ML19257B854
| ML19257B854 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 01/14/1980 |
| From: | Lewis S, Singer L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 8001210071 | |
| Download: ML19257B854 (17) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of
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SACRAMENTO MUNICIPAL UTILITY
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Docket No. 50-312 DISTRICT
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(Rancho Seco Nuclear Generating
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Station)
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SUPPLEMENTAL BRIEF OF NRC STAFF ON CONSIDERATION OF EMERGENCY PLANNING Stephen H. Lewis Lisa N. Singer Counsel for NRC Staff January 14, 1980 1773 119
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-i-TABLE OF CONTENTS Page INTRODUCTION....................................................
1 ARGUMENT........................................................ 2 CONCLUSION......................................................
10 TABLE OF AUTHORITIES Judicial Cases NRDC v. NRC, 547 F.2d 663 (D.C. Cir. 1976), rev'd sub nom.
Vermont Yankee Nuclear Power Corp. v. NRDC, 435 U.S. 519 T1978)........................................................ 5 Commission Cases Long Island Lighting Company (Shoreham)
ALAB-99, 6 AEC 53 (1973)......................................
5,6,7,8 ALAB-156, 6 AEC 831 (1973)....................................
5,6,7,8 Metropolitan Edison Company, et al (Three Mile Island, Unit 1)
Order and Notice of Hearing Taugust 9, 1979)...................
4 Potomac Electric Power Company (Douglas Point)
ALAB-218, 8 AEC 79 (1974).....................................
1,5,6,7,9 Sacramento Municipal Utility District (Rancho Seco)
Order (May 7, 1979)...........................................
3, 4 Order (June 21, 1979).........................................
3, 4 Order Ruling on Scope and Contentions (October 9, 1979).......
1 Referral of a Licensing Board Ruling to the Atomic Safety and Licensing Appeal Board (December 14, 1979)...............
2, 5 Order Accepting Referral (December 19, 1979)..................
1 1773 120
- ii -
Page Toledo Edison Comoany, eti al,. (Davis Besse, Unit 1).............. 4 Vermont Yankee Nuclear Power Corporation (Vermont Yankee)
ALAB-56, 4 AEC 930 (1972).....................................
5, 6, 7, 8, 10 ALAB-138, 6 AEC 520 (1973)....................................
5, 6, 7, 8, 10 ALAB-179, 7 AEC 159 (1974)....................................
7 Federal Register Notices 37 Fed. Reg. 24191 (November 15,1972)..........................
6 39 Fed. Reg. 14188 (April 22, 1974)............................
7 44 Fed. Reg. 61123 (October 23, 1979)..........................
9 44 Fed. Reg. 65049 (November 9, 1979).......................... 9 44 Fed. Reg. 75167 (December 19, 1979).........................
2,7,8 Transcripts of Commission Meetings Public Meeting -- Discussions of Modifications to the Rancho Seco Order (July 11, 1979)................................... 4 1773 121
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of
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SACRAMENTO MUf!ICIPAL UTILITY
)
Docket No. 50-312 DISTRICT
)
)
(Rancho Seco Nuclear Generating
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Station)
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SUPPLEMENTAL BRIEF 0F NRC STAFF ON CONSIDERATION OF EMERGENCY PLANNING INTRODUCTION This brief is filed by the NRC Staff in response to the opportunity afforded 1/
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by the Appeal Board for the parties to supplement their views on whether off-site emergency planning should be considered as an issue in this proceeding.
2/
The Licensing Board had earlier ruled that the issue was not a proper subject for consideration in individual licensing proceedings because of the Commission's announcement of its intent to undertake rulemaking on emergency planning. The Licensing Loard had based its ruling on the case law reviewed with approval in the Appeal Board's Douglas Point decision.~3/Absent the rulemaking, the Licensing Board stated, it would have admitted the contentions asserted on off-site emer-gency planning as within the scope of the proceeding.~4/
Upon the " Motion of the 1/ Order Accepting Referral, December 19, 1979.
