ML20063P876
| ML20063P876 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/13/1982 |
| From: | Pigott D ORRICK, HERRINGTON & SUTCLIFFE, SOUTHERN CALIFORNIA EDISON CO. |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8210150454 | |
| Download: ML20063P876 (10) | |
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DOCMETED USHRC e
UNITED STATES OF AMERIqg-4 ggg 4
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NUCLEAR REGULATORY COMMISSION rp r:C7 nr ?.E T '
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In the Matter of 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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)
l APPLICANTS' POSITION ON LICENSING i
BOARD'S REQUEST FOR DIRECTION ON WHETHER TO PROCEED TO HEARINGS i
l DAVID R. PICOTT
. EDWARD B. ROGIN SAMUEL B. CASEY Of ORRICK, HERRINGTON & SUTCLIFFE A Professional Corporation 600 Montgomery Street i
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) 572-1900 Attorneys for Applicants, Southern California Edison 2ompany, San Diego Gas & Electric Company, City of Anaheim, California and City of Riverside, California Dated:
October 13, 1982.
1 P210150454 821013 gDRADOCK 05000361
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
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SOUTHERN CALIFORNIA EDISON
)
DOCKET NOS. 50-361 OL COMPANY, et al.
)
50-362 OL
)
(San Onofre Nuclear Generating
)
Station, Units 2 and 3)
)
)
APPLICANTS' POSITION ON LICENSING BOARD'S REQUEST FOR DIRECTION ON WHETHER TO PROCEED TO HEARINGS.
I.
INTRODUCTION On October 5, 1982 the Atomic Safety and Licensing Board issued in the above docket " Memorandum and Order (Identifying a Question to the Commission)"
(" Order of October 5, 1982") which certified to the Commission the following questions:
Does the Commission wish the Licensing Board to continue the proceeding initiated by the Board's Order of October 1, 1982, with a view toward the Commission's considering the record and the Licensing Board's findings in its decision of the certified questions?
l Alternatively, does the Commission wish the l
Licensing Board to terminate or suspend its proceeding until after the Commission decides l
the certified questions, in order to avoid the possible waste of resources?
l In the Licensing Board's view these questions are made l
necessary as a result of the Commission having directed l
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s certification of two questions that will determine the legal definition of 10 CFR 50.47(b)(12) and the standards necessary to meet that definition.
(Order (CLI-82-27).)
At the same time, the Commission left intact the Licensing Board's determination that Applicants had not met the Licensing Board's definition of 10 CFR 50.47(b)(12) and the Board's condition requiring Applic=.uts to meet their as yet undefined standards within six-months of commencing full-power operation.
Prior to the Order of October 5, 1982, on October 1, 1982 the Licensing Board had issued " Memorandum and Order (Setting Medical Arrangements Question for Hearing)."
(" Order of October 1, 1982".)
The Order of October 1, 1982 defines issues, sets dates for filing testimony and dates for commencing hearing.
Applicants construed the order to be the equivalent of a prehearing
- conference order and, pursuant to 10 CFR 2.752(c) filed
" Applicants' Objections to Prehearing Memorandum and Order Re Medical Arrangements.", dated October 8 1982 (" Applicants' Objections")
(A copy of said filing is attached for ease of reference.)
As reflected in Applicants' Objections, it is Applicants' position that the Licensing Board's view of the 10 CFR 50.47(b)(12), medical services issue exceeds any reasonable interpgetation of that provision and raises questions calling for site specific accident analysis and I
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probability assessments which far exceed the proper scope of inquiry.
Applicants advised the Licensing Board in Applicants' Objections that it could not adequately respond to the Licensing Board's questions within the timeframe established by the Licensing Board.
Further, Applicants 4
concluded that it is now appropriate to await the Commission's definition of 10 CFR 50.47(b)(12) and its guidance as to compliance with that regulation prior to any further proceeding.
Applicants' position remaire. unchanged.
II.
APPLICANTS OBJECT TO FURTHER HEARINGS ON THE MEDICAL SERVICES ISSUE PENDING THE COMMISSIONS DEFINITION OF 10 CFR 50.47(b)(12) AND ISSUANCE OF GUIDANCE AS TO COMPLIANCE Applicants have reviewed the Licensing Board's Order of October 5, 1982.
Applicants object to the Licensing Board's attempt to turn this docket into a rulemaking proceeding.
