ML19206A268
| ML19206A268 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse, Peach Bottom, Harris, Wolf Creek, Saint Lucie, Hope Creek, Seabrook, North Anna, Sterling, 05000484, Washington Public Power Supply System, Cherokee, Marble Hill, Hartsville, Phipps Bend, Yellow Creek, Crane  |
| Issue date: | 05/30/1978 |
| From: | Duflo M NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| To: | |
| References | |
| NUDOCS 7904190003 | |
| Download: ML19206A268 (22) | |
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g RIITED STATES CF AMERICA NCCLEAR REGULATORY CCSS!!SSICN s4 giiW.
p ATCMIC SAFITY AND LICENSING APPEAL SOARDS*
,Ebr 47 V
D Ng2 D
Alan S.
Rosenthal, Chairman IN N. gJ S '7 "
Dr. Jchn H.
Buck Michael C. Farrar
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Richard S. Sal:=an g
@,p Jerone E. Shari=an M5 Dr. W. Reed Jchnson gE,
"t 'm > s ' j '
Q r,
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/%',v,
v In the Matters of
)
' J./?
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)
PHILACELPHIA ELECTRIC COMPANY et al.
)
Cocket Nos.
50-277
)
20-2.,.,
s (Peach 3cttem Atemic Pcwer Station,
)
Units 2 and 3)
)
)
". TROPOLITAN EDISCN COMPANY et al.
)
)
(Three Mile Island Nuclear Station,
)
Occket No. 50-320 Unit No. 2)
)
)
m VIRGI' IIA ELECTRIC AND PCWER COMPANY
)
)
(North Anna Pcwer Statien,
)
Occket Nos. 50-338, Units 1 and 2)
)
50-339
)
PC3LIC SF'VICE ELECTRIC AND GAS
)
CCMPAN
)
)
(Ecpe C;;eek Generating Statien,
)
Oceket Nos. 50-354 Units 1 and 2)
)
50-355
)
FLORIDA PCNER AND LIGHT COMPANY
)
)
(S t.
Lucie Plant, Unit Nc. 2)
)
Occket No. 50-359
)
CAROLINA PCWER AND LIGHT CCMPANY
)
)
(Shearen Harris Nuclear Pcwer Plant,
)
Occket Nos. 50-400 Unitr 1,2,3 and 4)
)
50-401
)
50-402
)
50-403 Zvery Appeal Panel Menher is en ene or nere of the 3 cards hearing the captioned proceedings; their ecliective designatien is sircly a convenience in issuing this jcinc crder.
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7DN290 %
S2*064 N
- PUBLIC SERVICE COMPANY OF NEW
)
HAMPSHIRE et al.
)
)
(Seabrock Station, Units 1 and 2)
)
Decket Nos. 50-443
)
50-444
)
KANSAS GAS AND ELECTRIC CCMPANY AND )
KANSAS CITY POWER AND LIGHT
)
CCMPANY
)
)
(Wolf Creek Generating Station,
)
Decket No. STY 50-432 Uni Nc. 1)
)
)
NORTHERN STATES POWER COMPANY
)
(MINNESCTA) AND NORTHERN STATES
)
POWER CCMPANY (WISCONSIN)
)
)
(Tyrone Energy Park, Unit No. 1)
)
Cocke: Nc. STN 50-484
)
RCCHESTER GAS AND ELECTRIC
)
CORPORATION et al.
)
)
(Sterling Power Project Nuclear
)
Decket No. STS 50-485 Unit No. 1)
)
)
DURE POWER CCMPANY
)
)
(Cherckee Nuclear Station,
)
Decket Ncs. STN 50-491 Units 1, 2 and 3)
)
STN 50-492
)
S"'N 5 0-4 9 3 THE TOLECO EDISCN COMPANY et al.
