ML19338C110
| ML19338C110 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley, Peach Bottom, Salem, Hope Creek, Susquehanna, Seabrook, Limerick, Vermont Yankee, Callaway, Midland, Crane File:NorthStar Vermont Yankee icon.png |
| Issue date: | 10/22/1976 |
| From: | Engelhardt T NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8008050562 | |
| Download: ML19338C110 (17) | |
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- UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
BEFORE THE COMMISSION In the Matter of-VERMONT YANKEE NUCLEAR POWER CORPORATION
)
Docket.No. 50-271 (Vermont Yankee Nuclear Power Station)
)
)
PUBLIC. SERVICE ELECTRIC & GAS COMPANY
)
Docket Nos. 50-272 (Salem _ Nuclear Generating Station, Units 1 & 2)
)
50-311 PHILADELPHIA ELECTRIC COMPANY'(Peach Bottom
)
Docket Nos. 50-277 Atomic ' Power Station, Units -2 & 3) 50-278 METROPOLITAN EDISON COMPANY, ET AL. (Three Docket Nos. 50-289 Mile Island Nuclear Station, Units 1 & 2)
)
50-320 u CONSUMERS POWER COMPANY'(Midland Plant, Docket NosM Units 1 & 2)
)
50-330 DUQUESNE'LIGHTCOMPANY,ETAL.(Beaver Docket Nos. 50-334 Valley Power Station, Units 1 & 2)-
}
50-412-
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PHILADELPHIA ELECTRIC COMPANY (Limerick Docket Nos. 50-352 Generating Station,- Units 1 & 2) 50-353 PUBLIC SERVICE ELECTRIC AND GAS COMPANY and
)
Docket Nos. 50-354 ATLANTIC: CITY ELECTRIC COMPANY'(Hope
)
50-355 Creek Generating Station, Units 1 & 2)
PENNSYLVANIA POWER AND LIGHT COMPANY
)
Docket Nos. 50-387 (Susquehanna Steam Electric Station,
)
50-388 Units l ' & 2)
- PUBLIC SERVICE COMPANY OF NEW-HAMPSHIRE,-
-. Seabrook Station, Units 1 & 2) 50-444
)
~ UNION ELECTRIC COMPANY (Callaway Pl' ant,
))
Docket Nos. STN 50-483
. Units 1. & 2)
STN 50-486 STAFF RESPONSE-T0 COMMISSION DIRECTIVE OF OCTOBER 13, 1976 October 22,11976-~
Thomas F. Engelhardt Deputy Executive Legal-Director 1800805.o S M y... ;
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.On. 0ctober 13, 1976 the' Commission:noted that it was considering suspending ~
further actions 'in the above-referen..:d dockets in light of certain recent events and-' circumstances which will be -referred to'in the discussion follow-1/-
ing.'-~
The parties 'in these dockets were then directed to. respond to a 2/
pending motion to the effect that such actions be~ taken.
Background
A rather.. complex series of. events and circumstances has led to the present
' question of'whether to suspend further proceedings in these dockets.
First of all, on July 21, 1976 the U.S. Court of Appeals for the District of Columbia Circuit handed down a decision in the case of Natural Resources Defense ~ Council'v. NRC.
This decision declared the Comission's rule.
for treating two aspects of the fuel cycle - reprocessing and waste mana5a-ment --inadequately' supported by the rulemaking record.
In a General Statement:of Policy
- (GSP) responding to' the court's action, the Comission
_1/ Letter from Secretary of the Commission to all parties in these dockets,
. dated October 13, 1976.
2/; -Motion of-Vennent Yankee Nuclear. Power Corporation dated September 27,
.1976. and docketed (in Docket No. 50-271) on 0ctober 1,1976.
~
3/.- CADC Nos. 1385 and 74-1586 (July 21,1976).
_4f Table.S-3 included -in -10 CFR Part 51.
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_J/.41 Fed. Reg.34707f(August ~16,1976).
