ML20010F385

Response to ASLB 810814 Memorandum & Order on Prehearing Conference.Provides Identities & Qualifications of Witnesses to Testify on Seven Contentions.Certificate of Svc Encl

ML20010F385
Person / Time
Site:	Susquehanna
Issue date:	09/08/1981
From:	Cutchin J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
References
NUDOCS 8109100117
Download: ML20010F385 (17)

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fiUCLEAR REGULATORY COMMISSION C>

f BEFORE THE ATOMIC SAFETY AND LICEllSIf4G BOARD A

In the Matter of

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PENi4SYLVANIA POWER AND LIGHT C0.

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Docket No. 50-387 ALLEGHENY ELECTRIC COOPERATIVE, INC.

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50-388

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(Susquehanna Steam Electric Station,

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Units 1 and 2)

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IDENTITIES, QUALIFICATI0fiS AND TESTIMONY OF flRC STAFF WITNESSES In its "ilemorandum and Order on Prehearing Conference" dated August 14, 1981 the Licensing Board directed that the identities, qualifications, subject matter and substance of the testimony of expert witnesses on the second seven contentions (or portions of contentions) to be heard at the evidentiary hearing scheduled to begin on October 6,1981 be filed by September 8,1981. The identities of the Staff's witnesses on the accord seven contentions to be heard and the subject matter and substance of their testimony are provided below.

Copies of the professional qualifications of the witnesses for whom they have not previously been transmitted are attached.

Contention 2 (Chlorine)

That portion of the contention dealing with the health effects of chlorine may again become the subject of a motion for summary disposition. However, if that portion of the contention is litigated the Staff's witness will be Mr. John C. Lehr. Mr. Lehr will testify that l

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the health effects of chlorine discharges to the Susquehanna River have been adequately assessed and factored into the cost-benefit balance.

Contentions 6 and 20 These contentions challenge the adequacy of the emergency plans of the Applicants, the Commonwealth of Pennsylvania and Luzerne County.

The Staff's witnesses will be Messrs. Stephen H. Chesnut and Bruce J.

Swiren. Mr. Chestnut will testi on those aspects of emergency planning and preparedness dealing with the interfaces between Applicants and off-site agencies and with evacuation time estimates. Mr. Swiren will testify on the off-site aspects of emergency preparedness and the conformance of the emergency plans of the Commonwealth of Pennsylvania and Lucerne County with the guidance in NUREG-0654, Revision 1,

" Criteria for Preparation ard Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"

dated November 1980.

Contention 9 The contention alleges that the health and monetary costs of decommissioning the Susquehanna facility at the end of its useful life have been incorrectly assessed, that the true costs will tilt the cost-benefit balance against granting operating licenses, and that the Applicants are not financially qualified to assume the true monetary costs. The Staff's witnesses will be Dr. Carl Feldman, Dr. Raghaw Prasad

and Mr. Michael L. Karlowicz. These witnesses will tesify that the health and monetary costs of decommissioning have been appropriately assessed and that the cost-benefit balance supports the granting of operating licenses.

Contention 11 Only that portion of the contention dealing with safe on-site storage of low-level radioactive wastes (LLW) survives for litigation. The Staff's witnesses will be Dr. Charles L. Miller and Mr. Peter Loysen.

They will testify on the amount of LLW generated, the packaging of LLW for shipment or storage, and the capacity and safety of the LUl storage area that is to be provided on the site.

Contention 14 This contention deals with tPe capacity factor assumed in assessing the benefits of the facility for cost-benefit balancing purposes and may become the subject of a motion for summary disposition. However, if the contention is litigated the Staff's witness will be Dr. Raghaw Prasad.

He will testify that even though the actual capacity factor for the Susquehanna facility may be lower than that assumeo by the Applicants in their Environmental Report the benefits of operation of the facility will outweigh the environmental cost; of operation.

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4-Contention 21 This contention challenges the adequacy of the design of the scram system. The Staff's witness will be Mr. Kenneth T. Eccleston. Mr.

