ML19206A150
| ML19206A150 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/08/1978 |
| From: | Kepford C CITIZENS FOR SAFE ENVIRONMENT |
| To: | |
| References | |
| NUDOCS 7904180331 | |
| Download: ML19206A150 (11) | |
Text
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9 V
4 UNITED STA*ES OF AMERICA fog y
gC) 7 "'C NUCLEAR REGULATCRY COMMISSICN M
Before the Nuclear Reeulatory Commission hA m-zie n In the Matter of
)
METROPOLITAN EDISON COMPANT, Dockst No. 50-32 et a1.
3 (Three Mile Island Nuclear
)
Generating Station, Unit 2)
)
IN SRVE' TORS' APPEAL TO *EE COMMISSION OF A STAT CF THE INITIAL DECISION Under the authority of Part 2.783 of the Commission 's Rules, the Intervenors ' request tha t the Commission issue a atay of the Initial Decision (ID) of Dec 19, 1977, in this proceeding.
This action is requested because the ID inaued by the Licensing Board contains numerous flagrant violations of the Administrative Procedure Act of 1946 ( APA), the Atomic Energy Act of 1954, as amended, ( AEA), the National Environmental Policy Act of 1969, (NETA), the Energy Reorganization Act of 1974 (ERA), and the Con:siasion's Rules.
This action is requested of the Commission because an appeal for a stay made to the Atomic Safety and Licensing Appeal Board ( AB)(Dec. 29, 1977, and Supplemental Memorandum, Jan. 13, 1978) was rejected with little indication that the AB either read or underatood the filings or was aware of the requirements of the APA, 5 U.S.C. 557(c) or its other statutory responsibilities reaching its decision of Jan. 27, 3 978, ( ALAB 456).
This appeal will by the limitations of space be a very conde taed version of the Intervenors' Brief of Jan. 30, 1978, and will discuss the criteria of 10 CTR 2.788(e) in order.
1 The analysis upon which the Licensing Board and the Staff relied fraudu-lently concealed vital information and required that the 3 card and Staff turn their backs on the laws of both physica and man, as shown below.
The Staff additionally must disregard the statements of the Jts ff'e own Witness, Dr. Gotchy, -
who wholly and completely corrobora ted the basic thrust of the testimony of Intervenors' Witnesa Kepford.
~he subject here was the quantity of raden-222 released to the environment from abandoned mill tailings piles of one year's operation of "MI-2.
Kopford had shown tha t there were three separate sources or raden-222, each producing enormous cuantities of raden (Kepford testimony,
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Table 2).
The thorium-230 initially present in the tailings piles would pro-duce about 320 million curisa,while the small amount of utrecovered uranium-238 would produce about 2 trillion curies, and the depleted uranium-238, about 13 trillion curiet.
The environmental impacts of these emisaicus have never been 49"~"6 79 OVIS 033 I
acknowledged by the Staff, let elene cocaidered and evaluated.
It should be noted, however, that when Staff Witneca Gotchy vaa recalled to the witness stand by the Staff to rebut Kopford's testimrav, he acknowledged that he could not argue with the numberKeptord had produced (tt, 7.890).
The end result has been tha t the S.af f and Licensing Board relied on an inadeouste survey of the health effects of the uranium fuel cycle,
a seriously defective coat-benefit analysis for TMI-2, and an ecually defective analysis of alternatives to the opera tion of TMI-2.
The ID is not aupoorted in the evidentiary record by reasoned judgmenta, full disclosure of environmental damage, or evaluations of environmental damage "to the fullest extent possible,"
in violation of the AFA, AEA, and NEPA, and the Commission's own Rules 2.760(c).
Instead, the Staff Licensing Board andAppeal Board relied on the dia-credited Table S-3 of 10 CTR 51. 20(e) to exclude from consideration b.v far the largest sources of radioactive emissions from the entire ura.i1um fuel cycle--
the abandoned =111 tailinga piles.
The Staff " Appendix" of Jan. 20, 1978, stateo clearly that all emissions from the abandoned piles are not included in Tsble S-3 (Lowenberg Affadavit, page 14).
Neither the Staff ner the Co= mission itself has the sta tutory authority to use tue Commission's Rules to conceal important environmental information.
NEFA specifically prohibits ad=inistrative regulations which prevent " full compliance with NEPA." (NEPA, Sec. 103).
