ML20028C895
| ML20028C895 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Hope Creek, 05000000, Crane |
| Issue date: | 01/11/1983 |
| From: | Silberg J METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | NRC COMMISSION (OCM) |
| References | |
| ALAB-701, NUDOCS 8301140275 | |
| Download: ML20028C895 (15) | |
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January 11, gid8%TED U9E UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '83 JM 13 M:3j BEFORE THE COMMISSION In the Matters of
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PHILADELPHIA ELECTRIC COMPANY ET AL.
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Docket Nos. 50-277 (Peach Bottom Atomic Power Station,
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50-278 Units 2 and 3)
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METROPOLITAN EDISON COMPANY E_T_ AL.
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Docket No.
50-320 (Three Mile Island Nuclear Station,
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Unit 2)
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i PUBLIC SERVICE ELECTRIC AND GAS CO.
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Docket Nos. 50-354 (Hope Creek Generating Station,
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50-355 Units 1 and 2)
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THREE MILE ISLAND UNIT 2 LICENSEES' ANSWER TO INTERVENORS' PETITION FOR REVIEW INTRODUCTION On December 27, 1982, intervenors in the Peach Bottom Units 2 and 3 and Three Mile Island Unit 2 proceedings (Citizens for a Safe Environment and Environmental Coalition on Nuclear Power) ("Intervenors"), by their represen-tative Dr. Judith H. Johnsrud, filed a " Petition for Review of the Consolidated Radon Proceedings" (" Petition"), in which they apparently seek review by the Commissiotfb'f ALAB-701, 16 NRC (November 19,1982).N ALAB-701 is the last in a series of decisions by the Atomic Safety and Licensing Appeal Boards in what has come to be known as the " consolidated radon proceeding".
See, ALAB-480, if The Petition implies, but does not explicitly state, which Appeal Board action Petitioners seek to have reviewed.
Since no review was sought or granted of any of the previous Appeal Boards' decisions, and since the Commission did not review them sua sponte within the time set in 10 CFR 52.786(a), all decisions by the Appeal Boards on the radon issue except for ALAB-701 are now final agency action.
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. 7 NRC 796 (1978); ALAB-509, 8 NRC 679 (1978); ALAB-540, 9 NRC 428 (1979);
ALAB-562, 10 NRC 437 (1979); ALAB-640, 13 NRC 487 (1981); ALAB-654, 14 NRC 632 (1981); and ALAB-701, 16 NRC
_,(November-19, 1982). The Three Mile Island Unit 2 licensees oppose the Intervenors' Petition and, for the reasons dis-cussed below, submit that the Petition should be denied.
HISTORY OF PROCEEDING The extended history of the consolidated radon proceeding has been set forth at length in the Appeal Boards' decisions, particularly ALAB-640 and ALAB-701.
Briefly summarized, this proceeding deals with one of the entries in Table S-3 of 10 CFR Part 51, which contains among other things numerical data on the amounts and the environmental effects of various radioisotopes produced during the uranium fuel cycle for a reference reactor. These release and envi-ronmental effect values are to be factored into the cost-benefit analysis per-formed by the Commission in licensing commercial power reactors.
One of the effluents resulting from the milling and mining of uranium to produce reactor fuel is radon-222, a radioactive gas. As originally issued in 1974, Table S-3 contained a value for radon-222 emissions.
In November 1975, the New England Coalition on Nuclear Pollution ("NECNP") filed a rulemaking petition seeking that Table S-3 be amended. One of NECNP's claims was that Table S-3fsWriously understated the amounts of radon to be emitted over long periods of time from mill tailings piles.2/ 41 Fed. Reg. 448 (January 16, 1976).
2/ Thus, it was the action of NECNP in 1975 that prompted the Commission to revisit the radon-222 issue and not, as alleged in t'he Petition, Dr. Chauncey Kepford's 1977 testimony in the Three Mile Island proceeding.
Intervenors have previously acknowledged NECNP's initiating role.
