H I LL H R I STOP HER AN 0 PH I LLIPS P C ap~<ppi+~+~ ~~

ISOO M STREET/ N. W. ~

WASHINGTON, De C. 20036

OVMONO PECK HILlRICHARO M, PHILLIPSOIL&CRT C MILLCRJOSEPH J. BRIGATIALAN J. B ER KCLEYCHARLES LCC EISCNCHERIP 5EOKYTHCOOORC I PRCSSROBERT W, OGREN5TCPH CN W. GRAF MANJAMC5 RICHARO 0 NEILLKARLAJ LCTSCHCMICHELE PAHY MOSSCHRISTOPHER B, HAN&ACKPAUL C HUROLC,~SAMUEL O. TURN CRPATRICIA HCEKMANN WITTILWILLIAMC. PERRYMICHACI 5 MILIER

GCORGC I CHRISTOPHERCARRY C. BROWNALAN ROY OYNNCRJVAN A &CLRCALJAMES G.VAUGHTERCLINOR W, GAMMONROBCRT A WITTICHCRB CRT H. BROWNRONALO W. STEVENSLAWRENCE COC LANPHCRROSCRT R BCLAIRJANET L NICHOLSONRICHARO C 5TEARN5CLIPPORO J Al CXANOERWILLIAMJ. MANNINGJOAN H,GRCGORYTHOMA5 P COONCY ZZOONALO W. SMITH

March 17, 1980

FRANCIS THORNTON GRCCNLCOUNSEL

TCLCPHONC (&02) AS& 7000

CA&LE< HIPHI

TELEX AAOZOQ HIPH V I

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WRITCR 5 OIRECT OIAL NVM&CR

452-7005

Ms. Barbara A. TompkinsSecretary to the Appeal BoardU. S. Nuclear Regulatory CommissionWashington, D. C. 20555

Re: In the Matter of:Pacific Gas a Electric Company(Diablo Canyon Nuclear Power

rrt, (nits 1 & 2) Docket Nos.-50-275;/50-323 O.L.

Dear Ms. Tompkins:

The undersigned will argue on behalf of Edmund G.

Brown, Jr., Governor of the State of California, at the

hearing scheduled for April 3, 1980.

Very truly yours,/

~ /'/ // /r--'~ ~ 1'

Herbert H. Brown,HILLi CHRISTOPHER1900 M Street, N.Washington, D. C.

EspyAND PHILLIPST P.C.W.20036

(202) 452-7005

DOCKETEDUS"'FlC

cco See attached Certificate of Service

8004 090033

MAR i "" >-"~>Office|itth&S lc tf

Docic n<L S wIBra"-CII ~ceo

UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION

BEFORE. THE ATOMIC SAFETY AND LICENSING APPEAL BOARD

In the Matter of ))

PACIFIC GAS AND ELECTRIC COMPANY ))

(Diablo Conyon Nuclear Power Plant )Units Nos. 1 and 2) )

Docket Nos. 50-275 O.L.50-323 O.L.

CERTIFICATE OF SERVICE

I hereby certify that copies of the attached letter to Ms.Barbara A., Tompkins, dated March 17, 1980, in the above-captionedproceeding, have been served on the following, by deposit. in theUnited States mail, fi st class:

Richard S. Salzman, Esq., Chairman .

Atomic Safety and Licensing Appeal BoardU. S. Nuclear Regulatory CommissionWashington, D. C. 20555

Dr. John H. BuckAtomic Safety and Licensing Appeal BoardU. S. Nuclear Regulatory CommissionWashington, D. C. 20555

Dr. W. Reed JohnsonAtomic Safety and Licensing Appeal BoardU. S. Nuclear Regulatory CommissionWashington, D. C. 20555

'Mr. Thomas S. Moore, MemberAtomic Safety and Licensing Appeal BoardU. S. Nuclear Regulatory CommissionWashington, D. C.. 20555

Elizabeth S. Bowers, EsquireAtomic Safety and Licensing BoardU. S. Nuclear Regulatory. CommissionWashington, D. C. 20555

Mr. Glenn O. BrightAtomic Safety and Licensing BoardU. S. Nuclear Regulatory CommissionWashington, D. C. 20555

Mrs. Elizabeth Apfelberg182 Luneta Dr'iveSan Luis Obispo, CA 93401

Dr. William E. MartinSenior FcologistBattelle Memorial InstituteColumbus, Ohio 43201

2.

