|
---|
Category:INTERVENTION PETITIONS
MONTHYEARML20046D0121993-08-0909 August 1993 Pacific Gas & Electric Co Response to Supplemental Requests for Production of Documents Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc.Related Correspondence ML20045D1991993-06-11011 June 1993 PG&E Supplemental Response to Miscellaneous Requests for Production of Documents Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc.Related Correspondence ML20045A6571993-05-28028 May 1993 PG&E Response to Second Set of Supplemental Interrogatories & Requests for Production of Documents Cable Failures at Dcnpp Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc.Related Correspondence ML20045A6501993-05-26026 May 1993 PG&E Response to Miscellaneous Requests for Production of Documents Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc.Related Correspondence ML20056C0921993-03-16016 March 1993 San Luis Obispo Mothers for Peace Second late-filed Contention.* Suppls San Luis Obispo Mothers for Peace Suppl to Petition to Intervene.License Extension Request Should Be Denied Until Situation Resolved.W/Certificate of Svc ML20128B8181992-11-30030 November 1992 NRC Staff Response to San Luis Obispo Mothers for Peace Suppl to Petition to Intervene.* Petitioner 920818 Petition Requesting Hearing as Suppl by 921026 Suppl to Petition to Intervene Should Be Denied ML20128A1301992-11-18018 November 1992 Pacific Gas & Electric Co Response to Petitioner Suppl to Petition to Intervene.* Certificate of Svc Encl ML20116F0321992-10-26026 October 1992 San Luis Obispo Mothers for Peace Suppl to Petition to Intervene.* Petitioner Requests That PG&E Be Denied Request for Extension of License & That NEPA Stds Be Met. W/Certificate of Svc ML20127D5071992-09-0404 September 1992 Pacific Gas & Electric Co Answer to Request for Hearing & Petition to Intervene.* Ltr, Requesting Hearing & Intervenor Status Does Not Satisfy Requirements for Intervention & Should Be Denied.W/Certificate of Svc ML20247Q6091989-07-24024 July 1989 Sierra Club Request to Withdraw Contentions.* Requests That All Outstanding Contentions in Current Proceedings Be Withdrawn W/Understanding That Further Discussion W/Nrc Re Implementation of NEPA Will Occur.W/Certificate of Svc ML20151T4351988-04-25025 April 1988 Amended Petition to Intervene.* License Condition 2.C.(7) of Full Power License DPR-80 Requires That Long Term Seismic Program Final Rept Be Submitted on 880731.Util License Amend Request Inadequate & Must Be Denied.W/Certificate of Svc ML20155H1111986-05-0909 May 1986 Response Supporting Amended Petitions of San Louis Obispo Mothers for Peace,Consumers Organized for Defense of Environ Safety & Sierra Club for Leave to Intervene & Request for Hearing.W/Certificate of Svc ML20203L5191986-04-26026 April 1986 Petition of Consumers Organized for Defense of Environ Safety for Leave to Intervene & Request for Hearing ML20203L5361986-04-26026 April 1986 Contentions Opposing Util Request to Increase Waste Storage by Reracking Spent Fuel Pools.Alternatives to Reracking Not Considered.Consideration of Seismic Design Premature Since Program Not to Be Completed Until 1988 ML20203G2681986-04-24024 April 1986 Contentions of Sierra Club Re Consideration of Issuance of Amends to Licenses DPR-80 & DPR-82 on Proposed Reracking of Spent Fuel Pools & Proposed NSHC Determination Before NRC ML20210K6791986-04-22022 April 1986 Contentions on Util Request to Increase Waste Storage by Reracking Spent Fuel Pools.Alternatives to Proposed Reracking Listed,Including Contracting Out or Transshipment of Spent Fuel for Storage at govt-owned Spent Fuel Facility ML20147D9761986-03-17017 March 1986 Mothers for Peace Amend to Petition to Intervene.* Forwards Sworn Statement from N Culver Authorizing Mothers for Peace to Act on Her Behalf in NRC Proceedings Re Util Application Re Spent Fuel Storage.W/O Statement.Served on 860325 ML20154D5581986-03-0303 March 1986 Response Opposing Consumers Organized for Defense of Environ Safety & Sierra Club Petition for Leave to Intervene Re Util Request to Increase Spent Fuel Storage Capacity.W/Notice of Appearance & Certificate of Svc ML20154C2911986-02-27027 February 1986 Response to Mothers for Peace 860207 Petition for Leave to Intervene Re Util Request for Amends to Licenses DPR-80 & DPR-82,increasing Spent Fuel Storage Capacity.Time Needed to Satisfy Standing Requirements.W/Certificate of Svc ML20154B7811986-02-27027 February 1986 Answer to Consumers Organized for Defense of Environ Safety (Codes) Petition for Leave to Intervene.Petition Fatally Defective & Should Be Denied.Certificate of Svc Encl ML20205J7621986-02-12012 February 1986 Petition of Consumers Organized for Defense of Environ Safety for Leave to Intervene & Request for Hearing.Served on 860225 ML20205J6821986-02-10010 February 1986 Petition of Sierra Club for Leave to Intervene in Any Hearing Called by Commission to Hear Arguments on Amends to Licenses DPR-80 & DPR-82.Served on 860225 ML20147E0081986-02-0707 February 1986 License Amend to Rerack Spent Fuel Pools.* Request for Hearing & Petition for Leave to Intervene in Consideration of Issuance of Amends to Licenses DPR-80 & DPR-82 Re Spent Fuel Pool Reracking ML20087J1931984-03-20020 March 1984 Renewal of Application for Stay to Permit Review of Joint Intervenors Emergency Motion.Unexecuted Affidavit of M Kaku & Certificate of Svc Encl ML20087F2181984-03-15015 March 1984 Motion for Leave to File Reply to Util Answer in Opposition to Motion to Reopen Record.Certificate of Svc Encl ML20080B5181984-02-0303 February 1984 Motion for Leave to File Reply to Util & NRC Answers to Joint Intervenors 840109 Petition for Review of ALAB-756 ML20090H3641983-10-25025 October 1983 Reply to Util Objections to Joint Intervenors Proposed Exhibits.Objections Should Be Overruled.Certificate of Svc Encl ML20085L3571983-10-20020 October 1983 Objection to Joint Intervenors Proposed Exhibits 128 & 129 & State of CA Governor Exhibit 11 Re Design Qa.Exhibits Irrelevant & Immaterial to Proceeding.Certificate of Svc Encl ML20078F5591983-10-0404 October 1983 Response Opposing Governor Deukmejian & Joint Intervenors 