ML19350D830
| ML19350D830 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/08/1981 |
| From: | Burger F, Burger J, Laroche W, Sanger H, Wallace L TENNESSEE VALLEY AUTHORITY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OLA, NUDOCS 8105190397 | |
| Download: ML19350D830 (20) | |
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NUCLEAR REGULATORY COMMISSION Gi m
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD PANEL In the Matter of
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Docket Nos. 50-259 OLA TENNESSEE VALLEY AUTHORITY
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50-260 OLA
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50-296 OLA (Browns Ferry Nuclear Plant,
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(Low-Level Radioactive Units 1, 2, and 3)
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Waste Storage Facility)
APPLICANT TENNESSEE VALLEY AUTHORITY'S RESPONSE TO PETITIONERS' NOEL M. BECK, ET AL., SECOND AMENDMENT OF PETITIONS TO INTERVENE INTRODUCTION This proceeding concerns the Tennessee Valley Authority's (TVA) application to amend the Browns Ferry Nuclear Plant operating license for the sole purpose of obtaining permission to store onsite for up to five years low-level radioactive waste (LLRW) generated in the course of normal plant operation. Notice of an opportunity for hearing (Notice) was dated December 11, 1980 (45 Fed. Reg. 81,697).
Petitioners filed a number of identical petitions for leave to inter-l In its respcase filed January 27, 1981 TVA took the position vene.
that the petitions should be denied because none demonstrate a sufficient injury to any cognizable interest to justify intervention as of right or in the discretion of the Nuclear Regulatory Commission (Commission or NRC).
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I subsequent to the Atomic Safety and Licensing Board's (Licensing Board or Board) order setting a prehearing conference, all petitioners through a single document amended the petitions and stated four issues which they sought to litigate. TVA filed a response dated April 3, 1981 to the amended petitions also opposing them because of a failure to raise valid contentions.
At the April 10, 1981 prehearing conferences, petitioners asked that the Board delay issuing any order concerning the adequacy of the petitions until such time as they filed an additional. amendment.
The Board allowed petitioners 15 days to do this but specified that in so doing the requirement for submitting a justification for late filing was not waived. This document constitutes TVA's response to the second amendment to the petitious to intervene.
STATEMENT The statement of facts which follows reflects more informa-tion than is apparent from the bare licensing documents which have been submitted. TVA has gone into this detail because of the interest that the Board showed in the reasons for TVA's 5-year storage proposal.
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Operation of Browns Ferry Nuclear Plant results in planned I
generation of LLRW. This waste consists of ion exchange and condensate demineralizer resins and miscellaneoun trash such as polyethylene boots, rubber shoe covers, plastic hose, gloves, pine crates, scrap I
iron, mops, and brooms. TVA must be able to store or dispose of this 2
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waste in order to continue to operate the plant. Although there is a small amount of onsite storage capacity available at the plant, TVA presently ships most of its LLRW to the licensed LLRW disposal facility at Barnwell, South Carolina. However, space is limited at Barnwell, and the facility operator restricts the volume of wastes it will accept from the various utilities and others shipping wastes to Ba rnwell. The disposal space allocated to TVA for its-LLRW is gradu-ally decreasing, and TVA, like all others who ship to Barnwell, has been forced to seek alternative arrangements for managing ita LLRW.
Accordingly, the TVA Board has authorized the TVA staff to install facilities at the Browns ferry, Sequoyah, and Watts Bar Nuclear Plant cites which could be used to store LLRW until satisfac-tory provisions could be made for permanent disposal. At the same time the TVA Board authorized the staff to begin the preliminary design and investigative work that could eventually lead to a contract for the procurement and installation of a volume reduction system (VRS) at Browns Ferry, Sequoyah, and Watts Bar if a satisfactory system could be obtained. Actual procurement and construction of a VRS at any of these plants will not be made until satisfactory comple-tion of the design and environmental studies.
TVA's original (July 31, 1980) request to NRC was for approval to store LLRW onsite at Browns Ferry for the life of the l
plant. TVA later (November 17, 1980) modified the request to ask for 3
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approval to store LLRW for up to five years after the NRC staff informed TVA that it had decided to prepare an environmental impact statement (EIS) prior to approving any life-of-plant st(rage application 4.