See, "Intervenors' Response to Staff Motion of April 27, 1978 to Consolidate Proceedings", dated May 6, l
1978, at 5, and "Intervenors' Appeal From an Appeal Board Order on the Grounds i
of Fraud and Other Grounds", dated June 12, 1978, at 4-5, 36-37.
- Compare, Petitlop at 1, 2, 7.
This fact would have only historical interest but for Intervenors' attempt to establish Dr. Kepford's expertise by erroneously claiming that he caused the Commission to delete the radon entry from Table S-3.
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The Commission issued a rule in April, 1978 in response to NECNP's peti-tion. 'The Commission determined that "the current. Table S-3 value for. Radon-222 is incorrect" and deleted the value from the table. 43' Fed. Reg. 15613, 15615 4
(April-14,.1978). The Commission adopted a~ case by case approach whereby the radon issue would be decided by adjudication in each licensing proceeding. Id.3/
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Following the Commission action, the Appeal 1 Boards decided to handle the radon issue in the seventeen proceedings before them by adopting as " lead case" the evidentiary record and Licensing Board decision on radon in the Perkins pro-ceeding (Duke Power Co. (Perkins Nuclear Station, Units 1, 2 and 3), Docket Nos.
STN-50-488, 50-489 and 50-490). Parties to the seventeen proceedings were allowed to'" supplement, contradict, or object to" the Perkins record and decision.
ALAB-480, 7 NRC 796, 804-806 (1978).
Intervenors in five of'these proceedings objected to the Perkins record and decision.
The Appeal Boards then decided to consolidate for hearing purposes the five proceedings in which objections to Perkins.had been filedb! and hold the remafning proceedings in abeyance. ALAB-540, 9 NRC 428, 433 (1979). After summary disposition of some objections, the Appeal Boards set for evidentiary hearing several matters including the radon emissions from mill tailing piles, underground mines, and open pit mines. ALAB-562, 10 NRC 437, 441-43.(1979).
wN 3/ The Commission announced that it intended to determine, when the Generic Environmental Impact Statement ("GEIS") on uranium milling was released, whether to initiate a rulemaking proceeding to include a revised value for radon-222 in Table S-3.
43 Fed. Reg. at 15615. The GEIS, NUREG-0706, was issued in September 1980. The GEIS, together with the information developed in the instant proceeding, should provide the Commission with ample basis for filling the radon-222 entry on Table S-3 and thus avoiding further case-by-case adjudication of the issue.
4/ In addition to the three proceedings captioned here, the other two proceedings that were consolidated were Northern States Power Co. (Tyrone Energy Park, Unit 1),
Docket No. STN-50-484, and Rochester Gas and Electric Corporation (Sterling Power Project Nuclear Unit No. 1), Docket No. STN-485. Subsequently, however, the Tyrone and Sterling projects were cancelled and for that reason were dismissed from the consolidated proceeding.
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y A'three-day evidentiary hearing was. held on'these marters in February,.
1980. Based on the hearing record,5/ the Appeal Boards' issued a comprehensive' decision in which they determined the annual radon releases attributable to mining'and milling. ALAB-640, 13 NRC 487, 539-42.(1981).
Consideration of the health consequences of these releases was deferred..Id at 543-45.
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sought Commission review of ALAB-640 and the Commission declined to review it'. !-
In ALAB-654', 14 NRC 632 (1981), the Appeal Boards established ground rules for dealing with the health effects aspects of the radon issue. Intervenors I
were given the burden of going forward..As a precondition to an evidentiary-hearing on the health effects of radon releases, the.Intervenors were required to present the documented opinion of one or more qualified authorities that the fuel cycle-related radon emissions will have a significant adverse effect on human health. 14 NRC at 635. Such expert opinion would have to-take into account both the amount of natural radon emissions and the fluctuations in natural radon releases from one location to another. No party sought Constission review of ALAB-654 and the Commission decided that.there was no need to review it.
On December 22, 1981, Intervenors filed a response to ALAB-654, including i
an affidavit by Dr. Kepford. The NRC Staff, the Three Mile Island licensees, and the Peach Bottom and Hope Creek licensees replied to Intervenors noting that Dr. Kepford was not a qualified authority on the subject of health effects of radiation p/
7 5_/ Witnesses for the licensees, NRC Staff, and the intervenors in the Sterling.
proceeding testified at the hearing.
