ML18026A067
| ML18026A067 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/27/1974 |
| From: | Reis H Florida Power & Light Co, Lowenstein, Newman, Reis & Axelrad, Steel Hector & Davis |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| Download: ML18026A067 (37) | |
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~ l, UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
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FLORIDA POWER & LIGHT COMPANY ) Docket No. 50-389
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(St. Lucie Nuclear Power Plant, )
Unit 2) )
'EPLY OF APPLICANT TO PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW In accordance with 10 CFR g 2.754(b) (3) and this Board's direction (Tr. 3377), the Applicant, Florida Power 6 Light Company (FPL), hereby submits this reply to the proposed findings of fact and conclusions of law filed by the other parties to this proceeding.
Both Applicant's and the AEC Regulatory Staff's proposed a
findings of fact and conclusions of law have been filed in accordance with 10 CFR 5 2.754 and the Board's directions of November 19, 1974 (Tr. 3369-3370, 3376-3377). The proposed findings and conclusions of the Applicant and the Staff are in basic agreement. To the extent that they do differ, Applicant requests that the Board adopt Applicant's proposed findings of fact and conclusions of law. With one exception, the Applicant does not believe those differences are sufficiently significant to make it necessary to burden the Board with a discuss.~on of them.
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Paragraph 28 of the Staff's Proposed Findings contains language which implies that cooling water can be discharged solely through one discharge line while Unit 1 and Unit 2 are both in operation. That implication is incorrect. Tr. 2298-2300; Applicant's Proposed Findings, para. 158, p. 76; Staff's Proposed Findings, paras. 42 and 43, pp. 20-21. Zn fact/
para. 28 is part of Section IXB of the Staff's Proposed Findings, entitled "Impacts of Construction," and is intended to be in effect only before Unit 2 goes into operation. Accordingly, the paragraph should be clarified. Such clarification 'can be effected'f the. next-to-last sentence of the paragraph is modified by (i) adding the words "Before Unit. 2 becomes opera-tional" at the beginning of the sentence; and (ii) substi-tuting the words "would allow 'discharges" for the words "allow operation" in the third line. As so amended, the sentence would read: "Before Unit 2 becomes operational, the Staff requires shutting off one of the two discharge lines (preferably the Unit 1 Y-type discharge line) once the Unit 2 multiport line becomes available and would allow discharges with both discharge lines only when Unit, 1 is shut down or I
full dilution flow from the Unit 2 circulating pumps is available."
The remainder of this reply is devoted, to a discussion of the "Xntervenors Proposed Findings of Law."
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At the outset we note that the document wholly fail" to address Contentions 1.1, 1..2, 1.2.1, 1-.6(c), 2.3 and 3.2.
This failure has occurred in the face of the Board's express direction that proposed findings of fact, and conclusions of law "will be filed by each party in accordance with the rules of practice . . . ." Tr. 3369. The issues included in Con-tentions 1.1, 1.2, 1.2.1, 1.6(c), -2.3 and 3.2 were the subject of extensive consideration by the Board in this proceeding.
"At least as to those issues the failure to file proposed findings represents a clear'default." 'on'sumers Power Compan (Midland Plant, Units 1 and 2), ALAB-123, RAX-73-5, 331,,333-334 (1973) .. Accordingly and pursuant .to 10 CFR 5 2.754(a),
Applicant requests the Board to declare the Xntervenors to be in default with respect to those 'issues. Such default could be taken into account in any challenge on appeal to the findings of the Licensing Board." 'orthern St'ates Power
~Ccm 'an (Prairie Island Nuclear Generating Plant, Units I and 2),.ALAB-244, Slip Op., p. 17 (November 21, 1974) .
Xntervenors'roposed Findings purport to address only Contention 2. 2, relating to population; Contention 2. 1 (b) concerning hurricanes and site suitability; Contention 1.3, relating to need for power; and LWA activities. We discu s each of these matters 'below.