)
)
(Davis-Sesse Nuclear Power Station, )
Cccket Ncs. 50-500 Units 2 and 3)
)
50-501
)
WASHINGTCN PUBLIC PCWER SUPPLY
)
SYSTEM
)
)
(WPPSS Nuclear Picject Nc. 4)
)
Cccket Nc. 50-513
)
TENNESSEE 7 ALLEY AUTHORITY
)
)
(Hartsville Nuclear Plant, Units
)
Decket Nos. STN 50-513 1A, 2A, lE and 23)
)
STN 50-519
)
STN.50-520
)
STN'50-521 32-065
. PUBLIC SERV!CE CCMPANY 05' INDIANA,
)
INC.
)
)
(Marble Hill Nuclear Generating Statien, )
Occket Ncs. ST:: 50-546 Units 1 and 2)
)
STN 50-547
)
TENNESSEE VALLEY AUTHORITY
)
)
(Phipps Pend Nuclear Planc,
)
Docket Nos. 50-553 Units 1 and 2)
)
50-554
)
TENNESSEE VALLEY AUTHORITY
)
)
(Yellow Creek Nuclear Pcwer Plant,
)
Docket Nos.
S"I 5 0-5 6 6 Units 1 and 2)
)
STN 50-567
)
4-M.E,MORANDCM AND ORDER May 30, 1978
( ALA3-4 8 0 )
1.
On April 11, 1978, the Ccamission amended Table S-3 of 10 CFR Part 51, entitled "Su= mary ef Environmental Considerations for Uranium Fuel Cycle", to delete the value assigned to the emissions of raden-222 expected to occur as a result of the mining and milling of uranium.
43 Fed.
Reg. 15613 (April 14, 1978).
The basis for this action was that that value was incorrect.
The Ccmmission went en to state that, although the questien of the correct value was under reconsideration, it had decided not to institute at this juncture a rulemaking proceeding en raden emissions.
Rather, the matter was to be considered "in individual (licensing] proceedings".
In this connection, the Cc= mission directed that the raden questien be enter-tained not merely in those preceedings in which it had been previcusly placed in issue (cr in which a c. arty new desired to raise it) but, as well, in all other proceed-ings "still pending before Licensing or Appeal Beards".
The Cc= mission went en to state that, " [w] here cases are pending before Appeal Ecards, the Appeal Ecards are also b'4-0E7
. directed to recpen the records to receive new evidence en raden releases and en health effects resulting frem raden releases".
43 Fed. Reg. at 15615-16.
We first teck note of these instructions in an opinion issued en April 19 in the Eartsville croceeding. m'/
3ecause that prcceeding remained before the Licensing Board on another issue, we crdered that Board to recpen the record to " receive written evidence en radon releases and the health effects resulting therefrem.
Whether or not a hear-ing is required in connection with that evidence will be for the Licensing Scard to determine in the first instance".
7 NRC at (slip cpinien, p. 9 ). -2/
-1/ Tennessee Valley Authority (Hartsville Nuclear Plant, Units lA, 2A, 13, 23), ALA3-467, 7 NRC
__2/ This course was presaged by what we had done sc=e three weeks earlier in Metrocolitan Edisen Co. (Ttree Mile Island Nuclear Station, Unit No. 2), ALA3-465, 7 NRC (March 27, 1978).
In that case, the Commi.csion had directed us te review the Licensing 3 card'-
initial decisien authoricing the issuance of an cperating license as though Table S-3 contained no value for radon emissions at all.
CLI-78-3, 7 NRC (March 2, 1978).
After explcring with the parties how that direction might be best carried cut, we remanded the raden issue to the Licensing Scard with instructions "to recpen the record to receive new evidence, to hold such further hearings as may be required and to render a supplemental initial decisica".
ALAE-465, 7 NRC at (slip opinion, p.
- 3).
See also Northern States Power Co. (Tyrcne Energy Park, Unit 1), ALA3-464, 7 NRC (March 17, 1975).
{'O
- ~
ON
. Shortly after AL.13-467 was issued, the NRC staff moved us to censolidate a total of 17 proceedings for the limited purpose of receiving new evidence and making a decision regarding the environmental impact of raden releases in the uranium fuel cycle.
