ML19309B011
| ML19309B011 | |
| Person / Time | |
|---|---|
| Site: | Bailly |
| Issue date: | 02/26/1980 |
| From: | Vollen R VOLLEN, R.J. & WHICHER, J.M. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8004020478 | |
| Download: ML19309B011 (22) | |
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,4-February 26, 1980,
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NUCLEAR REGULATORY ComtISSION b
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BEFORE THE ATOMIC SAFETY 'AND LICENSING BOARD
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c-In'the Matter Of
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DOCKET NO. 50-367
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NORTHERN INDIANA PUBLIC
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(Construction Permit SERVICE COMPANY
)
Extension)
(Bailly Generating Station, )
Nuclear 1)
)
JOINT INTERVENORS' FIRST SUPPLEMENT TO PETITION FOR LEAVE TO INTERVENE The Board has directed that "the petitioners shall file, supplements to their petitions... which shall include
~
a list of specific contentions soug' c to be litigated in this proceeding."
(Order Setting Sp cial Pre-Hearing Conference, dated February 7, 1980, p. 3).
Porter County Chapter of the Izaak Walton League of America, Inc.; Concerned Citizens Against Bailly Nuclear Site; Businessmen for the Public Interest, Inc.; James E. Newman and Mildred Warner
(" Joint Intervenors"), by their attorneys, hereby submit their First Supplement in compliance with the Board's direction.
A number of important. issues, such as petitioners' standing, the scope of the hearing, the applicability of 10 CFR 550.55(b), many of which were first raised by the responses of NIPSCO and the Staff to the Petitions for Leave 8004020478
to Intervene',.are pending before the Board.
Joint Intervenors
~
had' hoped to address these issues, as well as listing addi-tional specific contentions sought to b'e litigated.in this proceeding, in this First Supplement.
However, in the short
, time permitted to them to prepare this Supplement, Joint Intervenors simply have been unable to do so, and shall seek to present their positions orally at the prehearing conference scheduled for March 12, 1980.
INTRODUCTION Before listing the specific contentions, in addition to those set forth or incorporated by reference in the Petition for Leave to Intervene, which Joint Intervenors seek co litigate in this proceeding, a brief statement of the background of this proceeding and of Joint Intervenors' role in it is appro -
priate.
The responses of both NIPSCO and the Secff attempt to characterize Joint Intervenors' position as seeking to re-litigate issues that have been litigated before.
In fact, just the opposite is the' truth.
None of the contentions which we seek to litigate in this proceeding has ever been the subject matter of an AEC or an NRC hearing concerning Bailly.
The facts asserted in each.of them arose after the original construction permit proceeding was concluded and while we previously have asked for hearings on some, but not all, of these contentions, we have never received one.
In each instance we have been denied a hearing, not because the contentions
. lacked merit, but because, we were told, we had chosen the ww
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wrong forum, or the wrong time, or the Staff had discretion not to hold a hearing.
Now, on NIPSCO's application for an amendment'to the construction permit, the statute requires a hearing.
It must be held now;. and, the Staff, as a party, has no discretion to deny our requests.
None of the prior petitions, requests, decisiont or rulings concerning Bailly constitute a bar to or limitation on the contentions which Joint Intervenors seek to litigate.
To the contrary, much of that history points to the conclusion that Joint Intervenors finally have found the right forum and the right time.
The statute' requires that the blinders which previously have limited the Commission's vision now be r'emoved.
CONTENTIONS Joint Intervenors conten'd that NIPSCO has not shown, and cannot show, good cause for the extension of the completion date which it seeks, as required by Section 185 of the Atomic Energy Act.
The specific contentions wnich Joint Intervenors seek to litigate in this proceeding are as follows:
1.
NIPSCO has not shown in the assertions in its letters of February 7, 1979 and August 31, 1979 or otherwise, that the failure to complete construction of Bailly by September 1, 1979 was for reasons beyond its control.
If in fact the identification by NIPSCO of September 1, 1979 as the latest completion date was based on an assumption in 1973 that.the construction permit would be issued on January 1, 1974, neither the assumption nor the ability, prior to issuance of.the construction permit on May 1, 1974, to identify a later date were beyond the control of NIPSCO.
Thus, when the alleged 1973 assumption proved to be invalid, i.e., when January 1, 1974 arrived and the construction permit had not been issued, NIPSCO could have identified a later completion date.
The factors set forth in paragraph numbered 1 of NIPSCO's letter of February 7,- 1979, do not constitute acts beyond the control of NIPSCO.
