ML20072L170

Second Set of Interrogatories Propounded to Independent Design Verification Program Contractors

ML20072L170
Person / Time
Site:	Diablo Canyon
Issue date:	07/08/1983
From:	Durbin S CALIFORNIA, STATE OF
To:
Shared Package
ML20072L173	List: ML20072L170 ML20072L175
References
ISSUANCES-OL, NUDOCS 8307130072
Download: ML20072L170 (20)

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UNITED STATES OF AMERICA

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NUCLEAR REGULATORY COMMISSION t

BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL bog cn= d N %s N ryggg&hr.

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PACIFIC GAS AND ELECTRIC COMPANY

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Docket Nos. 50-275 O.L.

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50-323 0.L.

(Diablo Canyon Nuclear Power

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Plant, Units 1 and 2)

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SECOND SET OF INTERAOGATORIES PROPOUNDED TO THE INDEPENDENT DESIGN VERIFICATION PROGRAM CONTRACTORS BY GOVERNOR DEUKMEJI AN In accordance with the ag reement of the parties concerning discovery directed to the Independent Design Verification Prog ram contractors, and to accommodate the special relationship between the applicant and its contractors as conducting the IDVP, Governor George Deukmejian hereby

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propounds directly to said contractors this Second Set of I

In te rr oga tor ie s, to be answered under oath within fourteen days, pursuan t to 10 C.F.R.

sec tion 2.740b.

INSTRUCTIONS A.

Where you have incomplete information that precludes your fully answering an interrogatory, give such

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information as you -have and sta te what information you do not have.

If you are unable to give the inf ormation in the 'f orm sought but have the information aggregated dif ferently, give the_infor.mation in, the f orm in which you have it and explain.

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B.

When a sk ed in the interrogatories below to identify or to give the identity of a person, please give the following information about him or her:

1.

full name; 2.

present job title and employer; C.

When asked in the interrogatories below to identify or to give the identity of a document, please give the

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fo11owing information about the document:

1.

its title, if any;.

2.

its nature (e.g.,

le tte r, memorandum, chart, compu ter pr in tou t, ledge r) ;

3.

th e da te, if any, stated on the document; 4.

the identity of each person who signed it; 5.

the identity of each person to whom it is addressed.

s D.

As used herein, the singular form of a noun or e

pronoun shall be considered to include within its meaning the i

plural form of the noun or pronoun so used, and vice versa; similarly, the use of the masculine form of a pronoun shall be considered to include also within its meaning the feminine form of the pronoun so used, and vice' versa; and in a similar fashion any tense of any verb used herein shall be considered v

also to include within its meaning all other tenses of the verb so used.

E.

The use of the word "or" is the inclusive form of thaE bonfunction, implicitly including within its meaning the

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word "and."

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F.

Should you have any questions regarding the meaning of any term or interpretation of any interrogatory, you are encou raged to consult with counsel regarding such questions.

DEFINITIONS (1)

" ANSI" means American National S tandards Institute.

(2)

" Appendix A" means Appendix A to part 50 of 10 C.F.R.

(3)

" Appendix B" means Appendix B to par t 50 of 10 C.F.R.

e (4)

"Bechtel" means the Bechtel Po'wer Corporation.

(5)

" Corrective Action Prog ram". (CAP) means.the DCP Internal Technical Program.

(6)

"Diablo Canyon" means units 1 and 2 of the Diablo Canyon Nuclear Power Plant, including all structures, systems, and components at the site.

(7)

"Diablo Canyon Project" (DCP) means PG&E, Bechtel, all joint projects of PG&E and Bechtel foncerning Diablo Canyon, and all contractors, subcontrac tor s, consultants, and agents of the foregoing, excluding the IDVP.

i (8)

" Document" means any and all things that constitute

" writings" pursuant to rule 1001 of the Federal Rules of Evidence.

(9)

"Important to safety" means SS&Cs that provide reason 6ble assu rance that the f acility can be operated without

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undue risk to the health and safety of the public.

(10) " Independent Design Verification Prog ram" (IDVP) means j

the program established by the November 19, 1981, order of the i

' Nuclear Regulatory Commission (NRC), the November 19, 1981, l

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. letter f rom Harold Denton to Malcolm Furbush, and implementing l

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I directives of the NRC staf f, as that program may have been modified since that date.