2/ Order Ruling on Scope and Contentions, at 3-4, 19-20, October 9, 1979.
3_/ Potomac Electric Power Co. (Douglas Point), ALAB-218, 8 AEC 79.(1974).
4_/ October 9, 1979 Order, supra, n.2, at 19-20.
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. California Energy Commission-5/
for Reconsideration or, in the Alternative, for Certificaticn to the Commission," the majority of the Licensing Board reaffirmed its earlier ruling and the basis for it and referred its decision (under 10 C.F.R. 12.730(f)) to the Appeal Board.-6/The Chairman of the Licensing Board concurred in the result, but based her concurrence on the position argued by the Staff, and 7/
the similar position advanced by the Licensee! that the issue was beyond the scope of the proceeding.
The Appeal Board also attached to its order the Commission's notice of Proposec Rule--Emergency Planning, 44 Fed. Reg. 75167 (December 19,1979) and directed the parties to be prepared to discuss the relevance of that notice to the rule-making question. The Staff addresses in this brief the questions of 1) whether off-site energency planning is within the scope of this proceeding and 2) whether emergency planning is an inappropriate consideration in this proceeding in view of the pendency of rulemaking to upgrade the requirements presently set forth in Commission regulations. With regard to the latter question, the Staff has con-sidered the relevance of the Commission's most recent notice.
ARGUMENT I.
The position of the Staff that the subject of off-site emergency planning is beyond the scope of this proceeding is set forth in our "Brief on Scope of the Proceeding" (August 27,1979) and our " Response to CEC's ' Motion... for 5/ Hereafter, " CEC."
-6/ Referral of a Licensing Board Ruling to the Atomic Safety and Licensing Appeal Board, December 14, 1979, hereafter " Referral Order."
-7/ Brief of the Sacramento Municipal Utility District on the Scope of the Board's Jurisdiction (August 24, 1979); Licensee's Answer to Motion of the California Energy Commission for Reconsideration or, in the Alternative, for Certification to the Commission (November 8, 1979).
1773 123 Reconsideration or, in the Alternative, for Certification to the Commission'"
(November 13,1979). The Appeal Board acknowledged that these matters had been fully briefed before the Licensing Board, but afforded the parties the opportunity to comment upon the fuller explanation given by the Board in its order denying reconsideration.
The Commission Order of June 21, 1979 designated the three issues to be con-8/
sidered in this proceeding," all of which are directly related to the ability of the Rancho Seco facility to respond safely to feedwater transients.
In its Referral Order the Licensing Board majority concluded,without elaboration, that "there is a reasonable nexus between emergency planning / response and occurrence offeedwatertransients"andthus"/J/ecauseofthatnexus,emergencyplanning/
response should not be outside the scope of this proceeding." Referral Order, at 4.
Based upon our analysis of the May 7, 1979 Commission Order confirming the shutdown of this facility and the June 21, 1979 Commission Order establish-ing the issues to be considered in this proceeding, we adhere to our position that the ability of the facility to " respond safely to feedwater transients" does not include off-site emergency responses. The whole focus of the Commission in ordering the shutdown of this facility (and the other operating B&W plants) was the unique sensitivity of these plants to feedwater transients and the role
_8/ The issues designated by the Commission are:
- 1. Whether the actions reguired by subparagraphs (a) through (e) of Section IV of the /May 7, 1979/ Order are necessary and sufficient to provide reasonable assurance that the facility will respond safely to feedwater transients, pending completion of the long-term modifications set forth in Section II /of the May7,1979Orde[/.
- 2. Whether the licensee should be required to accomplish, as promptly as practicable, the long-term modifications set forth in Section II of the Order.
- 3. Whether these long-term modifications are sufficient to provide continued reasonable assurance that the facility will respond safely to feedwater transients.
1773 124
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that this sensitivity might play as a precursor or contributor to a TMI-2 type of accident. The issue of off-site emergency planning / response was clearly not encompassed within that concern.
