ML20058G316
| ML20058G316 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/13/1981 |
| From: | Brown H CALIFORNIA, STATE OF, HILL, CHRISTOPHER & PHILLIPS |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20058G314 | List: |
| References | |
| ALAB-653, ISSUANCES-OL, NUDOCS 8208030280 | |
| Download: ML20058G316 (13) | |
Text
.
.--y -..
-e coc,xgo ijt J01.30 P352
, i... .-: UNITED STATES OF AMERICA CFFLy. n- ;.gggy .y '
NUCLEAR REGULATORY COMMISSTc0COM,:.. N3"4 SE:.V"- ~
i_m a MICH
... ./.C.
g.
BEFORE THE COMMISSION ._
SERVED JUL 301982
)
In the Matter of )
) . Docket Nos. 50-275 0.L.
PACIFIC GAS AND ELECTRIC COMPANY ) 50-323 0.L.
)
(Diablo Canyon Nuclear Power ) (Security Plan Proceeding)
Plant, Units 1 and 2) )
)
PETITION FOR REVIEW OF ALAB-653 RESTElCTED SUBMITTED BY .
GOVERNOR EDMUND G. BROWN JR. I 1 .
October 13, 1981 1 ! j 1 1 'M 1M E
- , . / . . .
m i W M B208030280 B20730
- DR ADOCK 05000275 PDR
_1 . .
Brown Jr. , rapeccenting tha Pursuant to 10 C.F.R. 5 2.786, Governor Ed=und C.
Scace of California, hereby petitions f or review of ALG-6f 3, dated Septe=ber 9,1981, .
The decision by only two Board members is an which approved PG&E's security plan.
inicial decision which will receive no administrative appellate review unless the
~
1/
3ecause the Board's decision
- Cor: mission grants the Governor's instant petition. .
)
73 in a contested proceeding is the first Board av = M iation of the meaning of Par:
and because the decision raises 1=portant and critical questions of law, policy, and f fact affecting the security of'the Diablo Canyon plant, the co=non defense and-and security and the public health and safety standards of the Atomic Energy Act Part 73 of the NRC's regulations, the Commissten should review the neries of this c_a_s e:
The security of the Diablo Canyon plant is subject not only to Federal regulatory authority, but it affects profoundly the police power obligations of the State of A security threat to Diablo Canyon would invoke State, local, and regional California. .
governmental responsibilities. Any shortcoming of the NRC in performing its regula-.
tory function of ensuring adequate physical protection would in the real world directly increase the police power burden on the State and local govern =ents.
The Appeal Board's decision provides no, basis for confidence in the adequacy of Unless the Cocnission steps in now to confront the ;
the Diablo Canyon security plan.
genuine issues 'that have been raised by the State, the Board's unsatisfactory work-product will stand as a precedent of the RC's unwillingness to deal squarely with hard questions raised by the NRC's own regulations and its administrative processes.
Indeed, the essence of the Appeal Board's decision does no more chan e=asculate the NRC's regulations in Part 73. The Commission vill recall that from 1973 through February 1977, when the current Part 73 was proculgated, the AEC, the NRC, and the Congress acted with repeatedly increased stringency and urgency to upgrade physical 1/ The Appeal Board vacated the Licensing Board's earlier decision See and ALAS-f80, presided over a trial d_e, novo on the adequacy of PG&E's security plan.
11 NRC 227 (1980).
..* , -1 security at nuclear power plants. With one broad brush now, the Appeal Saari ':.s i written off the purposes of Part 73 and, indeed, the. language and meaning of the ..
regulations. For example: ,
b.' '. -- Seccion 73.55 requires chat there' be "high assurance" protection againse the
,"..- design basis threat. This requirement, by its own ter=s, is significantly
'S ,* - greater than che " reasonable assurance" required by Part 50 and elsewhere in the regulations. See 44 Fed. R3 68,185 (1979). The Board's dec i.Lon makes a mockery of the meaning and purpose of the "high assurance" standard.
- Section 73.1 defines the design basis threat to constitute "several persons."
In public statements,'.the NRC has repeatedly refused to limit "several" to a definite number. The Board's decision interpreted this deliberate indef-inite phrase to be the definite number of _
- Section 73.1 explicitly defines the design basis attackers to be qualified,
! well-equipped, experienced, and skilled. The Board's decision crests such i attackers as something significantly less.