Eccleston will testify that generic guidance for resolution of the Staff's concerns about pipe breaks in the scram system is provided in NUREG-0803, " Generic Safety Evaluation Report Regarding Integrity of BWR Scram System Piping," and that either conformance with that generic guidance or justification ar.d implementation of an alternate solution would be acceptable to the Staff.

Respectfully submitted, 4

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James M. Cutchin, IV Counsel for NRC Staff Dated at Bethesda, Maryland this 8th day of September,1981 e

FRDFESSIONEL 01LLI ICcTIONS

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JOHN C. LEHR U.S. Nuclear Regulatory Commission I ar currently en;1oyed as Senior Environnental Engineer in the Office of huclear Reactor Regulation, Division of Site Safety and Enviror. er,tal Analysis, in the Environner,tal Specialists Branch.

I have the responsibility for the independent review and analysis of the proposed site, alternative sites, site selection methodology, station construction, and design and operatien of those features if nuclear po,ver plants as they may affect natural water resources, existine water quality and use, water quality and usage goals as establisned by the responsible agency and other impacts on the aquatic enviror.nent.

In this capacity, I have prepared the abiotic aquatic impact sectices for NRC environr. ental inpact statements (EIS) or numerous constructior. permit and operating license applications.

For operating license applicaticts, I have provided the technical specifications in the area of water quality and chemical discherge licitations and monitoring requirements.

I have proviced the technical expertise in the NRC overview function of contractor prepared EIS's in the area of atictic aquatic impact assessments, including the need for mitigative actions and establishment of coordination with state and regional EPA offices.

In the above capacities, I have been responsible for the water quality related aspects of NRC licensing actions for over 70 applications.

I have also been responsible for the water quality related sections of several NRC NEPA alternate site investigations of proposed nuclear power plants, including the Seabrook Units 1 and 2 plant.

I have acted as a consultant to other NRC branches and provide analyses of wa;er c.uality problets through technical assistance requests, particularly to the Division of Operating Reactors on natters pertaining to assesstent of chemical effluent impacts and changes in abiotic effluent limitations and water chemistry monitoring programs for operating plants.

I have served as the coordinator and principal investigator in an in-house study to determine actual releases of residual chlorire from operating nuclear power plants.

In addition, I am the Division technical representative on several inter-office NRC Research Review Groups.

As such, ? am responsible for defin-ing and coordinating research needs in the area of aDiotic aquatic environnental centerns and for providing the technical guidance for on-going research programs in this area.

Examples of research activities governed by them review groups are asbestos in cooling tower waters, residual chlorine and chlorinatior by-products in power plant discharges in fresh and marine waters and investigation of the occurrence of pathogenic organisms in power plant cooling waters.

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I nave Lcen desianated as the in-house technical originator responsible for development of Environrental Standard Peview Plans addressing staff NEPA reviews of site water quality, plant water uses, plant chemical and sanitary wastes, water quality related impacts of plant operation, abiotic aquatic monitoring and chemical treatment system alteraatives.

In a related activity, I have i

participated as a member of the Standard Environnental Technical Specifications l

Task Group responsible for the abiotic aquatic nonitoring sections of the M:Guire Units 1 and 2 and the Three Mile Island Unit 2 ETS.

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• ve participated in technical conferences with and coordinated water quality related activities with the U.S. Environmental Protection Agency, the U.S. Army Corps of Engir.eers, and other Federal, State and local agencies regarding inclener.tation of the National Environmental Policy Act, the Federal Water Polluticr Control Act and its amendments, the Toxic Substances Act, the Drinking Water Act and the nenoranda of understanding between tne NRC and EPA and COE.

I have aisc developed expertise and been designated as the responsible technical scecialist ir. the areas of sound level predictior. tect'.iques for power plants anc their transnission lines and technicues for estination of connanity response tc environmental sound levels, as influenced by pov.sr plant construction and coeration.

I have been responsible for sections of h?.: environmental impact statements addressing tr.ese areas for se.eral prcpesec and operating nuclear power plants.