Moreover, our belief that the Commission did not intend to include the issue of emergency planning / response as an issue in this case is further supported by the express action taken by the Commission subsequent to the issuance of the June 21, 1979 Order in this proceeding.
In formulating the issues to be con-sidered in the Three Mile Island proceeding - another Babcock and Wilcox design facility - the Commission explicitly included emergency planning as an issue to be considered in that proceeding,-9/while choosing not to amend its Order in the present proceeding to add this subject as an issue to be litigated. However, in contrast, when the Connission determined in the companion Davis Besse shutdown proceeding that the issue of management competence should be considered,-10/
the Commission did not hesitate to reconsider its earlier order in this proceeding 11/
and effectively permit the litigation of that issue.- Thus, the demonstrated willingness of the Commission to construe its Order in this proceeding to permit additional issues where it determined such was necessary, strongly suggests, we 9/ Metropolitan Edison Comoany, et al. (Three Mile Island Nuclear Station, Unit 1), Docket ko. 50-289. Order and Notice of Hearing, at 6 (August 9, 1979).
10/ Toledo Edison Company, et al. (Davis Besse Nuclear Power Station, Unit 1)
Docket No. 50-346. Order, May 16, 1979.
11/ See transcript of Public Meeting -- Discussions of Modifications to the Rancho 3eco Order, July 11, 1979. The Commission reasoned that " management competence" to respond to feedwater transients is an issue related to the action taken by it in the May 7, 1979 Order and the issue could, therefore, be raised in the proceeding. Tr. 5, 6, 9.
Relying on the Licensing Board's Order that issues related to the Commission's action,but not specifically stated in the June 21, 1979 Order, could be raised in the proceeding, the Commission concluded that it was not necessary to amend the May 7, 1979 Order.
Id. See Licensing Board's
" Order for Filing of Amended and Supplemented RequestsTor / sic / and Notice of Prehearing Conference," at 3,n. 3 (July 3, 1979).
f773 125 believe, that its failure to do so with respect to emergency planning / response reflects a conclusion by the Commission that the subject was not appropriate for this proceeding. The concurring opinion of Chairman Bowers adopts this reasoning.
Referral Order at 11.
II If this Board should determine -- contrary to the arguments set forth above --
that the issue of emergency planning is appropriate for consideration in this proceeding, the Staff submits that the Licensing Board erred in concluding that the proposed emergency planning rulemaking precluded the litigation of all emergency planning issues in this case. Specifically, the Staff asserts that the Licensing Board improperly included within the breadth of its Order a prohibition on the litigation of the sufficiency of the Licensee's compliance with existing Commission emergency planning regulations.
In considering this issue, it is first necessary to appreciate the different contexts in which the cases leading up to Douglas Point and the Douglas Point 12/
case itself arose. The cases in the former category are Vermont Yankee ~d an Shorehan.~13/
The question in these cases was whether the environmental impact of the uranium fuel cycle, a subject not then covered by Commission regulation, was appropriate for consideration in individual reactor licensing proceedings.
In Vermont Yankee, ALAB-56, supra note 9, 4 AEC at 931-32, the Appeal Board held that the transportation of spent fuel from the facility to a reprocessing plant and the transportation of high and low-level wastes from the nuclear plant were
--~12/ Vermont Yankee Nuclear Power Corp. (Vermont Yankee), ALAB-56, 4 AEC 930 (1972), and ALAB-179, 7 AEC 159 (1974), rev'd NRDC v. NRC, 547 F.2d 663 (D.C. Cir. 1976), rev'd on other grounds sub nom.
Vermont Yankee Nuclear Power Corp. v. NRDC, 435 U.S. 519 (1978).
p/LongIslandLightinaCo.(Shoreham),ALAB-99,6AEC53(1973), and ALAB-156, 6 AEC 831 (1973).
1773 126 appropriate considerations in individual licensing proceedings, but that the operations of a reprocessing plant or the disposal of wastes resulting from reprocessing did not have to be considered in that forum. Because of the generic nature of those subjects, the Appeal Board held that they were not appropriate for adjudication ia individual proceedings.
