ML20004B601
| ML20004B601 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 05/20/1981 |
| From: | Guild R, Ruoff J FAIRFIELD UNITED ACTION, GUILD, R. |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| ISSUANCES-OL, NUDOCS 8105290146 | |
| Download: ML20004B601 (23) | |
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1 TABLE OF CONTENTS l
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Page STATEMENT OF THE CASE 1
STATEMENT OF FACTS 1
ARGUMENT THE LICENSING BOARD PROPERLY BALANCED THE APPLICABLE FACTORS, ADOPTED PRO-CEDURAL MEASURES TO AVOID DELAY, AND ADMITTED FAIRFIELD UNITED ACTION (FUA)
ON TMI-RELATED SMERGENCY PLANNING AND CORPORATE MANIGEMENT CONTENTIONS 4
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FUA'S STANDING TO INTFRVENE AND THE AD-VuSSABILITY OF ITS CsNTENTIONS ARE UN-CHALLENGED.
4 II FUA DEMONSTRATED GOOD CAUSE AT LEAST FOR THE BULK OF ITS LATENESS IN FILING TMI-RELATED CONTENTIONS 6
III THE PROCEEDING REPRESENTS THE BEST FORUM FOR THE PROTECTION OF FUA'S INTEREST IN HEALTH AND SAFETY MATTERS REGARDING THE SUMMER NUCLEAR STATION.
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IV THE EXISTING PARTIES, INCLUDING THE EXIST-ING INTERVENOR CANNOT ADEQUATELY REPRESENT FUA'S INTERESTS.
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FUA'S " INTENSIVE PREPARATIONS"~AND "DEM-ONSTRATED KNOWLEDGE" ON EMEAGENCY PIAN-NING AND CORPORATE MANAGEMENT MAKE CLEAR THAT ITS PARTICIPATION WILL CONTRIBUTE TO THE DEVELOPMENT OF A SOUND RECORD FOR DECISION 10
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VI INh e
LIMITING FUA TO ISSUES ALREADY ADMITTED
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AND REQUIRING FUA TO TAKE THE PROCEEDINGS AS IT FINDS THEM WILL ENSURE THAT THE IS-SUES WILL NOT BE BROADENED AND THAT "UN-PRODUCTIVE DELAY" WILL BE AVOIDED..
11 CONCLUSION 15 REQUEST FOR ORAL ARGUMENT 15
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TABLE OF AUTHORITIES
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P_agg Administrative Decisions:
Cincinnati Gas and Electric Co. (William H. ZinumeMuclear StationT~ LBP-80-14, 11 NRC 570 (1980) 7 M Island Lighting Company (Jainesport Nuclear Power Station, Units 1 and 2),
ALAB-292, 2 NRC 631.
12 Nuclear Fuel Services Company (Wost Valley Reprocessing Plant), CLI-75-4, 1 NRC 273.
8 Puget Sound Power and Light Company (Skagit Nuclear Power Project, Units 1 and-2), ALAB-559, 10 NRC 162 (1979) 14 South Carolina Electric and Gas Company, et al. (Virgil C. Sununer Nuclear Sta-
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hoe Unit 1)', LBP-78-6, 7 NRC 309
( 19 7 8 ). t. -.w.
.......... <....... /. 8,12,13
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o South Caroli'na Electiric and Gas Company, et al. (Virgil C. Summer Nuclear Sta-Ho E Unit 1), Partial Order Following Prehearing Conference (Admitting FUA on Contentions 1, 2, 7-13, aad 27, and Denying FUA's Other Contentions) (April l
30, 1981)
......... passim.
i South Carolina Electric and Gas Company, h
et al.-(Virgil.C. Summer Nuclear Sta-hoe Unit 1), Remainder of Order Fol-lowing Fourth Prehearing Conference (May 13, 1981).
10,11 Regulations and Ngtices:
10 C.F.R. S 2.714a 1
10 C.F.R. S 2.714 (a) (1) 6 10 C.F.R. S.2.763..
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42 Federal Register 20203.
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Other Authorities:
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Applicants' Answer to UntJ Oly Petition to Intervene of Fairfield United Actioc, Inc. (April 3, 1981) 5,13 Applicants' Brief in Support of Notice of Appeal (May 8, 1981).
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Applicants' Notice of Appeal (May 8,1981) 5 FUA Petition to Intervene and Request for c
Hearings and Supplement (March 23, 1981) 2,3
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NRC Staff Brief in Support of Appeal
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F.
