ML19339B024
| ML19339B024 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 11/03/1980 |
| From: | Black R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8011060180 | |
| Download: ML19339B024 (22) | |
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11/3/80 UNITED STATES OF AMERICA NUCLEAR REGULATORY C0fCIISSION FJ"rn;g,;nsTREUTION vro
- EsUmT BEFORE THE ATOMIC SAFETY AND LICENSING.BOAra. 4"1 8 5?
g In the Matter of
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a HOUSTON LIGHTING & POWER COMPANY
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Docket No. 50-466
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(Allens Creek Nuclear Generating
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Station, Unit 1)
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NRC STAFF RESPONSE IN OPPOSITION TO TEXPIRG'S MOTIONS FOR
SUMMARY
DISPOSITION DATED OCTOBER 8, 1980 On October 8,1980,S TEXPIRG filed a motion seeking sumary disposition of its contentions ACl (barge slip); 2 and 4 (cooling lake); 5, 7, 8 and ACl2 (alternative sources); and AC31 (technical qualifications).- # For the reasons set forth below, the Staff submits that the motion for summary disposition should be denied as a matter of law.
In previous Staff responses in opposition to other TEXPIRG motions for summary disposition, we have set forth the legal standards for summary disposition.
See e.g.. "NRC Staff Response In Opposition To TEXPIRG Motion For Summary Disposition of Contentier. AC8," dated October 2,1980. Our previous recitation of legal authorities makes it abundantly clear that the party secking summary SAlthough the certificate of service indicates that this motion was caile6 on October 8,1980, it is Staff's understanding that a copy was not delivered to Applicant until October 9,1980 (see " Applicant's Response to TEXPIRG's Motions for Sumary Disposition Served on October 9,1980," dated October 22, 1980) and Staff did not receive its copy from Applicant until October 14, 1980, because of an intervening weekend and holiday.
Staff was never served by mail.
Because this motion was due on October 8,1980, pursuant to the Board's Order of October 1,1980, it could be dismis"ed as untimely.
Be that as it may, the Staff urges the dismissal of the motion on other grounbs-set forth in this response, infra.
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-- These contentions arc reproduced and set forth in Attachment A for the con-venience of the Board. Although TEXPIRG has indicated thc+ its Contention 8 should be included in the " alternative sources" grouping, that so.M.in has been consolidated with Doherty Contention 8 and deals with Anticipated Transients Without Scram (ATWS). Thus, it appears that it has been added 4
to this motion by mistake and we do not include it in Attachment A.
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judgment, not the party opposing it, must demonstrate the absence of any genuine issues of material fact and the party opposing summary judgment need only show that there are genuine issues to be tried.
See eg., Cleveland Electric Illuminating Company (Perry, Units 1 and 2), ALAB-433, 6 NRC 741, 752-754 (1977).
Thus, in our previous responses in opposition to TEXPIRG motions for summary disposition, we attached affidavits from expert witnesses and presented statements of material facts which indicated that, in the Staff's opinion, genuine issues of fact remained to be litigated on each contention.
With respect to the instant motion, the Staff submits that the summary disposition motion is so legally insufficient that it fails to comply with the requirements of 10 C.F. R. 62.749. TEXPIRG has failed to meet its primary burden of placing sufficient admissible evidence into the record to show the total absence of a genuine controversy as to the determinative facts.
In fact, the motion has set forth no admissible evidentiary material by way of affidavits, depositions, or interrogatory responses, to meet this primary burden.
The motion consists entirely of unsupported assertions and legal conclusions by TEXPIRG's counsel.
These assertions and conclusions by counsel are not " relevant, material, and reliable evidence" and, therefore, not admissible in NRC proceedings.
Accordingly, it is clear that these assertions are no more than
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unadorned argument and, like briefs or legal memoranda not in affidavit form, cannot be used as evidentiary support for summary disposition.
Tunnell v. Wiley, 514 F.2d 971 (3d Cir.1975); Smith v. Mack Trucks, 505 F.2d 1248 (9th Cir.1974).
Based on this patent deficiency, the Staff is of the opinion that the summary disposition motion need not be answered.
It is well established that:
Where the evidentiary matter in support of the motion does not establish tiie absence of a genuine issue,
' summary judgment must be denied even if no opposing evidentiary matter is presented.
Cleveland Elect. ic Illuminating Co. (Perry Nuclear Power Plant, Units 1 and 2),
ALAB-443, 6 NRC 741, 753-754 (1977) quoting Adickes v. Kress & Co., 398 U.S.
144,159 (1970) (emphasis in origina.,
no defense to an insufficient showing is required.
6 Moore's Fed. Prac. 656.22[2] (2d Ed. 1980). Thus, by merely filing its motion for sunrnary disposition, TEXPIRG does not become entitled to answers givt. g it notice of the manner in which the Staff and Applicant will meet at trial the issues covered by the motion.
For the reasons set forth above, the Staff submits that TEXPIR'i's motion for summary deficient is entirely devoid of admissible evidentiary motter to support the motion and, therefore, should be denied as a matter of law because it does not meet the requirements of 10 C.F.R. 52.749. Accordingly, the Staff need not disclose or defend its position or to reply to the argument which, in effect, is an impermissible substitute for discovery.
To do otherwise would be a needless burden on Staff resources and would jeopardize established 1
l legal procedures recognized by the Commission and set forth in its Rules of Practice.
As stated above, Staff does not need to reply to ts.
T.,tance of TEXPIRG's motion because it should be denied as a matter of law.
However, we will set
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forth a few comments with respect to the contentions which are the subject of the,ummary disposition motion to indicate that the motion is totally lacking in :nerit and that there are issues remaining for trial on each contention.
o.
TEXPIRG AC sl.
The soon-to-be-published Second Supplement to the Allens Creek Final Environmental Statement (November 1980) will contain the Staff's assess-ment of the environmental impacts of the transportation of the reactor pressure vessel by barge.
It will also contain an assessment of the alternatives to that transportation proposal.
Contrary to TEXPIRG's unsupported assertion, ultimate NEPA judgments on any facility are to be made on the basis of the entire record, including supplemental testimony (and supplements to the FES),
before the adjudicatory tribunal.
Philadelphia Electric Co. (Limerick Gerierating Station, Units 1 and 2), ALAB-262,1 NRC 163 (1975).
In addition, the Comission's regulations recognize that evidence presented at a hearing may cause a Licensing Board to arrive at conclusions different from those in the FES, in which event the FES is simply deemed amended pro pnto.
10 C.F.R. 551.52(b)(3); Allied General Nuclear Services (Barnwell Nuclear Fuel Plant Separations Facility), ALAB-296, 2 NRC 671 (1975). Thus, the FES, F2S Supplements, and supplemental testimony can provide the basis and support for ultimate NEPA judgments.
TEXPIRG Contentions 2 and 4.
The Staff agrees with Applicant that paragraphs 1, 3
2 and 4 are mere restatements of TEXPIRG's contention and that paragraphs 3 and 5 appear to be outside the scope of the admitted contention.
See Applicant's Response, supra, p. 5.
In any event, the Staff has analyzed the proposed cooling lake and has concluded that it should provide a valuable recreational fishery
-] Applicant's reference to this paragraph as "4" appears to be a typographical 3
mistake.
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(Final Supplement to FES, Summary and Conclusions - Item 3(i), p. S.iv). Thus, a genuine issue with respeu. to this contention remains for litigation.
TEXPIRG Contentions 5, 7 and AC 12.
The assertions in support of summary disposition with respect to these contentions have no evidentiary basis.
In addir. ion, Paragraph 1, which addresses "need for power" is beyond the scope of the admitted contentions.
Section 9.1 of the FES and Final Supplement to the FES evaluated alternative energy sources.
Based on this evaluation, the Staff believes that a genuine issue remains with respect to these content 10.r.
TEXPIRG Contention AC 31. Again, the assertions in support of summary dis-position with respect to this contention have no evidentiary basis and, in fact, are not relevant and material to the disposition of the issue.
In Supplement No. 2 to the Safety Evaluation Report related to construction of Allens Creek Nuclear Generating Station, Unit 1, NUREG-0515, March,1979, the Staff affirmed its conclusion that the Applicant is technically qualified to design and construct the Allens Creek Nuclear Generating Station, Unit 1 (Section 13.1). As stated we had noted that the Applicant's (1) updated corporate and technical organization, (2) technical resources as embodied in the numbers and technical experience of personnel assigned and available to the project, and (3) the quality assurance program as described in
Section 17.0 of the report were acceptable.
Thus, the current Staff position is not in ao:eement with TEXPIRG's contention that HL&P is not technically qualified to design and construct the Allens Creek Nuclear Generating Station.
With regard to the foul bases that TEXPIRG listed in its motion for summary disposition we note that:
(1) the Commission's regulations do not specify that an applicant nust have more than six Ph.D. 's, (2) no deficiencies in the quality control and construction program at the South Texas plant have f
been identified by the NRC Staff as a sufficient basis for requiring changes in HL&P's organization for design and construction of ACNGS as described in its Preliminary Safety Analysis Report (PSAR), (3) the Commission's regulations do not require a specific accuracy in estimating amounts of materials to be purchased, and (4) the Commission's regulations do not requi 2 that rejection of the applicant lowest on a list ranked by performance (even if that were the situation) if the applicant meets the Commission's regulations.
In conclusion, this motion must be denied because it (1) does not meet the requirements of 10 C.F.R. 62.749, and (2) the assertions in support of sumary disposition on each of the contentions have no evidentiary basis and, in some instances, are outside the scope of the admitted contention.
Res4ectfully submitted, J (;d
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Richard L.
lack Counsel for NRC Staff Dated at Bethesda, Maryland, this 3rd day of November,1980.
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Attachment A B t;ge slip TixPirg AC 1 s
i Applicant has disclosed that it will transport the reactor vessel to the Allens Creek site by barge.
It will be,necessary to dredge the San Bernard River to allow such barging.
This dredging wi]l disrupt marine life, cloud the water, destroy river bottom life, require spoil disposal, and promote increased industrial use of the river, resulting in secondary environmental impacts.
S.4.5.1 (3) on P9 S.
4-14 of the Final Supplement to the Final Environmental Impact Statement (FSFEIS) does not adequately disclose and analyze the alternatives chosen for the transport of construction related components to the site.
In particular, the Applicant has not clearly determined whether waterway barge transit will be used for transportation of large reactor components to the site.
Such a transportation scheme would require dredging and channelizing of sections of the San Bernard River or Brazos River.
Such activity would disrupt marine life in that river, create excessive turbidity, and clouding of the water, destroy river bottom life, require environniental destruction during spoil disposal and initiate secondary impact in the form of increased industrial uses of the rivers.
Petitioner contends that Applicant's commitr.ent to transportation of the reactor vessel should be expressed more specifically and that the Board should either deny the license wholly or require the alternative site action sought by TexPirg in Contention 1 of the " Stipulation between TexPirg and the NRC Staff", if the dredging and channelizing is necessary.
The final EIs does not specify how the reactor vessel will be transported to the construction site and what means have to be taken to effect this transportation.
The probability that this transportation will have an environ-t t
mental impact necessitates its coverage in a final EIS for construction.
For example, dredging, widening or otherwise altering the Brazos River to bring the vessel to the site by barge would have an environmental effect.
It is requested that the construction permit not be issued until the reactor vessel transportation is ouffi-ciently addressed.
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o Cooling lake / recreational benefits Tex?irg 2 and 4
[Griffith 4; McCorkle 2]
Due to its size and location, the cooling lake for the nuclear power plant at Allens. Creek will be useless as a recreational. fishery.
In particular:
(1)
The location fails to include the nearby bluff area as a. recreational and fish spawning area.
(The dam should be extended north to a point just east of its present' northeast corner.
This extension will channel more runoff into the lake and will submerge the bluff area.)
(2) chlorine releases into the lake will kill significant numbers of fish.
(3)
Sewage discharges from Wallis, sealy, and the nuclear power plant will cause excessive algae growth in the lake.
(4)
Heavy metals will concentrate in the lake and in the fish, making them inedible.
(5)
Thermal shock will kill large numbers of fish when the plant shuts down during the winter.
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j{TcxPir'g 2]';The smaller cooling lake size and changed location of the lake vis a vis the original proposal will render the lake useless as a viable recreational fishery because:
a.
the changed location eliminates the Bluff area as a recreationa,1 and fish spawning area; b.
the amount of chlorine which will be released to the lake has more than doubled, which will result l
in significant fish kills; c.
sewer discharges from Wallis, Sealy and the nuclear plant will cause an excessive algae growth in the lake; f
d.
the heavy metal concentrations in the lake will result in heavy metals concentrating in the fish and will make them inedible; and k
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thermal shock will kill large numbers of fish during the winter when plant shutdowns occur.
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[TexPirg 4]
Even 'if a cooling lake is approved by the Board,the Board should require that it be redesigned to
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be more.of an environmental benefit and less of an environ-mental burden.
Specifically, the dam (levee) should be extended northward to a point just east of its present northeast corner so that the runoff can go into the lake and so that the north bluff area can be a viable fish spawi.ing is re a.
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I Solid waste combustion -TexPirg 5~[Cumings 6(b)]
Residents of Houston produce 6,000 tons of solid waste daily.
By building a 3,000-ton-a-day electrical generating plant fueled by this solid waste, Applicant can obviate the need-for the ACNGS.
Nei'ther the Applicant nor the Staff have given adequate consideration to the combustion of solid waste as an alternative energy source, because:
a.
The Staff concludes on S 9-9 of the DS-FES that "the lack of demonstrated technology on a commer-cial basis eliminates the potential future energy 1
sources from consideration as alternatives for i
central station power by the late 1980's, apparent-ly including refuse combustion among the " future alternatives".
However, the evidence will indi-cate that the Staff has been inaccurate with regard to solid waste combustion.
Twenty-one operational plants exist in the United States, with more than one dozen under construction, over forty in the advance planning stage, and over 4
sixty in the feasibility study stage.
- Further, such facilities have operated successfully in Europe for over 40 years.
i b.
The Staff states on S 9-6 of DS-FES that solid waste generation plants should be used to " regain lost energy", but expresses doubt that such plants will be contributing electricity in the near future.
The heat content of solid mixed municipal waste is approximately 5,000 BTU /lb. or 40 percent the value of coal.
In waste processing systems, the removal of light combustibles and separation of non-combustibles like glass and metals yield a paper-rich fraction in excess of 10,000 BTU /lb. or 90 percent the heat value of coal.
Among the 80 operating " waste-to-electricity" plants in Europe are plants in Amsterdam and Frankfurt which supply i
six and seven percent of their city's electricity needs, respectively.
The assumptions of the Staff regarding the use of this option are therefore incorrect.
6.
c.
The six thousand tons per day of solid waste in Houston ale more than adequate to support a three-thousand ton per day conversion plant that would obviate the need for the proposed ACNGS; and this alternative is technologically, environmentally, I
and economically desirable relative to nuclear generation stations.
(This option should be an 4
issue at this hearing.
Petitioner believes the t
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solid waste of Houston can sustain 800-1,000 MWe i
of production; though this level of supply could not have substituted for the two-unit'ACNGS proposal i
in 1975, it does become viable in comparison to only one unit.
In addition, since July, 1975, 28 cencnunities have begun feasibility studies for solid waste power generation, 14 new plants went into the planning stage, and tuo more plants becan.e operational - thus suggesting an increased viability of this option during that time).
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Energy conservation T0xPirg 7c.-c'[Doggett 1(a)]
t There has not been a dispositive assessment of the I
energy demand reduction potential that might derive from i
conservation measures available to Applicant because:
a.
direct capital investment by the Applicant for conservation retrofitting in the service area has-not been considered; i
b.
inadequate attention has been given to the likelihood that major industrial user 3 in-the 4
Houston area will be producing their own energy in the near-future; and, c.
the rate structure of the Applicant dees not provide an incentive for energy conservation.*/
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Solar power tToxPirg 7J-[Cumings 6(c)].
A:
There has not been a dispositive assessment of the energy demand reduction potential that might derive from conservation measures available to Applicant, because neither Al'plicant nor Staff has considered the increased use of passive solar techniques.*/
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As consolidated by the Board's Order of May 23, 1980.
b.
TexPIRG Contention 7_(9/26/78)
Energy conservation has not been adequately considered as an alternative to the proposed facility because:
a.
direct capital investment by the Applicant for conservation retrofitting in the service area has not been considered.
Examples of reasonable retro-fits are more effective insulation, seali?,, more efficient lighting units, imp. roved air concitioning maintenance, use of more efficient glass, and use of
,more efficient industrial processes such as waste heat recovery.
Expenditure of funds by the Applicant in the range of 50 percent that proposed for ACSGS would mean that the remaining demand for electrical power could be met with solid waste ccmbustion as detailed in a separate contention; b.
inadequate attention has been given to the likeli-hood that major industrial users in the Houston area vill be producing their own energy in the near future.
Texas City industrial complex, Dow Chemical complex and Bayport complex are presently cor.sidering such an option; c.
the rate structure of the Applicant does not provide
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an incentive for energy conservation.
Recent testi-many before the Texas Public Utility Commission by Dr. Frederick Wells demonstrates the viability of-altering the rate structure to significantly reduce power usage; and d.
neither the Applicant nor the staff has considered the increased use of " passive solar" techniques, such as architectural modifications and landscaping techniques that optimize the use of solar energy for residential and commercial structures.
Expanded conservation measures as set forth above would mitigate the need for a large central power station such as ACNGS.
This is especially true because:
1.
applicant's projections of power demand have cecreased 22 percent in the period in which the proposed facility was d'eferred, and 2.
reduced power production of a one-unit AC::GS Vis a vis that of the original two-unit proposal can more readily be obviated by the measures outlined above.
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Solar _yower TexPirg 7d [Cumings 6(c)].
A:
There has not been a dispositive assessment of the energy demand reduction potential that might derive from censervation measures available to Applicant, because neither Applicant nor Staff has considered the increased use of passive solar techniques.*/
- f As consolidated by the Board's Order of May 23, 1980.
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Energy conservation
[Cummings 6 (c) ; Doggett 1(a); TexPirg 7]
A.
[TP)
Energy conservation has not been adequately considered as an alternative to the proposed facility because:
a.
direct capital invesbr.ent by the Applicant for conservation retrofitting in the service area has not been considered.
Examples of reasonable retrofits are more effective insulation, sealing, more efficient lighting units, improved air conditioning maintenance, use of more officient glass, and use of more efficient industrial processes such as waste heat recovery.
Ex-penditure of funds by the Applicant in the range of 50 percent that proposed for ACNGS would mean that the remaining demand for electrical power could be met with solid waste combustion as detailed in a separate contention; b.
inadequate attention has been given to the likeli-hood that major industrial users in the Houston area will be producing their own energy in the near future.
Texas City industrial complex, Dow d
Chemical complex and Bayport complex are presently considering such an option;
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c.
the rate structure of the Applicant does not provide an incentive for energy conservation.
Recent testimony before the Texas Public Utility Commission by Dr. Frederick Wells demonstrates the viability of altering the rate structure to significantly reduce power usage; and d.
neither the Applicant nor the Staff has con-sidered the increased use of " passive solar" techniques, such as architectural modifications and landscaping techniques that optimize the use of solar energy for residential and commercial structures.
Expanded conservation measures as set forth above
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would mitigate the need for a large central power station such as ACNGS.
This is especially true because:
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applicant's projections of power demand have I
decreased 22 percent in the period in which the proposed facility was deferred, and 2.
reduced power production of a one-unit ACNGS vis a vis that of the original two-unit proposal can inore readily be obviated by the measures outlined above.
B.
(D]
Has a dispositive ascessment been made of the energy demand reduction potential that might derive from cons <rvation measures available to applicant?
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1 Interconnection / purchase of power tTexPirg AC lL Applicant can eliminate the need for ACNGS by interconnecting with other electrical systems across the country, because they have excess capacity which can be purchased by HL&P in lieu of constructing ACNGS.
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Studies such as that conducted by Taylor in Energy:
The Easy _ Fath and by the Subcommittee on Energy of the Joint Commission of Congress indicate that national, systemwide conservation decreases the need for new generating facilities nationwide; and this can provide the applicant here the alternative of interconnecting the HL&P system to other electrical systems across the nation which presently have excess capacity and will have even greater excess capacity in the future due to conservation.
By interconnection of grids, the required reserved margin can be reduced for_HL&P, and the need for additional generating capacity will be obviated because of the lowered need for reserves and the reduced industrial electrical demand (relative to that projected by Applicant) resulting from the Houston area's designation as an air quality non-attainment area.
The t
state and local governments, and business groups, have stated that the EPA's " offset policy" of enforcing the non-attainment designation will curtail Houston industrial growth.
The PID failed to consider the question of inter-connection as an alternative, and the FS-FES is deficient in that respect because it examines interconnection only in the sense of a discrete purchase of power transaction.
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Technical qualifications T7cxPirg Ar 31. [Doggett 3]
Applicant adequately shown,The PID did not thoroughly review, nor has the to construct ACNGS.
that HL&P is technically qualified that the Applicant is not technically qualified to dThe following forms a b and construct the proposed facility:
esign nuclear power ~ plant with a record of safe operation;The Ap a.
b.
In 1978, that HL&P had underestimated the amount of steelan internal study by the for HL&P's South Texas Project by 122 required rebar by 125 terminations %, piping by 88%, wire an%, concrete by 63%,
by 71 d cables by 100%,
49%, at the time o%, cable trays by 116%, and conduit by f application to build the South Texas Project in 1973.
timation was partially due to " development from theThe report conclud tual stage" which had occurred since the construction license concep-proceedings there.
in the Applicant's power plant construction planniThis may indicate tech ng; c.
NRC inspections indicate that the Applicant de
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viated in at least three instances from the PSAR submitted for its South Texas Project, all of which related to quality assurance, and this raises questions regarding the Applicant's ability to meet commitments in its ACNOS PSAR:
d.
meet a commitment that a gantry crade <1t the South TcxasH Project meet tornado stress leve)s due to providing i quate bid specifications to contractors, nade-relates to the technical performance of the Applicant inand this directly this docket; Texas Project (Rpt.In a 1977 NRC ' inspection report at HL&P's South e.
450-498-08),
the ten quality control inspectors stated that thHL&P was informed six of experienced harassment ey had and despite this notice,(including an individual report of a death threat),
instances of quality control inspector-reported harassat least four other were noted in later NRC inspections; ment NRC report states that QC inspectors at South Texas Pand an August 22, 1978 technical assistance from Project Quality Assurance Liagreed roject personnel; censee s _
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On Sept. 15, 1978, the NRC reported an investiga-tion of an' incident in which a quality control inspector alleged that HL&P's contracter at the South Texas Project fired him for strict inspection behavior, while the contrac-tor's employee alleged a conversation with the quality control inspector in which the inspector allegedly solicited a bribe and supposedly stated th-'t IIL&P would " stay out" of any quality control let-downs; and though intervenor does not know what in fact occurred in this incident, the matter is sufficiently serious to form the basis for the considera-tion of this contention in this docket; g.
HL&P is the Project Manager of South Texas Project and is ultimately responsible to the NRC for the 24 items of non-compliance reported in inspections there so far, and for the numerous construction problems such as building the mechanical auxillary building one foot too narrow and install-ing understrength bolts, and that such performance as project manager there raises questions as to the technical qualifica-tions of Applicant.
Because of the factors stated above, Intervenor contends that Applicant should be required to show that technical capabilities have been upgraded such that the
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problems encountered at its other nuclear project will not occur at ACNGS, with a finding that Applicant is not techni-cally qualified if that is not shown.*/
1 No rewording proposed.
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O'lliED STATES OF AMERICA NUCLEAR REGULATURY C0rtilSSION BEFORE Tile ATOMIC SAFETY AND LICEllSING BOARD In the Matter of Il00510N LIGitTING & POWER C0!!PANY Docket No. 50-466 (Allens Creek Nuclear Generatinq
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Station, Unit 1)
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CERTIFICATE Or SERVICE I hereby certify that copies of "NRC STAFF RESPONSE IN OPPOSITION TO TEXPIRG'S MOTION FOR
SUMMARY
DISPOSITION DATED OCTOBER 8,1980" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or as indicated by an asterisk by deposit in the Nuclear Regulatory Commission internal mail system, this 3rd day of November,1980:
Sheldon J. !!alfe, Esq., Chairman
- Susan Plettman, Esq.
Atomic Safety and Licensing Board Panel David Preister, Esq.
U.S. Nuclear Regulatory Commission Texas Attorney General's Office l'ashington, DC 20555 P.O. Box 12548 Capitol Station Dr. E. Leonard Cheatum Austin, Texas 78711 Route 3, Box 350A
!!atkinsville, Georgia 30677 Hon. Jerry Sliva, Mayor City of Wallis, Texas 77485 fir. Gustave A. Linenberger
- Atomic Safety and Licensing Board Panel Hon. John R. Mikeska U.S. tiuclear Regulatory Commission Austin County Judge Washington, DC 20S55 P.O. Box 310 Bellville, Texas 77418 M. John F. Doherty 4327 Alconbury Street Houston, Texas 77021 J. Gregory Copeland, Esq.
Baker & Botts One Shell Plaza llauston, Texas 77002 Mr. F. H. Potthoff, III Jack itewnan, Esq.
1814 Pine Village Lowenstein, Reis, Newman & Axelrad Houston, Texas 77080 1025 Connecticut Avenue, N.W.
Washington, DC 20037 D. flarrack 420 Mulberry Lane Carro Ilinderstein Bellaire, Texas 77401 8/39 Link Terrace liauston, Texas 71025
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Texas Public Interest Margaret Bishop Research Group, Inc.
J. !1 organ Bishop c/o James Scott, Jr., Esq.
11418 Oak Spring 13935 Ivynount Houston, Texas 77043
, Sugarland, Texas 77478 Brcnda A. McCorkle 6140 Darnell Houston, Texas 770/4 Mr. !!ayne Rentfro P.O. Box 1335 Rosenberg, Texas 77471 Stephen A. Doggett, Esq.
Pollan, flicholson & Doggett Rosenary N. Lesner P.O. Box 592 11423 Oak Spring Rosenberg, Texas 77471 Houston, Texas 77043 Bryan L. Baker
,1923 Hawthorne Houston, Texas 77098 Robin Griffith Leotis Johnston 1034 Sally Ann 140/ Scenic Ridge Rosenberg, Texas 77471 Houston, Texas 77043 Elinore P. Cunmings Atomic Safety and Licensing
- 926 Horace Mann Appeal Board Rosenberg, Texas 77471 U.S. fluclear Regulatory Comaission i1ashington, DC 20555 Atomic Safety and Licensing
- Board Panel U.S. Nuclear Regulatory Connission Mr. !iilliam Perrenod Washington, DC 20555 4070 iterrick Houston, TX 77025 Docketing and Service Section
- Office of the Secretary Carolina Conn U.S. :1uclear Regulatory Connission 1414 Scenic Ridge Nashington, DC 20555 Houston, Texas 77043
- r. William J. Schuessler U.S. !!uclear Regulatory Commission S810 Darnell Region IV Houston, Texas 77074 Office of Inspection and Enforcement 611 Ryan Plaza Drive The lionorable Ron Waters Suite 1000 State Representative, Distri.ct 79 Arlington, Texas 76011 3620 Washington Avenue, !!o. 362 a/ut LA Houston, TX 77007 Rich 6rdL.Bigck Counsel for NRC Staff i
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