Philip A. Crane, Jr., EsquirePacific Gas and Electric CompanyRoom 3127

, 77 Beale StreetSan Francisco, CA 94106

Mr. Frederick, EisslerScenic Shoreline Preservation Conference, Inc.4623 More Mesa DriveSanta Barbara, CA 93105

Mrs. Raye Fleming1920 Mattie RoadShell Beach, CA 93449

Mr. Gordon Silver1760 Alisal StreetSan Luis Obispo, CA 93401

John R. Phillips, EsquireSimon Klevansky, Esquire.Margaret Blodgett, EsquireCenter for Law in the Public Interest10203 Santa Monica DriveLos Angeles, CA 90067

Arthur C. Gehr, EsquireSnell & Wilmer3100 Valley CenterPhoenix, Arizona 85073

Paul C. Valentine, Esquire321 Lytton AvenuePalo Alto, CA 94302

.Yale I. Jones, Esquire100 Van Ness Avenue19th floorSan Francisco, CA 94102

Janice E. Kerr, EsquireLawrence Q. Garcia, Esquire350 McAllister StreetSan Francisco, CA 94102

Mr. James O. SchuylerNuclear Projects EngineerPacific Gas and Electric Company77 Beale StreetSan Francisco, CA 94106

Bruce Norton, Esquire3216 North 3rd StreetSuite 202Phoenix, Arizona 85102.

0

3 ~

David S. Fleischaker, EsquireSuite 7091735 Eye Street, N. W.Washington, D. C. 20006

Mrs. Sandra A. Silver1760 Alisal StreetSan Luis Obispo, CA 93401

Atomic- Safety and Licensing Appeal PanelU. S. Nuclear Regulatory CommissionWashington, D. C. 20555

Atomic Safety and Licensing Board PanelU. S. Nuclear Regulatory CommissionWashington, D. C. 20555

Docketing and Service SectionOffice of the SecretaryU. S. Nuclear Regulatory CommissionWashington, D. C. 20555

Richard B. HubbardMHB Technical Associates1723 Hamilton Avenue — Suite KSan Jose, CA 95125

John MarrsManaging EditorSan Luis Obispo CountyTelegram-Tribune1321 Johnson AvenueP. O. Box 112San Luis Obispo, CA 93406

Andrew Baldwin, Esquire124 Spear StreetSan Francisco, CA 94105

J. Anthony Kline, EsquireLegal Affairs SecretaryGovernor's OfficeState CapitolSacramento, CA 95814

Herbert, H. BrownHILL~ CHRISTOPHER AND PHILLIPS'E CD

1900 M Street, N. W.Washington, D. C. 20036

March 17, 1980

TALC L JOHKiI IHDA J, DHOWH

„PRAHCIS V CLIIPOIWDWILLIAH0, HcDCVITTCRAIO D 'OYKHAH

JONES. BROWN 8c CLIFFORD-ATTOIIHCVOAT LA'W

~ OO VAH HCOO AVLHUC IIITH PLODIfBAN FRANCISCO, CAl II CIRNIA QAIOZ

March 17, 1980

IAISI ASI NSIO

Richard S. Salzman, Esq:, ChairmanAtomic Safety 6 Licensirig Appeals BoardU.S- Nuclear Regulatory CommissionWashington, D.C. 20555

7

Thomas 5. Moore, Esq.Atomic Safety 6 Licensing Appeal BoardU.S. Nuclear Regulatory CommissionWashington, D.C. ~ 20555

P

Dr. Reed JohnsonAtomic Safety 6 Licensing Appeal BoardU-S. Nuclear Regulatory CommissionWashington, D.C. 20353

DOCKETEDU-"->.'r.c

MAR 2 r;c.c.;g,Qffic. of tha 8ggg~

D0Ciati<g Q V~~~S~IMC

V

In the Matter ofPacific Gas an Electric Company

(Diablo 'Canyon Nuclear r Plant, Un'its Nos. 1 and 2)Docket Nos. -275 O.L. and 50-323 O.L.,

Gentlemen:I

As per the First Prehearing Conference- Order of February 25, 1980,I enclose the Notice of Appearance of myself, as lead counsel, andMessrs. Valentine and Baldwin.