-1 PG&E accompted to demonstrate on paper in Chapter 11 of its security plan j the capability of its security force to protect against the design basis
.; threat. The evidence at the hearing discredited Chapter 11 and showed that
- the PG&E security force failed to protect against even PG&E's own "wcrse case" attack scenarios. Surely, a security foreg that loses on paper l against the very adversary that it postulates must be suspect for an./
realistic attack. The Board's decision found that Chapter 11 is noc l* -
6 material. -
l 4 Section 73.55 requires that the Diablo Canyon security plan protect against
'f the threac-level deffned in Section 73.1. The Board's decision found chac
- there is no need er identify or analyze any site-specific threat to Diablo
[ Canyon. Thus, the fact that the Staff never even inquired of or discussed I any level of potential threat to Diablo Canyon with the California Depart- ,
U ment of Justice or other State law enforcement offices, or with the T3I, -.
l the CIA, the DIA, local law enforcement agencies, cr any other competent law enforcescut entity, was written off by the Board as 9-terial. The undis-l puted evidence of record cacaloguing potential terrorisc threats specifically in California, as published by the Actorney General of California, was given f no weight by the Board and did not even prompc the Board's curiosity to require.a,.Scaff discussion with appropriate State officials.
- Section 73.55 requires that there be support arrangements with local law enforcement agencies. The Board's decision found that ic is only neces'sarf
~
kl for a piece of paper to exist. Whether chat paper establishes useful law E 'enforcec:ent support or a workable relacionship was treated as immacerial by the Board.
T)le Governor's position in this proceeding was presented by two e=inently qualified i General Louis 0. Giuffrida, then Director of the Califor=1a Speciali:s-security experts.
.i-Training Institute cnd now Director of FI'd.A, and Mr. Richard E. White, a retned 25-year veteran of the FBI and former Director of the 73I's Sacramento office, demonscrated i
-. ~ - _ - - -.
~3- ,
with chapter and verse c.w inadtquacies of the PG&E security plan and also offered myriad ideas to improve the plan. The constructive criticisms of these experts should ,,
have. invited the Scard to upgrade ?G&E's plan and to re-direct the Staff toward meaning-
~
ful application.of the requiraments.of Parr.73...Instead .the Board built a barrierI 7'
.~ -G l-between itself and the r:1dence presented by General Giuffrida and Mr. White. y'-[
The Board's systa=atic rejection of the testimony of General Giuffrida and Mr.
White points out a threshold issue for this Comission's consideration: namely, the credibility of the NRC's physi al security regulations. Does the N2C.do in practice what its 5egulations preach the NRC will do? Thus, at the hear of this case is the strong, authoritative language of Part 73. This language creates the impression that the NRC means serious business on physical security at every nuclear power planc. The public relies on this languages, jusc .as California did in this case, to believe that the regulations are being 'splemented s-ich dedication comensurate to the rhetor
~
used by the Comission and its Staff in public statements.~and testimony before comittees of the Congress. General Ciuffrida and Mr. White add further dimension, because they applied their independent ;rofessional expertise to the language of Par: 73 and, 1f ,
the Board's decision stands, were clearly led afield by the Comission's own language.
If for no reason other than to provide c'redibility and practical meaning to Par: ,
73, the Commission should fully review the Board's decision. Otherwise, other states that may participate in NRC security proceedings vill confront the same mixed signals frem the Comission that California has experienced here. The Comission has latitude in how it defines the "public health and safety" and the "co= mon defense and security" and in vhat regulatory requirements it choosestoimplebent those standards.
~
However, the Comission has no right to create a public impression that is inconsistent with the Comission's private intent. If the Governor's positions in this proceeding are unsound in fact or unwise in policy, the Co= mission owes it to the public and the State to explain why. If the Governor's posittens are of nerit, the Co==1ssion owes it also to itself to explain why. In either case, there is no reason for the Com=1ssion to duck a full review of the Board's decision.
. ,o
.. . -4 The Appeal Board's significant legal, policy, and f actue.1 errors which the Commission should address are set forth below: y I. Section 73.l(a)(1) Does Not Li it "Several Persons" to V .
The Appeal Board ruled that the design basis threat of Section 73.1 - the threat of "several persons" - is limited to no more than ALAB-653, p. 14.'
This was a crucial rul'_ng, because the Board acknowledged that the evidence does not support a finding that PG&E could*
defend against an accack by- more chan 2/ .
ALAB-653, p. 32.
The Connaission recently recognized the importance of the "several persons" issua.