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I have a Bachelor of Science degree in Mechanical Engineering from Drexel Institute of Technology (1959) and a Master of Science degree ir. Environmental Engineering from Drexel University (1972) specialicin; ir. water associated problem.s in the environment.

My academic backgrounc includes studies in water chemistry, domestic and industrial waste treatment, and water resources management.

From 1969 to 1972, I was a mechanical engineer at tne U.S. Arry Frankford Arsenal, Pniladelphic, Pennsylvania.

I was assignec as Project Manager of materials handling, and pollution control efforts for the Smell Caliber 3

Annanition Mocernization Program.

I participated ir. the development of solid and licuid waste managenent and noise control programs for metal parts manufacturing facilities.

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STE;';I:;l H. Ci!ESNUT PROFr.SSIO:.'AL QU:\\LIFICATIONS OIrICE OF INSPECTION At:D ENFORCE!!ENT U.S.110CLF.AR REPIL ATORY CO.". ilSSION '

i ny name is Stephen H. Chesnut.

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I c:a currently a floclear Engineer assigned to i

Of fice of Inspection and Enforc:..:ie; ni.Joess Lic:nsitig Cranch, Division of Erergency Preparedn2ss l

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I:y di.ics include the revi a and evalu-ation of flu lca Pouer Reactor Exerc'n y Plans.

I received a Bach 21or or Science dagre2 in IMch,nical Enginacring in 1974 fre.a t

the U.5. Naval Acadercy.

From 1974 to 1979 I sics a cc...aissioned of ficer in the U.S. Navy fluclear Pc. tar Uhile in the U.S. Navy, I completed considerable training in th2 prog rar, operation and supervision of nuclear power plants.

I served as division i

1 of ficer of several divisions responsible for personnel training, plant opara-tion, nuclear material naint:nanca, and radiological controls on board a nuclear subv.arine.

Of ficer, responsible for th: Additionally I qualifi:d and servad as Acting Chief Engin:2r of a navai ne:1.:ar poo;:r pit.nt.overall op? ration, suparvision, and uainten?.n::

Fo11 cuing ey tour in th2 U.S. ib.y, I 0; :at or.: yaar as a senior engin2 acing consult,nt, c,sploy:d by Dooz, Allen co f !!' iilton.

During this period, I 1

served as a consul tant. to ti.a D.: pari.. nt of th y thvy, and providad tachnical i

engincaring revi::us and race.. aamhtica: to ths T31D2:11 nuclear sub_iarine i

ccquisition prca.tu.

i y Join 2d the inC in lby 1900 v;ure I.y duti_:, incled; ths ravicu ancf[~/alua o,. nucl r

cu; plan; caerc n:y plcog., Th' ravi: o rasnit in th irbntifi-scr..ancies an:. se:n cp.:c (ic recc: aandations to i" pro", o[v-~jll E..,2rg2ncy Preparedn2ss or I!ucl.ar ihn: tor Sitas.

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Preparc.iness Tec.c Leader for ti.; i:r:laa

."c 2r Plants in Pan:nylvanIu.

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V Bruce J. Swiren Emergency Management Specialist Federal Emergency Management Agency Plans and Prep 3radness Division Region III, Philadelphia, Pennsylvania EDUCATI ON B.A. Temple University, May 1973 B.S. in Biology, University of New Ha pshire, December 1974 EXPERIENCE Federal Emergency Management Agency Region III December 1980 to present Plans and Preparedness Division Serves as project leader for Beaver Valley and Susquehanna nuclear power plants, Responsible for providing guidance to state planners, and an alternative for TMI.

reviewing and evaluating plans and providing constructive analysis on state and local off-site REP plans respective to fixed nuclear facilities. Responsibilities include participating as a Federal observer in site specific REP exercises in To date, I was the prin:iple Federal observer in Dauph'in County Region III.

for the June 2,1981 TMI exercise.

Plans reviewed to date include the Pennsylvania State plan in various draft forms, the Dauphin County plan relative to TMI and the West Virginia State Plan relative to the Beaver Valley fixed Also serves as a member on the FEMA Region III hazardous nuclear facility.

materials task force which involves at this stage, the development of interim guidelices, consistent with national policy, for the review of state and local hazardous materials plans, including radi.oactive material.