Intervenor will be presenting the testimony of Jeremiah P. Tayloras an expert witness in security matters. A summary of his educationand experience in this regard is enclosed. It is hoped that any objec-tion that, applicant might have to Mr. Taylor's qualifications can beresolved at the April 2, 1980 pre-hearing conference in order thatMr. Taylor may begin reviewing the sanitized version of the plan immedi-ately and assist in formulating intervenor's specific contentions.

Very truly yours,

Yale I. 'Jones(Lead Counsel for IntervenorSan Luis Obispo Mothers for Peace)

cc: Page 2

March 17, 1980Page 2

Enclosure as stated

cc: (w/ enclosures)

Elizabeth S. Bowers, Esq.Mr. Glenn. 0. BrightMrs. Elizabeth ApfelbergDr. Villiam E. MartinPhilip A. Crane, Jr., Esq.Mr. Frederick EisslerMrs. Raye FlemingMr. Gordon SilverJohn R. Phillips, Esq.Arthur C. Gehr, Esq.Paul C. Valentine, Esq.Janice E. Kerr, Esq.Mr. James 0. SchuylerEdward G. Ketchen, Esq.

Bruce Norton, Esq-David S. Fleischaker, Esq.Mrs. Sandra A. SilverAtomic . Safety 6 Licensing Appeal PanelAtomic Safety 6 Licensing Board PanelDocketing and Service SectionRichard B. HubbardJohn MarrsAndrew Baldwin, Esq.Herbert H. 'BrownJ. Anthony KleinJames R. TourtellotteL. Dow Davis,'sq.Mare R. Staenberg

UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION

cgP~~V5IED

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)gf Q Q ~ )"N'0AS'ffics

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4

BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD

In the Natter of ))

PACIFIC GAS AND ELECTRIC COMPANY ))

(Diablo Canyon Nuclear Power Plant )Unit Nos. l'nd .2) ,* )

NOTICE OF APPEARANCE

Docket Nos. 50-275 O-L-50-323 O.L

10 Notice is hereby given that the following attorneys hereby

ll enter their appearance on behalf of intervenor SAN LUiS OBISPO

12 MOTHERS FOR -PEACE,and provide the following information in accord-

'13

14

ance with 52;718ta),-10 CFR Part 2:I

Name — Yale I. Jones (Lead Counsel)

15

16

17

'819

20

21

F 22

24

25

I.Aw OFFICCS4ES. BRO'IVY: CurroxuFAN NCSS AVCNVCIS TH FI.OOII

A ANCISCO, CA ~ AIOS~ ~ IS> ASI SSIO

Address

Telephone Number

Admi s s ion s

Name

Address

Telephone NumberEp

Admissions

100 Van Ness Avenue, 19th FloorSan Francisco,. CA 94102

(415) 431-5310

Supreme Court for the State ofCaliforniaUnited States District Court forthe Northern District of CaliforniaPaul'. Valentine, Esp.