Prior to submitting its original request, TVA had completed environmental assessments (EA) for Browns Ferry, Sequoyah, and Watts Bar Nuclear Plants which addressed both life-of-plant storage and volume reduction. Those assessments concluded that insignificant environmental consequences would result from life-of plant LLRW storage and volume reduction at these plants. The EAs are not required NRC licensing documents but were prepared as a part of TVA's internal review process. More importantly, the preparation of an EA for a particular actio.2 does not commit TVA to that action. The EA merely evaluates the environmental consequences of the action should TVA at some point decide to take that action. Thus, all that TVA is proposing at this point is to build and use for up to five years LLRW storage modules at Browns Ferry. TVA, as it must, is taking certain steps and carrying out advance contingency planning. This is not the same as saying that TVA has plans for LLRW which it is hiding from the public or the Board as alleged by the petitioners. Nothing could be further from the truth.
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In light of these facts, it is apparent that the petitioners' position concerning the requested license amendment is based on a l
fundamentally incorrect assumption. They apparently believe the l
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proposed license amendment involves only a small part of what TVA actually plans to do and that TVA has already made a final decision to store LLRW onsite for the life of the plant and to install a i
volume reduction system. This can be seen from an examinati)n of the petitioners' contentions.
The original four contentions can be summarized as follows:
1.
Petitioners allege TVA is undertaking a major program at Browns Ferry including life-of-plant storage and volume reduction by incineration. Review and spproval of only a 5-year storage proposal at this point would be an incremental review impermissible under NEPA.
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Again assuming the program for life-of-plant storage and volume reduction, TVA has not submitted sufficient information to NRC to allow NRC to conduct an environ-mental review of the full program.
3.
NRC would be in violation of NEPA if it Jicensed life-of plant storage and volume reduction at Browns Ferry without first preparing an EIS.
4.
This contention is the same as the second except that the alleged insufficient information involven health and safety rather than environmental matters.
Obviously, if petitioners' assumption that TVA is proposing life-of-plant storage and volume reduction is incorrect, which it is, these four contentions are fundamentally flawed.
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a This deficiency carries through to petitioners' final i
amendment to their contentions. Contentions 5 and 6 merely restate and expand original contentions 1 and 3 and again incorrectly assume that TVA has already decided on life-of plant storage and volume reduction. Contention 7 makes a strictly legal argument analogous to contention 3 which cannot be admitted as a contention. Contention 8 merely contains additional hand waving to try to convince the Board that TVA is actually proceeding on the broad program that pecitioners are alleging.
It does sot contain a single recognizable factual f
issue but instead simply argues that TVA is trying to avoid scrutiny of its actual plan. Contention 9 is the only proposed contention which even relates to TVA's proposed license amendment, but that contention must fail, if for r o other reason than because it is impermissibly vague.
After the NRC staff completes its contemplated industry-wide EIS on long-term storage, TVA may again seek approval to store LLRW onsite at Browns Ferry for the life of the plant. However, TVA has not made any decision to do so, and any future TVA decision in this area would be dependent on the results of NRC's studies of l
long-term onsite storage of LLRW. Furthermore, any environmental consequences of this future expansion could be adequately considered at that time, and since the 5 year proposal has significant utility, l
j no future alteration would be foreclosed by proceeding with onsite storage for up to five years.
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The LLRW storage modules which TVA proposes to use have independent urility, and TVA would build them regardless of whether the wastes would stay onsite or would be transferred to a disposal facility prior to the expiration of the requested 5-year authorization.
They ensure that plant operations can continue while ultimate disposal options are developed. Therefore in essence, these petitioners are asking this Board to inquire into "TVA's LLRW management plan" when no comprehensive plan exists or is being proposed.
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An EIS Is Not Required on This Proposal.
Even if the petitioners vere correct in assuming that TVA had a comprehensive low-level waste program for Browns Ferry, and they are not, the 5-year storage facility could be licensed without preparation of an EIS. Spent fuel capacity expansion, a seemingly more compelling situation, has been permitted without an EIS in every case (see In re Consumers Power Co. (Big Rock Point Nuclear Plant),
ALAB-636, Nuc. Reg. Rep. (CCH) 130,580, at 29,725 (1981)). It would be incongruous for TVA's request to expand LLRW storage to be subject to the preparation of an EIS when its spent fuel capacity expansion request was granted at Browns Ferry without one.