(11) " Person" includes natural persons, cor pora tions, par tnerships, other business entities, and public agencies.

(12) "PG&E" means the Pacific Gas and Electric Company and its agents, employees, con t rac tor s, subcon t rac tor s, a f filia tes, depa rtmen ts, divisions, units, subunits, and attorneys, excluding the IDVP.

(13) " Procured components" are components tha t were purchased by PG&E, rather than designed by employees of PG&E or PG&E design contractors.

(14) " Quality assurance" means. all those planned and systematic actions necessary to provide adequate confidence that a structure, system, or component will perform satisfactorily in service.

Quality assurance includes quality 4

control.

I (15) " Quality control" means those quality assurance I

actions related to the physical characteristics of a material, str uc tu re, component, or system, which provide a maans to control the quality of the material, structure, component, or system to predetermined requirements.

(16) " Reg. Guide" means a ' egulatory Guide of the Nuclear s~

Regulatory Commissi6n.

(17) " Safety-related" means those SS&Cs necessary to assu re :

(1) the integrity of the reactor coolant pressure 4

-- boundary; -(:2) the capability to shut down the reactor and maintain it in a safe shutdown condition; or (3 ) the capability l

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to, prevent or mitigate the consequences of accidents which could result in potential off-site exposures comparable to the guideline exposures of 10 C.F.R.

part 100.

(18) "SS&C" means structures, syste ms, and components.

(19) " WASH-1283" means the document issued by the Atomic Energy Commission on or about May 24, 1974, entitled " Guidance on Quality Assurance Requirements During Design and Procurement

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Phase of Nuclear Powe r Plan ts *- - Revis i'on 1. "

(20) "You" and "your" refer to Teledyne Engineering Services and, according to context, to its subcontractors.

INTERROGATORIES 1.

Have you determined whether PG&E complied with each and every criterion of Appendix B in the seismic design of safety-related SS&Cs at Diablo Canyon performed before institution of the CAP?

,5 2.

If you made such a determination, for each criterion what was that determination?

i 3.

Have you determined whether PG&E complied with each and every criterion of Appendix B in the seismic design of safety-related SS&Cs at Diablo Canyon performed since institution of the CAP?

4.'

If you made such a determination, for each criterion what was that determination?

5.

Have you determined whether PG&E complied with each and every criterion of Appendix B in the nonseismic design of safety-related SS&Cs at Diablo Canyon before institution of the CAP?

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If you made such a determination, for each criterion what was that determination?

i 7.

Have you determined whether PG&E complied with each and every criterion of Appendix B in the nonseismic design of safety-related SS&Cs at Diablo Canyon since institution of the CAP?

8.

If you made such a determination, for each criterion

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what was that determination?

9.

Have you determined whether-PG&E complied with each and every quality assurance requirement of Appendix A in the design of safety-related Diablo Canyon SS&Cs performed before institution of the CAP?

10.

If you made such a. determination, for each quality assu ra nce requirement what was that determination?

11.

Have you determined whethag PG&E complied with each and every quality assurance requirement of Appendix A in the design of safety-related Diablo Canyon SS&Cs performed since i

institution of the CAP?

12.

If you made such a determination, for each quality assu ra nce requirement what was that determination?

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13.

Have you determined whether PG&E complied with each and every quality assurance requirement of Appendix A in the design of important to safety but not safety-related Diablo Canyon SS&Cs designed before institution of the CAP?

14.

If you made such a determination, for each quality a ssu ra nce requirement what was that determination?

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15.

Have you determined whether PC&E complied with each and every quality assurance requirement of Appendix A in the x.

design of important to safety but not safety-related Diablo Canyon SS&Cs designed since institution of the CAP?

16.

If you made such a determination, for each quality assurance requirement what was that determination?

17.

Have you determined whether PG&E complied with WASH-1283 in the design of Diablo Canyon?

18.

If you made such a determination, what was that determination?

19.

