ML12181A173

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Letter to Ms. Vietti-Cook Withdrawal of Appearance of Eric J. Epstein from the Bell Bend Nuclear Power Plant Docket No. 52-039-COL Proceeding and TMI-Alert Inc.'S Support for the Petition to Suspend Final Decisions in All Pending Licensing
ML12181A173
Person / Time
Site: Davis Besse, Fermi, Watts Bar, Grand Gulf, Seabrook, Turkey Point, Diablo Canyon, Callaway, South Texas, Comanche Peak, Bellefonte, 05200012, 05200013, 05200017, 05200022, 05200023, 05200016, 05000039, Lee
Issue date: 06/20/2012
From: Epstein E
Three Mile Island Alert
To: Annette Vietti-Cook
NRC/SECY
SECY/RAS
References
RAS GGG-2, +reviewedmmc1, +reviewedgfw, +reviewedjr, +reviewedcpp
Download: ML12181A173 (19)
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DOCKETED USNRC June 20, 2012 June 21, 2012(8:00 a.m.)

OFFICE OF SECRETARY Annette L. Vietti-Cook, RULEMAKINGS AND ADJUDICATIONS STAFF Secretary of the Commission U.S. Nuclear Regulatory Commission' Washington, D.C. 20555 NRCExecsec@nrc.gov Re: TMI-Alert Inc.'s Support for the Petition to Suspend Final Decisions in All Pending Licensing Programs

Dear Ms. Vietti-Cook:

On Monday June 18, 2012, I filed a Petition ("Petition") in concert with Joint Petitioners to Suspend Final Decisions in All Pending Licensing Proceedings Pending Completion of Remanded Waste Confidence Proceedings, Re: Bell Bend Nuclear Power Plant, (Docket No.52-039 COL.)

I am formally withdravving my appearance in the Bell Bend Nuclear Power Plant, Docket No. 52-039-COL.

I am refiling on behalf of Three Mile Island, Alert, Inc., and formally supporting the Petition to Suspend Final Decision in All Pending Reactor Licensees Proceedings Pending Completion of Remanded Waste Confidence Proceedings.

The Petition also asked the NRC to establish procedures for ensuring that members of the public are given an opportunity to participate in the remanded proceedings. Three Mile Island Island Alert is a cosponsor of the Petition.

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Three Mile Island Alert was established in 1977 and has 600 lnembers who live in close proximity to operating and proposed nuclear reactors. We are not submitting the Petition in any specific docket but we are resubmitting this Petition for your general consideration, Enclosures 2

Three Mile Island Alert (TMIA) is a non-profit citizens' organization formed in 1977 after the construction and licensing of Three Mile Island Unit-1 and after TMI -2 was constructed. TMIA is the largest and oldest safe-energy group in central Pennsylvania. TMIA has enjoyed widespread public and political support in its role as a watchdog of the Three Mile Island Nuclear Generating Station. In the spring of 1987, TMIA was recognized by the Pennsylvania House of Representatives for 10 years of community service. The House, along "vith the City of Harrisburg, formally applauded TMIA's efforts on behalf of the community at their 20th and 25th anniversaries.

Since the March 1979 accident at TMI-2, TMIA has been actively involved with many Three Mile Island related issues including: active intervener before the Nuclear Regulatory Commission (NRC) in hearings involving safety, technical and managerial issues; monitoring and tracking chronic safety, technical and managerial problems at Unit-1 and Unit-2; tracking adverse health effects as a result of the TMI-2 accident and the normal operation of Unit-1 (since 1974); participating in two radiation monitoring networks; evaluating security problems at the Island; and, providing information, research and educational materials to the general public, media and elected officials.

TMIA also serves as regional clearinghouse on a broad spectrum of issues relating to nuclear power production including problems at Peach Bottom-2 and

-3, Susquehanna-1 and -2 and the proposed siting, licensing and construction of a low-level radioactive waste dump in Pennsylvania.

