ML19242B323
| ML19242B323 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/02/1979 |
| From: | Ulman M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| Shared Package | |
| ML19242B322 | List: |
| References | |
| NUDOCS 7908080088 | |
| Download: ML19242B323 (18) | |
Text
07/02/79 UtilTED STATES OF AMERICA fiUCLEAR REGULATORY C0:1:11SSIOTI BEFORE THE AT0!1IC SAFETY AilD LICE liSIfiG BOARD _
In the Matter of
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HOUST0!1 LIGHTIfiG AtiD POWER COMPA!iY,
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50-499
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(South Texas Project, Units 1 and 2)
)
STAFF STATE!1Ei1T OF POSITIOt1 0" RlvlSED C0fiTEtiTI0fjS OF CITIZEtiS COT;CER:iED ABOUT tiUCLEAR POWER (CCA!iF) AtiD CITIZEftS FOR EQUITABLE UTILITIES, IfiC. (CEU)
A.
CCAtiP Introduction In its Prehearing Conference Order dated April 3,1979, the Board found two of CCAt P's contentions (#2 and #3) to be acmissible, subject to revision in accordance with the guidance provided by the Board in its Order.
Sea Pre-hearing Conference Order, 'o.
20-25.
The filing dated May 24,1979, from CCAfiP contains CCAfiP's refomulation of both contentions.
At a reeting on May 10,1979, the parties reached agreement on language for rm tention #3, but could not agree on contention #2.
As explair.ed below, the Staff agrees with the Applicants that contention #3 is acceptable, b0t objects to those portions of contention #2 which, in the Staff's view, cover subject, beyond the scope of.the original contention.
7 9080 8 oc'E s,,
1 J
. Statement of Revised Contention Contentien #2 1.
The South Texas Nuclear Project has not been built in a manner such that a clear showing of safety can be provided to the Nuclear Regulatory Commission and, therefore, the operating license for the South Texas Nuclear Project should be denied.
2.
The South Texas Nuclear Project has not been. built in com-pliance with designs, specifications, and procedures.
3.
The manner in which the South Texas Nuclear Project has been constructed creates the very real possibility that the operation of this reactor could constitute a serious hazard to the citizens of this State.
4.
The defects in the construction of the South Texas Nuclear Project are a result of a conspiracy which continues to this date.
5.
The purposes of the conspiracy are to evade, violate, and avoid the requirements of design, specification, and procedures.
6.
In the alternative, there was and continues tc be gross negli-gence involving numerous mistakes, errors, and failures to properly comply with the designs, specifications, and procedures which have potentially serious and grave consequences in terns of the health and safety of the general public.
7.
What follows are exanples which comprise part but not the entirety of what the intervenor plans to present to the Licensing Board in support of its contentions.
There is no reasonable assurance that the activities authorized by the operating license for the South Texas Nuclear Project can be conducted with-out endangering the health and safety of the public in that:
a.
There are membrane seals in the containment structure which are damaged.
b.
There are steel reinforcement bars which are missing from the concrete around the equipment doors in the containment and such bars are missing from the containment structure as well, c.
There are cadwelds which have been integrated into parts of the plant structure which are not capable of being verified with regard to compliance with 10 CFR Part 50 Appendix 8.
d.
There has been a surveying error which has resulted in the eastern edge of the Unit 2 flechanical Electrical Auxiliary Building o
a i L
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. being constructed one (1) foot short (in the east-west direction) from its design location (violation of 10 CFR 50 Appendix B).
e.
There has been field construction in error and as a result, extensive voids exist in the concrete wall enclosing the containment building (violation of 10 CFR 50).
f.
In violation of Quality Assurance and Quality Control require-ments applicable to the South Texas Nuclear Project with regard to document control, a field document relating to cadweld inspections has been irretrievably lost (violation of 10 CFR 50 Appendix B).
g.