September 1978 to October 1980 Environmental Protection Agency Hazardous Materials Branch Region III As an environmental protection specialist, in the Hazardous Materials Branch, served as a technical liaison to federal agencies, states, local governments Performed and the public in the area of hazardous and solid waste disposal.

site investigations and inspections relative to determining the adequacy of Served as the disposal actions and the prevention of on-going illegal dumping. lea of Pennsylvania's State Plans for management of hazardo,r waste, generation, storage, and disposal.

-i Environmental Protection Agency Region III Pesticides Branch March 1975 to September 1978 As an environmental protection specialist in the Pesticides Branch, served as the technical liaison to Federal agencies, state and local governments, and 'he public in the areas of proper pesticides use and disposal.

Provided guidance and assistance to state governments in Region III in the development and implementation of pesticide application certification training programs and State Plans for managing a full state level regulatory program for pesticides use and disposal.

Performed use investigations of agricultural and residential applications of pesticides to determine the level of compiiance with Federal standards.

Spccialized Training in REP 1.

Radiological Emergency Response Course, April 1981 Las Vegas and Mercury Test Site i;evada.

Covered ba-ic aspects of nuclear radiation and the basic procedures and techniques for responding to an accident involving nuclear materials.

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Techniques for Managing Public Meetings, March 1981, Washington, D. C.

A NRC-sponsored seminar dealing with techniques to successfully conduct public meetings concerning REP plans.

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Radiological Emergency Preparedness Planning Seminar, January 1981 Emmitsburg, Maryland.

Discussions on FEMA and NRC nuclear radiological emergency preparedness (REP), NUREG-0654 planning methods and interactions with Utility, state and local planners and decision-makers.

_ Professional Qualifications My name is Carl Feldman.

I am a Nuclear Engineer with the Division of Engineering Technology, Chemical Engineering Branch, in the Office of Nuclear Regulatory Research.

Presently I am respo'nsible for preparing a final environ-mental impact statement on decommissioning of nuclear facilities.

I am responsible for evaluating decommiss'ioning models in the area of technology, safety and costs for nuclear facilities.

I have been a member of the decommissioning staff for about three years, first in the Office of Standards Development and subsequently in the Office of Nuclear Regulatory Research.

I received a B.S. in Physics from the City College of New York in 1960, an M.S. in Physics from Rutgers University in 1963, and a Ph.D. in Solid State Physics from Rutgers University in 1967.

From 1956 to 1973 I worked at Grumman Aerospace Corporation as a Research Scientist in the area of materials engineering and integration and served as Project Manager for Aerospace Materials Applications.

From 1973 to 1978 I worked at NUS Corporation in the areas of environmental and occupational radiation dose assessments in the Division of Environmental Safeguards and participated in the development of nuclear reactor environmental reports and safety analysis reports.

Since joining the NRC in 1978 I have been with both the Office of Standards Development and its subsequent reorganization with the Office of Nuclear Regulatory Research.

During this time I have been a member of the decommissioning staff involved in reevaluating the NRC policy on nuclear facility decommissioning and have been technical program manager on the Battelle Pacific Northwest Laboratory (PNL) development of a report and addendum on the technology, safety and costs of decommissioning a pressur ized water nuclear reactor, (NUREG/CR-0130), and was involved in critical review of the PNL report on decommissioning of a boiling water reactor,(NUREG/CR-0672).

I have also participated in two sets of State Uorkshops l

on decommissioning. At the second State Workshop I presented a talk on the early I

draft generic environmental impact statement results and have been involved in l

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,o.- numerous technical presentations in the decommissioning area to various industrial and public groups.

Presently, I am a member of the American Physical Society, Divisions of Nuclear and Solid State Physics.

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s-PROIISS10.';AL QUAliflCATIONS OF MICH/.El L. KARLOWICZ I am employed as a financial Analyst by the U. S. I!uclear Regulatory Commission. !!y primary responsibility is the perfomance of the financial' qualifications review of applicants during the nuclear licensing process.