Aspects of each of these proceed-ings were said to be then pending before an appeal board; the motion did not enccmpass any proceeding in which the Licensing Scard had not as yet rendered its decisicn on the issuance of a construction permit, limited work author-i ation er operating license. d'/
The justification offered by the staff for seeking consolidation was that the "public interest" would be served.
By way of elaboration, we were told (motion, pp. 4-6; fcotncte emitted) :
Since the question of raden impacts is general and totally unrelated to the particular situa-tions of particular reac Ors, there wculd be ac real advantage to having the issue addressed by the Licensing Scards which received the evi-dence on the other issues in the proceedings.
The Appeal 3 card need not involve itself in drawing up detailed cest-benefit balances in close cases.
It could reasonably limit its
_3/ Included, hcwever, were Hartsville, sucra fn.
1, and Three Mile Island, sucra in. 2
-- despite the earlier remand of the raden issue to the Licensing Scard in each of those cases.
Not included was Washincron Public Pcwer Supply System (W2PSS Nuclear Pro ect, Ncs. 3 and 5), Cocket Nos. STN 50-508, 50-509, which case is pending before us for review on our own motien, because the staff feels that it is not necessary to recpen that proceeding.
'gz 063
- function te making an initial determination of whether the effects of radiation from radon could be substantial enough to affect the cest-benefit balances or determinations on the health effects of the nuclear fuel cycle.
Cf. Verment Yankee Nuclear Pcwer Coro., e't al. (7Erment Yankee Nuclear Pcwer Station), CLI-77-10, 5 NRC 717 (1977); ALA3-392, 5 NRC 767 (1977).
If the radon impacts are determined te be very small, there would be no need to have the particularized redeterminations of the cost-benefit balance made by the individual Licensinc Scards.
C_f.
Public Service Electric and Gas Co., et al._
(Salem Nuclear Genera:Ing Station, Units 1 and
- 2), ALA3-426, 6 NRC 206 (1977).
Should there be no censolidation, the Staff's testimony would be essentially the
'mc in each proceeding.
Presenting it one time Jeuld be
=cre efficient and less expensive.
Because of conflic ing demands on the time of a linited number of Staff witnesses, scheduling these witnesses in many separate proceedings would inevitably mean substantial delays in reaching the issue in many proceedings.
Similarly, we think it likely that a gced danl of rebuttal evidence would be duplicated from cne proceed-ing to another.
Consolidation could thus speed up the consideration of the raden-related issues and conserve the rescurces of all parties.
Consolidation would also be generally fair to Applicants and Intervencrs.
Those trying the third or fourth cases involving these issues would not be faced with the effects of these issues having been determined previcusly in other proceedings.
Althcugh the effects of the earlier decisiens would not be binding, there is no gainsaying that the earlier public deci-sien would affect later cases.
Conversely, if early decisions en the raden releases had no effect on later decisiens, the likelihced Of incensistent decisions would be increased.
This result tcc should be avoided.
32^070
. The =ction went en to indicate (at pp. 6-7) that,
"[a]s a first step", the staff proposes to tender five affidavits which purportedly establish (1) that the enviren-mental i= pact of raden releases in the uranium mining and milline. process are se insignificant that the cost / benefit balance for ne facility would be "substantially affected";
and (2) "that after the raden impacts are considered, a wide gap still exists between the projected health effects of the uraniun and coal fuel cycles".
The staff recognized, hcwever, that at least scme parties in one er more of the individual cases might wish to ecutrovert that evidence.
The =ction concluded en this note (p. 8) :
We respectfully request uhat the Appeal Scard crder the consolidation of the abcve-captioned proceedings for the purpose of dealing with the raden issue.
A conference of carties to the censolidated proceeding should'be held with the Appeal Scard members involved to discuss procedures for the consolidated hear-ing, including methods of efficiently and expediticusly handling discovery, submission of written testimony, identification of Scard questions, and cross-examination.