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. said it was going to reopen the proceedings directly affected by the 6/
t'.eci si on.
The Commissior said, further, that it would resolve the '
question of how to deal with other licensing proceedings that might be impacted by the court's' decision on the basis of its evaluation of estab-lished equitable factors. These dockets are the cases which have either already been reopened or in which reopening is being sought on Table S-3 grounds. -7/
Subsequent to the.GSP, Supreme Court review was saught by one of the affected licensees (Vermont Yankee) of the Court of Appeals holding and motions were filed with the Court of Appeals seeking a stay of its mandate.
The Court of Appeals granted a stay of. its mandate on October 8,1976, thus effectively postponing its issuance until the Supreme Court acts on the pending petition for a writ of certiorari.
Five days later, cn October 13, 1976, the same day it issued the directive
-to which this pleading responds, the-Commission issued a notice of proposed i
_6] The Vermont' Yankee and Midland proceedings.
. _ 7_/ These dockets.have been referred to loosely as involving show cause proceedings.. In reality they are in various procedural postures.
1 However, since the particular procedural status of cach docket is of no
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importance.to the basic question raised by the comission's October 13
? directive, the Staff's-response is generic and directed to all the dockets.
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rulemaking
' which preposed interim revisiens to Table S-3 on the basis
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- of a completed Staff survey also issued thi.t. day.
In proposing an interim
- rule.on the basis of the values in the Staff supplemei.T c':rvey, the Comissionl expressed the view that the supplemental survey " represents a full 'and candid discussion of spent fuel reprocessing and waste management impacts" and that it "can serve as an adequate foundation" for an interim rule. The Comission also stated its present judgment that the impact values in the. survey were unlikely to prove to be dramatically in error.
The foregoing events and circumstances essentially comprise tr.e factual matrix giving rise to the issue of whether to suspend the pending show cause type proceedings.
For. the ressons which follow, it is the. Staff's j
vic that the Comission should as a matter of sound policy require such suspensions pending an effective interim rule.
FOUR FACTORS WARRANT DECISION TO SUSPEND'FURTHER PROCEEDINGS
~ 1.
Suspension of further proceedings makes sense in light of the court's
~
stay of its mandate.
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The Court's order of October. 8,1976, staying the mandate for its decision 4
on the waste management and reprocessing aspects of Table S-3, is undeniably 8/
" Uranium Fuel Cycle Impacts'from Spent Fuel Reprocessing and Radioactive
. Waste Management," 41' F.R. 45849 (October 18,1976).
9/
" Environmental Survey 'of the Reprocessing and Waste Management Portion
.of the LWR Fuel Cycle" NUREG-Oll6 (Supplement to WASH-1248).
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-Delphic in' tone.
We can say 'with some assurance, however, that the
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courtYaction removed any doubt on.the question whether licenses could in~
fact be -legally; issued subsequent to July 21, 1976, the.date of its
- decision.
Licenses can be issued if they are made subject to the outcome 10/
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- of."the pro'ceedings herein."-
Since appropriately qualified licenses clearly can now be issued - where it wasn't clear before - it would incon-j.
sistent with the court's action to call existing licenses'into question on Table S-3 grounds.
Therefore, the proceedings in these dockets -to do 11f-f just that should'be suspended.
S'nce the mandate has not-issued, the decision issued on July 21, 1976, j '
does not, of itself, legally compel Comission action in Vennont Yankee or 1
any other case.
The question of the appropriate action to take in this period'is thus a policy.one, to be decided in light of the best information i
available and all the relevant circumstances. A similar question was presented to the Commission when the GSP was issued, and the chain of events i
leading to initiation of:these proceedings begun.
At that time, the Commission decided -that requests' to suspend existing license permits, and LWA's would beJentertainedion their merits.. The facts and circums'tances are now changed
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. and,'we submit, sound policy considerations now dictate that these pro-ceedings be suspended.