830929 Addl Contentions on Qa.Contentions Lack Specificity &/Or Fail to Meet Criteria for late-filed Contentions. Certificate of Svc Encl ML20080M5911983-09-29029 September 1983 Addl Contentions on Design QA ML20078B5191983-09-22022 September 1983 Response Opposing Governor Deukmejian & Joint Intervenors 830908 Particularization of Contentions 3 & 4 Submitted Per Aslab 830826 Order.Contentions Are Unaccompanied by Facts Upon Which Claims Based.Certificate of Svc Encl ML20078A5151983-09-21021 September 1983 Answer Opposing Joint Intervenors 830906 Request for Hearing on Decision to Lift Suspension of License DPR-76.No Legal or Factual Basis Provided.Precedent Re TMI Restart Hearing Inapplicable.Certificate of Svc Encl ML20080J2731983-09-21021 September 1983 Response Opposing Joint Intervenors 830908 Request for Formal Hearing on Reinstatement of Low Power Ol.Neither Atomic Energy Act Nor Rationale for TMI-1 Hearing Mandates Formal Hearing.Certificate of Svc Encl ML20080F1031983-09-13013 September 1983 Answer Opposing Joint Intervenors 830829 Request for Hearing on Util 830817 Request for Extension of License DPR-76 from 1 to 3 Yrs from Date of Issuance.Request Subsumed by full-term OL Request.Certificate of Svc Encl ML20077N3701983-09-0808 September 1983 Governor Deukmejian & Joint Intervenors Contentions on Design Qa.Certificate of Svc Encl ML20081A4551983-09-0808 September 1983 Contentions on Design QA Re Verification of Samples for Idvp ML20024F3691983-09-0606 September 1983 Request for Hearing on Issues Re Lifting of Suspended Low Power OL & Effectiveness of 1-yr Low Power OL 2 Yrs After Issuance.Certificate of Svc Encl ML20076G8921983-08-29029 August 1983 Request for Hearing on 830817 Application for Amend to License DPR-76 to Extend Term of Suspended Low Power OL to 3 Yrs from Date of Issuance.Certificate of Svc Encl ML20076B9741983-08-16016 August 1983 Reply to Util & NRC Responses to Joint Intervenors & Governor Deukmejian Contentions on Design Qa.Adequate Basis for Contentions Supplied by June 1982 Motion to Reopen Record.Certificate of Svc Encl ML20080C2291983-08-16016 August 1983 Reply to Util & NRC Responses to Governor Deukmejian Contentions on Design Qa.Focus of Hearing Should Be on Effectiveness of Idvp & Internal Technical Program (ITP) & Whether Programs Assure Safety.Certificate of Svc Encl ML20024D6191983-08-0101 August 1983 Response Opposing Governor Deukmejian & Joint Intervenors Proposed Contentions on Design Qa.Contentions Should Be Dismissed for Noncompliance W/Applicable Regulations & Case Law.Certificate of Svc Encl ML20077F9121983-07-19019 July 1983 Contentions Re Failure of Applicant & Major Subcontractors to Develop & Implement Timely Qa/Qc Program for Design & Redesign of Structures,Sys & Components Important to Safety ML20024D2201983-07-15015 July 1983 Contentions of Governor Deukmejian Re Failure of Applicant & Major Subcontractors to Develop & Implement Timely Qa/Qc Program for Design & Redesign of Structures,Sys & Components Important to Safety ML20027B2501982-09-13013 September 1982 Reply to Util Opposition to Joint Intervenors 820811 Request for Hearing on Util 820803 Application for Amend to Unit 1 Ol.Regulations Provide No Distinction Between Amend to OL & Amend for OL Renewal.Certificate of Svc Encl ML20063K2561982-09-0101 September 1982 Response Supporting Joint Intervenors 820817 Request for Hearing.Util Application for License Amend Extending Suspended Low Power OL Expiration Date Requires Hearing. Certificate of Svc Encl ML20063M2191982-09-0101 September 1982 Reply Opposing Joint Intervenor 820817 Request for Hearing on Util Application for Renewal of Low Power Ol.License Renewals Are Not Amends within Rules Governing Proceedings. Certificate of Svc Encl ML20062M9371982-08-17017 August 1982 Request for Hearing on Util 820803 Application for Amend to License DPR-76,which Would Renew Low Power License Granted on 810921 & Suspended on 811119.Certificate of Svc Encl ML20236N2081974-01-23023 January 1974 Answer to 740114 Petition for Leave to Intervene Filed by Jj Forster & L Valentine.Petition Should Be Denied. Certificate of Svc Encl ML20236N2861973-11-20020 November 1973 Petition of Jj Forster & L Valentine for Leave to Intervene ML20236N3151973-11-15015 November 1973 Petition of Ee Apfelberg & SA Silver as Representatives of San Luis Obispo Mothers of Peace for Leave to Intervene 1993-08-09
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20046D0121993-08-0909 August 1993 Pacific Gas & Electric Co Response to Supplemental Requests for Production of Documents Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc.Related Correspondence ML20045D1991993-06-11011 June 1993 PG&E Supplemental Response to Miscellaneous Requests for Production of Documents Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc.Related Correspondence ML20045A6571993-05-28028 May 1993 PG&E Response to Second Set of Supplemental Interrogatories & Requests for Production of Documents Cable Failures at Dcnpp Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc.Related Correspondence ML20045A6501993-05-26026 May 1993 PG&E Response to Miscellaneous Requests for Production of Documents Filed by San Luis Obispo Mothers for Peace.* W/Certificate of Svc.Related Correspondence ML20056C0921993-03-16016 March 1993 San Luis Obispo Mothers for Peace Second late-filed Contention.* Suppls San Luis Obispo Mothers for Peace Suppl to Petition to Intervene.License Extension Request Should Be Denied Until Situation Resolved.W/Certificate of Svc ML20128B8181992-11-30030 November 1992 NRC Staff Response to San Luis Obispo Mothers for Peace Suppl to Petition to Intervene.* Petitioner 920818 Petition Requesting Hearing as Suppl by 921026 Suppl to Petition to Intervene Should Be Denied ML20128A1301992-11-18018 November 1992 Pacific Gas & Electric Co Response to Petitioner Suppl to Petition to Intervene.* Certificate of Svc Encl ML20116F0321992-10-26026 October 1992 San Luis Obispo Mothers for Peace Suppl to Petition to Intervene.