ML19325D563
| ML19325D563 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/16/1989 |
| From: | Matt Young NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19325D564 | List: |
| References | |
| CON-#489-9315 OL, NUDOCS 8910250043 | |
| Download: ML19325D563 (15) | |
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Octo Qpj 6, 1989 l
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v%9 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'89 OCT 17 P1 :45 n
y BEFORE THE ATOMIC SAFETY AND LICENSING BOARD,7 0.
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DOCH p h
S In the' Matter of
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Docket Nos. 50-443 OL m
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PUBLIC SERVICE COMPANY OF 50-444 OL l
NEWHAMPSHIRE,it,,a.l.
Off-site Emergency Planning l
(Seabrook Station, Units 1 and 2)
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'I NRC RESPONSE TO INTERVENORS' MOTION TO ADMIT CONTENTIONS ON SEPTEMBER 27, 1989 EXERCISE INTRODUCTION By motion dated September 28, 1989, the Massachusetts Attorney General, Seacoast Anti-Pollution League, and New England Coalition on Nuclear' Pollution.("Intervenors") asked the Board to admit for litigation in the 'above-captioned. proceeding a contention that alleges that the l
l-September 27, 1989 exercise of the Seabrook Station Radiological Emergency Plan ("SSRERP" or "onsite plan") was not broad.enough in scope. 1/ Inter-L l
venors maintain that the September 1989 exercise was not a " full-scale onsite exercise of the Seabrook emergency plan" in that it "did' not test L
l either all or... a significant number of the major observable portions" l
of the onsite plan. Motion at Attachment A.
The Staff opposes the Motion because it fails to provide the requisite showing for a motion to reopen, to provide an adequate basis for the profferred contention and to meet the five-factor balancing test for late-filed contentions.
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Intervenors' Motion to Admit Contentions on the September 27, 1989 Plan Exercise, September 28, 1989 (" Motion").
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l e-DISCUSSION F
A.
The Contention Lacks the Reouisite Basis for Admission Before addressing whether the Motion meets the criteria for reopening under 10 C.F.R. 'i 2.734 and the five-factor test for late-filed conten-tions referenced in that regulation, it is useful to understand what s
regulatory. requirements are applicable to onsite exercises.
10 C.F.R. Part 50, Appendix E, i IV.1, provides that:
1.
A full participation exercise which tests as much of the licensee,. State ' and local emergency plans as is reasonably achievable without mandatory public participation shall be conducted for each site at which a power reactor is located for which-the first operating license for that site is issued after i
July 13, 1982.
This exercise shall be conducted within two 7
years before the issuance' of the first operating license for full power (one authorizing operation above 5% of rated power) i L
of the first reactor and shall include participation by each
. State and local government within the plume exposure pathway EPZ and each State within the ingestion' exposure pathway EPZ.
L If the full ' participation exercise is conducted more than one year prior to issuance of an operating licensee for full power, an exercise which ' tests the licensee's onsite emergency plans shall be conducted within one year before issuance of an operating license for full power.
This exercise need not have l
State or local government participation.
The scope of a full-participation exercise is indicated in the L
regulations by the footnote defining that term which provides in part.
that the exercise include " major observable portions of the onsite and offsite plan and mobilization of State, local and licensee personnel
...." Appendix E, 6 IV.F.1, n. 4.
Thus, the exercise provides a broad tes't of the licensee's emergency response capability in conjunction with state and local authorities.
The regulations, however, do not contain a similar definition for onsite exercises.
Neither do the regulations contain a statement as to
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what specific einments must be demonstrated in an onsite exercise that b"
post-dates a full-participation exercise. See 10 C.F.R. Part 50, Appendix q
E, 9 IV.F; Affidavit' of Falk Kantor (attached) at 19.
The regulations L
merely state that each licensee "shall annually exercise its emergency plan."
10 C.F.R. Part 50, Appendix E, 5 IV.F.2.
It is clear, however, that the purpose of a pre-license, onsite exercise is different and the exercise not as extensive in scope as a full-participation exercise.
As 1
the Commission stated:
1 This annual emergency response function drill ensures that the licensee's new personnel are adequately and promptly trained and l
that existing licensee personnel maintain their emergency response capability.
