following I
geologic features:
(1)
ABCD features at the site.
(2)
Features located at Trail 6, Targe: Canyon, Dead Dog Canyon, Horno Canyon, and " onshore faults E and F".
(3)
Such other features as the parties may agree are relevant to the seismology of the SONGS site or with respect to which Intervenor Friends of the Earth makes a threshold showing of relevance.
4.
Whether based on the geologic and seismic characteristics of the OZD, including its length, assignment of Ms7 as the maximum magnitude earthquake for the OZD renders the seismic design basis for SONGS 2 & 3 inadequate to protect the public health and safety, i
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TO THE NUCLEAR REGULATORY COMMISSION:
I INTRODUCTION on May 11, 1982, there was served "Intervenors',
Carstens, et al. Application for Stay of Low Power License (10 C.F.R. 2.788) and Appeal from Denial of By [ sic] the ASLAB" ("Intervenors' Appeal").
Pursuant to 10 C.F.R. 2.788(d), Southern California Edison Company, San Diego Gas &
Electric Company, City of Anaheim, California, and City of Riverside, California (" Applicants") hereby file their response in cpposition to Intervenors' Appeal.
Intervenors' current attempt to obtain a stay of the fuel loading and low power testing license granted for San Onofre Nuclear Generating Station, Unit No..1 (" San onofre Unit 2") does net present any allegation of substance that was not considered and rejected both by the Atomic Safety and Licensing Board (" Licensing Board") in its Partial Initial Decision ("PID") of January 11, 1982, and the Atomic l
Safety and Licensing Appeal Board (" Appeal Board") in its Decision of April 26, 1982 denying Intervenors' request for a stay of the PID.
II INTERVENORS AGAIN FAIL TO ALLEGE FACTS THAT WOULD ALLOW TIiEM TO PREVAIL ON APPEAL.
Intervenors correctly recite the four factors to be considered in determining an application for a stay pending
appeal.
10 C.F.R. 5 2.788)(e).
Intervenors' Appeal again fails to meet these regulatory requirements.
A.
The Board Did Not Commit Error In Refusing To Allow Intervenors To Litigate The Capability of The Cristianitos Fault.
Intervenors once again allege that they were improperly foreclosed from litigating whether the Cristianitos fault is capable.
Intervenors correctly allege that the Cristianitos fault is located about one-half mile from the site and that if it were shown to be capable, "perhaps" that would be crucial to the safety of the site.
Beyond these two allegations, Intervenors' contentions are not supported by the facts.
The Cristianitos fault has been examined extensively.
As early as the Initial Decision granting a permit for the construction of SONGS Unit No.
1, the Licensing Board specifically found, in paragraph 22 of that Decision, that the Cristianitos is "an inactive fault."
In the Matter of Southern California Edison Company, et al.,
2 AEC 366 (1964).
At the proceedings for a Construction Permit
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for SONGS Units 2 & 3, the site geology and seismology were considered and a portion of that cubject specifically l
litigated.
The Cristianitos was investigated and reviewed by Applicants and NRC Staff.
The Staff Safety Evaluation Report, CP Stage, E 3.1.4 concluded that the Cristianitos fault is inactive when evaluated against the then proposed l
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criteria of 10 C.F.R. Part 100, Appendix A.
The Cristianitos fault has not been a specific litigation issue, but has been examined and considered in previous licensing procedures with respect to the San Onofre site.
In considering Intervenors' contentions it should be noted that as of December 6, 1977, these same Intervenors did not consider the Cristianitos to be a capable fault.
Prehearing Conference Transcript, Dec. 6 ', 1977, pp. 23-25.
As of that prehearing conference, Intervenors did not have and did not claim to have any factual basis, as required by 10 C.F.R. 5 2.714, to raise the capabilit'y of the Cristianitos fault as a contention in the operating license proceedings.
As of April 29, 1981, the date of the final prehearing conference, seismic, these sama Intervenors still had not stated a basis for raising the issue of the capability of the Cristianitos fault.
Subsequent to that prehearing conference, Intervenors submitted " Revised r
l Contentions Submitted By Intervenors FOE, et al.",
dated May 5,
1981.