Applicants contend that a licensing hearing is to determine whether an applicant meets NRC regulations and is entitled to receive the applied for license.
The Licensing Board appears to view their purpose differently; We think that the inquiry outlined in our Order [ MEMORANDUM AND ORDER (SETTING MEDICAL ARRANGEMENTS QUESTION FOR HEARING)] would be helpful to the Commission in resolving medical services questions not only on the facts of this case, but also in providing guidance for other cases.
If the Commission briefly postpones consideration of the certified questions until after it has our 3
report in January, the Commission will then have before it considerable information about medical services available in a major metropolitan area in the event of a serious nuclear plant accident.
Such information is not in the rulemaking record or, so far as we are aware, in the records of other NRC cases." (Order of October 5, 1982, p. 3.)
The Board obviously believes the record in this case should form a part of the basis for the Commission's interpretation of 10 CFR 50.47(b)(12).
This certification arises from our concern that the Commission might decidethe questions certified in its September 24, 1982 Order before we can complete the hearing process and report to the Commission.
(Order of October 5, 1982, p.
2.)
L view of the Licensing Board's expanded purpose for conducting hearings, coupled with its expanded view of the appropriate record to be developed in this proceeding, Applicants do not believe hearings are appropriate pending Commission action on the certified questions defining the proper scope of 10 CFR 50.47(b)(12).
As reflected in Applicants Objections attached, the Licensing Board is now calling for site-specific accident analysis for a specific accident.
Further, the Board is requesting probability assessments associated with that accident analysis.
Such questions exceed the scope of the regulations and the guidance criteria found in NUREG-0654.
NUREG-0654 is based on analysis of a spectrum of accidents and probabilities associated with such accidents.
Such a planning basis was set forth in NUREG-0396, 4
specifically approved in a Commission Policy Statement (44 FED. REG. 61123) and incorporated in NUREG-0654.
(NUREG-0654 at pp. 5-7.)
The Licensing Board is also attempting to include.-
a third reactor, San Onofra Unit No.
1, which is not within the scope of this docket in its accident analysis and probability requirement.
(Order of October 1, 1982.)
Clearly the Licensing Board has exceeded its proper scope of inquiry.
Applicants object to the Licensing Board attempting to analyze emergency planning capabilities at San Onofre Units 2 & 3 in the context of the point at which planning ultimately fails.
There is no regulatory rationale for this approach nor is it related to the regulatory scheme set forth in 10 CFR 50.47(b)(12) and NUREG-0654.
Applicants submit that tne newly defined " overwhelming" accident approach fashioned by this Licensing Board exceeds the scope of the regulations and places an unwarranted burden on Applicants.
i CONCLUSION As Applicants in an operating license proceeding, Applicants submit they are entitled to proceed on the basis of established regulations and guidance criteria.
It is obvious that the meaning of 10 CFR 50.47(b)(12) will not be settled until such time as the Commission acts on the certified questions currently before it.
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1 Applicants should not be required to proceed to hearings until an interpretation of the basic regulation is settled.
This is especially true where, as here, the Licensing Board evidences an expansive interpretation of the regulations that would require substantial expenditure of time and resources and which, Applicants submit, is pursuant to an incorrect interpretation of the regulation.
Respectfully submitted, DNVID R.
PIGOTT EDWARD B. ROGIN SAMUEL B. CASEY Of ORRICK. HERRINGTON & SUTCLIFFE A Professional Corporation CHARLES R. KOCHER JAMES A.
BEOLETTO SOUTHERN CALIFORNIA EDISON COMPANY By David R. Pifott Counsel for Applicants 6
l UNITED STATES'OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
SOUTHERN CALIFORNIA EDISON
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DOCKET NOS. 50-361 OL COMPANY, et al.
)
50-362 OL
)
(San Onofre Nuclear Generating
)
Station, Units 2 and 3)
)
)
APPLICANTS' OBJECTIONS TO PREHEARING MEMORANDUM AND ORDER RE MEDICAL ARRANGEMENTS DAVID R. PIGOTT EDWARD B. ROGIN SAMUEL B. CAEEY Of ORRICK, HERRINGTON & SUTCLIFFE A Professional Corporation 600 Montgomery Street 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) 572-1122 Attorneys for Applicants, Southern California Edison Company, San Diego Gas & Electric Company, City of Anaheim, California and City of Riverside, California Dated:
October 8, 1982.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
SOUTHERN CALIFORNIA EDISON
)
DOCKET NOS. 50-361 OL COMPANY, et al.