Nuclear Regulatory Inspection records indicate that construc-tion records and quality control and quality assurance records have been falsified by employees of Houston Lighting and Power and Brown and Root (violation of 10 CFR 50, Appendix B, sections VI, XVLL).
The Applicants Quality Assurance Plan was not effectuated because of the following:
Quality Control as per the requirements of 10 CFR 50 Appendix B has not been complied with.
In particular,10 CFR 50 Appendix B Section 3 was violated because:
a.
Efforts by quality control inspectors to verify that design changes were executed in accordance with the purposes of the original design were repeatedly and systematically thwarted, b.
There were personnel other than the original designer approving design changes with no first hand knowledge of the purpose of the original design.
c.
There were design changes approved by personnel unquali-fied in the type of design where the change was made, d.
There were numerous pour cards that were supposed to record the correct execution of concrete pours which were falsi-fied by numerous persons.
e.
There has been and continues to be assaults on the Applicant's quality control inspectors, continual threats of bodily hana to those inspectors, firing of inspectors, and other acts constituting a pattern of behavior designed to intimidate the inspectors.
As a result of the intimidations, certain inspections were never done because the inspectors decided to play cards over a period of four months rather than risk their safety on the plant grounds.
c_,)?
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As a result of the foregoing, the Commission cannot make the findings required by 10 CFR 50.57(a) (1) and (2) necessary for issuance of an operating license for the South Texas l'uclear Project.
Staff Position CCANo's original contention #2 put into issue whether construction of STP has been carried out in accordance with applicable requirements and listed six construction deficiencies in subparagraphs (b) through (g).
Al though the Board found that the contention raised questions as to the adequacy of construction which should be resolved on the record, the Board detennined that CCANP should specify the provisions of NRC regulations or other require-ments which the six specific alleged practices may have violated.
Order at
- p. 21.
The Board also deleted subparagraph section (a) of the contention as too general to be considered anything but introductory.
Contention #2, as revised by CCANP, contains an introduction and a " Specific Contention" which lists numerous allegedly deficient construction practices with respect to STP.
CCANP has also deleted subparagraphs (e), (f), and (g) of the original contention.
The Staff believes that only subparagraphs d.,
- e. and f. on pp. I and 2 of the revised contention are acceptable,E since they cover the allegedly
]f These subparagraphs correspond to subparagraphs b., c. and d. of the original contention.
The Applicants agree that the subject matter of subparagraphs d. and f.
have been particularized sufficiently to identify the " precise defects or practices which the petitioner has in mind and the quality assurance provisions which CCANP claims are being violated." See " Applicants' Response to Citizens Concerned About Nuclear Power Reformulated Con-tentions", dated June 5, 1979, p.2.
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\\)J deficient construction practices which were identified in the original con-tention. All of the other items in the revised contention (a., b. and c. on p.1; g. on p.2, and items a. through e. on pp.2-3) should be rejected, since they are beyond the scope of the original contention.
Inclusion in the refomulated contention of these items constitutes an amendment of the original contention which should not be entertained absent a showing of good cause by CCAi1P for failure to file the amendment in a timely manner.
10 CFR
@2.714 (a) and (b).
The Staff believes that subparagraphs d., c. and f. of the contention are acceptable, with minor revisions, as set forth below. -
"There is no reasonable assurance that the activities authorized by the operating license for the South Texas fluclear Project can be conducted without endangering the health and safety of the public in that:
1.
There has been a surveying error which has resulted in the eastern edge of the Unit 2 flechanical Electrical Auxiliary Building being constructed one (1) foot short (in the east-west direction) from its design location.
This error violates 10 CFR Part 50, Appendix B, Sections X and XI.
2.
There has been field construction error and as a result, extensive voids exist in the concrete wall enclosing the contain-ment building, in violation of 10 CFR Part 50, Appendiv ", Sections IX and X.
2_/
lhis revision eliminates the introduction to the contention, which contains argumentative tems which appear to have no factual foundation or basis, and the closing statement. We have inserted the appropriate sections of 10 CFR Part 50, Appendix B.