Indeed, in its September 21, 1981 Memorandum and Order, the Corsaission stated:
The Commission does not necessarily agree with the Board's conclusion regarding the definition of the word "several" found in 10 C.F.R. 73.l(a)(1)(1). The Cocuission will pro , .
vide guidance on this matter at a later date. (p. 2)
~
(E.phasis supplied.)
~
The term "several persons" is an inherently indefinite phrase which the Appeal Board incorrectly found to be definite: no more than .
_,f f ,The ~ Board's int'erpre--
tacion does violence to the plain meaning of the English language and conflicts with the undisputed evidence presented by the Governor's experts that design basis attackers
. 11 would likely assemble a. force of greater than _ but no more than 12 ettackars.
II, The Evidence Cocoelled the Board to Consider an Attack by More Than Persons.
Even assucting that Section 73.1 limits the notzal design bas.is threat to , ,,
persons, the Governor's witnesses demonstrated without contradiction that an attack on ;
Diablo Canyon would likely involve more than_ ' persons. The Governor thus moved for 1/ The Governor demonstrates hereafter that the evidence does not support a finding of an ability,to defend against even persons.
-3/ Giuffrida at 19-21; *-tice at 14-15 ; see 3rief of Governor 3rown on the F.eani=g of "Several Persons" in Section 73.l(a)(1) of the NRC's Regulations, Jan.13, 1 1981.
l .
-, ,- = - - - - - ' - - - - - -- - - - - -
. l vaiver of the regulation in the event the Board restricted "saveral" to 4/
persons." The evidence submitted by the Governor's vitnesses dancastrated that: ,
-- A group planning an attack on Diablo Canyon would recruit a team of
.L
~ ~~
t -
. ?u .. .
Attackers with the traits and attributes of those described in the design basta threat of Section 73.1 are available and could be trained. ~
equipped, and noved to the plant undetected;
- There is a terrorist threat in California that has been documented in the 1980 Report of the California Actorney General. 5/ '
i The Staff and PG&E did not refute this' evidence and, indeed, never responded to the Governor's vaiver motion. Further, the Staff never even incuired of the State, the F3I, or any other Federal or State authoriev regarding the terrorist threat in California, although the Staff witness agreed that such threat data would be relevant to Diablo Canyon. Tr. 2076-77 (Miller) . The Board, however, rejected the Governor's request to waive ch'eTegulation. The' Board's'" reason" was that the Governor's
~
witnesses f ailed to prove that therewas"acarticulart:edthreat to Diablo Canven."
ALA3-653, p. 40 (emphasis supplied). The Commission surely cannot have intended Section 2.758 to be construed in such a manner that' relieves its own Staff from making obviously relevant inquiries and makes a virtual. shell-game out of who should have the procedural burden of proof. Indeed, it is ths Staff's obligation to review PG&E's plan thoroughly. .
,__ __ III. The PG&E Securiev System Cannot Defend Against Even Atrackers.
The Appeal Board ruled that PG&E need only comply with a " generic" threat that is devoid of particular1:ed meaning. For instance, the Board stated:
(T]here is no necessity to understand, characterite, and analyze 'the attributes of the attackers . . . in light of 4/ 3rief of Governor Brown on the . Meaning of Several Persons in Section 73.1(a)(1) of the NRC's Regulations, Jan. 13, 1981, pp. 12-14.
5/ Id., p. 13; see Brief or Proposed Findings of Fact and Conclusions of Law Sub-
=1tted by Governor 3rown, Jan. 9,1981, pp. 70-77 (" Proposed Findings") .
e m -. + -
-~___. _ _ -
. . ' .i , ,
the sice-specific condicions at Diablo Canyon,' because
- he charac: eristics and at:ribu:es of the adversary are also generic and are already set forth in :se regula: ion. . ,l ALA3-453, p. 43. i 6/
nis ignores the fundamen:al process of securi:7 pla=ning. ne language of :he regul.a-
!' cion is generic, bu: 1: needs intersrecation and exsosition to ::anslace 1: into che f.
real-world si:uation ac Diablo Canycn. nus, 1: is essencial for PG&E :o identify mean1=gfully the skills and other at::1bu:e's of the ac:ackers and :s prepara PG&I's rcsponders for that situation. 'g?C&E has not.dena chis. See Giuffrida ac 4, 10.
i I' De NRC's regula:icos require chac PGLE's securi:y arrangemen:s be desig=ed to provide "high assurance" protection against attackers who possess the actributes specified in See:1on 73.1(a)(1) . See 10 C.F.R. 5 73.55(a) . There is no evidentiary bcsis, however, for fi= ding chac PG&E's securt:y arrangments are so designed, because
.?G&E has neither taken cogni:ance of the at: 1butes of the design basis at:ackers nor ccaly=ed how chose actributes affec: :he security of the D,iablo Ca= yon pla==. Tr.
