ML20003F454
| ML20003F454 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 04/20/1981 |
| From: | Lessy R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8104210271 | |
| Download: ML20003F454 (11) | |
Text
i 04/20/81 t
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UNITED STATES OF AMERICA N
eg NUCLEAR REGULATORY COMMISSION o., %
BEFORE THE AT0t11C SAFETY AND LICENSING BOARD In the flatter of
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4 Uti10N ELECTRIC C0!!PANY
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Docket Nos. STN 50-483
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STN 50-486 (Callaway Plant, Units 1 and 2)
)
SUPPLEMEMENTAL RESPONSE OF THE NRC STAFF TO CONTENTION 2 PROPOSED BY JOINT INTERVENORS 1.
INTRODUCTION As was discussed at the Special Prehearing Conference held on March 24,1981 in Jefferson City, the undersigned Staff Counsel tocether with Counsel for the Permittee, and Counsel for the Joint IntervenorsE participated in a meeting for the discussion of Joint Intervenors' contentions prior to the special prehearing conference. That meeting resulted in the filing on the day of the hearing of revised contentions by the Joint Intervenors. These revised contentions were discussed in detail at tne special prehearing conference. As to Joint Intervenors' substituted Contention 2, concerning radioactive releases into the environment, the Staff stated its disagreement with both the introductory I
-1/
The Coalition for the Environment, St. Louis Region; flissourians for Safe Energy; and Crawdad Alliance. Added to the foregoing is petitioner, Kay Drey.
exaano TI) sentence of the contentiork as well as subparagraph F of the contention.3] The Staff expressed no disagreement with the remainder of the submitted contention at that time. Both of the aforementioned Staff comments related to the delineation of the appropriate environmental standards for radiation (See Tr. 65-70).
Subsequent to the special prehearing conference the f4RC adopted a final rule entitled " Environmental Radiation Protection Standards for Nuclear Power Operations," 46 Fed. Reg. 18525-26 (f4 arch 25, 1981) which is attached hereto. The adoption of that rule, to be effective June 23, 1981, bears on the contention as discussed at the special prehearing conference, and the principle purpose of this supplemental response is to comment on the new rule as it bears upon the proposed contention.
II.
DISCUSSION A.
Contention 2:
Introductory Sentence The amended rule provides, inter alia, for the addition of new paragraph 10 C.F.R. 5 20.105(c) which will read as follows:
,2f "The Applicant cannot provide reasonable assurance that the Callaway Plant will be operated in compliance with applicable environmental standards for radiation (e.g., 10 C.F.R. Part 50, Appendix I and 40 C.F.R. Part 190).
In the absence of such assurance the operation of the plant clearly would be unlawful."
i 3/
" Planned releases of radioactive materials from three nuclear reactors upwind and upstream from the Callaway Plant on the f4issouri River may also impact upon the local residents.
Residents of fletropolitan St. Louis may also be affected by gaseous emissions froa a uranium fuel fabrication plant in Hematite, liissouri, 32 miles south of St. Louis."
i
(c)
In addition to other requirements of this part, licensees engaged in uranium fuel cycle operation subject to the provisions of 40 C.F.R.
Part 90, " Environmental Radiation Protection Standards for Nuclear Power Operations," shall comply with that part.
The " supplementary information" accompanying the issuance of the rule indicates "the purpose of the amendments is to incorporate the existing 40 C.F.R. Part 190 requirements into NRC regulations to make it more clear that compliance with 40 C.F.R. Part 190 is required." (46 Fed.
Reg. 18525). However, the supplementary information also provides:
... For the most part, these amendments simply incorporate into 10 C.F.R. Part 20 the NRC's already existing responsibility to enforce 40 C.F.R. Part 190 at the fuel cycle facilities including uranium mills.
Issuance of these amendments as a final rule does not modify that responsibility. Thus because these amendments do not change the status quo regarding the Commission's authority, they can be issued before the Commission reaches a decision on pending requests to delay enforcement of Part 190.
