ML20024B978
| ML20024B978 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/08/1983 |
| From: | Barth C NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8307120077 | |
| Download: ML20024B978 (18) | |
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07/08/83 6
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of CAROLINA POWER AND LIGHT COMPANY AND NORTH CAROLINA EASTERN MUNICIPAL Docket Nos. 50-400 OL POWER AGENCY
)
50-401 OL
)
(Shearon Harris Nuclear Power Plant,
)
Units 1 and 2)
)
NRC STAFF RESPONSE TO WELLS EDDLEMAN'S RESPONSE TO THE STAFF'S DRAFT ENVIRONMENTAL IMPACT STATEMENT I.
BACKGROUND The Licensing Board's Order of May 27,1983(page25) authorized the filing of contentions based on new information contained in the Staff's Draft Environmental Impact Statement (DEIS). Such contentions premised upon new information not othemise available in the public realm need not meet the tests of nontimely filings contained in 10 CFR 92.714(a)(1)(1-v).
(Tr. p. 33-37)
Intervenors were also permitted to use "new infonnation" in the DEIS to support contentions previously deferred by the Board. The criteria to be applied to the proffered contentions were those set forth in 10 CFR S 2.714(b) for timely filed contentions.
(Tr. p. 33-37)
On July 1, 1983 the Commission issued its decision in Duke Power Company, et al. (Catawba Nuclear Station, Units 1 and 2), CLI-83-19, NRC (1983), which considered the standards to be applied to conten-l tions premised upon information contained in licensing-related documents not required to be prepared early enough so as to enable an intervenor to l
frame contentions in a timely manner in accord with the provisions of 10 CFR 6 2.714(b).
DESIGNATED ORIGINAL
/] 9 83 7 7
08 Certified By Q
Because of the generic nature of the issues in Catawba, the Commis-sion invited briefs from the parties and any other person who wished to submit an amicus brief. Catawba, supra, slip op. at 2.
Based on its review of these filings, the Comission detennined that it is reasonable to apply the late-filing criteria in 10 CFR 9 2.714(a)(1) and the Appeal Board's three-part test for good cause to contentions that are filed late because they depend solely on infonnation contained in institu-tionally unavailable licensing-related documents.1/ _Id., slip op. at 2,
- 10. Further, the Commission determined that the institutional unavaila-bility of a licensing related document does not establish good cause for filing a contention late if information was available early enough to provide the basis for the timely filing of that contention.2_/
Id.,
slip op. at 2, 12.
The Staff issued its DEIS in April 1983 and Mr. Eddleman responded on June 23, 1983.3_/ The Applicant's June 27, 1983 filing characterizes Mr. Eddleman's response as "very difficult to understand." The Staff also found it confusing. For this reason, we anticipate that there may
-1/
The Commission believes that the five factors together, are per-mitted by Section 189a. of the Act and are reasonable procedural requirements for determining whether to admit contentions that are filed late because they rely solely on information contained in licensing-related documents that were not required to be prepared or submitted early enough to provide a basis for the timely formulation of contentions.
Id., slip op. at 5, 6.
-2/
The Comission set out in its decision the fundamental principles upon which it bases its conclusion that Intervenors are required to diligently uncover and apply all publicly available information to the prompt formulation of contentions.
Id., slip op. at 10,11.
-3/
. Wells Eddleman's Respor.se to Staff DEIS," dated June 20, 1983.
(Response).
4 be some differences of opinion among the parties as to the meaning of portions of the filing. Following is the Staff's discussion and analysis of Mr. Eddleman's June 20, 1983 filing, in the order presented in that filing.
II. DISCUSSION A contention must have a specifically detailed foundation in fact relating to the reactor and site in the proceeding. This is done by alleging specific facts, or specific factual scenarios. This is the
" basis" requirement of 10 CFR 5 2.714(b).
In Texas Utilities Generating Company, et al. (Comanche Peak Steam Electric ' tation, Units 1 and 2),
S CLI-81-36, 14 NRC 1111 (1981), the Commission stated:
At present, all an intervenor need do to support admission of a contention is set forth the basis for the contention with reasonable specificity.
I_d. at 1114.
In support thereof the Commission cited Mississippi Power and Light Company (Grand Gulf Nuclear Station, Units 1 and 2), ALAB-130, 6 AEC 423, j
426(1973). An acceptable contention must have a " basis" regardless of when it is filed.
In Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2), ALAB-728 NRC (Slip op.,
May 18, 1983) the Appeal Board addressed, inter alia, certain contentions l
rejected by the Licensing Board. The Appeal Board addressed rejected l
Contention 11 in the context of meeting the requirements for reopening a closed record. There the Appeal Board stated:
l They merely allege, without more, that the applicant's l
analyses are inadequate. This is patently insufficient to l
meet their burden. The joint intervenors have not presented I
any evidence that the applicant's analyses do not comply with the NUREG-0737 requirement. Nor have they come fomard with
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I.
a specific critique of the applicant's analyses or an analysis of their own, with an explanation why it must be performed. Stated otherwise, the joint intervenors have improperly attempted [ slip op. 56] to shift their burden of coming forward with significant new evidence of what more needs to be done by the simple expedient of pleading that the applicant has not done enough to comply with the regulations.
Accordingly, the joint intervenors' clarified contention 11 was properly. rejected.
[Slipop.57]
The bare allegation by an-intervenor that a staff or applicant analysis is flawed, or that they must do more, or that a regulation is not complied with, does not satisfy the " basis" requirement of the 4
Commission's regulations. Assertion of the ultimate conclusion of defect or error without setting forth a specific detailed factual foundation or
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a specific factual scenario, or an analysis of their own, makes a proffered contention not admissible. Previously we have referred to these as ipse dixit unsupported allegations.
In our filing of June 22, 1982 (pages 2-10) we addressed the criteria for an acceptable contention.
l That discussion coupled with the above discussion of " basis" represents the legal principles the Staff believes should be applied in considering the proposed contentions.
III. THE CONTENTIONS Mr. Eddleman seems to request that deferred contention number 88 and rejected number 105 now be admitted. Contention number 88 on page 198 of l
Mr. Eddleman's May 14, 1982 filing alleges that the Environmental Report (ER) "is deficient in that it considers as benefits the use of the Harris l
plant lake and surrounding area for recreation, hunting and fishing...."
The Staff's DEIS does not consider social use of the Harris site as a
" benefit" under NEPA - see Table 6.1 on page 6-2.
Thus(a)thereisno
-l "new material" in the DEIS to support contention number 88, and (b) the DEIS itself provides no basis for Eddleman number 88.
It should not be admitted.
Rejected contention 105 (page 210 Eddleman 5/14/82 filing) asserts that the LPZ is not properly established using 10 CFR 6100.11 criteria.
The DEIS analysis used similar parameters to those contained in the ER.
Mr. Eddleman's argument on pages 5 and 6 of his June 20, 1983 filing are remarkably similar to pages 210 and 211 of his May 14, 1982 filing which was rejected. There is no "new material" in the DEIS to which Mr. Eddleman can point. We do point out that the worst accident case in footnote 1 to 10 CFR 6 100.11 is an accident which assumes a 1% core meltdown. To understand the 10 CFR Part 100 siting requirements, Mr. Eddleman needs to read and understand Technical Information Document 14844 dated March 23, 1982 which contains the procedures to determine the siting distances.
That document is referenced at the end of 10 CFR Part 100 - see 10 CFR page 742, Jan. 1, 1983 Revision. The release rates for fission products and the extent of core damage are provided in Regulatory Guide 1.4--which is not new information. Mr. Eddleman's filing provides no supports for his proposition that greater than design basis accidents need be con-I sidered. Contention 105 should not be admitted.
The Staff DEIS contains no "new information" not previously avail-able in the public domain in regard to accepted contention 75 relating to corbicula. These clams are known and have been known for some years to exist in North Carolina. Also, we are limited here to Mr. Eddleman i
proffering new issues. His contention number 75 on clams has already i
been admitted. His revision of that contention and discussion on pages 8
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and 9 of his June 20, 1983 filing add nothing of substance to the contention but only additional prolixity.
Rejectedcontention8(b)assertedthatthehealtheffectsofTable S-3 were inadequat,ely assessed.
(Board Order Sept. 22, 1982 page 38).
Table S-3 is the Comission's generic assessment of the environmental effects of the uranium fuel cycle. The Supreme Court in Baltimore Gas and Electric Co. v. Natural Resources Defense Council, No.82-524, June 6,1983 (slip op.) upheld the validity of the Comission'.s generic assessment. Mr. Eddleman's allegation on page 12 of his June 20, 1983 filing that Table S-3 is defective is a challenge to the Comission's regulations not permitted by 10 CFR 6 2.758. Rejected contention 8(b) should remain rejected and proffered contention 8(f) should not be admitted. We again point out that no "new information" is presented in the DEIS.