!t should also be noted that i tems 1., 2. and 3. correspond to subpare;raphs d., e. and f.,
respectively, of CCAf;P's reformulated contention.
C, g -
s 3.
In violation of Quality Asm renca end ruality Control require-ments applicable to the South Texas iuclear Project with regard to document control (10 CFR Part 50, Appendix B, Sections Vi and XVII),
a field document relating to cadueld inspections has been lost.
As a result of the foregoing, the Comission cannot make the findings required by 10 CFR ?s50.57(a)(1) and (2) necessary for issuance of an operating license for the South Texas I;uclear Project."
Statement of Revised Contention Contention #3 South Texas Project Units 1 and 2 are pressurized water reactors.
Such reactors have experienced about thirty reported instances (most of which occurred during startup or shutdown) in which temperature-pressure limits of the reactor vessels (as reflected in plant technical specifications) in the reactor coolant-system have caused excessive pressures on reactor pressure vessels.
The South Texas fluclear Project does not incorporate design features or administrative pro-cedures which are adequate to prevent or ameliorate such pressure transients nor have any technical specifications been proposed for this purpose.
The South Texas fluclear Project will, therefore, not be in compliance with 10 CFR Part 50.
Staff Position The Staff agrees with the ApplicantsE that CCANP refomulated contention
- 3, as set forth above, satisfies the requirements for establishing an acceptable contention.
B.
CEV Introduction CEU's Supplement contains revised versions of CEU's original contentions (two of which, Contentions #1 and #5, were determined by the Board to be 3/
See " Applicants ' Response," supra, p.6.
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valid) and a discussion of those contentions for which the Board requested additional information.E As discussed below, there is agreement among the parties on one of the contentions, contention #5.
For the remaining conten-tions, the Staff has indir'ted which contentions, or portions thereof, it believes should be accepted by the Board.
Statement of Revised Contention Contention 31 The South Texas Project (STP) Category 1 structures and equip-ment are inadequately designed and constructed with respect to wind loadings as demonstrated by the fact that actual wind velocities associated with hurricanes which have occurred along the Texas Gulf Coast have exceeded wind loadings for which STP structures have been designed and evaluated.
Further there are non-Category I struc-tures containing equipment which if destroyed or damaged would jeopardize the safe operation of STP.
These non-category 1 buildings are not designed to withstand winds generated by hurricanes and if damaged would provide missile type projectiles which could penetrate Category 1 structuras which are inadeuqately protected.
[ Footnotes eliminated.]
Staff Postion The Licensing Board agreed with the Staff that to the extent that CEV con-tended in its original contention that the operating wind speed of 120 miles y
Even as to these two contentions, the Board stated that they should be rewritten to assert only the specific matters at issue.
Order at 53.
5/
With respect to these contentions, the Board commented:
"... we do not have enough information to accept or reject any of them.
The filing of CEU's petition af ter the special prehearing conference made this situation almost inevi table.
Because we believe that certain of the matters raised may possibly warrant adjudication, we are af fording CEU an addi tional opportunity to per-fect certain aspects of its contentions..." Order at 56
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per hour with a peak gust value of 156 miles per hour for the South Texas Project (as identified in Section 2.3 of the PSAR and found acceptable by the Staff in Section 2.3.2 of the SER (CP)) is not sufficient, this is a valid contention.
Order, pp. 53-55.
The Staff believes that the revised contention complies with the Board's direction that the cor;tention be rewritten to assert only the specific matters at issue and is admissible.
Although CEU's original version stated a concern that the wind speeds recorded in the STP vicinity would breach the containment, the Staff believes that it is a reasonable inference from the original contention that CEU's concerns encompassed the potential for missile impacts from non-Category I structures due to higher velocity winds.
- Thus, we do not concur with the Applicant's position that the contention must be limited to Category I structures, without considering whether such structures are adequately protected against missiles from wind-damaged non-Category I s tructu res.
