ML19271A995
| ML19271A995 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 08/07/1980 |
| From: | Copeland J, Newman J HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-CP, NUDOCS 8008110501 | |
| Download: ML19271A995 (21) | |
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD cN vJ ,1 bol C
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In the Matter of )
) Docket No. 50-466 HOUSTON LIGHTING & POWER COMPANY
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(Allens Creek Nuclear Generating )
Station, Unit 1) )
)
TPPLICANT'S RESPONSE IN OPPOSITION TO TEXPRIG'S CLASS 9 MOTION I. Introduction On July 24, 1980, TexPIRG served a motion entitled "Mo-tion for Directive That a Supplement to the Allens Creek E.I.S.
Be Prepared; Re: Class 9 Accidents" (Motion). The Motion re-quested that the Licensing Board order the NRC Staff "to pre-pare a supplement to the Final Environmental Statement (FES) for Allens Creek Nuclear Generating Station (ACNGS) which ade-quately and thoroughly assesses the impact of worst-case acci-:
dents, and other accidents referred to in the FES for ACNGS as
' Class 9.'"1! Houston Lighting and Power Company (Applicant) hereby submits its response in opposition to the Motion.
i'/Motion, p. 1.
9 J) SOS
II. Background 1971, the Atomic Energy Commission issued On December 1, Part 50 a Proposed Annex to former Appendix D to 10 C.F.R.
(Proposed Annex) . 36 Fed. Reg. 22851 (1971). 'Ihe Proposed Annex es -
tablished nine classes of accidents, the most severe of which were Class 9 accidents.l! The Commission stated that it was "not necessary to discuss" Class 9 accidents in environmental reports and environmental inpact statements because of the re-mote probability and extremely low environmental risk of such Although the Proposed Annex was never formally an accident.
it was intended to provide "in-promulgated as a regulation, bject.
terim guidance" pending completion of rulemaking on the su The Proposed Annex has been interpreted as proscribing How-consideration of Class 9 accidents for land-based plants.
ever, two exceptions to this general rule did arise over the First, years during which the Proposed Annex was in effect.
the NRC Staff was permitted to consider Class 9 accidents in in which an increased probability of a "special circumstances" Offshore Power Class 9 accident necessitated its consideration.
ALAB-489, 3 NRC 194, Systems (Floating Nuclear Power Plants),
Second, in 2'12 (1978), aff'd. CLI-79-9, 10 NRC 257 (1979).
-1/The Proposed Annex defined a Class 9 accident as " sequences of postulated. successive failures more severe than th engineered safety features."
Offshore Power Systems, supra, the Commission directed the Staff to bring to its attention any individual land-based plants which warranted a consideration of Class 9 accidents. -
i.e., in those " exceptional case [s] that might warrant addi-tional consideration: higher population density, proximity to man-made or natural hazard, unusual site configuration, unusual design features, etc, . .
" Public Service Company of Oklahoma (Black Fox Station, Units 1 and 2), CLI-80-8, 11 NRC 433, 434 (1980) (emphasis in original) .
The NRC Staff did not include a detailed consideration of Class 9 accidents in either the FES for ACNGS (dated Novem-ber 1974) or the Final Supplement to the FES (dated August 1978). This was in accordance with the interim guidance pro-vided by the Proposed Annex, since the Staff judged the pro-bability of Class 9 accidents at ACNGS to be "so small that their environmental risk is extremely low."l! Additionally, ACNGS did not fall under the exception of Offshore Power Sys-tems since the NRC Staff did not determine "that the Allens Creek plant or site is so exceptional that it should be pro-posed to the Commission as a situation requiring" a considera-tion of Class 9 accidents.2/ Thus, the NRC Staff's treatment 1!FES, p. 7-1.
2/"NRC Staff Response to New Contentions 48 and 49 and an
- Amendment to Admitted Contention 17 Submitted by Intervenor John F. Doher,ty," dated April 28, 1980, p. 11. See also Houston Lighting and Power Company (Allens Creek Nuclear Generating Station, Unit 1) , " Order" by Licensing Board, dated May 15, 1980, p. 5.
of Class 9 accidents for ACNGS complied with the interim guidance of the Proposed Annex.
The Proposed Annex was withdrawn by the Commission on June 13, 1980, and was replaced by a Statement of Interim Policy on the consideration of accidents in environmental 45 Fed. Reg.
impact statements and environmental reports.
