ML20003E350
| ML20003E350 | |
| Person / Time | |
|---|---|
| Site: | Armed Forces Radiobiology Research Institute |
| Issue date: | 03/30/1981 |
| From: | Bachman R, Brittigan R, Entwisle E ARMED FORCES RADIOBIOLOGICAL RESEARCH INSTITUTE, CITIZENS FOR NUCLEAR REACTOR SAFETY, INC., NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 8104030067 | |
| Download: ML20003E350 (19) | |
Text
<
03/33/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE AT0f'IC SAFETY AND LICENSING BOARD In the i4atter of
)
)
Docket No. 50-170 ARME0'F0P~
'AnI0 BIOLOGY RESEARCH
)
I:5TITUTE
)
(Renewal of Facility
)
License tio. D-3A)
(TRIGA-Type Research Reactor)
)
STIPUL ATIOFJ The NR: Staff (Staff), Arned Forces Radiobiology Research Institute
( AFPP! or Licensee), and. Citizens for Nuclear Reactor Safety, Inc. (CND.5 or Petitioner), by their respective attorneys' or authorized representatives, hereby stipulate and agree as follows:
Discussions 'having been ' eld between the Staff, Licensee and Detitiona-1.
h pursuant to the letter from Staff Counsel to Administrative Judge
-Carter dated January:16,1981, the Detitioner agrees that the sole contentions it ic-asserting in this proceeding are those set forth in 4
Attachment A (Stipulated Contentions) and Attachment R (Unstipulated :
Contentions), subjact' to the reservation set forth in-paragraph 6 bel ow.
The' renunt ering and wording of.the contentions set forth in Attachments A and:B supersede that set "forth in all filings Sv *1e Petitioner prior to this.date.
4104080 DM 4
=
4
. :2.
LExcept as set forth in Attachr.ents A and B, the Petitioner hereby withdraws all other contentions sublitted by it in all of its previous petitions and filings.
- 3. -
ine parties to this_ Stipulation agree that the contentions set forth
-in Attach ent A reet the re;uirements of 10 CFP ! 2.71a as tn spe:i-
~
f t:ity and basis, raise appropriate issues for deter-inatico in this proceeding, and thus constitute adnissible contentions Perein.
s 4
Tea Petitioner asse' ts that the unstipulated contentions sat forth ir.
r Attachment S are.also pro;er contentions which should be admittei a:
-natters in controversy and will file by April 14, 1981, or su-h other
-date as is-set by the Licensing Board, such statement of position as it deems necessary and appropriate witn respect to these contentiens.
s 5..
Tne Staff and/ ors the Licensee do not agree that the contentions set Lforth in Attachcent-S are. proper contentions to be admitted as ratters in controversy. The Staff and/or -the Licensee Applicant will file
. statements of position with respect to these contentions by April 14,
~
~1031, or such other'date as is set by'the Licensing Board.
16.
nothing.
this Stipulation shall;bh deeced to prevent the Petitioner fran' filing new or amended ' contentions upon a showing of goc'd cause as required by;10 CFP. i-2.714-of the Coccission's regulations.
4
. 7.
Notning contained in this Stipulation:
(a) shall be deemed an adnission 5y the Staff or the Licensee of the cerits of any contention or the validity of any allegation of fact or law stated in any contention; nae,
( b) shall be construed as a waiver by any osrty ta 3
t*.is stipulation of any rig 5ts with respect to the admissibility of evidence pursuant to 10 CFR @ 2.743 of the Co cission's regulations.
7.
Each party to this Stipulation excressly reserves any right to nove for sun.lary disposition pursuant to.10 CFR @ 2.749 of the Cornission's regulations 'in regard to any contention advanced by the Petitioner and adlitted by the Licensing Board.
~
' x8 s. y 8 i -,-'.u,
.y,,
L,2, % 5 -
~; y,
- = n (cate)
El t;abeth 8. Entwisle, Esc.
~ET Counsel for Citizens for Nuclear Reactor Safety, Inc.
f b $$/.
/
A
~ ' '
[date) hard G. Bachmann, Esq.
Counsel ' for NRC. Staff
' Mens $ - 3 r 14Ci RU of Y % -
^
(date)
Robert L. Brittigani Esq.
Counsel for Armed Forces Radiobiology Research Instituta v
F b
ATTACHMENT A STIPULATED CONTENTIONS 1.