TMIA's policy is generated by a seven member planning council which meets quarterly. TMIA meets regularly with the NRC and Pennsylvania Department of Environmental Protection to discuss issues and problems relating to TMI-l and -2. The organization has two part-time volunteers who staff the office. In addition, several individuals write, edit and mail TMIA's newsletter. All of TMIA's funding comes from membership dues, private contributions and fund raising events.

TMIA's office is open Monday through Friday from 10:00 am to 6:00 pm.

Weekend visits are available by appointment. The public and all interested parties are encouraged to stop by or contact the group by phone or mail.

tmia.com 2

June 18,2012 UNITED STATES OF AMERlCA U.S. !\LJCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of )

Calvert Cliffs 3 Nuclear Project, LLC ) Docket No. 52-016-COL (Calvert Cliffs ~uclear Power Plant, Unit 3) )

In the Matter of )

Detroit Edison Co. ) Docket No. 52-033-COL (Fermi Nuclear Power Plant, Unit 3) )

In the Matter of )

Duke Energy Carolinas, L.L.C ) Docket Nos.52-018 (William States Lee III Nuclear Station, ) and 52-019 Units 1 and 2) )

In the Matter of )

Entergy Operations, Inc. ) Docket No. 50-416-LR (Grand Gulf Nuclear Station Unit 1) )

In the Matter of )

Entergy Operations, Inc. ) Docket No. 52-024-COL (Grand Gulf Nuclear Station Unit 3) )

In the Matter of )

FirstEnergy Nuclear Operating Co. ) Docket No. 50-346-LR (Davis-Besse Nuclear Power Station, )

Unit 1) )

In the Matter of )

Florida Power & Light Co. ) Docket Nos. 52-040-COL (Turkey Point Units 6 and 7) ) and 52-041-COL In the Matter of )

Luminant Generation, Co., LLC ) Docket Nos. 52-034-COL (Comanche Peak Nuclear Power Plant, ) and 52-035-COL Units 3 and 4) )

In the Matter of )

Nextera Energy Seabrook, L.LC ) Docket No. 50-443-LR (Seabrook Station, Unit 1) )

In the Matter of )

Pacific Gas and Electric Co. ) Docket Nos. SO-275-LR (Diablo Canyon Nuclear Power Plant, ) and SO-323-LR Units 1 and 2) )

In the Matter of )

PPL Bell Bend, L.L.c. ) Docket No. 52-039-COL (Bell Bend Nuclear Power Plant) )

In the Matter of )

Progress Energy Carolinas, Inc. ) Docket Nos. 52-022-COL (Shearon Harris Nuclear Power Plant, ) and 52-023-COL Units 2 and 3) )

In the Matter of )

Progress Energy Florida, Inc. ) Docket Nos. 52-029-COL (Levy County Nuclear Power Plant, ) and 52-030-COL Units 1 and 2) )

In the Matter of )

South Texas Nuclear Operating Co. ) Docket Nos. SO-498-LR (South Texas Project, ) and 50-499-LR Units 1 and 2) )

In the Matter of )

South Texas Nuclear Operating Co. ) Docket Nos. 52-012-COL (South Texas Project, ) and S2-0 \3-COL Units 3 and 4) )

In the Matter of )

Tennessee Valley Authority ) Docket Nos. 52-014-COL (Bellefonte Nuclear Power Plant, ) and 52-0IS-COL Units 3 and 4) )

In the Matter of )

Tennessee Valley Authority ) Docket No. 50-0391-0L (Watts Bar Unit 2) )

In the Matter of )

Union Electric Co. ) Docket No. 50-483-LR (Callaway Plant Unit 1) )

In the Matter of )

Virginia Electric and Power Co. )

d/b/a! Dominion Virginia Power and ) Docket No. S2-0I7-COL Old Dominion Electric Cooperative )

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(North Anna Unit 3) )

PETITION TO SUSPEND FINAL DECISIONS IN ALL PENDING REACTOR LICENSING PROCEEDINGS PENDING COlVIPLETION OF REMANDED WASTE CONFIDENCE PROCEEDINGS I. INTRODUCTION On June 8, 2012, in State ofNew York v. Nuclear Reg. Comm., No. 11-1045, the U.S.