Any further rei.*,ance on the 74.5 curies of redon-222 number in Table S-3, is knowing exclusion of the appropriate numbers, billions of times larger, (Keptord testimony, Table 2) is nothing short of fraudulent.
(One must wonder just how many licenses have been issued by the Commission, with full knowledge of the glaring dishonesty in Table S-3).
In dismissing Kepford's testimony in the ID, the Board re21ed totally on saaertions that the redon-222 releases attributable to te operation of TMI-2 would be small compared to background rolesses of raden-222 (ID, para. 225) and the number of deaths caused by tne operation of TMI-2 would be ama'll com-pared to the people who would die from all other causes la the same, time period.
(ID para. 12 5 ).
The Staff, Applicant Licensing Board and Appeal Boards, nave all failed to shoulder the " burden of proof" (10 CFR 2.732), articulate the relevance of these two arguments (In contraat, see tr. 2863, 2865, 2869, 2875).
The Intervenora have, however, shown these arguments to be wholly without merit.
4W 1.u?
e Since the health effecta of alternative fuel cycles are bein co= pared, any cause of any health ef fect which operates equally upon all optione does not affect the com erison.
Thus, the level of background releases of redon-2'2, the number of people dying from natural causes over any tima apan, or the deatna duo to bites by poisonous insecta and reptiler:, play no part in the comesrs tive a na lysis.
Furthermore, NEPA colla for an analysis of the project itself, not in comparison with any non-related subjecte.
The woefully inadequate nature of Table 3-3 was further illumincted by a memorandum of Dr. Walter Jordan of the ASL3, (dated Sept. 21,197*/) which dia-cuased only the thorium-230 contribution to redon-222 emissions.
He found Table S-3 in error by a factor of 100,000, and an error of the same magnitude in the population exposure of 100 person-res listed therein.
The Staff "Appendiz" of Jan. 20, 1973, added further evidence against the 74.5 curie number of Table S-3.
Here it is shown that thia 74.5 curies number reflects the redon 222 emissions during active mill operations, and ex-cludes all contributions from the abandoned mill tailings piles (Lewenberg Af-fadavit, para. 14).
The Staff has yet to discuss justification of in-luding in Table S-3 thia 74.5 curie number, while excluding the annual emissions of 110 curies of radon-222 from the abandoned tailings piles which go on for billions of years (Magno Affadsvit, para. 9).
The Staff " solution" to the problem of redon-222 is nothing more than a abort term egydient, since the solution is desirned to fail well before 10C0 years expires, less than one-eightieth of the first half-life of thorium-230 (Gotchy Affadavit, page 4).
The Staff still conceals the overwhelming quantity of redon-222 to be relsaeed to the environment as a result of just one year's operattr of TMI-2, in defiance of the AEA and NEPA.
The Gotchy testimony was entered into the proceeding as a supplement to the FSTES (tr. 2097).
This testimony was offered to Federal agencies for co= ent on Sept. 29, 1977, and a revised version of the testimony reflecting agency and public comments has yet to be issued.
Th e ID was issued in advance of the completion of this portion of the FSTES, in violation of NEFt.
The mere promise of the Commission to consider on a generic basis the mill tailings problem a t some future date (41 Fed. Reg. L2430-1, 42 Fed. Reg.
13874-5) does not allow the Staff, Board or Appeal Board to shirk their respec-tive duties under NEPA and refuse to censider the factual nature of the radon-222 a=iasionn in this proceeding.
None of the advocates of this " major Federal action" ina yet to show that a complete and " full NEPA review" is not reouired prior to this licensing action.
T "'." S
4 This plant cannot be legally licensed until the Staff and Licensing Board have fully considered the entire radon-222 problem.
By definine 74.5 curies sa the only quatity of raden-222 to be discussed in reactor licensings as the Apped Board would dictate in ALAB 456, the Commission conceala trillions of curies of redon-222 and fraudulently denies the existence of the radon by ignoring the laws of physica governing radioactive decay.
Neither the Staff, Licensing Board, or Ippeal Board have any authority under any statute to withhold or refusa to consider auch informa tion, to commit fraud on a continuing baaia, or to repeal the laws of physica.
No attempt was made by the Intervenora to invoke Sec. 2.758(b) of the Commission's Rules since this rule only applies to unique circumstances.
Further-more, in the short time between the submission of the Gotchy testimony by the Staff and the commencement of creaa-examina tica (May 21, 1977 and June 7, 1977, respectively) the Intervenors were too deprived of the necessary time, energy, manpower,and money, for yet another unnecessary filing.
