ML19029A493

List for Reasons Why Strongly Oppose Issuance of Operating License for Salem Unit 2

ML19029A493
Person / Time
Site:	Salem
Issue date:	01/18/1979
From:	Zitzer P Committee for Application of Nuremberg Principles to U.S. Nuclear Power Production
To:	Igne E Advisory Committee on Reactor Safeguards
References
Download: ML19029A493 (11)

Text

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CHAIRMAN Bill Garner, Esq.

Scottsboro, AL 1( (~/P{Y 12 ,

MEMBERS Mr. Elipidio G. I~ne Dr. John W. Gofman San Francisco, CA A1visory Committee on 2eqctor Nuclear Re~ 1.ll11::0:-y Cor:iriission Dr. Chauncey Kepford State College, PA Wqshin~ton, D.C. 20555 Dr. Bruce von Zellen DeKalb, IL Re; Operatin;;:i; License Heg.rinc; for Snlem lL'.i~, :2 Dr. Judith Johnsurd State College, PA Jg,n. 24, 1979 Sidney J. Goodman, PE h:un.mus, NJ De~ r :vI r . I gne :

Helen Mills Atlanta, GA Marilyn Shineflug We strorn~ly oppose the issuance of ~:i.r.. oper""..tin::~ License DeKalb, IL for s~leo lni~ 2 for the followin~ re~s8ns:

Larry Bogart Allendale, NJ

1) We are in 3..greement with Dr. KP-pford' s sta.t<'rn<:L to Virginia Southard Harrisburg, PA Dr. Greenwoccl, Office of Science & Techric,10.'>;~' FnliGy, Anna Mayo Executive Off' ice of Lhe President.- 11 *rhe r<J.5i*::::.~:;i.:* :;wr)c.1~:-*:;1 i~;

New York, NY a oroduction problem. Hu.man action alone oro(L1<c1:>d Phillis Zitzer Salford, PA r"l.Clioactive waste; h1:mp,n qc~;ion. 8.lone C.<U1. hqL~ t:he prc-d.('+-i("\n Qt~... '-h-""S8

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2) 'I1he ap!Jlic::-,nt hqs !:! lreqdy re -~ues ~.ed. pernii s s ion f o:r t n-creqsed spent nucle!l.r f*ipl rod "';tor*'-<e on :.:-1e ::>1lem site. Hope c.reek I -,n'.1 II '-*.re on Lhe s--~mc: si*>..

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, * .l .n>>L '- ** e J) The inability to dL~*:!or.:e of exis**.ing W"l.s*1:::-;s, *;o-~  ;:-:vid<:'~1'.**cl in the recent I.R.G. reporc:, m<;.ke~3 it imp"'r~i.'* i..v~.., t.h:-:i~ '.*;e' "limit th'~ problem" ncvJ' by fo:*,*:*,:Ging t,hc f 1r'.l1er u::e cf' 0 nuclear reactors i.mt il =-tni4 unln;:_:s p::-:rr1'1.-:!e::.Tt: **r*,_~-'-:.e 'iir~

pos:~ l fnr ~,hf' f*:ll ~Y:rio<:'l of t.oxi*~i.'.y h:.:is b:*en :le:non-sr~r:=tted t(~ "1:0rk.

4) Le:::::L-,lqtion introc1Hc:ed on J:::ri.. 16,19?9 by U-,*'w Jc:;r~:;:::y ler~isl 01 t:ors wo:~ld. pr::vent :::1.ny n~~cl.:;r;r J.1l**1n'.~ YL)t y:-t operati:1f:r, from startin~.:r, up un*:.il '.~he n:..1Gle=n* \\i'J.ste dispos':;,l proble:n is solved. *i'nis bill wo-~ld <i1'fect SP..lem 2 :::i.nd Hooe Cr":°~k 1 *:ind 2 ( see enclo~;c::.i s2~*-.j_cl**)

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5) There is =1n unu 8 ;J.n.l concentra-::ion of nucleqr po.'h:r pL;n s in this are*i. und.c<' various stqges of con~3trucr.i:Jr~ a.nd.

oper:lti~Yt: ( .See enc2-osei m;:i.p). ,_

6) Pe""l.ch Bottor:i, O!:tly J_5 niles from Ar*ti.fici:*=~l I~:;l*1!1d (:::.*, -*<!)