Court of Appeals for the District of Columbia Circuit issued a decision vacating the u.s. Nuclear Regulatory Commission's (NRC's or "Commission's") Waste Confidence Decision Update

("WCD Update") (75 Fed. Reg. 81,037 (Dec. 23, 2010>> and its Temporary Storage Rule

("TSR") (75 Fed Reg. 81,032 (Dec. 23,2010>> and remanded them to the NRC. As a result, the findings of the WCD Update and the TSR regarding the safety and environmental impacts of spent reactor fuel storage and disposal no longer provide a legally valid basis for any NRC reactor licensing decision.

Therefore, pursuant to NRC regulation 10 C.F.R. § 2.323, the National Enviromnental Policy Act ("NEPA"), the Atomic Energy Act ("AEA"), and the court's decision in State ofNeH' York, Petitioners in the above-captioned licensing proceedings respectfully request the Commission to (1) suspend its final licensing decisions in all pending NRC licensing proceedings pending completion of the remanded proceedings on the WCD Update and TSR; and (2) establish a process for ensuring that the remanded proceeding complies with the public participation requirements of Section 189a ofthe Atomic Energy Act, 42 USc. § 2239(a). The Petitioners have submitted this request in virtually every NRC reactor licensing proceeding now 3

pending before the NRC, including twelve applications for combined licenses ("COLs"),

applications for license renewal ("LR"), and one application for an operating license ("OL,,).I As discussed in Section II below, many of the Petitioners are currently participating as intervenors in J\'RC licensing cases for new or reactors. Other Petitioners are neighbors of existing or proposed reactors who would have participated in NRC licensing proceedings had they not been barred from raising their concerns about spent fuel storage and disposal by the Commission decisions that were struck down by the court. By joining together in this Petition, Petitioners seek to ensure that the environmental analyses ordered by the U.S. Court of Appeals in State ofNew York will be fully applied in each reactor licensing case before operation is permitted, and that they will be given a meaningful opportunity to participate in the decision-making process.

At the outset, the Petitioners wish to establish with clarity what this Petition is not. This is not a motion for a stay of the effectiveness of a decision pursuant to lO C.F.R. § 2.342 or any other kind of request for equitable relief. Instead, the Petition is a demand for non-discretionary compliance with the requirements ofNEPA, the and the court's decision in State ofNew York In addition, this Petition is not a request to suspend all or any licensing proceedings.

Petitioners do not demand any change in the schedules for the NRC Staff s review of reactor license applications or adjudications in pending reactor licensing cases. This Petition seeks the suspension of final lieensing decisions only, pending the NRC's comp letion of the NEPA 1 Petitioners recognize that until the mandate issues in State afNew York, the WCD and TSR remain effective. Nevertheless, Petitioners have submitted this Petition within ten days of becoming aware of the court's ruling, in light of Commission precedents judging the timeliness of motions and contentions according to when Petitioners became aware of a decision's potential effect on their interests. Duke Energy COlp. (McGuire Nuclear Station, Units 1 and 2; Catawba Nuclear Station, Units 1 and 2), CLI-02-28, 56 NRC 373, 386 (2002). If the Commission determines that this Petition is premature, Petitioners request that the Petition be held in abeyance pending issuance of the mandate.

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proceedings remanded by the U.S. Court of Appeals. In addition, Petitioners seek a ruling ensuring that they will be given an adequate opportunity for public participation in the remanded proceeding. The requested relief is fully consistent with the Commission's holding in Entergy Nuclear Operations, Inc. (Indian Point, Units 2 and 3), 72 NRC 98, 100 (2010) ("Indian Point")

that it will not conclude action on the Indian Point license renewal application "until the [waste confidence] rulemaking is resolved." Petitioners seek a ruling by the Commission that it will apply the Indian Point precedent to all pending reactor licensing cases.

II. DESCRIPTION OF PETITIONERS Petitioners are individuals and organizations dedicated to the protection of the environment. These individuals and the members of these organizations live or work near operating or proposed nuclear reactors. Some organizations and individuals have been admitted as intervenors in the above-captioned pending NRC proceedings for the review of applications for COLs, license renewals, and an operating license. Other Petitioners are neighbors of proposed reactors or existing reactors whose license applications are under review by the NRC.