(46 Fed. Reg. 18525, n. 1).
In light of the new rule, the Staff's position on the admissibility of the contention has not changed, i.e., "... that the NRC does not ignore the EPA standards, but implements such standards through its [own]
regulations" (Tr. 65-66).
In that regard it should be recalled that at l
the discussion of this contention during the prehearing conference, Mr.
Chackes, counsel for the Joint Intervenors stated:
l
. 6 I understand that the NRC during 1980 has announced that it is in the process of amendment 10 C.F.R. Part 20 to incorporate and comply with the EPA standard.
Until that's done I think the EPA standard has to be enforced in a case by case basis in individual licensing proceedings" (Tr. 65).
Since 10 C.F.R. Part 20 has been so amended with respect to the EPA standard, the Staff would withdraw its objections to the admissibility for purposes of discovery of the above quoted introductory sentence of Joint Intervenors' Contention 2, if, pursuant to Mr. Chackes remarks, the contention were to read as follows:
The Applicant cannot provide reasonable assurance that the Callaway Plant will be operated in compliance with applicable environmental standards for radiation (10 C.F.R. Parts 20, as amended, and Part 50, Appendix I).
B.
Contention 2:
Subparagraph (F)
The aforementioned amendments do not remove the Staff's prior objections to subparagraph (F) of Joint Intervenors' Contention 2 which reads as follows:
Planned releases of radioactive materials frrom three nuclear reactors upwind and upstream from the Callaway Plant on the Missouri River may also impact upon the local residents.
Residents of Metropolitan St. Louis may also be affected by gaseous emissions from a uranium fuel fabrication plant in Hematite, Missouri, 32 miles south of St.
Louis.
In addition to the objections to the adequacy of this portion of the contention expressed at the prehearing conference (see Tr. 65 et sea), it j
should be emphasized that the EPA Administrator, in promulgating 40 C.F.R. Part 190 stated that it would be unnecessary for the NRC to reexamine license conditions for compatability with the newly promulgated
. n EPA regulations "unless the nearest neighboring site covered by this standard is within ten miles." 42 Fed. Reg. 2858. The plants which Joint Intervenors have referenced as " upstream frcm the Callaway Plant" are well beyond ten miles from the Callaway site.
In addition, the Staff believes that subpart (F) of Contention 2 should not be admitted as Joint Intervenors have failed to allege any basis indicating the potential validity of the contention, particularly in light of the above statements by EPA. See Detroit Edison Co. (Enrico Fermi Atomic Power Plant, Unit 2), LBP-78-11, 7 NRC 381, 386-87, aff'd, ALAB-470, 7 HRC 473 (1978).
C.
Contention 2:
Subparagraph (I)
Although not directly related to the previously discussed amendments to 10 C.F.R. Part 20, the Staff wishes to briefly restate its views concerning the unsuitability for admission of revised Contention 2, subparagraph (I). That paragraph provides:
UE's estimates of radiation Jose from the Callaway Plant emissions do not adeq';ately reflect new data on the health effects of low-level radiation, and of tritium in particular.
Permittee has objected to this subparagraph on the grounds that:
(i) "it serves little purpose to address the health effects of the Part 20 limits when Applicant is required to install equipment to limit radiaoctive effluents to the 'as low as reasonably achievable' guidelines in Appendix I to 10 C.F.R. Part 50"S/ and (ii) although proper 4/
" Applicant's Response To Contention 2 Proposed By Joint Intervenors," p. 8 (!1 arch 24, 1981).
