ML20027B581
| ML20027B581 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 09/15/1982 |
| From: | Dignan T Maine Yankee, ROPES & GRAY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OLA, NUDOCS 8209210313 | |
| Download: ML20027B581 (25) | |
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DOCKETED USNRC T2 SEP 20 A!1:15 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
)
MAINE YANKEE ATOMIC POWER COMPANY
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Docket No. 50-309-OLA
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(Spent Fuel Compaction)
(Maine Yankee Atomic Power Station))
)
APPLICANT'S REPLY TO
" ADDITIONAL CONTENTIONS OF THE STATE OF MAINE" Introduction In a memorandum and order issued on April 12, 1982, this Board made rulings as to each of the then pending contentions of the two intervenors herein.
Maine Yankee Atomic Power Co. (Maine Yankee Atomic Power Station), LBP-82 __, 15 NRC (1982) (hereafter "ASLB April 12 Order" and cited to the slip opinion).
With respect to certain of those contentions, the Board ruled that they were premature at the time because the 820 9 2103 (3 c_;
g)$N
Staff's Environmental Impact Appraisal ("EIA") and Safety Evaluation Report ("SER") had yet to be published.
- See, e.g.,
April 12 order at 7, 9, 17.
Subsequently, on July 20, 1982, this Board issued a memorandum and order concerning the schedule for further proceedings in this matter.
(Hereafter cited "Sched. Memo".)
Therein the Board memorialized what had been implicit in the ASLB April 12 Order, i.e.,
that the intervenors would be given an opportunity to file further proposed contentions "on EIA and SER issues."
Sched. Memo at 2.
The Board did not issue any order which granted the intervenors leave to file any further contentions they wanted on any subject or to refile previous contentions already rejected for reasons other than prematurity due to the lack of an EIA or SER.
In adopting the course it did, this Board presaged the position and views recently expressed by the Appeal Board in Duke Power Co. (Catawba Nuclear Station, Units 1 and 2), ALAB-687, 16 NRC (August 19, 1982)
(hereafter "ALAB-687" and cited to the slip opinion).
ALAB-687 involved the referral by a Licensing Board to the Appeal Board of three rulings the Licensing Board had made in acting upon various petitions to intervene.
in an operating license proceeding.
The three rulings, see ALAB-687 at 2-3, in substance conditionally admitted into the proceeding certain contentions advanced by intervenors, notwithstanding the Licensing Board's determination that the specificity requirements of 10 CFR $ 2.714(b) had not been satisfied.
Of primary relevance to the matters here at bar, the Licensing Board had conditionally admitted ten of these contentions on the ground that the inability of the intervenors to meet the specificity requirements resulted from the unavailability of staff or applicant documents (e.g.,
SER and EIA), and had ruled that the late filing criteria of 10 CFR $ 2.714(a) would not be applied to contentions based on these documents if promptly filed after the documents issued.
In ALAB-687, the Appeal Board held that the Licensing Board in that case had erred in actually admitting any contention, conditionally or otherwise, that did not, as of the time it was admitted, meet the specificity requirement of 10 CFR $ 2.714(b).
i "Given the terms and history of Section 2.714(a), we are compelled to the conclusion that a licensing board is not authorized to admit conditionally, for any reason, a contention that falls short of meeting the specificity requirements."
l l e
ALAB-687 at 11 (emphasis in original).
In short, the Appeal Board approved the position taken by this Board to the effect that contentions either "make the grade" when filed or they must be excluded.
In addition, the Appeal Board affirmed the ruling of the Licensing Board made in that case, and implicit in this Board's April 12 Order, to the effect that the late filing criteria in 10 CFR S 2.714(a) should not be utilized to bar the admission of a contention that truly was based, and could only have been based, upon a late filed Staff or Applicant document.
ALAB-687 at 16-17.
- However, when making this holding, the Appeal Board also made crystal clear, that the issuance of an EIA or SER or any similar document was not to be viewed as giving license to an intervenor to file any new contentions that could have been asserted prior to the issuance of the document itself.
The Appeal Board referred to the concept that:
"an intervention petitioner has an ironclad obligation to examine the publicly available documentary material pertaining to the facility in question with sufficient care to enable it to uncover any information that could serve as the foundation for a specific contention."