* Petitioner Requests That PG&E Be Denied Request for Extension of License & That NEPA Stds Be Met. W/Certificate of Svc ML20127D5071992-09-0404 September 1992 Pacific Gas & Electric Co Answer to Request for Hearing & Petition to Intervene.* Ltr, Requesting Hearing & Intervenor Status Does Not Satisfy Requirements for Intervention & Should Be Denied.W/Certificate of Svc ML20247Q6091989-07-24024 July 1989 Sierra Club Request to Withdraw Contentions.* Requests That All Outstanding Contentions in Current Proceedings Be Withdrawn W/Understanding That Further Discussion W/Nrc Re Implementation of NEPA Will Occur.W/Certificate of Svc ML20151T4351988-04-25025 April 1988 Amended Petition to Intervene.* License Condition 2.C.(7) of Full Power License DPR-80 Requires That Long Term Seismic Program Final Rept Be Submitted on 880731.Util License Amend Request Inadequate & Must Be Denied.W/Certificate of Svc ML20155H1111986-05-0909 May 1986 Response Supporting Amended Petitions of San Louis Obispo Mothers for Peace,Consumers Organized for Defense of Environ Safety & Sierra Club for Leave to Intervene & Request for Hearing.W/Certificate of Svc ML20203L5191986-04-26026 April 1986 Petition of Consumers Organized for Defense of Environ Safety for Leave to Intervene & Request for Hearing ML20203L5361986-04-26026 April 1986 Contentions Opposing Util Request to Increase Waste Storage by Reracking Spent Fuel Pools.Alternatives to Reracking Not Considered.Consideration of Seismic Design Premature Since Program Not to Be Completed Until 1988 ML20203G2681986-04-24024 April 1986 Contentions of Sierra Club Re Consideration of Issuance of Amends to Licenses DPR-80 & DPR-82 on Proposed Reracking of Spent Fuel Pools & Proposed NSHC Determination Before NRC ML20210K6791986-04-22022 April 1986 Contentions on Util Request to Increase Waste Storage by Reracking Spent Fuel Pools.Alternatives to Proposed Reracking Listed,Including Contracting Out or Transshipment of Spent Fuel for Storage at govt-owned Spent Fuel Facility ML20147D9761986-03-17017 March 1986 Mothers for Peace Amend to Petition to Intervene.* Forwards Sworn Statement from N Culver Authorizing Mothers for Peace to Act on Her Behalf in NRC Proceedings Re Util Application Re Spent Fuel Storage.W/O Statement.Served on 860325 ML20154D5581986-03-0303 March 1986 Response Opposing Consumers Organized for Defense of Environ Safety & Sierra Club Petition for Leave to Intervene Re Util Request to Increase Spent Fuel Storage Capacity.W/Notice of Appearance & Certificate of Svc ML20154C2911986-02-27027 February 1986 Response to Mothers for Peace 860207 Petition for Leave to Intervene Re Util Request for Amends to Licenses DPR-80 & DPR-82,increasing Spent Fuel Storage Capacity.Time Needed to Satisfy Standing Requirements.W/Certificate of Svc ML20154B7811986-02-27027 February 1986 Answer to Consumers Organized for Defense of Environ Safety (Codes) Petition for Leave to Intervene.Petition Fatally Defective & Should Be Denied.Certificate of Svc Encl ML20205J7621986-02-12012 February 1986 Petition of Consumers Organized for Defense of Environ Safety for Leave to Intervene & Request for Hearing.Served on 860225 ML20205J6821986-02-10010 February 1986 Petition of Sierra Club for Leave to Intervene in Any Hearing Called by Commission to Hear Arguments on Amends to Licenses DPR-80 & DPR-82.Served on 860225 ML20147E0081986-02-0707 February 1986 License Amend to Rerack Spent Fuel Pools.* Request for Hearing & Petition for Leave to Intervene in Consideration of Issuance of Amends to Licenses DPR-80 & DPR-82 Re Spent Fuel Pool Reracking ML20087J1931984-03-20020 March 1984 Renewal of Application for Stay to Permit Review of Joint Intervenors Emergency Motion.Unexecuted Affidavit of M Kaku & Certificate of Svc Encl ML20087F2181984-03-15015 March 1984 Motion for Leave to File Reply to Util Answer in Opposition to Motion to Reopen Record.Certificate of Svc Encl ML20080B5181984-02-0303 February 1984 Motion for Leave to File Reply to Util & NRC Answers to Joint Intervenors 840109 Petition for Review of ALAB-756 ML20090H3641983-10-25025 October 1983 Reply to Util Objections to Joint Intervenors Proposed Exhibits.Objections Should Be Overruled.Certificate of Svc Encl ML20085L3571983-10-20020 October 1983 Objection to Joint Intervenors Proposed Exhibits 128 & 129 & State of CA Governor Exhibit 11 Re Design Qa.Exhibits Irrelevant & Immaterial to Proceeding.Certificate of Svc Encl ML20078F5591983-10-0404 October 1983 Response Opposing Governor Deukmejian & Joint Intervenors 830929 Addl Contentions on Qa.Contentions Lack Specificity &/Or Fail to Meet Criteria for late-filed Contentions. Certificate of Svc Encl ML20080M5911983-09-29029 September 1983 Addl Contentions on Design QA ML20078B5191983-09-22022 September 1983 Response Opposing Governor Deukmejian & Joint Intervenors 830908 Particularization of Contentions 3 & 4 Submitted Per Aslab 830826 Order.Contentions Are Unaccompanied by Facts Upon Which Claims Based.Certificate of Svc Encl ML20078A5151983-09-21021 September 1983 Answer Opposing Joint Intervenors 830906 Request for Hearing on Decision to Lift Suspension of License DPR-76.No Legal or Factual Basis Provided.Precedent Re TMI Restart Hearing Inapplicable.Certificate of Svc Encl ML20080J2731983-09-21021 September 1983 Response Opposing Joint Intervenors 830908 Request for Formal Hearing on Reinstatement of Low Power Ol.Neither Atomic Energy Act Nor Rationale for TMI-1 Hearing Mandates Formal Hearing.Certificate of Svc Encl ML20080F1031983-09-13013 September 1983 Answer Opposing Joint Intervenors 830829 Request for Hearing on Util 830817 Request for Extension of License DPR-76 from 1 to 3 Yrs from Date of Issuance.Request Subsumed by full-term OL Request.Certificate of Svc Encl ML20077N3701983-09-0808 September 1983 Governor Deukmejian & Joint Intervenors Contentions on Design Qa.Certificate of Svc Encl ML20081A4551983-09-0808 September 1983 Contentions on Design QA Re Verification of Samples for Idvp ML20024F3691983-09-0606 September 1983 Request for Hearing on Issues Re Lifting of Suspended Low Power OL & Effectiveness of 1-yr Low Power OL 2 Yrs After Issuance.Certificate of Svc Encl ML20076G8921983-08-29029 August 1983 Request for Hearing on 830817 