Spent fuel storah is being handled consistent with Commission guidance even though no ultimate disposal facilities are available.
In contrast, facilities in the United States are available today for LLRW disposal, although l
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their-capacity is limited. -While spent fuel disposal has been stalled, LLRW disposal is proceeding and more sites should be opened in the future in~ light of the Low Level Radioactive Waste Policy Act (Pub.
Law No.96-573).I Petitioners in their contentions abstractly focus on the stark legal issue of segmentation and the question of whether an EIS must be prepared on all possible management options for Browns Ferry LLRW. However, this issue with respect to spent fuel has already been decided. The opinion of the circuit court for the District of Columbia is dispositive of the issue here. That court let stand an Appeal Board's denial of an intervenor's attempt to delay spent fuel storage capacity expansion (analogous to what petitioners would have this Board do), that request being based on the fact that a utility would have to request an additional license amendment for long-term storage.
[Intervenor] contends that NRC violated NEPA by improperly " segmenting" its consideration of the environmental impact of expansion of onsite storage capacity at Prairie Island. The theory is-that because the present expansion of the spent fuel pool will accommodate the spent fuel assemblies produced at Prairie Island only until 1982, a request for further expansion is inevit-able. Citing Kleppe v.' Sierra Club, 427 U.S.
i 390, 96 S.Ct. 2718, 49 L.Ed.2d 576 (1976),
Minnesota argues that the NRC was required to take into account the environmental impact of this " unavoidable consequence" of the current expansion.
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1 Under that act the States, with the assistance of the Department of Energy, will be developing low-level disposal facilities on a regional basis. This may provide additional disposal alternatives.
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We find this argument without substance. Minnesota has not pointed to any consequence of future expansion that could not be adequately considered at the time of any requests for further expan-sion.
The Staff specifically found that the licensing action here would not foreclose alternatives available with. respect to other licensing actions designed to ameliorate a possible shortage of spent fuel capacity (noting that "taking this action would not necessarily commit the NRC to repeat this action or a related action") and that addressing the environmental impact associated with the proposed licensing action would not overlook any cumulative environ-mental impacts [ Minnesota v. NRC, 602 F.2d 412, 416 n.5 (D.C. Cir.1979)].
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Petitioners have not alleged with specificity any conse-quence from long-term storage or a VRS that could not be adequately considered at the time, if ever, TVA makes such requests. Volume reduction is independent of onsite storage. A commitment to use a VRS can be made without onsite storage. Similarly, a commitment to storage does not require the eventual use of volume reduction.
Indeed, as indicated above, TVA has no commitment to a comprehensive long-term storage and reduction program. Five-year storage is essen-tially an insurance policy which allows continued plant operations while regionally acceptable disposal plans are developed.
If long-term l
storage or volume reduction is eventually deemed a desirable component i
j of some ultimate disposal plan, those options must still be evaluated at the time a license amendment is requested. Finally, the design of t
the storage modules is such that they can be built as needed and l
storage can be halted at any time circumstances warrant. Thus, the independent need for and utility of TVA's proposal, as well as the 9
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insignificance of the impacts which flow from it, compel the conclusion that this action can proceed without preparation of an EIS by NRC.
II Petitioners Have Alleged No Adequate Contentions.
A.
Contentions 5 and 6 do not cv enn to the requirements of section. 714.
Contentions 5 and 6 suffer us the same general defects as do the original contentions because of lack of relevance and precision.
These contentions, which seek to raise matters outside the scope of the Notice, specifically long-term storage options and a VRS, are clearly irrelevant. In determining whether to entertain an issue, the Board must respect the terms of the Notice (In re Northern Ind. Pub.
Serv. Co. (Bailly Generating Station, Nuclear 1), ALAB-619,12 NRC 558, 565 (1980)). Thus, these two contentions must be rejected.
