ML20081B225

Affidavit of RB Hubbard Re safety-related Aspects of QA Programs.Prof Qualifications & Certificate of Svc Encl

ML20081B225
Person / Time
Site:	Diablo Canyon
Issue date:	10/21/1983
From:	Hubbard R CALIFORNIA, STATE OF
To:
Shared Package
ML20081B167	List: ML20081B163 ML20081B178 ML20081B225
References
ISSUANCES-OL, NUDOCS 8310270377
Download: ML20081B225 (17)

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" "C NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND IICENSING g PFg g Apj:jf

, , - : , ~ .~ c -

In the Matter of )

) Docket Nos. 50-275 0.L.

PACIFIC GAS AND ELECTRIC COMPANY ) 50-323 0.L.

)

(Diablo Canycn Nuclear Project, )

Units 1 and 2) )

)

STATE OF CALIFORNIA )

) ss.

COUNTY OF LOS ANGELES )

AFFIDAVIT OF RICHARD B. HUBBARD Richard B. Hubbard, being first duly sworn, attests:

1. I am a Professional Quality Engineer licensed by the State of California (License Number QU 805). I am currently a vice-president of MHB Technical Associates, a corporation engaged in the business of technical consulting on nuclear power facilities which I co-founded in 1976. My business address is l 1723 Hamilton Avenue, San Jose, California.

2. I hold a B.S. in Electrical Engineering from the University of Arizona (1960), and an M.B.A. from the University of Arizona (1969). I have 19 years' experience in the design and manufacture of systems and equipment for nuclear power generation facilities, including 11 years' experience in responsible j engineering and manufacturing managerial positions in the Nuclear Instrumentation Department (1965-1971), Atomic Power Equipment i,

Department (1971-1975), and Nuclear Energy Control and 1.

8310270377 831017

. PDR ADDCK 05000275

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Instrumentation Department (1975-1976) of the General Electric Company (GE).

3. For the past 7 years, I, along with my co-founders of MHB Technical Associates, have conducted numerous studies pertaining to the safety, quality, reliability, and economic aspects of nuclear power facilitien. I have been a consultant in this capacity to California, Massachusetts, Oklahoma, and Illinois Attorneys General, Minnesota Pollution Control Agency, German Ministry for Research and Technology, Governor of California, Swedish Energy Commission, Swedish Nuclear Inspectorate, Suffolk County in New York State, Ohio Consumer's Counsel, New Jersey Public Advocate, and U.S. Department of Ene rg y.

4. I have testified on safety-related aspects of nuclear power facilities' quality assurance programs as an expert witness bef6re the NRC Licensing Boards; before and at the request of the NRC's Advisory Committee on Reactor Safeguards; before the Joint Committee on Atomic Energy of the United States i Congress; and before various federal and state legislative and administrative bodies.

I 5. From November 1971 to February 1976, I was a manager of Quality Assurhace for the manufacturing operations at the San Jose, California, headquarters of GE's Nuclear Energy Division. I was responsible for the development and implemen-tation of quality plans, programs, methods, and equipment to assure that equ.ipment for nuclear plants designed, manufactured 2.

I and procured by GE met quality requirements as defined in NRC regulation 10 C.F.R. Part 50, Appendix B; ASME Boiler and Pressure Vessel Code; eustomer contracts; and GE corporate policies and procedures. The product areas include radiation sensors, reactor vessel internals, fuel handling and servicing tools, nuclear plant control and protection instrumentation systems, containment electrical penetrations, and control room panels for the Nuclear Steam Supply System (NSSS) and Balance of Plant (BOP). I was responsible for approximately 45 exempt personnel, 22 non-exempt personnel, and 129 hourly personnel with a yearly expense budget of nearly $4 million and an equipment investri.ent budget of approximately $1.2 million. While employed by GE, I was responsible for developing a quality system which received NRC certificaticri in 1975. The QA syste.m was also successfully surveyed for ASME "N" and "NPT" symbol autherizations in 1972 and 1975, plus ASME "U" and "S" symbol authorizations in 1975. I was also responsible for the quality assurance program and its implementation at GE's spare and renewal parts warehouse in San Jose.

