ML19305C508
| ML19305C508 | |
| Person / Time | |
|---|---|
| Site: | 07001308 |
| Issue date: | 02/29/1980 |
| From: | Rooney M, Szwajkowski R GENERAL ELECTRIC CO. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8003310001 | |
| Download: ML19305C508 (18) | |
Text
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e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IN THE MATTER OF
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GENERAL ELECTRIC COMPANY
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Docket No. 70-1308
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-(GE Morris Operation Spent
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Fuel Storage Facility)
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STATEMENT OF POSITION OF GENERAL ELECTRIC COMPANY ON THE AMENDED CONTENTIONS OF THE STATE OF ILLINOIS This statement constitutes the position of General Electric Company
(" General Electric") concerning the Amended Contentions of the People of the State of Illinois (the ' State")
filed in the above-captioned matter on February 14, 1980.
GENERAL OBJECTION TO ALL CONTENTIONS G"Teral Electric objects to each contention 1 through i
11 inclusive, on the grounds that each should be stricken for failure to meet the requirements of 10 C.F.R. 52.714(a) because each contention lacks specificity and fails to set forth any basis.
SPECIFIC OBJECTIONS TO AMENDED CONTENTIONS CONTENTION 1 STATES:
1.
The amended Consolidated Safety Analycis Report (hereinafter "CSAR") prepared by the Applicant does not provide reasonable assurance, as required by 42 U.S.C.
S2232(a) and 10 CFR Parts 40, 50, & 70 8003 310 hoot
that the continued operation of the Morris facility will not endanger the health and safety of the public due to accidental release of radioactivity.
The retraction of the risk analysis of the Rasmussen Report, WASH 1400, and the acknowledgement by the Nuclear Regulatory Commission Staff that Class 9 accidents are indeed a possibility
- indicate that accurate accident analyses are necessitated for nuclear facilities of all types.
Without further adequate risk analysis the public cannot be assured that continued storage of spent fuel at Morris will not be hazardous to the public health and welfare.
The CSAR does not adequately describe and analyze the risk of all credible accidents and the consequences thereof including:
(a) the effects on the Morris facility of a Class 9 accident at the adjacent Dresden Nuclear Reactor; (b)
The consequences of simultaneous accidental radioactive releases from the Dresden Nuclear Reactor and the Morris Spent Fuel Storage Facility; 1
(c)
The risks and consequences of the re-lease of radioactive elements in excess of Part 20 regulations as a result of any credible accidental occurrence at the Morris facility including, but not limited to, tornado related incidents; "See Statement of Mattson, NRC, TMI Task Force In The Matter of Public Service Company of New Jersey.
(Salem Nuclear Plant Spent Fuel Pool Expansion) ASLB-Docket No.
(sic)."
RESPONSE
To the extent that the introductory paragraphs state that the i
CSAR does not meet the requirements of 10 C.F.R.,
Part 50 it should be stricken as irrelevant because that Part relates to the licensing of production and utilization facilities and is not applicable to the Morris facility.
Moreover, the State's assertion <
is factually inaccurate in that the body of the Rasmussen Report was not retracted by the NRC, only support for its Executive Summary was withdrawn.
Indeed, the Commission has stated:
"With respect to the component parts of the study, the Commission expects the Staff to make use of them as appropriate, that is, where the data base is adequate and analytical techniques permit.
Taking due account of the reservations expressed in the Review Group Report and in its presentation to the Commission, the Commission supports the extended use of probabilistic risk.
assessment in regulatory decision-making."
(NRC Statement On Risk Assessment And the Reactor i
Safety Study Report (WASH 1400) In Light Of the Risk Assessment Review Group Report, p.
4, January 18, 1979.)
Finally, Chapter 8 of the CSAR sets forth analyses of all credible accidents.
The State fails to identify any postulated accident, Class 9 or otherwise, which is inadequately analyzed in the CSAR.
Subsection (a) of this contention is vague and lacks the requisite specificity in that it fails to identify a postulated accident which has not been adequately analyzed.
Furthermore, the applicable regulations do not require any analysis of an accident at Dresden for relicensing the Morris facility. /
Subsection (b) should also be stricken for the same reasons.