)
50-362 OL
{
)
(San Onofre Nuclear Generating
)
Station, Units 2 and 3)
)
)
APPLICANTS' OBJECTIONS TO PREHEARING MEMORANDUM AND ORDER RE MEDICAL ARRANGEMENTS I
INTRODUCTION The Atomic Safety and Licensing Board (" Board") on October 1, 1982 issued its " Memorandum and Order Setting Medical Arrangements Questions for Hearing" (" Order").
Applicants construe the Order to be the equivalent of a Prehearing Conference Order inasmuch as said Order defines issues and sets procedural dates leading to a hearing.
Purusant to 10 CFR $ 2.752(c), Applicants hereby object to the Order and request the Board to revise the Order in consideration of the objections presented below.
II PRELIMINARY STATEMENT The Applicants object to the Order for two reasons.
First, the Order proposes a hearing on issues which are beyond the scope of the Commission's emergency planning to qin1-E' R S O hD
regulations withcut regard to how the Commission may determine the certified questions pending before it relating td the identical subject matter.
Second, the Order requires the preparation of evidence far beyond the standards enunciated by the Commission in NUREG-0654.
The evidence requested also exceeds the scope of the evidence Applicants have previously proposed to present such that the hearing schedule contained in the Order is unreasonable.
The Order reflects the manifest need for Commission guidance.
Without such guidance, a hearing on the issues proposed by the Order may result in a substantial waste of resources.
Applicants aubmit that no further emergency medical arrangement issues should be delineated for hearing or hearings thereon scheduled until the parties and the Board have the benefit of further Commission interpretation of the legal requirements and technical standards involved in meeting the regulations.
Applicants anticipate that such interpretative guidance and standards will be forthcoming through determination of the certified issues now before the Commission.
III STATEMENT OF THE CASE The issue of medical services for the general public in the event of a release of radiation at San Onofre 2 & 3 originates from a determination by this Board in its Initial Decision of May 14, 1982.
The Board there determined 2
that a proper construction of 10 CFR S 50.47 (b) (12) 1/
included offsite medical services arrangements for the general public.
(Initial Decision, p. 28.)
The Board found that although some medical services then were avail-able that would benefit the general public, the Applicants did not demonstrate that the level of services was sufficient to meet the standards the Board deemed adequate.
The Board retained jurisdiction of the medical services issue and conditioned issuance of a full power operation on Applicants providing the necessary level of medical arrangements within six months of commencing full power operation.
Subsequent to the Initial Decision, in Decision, ALAB-680, July 16, 1982, the Atomic Safety and Licensing Appeal Board indicated that it may not agree with the Licensing Board's interpret 3 tion of the medical services requirement.
(ALAB-680, pp. 13-22.)
On September 24, 1982, the Commission issued its
(
Order (CLI-82-27), wherein it noted the differing interpreta-tions of 10 CFR S 50.47 (b) (12) and directed certification of two questions that will settle the interpretation of that 1/
10 CFR S 50.47 states in part:
(b)
The onsite and offsite emergency response plans for nuclear power reactors must meet the following standards:
(12)
Arrangements are made for medical services for contaminated injured individuals.
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provision and, if necessary, provide guidance as to the arrange-ments necessary to meet the regulatory requirement.
Initial briefs on the certified questions are due October 14, 1982.
on August 6, 1982, this Board issued its Memorandum and Order (Concerning Whether Further Proceedings on the 2quacy of Offsite Planning for Medical Services Should Be conducted).
Among other items, the Board solicited the parties' comments on the appropriate procedure to be followed in resolving the retained medical services issue.
In Applicants' Response to Memorandum and Order Concerning Whether Further Proceedings on the Adequacy of Offsite Planning for Medical Services Should Be Conducted, dated September 3, 1982, Applicants suggested the issue be certified to the Commission but that filing dates be set for the parties' affirmative cases, in the form of affidavits, on the issue as posed in the Initial Decision of May 14, 1982.
If a hearing was ultimately required, such affidavits, with any necessary supplementation required by a certification decision would constitute the direct evidence at any further hearing.