40101. The Interim Policy abolishes the classification of accidents established in the Proposed Annex, and requires every environmental impact statement to contain a reasoned consideration of the environmental risks attributable to accidents, including accidents which are not reasonably ex-pected to occur. The Interim Policy also states:
It is the intent of the Commission in issuing this Statement of Interim Policy that the Staff will initiate treatments of accident considerations, in accordance with the forego-ing guidance, in its ongoing NEPA reviews, i.e.,
for any proceeding at a licensing stage where a Final Environmental Impact Statement has not yet been issued. These new treatments, which will take into account significant site- and plant ~
specific features, will result in more detailed discussions of accident risks than in previous environmental statements, particularly for those related to conventional light water plants at land-based sites. It is expected that these re-vised treatments will lead to conclusions re-garding the environmental risks of accidents similar to those that would be reached by a continuation of current practices, particularly for cases involving special circumstances where Class 9 risks have been considered by the Staff, as described above. Thus, this change in policy is not to be construed as any lack of confidence in conclusions regarding the environmental risks of accidents expressed in any previously issued Statements, nor, absent a showing of similar
special circumstances, as a basis for opening, reopening, or expanding any previous or ongo-ing proceeding.5 However, it is also the intent of the Com-mission that the Staff take steps to identify additional cases that might warrant early consi-deration of either additional features or other actions which would prevent or mitigate the con-sequences of serious accidents. Cases for such consideration are those for which a Final Envi-ronmental Statement has already been issued at the Construction Pernit stage but for which the Operating License review stage has not been reached. In carrying out this directive, the Staff should consider relevant site features, including population density, associated with accident risk in comparison to such features at presently operating plants. Staff should also consider the likelihood that substantive changes in plant design features which may com-pensate further for adverse site features may be more easily incorporated in plants when con-struction has not yet progressed very far.
Environmental Reports submitted by appli-cants for construction permits and for operating licenses on or after July 1, 1980 should include a discussion of the environmental risks associ-ated with accidents that follows the guidance given herein.
5 Commissioners Gilinsky and Bradford dis-agree with the inclusion of the preceding two sentences. They feel that they are absolutely inconsistent with an even-handed reappraisal of the former, erroneous position on Class 9 accidents.
III. Discussion A. Introduction TexPIRG primarily relies upon the Statement of Interim Policy as the basis for its Motion, and argues that "the staff is bound by the Commission's new policy statement to revise the FES for ACNGS by evaluating ' Class 9' accident im-pacts."l! Additionally, TexPIRG asserts that the FES for ACNGS will violate the National Environmental Policy Act (NEPA) unless it evaluates Class 9 accidents. There is no merit in either argument, and consequently the Motion should be de-nied.
B. The Statement of Interim Policy Does Not Require Class 9 Accidents To Be Considered in a Supple-mental FES for ACNGS TexPIRG interprets the Statement of Interim Policy as a direction to the Staff to consider Class 9 accidents in those proceedings in which a " final" or " complete" final environmental statement has not been issued. TexPIRG asserts that the FES in ACNGS is not a final or complete document because the Staff is
- preparing a supplement to the FES and because the FES is sd3 ject to modification by the initial decision under 10 C.F.R. S 51. 5 2 (b) (3 ) .
Thus, TexPIRG concludes that the Statement of Interim Policy requires the Staff to prepare a supplemental FES on Class 9 accidents for ACNGS. TexPIRG has misconstrued the Statement of Interim Policy.
-1/ Motion, p. 2.
The Statement of Interim Policy represents a change of policy from the interim guidance provided by the Proposed Annex. The Commission realized that this change might have an adverse impact upon the progress of licensing proceedings, and it expressed a desire for an " orderly transition" between policies.1/ In an attempt to minimize the disruptive poten-t .al of the change in policy, the Commission established a carefully delineated timetable to govern the transition:
- 1) Only those environmental repcrts submitted on or after July 1, 1980 must include the requisite consideration of accidents. /
- 2) Only those final environmental statements issued on or after June 13, 1980 must include a considera-tion of accidents.1!
- 3) The Staff is not required to initiate a considera-tion of accidents in ongoing proceedings during 1/ See Transcript of Commission Meeting of April 16, 1980 on
- Discussion of SECY-80-131 - Accident Considerations Under NEPA" (hereinaf ter referred to as Tr. ) , p. 53. It is wor-thy of note that that Commission meeting discussed what ultimately became the Commission's Interim Policy Statement.