Additionally, this subsection is inadequate because no inter-relationship between the Dresden and the Morris facilities has
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This Board should note that in the recent proceeding relating to the expansion of storage capacity at the Zion site, in which the State was also a party, the " effects of a Class 9 l
accident" at that facility was neither submitted by the State l
as a co."tention nor considered as such at the hearing.
In the l
Matter of Commonwealth Edison Company (Zion Station, Units 1 and 2), Docket Nos. 50-295, and 50-304, Initial Decision, February 14, 1980..-
been stated.
Proximity is not an adequate basis to establish relevancy.
Subsection (c) should also be stricken because the CSAP.
analyzes the consequences of all credible accidental occurrences, including tornado related accidents.
The State does not 4
identify accidental occurrences not analyzed nor any defects in the analyses _provided.
To the extent that this contention,otherwise states that the CSAR fails to consider adequately the health and safety of the public it must be stricken as vague and without support.
CONTENTION 2 STATES:
2.
The CSAR does not provide adequate assessment of credible risks of sabotage related events and the consequences thereof.
RESPONSE
This contention, almost identical to the previously with-drawn contention C1, should be stricken because the Morris facility is in compliance with 10 C.F.R. S 73.50.
The contention, to the extent that it is an attack upon the validity of that existing regulation, is improper and should be stricken pursuant to 10 C.F.R. S 2.758.
While not required to do so, General Electric has nevertheless conducted a sabotage analysis.
(NEDM-20682, November 1, 1974.)
Additionally, this contention is vague and lacks any basis in that the State has neither specified any deficiency in the analyses nor identified any " sabotage related event" to be analyzed..
CONTENTION 3 STATES:
3.
The CSAR underestimates or does not state fully the projected effects on the health of personnel, their families and the public from exposure to radia-tion:
a)
The CSAR does not state total whole body exposure to occupational personnel for the expected life of the Morris facility; b)
The CSAR does not project expected genetic effects on personnel or to the general population caused by such whole body exposures; c)
The CSAR includes only irradiated fuel and contaminated basin water as radiation sources.
Other tanks and pipes should be included.
(See G.E.
" Status of Existing Licensing" 2/21/79, Exceptions to Com-pliance With Regulatory Guide 3.44 S 7.2
" Radiation Sources".)
d)
The CSAR does not account for additional radiation exposure to occupation personnel during testing or experimentation with fuel disassembly, dry storage or compac-tion, of all which are projected for the near future at Morris.
e)
The CSAR does not address the absence of effective effluent monitoring.
i.
There are no devices to measure flows of air.
ii.
There is no routine procedure to measure Kr 85 (See G.E.
" Status of Existing Licensing" 2/21/79, item 16.)
RESPONSE
The introductory paragraph is vague in that it fails to identify the health effects which the CSAR underestimates or does not fully state.
Additionally, there is no specification as to the basis for consideration of such effects on the " families" of personnel.
3 (a) and 3(b).
The whole body exposure on occupational personnel has been determined in accordance with 10 C.F.R.,
Part 20 and is within the limitations contained in that part.
See CSAR, S 7.5.
Furthermore, by referring to the " life of the facility" this contention attempts to raise matters beyond the scope of the Application and should be rejected.
To the extent that these subsections allege that those standards are in-adequate they constitute an impermissible attack upon existing regulations and, accordingly, should be stricken pursuant to 10 C.F.R. S 2.758.
3(c).
This contention is inaccurate and should be stricken because documentation submitted supporting the license renewal contains an analysis of the total radiation exposure to employees irrespective of the source.
See " Operating Experience - Irradiated Fuel Storage at Morris Operation," NEDO - 20969B2/B3, January, 1979 S 4.
No support for any allegation that this discussion is in-adequate is provided.
Finally, all radiation exposure levels are well within the limits established by 10 C.F.R. Part 20.
3(d).
This contention should be stricken as irrelevant to the issues before the Atomic Safety and Licensing Board with regard to the pending license renewal application.
Testing and experimenting with fuel disassembly and dry storage or compaction are not contemplated in the pending license application.
3 (e).
This subsection should be stricken because the Morris facility is in compliance with 10 C.F.R.,
Part 20 and more specifi-cally 10 C.F.R. 5 20.106.
To the extent that this subsection is I
an attack upon the validity of existing regulations, it la im-proper and should be stricken pursuant to 10 C.F.R. S 2.758.