IV APPLICANTS OBJECT TO PROCEEDING TO HEARING ON THE QUESTIONS SET FORTH IN THE BOARD'S ORDER OF OCTOBER 1, 1982 PRIOR TO COMMISSION DETERMINATION OF THE CERTIFIED ISSUES Applicants prior willingness to prepare and file its direct case on further arrangements for offsite medical services was based on the premise that any further 4
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hearings would be based on the questions posed by the Initial Decision of May 14, 1982.
Applicants also had assumed that the theory of Applicants' case and the evidence necessary to support that case would be within Applicants' judgment.
Applicants consider the Order to call for an evidentiary showing greatly in excess of that indicated as necessary by the Initial Decision and in support of theories different from those of Applicants.
The evidence required by the Board's Order would necessitate a site specific accident analysis exceeding the plant's design basis as well as probability studies of such specific accidents.
Such studies and analysis would be costly dnd would require much more time than is available pursuant to the Board's Order.
The Board's request for a definition of the accident that would " overwhelm" local resources is contrary to the basic premise of NUREG-0654 which is to avoid the necessity for site specific accident analysis.
This premise is clearly documented in Criteria for Preparation and I
Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, NUREG-0654.
"No single specific accident should be isolated as the one for which to plan because each accident could have different consequences, both in nature and degree.
Further, the range of possible selection for a planning basis is very large, starting with a zero point of requiring no planning l
at all because significant offsite radiological l
accident consequences are unlikely to occur, to planning for the worst possible accident, regardless of its extremely low liklihood.
The NRC/ EPA Task Force did not attempt to define a single accident sequence or even a limited number of sequences.
Rather, it identified the bounds of 5
o the parameters for which planning is recommended, based upon knowledge of the potential consequences, timing, and release characteristics of a spectrum of accidents.
Although the selected planning basis is independent of specific accident sequences, a number of accident descriptions were considered in the development of the guidance, including the core melt accident release categories of the Reactor Safety Study." (NUREG-0654, pp. 6-7.)
The Commission has adopted both regulations and guidance to be followed in reviewing emergency preparedness.
The spectrum of accidents has been addressed and the criteria necessary to protect the public in the event of an accident established.
Applicants object to being required to develop a specific accident and its probabilities that would
" overwhelm" the local resources.
Such a requirement greatly exceeds the Commission's regulations.
The Board's questions also exceed the scope of the docket in that they ask for accident analysis and probability assessment based on operation of San Onofre Unit No. 1, as well as San Onofre Units 2 & 3.
(Order, p. 5.)
Applicants obj'ect to the inclusion of San Onofre Unit No. 1 in the emergency preparedness requirements for San Onofre Units 2 & 3.
Further, 10 CFR Part 50 does not require risk assessments of either Applicants or licensees and such work has rarely been undertaken for a specific reactor site.
In addition to the Board's apparent desire to define the level at which loca.1 resources are overwhelmed, the Board asks for yet another level of planning; arrangements necessary or desirable for distant medical facilities once local resources are overwhelmed.
(Order, 6
- p. 6.)
Applicants consider such an evidentiary requirement to exceed the requirements of 10 CFR S 50.47 (b) (12) or the guidance of NUREG-0654.
The Board calls for a briefing on the meaning of the phrase " contaminated injured individuals" as used in 10 CFR 5 50.47(b)(12).
This is precisely the question asked by the Commission in its directed certification order of September 24, 1982.
Applicants do not consider it appropriate to require duplicate briefing of issues.
Once the Commission defines the regulatory meaning of
" contaminated injured individuals," this Board's definition of that same phrase is superfluous.
Applicants object to such a redundant procedure.
V POTENTIAL HEARING DATES Applicants would be prepared to submit their direct case as they deem necessary to meet the issues raised in the Initial Decision of May 14, 1982 by November 10, 1982.
Appli-(
cants cannot provide adequate direct testimony on the questions i
promulgated by the Board in its Order by November 10, 1982.
The inventory of local resources coupled with the accident analysis and probability assessment required by the Board's questions cannot be accomplished within the timeframe f
set by the Board.
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VI CONCLUSION Applicants consider the Board's Order to reflect an unwarranted and unreasonable expansion of the medical services issue reserved in the Initial Decision of May 14, 1982.
In view of this expansion of the Board's view of the issue, Applicants do not consider it appropriate to proceed further with respect to the issue until the Commission has determined the questions subject to certification.