With respect to each of the ANSI standards specified below in items A through G, state separately:

(a)

Have you determined whether PG&E complied with the standard in the seismic design of Diablo Canyon performed before institution of the CAP?

s -s (b)

If you made such a determination, what was that de te rmina tion?

Your answer should indicate:

I (i) against which revision of each standard compliance was tested; (ii) the periods during which compliance was found to exist; and (iii) for which design groups in the design chain s

compliance was found to exist.

The standards to which this interrogatory refers are:

(A)

ANSI N45.2

{B)

ANSI W45.2.9 (C)

ANSI N45.2.10 s

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(D)

ANSI N45.2.ll 9

(E)

ANSI N45.2.12 m

(F)

ANSI N45.2.13 (G)

ANSI N45.2.23.

20Property "ANSI code" (as page type) with input value "ANSI N45.2.23.</br></br>20" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..

With respect to each of the ANSI standards speci-fied below in items A through G, sta te separately:

(a)

Have you determined whether PG&E complied with the standard in the seismic design'of Diablo Canyon performed since institution of the CAP?

(b)

If you made such a determination, what was that de te rmina tion?

Your answer should indicate:

( i) against which revision of each standard compliance was test.ed; (ii) the periods during which compliance was found to exist; and s,3 (iii) for which design groups in the design chain I

compliance was found to ex ist.

I The standards to which this ' interrogatory refers are:

(A)

ANSI N45.2 (P )

ANSI N45.2.9 (C)

ANSI N45.2.10 (D)

ANSI N45.2.ll

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(B)

ANSI N45.2.12 (F)

ANSI N45.2.13 (G)

ANSI N45.2.23.

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21.

With respect to each of the ANSI standards specified below in items A through G, sta te separately:

(a)

Have you determined whether PG&E complied with the standard in the nonseismic design of safety-related Diablo Canyon SS&Cs designed before institution of the CAP?

(b)

If you made such a determination, what was that determination?

Your answer should indicate:

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(i) against which revisio'n of each standard compliance was tested; (ii) the periods during which compliance was found to exist; and (iii) for which design groups in the design chain compliance was found to exist.

The standards to which this interrogatory refers are:

(A)

ANSI N45.2

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ANSI N45.2.9 (C)

ANSI N45.2.10 1

(D)

ANSI N45.2.ll (E)

ANSI N45.2.12 (F)

ANSI N45.2.13 (G)

ANSI N45.2.23.

22Property "ANSI code" (as page type) with input value "ANSI N45.2.23.</br></br>22" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..

With respect to each of the ANSI standards specified l

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below in items A through G, state separately:

i (a)

Have you determined whether PG&E complied with the standard in the nonseismic design of safety-related t

~Ulabl6 Canyon 55&Cs designed since institution of the CAP?

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C (b)

If you made such a determination, what was that de te rmina tion?

Your answer should ind icate :

(i) against which revision of each standard compliance was tested; (ii) the periods during which compliance was found to exist; and (iii) for whict: design groups in the design chain

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compliance was f ound *to ex ist.'

The standards to which this interrogatory refers are:

(A)

ANSI N45.2 (B)

ANSI N45.2.9 (C)

ANSI N45.2.10 (D)

ANSI N45.2.ll (E)

ANSI N45.2.12 (F)

ANSI N45.2.13

,3 (G)

ANSI N45.2.23.

i 23.

With respect to each of the Reg. Guides specified i

below in items A through G, state separa tely:

(a)

Have you determined whether PG&E complied with the Reg. Guide in the seismic design of Diablo Canyon performed before institution of the CAP?

(b)

If you made such a determination, what was that

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de te rmina tion?

Your answer should indicate:

(i) against which revision of each Reg. Guide compliance was tested;

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(ii) 'the periods during which compliance was found to exist; and 10.

(iii) for which design groups in the design chain compliance was found to exist.

The Reg. Guides to which this interrogatory refers are:

(A) 1.28

(:B) 1.88 (C) 1.74 (D) 1.64 (E) 1.144 (F) 1.123 (G) 1.146 24.

With respect to each of the Reg. Guides specified below in items A through G, state separately:

(a)

Have you determined whether PG&E complied with the Reg. Guide in the seismic design of Diablo Canyon performed since institution of the CAP?