Similarly, Joint Intervenors contend that the assertion in paragraph numbered 2 of the February 7, 1979 letter that NIPSCO's ability to achieve only 14 months of construction was because of delays b'cyond NIPSCO's control is not correct.
NIPSCO's letter implies that the stay issued by the United States Court of Appeals for the ' Seventh Circuit on October 16, 1974 prevented construction until November 8,1976.
In fact, that stay ceased being a bar to construction, either in April; 1976 or at the latest in June, 1976 when the Seventh Circuit denied rehearing.
Moreover, there has been no showing, but only an assertion, that the contractors could not have been remobilized in less than two months.
Joint Intervenors contend that contractors could have been mobilized far earlier than two months after November 8, 1976.
The two month delay claimed by_NIPSCO for installation of a slurry wall certainly was not beyond its control.
There i
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a e-does not appear to be any valid reason why the slurry wall could not.have been proposed and included in the original con'struction schedule.
In paragraph numbered 2 of its February 7,1979 letter, NIPSCO.also asserts that the halt of construction since September 28, 1977 is for reasons beyond its control.
Joint Intervenors
~
contend that the contrary is true.
NIPSCO brought about the direction from the Staff to halt construction by its own actions in proposing a method,of foundation pile installation - water-jetting - never before proposed in connection with construction of Bailly and in proposing a change in the foundatiori design from one in which the piles would go to bedrock or the glacial till immediately above bedrock to one in which the fou~ndation would consist of substantially shorter piles.
Thus, the halt in construction resulted from NIPSCO's proposed changes in the design and construction of the plant, which proposed changes' were not beyond the control of NIPS CO.
(If, on the other hand,.
NIPSCO's suggestion that the Staff review, pending which construction has-been halted, was contemplated by the Safety
~ Evaluation Report, is accepted as true, it must al'so be true that the time for that Staff review would also have been known at the time of the Safety Evaluation Report, prior to the issuance of the construction permit.
Thus, under NIPSCO's theory there has been no unanticipated Staff review.)
In paragraph numbered 3 of NIPSCO's February 7, 1979, letter it is asserted that developments since the construction permit was issued "among other things, more numerous.and more detailed regulatory guides" constitute good cause for the 9
-requested extension.
NIPSCO has not identified those guides, or other things which it relies upon for its claim.
Joint Intervenors contend. that 'oefore it can be determined whether or not NIPSCO has shown good cause those regulatory guides must be id'entified; HIPSCO must demonstrate its ability to comply,with 'them; and the "other things" referred to by NIPSCO must be identified and their effects and significance must be considered. -Joint Intervenors further contend that just as NIPSCO asserted that now. regulatory standards are relevant to the issue of its requested extension, so the. issue of NIPSCO's ability to comply with those standards is relevant.
In sum, Joint Intervenors seek to litigate the issues of what in fact the reasons were for NIPSCO's failure to have completed construction by September 1, 1979, and whether.those reasons were or were not beyond the control of NIPSCO.
2.
The August 31, 1979 letter from NIPSCO asserts that 'the construction permit "should be extended to December 1, 1987, or 98 months af ter the NRC concurs in resumption of pile placement.". While there is some ambiguity, it appears that NIPSCO is seeking, in the alternative, an extension not to a Joint specific date but for a period of time after an event.
Intervenors contend that there is no authority in law for an extension of that type.
Section'185 of the Atomic Energy Act and-10.CFR 550.55(b) of the Commission's regulations contemplate an extension only of a date, not an extension for a period of time.
.Thus, to the extent that NIPSCO's application seeks _
an extension to or for anything other than a specific date,
' t' sho'ul'd be denied because no such extension is authorized i
by law.
3.
NIPSCO's letter of August 31, 1979, sets forth a. numb'er of factors which it claims justify an extension of the latest completion date. to December 1, 1987 (an extension of 99 months, b'eyond the. original' cons truction permit, as compare'd to the 64 month period' covered by the original construction period).
' Joint.Intervenors seek to litigate each of those factors and contend that those factors do not justify the extension sought by'NIPSCO in this proceeding.
For example, Joint Intervenors contend that the reasons why the NRC "still has under consideration and has not yet acted upon the information that NIPSCO has submitted regarding the driving of piles at the site" (NIPSCO letter of August 31, 1979) (still true as of the d' ate of filing this Supplement, except that the review has been expanded to include the Army Corps of Engineers), include such things as the fact that there is substantial doubt that NIPSCO's current foundation design provides reasonable assurance of protection of the public health and safety.