(May 11, 1981) 4 6,9 NRC Staff Opp)sition to Untimely Petition to Intervene (April 13, 1981).
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STATEMENT OF THE CASE g
These are appeals by the Applicants South Carolina Electric & Gas Company and South Carolina Public Service Authority and the Nuclear Regulatory Commission Staff taken g
pursuant to 10 C.F.R. S 2.714a from a Licensing Board Order dated April 30, 1981, admitting Fairfield United Action as a party to this proceeding on corporate' management and g
emergency planning issues, but denying admission of other 4
health and safety contentions.
Applicants and Staff present the question of whether the Petition to Intervene should 3-have been wholly denied.
No other appeal from this Order is allowed at this time.
The Atomic Safety and Licensing' Appeal Board provid'ad 3
by order dated May 12, 1981, for the submission of responses to these appeals by May 21, 1981.
STATEMENT OF FACTS Fairfield United Action (hereafter FUA) was organized during 1980 for the purpose of protecting the health, safety 9
and welfare of residents of ~ Fairfield County South Carolina, the site of the Virgil C. Susper Nuclear Station.
Through participation in.the organization's prograr. members only S
recently beame educated with regard to the design, construc-tion, and the probable effects on them of the operation of 9
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r the Summer plant. (FUA Petition pp. 1-3).
Members of FUA jb became active and informed on the subject of eme.rgency l
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q planning for the facility and participated in an emergency planning meeting conducted by the.NRC Staff in their community 1
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in July 1980.
These activities led to the group's incorpora-
\\4 tion in September 1980. (Tr. 586). Although some of FUA's 4
members have only recently moved near the Summer plant, the' 4
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members who have lived in Fairfield County for many years have until recently relied on information froc: the Applicant con-cerning the effects of plant operations, representations l
that its operation would pose no risk to their health and safety, which information they only recently came to believe to be false and misleading. (FUA Petition pp. 2-3; Tr. 520, 521). Those members of PUA who lived near the plant in 1977 l
when the application for operating license was filed and the notice of opportunity for hearing was published (42 Fed.
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Reg. 20203, April 18, 1977) were not informed of their interest in the operation of the facility, of their rights and remedies regarding the proceeding, or of the Federal
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Register notice itself.
After formal organizat. ion of FUA its members became aware of the pending operating license proceeding and of the participation of the only intervening
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party, Mr. Brett.Bursey, a resident of Little Mountain in Richland County (Tr. 603).
FUA representatives attended the pre-hearing conference
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in this proceeding held November 25, 1980, and learned that Mr. Bursey was to meet certain deadlines with respect to I
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submitting names and summaries of testimony of witnesses and
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for raising new matter concerning Three Mile Island related requirements (FUA Petition p. 4: Tr. 587-589).
From then until mid-February 1981 FUA members were informed by Mr. Bur-
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sey that he was in compliance with these requirements.
In mid-February 1981 FUA learned of a February 10, 1981 letter to the Licensing Board from Counsel for the Applicant assert-ing that Mr. Bursey was precluded "from putting on any witnesses or exhibits on his six admitted contentions,"
from raising any TMI-related matters, and that he should be
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held in " total default," for failure to comply with dead-
' lines (FUA Petition p. 4).
FUA immediately undertook to inform itself as to the rights'and remedies available to protect its
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interest and on March 22, 1981 filed its Petition to Inter-vene and Request for Hearing with the affadavits of eight members residing in proximity to the Summer Station and a
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Supplement containing twenty-seven contentions and the bases therefore.
FUA's ability to inform itself of developments in the
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proceeding was severely h6mpered by the absence for several years of a properly managed local public document room in Fairfield County (FUA Petition, pp. 4-5).
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The Applicant served its Answer to FUA's Petition:cn April 6',1981 (Tr. 342) and FUA appeared April 7 and 8, 1981 at the previously scheduled prehearing conference at which
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time the Licensing Board took up' consideration of FUA's Petition and Supplement containing contentions.
By Order
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dated April 30, 1981, the Board admitted FUA on its con-l g
tantidns 1,2 and 27 regarding corporate management, 7-13 regarding emergency planning, and denied admission of all other contentions.
These appeals by the Applicants and Staff followed.
g ARGUMENT
~O THE LICENSING BOARD PROPERLY BALANCED l
THE APPLICABLE FACTORS, ADOPTED PRO-CEDURAL MEASURES TO AVOID DELAY, AND l
ADMITTED FAIRFIELD UNITED ACTION (FUA)
ON TMI-RELATED EMERGENCY PLANNING AND
'O CORPORATE MANAGEMENT CONTENTIONS.