Application for Amend to License DPR-76 to Extend Term of Suspended Low Power OL to 3 Yrs from Date of Issuance.Certificate of Svc Encl ML20076B9741983-08-16016 August 1983 Reply to Util & NRC Responses to Joint Intervenors & Governor Deukmejian Contentions on Design Qa.Adequate Basis for Contentions Supplied by June 1982 Motion to Reopen Record.Certificate of Svc Encl ML20080C2291983-08-16016 August 1983 Reply to Util & NRC Responses to Governor Deukmejian Contentions on Design Qa.Focus of Hearing Should Be on Effectiveness of Idvp & Internal Technical Program (ITP) & Whether Programs Assure Safety.Certificate of Svc Encl ML20024D6191983-08-0101 August 1983 Response Opposing Governor Deukmejian & Joint Intervenors Proposed Contentions on Design Qa.Contentions Should Be Dismissed for Noncompliance W/Applicable Regulations & Case Law.Certificate of Svc Encl ML20077F9121983-07-19019 July 1983 Contentions Re Failure of Applicant & Major Subcontractors to Develop & Implement Timely Qa/Qc Program for Design & Redesign of Structures,Sys & Components Important to Safety ML20024D2201983-07-15015 July 1983 Contentions of Governor Deukmejian Re Failure of Applicant & Major Subcontractors to Develop & Implement Timely Qa/Qc Program for Design & Redesign of Structures,Sys & Components Important to Safety ML20027B2501982-09-13013 September 1982 Reply to Util Opposition to Joint Intervenors 820811 Request for Hearing on Util 820803 Application for Amend to Unit 1 Ol.Regulations Provide No Distinction Between Amend to OL & Amend for OL Renewal.Certificate of Svc Encl ML20063K2561982-09-0101 September 1982 Response Supporting Joint Intervenors 820817 Request for Hearing.Util Application for License Amend Extending Suspended Low Power OL Expiration Date Requires Hearing. Certificate of Svc Encl ML20063M2191982-09-0101 September 1982 Reply Opposing Joint Intervenor 820817 Request for Hearing on Util Application for Renewal of Low Power Ol.License Renewals Are Not Amends within Rules Governing Proceedings. Certificate of Svc Encl ML20062M9371982-08-17017 August 1982 Request for Hearing on Util 820803 Application for Amend to License DPR-76,which Would Renew Low Power License Granted on 810921 & Suspended on 811119.Certificate of Svc Encl ML20236N2081974-01-23023 January 1974 Answer to 740114 Petition for Leave to Intervene Filed by Jj Forster & L Valentine.Petition Should Be Denied. Certificate of Svc Encl ML20236N2861973-11-20020 November 1973 Petition of Jj Forster & L Valentine for Leave to Intervene ML20236N3151973-11-15015 November 1973 Petition of Ee Apfelberg & SA Silver as Representatives of San Luis Obispo Mothers of Peace for Leave to Intervene 1993-08-09
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARDCL-99-123, Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations1999-09-20020 September 1999 Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations ML20205N4081999-04-14014 April 1999 Comments Opposing Proposed Rules 10CFR2,19 & 20 Re Proposed Repository at Yucca Mountain.Requests Information on How Much Radiation Being Released Now at Diablo & Hanford NPPs ML20205N4601999-03-21021 March 1999 Introduces K Schumann as Representative of Nuclear Waste Committee (Nuwic) of San Lius Obispo County.Informs That Nuwic & Nuclear Waste Management Committee Concerned with Transportation of Spent Nuclear Fuel Rods from Dcnpp ML20195E8841998-11-24024 November 1998 Petition for Mod to OLs to Require Plant Owner to Have Independent Contractor Evaluate Plant Safety Culture ML20236T3011998-07-24024 July 1998 Order Prohibiting Involvement in NRC Licensed Avtivities (Effective Immediately).Lh Brooks Prohibited for 5 Yrs from Date of Order from Engaging in NRC Licensed Activities ML20248C2261998-05-22022 May 1998 Comment Opposing Revised Proposed Rule 10CFR50 Re Protection & Safety Sys ML20129J4191996-10-18018 October 1996 Order Approving Application Re Corporate Restructuring of Pacific Gas & Electric Company by Establishment of Holding Company DCL-95-206, Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations1995-10-0606 October 1995 Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations ML20091P8721995-08-23023 August 1995 Comment Opposing Petition for Rulemaking PRM-50-61 Re Nuclear Energy Institute Proposed Amends on Fire Safety for All NPPs DCL-95-001, Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments1995-01-0303 January 1995 Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments ML20077M7521994-12-30030 December 1994 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operation for Nuclear Power Reactors DCL-94-270, Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal1994-12-0808 December 1994 Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal ML20149H0851994-11-0404 November 1994 Initial Decision (Construction Period Recovery/Recapture).* Renewed Motion to Reopen Record 940808,denied.Served on 941104.W/Certificate of Svc ML20072L2651994-08-23023 August 1994 PG&E Opposition to San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record.* Util Opposes San Luis Obispo for Peace Motion Based on Affidavit Stating No Evidence Found in Motion Re Flaw in Program.W/Certificate of Svc ML20072F0291994-08-12012 August 1994 Erratum to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Intervenors Corrects Error in Renewed Motion to Reopen Record Re Application for License Amend to Extend Term of Operating License for Plant.W/Certificate of Svc ML20072B2651994-08-0909 August 1994 Comment Supporting Proposed Rule 10CFR26 Re FFD Requirements Concerning Random Drug Testing ML20072A5821994-08-0808 August 1994 San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record Re PG&E Application for Amend to Extend Term of OL for Plant.