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.By-the quoted phrase the court presumably means the proceeding; 't1 the cases before the court.
11/ In the-Midland' proceeding, the remanded issues include the consideration of energy. conservation alternatives and clarification of the ACRS ' report as-well-as. the ; fuel 1 cycle. issues.
Only the. fuel cycle should be suspended.
The other issues should be allowed tc proceed to resolution.
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Suspension of;further proceedings makes sense from a timing standpoint.
The Commission's August 13 GSP noted that if a supplemental survey of adequate quality and breadth' could be developed by the end of. September, 1976,. an interim rule "might be promulgated as early as December,1976."
This schedule has slipped approximately two weeks.- Nevertheless, on the present schedule, an interim rule could be in place by mid-January.
Such a rule would obviate the pending Table S-3 issues because it would remove uncertainties regarding the values to be used for spent fuel i
reprocessing and waste management impacts in individual cost-benefit analyses.
- Moreover, the practical likelihood that these show cause type actions could be-brought to ~ completion before mid-January is negligible.
Finally, if~
the matters were allowed to continue there would be a substantial expenditure
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of-time and. effort which would be wasted as a result of an effective -interim rule's preemption of the issues.
3.
Suspension of further proceedings makes sense in light of the quality of the survey.
The Comission should act upon the best available information.
The supplemental environmental-surv~ey of reprocessing and waste management
-impacts is the best.available information.
It is described in the notice J
of proposed rulemaking of October 13, 1976, as " full," " candid,"~" thorough,"
and as."an~ adequate foundation" for a revised Table S-3.
The -Comission said in that notice that its present judgment was that the values in the
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survey would not likely.he found to be dramatically wrong.
Since show cause proceedings should be based on the interim rule as adopted if they
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~ can be. justified _in light of revisions to Table S-3, ad hoc. proceedings c
which get under way'only to be foreclosed' by the adoption of the interim 12_f
-rule'are ill-advised.
Suspension of outstanding licenses should await i-and be based upon the ultimately adopted Table' S-3.
This result is dictated-by a need to efficiently luse Comission resources.
I 4.
Suspension of further proceedings makes sense because the cost-benefit j
balance.is not likely to be tilted.
-The fuel cycle impacts attributable to an individual reactor's cost-benefit assessment--particularly those which would occur over the next few months--are relatively small.
t The' waste management and f
reprocessing portions of the fuel cycle are a fraction of the total impacts
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of the fuel cycle.
Thus, any differences, even large differences, in values i
for-these impacts between existing -Table S-3 and proposed Table S-3, (including any appropriate revisions thereto as a result of the rule-
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. making process) will not likely show up as large differences in the overall cost-bnnefit analysis,for an individual reactor.
Since any overall perturbation i
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However, it.is noted that a-decision on:the interim rule will be based '
t on the: surveys as modified'by those public comments wnich the Comission finds ~ to be_ persuasive.
During the period of__ notice and coment; the parties can direct their attention to the rulemaking proceeding. After.
the airing of-these issues, it may be appropriate for the Comission to i
review these dockets on its own motion at the conclusion of the' interim
- rulemaking process.. In the event the. Commission is persuaded that the Lcomments show a need tolreactivate show cause type proceedings on S-3
'iss~ues,.it.could do so at that time'.
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for Table S-3 reasons can as a practical matter only be minor, it could onlyttilt'an individual cost-benefit balance in a different airection if.that' balance were in virtual equipoise.
None of~the balances that have been struck in the cases in these dockets have been founu to be in I
such a state.
Suspension is a Matter of Discretion,Not of Law In view of the Staff's conclusion that the Commission should suspend further show cause type actions in these dockets, we did not find it necessary to reach the point raised in the motion of Vermont Yankee Nuclear 'ower Corporation to the effect that it would be contrary to law not-to do so.
Generally, the Commission has broad discretion in the r
exercise of its regulatory authority.