2076-77 (!"11 er) ; Gov. Brown Ex. 5-2, at 4-7 ; Gov. Brown Ex. 5-3, ac 14-15.
l 6_/
D e Governor's Proposed Findings demonstraced the error is faili=g to analyze che
- design basis chreac:
PG&E performed no analysis of the skills, training, dedicacion, weapons, cools, communicacions equipment, and scrategy of :he design basis adversary. Racher, PG&E simply rests 1:s case en the self-se:vi=g cautology chac it has assumed the skills and traising of the adversary to be ' chose defined by 10 C.F.R. 73.5 5 (a) (1) . . .. ' Gov. Brown Ex. 5-2, ac 4-7; Gov. Brown Ex. 5-3, ac 14-15. But, See: ion 73.55 is merely general, and it is for PG&E as the applicant. to put mean1=g into the- -
words of chac see:1on under the si:e specific condicions ac
. 1:s own Diablo Canyon planc. nus, 1; is incongruous under che NRC's regulacions chac cht ?C&E Panel castified, 'a specific profile of the 'several persons' who execute che ex:ernal :hreac to :he fac111:7 was not drawn-up- in prepara- - - - - -
tion of Chapter 11. D e assumption was =ade :hac :he i=:ruders had whatever sufficient skills, ::aining and dedicacion were necessary . . . and chac only a superior number of vall-armed and trained securi:7 officers could neutralize che chreat.' PG&E Panel at 6. D ese words of PG&E rs=ain meaning-less, because no specific charac:aris:1cs have been attributed .
to che persons assumed by the design basis :hreac :o ac::ck
- he fac111:7 ?. S.
Furrher, che design basis threa: requires pro:ec:Lon agains: a::acks by s:aal:h or decepcion such as diversionary at:acks and explosions en :he perine:ers. Tr. 1373 ,
(PG&Z Panel); Giuffrida a: 7-8, 16, 19; Tr. 242C-21, 2316-17 (Giuffrida); 2979-98 ,
(Dec:=an); 2553 (Whi:e). The Appeal 3 card glossed over PG&I's lack of preparation for at:acks by s:ealth vi:h. he. t inc.redible conclusion that at ackers could sci: engage Z/ . .. .
in such diversions. ALAB 653, p. 45. -
In short, PG05'has, engaged in a paper planning exercise shich the Scaff and :he Board have approved. PCaI has"nechanically* cons: rue:ed a "securi:y system," but has n:ver at:e=pced to posculace in a real-world situacien how : hat system might perfor=.
The NRC's regulacions, in requiring "high assurance" proteccion, surely require sore.
IV. ' Chancer 11 of the Securi:v "dlan Demonstrates ?G&I'sTailtire to
~
Precare for a Realistic Actack.
PG&I'sfailuretoprepareforreal-worldsecuri:7situationsisconclusive1h -
S/
~
illustrated by Chapter 11 of PG&I's Security Plan. Chapter 11, en:1: led "Overall Thysical Securi:7 Program Perfor=ance," is designed to demonstrace :ha: the Plan satis-fies the general perfor=ance requirements of See:1on 73.1(a)(1), namely, cha: che Plan provides "high assurance" protec:Lon agains: the design basis :hreat. PG&Z Iz. S-64, Ch. 11. In the words of PG&I's U.:sesses, " Chapter 11 of the Securi:7 Plan describes the basis for councert=g the threats." PG&I Panel Tescimony at 7. In fae:, Chapter 11 ~
demons:: aces precisely :he opposite, and discloses glaring inadequacies in PG&I's physical securi:7 ' arrangements.
1/ With respec: to weapons and equipment, PGaZ's and the Appeal Board's analyses are similarly deficient in that such ice =s (a=oug others) as explosives, air-craft, incapaci:aci=g gas, nortars and anci-cank weapons have all bee. idenci-fied by the NRC 1:self, and ignored by ?C&I, as :he equip = enc which adversaries could have available in an at:ack. ALL3-653, p. 44 ; NRC Staff Ex. 5-16, at 2;
"'lar at 20.
This na::er was addressed ex ensively by the Governor ac pages 19-41 of his
~
8/
Proposed Findings.