recer.~:lv re,,.~ived DH'mission to incre::.~se the :-:;rn:'nt f:;e

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7) See enclosed Inclivid' 1* 01l SiLe R'3.ting for Fo?.ch Bo :.or-,

Docket 50-277 Aoril 1978: 11 Leas;*. ss.f~:: si~;2 ii1 l'..::~<ic-r~ L Poorest Mqnqgem~nt" *

8) See enclosed Ind.ivid:_u1l Site !t::-i.tin::r, for- S:::_lem I, ~)ock~:~~ ')'J-272 Anril, 1978 11 The plant con",rol room W'~.s :.i.c::si".necl in-house- it is a disaster wait in,-~ to h.apDen. u

9) The excess ~enerating cqpacity of each of the join~ own0~s of Sr.:i.lem 2 is approachin:J," .50;-b. rrhereis no need ;~or; power.

10) fiqdon releases and associated he8 l th effects resu l ':, ing-frorn the onera~ion of S~lem 2 must be considered in terMs of the cosi benefit bal~nce. Docket 50-354 & 355 "Licensees' Answer to ~otion to Consolidate Proce*'lin~s to receive new evidPnce with regard to rqdon rele~ses qnd associated health effects". ~3Y 9, 1978:

It must be remembered th~1t , at least fer *t:he 11 Hope C ref-~k and Pe!:>,ch Bot tom proceedings, ~hr; Ape:e,11 Boar:1s have alre~dy cor.sidered. the :r1estion of whether the cost-:Je!1efit baLince for the f::lCility or unit in question tips or might tip in f~vor of

• a.bA.ndonment of ;;he fn.cility, in lic;h'..: of the in:c'r*im f'lel cycle. 11 In view of the above, it. is evid2nt th.'°!t public senti1:ient runs counter to further lic'.:*msing of rvcl~ar power pl!:m-:s.

Cre11.tion of more w,g,ste is mor.~1lly indefensible. Invol1.rn.t,:i.ry exposure to dqma&?;in;sr:-i.diqtion is in viol:ition of civil rir;ht-.~3, cqusin~ he~lth effects (deaths) to ~he ~eneral populqtion, as thoro1w;hly exposed in the Honicker vs. H8ndrie Pet i +-, i.on.

We see no re::i.:3on why she le,*,nl principles of individ1.l:1l rP-spons ibili ty establL~hecl at*. the .Nurembnrg t ri:.=1.ls sho*i lc1 not also auply to che Officiqls of :he U.S.Govern~Ant who betrq,y ~hP. public trust -:i.nd sqf~ty.

S incerely _

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Phyllis Zitzer Box 207 Salford, Pa. 18957 cc: Commissioners 215..:.287-7459 nenctrie Kennedy Bradford Gilinski Ahearn

Committee for Application of Nuremberg Principles to U.S. Nuclear Power Production Route 4, Box 332 ~ Scottsboro, Alabama 35768

• Telephone 2 CHAIRMAN Bill Garner, Esq.

Scottsboro, AL MEMBERS Dr. John W. Gofman San Francisco. CA 9r. Ted Greenwood Dr. Chauncey Kepford Office of Science and Technology Policy State College, PA Dr. Bruce von Zellen Executive Office of the President DeKalb, IL Washington, D.C. 20500 Dr. Judith Johnsurd State College, PA Sidney J. Goodman, PE

Dear Dr. Greemroorl,

Helen Mills Atlanta, GA This letter contains a very brief s~... mmary of my Marilyn Shineflug DeKalb. IL comments, observations, and opinions concerning the "Subg"*;up Larry Bogart Reoort on Alternative Strate~ies for the Isolation of Nuclear Allendale, NJ Wastes,"* TID-28818. 'I'he reasons for this brief su.mmg.ry ~r*~:

Virginia Southard due to the distressingly short col71:nent period, the shortei*

Harrisburg, PA period yet during which the Subgroup ~eport wqs ~vall~0:e, Anna Mayo New York. NY and the volume of my notes on the report. These notes ~ilL Phillis Zitzer be digested, transcribed, g_nd foreward.ed as soon as is Salford, PA possible.

Contrary to the assertion of the authors of the .Su"b.~;1'C)t1p Report (page 16, first f 1J_ll se~1'.,ence), I sub:,1it th::it t11:~:1an action alone will be the deter~inin~ factor with reg~rd t0 the fate of radionuclides in any repository or other :lump site. After qll, human action c~eated the wastes, qnd has ~:

delayed for years the need for a solution to the problex.