As a result, crosa-examination proceeded on the supposed "ferbidden" subject, as described above.
It should also be reitterated that the Consiasion has ne legal authority to de-ceive and perpetuate fraud upon the Intervenors and the public or to prevent legitimate inquiry into the baaia, if any, of licensing actions.
TMI-2 cannot be legally licensed to oterate until the environmental impact of the largest single quantity of radioactive emissions in the entire fuel cycle, redon-222 has been discussed honestly and openly, to the fullest extent possible.
in an environmental impset statement.
To da te, no adecua te environmen tal impac t statement has ever been filed covering the long-term emissions from the abandoned mill tailings piles.
Under the authority of 10 CTR 50, Appendix 0, the Board is required to conduct a " full NEPA review" (ID, paraa.80-130).
The Board's review, if indeed it ever took place, it nothing but an unques tioning rubber-stamp approval of any Staf f and Applican t filings.
The Board chose to ignore new information on the enhanced ef fectiveneas of low-level radia tion in causing cancer ( tr. 253-63, 2331-9), reactor decommissioning (tr. 263, 2390-97) (See also Answers of eter N. Skinner to Surrested Ouestions of Pull Farticirants on Behalf of the Stite of New York, Docke t No. FM-50-3, Dec. 2, 1977,
- p. 21-27 ), the ulti=a te dierosal of the depleted uranium-238 generated to f uel TMI-2 (Xeptord tes timony, page 3), and the issues put before th e Board by, among others, Mr. Larry Arnold and Dr. Carl Jarboe.
This is not an ernaustive list; it la a representative list of issues the feard failed to consider in its supposed and nonaxistent " full NE7A review".
D ~ I.bb
s The Co nission practice of denying funding to Interrenora creates an extraordisa ry imbalano ; anong the :artise with regard to the ability of the various parties to protect th eir righ ts.
This practic e of denying the Inter-venora the right and ability to present a direct case further subsidizes the Applicant since it esses the Applicant's burden of esse perparation and removes illegally from the Applicant the burden of proof.
This is particularly impor-ttat when a subject like the airplane crash issue arises.
Here the Applicant stated it would take months of highly technical work to establish whether or not TMI-2 could withstand the crash of a larger than design-basis aircraf t (tr. 615, 640-1). With less than $500 to cover all expenses for this entire proceeding, the Intervenors were precluded from obtai=ing the kind of expert technical aasia-tance needed to fully rebut even the testimony tha t was of fered by the Staff and Applicant.
Furthermore, the ID and ALA3 456 do not =eet the requirements of the APA and tue AEA, Sec. 181.
The Intervenors have a rignt to know why these extensive findings were rejected, since the ATA requires that a reasoned and articula ted justification of agency decisions "shall show the ruling on each finding, con-clusion, or exception presen ted" (5 U.S.C. 557(e)).
In this proceeding, the
' Intervenors filed on Aug. 15, 1977, Findings of Fact and Conclusions of Law covering 109 pointa of fact and law.
The ID contained reference to only 2 2 ALAB 456 is equally deficient.
This Commission practice of issuing ridiculously incomplete and illegal decisions has the effect of shif ting the burden of going forward upon the Intervenors, since the Intervenors must then act promptly, yet in the dark, to prevent an illegal decision from becoming effective, as in the present case.
This practice is beyond the statutory authority of the Consimaion under the A?.s., AZA, ERA, and NEPA.
This practice is particularly repugnant in this proceediag, since ene of the reasons the Intervenors are deeply in debt is because of previous involvement with the Commission regarding tne laauesof Intervenor financing and the burden of proof.
See York Committee for a Safe Environ =ent v. USNRC at n.13 (D.C.
Cir., 1975 7( tr. 247-5I).
Contention 5 of the Intervenors' Fetition alleged tha t the esfety-related structures of TMI-2 are of insufficient str-ngth to withstand the impact of aircraft above 200,000 lbs.
All parties conceded that this statement was a statenent of fact (ID, para. 40).
Further, none of the parties refuted the
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concern of the Intervenora that such an i= pact sight lead to radiological con-sequences greater than the admittedly unacceptable levels of 10 CT2 Part 100, 48-l200
6 The aircraf t crash into a nuclear rower plant, as TMI-2, crastes a spectre unlike any other externally propagated hazard, with the possible ex-ception of earthquakes.