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The evidence presented in this proceeding overwhelmingly supports 1/
the conclusion that "the proposed site meets the requirements of 10 CFR Part 100 as to population density and use characteristics." In consequence on this record Contention 2. 2 (a) must be decided favorably to the Applicant's position. Perhaps in recognition of this, Inter-venors do not request the Board to conclude that .the requirements of 10 CFR Part 100 relating to population have not been met. They merely
'I request that the Board direct that "fuller consideration be given to present population and its future projections..." (Intervenors 2/
Proposed Findings, p. 4) and that more intensive consideration be given to possible alternative sites (pp. 2, 8) . However, as we show below, the alleged bases for the suggestion that this Board should direct "fuller consideration" are wholly without merit.
Intervenors cite the initial decision in Public Service Electric and Gas Com an and Atlant'ic Cit El'e'ctric Com an (Hope Creek Gen-crating Station Units l. and 2), LPB-74-79, RAI-74-10, 745, to support their argument that the population levels projected to occur around the St. Lucie site require additional investigation of alternative sites. Apparently in further support of this position, at page 6 Intervenors quote Dr. Bernard as stating that:
"I'f:the' ul'ati;on wire'rojected to increase to the hypo-
'the'Cecal'evelof 134',000'ersons'ithe.n a 5 male ra zus of the St. Lucie site, the Staff would require the Applicant to znvestzgate alternative sites." (Emphasis added)
R gl That evidence is summarized in the Staff's Proposed Findings -at paras. 128-153, pp. 59-65, and in the Applicant's Proposed Findings at paras.92-144, pp. 45-69.
2/ Hereinafter, page references are to Intervenors Proposed Findings of Law unless the con'z'the.-ise in~ica'io".
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Intervenors ignore the fact that, in the very next sentence of his testimony, Dr. Bernard said:
"However, since the Staff does not project a population of this magnitude at St. Lucie, the investigation of alternative sites for this purpose has not, been required." (Supple-mental Testimony of AEC Regulatory Staff on Board Questions Related to Demography, p. 2; follows Tr. 2722) 3/
It is clear that, no one, including Inter'ven'ors'itness, pro-jects "a population of this magnitude at St. Lucie." Indeed,
'he entire passage quoted by Intervenors is in response to a question by Dr. Hooper in which he hypothetically doubled the highest projection made by any witness for the are'a within 5 miles of the plant. See, Applicant's Proposed Findings, paras.
139@ 142'p 67 j 69 ~
There is no support for the argument that, because of the population projections in this case, some investigation of al-ternative sites was required, different or more intensive than what took place. Intervenors'itation to the Hope Creek case
'I is entirely inapposite. To the contrary, Intervenors have raised no 'genuine issue of material fact in this proceeding with respect to alternative sites. Contention 1.6(b) was, therefore, dismissed summarily. "Order on Motion for Summary Disposition," para. 8, September 25, 1974. The comparison of the site with the best available alternatives, as analyzed in the FES, is a proper analy; sis of alternative sites. Northern Indiana Public Service Company 3/ The highest projection, 67,000, was made by Schro.dt. See Gchm-dt tc"t.;;.o."'y, p.
Intervenors'z.tness 1C; cllo;;
Tr. 1096.
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(Bailly Generating Station, Nuclear-l), ALAB-224, RAI-74 8g 244 at 268-269 (August 29, 1974) .
~.Neither do Intervenors'uestions concerning the ad-.
missibility and weight to be accorded to those parts of the Preliminary Safety Analysis Report and the Environmental Report which relate to population raise any issue of significance.
Contrary to Intervenors'ssertion at pp. 3, there is no doubt that Applicant's witnesses Kent and O'Neal are qualified to testify to the authenticity of the ER and PSAR. They super-vised the preparation of these documents. Joint Testimony'of Ellis O'Neal and Clifford S. Kent, Jr., follows Tr. 344. As=
stated by the Atomic Safety and Licensing Appeal Board:
"The admissibility of the [PSAR] into the hearing record need be tested only by its identification as the document prepared. pur-to Commission regulations and submitted 'uant to the Commission as a part of the application.