Paragraph (h) of that pleading attempted to raise the capability of the Cristianitos fault as an issue in the operating license proceeding.
The Intervenors presented no l
l factual basis for their allegation and the Board properly l
rejected the proposed issue for " lack of specificity."
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Revised Prehearing Conference Order, dated May 29, 1981, at page 6.
Thus, as of the commencement of the seismic 3
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4 hearings, Intervenors had been unable to state any basis for an issue questioning the capability of the Cristianitos fault.
Intervenors argue that the Board erred in
" foreclosing" their proposed issue based on principles of res judicata.
Applicants submit that the essential point in the Board's handling of the issue is that it did not rely on and specifically disavowed the applicability of the judicial doctrine of res judicata and collateral estoppel to the present case.
PID, p.
23.
Intervenors argue that because there is no
" identity of the parties" or " prior adjudication" as defined in the judicial application of the doctrine, they have an absolute right to raise the Cristianitos issue without i
stating a basis.
The Licensing Board's overall holding is:
The Board determined that the prior opportunity to litigate the capability of the Cristianitos at the Construction Permit stage foreclosed the relitigation of that question in this proceeding, absent a sufficient showing of changed circumstances, a showing that was not i
l made.
(PID,
- p. 21.)
The Board's holding is equally applicable to a new Intervenor or one previously involved in the proceeding.
The presence or absence of the elements of res judicata is irrelevant.
Pursuant to Contention No.
1, Intervenors could l
have submitted evidence that data from earthcuakes which 1
[
occurred subsequent to issuance of the Construction Permit I
showed the seismic design basis for SONGS 2 & 3 to be inadequate. Intervenors attempted to submit such evidence 1
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through the cross-examination of Applicants' and NRC Staff witnesses, as well as the direct testimony of their own witness, Mr. Simons.
The testimony of Mr. Simons was struck because, among other reasons, it lacked probative value.
Intervenors were also unable to support their position through cross-examination of Applicants' and NRC Staff witnesses.
B.
Foreclosure Of Intervenors' Proposed Cristianitos Issue Did Not Improperly Impact the Proceedings.
Intervenors complain that the primary deficiency in the FID is that all of Intervenors' testimony regarding the capability of the Cristianitos fault, both before and after issuance of the CP, was stricken from the record.
Intervenors' Appeal, p.
4.
Intervenors refuse to recognize that their proposed testimony was submitted to the Licensing Board, was the subject of cross-examination and was struck for good reason -- it lacked probative value.
(Transcript 4593-4611; 4778-4859.)
The effect of the Licensing Board's determination was to preclude Intervenors from litigating a baseless issue.
There was no impact on the trial of the admitted contentions.
C The Issue Of The Capability Of The Cristianitos Fault Was Not Within The Scope Of Contention No.
3.
Intervenors present a new argument, not raised before either the Licensing Board or the Appeal Board: that Contention No. 3 included the question of capability of the 5
Cristianitos fault.
Intervenors' Appeal, p.5.
Applicants note that Intervenors argument is made without any reference to the transcript.
Applicants submit that this is because the question of the capability of the Cristianitos fault was never presented as being a part of Contention No.
3.
' Contention No. 3 was an " update" issue with respect to the geology of the area surrounding the site.
It was the purpose of this issue to assure that there was not some newly discovered feature that could effect the seismic design of the plant.
Prehearing Conf. April 29, 1980, TR 311-314; 318-320.
Contention No. 3 lists a number of geolcgic features that were discovered subsequent to issuance of the Construction Permit.
The issue was left partially open in order that Intervenors be allowed to show that some otherwise overlooked feature may have a bearing on the seismic design of the plant.
Had Intervenors attempted to raise the issue under Contention No.
3, it would have been rejected.
To the extent Intervenors proposed evidence related to matters subsequent to issuance of the CP, it would have been appropriate under
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Contention No.
1.
To the extent Intervenors proposed l
evidence related to geologic features known of and considered i
prior to issuance of the CP, it would have been beyond the l
scope of the admitted issues.
Intervenors' proposed issue does not fall within Contention No.
3.