ALAB-687 at 13. l l
9
In addition, the Appeal Board described the type of contention it had in mind as being admissible absent compliance with the late filing criteria thus:
"a contention cannot be rejected as untimely if it (1) is wholly dependent upon the content of a particular document; (2) could not therefore be advanced with any degree of specificity (if at all) in advance of the public availability of that document and (3) is tendered with the requisite degree of promptness once the document comes into existence and is accessible for public examination".
ALAB-687 at 16 (emphases added)..
In short, the prior Order of this Board in this proceeding, coupled with the reasoning of the Appeal Board in ALAB-687, dictates that any contention now made by the State of Maine (" State") which was susceptible of articulation prior to the issuance of the EIA and SER, see ALAB-687 at 17 & 18 n.17, and any contention previously made and rejected on its merits, are not properly made at this time and should be rejected again in light of the fact that the State has made no effort in its latest filing to comply with the late filing criteria.
As will be seen below, a number of the State's " Additional Contentions" suffer this infirmity..
We deal with the Amended Contentions seriatim by the numbers given them by the State.
Additional Contention No. 6 By Additional Contention No. 6 the State seeks to inject the issue of whether a full dress Environmental Impact Statement (EIS) should be required in this proceeding.
Clearly, in light of the fact that Maine's initial contention in this regard was previously rejected as premature for lack'of an extant EIA, ASLB April 12 Order at 17, it is timely filed at this time.
However, for the reasons set forth below, the Applicant says that the contention still should not be admitted because it lacks basis as a close analysis of the State's latest filing reveals.
To begin with, the State says it
" strenuously disagrees with the NRC staff conclusion that Maine Yankee's proposal
'will not significantly affect the quality of the human environment' and thus renews its contention that an EIS must be prepared."
Maine Add. Cont. at 3.
The State's unvarnished disagreement (strenuous or otherwise) is not enough to supply the needed basis.
Next, the State refers us to the State's Amended Contentions filed on October 5, 1981, summarizes the _.
four " reasons" given there for the State's position, and then " incorporates by reference the Basis statement contained in its Amended Contentions", and goes on to supplement that statement.
Maine Add. Cont. at 3-4.
Prescinding from the impropriety of incorporating documents by reference as a basis for contentions, see TVA (Browns Ferry Nuclear Plant, Units 1 and 2), LBP-76-10, 3 NRC 200, 216 (1976), thus making the drafting of any response more burdensonie, the fact is, as seen below, the Amended Contentions were bereft of basis and the new supplement helps not at all.
What the State now refers to as its first " reason" why an EIS should be required, was stated in the Amended Contentions filed October 5, 1981 (hereafter referred to as the 1981 Amended Contentions and cited "AC-1981") as contention la:
"a.
The proposed reracking and pin compaction storage methods significantly increase both the probability of occurrence of a release of radiation or radioactive materials into the environment and the environmental consequences of such a release in the event of a total or partial loss of coolant at the spent fuel pool."
AC 1981 at 1.
The " basis" set out in the 1981 Amended Contentions for this statement recites that two categories of acaidents could initiate a total or._
I partial loss of coolant at the spent fuel pool at Maine Yankee Atomic Power Station (MYAPS).
The first category is a group of Class 9 accidents. AC 1981 at 3.
Class 9 accidents need not be considered in this spent fuel pool proceeding at least absent a Staff decision that unique circumstances exist.
Public Service Co. of Oklahoma (Black Fox Station, Units 1 and 2), CLI-80-8, 11 NRC 433 (1980); Public Service Electric and Gas Co.
(Salem Nuclear Generating Station, Unit 1), ALAB-588 11 NRC 533, 537 (1980).
The second category of accidents described in the 1981 Amended Contentior, in connection with loss of coolant in the spent fuel pool:
" consists of accidents that directly impact on the spent fuel pool resulting in a breach of the spent fuel pool and a rapid release of pool coolant.
These accidents include sabotage, an airplane accident, a missile, an earthquake, an accident involving the fuel transfer tube, and the drop of a heavy object such as a shipping cask."
AC 1981 at 3.
All of these accident scenarios involving the integrity of the design of the spent fuel pool itself were dealt with at the operating license stage and cannot be relitigated in a license amendment proceeding.
See Northern States Power Co. (Prairie Island Nuclear Generating Plant, Units 1 and 2), ALAB-455, 7 NRC 41, 46 n.4 (1978).