* Motion to Reopen Record to Introduce Insp Rept Identifying Alleged Problems W/Plant.W/Certificate of Svc ML20071L2061994-07-26026 July 1994 Comment Supporting Proposed Rule 10CFR26 Re Changing Current Drug Testing Policies to Exclude All Personnel in nonsafety-related Positions ML20072B8481994-07-26026 July 1994 Comment Opposing Proposed Rule 10CFR26 Re Changes to FFD Requirements Concerning Random Drug Testing ML20071L1901994-07-20020 July 1994 Comments on Proposed Rule 10CFR26 Re Relaxing Rule on Drug Testing of Employees Working at NPP DCL-94-134, Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program DCL-94-135, Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs ML20064D1791994-03-0707 March 1994 Pacific Gas and Electric Co Reply in Opposition to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Motion to Reopen Record Denied.W/Certificate of Svc ML20064D1961994-03-0404 March 1994 Affidavit of Mj Angus Re Motion to Reopen Record ML20063L5721994-02-25025 February 1994 San Luis Obispo Mothers for Peace Re Util Application for License Amend to Extend Term of Operating License for Plant.* Advises That Record of Proceeding Should Be Reopened to Consider Insp 93-36 Re Util Surveillance of Asw Sys DCL-94-021, Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation1994-01-26026 January 1994 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation ML20059D2431994-01-0707 January 1994 Package of Intervenor Exhibits Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20062N0001993-12-30030 December 1993 PG&E Reply Findings of Fact & Conclusions of Law.* Mothers for Peace Proposed Findings & Conclusions Do Not Provide Any Supportable Rationale to Change Findings & Conclusions Previously Proposed by Pg&E.W/Certificate of Svc ML20058P3931993-12-22022 December 1993 NRC Staff Findings of Fact & Conclusions of Law in Form of Initial Decision.* Certificate of Svc ML20058K7491993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Board Has Extended Filing Time for Util Until 931230.W/Certificate of Svc. Served on 931206.Granted for Board on 931203 ML20058K8771993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Requests That Board Extend Date for Staff to File Findings Until 931222. W/Certificate of Svc ML20059M5291993-11-19019 November 1993 Applicant Exhibits A-21,A-22,A-24,A-25,A-26,A-29 & A-F1, Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20058E0741993-11-19019 November 1993 San Luis Obispo Mothers for Peace Proposed Findings of Fact & Conclusions of Law Re Licensee Application for License Amend to Extend Term of Operating License for Plant.* W/ Certificate of Svc ML20059E8931993-10-28028 October 1993 Memorandum & Order (Motion for Extension of Time).* San Luis Obispo Mothers for Peace 931018 Request for two-wk Extension of Time to File Proposed Findings of Fact & Conclusions of Law Granted.W/Certificate of Svc.Served on 931029 ML20059E8531993-10-27027 October 1993 NRC Staff Response to Board Memorandum & Order Re Extension of Time.* Staff Believes That San Luis Obispo Mothers for Peace Has Shown No Good Cause for Requesting Extension to File Proposed Findings of Fact.W/Certificate of Svc ML20059E8631993-10-25025 October 1993 Pacific Gas & Electric Co Response to Motion for Extension of Time.* Util Does Not Agree W/Board Assessment That Mothers for Peace Request Appears to Be Reasonable But Will Not Oppose Request.W/Certificate of Svc ML20059B2191993-10-19019 October 1993 Memorandum & Order (Responses to Motion for Extension of Time).* Board Believes Intervenor Request for Extension of Time to File Proposed Findings of Fact Appears Reasonable. W/Certificate of Svc.Served on 931019 ML20059B1071993-10-18018 October 1993 San Luis Obispo Mothers for Peace Motion for Extension of Time for Filing Proposing Findings of Fact & Conclusions of Law.* Requests Extension of Two Wks or Until 931119 to File Proposed Findings of Fact.W/Certificate of Svc ML20057D0531993-09-23023 September 1993 Notice of Appearance.* Notice Given That Undersigned Attorney Enters Appearance in Listed Matter & Listed Info Provided.W/Certificate of Svc ML20057B0401993-09-14014 September 1993 NRC Staff Reply to PG&E Response to Staff Motion to Amend Protective Order.* NRC Staff Moves Board to Adopt Language Requested in 930817 Motion as Stated.W/Certificate of Svc ML20056G4891993-08-30030 August 1993 Pacific Gas & Electric Co Response to Motion to Amend Protective Order.* Staff Asks That Protective Order Be Clarified by Adding New Footnote to Paragraph 3 of Order. W/Certificate of Svc ML20059M1381993-08-24024 August 1993 Staff Exhibit S-1,consisting of Re 920519 Enforcement Conference ML20059D2071993-08-24024 August 1993 Intervenor Exhibit I-MFP-193,consisting of Review of LER 1-90-015-00,re Docket 50-275,dtd 910118 ML20059D2241993-08-24024 August 1993 Intervenor Exhibit I-MFP-220,consisting of Protest of Util ML20059M8621993-08-24024 August 1993 Intervenor Exhibit I-MFP-35,consisting of Rept, Self- Evaluation of Diablo Canyon Power Plant, Dtd Jul 1993 IR 05000275/19920261993-08-24024 August 1993 Intervenor Exhibit I-MFP-118,consisting of Notice of Violation & Insp Rept Re Docket 50-275/92-26 & 50-323/93-26,dtd 921113 ML20059D0841993-08-24024 August 1993 Intervenor Exhibit I-MFP-139,consisting of Insp Rept Re Dockets 50-275 & 50-323,dtd 920417 IR 05000275/19920131993-08-24024 August 1993 Intervenor Exhibit I-MFP-140,consisting of 920416,mgt Meeting Repts 50-275/92-13 & 50-323/92-13 IR 05000275/19910061993-08-24024 August 1993 Intervenor Exhibit I-MFP-71,consisting of Rept of EC W/Util Mgt,Re Rept Numbers 50-275/91-06 & 50-323/91-06,dtd 910411 IR 05000275/19930111993-08-24024 August 1993 Intervenor Exhibit I-MFP-26,consisting of Re Insp Repts 50-275/93-11 & 50-323/93-11 1999-09-20
[Table view] |
Text
r n'
i 00CKETED UNITED STATES OF AMERICA' USN.tc NUCLEAR REGULATORY COMMISSION
~
ATOMIC SAFETY'AND LICENSING APPEAL B P 12 di:18 C,5 9 EE C ~ SI m n -
In the Matter of' ) b p c .p .;5. ,,7
) < .N PACIFIC GAS -AND ELECTRIC COMPANY ) Docket Nos. 50-275 OL
) 50-323 OL
= (Diablo Canyon Nuclear Power )
Plant, Units 1 and 2) )
__ .. )
GOVERNOR DEUKMEJIAN'S AND JOINT. INTERVENORS '
-CONTENTIONS : ON DESIGN QUALITY ASSURANCE Pursuant to the Atomic Safety' and L'icensing Appeal s
- Board's August:26, 1983; order. Governor Deukmejian and the Joint Intervenors hereby-submit their contentions on' design quality ~ assurance. For the convenience of the board and the 4
- parties, the contentions are stated in their' entirety, with i the matters added with this filing underscored.