contentions regarding health effects may be litigated in individual licensing proceedings the Canaission has advised boards "to take official notice of certain facts and not to adjudicate the issue on a clean state" citing Public Service Company of Oklahoma (Black Fox Station, Units 1 and 2), CLI-80-31, 12 NRC 264 at 266-67 (1980).E/
While the Staff agrees with such observations, the Staff would like to emphasize in addition, that subparagraph (k) is so vague as to be meaningless. What "new data on health effects" are Joint Intervenors considering? What " estimates" of UE inadequately consider such "new data"? The Staff opposes subparagraph (k) because Joint Intervenors have failed both to put the other parties on notice "so that they will know at least generally what they will have to defend against or oppose,"$/ and have failed to establish sufficient foundation for the contention to warrant further inquiry into the subject matter.2/
J i
III. CONCLUSION For the reasons discussed above, the Staff believes that Joint Intervenors' Contention 2(F) and (I) should not be admitted in this l
proceeding and that the introductory language of Contention 2 if admitted l
5/
Id.
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See Philadelphia Electric Co. (Peach Bottom Atomic Power Station, Units 2 and 3), 8 AEC 13 at pp. 20-21 (1974).
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Id.
l l
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at all, for purposes of discovery, should be adraitted in the form herein suggested, taking into account the recent amendments to 10 C.F.R. Part 20.
Respectfully submitted, O
k(Nl*
Roy P. Lessy Counsel far NRC Staff Dated at Bethesda, Maryland this 20th day of April,1980.
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- o of t'.c i I'lli AL DEGISTCR Against R.idiation." to incorporate the Street, Washington. D C. 20555. No
.,s.. ;.* ' y d>.vnents having a sisting Environmental Protection significant adverse comments or u
g...at
,.;.i.. ' 'ty 3 tcpt effect, rnest Agency (F.pA) sequirement for questions were received on the ce w s.h...e s. p 3 to and cod.e.ed in connpfiance with 40 CFR Part 190 proposed amendments during the public t. r.ie et r. s rat n. p!at.ons, wh.ch is
- - a 3 o tcr $3 tales purruant to 44
..rns isonmentril Radiation Protectiori comment period.' Therefore, they are St ind.uds for Nuclear Power' being published in final form with only it.
C e of fri ial Rr.ptatons is sold (7; crations.** The EPA published 40 CFR one minor change. Following is a 13 1N S r.,
t a *t of th uments.
P. rt 140 on jennary 13.1977 (42 FR di>cussion of the issues raised by the r...
of n% t r8s a.c istid in the
. *.~.fi). In arc ordance with a public comments.
t.
e e t r!.nAL I;rG:St LR Mue of cach f.ft morandum of Underst.indir g
- 1. One comment stated that the m.nm 1.etwren EPA smd the former Alumic amendments were unnecessary because Ent-rgy Comminion (38 FR 24?36
!icensees are aheady required to comply
- Si prember 11.1973). NRC is responsible with 40 CFR Part 190. The purpose of the f.'tICI E AR HI GULA10RY for enfoning the provisions of 40 CFR amendm.uts is to incorporate the C0f'*"' MIN Irt itio for NRC licensees.
esisting 40 CFR Part 190 requirements Title 40 CFR Part 190 rquires certain into NRC regulations to make it more 10 CFR P. rt 20 uranium fuel cycle facilities to be cicar that cornpliance with 40 CFR Part opcr.ited so that releases of radioactive 100 is required.
rnvironmentat Radiation Protection material and resulting radiation doses to
- 2. One comment stated that the Standards for f.'ockat Pov.cr the public are below specified limits.
requirements of 40 CFR Part 190 and 10 Operctions The effectis e dates for compliance are CFR Part 50 Appendix ! should be December 1.1979 for most opt rations; ccmbined. because both regulations Act u y: No.lcar Krgulatory December l.1950 for uranium rnills, and relate to radioactis e re! cases from Comn:iuien.
january 1.1983 for discharges of nuclear pcw er reactors. This is not AcTios: Fma! s ule.
krypton. tis and iodine 129. The practical because 40 CFR Part 190 also cus.mi.r.v; The Nuclear Regulatory regulation prosides that under certain applies to fuel cycle facilities other than circumstances variances may be granted ' power reactors, and because the two Cometssion is.. men.fmg its regulat.
ions to incorporate the custmg by the regulatory agency respcasible for regulations are not identical. Howes er.