Accord: Portland General Electric Co. (Trojan Nuclear Plant), ALAB-531, 9 NRC 263, 266 n.6 (1979); Public Service Electric and Gas Co. (Salem Nuclear Generating Station, Unit 1), ALAB-650, 14 NRC 43, 60 n.24 (1981).
Indeed, one Appeal Board has squarely held that no EIS is required predicated on harm to the environment from a gross loss of water from the spent fuel pool because such an event is only a remote and speculative possibility.
ALAB-650, supra, at 62-64 nn. 29, 31.
Finally, we note one assertion made in connection with this argument in the 1981 Amended Contentions that is erroneous on its face.
Maine says:
"The probability of the occurrence of such risks is increased by both the proposed reracking and pin compaction because the denser configuration of spent fuel assemblies proposed by the applicant will decrease natural convection cooling in the event of a loss of coolant accident, causing both old and new fuel rods to heat up to the point of sustained oxidation and an exothermic reaction."
AC 1981 at 4.
This is axiomatically false.
All of the accidents in either category described by the State are triggered by forces outside the spent fuel pool.
Filling the spent fuel pool with more spent fuel does not increse the probabilities of occurence of such accidents one iota.
In its " Additional Conte.itions" the State supplements the above described arguments with the following statement:
"The first reason why an EIS is required is because, in the event of either a partial or total loss of coolant accident involving the spent fuel pool, the proposed methods of reracking and pin compaction will increase both the probability of a release of radiation and the consequences resulting from such a release.
The increased risks of such a release and its consequences must be analyzed in an EIS in accordance with NEPA and 10 CFR Part 51."
Maine Add. Cont. at 4.
This adds nothing.
As pointed out above the statement as to increased probability is false.
It is true that more spent fuel in the pool means that the consequences of a given event, if it occurred, could be greater to some degree.
But nothing has occurred that enables the State to avoid the barrier to this reasoning created by the decisions cited above as to the lack of necessity to consider events which allegedly could fail the pool itself.
What the State now refers to as its second " reason" why an EIS should be required was stated in the 1981 Amended Contentions as contention lb:
"b.
Pin compaction is a new technology that has never been licensed by the NRC; its implementation at Maine Yankee involves unknown safety and environmental.
risks; and, if approved, it would establish precedent for future applications to the NRC by other utilities in need of expanded spent fuel storage."
AC 1981 at 4.
The " basis" set forth in the 1981 Amended Contentions in this statement is nothing more than an expansion of the statement itself which, stripped of rhetoric, means that an EIS is required anytime anything new is done.
This is not so.
An EIS is required when there is contemplated a major federal action significantly affecting the human environment.
Whether the action involves new technology or not is irrelevant.2 In its " Additional Contentions" the State
" supplements" its position.by. essentially repeating the argument.
Maine Add. Cont. at 5-6.
Nothing of substance is added.
What the State now refers to as its third " reason" why an EIS should be required was stated in the 1981 Amended Contentions as contention Ic.
1 It may also be observed that pin compaction is not a "new technology that has never been licensed by the NRC;" pin compaction is nothing more than removing and inserting spent fuel pins from and into fuel assemblies, operations that have often been performed at various other reactors. l l
I
"c.
The use of the cask laydown area will prevent or significantly impede the removal of spent fuel from the existing spent fuel pool during the period of licensed operations and also upon cessation of commercial operations of the plant."
AC 1981 at 6.
The " basis" stated for this statement is:
"By use of the cask laydown area for spent fuel storage, Maine Yankee will lose its ability to remove spent fuel from the pool.
The cask laydown area is necessary to permit placement of a shipping cask in the pool to remove spent fuel for such purposes as removal of defective spent fuel rods and removal of spent fuel for alternative interim storage and for long-term storage or disposal.
Maine Yankee proposes to use the cask laydown area for storage of spent fuel when there is no other space in the pool to store fuel or to place a shipping cask.
However, an accident involving the reactor or the fuel transfer tube may prevent replacing the fuel in the reactor as anticipated by the licensee, Under these circumstances the use of the cask laydown area for spent fuel storage will result in an irreversible and irretrievable commitment of resources that requires the preparation of an Environmental Impact Statement in accordance with NEPA and 10 CFR Part 51."
AC 1981 at 6 (emphasis supplied).
i i
The key to this argument is the portion set out l
l above with emphasis.
The concept is that when the cask i
laydown area has been filled up with fuel rejected from l
l the core for some purpose, there will be an accident in !
the reactor which will preclude reloading that fuel back into the vessel.