6. I am a member of the IEEE Nuclear Power Engineering Standards Subcommittee responsible for the preparation and revision of a number of Quality Assurance standards for safety-related aspects of nuclear power facilities.

3.

7. A summary of my experience and professional qualifications is set forth in Attachment A, which is appended to thi's affidavit N Y RICHARD B. HUBBARD Subscribed and sworn to before me this .2/ M day ofd d M a , 1983 I JUDITH M. RANGER

) NOTARY PUBUC . CAUFORNIA M

• COUN1Y OF LOS ANGELES My Conwnhaion Empires July 10.1985

~ ~~~~~~

otary Public in a for Said County and State f

4.

ATTACH'!ENT A -

, PROFESSIONAL QUALIFICATIONS OF RICHARD B. HUBBARD

. RICHARD B. HUBBARD MHB Technic ~al Associates 1723 Hamilton Avenue Seite K San Jose, California 95125

( EXPERIENCE:

l 9/76 - PRESENT Vice-President - MHB Technical Associates, San Jose, California.

Founder, and Vice-President of technical consulting firm. Specialists in independent energy assessments for government agencies, particularly technical and economic evaluation of nuclear power facilities. Consultant l

in this capacity to California, Massachusetts, Oklahoma and Illinois Attorney Generals, Minnesota Pollution Control Agency, German Ministry for Research and Technology, Governor of California, Swedish Energy Commission, Swedish Nuclear Inspectorate, Suffolk County, Ohio Consumer's Counsel, New Jersey Public Advocate, and the U. S. Department of Energy. Also provided studies and testimony for various public interest groups including the Center for Law in the Pub 1fc Interest, Los Angeles; Public Law Utility Group, Baton Rouge, Louisiana; Friends of tne Earth (FDE) Italy; and the Union of Corcerned Scientists, Cambridge, Massachusetts. Provided testimony to the U.S. Senate / House Joint Committee on Atomic Energy, the U.S. House committee on Interior and Insular Affairs, the California Assembly, Land Use, and Energy Committee, the Advisory Committee on Reactor l

Safeguards, and the Atomic Safety and Licensing Board. Performed ,

comprehensive risk analysis of the accident probabilities and consequences l at the Barseback Nuclear Plant for the Swedish Energy Commission and I

edited, as well as contributed to, the Union of Concerned Scientist's technical review of the NRC's Reactor Safety' Study (WASH-1400).

2/76 - 9/76 Consultant, Project Survival, Palo Alto, California.

Volunteer work on Nuclear Safeguards Initiative campaigns in California, Oregon, Washington, Arizona, and Colorado. Numerous presentations on nuclear power and alternative energy options to civic, government, and college groups. Also resource person for public service presentations on radic and television.

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5/75 - 1/76 Manager - Duality Assurance Section, Nuclear Energy Control and Instrumentation Department, General Electric Company, San Jose, California.

Report to the Department General Manager. Develop and implement quality

}. plans, programs, methods, and equipment which assure that products produced by the Department meet quality requirements as defined in NRC regulation 10 CFR 50 Appendix B, ASME Boiler and Pressure Vessel Code, customer

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contracts, and GE Corporate policies and procedures. Product areas include radiation sensors, reactor vessel internals, fuel handling and servicing tools, nuclear plant control and protection instrumentation systems, and nuclear steam supply and Balance of Plant control room panels. Responsible for approximately 45 exempt personnel. 22 non-exempt personnel, and 129 hourly personnel with an expense budget of nearly 4 million dollars and equipment investment budget of approximately 1.2 million dollars. -

11/71 - 5/75 Manager - Quality Assurance Subsection, Manufacturing Section of Atomic Power Equipment Department, General Electric Company, San Jose, California.

Report to the Manager of Manufacturing. Same functional and product responsibilities as in Engagement #1, except at a lower organizational

! report level. Developed a quality system which received NRC certification l in 1975. The system was also successfully surveyed for ASME "N" and "NPT" symbol authorization in 1972 and 1975, plus ASME "U" and "S" symbol authorizations in 1975. Responsible for from 23 to 39 exempt personnel, 7 to 14 non-exempt personnel, and 53 to 97 hourly personnel.

l l 3/70 - 11/71 1

Manager - Application Engineering Subsection, Nuclear Instrumentation i

Department, General Electric Company, San Jose, California.