- 1. The' scope of'the IDVP review of both the seismic and non-seismic. aspects of the designs of safety-related c systems, structurgs.and components (SS&C's) was too narrow in the following respects
.(a) The IDVP did not verify samples from each L design activity'(seismic and non-seismic).
l l- . (b) In the design activities the IDVP did review, l it-did not verify samples from each of the design groups
! .in' the design chain' performing the design activity.
l l -(c) The IDVP.did not have statistically valid samples from which to draw conclusions, i
!~ (d)- ~ Th'e IDVP failed to verify independently the analyses but merely checked data of inputs to models i- used by PG&E.
'N30913OO51 830908 e
- oa ^""
- 7J
. OsQS
2.
(e) The IDVP failed to verify the design of Unit 2. ,
- 2. The scope of the ITP review of both the seismic and non-seismic acpects of the designs of the safety-related systems, structures and components (SS&C's) was too narrow in the following respects:
(a) -The ITP did not verify samples from each design activity (seismic and non-seismic).
(b) In the design activities the ITP did review, it did not verify samples from each of the design groups in the design chain performing the design activity.
(c) The ITP did not have statistically valid samples from which to draw conclusions.
(d) The ITP has failed systematically to verify the adequacy of the design of Unit 2.
- 3. In various situations listed below the ITP used improper engineering standards to determine whether design
' activities met license criteria. In some of these situations the IDVP either used or approved the use of such improper standards or did not verify them at all.
(a) The ITP accepted the mean measured performance y of structures and materials in lieu of code-specified ;
minima in its seismic analysis for the Hosqri event of the containment, auxiliary building, fuel handling building, turbine building, and intake structure.
' ~
(b) The ITP failed to verify that the' stress and j load factors for steel used in the containment building were within code values in its seismic analysis for the Hosqri event. [
l (c). The ITP failed to specify all damping values used in various seismic modes in the containment and auxiliary buildings in that, for containment for the DE and the DDE, different damping values are used in different components of the system, but the resultinq values of damping for each mode in the modal analysis ,
are not specified. For the auxiliary building, values of damping for each mode in the modal analysis are not
. _ _ -.. , - . . - ~ _ .__ _ _ __. _. -.
j 3.
1 specified, and the ITP has-not specified what damping- -
4 values, if any, were used for the soil springs. :
. _ (d). The ITP failed to verify that PG&E's use of the double algebraic sum method of calculation (rather
, than the sum of the squares method) was an acceptable a substitution in the' Phase 1 Final Report's calculation L of member forces for the Hoscri event, where the double.
- algebraic sum method is used solely for closely spaced
- modes, and sum of the squares method is used elsewhere.
(e) The ITP's use of time-history modeling techniques for some accelerations, displacements and shell forces in the -containment structure and Blume
- response spectra for other accelerations, displacements
{ and shell forces in~the same structure was improper.
(f)' The ITP's modeling of_the soil properties for
- the containment and auxiliary buildings was improper in that
l (i) ' in the soil structure interaction analysis of containment for the DE and the DDE, use of boundary motion inputs to the model were improperly used;-
- (ii) the soil structure interaction analysis L for containment for the DE and'the-DDE uses a 7 percent damping value-for rock,-which is
' unconservative, especially for the DE; (iii) the dynamic analyses of the containment
- for all earthquakes omit any analysis of uplifting of the foundation mat; (iv) the modeling of the soil springs for the
( auxiliary building does not specify soil l- ' properties;
- . (v) in the modeling of the soil springs for
- the auxiliary building, the motion inputs to the lower ends of the springs does not account for all soil-structure interaction phenomena that could be expected.
~
g Tr ) .v- geg t*'s eW-' g-9 g- --pg. .y-g.e., ep.,9 93-,,+ g.g g wme %-gri- g,---*-.-w-y "g--M--em.-ame-Wwwg -,-gg-- g y3-wasgg.c .ay+my--** ygg,-p,.gy-miw-tg wag meegnee r e-yv'
- . . - . . .= .. _. . . --
l .-. .
I 4.
(g)_ The~ITP's modeling of the crane in the turbine building was improper in that it models the crane only for a single-(parked) position and load-(unloaded). l (h)' The ITP's modeling of torsion factors for different-buildings by diff,ering' techniques is improper in that PG&E's modeling of torsion factors is not shown to be conservative, and is unconservative in at least one case.
(i) ~The ITP's modeling of hydrodynamic forces for the' intake structure were improper.in that sloshing
[ _ effects for the inside water and hydrodynamic pressures i on the outside of the structure were not considered.
l-(j) The ITP's'modeling of the intake structure by using different models-for horizontal and vertical seismic loadings and combining vertical and horizontal responses was improper in'that the modeling of the crane combines linear and nonlinear analyses for the different i loads without justification.
(k) The ITP's modeling of the intake structure i
.by.using ductility factors for steel and concrete was j
~
. improper in that no explanation or iustification for
- ductility estimates are provided, and in that a post yield analvis was apparently done to determine pier ductility characteristics, also without justification or- !
listing of results. .
l !
l (1) The ITP's computations of modes in the i containment building having frequencies between 20 and ;
i 33 HZ was improper in that the analysis does not present data on the amount of mass accounted for by these modes, '
p and in that it is not clear that-criteria were correctly '
applied. ,
() The ITP's modeling of the containment building '
by failing to use two horizontal components for the DE.~
and DDE was improper in that it is not clear whether criteria were correctly applied.
I (n) The ITP's stress values for concrete in shear walls used in modeling the auxiliary building was improper in that the stress value (allowable) used for i
.-..~. _ . _ _ . . . _ _ _ . _ . - . _ . . _ - , _ . _ - - _ _ _ . _ _ , , _ _ _ _ . _ . . . , _ _ , _ . . __
l 5.- ,
i
^
~
shear-in the concrete walls-is large, is less
^ - conservative than what is provided in ACI 318-77, and-
-may cause wide cracks.