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O FUA'S STANDING TO INTERVENE AND THE 1
ADMISSABILITY OF ITS CONTENTIONS ARE UNCHALLENGED.
- O In its Order dated April 30, 1981, the Licensing Board determined that FUA had established standing to intervene based on the geographic residence of its members in proxim-lQ ity to the Sununer Nuclear Station and that its contentions t
were legally sufficient since they were either encompassed 4
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in already admitted contentions or were otherwise admissable Q
(Order, at p. 3).
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The Applicant does not appear to contest this view:
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Our opposition to the petition does not otherwise turn on factors applicable to timely petitions.
Our main
_ point is that petitioners have not dili-
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gently pursued and timely asserted their.
interest, and no longer have the right to
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be a party that they might well have had earlier.
(Applicant's Answer, p. 3, fn. 2.)
The Staff generally joined the Applicants' basis for opposition (Tr. p. 344) and, likewise, emphasized its be-j lief in the absence of demonstrated good cause for late filing (NRC Staff Opposition at p. 2).
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The Applicant and Staff, more than anything, claim cog-nizable prejudice to them from the conversion of an essen-l tially " default" proceeding into a more or less contested
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case by the admission of FUA:
Stated more starkly, and with all sincere l
respect to ' he Board below and for the NRC l
administrative process, this appeal presents the question whether Applicants are to be protected against extreme prejudice to their rights.
or whether such rights are to be submerged at the behest of an articulate group that has slept on its rights.
(Applicants' Notice of Appeal, p. 2.)
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Continuing:
. the Board's action turns a moderately contested proceeding into a seriously con-tested one without adequate consideration of the Applicants' rights and obligations to
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their customers.
(Applicants' Brief, p. 18.)
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The Staff shares this disappointment:
One genuine effect of the Board's Order
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is to " shore-up" the existing intervenor, who, as the Board aptly noted, has been less than diligent in presenting his case.
the entry of a fresh litigant in opposition to the license is fundamentally unfair to the other litigants and establishes an unde-3 sireable preced nt for future cases.
(NRC Staff Brief. ct p. 9.)
The Board, instead, focused on a balancing of the
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factors specified in 10 C.F.R. 5 2.714 (a) (1) in weighing a late-filed petition cnd struck the balance in favor of admitting FUA on a limited basis.
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FUA DEMONSTRATED GOOD CAUSE AT LEAST FOR THE BULK OF ITS LATENESS IN FILING TMI-RELATED CONTENTIONS.
i Upon dividing the TMI-related corporate managemert l
(1,2 and 27) and emergency planning (7-13) contentions from all others the Board determined that "there was good cause for the bulk of the. delay in filing" the TMI-related con-tentions and that the " good cause" factor should be assigned "almost no weight" against admitting FUA (Order at p. 7).
g Given the developteent during mid-1980 of NRC policy on amer-gency planning and "the Commission's focus on management capability in the post-TMI era" (Order at p. 6) which coin-cided with FUA's organizational activities culminating in its incorpration in September 1980 (Idr Tr. 586), the Board
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_7 observed that good cause would clearly justify delay in
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filing for intervention through "the middle or latter part i
of 1980."
Although it rejected as " legally insufficient" FUA's reliance on Mr. Bursey's intervention as justifica-7) tion for the additional months of delay in filing, the Board expressed its practical sympathy for this explanation (Order,
- p. 6).
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It also concluded that no delay of the proceeding or disadvantage to any other party flowed from this additional tardiness and that, therefore, it could not find a lack of
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good cause on these TMI-related contentions.(Order, p. 7).
In reaching this conclusion, the Board expresses agree-ment with the analysis offered in Cincinnati Gas and Elec-
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tric Co. (William H. Zimmer Nuclear Station), 'LBP-80-14, 11 NRC 570,'74 (1980), to the effect that vast changes in
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the criteria for emergency planning and expanded scope of
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relief available in licensing on that issue can establish good cause for late filing.
The Board applies the same analysis with respect to the managerent capability issue O
also the subject of post-TMI focus by the Commission.
FUA supports the logic of r.he Zimmer decisian as applied here, but the Board should also have more carefully considered gp the cumulative effects of the other " good cause" elements which it has advanced to justify its late-filing of the TMI-related contentions.