Among the causes of doubt about the adequacy of the currently proposed foundation design is the fact that it does not preclude or even adequately consider the possibility of substantial differential settlement among different Class I structures, between Class I' structures and non-Class I structures, and among the piping and other connections between structures or components of the facility.
Moreover,.
the currcnt foundation design proposal may be inadequate to withstand design basis seismic events, particularly in view
.of the possibility of liquefaction and in view of the deteriora-tion of load-bearing capacity of many portions of the Bailly site caused by.NIPSCO's testing, water-jetting and experimenta-tion activities.
Another of the factors asserted by NI'PSCO is'that "there are indications that NRC reviews arising from the Three Mile Island incident will extend the schedule of all plants under construction.
Delays have apparently already occurred with respect to Bailly N-1, in that members of the NRC Staff have extended the period for their review of the piles because they"had to undertake generic reviews arising from TMI.
(NIPSCO letter of August 31, 1979).
Joint Intervenors contend that the extent to which TMI has caused delays, and in what particulars with respect to Bailly, should be litigated in this proceeding.
If, as NIPSCO asserts, generic reviews arising from TMI are important enough to be a cause of delay with respect to Bailly,' Joint Intervenors contend those reviews, and their findings, and their conclusions, must be considered with respect to whether i
good cause exists for the extension of the Bailly construction permit.
In sum, Joint Intervenors seek to litigate in this proceeding all of the reasons NIPSCO asserts for its claim that it has shown good cause for its requested extension. j
s 4.
NIPSCO was authorized by the construction permit to engage in a program of site dewatering, which. the Licensing Board's Initial Decision found will have effects in the adjacent Indiana Dunes National Lakeshore, only in the period until September 1, 1979.
The extension sought by NIPSCO would permit dewatering to continue for 99 months beyond-the period autho-rized by the construction permit.
Joint Intervenors contend that dewatering during this drastically extended period will cause further and additional irreparable injury to the National.
Lakeshore.
The Licensing Board also found that " ash pond seepage is likely to offset the drawdown to some extent" (LBP-74-19; RAI 4, pp. 557, 5 89).
However, because NIPSCO has agreed with the U. S. Department of the Interior to seal the ash ponds and permit no further seepage from them into the National Lakeshore, this offsetting factor relied upon in the Initial Decision will be unavailable during the extended period of site dewatering sought by NIPSCO.
The issuance of a construc-tion permit amendment, authorizing construction dewatering over a longer period of time will cause injury to Joint Intervenors' interests by causing irreparable injury to the fragile and unique vegetation and ecosystem in the National Lakeshore.
This additional harm and injury will be suffered as a result of the extended period of construction if the extension is granted.
l Mora specifically, the additional length of construction site dewatering will adversely affect the National Lakeshore l
by-altering the water levels, water flow patterns, and water characteristics in such a manner as to cause the climination
_9
of those species of flora which presently exist in the wetland system, including the " Bog Indicator" species which contribute to the significance of the Ind'iana Dunes.
The existence of such species-is directly dependent upon the aquatic environment.
The additional period of construction sought is sufficient to cause some of the rare species, parti-cularly the'" Bog' Indicator" plants to disappear from the dunes ecosystem.
The construction site dewatering results in a cone of depression in the water table and causes the ground water to flow toward the construction site excavation, a condition that exists as long as ground water is removed from the excavation.
The result is a drying effect in the wetland system around the s'ite, and extending into the wetlands of the National
'Lakeshore for' distances of over a mile.
The construction period will extend beyond the point by which NIPSCO has agreed that the ' ash basins will be sealed, and the water mound has decayed.
Either a deficiency of water, or a surplus of water; a chan'ge in water characteristics; an 1,ncrease in the rate or direction of water ficw; dilution of the existing water; and/or replacement of the water which differs in characteristics from the water at any' specific location within the National Lakeshore, wi-ll result in changing or otherwise adversely affecting the National Lakeshore.
In sum, Joint Intervenors contend that the additional years of construction site devatering sought by NIPSCO will cause irreparable harm to the _ unique and fragile ecology of the Indiana Dunes National Lakeshore, and contend that such u
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harm precludes a finding of good cause for NIPSCO's requested extension, and seek to litigate that contention in this pro-coeding.
5.
Joint Intervenors contend that no remedial program can effectively prevent or mitigate the irreparable injury to the' Indiana Dunes National Lakeshore threatened by NIPSCO's proposed extended period of construction dewatering.