~
- s. , ,
'. s N e6 PG&E's attack scenarios in Chapter 11 are neither among the worst cases
" conceivable," as PG&E states, no intersally realistic in terms of the profilas of the design basis' attackers, cargets, tacci,cs, weapons, time-frames, or the abilities s 9/
. of the PG&E guard force to respond. Tr. 2419-21 (Giuffrida). Never heless, the 3 card concluded "that perceived inadequacies in the Chapter 11 cases and their analysis by the applicant, cannot necessarily be translated into inadecuacies in the security system." ALA3-653, p."132. The Board thus , ruled that a security plan that cannot even pass muster on paper can nevertheless be expected to succeed in the real world.
x 9/ yor instance, the Chapter 11 cases contain none of the following: _
(a) Diversions at the perimeter f ence or elsewhere to confuse PG&E responders as to the location ef'the accack. Giuffrida at 7-8, 16, 19; Tr. 2420-21, 2216-17 (Giuffrida).
(b) Use of snip 2rs with silencers who could stay out of view of detection devices and assassinate one or more guards in' the protected area. Giuffrida at 19; White at 12-13; Tr.
1683 (Medcalf).
. ' Tr.1609 (Lundsford) .
\
't) lastruction or blockage of the access road so that law enforcement agency assistance is hindered or ~ prevented.
Giuffrida at 19, 22; Tr.1684 (Medcalf) .
(d) Use of-explosives once inside the build ngs to celay or deter armed responders' pursuit. Tr. 1681-84 (Medcalf). ,
(e) Death or severe injury of EG traed responder. Tr. 1683 (Med-calf). This is extrv"?[ M : in view of the fac: that the attackers'probably add. 23
- trer armed than the defenders. .
See NRC Staff Ex. S ,5; 15. k.~2-24
~
J4 (Giuffrida). ~
(f) Any breakdovu$r, mistakes, impediments or other difficulti'es affecting PG&d"s armed responders. Tr.1683-84 (PG&E Panel);
Gov. Brown Ex. S-2, at 14-17. This is totally unrealistic, since one should always assume that a security response plan vill have some flaws or that unforeseen evetas will occur.
It is particularly unrealistic at Diablo Cany6h, where PG&E has never performed comprehensive =ock exercises which night othervise provide some confidence in the security syscam.
Giuffrida at 17, 21-22; white at 13-14
~
- - - - -.- _ . .- _L
, V. PG&E's Securiev Force is Inadecuatelv Trained.
s The Appeal Board ruled that PG&E's guard training pursuant to Regulatory Guide 10/
5.20 was inadequate to prepare for the des,ign basis threat. ALA3-653, pp. 72-73.
The Governor submits that this ruling clearly required.the Board to disapprove rhe -
PG&E security plan. Illog1cally, however, the Board proceeded to rule that PG&E's training would in the future prove to be in compliance with Par: 73, Appendix 3, even though PG&E's Appendix 3 training plan was not introduced into evidence and no evidence whatsoever was taken concerning PG&E's compliance with Appendix 3 training requirements.
~
ALA3-653, pp. 64 n. 92, 73-75. The Appeal Board has thus committed the same error for which it so sha g].y,r_evers_ed the Licensing Board: it approved a plan without even receiving it into evidence. See 11 NRC 227 (1980). Indeed, without evidence or special insight, the Board predicted the future. -
The Appeal Board was required to render its decision.on the basis of the evidence of record. 10 C.F.R. 5 2.760. It did not. This Commission accordingly must reverse
_11/
and direct the Board to reconvene the hearing on Appendix 3 matters.
VI. The Anoeal Board Misincererets the Recuirements for Local Law Enforce =ent Assistance.
NRC Regulations require PG&E to establish and document liaison with local law l caforcement agencies ("LLIA"). 10 C.F.R. 5 5 73.55 (f) (1) , (h)(2) . PG&E must also describe the response capabill tes and criteria for LLEA assistance and discuss the i
verking arrangements for communication with the agencies. 10 C.F.R. Part 73, App. A, I
l 10/ This holding clearly is correct. For instance, while there had been some security
' drills, none was designed with reference to the design basis threat, and none in-volved a violent external assault with an attacker breaching the perimeter fence and entering the protected area. Tr. 1877-78 (PG&E Panel). Indeed, at the time j
the drills took place (1978-79), neither the CAS nor SAS was operable, and the drills were strictly for trainees. Tr. 1864-65 (Fisher); 1972-73 (PG&E Panel) .