With respect to subsection 3 (e) (i), the Morris facility con-tinuously measures and records the ventilation exhaust air flow rates (stack air flow).
See CSAR Table 5-2.
Although the Morris facility is not required to measure the flow of en-vironmental diluting air, that information is measured on a continuing basis at the Dresden Meteorological Tower and reported to Morris on a monthly basis or upon request.
See Operating Experience Report, NEDO 20969B2/B3 Ch. 5 and Appendices A/B2 (January 1979).
With respect to subsection 3 (e) (ii), while the Morris facility does not routinely measure KR 85 appropriate analysi.s has established that KR releases are well within applicable limits.
CSAR $7.3.3.
No support for any allegation that this discussion is inadequate is provided.
CONTENTION 4 STATES:
4.
The CSAR is incomplete in that it does not discuss prospective plans (in 1980) for testing of fuel, reconfiguration of storage, experimentation of storage modes, and other innovative techniques which General Electric has planned in cooperation with other private corporations and Government agencies.
i
- / The GEIS On Handling and Storage Of Spent Light Water Power Reactor Fuel reached a similar conclusion:
" [The NFS] experience indicates that even the rupture of a number of fuel elements in the storage pool would not cause a release of 85 Kr'in sufficient quantities to be measurable off-site."
NUREG-0575, Vol. 1, S 4.2.2.2 at p.
4-15 (August, 1979).
RESPONSE
This contention should be stricken as irrelevant to the issues before the Atomic Safety and Licensing Board because testing of fuel, reconfiguration of storage, experimentation of storage modes and other innovative techniques are not the sub-ject matter of the pending license renewal application.
CONTENTION 5 STATES:
5.
The decommissioning and emergency plans sub-mitted by the Applicant as part of its application cannot be adequately jrdged at this time.
With the assistance of the NRC staff, the Applicant has attempted to adapt its CSAR to the proposed 10 C.F.R.,
Part 72 which they presume will eventually regulate Away From Reactor storage.
However, as the regulation has not yet been adopted by the Commission it is now impossible to judge whether the decommissioning and emergency plans will be adequate to conform to the finally approved regulation.
The NRC Staff is well aware that the Decommissioning plan presented by Applicant in the CSAR may demand revision.
See letter of March 1, 1979 to D. M. Dawson, Manager, Licensing &
Transportation, Nuclear Energy Programs Division, General Electric Co. from Leland C. Rouse, Acting Chief Fuel Reprocessing and Recycle Branch, Division of Fuel Cycle and Material Safety, NRC, wherein the Decommis-sioning plan for Morris is referred to and it is stated:
It should be pointed out that new decommission-ing criteria for nuclear facilities are now being developed.
When issued, these criteria may require revision of the plan.
Until the final promulgation of Part 72 the Decommis-sioning Plan must be considered inadequate.
RESPONSE
The CSAR and supporting documentation contain decommis-sioning and emergency plans in accordance with all presently applicable regulations.
See CSAR Appendix A.7 and Radiological Emergency Plan For Morris Operation, NEDE 21894 (June 1978).
l No support for any allegation that these plans are inadequate is provided.
To the extent that this contention states that the pending license renewal application is subject to the draft rules proposed in 10 C.F.R., Part 72, it should be stricken as irrelevant because those draft rules have no bearing upon the pending license renewal application.
General Electric will revise its decommissioning and emergency plans to conform to any changes in regulations to the extent that is required by law.
As presently constituted this contention is speculative as to what those changes may be.
CONTENTION 6 STATES:
6.
The Decommissioning Plan proposed in the CSAR is inadequate for the following reasons:
a)
There is insufficient determination of ultimate decontamination and decommissioning costs.
Costs have not been adjusted for inflation for the projected time of decon-tamination.
CSAR pp. A7-13, A7-14.
With-out an accurate cost assessment GE cannot make a valid commitment to meet de-commissioning costs.
b)
There is insufficient assurance that the applicant will be financially capable to meet decontamination and decommissioning costs.
Other than a general statement regarding GE's present relative solvency there is no verifiable financial statement to show GE can meet future costs as is required by 10 C.F.R. S 70.22(a).