Human action alone now has crear~ed a climate of rnsh to d i.s-pose of them. Human action alone will determine t~e tim~,

place, medium, depth, method, pnck~ging, and snon, of r~dio active waste disposal. It must also be realized thRt it will also be human action alone which will lead to cost-saving erosions of mar~ins of safety for whatever repcsitory is chosen. Human action alone can cause the effectiveness of any or all of the barriers between any dispose*-J.-or ra11.was :.~:;

and the biosohere to be oartiallv or f~llv defeated. All uf the grandiose plans, prorni ses of" "tech:.-1ol;gical sncces s" ( :). *;.?) ,

"proc.:r"lmma~ic success" ( p. !.J.4), reliance on 11 r*ec**-:tln.tory r~.'-

• qnirements" (p. 45), and imitation information (popularly referred to as nur.ibers dt;ri ved from risk asses srn.ent) in tr18 end are self-deluding and self-d.efeating. In addition, snch management schenes are bu.t cor:i.pc*nents of a vie ious shel l-::ar:1:,)

designed to irnep atten':.ion from bein,;r oaid to ~-he onlv

• rele~ant question, the question of d;r~tional success~ can a repository be prepared ~o contai~ all radwastes nlqced in it for the d"clration of the toxic oeriod of the w~sLes? l r. st*~<~::is anpropri::i.te ~o :remind ~he ::i. 1.tthors of the Su.br_;roup Report of the old hosp1 tql joke: l;he operation wA.s a S'.tccess, but the

Committee for Application of Nuremberg Principles to U.S. Nuclear Power Production Route 4, Box 332

• Scottsboro, Alabama 35768 *Telephone 205/259-5770

et*re.'-t"S Virginia Southard Harrisburg, PA from safety - and credibility - that so thoro1..u~hly per:neates Anna Mayo this report. This attitude goes a long way toward v1ar~nt0Pin~ New York, NY the report of the stupid bureaucratic blund~::rs that ca.used Phillis Zitzer the irradiation of the entire world 1 s population throu<h bomb Salford, PA testin~, with the subsequent tragedies: the uranium Miner~ deaths d11e to lung cancer, the enhanced ca~cer rates ~trnOYl?' bomb blast observers (like Smokey), ani others. ?olic.v must not be allowed to be a substit'Jte for safet~y 'l.nd th~: duratlonal stlccess of arty radwaste repository, be it high-or low-level, TRU waste, or mill tailings. I urgently request that you inform whoever it is ir:. this government that the public that was so easily (anti r*0~17:irn-o1.y) hoodwinked and lied to in the past by the apolo:r;ist~:; for Lfie nuclear industry has changed. *rhe public is increasin~l;y -::irH1 rapidly becor:iing aware of the n:iture of the ra1.w:1.flte orobL;:-r: and the cause of the problem: the rq.dwaste problem i~> a production problem. Human action alone prod~1ces radicni.ct i ve waste; human ~8tion alone can halt the production of these wastes, l see* no reason why the legal principles of indi v:Li-ual res pons ibili ty es.:tablished at the Nurei!lburg trials sfwuld not also apply to the officials of the D.S. Government who. betray the public trust and safety. Yours sincerely, Dr. Ch::umcey Kenfor.:1 4J3 Orlando AvP: State Cclle~e, Pn. 1 6t~01 .I ' Addend.um to Individual Site Ratings from the IE Employee survay on Evaluation of Licensees - April 1978 Docket No.: 50-272 Site: Salem Answers to Question 17 (If a change to safety level occurred, please describe it briefly): Relatively new plant. Still *has growing pains. Needs close attention (by IE) to assure appropriate improvements are made. Power ascension testing revealed problems that were corrected by management, both in hardware and procedures. Answers to *Question 18 (Are there other things we should consider about the safety of this plant?): / The plant control room was designed in-house - it is a disaster waiting to happen .

• --- J d In startup phase. Have had a number of problems. This can be due either to poor system or poor management or the 11 normal 11 failures when new systems are placed into service.