4 AEC at 935. The Appeal Board's treatment of the subject indicates that it was influenced by two principal facts:
- 1) that the impacts associated with the reprocessing of spent fuel and disposal of wastes associated with the Vermont Yankee facility would not differ in any significant respect from those associated with any other reactor of similar size, and 2) that the type of information and analysis that was required could only be developed on an industry-wide basis. 4 AEC at 933-935.
At the time ALAB-56 was issued, the Commission had not yet instituted a rule-making proceeding on how to f actor uranium fuel cycle impacts into individual 14/
proceedings.
Shortly thereafter, the Commission published a " Notice of Pro-posed Rule Making -- Environmental Effects of the Uranium Fuel Cycle," 37 Fed.
Reo. 24191, November 15, 1972.
In Shoreham, ALAB-99, supra, note 10, 6 NRC at 56-57, the Appeal Board pointed to the pendency of this rulemaking as render-ing the consideration of uranium fuel cycle impacts inappropriate in individual 15/
licensing proceedings.-
By the time of the Appeal Board's decision in Douglas Point, the Commission's rulemaking had been completed and a regulation had been promulgated.---16/
The 14/ The Appeal Board, in fact, suggested rulemaking as the appropriate procedure for pursuing the intervenor's concerns. 4 AEC at 937.
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---15/ The Appeal Board later reaffirmed this ruling in ALAB-156, supra n. 10, 6 AEC at 833 and also reaffirmed its Vermont Yankee ruling in ALAB-179, supra n.9, 7 AEC at 163-164.
16/ This regulation is now codified in 10 C.F.R. 951.20(e) and Table S.3.
Appeal Board specifically held that now that a regulatior, had been promulgated, the intervenor was entitled to litigate compliance with that regulation.
1_7/
Douglas Point, ALAB-218, supra note 3, 8 AEC at 88.
In that case, this meant that the intervenor could litigate the question of whether the values set forth in Table S.3 tipped the balance against construction of the facility.
Id.
The situation at hand is analogous to that presented in Douglas Point, rather than to that presented in Vermont Yankee and Shoreham. The Commission has an existing regulation (10 C.F.R. Part 50, Appendix E) setting forth the require-ments for emergency planning by Commission licensees. With respect to the requirements of this regulation, as with Table S.3 in D_ouglas Point, the doctrine enunciated in Vermont Yankee and its progeny has no applicability.
In an appro-priate proceeding, an intervenor would be free to raise the issue of compliance with that regulation.~1P/
The Commission's requirements in the area of emergency planning would, however, be significantly upgraded by adoption of the proposed amendments published on December 19, 1979. 44 Fed. Reg. 75167. The amended regulations would include 17/ The Appeal Board, citing to the Commission's Statement of Consideration accompanying the promulgation of Table S.3, 39 Fed. Reg.14188 (April 22, 1974), noted that to the extent the new regulation differed from Vermont Yankee, ALAB-58, suora, n.12, that decision was stripped of any "further precedential significance." 8 AEC at 82.
Our review of the Statement of Consideration has satisfied us that the Commission was referring only to the specific holding in Vermont Yankee, viz., that reprocessing and waste disposal did not have to be considered in individual licensing proceedings.
The Commission did not comment upon, and we believe left intact, the general holding that matters which are (or are about to be) in rulemaking should not be considered in individual licensing proceedings.
~18/ Doualas Point, suora n. 3, 8 AEC at 88.
See also Vermont Yankee Nuclear Nwer Corp. (Vermont Yankee), ALAB-133, 6 AEC 520, 528 (1973).