Envirenmental Protection Agency enforcing 40 CFR Part 190 w henes er possible. the NRC staff is requircm nt for certain nranium fue!
The amendments to NRC re;ulations avoiding unnecessary duplicative c3 cic licensrcs to comply with the EPA.s state that NRClicensees must comply requirements for reactors by combininF
" Ens incamental Radiation Protection with 40 CFR Part 190 and require release limits and reporting licensees to sul mit reports to NRC when requirements for 40 CFR Part 190 with Stand. 8 Oper 9 5 fie Nucicar Power 40 CFR Part 190 limits has e been or may esisting Appendix ! requirements in tiens. These standards requ. ire be siolated.
ccria'n u:.im..m fuct c3 cic facilities to be indis idual licensees' technical eper..tc.'sa. h that retrases of The NRC has submitted these specifications.
tr.dio.,cta e uut. rials and resulting amendments to the Comptrol:er General
- 3. One comtnent expressed concern radi..tien de cs to the pubbe are below for such resiew as may be a[ ropriate that 40 CFR Part 190 apphed to sper:fic.* lun.ts The amendments also under the Federal Reports Act, as combined radiation doses from all fuel regare brenscr3 to su!.mit r ports t amended. 44 U.S C. 3512. The date on NRC wh. n these stan.!ards hne been w hich the reporting requirement of this ein ocio5,r. srx erpresimaiet> four months cr ms> be escceded.
rule becomes effectise reflects inclusio 1 after the cenment rened closed se$ erst crera'ar*
of the 45 dav period which that statute of ura ni== mit?' innd) 01'd l't" **d"" ""'
[FFECUVE Dalt S:The rIIcclis e dates for allows for dit.h review b1 U.S C. {T,7,# ",'M,',8,,'y,*),,",T','jiY,'ac the custmp tryuirement to comply with 3513(c){:)).
, i FPA's 4? Ct'R Part W are nIrcady As discussed in the notice of proposed Rercswirs that t'e:r com:nents were late. 'thne rreram to erforce F*H W
- rani"* *ll spect ied in u CFR W 12: December 1 r
rulemaking. the Commission has er ' ar"'"" O n *' d "n
- h * * ' *"'
1M1 fcr uranium mills, and january 1 ci nefuded that an ensironmentalimpact y"*,U'Md * '.', j,N,[' ",# *",* [
19 9 for rnest crerations: December 1
,n statement for the amendments is not 193.1 for dis.furges of Lr3 plon.85 and
,,.nium rnms in a nprare action.the Amerec.n iodinc.1:9 Fhe, frcctn e date for these required, bernuse they will not st.n rFConren s'so mosed the Comminion in
,;jnir,cantly nfrcct the qualits of the 0*t "m r.n')m'mr.':ementation and C
nmen.8 :. at to to CFR Part 20 is June burnan environment
- entnc meni a emand munium 23 1 % 1-The omend:ncnts were publ:shed for rnalis The Co. 2:nion is current!) coeside ring n,sc r.?.. ss b oer. ne isso. rue of ti ne e en re..o i; c.i cra'r.1sO*; c o': TACT'.
public comment on April 17.15 50 (45 FR
.menhents as e " at rute cred* cot be dele >cd
.Nir. jehn h. N lhcLey. Offier of Of072). with comments requested by r r me rans pa ene mn3 menu s.mP y t
l St.ind..:.!5 Dcs e 10pment.11 S. Nuclear junc 16.19.".0 Timely cominen!s wcre
'"3.*[*'[*, f.
,"rf $c$'r$'d8,
Ecgulater) Coa mission. WashiPS on, rt cris ed from Northeast Utiht es. Duke t
r,,1c3,re f.c.u,o inctoteg :.n om enitre.
