ML20079E334
| ML20079E334 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/09/1984 |
| From: | Strumwasser M CALIFORNIA, STATE OF |
| To: | NRC COMMISSION (OCM) |
| References | |
| ALAB-756, ISSUANCES-OL, NUDOCS 8401170249 | |
| Download: ML20079E334 (15) | |
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DOCV?TED I'"'
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION eg p j f, p .h In-the Matter of ).
)
PACIFIC' GAS AND ELECTRIC COMPANY ' ) Docket Nos. 50-275 OL
..1 . ). 50-323 OL
- (Diablo Canyon Nuclear. Power )
1 Plant,-Units 1 and-2)' )
)
PETITION FOR REVIEW f JOHNRK. VAN DE KAMP, Attorney Gen.eral of the State of California ANDREA SHERIDAN ORDIN, Chief Assistant Attorney General.
MICHAEL J. STRUMWASSER, Special-1 Counsel to the Attorney General PETER H. KAUFMAN, SUSAN L. DURBIN, Deputy Attorneys General Attorneys.for Governor q ~ George Deukmejian 3580 Wilshire Boulevard, Suite 800 4 Los-Angeles, California 90010 (213) 736-2102 I e' d
-9.e'
F UNITED STATES OF AMERICA NUCLEAR REGULATORY COPHISSION In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 OL
) 50-323 OL (Diablo Canyon Nuclear Power )
Plant, Units 1 and 2) )
.- )
-* PETITION FOR REVIEW OF ALAB-756 Governor George Deukmejian hereby petitions the Nuclear Regulatory Comnission (NRC), pursuant tc 10 C.F.R. section 2.786, subdivision (b), to review the Decenber 19, 1983, decision of the Atoraic Safety and Licensing Appeal Board (Appeal' Board) denying the Governor's motion to reopen the licensing record on the issue of construction quality assurance.
In response.to the disclosure in the last two years of widespread quality assurance (QA) deficiencies at Diablo Canyon, Governor Deukmejian and his predecessor had moved the Appeal Board to reopen the record on QA.
The motion cited the known design and construction errors, independent evidence of programatic QA deficiencies at Diablo Canyon, and the pace and
. extent of modifications to the facility then taking place. In ALAB.-756, which followed a four-day " evidentiary hearing" on the motion, the board
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denied the Governor's motion and refused to order hearings on the quality of construction at Diablo Canyon.
I. 'IHE APPEAL BOARD HAS ADOPTED A NEW STANDARD FOR A M0rION TO REOPM THAT, TOGETHER WITH THE PROCEDURE FOLLOWED BY THE BOARD, DISABLES THE COtNISSION FROM EVER DEALING WITH EVIDENCE OF SERIOUS SAFETY CONCERNS Under established NRC jurisprudence, a party moving to reopen the record on the basis of newly discovered evidence has had to show that the 1
evidence was " strong enough, in the light of any opposing filings, to avoid stmmary disposition." (Vermont Yankee Nuclear Power Corp. (Vermont Yankee Nuclear Generating Station) ALAB-138 (1973) 6 ABC 520, 523.) Indeed, this same Appeal Board (since reconstituted) has itself characterized the test as
"[mlight a different result have been reach had the newly proffered material been considered initially?" (Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2) ALAB-598 (1980) 11 NRC 876.) Yet
, the board now announces a new standard:
"In order for new evidence to raise a 'significant safety issue' for purposees of reopening the record, it must establish either that uncorrected construction errors endanger p1' ant operation, or that there has been a breakdown of the quality assurance progra sufficient to raise legitimate doubt as to the plant's capability of being operated safely." (Slip Opinion at 7 (mphasis supplied) .)
This deviation is not merely a sterile legal point -- particularly given the procedure employed by the board for ruling on the motion. After the parties had filed their moving and opposing papers, the record,-by the Appeal Board's own admission, contained a "ntunber of unanswered questions
. . . concerning the nature and significance of the new evidence . . . ."
