ML20084C873
| ML20084C873 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/26/1984 |
| From: | Strumwasser M CALIFORNIA, STATE OF |
| To: | |
| References | |
| ALAB-763, NRC, OL, NUDOCS 8405010010 | |
| Download: ML20084C873 (16) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COPNISSION 00CKETED USHRC In the Matter of
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84 APR 27 P3:33 PACIFIC GAS AND ELETRIC COMPANY )
Docket Nos. 50-275 OL
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50-323 POL;g y g g v.
(Diablo Canyon Nuclear Power
)
T C N; 4 Sp.,.
Plant, Units 1 and 2)
)
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PETITION FOR REVIEW OF ALAB-763 Governor George Deukmejian hereby petitions the Nuclear Regulatory Ccmnission (NRC) to review the decision of the Atanic Safety and Licensing Appeal Board (Appeal Board) in ALAB-763 concerning the adequacy of design quality assurance (0A) at the Diablo Canyon Nuclear Power Plant.
I.
THE APPEAL BOARD HAS CREATED AN ERRONEOUS STANDARD FOR DESIGN QUALITY ASSURANCE 'IO OVERCOME THE UNCOtfrRADICTED EVIDENCE THAT DIABLO CANYON FAILS TO MEET THE STANDARD ESTABLISHED BY THE REGULATIONS AND SOUGHT BY THIS COPHISSION In 1981, faced with the mounting evidence of an unprecedented failure of Pacific Gas and Electric Company (PG&E) to meet NRC quality assurance requirenents and to design Diablo Canyon in conformance with its licensing criteria, the comnission established an Independent Design verification Program (IDVP) to provide the assurance of quality missing fran the design.
The standard for this effort was stated in March 1982 in SECY-82-89: 'Ihe IDVP was to denonstr' ate that "there is reasonable assurance that the overall... design is in conformance with the application...."
(PG&E Exh.156, p. 2; see also PG&E Exh. 157, p. 7.)
The Appeal Board initially adopted the same standard in the proceeding on the reopened record:
"Normally, an effectively functioning design quality assurance progran 8405010010 840426 1
PDR ADOCK 05000275 G
ensures that the design of a nuclear power plant is in conformance with the design criteria and ccmnitments set forth in an applicant's PSAR and FSAR.
In the case of Diablo Canyon, however, this confidence has been seriously eroded....
[T]here is now substantial uncertainty whether any particular structure, systen or ccrnponent was designed in accordance with stated criteria and ccmnitments.
"In these ciretzustances, the Comnission mandated the IDVP to provide after-the-fact assurance that the Diablo Canyon design conformed to the various design criteria...."
(Order of August 16, 1983 (unpublished), at 4-6 (fn. anitted).)
In the course of the hearing before the Appeal Board it became clear that Diablo Canyon does not meet that standard.
Indeed, witnesses fran the applicant, the IDVP, and the NRC staff all agreed that it was " virtually certain" that there renain in the design of both units errors that cause the design to fail to meet the licensing criteria.
(Tr. Dll77, D1543; see also Tr. D2264-65.) The problen facing the board was the fact that neither the IDVP nor PG&E itself examined more than a sample of the design (a process explicitly authorized by the comnission, to which no party objects) ard found nunerous design errors resulting in violations of the licensing
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criteria - an outcone apparently not expected.
Faced with this fact, the Appeal Board cast off from the established regulatory standard and landed on a more hospitable test, one of unbridled discretion: The verification progran was merely to give " adequate confidence" that there renain no undetected violations of licensing criteria that would be " safety-significant." The regulations define " adequate confidence" as the assurance that canes fran a program meeting the eighteen criteria of Appendix B to 10 C.F.R. part 50 (Appendix B).
The board's use of the phrase, stripped of its context, leaves the board free to define
" adequate" on an ad hoc basis, inviting the suspicion that they are matching the definition to an applicant's perfonnance. And witinut any citation of authority, the board announces that there are licensing criteria for safety-related structures, systens, and conponents that are not significant to 2
safety and that may be violated without jeopardizing one's right to a license.
(Slip Opn., pp. 31-32, fn. 68.)
Beyond the absence of any authority that some safety-related licensing criteria may be ignored, there is simply no basis for any conclusion about the safety-significance of the errors that were detected -- much less about the errors that reain undetected. The assessment of safety significance of a deviation from licensing criteria is, according to the evidence, complex and difficult - so difficult, in fact, tnat the IDVP shied away from any such assessment of the and expressly disclaimed any opinion on whether the errors it detected were safety-significant.1/ (Tr. D1555, D1557; PG&E Exh. 90, p. 6.4-1.)