Statement of Revised Contention Contentions 2&3 Infonnation which is available demonstrates that the effects of discharges of plant effluents into Little Robbins Slough and the coolintl )ake will dversely affect aquatic organisms in the 6
food chain 6/
There are footnotes to this contention which appear on p.2 of Part 1 of CEU's supplement and on pp.2-3 (
Part 2.
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a s
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_9_
CEV has rearitten and nombined contentions *2 and d3 cnunerated in its original petition.
The original contentions suggested that neu information may exist with respect to the envi ronmental impact of the facility's opera-tion on marine life and certain wildlife species.
However, the Board found that CEV did not describe the infonaation with sufficient particularity for it to detennine how new or significant the infonaation is.
Order at p. 57.
The footnotes (see footnote 4 on p.2 of Part 1 of the supplement and foot-note 6 pp.2-3 of Part 2 of the supplement) to CEU's revised contentions contain citations relied upon by CEU in support of its revised contention.
Although there is no extensive discussion of the citations, in the Staff's view, these citations and the supporting discussion are sufficient to show with respect to this issue, that significant new information concerning radionuclide concentration in aquatic organisms may have developed af ter the construction pennit warranting consideration of this matter in the operating license proceeding.U Since the focus of CEU's concern is limited to bicaccumulations of radio-nuclides in aquatic organisms, the Staff proposes the following in lieu of CEU 's revised contentions 2&3:
"Infonnation is available [ insert citations contained in foot-notes to revised contentions 2&3) which indicates that the Staff's treatment (in FES section 5.4.1.3 and Table 5.7) of bicaccumulation of radionuclides in aquatic organisms is inadequate or in error."
7f We do note that dates of publication are given for only two of the citations, which raises a question as to whether aB of this infor-mation developed subsequent to the publication of the Construction Pennit Final Environmental Statement (FES).
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2 Cp Contention 4 CEU has withdrawn this contention.
Statement. of Revised Contention Contention 5 Staff and Applicant caiculations of radionuclides deposition rates do not take into account the relatively high and continual humidity in the area of STP to determine compliance with 10 C E Pa rt 50, Appendix 1.
Staff Position The Staff agrees with the Applicants / that this contention should be accepted.
8 Statement of Revised Contention Contention 6 tiilk producing animals will be pastured within a 5 mile radius of STP, and as a result, Applicant will not be able to comply with 10 CFR 50, Appendix I.
Staff Postion The Board read CEU's original contention 6'as a safety matter which takes issue with the cow-milk pathway calculations for radiation exposures".
Order at pp.58-59.
As stated by the Board, this contention:
"... seems to assert that, contrary to the information supplied by the Applicants, there are cows closer than 5 miles to the plant." Order at p.59.
The Board concluded that:
"If CEU should have information demonstrating that such cows are present within 5 miles of the facility, the contention would be a valid one."
Order at p.59.
8/
See " Applicants' Response to Supplement to Citizens for Equitable Utilities, Inc. Original Petition," dated June 5,1979, p.4.
.q b*
( k _)
The Staff does not telieve that CEU, in its Pay 29, 1979 supplement, has made such a denonstration, and therefore this contention is not acceptable.
The statement (on p.4 of the Supplement, Part 2) that "It is a ccmmon practice among fanners and ranchers in this area to keep dairy cows..." is inadequate in this respect.9/
Statement of Revised Contention Contentian 7 Due to soil cor.ditions peculiar to this area, inadequate water flow in the Colorado River and diminishing groundwater supply, Appli-cant will not be able to naintain the 7,000 acre cooling pond at a sufficient level to allow continued safe operation of STP.
Staff Position In analyzing CEU's original contention 7, the Board noted that the conten-tion appeared to raise c safety issue with respect to the availability of make-up water for the na.1 cooling reservoir.
The Board detennined that in order for this contention to be acceptable, further particularization of the infonnation or data relied upon was necessary to assure that a real issue is presented.