Siegel v. Atomic Energy Commission,
~
400 F.2d 778-(CADC; 1968), see also, FCC v. Pottsville Broadcasting Compa 11,1309 U.S.134 (1940). Also, it is true, generally, that while a specific agency action is undergoing judicial scrutiny the at2qcy is powerless to act with respect to that specific action.
Jaffe, Judicial
_ Review of Administrative Action, 711 (1965). gThese_ general principles make clear, however.. that an agency is _ legally free to exercise its regulatory authority lin matters related - even closely related - to the specific agency action undergoing judicial scrutiny.
Thus, to.take a hypothetical example, general Commission concern based on new information
n
- w over the? numerical. values for the reprocessing or waste management impacts could properly trigger an exercise-of regulatory authority by the Commission resultingLin license suspensions.
If broad-scale license suspensions were g
dictated by such information-the suspensions could properly be imposed, even_with respect to Vermont Yankee.
For regardless of whether the Supreme
- Court might ultimately find that the old Table S-3 values were adequately-supported at the time they were' developed that would not have been the issue' triggering suspension; new information would have been the basis.
It, therefore, seems clear that as a matter of law the Commission retains the discretion to pennit the show cause type proceedings to continue based upon the new information developed in the supplemental survey.
For the sound policy _ reasons enumerated above it should not do so.
Conclusion E
- In view of-the court's action staying its mandate, the issuance of the notice of proposed rulemaking, the publication of the supplement to the environmental survey, and the Comission's stated expectatio.n that an interim rule will be t
.lMJ0f. course, as noted elsewhere herein, there is no reascnably conceivable way as a practical matter that the re.lat'vely minor effects which the numerical-values for these impacts repruent in individual impact state-
-ments' could actually change so as to warrant-broad ' scale' license suspensions.
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w.y 9-in. place in.the'near future, the~ Commission should suspend all show cause.
. type proceedings' requested or initiated on the basis of the Comission's
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policy statement or the Court of Appeals ~ decision in NRDC_ v. NRC. Orderly
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conduct of licensing proceedings and effective public interest regulation.
- can best be'ac'complished by deferring action on these mattes ending the adoption or rejection of an interim rule'.
Respectfully submitted, mm Thomas F. Engelhardt Deputy Executive Legal Director Dated at Ba.thesda, Maryland this 22nd day of October,1976.
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- ~'- G UNITED STATES'0F AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION
.In'the Matter of-VERMONTLYANKEE NUCLEAR POWER CORPORATION
)
Docket No. 50-271
'(Vermont Yankee Nuclear Power Station) l
- PUBLIC SERVICE ELECTRIC & GAS COMPANY Docket Nos. 50-272
-(Salem Nuclear Generating _-Station, Units.1 & 2) 50-311-PHILADELPHIA ELECTRIC _ COMPANY-(Peach Bottom-
)
Docket Nos. 50-277 Atomic Power Sta. tion, Units 2 & 3).
50-278 METROPOLITAN EDISON COMPANY, ET'AL. (Three
)
Docket Nos. 50-289 Mile -Island Nuclear Station, Units l'& 2)
)
50-320.
CONSUMERS POWER COMPANY (Midland Plant, Docket Nos. 50-329
)
50-330 Units.1 & 2) j-DUQUESNE LIGHT COMPANY, ET AL. (Beaver Docket Nos. 50-334 Valley Power Station, Units 1 & 2)
).
50-412 PHILADELPHIA ELECTRIC COMPANY (Limerick Docket Nos. 50-352 Generating Station, Units 1 & 2) 50-353 PUBLIC SERVICE ELECTRIC AND GAS COMPANY and
)
Docket Nos. 50-354 ATLANTICCITYELECTRICCOMPANY(Hope.