The existing requirement of a pre-operational onsite exercise within one year prior to full-power license issuance is consistent with this philosophy as well as l
the Commission's general desire to have pre-operational emer-gency planning exercises as close as practicable to the time of i
licensing.
I 52' Fed. Reg. 16823, 16824-25 (May 6, 1987).
Thus, the underlying purpose I
of the rule, therefore, is ~ to test or confirm emergency preparedness as a
l close as ' practicable to the issuance of a full-power license in order to l
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assess the preparedness of operational staff.
In the absence of specific j
criteria' in the regulations, the Staff has issued guidance for use in exercising and evaluating onsite plans which indicates those plan aspects that should be included in an onsite exercise.
Kantor Affidavit at 11 8-9.
Intervenors insist that the plan elements that are to be tested during the exercise of the SSRERP are the same as those tested in a full-participation exercise in order to demonstrate that the SSRERP can be implemented to provide reasonable assurance that adequate protective measures can and will be taken in the event of an emergency. Motion at 2 and Attachment A at 2-3.
Intervenors claim that the onsite exercise was
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- "so truncated in its scenario that major portions of the SSRERP were not demonstrated."
Motion at 2.
Allegedly there was a failure to demon-
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y strate exercise objectives tested in the June 1988 full-scale exercise in that the exercise did not:
- 1) advance beyond the declaration of a site area emergency and thus did not sufficiently test offsite protection action decisionmaking; 2) involve an 'offsite medical emergency team or medical treatment facility; 3) involve dispatch of any field monitoring teams and monitoring and assessment activities; and 4) involve any onsite personnel monitoring and decontamination at offsite locations such as the Seabrook Dog Track and the " Warehouse" on Route 107. M.atAttachmentA.
Intervenors base their position on the scope of an exercise on the Appeal L
Board's holding in Lona Island Lighting Co.
(Shoreham Nuclear Power Station, Unit 1), ALAB-900, 28 NRC 275 (1988). Staff Inspection Procedures 82301 and 82302, the matrix for the 1988 Seabrook full-participation exer-l cise and their interpretation of 10 C.F.R. 6 50.47(b)(14) and Appendix E, 6 IV.F.1.
Motion at 2 and Attachment-A.
The Staff does not dispute that Intervenors have met the specificity l.
requirement for admission of the contention.
They have failed, however, to provide an adequate basis for the contention in accordance with 10 C.F.R. 5 2.714.
Intervenors' centention that the exercise was t
l inadequate in scope apparently results from confusion as to the require-i ments for a full-participation exercise and those for an onsite exercise.
As noted above, the regulatory standard that " major observable portions" of a plan be exercised pertains to the requirement for full-participation exercises set forth in 10 C.F.R. Part 50. Appendix E, 6 IV.F.1, note 4.
While the Appeal Board has ruled that intervenors may 1
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" permit.'a' meaningful test and evaluation of the emergency plan to a'scertain if that plan is fundamentally flawed," Shoreham, supra at 286, D
its - comments were made in the context of evaluating full-participation exercises.
Those exercises, also called " initial exercises," must,-
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pursuant to-Appendix E, LIV.F.1, test major observable portions of both onsite and offsite plans.
Kantor at 1 9.
Contrary to Intervenors' I
assertion (Motion, Attachment A at 1), the onsite exercise held within one t
year before issuance of a full-power license is not the initial exercise I
for licensing purposes.
Since onsite exercises are not to test all of the objectives demonstrated in an full-participation exercise, reliance on elements to be included in a full-scale exercise (i.e., the 1988 exercise l
matrix)'doesnotprovideanadequatebasisfortheContention.
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Inaddition,10C.F.R.S50.47(b)(14)statesthat"periodicexercises n
are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain. key skills," but that provision does not specify what areas of a l
plan are considered major.
Thus a reference to that regulation, alone, I
does not provide an adequate basis for a contention alleging that an exercise was so limited in scope that it did comply with the regulations.
The Staff inspection procedures cited by Intervenors (Motion, Exhibits 1 and 2) also fail to provide a basis for the contention that an onsite exercise must be comparable in scope to a full-participation exer-cise.
First, Intervencrs rely on the outdated, 1983 version of Inspection Procedure 82301.
The version in effect at the time of the exercise does not contain the language which equates the scope of an onsite exercise s
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' with a full-participation exercise.