In addition, contention 5 is irrelevant to any issue before this Board in that it would have the Board conduct a review of TVA's administrative decision, not an NRC proposed action. TVA's evaluation of environmental impacts pursuant to the National Environmental Policy Act (NEPA) and the resulting decisions of t;e TVA Board are independent from any NRC decisions and may not be litigated in NRC prtc-edings (see In re Tennessee Valley Authority (Phipps Bend Nuclear Plant, Units 1 and 2), ALAB-506, 3 NRC 532 (1978)). Under the provi-sions of the Administrative Procedure Act, TVA's NEPA evaluations, to 10
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the extent they can be challenged, must be litigated in federal court. Under these circumstances, it is beyond the authority of and totally inappropriate for a '.icensing board to entertain a collateral attack on the validity of the EA prepated by TVA (In re Detroit Edison Co. (Enrico Fermi Atomic Power Plant, Unit 2), LBP-79-1, 9 NRC 73, 85 (1979); cf. In re Pub. Serv. Co. of Ind., Inc. (Marble Hill Nuclear Generating Station, Units 1 and 2), ALAB-459, 7 NRC 179 (1978) (NRC has no authority to decide a matter resting in the jurisdiction of State regulatory agencies); accord, In re Northern States Power Co.
(Tyrone Energy Park, Unit 1), AIAB-464, 7 NRC 372 (1978)).
The Board below was therefore plainly correct in refusing to hear witnesses or allow discovery for the purposes of reviewing REA's decision to guarantee a construction loan for Wabash Valley
[for a portion of its 17-percent interest in facility]. The matter was not an issue open for consideration by a board conducting a construction permit proceeding under the Atomic Energy Act.
If relief is warranted from the REA's decision to guarantee the loan in question, it must be sought elsewhere [In re Pub. Serv. Co. of Ind., Inc.
(Marble Hill Nuclear Generating Station, Units 1 and 2), ALAB-493, 8 NRC 253, 267-68 (1978)].
Petitioners attempt by contention 6 to question TVA's NEPA analysis, and as discussed above, this is an inappropriate forum for that type of attack. Otherwise, contention 6 lacks the requisite precision and clarity. The contention appears to be no more than a restatement of contention 1.
As TVA has discussed, contention 1 did not raise any matter that could be litigated.
Contention 6 conta4.ns additional defects.
In particular, contention 6(a) appears to challenge release levels set in NRC regulations 11
designed to protect health and safety by alleging VRS releases will cause cancer. This is an impermissible contention under the provisions of 10 C.F.R. $ 2.758 (1980) (see, n, In re Commonwealth Edison Co.
(Byron Nuclear Power Station, Units 1 and 2), LBP-80-30, 12 NRC 683 (1980); In re Potomac Elec. Power Co. (Douglas Point Nuclear Generating Station, Units 1 and 2), ALAB-218, 8 AEC 79, 88-89 (1974)). Similarly, contention 6(e) must be rejected.
It does not disclose in the first instance how the value ss r. precedent, if any, of a Browns Ferry decision would affect whether the Browns Ferry proposal is or is not a major federal action. To the extent 6(e) suggests that the NRC will not follow its regulations in licensing other facilities at other plants based on a Browns Ferry " precedent," the contention is both inappropriate and irrelevant.
Contention 6(g) is also irrelevant in that it does not disclose how construction scheduling could affect whether a proposal is a major federal action. Contentions 6(b), 6(c), 6(d), and 6(f) address factual matters, but they are so wholly unspecific that they fail to comply with section 2.714.
For the foregoing reasons, conten-tions 5 and 6 must be rejected.
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Contention 7 is inadequate.
Contention 7 alleges that TVA's application should be processed under 10 C.F.R. pt. 30 rather than part 50.
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I no factual dispute whatsoever. The question of whether TVA's applica-tion should be processed under one part of NRC's regulations rather than another is a purely legal issue. No basis for the legal assertion is given and therefore even if the contention contained a legitimate factual issue, it would still be unacceptable.
It is essentially a restatement of contention 3, although based on an inconsistent legal theory, because it seeks to have an EIS prepared. Like contentien 3, it must also be rejected as irrelevant and nonspecific.
C.
Contention 8 does not conform to the requirements of section 2.714.
Contention 8 is an odd sixture of many prior contentions and suffers from the same problems. To the extent this contention would require the Board to evaluate an irrelevant matter, long-term storage, it is no acre than a restatement of contention 1 and must be rej ected. Contention 8(b), like contention 7, presents a noncognizable legal issue concerning licensing under part 30.
Parts 3(a) and 8(c) seek to have this proceeding terminated or at a minimum delayed untf L TVA reevaluates its EA.