The problem here resta solely with the ability, or inability, of the safety-related structures to withstand aircraf t crashes.
The record remains totally void of any information on the nature or decree of any subsequent failures of the plant safety boundarica and the consequences of such failures.
Thus, the point nade by Staff Witness Read, "Teu never accept the probability if the consequences are too high." (tr. 709-10) fell on deaf ears.
In reality, the Staff and Applicant crash probability assumptions were given complete acceptance by the Board, with only the most vague of references to consequences, even though the Board explicitly had expressed concern over whether or not a large aircraf t could initia te a Class 9 accident (tr. 727-8).
The Board relied on unquestionable numbers obtained from inserting da ta of un-known accuracy and applicability into unverifiable modela.
This reasoning by the Board does not even satisfy 10 CTR 2.760(c),
is arbitrary and capricious, and fails to meet the requirements of the AEA, NEPA and ERA to protect the health and safety of the public.
The Board obviously prefers to pity bookie when other peoples ' lives are a t stake.
The Board has no auch authority.
The question of who looks af ter the health and safety of the pu-lic during and af ter a reactor accident was discussed in this proceeding.
Various Sta ff witnescea established that the Applicant has the sole responsibility of assessing population exposure inside the Low Population Zone (LPZ)(tr. 1770), that the State would monitor eqpeure to the public outside the LFZ( tr.1075 ),
and that it was NRC policy not to measure population exposures (tr. 1065).
The record is clear that no one was able to say who has the legal responsibility for pro-tecting the health and safety of the public outside th e LPZ ( tr. 1770-1).
The record shown conclusively that the Ces=1ssion has no mechanism to determise whether or not the Stata can even carry out its role in the event of an accident (tr. 1078, 1745-6, 1812).
This is of particular importance since the Sta te has indicated itself that it ant'cipa tes severe proble=a in this area (tr. 1109).
In addition, in a draft re:ert =ade available to the Intervenora in January,1973, antitled Proceedines : Worksher en th e Ce t ch e r, lo?6 Tallout Radiatien Incident (USIPA, Region III, Phila., Ts., undated), Mr. Thomas Geruaky sta tes clearly and eacdidly tha t while the Sta ce could handle the fallout inci-dent, he doubted serious 17 if it could respond acceptably to a reactor accident emergency (Proceedisga, pages 23 4).
Gerusky la the Director of the Bureau of Eadiological Esalth ci Pennsylvania. the asenne en wh4-h
- k-c---d-d--
@~M1
7 delegated the authority to protect the health and safety of the public (tr.10~/5).
The state =ents of Gerusky regarding the lack of preparedneee of the State were concealed from the Board by two parties to this proceeding, the State and tue Applicant, (a representajive of the Applicant also attended this Workshop),
a violation of 10 CFR 51.20(d).
The Price-Anderson Act was intended to require that the Co= mission _i_n-prove the prospects that a claisant sight be able to establish the causal connec-tion between radiation exposure and subsecuent injuries.
As described in the Intervecors' Brief of Jan. 30,197f., and as shewn in the T:4I-2 proceeding, the Co=siasion now requires the Applicant to be the initial, primary, and essentially sole source of radiolegical infor=ation in the event of a radiologiesl accident (ID, para. 53).
But Sec.190 of the AZA prohibits vic ties of a nuclear accident fres using data reported by the Applicant in a suit for deseges.
3y relying ex-clusively upon the Applicant to monitor during a radiolegical accident, the Co= mission, in view of Sec.190, denies the right to compensatice which th e Cc= mis-aion itself is required to protect and advance under the Price-Anderson Act.
Commiaaion reliance upon the Applicant for information thus denica victime of a nuclear accident the opportunity to introduce in court the only evidence likely to establish a clais under the Price-Anderson Act.
The Commission thereby violates the AEA, NEPA, and ERA, and illegally denies victica of a nuclear seeident their constitutions 1 rights of due process and ecual protection.
This crucial assesament of p=blic radiation exposure is of =ajor import to protection of "the health and safety of the public," and cannot be delega ted haphazardly by the Commission, the Staff, or the Board.
The Board is not con-cerned that the Applicant exercises complete control over the infor=ation used to
=ske the i=itial decisions which trigger the beginning of this crucial assesa=ent (ID, para. 53), and has therefore exceeded its statutory reopenate111 ties under the AEA and 10 CTR 2.760(c).