Accicents I Tne analysis of the " Fuel Elemer.t Clad Failure Accident", o*e of t e two desige, basis accidents (DBAs) within Applicant's Hazard Summary Deport
' f HSR) 'is.faa!!y in that:
' The analjsis of tne " Fuel' Element Clad Failure Accident" erronec;slj assu tes that :ladding failure daring a ' pulse operation or inadvertant
' transient would occur at a peak fuel element temperature of less than 100*C.
Petitioner contends that sach cladding failure would be cuch more likely
-to occur.at elevated fuel tear.ratures (in excess of 400'C), resultf rg in far
. greater gap activity and fission product releases than the HSR-postulates.
2.
Accidents II~
Accidents can' be expectea to occur'at the AFRRI reactor of a different kind and. greater severity than those_ described in the HSR.
Such accidents should be.nore properly designated D3A's to ensure that sach accidents would
~
not _ result in releases in excess of: regulatory linits.
- 1) ~ Fuel element storage rack failure. The HSR does not provide-reasonable assurance that such an accident cannot occur in that: _a) it' Trails 1t'o publish' the calculations from which it concludes that a contact configuration of-the twelve' elements stored 'in Applicant's pool would not
a-4 ATTACH'E A result in a critical mass; b) it does not cite the source for its statement that experience shows it takes approximately 67 closely packed uel elenents
.to achieve criticality.
- 2) Failure-of an experinent.
Applicant has failed to show tnat several instances of 931' unctions of confinenent safeguards at AFR?! co;11
- "at recur during an experimer.t failure, resulting in the release af radiation in excess of occupational and offsite linits.
Such nalfunctions include:
a) L breach of containment caused by missing rubber gasket sealing raterial on the.10Jble doors to the corridor behind the reactor control room, in violation of Applicant's Technical Specification,1 I. A.4 (See, Notice of
'!iniation, App. A, NRC Inspection Report Docket No. 50-170, 10/13/73);
b) failure of the reactor roon ventilation dampers to close on August 26, 1975 when the Continuous Air ftonitor was alamed (see, D' A Abnornal Occurrence Report to Directorate of Reactor Licensing, dated Septenber 3,1975, Docket
- o. 50-170, 9/10/7:.); c) failure of the lead shielding doors to stop opening at the folly opened position (see DNA % normal Occurrence Report, dated July 27, 1976, Docket No. 50-170,8/16/76); d) reactor core position sa'ety interlock nalfunction on February 1,1973 (not recorded in Docket No. 50-170).
Petitioner contends that. human error coupled with failure of built-in safeguards could lead to a series of events resulting in releases of radioactivity in excess of regulatory limits and cites the following past malfunctions at. AFRRI as evidence that such failures cou'ld occur there in the future: a).nalfunction of Safety Channel One on ffarch 15, 1983 An NRC inspection on March 17,1980." revealed that Safety Channel One would
=
ATTACH'iU.T A not initiate a scran in accordance with [ Applicant's] Technical Specifi-ca tions"; b) reactor exhaust systen malfunction on August 9,1979 caused by an electrical fire in the EF-1 cubicle of the notor control center, in torn caused by a power surge due to a faulty transformer; c) nalfunction of the fuel ele ent temperature sensing circuit caused by a " floating
- signal ground", reported by DNA on August 1,1979; d) malfunction of tba
(
pool water level sensing float switch caused by wear on the jacketing around the wires leading to the switch, reported by DNA or. July 31, 19'?,
e).Talfunction of Radiation l'onitoring System caused by two loose wires in the control box and resulting in a failure of the reactor roo, ventilation dampers to close (on August 26,1975 (referred to in Contention 25),
Accidents II, suora);
f) calfunction of the Fuel Tenperature - Automatic Scram Systen on January 29, 1974, caused by a build-up of high resistance material on the mechanical contacts of the TZ output meter; g) cal function of the Reactor Core PCsition Safety Interlock Systen on February 1,1973, caused by a faulty de-energizing relay (referred to in. Contention 2d),
accidents II, suora).
- Applicant has not shown that the TRIGT. reactor's nenative terperature
' coefficient will autonatically shut down the reactor in accident situations with damaged fuel elements, where the coderating effect of the hydrogen nuclei.in the U-Zr-Mx alloy-nay be significantly reduced and the value of
- the negative temperature coefficient is changed.
k.' Multiple fuel elenent cladding-failure accidants have not been-considered in.the HSR.