The proposed Statement of Interim Policy contained in SECY-80-131 and the actual Statement of Interim Policy differ substantively only in that the actual Statement added the first full paragraph in the last column of 45 Fed. Reg. at "
40103, which begins "However, it is also the intent . . .
-2/45 Fed. Reg. ;tt 4 010 3.
1! 45 Fed. Reg. at 40103.
the time between the issuance of the FES and the issuance of the initial decision.1/
- 4) Absent "special circumstances," the Statement of Interim Policy cannot be used as the basis for re-opening or expanding previous or ongoing proceed-ings.2/
5)
For those plants for which an FES has been issued at the construction permit stage but for which the operating license review stage has not been reached, the Staff is directed to take steps to identify those plants that might warrant early considera-tion.3!
- 6) Plants for which an FES has been issued at the con-struction permit stage will be subject to an acci-dent consideration at the operating license review stage.1!
3!Tr. 50-55; 45 Fed. Reg. at 40103.
2,/ 45 Fed. Reg. at 40103.
1! 45 Fed. Reg. at 40103.
1! Tr. 44-45, 70-88.
As can be seen, the Statement of Interim Policy establishes a carefully drafted structure governing the timing of the consideration of Class 9 accidents. In specifying at what point Class 9 accidents will be addressed in ongoing NEPA reviews, it instructs the Staff to initiate the consideration of such acci-dents in a construction permit proceeding only "where a Final En-vironmental Impact Statement has not yet been issued" by the Staff.1/
Since the Staff has prepared and issued an FES for ACKE, it need not consider Class 9 accidents in this proceeding. Thus, the e:spli-cit direction contained in the Statement of Interim Policy provides a clear and straightforward basis for denying TexPIRG's motion.
TexPIRG suggests that the Statement of Interim Policy requires the Staff to consider Class 9 accidents unless a " complete" or " final" final environmental impact statement has been issued.
Such a suggestion is without support in the Staff's proposed Statement of Interim F31 icy,A! in the transcript of the Com-mission's meeting on accident considerations, or in t?^
Statement of Interim Policy itself. If the Commissicn had intended the issuance of an initial decision or a supplemental FES to constitute the cutoff point beyond which the Staff need not undertake a consideration of Class 9 accidents, it would have simply and explicitly so provided. Instead, the Commission chose to establish the issuance of the FES as the cutoff pcint.2/
1/45 Fed. Reg. at 40103.
2/" Accident Considerations Under NEPA," SECY-80-131, March 11, 1980.
2/ An FES is that document issued in response to comments received on the draft environmental statement. A supplement to a FES is termed a " supplemental FES" and is a different document than the FES. See 40 C.F.R. S 1502.9.
Moreover, the Statement of Interim Policy itself, be-lies the argument that the issuance of an initial decision or a supplemental FES is the appropriate cutoff point. Often a supplemental FES is not issued until late in a proceeding, and an initial decision cannot be rendered until hearings are com-pleted. The designation of either of these events as the cut-off point would not provide for the " orderly transition," de-sired by the Commission, since the preparation of a Class 9 accident analysis at either of these times would pose the po-tential for a severe disruption of a proceeding. The Staff
. estimates that the initial preparation of an accident analysis pursuant to the Statement of Interim Policy will require four to six man-months.1/ If the further delay caused by the admission of new contentions regarding Class 9 accidents is taken into account, this proceeding could be substantially disrupted by the granting of TexPIRG's motion. The Commission obviously desired to avoid such a result and expressly so stated:
Thus, this change in policy is not to be construed as any lack of confidence in conclu-sions regarding the environmental risks of accidents expressed in any previously issued Statements, nor, absent a showing of similar special circumstances, as a basis for opening,
-1/Tr. 9 .
reopening, or expanding any previous or ongo-ing proceedina.
45 Fed. Reg. at 40103 (emphasis added; footnote omitted).1/
TexPIRG may believe that it is mechanistic to uti-lize the issuance of an FES as the cutoff point in those proceedings in which a consideration of Class 9 accidents might be warranted. The Commission appreciated this concern and provided for two different exceptions to an otherwise absolute rule. First, an ongoing proceeding may be opened or reopened if "special circumstances" exist.1! Second, the Staff may " identify additional cases that might warrant early consideration of either additional features or other actions which would prevent or mitigate the consequences of serious accidents."1!