D C. :M55 (;Aone: (M1) 443-59%).
Power Company. Consumers Pewer t...nre er e car : t nb. ts s. on.t rute dan ser rtt er.
t sa.s.. ora mom The Ccmpany, and ILc County of Sa a<t r' L's **' '"pnata3 Tho b e. w Ao, NuiL :R.3.l.10 3 Cc:.mi> sion (NR C)
The pubhc reman nts are su:. n.Diego..c c-4..'s d: r at chge t*,e s'at6s q.o r.garJ..
. b.c for g, n.
,,,,.,,,,% g,3 m 3,,.. d is.un. n.'n. it< r. c ' ens in to CFR fr.. inspretian or cop 3 ng for e Ice at i
h t.. e c c. --., :. rn:$ e s. dec, er en Part 20. ' Si id..:da fo: l'.etection the NI;C Pubbs Document Re.m.1717 H
- r. -d u N eve te de!an 5.-f cu rird of F ri1*
2G T. ?. i. I L J.t t / Vol. G. No. 57 / V.*rdnesdPy. ?.' rch 25.1931 / Rules and Regulations g. tr f..cihtirs. m.J ir:g it diffir ult to PART 20-STANDARDS FOR indniduals to radiation or to radmactn r
. " 6ne re o; fr are. FPA..difrosed PROTECTION AG AINST RADl?. TION rnaterial;les els of radiation and r ue whe n 0 CFR Part 100 was concentrations of radioactive matenal t'
t
- . ! In hed EPA st.ited. "* *
- in the 1 ^ "C"l'aragraph (c) is added to involsed the cause of the exposure.
?I ruajority of situations, the sum of i 20.105 to read as follows:
levels or concentrations; and correctis e s
a'! seasonabl postulable contributions
( 20.105 Permtssrbre leveta of red-tionin steps taken or planned to assure against 3
fa..:n sources other than the immediate unrestricted areas.
a recurrence, including the schedule for site will be sm.ill compared to these achieving conformance with 40 CFR Part st. ndards and should be ignored in (c) In addition to other requirements 100 and associated license conditions.
er essing compliance"(42 FR 2858 of this part, licensees engaged in
- l. nuary 13,1977).
uranium fuel cycle operations subject to (S-ction 161b.161o Pub. L 83-703. 68 Stat.
4 One comment pointed out that 40 the provisions of 40 CFR Part 190 r 5. 950 (42 U.S C. 2201). Sec. hn. a s CG Part 190.llows for licensees to "Environmenta' Radiation Protection arr. ended. Pub. L 93-438. 88 Stat.1243. Pub L obtam variances to exceed 40 CFR Part Standards for Naclear Pow er
[g',(,89.nd N derstan etween the tud limits under temporary and unusual Operations shall comply with that Ensitor. mental Protection Agency and the ccaditions, and requested NRC to pa rt.
specify procedures for obtaining such
- 2. Paragraph (f) of i 20106 is revised.
Atomic Eners) Commission. August 1973. 38 FR 24936. September 11.1973) uriances. Because s ariances will be and a new paragraph (g)is added. to considered only in unusual cases,it is read as follows:
Dated at Washington, D C this 17th day of March.1981.
ptcferable to treat each case on an
{2o.106 Radioactivity in effluents to For the Nuclear Regulatory Commission.
indaidual basis. This is consistent with unrestricted areas.
Semuel l. Chnk.
csistirp NRC regulations, w hich do not spi cif procedures for obtammg g,y,,,,7,f,3, com,j,,j,,
3 (f) The provisions of paragraphs (a) irs ox ne.o r.iw su s es..ni s..riances to escced regulatory limits.
through (e) of this section do not appfy tum coM ruo-ci.as Rather.10 CFR I 20 '.01 states. "The to disposal of radioactive materialinto Commission may, upon application by sanitary sew erage systems, which ts an3 licensee or upon its own mitiative, guverned by 1 20.303.