The failure of the Staff and Board to leek significantly beyond the confines of the LF3 to protect the health and safety of the public in the even t of an accident constitutes a failure to conform with the mandate of the AEA, ERA and NEPA.
New inforcatnon on the effecta of lew-level radiatics on humana (tr.
2331-3) likewise prevents the 3 card and Staff from relying on this narrew inter-protation of the area which could to affected by a nuclear accident.
The violations of law and the Cc==1asion's Rules discuased above are by no means the only ones in this proceeding; they are included here as being repre-sentative of the contempt shown for the APA, AEA, NEPA, ERA, the Cosaisalon's own
& ~ '.~,0
8 rules and the applicable constitutional guarsntees by the Applicant, Staff, Licensing Bosrd, and Appeal Board in this proceeding.
The Intervenors sub=it that even a single violation la sufficient grounds for the granting of a stay of the ID.
The nuderous independent violations of the law perpe tra ted by the Applicant, Staff, Licensing Board and Appeal Board require the granting of a stay.
2.
The loading of fuel into TMI-2 will have been preceeded bv uranius are mining, silling, and all the preceeding eteps in the fuel cycle.
The =1111sg o f the ore,with the attendant creation of mill tailings piles and depleted uranium-238 maaka the beginning of a billion-year public health probles the Consission has yet to exasine as required by NEFA.
The known la tency period of cancer precludes the ide=tification of the individuals for wnos the =111 tailings piles pose an i=sediate threat. That does not mean irreparable injury will not be done, as soon as the mill tailings piles are created, since it has yet to be established that the mill tailings problem or the depleted uranium-238 problem can be permanently solved at all.
The fuel which the Applicant protesta is destined for TMI-2 can be used to fuel en already licensed reactor.
This would prevent the production of further mill tailings and would prevent irreparable injury due to the operation of TMI-2.
In addition, the initial achisvesent of fission in the core of TMI-2 transforma TMI-2, irrevocably inte a heap of radioactive waste in need of de-commissioning at some fu ture time.
Reactor decccmissioning is yet another subject which the Staff has given only the most superficial treatment (y35ES,
- p. 9-20, 21). No discussion la offered concerning the nature or degree of deco =missioning problems, the range of cos t estima tes, or the long-ters aspec ts of the problem.
Neither the Applicant, Sta ff, any Scard, or the Cos=iasion has the right or authority to make TMI-2 irrevocably radicactive prior to the ex.
haustion of all appeals to the Commission by the Intervenors.
The allowing of TMI-2 to bece:e radioactive slao constitutes an irreparable injury to the Intervenors, since the Board cannot, consistent with the law, grant an operating licenae to TMI-2 as shown above.
The Intervenors and other members of the public are harmed irreparably once the plant becomes radioactive because they will bear the ful_1 coat of deco==1asionis; which the Sta ff, Licensing Board and Appeal Board have refused to fully evaluate.
(19 ;20 3
9 3.
The Intervenore submit that no party to tnia preca:J:n; 22 harmed by the s tay of ';his decision pending the o=hauation of cli r.s r r.
provided for in the Cemsission's rules.
Th e Applic an t has, far it; crn reasons, delayed the :ompletion date of TMI-2 for about 4 yearn (ne2, 15.
instance, Construction Status Report, July,1977, NURE -0030-77/7),
Th a Applicant has made ne sention who decides to cause this delay and ao.< auc.
this delay has escalated the cost of TMI-2, aniwho =uat pay t
for it.
Fur th er-I more, it ir questio:able whether ot not the power is needed.
A Dec. 13, 1977 news release from the Department of Energy (FE-87) reporta a 55.55 c; cess generating capacity in the Mid-Atlantic area, which includos th a Applicant's service area.
Fur thermor e, the bringing of TMI-2 into nervice will in-eac >
clectricity costa to the Applicant'6 customera (tr. 1257)
If tha Applicant was truly interea ed in i==ediata, law?ul operation of TM!-2, ths Applicaat could have encouraged the development of an ID whose legality una beycnd que tiot..
Instead, the Applicant relied on the Staff and the Licensing and Appeal Boards to protect the Applicant and move the burden of proof on to the Int ava aces, ac described earlier.
The Applicant has no vested right to demand an operatin; license prior to a final finding by the Com:ission tha t the plant can be law-fully licensed.
Nor doe s the Applicant have the right to dresa up dn sagsu in an attempt to justify the issuance of an illegal opera ting licenz a.