NIPSCO'r recent proposals to re-introduce replacement water from alternate sources have never been considered in public hearings
~and Joint Intervenors contend that the proposed remedial program will not prevent adverse impact upon the National Lakeshore for the following reasons, among others :
A.
The point (or points) of introduction of replacement water have not been shown to be capable of naintaining
. natural water levels within all areas of the National Lakeshore while maintaining a dry' excavation to the depth needed and during the additional period of construction time.
B.
The replacement water l'evels are not keyed to the.' natural' water table levels, or the natural interdunal pond and wetland levels, including measures to maintain the natural seasonal variations and yearly variations within all areas of the National Lakeshore.
Variations of water levels must also be timed to coincide with the timing of natural seaaonal cycles, a condition which is not considered in the proposed water i
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-replacement program and which will be exacerbated by the longer construction period..
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C.
The replacement water will. not have the same characteristics as.the: water removed.
The natural water has a low flow rate and a long term turnover during which time the water 1s conditioned by natural processes, such as organic decay. 'Further, the water characteristics vary considerably
' from one location to another, and from strata to strata, or from near surface t.o greater depths.
The water replacement program does not match these characteristics with specific locality.
D.
The removal and replacement of ground water, whatever the type or source of 5 eater, will result in an increased rate of ground water movement, which will dilute and replace the existing water without permitting the normal, slow, natural conditioning from organic processes.
The additional period of time will permit a greater dilution and/,or replacement of the natural water.
E.
Recent studies by the United States Geological Survey have indicated that an underlying strata, which previously was assumed to act as a barrier to limit the effect of site dewatering, dimfnfshes in thickness to the point of disappearance, least to the point of being ineffectual.
The result is or at that construction site dewataring will drain an aquifer not previously considered and which has a direct connection with the wetlands of the National Lakeshore considerably farther to the east than previously assumed, including the waters of Cowles Bog.
The additional period of construction time will result in~a longer. period in which such waters are subjected to artificially induced alterations, resulting in an immediate
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and severe adverse impact upon such areas of the National Lakeshore.
6.
Joint Intervonors contend that there are re.asons why construction of Bailly was not completed by September 1, 1979, which are not referred to by NIPSCO and which do not constitute " good cause" for an extension of the construction permit.
In'cluded in these reasons are the rapid and dramatic
'ecreas'e in the rate of growth o.f demand on NIPSCO's system d
following tho' issuance of the construction permit.
For example, in 1975, there was only.052% growth in peak demand over 1974, in 1978 the rate of growth was only 3.2% over 1.977,and in 1979 the peak demand was slightly less than in 1978.
At.he same time that demand was not increasing as NIPSCO previously had predicted it would, NIPSCO was adding to its electrical genera-ting capacity by building additional fossil plants.
- Thus, since 1974 NIPSCO has added approximately 1000 FM of generating capacityatitsKankake'e-Riversbteandhasannouncedplans to add still additional capacity at that site.
These two factors of reduced rate of growth and increased generating capacity led NIPSCO to the conclusion that the need for the power to be generated by Bailly was reduced, or at the very least, that the date by which~it could be claimed to be needed was substantially deferred.
Therefore NIPSCO chose not to pursue construction of Bailly as expeditiously as it might have.
This decision of NIPSCO not to build Bailly as quickly as it could was further motivated by the dramatic-increase in the estimated cost of the proposed plant, from about
$i80 million in 1974, to in excess of $1 billion currently. I
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In sum, Jot._
Intervenors contend that part of the reason why construction of Bailly was not completed by September 1,1979,' was because NIPSCO lacked the. motivation and the fi6ancial resources'to get it completed.
Joint Intervenors seek to litigate in this proceeding the reasons why NIPSCO did not ccmplete construction of Bailly by September 1, 1979.
7.
Joint Intervonors contend. that.the reason why Bailly was not completed by the latest' completion date grows out of the lack of thorough and adequate planning and design by NIPSCO, its' contractors and subcontractors.
All of the delay growing out of the Staff's direction to NIPSCO to halt pile driving.could have been avoided had NIPSCO and its contractors and subcontractors done. a more thorough and careful
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job of planning for and designing the Bailly plant.
More
.information about the geology of the site and the design of the foundation for a nuclear plant to be built cn1 that site, and the method of~constructin6 a foundation of that design could have avoided 'much of the delay in construction period since~the construction permit was issued.
In short, had NIPSCO, and its' contractors and subcontractors', known more about what they were doing, much of the delay would not have occurred.