All of the Petitioners are concerned about the environmental and public health risks posed by the storage and ultimate disposal of spent fuel. Many of them have tried, without success, to raise their concerns about spent fuel in NRC licensing proceedings and rulemakings.

They now seek to protect their health, the health of their families, and the health of the environment, by ensuring that the NRC does not take any licensing action for a given reactor unless and until it has completed the environmental review of spent fuel storage and disposal mandated by the U.S. Court of Appeals in State ofNew York. The Petitioners also seek to ensure that they are given an opportunity to participate in the NRC's decision-making process, as required by Section 189a of the AEA, 42 U.S.c. § 2239(a).

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Many of the Petitioners have already established their standing to bring this Petition by gaining admission as intervenors in some of the above-captioned NRC licensing proceedings.

Other Petitioners are organizations whose members live within 50 miles of a nuclear reactor and who would have successfully petitioned to intervene regarding the issues remanded by the court in State ofNew York had they not been precluded from intervening by the very rules that the court struck down. They intend to submit hearing requests regarding the effect of State ofNew York on the licensing proceedings in which they are interested, and will submit standing declarations at that time. In the interim, they join the admitted intervenors in seeking the suspension of all licensing decisions pending compliance by the NRC with State ofNew York.

A list ofthe Petitioners follows:

  • Beyond Nuclear, Inc. (Intervenor in Fermi COL proceeding, Calvert Cliffs COL proceeding, and Davis-Besse license renewal proceeding; potential intervenor in Grand Gulf COL and Grand Gulflicense renewal proceedings)
  • Blue Ridge Environmental Defense League, Inc. and chapters ("BREDL") (Intervenor in Bellefonte COL proceeding and North Anna COL proceeding; previously sought intervention in W.S. Lee COL proceeding and Bellefonte OL proceeding)
  • Citizens Allied for Safe Energy, Inc. (Former intervenor in Turkey Point COL proceeding)
  • Citizens Environmental Alliance of Southwestern Ontario, Inc. (Intervenor in Fermi COL proceeding and Davis-Besse license renewal proceeding)
  • Citizens for Alternatives to Chemical Contamination (Intervenor in Fermi COL proceeding) 6
  • Ecology Party of Florida (Intervenor in Levy COL proceeding)
  • Eric Epstein (potential intervenor in Bell Bend COL proceeding)
  • Friends of the Coast, Inc. (Intervenor in Seabrook license renewal proceeding)
  • Dan Kipnis (Intervenor in Turkey Point proceeding)
  • National Parks Conservation Association, Inc. (Intervenor in Turkey Point COL proceeding)
  • Mark Oncavage (Intervenor in Turkey Point COL proceeding)
  • Missouri Coalition for the Environment, Inc. (Petitioner in Callaway license renewal proceeding; Intervenor in suspended Callaway COL proceeding)
  • New England Coalition, Inc. (Intervenor in Seabrook license renewal proceeding)
  • North Carolina Waste Reduction and Awareness Network, Inc. (Admitted as an Intervenor in now-closed Shearon Harris COL proceeding)
  • Nuclear Information and Resource Service, Inc. (Intervenor in Calvert Cliffs COL proceeding and Levy COL proceeding)
  • Public Citizen, Inc. (Intervenor in South Texas COL proceeding; admitted as Intervenor in now-closed Comanche Peak COL proceeding; potential intervenor in South Texas license renewal proceeding) 7
  • San Luis Obispo Mothers for Peace, Inc. (Intervenor in Diablo Canyon license renewal proceeding)
  • Southern Maryland CARES, Inc. (Citizens Alliance for Renewable Energy Solutions)

(Intervenor in Calvert Cliffs COL proceeding)

  • Sustainable Energy and Economic Development ("SEED") Coalition, Inc. (Intervenor in South Texas COL proceeding; admitted as Intervenor in now-closed Comanche Peak COL proceeding; potential intervenor in South Texas license renewal proceeding)