Assuming arguendo that TVA is reevaluating the Brovar Ferry EA, which it is j
not, TVA's determinations with respect to its NEPA obligations cannot be litigated here.
Contention 8(a) also argues that TVA should not be permitted under any circumstance to apply for a license amendment. This amounts to a petition for an injunction against that which Commission regula-tions otherwise permit. Such relief is impermissible (In re Rochester 13
l Gas & Elec. Co. (Sterling Power Project Nuclear Unit No.1), ALAB-507, 8 NRC 551 (1978)).
For the foregoing reasons, contention 8 must be rejected.
D.
Contention 9 is inadequate.
Contention 9, like others in the proposed amendments, draws into question the adequacy of TVA's analyses in its EA.
It is NRC's, not TVA's, evaluations of environmental impacts that are relevant in this proceeding. TVA's EA foc. Browns Ferry is an internal TVA document, not a required NRC licensing document. The adequacy of the EA is not reviewable here and the contention must be rejected.
Moreover, this contention cannot be maintained because of its lack of clarity and precision.
In a recent decision a licensing board considered the following contention:
The Applicants have not adequately figured the costs and impacts of storage or disposal of spent fuel and other radioactive wastes, for the tern of the operating licenses, in the cost / benefit analysis [In re Arizona Pub. Serv. Co. (Palo Verde Nuclear Generating Station, Units 1, 2 and 3), Slip. Op. at 7 (April 16, 1981)].
The Board found:
This contention is too vague to be admissible.
It fails to meet the specificity and bases require-ment of 10 C.F.R. 5 2.714.
Principally, it is not clear what issue the Intervenor is asking the Board to accept for litigation. Moreover, it is not clear what " impacts" are referred to [id. ].
Similarly, contention 9 is vague. It is unclear what costs are referred to and what their effect on an NRC Staff evaluation would l
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be.
Petitioner's simply furnish na factual basis from which it can be determined how they would have this Board evaluate decommissioning costs in its decisionmaking.
Contention 9 also raises the issue of the costs of ultimate waste disposal in the context of an operating license amendment.
LLRW is generated at the plant, the operation of which is not an issue in this proceeding. There are certain costs associated with this waste which must be incurred in its ultimatre disposal whether or not it is stored before disposal.
In short, petitioners try.to raise the issue of operating costs and that cannot be litigated here.
In this connection, it should be noted that the Prairie Island units were licensed for operation on the basis that they would generate radioactive wastes in a certain amount over the full term of their licenses. The amendment in question does not alter the situation; i.e., the proposed increase in the storage capacity of the spent fuel pool would not occasion the generation of more wastes than had been previously projected
[In re Northern States Power Co. (Prairie Island Nuclear Generating Plants, Unit 1 and 2), ALAB-455, 7 NRC 41, 46-47 n.4 (1978) (spent fuel pool capacity expension); aff'd in pertinent part and remanded on other grounds sub nom. Minnesota
- v. NRC, 602 F.2d 412 (D.C. Cir. 1979)].
Accord, In re Portland Elec. Co. (Trojas Nuclear Plant), ALAB-531, 9 NRC 263 (1979) (spent fuel pool capacity expansion). Moreover, matters related to the ultimate disposal of wastes cannot be liti-gated in any event (see, e.g., In re Pennsylvania Power & Light Co.
1 (Susquehanna Steam Electric Station, Units 1 and 2), LBP-79-6, 9 NRC l
t 291 (1979) (the issue of offsite transportation of wastes is outside the scope of an operating license proceeding as is the ultimate dit tion of these wastes).
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III Petitioners' Amended Petition Fails To State Any Justification for Filing Contentions in an Untimely Manner.
In any event, the second amendment to the petition should be denied because it was untimely filed without any supporting justi-fication. Section 2.714 of 10 C.F.R'.' (1980) provides that a petition to intervene "shall be filed not later than the time specified in the notice of hearing" and the sugplement stating contentions mutt be filed at least 15 days prior to the first prehearing conference. A petitioner who fails to file a satisfactory supplement "will not be permitted to participate as a party" (10 C.F.R. I 2.714(b)). Additir.nal time for filing the supplement may be granted based on the balancing of the five factors stated in section 2.714(a)(1) (10 C.F.R. 5 2.714(b)).
Petitioners' amendment is clearly untimely.