)
50-355 Creek Generating Station, Units 1 & 2)
PENNSYLVANIA POWER AND LIGHT COMPANY
)
Docket Nos. 50-387 (Susquehanna Steam Electric Station,
)
50-388 Units ~1 & 2)
)
PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, Docket Nos. 50-443
.g A1. (Seabrook Station, Units 1 & 2)
)
50-444
)
UNION ELECTRIC COMPANY. (Callaway Plant,
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)
Docket Nos. STN 50-483 Units--I & 2).
)
STN 50-485 i
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CERTIFICATE OF SERVICE I he*eby certify that copies of " STAFF RESPONSE TO COMMISSION DIRECTIVE
' 0F OCTOBER 13, 1976 in the above-captioned proceeding have been sarved on each persor, on the. list accompanying the Comission's October i!. 1976 letter which directed this response.
Service was effected by-deposit in the United States mail, first class or air mail, or, as indicated by ar.
asterisk,' through deposit in the Nuclear Regulatory Commission internal mail system, this 22nd day of October, 1976.
?
Thomas F. Engelhardt Deputy Executive Legal Direc. tor
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- Samuel: W. Jensch, Esq.
Mr. John W. Stevens, Director Atomic Safety and Licensing Board
- Conservation ' Society of Southern U. S. Nuclear Regulatory Commission Vermont Washington,-D.~ C.
20555 P. O. Box 256 Townshend, Vermont 05353 Cr. David B. Hall Los Alamos Scientific Laboratory
. Honorable Donald W. Stever, Jr.
P. O. Box 1663 Assistant Attorney General Los Alamos, New Mexico 87544 State of New Hampshire State House Annex Dr.-Paul W. Purdom Concord, New Hampshire 03301 245 Gulph; Hills Road-Radnor, Pennsylvania.19087 Anthony Z. Roisman, Esq.
Karin P. Sheldon, Esq.
- Docketing and Service _ Section Roisman, Kessler and Cashdan
-Office of the Secretary 1025 15th Street, N.W.
U. S. Nuclear Regulatory Commission-Washington, D. C.
20005 Washington, D. C.
20555 Jonathan N. Brownell, Esq.
John D. Carbine,-Esq.
Paterson, Gibson, Noble and
'Ryan, Smith and Carbine Brownell 98 Merchants Row 26 State Street Rutland, Vermont 05701-
' Montpelier, Vermont 05602 John A. Ritsher, Esq.
Peter S. Paine, Jr., Esq.
Thomas G. Dignan,-Esq.
General Cornsel Ropes and Gray Lake Chamr lain Comnittee
~225 Franklin Street One State Street Plaza 1
Boston,. Massachusetts 02110 New York, New York 10004 Honorable Jerome Diamond John _H. Adams,-Eso.
Attorney General Natural Resources Defense Council, Ind State of Vermont 15-West 44th Street Pavilion Office Building New York, New York 1C936 109' State Street ~
Montpelier, Vermont 05602 Richard E. Ayres, Esq.
Natural Resources Defense Council, Inq Honorable John A. Calhoun 917 f-15th Street, N.W.
Assistant Attorney General
-Washington, D. C.
20036 1
. tate-of-Vermont Pavilion Office Building Richard H. Saudek, Esq.
109 State Street _
General Counsel
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- Montpelier,' Vennant - 05602
. Vermont Public Service Board 120 State Street LHonorable _Gregor I. McGregor State Office Building -
- Assistant Attorney General Montpelier, Vermont 05602 Commonwealth of Massachusetts -
State House Boston,. Massachusetts 02133-
. Dr. Ernest 0. Salo
- Edward Luton, Esq..
- Professor
- Atomic Safety and Licensing Board U. lS. ' Nuclear Regulatory Commission Fisheries Research Institute WH-10 Washington, D. C.
20555 College of Fisheries
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University of Washington
- JDr-Emmeth A. Luebke Seattle, Washington 98195 Atomic Safety and Licensing Board U. S. Nuclear Regulatory: Commission Edward G. Bauer, Jr., Esq.
Washington, D. C.