While authority exists for rejecting 43 specific asserted justifications for lateness - considered O
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s-in isolation - (order, pp. 4-5), FUA urges that the Board
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should properly weigh-the totality of the circumstances, taken together rather than in isolation, in passing on its claim of good cause.
If so viewed in this case, FUA's justi-
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fication for lateness on TMI-related contentions emerges even more clearly than as seen in the Board's more circum-l scribed approach.
of course, the significance of the merit assigned to a i
petitioner's explanation for lateness rests on its implica-(
tions for weighing the remaining factors, as the commission
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has stated:
Late petitioners properly have a sub-stantial burden in justifying their tar-diness.
And the burden of justifying in-tervention on the basis of the factors in the rule is considerably greater when the latecomer has no good excuse.
Nuclear Fuel Services, Inc. et al. (West Valley Reprocessing l
Plant), CLI-75-4, 1 NRC 273,275 (1975).
Conversely, where
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a " marginally good excuse" is established for lateness a lesser burden attaches to evaluation of the remaining fac-i tors.
South Carolina Electric and Gas Company, et al.
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(Virgil C. Summer Nuclear Station, Unit 1), LBP-70-6, 7 NRC 209 (1978).
Having advanced such good cause for lateness on the TMI-related contentions, FUA's burden should be reduced on the remaining factorc.
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3 III S
THIS PROCEEDING REPRESENTS THE BEST FORUM FOR THE PROTECTION OF FUA'S INTEREST IN HEALTH AND SAFETY MATTERS REGARDING THE SUNMER NUCLEAR STATION.
D The Staff concedes that "this proceeding is the best forum to litigate concerns regarding radiological health and safety" (NRC Staff Erief at p. 5), but they and the Applicants would direct FUA to make a limited appearance f
and " bring its concerns to the NRC" outside the adjudica-tory process (Id., Applicants' Brief, pp. 18-20).
The Board correctly weighed this factor in FUA's favor and observed that in light of past difficulty in gaining access to county emergency plans:
Petitioner's admission into this proceeding on the emergency planning contentions should not only facilitate its being heard on those 1
issues in this forum, but should also serve i
to open some of the emergency planning to pub-
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lic input and scrutiny as should have been the case from the first.
(Order, p. 11.)
FUA and its members have diligently sought to protect their interests through available processes, including in-
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tervention in state rate-making proceedings and active par-ticipation in emergency planning for the Summer plant (Order,
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- p. 10).
But this forum can uniquely. permit it to address its health and safety concerns.
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' l ISTING INTERVENOR, CANNOT ADEQUATEL7 RE-PRESENT FUA'S INTERESTS.
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The Board properly concludes that FUA "is best quali-fled to represent its own interests," and that in light of U
. the manner in'which the existing in-tervention' has been handled [,] [w]e see no
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reason why petitioner should have any con-f4.dence that Mr. Bursey will represent its interests any better than he has, so far, represented his own.
l (Order, p. 11.)
In its recent Order dated May 13, 1981, completing action on matters from the prehearing conference of April 7 and 8, 1981, the Board further underscored the desireabil-y ity of permitting FUA to represent its own interests in per-mitting FUA to cross-examine on all issues because of our lack of confidence in the other intervenor's ability to effectively prepare his case and because of the contri-bution we believe FUA might make on all of the issues.
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(Remainder of Order, p. 10.)
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FUA'S " INTENSIVE PREPARATION" AND " DEMON-STRATED KNOWLEDGE" ON EMERGENCY PLANNING AND CORPORATE MANAGEMENT MAKE CLEAR THAT ITS PARTICIPATION WILL CONTRIBUTE TO THE i
DEVELOPMENT OF A SOUrID RECORD FOR DECISION.
The Board weighs the " ability to contribute" factor most heavily in favor of admitting FUA on the TMI-related contentions:
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) As is apparent from FUA's pleadings and from the general. discussion at the preheari1g-conference, petitioner's mem-1 bers have become well versed in the for-mer areas [ corporate management and emer-gency planning], independently of any in-tention of intervening in this proceeding, through their participation in rate-making proceedings and in the ongoing emergency
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planning.
L (Order, p. 10.)
This finding is buttressed by the Board's subsequent ruling permitting FUA broad discretionary cross-examina-tion, "because of the contribution we believe FUA might make on all of the issues" (Remainder of Order, p. 10).
This showing was made at a prehearing conference at l
which it intended to appear solely as an observer since it had received no formal direction to appear or notice that it would be required to go forward (Tr. 342, 343, 463).