Rejected contention 22 is sought to be revitalized and amended as the DEIS does not consider monetary costs of emergency planning etc. and that "The Staff has' made no showing that the benefit of additional capacity even exists in this case." (a)Thereisnonewinformationin the DEIS not previously available in the public domain in regard to rejected contention 22.
(b) The Comission has precluded litigating need for power in operating license proceedings, 10 CFR 6 51.53(c) and this is the thrust of rejected contention 22c. The new proposed wording of 22(c) is: "The Staff has failed to demonstrate that the benefits of operating Harris outweigh the costs." Response at 16. Need-for-power is now a given pursuant to 10 CFR S 51.33(c). The costs cited by Mr. Eddleman are
monetary costs and NEPA requires balancing environmental costs with bene-fit to society. See Cincinnati Gas and Electric Co. et al., (Wm. H.
Zimmer Nuclear Station) LBP-80-24,12 NRC 231 (1980) where the Licensing Board presents a short and reasoned discussion of this matter. The power from the Harris facility will be used. There is no question but that demand has changed since the filing of the application for the construc-tion permit. This has been before the Comission in regard to Harris.
CLI-79-5, 9 NRC 607 (1979). When the power will be needed remains an open issue only as to an exact date. See Commonwealth Edison Company (Byron Nuclear Power Station, Units 1 and 2), LBP-80-30,12 NRC 683, 691 (1980). The Appeal Board has twice stated "[i]f the electricity to be produced by a proposed project is genuinely needed... then the societal benefits achieved by having that electricity are immeasurable." Vermont Yankee Nuclear Power Corporation (Vermont Yankee Power Station),
ALAB-179, 7 AEC 159, 173 (1974) and Niagara Mohawk Power Corporation (Nine Mile Point Nuclear Power Station, Unit 2), ALAB-284,1 NRC 347, 368 (1975).
Neither the DEIS or Mr. Eddleman provide new information which would support the new proffered contention 22(c) and it should be rejected.
Mr. Eddleman has filed a 10 CFR 9 2.758 petition upon need for power and alternatives to Harris on June 30, 1983. Our response to that petition will further address this matter.
Contention 25 alleged that "An alternative of less environmental impact than spent fuel shipments from Robinson and Brunswick to Harris needs to be considered...."
(page 90 Eddleman 5/14/82 filing). The Licensing Board deferred ruling upon this contention (Board Order Sept. 22, 1982 page 45). Now Mr. Eddleman proposes a new contention 25B
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g which states "The DEIS has improperly failed to consider the radiological impacts and NEPA alternatives to, and costs benefit of shipping spent fuel to Harris."
(Responseat18). To support his new contention he alleges that shipping spent fuel to Harris from Robinson and Brunswick and then from Harris to an offsite storage facility would result in twice the Table S-4 values. Table S-4 is the Comission's generic assessment of the environmental impacts of transportation of fuel and waste to and from one light-water-cooled nuclear power reactor (10 CFR Part 51).
First, the DEIS does not present "new infonnation" not previously avail-able. Second, there is no factual basis presented by Mr. Eddleman to support his allegation that there are lesser adverse environmental effects by doing something other than shipping spent fuel to Harris.
Newly proffered contention 258 should be denied.
j Contention 34 alleged that the ER and FSAR were deficient in not considering acts of sabotage and terrorism against the facility, i
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including " melting of the spent fuel pool" - which is made of reinforced concrete and steel (May 14, 1982 filing page 102). The Licensing Board deferred this contention along with other security plan contentions (Board Order Sept. 22,1982page87). There is nothing in the DEIS which changes this situation. The Applicants have not yet submitted a security plan which conforms to 10 CFR Part 73. When they do, security plan contentions may be proffered. Deferred contention 34 should remain i
deferred for the time being.
On page 22 of his Jun 20, 1983 filing Mr. Eddleman alludes to i
contention 36 and weaves it with contention 34. This is confused and l
jumbled rhetoric which we fail fully to comprehend The Board's ruling l
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9 on page 48 of its Sept. 22, 1982 Order should remain undisturbed.
Insofar as contention 34 concerns terrorism or sabotage it comes within the ambit of security plan contentions which have been deferred. The DEIS provides no new infonnation over and above that provided in the ER and provides no new security plan information.