Wc wculd suggest that such a conference be held in the near future at a location as reasonably cen-venient as possible to all parties who indicate an interest in paruicipating.
Tc put it mildly, the metien was not well received by other parties.
The applicants in all but ene cf the 4 -071
O
_ 9_
17 proceedings were heard frem; withcut exceptien, the response teck the form of an unqualified opposition to censolidation.
In only three proceedings did intervencrs reply to the =ction; each of those responses likewise expressed the view that it should be denied.
The reasons advanced were not precisely the same in each instance.
We need not rehearse thes all here.
Scme of the =cre frequently expressed objections of applicants were that consolidation (1) would be incensistent with the Ccmmission's apparent decision that the raden issue shculd not be treated generically at this time; (2) would be inefficient and time-consuming and, additionally, would pose sericus legistical problems; and (3) would impose unwarrantad burdens upon those applicants who are not cen-fronted with a contest on the raden issue (i.e.,
an appil-cant in a proceeding in which the issue has not been placed in controversy should not have to participate in a dispute between parties to other proceedings). 3/
For their part,
_4/ Scme of the ac_c_licants went so far as to assert that the April 11 crder does not apply to their proceedings.
We st=marily reject these assertions.
They rest en the theory that the Cc= mission intended the crder to extend only to these proceedings in which NEPA issues still remain open (i.e.,
have not received final dis-position within the ccm=issicn).
But the direction that the record be recpened in " cases *
- pending -
before Appeal 3 cards" was withcut any such qualifica-tien, express er implied.
To the contrary, it clearly
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.du-4 32-072
. the responding intervencrs believe, inter alia, that con-solidation would be financially burdenseme to them. 5!
2.
We are satisfied that the Ccmmission's April 11 crder neither explicitly nor implicitly precludes the relief which the staff seeks.
Although electing not to initiate new a rulemaking proceeding en the raden issue, but instead to call for a reopening of the record in each individual pending case, the Cc= mission left to the dis-cretion of the varicus appeal and licensing bcards both how the reopening was to be acccmplished and hcw the "new evidence on radon releases and on health effects result-ing frc= raden releases" was then to be treated.
More specifically, the Cc= mission did not purport Oc suspend
_/ (FCCTNCTE CCNTINUED FRCM PREVICUS PAGE)
+
appears frem the terms of the Commission's order that it wishes the raden cuestion to be reexamined in =ver.r pending proceeding in which the now-repudiated va.ae for radon emissions assigned in Table S-3 had been employed.
5/ There is sharp disagreement between applicants and intervencrs as to the adequacy of the affidavits iden-tified in the staff's motion.
We need not, of course, address that centroversy at this time.
As already noted, the staff reccgnizes that, were the proceedings to be censolidated, an opportunity would still have to be provided other parties to challenge the content or sufficiency cf the affidavits.
U'd ^073
O 11 -
the operation of 10 CFR 2.716, which expressly authcri:es it (and thus us as its delegate) to "consclidate for hear-ing or for other purposes two or =cre proceedings" en a finding "that such action wd.ll ce conducive to the proper dispatch of its business and to the ends of justice".-6/
We are nonetheless constrained to observe that the stnff's =ction is a scurce of some pucclement.
The April 11 crder was not issued by the Cc= mission sua sconte.
- Rather, tha. crder represented the adoption of a scaff recc=menda-tion (in t. e Ccmmission's words) "that Table S-3 be amended to remove the value for raden releases and that the subject of raden releases and asscciated health effects be declared litigable in all individual licensing proceedings".
See Three Mile Island, CLI-73-3, surra fn.
2, 7 NRC at (slip opinion, p.
- 3).
When it made that recc=mendaticn, the staff prestnably was just as aware as it is new of each of the censideraticns which, according cc its conscl-idation =ction, militate against case-by-case treatment of what is beyond dispute a cruly generic issue.