S!?ALI. BUSINESS ADf/.INISTRATION gr..nt such exemptions from the (g)In addition to other requirements requirements of the regulations in this of this part. licensees engaged in 13 CFR Part 123 part as it determines are authorized by uranium fuel cycle operations subject to law and will not result in undue hazard the provisions of 40 CFR Part 190.
[Rn. 9, Amt.17]
to hfe or property."
" Environmental Radiation Protection One minor clarif mg change related to Standard for Nuclear Power Disaster Loans; Changes in Eligibility 3
sariances was made to the proposed Operations." shall comply with that AG EN CY:SmallBusiness Administration.
rule. When a hcensee submits to NRC a part.
ACTION: Final rule.
c.
report of excessis e radioactis e releases.
- 3. Paragraph (b) of i 20.405 is revised.
the description of corrective steps taken and a new paragraph (c) is added, to suuuAny:In recognition of severe or planned shallinclude the schedule for read as follows:
funding limitations in the face of achieving conformance with 40 CFR Part unprecedented demand for drought W and associated license conditions.
I 20 405 Reports of on upoms and disaster assistance, changes in ehgibility
- * " * * #8 This is consistent with 40 CFR 190.11.
are necessary to assure the continuing which requires that a regulatory agency availability of recovery assistance to all granting a sariance should make public (b) Any reportTiled with the disaster victims. Due to the emergency the schedule for achieving conformance Commission pursuant to paragraph (a) nature of these changes, they will with 40 CFR Part 190.
of this section shall melude for each become effective March 19.1981. for individual esposed the name, social disaster loans approved on or after that
- 5. One comment stated that licensees
.and should have 60 da3 s to report violations estimate of th'e m." dividual.
date. The changes affect the rules for a
s exposure. disaster declarations ard will reduce the of 40 CFR Part 190 to NRC. rather than MPort shall be prepared so that this amounts of physical disaster loans the 30 days specified in the proposed mformation is stated in a separate part (other than home loans) to not more b"
licensees need more time to perform (c} In ad ition to any notification
- I'#Y ' ' '
.~ '
calculations associated with assessina required by i 20.403 each licensee shall
d '
compliance.The NRC staff has make a report in writing within 30 days nl o conce s a le o a n the concluded that the 30-day requirement is to the appropriate NRC Regional Office financial assistance from their own or rc.isonable. Specific license conditions listed in Appendix D, with a copy to the their principals' resources or credit.
which implement this requirement for Director of Inspection and Enforcement, individual facilities will a!!ow U.S. Nuclear Regulatory Commission.
EFFECTIVE DATE: March 19.1981.
' reasonable time to gather data and Wa shington. D C. 20555. of levels of FOR FVRTHER INFORM ATION CONTACT'.
perform dose calculations as radiation or releases of radioactive Questions may be addressed to: Charles appropriate, materialin esecss oflimits specified by R.Hertzberg Acting Director. Disaster Pursuant to the Atomic Energy Act of 40 CFR Part 190. " Environmental Operations. Small Business 1954. as amended, the Energy Radiation Protection Standards for Administra tion.1441 L Street. N.W Rcorganization Act of1974, as amendei Nuclear Pow cr Operations." or in excess Wastoagton. D C. 20416.[202) 653-6574.
a?.d seClion 553 of title 5 of the United of license conditions related to EUF PLEM DiT ARY INF OR u ATION:"Ihe St.ites Code. the fo!!owing amendments compliance with 40 CFR Part 190 Each drought catastrophes of the past summer a:. published as a document subject to report reqmred under this paragraph have placed a severe strain on funds codification.
shall describe the extent of exposure of asailable for disaster assistance. In a
P00R ORIGINAL
UI:lfE0 STATES OF A!T':CA NUCLEAR Rf.GULATORY CO ::'ISSION.