In such a circumstance they have the burden to establish that the late filed contentions meet the five factors (In re Nuclear Fuels Serv., Inc.
(West Valley Reprocessing Plant), CLI-75-4, 1 NRC 273 (1975)).
- Yet, they have failed to advance any reason which justifies late filing. The Board may not accept untimely contentions unless the five factors l
have been addressed (see In re detropolitan Edison Co. (Three Mile Island Nuclear Station, Unit 2), ALAB-384, 5 NRC 612, 616 n.6 (1977)).
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d CONCLUSION TVA's management hac prudently directed the TVA staff to evaluate various LLRW management options in order to ensure that Browns Ferry, as well as other TVA nuclear plants, is not forced to shut down because of inability to manage LLRW. Many other utilities are doing this as well. The TVA staff responsibly evaluated the potential environmental effects of carrying out various LLRW manage-ment measures, namely, life-of-plant storage onsite along with volume It would be the Eeight of irony for this Board to penalize reduction.
TVA for its forethought by allowing intervention, and thus subjecting this rather minor license amendment to a potentially protracted proceeding before any of the storage modules could be used, on the 4
basis of nonspecific contentions which go far beyond the scope of the proposed license amendment and any plans which TVA has for LLRW management.
Tb-Commission is at this very moment formulati2g a statement of policy directing licensing boards to expedite licensing proceedings. This Board has no obligation to allow intervention when these petitioners have simply not demonstrated a sufficient basis for intervention. Moreover, denial of these petitions to intervene will not preclude any party from intervening in any later proceeding that might consider long-term storage or volume reduction if that person has an interesc which would be affected. At that time the types of issues petitioners attempt tc raise would be relevant and timely and i
could be addressed.
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l For the foregoing reasons, and for the reasons stated '.n its earlier rer.ponses, TVA respectfully requests that the petitions for intervention be dismissed with prejudice.
Respectfully submitted, LYb d e
Herbert S. Sange'r, Jr. O
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General Counsel Tennessee Valley Authority Knoxville, Tennessee 37902 Telephone No. 615-632-2241 FTS No. 856-2241 5
Lewis E. Wallace Deputy General Counsel 0,-
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Ja s F. Burger
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o W. Walter LaRoche N
Attorneys for Tennessee Valley Authority Knoxville, Tennessee May 8, 1981
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATONIC SAFETY AND LICENSING BOARD PANEL In the Matter of
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Docket Nos. 50-259 OLA TENN' LLEY AUTHORITY
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50-260 OLA
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50-296 OLA (Browns Ferry Nuclear Plant,
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(Low-Level Radioactive Units 1, 2, and 3)
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Waste Storage Facility)
CERTIFICATE OF SERVICE I hereby certify that I have served the original and two conformed copies of the following document on the Nuclear Regulatory Commission by depositing them in the United States mail, postage prepaid and addressed to Secretary, U.S. Nuclear Regulatory Ccamission, Washington, DC 20555, Attention: Docketing and Service Branch:
Applicant Tennessee Valley Authority's Response to Petitioners' Noel M. Beck, et al., Second Amendment of Petitions To Intervene and that I have served a copy of the above document upon the persons listed below by depositing them in the United States mail, postage prepaid and addressed:
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I Jessica H. Laverty, Esq.
Leroy J. Ellis III, Esq.
Stephen H. Lewis, Esq.
421 Charlotte Avenue Office of the Executive Nashville, Tennessee 37219 Legal Director U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, DC 20555 Appeal Board Panel C 3. Nuclear Regulatory Commission Hcrbert Grossman, Esq.
asshington, DC 20555 Administrative Judge and Chairman, Atomic Safety and Licensing Board Dr. Quentin J. Stober, U.S. Nuclear Regulatory Commission Administrative Judge Washington, DC 20555 Fisheries Rer.earch Institute University of Washington Mrs. Elizabeth B. Johnson:
Seattle, Washington 98195 Administrative Judge Oak Ridge National Laboratory Robert B. Pyle, Esq.
P.O. Box X
~3 4220 Nolensville Road-Building 3500 Nashville, Tennessee 37211 Oak Ridge, Tennessee 37830 U
This SH \\ day of May, 1981.
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4 W. Walt'er LaRoche Attorney for Applicant Tennessee Valley Authority 2
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