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D.
The Boards Have Correctly Characterized The Geologic Nature Of The Offshore Zone Of Deformation.
Intervenors' Appeal (page 6) again raises the issue of whether the Offshore Zone of Deformation, the controlling structure for the seismic design of San Onofre Units 2 & 3, has been correctly characterized by the Licensing and Appeal Boards.
Intervenors add nothing that has not already been considered.
Intervenors argue that the Appeal Board erred in accepting the Licensing Board's characterization of the Offshore Zone of Deformation.
Intervenors provids no additional basis for a finding that they are likely to pre' vail on the merits of their argument.
E.
Intervenors Restatement Of Arguments Made Both To The Licensing Board And The Appeal Board Do Not Constitute Ground For Granting A Stay.
Intervenors' Appeal (pages 7-8) restates substantive arguments they have made throughout the proceeding.
Intervenors argue that Dr. Slemmons, the NRC Staff, Applicants, the Licensing Board, and the Appeal Board all have failed to correctly apply the data set forth in the testimony of NRC Staff's witness Dr. Slemmons.
Intervenors' argument has been regularly rejected.
Intervenors add nothing in their application that would indicate the previous rejections were unfounded.
Intervenors also reiterate their construction of the testimony of Dr. Boore and Dr. Luco.
Again, the 7
testimony of Dr. Boore and Dr. Luco has been considered by both the Licensing Board and the Appeal Board in coming to their determinations.
Intervenors disagree with their findings but present no additional reason why those Boards are wrong.
III INTERVENORS HAVE FAILED TO SHOW
, POTENTIAL IRREPARABLE INJURY.
Intervenors again rely on an inappropriate definition of " irreparable injury",
i.e.,
that it is not subject to pecuniary measurement and damage could exceed the limits of the Price-Anderson Act.
Intervenors have failed to demonstrate the type of irreparable injury prerequisite to issuance of a stay.
Public Service Company of Indiana (Marble Hill), ALAB-487, 6 NRC 630, 632 (1977); Philadelphia Electric Company (Peach Bottom), ALAB-158, 6 AEC 999 (1973).
Intervenors' speculation on the likelihood and consequences of a nuclear accident during the appeal period is not the irreparable injury that justifies a stay.
_ State of New York v. NRC, 550 F.2d 745, 756-57 (2d Cir. 1977);
Virginia Sunshine Alliance v. Hendrie, 477 F.Supp. 68, 70 (D.D.C. 1979).
IV THE GRANT OF A STAY WOULD HARM APPLICANTS AND WOULD NOT BE IN THE PUBLIC INTEREST.
Intervenors' arguments that the grant of a stay will not inordinately harm Applicants and will facilitate a 8
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4 later fuel conversion or seismic upgrade are incorrect.
Applicants' substantive response to their argument was set forth in " Affidavit of Robert Dietch" submitted as a part of
" Applicants' Response in Opposition to Intervenors Carstens, et al's Application For a Stay."
A copy of that affidavit is attached.
The significance of this harm to Applicants has been recognized.
Public Service Co. of Indiana (Marble Hill), ALAB-487, 6 NRC 630, 634 (1977); Florida Power & Light Company (St. Lucie), ALAB-404, 5 NRC 1185, 1188 (1977).
P.pplicants fuel loading is complete and the low power tests are proceeding essentially as scheduled.
Granting a stay would seriously interrupt this program.
It should also be noted that on May 14, 1982, the Atomic Safety and Licensing Board issued its Initial Decision which resolved the remaining emergency planning issues and authorized issuance of a full power operating license.
The "public interest" lies with preserving the presumption of validity that attaches to the Licensing and Appeal Boards decisions in the absence of a substantial ~
reason for a stay.
Florida Power & Light Company, supra, 5 NRC at 1189. Inte-venors have failed to make such a showing.
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1 The public interest requires that Intervenors' stay request t
be denied.
Dated:
May 26, 1982.
Respectfully submitted, DAVID R. PIGOTT E D W A R D '3. ROGIN SAMUEL B. CASEY JOHN A. MENDEZ Of ORRICK, HERRINGTON & SUTCLIFFE i
A Professional Corporation CHARLES R. KOCHER JAMES A. BEOLETTO SOUTHERN CALIFORNIA EIDSON COMPANY By David R.