Affidavit of Edwin F. Fox (attached) at f 12. Also, inspection Procedure 02302, which is appended as Exhibit 2 to the Motion, states that medical services / supports (Contention Item 2) and field monitoring / assessment (Contention item 3) need only be demon-strated over a five year period.
Fox Affidavit at 119-10.
Neither procedure provide a basis for Intervenors' position that more than a site area emergency is needed to test the c9 site plan.
Moreover, even if the prot;edures could be construed as providing support for the :ontation,'the
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contsntion would still lack a basis since Sta f f guidance documents do not constitute regulatory requirements. U Thus, the contention lacks basis for the proposition that an onsite exercise must be similar in scope to a full-participation exercise.
B.
Intervenors Must Satisfy The Standards For Reopening A Closed elecord Intervenors argue that (1) the decision in UCS v. NRC, 735 F.2d 1437 (D.C. Cir. 1984), cert. don'd, 469 U.S. 1132 (1985), requires that they be provided an opportunity to challenge not only exercise results but also
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j' the scope of exercises and (2) the Comission's decision in CLI-89-19, l
30 NRC _ _ (Sept. 15, 1989), slip op, at 2, 4 n.5, implies that the l
standards for reopening are not applicable to contentions proffered regarding the onsite exercise. Motion at 3-4, 8-9.
The Staff has extensively briefed tLe issue of the applicability of the. reopening criteria to all late-filed contentions sought to be admitted i
1 2/
See Gulf States Utilities Co. (River Bend Station, Units 1 and 2),
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ACAB-444, 6 NFC
- 750,
,/2-73 (1977);
petition for Emergency and Remedid1 Relief, CLI-78-6, 7 NRC 404, 406-07 (1978).
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7-in a proceeding where the record has closed. 2/ The regulation codifying i
the standards for reopening was promulgated by the Comission after the
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,U,C,S, decision ($1 Fed. Reg. 19539, May 30, 1986; S1 Fed. Reg. 23523 j
June 30,1986) and is binding. #/
Intervenors' reliance on a terse foot-l note in CLI-89-19 is misplaced.
The issue before the Comission was not whether 10 C.F.R. I 2.734 should be applied to contentions filed on the onsite exercise, but ratner whether there was a justification for an l
exemption from, or waiver of, the requirement to exercise the onsite j
emergency plan within a year before issuance of a full-power license for Seabrook.
Thus, the Commission's statement should not be construed as being inconsistent with Commission precedent end court-approved procedural l
requirements concerning the exercise of hearing rights.
See eA.
San Luis Obispo Mothers for Peace v. NRC, 751 F.2d 1287,1318 (D.C. Cir.
1984), aff'd rehearing en banc, 789 F.2d 26, 29-30, 44 (1986), cert.
denied, 479 U.S. 923 (1986);
Oystershell Alliance v. NRC, 800 F.2d 1201, l
1207 (D.C. Cir.1986); Duke Power Co. (Catawba Nuclear Station, Units 1 and 2), CLI-83-19, 17 NRC 1041, 1045, citing, BPI v. AEC, 502 F.2d 424 (D.C. Cir. 1974) an' Easton Utilities Com. v. AEC, 424 F.2d 847 (D.C.
i Cir. 1970).
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h. NRC Staff Response to Intervenors' " Motion to Admit Contention, or in the Alternative. To Reopen the Record. And Request for Hearing," August 18, 1989, at 10-13; NRC Response to Intervenors' l
Motion for Leave To Add Bases to low Power Testing Contention. To Admit further Contentions, or To Reopen the Record and Request for Hearing, September 14, 1989, at 2-7.
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This Board has also recently rejected Intervenors' position on the inapplicability of the reopening standards.
See Memorandum and Order, LBP-89-28, 30 NRC (Oct. 12, 1989), sTip op. at 13-16.
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8-l Accordingly, contentions on the scheduled exercise may not be q
admitted unless Intervenors prevail on a motion to reopen the proceeding j
under 10 C.F.R. 6 2.734 and meet the late-filing criteria of 2.714(a)(1),
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1.
The Intervenors have not met the Standards for Reepening Because the Motien comes at the conclusion of the hearing on offsite emergency planning issues it must satisfy the standards for reopening the S,ef, LBP-89-23, slip op. at 14-15.