Cne thus
~~6/ Iffective May 26, 1978, Section 2.716 was amended to ccnfer this authority en " presiding officers" (i.e.,
licensing boards) as well.
43 Fed. Reg. 17798, 17302 (April 26, 1978).
LU-074 might reascnahly ask why these censiderations did not
.~rcmpt the staff to reccmmend a rulemaking proceeding to c
amend Table S-3.
Alternatively, once it had focused upon the manifest difficulties attendant upon having many adjudicatory boards independently hear and decide the same generic issue, why did the staf f not then bring these difficulties to the Cecmission's attention with a recuest for a mcdification of the directives sct forth in the Ac. d ' -
o.da-'.
Although we have not paused to solicit the scaff's answers to these cuestions, the only possible explanation which ccmes to mind is that the staff's reanalysis of the radon matter has not as yet reached the point, at which the staff might be ready to effer its final views en hcw Table S-3 should be revised with regard to raden emissions.
It wculd appear fr m the consolidation motion, hcwever, that the reanalysis has progressed at least far enough that the staff is new quite prepared to assert that it should be used to determine the appropriate licensing action with regard to a substantial nu=ber of nuclear facilities --
not merely the 17 covered by the motien but also several c ~..'.e - -
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level of confidence, we fail co understand the reticence b2-075
. Of the staff to employ its present chinking en the sub";ect as a foundation for a proposed interin revision to Table S-3.
Stated otherwise, what is a sufficient evaluation (as the staff sees it) for the purposes cf two dozen or so pending proceedings ought to be no less satisfactcry for the relatively few additional proceedings te which an interim rule mic.ht ac. c. iv.
All things ccncidered, there is scant cause te lend a sympathetic ear to the staff's concerns regardin-the w
additional burdens to which it may be subjected in the absence of censolidation.
Apart from that, there is much to be said for the consensus of the responding parties that consolidatien (alcng the lines proposed by the staff) would be unworkable and, as to many (if not all) of these parties, unfair.
Indeed, the validity of the objections to this effect seems to us to be sufficiently self-evident to require no further discussion.
At the same cime, hcwever, we cannot allow cur dis-satisfaction with the staff's handling of this matter to obscure that there is little to be said for calling upcn 17 different licensing beards to hear and decide this a
-076
- 14 generic issue independently.-7/
3ecause of this, we have resisted the natural temptation simply to deny the cen-solidation =ction and to leave it to the staff to seek, if so inclined, relief of scme kind from the Ccemission itself.
Instead, we have undertaken to search en cur own for scme alternative solution to the problem (within the frmnework of the April 11 crder) which would be both feasible and f air to all concerned.
We cenclude that there is such a solution.
Although by no means perfect (we doubt that any flawless precedure for dealing with this situation eculd be devised), it seems to us to be a reasonable accc=meda-tion of the ccmpeting interests which either have specif-ically been brought to our attention or have occurred ec us.
The Licensing Scard in the Perkins censtruction permit proceeding-8/ has recently held an evidentiary hearing en
~~7/ " [I] t would be absurd that the issue of the enviren-mental effect of uranium mining in Wycminc should have to be separately censidered on every application to construct nuclear plants from Maine to California.
Rather the idea that a licensing agency shculd endeavor to identify environmental issues ccmmon to many appl:-
cations and handle them in ' generic' proceedings would seem to benefit all parties, particularly the peerly-financed environmental groups."
Iccicev Action v.
- AEC, 492 F.2d 998, 1002 (2nd Cir. 1974) (per Friendly, C.
J.).
_S/ Duke Pcwer Co. (Perkins Nuclear Station, Units 1, 2
and 3), Lcc.<et Ncs. STN 50-489, 50-489, 50-490.
u'd -077
.a the raden question and, as we understand it, will shortly
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to a memorandum written by Dr. Jordan last fall, in which he raised questions regarding the accuracy of the value then assigned te raden in Table S-3.
Also involved in the Perkins hearing is Dr. Chauncey R.
Kepford.