III. FACTUAL BACKGROUND In 1984, the NRC issued its first WCD, making findings regarding the safety of spent fuel disposal and the safety and environmental impacts of spent fuel storage. Over the several decades that have passed since then, the NRC has updated the WCD. The latest update was issued in December 2010. On June 8, 2012, the U.S. Court of Appeals for the D.C. Circuit took review of the NRC's 2010 WCD Update and TSR and vacated those rules in their entirety. In the course of reviewing the WCD Update, the court found that the WCD is a "major federal action" under NEPA, therefore requiring either a finding of no significant impact ("FONSI") or an environmental impact statement ("EIS"). ld., slip op. at 8. The court also found it was "eminently clear that the WCD will be used to enable licensing decisions based on its findings" because the WCD "renders uncontestable general conclusions about the environmental effect of plant licensure that will apply in every licensing decision." ld., slip op. at 9 (citing 10 C.F.R. § S1.23(b)).

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With respect to the WCD's conclusions regarding spent fuel disposal, the court observed that the NRC has "no long-term plan other than hoping for a geologic repository" and that spent reactor fuel "will seemingly be stored on site at nuclear plants on a permanent basis" if the government "continues to fail in its quest" to site a permanent repository. Id, slip op. at 13.

Thus, the court concluded that the WCD "must be vacated" with respect to its conclusion in Finding 2 that a suitable spent fuel repository will be available "when necessary." Id, slip op. at

11. In order to comply with NEPA, the court found that the NRC must "examine the environmental effects offailing to establish a repository." Id, slip op. at 12.

With respect to the TSR's conclusions regarding the environmental impacts of temporary storage of spent reactor fuel at reactor sites, the court concluded that the NRC's environmental assessment ("EA") and FONSI issued as part of the TSR "are not supported by substantial evidence on the record" in two respects. First, the NRC had reached a conclusion that the environmental impacts of spent fuel pool leaks will be insignificant, based on an evaluation of past leakage. The court concluded that the past incidence of leaks was not an adequate predictor of leakage thirty years hence, and therefore ordered the NRC to examine the risks of spent fuel pool leaks "in a forward-looking fashion." Id, slip op. at 14. In addition, the court found that the NRC's analysis of the environmental impacts of pool fires was deficient because it examined only the probability of spent fuel pool fires and not their consequences. Id, slip op. at 18-19.

"Depending on the weighing of the probability and the consequences," the court observed, "an EIS mayor may not be required." Id, slip op. at 19.

In remanding the WCD Update and the TSR to the NRC, the court purposely did not express an opinion regarding whether an EIS would be required or an EA would be sufficient.

Instead, it left that determination up to the discretion of the NRC. Id, slip op. at 12,20.

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IV. ARGUMENT A. The Commission Must Suspend All Licensing Decisions Pending Completion Of the Remanded Waste Confidence Proceedings.

As the court concluded in State ofNew York, the NRC considers the WCD and its Update to constitute essential findings regarding the feasibility and likelihood of spent fuel disposal that are prerequisites to the licensing of any reactor. Similarly, the conclusions of the TSR regarding the environmental impacts of spent fuel that will be generated by a reactor's operation are prerequisites to reactor licensing. The effect of the court's vacatur of the WCD Update and the TSR is to render these essential findings regarding spent fuel storage and disposal "null and void." See Black's Law Dictionary 1388 (5th ed. 1979) (to vacate is "[t]o render an act void; as, to vacate an entry or record, or ajudgment.") Thus, unless and until the NRC completes the proceedings remanded by the court in State ofNew York, the NRC has no legal basis for licensing or re-licensing any nuclear reactor. Robertson v. Methow Valley Citizens Council, 490 U.S. 332, 349 (1989) (agency must consider environmental impacts of a proposed action before taking the action).