Responsible for the post order technical interface with architect engineers and power plant owners to define and schedule the instrumentation and control aystems for the Nuclear Steam Supply and Balance of Plant portion of nuclear power generating stations. Responsibilities included ,

preparation of the plant instrument list with approximate location, review of interfare drawings to define functional design requirements, and release l of functional requirements for detailed equipment designs. Personnel j supervised included 17 engineers and 5 non-exempt personnel, l

12/69 - 3/70 C,hairman - Equipment Room Task Force, Nuclear Instrumentation Department, General Electric Company, San Jose, California.

Responsible for a special task force reporting to the Department General Manager to define methods to Laprove the quality and reduce the

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installation time and cost of nuclear power plant control rooms. Study resulted in the conception of a factory-fabricated control room consisting of signal conditioning and operator control panels mounted on modular floor sections which are completely assembled in the factory and thoroughly tested for proper operation of interacting devices. Personnel supervised included 10 exempt personnel.

12/65 - 12/69 Manager - Proposal Engineering Subsection, Nuclear Instrumentation j Department, General Electric Company, San Jose, California.

Responsible for the application of instrumentation systems fo,r nuclear power reactors during the proposal and pre-order period. Responsible for -

technical review of bid specifications, preparation of technical bid clarifications and exceptions, definition of material list for cost estimating, and the "as sold" review of contracts prior to turnover to Application Engineering. Personnel supervised varied from 2 to 9 engineers.

8/64 - 12/65 Sales Engineer, Nuclear Electronics Business Section of Atomic Power Equipment Department, General Electric Company, San Jose, California.

Responsible for the bid review, contract negotation, and sale of instrumentation systems and components for nuclear power plants, test reactors, and radiation hot cells. Also responsible for industrial sales of radiation sensing systems for measurement of chemical properties, level, and density.

10/61 - 8/64 Application Engineer, Low Voltage Switchgear Department, General Electric Company, Philadelphia, Pennsylvania Responsible for the application and design of advanced diode and ,

( silicon-controlled rectifier (SCR) constant voltage DC power systems and variable voltage DC power systems for industrial applications. Designed, followed manufacturing and personally tested an advanced SCR power supply l

for product introduction at the Iron and Steel Show. Project Engineer for a DC power system for an aluminum pot line provided to Anaconda beginning at the 161KV switchyard and encompassing all the equipment to convert the power to 700 volts DC at 160,000 amperes.

9/60 - 10/61 GE Rotational Training Program Four 3-month assignments on the GE Rotational Training Program for college technical graduates as follows:

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a. Installation and Service _Eng. - Detroit, Michigan Installation and startup testing of the world's largest automated hot

, strip steel mill.

b. Tester - Industry Control - Roanoke, Virginia Factory testing of contrci panels for control of steel, paper, pulp, and utility mills and power plants.

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c. Engineer - Light Military Electronics - Johnson City, New York Design of ground support equipment for testing the auto pilots on the F-105.

d. Sales Engineer - Morrison, Illinois Sales of appliance controle including range timers and refrigerator cold controls. t EDUCATION:

Bachelor of Science Electrical Engineering, University of Arizona, 1960.

Master of Business Administration, University of Santa Clara, 1969.

PROFESSIONAL AFFILIATION:

Registered Quality Engineer, License No. QU805, State of California.

Member of Subcommittee 8 of the Nuclear Power Engineering Committee of the IEEE Power Engineering Society responsible for the preparation and revision of the following national Q.A. Standards:

l .

. a. IEEE 498 (ANSI N45.2.16): Requirements for the Calibration and Control of Measuring and Test Equipment used in the Construction and j Maintenance of Nuclear Power Generating Stations.

b. IEEE 336 (ANSI N45.2.4): Installation, Inspection, and Testing ,

Requirements for Class IE Instrumentation and Electric Equipment at Nuclear Power Generating Stations.

c. IEEE 467  : Quality Assurance Program Requirements for the Design and Manufacture of Class IE Instrumentation and Electric Equipment for Nuclear Power Generating Stations.