Yet ALAB-763 relies on opinions about the safety-significance of unknown errors. This 1-ft the IDVP in the awkward position of testifying that it had no opinion on the safety significance of the errors it had detected / but did have an opinion on the safety significance 2
of the errors sure to exist in unknown nmbers in unknown locations, involving unknown cmponents, violating unknown licensing conditions.
1.
The Appeal Board concedes that assessments about safety-significance "as a general proposition" require formal analysis. But in this case, the board is prepared to say that the identified non-seismic errors are "of minor safety signficance."
(Slip Opn., p. 42, fn. 82.)
According to the testimony, formal analysis is required because the unobvious interactions of errors among complex systems can create unforseen safety hazards.
(Tr. D1555, D1557, ff. D2313 at 10-11.) The board offers no explanation how, from an examination of the obvious safety implications of the known errors, it can determine that no analysis of their unobvious implications is requ. ired.
2.
The staff and applicant were less cautious about offering opinions on the safety-significance of the known errors. IG&E performed what it called a study of thm (consisting mainly of the statement that, in the opinion of its engineers, each had no safety significance (see PG&E Exh. 92)); the staff did no more than cite and agree with that study.
In assessing the staff opinion, it is useful to note that, in the view of the staff, none of the known errors -- not the mirror image error, not the incorrect spectra, not the erroneous calculation of masses, none of the errors -- constituted a safety-significant error.
(Tr. D2696-99.) of-course, nobody did a study of the safety signficance of the unknown errors.
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(Tr. D1554, D1557-59; PG&E Exh. 90, p. 6.2.5-2.)
To justify their novel standard,the Appeal Board compares its notion of
" adequate confidence" to a straw-man standard of error-free design.
(Slip Opn., p. 32, fn. 68.) Noting that no power plant is error-free, the board leaps to the conclusion that errors -- including errors violating licensing f
criteria - simply don't count; to hold otherwise, the board implies, would require "' perfection'" of applicants.
(Ibid.) Because the Governor raised 4
[
the issue of remaining errors violating licensing criteria, 'a "apparently i
would accept only a zero error rate."
(Id., p. 33, fn. 70.)
l Nowhere does the Appeal Board acknowledge that the Governor did, indeed, propose an alternative standard for the verification progre, one that does not require "' perfection,'" nor an error-free design, nor l
l certainty of full compliance with licensing criteria. In his proposed i
J findings, the Governor noted that the comission's regulations provide a
" reasonable assurance" of safety not by making errors impossible but by providing a process, a properly functioning QA progra, that ensures that i
the probability of such errors is acceptably low. '!hus, a verification program can retrofit safety in either.of two ways:- (1) by showing, on the basis of scientifically valid samples, that the plant (or a given portion of i
f it) is free of errors violating licensing criteria / or (2) by giving the 3
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design the same level of scrutiny it would have received under a legally sufficient QA progre.
(Governor's Proposed Findings & Conclusions, p. 9.)
b 3.
Even this part of the standard does not require "' perfection.'"
The point here is to provide an applicant that is highly confident of the adequacy of its design, or a portion of it-(such as a given system or the work of a given design group), a way to avoid the 100 percent review of the design. For that portion of the design not qualified by sampling, a full review would be sufficient, irrespective of the neber of the errors uncovered and corrected, since that review would provide the see level of
. assurance an adequate QA program would have provided in the first place.-
4
Diablo Canyon meets neither alternative of the Governor's proposed standard.
It fails to qualify under part 1 mainly because the samples drawn contained nmerous errors causing violation.c of licensing criteriat--
- dmonstrating precisely the opposite of what was sought to be shoan.' And the progrm did not try to meet part 2.
Under an adequate QA program the entire design would be subjected to review by a secon3 engineer or designer plus approval of all design work by a supervisor - (n addition to the,
/'
inspections and audits required by Appandix B.
(Tr. D401.) Neither tha IDVP nor PG&E's internal technical program ("ITP") reviewed t% entire design - an criissi$n that produced "puzz1 ment" even on' the par't of the
,s '
J In rejecting a review of 100 percent of the design, the Appeal Board confuses two distinct concepts:
100 percent conf dence that the design is error-free and 100 percent coverage of the review.