Pigott Counsel for Applicants j
10
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of SOUTHERN
)
Docket Nos. 50-360 OL CALIFORNIA EDISON COMPANY,
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50-361 OL et al. (San Onofre Nuclear
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AFFIDAVIT OF ROBERT DIETCH Generating Stition,
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IN OPPOSITION TO INTERVENORS' Units 2 and 3).
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APPLICATION FOR STAY OF LOW
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POWER LICENSE State of California,
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ss.
County of Los Angeles. )
I, Robert Dietch, being first duly sworn, declare that if called to testify in this proceeding, I could competently do so, as follows:
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l 1.
At all pertinent times referred to herein, I have been employed by Southern California Edison Company
("SCE") as Vice President, Nuclear Engineering and operation.
In this capacity, I have direct management responsibility for Nuclear Regulatory Commission ("NRC")
licensing proceedings and for the operation of the San Onofre Nuclear Generating Station (" SONGS").
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2.
The purposes of this affidavit are to t
demonstrate that construction of SONGS Unit 2 is complete; that Applicants are prepared to commence the fuel-loading and low-power testing program fer SONGS Unit 2 in February,,1982; that to Applicants' knowledge there are no unresolved issues barring the issuance of the fuel-loading and low-power testing license for SONGS Unit 2; that it appears to n o.1, in n,
1 m C 2 X y c A i g u tf'7~-
Applicants at this time that such issuance is imminent; that any delay in the Project Schedule for any reason, including the grant of the stay requested by the Intervenors, will result in substantial and irreparable injury to Applicants, Applicants raiepayers, and the environment; and that the
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l radioactivity created by the low power testing program will not preclude the Applicants' capability to implement any plant modifications that may be required by the NRC.
1 3.
On January 11, 1982, the Atomic Safety and i
Licensing Board (the " Board") of the United States Nuclear Regulatory Commission ("NRC") issued its Partial Initial Decision and Order authorizing issuance of a fuel-loading and low-power testing license for SONGS Unit 2.
Under the NRC's Rules of Practice, the Board's Order is immediately effective and requires issuance of the license authorized by the initial Decision and Order within ten (10) days from the date of the decision or as soon thereafter as the NRC's Director of Nuclear Reactor Regulation (the " Director") can make the l
findings required by 10 C.F.R. l 50.57(a).
The Partial Initial Decision and Order also required that the onsite Emergency Plan for SONGS Units 2 and 3 be in effect.
l 4.
Since issuance of the Partial Initial Decision l
and Order the following items noted by Intervenors in thei.r Application for a Stay have been completed:
4.1 The NRC Staff has announced that the required number of Senior Reactor Operators are now l
qualified to operate SONGS Unit 2.
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4.2 An independent consultant has submitted to the Director a report on the Seismic Design Verification Program for SONGS Unit 2.
Applicants have no reason to believe that this report is insufficient to justify issuance of a fuel-loading, low-power testing license for SONGS Unit 2.
- 5.. The onsite Emergency Plan i'or SONGS Units 2 and 3 has been fully implemented, including complete ir.plementing procedures and accomplishment of all required l
training.
The NRC Staff has completed its inspection and is l
currently preparing its report to the Board regarding the onsite Emergency Plan.
Based upon exit interviews with the l
NRC Staff, Applicants have no reason to believe that this report will not be favorable.
l 6.
As of this date, I am informed and bet.ieve that all items remaining to permit the Director to make the necessary findings under 10 C.F.R. 5 50.57(a) and issue the license for SONGS Unit 2 have been resolved and issuance of said license is imminent.
7.
Construction of SONGS Unit 2 is substantially complete and the Project Schedule currently calls for fuel loading in February, 1982.
All required equipment and personnel are onsite awaiting the issuance of the fuel loading, low-power testing license for SONGS Unit 2.
Upon issuance of this license, a detailed low-power testing -
program will be accomplished.