Design of controls with back-lighted pushbottons results in operator data assessment problems, especially when lights are burned out. Manage-ment is aware of problem and IE is following up. ,.Ji New plant - recently completed full power testing* - plant still in *early _.._., operating phases. ~ ~ .ATLANTIC CITY 1 &: 2 ' Sea.f'ord e Operating eLaurel ~ H8R~truction ~ Proposed The hazards of nuclear power The CPt1IC1r fo1 *Scienct1 in rile Put1lil lf1rt*t1*::r I!' ,j 11onprol1(, (;l\-t'\t*n1pt ft'~(:a,1r.;/1 Otf1~u11::11io1i tl1i1l has ht*t?rr WLl!J..iny ILu 01t .. 11.i:.:.t six ye.us u1 .11t.'.1.:' vt t'l1t'qw policy. t!llV1'UW11Cll/,"J/ p1otr.c!im1. dl1lf \!,11iu11s COfl';1111rr~r COflCf'rtl~. i..~St*N ~1~J..od ,Keo 00~0119. w/10 works 011 CSPl's project on erWl!IY* ro s11111m:111~" ll1t1 arg;1111.t,11ion's views 011 nuclear power. Hew is w/l.il Ile wrote. The vocal and increasingly active opponents of tbe nation's atomic energy programs in-variably base their opposition on the potential dangers inherent in the generation of power from nuclear fuels. Are lhey hypothesizing problems that are of lhe one-in-a-million-chance variety? Are !heir concerns more fantasy than fact? A review of the safety record of domestic nuclear facilities during the past three decades reveals a history of worker deaths. plant accidents. acts of terrorism. and other incredible mishaps. In fact almost every "one-in-a-million" occurrence has already occurred as well as a number of incidents whose probability was considered so statistically minute as to not be worth evaluating. Whereas federal and industrial spokespersons have extolled the safety record of nuclear power. studies issued-but kept unpublicized-by the old Atomic Energy Commission. the Nuclear Regulatory Commission. and other agencies document a far different story. They report that in the previous 33 years. there have been over 10,000 disabling work injuries at domestic nuclear facilities including more than 300 fatalities. Hundreds of other workers are expected to die of radiation-induced cancers by 1990. In lhe past seven years. there have been 150 instances of threats *against nuclear instal-lations across the U.S. These have included three cases in which bombs were successfully planted on facility sites and several instances of arson in which major fire damage resulted. On the average. NRC loses (or has had stolen) as much as 100 lb of uranium and 60 lb of plutonium every year-enough to make more than 10 atomic bombs. "Acts of God" also have taken their toll. Lightning and cold weather have disabled plant safety/security systems. Gale force winds damaged AEC's Amarillo. Tex .. facility in 1967. A tornado passed through the site of a proposed plant in Dixon Springs. Tenn .. and another came within 10 miles of an operating reactor in Athens. Ala. Several reactors are built near or astride geological faults either known to be or suspected of being still active, including several that have experienced quakes this century. On at least two occasions. 8-52 bombers have crashed within sight of nuclear facilities. The power level of fissile systems has become uncontrollable on 26 occasions in the past three decades: that is. nuclear accidents either occurred or were just avoided. These include a core meltdown al the first experimental breeder reactor in 195 5 as well as a partial fuel meltdown of the Fermi I breeder near Detroit in 1966. The well-publicized 1975 Brown's Ferry fire started with a worker carelessly using a candle to lest for air leaks; ii ended with most of the plant's safety sy~tems rendered inoperable and more than $50 million in damages. Thus. while nuclear supporters have glorified their industry in terms that have bordered on outright fabrication. serious mishaps have been occurring with frightening regularity. There are alternatives. however. to continued exposure lo such hazards. Nuclear power presently constitutes only 3 % of total domestic energy consumption. That is a contribution to the nation's energy budget which could be easily eliminated through simple conservation strategies or through the implementation of presently available and cost-competitive solar technologies. Moreover. numerous studies issued by the Energy ResP.arch & Development Administration and the Federal Energy Administration confirm that ru:ure energy needs that would otherwise be met with nuclear power can also be satisifed with conservation, solar and wind technologies. For these reasons. the U S. st1ould immedi;:ilely declare a moratorium on new reactor construction and begin a phaseout of all existing nuclear programs other than perhaps some research efforts Our experience with nuclear facilities has alre;idy proven the truth of Murphy's Law: *

• 1f anything can possibly go wrong. it will": lurther test data are not needed. D 1