20555 Vice President-& General Counsel Philadelphia Electric Company -
Dr.. Harry Foreman 2301 Market Street Box 395 Mayo.
Philadelphia, Pennsylvania 19101 University of Minnesota Minneapolis, Minnesota 55455 Eugene.J. Bradley, Esq.
Philadelphia Electric Company Troy B. Conner, Esq.
2301 Market Street Joseph B. Knotts, Jr., Esq.
Philadelphia, Pennsylvania 19101 Conner. and Knotts 1747 Pennsylvania Avenue, N.W.
Honorable Frank R. Clokey Washington, D. C.
20006 Special Assistant Attorney General Commonwealth of Pennsylvania Richard Fryling, Jr., Esq.
P. O. Box 2063 Public Service Electric and Gas Co.
Harrisburg, Pennsylvania 19105 80 Park Place Newark, New Jersey 07101 Raymond L. Hovis, Esq.
35 South Duke Street Mrs. W.15. McElmoyl York, Pennsylvania 17401
.205 Howard Avenue Woodstown, New Jersey 08098 Honorable W. W. Anderson Deputy Attorney General Honorable William Gural Department of Justice Deputy Attorney General Capitol.~ Annex State of New Jersey Harrisburg, Pennsylvania 17120 101 Commerce. Street.
Newark, New. 3rsey 07102 Honorable Theodore A. Adler Deputy Attorney General Honorable ;oseph W. Ferraro, Jr.
-Department of Justice c
. Deputy A' corney General Capitol Annex l
-Room 208 Harrisburg, Pennsylvania 17120-101 Commerce Street ~
Newark, New Jersey 07102 Honorable Warren K. Rich Special Assistant Attorney General Dc. Kenneth A.'McCollom Department of Natural Resources l
Assistant-Dean State Office Building l
College of Engineering Annapolis, Maryland E1404 l
-0klahoma State University-Stillwater, Oklahoma 74074-M TM F
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Mr. IHerbert M. Sachs, Director-Douglas Baker, Esq.
_ Department of Natural Resources Box 337, Route 2 Water' Resources 1 Administration Kimberton Road Tawes : State Office. Building -
Phoenixville, Pennsylvania 19460
- . Annapolis, Maryland:-21401 '
Miss Mary V. Southard,; Chairman Richard S. Watt', Esq.-
Citizens for.a Safe Environment e
.U.-S. Environmental Protection P. O.-Box 405 L
. ~ Agency-
'Harrisburg, ' Pennsylvania 17108
~
E Region _ III..Curtis Building L
6th'and Walnut Streets Honorable Karir, W. Carter-
- Philadelphia, Pennsylvania _19106 Assistant-Attorney General Office of Enforcement i
Honorable John Bn Griffith.
Department of Environmental-Resources L i i
'Special-Assistant 1 Attorney General 709 Health 'and Welfare Building
_ State of Maryland
- Harrisburg, Pennsylvania 17120 Tawes State Office-' Building. (C-4).
580 Taylor.' Avenue-Lawrence Sager, Esq.
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. Annapolis, Maryland 21401 Sager and. Sager Associates 45 High Street F
Dr. M.-Stanley Livingston Pottstown, Pennsylvania 19464-
-1005'Calle Largo
- Santa Fei New Mexico 87501
- Daniel M. Head, Esq.
Atomic Safety and Licensing Board Dr.. John R..Lyman l'. S.- Nuclear Regulatory Commission
~
404 Clayton Road Washington, D. C.
20555 -
i
. Chapel Hill, North Carolina. 27514 I
Dr. J. Venn Leeds, Jr., Esq.
Gerald Charnoff, Esq.
10807 Atwell George F. Trowbridge,' Esq..
Houston, Texas 77096
- Shaw, Pittman, Potts and Trowbridge -
(91017th Street,:N.W.
. Myron M. Cherry, Esq.
Washington,-D. C.