BEFORE THE AT0!11C SAFETY AND LICENSING BOARD In the Matter of
)
)
U210N ELECTRIC C0iPANY
)
Docket flos. STil 50-483
)
STN 50-486-(Callaway F! ant, Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify'that copies of " SUPPLEMENTAL RESPONSE OF THE NRC STAFF TO CONTENTION 2 PROPOSED BY JOINT INTERVEN0RS" in the above-captioned proceeding have been served on the following by deposit ir the United States mail, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 20th day of April,1981:
Ja:nes P. Gleason, Esq., Chainnan Barbara Shull Atonic Safety and Licensing Board Lenore Loeb 513 Gilnoure Drive League of Ho.,en Voters of 11issouri Silver Spring, MD 20901 2138 *..'oodson Road St. Louis,f10 63114 Mr. Glenn 0. Bright
- Atomic Safety and Licensing Board liar.iorie Reilly U.S. Nuclear Regulatory Cos1ission Energy Chairaan of the League of
- ashington, DC 20555 Wo en Voters of Univ. City,f10 7065 Pershing Avenuc
.^
Dr. Jerry R. Kline*
University City, M0 63130 Atonic Safety and Licensing Board U.S. Nuclear Regulatory Cosaission Gerald Charnoff, Esq.
h'ashington, DC 20555 Thomas A. Baxter, Esq.
Shaw, Pittman, Potts & Trowbridge "r. J0hn G. Reed 1800 !! Street, N.W.
Rt. 1 Washington, DC 20036 Kingdom City,t0 65262 Dan I. Rolef Treva J. Hearne President, Board of Directors Assistant General Counsel for the Coalition for the Environaent, Missouri Public Service Commission St. Louis Region P.O. Box 360 6267 Delnar Boulevard Jefferson City, MO 65101 University City, l-10 63130
Nnald Dollin.jer, ite:aber Posa levering,I M her
- lissourians for Safe Energy Cra. :aJ Alliance G?6/ Delmar Boulevard 7370c Dale Avenue
'Jaiversity City, i;0 63130 St. Louis,110 63117
- r. Fred Luokey
!!ay Sray Pr esiding Judge, Itontgo; aery Co mty 515 "ast Point Avenue "aral Route Univ 2rsity City, i:0
.63130 Rhinelan.1, t'0 65069
- 'ayor !!c. ard Stef fen Chamois,
- 10 65024 Professor William H.11 iller Mr. Earl Brown Missouri I:ansas Section, School District Superintenifeqt 41arican T:uclear Society P.O. ' lox 9 Departr.ent of fluclear Engineering Kingde.n City,110 55262 1026 Engineering Building University of Missouri itr. Scnuel J. Birk Columbia, i10 65211 R.R. =1, Box'243 11orrison,110 65061 l
tis. J. Botwinick i
336 Portico Court ifr. Harold Lott. nan Chesterfield, r10 63017 Presiding Judge, Dasconade County Robert G. !!right R t. 1 Associate Judge, Eastern District Owensville,f10 65056 County Court, Callaway County, Missauri C. Floyd itathews Route *1 Birch, Horton, Bittnar and 'Lncoe Ful ton, '10 65251 Suite 1100 1140 Connecticut Avenue, N.h'.
Atonic Safety and Licensing 4
!!ashington,- DC 20036 Board Panel
- U.S. Nuclear Regulatory Conuission Dock 2 ting and Service Section*
Nashington, DC 20555 Office of the Secretary U.S. Nuclear Regulatory Co:.:aission Atonic Safety and Licensing
!!ashington, DC 20555 Appeal Board
- U.S. Nuclear Regulatory Coauission L'ashington, DC 20555 Kenneth ti. Chackes Chackes and Hoare
-}
Attorney for Joint Intervenors cWM 314 N. Broadway I
St. Louis, Missouri 63102 Roy P. Lessy Deputy Assist Chief Hearing Counsel