4 (b)

If you made such a determination, what was that de te rmina tion?

Your answer should indicate:

i (i) against which revision of each Reg. Guide compliance was tested; (ii) the periods during which compliance was found to exist; and (iii) for which design groups in the design chain

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compliance was found to exist.

The Reg. Guides to which this interrogatory refers are:

(A) 1.28

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1.88-(C) 1.74

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(D) 1.64 (E) 1.144 (F) 1.123 (G) 1.146 25.

With respect to each of the Reg. Guides specified below in items A through'G, state separately:

(a)

Have you determined whether PG&E complied with

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the Reg. Guide in the nonsbismic de' sign of safety-related SS&Cs at Diablo Canyon designed before institution of the CAP?

(b)

If you made such a determination, what was that de termina tion?

Your answer should indicate:

(i) against which revision of each Reg. Guide compliance was tested; (ii) the periods durias which compliance was found to exist; and t

(iii) for which design groups in the design chain I

compliance was found to exist.

The Reg. Guides to which this interrogatory refers are:

(A) 1.28 (B) 1.88' l

(C) 1.74 L

(D) 1.64 (E) 1.144 (F) 1.123 (G) 1.146'

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26.

With respect to each of the Reg. Guides specified

' below in items A through G, state separately:

(a)

Have you determined whether PG&E complied with the Reg. Guide in the nonseismic design of safety-related SS&Cs at Diablo Canyon designed since institution of the CAP?

(b)

If you made such a determination, what was that de termina tion?

Your answer should indicate:

(i) against which revision of each. Reg. Guide compliance was tested; (ii) the periods during which compliance was found to exist; and (iii) for which design groups in the design chain compliance was found to exist.

The Reg. Guides to which thissinterrogatory refers are:

4-(A) 1.28 (B )

1.88 i

(C) 1.74 (D) 1.64 (E) 1.144 (F) 1.123 (G) 1.146 s

27.

Has the seismic design work of each and every design group in the design chain for each and every safety-related SS&C designed before institution of the CAP been reviewed by the -IDVP? -

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t-28.

If your answer to the preceding interrogatory is other than an unqualified "yes," for all safety-related SS&Cs that have not been so reviewed state:

(a) the iden tity and locations of the SS&Cs, and the identity ot the design groups whose work was not reviewed; (b) the reason for their exclusion from review; (c) the identity of the person. responsible for the

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decision to exclude them; (d) whether you have formed an opinion as to whether the SS&C meets PG&E's licensing commitments and the regulatory requirements; (e) if you have formed such an opinion, what your opinion is and the basis.of your opinion.

29.

Has the seismic design work of each and every design group in the design chain for each and every safety-related SS&C designed since institut, ion of the CAP been reviewed by the I

IDVP?

I 30.

If your answer to the preceding interrogatory is other than an unqualified "yes," for all safety-related SS&Cs that have not been so reviewed state:

(a) the ~ identity and locations of the SS&Cs, and the l

identity of the design groups whose work was not reviewed; y

(b) the reason for their exclusion from review; (c) the identity of the person responsible for the decision to exclude them; 9

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(d) whether yoin have formed an opinion as to whether the SS&C meets PG&E's licensing commitments and the regula tory requirements; (e) if you have formed such an opinion, what your opinion is and the basis of your opinion.

31.

Has the seismic qualification of all procured s

components used in safety-related SS&Cs been reviewed by the IDVP?

32.

If your answer to the preceding interrog.atory is other than an unqualified "yes," for all such procured components that have not been so reviewed state:

(a) their identity and locations; (b) the vendor or vendor s; (c) the reason for their exclusion from review; (d)'

the identity of the gerson responsible for the decision to exclude them; i

(e) whether you have formed an opinion as to whether i

use of the procured components meets PG&E's licensing commitments and the regulatory requirements;

( f) if you have formed such an opinion, what your

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opinion is and the basis of your opinion.

33.

Has the seismic design work of each and every design N

group in the design chain for each and every safety-related SS&C that was reviewed by the IDVP been reviewed for the DE, DDE, and Hosgri earthquake?