20006 Suite'4501
~
One. IBM Plaza
' Herbert,C. Goldstein, Esq.
Chicago, Illinois 60611
- 133'St&te Street
' Harrisburs. iPennsylvania 17101 Harold F. ' Reis, Esq.
Lowenstein, Newman, Reis and Dr. (Chauncey R. Kepford.
Axelrad Citizens for a Safe Environment ar.d
-1025 Connecticut Avenue, N.W.
York Comittee forf a. Safe Environment.
Wathington, D.'
C.-
20036
- 2586. Broad Street '
York. Pennsylvania 17404 Honorable William H. Ward
- Assistant Attorney' General
-State of Kansas Topeka, Kansas 66612 e
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~ Joseph A.'Fricker, Jr., Esq.
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Utility Counsel Reilly,1 Like:and Schneider 200' West Main Street.
313 City-County Building Babylon,1New York ull702 Pittsburgh, Pennsylvania 15219
- HowardJ.Vogel)'Esq..
Thomas M..Kerr, Esq.
KnittleTand Vogel American Civil Liberties Union.
- 814 Flour. Exchange. Building.
of Pennsylvania
. Minneapolis, Minnesota 55415~
- 20R Wood; Street
. James?A. Kendall,-Esq.
_ Pittsburgh, Pennsylvania 15222:
4
' Currie and Kendall '
Dr. Robert L. Holton-135 North Saginaw Road
_ Department of 0ceanography Midland, Michigan. 48640 Oregon State University
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Corvallis, Oregon 97331 Judd L. Bacon, Esq.
Consumers Power Company-Honorable Lawrence Ceughl_in 212 West' Michigan Avenue House of' Representatives Jackson,: Michigan 49201 Washington, D. C. - 20515 William lJ.zGinster, Esq.
-Roger B..Reynolds, Jr.,.Esq.
lMerrilliBuilding, Suite 4 325 Swede' Street L
Saginaw, Michigan 48602 3
Norristown,_-Pennsylvania 19401 Milton R. Wessel Esq. -
Honorable Hershel J. Richman
- 4. Little Lane'.
Special= Assistant Attorney General White Plains, New; York 10605 '
Commonwealth of Pennsylvania 1
):
Curtis G. Beck Harrisburg, Pennsylvania.':17120 F-Honorabl:
. Assistant. Attorney General--
Ronald-J. Wilson, Esq.
_Seven Story.0ffice Building 810.18th Street, N.W.
-525 West 0ttawa Washington, D..C.
20036' Lansing -Michigan f48913 Phi. lip P. Kalodner, Esq.
Lee Nute, Esq.
Pennsylvania Public Utility Michigan Division-Comission b
-The Dow Chemical Company P. Ot. Box 3265 47-Building.
Harrisburg, Pennsylvania -17120
. Midland, Michigan c48640 JosephEA. Smyth,-Esq.
~
t* Mr.f Frederick J. 'Shon Assistant County Solicitor R
Atomic' Safetyf and'Li. censing Board County of Montgomery Courthouse U. S.: Nuclear Regulatory Comission
. Norristown, Pennsylvania :.19404
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Washington,fD.--C. c20555-1 e<
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Robert D. Westreich, Esq.
L WilliardiC..Hetzel,ESolicitor L
- Board of: Supervisors' Assistant Deputy Public Advocate
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- Upper Frederick Township.
-P. 0. Box 141
.i 312-Main Street S20 East State Street j
-East Greenville, Pennsylvania 18041 Trenton, New Jersey 08625 Dr.IErnest E. Hill William Horner, Esq.
Lawrence Livermore Laboratory 67 Market Street i-University of' California.
Salem, New Jersey 08079 P. 0. Box 808, L-123-Livermore, California' '94550' Paul W; Rosenberg, Esq.
2323 South Broad Street Frederick-M. Broadfoot, _ Esq.
Trenton, New Jersey 08610 1
Public Service Electric and Gas Co.