(Slip Opn., p. 33, fn. 70.)
It is true, as the board observes, that evea a 100 p ccent review y
does not provide absolute certainty that the design is error-free.
(Slip Opn., p. 44, fn. 86.) But the regulations do require that 100 percent of the design be cove. red by the CA program. Although 100 percent confidence in the design is linpossible,100 percent coverage by the OA progrm is possible andnecessarytoyieldahigherconfidenceintheOebignthanaquality assurance progr m that checks only a fraction of the design. This higher confidence is the minimm level of confidence implicit in Apgendix B.
n, This confusion was empounded by /another:f the failure to fistinguish
/,
4 between the design procesv and'.th,eidesign produ2,t. According to the board,
-a
,e the important question is not what,propgrtion of the design was verified but f
whether the verification program "was sofficient to test thoroughly the design process."
(Slip Opn., p. 41, fn. 80.) QA progres are intended to assure the adequacy'bf both the design process and the product of that j
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process -- the design itself.
(Appendix B, Criterion III.)
By focusing on the design process, the board. effectively abandons any hope that the verification program will provide the same assurance as a proper QA program.
Plainly the Appeal Board has adopted a lower standard for quality assurance at Diablo Canyon than it would require of any other plant.
'Indeed, it is instructive to consider the application of the Diablo standard to another plant. Suppose another utility came to the NRC saying that it proposed to cmit a QA program for its design that its quality control would be such that the ecmnission would have " substantial uncertainty whether any particular structure, system or ccrnponent was designed in accordance with stated criteria and ccanitments."
(Order of August 16, 1983 (unpublished), at 2.)
Instead it would review the design after the fact --
but not the entire design, just a sample " sufficient :o test thoroughly the design process."
(Slip Opn., p. 41, fn. 80. ) And that test would be judged not by whether there were errors in the sample examinad; it would not turn s
on whether sone of the discovered errors violated licensing criteria; it would not even be affected by whether there renained undetected errors violating licensing criteria.
Instead, it would turn on whether the errors
_ conc $ded to exist and to violate licensing criteria were deemed -- without
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formal analysis, indeed without even knowing what and where the errors were
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-- not to be " safety-significant." The ecmnission would never license any other power plant on that basis. There certainly is nothing in the sorry histiory of Diablo Canyon to justify that standard here.
II.
THE POST-1981 QA PROGRAMS STILL FAIL TO MEET APPENDIX B t!nlike the QA program in effect prior to license suspension,.the Appeal Board's review of the QA program since November 1981 did not begin with any 6
finding of the program's adequacy or inadequacy.
It is therefore properly evaluated in terms of the specific requirments of Appendix B.
Rmarkably, neither the staff nor the IDVP reached any conclusion on ccepliance with Appendix B, and the Appeal Board makes no finding on Appendix B.
The PG&E Program. Until August 1982 the Diablo Canyon QA program was solely the IG&E QA program.
(Ff. Tr. D847, p. 10.) There is ample evidence of the deficiency of that program. The staff testified to continuing deficiencies in implmentation through mid-1982.
(Tr. D3024-26.) Docunents producal from PG&E files revealed documentary gaps and contradictions indicating inadequacies in training, interface control, updating of license ccumitments, aM, in fact, the failure to meet QA conmitments.
(Gov.
Exh. 35, pp. 3-4; Gov. Exh. 36, pp. 3, 5-7.)4/ The staff's witness on the QA program testified that, if those fiMings were true, then the program failed to meet Appendix B.
_. 02969-70.)
PG&E's principal defense to the deficiencies in its QA program was the claim that they didn't much matter because most of the design work (perhaps 95 percent) on the modifications was done after August 1982.
(Tr. D3157-60.) There is no evidence what that 5 percent or so consisted of. 'Ihe IDVP did not verify the pre-August 1982 program (see PG&E Exh.133), and neither i
PG&E nor the IDVP nor the staff nor the Appeal Board found it necessary to identify the nature aM quality of that work.
The DCP Program. Beginning in August 1982 the project was governed by 4.
Significantly, no member of the PG&E panel on the post-1981 quality assurance panel even knew of the existence of these documents.
(Tr. D3155-56, D3198-99.) Once they had reviewed them, the witnesses sought to explain them away by sayirs that the authors had not reviewed the entire QA program which, they testified, was distributed among some twenty-odd manuals.