1ho Cc=missiods fundacental responsibility is to protect the health and safe ty ci the public.
This statutory responsibility cannot be ignored to suic th e Applicants' fantasies particularly where auch illegal action would 21so esla, irre parable injury to the Intervenors and the general public.
4 Ihe public interest is best served when the legal and cons titucienci rights of all parties concerned in the proceeding have been protected.
Th; denial of the right to present a full line of witnesses in this proceedicc.._
to the practice of forcing a unique financial burden on the Intervoners by th Commission destroys the Intervenors ' righ ts.
The public in teres t is not serva by allowing an illegally and fraudulently licensed THI-2 to becccc irrevocacl; radioactive to placate the Applicant.
As discussed in part 1 of this Appef, the illegalities committed by the Staff, Applicant, Licenning Board, and Appeal Board, as outlined in the Intervenors ' filings of Aug.
15, 1977
~ 3v. 2C, 1977, Dec. 30, 1977, and Jan. 13, 1978, have yet to be fully responded to according to the law.
As su=marized above, NEPA, ERA, AEA, and the Co= mission 'a Rules have been flouted and mocked by the Staff, Applicsnt, Licensing Board, and the Appeal Board.
These law violations do not serve tha public interes t.
F 7,Cd:
10 The public interest is also served when agency decisions are arrived at legally and licensing hearings are conducted openly, hacently, unpartially, and according to the applicable statutes.
The " kangaroo court" nature of this proceeding, with the eventual outcome never in doubt, is an abyamal example of model agency procedures.
The public interest would also be
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served by the issuance of a decision to this Appeal according to the require-
=ents of the AEA, Sec.181, and the APA.
The public interest dictates that until the Co mission has ruled that. the operation of TMI-2 la legal and proper, the Applicant has no vested right to even risk irreparable injury to any party to this proceeding, or anyone else.
The public has a right to have seencies of government follow the dictates of the law.
The ID suat be stayed and reversed in order to restore public confidece and trust in the Commission and its attitudes toward its statutory obligations.
Respectfully submitted, teld1?
/
ChaunceyK(($ord'
.-/
Representative of the Intervenors M h[f[f 433 Criando Avenue State College, Pennsylvania 16801 4
e
CERTIFICATE OF SERVICE I hereby certify that copies of "Intervenors' Appeal to the Ccanission of a Stey of the Initial Decision" of Tebruary 8, 1978, have been served on the following by deposit in the U.S. Mail, Firs t Class,
postpaid, this th day of February, 1978, Edward Lutos, Eso., Chairman George F. Trowbridre, Esq.
Atomic Safety and licensing Board Shaw, Fittman, Fotta L U.S. Nuclear Regulatory Consission Trowbridge Washington, D.C. 20555 1500 M Street. N.W.
Washington, D.C. 2C036 Mr. Gustave A. Linenberger Atomic 52fety and Licensing Board Atomic Safety & Licensing Board I'anel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 U.C. Nuclear Reguratory Comnission Dr. Ernest O. Salo Washington, D.C. 20555 Professor, Finheries Research Atomic Safety and Licensing Institut e, Wii-10 College of Fisheries Appeal Board University of washington U.S. Nuclear Regulatory Saattle, Washington 98195 Commission Washington, D.C. 20555 Xarin W. Carter, Asst. Attorney General Office of Enforcement Docketing and Service Section Uepartnent of Environmental Resources Office of the Secretary 709 Health and Welfare Building Harrisburg, Fennsv1vania 17120 U.S. Nuclear Re ula tory Commirsion Alan S. Rosenthal. Esq., Chairman Atomic Safety and Licensing Appeal Hfary J. McGurren Counsel for NEC Staff Panel U.S. Nuclear Regulatory Commission ed N'I Nuclear Regulatory Commissica g
shington, D.C.
20535 Washington. D. C.
20555 N
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Dr. W. Reed Johnson. Member Atomic Safety and Licensing Appeal lh Q
Q y,h A*
Panel U.S. Nuclear Regulatory Commission $
vp#V 7
Washington, D. C. 20555 m & & ! i. / d'- f o
s Jerome.r. Sharf=an. Esq., Member ChaunceyKep[,0s.
Atc=ic Safety and Licensing Appeal Representative of the Intervenors Panel h33 Orlando Ave.
U.S. Nuclear Regulatory Commission stste College, Pa.16c01
.w..u--van. D. C.
20555 aW'CG