Completion of this program takes approximately 108 days of continuous activities and involves licensed operators supported by a group of about
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twenty SCE start-up personnel, approximately ten start-up personnel from the Combustion Engineering Company, and various other technical experts from SCE and other vendors of major components, as required.
8.
2 The record on the Applicants' application for full-power authoriza'; ion for SONGS Units 2 and 3, is closed and no reason appears why issuance of an Initial Decision on this application cannot be issued by the Board well in advance of the completion of the low power testing program for SONGS, Unit 2.
Based upon industry experience, it is unlikely that SONGS Unit 2 low-power testing program -*n be accomplished in much less time, and it may take more time.
For example, Sequoyah Unit 1 took 147 days; Maquire Unit 1 took about 132 days; North Anna Unit 2 took 103 days, and Salem Unit 2 took 98 days.
Accordingly, it reasonably appears to Applicants that any delay in commencing the low power testing program will result in a day-for-day delay in full-power operation of SONGS Unit 2.
9.
Any delay in the Project Schedule for SONGS Unit 2 will result in substantial increases in the cost of the project.
These costs will ultimately be borne either by the Applicants or the Applicant's ratepayers in the form of increased utility rates.
A delay in the Unit 2 Project Schedule would result in additional costs of approximately
$52.5 million per month, or $1.73 million per day, of delay.
This cost increase is attributable to the following factors:
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9.1 Cost of Alternative Fuel:
In the event SCE is unable to operate SONGS 2, it must turn to fuel oil to generate the electricity which would otherwise have been generated by Unit 2.
Approximately 0.9 million barrels of fuel oil per konth would be needed to generate this power.
This will result in additional fuel costs of $36 million per month.
9.2 Financing Costs:
Applicants are precluded by law from recovering the costs of construction of the SONGS Unit 2 from the utility ratepayer until SONGS Unit 2 is placed in full-power operation.
As a result, Applicants must finance all construction costs until SONGS Unit 2 is placed in full-power operation.
These financing costs are approximately $12.5 million per month.
Accordingly, each month of delay in placing SONGS Unit 2 in operation results in increased financing costs of $12.5 million.
9.3 Additional Costs:
Additional operating costs would be incurred by the Applicants in the amount of approximately $4 million for each month in which Applicants are forced to maintain SONGS Unit 2 in a standby, nonoperational mode.
9.4 Environmental Costs:
Because it will be necessary to burn an additional 0.9 million barrels of fuel oilinplaceofthenuclearfuelintheeventoperationoh the SONGS Unit 2 is delayed, an additional 1350 tons per month of pollutants (based upon system simulation due 5
primarily to additional Nitrogen Oxides and Sulfur Dioxides) will be emitted relative to the amount of polluntants which will be emitted if the SONGS Unit 2 could be placed in operation.
10.2 It has been the industry experience that performance of repairs, maintenance and modifications after completion of low-power tests are not made significantly more difficult or costly by reason of fission products in the core l
or contamination of the primary coolant system resulting from low-power test.
In fact, both Salem Unit 2 and North Anna Unit 2 have reported that after completion of low-power tests there was no increase in background radiation in the containment.
Indeed, workers at Salem 2 performed a number of TMI-related improvements, including modifications requiring contact with the primary coolant, without protective clothing.
11.
SCE has had substantial experience involving structural and mechanical modifications to SONGS Unit 1 after that reactor had been operating for a number of years at full power creating a much larger inventory of fission products in the core and in the primary coolant system than would be present at the completion of a low-power testing program.
Based on SCE's experience, I would conclude that there 1.s no work which cannot be accomplished at SONGS Unit 2 simply because low-power tests have been conducted and fission i
i products are in the reactor core.
Any work that might be 6
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required would only result in minor cost it. creases due to special provisions to minimize worker radiation.
12.
Based upon the considerations described above, I would conclude that while a decision to stay the low-power license is not required to preserve Applicants' ability to make whatever modifications the NRC should decide in the future are necessary, such a decision would immediately cause unnecessaty and irreparable environmental damage and financial loss to Applicants, Applicants ratepayers and the public at large.