See Order at pp. 54-55 and pp. 59-60.
Footnotes to this contention on p.3 of Part 1 of the supplement and p.5 of Part 2 contain citations relied upon by CEV in support of its contention.
Although there is not an extensive discussion of these cit tions, the Staff
~9/
The Staf f would further note that CEU has not clarified the point of reference from whici. che location of the nearest grazing a.iimal was calculated.
The reference point used by the Staff is not the site boundary, but the centerline of the reactor nearest the location of the grazing animal or animals.
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, believes that the contention as supplemented by the citations and discussion (on p.5 of Part 2 of supplement) provides the information requested by the Board and therefore neets the requirenents as to specificity and basis.
CEV has stated with adequate specificity and basis, why it believes that Appli-cants will not be able to maintain the 7,000 acre cooling pond at a sufficient level.
The Staff does not believe, as the Applicants assert,10/ that the particularization provided by CEV constitutes an impermissible (i.e., untimely) amendment of the contention by CEU, since CEU is merely providing information to the Board regarding the basis for its contention; it is not expanding the substance of its proposed coritention.
In view of the foregoing, it is the Staff's position that contention 7, as revised and supplenented by CEU, is acceptable.
Statement of Revised Contention Contention 8 Proposed amendments of 10 CFR 50, Appendix E, 43 Fed. Reg. 37473, August 23, 1978, are to be used as interim guidance evaluat-ing, inter alia, applications for operating licenses.
Such amend-ments require that emergency plans must, in defined circumstances, extend, as appropriate, to areas beyond the LPZ.
Such requi rements are applicable in the case of STP because of the following:
(A) fiatagorda Elementary School with an enrollment of more than 80 students, which is approximately 8 miles from STP in a south-southeasterly direction, would have to travel towards STP in order to evacuate since the only evacuation, State Highway 60, ends in fiatagorda.
10/ See " Applicants' Response," supra, p. 7.
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(B) At the end of Sta t, Niitay CD in "atagorda there begins a secondary road, 2031, idich crosses the intercoastal canal and continues 6.6 oiles dosen the peninsula, ending on the Gulf.
There are numerous residents in these areas who have no other route than Highway 60 for evacuation.
(C) The evacuation plan for~lulated by the Texas Depart-ment of Public Safety is only "in case of nuclear war."
An uncompleted plan by the Texas Health Department would not apply to l'atagorda as it only covers a 5-mile L.P.Z.
Accordingly, the STP erergency plan does not con-form to the requirements of the above referenced proposed amendments to 10 CFR 50, Aopendix E 5;hich are currently effective as interin guidelines.
Staff Position This contention relates to the emergency plan for STP, The original conten-tion merely claimed that the only evacuation route for certain persons residing near STP requires them to go closer to the plant in order to get away from i t.
The Board distinguished this contention, as originally written, from a claim accepted as a contention in Femi,N/ where it was clear that the persons who were to be evacuated resided in an area where evacuation was required; i.e. within the Low Population Zone (LPZ).
The Board requested additional infon ation to clarify this and to indicate whether, in accordance with curr ently proposed regulations (to be applied pending adoption of final regulations),12/ emergency planning measures may be necessary for areas beyond the LPZ for STP, which here has an outer radius of 3 miles from the plant. Order at p.60.
H/ Detroi t Edi son Co. (Enrico Femi Atomic Power Plant, Unit 2) LBP-79-1, 9 t;RC at (Slip Op. pp.12-13).
H/ 43 Fed. M. 37473 (August 23,1978).
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It is the Staff's position that the informt 'on supplied by CEU in its revised contention on the proximity of a school to STP and the limiter applicability of state emergency criteria, is sufficient to raisc F 1ssue as to whether emergency planning measures are necessary for areas beyond the LPZ.
Derefore, this contention should be admitted, as nodified by the Staff below. E /
Proposed amendments to 10 CrR Part 50, Appendix E (43 Fed. Req. 37473, August 23, 1978) are to be used as "interin guidance" in evaluating inter alia applications for operating licenses.