2 80 Park' Place-'-
Honorable F. Michael Parkowski-i Newark, New Jersey - 07101 Deputy Attorney General Department of Natural Resources Honorable-Mark L. First and Environmental' Control
.-[
Deputy Attorney General Tatnall Building i
State of New Jersey -
Dover, - Delaware 19901 f
36: West State' Street Trenton,-.New Jersey 08625
- Mr. Lester Ktrablith, Jr.
i Atomic Safety and Licensing Board
~
- Hor.orable Edward G. Biester, Jr.
U. S. Nuclear Regulatory Commission House of Representatives--
Washington, D.
C.-
20555 Washington, D. C.
-20515 -
John R. Biggar, Esq.
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Robert H.-Yaroschuk, Esq.
Pennsylvania Power & Light-Company t
- Bucks County Solicitor'
-901 Hamilton Street 1
Administration Building, Room.521 Allentown, Pennsylvania' 18101
,~
- Doylestown,-Pennsylvania.18901 j-l
_ Ms. Corothy Endrizzi William J; Laputka RD 1, Box _76 Township _ Manager; Sugarload, Pennsylvania 18249 L
' Falls Township Board of Supervisors-p 285 Yardley Avenue!
~
- John M.-Frysiak, Esq.
F Fallsington,EPennsylvania ; 19054 Atomid Safety and Licensing Board U. S. Nuclear. Regulatory Commission Samuel MW Snipes, Esq.
Washington, D. C.
20555 i
49-South Main ~ Street
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Yardley, Pennsylvania 19067
- Dr. Marvin M. Mann-Atomic Safety and Licensing Board Mr. David A.: Caccia'.
~ U. S. Nuclear Regulatory Comission
- - -Box 70-A RD 12
-Washington,'D. C.
20555 Sewell, New Jers'ey;(08080-d i
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Bruce S. Feldacker, Esq.
' Ralph Wood, Esq1 General Counsel Schuchat, Cook and Werner
- Public Service Company of New Hampshire 705.011ve Street - Suite 824 1000 Elm Street'.
St. Louis,' Missouri 63101
' Manchester, New Hampshire -03842 Dr. Vern R. Starks Ms.LElizabeth H. Weinhold Route 1, Box 863 Brandstreet Road-Ketchikan, Alaska 99901 Hampton, New Hampshire 03842 David J. Letvin, Esq.
Mr. Tudor'Richards-Cohn, Carr, Korein, Kunin k
Executive Director.
'and Brennan
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Audubon Society of New Hampshire 412 Missouri Avenue 3 Silk Farm Road East St. Louis, Illinois 62201
't Concord, New Hampshire 03301 Mr. David J. Newburger Mr. Paul 0. Bofinger' Washington University I
Chief = Forester Box 1120 4
Society for.the Protection of New St. Louis, Missouri 63103 Hampshire Forests j
86 Mountain Road Michael K. McCade, Er.q.
j 03301 First Assistant Commission Counsel l:
Concord, New Hampshire i
Missouri Public Service Conmission
- F Robert A.'Backus, Esq.
P. O. Box 360' Devine, ~Millimet, Stahl & Branch Jefferson City, Missouri.65101 i
1850 Elm Street
- Manchester, New Hampshire 03105 Mr. Robert L. Gilmore Secretary Missouri Public Service Company
. Norman.Ross, Esq.
- 30 Francis Street-P. O. Box 360 t
3rookline, Massachusetts 02146 Jefferson City, Missouri 65101
' Honorable Ellyn R. Weiss Assistant' Attorney General Environmental : Pro tection Divi sion s
_ One Ashburton Place i
Boston, Massachusetts 02108
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Dennis J. Tuchler,'Esq.
o St. -Louis University Law School
-3700 Lindell: Boulevard St. Louis, Missouri 63108
( Dr. George C. - Anderson
- Department ~ of 0ceanography -
. University of Washington-Seattle,1 Washington' 98195.
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