Such accidents could result from:.a) defects in
~
-the naterial integrity of,-the fuel elements themselves; b) an uncontrolled
-,.-,v.
.e
f ATTACH"EN' A
-t-power excursion in the reactor core; c) LOCA; d) sabotage, aircrr.ft
- collision or natural ("act of God") accident.
3.
Erergency Plan The Energency Plan prepared by Applicant in conjunction with its license renewal-app'ication does not comply with the standards set forth at 10:CFR Part 50, Appendix E, in that it fails to provide reasonaS!e assurance that appropriate naasures will be taken to protect the pJblic he3lth and safety in the event of offsite releases following a cajar accident such as those des:ribed in Accidents I and II, supra.
The following eierents required F, Appendix E are cissing fron the Plan:
A.
Organization 1)
Description of the nornal-plant operating organization.
2)" Datailed discussion of plant staff emergen:y assignrents and duties of an onsite emergency coordinator in charge of exchan;ing infor-
~
nation with offsite emergency authorities.
- 3). Description of Applicant's headouarters personnel who will be.sent to'the plant to augment the onsite emergency-organization.
- 4) l Identification of and methods used by Applicant's personnel responsible for making offsite' dose projections. and transmitting the results to State and local-authorities, NRC ano other appropriate govern-mental entities.
.5).
Identification of Applicant's endloyeessand consultants with special qualifications for coping with emergency conditions, n
h e
u
. m
.2..2
ATTACH!'ENT A',
.6) Description of local offsite energency support services.
7)
Identification of, and assistance expected from State, local and Federal agencies with energency responsibilities.
8)
Identificat' ion of State and local officials responsible for planning protective actions, including evacuations.
t B.
Assessrent Actions 1)' Description of offsite nooitoring methods fo. deternining the
~
aagnitude 'and1 continually assessing the impact of radioactive releases.
C.
Ac'tivation of Erergency Organization
- 1) Description of emergency action levels for notifying offsite agencies and. notation that a nessage authentication sc! e e exists for such j -
dgencies.
'3.=
Notification Procedures
'1) Description of means for-notifying and agreements reached with' local. State and Federal. officials an'd agencies for the prompt. noti'ication
-'and evacuation:of,-and other protective measures for, the public.
2). Identification of the State and' local government agencies witnin
' Applicant's Erergency Planning Zone (EPZ).
'3). Description of provisions for yearly dissenination to the public within..th'e' plume pathway EPZ of' information:on energency planning,-nature -
i <
and effects of-radiation, and a listing of local broadcast stations.'.
- 4). Demonstration -that the State / local officials can nake a public notification decision promptly on being inforced ofcan energency.
4
'(
.-J '....'
-- --.--.--.--.-- -.-.L.----..---. -..-. -
- -.-.-.-- - ----.-..l
ATTACH!fD,T A !
E.
Emercency Facilities and Eouierent
- 1) Description of arrangements for transporting contar.inated indivi-I duals to identified treatment facilities outside the s,te bounda y (i.e.,
f acilities other.then the National Naval l'edical Center).
2)
Des:-iption of arrangenents for treatment of said individuals at said facilities.
- 3) Description of a near-site emergency cceratiens fa:ility and offsite communications systems with a backup powar source.
c.
Training
- 1) Description of provisions for conducting a radiological crien-tation training pragran for local Civil Defense, law enforcecent, and ne.:3 nedia personnel.
-G.
Recovery
- 1) ' Description of criteria _for detennining when Applicant's_ facility nay be ro-entered or-its operation nay be resumed.
4.
/ Routine Emissions I Applicant has 'not demonstrated that airborne and waterborne radioactive
~
emissions. from routine operations and disposal of solid wastes _ will_ be maintained 'within the.licits of-10 CFR Part 20 in that actual and probable violations of-these regulatory limits haveltaken ~ place on-the occasions
~
listedL below and Applicant's radiation nonitoring' methods 'and corrective actions are inadequate to detect and prevent their recurrence.
A
~.
ATTACH!ENT A-1) Applicact's equiprent, nethods, and reporting system for measaring releases into the f*ontgomery CoJnty sanitary sewerage syster, and at its perimeter and offsite monitoring stations do not provide reasonable assurance that violations of. regulatory linits have in all instances been or will ha detected.