A bond or other assurance of financial capability should be required to provide a guarantee that decontamination and decommissioning costs will be fully covered.
c)
There is no contingency planning for emergency termination and decommissioning.
CSAR S A.7.2.1.
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d)
There is no consideration of possible perpetual care and maintenance due to incomplete decontamination or decommis-sioning including:
1.
Inability to dispose of LAW vault material (See G.E.
" Status of Licensing" par. 19);
ii.
residual contamination of waste vaults or other stationary parts of the facility; i
iii.
ground water contamination which would require maintenance to prevent leaching offsite; iv.
unavailability of offsite disposal facilities for dismantled facility and wastes.
RESPONSE
6(a).
This contention is incorrect and should be dismissed for want of basis.
The cost of decommissioning under the present decommissioning plan, can be projected to any future date by use of appropriate escalation factors.
Under applicable regula-tion", General Electric's decommissioning plan accurately asse.9ses the cost of decommissioning.
No support for any allega-tion that this assessment is inaccurate is provided.
6(b).
This contention should be stricken because there is no showing or support for the contention that General Electric is not financially capable of decommissioning the Morris facility.
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The Morris Operation is licensed in accordance with 10 C.F.R.,
Parts 30, 40, and 70 and is in compliance with those Parts.
No bond or other assurance of financial capability is required under 1
existing regulations and, to the extent that this contention attacks. those regulations, it should be stricken pursuant to 10 C.F.R. S 2.758.
6 (_c).
This contention is vague and incomprehensible in that the phrase " emergency termination and decommissioning,"
is undefined. Moreover, this subsection should be stricken because i
there is no regulatory requirement that the CSAR contain con-tingency planning for emergency termination and decommissioning.
It, accordingly, should be stricken pursuant to 10 C.F.R.
S 2.758 as an impermissible attack on existing regulations.
6(d).
This subsection should be stricken as an impermis-4 sible attack upon existing regulations pursuant to 10 C.F.R.
[
S 2.758 because General Electric is not required to determine responsibility for the perpetual care of the Morris facility l
after decommissioning.
More importantly, there is no reason to believe that perpetual care of the decommissioned facility will be re-quired..See CSAR, Appendix A.7, S A.7.4.2.
Subpart (i) through (iv) are factually incorrect and inaccurate and should be dis-l missed for want of basis:
(i) material from the LAW vault can-be disposed under current regulations and procedures at existing licensed facilities, for example, Beatty, Nevada and Hanf ord, z Washington.
(ii) currently available techniques, in-cluding detergent scrubbing and acid etching, exist to decontami-
'nate the vaults (see CSAR, Appendix A.7); (iii) ground water or perched water contamination has been demonstrated not to occur 4
i (see CSAR, Appendices B.10 and B.12; SS 8.3.1.1 and 8.3.12; i
~ 1 i
see also NEDO-20969B3, supra, S 5.3); and (iv) in view of the decision by the NRC to address the question of long-term or permanent storage and disposal of nuclear waste in a generic proceeding.,
'this subsection should not be considered by this Atomic Safety and Licensing Board (see Resp'onse to Contention 9),
i CONTENTION 7 STATES:
7.
The Emergency plan in the CSAR is inadequate in that:
a) it does not specify emergency procedures such as that required for unloading the spent fuel pool and transporting or storing irradiated fuel.
Figure 9-4
" Emergency Plan Relationships for Morris Operation", NEDO-21326C, January 1979 supplement to the CSAR includes " emergency transportation of irradiated fuel" as a concept, but nowhere is this concept developed.
b)
There is no reference to tests or other means by which it can be determined that the existing emergency plans are adequate.
Adequate test programs of both communica-tions systems and procedures should be documented prior to licensing.
RESPONSE
7(a).
This contention should be stricken as irrelevant because, under existing regulations, there is no requirement that General Electric prepare an Emergency Plan for unloading the spent fuel pool and transporting or storing the fuel. / The subsection'is, accordingly, an impermissible attack upon the validity of existing regulations and should be stricken pursuant to 10 C.F.R. S 2.758.
Additionally, the State fails to specify any circumstances under which the pool would be required to be
-*/ The State has both misquoted and misconstrued Figure 9-4.