One of a series of editorials on nucJ ear power in °Chem.ic2~ .<ind Engineering News". Renrinted by permis3i0n of the 9!lbl ishers. 'The purpose of the £.QALITION FOR rlUCLE.~.!\ PO'.*:>C:t PCSTE'ONE!*n::N? is ~o postpone the construction cif nucJ e<-.r taciJ.iU.es in ~elaware until satisfactory a.'1sNers have been pr'Jvided to a nlL'l1ber af questi::ms, including:

1. Will radioactive material escape?

2. Has a solution been demonstr?.ted for disposal of radioactive ***aste?

3. Has full insur;uice protection been provided?

4. Is there an adequa.t~ eva.cuation pl?~ in case of qccident?

5. Are there adequate safeguards against theft and se.botage?

To accomplish this purpose, the COALITION focuses public attention on the dangers of nuclear technology, informs the pub!.ic as to the availability of clean, safe and economic11l energy ?.lternatives, and takes non-violent, direct action to oppose policies which .ieope.rdize the heal th and safety of the entire hu.'l'lan race. JOIN US IF YOU AGREE WITH OUR AIMS: CN'PP 810 West 25th St. Wilmington, DE 19802 Phone 652-2456 Addendu~o I:ndi vidue.l Site - Ratings from the IE Employee survay on Evaluation of Licensees - April 1978 Docket No.: 50-277 Site: Peach Bottom Answers to Question 17 (If a change to safety level occurred, please describe it briefly): / Plant radiation levels have been increasing with time. Design and '1 staffing of plant appear to have not been capable of handling this '-1/ change. Management has been slow to take large step changes to correct problems. Back to back overhaul/upkeep periods for units 2 & 3 appear to have produced a tired operating group prone to error. Careless operations and poor maintenance. Corrective action taken to repair core spray line cracks, feedwater spargers and nozzles and control rod drive return nozzle. Licensee made significant effort ta reduce routine radioactive release from reactor building vents through equipment repairs. Answers to Question 18 (Are there other things we should consider about the safety of this plant?):

• -\

See question 69 and 28. L.. QA program not upgraded to current standards. Security not upgraded. ~Many repeat items of noncompliance. Least safe site in Region Z! "q Poorest management! --_-_-____ r---- "<::- ~- Quality of people (i.e., technical educational level) that are operating a plant and the type of organizational structure they are placed in can have a significant impact on safety. Higher number of inspections due to proximity to regional office. Recent management meeting with the President - expect to determine by scheduled inspections in the next 30 days if significant improvements were made. Plant management exhibits an appearance of attempting to control N~C 11 11 inspector access thru continual escort - general attitude appears to be one of compliance as required instead of an aggressive prosecution of management controls. The problem with this plant is that it is a big BWR - by definition, they will have problems unless they have a good op. staff. PB does ... Upgrading of requirements upon this licensee, particularly in cases of security and QA. 1~ , i ,! I l/ ...

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By.:DAV:JD Al,TANER . -~Salem*I, *a1r~~_i~.OP..e._~~-li9~,-.... .. bill through legislature in time to stop , _;:, ** *. .Sunbeam Staff. . . . .* rn~ b114~fi5onsored by Assemblyman

• lhe commercial operation of Salem II

, SALEM ~tA. bill introduced Yesterday_ D?nald Stewart <D-3) and Donald scheduled for a mid-summer start-up:

Jn 1he

• Assi!ffi'bzywould prevent i anv -. D1Fra~c,e:>co (~-22), would. not allo.w He added that he thought the bill had a

.'"itlJCTear plant nol vel o~rating_fn>.!.!J.__::' N.J. ut1l:hes to mclude costs m~urred m good chance of stopping the construction

• ~*artmg up untii the nuclear waste the mamtenance and operation of a of Hope Creek I and II, if the govern:-*--*

01sposal. problem'. is $olved... ... nuclear plant in their base utility rates. men! fails to solve the waste problem.