Deferred contention 57(d) relates to emergency planning and the cost of such planning (page 153, May 14, 1982 filing). As we noted above, we are concerned with environmental costs. Secondly', the DEIS contains no new information on 57(d) (emergency planning) over and above that contained in the ER. Deferredcontention57(d)shouldbedenied.
Page 24 of Mr. Eddleman's June 20, 1983 filing discusses his deferred contention 61, which addresses the health effects of radon. The DEIS adds nothing to the Perkins radon record which has been in the public domain for years. Deferred contention 61 should be denied.
Deferredcontention64(d)(page168ofEddleman'sMay 14, 1982 filing) alleges that the radiological impact of spent fuel transportation is inadequate. The Staff used the impacts assessed in Table S-4, 10 CFR Part 51.
Contention 64(d and e) should be denied as an impermissible attack upon the Commission's regulations.
l Eddleman Contention 80 is unclear and difficult to follow. A number of unrelated allegations are put forth, covering a wide range of subject areas, without identification of any specific deficiencies, and without identifying what is "new."
Contention 80 (page 10 of his June 20, 1983 l
l filing) alleges "deficiencles in mixing and dispersion models use by Applicants and NRC Staff." No specific deficiencies in mixing and dis-persion models are identified in the allegation, and nothing "new" is identified in the DEIS.
No new dose models are identified in the allegation. As the DEIS states (P. 5-51), the range of potential health effects, including cancer mortality and the probable value thereof are from the BEIR-III Report (1980).
In any case, although BEIR-I and BEIR-III differ in detail, there is no basis (and none set forth by Mr. Eddleman) for stating unequivocally that, overall, either Report results in significantly higher total risks.
Mr. Eddleman further states "At page 5-82, the Staff explicitly confirms the weak-ness of its models with respect to rainout (precipi-tation of nuclides from radioactive emissions, stating that "recent developments in the area'of atmospheric dispersion modeling used in CRAC (the computer code developed in the RSS" (Reactor Safety Study,** Rasmussen Report) " indicate that an improved meteorological sampling scheme would reduce the uncertainties arising from this source (including the effect of washout by precipitation,"
uncertainties remain. That is an acknowledgment that the modeling of rainout would improve NRC's models of radioactive material dispersion. Thus, the DEIS simply confirms and extends a bit the basis of Eddleman 80."
(Responseat10)
Among other things, this paragraph uses the Staff statements about CRAC uncertainties (DEIS, p. S-82) to support Eddleman 80. The allega-tions in Eddleman 80 are directed to those models that are used for calculations with respect to 10 CFR Part 20. The methodology of the calculations directed toward 10 CFR Part 20 and the methodology used in CRAC are so different that the statements about CRAC uncertainties that Eddleman quotes are irrelevant to the allegations in Eddleman 80.
Contentions 85 and 86'(pages 192 and 193 of May 14, 1982 filing) allege inadequate consideration of fish kills in the cooling lake. These
matters were addressed in pages 5-13 through 5-20 of the Revised Final Environmental Impact Statement, Construction Permit, March 1974 (RFES).
Discharge temperatures fror.: the cooling tower blowdown were addressed in the ER. The DEIS in this proceeding adds nothing "new" to infomation already available in the public domain. Mr. Eddleman does not demon-strate that the DEIS contains "new infomation" not in the construction permit ER or RFES. Contentions 85 and 86 should be denied.
Contention 95 alleges that the Staff's environmental statement is deficient in not considering the cost of property insurance in the cost-benefit analysis. Again, the environmental costs are to be weighed against the societal benefits. See Zimer, supra. Mr. Eddleman's June 20, 1983 filing sets forth no law or regulation which supports his allegation. Mr. Eddleman's discussion of insurance cost balanced against insurance loss in a macroeconomic setting as being contrary to the Staff's assessment of the probability of accident is a non sequitur, and adds nothing to support his contention. Deferred contention 95 should be denied.
Eddleman contention 110 (May 14, 1982 filingpage220)allegesthat the Staff's environmental statement (not then in existence) is deficient for failing to provide the information requested in contention 108.
Rejectedcontention108(May14,1982page215)allegedthatthe designers and builders, in the broadest sense of the words, have failed to analyze fully the performance of the reactor control systems during transients and accidents. 'The Board rejected contention 108, comenting that they " experienced some difficulty in determining just what conten-l
tions were set forth" (Board Order dated Sept. 22,1982page67). The Staff's DEIS adds no new information upon the testing of safety related equipment and contention 110 should be rejected.