So long as the [PSAR] meets such an identifi-cation test it is admissible."
Boston Edison Compan (Pilgrim Nuclear Power Station), ALAB-83, WASH-1218 (Supp.), p. 552, 567 (December 4, 1972) .
So far as weight is concerned, Philip W. Moore, Applicant's demography witness, testified that his firm had prepared all of the material submitted by Applicant to the AEC with the exception of certain updated figures prepared by Applicant.
Tr. 767-768; 813-814. Moreover, Mr. Moore stated that he was in general agreement with the updated figures with exceptions noted in his testimony. Tr.. 768.
~. r Mr. Moore, who was cross-examined at. length by Intervenors'ounsel, was familiar with all of the data in the ER and PSAR.
Tr. 768, 813-814. Moreover, the Staff made its own independent study of population on which it, relied. Testimony of Calvin H.
Moon, p. 2, follows Tr. 3340; Tr. 2321. In this proceeding as in the Pi1qrim case:
"The weight which should be given to the contents of the [PSAR] is another matter which depends on the evidentiary record which is developed in connection with specific matters, in controversy. The Joint Intervenors were
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'outset of this proceeding to challenge the probative value of any specific information in the [PSAR] which concerns matters in con-troversy in this proceeding."
ALAB-83, ~su ra, WASH-1218 (Supp.), p. 567. Accordingly, the PSAR and ER have been properly authenticated and have probative 4/
va'lue.
Intervenors'fforts to discredit Mr. Moore fail. Their pejorative references (p. 2) to a bankrupt corporation in the..
context of population. projections are wholly irrelevant; and,.
in fact, there is nothing in the record which indicates that population projections were made by any corporation which is now,,
4/ The factual context of this case is strikingly similar to that in the P~il rim case. The PSAR was introduced in evidence through the testimony of witnesses under whose supervision the documents were prepared. Intervenors'lanket objection .to admission of the PSAR was denied.- Intervenors'otion to strike certain portions of the PSAR not within the expertise or competence of the sponsoring witnesses was denied. 'ee, WASH-.1218 (Supp.),
- p. 567.
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8-or ever has been, in bankruptcy. Tr. 736-'737, 741, 750, 752.
In fact the record discloses that Mr. Moore based. his evaluation on 25 years'xperience and data, including data specific to the St. Lucie area. Testimony of Philip N. Moore Relating to Contention 2. 2 (c), p. 2, follows Tr. 764; Tr. 827. The past studies of Mr. Moore's firm have proved to be reliable. Tr. 887.
The fact that in March, 1974, his firm was requested to re-evaluate information in the PSAR to prepare for hearings in this proceeding, is of no significance insofar as the weight or credi-bility of his testimony is concerned. (p. 3).
As noted in paragraph 140, of Applicant's findings, Mr. Moore, based on his long experience, projected what he considered to be realistic population figures. In large part Intervenors'fforts to discredit him depend. upon .distortions of the record. For example, Mr. Moore did not consider Mr. Shinn's count (p. 3) because he had no way to evaluate its reliability.
Tr..886. He did not consider timesharing ownership (p. 4) to be.
significant. Tr. 823. Although he testified that "plans existed" to construct a town in connection with a proposed oil refinery about 20 miles from the site (p. 4), he stated,.based on a firsthand knowledge of the situation, that the likelihood that.
the refinery or the town would ever be built is very small.