(Slip Opinion at 3.) Instead of granting the motion to reopen on the basis.
of a plainly sufficient record, the Appeal Board convened an evidentiary heariag to weigh the evidence on the allegaticas of QA inadequacies. This hearing is precisely what is supposed to follow the granting of a motion to reopen and discovery by the parties into the underlying facts.
Instead, the Appeal Board permitted the applicant to respond to the allegations with self-serving, conclucory testimony frm its own personnel extolling the virtues of its QA program, and with evidence culled from its e
files supporting the claims. While the moving parties were allowed to
- cross-examine the witnesses, there was no realistic opportunity for effective cross-examination of witnesses who had not been deposed, just as 2
there was no chance to discover arnong witnesses under applicant's control potential impeaching testimony nor to offer into evidence docunents necessarily in applicant's possession that could rebut the self-serving claims. Thus, the board disposed of evidence entitling the moving parties to a hearing by convening a hollow substitute for the hearing that abrogated the right to procedures necessary for independent parties to represent their interests and to assist this cmmission in its adjudicatory mission.
The dangers of the board's rulings were amply demonstrated by events that followed the July hearing. At the July hearing PG&E witnesses had sought-to limit the damage to their case from alleged serious QA breaches by the H.P. Foley Company by pointing to the superior performance of the other
" major" construction contractor at Diablo Canyon, Pullman Power Products.
(Tr. 573-74, 605-606.) A Septenber 9 filing by the Joint Intervenors I
l revealed the existence of a 1977 independent audit of Pullman showing that it failed to meet all but one of the commission's 18 QA criteria of 10 C.F.R. part 50, Appendix B (Appendix B) and revealing the falsification of records, absence of any corrective action system, inadequate direction to workers, failure to require the contractor to comply with Appendix B, and numerous examples of construction errors. (See Joint Intervenors' Supplement to Motion to Reopen the Record on Construction Quality Assurance, Attachnent 2.) Neither the NIC Staff nor the other parties knew of the existence of the audit, which was conducted at the very time of the 1977 hearings before the Atanic Safety and Licensing Board (Licensing Board) on the PG&E QA program. IC&E neither disclosed the audit in 1977 nor proffered it at the July 1983 hearing before the Appeal Board. Discovery would have
, revealed the Pullman audit - and whatever similar evidence renains today undisclosed. Plainly, cross-exanination would have been significantly !
I different had that document been discovered before the July hearing. Just 3
as plainly, neither the parties nor this camission have any idea how many more such documents remain secretal in PG&E's files.
hre are numerous similar examples demonstrating that the test for reopening, together with procedure used by-the Appeal Board, prevented the board from dealing fairly and correctly with the motion.- % board relies on evidence produced after the hearing to resolve issues raised at the hearing.1 It accepts the claims of PG&E witnesses that the deficiencies
, infecting the quality of design did not produce like results in
. construction, dismissing evidence to the contrary as " gross speculation."
- (Slip Opinion at 9.)2 This simply d monstrates the wisd e of the established rule that once a party has tendered evidence which, together with the applicant's response, creates a triable issue of fact, the record must be reopened, with a full hearing to follow discovery.
II. THE GOVERNOR HAS SHOWN THAT BOTH THE CONSTRUCTION QA PROGRAM AND THE-CONSTRUCTION WORK ITSELF FAIL TO MEET THE COPNISSION'S REGULATIONS A. The Undisputed Evidence Deonstrates that PG&E Neither Cenmitted Itself to Comply with Appendix B, Nor Ce plied, in the
- Construction of Unit 1 After 1970 f
iWarren Raymond, IG&E's Manager of Quality Assurance from 1979 to 1983,
- testified that PG&E never formally comitted itself to ceply fully with L Appendix B in the construction of Unit 1. (Tr. 462.) Instead, it merely
'- 1. For ex mple, in responding to allegations that the 1983 work has been deficient, the board cites an October 7, 1983, inspection report.
(Slip Opinion at 25, fn. 32.) Similarly,.in dismissing the gravity of the Pullman audit, the board relies on evidence tendered after the December 13, 1983, Board Notification 83-188, which contains claims, never subject to discovery, made by witnesses never subject to cross-ex mination.