Enviroanental nonitoring is inadequate to determine radiation doses to
' the p;b'ic due to inhalation or ingestion because:
a) fil.1 dosimetry detects only external gancia radiation, b) the particulate radioactivity nonitor for airborne ef fluents (i.e. a pancake-probe C-M counter) is not isokinetic, and therefore cannot be used for meaningful evaluations.. Applicant's only other stack efflue,:
nooitoring systen, the radioactive gas nonitor, is likewise not reliable for particulate sanpling.
(See, Environmental Release Report issued 12/14/71, covering period 1/1/70
-9/30/71, and Inspection Report-No. 50-170/77-01-01.)
c)
Applicant was cited by the ND.C for a violation of environ entai sampling and analysis pec;edures.
The Violation f otice of Gross Beta Effluent Analysis, based on an NoC Inspection conducted January 12-14, 1977,' cited Applicant for calculational omissions, methods for prepa*ing
--and analy:ing samples, and-instrumentation used.
The gross beta neasure-rents were nade-without-the use of. a beta self-absorption correction in the presence of:significant amounts'of suspended solid naterial.
(see f!P.C In'spection Reports' No. '50-170/77-01-02 and 50-170/77-01-03.) tooreover,
. Applicant's " Environmental Sampling and. Analysis". program does not provide
. adequate'information on.how quarterly environmental samples of water, soil' g.
ATTACHMENT A ;
and vegetation are prepared and analyzed, nor does it provide the raw data i
collected over the past ten years.
d) Tha " concentric cylinder set model" used by Applicant to derive _its dose assessnents to the environment, and from which it concludes its effluents are within re;ulatory linits, is an unrealistic model.
- 2) An NRC-inspection conducted January 10-12, 1979 revealed that, cor.trary to Applicant's Technical Specifications governing discharge of airborne radionuclides, Argon-41.and other radionuclides were discharge.f ?t ground level outside the reactor building for several nonths through a leal:
in the ventilation exhaust stack drain line (see NRC Inspection Report No. 50-170/79-01).
It is highly probable that this resulted in releases in excess of the naximum permissible concentrations set forth at 10 CFR -Part 20, Appendix B.
- 3) Applicant's Airborne Release Reports for 1962, 1963, and 195d and AEC Inspection Reports for the same years (Docket'No. 50-170) reveal that releases of Argon-41 fron Applicant's stack exceeded the maximum pennissible
. concentration for unrestricted areas listed at 10 CFR Part 20, Appendix B, during1those years.
(Also see letter fran AEC to National Naval Medical Center (N"MC) dated October 6, L1961, Docket No. 50-170).
- 4) Applicant's Environmental Release Data and Perimeter "onitoring Reports, Docket No. 50-170 (5/27/66 report and 9/20/66 report), show that chissions-from the AFRRI facility in 1962 and 1953 resulted in annual whole h
~
body' doses -in unrestricted areas in excess of the _NRC's regulatory limit of 0.5 rem.
n
- ATTACH!:ENT A 5.
NEPA I The'NRC Staff has not prepared an environmental impact statenent (EIS)
.eddressing the proposed licensing action.
In view of~ the foregoing contentions which, in their sua, establish that e:11ssions fr&f routine operations and postulated accidents at the A::RI. facility present a significant threat to the pcic health and-safety, Petitioner contends' that the proposed licensing action is a na,:;r
- Feieral action with significant environmental ' effects.
As such, NE?a requires preparation of a site-specific EIS.
S.
NEPA II The NRO Staff's environ <nental inpact appraisal does not adequately consider-the -impacts associated withl operating the AFRRI facility for another. twenty! years, nor does it adequately consider alternatives to re-licensing the facility, including' the no-action alternative, relocating the react?r, Lor doing the;research at other reactors _ as required by 10 CFR Part 51.
i li.
I-4 t
OT i
~~ # -"
.a ATTACHMENT 8 UNSTIPULATED CONTENTIONS 1.
Accidents I The analysis of the loss of coolant accident (LOCA) and the two design basis accidents (03As) within Applicant's Hazard Suwaary Report (HSR) is faulty in that:
1)
It erroneously concludes that in event of an accident described therein as " Loss of Shielding and Cooling Water", air convection cooling would be sufficient to prevent cladding failure and significant fission product release.