Dr. Kepford did not seek to testify.
6_/ On October 24, 1981, Dr. Kepford on his own behalf filed a petition to review ALAB-640 with the U.S. Court of Appeals for the D.C. Circuit. Kepford v. USNRC, No. 81-2111. The case is being held in abeyance pending completion of the con-solidated radon proceeding.
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The Three Mile Island licensees' reply also included a detailed affidavit by Dr. Leonard Hamilton showing the insignificant health effects from the radon releases determined in ALAB-640.
Dr. Hamilt e is a highly qualified expert on radiation health effects, as the Perkins Li-:ensing Board and the Appeal Boards have found.
LBP-78-25, 8 NRC at 95-100; ALAB-654, 14 NRC at 634; ALAB-701 at 8, 16.
Intervenors have not challenged Dr. Hamilton's qualifications.
4 On November 19,-1982, the Appeal Boards issued ALAB-701, in which they concluded that Intervenors had not shown that.Dr. Kepford possessed the required
. qualifications to address the' health effects issue, slip op.' at 12-14, and that Intervenors had also failed to meet the second ALAB-654 requirement, i.e.,
that the expert opinion discuss the significance of the fuel cycle radon releases in light of the. magnitude and fluctuations in natural radon emissions, slip'op. at 15-16.
Consequently, the Appeal Boards reached their decision by reviewing the evidence in the Perkins record. The Appeal Boards held that the fuel cycle radon releases determined in ALAB-640 posed a "vanishingly small" incremental health l
risk to the population.
Id.at 24. The instant petition for review ensued.
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ARGUMENT I.
THE APPEAL BOARDS WERE JUSTIFIED IN RELYING UPON THE PERKINS RECORD FOR DETERMINING THE HEALTH EFFECTS OF RADON RELEASES Although not clearly articulared, the Petition appears to raise two alle-gations of error against the Appeal Boards' decision in ALAB-701:
(1) that the Appeal Boards should have held an evidentiary hearing on the issue of the health effects of radon releases from the uranium fuel cycle, instead of relying on the
.e evidence in the Perkins record; and (2) that the Appeal Board erred in adopting the dji minimis approach used by the Licensing Board in Perkins (see LBP-78-25, 1
e supra, 8 NRC at 100).
gese The first argument is easily put to rest. The Appeal Boards noted in ALAB-654 that there was a thorough discussion by " highly qualified expert witnesses" of the health effects issue in the Perkins proceeding. The Appeal l
Boards ruled that, in order for further evidence to be taken on the issue, the 1
intervenors would have to show that there was a difference of opinion among experts on whether "the incremental fuel cycle-related radon emissions will have a significant environmental effect on human health." 14 NRC at 635.
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In response to ALAB-654, Petitioners offered an affidavit from Dr. Kopford.
That document did not establish th'at Dr. Kepford is qualified to offer expert
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testimony on the health effects issue, and did.not address the considerations requested by the-Appeal Boards but merely took exception to them. The Appeal Boards in ALAB-701 noted that Dr. Kepford's competence as an expert on the health.
effects of radiation was nowhere established (slip op at 12-14), and that his
- affidavit failed to address the significance of the fuel cycle radon releases measured against the amount and fluctuations on natural radon emissions. Slip.
op. at 14-16.
Intervenors allege that it was error for the Appeal Boards not to recognize 4
Dr. Kepford as a health effects expert. Petition at 3.
The Petition asserts that Dr. Kepford's expertise is evidenced by his participation in Three Mile Island and Perkins, as well as in the instant proceeding. Petition at 7.
Such circular reasoning, however, cannot obscure the fact (admitted by Dr. Kepford in Perkins) that he has received no academic training or otherwise performed any activity relevant to the assessment of the effects of radon-222 emissions on human health. Sea Deposition of Chauncey Kepford in the Perkins proceeding, taken on June 8, 1978, Tr. 2677-2710.