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I am currently a member of the IEEE Committee which is preparing a standard relating,to the selection and utilization of replacement parts for Class IE equipment during the construction and operation phase.

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PUBLICATIONS AND TESTIMONY:

1.

In-Core System Provides Continuous Flux Map of Reactor Cores, R. B.

'Hubbard and C. E. Foreman, Power, November, 1967.

2. Quality Assurance:

Nay, 1972.

Providing It, Proving It, R. B. Hubbard, Power,

3. Testimony of R. B. Hubbard, D. G. Bridenbaugh, and G. C. Minor before the United States Congress, Joint Committee on Autonic Energy, February 18, 1976, Washington, D.C. (Published by the Union of Concerned Scientists, Cambridge, Massachusetts.) Excerpts from testimony published in Quote without Comment, Chestech, Nay, 1976.

4. Testimony of R. B. Bubbard, D. G. Bridenbaugh, and G. C. Minor to the California State Assembly Committee on Resources. Land Use, and Energy, Sacramento, California, March 8, 1976.

5. Testimony of R. B. Hubbard and G. C. Minor before California State Senate Committee California, March on Public Utilities, Transit, and Energy, Sacramento, 23, 1976. .

6.

Testimony of R. B. Hubbard and G. C. Minor, Judicial Hearings Regarding Grafenrheinfeld Nuclear Plant, March 16 & 17, 1977, Wurzburg, Germany. i J

7.

Testimony of R. B. Hubbard to United States House of Representatives, Subcommittee on Energy and the Environment, June 30, 1977, Washington, D.C., entitled, Effectiveness of NRC Regulations - Modifications to Diablo Canyon Nuclear Units.

8. Testimony of R. B. Hubbard to the Advisory Committee on Reactor Safeguards, August 12, 1977, Washington, D.C., Risk Uncertainty Due to Deficiencies in Diablo Canyon Quality Assurance Program and Failure to Implement Current NRC Practices.

9.

i The Risks of Nuclear Power Reactors: A Review of the NRC Reactor Safety Study WASH-1400, Kendall, et. al., edited by R. B. Hubbard and G. C. Minor for the Union of Concerned Scientists, August, 1977.

I 10.

Swedish Reactor Safety Study: Barseback Risk Assessment, NHB Technical Associates, January 1978 (Published by Swedish Department of Industry as Document DSI (1978:1).

11.

Testimony of R. B. Eubbard before the Energy Facility Siting Counsil, March 31, 1978, in the matter of Pebble Springs Nuclear Power Plant, Risk Assessment: Pebble Springs Nuclear Plant, Portland, Oregon.

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I 12.

Presentation by R. B. Hubbard before the Federal Ministry for Research and Technology (BMFT), August 31 and September 1, 1978 Meeting on

. Reactor Safety Research, Risk Analysis. Bonn, Germany.

13. Testimony by R. B. Hubbard, D. G. Bridenbaugh, and G. C. Minor before the Atomic Safety and Licensing Board, September 25, 1978, in the matter of the hearings, Black Tulsa, Fox Nuclear Power Station Construction Permit Oklahoma.

14.

Testimony of R. B. Hubbard before the Atomic Safety and Licensing Board, November 17, 1978, in the matter of Diablo Canyon Nuclear Power Plant Operating License Hearings, Operating Basis Earthquake and t _S_eismic Reanalysis of Structures, Systems, and Components, Avila Beach, California.

15. Testimony of R. B. Hubbard and D. C. Bridenbaugh before the Louisiana Public Service Commission, November 19, 1978, Nuclear Plant and Power Generation Costs, Baton Rouge, Louisiana.

16. Testimony of R. B. Hubbard before the California Legislature.

Subcommittee on Energy, Los Angeles, April 12, 1979.

17. Testimony of R. B. Hubbard and G. C. Hinor before the Federal Trade Commission, on behalf of the Union of Concerned Scientists Standards and Certification Proposed Rule 16 CFR Part 457, May 18,1979.

18. ALO-62, Improving the Safety of LWR Power Plants, NHB Technical Associates, prepared for U.S. Department of Energy, Sandia National Laboratories, September, 1979, available from NTIS.