In the present circumstances it is now appropriate to await the Commission's definition of 10 CFR 5 50.47(b)(12) and its guidance as to compliance with that regulation prior to any further proceedings by this Board.
Respectfully submitted, DAVID R. PIGOTT EDWARD B. ROGIN SAMUEL B. CASEY Of ORRICK, HERRINGTON & SUTCLIFFE A Professional Corporation CHARLES R. KOCHER JAMES A. BEOLETTO SOUTHERN CALIFORNIA EDISON COMPANY By
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David R.
Pigott Counsel for Applicants l
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DECLARATION OF SERVICE BY MAIL 1
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 94111.
I served the foregoing APPLICANTS' OBJECTIONS TO PREHEARING MEMORANDUM AND ORDER RE MEDICAL ARRANGEMENTS dated October 8,1982, by depositing a true copy thereof in the United States mail in San Francisco, California, on October 8, 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 U.S. Nuclear Regulatory Commission University of California Washington, D.C. 20555 P.O. Box 247 Bodega Bay, CA 94923 Dr. Reginal 6 L. Gotchy Atomic Safety and Licensing Mrs. Elizabeth B. Johnson Appeal Board Administrative Judge U S. Nuclear Regulatory Ccmmission Oak Ridge National Laboratory Washington, D.C. 20555 Oak Ridge, TN 37830 i
Dr. W. Reed Johnson Robert Dietch, Vice President i
Atomic Safety and Licensing Southern California Edison Co.
Appeal Board 2244 Walnut Grove Avenue U.S. Nuclear Regulatory Commission P.O. Box 800 i
Washington, D.C. 20555 Rosemead, CA 91770 James L. Kelley, 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 Nuclear Regulatory Commission GUARD Office of the Executive Legal Director 3908 Calle Ariana i
Washington, D.C. 20555 San Clemente, CA 92801 l
u.
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 Simpsod, 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 Atomic Safety and Licensing Suite 308 Appeal Board Laguna Hills, CA 92653 U.S. Nuclear Regulatory Commission Alan R. Watts, Esq.
Washington, D.C. 20555 Rourke & Woodruff California First Bank Building Atomic Safety and Licensing 10555 North Main Street Board Santa Ana, CA 92701 U.S. Nuclear Regulatory Commission Gary D. Cotton Washington, D.C. 20555 Louis Bernath San Diego Gas & Electric Co.
Samuel J. Chilk 101 Ash Street Secretary of the Commission P.O. Box 1831 U.S. Nuclear Regulatory San Diego, CA 92112 Commission Washington, D.C. 20555 Executed on October 8, 1982, in the City and County of San Francisco, State of California.
I declare under penalty of perjury that the foregoing is true and correct.
KAREN ANDRESEN 2
a
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 94111.
I served the foregoing APPLICANTS' POSITION ON LICENSING BOARD'S REQUEST FOR DIRECTION ON WHETHER TO PROCEED TO HEARINGS dated October 13, 1982, by depositing a true copy thereof enclosed in the United States mail, first class (or by Express Mail, where asterisked) at San Francisco, California, on October 13, 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 U.S. Nuclear Regulatory Commission University of California Washington, D.C.
20555 P.O. Box 247 Bodega Bay, CA 94923 Dr. Reginald 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. Kelley, 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 Nuclear Regulatory Commission GUARD Office of the Executive Legal Director 3908 Calle Ariana Washington, D.C.
20555 San Clemente, CA 92801
4 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.
24012 Calle de la Plata Atomic Safety and Licensing Suite 330 Appeal Board Laguna Hills, CA 92653 U.S. Nuclear Regulatory Commission Alan R. Watts, Esq.
Washington, D.C.
20555 Rourke & Woodruff California First Bank Building Atomic Safety and Licensing 10555 North Main Street Board Santa Ana, CA 92701 U.S. Nuclear Regulatory Commission Gary D. Cotton Washington, D.C.
20555 Louis Bernath San Diego Gas & Electric Co.
Samuel J. Chilk 101 Ash Street Secretary of the Commission P.O.
Box 1831 U.S. Nuclear Regulatory San Diego, CA 92112 Commission Washington, D.C.
20555 Executed on October 13, 1982, in the City and County of San Francisco, State of California.
I declare under penalty of perjury that the foregoing is true and correct.
KAREN ANDRESEN 2
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