321 Lytton AvenueP.O. Box 210Palo Alto, CA 94302

(415) 327-6700

Supreme Court of the United States— Supreme Court. for the State of

California

I

United States District.'ourt forthe District of Columbia and North-ern, Eastern, Southern and CentralDistricts of California

6

Name

Address

Telephone Number

Admissions

-'Andrew Baldwin

124 Spear StreetSan Francisco, CA 94105

(415) 495-4770

Supreme Court for the State ofCaliforniaNinth Circuit Court of Appeals

10

12

- 13

14

Yale I. Jones (Lead Counsel),Paul C. Valen'tine and

Andrew Baldwin,="Counsel forSan Luis Obispo I<others for Peace

by Yale I. Jones

15

16

Dated at San Francisco, California,this 17th day of liarch, 1980

17

19

20

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23

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26

LAW OCI'ICCS'CES. BROVCÃ

CL!PFORDVAN NCSS AVCNUCI'H SLOOII

AANCISCO, CA 5 ~ IOCIAISI Ail SilO

tSCHOOLING AND TRAINING RESUME

JEREMIAH PRICE TAYLOR, born September 24, 1921~ Present full "me address:

135 Lake nore DriveSan Franc'sco, CA 94132(415) 665-4764

f)Qf\(

, ff ao ~ (1a44y /g C .i cog mtw+4 QJ'

'~(c-'St'aa Sg-gi,~Sb'w44i7g gr g"pgg

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Harried: Fathe of three grown chilaren.SCHOOLING: High school graauate, Oakland, California,June 1940.

City College of San Francisco, l-l/2 years tto January 1942. Pre-legal courses.Jul„.-/December 1944. Maritime Academv Officers'rainingScho=l in Alameda, CA. for commission as Ensign inHari=ime Service with a Marine Deck Officer's License.

Date .Location-= spices ~Sub 'ct Tvue1958 Jan.

t

1963 Hay

1963 June .

1967 Jan.

1969 Jan

Presidio =.F , .U.S. Army

S.F. Cit-; College, SFPD

S.F. Cit'ollege, SFPD1

. Univ. S.=-., U. S. CommunityRelations CommissionI

S.F. State University

Explosive Ord.-Reconn; Course

Piot and Civil CrowdControl

Chemical Agent Use.

Course

Course

Law Enforcement andSecurity

Seminar

Community Relations Seminar

1969 March

1970 Jan.

S.F. Pol'e Training Div.U S A

SFPD, Ca'-fornia PoliceOff. Sta.==ards & Training(POST)

Disaster Pre-arednessand Handl inc

Policing

Course

Cou se

1970 July Long Bea".-; State CollegeCalif. De=t. of JusticePolice Helicopter Use Course

1970 Nov. SFPD Tra=.-.ing Div. Civil Dis"u="anceHandling

Course

1971 July Long,Bee==. State Colleae Police .'lana =ament Course1972 Nov. Quantico, Virginia, FBI

~ ~

Urban Polic'ngProblems

Sympos1um

Date

1973 March

1973 April

1973 May

1974 March

1975 March

1975 Nay

1975 July

1975 Oct.

1975 Oct.

Location-F=soices

SFPD, Calife POST

San Jose State CollegeCalifornia POST

SF Police "aining Divn.

SF Police =aining Divn.

SF, U. S.A.:-. 6 FBI

. SF, Mayor's Office ofEmergency. Service

SF, U.S. De-t. of Justice

SFPD Train='"..g DivisionSF, U.S. Se=ret, Service/FBI/State "apartment

~Sub'ect-

p'olice EmergencyManagement

Police ExecutiveDevelopment

Hostage ?Negotiations

Hostages

Civilian Unrest(Iranians)

Earthauake a DisasterCoordination

Team Policing andCoordination

Terrorist ActivityDignitary Protection

Tvoe

Course

Course

Course

Course

Seminar

Seminar

Seminar

Semina

Seminar

1975 Nov..

1976 Jan.

1976 March

1976 Nov..

,SF, Presidio,- U.S. Army

SF, FBI/Postal AuthoritiesSF, Calif. Office of Emer-aency Services

San Mateo, A, SkylineCollege, Ca ifornia PeaceOfficers'=-sociation

UIP Security Seminar

Disaster Operations Seminar

Terrorism and Organ- Courseized Crime

Explosive'Ordnance . .SeminarProblems

1976 Dec. SFPD Trair.=".g Divn. Senior Adm. PolicingProblems

Seminar

1977 Feb.

1977 Mavr

1977 Aug.

SFPD Train ng Divn.