To the extent that TexPIRG is arguingS ! that "special circumstances" exist for ACNGS which require a reopening and
-1/TexPIRG goes to the extreme of arguing that there is no final environmental statement for purposes of the Interim Policy Statement until an initial decision has been ren-dered. This argument, if accepted, would clearly vitiate the carefully staged transitional mechanism incorporated into the Interim Policy Statement. Thus, the above cited admonition that the Statement of Interim Policy should not be used "as a basis for opening, reopening, or expanding any . . . ongoing proceeding" would be rendered virtually meaningless.
2/The "special circumstances" are similar to those which would have warranted a consideration of Class 9 accidents under the Proposed Annex. See 45 Fed. Reg. at 40103.
3!45 Fed. Reg. at 40103. This exception appears to be similar to the Commission's directives in OPS and Black Fox, supra.
2'/See Motion, pp. 3, 5-7.
expanding of the ACNGS FES, its arguments must be re ected.
The Sta f f has "not determined that the Allens Creek plant or site is so exceptional that it should be proposed to the Commission as a situation requiring waiver of the Commission's policy" under Offshore Power Systems.l! The conclusion is no different under the special circumstances criterion in the Statement of Interim Policy. Thus, a consideration of Class 9 accidents is not warranted at this stage of the proceeding.
Finally, policy reasons militate against the interpre-tation of the Statement of Interim Policy which is being prof-fered by TexPIRG. As discussed above, preparation of a Class 9 accident analysis for the Allens Creek FES would entail a substantial disruption of the ACNGS proceeding. The Commis-sion clearly intended to avoid this type of disruption in promulgating the Statement of Interim Policy. Further, it is unlikely that a consideration of Class 9 accidents would sig-nificantly affect the merits of the NEPA analysis contained in the existing final environmental statements for ACNGS, since, as the Commission itself noted, the " change in policy is not to be construed as any lack of confidence in conclusions regard-ing the environmental risks of accidents expressed" in an FES such as that for ACNGS.S!
Finally, the absence of a consideration of Class 9 accidents in the FES for the ACNGS construction permit does not mean that 1/"NRC Staff Re,sponse to New Contentions 48 and 49 and an Amendment to Admitted Contention 17 Submitted by Inter-venor John F. Doherty," dated April 28, 1980, p. 11. See also the Licensirc Soard's " Order" of May 15, 1980, p. 5.
2 4 5 Fed. Reg. at 40103.
the plant will escape such consideration, since the Staff will be obliged to consider Class 9 accidents in the supple-mental FES for the ACNGS operating license review.l! Thus, there is no compelling reason to order the Staff to consider Class 9 accidents at this stage of the Allens Creek proceedings.
C. NEPA Does Not Require a Consideration of Class 9 Accidents TexPIRG claims that the FES for ACNGS will not be in com-pliance with NEPA unless it contains a consideration of Class 9 accidents. TexPIRG derives such a requirement from Cume sarces:
(1) NEPA's " full disclosure" requirement which mandates the consideration of Class 9 accidents; (2) CEQ regulations which require a " worst case" analysis in environmental statements; and (3) a letter from CEQ Chairman Gus Speth, dated March 26, 1980, recommending consideration of such accidents in the Com-mission's environmental impact statements.
- 1. Apparently, TexPIRG believes that NEPA requires the Staff to consider Class 9 accidents even in those proceedings in which an FES has been issued prior to the ef fective date of the State-ment of Interim Policy. Clearly, this interpretation does not comport with that of the Commission, since the Statement of In-terim Policy does not authorize the Staff to consider Class 9 accidents in such proceedings. In fact, the Commission had con-sidered substantially the same arguments at the time it adopted
-1/Tr. 44-45, 70-88.
the Statement of Interim Policy.1/ By promulgating the Statement of Interim Policy with knowledge of the legal arguments which might be advanced against it, the Commission has rejected the legal theories espoused by TexPIRG. Since the Licensing Board is bound by the Commission's determinations, TexPIRG's Motion on this ground must be denied.
Undoubtedly, the Commission's interpretation of NEPA is correct. Although NEPA is a full-disclosure law, it also em-bodies a " rule of reason." NEPA does not compel a federal agency to consider remote and speculative environmental impacts of an agency action. For this reason, the courts have consistently held accidents need not be considered under NEPA. Carolina Environmental Study Group v. United States, 510 F.2d 796 (D.C.