- 2. '1he motion had cited past testimony by NRC personnel before
? Congress to the effect that:the root cause of past QA problems has been an inadequate cerimitment by management to quality assurance. On cross-exmination, PG&E witnesses testified that PG&E's managment had an identical conmitment to design and construction QA. (Tr. 403, 407.) The Appeal Board simply chose to accept the see witnesses' self-serving claims
< that the differences in the details of design and construction QA preclude
! the ' natural inference fra the known design errors to ' suspect the efficacy l of QA for construction.
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agreed to emply with Appendix B "as practicable." (Tr. 465) Mr. Raymond was clear that "as practicable" did not mean PG&E would comply with the regulations for all construction following their adoption in 1970:
"Q. ... [D]o you understand the term 'as practicable' to mean that Appendix B applied to all unit 1 construction activities undertaken after Appendix B became effective? '
"A. (Witness Raymond) No, I did net.
. "Q. ... You understood, did you not, that there could be could be construction activities in unit 1, after Appendix B became effective, that need not emply with Appendix B?
"A. Yes." (Tr. 465.)
Mr. Raymond was similarly clear that the construction performed after 1970 did not, in fact, fully meet the regulations. (Tr. 465-66.)
The Appeal Board.'s startling response to this admission is to pronounce that emplian with the regulation was not required. (Slip Opinion at 21-23.) In defense of this proposition, the board quotes from the Statm ent of Considerations in the Federal Register accmpanying publication of the regulations in 1970 to the effect that the regulations would be "used for guidance" in evaluating the QA programs of then-current permit holders. (35 Fed. Reg. 10498, 10499.) But the full statement makes it clear that the quoted language was interded to have precisely the opposite meaning to that attributed by the board. 'Ihe statment says that the QA criteria, which
, " apply to all activities which affect safety-related functions," (id. at l
10498) "are intended to assist applicants" for licenses to comply with the requirment of existing regulations that the preliminary safety analysis f report docment a QA program and that satisfactory management controls be developed. The next paragraph contains the language quoted by the board:
l "The criteria will also be used for guidance in evaluating the adequacy of the quality assurance programs in use by holders of construction perraits and operating licenses." (35 Fed. Reg. at 10499.)
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The context makes it clear that the paragraph on which tha Appeal Board relies was intended to avoid the very inference the board draws frm it --
that, having spoken about future applicants, the camission intended to make the regulations prospective only. In fact, the statement shows that Appendix B was intended to apply to current as well as future permitees.- Of course, the regulations contain no provision exempting current permitees or limiting application of the regulations. The quoted statment demonstrates that the omission was purposeful. Indeed, had the camission intended to create an exmption to its regulations, it would have had to do so in the regulations themselves; an agency is otherwise without power to excuse nonempliance with its rules. (United States v. Nixon (1974) 418 U.S. 683, 694-96; Thompson v. Spear (5th Cir. 1937) 91 F.2d 430, 434.)3 Nothing is more corrosive of the regulatory process than casual suggestions by administrative agencies that their regulations contain exmptions contrary to their express language, which regulatees are at liberty to interpret to their liking. The Governor respectfully subnits that the Appeal Board's decision requires correction by the cmmission.
B. The Board Has Ignored the Evidence of Serious QA Failures in the Ongoing Construction Work that Demonstrate the Recurring Deficiencies in the PG&E QA Program The Appeal Board's decision glosses over the serious probims in the construction work associated with the current rourxl of modifications and
- 3. The Appeal Board also offers the view that the regulations could not have been intended to be " effective 30 days after publication in the Federal Register (35 Fed. Reg, at 10499), as the notice recited, because "the nature of the construction process for a plant already being built
, . . . precluded the empletc and inmediate application of the quality assurance criteria." (Slip Opinion at 21.) In fact, the regulations wure first proposed fifteen months before they became effective, giving the
- industry ample time to prepare to emply. (34 Fed. Reg. 6599 (Apr.17, 1969.) There is no reason to believe that the camission had to or did intend anything other than what it stated: to make the regulations uniformly effective on July 27, 1970.