This

• 0111 woUid =@el!!ar@iiiY affect Stewart said yesterday that the bill's* The bill's intention is not to slop rbe

~Jem II ~nd. Ho~ S:ree!t Liind It-~ . :sponsors would be aiming to push the .* ....___ ,.. - growth of nuclear power, Stewart said, -~=--=-'-----"-*** bu1 lo forc:e lhe federal government to solve U:ie*prohlem of ~rmanem storage. o{ sperff fuel rods and'other rad!Oactive waste products. "We're not saying 'we want this; we want Iha~,* all we're saying is that somebody better come up with something,'.'. Stewart said. Slewart added that he wanted to prevent South Jersey from becoming the "nuclear dumping ground of *the nalion." Nuclear waste disposal js a con-troversial issue almost everywhere I here are nuclear plants. Several slates

• • sa-lem II have passed legislation forbidding disposal on their land, and public. firms hav~ not been able Lo reprocess the spent fuel ever since President Carter

• (Continued from page 1) pul a moratorium on reprocessing probably speeded up work on this bill, shortly after taking office.

SI ewart said, but it had been in the

• Stewart said he believed the solution works long before last week .. 10 n_uclear waste was technologically But Stewart said he thought this bill feasible, and he hoped that the bill would would inciir':?ct.!y help LA.C's ;;ffort to make federal officials "put their money keep ils money, by educating the where !heir mouth is."

legislators on hazards that go with its "I expect il to get the government millions. moving," Stewart said. "I think when we talk about this, 75

• Stewart said he thought that "North percent of the legislators don't know Jersey media" would say that this bill what we're talking about," Stewart said. came as a direct result of Governor "This will help the. legislators realize Brendan Bryne's State of the Slate there are two sides lo the story." message, in which he singled out Lower Public Service Electric and Gas Alloways Creek's multi-million dollar spokesman Edward Anderson said the gross receipts revenues as funds that utility did not want to comment on the should be used for urban a id.

bill at such . an early stage of its The governor's remarks last week development. * <Continuea on .Page 3) But speaking generally, he warned I hat any delay in the start-up of Salem II would cost consumers millions of dollars; ' UNITED STATES OF AHERIC..:.\ NUCLEAR REGULATORY co~~1ISSIO~ In the Natter of ) ) PUBLIC SERVICE ELECTRIC AND ) Docket No.(s) 50-272 GAS COMP A.t.'lY ) ) (Salem Nuclear Generating Station,) Unit l} ) ) ) CERTIFICATE OF SERVICE . 4 hereby certify that I have this day served the foregoing document(s) upon each person designated on the official service list co~piled by the Office of the Secretary of the Co"Grrnission in this proceading in accordance with the requirements of Section 2.712 of 10_ CFR Part 2 - Rule~ of Practice, of the Nuclear Regulatory Commission's Rules and Regulations. day. of r Dated at Washington, D.C. this ffe . c//JJ q 197-1-. Secretary of the UNITED STATES OF AMERICA NUCLEAR REGUL.\TORY COHMISSION In the Matter of ) ) PUBLIC SERVICE ELECTRIC AND GAS ) Docket No.(s) 50-272 CO:MPANY ) ) (Salem Nuclear Generating Station; ) Unit 1) ) ) SERVICE LIST Gary L. Milhollin, Esq. William C. Horner, Esq. 1815 Jefferson Street 67 Market Street Madison, Wisconsin 53711 Salem, New Jersey 08079 Mr. Glenn 0. Bright R. William Potter, Esq. Atomic Stafety and Licensing Board Assistant Deputy Public Advocate U.S. Nuclear Regulatory Commission Department of the Public Advocate Washington, D.C. 20555 P.O. Box 141 Trenton,. New Jersey 08601 Dr.* James* C. Lamb, III. 313 Woodhaven Road Mr. Alfred C. Coleman, Jr. Chapel Hill~ North Carolina 27514 Ms. Eleanor G. Coleman 35 "K" Drive Counsel for NRC Staff Pennsville, New Jersey 08070 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 *Ms. Ruth Fisher "The Sun People" Troy B.. Conner, Jr. , Esq. Alternate Energy Advocates Conner, Moore and Corber South Dertnis, New Jersey 08245

• 1747 Pennsylvania Avenue, N.W. June D. ~1acArtor, Esq.

Washington, D.C. 20006 Deputy Attorney General P.O. Box 1401 Dover, Delaware 19901 Richard M. Hluchan, ~sq. 8.6 West Street Richard Fryling, Jr., Esq. Trent_~~' New Jersey 08625 Public Service Electric and Gas Company C:i.r.l Valore~ JR.~ Esa.. 80 Park Place Valore, McAllister, Aron and Newark, New Jersey 07101 Westmoreland, P.A. 535 Tilton Road Northfield, New Jersey 08225