That figure; refers to" Emergency Plan Transportation of Irradiated Fuel" and relates to responses to accidents which might occur during the transportation of irradiated fuel. -
unloaded or the fuel transported on an emergency basis.
7(b).
The documentation supporting the pending license renewal application adequately addresses this conten-tion.
See NEDE-21894, S 8,
" Maintaining Emergency Preparedness."
No support for any allegation rhat this discussion is inadequate is provided.
CONTENTIO'l 8 STATES:
8.
The discussion of emergency planning in the CS1.R is inadequate in that there is no mention of an evacuation plan that would be put into effect should an.iccident occur at Morris or Dresden which required evccuation of occupational personnel and/or nearby residents.
Although Appendix 3 of NEDE 21894 lists
" Evacuation and Personnel Accountability" under
" General Personnel Actions" there does not appear to be any specific evacuation procedure included in the
" Radiological Emergency Plan for Morris Operation" of June 1978 recently submitted to supplement the CSAR.
It has been proposed that nuclear facilities in highly populated areas may face shut down if adequate plans are not made to evacuate residents in a 10-mile radius of the facility.
Morris is located near Joliet, a city of 80,000 people, 50 miles south of Chicago.
The Applicant should be required to formulate an updated evacuation plan or include in the CSAR an emergency plan that would service Morris.
RESPONSE
This contention should be stricken because under applicable regulations General Electric is not required, nor indeed authorized, to prepare and implement an emergency evacuation plan for other than its own personnel and facility.
To the extent that this contention is an impermissible attack upon existing regulations, it should accordingly be stricken pursuant to 10 C.F.R. S 2.578.
Moreover, specific procedures for emergency planning are contained in Morris Operation Instructions and other documents, but not in the CSAR in accordance with NRC practice.
See CSAR S 9.
CONTENTION 9 STATES:
9.
The applicant has failed to analyze the relevant safety and health issues.from the perspective of long-term storage.
Although the license applica-tion foresees a licensing period of 20 years, there is no assurance that fuel will not, of necessity, be left for a longer period at Morris.
Prior to a finding of the Commission that storage at Morris beyond 20 years will be unnecessary because govern-ment facilities, other than Morris, will then be available for the existing fuel, the license applica-tion is incomplete without a long-term analysis.
RESPONSE
This contention should be stricken as irrelevant and in-appropriate for consideration by this Atomic Safety and Licensing Board in view of the decisions by the NRC to address the question of long-term or permanent storage or disposal of nuclear waste in a generic proceeding.
See Minnesota v. NRC; Nos. 78-1269, 78-2032 (D.C. Cir. May 23, 1979); Virginia Electric & Power Co.,
(North Anna Power Station, Units 1 and 2) (August 17, 1979).
In instituting the generic proceeding, the Commission stated:
"The Commission has decided, however, that during this proceeding the issues being considered in the undertaking should not be addressed in individual licensing proceedings.
These issues are most appropriately addressed in a generic proceeding of the character here envisaged."
44 Fed. Reg. 61373. (Emphasis supplied.)
CONTENTION 10 STATES:
10.
The Design Earthquake data in the CSAR are insufficient to meet proposed regulation S 72.66.
Morris is designed to 0.29 (sic) and the proposed i
regulation calls for a " peak horizontal ground accelera-i tion of not greater than 0.25 g....."
The applicant has not satisfied the proposed regulation by establishing the CSAR site specific "g value" by the procedures of 10 C.F.R. Part 100.
RESPONSE
This contention should be stricken as irrelevant because the draft rule proposed as 10 C.F.R.,
Part 72, specifically S 72.66 is not in effect and, accordingly, has no bearing upon the pending license renewal application.
Moreover, proposed 10 C.F.R.
S 72.66(a) provides that a site with a peak horizontal ground acceleration of not greater than 0.25 g shall be deemed tc be suitable.
The Morris facility site is located in a region in which the expected peak horizontal ground acceleration does not exceed 0.20 g, / less than that specified by proposed regulation S 72.66(a).
Since it meets this criterion even under the proposed regulation the CSAR for the Morris facility need not utilize the procedures in 10 C.F.R. Part 100.
CONTENTION 11 STATES:
11.