( 19. Testimony by R. B. Hubbard before the Arizona State Legislature, Special Interim House Committee on Atomic Energy, Overview of Nuclear Safety, Phoenix, AZ, September 20, 1979.

20. "The Role of the Technical Consultant", Practising Law Institute program on " Nuclear Litigation", New York City and Chicago, November, '

1979. Available from PLI, New York City.

21. Uncertainty in Nuclear Risk Assessment Methodology, MHB Technical Associates, March, 1980, prepared for and available from Swedish Nuclear Power Inspectorate,-Stockholm, Sweden.

l

22. Italian Reactor Safety Study: Caorso Risk Assessment, MHB Technical Associates, March, 1980, prepared for and available from Friends of the Earth, Rome, Italy.

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23. , Development of Study Plans: Safety Assessment of Monticello and Prairie Island Nuclear Stations, MHB Technical Associates, August, 1980, prepared for and available from the Minnesota Pollution Control Agency.

24. Affidavit of Richard B. Hubbard and Gregory C. Minor before the

• Illinois Commerce Commission, In the Matter of an Investigation of the Plant Construction Program of the Commonwealth Edison Company, i

prepared for the League of Women Voters of Rockford, Illinois, November 12, 1980, ICC Case No. 78-0646, i

25. Systems Interaction and Single Failure Criterion, NHB Technical Associates, January, 1981, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.

26. Summary of Emergency Response Planning Criteria for Regional and Local Authorities Near Nuclear Electric Generating Stations, MHB Technical Associates, June, 1981, prepared for and available from Friends of the Earth, Rome, Italy.

, 27. Economic Assessment: Ownership Interest In Palo Verde Nuclear

' Station, September 11, 1981, prepared for and available from the City of Riverside, California.

l l 28. Systems Interaction and Single Failure Criterion: Phase II report, MHB Technical Associates, December, 1981, prepared for and available from the Swedish Nuclear Power Inspectorate, Stockholm, Sweden.

29. Testimony of Richard Hubbard and Gregory Minor on Emergency Response Planning, Diablo Canyon Operating License hearings before ASLB, January 11, 1982.

l 30. Statement of Richard Hubbard before the U.S. House Subcommittee on Energy and Environment concerning QA program breakdowns, November 19, l 1981.

31. Testimony of Richard Hubbard on Quality Assurance, South' Texas Operating License hearing before ASLB, prefiled June, 1981.

l 32. Presentation of Richard Hubbard for Governor Edmund G. Brown, Jr.

i concerning PG&E's Proposed Seismic Design Reverification Program, Diablo Canyon Nuclear Power Plant, February 1982.

33. Testimony of R. B. Hubbard, G. C. Minor, M. W. Goldsmith, S. J.

• Harwood on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Contention 7B, Safety Classification and Systems Interaction, April 13, 1982.

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34. Testimony of R. B. Hubbard and D. G. Bridenbaugh, in the matter of l

. Jersey, Central Power and Light Company For an Increase in Rates for Electrical Service, on behalf of New Jersey Department of the Public i Advocate, Division of Rate Counsel, Three Mile Island Units 1 12, Cleanup and Modification Programs, May, 1982.

35. Testimony of R. B. Hubbard and G. C. Minor on behalf of Suffolk

"" County, before the Atomic Safety and Licensing Board, in the matter of Long Tuland Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Suffolk County contention 27 and SOC Contention 3, Post-Accident Monitoring, May 25, 1982.

36. Presentation of R. B. Hubbard for Governor Edmund G. Br'o wn, Jr.

concerning Diablo Canyon Reverification Program, Diablo Canyon Nuclear Power Plant, September, 1982.

37. Testimony of R. B. Hubbard on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power Station, Unit 1, regarding Suffolk County Contentions 12, 13, 14, and 15, Quality Assurance / Quality Control, June 29, 1982.

38. Presentation of Richard B. Hubbard on Behalf of the State of California, Before the NRC Commissioners, Proposed Phase II Diablo Canyon Reverification Program (IDVP), November 10, 1982.