Petitioner contends that in the event of a rapid loss of coolant.while I
the reactor core is in the pulse mode there could be a sudden temperature elevation sufficient to cause multiple cladding failures and fission product releases.in excess of. the limits provided in 10 CFR Part 20;
- 2) Both of the DBA analyses in the HSR (" Fuel Element Drop Accident" and " Fuel Element Clad Failure Accident") erroneously consider only those radiation doses to humans that would result from subnersion exposure to the
. noble gases released.
Petitioner contends that if such accidents were to occur, indivudals would receive additional exposure due to internal emissions of the noble gases, sustaining injuries'far greater than those predicted in the HSR;
ATTACHP.ENT B 2.
Accidents II Accidents can be expected to occur at the AFERI reactor of a different kind and greater severity than those desu Pued in the HSR.
Such accidents would result in sfgnificant offsite releases and include:
1). Failure of the N-15 diffuser system.
Petitioner contends that in tne event of such failure, N-16 bubbles would accumulate along the surface
- of the fuel element cladding causing:
a) insulation of the fuel elenents from the water coolant resulting in rapid tenperature elevation of the elements and cossible multiple clad failures, and loss of water shielding; and b) production and release of the gaseous radionuclide N-16 with its powerful gamma ray.
- 2) Two maximum credible accidents (MCAs) beyond the design basis o' the reactor.(Class 9 accidents): a) power excursion accident (PEA) resulting in cultiple cladding failures at an elevated temperature with reduction in the thermalizing effect of hydrogen, followed by an explosive zirconium-steam interaction; and b) LOCA resulting in multiple cladding failures at an elevated temperature, followed by an explosive zirconium-air interaction.
3.
Testino Facility.
Petitioner contends that the AFRRI facility is a testing facility within the meaning'of 5 31.a(3) and i 104(c) of the Atomic Energy Act of 1954, as amended, and i 50.21(c) and i 50.2(r) of 10 CFR Part 50.
[ AFFIDAVIT TO BE SU3fflTTED AT-THE tit:E OF FILING OF STATEtiENTS OF POSITION]
I ATTAChME'JT B 4 Sitina Applicant has failed to demonstrate that the AFRRI facility satisfies the siting criteria set forth at 10 CFR Part 100.
Petitioner contends the AFRRI reactor falls within the scope of Part 100 siting criteria either as a testing reactor or a research reactor and cites for the latter case the Memorandum from Vollmer (Director,
' Division of Engineering, NRR), to Eisenhut (Director, Division of Licensing, fiRR).
Petitioner contends that because of the density and residential nature of the population in the plume exposure EPZ, the inadequacy and inaccessi-bility of highways, the inadequacy of Applicant's Emergency Plan, and meteorological, geological and hydrological conditions of the area surrounding the facility, Applicant cannot provide reasonable assurance that Part 100 offsite dose limits would not be exceeded in the event of a
-naximon credible accident.
5.
Routine Emissions I Applicant has not demonstrated that airborne and waterborne radioactive emissions' from routine operations and disposal of solid wastes will be maintained within the limits of 10 CFR Part 20 in that actual and probable violations of these regulatory limits have taken place on the occasions listed below and Applicant's radiation monitoring methods and corrective actions are inadequate to detect and prevent their recurrence.
~
- 1) The data ' cited in 4) of the stipulated contention (Routine Enis-sions I) and Applicant's written response to Petitioner's question subnitted in the winter of 1979, "[w] hat is the highest total exposure measures over e
9 ATTACHMENT B the year at any one of the reactor environnental nonitoring stations, for the [ years 1975-1979]", demonstrate that releases measured at these stations from 1962 through 1965,1978 and 1979 resulted in average annual whole body doses to members of the pJDliC in excess of EPA's limit of 25 rrem.
- 2) Applicant's incineration at NNMC of 160 boxes of contaminated solid waste, cited in NRC Inspection Reports for 1975-1976, Docket No. 50-170, resulted in the release of radioactive gases and particulates
-in excess of the limits set fortn at 10 CFR Part 20, Appendix C.
- 3) Since Applicant's Environmental Impact Appraisal (EIA), submitted in conjunction with its license renewal application, admits that the highest average unrestricted area exposure rate from airborne releases (set forth in the EIA) extends to residential areas, it is highly probable that such exposures have resulted and continue to result in doses to the public in excess of 0.5 ren and, violate the principle that emissions from Applicant's operation be kept as low as is reasonably achievable (the ALARA principle).