FUA's request for an opportunity to submit a bill of 1
l-particulars in further support of its claim on this factor was declined by the Board (Tr. 662,663).
f VI LIMITING FUA TO ISSUES ALREADY ADMITTED AND REQUIRING FUA TO TAKE THE PROCEEDINGS AS IT FINDS THEM WILL ENSURE THAT THE IS-SUES WILL NOT BE BROADENED AND THAT "UN-PRODUCTIVE DELAY" WILL BE AVOIDED.
l The Board concluded that by limiting FUA's admission to the Tmi-related~ corporate management and emergency plan-ning contentions and requiring it to "take the proceedings l
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- 12 as they are," with FUA limited to the affirmative case al-j ready disclosed in detail in its pleadings and during the prehearing conference, issues will be desireably particular-ized but not broadened and delay attributable to FUA tardi-
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ness will be avoided (Order, pp. 7-9).
The Board correctly measures the relevant delay
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3 attributable directly to FUA, Long Island Lighting C.
p (Jamesport Nuclear Power Station, Units 1 and 2), ALAB-292, f
2 NRC 631, 650, fn. 25 (1975); as contrasted with the ap-plication of some "real world calendar" concept bearing no i
relation to the lateness itself (Tr. 567,568), or as applied l
to essentially an uncontested case where "there will be no l
issues to broaden nor a proceeding to delay."
South Caro-
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lina Electric and Gas Company, et al. (Virgil C. Summer Nuclear Station, Unit 1), LBP-78-6, 7 NRC 209, 213 (1978).
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Even considering application of an impermissable measure-
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ment - not related to the lateness itself - the Board forsees no unwarranted or unproductive extension'of the hearing process (Order, p. 9).
Since both admitted iasues are not
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susceptible to summary disposition, are governed by evolv-ing Commission policy or Staff pocitions, no relevant delay can be attributable to FUA's untimeliness.
h Staff and Applicant would engraft an additional con-I sideration to this factor - one of purported hardship or prejudice attributable to petitioner's admission into what
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would otherwise be close to a default case.
For the reasons l
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l stated, supra at pp. 5,6, loss of this " free ride" is not lO a valid c nsiderati n t attribute to petitioner, any more 4
than would allowing Applicant'to measure delay against a schedule where no hearing would be held at all.
- Susener,
!O supra at 213.
f i
Applicant criticizes the Board for failure to "addrass i
the costs of delay to Applicants and their custdmers" (Ap-O plicants' Brief, p. 1), andisuggest that their submission regarding alleged costs of delay went uncontroverted (Ap-plicants' Brief, p. 13).
Both positions misstate the record.
fO FUA expressly disputed the' validity of the Applicants' FUA specifi-
.-" cost of delay" Attachment 2-C to its Answer.:
f cally requested an opportunity to examine the methodology O
and assumptions underlying the estimates (Tr. 532) and j
pointed out that on the face of the schedule the data belies l
Applicants' asserted need to have the plant "available for iO the heavy demands of late Spring and Summer of 1982" (Ap-f plicants' Auswer, p. 15) since South Carolina Electric and Gas ;ompany's excessive reserve margin at Summer peak in O
1982 is reflected in Applicants' o '3sion of n " Replace-ment Cost of Capacity" associated with delay for South Caro-lina Electric and Gas Company (Tr. 529-532).
The Applicants lO did not dispute thir reading (Tr. 539,540).
The Licensing Foard questioned Applicants closely con-l carning costs reflected on this schedule:
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CHAIRMAN GROSSMAN:
The question really is whether'there is any justification for any j
of those figures that we have seen submit-ted and which apparently a great number of people are relying upon recently.
[D]oyouhavethoshhiguresavailable?
l MR. KNOTTS:
I believe.
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(brief pause)
We. don't have them with us, Your. Honor, but we could supply them.
(Tr. 542.)
No such figures have yet been supplied for the record by l
Applicants.
In sum, the Licensing Board's treatment of the delay factor is fully supported by the pertinent authorities and my i
by the record - including all consideration due Applicants' position.
While the " promiscuous" granting of late interventen-f tions poses the " clear and unacceptable threat to the in-tegrity of the entire adjudicatory process,"~as observed by l
the Appeal Board in Puget Sound, Power and Light Company,
.et al. (Skagit= Nuclear Power Project, Units 1 and 2) ALAB-559, j
I 10 NRC 162 (1979), so would the rejection of a meritorious petition equally threaten the integrity of the adjudicatory l
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process where the consequence is a mere sham of an adjudi-cation without capable adversary parties and a sound record
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for decision on vital health and safety issues affecting the I
i public.