In the capacity c3 a a-."a.ic=1 4..*.a -- c. a -
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".a c oss-examined the witnesses for the staff and the applicant.-9/
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4.. *k.e "-"-aa Mile Island preceeding, in which he represents 'we inter-venor organizations.
He was an early and cutspcken critic cf the treatment fo rmer1v. c.iven raden enissions in Table S-3 and has evinced a good measure of skepticism respect-4,
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It is at least possible, however, that, ence that record is ccmplete, there will be general agrea-me.,..
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/4-078
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. f acets of the raden inquiry.
This possibility would appear to be enhanced by the presence of Drs. Jordan and Kepford.
In this connection, a preliminary look at the transcript of the two-day hearing discloses that Dr. Jordan was not merelv. a c.assive observer.
As was his richt -- indeed his manifest duty in the full discharge of his responsi-bilities as a technical member of the Licensing Scard --
he interrogated the witnesses himself en aspects of the radon inquiry which appeared to him to warrant further exploration.
In the. circumstances, the Perkins record (when ccm-plete) should be sufficient to serve as the base point for the examination of the raden issue in the 17 qther pro-ceedings to which the staff motion relates.
This is not to say, of course, that every party te each of these pro-ceedings will necessarily concur that that record is satis-f actory in every particular.
No matter hcw thercugh may have been the treatment of the raden issue in Perkins, one or mere of the parties 00 other cases nonetheless may conclude that there were stones left unturned; 1.e.,
that certions of the staff's new analysis were tot adec.uatelv.
tested er that there is available evidence bearing upon the issue beycnd that presented to the Perkins 3 card.
32*073
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~.."e sa.e time, however, it would be to no party's advantage to insist that the raden issue be relitigated frcm the start-3.
ing ine in gis own case, so long as,e were given an n
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In chcrt, the use of Perkins as the " lead case" en this generic issue would (1) cbviate the need for the
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the raden issue in that proceeding.
The remand of the 4-ue '
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d aa Ecards in ALA3-465 and ALAB-467, respectively, is vacatec.
Also withdrawn is so nuch of ALA3-464, surra, as indicatel d4'080 that, in certain circumstances, the Tyrone Licensing Scard should recpen the record on the issue.
2.
Within 10 days after the evidentiary record on the raden issue is closed in Perkins, a coc.v. of that record shall be served upon every party to each of the 17 proceed-
'0 Ings.- /
It shall be the rescensibility cf the NRC staff to insure that such service is acccmelished.
Further, the record in each of the 17 proceedings shall be deemed auto-
=atically recpened for the receipt of the evidence sc served.
3.
Within 14 days after his receipt of the Perkins evidentiary record, any such c. arty. may rec _uest in writin9 that the appeal beard assigned to the particular proceed-ing (a) receive additional written evidence en the raden question; (b) call for a further hearing en the Perkins record; or (c) consider Objections to any aspect of che Perkins raden proceeding.
The request shall set forth with specificity the reseects in which the Perkins record is deemed to be inccmplete, inaccurate, or objectionable, as well as precisely hcw such defects should be remedied.
_1_0/ As used hereia, the term " party" shall be deemed :
include a par _icipant under 10 CFR 2.715 (c).
u'l-081
19 -
Responses to such requests may be filed bv. any other c. arty tc the proceeding within 10 days thereaf ter.
4.
When rendered, the Licensing Scard's decision en the raden question in Perkins shall be served on everv.
party to each of the 17 nreceedings (the staff shall see J
to
..t that this service is acccmplished).
Within 14 days follcwing that service, a c. arty may file a memoranden with the appropriate appeal board addressed to two ques-tiens: (a) whether the Perkins evidentiary record supports the generic findings and conclusions of the Licensing Board respecting the amount of the raden emissiens in the mining and milling process and resultant health effects; and (b) whether the raden emissions and resultant health effects are such as tc tip the NEPA balance agains cen-s '- -" c~ ' 4 ^. (c. cre =*-*c.n) c#
~".e a-*-4^"'=-
a c --- - t
_4..
d'd'-
question.e1/
(A party who has earlier filed a request to 7
supplement in his proceeding the evidentiary record adduced in Perkins might, of course, chcose to defer the submissicn of a memorandum en these two questions pending the outccme of his request and any supplementation of the reccrd which may be ordered.)