j773 j]@
.8-requirements of a radically different nature from those found in the present regulations. Thus, for example, licensees would Le required to submit much more detailed emergency planning documentation than is presently required.---19/
The doctrine that in individual licensing proceedings boards should not con-sider matters that are in rulemaking is appropriate for application in the cir-cumstances of this case insofs as the proposed upgraded requirements are concerned. The same types of considerations which counselled that the uranium fuel cycle impacts in Vermont Yankee and Shoreham should be considered in rulemaking, rather than in individual adjudication, are also present here. The considerations involved in the emergency planning rulemaking are predominantly generic in nature, for example whether suspension of operation should automatically follow from lack of Federal government " concurrence" in applicable State and local emergency response plants. Such considerations are equally applicable to all reactors and merit industry-wide consideration, rather than adjudication in iridividual licens-2j1/
ing proceedirigs. Site specific considerations would arise with respect to such issues as the precise configuration of " emergency planning zones" (EPZ) around
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a particular site. However, the process of establishing EPZ's for any particular 19/ 44 Fed. Rea. 75168.
2_0/ The Licensing Board najority was also influenced by the fact that, since the Conmission's emergency planning regulations are in a state of flux, any inquiry that it undertook on the subject would need to be duplicated once the new regulatory standards are in place.
Referral Order at 6-7.
The Board's reasoning provides further support for deferring to a pending rulemaking, since any of several actions could be taken by the Commission with respect to the proposed rule, e.g., adoption, rejection, or adoption in a different form.
1773 129
. site or taking other site specific elements into acc. ant would have to follow Commission's adoption of the proposed rule.~21/
Thus, if the Appeal Board were to determine that the issue of emergency planning response was appropriately within the scope of this proceeding, the parties to this action could, under the authority of Doualas Point, properly litigate the licensee's compliance with the Commission's existing emergency planning regu-lations,-22/and such litigation would not be barred by the existing rulemaking.
However, if the Intervenors are seeking to litigate emergency planning concerns beyond the licensee's compliance with the Conmission's existing regulation and encompassing matters within the scope of the generic issues considered by the H/ See the Commission's Policy Statement -- Planning Basis for Emergency Responses to Nuclear Power Reactor Accidents, 44 Fed. Reg. 61123 (October 23,1979).
22/ In determining the regulatory standards which would be applied in any con-sideration of emergency planning in this proceeding, the Licensing Board should consider as guidance the following language of the new Appendix B to 10 C.F.R. Part 50 (Suspension of 10 C.F.R. 12.764 and Statenent of Policy on Conduct of Adjudicatory Proceedings):
In reaching their decisions the Boards should interpret exist-ing regulations and regulatory policies with due consideration to the implications for those regulations and policies of the Three Mile Island accident.
In this regard it should be under-stood that as a result of analyses still under way the Commis-sion may change its present regulations and regulatory policies in important respects and thus compliance with existing regula-tions may turn out to no longer warrant approval of a license application.
44 Fed. R_ea. 65049, 65050 (November 9, 1979).
1773 130 proposed rulemaking, then such issues are, under the reasoning of Vermont Yankee, precluded from litigation in this proceeding.-23/
ly The emergency planning issue sought to be raised by CEC is reproduced below.
"4.
Whether, notwithstanding measures taken and contemplated to deal with feedwater transient problems, the facility should be required to revise emergency planning procedures so that, in the event of future problems, persons in the immediate reactor area and in the facility's reasonable impact area will not be exposed to danger. /Tootnote deletef/. As stated in flVREG-0560: 'Although some improver ~ents can and shiiuld be made to feedwater system relia-bility and to identify and correct design deficiencies, the occur-ance of feedwater transients cannot be eliminated.... The emphasis should be on coping and mitigating the consequences of feedwater transients.' This issue will encompass certain of the same concerns raised in flUREG-0396 and a U.S. GA0 Report EriD 78-110,llarch 30, 1979. This issue will require analysis of whether the facility's current emergency plans and the state and local plans associated therewith are adequate, or whether changes should be required within a definite timeframe or before the facility is permitted to operate further. This issue will also require inquiry into:
- Whether the scope of accidents covered by the facility's emergency planning procedures should be expanded to cover planning for protection of Class 9 accidents, Tril-level incidents, and other more serious events not currently covered?