Joint.Intervenors contend that lack'of competence does not constitute good cause for an extension of the-latest completion
'date in the construction permit.
Joint'Intervenors seek to' litigate whether NIPSCO's, or' its ' contractors ' or su: contractors ', lack of adequate study, preparation, technical knowledge,.or-design' ability,
'is' a. substantial.part of-the reason why Bailly was not,_
completed by September 1, 1979.
8.
Joint Intervenors contend that the use of pilings under the Reactor Building which do not reach bedrock will mean that all components of the Bailly plant, including water intake,. pump house, cooling tower and the several components adjacent to or in near proximity to the Reactor Building, and the piping and electrical connections between components, will be " floating" and subject to horizontal, vertical, and rota-tional differential movement.
Such differential movements would be more difficult to predict and would be exacerbated by seismic forces, particularly considering the water saturated, erratic, bearing strata.
No study of the short pilings of which Joint.Intervenors are aware has considered differential movement between all of the various station components, or of the support of the connecting piping and other systems necessary to achieve at least the stage of " safe shut down," or of the penetrations of the concrete of such piping and connec-tions.
It also appears that the review of NIPSCO's short pilings proposal being undertaken by the United States Army Corps of Engineers is limited to a review of prior studies.
Joint Intervenors contend.that comprehensive studies should be made, and that the station foundation design be changed to prevent, or compensate for, the differential movements described above, before the construction permit amendment can be granted.,
9.
Tha 1979 accident at the Thren Mile Island Unit 2 facility ("TMI") has not previously been considered in connec-tion with Bailly.
Joint Intervenors contend that TMI was a Class 9 accident; it was an accident involving significant core damage and releases of radioactivity.
It can no longer be said that the probability of such an accident occurring is so low or remote as to preclude discussion.
The determination of whether or not to grant an extension of the latest com-pletion date for Bailly must take into acco'unt, dincuss and consider an accident such as actually occurred at TMI, in terms of the consequences of such an accident, their effect on the cost-benefit balance for the facility, and measures to prevent or mitigate the occurrence or effects of such an accident.
This contention includes both environmental and safety considerations.
In light of TMI, good cause for extending the Bailly construction permit does not exist.
10.
Joint Intervenors contend that the Staff position, that it is premature to reach a decision now as to whether or not the Staff will perform a safety and an environmental evaluation (NRC Staff Response, p.18), is legally and factually insupportable.
The Staff should be ordered.to state its position and, if its position is that it is not going to perform such evaluations, it should be ordered to prepare them.
11.
Joint Intervenors contend that there are three broad categories of things that must be considered in deter-mining whether or not NIPSCO has shown good cause for its !
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requested' construction permit extension:
(a) the status of construction; (b) the reasons why construction was not
, completed; and (c) significant developments relevant to public
~ health 'and safety and to environmental considerations since the construction permit was issued.
It is only by looking at all of these areas that the Board can give meaning to the statutory requirement of " good cause."
The alternative view suggested by NIPSCO an'd the Staff, of.looking only to the reasons why construction was not completed, is unduly mechanis-tic and narrow.
It improperly reduces the statutory requirc-ment of a showing good cause for an ext'ension to a showing of good cause for failing to have completed.
We maintain that good cause requires a balancing of the three types of factors set forth above.
Here, Joint Intervenors contend that the consideration and balancing of the three eypes of factors compels.the conclusion that good cause for the 'xtension requested by e
NIPSCO does not exist.
(a)
As far as Joint Intervonors are aware, there is no dispute concerning the, factor of the status of construction.
Wi th the construction permit having expired on September 1, 1979, construction of Bailly is only approximately 1% complete.
(b)
As to the reasons why so little construction was completed by September 1, 1979, there is substantial dispute.
NIPSCO asserts that construction was not completed because of others - Joint Intervenors and the Staff; and, as set forth in prior contentions, Joint Intervenors assert that the failure i
6 wcs within.NIPSCO's control.
After the developm:nt of a' full record, the Board will be in a position to determine the reasons for the failure to have completed construction.
(c)
It is the third factor - significant developments since the construction permit was issued - which Joint Intervenors maintain is of critical importance to the " good cause" issue and which NIPSCO and the Staff apparently maintain is irrelevant to that issue.
Joint Intervenors contend that, while the final balance will vary, dependihg on the status of construction and the significance of the developments, " good cause" must consider developments in the~real world.
Among the significant developments which have occurred since the Bailly construction permit was issued on May 1,1974, and which have been considered in a hearing concerning Bailly, and which must be considered to determine whether NIPSCO has shown good cause, are those set forth in the Petition for Leave to Intervene.