39. Testimony of R. B. Hubbard and Dr. Francisco J. Samaniego on behalf of Suffolk County, Before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, Shoreham Nuclear Power

• Station, Unit 1, regarding Torrey Pines Technology's Inspection of ,

Shoreham Nuclear Power Station, December 21, 1982. l

) l I

40. Supplemental testimony of G. C. M.inor, R. B. Hubbard, and M. W.

Goldsmith on behalf of Suffolk County, before the Atomic Safety and Licensing Board, in the matter of Long Island Lighting Company, ,

Shoreham Nuclear Power Station, Unit 1, regarding Suffolk County Contention 7B, Safety Classification and Systems Interaction, March 23, 1983. '

41. Supplemental Affidavit of R. B. Hubbard before the Atomic Safety and Licensing Appeal Board Concerning Breakdowns in the Diablo Canyon {

Quality Assurance Program, March 29, 1983.

42. Declaration of R. B. Hub l bard before the Atomic Safety and Licensing i i

Appeal Board, Concerning Breakdowns in Constructicn Quality Assurance '

at Diablo Canyon, May 6, 1983.

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\

UNITED STATES OF AMERICA OgETED p NUCLEAR REGULATORY COMMISSION

• BEFORE THE ATOMIC SAFETY AND LICENSING PP L BOA 0FF,CE 0 SECH4; 00CMilhG & $Ei i 4

) BRANCH In the Matter of )

)

PACIFIC GAS AND ELECTRIC COMPANY ) Docket Nos. 50-275 0.L.

) 50-323 O.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 Answer of Governor Deukmejian to Applicant's

" Motion to Enforce Order" and Affidavit of Richard B. Hubbard served on the following by U.S. 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 i 1717 H S treet, N.W.

I Washington, D.C. 20555 Hon. Victor Gilinsky, Commissioner U.S. Nuclear Regulatory Commission 1717 H S treet, N.W.

Washington, D.C. 20555 Hon. Thomas Roberts, Commissioner l U.S. Nuclear Regulatory Commission 1717 H S treet, N.W.

l Washington, D.C. 20555 l

1.

l

I Hon. James Asselstine, Commissioner U.S. Nuclear Regulatory Commission 1717 H S tre e 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 Washington, D.C. 20555 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 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 2.

Lawrence Chandler, Esq.

• Henry J. McGurren, Esq.

Office of Executive Legal Director BETH 042 U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 Secretary U.S. Nuclear Regulatory Commission Washing ton, D.C. 20555 Atten tion: Docketing and Service Section Mrs. Elizabeth Apfelberg 1415 Cozadero San Luis Obispo, CA 93401 Janice E. Kerr, Esq.

Public Utilities Commission 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 Conf erence, Inc.

4623 More Mesa Drive Santa Barbara, CA 93105 Gordon Silver Sandra A. Silver 1760 Alisal Street San Luis Obispo, CA 93401 Joel R. Reynolds, Esq.

! Eric Havian, Esq.

l 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 Phoenix, AZ 85064 Philip A. Crane, Jr. , Esq.

• Richard F. Locke, EFq.

Pacific Gas and Electric Company 77 Beale Street, Room 3135 San F rancisco, CA 94106 3.

T

David S. Fleischaker, Esq.

P. O. Box 1178 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 San Jose, CA 95125 Mr. Carl Neiberger Telegram Tribune P. O. Box 112 San Luis Obispo, CA 93402 Virginia and Gordon Bruno Pecho Ranch P.O. Box 6289 Los Osos, CA 93402 Nancy Culver 192 Luneta San Luis Obispo, CA 93401 Maurice Axelrad, Esq.

• Lowenstein, Newman, Reis, & Axelrad 1025 Connecticut Avenue, N.W.

Washington, D.C. 20036 4.

I Cheryle Johnson Five Cities Times Press Recorder P.O. Box 460 Arroyo Grande, CA 93420 DATED: October 21, 1983 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. DURB IN ,

PETER H. KAUFMAN,.

Deputy Attorneys General By / W T CHAEL J. STRUMWASSER Attorneys for Governor George Deukmejian 3580 Wilshire Boulevard Suite 800 Los Angelen, California 90010 (213) 736-2102 5.

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