- i.. D3152.) Assuning that was true, and ignoring the implications of that fact for the likelihood that responsible m ployees could-fiM out what the program required, it still leaves unexplained the findings of contradictions within the QA docments.
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the QA program for the cabined PG&E-Bechtel Diablo Canyon Project (DCP).
(Ff. Tr. D847, pp. 10-11.) Once again, there is no evidence the program meets Appendix B.
The IDVP, which had reviewed the pre-1981 progra against the
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requir m ents of Appendix B with devastating results, chose not to compare the post-1981 progre with Appendix B /; rather, the IDVP simply cmpared 5
the QA progra to PG&E's own requirements.
(PG&E Exh. 90, pp. 4.2.1-2, 4.2.1-26.)
Instead of evidence that PG&E cmplied with Appendix B, the I
record contains the IDVP's concession that the program was not timely impl me t d in strict accordance with Appendix B (Tr. D1699) and was not e ne fully functioning in Nov mber 1982, when the design work was sufficiently l
far along to begin what c a e to be called the " Big Push" for construction of the modifications.
(Tr. D1662-66.)
4 PG&E simply did not meet its burden of demonstrating that its post-1981 QA program met Appendix B.
That fact provides the context in which the rest of the evidence on performance of the progra must be judged. And the record is replete with evidence of QA deficiencies.
The IDVP review of the seismic redesign found n e erous errors, including a substantial neber of discrepancies between as-built drawings and design docments.
(Ff. Tr. D2084, pp.15-17, tables 5-1, 8-1.)6/ g I
Bechtel audit likewise found deficiencies requiring corrective action i
j.
throughout the progrm.
(Gov. Exh. 33.) - A PG&E audit showed that half of f
the DCP engineering ' manuals were out-of-date.
(Gov. Exh. 42.) On cross-5.
The IDVP justified the mission on the ground that it relied on NRC approval'of the progrm.
(PG&E Exh. 90, p. 4.2.1-26.)
Yet the staff reviewed only the DCP QA comitment, not the actual progra itself.
(Tr. D2977-79.)
- 6..
Significantly, questions are now emerging fra the staff about how the IDVP could have approved the DCP work in the. face of such
- discrepancies.
(See, e.g., Board Notification 84-082, p. 3.)
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o ex m ination PG&E witnesses admitted that the DCP did not perform audits of the adequacy of design documents as required by Criterion XVIII of Appendix B.
(Tr. D972-75, D976-78.)7/
It is useful see how PG&E dealt with the " design interface" rrablem --
~
the difficulty encounteral in cmmunications among design groups that led to the mirror-image error. As late as March 1983 the DCP engineering instructions establishing design interface controls consisted of a matrix assigning responsibility for each relevant combination of design groups --
an inemplete matrix with nearly every cell enpty.
(Gov. Exhs. 37-39.)
Once again the board dismisses these deficiencies with the familiar observation that nobody's perfect and the equally familiar refrain that the errors are not significant.
(Slip Opn., pp. 92-93, 97-98.) That may be sufficient to rebut the citation of errors in a progran that has, through other evidence, establishe6 its compliance with Appendix B.
In the absence of such evidence, the board's claim is irrelevant and implies a shifting of i
the burden of proof from the applicant to the parties challenging the adequacy of its program.
III.
THERE RDiAINS THE URGENT NEED TO COMPLETE THE VERIFICATION OF THE DIABLO CANYON DESIGN The growing importance of verification programs throughout the nuclear irr3ustry to compensate for past QA deficiencies makes the standards for review of such progr'ams of paramount importance to this emmission. Just as 7.
The staff is now requiring that PG&E undertake such technical audits and has issued a peoposed violation citing the past failure to do so.
(Board Notification 84-025, Tr. 104.) While PG&E has now agreed to perform such audits, it continues to maintain that Criterion XVIII does not require audits of the adequacy of the design.
(See Feb. 7, 1984, letter fra Schuyler (PG&E) to Eisenhut (NRC), PG&E letter no. DCL-84-046, p. 47.)
9
Diablo Canyon has focused attention on the probl e of QA failures in the nuclear irdustry, the camiission's handling of this case will establish the standard by which verification programs will be judged. The failure of this Appeal Board to hold Diablo Canyon to the same level of quality assurance that Appendix B requires creates a gaping hole in NRC regulation. ALAB-763 offers the licensee who violates the comission's regulations a lower standard for rmedial action than the original licensing requirments.