In addition, the Report to the Commissioners and to the Public by the NRC Special Inquiry Group on Three Mile Island under the direction of Mitchell Rogovin, issued since the Petition was filed, must be considered.
12.
Joint Intervenors incorporate by reference and reassert herein all other contentions set forth in, or incor-porated by reference in, the Petition for Leave to Intervene.
Joint Intervenors also reserve the right to add to, delete from, modify, amend or further supplement the list of specific contentions sought to be litigated in this proceeding.
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CONCLUSION
' Joint Intervenors have complied with the Order setting Special Pre-Hearing Conference to the best of our ability in the time available.
We are certain that this First Supplement
" satisfies the requirements of (10 CFR S2,714(b)] with respect to at least one contention."
We are equaliy certain that we have been unable in the time within which we vere required to file this First Supplement to list all of the contentions which we seek to have litigated in this matter and the bases for each contention set forth with reasonable specificity, and to address other matters which would appropriately have been set forth here.
Accordingly, Joint Inter'venors urge the Board, following the March 12, 1980 prehearing conference, to enter an order establishing (1) a briefing. schedule for any legal ~ issues still unresolved at that time;. (2) a time period within which the parties should be required to exchange information, to meet informally and attempt to reach agreement on contentions to be litigated in this proceeding; (3) a time period for any formal discovery to be done; and (4) a date for a second prehearing conference to resolve any differences among the parties con-cerning contentions to be litigated, or other matters, and to establish a hearing schedule and procedures.
DATED:
February 26, 1980 Respectfully submitted s'
W Robert J/'Vollen One of the Attorneys for Joint Intervenors -
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ROBERT J. VOLLEN c/o BPI 109 N. Dearborn St.
~ Chicago, IL 60602 (312) 641-5570 EDWARD W. OSANN, JR'.
One IBM Plaza Suite 4600 Chicago, IL 60611 (312) 822-9666
-ROBERT L. GRAHAM One-IBM Plaza 44th Floor Chicago, IL-60611 (312) 222-9350 Attorneys for Joint Intervenors i
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CERTIFICATE OF SERVICE I hereby certify that on this 26th day of February, 1980, I have served copies of the foregoing Joint Intervenors '
First Supplement to Petition for Leave to Intervene, dated February 26,'1980, upon each of the persons named on the attached' Service List, by causing copies to be deposited in the U.S. Mail, in envelopes properly addressed and sealed, first class postage prepaid, except that service upon those persons next to whose names there appears an asterisk (*)
was made by delivery to a representative of NIPSCO.
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SERVICE LIST Herbert Grossman, Esq., Chairman George and Anna Grabowski Atomic Safety and Licensing 7413 W. 136th Lane Board Panel Cedar Lake, IN 46303 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. George Schultz
- 'Dr. Richard F. Cole 110 California St.
Atomic Safety and Licensing Michigan City, IN 46360 U.
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Regulatory Commission Richard L. Robbins, Esq.
Washington, D.C.
20555 Lake Michigan Federation 53 W. Jackson Blvd.
Mr. Glenn 0. Bright Chicago, IL 60604 At cS and Licensing Mr. Mike Olszanski i
i" U 5.t wrbrsofAmerica Wk hi D
2 55 3703 Euclid Ave.
Maurice Axelrad, Esq.
East Chicago, IN 46312 Kathleen H. Shea, Esq.
- Steven C. Goldberg, Esq.
$$*,k"an T(('
Office of the Executive 1025 Connecticut Ave., N.W.
Legal Director Washington, D.C.
20036 U.S. Nuclear Regulatory Commission
- William h. Eichhorn, Esq.
Washington, D.C.
20555 Eichhorn, Eichhorn & Link 5243 Hohman Ave.
Dean Hansell, Esq.
Hammond, IN 46320 Assistant Attorney General John Van Vranken, Esq.
Environmental Control Division fkfa 188 W. Randolph St.- Suite 2315 P
hu t Esq.
Suite 700 Chicago, IL 60601 2000 P. Street, N.W.
Stephen Laudig, Esq.
Washington, D.C.
20555 445 N. Pennsy.lvania Ave.
Indianapolis, IN 46204 Atomic Safety and Licensing Board Panel Docketing and Service Station U.S. Nuclear Regulatory Commission Office of the Secretary Washington, D.C.
20555 U.S. Nuclear Regu'.atory Commission Atomic Safety and Licensing Washington, D.C.
20555 Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 s
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