-t c 4. The IDVP ' accepted deviations from the licensing '
' criteria ~without providing adequate engineering '
j - justification:in the following respects:
- a. Contrary to'the requirements of FSAR Section s
. 17.1 regarding compliancelof the as-built :
p installation with the design documents, the j IDVP review-of the AFWS disclosed that the ~
as-built installation failed to meet the design drawings in that (i) a steam trap on -
- the turbine-driven AFW pump steam supply line is not provided and (ii) there are discrepancies in the-arrangement of the
~
long-term cooling water supply line.
- b. ' Contrary ~ to FSAR Section 8.3.3., the electrical design does not fully comply with the commitments regarding separation and color coding.
~
-c. Contrary-to the single failure criterion of Appendix - A to 10 CFR 'Part 50, a single failure may cause loss of redundant power divisions because redundant electric power division trains are electrically interconnected through two circuit' breakers and a single power transfer switch.
h d. Contrary to'GDC 57 of' Appendix A, valve operators for the isolation valves which i' provide the steam supply to the turbine-driven auxilirry feed pump from two
, of the main steam generators have not been ,
classified and procured as safety related components.
I
- e. The single failure of an auxiliary relay would '
. prevent automatic closure of the redundant e
I e, e av. %-w ,.-,w---c- ,~.,e+ ,,e,w,-. , ym-,m,e - n -- ...cv.,,,..e --w.. ,#-ir-w,-., ...y,, ,%,-,-yw+ww----y-ev,,g-,,~,-,,,me
8 6.
steam generator blowdown isolation valves on 4
automatic initiation of the AFWS contrary to a Westinghouse interface requirement and FSAR Fiqure 7.2-1.
- f. Contrary to NUREG 0588 regarding environmental qualifications, flow transmitter FT-78 and flow control valve FCV-95 are located in a harsh environment but were not listed as such in the PG&E Environmental Qualfication Report dated September 1981, and are not yet ,
environmentally adalified.
3 Contrary to the requirements of NUREG 0588 regarding environmental qualifications, portions-of the CRVPS were omitted from PG&E's Environmental Qualification _ report.
l
- h. Contrary to PG&E's September 14 and December 28, 1978 licensing commitments, CRVPS equipment identified in the FSAR as necessary to maintain control room habitability during safe shutdown has not been evaluated regarding the effects of a moderate energy pipe break.
- i. The fire protection for the motor driven AFW pump room is not consistent with the PG&E l
licensing commitment for fire zone separation l as stated in its November 13, 1978
! Supplemental Information for Fire Protection Review ( "S IFP R") in that:
11 there is a large grated ventilation i
opening in the ceiling of the room; 21 a fire damper has gaps when it is closed; i
I
- j. The fire protection for the AFW pump room is not consistent with the PG&E licensinq l
l 1
/
- - . . . . . - ..- .. - ._ __-.. = . ... .. . ..._ . . . . . . -.
l 7.
commitment for cable separation as stated in
- its SIFPR of November 13, 1978 in that:
ll, the pumps for the motor driven AFW pumps and the control circuitry for a flow control valve necessary for operation of the turbine driven AFW pump are located in a single fire zoner E
21 cables for some AFW circuits are not routed in accord with descriptions in the SIFPR and four AFW circuits PGEE committed to identify and review in the SIFPR were not included in that document.
- k. Contrary to the licensing commitment set .
forth in its SIFPR of November 13, 1978, each
- of the three 4160 volt-- cable spreading rooms has a ventilation opening leading up to the
, 4160 volt switchaear rooms.
1.
~
Contrary to FSAR Section 3.6, possible iet impingement loads have not been considered in the design and qualification of safety
. related piping and eauipment inside containment.
i
- m. Contrary to QA program commitments in FSAR Section 17.1, documented evidence is "
inadequate to demonstrate that rupture restraints outside and inside containment 1 have been properly designed and installed to provide protection against rupture in high pressure piping.
- n. For the containment exterior shell review the ITP review used the AISC Code rather than
. Section-III of the ASME Code contrary to the commitment in Table 3.2-4 of the FSAR.
mwe'--' -s ++-m,- w q-Tu-eg, q - r n -- *p**ge %=m-M.=*z-h-pry-yue wt e y y vw y -- w ww-w - w v- v- y wr,---a-4-t
m
~.,
4 8.
- o. ~ Contrary to the recuirements of NUREG-0588 regarding environmental qualifications, safety-related cables and cable splices which cou:.d be subject to a harsh environment dur:.no a high-energy line break are not identified :.n the PG&E Environmental Qualification Report.
- p. The NSC pipe break analysis, which is Appendix A to FSAR Section 3.6, did not include all likely sources of water in the calculation of flooding levels.
7 4'
.g. Contrary to PG&E's December- 28, 1979 licensing commitment letter to the NRC, modifications to protect two Auxiliary Feedwater valves from the effects of moderate energy line breaks were not implemented.
- r. Contrary to the licensing commitment to maintain minimum system redundancy as stated in FSAR Section 3.6A (NSC evaluation of pipe c break outside containment), four components were identified for which high energy line cracks cou:,d cause temperatures in excess of the specif:; cation temperatures of the components.
l
- s. Contrary to the licensinq commitment to '
t maintain ~ minimum system redundancy as stated in FSAR, section 3.6A (NSC evaluation of pipe L break outside containment) , a conduit was i identified whose failure due to a high energy line crack could eliminate redundant Auxiliary Feedwater system flow.
- t. Contrary to the FSAR Section 8.3 commitment to l- provide switchaear buses with adequate short circuit interrupting capability, the calculated duties for circuit breakers on I 4160 V buses F, G, and H were above the
- . nameplate ratings for those buses.
i
t'
- 9. .
~
- u. Contrary to single-failure criteria stated'in PSAR Section 3.1,lv reviews of the Auxiliary Feedwater and Control Room Ventilation and Pressurization systems identified circuit separation and single failure deficiencies.
SLm:.lar deficiencies were identified in add:.tional verification reviews, which included other safety-related systems.
.5. The verification program has not verified that Diablo Canyon Units.1 and 2 "as built" conform to the design drawings and analyses.
t
- 6. The verification program failed to verify that the design of ' safety related equipment supplied to PG&E by ,
Westinghouse met licensing criteria.