The motion must be timely, record.
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except that an exceptionally grave issue may be considered in the l
discretion of the presiding officer even if untimely, (2} it must address j
a significant safety or environmental issue, and (3) it must demonstrate that a materially different result would be or would have been likely had the newly proffered evidence been considered initially.
10 C.F.R. 6 2.734.
Section 2.734(b) also requires that a motion to reopen be I
accompanied by one or more affidavits "which set forth the factual and/or technical bases for the movant's claim that the criteria in [l 2.734(a))
have been satisfied" and the affidavits must be executed by " competent individuals with knowledge of the facts alleged, or by experts in the i
disciplines appropriate to the issues raised."
The Appeal Board has
- stated,
"[T]he Comission expects its adjudicatory Boards to enforce section 2.734 requirements rigorously --
t 1.e., to reject out-of-hand reopening motions that do not meet those requirements within their four corners."
Seabrook, ALAB-915, 29 NRC 4?7, 432 (1989).
Accord, Long Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1), CLI-89-1, 29 NRC 89, 93-94 (1989).
The information in the motion must be set forth in greater detail than that required for i
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contentions, and must be more than allegations and tantamount to evidence.
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Shoreham, CLI-89-1, 29 NRC at 93.
Because reopening a closed record is an s
extraordinary action, the movant bears a heavy burden, Kansas Gas &
f E,lectric Co. (Wolf Creek Generating Station, Unit 1 (ALAB-462, 7 NRC 320, 323(1978). Evidence supporting reopening must be of sufficient weight to withstand a motion for sunnary disposition.
Vermont Yankee Power Corp.
t (Vermont Yankee Nuclear Power Station), ALAB-138, 6 NRC 520, 523 (1973).
The most important reopening standard is whether the motion raises a i
significant environmental or safety issue.
Phila elphia Electric Co.
(Limerick Generating Station, Units 1 and 2), ALAB-834, 23 NRC 263, 264 f
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(1986).
In addition, there must also be evidence that there is a funoamentalflawintheemergencyplan.El While the Staff does not dispute that the motion is timely, the i
Motion does not allege a significant safety or environmental issue, is not supported by affidavit, and does not establish that a different result r
would be cbtained if the information were considered.
As shown by the attached affidavits of Falk Kantor and Edwin Fox, the onsite exercise held i
i at Seabrook was sufficient in scope to test the Applicants' emergency response capability.
Kantor Affidavit at 11 10, 13; Fox Affidavit 1 6, 13.
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Fundamental flaws are those exercise " deficiencies which preclude a finding of reasonable assurance that protective measures can and will be taken," Long Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1), CLI-86-II, 23 NRC 577, 551 (1986), and reflect "a failure of an essential element of the plan, and... can be remedied only through sig(nificant revision of the pTan," Shoreham, ALAB-903, 28 NRC 499, !05 1988).
For example, errors arising from insufficient training do not ordinarily establish a fundamental flaw.
- Seabrook, ALAB-918, 29 NRC 473, 485-86 (1989).
I
' l Inspection Report No. 50-443/89-10, 6/ which contains the Staff's evalua-l tion of the exercise, concluded that the major aspects of the SSRERP were f
tested in the exercise and no weaknesses in the Applicants' emergency i
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preparedness were identified. Report at 3, 9.
i The four issues raised by Intervenors do not constitute deficiencies.
l Exercises need not advance beyond a Site Area Emergency in order for mejor f
portions of the response plan to be tested.
Fox at 11 b8.
Medical services / support need not be performed during an onsite exercise and was demonstrated during the 1988 full-participation exercise.
Kantor at 1 13.
Similarly, onsite personnel monitoring and decontamination at an offsite location need not be conducted during each onsite exercise since monitoring of onsite personnel is done routinely and the exercise scenario l.
was not required to include the release of a radioactive plume which could f'
contaminate onsite personnel.
Fox at 1 11.
Moreover, contrary to Inter-venors' assertion, field monitoring teams were dispatched and engaged in i
assessment activities.
Id. at 1 10.