The Commission has previously addressed the legal effect of an incomplete waste confidence proceeding. In Indian Point, the Commission refused to consider an intervenor's contention regarding spent fuel storage impacts in an individual licensing proceeding, but instead suggested that the intervenor could participate in the waste confidence rulemaking. 72 NRC at 100. The Commission also declared, however, that it would not "conclude action on the Indian Point license renewal application until the rulemaking is resolved." Id Petitioners respectfully submit that the precedent set by the Commission in Indian Point continues to require suspension of the Indian Point license renewal decision in that case, and also applies to all other pending reactor licensing cases. Because NEPA requires that environmental impacts must be taken into 10

account before the NRC takes a licensing decision, see Robertson, the NRC must hold all reactor licensing decisions in abeyance until it has completed its remanded proceedings for consideration of spent fuel storage and disposal impacts.

B. The AEA and NEPA Require the NRC to Offer an Opportunity to Participate in the Remanded Proceedings.

Section 189a of the AEA requires that in any proceeding for the issuance or amendment of a license, the NRC must offer interested persons the right to participate. 42 U.s.C. § 2239(a).

With respect to the WCD Update and the TSR, as the court has concluded and as NEPA requires, those decisions "apply in every licensing decision," State ofNew York, slip op. at 9, and therefore are governed by the procedural requirements of Section 189a. In addition, NRC regulations require the NRC to offer an opportunity for public comment on any EIS that it prepares. 10 C.F.R. §51.73. While NRC regulations do not specifically require the provision of an opportunity for comment on an EA, the Supreme Court has found that NEP A favors broad participation in environmental decisions. Marsh v. Or. Natural Res. Council, 490 U.S. 360, 371 (1989).

Petitioners seek to ensure that the NRC will fully comply Vv'ith the public participation requirements ofthe AEA and NEPA in the remanded waste confidence proceedings, by allowing them to (1) comment on any generic determinations that NRC may make and (2) raise contentions in individual licensing proceedings where they believe that generic rulemaking is insufficient to address their site-specific concerns. Therefore Petitioners request that the Commission issue any EAs it may prepare in proposed form for comment before making them final. In addition, Petitioners should be provided with at least 60 days - the standard time period for requesting a hearing to seek consideration, in individual licensing cases, of site-specific safety or environmental concerns raised by the remanded proceeding. A 60-day time period is 11

essential, given that some petitioners may be required to submit hearing requests, petitions to intervene, standing declarations, and motions to re-open the record in proceedings that have been closed or in which no hearing has been held.

IV. CONCLUSION For the foregoing reasons, the Petition should be granted. The Commission should issue an order that:

  • Suspends all final decisions in pending reactor licensing proceedings pending conclusion of the remanded proceeding to evaluate the environmental impacts of spent fuel storage and disposal;
  • Declares that any EAs or EISs issued by the NRC will be published in proposed form with a reasonable opportunity for public comment; and
  • Provides a period of at least 60 days for raising site-specific concerns relating to the remanded proceedings in individual licensing proceedings.

Respectfully submitted, Signed (electronically) by:

Diane Curran Harmon, Curran, Spielberg & Eisenberg, L.L.P.

1726 M Street N.W. Suite 600 Washington, D.C. 20036 202-328-3500 Fax: 202-328-6918 E-mail: ~=~==~====~~==~~

Counsel to San Luis Obispo lvfothersfor Peace in Diablo Canyon License Renewal Proceeding, Counsel to Southern Alliance for Clean Energy in Watts Bar Unit 2 Operating License Proceeding, counsel to i'luclear Information and Resource Service and Ecology Party ofFlorida in Levy COL proceeding, counsel to l"vfissouri Coalition for the Environment in Callaway Unit 1 license renewal proceeding 12

Signed (electronically) by:

Sara Barczak Southern Alliance for Clean Energy P.O. Box 1842 Knoxville, TN 37901 912-201-0354 E-mail: ~=~"-,,,,-!.!::..!.!=.z;~~

Duly authorized representative ofSouthern Alliance for Clean Energy in Bellefonte Units 3 and 4 COL proceeding and Signed (electronically) by:

Eric 1. Epstein 4100 Hilldale Road Harrisburg, PA 17112 717-541-1101 E-mail: .L."""~Jt!.~~~,~",,,,~,,, *.,J~

(pro se Petitioner in Bell Bend COL proceeding)