Dr. Kepford's pursuit of the radon-222 issue in the last five years is not, as Intervenors would have it, proof of expertise,,h,ut at most evidence of his interest in the subject. !
In any event, the Appeal Boards satisfied themselves that the facts and opinions expressed by Dr. Kepford in his affidavit in response to ALAB-654 were 8/ Intervenors urge, as proof of Dr. Kepford's expertise, that it was his testi-mony in the Three Mile Islat.d proceeding that " led the Commission" to vacate the radon release value in Table S-3.
Petition at 7.
As noted above, the exami-nation of the radon entry on Table S-3 was the result of a rulemaking petition filed by others two years before Dr. Kepford's testimony in Three Mile Island.
Dr. Kepford in fact argued to the Appeal Boards that it was Dr. Pohl's work, submitted to NRC in NECNP's 1975 rulemaking petition, that led to the deletion of the radon value from Table S-3.
Tr. 80.
7-neither new nor different fron'those he presented as a witness in Perkins. Nor did the Petition identify any such new facts or opinions. Thus,'even if the failure to qualify Dr. Kepford as an expert had been erroneous, such an error' would have been inconsequential. For, as the Appeals Boards' opinion shows, Dr. Kepford's views in Perkins were taken into consideration by the Appeal Boards in reaching their decision.. See ALAB-701, slip _op, at 22-23.
For these reasons, this alleged " error" by the Appeal Boards raises no valid grounds for Commission review of ALAB-701.'-
II.
THE APPEAL BOARDS CORRECTLY RULED THAT FUEL CYCLE RADON EMISSIONS HAVE'AN INSIGNIFICANT IMPACT ON HUMAN HEALTH The Appeal Boards determined in ALAB-640 that the " worst case" long term radon releases associated with the 30-year operation of a reference 1,000 MW(e) reactor would be 6,900 curies per year ("Ci/yr").
13 NRC at 542.1S! The record in Perkins is uncontested that natural radon releases from the soil in the United States are between 100 and 240 million Ci/yr. Gotchy, foll. Perkins Tr. 2369, at 14.
Thus, assuming that the average individual dose is proportional to the radon emission rate, fuel-cycle related radon releases attributable to lifetime operation of a reference reactor would increase by at most.0069% the average 9/ Attached to the Petition are excerpts from " Radiation and Human Health", a book by John W. Gofman, which Intervenors move be " entered in to the record in these prociEMings". Petition at 5 and n.l.
It is unclear for what purpose the excerpts from Dr. Gofman's book are offered.
If they are intended to be used as an expert opinion in response to ALAB-654, they are unacceptable evidence, since they are not in affidavit form, they are offered unjustifiably late (the book was copywritten in 1981), they are not based on the radon emission rates established in ALAB-640, and are based on a population of 1,000 reactors. For all these reasons, the excerpts from Dr. Gofman's book should be disregarded.
10/ This and the other findings by the Appeal Boards in ALAB-640 are not subject to question, constituting as they do final Commission action. Therefore, those portions of the Petition that contain challenges to the testimony leading to ALAB-640, or are inconsistent with the decision itself (Petition at 6 and n.3, 8 and n.5) should be disregarded as improperly raised.
1 i i individual dose due to natural radon releases from the soil. This incremental dose becomes even smaller when radon releases from indoor sources such as building materials are considered. The uncontested evidence'in Perkins demon-strates that the individual dose from exposure to indoor radon concentrations is on the average 30 times larger than_ the dose due to natural radon releases from thesoilandotheroutdoorsources.11!
Dr. Leonard Hamilton testified in Perkins that fuel cycle radon releases attributable to lifetime operation of a reference 1,000 MW(e) reactor (.0075 millirem / year) would add less than one part in 100,000 to the average individual dose due to indoor and outdoor natural radon (1650
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millirem / year). Accordingly, the incremental health risk posed by fuel cycle radon releases would be negligible. Perkins. Tr. 2276-78 (Hamilton).
There was no testimony at Perkins or elsewhere to contradict Dr. Hamilton's testimony and conclusions, and Intervenors have not attempted to dispute them,1 !
even though the Appeal Boards in ALAB-654 instructed that they needed to do so in order to create a triable issue of material fact.