We are not let in on the secret of how an accident will occur in the empty-of-fuel reactor vessel which will forever preclude reloading the fuel back into the vessel.
In the supplement contained in the Additional Contentions we are told what accidents the State has in mind:
" Specific means by which fuel could not be returned to the reactor vessel include jamming of the fuel transfer tube controls or gate; a fire in the containment building; or a reactor leak
- from, e.g.,
thermal shock."
Maine Add. Cont. at 6.
The first two' events, jamming of the " fuel transfer tube" or a fire in the containment, might delay the retransfer of fuel back to the vessel, they would not, however, forever preclude it.
We are at a loss to figure out how " thermal shock" can occur and crack an empty reactor vessel after the l
l reactor has been shut down and all of its fuel removed, and the State offers no explanation as to how this piece of magic will transpire.
l What the State now refers to as its fourth " reason" 1
why an EIS should be required was stated in the 1981 Amended Contentions as contention Id: l l
"d.
As a result of proposed license amendments, there will be significantly increased amounts of spent fuel stored at Maine Yankee on a long-term or permanent basis in the event that there is no available means of safely storing or disposing of the increased spent fuel off-site at the expiration of Maine Yankee's operating license in 2008."
AC 1981 at 6.
The " basis" for the statement is stated to be:
"No environmental impact statement has been prepared for Maine Yankee evaluating l
how the spent fuel generated by the plant's operations will be stored or disposed of following the expiration of the operating license in 2008.
The Commission is presently conducting a generic proceeding (the so-called ' Waste Confidence' proceedings) to determine its degree of confidence that there is reasonable assurance that there will be safe off-site disposal or storage methods available to Maine Yankee and other nuclear power plants when their respective operating licenses expire.
See 44 F.R.
61372 (October 25, 1979).
Unless such proceedings are completed prior to the issuance of the proposed license amendments with a determination of reasonable assurance of the availability of off-site storage or disposal by 2008 for Maine Yankee, a site-specific environmental impact statement must be prepared for the proposed license amendments addressing how the increased spent fuel to be stored on-site at Maine Yankee as a result of commercial operations will be stored or disposed of after the operating license expires."
AC 1981 at 6-7.
l l
l Safety and environmental issues arising from the hypothesis that spent fuel will remain on a nuclear power plant site after expiration of the operating license are precluded from consideration in individual license amendment proceedings by virtue of the existence of the rulemaking.
Public Service Electric and Gas Co. (Salem Nuclear Generating Station, Unit 1),
ALAB-650, 14 NRC 43, 68-69 (1981).
Id.,
LBP-80-10, 11 NRC 337, 338 (1980).
See also Virginia Electric and Power Company (North Anna Nuclear Power Station, Units 1 & 2), ALAB-584, 11 NRC 451, 464-65 (1980).
The State, in its Additional Contentions, supplements its presentation with an argument to the effect that the recent decision of the United States Court of Appeals for the District of Columbia Circuit in Potomac Alliance v. NRC, F.2d CCH Nuclear Reg. Rep.
20,231 (D.C. Cir. No. 80-1862, July 20, 1982), further bolsters its argument.
It does not.
In Potomac Alliance the Court told NRC to "get with it" on the Waste Confidence Rulemaking.
NRC has not changed the rules as to specific contentions in spent fuel pool cases one bit since Potomac Alliance.
This Board is bound by NRC and Appeal Board precedents, and Potomac Alliance and any interpretation thereof is irrelevant.,
,n
Additional Contention No. 7 The State's Additional Contention No. 7 is, as the state admits, Maine Add. Cont. at 10, the same contention as Contention No. 2 in the 1981 Amended Contentions.
This contention was found by this Board to be inadmissible in its prior order.
ASLB April 12 Order at 17.
The State requested reconsideraticn of this ruling, and reconsideration was denied by this Board on July 21, 1982.
Maine Yankee Atomic Power Co.
(Maine Yankee Atomic Power Station), LBP_82-16 NRC (July 21, 1982), Slip Op. at 2-3.
This is not a contention which was wholly dependent upon issuance of the SER; it not only could have been -- but it was --
advanced prior to the issuance of the SER.
The contention continues to suffer from the same infirmities that infected it earlier, and no effort has been made to justify it as a late filed contention.
It should be excluded.
l Additional Contention No. 8 l
The state says its Additional Contention No. 8 "is substantively the same as Amended Contention 3 filed by the State on October 5, 1981."