In our filing dated June 22, 1982, we opposed proffered contentions 108 and 110 as being vague-and without basis. The situation has not changed. Mr. Eddleman's June 20, 1983 filing in regarri to contentions 108 and 110 ramble from fish kills, to sabotage, to testing safety equipment. Basically Mr. Eddleman alleges as a defect in the DEIS that the safety systems are not reliable - without specifying which system, identifying the defect, and providing a basis to substantiate the allegation. The generality of his allegation parallels the generality which the Appeal Board found unacceptable in Diablo Canyon cited and quoted supra. Contentions 108 and 110 are not acceptable under 10 CFR 5 2.714 and contention 110 should be rejected.
Deferred contention 126 alleged deficiency in the economic costs of a Class IX accident had not been considered (May 14, 1982 filing page 233). The Licensing Board deferred ruling on this contention until'theFESisissued(BoardOrderdatedSept. 22, 1982 page 70).
Mr. Eddleman seeks to have the contention admitted now on the basis that state government facilities 25-30 miles from Harris could become l
contaminated from fallout. Mr. Eddleman does not show that the DEIS contains new dose computations, or meteorology or accident conditions different from those considered at the construction permit stage or contained in the OL-ER. The Appeal Board and Coninission have repeatedly stated that intervenors must check the public record. Here, in part, the DEIS takes into consideration NUREG-CR2591, " Estimating the Potential
Impacts of a Nuclear Reactor Accident," prepared by the Bureau of Economic Analysis, U.S. Department of Commerce. To support his conten-tion, Mr. Eddleman must show (1) that the DEIS has "new information" --
which he has not done -- and (2) that the 10 CFR H 2.714 contention criteria are met --i.e., he must allege a specific site-reactor defect and provide basis -- which he has not done. To support his allegation he must, in part, show that NUREG/CR2591 has defects which substantially affect the quality of human life. Mr. Eddleman fundamentally is assert-ing defects without examination of the large body of literature available in the public domain.
Mr. Eddleman seems to believe that atmospheric releases (caused by venting of steam) should have been taken into account in our analysis of the liquid pathway following a core melt accident. Mr. Eddleman's assumptions are incorrect, for airborne doses are calculated separately
[Section 5.9.4.4(3)] after consideration of all possible means of escape fromthecontainment(includingventing). The purpose of the liquid pathway study is to determine the upper (maximum) limit of dose due to waterborne radioactive effluents assuming that all of the leachable source term during the accident goes into the hydrosphere. Reducing the waterborne release to account for venting would reduce the liquid pathway dose.
Increasing the atmospheric dose to account for venting would result in counting part of the source term twice. The suggestions in the l
June 20, 1983 filing are scientifically unsound, and demonstrate j
a lack of appreciation of what a liquid pathway study does.
Some of Eddleman's concern in the " BASIS" following his contention l
may be due to the permeability values from the DEIS which were incorrectly l
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presented in units of ft/ day and should have been ft/ year (all calcula-tions were performed using the proper units and conclusions are not affected). The units will be corrected in the FES.
Although the DEIS section on which the contention is based does contain some new information which does not appear in RFES-CP or the applicant's ER-OL, Mr. Eddleman has not met the 10 CFR 12.714 test of demonstrating a defect which would affect the environment and then supporting his allegation with basis in fact. This contention 162 should be denied.
Eddleman Contention 163 alleges defects in not providing specific population projection figures for Apex and Cary and critizes the lack of disclosure of NRC's data base and projection methodology. The Staff will reference the source-data-base for population and will reference the methodology used to project the population to the year 2010 in the FES.
i Undoubtedly they are in OBERS (the systematic regional economic and l
demographic projection structure developed under the leadership of the i
Bureau of Economic Analysis of the U.S. Department of Commerce). OBERS is not "new" but has been in existence for years. We recommend that con-tention 163 be denied.
If the FES contains new significant information when it comes out, Mr. Eddleman will have an opportunity then to proffer a contention.
IV. CONCLUSION The Staff's DEIS contains no new infonnation not previously available in the public domain upon which new contentions could be proffered or which would provide a basis to admit previously rejected or l
deferred contentions. All contentions proffered for admission in Mr. Eddleman's filing of June 20, 1983 should be rejected.
Respectfully submitted.