Such :.andnents requi re that ener-gency plans must, in defined circumstances, extend, as appropriate, to ar eas beyond the Low Population Zone (LPZ).
Such requirements are applicable in the case of STP because of the following:
(A) Matagorda Elementary School with an enrellment of more than 80 students, is located approximately 8 miles from STP in a south-southeas*.erly di rection.
Persons at the school would have to travel towards STP in order to evacuate since the only evacuation route, State Highway 60, ends in Matagorda.
(B) At the end of State Highway 60 in Matagorda there begins a secondary road, 2031, v.hich crosses the intracoastal canal and continues 6.6 miles down the peninsula, ending on the Gulf.
There are nunerous residents in this area who have no other route than Hignway 60 for evacuation.
(C)
Thc evacuation plan formulated by the Texas Department o'
' *lic Safety is only "in case of nuclear war."
An incomplete pi oy the Texas Health Department would not apply to Matagorda as it only covers a 5-mile LPZ.
Accordingly, the STP emergency plan does not conform to the requirements of the above referenced proposed amendments to 10 CFR Part 50, Appendix E which are currently effective as interim guidelines.
Statement of Revised Contention Contention 9 Exa.1ples of construction deficiencies which may or may not be correctable and violations of 10 CFR Part 50 which have a direct bearing on the hr 11th and safety of CEU members are as follows:
H/ lhe Staf f's modification contains orly minor language changes and corrections.
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Falsification of documents, Inspection and Enforce-ment Activity Report (I&E) 77-03 of February 1977 (2/77) --
I&E #77-03 of 4/77 -- and I&E #78-08 of 5/78.
Violation of 10 CFR 50, Appendix B, XIV.
(B)
Use of unqualified personnel, I&E 77-01, 77-04 and 77-08.
'Holation of 10 CFR 50, Appendix B, Criterion II, V and VII.
(C) fio audi t of design review, I&E 77-08 and 77-13.
Vio-lation of 10 CFR 50 Criterion XVIII.
(D)
Containment Liner Infractions, I&E 77-01 and 78-07.
Violation of 10 CFR 50, Appendix B, Criterion VI and IX.
(E)
Failure to follow approved procedures, I&E 78-15 and 78-17.
Violation of 10 CFR 50, Appendix B, Criterion V.
(F)
Failure to provide acceptance criteria, I&E 78-15 and 78-17.
Violation of 10 CFR 50 Appendix B, Criterion V.
(G) floncompliance relating to ce weld activities, weld defects and inadequate welding techniques, and failure to follow cadweld procedures, I&E 77-05, 77-OF, 77-13 and 78-16.
Violation of 10 CFR 50, Appendix B, Criterion V, VIII, XIII and 10 CFR Pa rt 50.55(e).
(H)
Failure to provide revised drawings, I&E 78-08.
Vi o-lation of 10 CFR 50, Appendix B, Criterion VI.
(I)
Failure to Provide in-process inspection, I&E 78-15 and 78-16.
Violation of 10 CFR 50, Appendix B, Criterion X, and 10 CFR Part 50.55(e).
(J)
Examples of other violatior.- of 10 CFR 50.55(e) a,e as follows:
1.
Steel lef t out of containment.
2.
Voids in concrete of containment build-ing.
3.
Waterproof membrane rupture below ground level.
4.
ffon-compliance of steel plates in contain-ment liner.
)
\\v C gl> b Staff Position The only construction practices alleged with any degree of specificity by CEU in support of the original contention related to falsification of Quality Assurance /Quali ty Control records by the Applicants and/or contractors and the absence of a " current set of plans within the containcent building."14/
According to the Board, this contention, which it described as similar to CCAMP's contention 2, would be acceptable if extensively particularized.
Order at pp.62 and 47.
It is the Staff's opinion that the contention has been adequately particularized only with respect to that portion related to falsification of documents.