Beyond the precedential implications of this decision, Diablo Canyon rmains the subject of genuine doubt about the quality of its design. These doubts can only be resolved by completion of the work begun in 1981: a verification that dmonstrates, with the same certainty Appendix B dmands, that Diablo Canyon fully meets the safety requirements of the comission.
Because PG&E has still not established that it has a QA program in cmpliance with Appendix B, only the IDVP can provide that verification.
A good deal of work has already been done. The errors discovered thus far have all been corrected. The camission may well have adequate confidence in the facility to permit operation while the still-missing assurance of safety is provided. But the desire to avoid undue delay in operation should not force the comission to ignore the reaining uncertainties and leave those doubts lingering for the next forty years.
Dated: April 26, 1984 JOHN I. 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 PETE" H. KAUMAN, MARK u. URBAN, Deputy Attorneys General 0
U By MICH p J. STRUMWASSER Attorneys for Governor George Deukmejian 10
UNITED STATES OF AMERICA OhjfR 0
NUCLEAR REGULATORY COMMISSION
'8 APR27 pif4 y
In the Matter of
)
(,.[EOFSECg
)
50-275"O.M,l[fj$n.
PACIFIC GAS AND ELECTRIC COMPANY
)
Docket Nos.
)
50-323 0.L.
(Diablo Canyon Nuclear Power
)
Plant, Units 1 and 2)
)
)
NOTICE OF APPEARANCE NOTICE IS HEREBY GIVEN, pursuant to 10 C.F.R.
section 2.713, of the appearance of counsel as follows:
Name of Counsel:
Mark J. Urban Address of Counsel:
1515 K Street, Suite 511 Sacramento, CA 95814 i
Telephone of Counsel:
(916) 324-5347 Qualifying Admission:
California Supreme Court Party Represented:
George Deukmejian Governor of the State of California State Capitol Sacramento, CA 95814 DATED:
April 26, 1984 JOHN K. VAN DE KAMP, Attorney General of the State of California ANDREA SHERIDAN ORDIN, Chief Assistant Attorney General MICHAEL J. STRUMWASSER, Special Special Counsel to the Attorney General SUSAN L. DURBIN, PETER H. KAUFMAN, MARK J. URBAN, Deputy Attorneys General By MARK J. URBAN Attorneys Governor George Deukmejian
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k(E0 UNITED STATES OF AMERICA v
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In the Matter of
)
)
PACIFIC GAS AND ELECTRIC COMPANY
)
Docket Nos. 50-275 O.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 Petition for Review of ALAB-763 and Notice of Appearance 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.
I 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 l
1717 H Street, N.W.
Washington, D.C.
20555 Hon. Thomas Roberts, Commissioner
- U.S. Nuclear Regulatory Commission 1717 H Street, N'.W.
i l
Washington, D.C.
20555 l
I l
1.
i l
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Hon. James Asselstine, Commissioner
- U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, D.C.
20555 I
Hon. Frederick M. Bernthal, Commissioner
- U.S. Nuclear Regulatory Commission 1717 H Street, N.W.
Washington, 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 i
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 l
Judge Glenn O. Bright Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Judge Jerry R. Kline l
Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission l
Washington, D.C.,
20555 l
L Harold Denton Director of Nuclear Reactor Regulation i
U.S. Nuclear Regulatory Commission Washington, D.C.
20555 i
Leonard Bickwit, Esq.
Office of the General Counsel U.S. Nuclear' Regulatory Commission Washington, D.C. 20555 2.
4
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Lawrence Chandler, Esq.
- Henry J. McGurren, 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 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 Conference, Inc.
4623 More Mesa Drive l
Santa Barbara, CA 93105 Gordon Silver Sandra A. Silver 1760 Alisal Street San Luis Obispo, CA 93401 Joel R. Reynolds, Esq.
Eric Iavian, 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.
- Richard F. Locke, Esq.
Pacific Gas and Electric Company 77 Beale Street, Room 3135 San Francisco, CA 94106 j
3.
1
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 l
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.
Cheryle Johnson Five Cities Times Press Recorder P.O. Box 460 Arroyo Grande, CA 93420 DATED:
April 26, 1984 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, MARK J. URBAN, Deputy Attorneys General
' A/
a By
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([MECHAEL J. STRUMWASSER i
1 Attorneys or Governor George Deukmejian 3580 Wilshire Boulevard Suite 800 Los Angeles, California 90010 (213) 736-2102 i
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