Charles A. Barth Counsel for NRC Staff Dated at Bethesda, Maryland this 8th day of July, 1983 l
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O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Hatter of I
CAROLINA POWER AND LIGHT COMPANY AND Docket Nos. 50-400 OL NORTH CAROLINA EASTERN MUNICIPAL
)
50-401 OL POWER AGENCY (Shearon Harris Nuclear ' Power Plant.
'l Units 1and2) ll NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance in the captioned matter.
In accordance with 6 2.713(b), 10 CFR Part 2, the following information is provided:
Richard G. Bachmann Name U.S. Nuclear Regulatory Commission Address Office of the Executive Legal Director Washington, DC 20555 Area Code 301 - 492-8648 Telephone Number Supreme Court of the Sta,te of California Admission NRC Staff Name of Party i
U.S. Nuclear Regulatory Commission Washington, DC 20555 Richard G. Bachmann Counsel for NRC Staff 1
Dated at Bethesda, Maryland N
l this 8th day of July,1983.
[
UNITED STATES OF AMERICA g:
NUCLEAR REGULATORY COMMISSION i
i' BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
))
CAROLINA POWER AND LIGHT COMPANY AND l
Docket Nos. 50-400 OL NORTH CAROLINA EASTERN MUNICIPAL i
50-401 OL 9
POWER AGENCY
!l l
(Shearon Harris Nuclear Power Plant.
)
Units 1and2)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO WELLS EDDLEMAN'S RESPONSE TO THE STAFF'S DRAFT ENVIRONMENTAL IMPACT STATEMENT" AND " NOTICE OF APPEARANCE" for Richard G. Bachmann 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 Regulatory Commission's internal mail system, this 8th day of July,1983:
James L. Kelley, Chaiman*
Mr. Travis Payne, Esq.
Administrative Judge 723 W. Johnson St.
Atomic Safety and Licensing Board P.O. Box 12643 U.S. Nuclear Regulatory Comission Raleigh,NC 27605 Washington, DC 20555 Daniel F. Read, President Mr. Glenn O. Bright
- CHANGE Administrative Judge P.O. Box 524 Atomic Safety and Licensing Board Chapel Hill, NC 27514 U.S. Nuclear Regulatory Comission j
Washington, DC 20555 Daniel F. Read 100-B Stinson St.
Dr. James H. Carpenter
- Chapel Hill, NC 27514 Administrative Judge Atomic Safety and Licensing Board Patricia T. Newman, Co-Coordinator U.S. Nuclear Regulatory Comission
. Slater E. Newman, Co-Coordinator Washington, DC 20555 Citizens Against Nuclear Power 2309 Weymouth Ct.
George Jackson, Secretary Raleigh, NC 27612 l
Environmental Law Project l
School of Law, 064-A Richard D. Wilson, M.D.
University of North Carolina 729 Hunter St.
Chapel Hill, NC 27514 Apex, NC 27502 l
i I
s
.-~m-A mgm ew m Wells Eddleman
. Deborah Greenblatt, Esq.
718-A Iredell Street 1634 Crest Road Durham, NC 27701 Raleigh, NC 27606 John Runkle, Executive Coordinator Richard E. Jones. Esq.
Conservation Counsel of North Carolina Associate General Counsel 307 Granville Rd.
Carolina Power & Light Company Chapel Hill, NC 27514 P.O. Box 1551 Raleigh, NC 27602 George F. Trowbridge, Esq.
Thomas A. Baxter, Esq.
Atomic Safety and Licensing Board John H. O'Neill, Jr., Esq.
Panel
- Shaw, Pittman, Potts & Trowbridge U.S. Nuclear Regulatory Commission 1800 M Street, N.W.
Washington, DC 20555 Washington, DC 20036 Docketing and Service Section*
Dr. Phyllis Lotchin Office of the Secretary U.S. Nuclear Regulatory Commission 108 Bridle Run Chapel Hill, NC 27514 Washington, DC 20555 Atomic Safety and Licensing Appeal Ruthanne G. Miller, Esq.
Atomic Safety and Licensing Board Board Panel
- U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washir.gton, DC 20555 Washington, DC 20555*
Bradley W. Jones, Esq.
Karen E. Long, Esq.
Staff Attorney Regional Counsel Public Staff - NCUC USNRC, Region II P.O. Box 991 101 Marietta St., NW Raleigh, NC 27602 Suite 2900 Atlanta, GA 30303 4
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Richard G. Bachmann Counsel for NRC Staff
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