SF, Calif. Department ofJustice

SF Office c= EmergencyService

Senior Adm. SecurityProblems

Police Executivesand the Law

Disaster Planning

Seminar

Conferenc=

Seminar

1977 Oct. SF City Co eae Crim'ology Seminar

C

Dace Location-Aus ices ~sub 'ece ape

1977 Oc".

1977 No;.

1977 Dec.

1978 Ja-..

1978 Fe=.

1978 Fe".

Quantico, VA. NationalInstitute of Law Enforcement

SF Sheriff's OfficeSF, U.S. Secret Service

SFPD

Kansas City P.D., LEAA

SF, V.S. Coast Guard atTreasure Island

Managing PoliceOperations

Buildina Securitv

VIP Protection

Hazardous immaterial

Security 6 Polic3.ng

Nater front Security

Course

Seminar

Seminar

Seminar

Course

Seminar

1978 April

1978 Ap=il

1978 M--

1978 ju-.e

1978 Ju.".e

1978 Au".

1979 Ja."..

1979 March

1979

SF Office of EmergencyOperations

SF, U.S. Coast Guard

SFPD Training DivisionSFPD Training Division

Long Beach, CA, Calif. StateTraining InstituteSF Mayor's OfficeMarin County, CA, Calif.POST Divn.

Pomona, CA State CollegeLEAA

SF Mayor's Office

Disaster Operations

Shore s MarineTerrorism

Dignitary Protection

Police ExecutiveDevelopment..

International Terror-3. sm

Disaster. Planning

Police Executive~ Development

Criminal Investiga-tions.Police Protection

Seminar

Seminar

Seminar

Course

Course

Seminar

Course

Course

Seminar

1979 Ju.-.e

1979 Ju:-;

SFPD Training Divn.

SF, U.S. Alcohol/TobaccoFirearms Divn.

Senior PoliceManagement

Arson

Course

Conference

1979 De". Colorado Sprints, Col.LEAA I

Police Investigations Course

//

t

SUMMARY OF EXPERTISE, EDUCATION AND EXPERIENCE

OF JEREMIAH P TAYLOR

Jeremiah P.'aylor retired on January 1'6,. 1980 as

Deputy Chief of police for the City of San Francisco, Cali-

fornia after serving in that department continuously from

November 17,'947.. For the ten'ears between 1970 and his

retirement on January 16, 1980, Mr. Taylor served as Deputy

Chief of Operations'or in a .parallel position under the priornomenclature of Supervising Captain. In this capacity he had

day to day responsibility over approximately 1900 .sworn police

personnel and an additional .700 civilian employees

Some areas of Mr. Taylor's experience and expertise are

as follows:BUILDING AND 'SITE 'SECURITY

During the 1970's continued bombing attacks, armed assaults

and aggressive picketing action were directed at police facil-V

lities and .public buildings in San Francisco, and several

individuals were killed, many more being injured. As a result,Mr. Taylor planned, developed, refined, implemented and admin-

istered a personnel and physical security system for'. the nine

. police stations, the Hall of Justice and the City Ilail of

San Francisco. This called for study of the state of the art4p

in security measures, devices and hardware and consideration

of plans and proposals for building security. Included were

0

k

a study in depth of the types of potential attacks, threats

and dangers to be protected against. These included sabotage

efforts, single and multiple intruder penetration, gang as-

saults, sniper attacks, bomb attacks and interruption or

prev'ention of operation by mob action. After exploration

and consultation with security experts in diverse fields,and after surveying various types of security arrangements,

Mr.. Taylor supervised the implementation of a system forpersonnel, physical plant and. structure security for the

above-mentioned eleven locations in San Francisco. Subse-

quent to its installation Mr. Taylor's duties included'requentpersonal inspection and critiques for possible im-

provement of the human and physical components of this system.

In addition'to'he arrangement of structural architecture,alarm devices, protective shields and so forth, Mr. Taylor was

responsible for training personnel for general alertness forand knowledge of security matters.