This revicw includes an analysis of estimated construction costs in construction permit proceedings and operating and decommissioning e.xpenses in oper. ting license matters.

Concomitantly, the financial review encompasses the projected financing methuds by which the required funds-uill be obtained.

I also review the climate and trends of state utility commissions.

In this regard, I have prepared financial testimony for inclusion in supplements to the Staff's Safety Evaluation Report and for presentation at Atomic Safety and Licensing Board !!carings.

!!y responsibilities also include the monitoring and keeping abreast of the poney and capital markets, particularly those affecting the publicly and investor-ovined electric utility sector of the economy.

In this respect, I maintain a regular course of conrunication with the financial community.

This includes utility securities officers and specialists representing the major rating firms, investrent banling instituti~ons, brokerage houses, and the Securities and Exchange Commission.

Additionally, I serve as liaison for the NRC in financial natters with the rederal and State Utility Commissions.

I I received a Bachelor of Science Degree with a major in !!athematics in l

1972 from Saint Peter's College.

In 1976, I received my 41uris Doctorate from the Delaware law School.

Thereafter, T attended,the post-graduate l

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L. L. M. tax la. progran at fle.: York University in 1976 through 1977.

I have also undertalen studies in finance in the graduate program at the American University School of Business Administration.

t Prior to my joining the U. 5. iluclear Regulatory Comnission in December 1977, I spent three years with the New Jersey Department of the Public Advocate, Division of Rate Counsel.

As both attorney and econo:aist, my responsibilities included the representation of the public interest in litigation involving proposals of increases in rates or discontinuance of service by regulated industries.

From 1969 through 1970, I was employed by Public Sersice Electric and Gas Company in thcir System Planning and Development Department and the Office of the Corporate Economist.

There, I was responsible for conducting short, mediura, and long-range studies in financial planning, the preparation of expert t

testirnony, the iraplementation and development of financial modeling, and the performance of economic analysis.

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PROFESSIONAL QUALIFICATIONS l

Peter Loysen U.S. Nuclear Regulatory Comission I have been employed as Senicr Chen:ical Engineer in the Advanced Fuel and Spent Fuel Licensing Branch since October,1974. I am responsible for.

managing safety and environmental reviews of applications for licenses such.c those for spent fuel storage, reprocessing facilities and waste processing and storage.

I received a B. Ch. E. Degree from Rensselaer Polytechnic Institute in 1952.

From 1952 until 1956 and from 1961 through 1968, I was at the U.S. Atomic energy Commission's Health and Safety Laboratory in New York City where I provided health protection surveillance of AEC contractor production and research facilities and conducted field and laboratory research and studies into health protection problems pertaining to the contractor facilities.

From 1956 to 1961, I established and directed the occupational health and safety program at M&C Nuclear, a then major supplier of fabricated nuclear-fuel to the U.S. -Navy.

From 1968 to 1970, I established and directed the radiation protection program at Radiation Machinery Corporation, a manufacturer of irradiated wood-plastic composite flooring and packaged irradiators and supplier of irradiation services.

From 1970 until joining the NRC in 1974, I was Manager of Nuclear and Industrial Safety and then Manager of Regulatory Administration for the LWR Fuel Division of General Atomic Company (nee United Nuclear Corporation).

I was Certified in Health Physics by the American Board of Health Physics in 1962.

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KENNETH T. ECCLESTON PROFESSIONAL QUALIFICATIONS _

I am a Project Manager in Operating Reactors Branch No. 2, Division of Licensing, U.S. Nuclear Regulatory Commission.

In this capacity, I am responsible for the review and evaluation of safety and environmental -

considerations associated with the design and operation of the operating reactors assigned to me. This involves the planning, integration, and man.agement of the efforts of reviewers from specialized areas to formu-1, ate our technical evaluations.

I am also the staff's primary contact with the licensees.