The Nuclear Regulatory Commission has an obligation under the National Environmental Policy Act (NEPA) 42 USC 4332 (1969) to issue an environ-mental impact statement which will account for normal operation of the Morris facility and for the environ-mental impacts of:
a.
emergency evacuation and its consequences b.
decommissioning and/or residual contami-nation probabilities c.
testing of fuel in the spent fuel pool *
"/ See, Algermissen and Perkins, USGS, Open File Report 76-416,
-'1976, "A Probabilistic Estimate of Maximum Acceleration in Rock in the Contiguous United States."
i 1 l L
d.
dry storage of fuel in the canyon
- e.
expansion of the spent fuel pool
- f.
contraction of fuel assemblies for compact storage
- g.
storage of waste products or tools from decontamination of the Dresden reactor h.
any other proposed activity, other than simple storage of spent fuel in water
RESPONSE
This contention should be stricken as premature at thi; time.
A license renewal application does not necessarily re-quire that the NRC prepare an environmental impact statement
("EIS").
10 C.F.R.
S 51.5.
Whether an EIS is required depends on the particular circumstances.
10 C.F.R. S 51.5.
It is at the discretion of the NRC, guided by the 40 C.F.R.
S 1500.6, and based upon the findings of an environmental impact evaluation prepared by the NRC Staff to determine whether an EIS should be prepared.
Since that staff evaluation apparently has not been com-pleted, no decision can be reached as to whether preparation of a negative declaration supported by an Environmental Impact Appraisal or preparation of an EIS is more appropriate.
General Electric espectfully submits, however, that a negative declara-tion will be sufficient as it was in prior licensing actions relating to the Morris Operation.
Moreover, General Electric submits that none of the subsections of this contention raise issues which necessitate the preparation of an EIS.
To the extent that subsections (a) and (b) relate to the pending license renewal application they have been adequately addressed in the CSAR and..
i s
other supporting documentation.
Subsections (c) through (h) inclusive raise issues and questions totally 'aeyond the scope of the pending license application and should, accordingly, be stricken as irrelevant.
Since each and every amended contention of petitioner, the People of the State of Illinois, is invalid, General Electric submits that each should be stricken from the pending license renewal proceeding and requests that this Atomic Safety and Licensing Board do so.
DATED:
February 29, 1980.
Respectfully submitted, GENERAL ELECTRIC COMPANY By:
Ronald W.
Szwajkowski Matthew A.
Rooney Its Attorneys OF COUNSEL:
MAYER, BROWN & PLATT 231 South LaSalle Street Chicago, Illinois 60604 (312) 782-0600
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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GENERAL ELECTRIC COMPANY
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Consideration of Renewal of
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Docket No. 70-1308 Materials License No. SNW-1265 )
Issued to GE Morris Operation
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Fuel Storage Installation
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CERTIFICATE OF SERVICE The undersigned hereby certifies that he served a copy of the STATEMENT OF POSITION OF GENERAL ELECTRIC COMPANY ON THE AMENDED CONTENTIONS OF THE STATE OF ILLINOIS, in the above-captioned proceeding on the following persons by causing the said copies to be deposited in the United States mail at 231 South LaSalle Street, Chicago, Illinois, in plainly addressed and sealed envelopes with proper first class postage attached before 5:00 P.M.
on February 28, 1980:
Andrew C. Goodhope, Esq., Chairman Susan N. Sekuler, Esq.
Atomic Safety and Licensing Board George William Wolff, Esq.
3320 Estelle Terrace Office of the Attorney General Wheaton, Maryland 20906 188 West Randolph Street Suite 2315 Dr. Linda W. Little Chicago, Illinois 60601 Atomic Safety and Licensing Board 5000 Hermitage Drive Marjorie Ulman Rothschild, Esq.
Raleigh, North Carolina 27612 United States Nuclear Regula-tory Commission Dr. Forrest J. Remick Wash 1ngton, D.C.
20555 Atomic Safety and Licensing Board 305 East Hamilton Avenue Atomic Safety and Licensing State College, Pennsylvania 16801 Board Panel U. S. Nuclear Regulatory Commis-Atomic Safety and Licensing Appeal sion Panel Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Docketing and Service Section Office of the Secretary Bridget L.
- Rorem, U.S. Nuclear Regulatory Essex, Illinois 60935 Commission Washington, D.C.
20555 Ronald W.
SZwajkowski