- 7. The' verification program failed to identify the root causes for the failures in the PG&E design quality assurance program and failed to-determine if such failures raise generic concerns.
- 8. The ITP failed to develop and implement in a timely manner a design quality assurance program-in accordance with 10 CFR Part 50, Appendix B to assure the quality of the recent design modifications to the Diablo Canyon facility
- and the.IDVP failed to ensure that the corrective and l
t 1
i a r r
=
l l
+ - e- , ,.. mar w-i,--s-e4---r- ww-.+,w +-r ww tv -o--, -,e w g , v -er- v r -n +i nr-w-ww-*s-"~v+-"-t*W** w e +-*'-"eWV W 'Pe-*We=Ye---t-wt -vf -**'
10.
preventative action programs implemented by the ITP are sufficient to assure that the Diablo Canyon facilities will meet licensing criteria.
DATED: SEPTEMBER f , 1983.
Respectfully submitted, JOHN K. VAN DE KAMP, Attorney General of the State of California ANDREA SHERIDAN ORDIN, Chief Assistant Attorney General MICHAEL J. STRUMWASSER, Special Counsel to the Attorney General SUSAN L. DURBIN, PETER H. KAUFMAN, Deputy Attorneys General
/ /
MICHAEL' , STRUMWASSER Attorneys for Governor George Deukmejian 3580 Wilshire Boulevard Los Angeles, California 90010 Telephone: (213) 736-2102 JGEL R. REYNOLDS, Esq.
JOHN R. PHILLIPS, Esq.
ERIC HAVIAN, Esq.
Center For Law in the Public Interest 10951 West Pico Boulevard
.Los Angeles, California 90064 Telephone: (213) 470-3000 DAVID S. FLEISCHAKER, Esq.
P . O. B ox 1178 Oklahoma City, Oklahoma 73101 BY JO REYNDfdPpg Attorneys for Joint Intervenors SAN LUIS OBISPO MOTHERS FOR PEACE SCENIC SHORELINE PRESERVAI' ION CONFERENCE, INC.
ECOLOGY ACTION CLUB SANDRA SILVER ELIZABETH APFELBERG JOHN J. FORSTER
j l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
~
)
In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 0.L.
) 50-323 0.L.
(Diablo Canyon Nuclear Power ) '
Plant, Units 1 and 2) )
)
)
CERTIFICATE OF SERVICE I hereby certify that on this date I caused copies of the foregoing GOVERNOR DEUKMEJIAN'S AND JOINT INTERVENORS' CONTENTIONS ON DESIGN QUALITY ASSURANCE served on the following by United States Mail, First Class (except for those persons marked with an asterisk ("*"), to whom the envelope was posted Express Mail) , postage prepaid.
Hon. Nunzio Palladino, Chairman U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C. 20555 Hon. Victor Gilinsky, Commissioner U.S. Nuclear Regulatory Commission 1717 H S tr ee t , N .W.
Washington, D.C. 20555 Hon. Thomas Roberts, Commissioner U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C. 20555 1.
Hon. James Asselstine, Commissioner U.S. Nuclear Regulatory Commission 1717 H S tree t , N .W.
Washington, D.C. 20555 Hon. Frederick M. Bernthal, Commissioner U.S. Nuclear Regulatory Commission 1717 H S tree t , N .W.
Washington, D.C. 20555 0
Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Hon. Thomas S. Moore, Chairman
- Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Hon. W. Reed Johnson
- Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Hon. John H. Buck
- Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 Judge John F. Wolf, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission ,
Washington, D.C. 20555 Judge Glenn O. Bright Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Judge Jerry R. Kline Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 2.
Harold Denton Director of Nuclear Reactor Regulation-U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Leonard Bickwit, Esq.
Office of the General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Lawrence Chandler, Esq.
Office of Executive Legal Director BETH 042 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Section Mrs. Elizabeth Apfelberg 1415 Cozadero
. San Lui s Obi spo, CA 93401 Janice E. Kerr, Esq.
Public Utilities Commicsion 5246 State Building 350 McAllister Street San Francisco, CA 94102 Mrs. Raye Fleming 1920 Mattie Road Shell Beach, CA 93449 Mr. Frederick Eissler Scenic Shoreline Preservation Conference, Inc.
4623 More Mesa Drive Santa Barbara, CA 93105 3.
l I
Gordon Silver Sandra A. Silver 1760 Alisal Street San Luis Obispo, California 93401 Joel R. Reynolds, Esq.
Eric Havian, Esq.
John Phillips, Esq.
Center for Law in the Public Interest 10951 West Pico Boulevard, Third Floor Los Angeles, CA 90064 Bruce Norton, Esq.
- Norton, Burke, Berry & French 2002 East Osborn Phoenix, AZ 85064 Philip A. Crane, Jr. , Esq.
Pacific Gas and Electric Company San Francisco, CA 94120 David S. Fleischaker, Esq.
P. O. Box 1178 Oklahoma City, OK 73101 Arthur C. Gehr, Esq.
Snell & Wilmer ,
3100 Valley Bank Center Phoenix, AR 85073 i
Mr. Richard B. Hubbard MHB Technical Associates ,
1723 Hamilton Avenue, Suite K San Jose, CA 95125 Mr. Carl Neiberger-Telegram Tribune .i P. O. Box 112 l San Luis Obispo, CA 93402 l Virgina and Gordon Bruno Pecho Ranch P. O. Box 6289 Los Osos, CA 93402 4.
t .'. - -
Nancy Culver 192'Luneta San Luis- Obispo, CA 93401 p
Maurice Axelrad, Esq.
- Lowenstein, Newman, Reis & Axelrad 1025 Connecticut Avenue, N.W.
, Washington, D.C. 20036 i
- DATED
- SEPTEMBER 8, 1983
\
l 4
JOHN K. VAN DE KAMP, Attorney General of the State of California
- ANDREA SHERIDAN ORDIN, Chief ,
Assistant Attorney General l' MICHAEL J. STRUMWASSER, Special Counsel-to the Attorney General SUSAN L. DURBIN, PETER H. KAUFMAN, Deputy Attorneys General ,
l l
By N()MC SUSAN L. DURBIN m
Attorneys for Governor George Deukmejian 3580 Wilshire Boulevard Suite 800 Los Angeles, California 90010 Telephone: (213) 736-2105 5.
.