Even if Intervenors were to pre. ail in a showing that these teams were either not properly dispatched or exhi.
l bited performance inadequacies, Intervennrs could not obtain a finding l
that the exercise was nut sufficient in scope or there was a fundamental flaw since (1) they misinterpret the regulatory requirement for onsite exercises, (2) rely, in part on Staff documents, where
- current, 6/
This report is Appendix ! to " Applicants' Response to Intervenors'
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Motion to Admit Contentions on the September 27, 1989 Emergency Plan Exercise, October 11, 1989.
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l 11 only constitute guidance on the matter 1/ and (3) such alleged performance deficiencies could be corrected without significant plan revisions through
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additional training or drills.
Thus, Intervenors have not raised a signi-ficent safety issue which would affect the outcome of the Seabrook emer-gency planning proceeding and the motion to reopen should be denied on both procedural and substantive grounds.
2.
Intervenors Do Not Prevail on the Standards for Late-Filing Intervenors' failure to satisfy all of the criteria for reopening the record compels denial of the Motion.
It is also clear that, contrary to Interveners' assertion (Motion at 4-8), they do not meet the standards for admiscion of late-filed contentions set forth in 10 C.F.R.
f i 2.714(a)(1). 8/
That section provides that the proponent must demon-stri.te that a balancing of the five-factor weighs in favor of admitting the contention.
Corrnonwealth Edison Co. (Braidwood Nuclear Power Station, f
Units I und 2), CL1-86-8, 23 NRC 241 (1986); Duke Power Co. (Catawba i
Nuclear Station, Units 1 and 2), CLI-83-19,17 NRC 1041 (1983); Public l
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See River Bend, note 3,
su Lra; Vermont Yankee Nuclear Power Corp.
l T7ermont Yankee Nuclear PowTr Station), ALA5-179, 7 AEC 159, 174 n.
27(1974).
8/
The Comission has emphasized that Boards are to demand compliance with the lateness requirements of 10 C.F.R. I 2.714 Pacific Gas &
Electric Co. (Diablo Canyon Units 1 and 2), CLI-81-5, 13 NRC 361, 364 t
(1951).
The Appeal Eoard has also ruled that under the Connissions' Rules of Practice, any(contention, including an exercise contention,
"' filed later fifteen
- 15) days prior to the holding of the necial prehearing conference... within fifteen (15) days prior co the holding of the first prehearing conference' is nontimely and can be ad.nitted only upon a Salancing of the five lateness factors."
Seabrook, ALAB-918, 29 NRC 473, 480 (1989).
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Service Co. of New Hampshire (Seabrcok Station, Units 1 and 2), ALAB-883, 27NRC43,49(1988). Those factors are:
(1)
Good cause, if any, for failure to file on time.
(ii) The availability of other means whereby the petitioner's interest will be protected.
i (iii) The extent to which the petitioner's participation may reasonably be expected to assist in developing a sound
- record, (iv) The extent to which petitioner's interest will be repre-sented by other parties.
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(v)
The exter.t to which petitioner's participation will
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broaden the issues or delay the proceeding.
I a.
Good cause, other means and parties to protect Intervenors' interest The first factor (good cause for the failure to file on time), second
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factor (the availability of other means to protect petitioner's interest)
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t and fourth factor (the extent to which a petitioner's interest will be
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represented by other parties) weigh in favor of admission of the conten-l tion.
The Staff does not dispute that Intervenors satisfy the good cause showing.
Also, boards have generally recognized that there are no other means or parties to protect an intervenor's interests.
The Comissior, however, has repeatedly observed that the second and fourth factors are
" accorded less weight, under established Commission precedent, than
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factors one, three, and five."
Braidwood, supra, 23 NRC at 245; Soutj Carolina Electric & Gas Co. (Virgil C. Summer Nuclear Station. Unit 1),
ALAB-642, 13 NRC 881, 895 (1981).
Thus these factors slightly favor f
admission of the Contention.
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Contribution to the development of a sound record This factor -- the extent to which a petitioner can contritate to the development of a sound record -- is very important.
When a petitioner addresses this criterion "'it should set out with as much particularity as possible the precise issues it plans to cover, identify its prospective witnesses, and symarize their proposed testimony.'" Braidwood. 23 NRC at 246, quotina Mississippi Power & Light, (Grand Gulf Nuclear Power Station, Unit 1), ALAB-704, 16 NRC 1725,1730 (1982); accord, Public Service Co.
of New Hampshire (Seabrook Station, Units 1 and2), ALAB-918, 29 NRC 483-84 (1989).