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utterly fails to recognize the recurring pattern of such failures.
The board heard evidence of the " big push," the push to implenent all the modifications required by the design verification progran, which had been marked by errors in construction and deficiencies in the QA program.
- See of these deficiencies were disposed of by the board on the word of PG&E that they had eventually been resolved. For example, the board accepted the a
claires of PG&E that specific instances of inspector harrassment and improper removal of red tags by the H.P. Foley Company had been satisfactorily dealt 4
with. (Slip Opinion at 11-15.) But it failed to address the general concern expressed by Foley's discharged QA Manager that he was subject to a general pattern of production pressure and had inadequate independen .
(Tr. 219-21, 223, 229-30, 300, 304-305, 342-43, 351-52.) Similarly, the board acknowledged that inspectors had been working 60 to 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> a week and more (Slip Opinion at 13) - yet it accepted without question the PG&E claims that such problens were the unavoidable product of the build-up of the construction staff (ibid.) .4 Significantly, the Appeal Board points to PG&E's response to the problens with the Foley work as denonstrating "that the applicant's quality assurance program was performing in an acceptable manner." (Slip Opinion at 14.) Yet the NRC inspector who identified sme of the sane incidents and cited PG&E for them testified precisely to the contrary:
"Q.[By Judge Johnson] Would it normally be the practice of an NRC inspector to issuo a notice of violation regarding such QA defects when the Applicant's quality assurance progran had already detected the problem?
"A. If the Licensee had detected the problen and was aware of the broad spectrun of the problen, we would not issue
- 4. Among the allegations completely ignored by the board are the hiring of unqualified inspectors, inadequately trained welders, and understaffing of inspectors. (Tr. 567-68.)
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k an item of certpliance. However, in my opinion, they did not make that judgment that there was a widespread serious proble in that area.
"Q. Would you define ' serious'? You just used the word, that it was a serious proble. Could you define that, explain what you mean by that?.
i 1
"A. By ' serious' I meant that there were several failures to follow procedures, not only in the fact that - in the welding of the
- structure, but in the training of the welders - that was readily
]
apparent - but also in the inspector qualifications [.] That to me
. meant dt was a serious prob 1m." (Tr. 826-27.)
What the NRC's own inspector called "a widespread serious problem" the board dismisses as " minor welding deficiencies." (Slip Opinion at 14.)
l Furthermore, the board completely ignored evidence introduced by the 4
t Governor showing that. these deficiencies in the Foley program were repetitions of virtually identical probles in each of the two preceeding
" big pushes" - including similar welding probles in the Pullman work stretching back to 1972. (Gov. Exh. CQ-4, CQ-5,. CQ-7, CQ-10, CQ-ll, CQ-12, 4
- CO-21, .CQ-23, CQ-28, Co-29, C4-41, CQ-54.) Yet in Deceber 1983 the Appeal Board accepted PG&E's explanaticn for the findings of the 1977 Pullman audit that the concerns identified were satisfactorily resolved and "did not evidence a significant or systmatic failure of the quality assurance 1
program." (Slip Opinion at 26-27, fn. 35.)
) III. THE APPEAL BOARD HAS ADOPPED A NON-STANDARD.FOR DECIDING WHEN A
' QUALITY ASSURANCE PROGRAM HAS FAILED OFTEN ENOUGH TO WARRANT REOPENING THE RECORD In the face of the mountain of evidence of recurring QA failures, the Appeal Board retreats to the familiar observation that nobody's perfect:
, "Although a program _o'f construction quality assurance is specifically designed to catch construction errors, it
.is unreasonable to expect the program to uncover all
- j . , errors." (Slip Opinion at 7.)
'From this modest observation the board leaps to the conclusion that the
- neber of errors is imaterial to the adequacy of a QA program. ,
? "What is required instead is reasonable assurance that the plant, as built, can and will.be operated without endangering the public health and safety." (Ibid.).