Tr. 844-845. Mr. Moore did not testify (p. 4) that "he failed to research" the point of origin of camper condominium owners at Tr. 839, 841; he stated that he did not "condu t a survey" of
'uch owners on Hutchinson Island and. that his analysis was based
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on experience in Florida with respect to such camper condominium owners. Tr. 840-841. At Tr-. 748, Mr. Moore did not testify that he studied the Stuart, Martin County, Hutchinson Island area in 1974 "for the first time." (p. 4) Not only did he study'he area prior to 1974, he identified the study specifically, contrary to Intervenors'ssertion at p. 5. Tr. 2996. Although he testified, at Tr. 849,that he knew of no zoning density changes "in effect," (p. 4) he also testified "that zoning changes are being contemplated . ... ." Tr. 849.
Nor does Mr. Moore's testimony constitute a "refutat'ion" (p. 5) of the PSAR and ER. Moore did not testify at Tr. 2992 that a population of 22,266 could occur on Hutchinson Island.
That figure is contained in his prepared testimony which follows I
Tr. 2967, on Table 2.1-4,, page 2.1-20 of that testimony. The table itself, and the page of text two pages before the table, and was a 2' '" "
conservative estimate pending completion of formal demographic studies. The rea'listic evaluation prepared. by Mr.:Moore shows a lower expected population, but it, is not incon-sistent with the conservati've estimate in the testimony cited by Intervenors. Applicant's Findings, paras. 139-140, pp. 67-69..
The arguments made by Intervenors with respect to Dr. Bernard's qualifications (p. 5) have been answered in the Board's Order of November 29, 1974. They are also addressed in'ara. 114, pp. 55-
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56, of the Applicant's Proposed Findings and para. 137, p. 60, of the Staff's Proposed Findings., Nevertheless, two additional points may be made. First, the citation to Tr. 272 at p. 5 has no weight as evidence. It i.'s a citation to the opening statement of Applicant's counsel.'t also has nothing to do with population projections. Second, Richard Schmidt's testimony does not find fault. with reliance upon State of Florida population, statistics, as asserted by Intervenors on page 6 of Intervenors'indings.
Quite the contrary, Mr. Schmidt relies on the very same statistics.
Testimony of Richard Schmidt, pp. 3-5 and Tables 1 and 2, (notes),
I follows Tr. 1096.
At. the bottom of page 7 and continuing to page 8, Inter-venors refer to projections of possible accelerated growth beyond 1990 by Mr. Schmidt. However, they neglect to 'note that Mr.
Schmidt admitted these to be "speculation on some of the assump-tions" which he made in his testimony. Tr. 1148. The nature of the assumptions and their lack of validity are discussed in paras. 128-130, pp. 63-64,of Applicant's Proposed Findings.
Finally, the calculations with respect to the population center distance on page 8 ignore one crucial fact -- the popula-tion center distance can be reduced to 1 1/3 miles if future population growth warrants it. Testimony of Dr. Bernard, p. 2g follows Tr. 2722; Applicant's Findings, para 148. Using the same technique as Intervenors use on page 8, the population at 1 1/3 miles from the plant would be 1950 X 1 1/3 or approximately 2600 people, nearly ten times lower than the 10 CFR P art 100 criterion of 25,000.
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,. For all of the reasons stated above, the record does not support any of Intervenor's'roposed findings with respect to I
population, and they should be rejected.
As with respect to Contention 2.2, Intervenors do not now argue that Contention 2. 1 (b) be decided in their favor. They merely suggest (pp. 9-10) that !'ore complete analysis," "more accurate testimony" and "more stringent precautionary investigation" be provided or undertaken. The reques t for further evidence or proceedings is wholly lacking in justification.