Cir. 1975); Porter County Chapter v. AEC, 533 F.2d 1011 (7th Cir. 1976), cert. den., 429 U.S. 945 (1976); Aeschliman v. NRC, 547 F.2d 622 (D.C. Cir. 1976), rev'd. on other grounds, Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, 435 U.S. 519 (1978).
- 2. Despite the position of the Commission and the judicial decisions cited above, TexPIRG apparently believes that the Commis-sion will violate NEPA unless it complies with the regulations of CEO. However, nowhere does NEPA confer power upon the CEQ to promulgate regulations which are binding upon other Federal agencies.
See 42 U.S.C. S 4344. Thus, a failure of the NRC to honor CEQ re-gulations cannot' constitute a violation of NEPA. Essentially, 1/These similar arguments were analyzed in "NRC Compliance with CEQ NEPA Regulations," SECY-79-305, May 1, 1979, pp. 12-19.
TexPIRG's argument is that, nevertheless,the President has directed the NRC to comply with the CEQ regulations.
We si rait that the President is not authorized to direct an independent regulatory agency in the conduct of its substantive responsibili-ties.1/ Even if he were so authorized, section 3 of Executive Order No. 11991 only grants CEQ the power to promulgate "regula-tions to Federal agencies for the implementation of the procedural provisions" of NEPA. (emphasis added) As a basis for its argument that the NRC is compelled to consider Class 9 accidents, TexPIRG relies principally upon 40 C.F.R. S 1502.22(b) of the CEQ's re-gulations, which requires Federal agencies to perform a " worst case analysis. " Such a requirement describes what must be consi-dered, and not the method by which the consideration must proceed.
Thus, the requirement contained in S 1502. 22 (b) is manifestly sub-stantive in nature. Since Executive Order No. 11991 only confers
-1/ TexPIRG cites Exec. Order No. 11991, 3 C.F.R. 123 (1977), re-printed in 42 U.S.C. S 4321, as the source of CEQ's power to establish regulations which the NRC is compelled to obey.
However, the Nuclear negulatory Commission is an indepen?ent regulatory commission. Energy Reorganization Act of 1974, S 201, 42 U.S.C. S 5841. "Its duties are performed without executive leave Cnd, in the contemplation of the statute, must be free from executive control." See Humphrey's Exe-cutor v. United States, 295 U.S. 602, 628 (1935). In the absence of explicit statutory authorization, the principle of separation of powers forbids the President from exercising control over an independent regulatory agency. Id., Wiener
- v. United States, 375 U.S. 349 (1958). Since NEPA does not give the President the authority to issue executive orders requiring the Commission to comply with the regulations of CEQ, Executive Order No. 11991 is not binding upon the Com-mission, and the scope of the Order should be narrowly in-terpreted as spplying only to executive agencies. Moreover, a narrow interpretation would not be inconsistent with the Order, since section 2 of the Order, states that agencies are bound by CEQ regulations, "except where compliance would be inconsistent with statutory requirements."
upon CEQ the authority to issue procedural regulations, the power to promulgate S 1502.22(b) is beyond the jurisdiction of CEQ and the NRC is not bound to comply with the substantive provisions of this section.
- 3. Nor does the Speth letter mandate a different result.
That letter strongly urged a change in the Commission's policy so as to consider Class 9 accidents in it.1 environmental impact statements and transmitted a report and recommendations of the Environmental Law Institute to the same effect. Of course, these recommendations were not binding upon the Commission as a matter of law. The letter and report were before the Commission when the Commission adopted the Statement of Interim Policy. To be sure the Statement does represent a change in policy, however, not every recommendation of Mr. Speth or of the report is reflected in the Statement.
It is clear that the decision not to reopen previously issued environmental impact statements was deliberate. In a memorandum from the Director, Office of Nuclear Reactor Regulation to the Chairman of the Commission, dated March 28, 1980, the following was stated:
The final part of the report presents a number of recommendations for improving the content of EIS accident an alyse s , as well as methods for implement-ing the recommendations. I am happy to note that a recent staff paper transmitted to the Commission (SECY- 80-131) contains a staff proposal that is very largely in accord with the recommendations given in the CEQ report. A detailed listing of these, vis-a-vis the redent staff paper, is attached. A major point of disagreement should be noted, however. The CEQ report recommends that a supplementary EIS con-taining a revised accident analysis treatment should
be prepared for every operating plant, with priority given to those plants located near high populations, having other unique features making them " higher risk,"
or undergoing license amendments. The staff has recom-mended that, absent a showina of special circumstances the discussion in previously issued EIS's not be re-opened.1/
The Statement of Interim Policy expressly reflects the Staff's recommendation.