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While such assurance is certainly a requirment for licensing a plant, it has never before been suggested that the assurance is a substitute for missing compliance with the comission's regulations.5 The law is quite clear that, in addition to " reasonable assurance" of safety, an applicant must show that "the facility . . . has been constructed . . . in conformity . . . with the rules and regulations of the Conmission." (42 U.S.C. 2235.)
Presumably to impl ment its novel licensing standard, the board adopts s.
the further requirement that to reopen a record a moving party "must establish either that uncorrected construction errors endanger safe plant operation, or that there has been a breakdown of the quality assurance program sufficient to raise legitimate doubt as to the plant's capability of being operated safely." (Slip Opinion at 7.)
The first part of this test a party will scarcely ever be able to meet.
Absent unfettered access to the plant, it will be most difficult to point to specific uncorrected errors. As to the second part of the test, the board never says what constitutes a " sufficient breakdown" to merit reopening.
Instead, it simply lists same of the known deficiencies and pronounces each insufficient.
In 1981 the Licensing Board found the PG&E QA program for design, construction, and operation of Diablo Canyon "have been and are in empliance with the requirments of . . . Appendix B . . . ." (Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2) LBP-
- 5. The authority cited by the Appeal Board makes reasonable assurance of public hcalth ard safety a necessary but not alone a sufficient condition of licensing. The board cites section 50.57(a) (3) (i) of the ccmnission's
. regulations; section 50.57(a) (3) requires both that the public health and safety be assured and that there be reasonable assurance "that such activities will be conducted in compliance with the regulations of this
- chapter." The record contains uncontroverted evidence that the construction
. 0A program did not emply with the regulations - specifically with Appendix B. The board ignores the second half of the test under section 50.57 (a) (3) .
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81-21 (1981) 14 NRC 107,116.) That finding followed a two-page analysis of a two-day record consisting exclusively of PG&E and NBC Staff testimony on the sufficiency of the QA program. It is now clear that the 1981 decision was based on a record wholly inadequate to test the PG&E QA program, Since the July hearing, a torrent of additional allegations of serious safety deficiencies at Diablo Canyon have come to light (see Safety Evaluation
. Report, Supplement 21), further showing the inadequacy of the record to support a finding that the quality of construction has been assured. The parties are entitled to a full adjudication of these charges on the record.
When subsequent evidence denonstrates that a prior decision was based on an incomplete or inaccurate record insufficient te establish the facts putatively found, the record must be reopened to permit an informed decision. The Diablo Appeal Board has itself previously found that the record should be reopened when new evidence "may well shed significant additional light upon the correctness" of past findings and "may affect our evaluation" of a safety issue. (Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2) ALAB-598 (1980) 11 NRC 876, 879.) That is what is required here.
Governor Deukmejian respectfully requests that the camission review the refusal of the Appeal Board to reopen the record on construction QA.
Dated: January 9, 1984 JOHN K. VAN DE KAMP, Attorney General of the State of California ANDREA SHERIDAN ORDIN, Chief Assistant Attorney General MICHAEL J. STRUMNASSER, Special Counsel to the Attorney General SUSAN L. DURBIN PETER H. KAUFMAN, f Deputy Attorneys General
-/ Al ny /
/{ MI EL J. STRLPMASSER Attorneys for Governor George Deukmejian 10
-- w - v
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4
) .
In the Matter of )
)
PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 O.L.
) 50 -32 3 0.L.
(Diablo Canyon Nuclear Power )
Plant, Units 1 and 2) )
- )
CERTIFIC?.TE OF SERVICE I hereby certif y that on this date$/ I caused copies of the foregoing " Petition f or Review of ALAB-756" served on the folicwing by U.S. Mail, first class, postage prepaid.
Hon. Nunzio Palladino, Chairman U.S. Nuclear Regulator y Commission 1717 H S treet, N.W.
Washington, D.C. 20555 Hon. Victor Gilinsky, Commissioner U.S. Nuclear Regulator y Commission 1717 H S treet, N.W.