EXPLOSIVE ORDINANCE DEMOLITION UNIT (BOMB SQUAD)I

Specials in this unit were developed and trained by

IIr. Taylor to meet specific dangers and threats. This unitreported directly to Mr. Taylor and regularly advised him

with respect to security and safety measures with regard to

protection from explosives.RIOT AND CROND CONTROL

/This specialized unit was also developed and trained

. ~

~~

under Mr. Taylor's supervision and was under his command

and control. The safety of citizens and physical plant

safety and. security were the controlling objectives.

Mr. Taylor 'personally was the officer in charge at over 200

instances of riot and crowd .control in all areas of San Fran-

cisco during the last 10 years. These ranged from campus

riots at San Francisco State University and anti-war demon-1

strations in the parks and neighborhoods of San Francisco to

mass demonstrations in the-.city!s.congested downtown center.

Rioters up to the number of 599 and crowds approaching the

number of'00,000 were successfully controlled and dealt

with in these operations.

ANTI-SNIPER UNIT

This specialized unit was founded and trained under

Mr. Taylor's supervision for protection. against by preventive

action in advance. Under Mr. Taylor's supervision it also

responded to and neutralized threatening sniper attacks as

they developed.I

VERY IMPORTANT PERSONS (VIP) SECURITY UNIT

Again under Mr. Taylor's direct supervision this unitwas developed and trained -to provide protection to individualsas they appeared in public and traveled and with respect toother matters of personal security. Where appropriate, th'is

unit performed bodyguard duty.

E

HOSTAGE NEGOTIATXON

This technique was instituted and trained for during

Mr. Taylor's tenure as Deputy Chief. He was'ersonally

in charge of and successfully concluded many large scale

hostage negotiations. He trained and supervised personnel

specialized in this technique.

XNTELLXGENCE

Mr. Taylor trained, supervised and appropriately and

successfully deployed personnel for the purpose of gathering

intelligence information with respect to all aspects of

security matters under his jurisdiction.DISASTER AND SECURITY CO-ORDINATXON

As the San Francisco Police Department's representative

for the San Francisco City and County disaster office/Mr. Taylor co-ordinated the police function in city wide

security efforts in the event of a war or other disaster.h

The California State Disaster Office, including its provisionsfor police mutual aid in the event of a police problem over-

whelming some local jurisdiction, was Mr. Taylor's responsi-

bility. These offices closely consulted with Yir. Taylor on

the subject matter.

Mr. Taylor acted as liason with the United States Coast

Guard on matters dealing with dock-side vessel underwater

security. The underwater .rescue unit of the San Francisco4p

Police Department reported directly to. Mr. Taylor on its

1

function and was used by the Coast Guard as necessary

after. consultation with and approval of Mr.- Taylor.

Mr. Taylor co-ordinated on matters of personnel, plantand crowd control with the United States 6th-Army Headquarters

at the San Francisco Presido as problems arose on the areas

of their mutual boundaries.

After the opening of the Golden Gate Federal Park System

in the ocean coast area of San,Francisco, the United States

Park. Administration contacted.and conferred with Mr. Taylor

and his office on matters of security and geographic, instal-lation and personnel areas. Continuous co-ordination of

security arrangements was maintained with the Golden Gate

Federal Park System with respect to the installations and

crowds that were located or arose-on their mutual contiguous

boundaries.

Training exercises were held under Pe. Taylor's totalor partial supervision with all of the above-mentioned agencies

wherein the San'Francisco Police personnel as well as personnel

of the agencies developed and drilled in their duties and r'es-

ponsibilities for security and safety. As a result of these

-exercises, improved .plans and co-ordination were developed.

CONSULTATXON TO PRXVATE ORGANXZATXONS

Based on his experience and expertise, Mr. Taylor was

consulted in his official capacity by many private citizens,l)

companies and organizations with respect to security matters.

~ g

He did, in. fact, act as Police Department liason and advisor

to. these organizations, individuals and companies, among

the many of which was the Pacific Gas and Electric Company.

Attached is a summary of the specialized training. under-

gone by Mr. Taylor during the years he had supervisory res-

ponsibility with the San Francisco police Department.