The Staff objects to the remainder of the contention for two reasons:
first, the items enur.erated therein are beyond the scope of the original contention, second because with respect to these items, CEV has failed to comply with the Board's direction to specify the precise construction defects or practices which CEU has in mind.
Order at
- p. 47.
In view of the foregoing, the Staff proposes the following in lieu of contention 9, as set forth in CEU's supplement:
"HRC inspection records (Inspection and Enforcement Reports
- 77-03, 2/77; =77-03, 4/77, and #70-08, 5/78) indicate that South Texas Project construction records have been falsified by employees of Houston Lighting and Power Corpany and Brown and Root, in violation of 10 CFR Part 50, Appendix B, Sections VI and XVII.
As a result, the Commission cannot make the findings required by 10 CFR Ss50.57(a)(1) and (2)."
14/ See " Petition for Leave to Intervene by Citizens for Equitable Utilities, Inc.," dated February 23, 1979, p.22 (as designated by the Staff).
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C0f'CLUS I0t1 In view of the foregoir.
' ie Staff believes that CCAf1P revised contention
- 2 (as modified by the Staff) and contention #3 are acceptable and should be admitted as contentions in this proceeding.
Insofar as CEU's revised conten-tions are concerned, the Staff finds contentions 2 & 3 (combined), 8, and 9 to be acceptable, as nodified by the Staff.
The Staff believes that con-tentions 1, 5, and 7 are also admissible contentions.
Contention 6 should be rejected.
Pespectfully submitted,
/, % 4242 d. ((bucuv flarjorie B. Ulnan Counsel for f1RC Staff Dated at Bethesda, Maryland this 2nd day of July,1979 s)
O
UNITF.D STATES OF M1 ERICA NUCLEAR REGULNIORY CO DilSSION BEFORE Tlii: ATUS'IC SAFETY AND LICENSING BOARD ln the Flit ter of
)
)
!! OUST 0" LIGHTING AND POWER CO'iPANY, )
)
50-499
)
(South Texas Project, Units 1 and 2 )
CERTIFICATE OF SERVICE I hereby certify that copies of " STAFF STATEt1ENT OF POSITION ON REVISED CON-TENTIONS OF CITIZENS CONCERNED ABOUT NUCLEAR POWER (CCANP) AND CITIZENS FOR EQUITABLE UTILITIES, INC. (CEU)" in the above-captioned proceedirig have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 2nd day of July,1979:
Charles Bechhoefer, Esq., Chairman
- Richard W. Lowerre, Esq.
Atomic Safety and Licensing Board Assistant Attorncy General Panel Environmental Protection Division U.S. Nuclear Regulatory Commission P. O.
Box 12548, Capitol Station Washington, DC 20555 Austin, TX 78711 Dr. James C.
Lamb, III Jack R. Newman, Esq.
313 Woodhaven R0ad Lowenstein, Newman, Reis, Chapel Hill, North Carolina 27514 Axelrad & Toll 1025 Connecticut Aveaue, N.W.
Dr. Emmeth A.
Luebke*
Washington, DC 20036 Atonic Safety and Licensing Board Panel Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Panel
- Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Melhert Schwarz, Jr., Esq.
Baker and Botta Atomic Safety and Licensing Appeal One Shell Plaza Panel (5)*
Houston, TX 7700?
U.S. Nuclear Regulatory Commission Was.h in gt on, DC 20555 Mr. Lanny Alan Sinkin Citizens Concerned About Nuclear Docketing and Service Section (4)*
Power Office of the Secretary 838 E. Magnolia U.S. Nuclear Regulatory Commission San Antonio, TX 78212 Washington, DC 20555 Mrs. Peggy Buchorn Executive Director Citizens for Equitable Utilities, Inc.
Route 1, Box 432 Brazoria, TX 77422
$11 cut 4 '.lc 0. [] ww b Ed br$[ M C'" Staff o
.)
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