Washington, D.C. 20555 Hon. Thomas _ Roberts, Commissioner U.S. _ Nuclear Regulator y Commission 1717 H S treet, N.W.
Washington, D.C. 20555 1/ The final da te for the filing of this petition was extended by the Secretary of the Commission at the request of counsel for the Governor to and including January 11, 198 4.
, 1.
Hon. James Asselstine, Commissioner U.S. Nuclear Regulatory Commission 1717 H S tree t, N.W.
Washing ton, D.C. 20555 Hon. Frederick M. Bernthal, Commissioner U.S. Nuclear Regulatory Commission 1717 H S tree t, N.W.
Washing ton, D.C. 20555 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 20555 Washington, D.C.
Hon. John H. Buck Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, 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
. Harold Denton Director of Nuclear Reactor Regulation i U.S. Nuclear Regulatory Commission
. Washington, D.C. 20555
! e Leonard Bickwit, Esq.
- Office of the General Counsel l
- U.S. Nuclear Regulatory Commission
- Washington, D.C. 20555 2.
l.
Lawrence Chandler, Esq.
Henry J. McGur ren, Esq.
Office of Executive Legal Director BETH 042 U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 S ecre tary U.S. Nuclear Regulator y Commission Washing ton , D.C. 20555 A tten tion: Docketing and Service Section
- Mrs. Elizabeth Apfelberg 1415 Cozadero San. Luis Obispo, CA 93401 Janice E. Kerr, Esq.
Public Utilities Commission 5246 S tate Building 350 McAllister Street S an F ranc isco, CA 9410 2 Mrs. Raye Flemi ng 1920 Mattie Road Shell Beach , CA 93449 Mr. Frederick Eissler Scenic Shoreline Preservation Conference, I nc .
4623 More Mesa Drive Santa Barbara, CA 93105 Gordon Silver S andra A. Silver 1760 Alisal Street San Luis Obispo, CA 93401 Joel R. Reynolds, Esq.
E ric Havian, Esq.
John Phillips, Esq.
Center for Law in the Public Interest 10951 West Pico Boulevard, Third Floor Los Angeles, CA 90064 B ruce Nor ton, Esq.
Norton, Burke, Berry & French 2002 East Osborn P.O. Box 10569
, Phoenix, AZ 85064 Philip A. C ran e , J r . , Esq.
, Richard F. Locke, Esq.
Pacific Gas and Electric Company 77 Beale S treet, Room 3135 San Francisco, CA 94106 3.
l David S. Fleischaker, Esq.
P. O. Box 117 8
! Oklahoma City, OK 73101 Arthur C. Gehr, Esq.
Snell & Wilmer 3100 Valley Bank Center Phoenix, AZ 85073 Mr. Richard B. Hubbard MHB Technical Associates 1723 Hamilton Avenue, Suite K o San Jose, CA 95125 Mr. Carl Neiberger 6 Telegram Tribune P. O. Box 112 San Luis Obispo, CA 93402 Virginia and Gordon Brune P echo Ranch P.O. Box 6289 Los Osos, CA 93402 Nancy Culver 192s Luneta San Luis Obispo, CA 93401 Maurice Axelrad, Esq.
Lowen stein, Newman , Reis , & Axelrad 10 25 Connecticut Avenue, N.W.
Washington, D.C. 20036 Cheryle Johnson Five Cities Times. Press Recorder P.O. Box 460 Arroyo Grande , CA 93420 DATED: J anuary 11, 198 4 JOHN K. VAN DE KAMP, Attor ney General of the State of California ANDREA SHERIDAN ORDIN, Chief Assistant Attorney General MICHAEL J. STRUMWASSER, Special Counsel to the Attorney General SUSAN L. DURB IN, PETER H. KAUFMAN, Deputy Attor neys General By
, pICHAELJ. STRUMWASSER Attorneys for Governor George Deukmejian 3580 Wilshire Boulevard Suite 800 Los Angeles, Calif or nia 90010 ,
(213) 736-2102 '
4.
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