Maine Add. Cont. at 13.
l This is fairly gross understatement; the proposed l
contention is identical to old Amended Contention
> l l
No. 3.
Compare id. with AC 1981 at 7.
Amended Contention No. 3 was excluded by this Board in April of 1981.
ASLB April 12 Order at 18.
It was not and is not dependent on SER issuance.
No ef." ort is made to a
satisfy the late filing criteria.2 It should be excluded.
Additional Contention No. 9 By Additional Contention No. 9 the State seeks to delay the proceedings until completion of the " Waste Confidence" Rulemaking or require full exploration in this proceeding of the safety of spent fuel storage at MYAPS beyond 2008.
As the State admits, Maine Add.
Cont. at 14, this contention is the same as 1981 Amended Contention No.
4.
This contention was rejected by the Boacd in April of 1981, ASLB April 12 Order at 18; its formulation was and is not dependent upon availability of the EIA and SER, and no effo.:t has been made to satisfy the late filing criteria.
The contention should be excluded.
2 The State has, in its latest filing tried to supply a mechanism for the scenario it postulates.
The mechanisms are the non-nuclear accidents described with respect to Additional Contention No. 6 earlier and provide no better basis here than they did there.
See supra 8-10.
Additional Contention No. 10 By Additional Contention No. 10 the State seeks to inject into this case the issue of alternate technologies for handling the fuel storage problem.
In particular the State wishes to have the proceeding explore the following " specific alternatives:"
"a.
the use of the following alternate on-site, passive storage methods: dry storage in casks, vaults, caissons and concrete cannisters, either alone or within concrete buildings; "b.
delayed implementation of pin consolidation."
Maine Add. Cont. at 10.
The contention should be excluded.
As noted in the EIA, EIA at 1, the environmental effects arising from fuel pool capacity expansion have been found to be negligible 76 out of 76 times.
NRC has no obligation to explore alternatives unless they are environmentally superior.
Virginia Electric and Power Co. (North Anna l
Nuclear Power Station, Units 1 & 2), ALAB-584, 11 NRC l
451 (1980); Consumers Power Co. (Midland Plant, Units 1 1
j
& 2), ALAB-458, 7 NRC 155, 162 (1978).
If the l
l environmental effect of the proposed action is negligible, it is difficult to see how any case can be made that an alternative is essentially superior; and l
NRC has no obligation to try.
Duke Power Co.
(Amendment to Materials License SNM-1773), ALAB-651, 14 NRC 307, 321-22 (1981); Portland General Electric Co.
(Troj an Nuclear Plant), ALAB-531, 9 NRC 263, 266 (1979).
In addition, it is to be noted that the statement of basis does nothing more than repeat and repeat the view that alternatives must be explored.
We are given no specific reasons as to why further inquiry is merited as to any or all of them in this case.
Thus, there is no valid contention.
Vermont Yankee Nuclear Power Corporation v. NRDC, 435 U.S.
519, 551-54 (1978); Seacoast Anti-Pollution League v. NRC, 598 F.2d 1221 (1st Cir. 1979).
Additional Contention No. 11 Added Contention No. 11 is identical to 1981 Amended Contention No.
6.
It was excluded by this Board in April of 1981 on the grounds that there was no regulatory requirement that the Licensee show an immediate or any need for an amendment.
ASLB April 12 Order at 19.
The contention's formulation was and is not dependent upon issuance of the EIA and SER; no l
effort has been made to justify late filing.
It should be excluded. l l
Additional Contention No. 12 This contention is, by the State's own admission, similar to old Amended Contention No. 11, which has once already been rejected.
ASLB April 12 Order at 11.
Inter alia, this Board ruled "that there is no requirement that such procedures be submitted now."
Id. at 6.
We still are uninformed as to what specific regulation supposedly requires the provision of the information listed on pages 25-26 of the State's submission.
Vague assertions of alleged regulatory and statutory requirements hardly put the licensee on notice as to what it must defend against as is required by 10 CFR $ 2.714.
Philadelphia Electric Co.
(Peach Bottom Atomic Power Station, Units 2 and 3), ALAB-216, 8 AEC 13, 20 (1974).
This contention should again be rejected.
Additional Contention No. 13 By Additional Contention No. 13 the State seeks to inject into this proceeding so-called unresolved generic safety issues.