Intervenors'resent position appears to be that "in view of the vulnerability of Hutchinson Island during a hurricane" (i.e., the. likelihood that Hutchinson Island will be cut; see Tr. 1933, 1697-1699 and testimony of Arnold L. Sugg, p. 2, following Tr. 2000B all cited in the Intervenors'roposed T
Findings) and the fact. that the site is located on a sand island P
below the 35th parallel, more facts than are now known should be determined. However, Contention 2. 1(b) relates to the possible I
impact of hurricanes on the proposed site and the safe operation of the plant. As demonstrated in paras. 24-, 53, pp. 12-26, of the Applicant's Proposed Findings and in paras. 185-186, pp. 82-83, of the Staff's Proposed Findings, the only qualified expert witnesses concluded that while it is possible that a PMH could breach Hutchinson Island, the, integrity of the plant island
would be maintained and all features essential for safety would be protected.
Nor do any differences among the witnesses concerning the h
characteristics of stalled hurricanes (p. 9), throw doubt on the validity of these conclusions concerning the security of the plant site.'he potential effects of stalled hurricanes were taken into account in considering the effects of PMH caused erosion and in reading those conclusions. Tr. 1733-1734. See Staff's Proposed Findings, para. '187, p. 84; Applicant's Proposed Findings, para. 41, p. 20. ~
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Intervenors'roposed Findings as they relate to Contention 1.3 distort the record concerning the need for power. Thus, Intervenors appear to suggest (p. 11) that because FPL calculates reserve margins on a 15 minute peak load rather than a 60 minute peak, somehow the need for reserves has not been established.
However, they ignore the facts that the 15 minute peak must be met. (Tr. 616, 617), that use of the 15, minute margin is appropriate because of considerations unique to FPL's system (Tr. 661-662i 665), and that reserve margins calculated on the 15 minute peak basis correspond 'to 60 minute peaks well within the reserve margins 'recommended for the Applicant. See Applicant's Proposed
, Findings, para. 167, p. 82; Staff's Proposed Findings, para. 107,
- p. 48.
Intervenors also suggest (pp. 12, 13) that the only reason for the construction of the St. Lucie No. 2 facility is to substitute nuclear fueled'acilities for fossil-fueled capacity.
In fact, however, the record clearly reflects FPL's need for base lo'ad capacity, including St. Lucie Unit 2, to meet pro-jected increased demand on its system. Applicant's Proposed Findings, paras. 169, 170, pp. 84-85. Recognizing current uncer-tainties associated with forecasting, FPL's generation plans were developed to accommodate a band of growth rates ranging r
from 7% to 11%, and all studies based on growth rates within that band support the need for St. Lucie Unit 2. Testimony of Ernest L. Bivans Relating to Contention 1.3, p. 6, Table B-1; follows Tr. 383; paras. 169, 170, ~sn ra E.ven if the growth rate declines to 7%, the bottom of the band, FPL would not, because of the uncertainties involved in estimating both load and construction schedules six years in advance, defer commence-ment of construction of St. Lucie Unit 2. App. Exh. 7, Attach-ment B, p. 3.
If for no other reason, these considerations make the Intervenors'eference (p. 14) to the dissenting opinions in the initial decision in Nia ara Mohawk Power Corporation (Nine Mile Point, Unit 2), LBP-74-43, RAI-74-6, 1046 at 1090 (1974), inapposite.
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Unlike the situation in Nine Mile Point, here substitution of
'nuclear for fossil fuel is far from the only justification for St.
Lucie Unit No. 2. The plant is needed to generat'e electricity.
5/ RAI-74-6 at 1067.
Applicant has made load growth projections, based on the best state-of-the-art methods, which projections predict a need for .St. Lucie No. 2 in 1980. Applicant's Proposed Findings, paras. 170, 193-196, pp. 83, 95-97. These projections take into account energy conservation and the recent economic downturn. Applicant's
.Findings, paras. 171-182, 183-187, pp. 85-90. Consequently this case provides even more reasons for a finding favorable to the Applicant on need for power than,did the majority opinion in the Nine Mile Point case, and there is no reason to follow the dis-senting opinion in that case.