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'If your answer to the preceding interrogatory is other than an unqualified "ye's," for all safety-related SS&C that was not reviewed for all three earthqu$kes state:

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O (a) the identity and locations of the SS&Cs, and the i

identity of the design groups whose work was not reviewed; (b) for which of the three earthquakes they were not reviewed; (c) the reason for their exclusion from review for that earthquake; (d) the identity of the person. responsible for the

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decision to exclude them; '

(e) whether you have formed. an opinion.as to whether the SS&C meet PG&E's licensing commitments and the regulatory requirements with respect to the earthquakes for which they we re not reviewed ;

(f) if you have formed such an opinion, what your opinion is and the basis of your opinion.

35.

Has the seismic qualifica), ion of all procured components used in safety-related SS&Cs that were reviewed by I

the IDVP been reviewed for the DE, DDE, and Hosgri earthquake?

36.

If your answer to the preceding interrogatory is other than an unqualified "yes," for all such procured components that have not been so reviewed state:

(a) their identity and locations; (b) the vendor or vendors; (c) for which of the three earthquakes they were not reviewed; (d) the reason for their exclusion from review for that earthquake; I

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t (e) the identity of the person responsible for the decis ion to exclude it; n.

(f) whether you have formed an opinion as to whether use of the component meets PG&E's licensing commitments and the regulatory requirements with respect to the earthquakes for which it was not reviewed; (g) if you have formed such an. opinion, what your opinion is and the basis o'f your o[ inion.

37.

Has the nonseismic design work of e.ach.and every design group in the design chain for each and every safety-related SS&C been reviewed by the IDVP?

38.

If your answer to the preceding interrogatory is other than an unqualified "yes," for all safety-related SS&Cs that have not been so reviewed state:

(a) the identity and ldcations of the SS&Cs, and the identity of the design groups whose work was not reviewed; (b) the reason for their exclusion from review; i

(c) the identity of the person responsible for the decision to exclude them; (d) whether you have formed an opinion as to whether the SS&C meets PG&E's -licensing commitments and the regulatory requirements; s

(e) if you have formed such an opinion, what your opinion is and the basis of your opinion.

39.

For each and every EOI, with the exception of those relating solely to construction quality assurance, state the following:

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C (a) when the event giving rise to the EOI occurred; (b) what quality assurance program or implementation deficiency allowed the event to occu r ;

(c) what quality assurance program or implementation deficiency allowed the event to remain undetected; (d) what quality assurance program or procedures should have discovered the event;

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(e) what other quality assura'nce program or procedures was or were intended to detect the. event through redundant review; (f) your opinion as to whether the event had generic implications and the basis for your opinion; (g) your opinion as to whether the failure to detect the event had generic implications and the basis for your opinion; s,3 (h) what you did to determine that corrective action was properly taken to close out th e EOI.

I (i) if the EOI is listed in your Final Report as incomplete in any way, state:

1) each and every task remaining to be completed

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before the EOI will be closed; l

2) the date by which the EOI is expec ted, as of v

the date of your answer, to be closed.

If any action is required by PG&E before the EOI can be closed, state what action by PG&E is required and

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the date b which you expect PG&E to complete it.

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40.

For all activities, evaluatio$s, and items other than l

EOIs stated in the IDVP Final Report as incomplete, identify:

(a) each and every task remaining to be completed before the activity, evaluation, or item will be completed; (b) the date by which the activity, evaluation, or item is expected, as of the date of your answer, to be completed.

If any action is required by PG&E before the ac tivity, evaluation, or item can b'e completed, state what action by PG&E is required and the date,by which you expect PGLE to complete it.

41.

If your answer to any of the preceding interrogatories applies differently to unit 1 and unit 2 of Diablo Canyon, identify the interrogatory and explain how the answer differs for unit 1 and unit 2.

42.

For each of the preceding,. interrogatories, state

~separately for each interrogatory:

1 (a) the identity of each and every person who i

participated in its answer;-

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(b) the identity of each and every document relied upon in preparing the answer.

DATED:

July 8, 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 4 A bn--

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SUSAN L.

DURBIN Attorneys for Governor George Deukmejian 3580 Wilshire Boulevard Suite 800 Los Angeles, California 90010 (213) 736-2105

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