IV. Conclusion Since an FES has been issued for ACNGS, the Statement of Interim Policy does not require the Staff at this time to issue a supplemental FES which considers Class 9 accidents at Allens Creek. Additionally, neither NEPA nor any other authority re-quires such a consideration. Consequently, the Applicant res-pectfully submits that TexPIRG's Motion should be denied.
1! Memorandum for Chairman Ahearne from Harold R. Denton, Office of Nuclear Reactor Regulation, thru the Executive Director for Operations.
Subject:
Environment Law Institute Report of February 4, 1980, on the Adequacy of N2C's Environmental Analysis of Nuclear Accidents, pp. 1-2 (March 28, 1980)
(emphasis added) .
Respectfully submitted,
/
OF COUNSEL: ack R. New2. ant Steven P. Frant:
LOWENSTEIN, NEWMAN, REIS, David B. Raskin AXELRAD & TOLL 1025 Connecticut Avenue, NW 1025 Connecticut Avenue, NW Washington, DC 20036 Washington, DC 20036 J. Gregory Copeland BAKER & BOTTS C. Thomas Biddle, Jr.
3000 One Shell Plaza 3000 One Shell Plaza Houston, TX 77002 Houston, TX 77002 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY
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) K I,+ \ 8 HOUSTON LIGHTING & POWER COMPANY ) Docket No. 50-466
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(Allens Creek Nuclear Generating )
Station, Unit 1) )
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CERTIFICATE OF SERJIC_E_
I hereby certify that copies of the foregoing:
APPLICANT'S RESPONSE IN OPPOSITION TO TEXPIRG'S CLASS 9 MOTION was served upon the following persons, by hand *, or by deposit in the United States Mail, first class postage prepaid, this 7th day of August, 1980.
N David B. Raskin
- Sheldon J. Wolfe, Esq., Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 Richard Lowerre, Esq.
Assistant Attorney General
- Dr. E. Leonard Cheatum for the State of Texas Route 3, Box 350A Watkinsville, Georgia 30677 P. O. Box 12548 Capitol Station Austin, Texas 78711
- Mr . Gustave A. Linenberger Atomic Safety and Licensing Hon. Charles J. Dusek Board Panel Mayor, City of Wallis U.S. Nuclear Regulatory Commission P. O. Box 312 Washington, DC 20555 Wallis, Texas 77485
- Chase R. Stephens Hon. Leroy H. Grebe Docketing and Service Section County Judge, Austin County Office of the Secretary of P. O. Box 99 the Commission Bellville, Texas 77418 U.S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Appeal Board ,
Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555
- Steve Schinki, Esq. James M. Scott, Jr.
Staff Counsel 13935 Ivy Mount U.S. Nuclear Regulatory Sugar Land, Texas 77478 Com.ission ,
Washington, DC 20555 William Schuessler 5810 Darnell Joh.: F. Doherty Houston, Texas 77074 4327 Alconbury Street Houston, Texas 77021 Stephen A. Doggett, Esq.
P. O. Box 592 Madeline Bass Framson Rosenberg, Texas 77471 4822 Waynesboro Drive Houston, Texas 77035 Bryan L. Baker 1923 Hawthorne Robert S. Framson Houston, Texas 77098 4822 Waynesboro Drive Houston, Texas 77035 J. Morgan Bishop Margaret Bishop Carro Hinderstein 11418 Oak Spring 609 Fannin Street Houston, Texas 77043 Suite 521 Houston, Texas 77002 W. Matthew Perrenod 4070 Merrick D. Marrack Houston, Texas 77024 420 Mulberry Lane Bel.'. aire , Texas 77401 TexPIRG Att: Clarence Johnson Brenda McCorkle Executive Director 6140 Darnell Box 237 U.C Houston, Texas 77074 University of Houston Houston, Texas 77004 F. H. Potthoff, III 7200 Shady Villa, #110 Houston, Texas 77080 Wayne E. Rentfro P. O. Box 1335 Rosenberg, Texas 77471 A j
.: