ML19341D477

Response to ASLB 810209 Memorandum & Order Re Emergency Planning issues.NUREG-0654 Regulations Fully Applicable to TMI-1 for Purpose of Proceeding.Aslb Should Contact County & Local Witnesses.Certificate of Svc Encl

ML19341D477
Person / Time
Site:	Crane
Issue date:	02/24/1981
From:	Adler R PENNSYLVANIA, COMMONWEALTH OF
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8103050653
Download: ML19341D477 (16)

Text

{{#Wiki_filter:. . U.,. / 1.WI'ED STAIES OF AMERICA LP' ' ~ ~~ ~ NUCLEAR REGULATORY Cat 4ISSION muxE 7EE ATtI4IC SAFETI A10 LICENSING BOARD y$ J,j jj In the Matter of ) ) N E N TAN EDISON CI4PA14, ) cf 9 ) Docket No. 50-289 'b go- 'le Island Nuclear ) (Restart) /f gU fpc d.{ ,. y[I. Jp9t:5thit No.1) ) r gB M y g b.I 1 3, ?/,AII O111991 '.1 Ok p ce0,\\ f's.a c " ~ s sege 3 COtGEEA1lm 0F FmEYLVANIA'S Li ,N E W ON N U M M U IS E 6 i UsSe NUCLE 4a arcutAfont Conuel5110N '7 G(s' e a UIION / c,-I 7 This brief is filed in respense to the Board's 'Ymorandu:a and Order on Frargency Plaming Issues," dated Februarf 9,1981. 24 Board's Mancrandu:n and Order directed parties with an interest in emergency plaming issues (1) to state their views with respect to tsa four emergency plaming questions posed in the "Cactrrmalth of Pemsylvania's Cocznents and Proposals Regarding Methods to Expedite the Proceeding" (dated February 3, 1981); (2) to outline the status of negotiations and agreenent among the parties with respect to these issues; and (3) to make recocmendations for receiving evidence on emergency plannirg contentions. This brief will address the status of negotiations and agreement concurrent with the analysis of issues, since this approach aids in focusing the questions that must be presented to. the Board for decision. Before proceeding with the analysis, it is useful to clarify the fuhtal basis for the Cauuumalth's positions en mency plaming issues. The Board and the parties undoubtedly realize that the Co:muwealth's role with respect to the offsite ecergency planning phase of this proceeding ic dual in nature. On the ene M, h d i A 8103050/ N c:p

could be viewed as a pure advocate, defending the validity and adequacy of the state's radiological emergency planning ag=%t the allegations contained in intervenor contentions. On the other h.md, the Cocmonwealth maintains with respect to offsite emergency planning the same goals as it has stated consistently throughout the proceeding--that all issues impvd.nt to the safe operation of M-1 be subject to a full and fair adjudication and an appwytiate burden of proof. Consequently, positions adopted in this brief which may appear inconsistent with the Councawealth's role as an advocate, stect from the Ccx:r:cnwealth's overriding concerns with the health and welfare of its citizens. 'Ihe standards for 6e review of emergency plaming issues should be no less stringmt than for any other issue relevant to the restart of M i.. II. ANALYSIS AND STA'IUS OF IEGOTIATIONS AND AGME Counsel for the Licensee stated during da February 3, 1981 session on scheAn1hg and expedition of the proceeding that all of the emergency planning questions raised in the Cmmnwealth's Februamr 3,1981 filing were resolved previously during the October 30, 1980 special session on emergency planning. Counsel for the Cocr:cnwealth agreed with this statement; but pointed out that the Cocmission n:ight not necessarily agree with the resolution adopted by the parties. Upon a more careful reading of the October 30, 1980 transcript, hcmever, the Cocmonwealth concludes that the agreement reached during that session was less perfect than may have been apparent at the time. Fbreover, the Eoard issued no express rulings regarding the questions argued by the~ parties at the October 30, 1980 session. "mus, a nu=ber of issues r - M unresolved. Hopefully, rcre precision can be cbtained through the filing of the current round of briefs. 'Ihe Cu.maealth urges the Board to set a more j l definitive framecrk for the litigaticu of energency planning issues by ruling as soon as possible on all renaining areas of disagreenent. 'Ihis section will outline first those questions on which the Cournamealth agrees that satisfactory agreement was rarbd at the October 30, 1980 session. 'Ihis will be followed by an identification and analysis of those major questions where apparent disagreement renains. It should be noted that the questions posed in the emmawealth's February 3,1981 filing are not identical to those posed in the Cocmomalth's October 20, 1980 filing. 'Ihe specific October questions were, in fact, resolved et the October session. 'Ihe February questicns, however, relate to a:biguities r=4ning after the October session. Finally, as a st=rnary of the analysis, the e - a.alth will conclude this section by stating its positiens on the four questions cited in the Board's February 9,1981 Manorandum and Order. A. Areas o'f'Azreement 'Ihe "Cocznamealth of Pennsylvania's Forculatiot> of Unresolved Emergency Planning Questiens" (October 20, 1980) posed three questions: 1. What standards are to be used in this procW4ng to judge the adequacy of emergency planning (Reg. Guide 1.101, NUREG-0654, or the independent jutv-it of the Board)? 2. What level of off-site emergency planning rust be reviewed and evaluated in this proceeding (state, county, municipal)? 3. Who is responsible for applying the standards and making the initial determination of adequacy at each level of planning discussed in question 2 (FDR or NRC)? With respect to each of these specific questions, satisfactory agreecent was reached ancng the parties for the pu 7ses of this proceeding, as indicated belcw. 1. All interested pc._ des agreed ti:at NLEG-0654, as referenced. _

~ in the Camission's new emergency planning rule,1 is the ayywytiate set of standards to be applied in judpg the adequacy of mergency planning for *IMI-l restart. Tr. 4225 (Staff), 4233 (Licensee), 4239 (cermrmealth), 4259 (Sholly), 4264 (ECNP), 4270 (ANGRY). 2. No dispute existed concerning the jurisdiction of the Board to review state and county energency planning efforts. Tr. 4243-44 (Comonwealth), 4246 (Licensee), 4252-53 and 4256-57 QFA). Agrement by the intervenors is implicit in their position that scrutiny should extend still further down to the nunicipal level. Tr. 4248 (AMRY), 4251 (Sholly), 4321 (Newberry). Although the relevance of meiripal ~ plans was not quite as clear, it tr.., agreed that nunicipal plans uny be reviewed in this case at least to the extent that nunicipal resources are expressly relied upon in a county plan to perform a parHmlar service or function. Tr. 4243-44 (Ca monwealth), 4246-47 (Licensee), - 4252-53 and 4285-86 (FD %). See also Tr. 4471-72, 4477-82. 3. Representatives of FD R and the NRC explained the relative roles of FDR and NRC at great length during the October 30, 1980 session.~ Tr. 4274-%. FDR will make initial determinations and provide wit:nesses with respect to the adequacy of offsite energency plaming. NRC will do the same for onsite emergency planning and the overall status of emergency ~ planning for the site. Neither the Licensee, Tr. 4299, nor the Comonwealth, Tr. 4298, disagreed with this position. Although the intervenors expressed concerns regarding potential conflicts between F FA and NRC,'e.g. Tr. 4279 (Sholly), 4291 (ECNP), this question need not be addressed unless and until a conflict actually arises. The Chair::an raisd aAA4Hnnal unresolved questions regarding the nature of the rebuttable presur:ption 1. 45 Fed. Reg. 55408-13 (August 19,1980) (to be codified at 10 C.F.R. 5550.33, 50.47, Appendix E). i -4, j

given to FDR's findings under the emergency planning rule.2 Tr. 4278-

81. Arguments on this point, however, would be addressed more appropriately l

in proposed conclusions of law, when the precise nature and scope of the FDR findings in this case are more clearly defined. Tus, there is sufficient v eement among the parties regarding the relative roles of FDR and NRC for the purposes of the adjudication. B Areas of Accarent Disagreenent Although the specific questions posed in the Cccr:cnwealth's October 20, 1980 filing were resolved, as outlined above, analysis of the statenents made by the parties suggests additional points of disagreenent.3 These points are listed and aplained below. 1. Although all parties agreed that NEEG-0654 is applicable to 24I-1 in this prock agrmt on the precise nature of IUREG-0654 applicability was not as clear. The spectrun of opinions runs as follows. Licensee argued that NUREG-0654 cocpliance necessary for this proceeding requires " reasonable progress tc: ward compliance with de April 1 and July 1, 1981 dates specified in the new emergency plan rule." Tr. 4233. The Staff stated the standard somewtat differently, as "ccx::pliance with the new emergency planning rule, and... reasonable progress toward the dated remirenents of iat rule." Tr. 4226 (ecphasis _ added). A reasonable interpretation of this statement is that the Staff distinguishes between NCREG-0654 requirenents that pre-date E4I-l restart 2. "The NRC will base its finding on a review of the Federal Emergency Management Agency (FDR) findings and deter:::imations as to whether State and local emergency plans are adequate and capable of being implemented...In any NRC licensing proceeding, a FD% finding will constitute a rebuttable presu=ption on a question of adequacy." 45 Fed. Reg. 55409 (August 19,1980) (to be codified at 10 C.F.R. f50.47(a)(.21 3. The Cacz:enwealth does not suggest that any intentional effort was made to create a false i=pression of agreenent. It is easier to discern fine lines of distinction by analyzing a written account than by listening to a lengthy, multi-party oral argument.

I t l and those that post-date DfI-1 restart, with full compliance required l for the former and reasonable progress required for the latter. mis interpretation appears to be emBM by the Cb=4mmn's subsequent discussion with the Staff's counsel. Tr. 4228-30.4 2e enwrnwealth's position suggested that, for practical purposes, HUED-0654 should be considered a short-term restart requirement: _.1 We don't know exactly what reasonable progress is, but in this proceeding it probably does not matter beme of the ti=ing of the anA14nes contained in NUREG-0654, par *1=-ly April 1 and July 1. We think, as the staff does, that that time is 1-going to be upon us before the Qrr::ission has mh a decision about restart or approved what this Board has unde as a decision. So in essence, we are talking about compliance with NUREG-0654 by the time of restart 4. 'Ihe follcwing passage is particularly 41Wnating: "GAIEMAN SMIE: Would it be your view that the Li.:ensee does not have to comply with, for example, the 15 minute notification rule until July 1981? MR. GRAY: Yes, that would be our view, although as a practical matter, of course, it is likely that restart, if authardred, would i not occur until about that time or afterward in any event. CHAIRMAN SMIE: I understand, but assu:::ing just solely for the purpose of argument, you would not oppose the operation of DII 1 before July 1981 if they could not ecx:: ply with the 15 minute notification standard, if you had reascuable asstrance after July 1981 they could? MR. GRAY: Yes. With reasonable progress toward that capability." Tr. 4230..

because we assume that it is going to be later than the daad1Mes that are cont =4nad in huGG-0654.5 Tr. 4240. Finally, various intervenors stated categorically that full compliance with IMEG-0654 should be a prerequisite to M-1 restart. Tr. 4264-65 (ECNP), 4270 (AIGE). 2. B e same conclusions can be reached about the parties' ~ varying views by analyzing the reasons given for applying huEG-0654 to this proceeding.6 Licensee begins with the cerr u sion's long-te m order item 4(b), equating WREG-0654 with the 10-cile upgrade requiranent in item 4(b).7 Tr. 4234. This, in effect, makes cccolianc~e with NUREG- ~ 0654 a long-term requirenent, with the acccx::pazrf ng " reasonable progress" i standard, he Staff, on the other hand, inserts NLEG-0654 in place of the now withdrawn Regulatory Guide 1.101. Tr. 4225. Alternatively, the Staff agreed that ccx:pliance with Regulatory Guide 1.101 is no longer a " sufficient" short-term emergency planning standard. Tr. 4228. Using" ' either variat.icn of the Staff's analysis, co pliance with NUREG-0654-beccznes a short-term rather than a long-te::1 restart requirement, with the exception of those elenents of NUREG-0654 that clearly post-date restart. This difference between the Staff's and Licensee's position -%--"= 5. The Or =,malth, of course, agrees with the Staff's position that only reasonable progress need be demonstrated for requirements which will clearly post-date M-1 restart (for exa::ple the April 1,.1982 -- dand1 5e for installation of meterological equi y ant; NUREG-0654, y Annex 1 to Appendix 2, at 2-8). 6. Both the Ccxnnenwealth, Tr. 4240, and the Licensee, Tr. 4234, ~ ~ expressly e::phasized that their reasons for reaching NUREG-0654 differed. 7. Iong-term item 4(b) requires Licensee to: " extend the capability to take oggiugulate a::ergency actions for t.he population around the site to a distance of 10 miles."~ Slip ca. at 8..

also serves to focus the dichormy created by the prcx:ulgation of the new emergency planning rule betweca short-tem iten 3(a)8 and long-tem item 4(b). h Licensee takes the position that short-tem item 3(a) drops out, while ec pliance with NUREG-0654 and the new rule is inserted as long-term iten 4(b). 2:a Staff apparently is of the opposite view: long-tem item 4(b) drops out, while ccrupliance with NUREG-0654 and the nea rule becomes short-te=n iten 3(a). h Cuua.u malth reaches essentially the same position as the Staff, althou6h through a different analysis. Since only the Cct:u:ission has the authority to modify the August 9,1979 Order and Notice of Hearing, codification of either short-term itan 3(a)- - or long-term iten 4(b) could be accocplished only by'the Cacr:f.ssion's proculgation of the new rule. Tr. 4240. NLEEG-0654 is expressly noted in the new rule as the ugyteytiate set of criteria for judging emergency plaming, and therefore by i= plication replaces Regulatory Guide 1.101 ~ as part of short-term iten 3(a). This conclusion is further supported by a practical analysis of the new emergency planning rule. thder the new rule, M -1 could be treated either as a new operating license candidate under 10 C.F.R. 550.47, or as an operating power reactor under 10 C.F.R. 550.54. Treatment as a new operating licente candidate would require compliance 7' with the new emergency planning criteria prior to issuance, or in this case reactivatien, of an operating license. 10 C.F.R. 550.47(c)(1). Licensee undcubtedly will argue that HII-l should be treated as an operating reactor. But even in this case, full i=plementation of energency plans that cocply with the new criteria is required by April 8. Short-term iten 3(a) requires Licensee to: "L) grade emergency plans to satisfy Regulatory Guide 1.101 with spehl atterim to action level criteria based on plant parameters." Slip co. at 6 (emphasis added)..

Y 1, 1981--prior to 'IMI-l restart.9 10 C.F.R. 550.54(5)(2). It does not 2 make sense for the Board to judge under a " reasonable progress" standard coupliance with a regulation that has an April 1,1981 daad14na.10 'Ihe effect would be to grant M-1 a preferred status over other operating reactors. 3. As a result of the above-stated dispute over whether NUREG-0654 coupliance is a short-term or long-term requirement, an additional disagreenent arises concerning the Board's scrutiny of the actual can=c4 y to implement the 'IMI-1 emergency plans. As a corollary t 1 to Licensee's analysis, Licensee expressed the opinion that short-term r~ ~ item 3(d) requires only a: minimal requirement that cr=amications, acceptable, cocpatible e - m4 cations between the Licensee and the state and local governments *e established... i' Tr. 4237. ~ 'Ihis analysis limits the Board's jurisdiction in the short-term order. j . item to a paper analysis. ~ [ The Cocmonwealth disputed this interpretation at the October p 30, 1980 session: j Now, on the issue that we brought up about whether the capability to inplement the plans, as ~ Licensee's own analysis indicates that restart can be accacplished, c. 9. at the earliest, by Mamhar of 1981 (full power operation). li:mw.andun from George F. Trowbridge, Councel for Metropolitan.. Edison Company, to Chairman John F. Ahearne and en=dasioner Joseph. s M. Hendrie, February 17, 1981. i f

10. The Cacinonwealth excepts fmn this analysis requirenents in REEG-0654 that post-eate restart. See note 4, suora. 'Ihe 15-minate siren noti #ication systen, with a July 1, ITdT da=Alina, 10 C.F.R.

Part 50, Appendix 6, SIV D.3, pre-dates restart but post-dates the close of the record. 'Ihis is no different from numerous other issues in this roceeding for which Licensee will not be in j cocpliance at tae close of the evidentiary record, but for which Licensee has cr-deted to ccr:pliance prior to restart. As with these other issues, the Board will have to judge whether Licensee - has demonstrated that compliance will be achieved prior to restart. This is different frcan the long-term standard of reasonable progress towards cocpliance at the time of restart. _9_

C well as the suff4r4 m of the d e m ts themselves are to be considered in this proceedi g, I think we understand parHenlely from the En and NRC IEEGs that i=plementability... definitely is an issue sitich is cognizable in this proceeding, and we are not just talking about the sufficiency on the face of the documents th=esclves. Tt. 4241. De new energency plaming rule requires " reasonable assurance that appiverlate protective actions can and will be taken..." 10 C.F.R. 550.54(.5)(2) (emphasis.,ddad). Berefore, it ccc:pliance with the new rule is viewed as a short-term requirenent, the capability to implenent the emergency plans is a short-term consideration as well. 4. Re final area of disagreat relates to the manner in which the adequacy of county and local emergency planning will be litigated. See, e.g., Tr. 4248-50. h Cannonwealth notes that the problem of the lack of county and tunicipal witnesses has not been resolved. Testimony to be presented by the C6.uwmalth will rec-d. that da Board subpoena county coor'dinators as Board witnesses. C. Conclusion As a sumnary and conclusion to the analysis perfor=ed above, the Com:rmealth will state its positions on the four questions posed in the Board's February 9,1981 Menorandini and Order. (a) How should the new emergency planning regulations and I E EG-0654 be applied to M -l? and (b) Is full mR approval considered to be a restart requirenent 11 or is a " reasonable progress" standard tore oey&vytiate? Answer: 2 e new emergency planning regulations are fully applicable to M -1 for the p ses of this proceeding. He new regulations incorporate IEEG-0654 as the applicable dteria for ~jndging the adequacy of emergency planning.

11. Questiens (a) and (b) are rest agguoptiately addressed together. _

_=- \\ Licensee should be required to da:onstrate full cocpliance with the criteria enumerated in the new regulation, as dictated by the April 1, 1981 implementation date contained therein. Specific elements of empliance that post-date the expected date of restart, as defined in NUREG-0654, need only meet a " reasonable progress" standard. (c) What is meant by the requirenent to " Assess the relationship of State /Incal plans to the Licensee plans so as to assure the capability l to take emergency actions." (Short-tern item 3(d), August 9,1979 Order) Answer: 'Ihe key words that need to be defined -are: ...so as to assure the capabild'ty to take ecergency actions." 24 appropriate standard for this short-term itan is now defined by the new e:ergency 1. ~ plaming regulation, which requires " reasonable assurance that ayywy1. late protective actions can and will be taken..." 10 C.F.R. 550.54(5)(2).._ 'Ihis requires an assessment of the actual ability to. implement emergency. plans as a short-term requirenent. (d) Clarify the distinction in the August 9,1979 Order between short-term iten 3(d) and long-te=n itan 4(b) (capability for i ~ ~~ emergency actions to a distance of 10 miles around the 7.ite)._ _ _ _ _ i Answer: 'Ihe new emergency planning rule, encompassing NUREG - c._ t 0654, establishes the current standards for the entire short-term item 3. Based on this analysis, the only reaining long-term consideraHem would be those NUREG-0654 requirenents that post-date the expected date of restart. III. RECOECATIONS FOR RECEIVING EVIDENCE Testimeny on onsite emergency planning cententions has already been filed by the Licensee and the Staff. "Ais tesdrony is scheduled to be

heard beginning March 3, 1981. Testirony on offsite mergency planning contentions is scheduled to be filed between February 23, 1981, and March 16, 1981. 'Ihe only limitation proposed by the Cocmonwealth with respect to this testi=eny is that three weeks be allowed for preparation of cross-e.u:dnation, as agreed during the October 30, 1980 session. Tr. 4317. Asstning that testi::eny on offsite planning will not begin until early April, this should pose no problem. A sufficient a:: cunt of testfrony will be filed by the Staff and the Ccx:nonwealth during the week of February 23, 1981, to constme at least the first week of offsite planning hearing time. Bus, three weeks of preparation will be avnHnble even for testinony filed on March 16, 1981. An additional issue to be considered is the synthesis of the entire emergency planning effort for 'IMI-1. As part of the agreement to consider onsite and offsite emergency planning separately, Licensee agreed that: "the extent to which the two plans wrk together--can be addressed in the second stage of the filing...'Ihe second filing is offsite energency planning and one would consider the adequacy of offsite energency planning ard in the context of that one could also at that time consider the adequacy of the ability of the licensee's plan and the state plans to work together and to integrate into a ccc:prehensive whole." Tr. 4314-15. Finally, the Coccor: wealth reiterates the apparent void in the n:eans available to the Board to develop a record in the area of county and local emergency planning testi=x:ny. Although EDR will present general testiretry in this area, Tr. 4250, the Board may fird it desirable to see county and/or local witnesses. 'Ihe Chair nn, in fact, suggested that this might be acccr::plished through the Board's subpoena power. Tr. _12

4249. Be Cocmxw.alth urges the Board to consider this alternative after reading the testimony presented by the other parties and detMnMg whether the record has been satisfactorily developed. Respectfully submitted, kk o RDBERT W. ADIZR Attorney for the Oceanwealth Dated: February 24, 1981 e e _m 6 $ e S ~ We m d g r l ;

UNI'IED STATES & AMCA NUCLEAR REGULATORY 03EISSION BEFORE 1HE AIU CC SAFEIY M D LICENSING BGS.RD In the Matter of ) ) P2.uG01.ITRI EDISCH C0t4PANY, ) ) Docket 16. 50-289 ('Ihree Mf.le Island Nuclear ) (Restart) Station, thit No.1) ) (2xn21CA3E & SERVICE I hereby certify that the attached "Cuam..malth of Pennsylvania's Brief an Emergency Planning Issues" was served this 24th day of February, 1981, to the persons on the attached serdce list, by hard and/or by deposit in the U.S. mail, first class postage prepaid. ROBERT W. ADIZR Attorney.for the Camonwealth N e, t vCfo U o h FEB 3 0 M " i $$Eff 3 q,

e UNTID STXlES G" AMDCCA NLC.IAR REUUCUC C2tCSSI3t BEIVRE "SE A':Di!C SAP:TT A:D I.ICCSI!C BCARD In the Matter of ) ) IE:RONLITAN DISQI C31PANf, ) ) D>:ket :b. 50-289 ("hree Mile IsLevi bclear (Restart) Station, thit !b.1) SER7 ICE IlST George F. Itowbridge, Esquire Dr. Linda W. Little Shaw, Pittumn Potts & Trowbride Atocic Safety and Licer. sing Board Panel 1800 M Street, N.W. 5000 Hers tage Drive Wahington, D.C. 20006 Raleigh, ! brth Carolira 27612 Ms. Wrjorie M. Aa:nodt Docketing and Se vice Sec R.D. #5 Office of the Secretary Coatesville, Pennsylvania 19320 U.S. Ibclear Regulatory Ccrcission Eshington, D.C. 20555 Ms. Holly S. Kack, leg. Chai:mmn Anti-lhelear G.oup Representing Ellyn R. Wiss York (A CKf) Sheldon, Har::en. Roiscan & Weiss 245 W. Philadelphia Street 1725 I Street, N.W., Suite 506 Ycrk, Pemsy: wia 1740/* Eshington, D.C. 20006 Ms. Frieda Beryhill, Chainnan Karin P. Sheldon, Esquire (PA!;E) Coalition fer Ibclear Power Sheldon, Ha: en, Reis=an & Weiss Plant Postponanent 1725 I Street, :i.W., Suite 506 2610 Cresbn Drive Wshington, D.C. 20006 Wi1=ington, Delaware 19808 James A. Tourtellotte, Esgaire Pr. Robet Q. Pollard Office of the ?xecutive Legal Director 609 !bntpelier Street U.S. bclear Reg.datory em-f nsion Bal N e, N ryland 21:18 Eshit.gten, D.C. 20555 W 1ter W. Cohen, Esquire John A.1 erin, Esqdre Consumer Advocate Assistant Counsel Departrent of Justice Pennsylvania Public Utility em hsian Serr.6erry Square,14th noor P.O. Bcx 3265 Harrisburg, Pennsylvania 17127 Harrisburg, Pcmsylvania 17120 Dr. Chauncey Kepford Robert L. Knupp, Esqaire Judith H. Johnsrud Assistant Solicitor, County of Dauphin Envircrre. cal Coalition on bclear P.O. Box P, 407 North Front Street Power Harrisburg, Pemsylvania 17108 433 Orlando Avenue State College, Pennsylvania 16801 John E. Mimich, Chairman Dauphin County Board of Cacrissioners Mr. Steve C. Shelly Dauphin County Courtrouse Lhion of Cbncerned Scientists Front and Market Streets 1725 I Street, N.W., Suite 601 Harrisburg, Pe = sylvania 17101 Eshington D.C. 20006 Jordan D. Gr:lin@.an, Esquire Ms. Imise Bradford Attorney for Ue. terry Township "lMI Alert T.M.I. Steeing emittee 315 Peffe Street 2320 l brth Second Street Parrisburg, Pennsylvania 17102 Farrisburg, Pe=sylvania 17110 Ivan W. S=ith, Esquire, Chairnan Marvin I. Iewis At:cic Safety and Licensing Board Panel 6504 Bradford Terrace U.S. :bclear Regulatory Caccission Philadelphia, Pemsylvania 19149 W shington, D.C. 20555 Jane lee Dr. Wite H. Jordan R.D. 3. Sex 3521 Atocic Safety and Licesing Board Panel Etters, Pemsylvania 17319 881 West Oute Drive Oak Ridge, Temessee 37830 'hras J. Cedne, Esq2 ire Deputy Attorney General Division of La.t Rocr. 316,1100 Ray end Boulevard ! Wark, U m J esey 07102

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