Finally, with respect to Contention 1.3 a few miscellaneous distortions of the record by the Intervenors should, be noted. They cite (p. 13) Tr. 533 for the proposition that "additional reserve power through Florida Power Corporations [sic] interties with the Southern Companies . . ." is available to Applicant. That transcript
'reference supports only the existence of such interties. The evi-dence was. uncontradicted that the Southern Companies have no firm I
power for sale. Tr. 538, 540; Applicant's Proposed Findings, para.
188, p. 94. Intervenors also state (p. 14) that "uranium fuel may well be as scarce as fossil fuel... in the coming decade." There is no support in the record for such a proposition. On the other hand, Intervenors'eference to Tr. 713 indicates that the Appli-'ant, analyzed "concerns" with respect to the supply of coal, oil and nuclear fuel, and that concerns with respect to nuclear fuel I
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are "considerably less" than with 'respect to coal or oil. And at the bottom of page 14 Intervenors make some calculations con-cerning the costs of delay as to which there is no record support.
In addition, those calculations omit elements of expense involved
'in delaying St. Lucie Unit 2 for one year, such as costs of alternative capacity and fuel costs. Such a delay may also jeopardize the reliability of the system. Tr. 579-581.
Intervenors'ssertion (p. 15), that the question of an LWA-1 is moot, is incorrect. Additional work which requires an LWA-1 has been requested by Applicant. Applicant's Proposed Findings, para. 268, pp. 135-136; see also Staff's Proposed Findings, paras. 194-197, pp. 88-89. Accordingly, the Board should make findings of fact and conclusions of law with respect to NEPA matters and site suitability. 10 CFR 5 50.10(e) (2) .
10 CFR 5 50.10(e) (3) (ii) provides that an LWA-2 may only be issued after the licensing board,-in addition to making the
'findings and determinations required by 10 CFR 5 50 .10(e) (2), has "determined that there are no unresolved safety issues relating to the additional activities that may be authorized pursuant to this para-graph that would constitute ood cause for withholds.ng authors.zatz.on . Emp asks added)
Intervenors point out (p. 15) that there exist unresolved safety issues with respect to some of the activities for which the Applicant seeks an LWA-2. However, Intervenors point to no such unresolved issue which "would constitute good cause for
withholding authorization." To be sure they characterize (p. 15) as "unresolved safety issues" undefined "problems" concerning meteorology, population, and evacuation in an emergency. However, they do not specify how these "problems" either constitute "good cause for withholding authorization" or even how, if at all, they relate "to the additional activities which may be authorized."
In addition, evacuation in an emergency is an issue covered by Contention 3.2 as to which Intervenors have defaulted. Their objections to the issuance of an LWA-2 are therefore wholly without merit.
For all of the foregoing reasons, Applicant requests the Board to reject all of "Intervenors Proposed Findings of Law. "
Respectfully submitted,'TEEL HECTOR 6 DAVIS Co-counsel for Applicant 14th Floor Southeast, First National Bank Building Miami, Florida 33131 LOWENSTEIN, NEWMAN, REIS 6 AXELRAD Co-counsel for Applicant 10 25 Connecticut Avenue, N.W.
Washington, D. C. 20036 By:
Harold F. Rezs Dated: December 27,'974
0 XTED STATES OF AMERICA ATOMIC ENERGY COMMISSXON BEFORE THE ATOMIC -SAFETY AND LICENSING BOARD In the Matter of FLORIDA POWER 6 LIGHT COMPANY Docket No. 50-389 (St. Lucie Plant, Unit No. 2 ERRATA TO "APPLICANT'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE FORM OF A PARTIAL INITIAL DECISION" Applicant requests that its proposed findings of fact and conclusions of law, filed in this proceeding on December 9, 1974, be corrected as follows:
PAGE LINE CHANGE TO 2 6 2560 2570 3 2 of second 'l Iy ' II II Iy ' II footnote 18 n218111 11228111 IL 21 "surge would" "surge plus wave runup would" 32 II (g) II 'll (f) ll 33 21 tl 1 511 "115" 53 20 "Fort Pierce." "Fort Pierce,"
n date II II da tall "Mr. Schmidt" "10,760" ll 8 69 311 67 16 67 16 Change cite "Schmidt, p. 3 as corrected to. read: at TR. 1092."