This is what the State sought to do by old Amended Contention No. 16.
This contention was rejected in April of 1981.
ASLB April 12 Order at 22.
The State moved for reconsideration and the contention was again rejected.
ASLB July 1982 -
Order at 3-4.
The contention was-and is susceptible of formulation in the absence of the SER and EIA, nor has any basis been suggested that derives solely from either.
No attempt has been made to satisfy the late filing criteria.
Nothing said in the new filing cures the defect found in the old, namely, the failure to demonstrate the nexus between specific unresolved generic safety issues and spent fuel pool expansion (not original construction).
The contention should be rejected yet a third time.
Additional Contention No. 14 Additional Contention No. 14 is:
"The licensee has not demonstrated that it has established and can comply with a detailed quality assurance program which complies with 10 CFR 50, Appendix B."
The statement of basis for this contention begins:
"Although the State concedes tht Maine Yankee at least has a written quality assurance (QA) program, included as Appendix B in its FSAR, it has recently become apparent that the licensee is either unable or unwilling to conform its actions to a'QA program which merits NRC regulations (see 10 CFR Part 50, Appendix B)."
Maine Add. Cont. at 34.
The State then goes on to l
describe the existence of "at least 22" reportable occurrences at MYAPS as well as taken and contemplated l.
m m
enforcement actions because of alleged QA deficiencies.
Maine Add. Cont. at 14-15.
To begin with the formulation of this contention is in no way dependent upon the issuance of the SER or EIA.
Thus, it is plainly and simply a late filed contention and no attempt has been made to satisfy the late filing criteria.
The contention should be rejected on that ground alone.
In addition to the foregoing bar, a license amendment proceeding is not the proper forum to consider the issue of weaknesses (real or imagined) of an operating licensee's quality assurance program or its alleged failure to comply therewith.
If the State wants to raise that question and litigate it, the proper method is to file a request for a show cause order under 10 CFR S 2.206.
See Consumers Power Co.
(Midland Plant, Units 1 & 2), ALAB-674, 15 NRC CCH Nuclear Reg. Rep. 1 30,678 (May 5, 1982).
Additional Contention No. 15 Additional Contention No. 15 is:
"The licensee has not provided adequate assurance that the proposed modifications to the spent fuel pool assure adequate safety under normal and postulated accident conditions.
Therefore the licensee has not provided adequate p
assurance that it can comply with 10 CFR Part 50, Appendix A, General Design Criteria 61."
This contention was susceptible of formulation before the SER or EIA issued.
Indeed the first sentence of the contention is identical to the State's 1981 Amended Contention No. 13 which has already been rejected by this Board as vague.
ASLB April 12 Order at 21.
No attempt has been made to satisfy the late filed criteria and therefore the contention should be rejected on that ground alone.
Prescinding from the foregoing, the contention remains impermissibly vague.
We are given no basis for the State's assertion that the spent fuel pool design does not comply with the provisions of GDC 61.
More importantly, GDC 61 governs the fuel pool decign, not rack design, and we are wholly unadvised as to what aspect of fuel pool reracking transgresses GDC 61.
This is not surprising because GDC 61 does not come into play in a fuel pool capacity expansion case that, does not involve physical expansion of the pool. --
1 l
CONCLUSION 1
All of the State of Maine's Additional Contentions i
should be excluded.
1 Respectfully submitted,
' ' ~
i Thomas G.
Dignan, Jr.
R. K.
Gad III Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 Counsel for Applicant 1
i Dated:
September 15, 1982 5
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Certificate of Service I,
Robert K. Gad III, hereby certify that on September 15, 1982, I made service of the within
" Applicant's Reply to ' Additional Contentions of the State of Maine'," by mailing a copy thereof, postage prepaid, to:
Robert M.
Lazo, Esquire Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. Cadet H. Hand, Jr.
Director, Bodega Marine Laboratory University of California P.
O.
Box 247 Bodega Bay, California 94923 Administrative Judge Peter A. Morris Atomic Safety and Licensing Board Panel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Jay M.
Gutierrez, Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 David Santee Miller, Esquire Perkins Road Boothbay Harbor, Maine 04538 Rufus E.
Brown, Esquire Deputy Attorney General Department of the Attorney General State House - Station #6 Augusta, Maine 04333 Mr. Raymond G.
Shadis P.
O.
Box 76 North Edgecomb, Maine 04566
- V.l L
Robert K.fCad III
..