See 14 NRC at 635. Instead, Intervenors asserted in their response to ALAB-654, as they do here (see Petition at 3-6), that the individual radioactive doses due to natural radon sources are irrelevant to a determination of the health impact of the fuel cycle radon releases.
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Indoor concentrations of radon vary from 4 to 400 times the average outdoor concentration. The average indoor concentration is 30 times the average outdoors.
Perkins Tr?"2276-77 (Hamilton).
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12/ The Petition charges Dr. Hamilton with adopting the views of the 1980 "BEIR-3" report, while ignoring the " controversy contained in the report".
(Petition at 8).
This assertion is erroneous on at least two counts.
First, Dr. Hamilton's testi-mony in Perkins, given in 1978, did not rely on the "BEIR-3" report, but on the 1972 "BEIR-1" report. Perkins Tr. 2270-71. The reference to the BEIR-3 report is actually found in Dr. Hamilton's affidavit "Concerning the Health Effects of Radon Releases from Uranium Mining and Milling", dated January 29, 1982 and filed with the Three Mile Island licensees' reply to ALAB-654.
Second, and most important, both in his testimony in Perkins and in his most recent affidavit Dr. Hamilton l
computed the health effects from exposure to radon by utilizing a " linear hypothesis" which is, by all scientific opinion, a very conservative approach.
See Perkins Tr. 2270-71 (Hamilton).
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However, the courts have sanctioned a comparison of the radioactive emissions attributable to an industrial activity with natural background radiation as a way to determine whether the industrial activity has a significant environmental impact. Citizens For Safe Power v. NRC, 524 F.2d 1291,-1296-01 (D.C. Cir. 1975);
Peshlakai v. Duncan, 476 F. Supp.1247,1253 (D.D.C.1979)(radon emissions from uranium milling and mining de minimis when compared to natural background radiation). And where, as here, the activity is found to pose jijt minimis risks, it need not be considered by the agency in fulfilling.its statutory obligations.
Industrial Union Department v. American Petroleum Institute, 448 U.S. 607, 100 S. Ct. 2844, 2875 (1980)(C.J. Bu'rger, concurring); Citizens For Safe Power
- v. NRC, supra, 524 F.2d at 1300-01.
1 Even without reference to natural background radon, there is ample evidence in the record that fuel cycle radon releases pose an insignificant risk to public health.
Dr. Hamilton testified in Perkins that the lifetime risk of any individual 4
developing lung cancer as a result of the radon releases attributable to one year's
-10 operation of a reference reactor would be 5.4 x 10 Perkins Tr. 2656. This
~0 would translate into 1.6 x 10 for 30 years of reactor operation, or a probability of about 1 in sixty million for any individual to contract fatal lung cancer as a result of the fuel cycle radon releases.13/ Without question, this is an insig-nificant risk, and the Appeal Boards correctly ruled that "the fuel cycle contri-bution to the radon already in the environment -- a contribution that, once again, v.W is so slight as to be beyond detection (let alone measurement) -- cannot serve to tip the NEPA balance against operation of any of these three facilities", and that 13/
Dr. Kepford's testimo.ny in Perkins assigns a fatality rate of approximately 0.16 deaths per year to the long term radon releases attributable to all fuel needed for the lifetime of a reactor.
Kepford, foll. Perkins Tr. 2819 at Table 4.
Assuming a U.S. population of 3000,000,000 people, and a life expectancy of 70 years, Dr.
Kepford's computation translates into an individual risk of 0.16 x 70/300,000,000, or i
one in 30 million.
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"the incremental health risk to the population stemming from fuel cycle emissions (if indeed there is any) is vanishingly small". ALAB-701, slip op, at 21, 24, emphasis in. original.
CONCLUSION For the above stated reasons, the Three Mile Island licensees submit that the Appeal Boards' decision in ALAB-701 is clearly correct and the petition for Com-mission review should be denied. We would also urge, now that the consolidated radon proceeding has finally been completed, that the Commission promptly amend Table S-3 by adding a radon-222 value consistent with ALAB-640. Such action will avoid the necessity for needless case-by-case adjudication of radon issues.