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CONCLUSION
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'O For the foregoing reasons, Intervenor Fairfield United Action respectfully urges the Appeals Board to affirm the.
decision of the Licensing Board and dismiss these appeals.
g REQUEST FOR ORAL ARGUMENT Pursuant to 10 C.F.R. S 2.763 Intervenor Fairfield
.O United Action requests the opportunity to be heard in oral l
argument in this matter.
lO Respectfully submitted, i
g
'g Robert Guild Counsel Dr. John C. Ruoff Authorized Representative h
For Intervenor l
Fairfield. United Action Columbia, South Carolina j
May 20, 1981 p
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UNTTEC STMES OF AMERICA NUCLEAR REGULATORY COMtISSION i)
BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of:
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SOUTH CAROLINA ELECTRIC AND
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g-GAS COMPANY, et al.
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Docket 50-395-OL
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l (Virgil C. Sununer Nuclear
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Station, Unit 1)
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h CERTIFICATE OF SERVICE I hereby certify that copies of "Brief of Fairfield United Action in Opposition to Applicant and Staff Appeals from Order Granting Ntervention and Request for Oral Argument" I
and " Notice of..ppearance" were served upon the following g~
persons by deposit in the United States mail, first class postage prepaid, or placed in Express Mail, as indicated l
by an asterisk, this 20th day of May 1981.
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- Alsn S. Rosenthal,. Chairman Dr. Frank F. Hooper Atomic Safety and Licensing School of Natural Resources Appeal Board Panel University of Michigan U.S. Nuclear Regulatory Com-Ann Arbor, MI 48109 mission Washington, DC 20555 Mr. Gustave A. Linenberger i
(3 Member, Atomic Safety and
- Dr. John H. Buck, Member Licensing Board Panal Atomic Safety and Licensing U.S. Nuclear Regulatory Com-Appeal Board Panel mission U.S. Nuclear Regulatory Com-Washington, DC 20555 mission 3
Washington, DC 20555 Chairman, Atomic Safety and Licensing Board Panel
- Christine N. Kohl, Member U,4. Nuclear Regulatory Com-4 Atomic Safety and Licensing mission Appeal Board Panel Washington, DC 20555 l
U.S. Nuclear Regulatory Com-3 mission George Fischer, Esq.
Washington, DC 20555 Vice President and Group Executive South Carolina Electric & Gas Herbert Grossman, Esq.
Company Chairman, Atomic Safety and P.O. Box 764 Licensing Board Panel Columbia, SC 29218 3
U.S. Nuclear Regulatory Com-mission Washington, DC 20555 D
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Steven C. Goldberg, Esq.
Richard P. Wilson, Esq.
Office of the, Executive M-Assistant Attorney General
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gal Director South Carolina Attorney General's U.S. Nuclear Regulatory Com-Office mission P.O. Box 11549 Washington, DC 20555 Columbia, SC 29211 Mr. Brett Allen Bursey Randolph R. Mahan
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Route 1, Box 93-C~
South Carolina Electric & Gas
(
4 Little Mountain, SC 29075 Company P.O. Box 764 Mr. Chase R. Stephens Columbia, SC 29218 Docketing and Service Section i
Office of the Secretary Joseph B..Knotts, Jr.
(
U.S. Nuclear Regulatory Com-Debevoise & Liberman mission 1200 17th Street, N.W.
Washington, DC 20555 Washington, DC 20036 i
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Rollert Gul
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UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION m
BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARu
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In the Matter of:
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SOUTH CAROLINA ELECTRIC AND
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Docket No. 50-395 OL GAS COMPANY, et al.
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May 20, 1981 (Virgil C. Summer Nuclear
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Station, Unit 1)
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l NOTICE OF APPEARANCE y
Please take notice that the undersigned attorney I
hereby enters an appearance in the above-captioned matter l
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in accordance with 10 C.F.R. S 2.713:
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l Name:
Robert Guild.
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i Address:
314 Pall Mall l
Columbia, S.C.
29201
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Telephone Numbers:
803-252-0929 i
803-799-9668
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Admissions:
United States Court of Appeals for the Fourth Circuit; United
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States District Court for the District of South Carolina; 1 Supreme Court of South Carolina l
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[
M ert GuiEA-- -
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Counsel for Inter"Snor Fairfield United Action j
h May 1981 Columbia, South Carolina w
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