- Whether accident notification procedures such as the criteria for requiring IIRC notification used by Sf4UD should be revised?"
l773 131
. CONCLUSION For the reasons developed above, the Appeal Board should find that off-site emergency planning is beyond the scope of this proceeding and that it need not reach the question of whether the pendency of the rulemaking renders inappropriate consideration of emergency planning (in whole or in part) in this proceeding. Should the Appeal Board rule that off-site emergency plan-ning is within the scope of this proceeding, its consideration thereof should be guided by existing Commission regulations, with due regard to the impli-cations for these regulations of the TMI-2 accident.
See note 20, supra.
Respectfully submitted, Stephen.. Lewis Counsel for NRC Staff Ear Lisa N. S:nger Counsel for NRC Staff Dated at Bethesda, Maryland this 14th day of January,1980 1773 132
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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SACRAMENTO MUNICIPAL UTILITY
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Docket No. 50-312 DISTRICT
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(Rancho Seco Nuclear Generating
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Station)
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NOTICE OF APPEARANCE Notice if hereby given that the undersigned attorney herewith enters an appearance in the captioned matter.
In accordance with 52.713, 10 C.F.R. Part 2, the following information is provided:
Name
- Lisa N. Singer Address
- Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Telephone Number
- Area Code 301/492-7269 Admissions
- Supreme Court for the State of Massachusetts Supreme Court for the State of Rhode Island Name of Party
- NRC Staff U.S. Nuclear Regulatory Commission
/
Lisa N. Singer e
Counsel for NRC Staff Dated at Bethesda, Maryland this 14th day of January,1980.
}773 }33
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of
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SACRAMENTO MUNICIPAL UTILITY
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Docket No. 50-312 DISTRICT
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(Rancho Seco Nuclear Generating
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Station)
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CERTIFICATE OF SERVICE I hereby certify that copies of " SUPPLEMENTAL BRIEF 0F NRC STAFF ON CONSIDERA-TION OF EMERGENCY PLANNING," and "NOTIrc 0F APPEARANCE," for Lisa N. Singer, in the above-captioned proceeding 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 14th day of January, 1980:
- Richard S. Salzman, Esq., Chairnan
- Dr. Richard F. Cole Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Panel Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comnission Washington, D.C.
20555 Washington, D.C.
20555
- Dr. John H. Buck
- Mr. Frederick J. Shon Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Panel Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555
- Thomas S. Moore, Esq.
David S. Kaplan, Esq.
Atomic Safety and Licensing General Counsel Appeal Board Panel Sacramento Municipal Utility District U.S. Nuclear Regulatory Commission P. O.
Box 15S30 Washington, D.C.
20555 Sacramento, California 95S13
- Elizabeth S. Bowers, Esq.
Gary Hursh, Esq.
Atomic Safety and Licensing Board Panel 520 Capitol Mall U.S. Nuclear Regulatory Commission Suite 700 Washington, D.C.
20555 Sacramento, California 95814 1773 134
Mr. Richard D. Castro
- Atomic Safety and Licensing 2231 K Street Board Panel Sacramento, California 95816 U.S. Nuclear Regulatory Comission Washington, D.C.
20555 James S. Reed, Esq.
Michael H. Remy, Esq.
- Atomic Safety and Licensing Reed, Samuel & Remy Appeal Board Panel 717 K Street, Suite 405 U.S. Nuclear Regulatory Commission Sacramento, California 95814 Washington, D.C.
20555 Christopher Ellison, Esq.
- Docketing and Service Section Dian Grueneich, Esq.
Office of the Secretary California Energy Comission U.S. Nuclear Regulatcry Commission 1111 Howe Avenue Washington, D.C.
20555 Sacramento, California 95825 Herbert H. Brown, Esq.
Lawrence Coe Lanpher, Esq.
Hill, Christopher and Phillips, P.C.
1900 M Street, N.W.
Washington, D.C.
20036 Mr. Michael R. Eaton Energy Issues Coordinator Sierra Club Legislative Office 1107 9 Street, Room 1020 Sacramento, California 95814 Thomas A. Baxter, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washington, D.C.
20036
&p '- L
. buy Stephen H. Lewis Counsel for NRC Staff (773 135