The movant must therefore demonstrate that it possesses "special expertise on the subjects Mich it seeks to raiss "
Braidwood, 23 NRC at 246.
Intervenors identify a number of witnesses who they contend "can verify that major portions of the SSRERP were not exercised." Motion at 6-7.
With possibly the exception of the witnesses who claim they did not observe any dist,atch of offsite monitoring teams from the Emergency Operations Facility at Newington, the proffered testimony will not contribute to the development of a sound record nor establish a genuine issue of material fact.
As explained in the attached affidavits, the items 1-4' listed in the contention are not major portions of an onsite plan nor are they. required to be demonstrated during an onsite exercise, Fox Affidavit at 118-11; Kantor Affidavit at 112.
Further, Intervenors have not shown that the identified witnesses possess any special expertise in evaluating onsite exercises or in applying NRC guidance for such exercises.
Intervenors' reliance on the sumary niatrix for the 1988 full-participation exercise does not constitute a sufficient showing on this factor because all of the objectives set forth therein need not be
j f l tested in an onsite exercise.
See Kantor Affidavit at 1 9.
Moreover, the j
versions of the Inspection Procedures in effect at the time of the f
exercise clearly set forth the mejor elements of an onsite plan (Procedure 82302) which is contrary to Intervenors' contention.
Testing of medical support personnel (Item 2) and field monitoring (Item 3) need not be done during each onsite exercise. Onsite personnel monitoring (Item 4) is done routinely at plants and is not a major part of an onsite exercise.
Fox Affidavit at 11 9-11.
Also, a failure to include the items in an onsite I
exercise would not constitute a tack of adequate scope.
f Neither would svidence on the factual dispute presented by item 3 of l
Intervenors' Contention assist in the development of a sound evidentiary record.
Even if Intervenors were to prevail in a showing that, contrary f
to the fie tings in Inspection Report No. 50-443/89-10, issued October 5, t
1989, field monitoring teams were not properly dispatched and failed to perform their duties, such showing would not reveal a fundamental flaw in the plan since such performance errors would be readily correctable through trai..ing.
Sy Seabrook, ALAB-918, 29 NRC at 485-86. Thus, none of the issues raised by Intervenors constitute a sufficient basis for their contention or show they will make a meaningful contribution to the
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development of a sound evidentiary record.
Consequently, this factors weighs heavily against admission of the Contention.
c.
Broadening of issues and delay to the proceeding It cannot te disputed that admission of the contention will both broaden the issues and delay this operating license proceeding where all f
that remains is for the Board to issue an initial decision resolving the
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. matters placed in controversy by the remaining emergency planning conten-tions.
Despite their claims to the contrary (Motion at 7), Intervenors will likely request extensive discovery and will surely aggressively oppose any schedule that may result in the issuance of a full-power license for Seabrook. El Any hearing on matters not already admitted before the Board will likely delay the projected November 30, 1989 issuance for the initial decision on the 1988 exercise as it will divert the Board's attention from resolving those issues.
Thus this factor weighs heavily against the Motion.
the In sum, because the third and most important factor and the fif th factor -- delay and development of a sound record broadening of the proceeding -- weigh heavily against the admission of the i
Contention.
Consequently, a balancing of the five factors weighs against admission of the Contention, f
IV. CONCLUSION For the reasons stated above, Intervenors' motion to admit a i
contention on the onsite exercise should be denied.
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Respec ully submitted.
l Mit A. Young Counsel for NRC Staff Dated at Rockville, Maryland this 16th day of October 1989.
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The Mass AG is on record as stating that he will continue to engage Globe. August 9, 1989, at 21 (Attachment B to Applicants' lE.., Boston in efforts to thwart full-power operation of Seabrook, Application for an Exemption from the Requirement of 10 CFR Part 50, Appendix E.
Section IV.F.1, for the Conduct of an Exercise of the Licensees' l
Onsite Emergency Plans within One Year Before Issuance of a t
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Full-Power Operating License, August 11, 1989.
The recent flurry of i
plaadings in this proceeding is also evidence of Intervenors' resolve l
in that regard.
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