Signed (electronically) by:

Robert F. Eye Brett Jarmer Kauffman & Eye 123 SE 6 th Ave., Suite 200 Topeka, KS 66603 785-234-4040 E-mail: ~=G==~"'===~===

Counselfor Public Citizen and SEED Coalition in Comanche Peak COL proceeding. South Texas COL proceeding, and South Texas license renewal proceeding Signed (electronically) by:

Mindy Goldstein Turner Environmental Law Clinic l301 Clifton Road Atlanta, GA 30322 404-727-3432 Fax: 404-7272-7853 Email: ~~~=~~~'..1-"""'~

Counsel to Dan Kipnis, Mark Oncavage, National Parks Conservation Association, and the Southern Alliance for Clean Energy in Turkey Point Units 6 and 7 COL proceeding 13

Signed (electronically) by:

Paul Gunter Beyond Nuclear 6930 Carroll Ave., Suite 400 Takoma Park, MD 20912 301-270-2209 E-mail:

DuZv authorized representative ofBeyond Nuclear in Calvert Cliffs COL proceeding, Davis Besse license renewal proceeding, and Seabrook license renewal proceeding, Grand GulfCOL proceeding. Grand Gulflicense renewal proceeding Signed (electronicaIZv) by:

Kevin Kamps Beyond Nuclear 6930 Carroll Ave., Suite 400 Takoma Park, MD 20912 301-270-2209 E-mail:

Duly authorized representative ofBeyond Nuclear in Davis-Besse license renewal proceeding Signed (electronically) by:

Terry 1. Lodge 316 North Michigan Suite 520 Toledo, OR 43604-5627 419-255-7552 E-mail:

Attorneyfor Citizens Environment Alliance ofSouthwestern Ontario, Don't Waste Michigan, and the Green Party ofOhio in Davis-Besse lllue/ear Power Station Unit 1 license renewal proceeding.

Signed (electronically) by:

Michael Mariotte, Executive Director Nuclear Information and Resource Service 6930 Carroll Ave., Suite 340 Takoma Park, MD 20912 301-270-6477 E-mail:

Duly authorized representative ofNIRS in Calvert Cliffs COL proceeding Henry B. Robertson Great Rivers Environmental Law Center 705 Olive Street, Suite 614 St. Louis, MO 63101-2208 314-23 1-4 181 E-mail: ~=~=~~~~~'-'-'-'-~

Counsel to Missouri Coalition for the Environment in Callaway license renewal proceeding 14

Signed (electronically) by:

John D. Runkle 2121 Damascus Church Rd.

Chapel Hill, NC 27516 919-942-0600 Counsel to North Carolina Waste Awareness and Reduction Network in Shearon Harris 2 and 3 COL proceeding; Counsel to Blue Ridge Environmental Defense League in North Anna 3 COL proceeding Signed (electronically) by:

Raymond Shadis Friends of the CoastlNew England Coalition Post Office Box 98 Edgecomb, Maine 04556 207-882-7801 E-mail: ~~=~=~"'-'-'-'

Duly authorized representative ofFriends ofthe Coast and New England Coalition in Seabrook license renewal proceeding Signed (electronically) by:

Barry White Citizens Allied for Safe Energy 1001 SW 129 Terr.

Miami, FL 33176 305-251-1960 E-mail: =.:-:=~=;="-===..~=~'-"

Duly authorized representative ofCitizens Alliedfor Safo Energy in Turkey Point COL proceeding Signed (electronically) by:

Louis A. Zeller Blue Ridge Environmental Defense League P.O. Box 88 Glendale Springs, NC 28629 336-982-2691 E-mail: ~~~~~.~~.,,~

Duly authorized representative ofBlue Ridge Environmental Defense League and Bellefonte Efficiency and Sustainability Team in COL Proceedingfor Bellefonte Units 3 and 4; Duly authorized representative ofBlue Ridge Environmental Defonse League and People's Alliance for Clean Energy in North Anna COL proceeding; Duly authorized representative ofBlue Ridge Environmental Defonse League in Ws. Lee COL proceeding June 18,2012 15

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