- 4) Applicant's Environnental Release Report, issued 12/14/71, indicate that between 1/1/70 and 7/1/71 exposure rates in several unrestricted areas were as high as 1-5 mrad /hr.
At this rate, any person who lived or worked in these areas 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> in a year, or about 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> a week, would receive i
an annual whole body dose in excess of the NRC's limit of 0.5 ren/yr.
Since 50-60% of the area within a one mile radius of the AFRRI stack is residential, it~ is highly probable.that the population dose limit was exceeded during this period. This is a violation of the ALARA principle.
ATTACH!iE!!T B 6.
Routine Emissions II 10 CFR Part 20 limits are inadequate to protect the health and safety of the population in the vicinity of the AFRRI reactor.
This proceeding presents "special circunstances" within the meanin2 Of 10 CFR 9 2.758 that warrant the Board's consideration of whether the offsite air-and waterborne release linits set forth at 10 CFR Part 20 and Appendices B and C thereto are adequate to protect the public health and safety.
[ AFFIDAVIT TO BE SUBf1ITTE0 AT TIME OF FILING 0F STATEMENT OF POSITION]
7.
Security Neither the Physical Security Plan for the facility nor Applicant's history of security violations and substandard managenent and operating procedures demonstrate that the controlled access areas can be protected from sabotage or diversion of special nuclear naterial according to the standards set forth at 10 CFR Part 73.
The Draft Audit Report of the AFRRI facility prepared by the Defense Audit Service in 1979 cites frequent instances of security and management
- violations, including:
1)- Eightae" activations of the facility alarm system during a 34-day period, caused by personnel leaving work after normal duty hours from
~
unauthorized exits.
Auditors were told by AFRRI security personnel and other AFRRI officials that investigations were not made of the activations S,
ATTACHMD;T B and that not enough security people were on duty to investigate each time the alarn went of f;
- 2) unauthorized people entering the facility by following employees in who used their magnetic cards to unlock the door; 3) failure to escort visitors attending weekly seminars and provide the7 with dosic.eters; 4) failure of employees entering and exiting the building after hours to sign a log showing their time of arrival and departure;
- 5) violations of Applicant's accounting and discensing procedures for controlled substances such as narcotics.
d'
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Dfp' cd BEFORE THE ATOMIC SAFETY AND LICEN5ING BOARD Q
h c
/
In the Matter of
)
, -]
Doc k e t No. 50-170T',, *p GOV
)
p
,
- go ' ' 8/4, ~/
ARMED FORCES: RADI0 BIOLOGY RESEARCH
)
NIDe, '
INSTITUTE
)
(Renewal of Facilith License Nn. R-84) \\
/
23
)
tY (TRIM-Type Research Reactor)
)
i-OM CERTIFICATE OF SERVICE I hereby certify that copies of " STIPULATION" 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, through deposit in the Nuclear Regula-tory Commission's internal mail system, this 1st day of April, 1981:
Louis J. Carter, Esq., Chairman Elizabeth B. Entwisle, Esq.
Administrative Judge 8118 Hartford Avenue Atocic Safety and Licensing Board Silver Spring, MD 20910 23 Wiltshire Road Philadelphia, PA 19151 Atomic Safety and Licensing Board Panel
- Mr. Ernest E. Hill U,5-Nuclear Regulatory Comission Administrative Judge Wa:hington, DC 20555 Lawrence Livermore Laboratory University of California Atomic Safety and Licensing Appeal P.O. Sex 808 L-123 Panel (5)*
U.S. Nuclear Regulatory Commis sion Livemore, CA 94550-Washington, DC 20555 Cir. David R. Schink Administrative Judge Docketing and Service Section (7)*
Department of Oceanography Office of the Secretary
. Texas A&M University U.S. Nuclear Regulatory Comission i
College Station, TX 77840 Washington, DC 20555
-- Robert L. Brittigan, Eso.
General Counsel
- Ocfense Nuclear Agency Washington, DC 20305 Richard G. Bachmann Counsel for NRC Staff e s
..n y
,.g.,
-m y
,w qw--
y-.mv.,,-~,---g e
.-9
,g y
4 gm
-n
,,-..,:y
+-u-.e n.-wm v
,em-g e
mv,
,y ew,r--