Further, as a result of the high turnover rate among PG&E guards, it is clear that nost PG&E personnel who participated in the drills are no longer ?G&Z ar=ed responde:
Tr.1806,1875 (PG&E Panel) . Finally ~, the evidence presented by PG&E provides no assurance that future training will be adequate. No details have been worked out recardine necessarv exercises, and no descrintion of the drills is even included in the Security Plan. Tr. 2958 (Todaro); Tr. 1792-93 (Lunesford).
l 11/ The Appeal Board has furthered its errors by then delegating to the Director of
( . l e . .. 1
. i 5 3(d). See also 10 C.T R. 5 73.40(c)(2) and (3). The obvious purpose of these requirements is to ensure swift and effective-LLIA assistance in the event of a-security incident.
PG&E has not established any effective or workable liaison with LLEA. There are
( letters dated 1977 that committed local agencies to assist, but there never have been mock exercises or other eff ective traindng to demonstrate the capability for an effective, coordinated response. This is a particularly serious omission, because the first 7"A to arrive as the plant v 17 assumeco= mand,willpNbablypossessonlya d
shotgun and handgun against the "several persons" with design basis skills and weapons, and will possibly be a low-ranking patrolman who has not even been exposed to PG&E's cursory annual " familiarization" program. Tr. 1653-54 (Detras.n); PG&E Panel at 23; Giuffrida at 11; White at 9-10.-12/
The Board interpreted.the regulations to eliminate meaningful LLEA assistance as a requirement. Instead, the Board ruled, while citing Webster's dictionary, that the regulations require only " mutual understanding" .of PG&E and the "%. A1A3-653, p. 91._
The Board thus concluded:
Prearranged, detailed plans for interfacing applicant's security force and the LLEA response force so they may together respond to a myriad of security contingencies are not recuired bv the regulations. ALAB-653, p. 92 (emphasis supplied) .
The Board's holding is patently unreasonable.
11/ (Cont ' d) ,
Nuclear Reactor Regulation the responsibility to deter""e if PG&E actually meets the Appendix 3 requirements at some future time. ALAB-653,-p. 75. -Thus, the Appeal Board has pre-approved a plan, not in evidence, and isolated the plan from scrutiny in the contested evidenciary hearing by delegating to a NRC Staff member the ultimate approval of the Plan. We remind the Commission-that this is a con-tested licensing proceeding, where the Staff is merely a party. The Board's blatant departure from the requirements of the Administrative Procedure Act and the Cocmission's own regulations that decisions be based on the record [10 C.F.R.
5 2.760(c)] cannot be permitted to stand.
E/ See pages 53-62 of Governor's Proposed Findings for details of the inadequate liaison with LLEA.
. .. \
- 4 o, e
UNITED STATES OF AMERICA .
NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION -
A
, )
In the Matter of i )
) Docket Nos. 50-275 0.L.
PACIFIC GAS AND ELECTRIC COMPANY ) 50-323 0.L.
)
(Diablo Canyon Nuclear Power ) (Security Plan Proceeding)
Plant, Units 1 and 2) ).
) _ _
CERTIFICATE OF SERVICE I hereby certify that the " PETITION FOR REVIEW OF ALA3-653 RESTRICTED SUBMITTED BY GOVERNOR EDMUND G. BROWN JR." was served on October 13, 1981 by delivery of the same to Mr. Trip Rothschild, NRC Office of '
General Counsel, for furcher service in accordance with CLI-81-21.
4 S. ~
Christoph'er B. Hanback
- HILL, CHRISTOPHER AND PHILLIPS, P.C.
1900 M Street, N.W.
Washingcon, D.C. 20036 Attorney for Governor Edmund G. Brown, Jr. of the State of California .
' October 13, 1981
.,.m. _ _ - . , - . _ . . - . . . . . _ , . - , , _, , , . . , , _ _ . _ _ _ . , _. , _ ,,, . . _ _ _
e .0 s
, 1 i
g.
Respectfully submitted, Byron S. Georgiou
- Legal Affairs Secretary Governor's Office Sacramento, California 95814
' i; .
9 . iou / M /mg Herbert H. Brown Lawrence Coe Lanpher Christopher B. Hanback HILL, CHRISTOPHER AND PHILLIPS, P.C.
~
1900 M Street, N.W.
Washington, D.C. 20036 Attorneys for Governor Brown of the State of California October 13, 1981 4
ee
. en. .e
.-