,V
'.n
.._"_-...*-_4..c.
_.4. _4.2," e s *-i c n,
..".a_ _ a _- ' v, c^e u.' d a_ _d..'. a -
accept the Perkins Licensing 3 card's generic findings or emc. lev. his cwn analysis of the Perkins record (cre-s ".a ~.1 v, se_ _".'"..'.. _-a_sec ".s e.-
'..".e
_ _ _ s ' c_ u e s.. ).
dd'082
_ 5.
Each appeal board will deal with the radon questien independently.
The manner and timing of the dispcsitica ebvicusly will depend upon, inter alia, whether, in the specific proceeding, there are (a) recuests to supplement the record developed in Perkins; or (2) challenges to the Perkins findings.
We repeat our acknowledgment that the procedure cut-lined above is not free of all possible criticism -- indeed, it tco has scme c=nberseme features.
In none of the 17 cases, hcwever, has a party suggested an alternative pro-cedure which cc== ends itself as being more efficient and no less equitable.
That being so, we go this route.
It is so ORDERED.
FOR THE APPEAL BOAPIS ne& $
0w Y, -
- Margaten E.
Du Flo Secretary to the Appeal Scards
- 'd-0S13
UNITED 3TATES OF ASIRICA NUCLEAR RECULATORY C.^'.4ISSION In the Matter of
)
)
METROPOLITAN EDISON COMPANY,
)
)
)
(Three Mile Island Unit No. 2)
)
)
)
)
CERTIFICATE OF SER'!!CE I hereby certify that I have this day served the f ore;;cing document (sk upon each person designated on the of ficial service list ec= piled by the Office of the Secretary of the Cc= mission in this proceeding in accordance with the requirements of Section 2.712 of 10 CFR Part 2-Rules of Practice, of the Nuclear Regulatory Cc=tission's Rules and Regulations.
Cated at Washington, D.C.
this day of
/k4. f 197.
I J
'/
l Jt9fy
'202L dQ i.
Of fide o~f tne Secretary of the' Co=tission gg hl'4d5 fl0d L;Ll /Ye d.?d.LU Qzz s/
a2-084
C':ITED STATES OF A'iERICA NUCI. EAR REGL*LATCRY CCMMISSION In the Matter of
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)
METROPOLITAN EDISON C0 2A'iY, ET AL.
) Docket No. 50-320 -0L
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(Three Mile Island Unit No. 2)
)
SERVICE LIST Dr. Chauncey P. Kepford Edward Luton, Esq., Chairman 423 Criando Avenue Ato ic Safety and Licensing Board U. S. Nuclear Regulatory Cortsission St:te College, Pennsylver.ia 165Cl Washington, D. C. 20535 Mr. Gustave 2. Linenberger Atomic Safety and Licensing Eaard Honorable Karin W. Carter U. S. Nuclear Regulatory Co==ission Assistant Attorney General Washington, D. C.
20555 office of Enforcement Department of Environmental Resources Dr. Ernest O. Salo 709 Health and Welfare Building Professor Harrisburg, Pennsylvania 17120 Fisheries Research Institute, WH-10 College of Fisheries Miss Mary V. Southard University of Washington Citizens for a Safe Environment Seattle, Washington 98195 P.O. Box 405 Harrisburg, Pennsylvania 17108 George F. Trowbridge, Esq.
Shaw, Pittman, Potts, Trowbridge 122C M Street, 1:. F.
%hin ; ton, D. C.
2CCC6 Counsel for NP4 dtaff U. S. Nuclear Regulatory Co==ission Washington, D. C. 20:55 JJ-08b