69 25 "frivilous" "frivolous" 77 24 11 does II 11 do s e II II dose 78 does 11
PAGE LINE CHANGE TO 80 3 li "App cant.
Bivans, pp. 2-9."
"Applicant. Testimony of Ernest L. Bivans Relating to Contention 1. 3, pp. 2-9, follows Tr. 383, herein-after "Bivans."
83 25 "associate with "associated with an" all 100 18 2111." 2111.
105 24 "decised" decided 108 "genetical" "genetically" 129 Strike the word "However" 132 II 488II II 'll 5 36 132 15 "App. Exh. 7, "SER, p ~ 20-1" Attachment A,
- p. 1, follows Tr. 530."
II 135 8 May II II June II 136 23 NLWA-1 nLWA ] II 138 21 II BLWA."
LAWA 142 "Indded" "Indeed" Respectfully submitted, STEEL HECTOR 6 DAVIS Co-counsel for Applicant 14th Floor Southeast First National Bank Building
. Miami, Florida 33131 LOWENSTEIN J NEWMANg RE S I St AXELRAD Co-counsel for Applicant 1025 Connecticut Avenue, N.W.
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Washington, D. C. 20036 By:
Harold F. Res.s Dated: December 27, 1974
CERTIFICATE OF SERVICE I hereby'ertify that copies of the foregoing "Reply of Applicant to Proposed Findings of Fact and Conclusions of Law" and "Errata to 'Applicant's Proposed Findings of Fact and Con-clusions of Law in the Form of a Partial Initial Decision' both dated December 27, 1974, have been served on the following by deposit in the United States mail, first class or air mail, this 27th day of December, 1974.
John B. Farmakides, .Esq. Mr. Angelo Giambusso Chairman, Atomic Safety Deputy Director for Reactor Licensing Board Panel Projects U. S. Atomic Energy Commission U.S. Atomic Energy Commission Washington, D. C. 20545 Washington, D. C. 20545 Michael Glaser, Esq. Alan S. Rosenthal, Esq.
Alternate Chairman Chairman, Atomic Safety 6 Atomic Safety 6 Licensing Licensing Appeal Panel Board Panel U.S. Atomic Energy Commission 1150 17th Street, N.W. Washington, D. C. 20545, Washington, D. C. 20036
- Perry B. Seiffert, Esq.
Dr. Marvin M. Mann Counsel for AEC Regulatory Staff Technical Advisor U.S. Atomic Energy Commission Atomic Safety 6 Licensing Washington, D. C. 20545 Board Panel U.S. Atomic Energy Commission Martin Harold, Hodder, Esq.
Washington, D. C. 20545 1130 NE. 86 Street
, Miami, Florida 33138 Dr. David L. Hetrick, Professor, Nuclear Engineering Norman A. Coll, Esq.
.University of Arizona Co-Counsel for Applicant Tucson, Arizona 85721 Steel, Hector 6 Davis 1400 Southeast First National Dr. Frank F. Hooper, Chairman Bank Bldg.
Resource Ecology Program Miami, Florida 33131 School of Natural Resources University of Michigan Local Public Document Room Ann Arbor, Michigan 48104 Indian River Junior College
\ Library Mr. C. R. Stephens, Supervisor 3209 Virginia Avenue Docketing and Service Section Ft. Pierce, Florida '33450 Office of the Secretary of the Commission U.S. Atomic Energy Commission Washington, D. C. 20545 LOWENSTEIN, NEWMAN, REIS 6 AXELRAD Co-Counsel for Applicant 1025 Connecticut. Avenue, N.W.
.Washington, D. C. 20036 By Harold F. Rezs
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