I develop recommendations for licensing actions and integrate the results of our reviews into environmental and safety evaluation reports I am also the lead project man.ager for a number of s

ge'neric issues including the issues " Safety Concerns Associated with Pipe Breaks in the BWR Scram System" and "BWR Scram Systems."

I received j

a Bachelor of Science degree in Physics in 1970 from Manhattan College, New York, N. Y.

I also received a Master of Engineering degree in Nuclear Engineerir.g in 1975 from New York University.

I have over nine yt -

7f professional experience in the nuclear field and an additional two years experience in the mechanical engineering field.

I worked for the Consolidated Edison Company and held positions in the mechanical engineering department and in the nuclear field as a field engineer assigned on location to tha Indian Point facilities and as a systems engineer in the Nuclear Engineering Section.

I am presently the NRC Project Manager for the Monticello Nuclear Generating Plant and the Duane Arnold Energy Center.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY LICENSING BOARD In the Matter of

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PENNSYLVANIA P0llER AND LIGHT CO.

Docket Nos. 50-387 ALLEGHENY ELECTRIC COOPERATIVE, INC.

50-388 (Susquehanna Steam Electric Station, Units 1 and 2)

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CERTIFICATE OF SERVICE I hereby certify that copies of " IDENTITIES, QUALIFICATIONS AND TESTIMONY OF NRC STAFF WITNESSES" dated September 8, 1981 in the above-captioned proceeding has been served on the following by deposit in the United States mail, first class or, as indicated oy an asterisk, by deposit in the Nuclear Regulatory Commission's internal mail system, this 8th day of September, 1981 :

James P. Gleason, Chairman Dr. Judith H. Johnsrud Administrative Judge Co-Director 513 Gilmoure Drive Environmental Coalition on Silver Spring, MD 20901 Nuclear Power 433 Orlando Avenue

• Mr. Glenn 0. Bright State College, PA 16801 Administrative Judge Atomic Safety and Licensing Board Mr. Thomas M. Gerusky, Director U.S. Nuclear Regulatory Commission Bureau of Radiation Protection Washington, DC 20555 Department of Environmental Resources Commonwealth of Pennsylvania Dr. Paul W. Purdom P.O. Box 2063 Administrative Judge Harrisburg, PA 17120 l

245 Gulph Hills Road Radnor, PA 19087 Ms. Colleen Marsh Box 538A, RDf4 Jay Silberg, Esq.

Mountain Top, PA 17120 Shaw, Pittnan, Potts and Trowbridge 1800 M Street, N.W.

Mr. Thomas J. Halligan Washington, DC 20036 Correspondent: CAND P.O. Box 5 Bryan A. Snapp, Esq.

Scranton, PA 18501 Pennsylvania Power & Light Company Two North Ninth Street Allentown, PA 18101 i

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• Richard S. Salzman, Esq., Chairman, Susquehanna Environmental Administrative Judge advocates Atomic Safety and Licensing Appeal Board c/o Gerald Schultz, Esq.

U.S. Nuclear Regulatory Commission P.O. Box 1560 Washington, DC 205S5 Wilkes-Barre, PA 18703

• Dr. John H. Buck, Administrative Judge Mr. Robert M. Gallo Atomic Safety and Licensing Appeal Board Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 52 Washington, DC 20555 Shickshinny, PA 18655

• Mr. Thomas S. Moore, Administrative Judge Robert W. Adler Atomic Safety and Licensing Appeal Board Dept. of Environmental Resources U.S. Nuclear Regulatory Commission 505 Executive House Washington, DC 20555 P.O. Box 2357 Harrisburg, PA 17120

• Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commissior.

Mr. DeWitt C. Smith, Director Washington, DC 20555 Pennsylvania Emergency Management Agency

• Atomic Safety & Licensing Appeal Board Transportation and Safety Building Panel Harrisburg, PA 17120 U.S. Nuclear Regulatory Commission Washington, DC 20555

• Secretary U.S. Nuclear Regulatory Commission ATTN:

Chief, Docketing & Service Branch Washington, DC 20555

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James M. Cutchin, IV Counsel for NRC Staff v~-

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