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Robert Dietch re et day 1
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- M " "
2 of February, 1982.
l AGNES CRABTREE l
Pect Aav PtBuC CAUF08%iA l
Pe'NCIPAL Office 'N LOS ANGElf5 COUNTY l
l My Cernmcon Eso Aug 27.1962 w
. m.m Notary Public, State p
of California, County of Los Angeles 7
v-
DECLARATION OF SERVICE BY MAIL I am over the age of eighteen years and not a party to the above-entitled cause.
My business address is 600 Montgomery Street, 12th Floor, San Francisco, California 94]ll.
I served the foregoing APPLICANTS' OPPOSITION TO CARSTENS, ET AL. APPLICATION FOR STAY OF LOW POWER LICENSE (10 C.F.R. S 2.788) AND APPEAL FROM DENIAL OF STAY MOTION BY THE ASALB dated May 26, 1982, by depositing a true copy thereof in the United States mail in San Francisco, California, on May 26, 1982, enclosed in a sealed envelope with postage thereon fully prepaid, addressed as follows:
Stephen F. Eilperin, Esq.
Dr. Cadet H. Hand, Jr.
Chairman, Atomic Safety and Administrative Judge Licensing Appeal Board c/o Bodego Marine Laboratory l
U.S. Nuclear Regulatory Commission University of California Washington, D.C. 20555 P.O. Box 247 i
Bodega Bay, CA 94923 Dr. Reginal L. Gotchy Atomic Safety and Licensing Mrs. Elizabeth B. Johnson Appeal Board Administrative Judge U'.S. Nuclear Regulatory Commission Oak Ridge National Laboratory Washington, D.C. 20555 Oak Ridge, TN 37830 Dr. W. Reed Johnson Robert Dietch, Vice President Atomic Safety and Licensing Southern California Edison Co Appeal Board 2244 Walnut Grove Avenue U.S. Nuclear Regulatory Commission P.O. Box 800 Washington, D.C.
20555 Rosemead, CA 91770 James L. Kelly, Chairman Charles R. Kocher, Esq.
Administrative Judge James A. Beoletto, Esq.
Atomic Safety and Licensing Board Southern California Edison Co U.S. Nuclear Regulatory Commission 2244 Walnut Grove Avenue Washington, D.C. 20555 P.O. Box 800 Rosemead, CA 91770 Lawrence J. Chandler, Esq.
Donald F. Hassell, Esq.
Mrs. Lyn Harris Hicks I
Nuclear Regulatory Commission GUARD Office of the Executive Legal Director 3908 Calle Ariana Washington, D.C. 20555 San Clemente, CA 92801
o Richard J. Wharton, Esq.
Mr. Lloyd von Haden University of San Diego 2089 Foothill Drive School of Law Vista, CA 92083 Alcala Park San Diego, CA 92110 James F. Davis State Geologist Janice E. Kerr, Esq.
Division of Mines and Geology J.
Calvin Simpson, Esq.
1416 Ninth Street, Room 1341 Lawrence Q. Garcia, Esq.
Sacramento, CA 95814 California Public Utilities Commission Phyllis M. Gallagher, Esq.
5066 State Building 1695 W. Crescent Avenue San Francisco, CA 94102 Suite 222 Anaheim, CA 92801 Charles E. McClung, Jr., Esq.
23521 Paseo de Valencia Docketing and Service Section Suite 308 Office of the Secretary Laguna Hills, CA 92653 U.S. Nuclear Regulatory Commission Alan R. Watts, Esq.
Washington, D.C.
20555 Rourke & Woodrtff California First Bank Building Atomic Safety and Licensing 10555 North Main Street
-Appeal Board Santa Ana, CA 92701 U.S. Nuclear Regulatory Commission Gary D. Cotton Washington, D.C.
20555 Louis Bernath San Diego Gas & Electric Co.
Atomic Safety and Licensing 101 Ash Street Board P.O.
Box 1831 U.S. Nuclear Regulatory San Diego, CA 92112 Commission Washington, D.C.
20555 Executed on May 26, 1982, in the City and County I
of San Francisco, State of California.
I declare under penalty of perjury that the foregoing is true and correct.
i KAREN ANDRESEN l
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