Respectfully submitted, SHA PITTMAN, POTTS & TROWBRIDGE M
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BY :
m JAY E. SlLBERG, P.C/
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MA1 IAS F. TRAVIESO-DEAh Counsel for Metropolitan Edison Company, et al.
1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 DATED: January 11, 1983 3v4e 14/ The Appeal Boards were also correct in rejecting Intervenors' attempt to integrate fractional health impacts over thousands, millions and billions of years. As Dr. Hamilton testified in Perkins, addition of fractional deaths over generations is unrealistic and meaningless. What is meaningful is the health risk posed to any individual by the fuel cycle radon emissions. See Perkins Tr. 2274-75, 2333, 2653-57 (Hamilton). That risk, as seen above, is negligible.
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January 11, 1083 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION i
In the Matters of
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PHILADELPHIA ELECTRIC COMPANY ET AL.
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Docket Nos. 50-277 (Peach Bottom Atomic Power Station,
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50-278 Units 2 and 3)
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METROPOLITAN EDISON COMPANY E_T AL. ~
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Docket No.
50-320 (Three Mile Island Nuclear Station,
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Unit 2)
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PUBLIC SERVICE ELECTRIC AND GAS CO.
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Docket Nos. 50-354 (Hope Creek Generating Station,
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50-355 Units 1 and 2)
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CERTIFICATE OF SERVICE This is to certify _that copies of the foregoing "Three Mile Island Unit 2 Licensees' Answer to Intervaaors' Petition for Review" were served by deposit in the United States Mail, first class, postage prepaid, this lith day of January, 1983, to all those on the attached Service List.
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DATED: January 11, 1983
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UNITED STATES OF' AMERICA-NUCLEAR REGULATORY COMMISSION BEFORE THE ColffISSION
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LIn'the Matters.of:
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PHILADELPHIA. ELECTRIC COMPANY ET AL.
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Docket Nos. 50-277 (Peach Botton Atomic Power Sta Eon,
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.50-278 1 Units 2.and 3)
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' METROPOLITAN EDISON COMPANY, _ET AL.-
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Docket No. 320 (Three Mile Island Nuclear Station,.
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Unit 2).
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PUBLIC SERVICE ELECTRIC AND GAS COMPANY )
Docket Nos. 50-354 (Hope Creek Generation Station,
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50-355 Units 1-and 2)
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't SERVICE LIST Nunzio J. Palladino, Chair Dr. W. Reed Johnson, Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Appeal Board ~
1717 H Street, N.W.
U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Washington, D.C.
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..20555 Victor Cilinsky, Commissioner Thomas S. Moore, Esquire U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Appeal Board Washington, D.C.
20555-U.S. Nuclear Regulatory Comission Washington, D.C.
20555 John F. Ahearne, Comissioner U.S. Nuclear Regulatory Comission Christine N. Kohl, Esquire.
Washington, D.C.
20555 Atomic Safety and Licensing Appeal Board Panel Thomas M. Roberts, Commissioner U.S. Nuclear Regulatory Comission U.S. Nucleat Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 M
Judge Reginald L. Gotchy James K. Asselstine, Commissioner Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 i
Dr. John H. Buck, Administrative Dr. Ernest E. Hill Judge Administrative Judge Atomic Safety and Licensing Lawrence Livermore Laboratory Appeal-Board University of California e
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U.S. Nuclear Regulatory Comission Post Office Box 808, L-123 l
Washington, D.C.
20555-Livermore, California 94550
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-Alan S. Rosenthal, Esquire Dr. Oscar H. Paris Chairman, Atomic Safety and Licensing Administrative Judge Appeal Board-Atomic Safety and Licensing Board Panel l
- U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission
. Washington, D.C..
20555. !
Washington, D.C... 20555
Ivan W. Smith, Esquire Edward G. Bauer, Jr., Esquire Administrative Judge Vice President and General Counsel Atomic Safety & Licensing Board Panel Philadelphia Electric Company U.S. Nuclear Regulatory Commission 1000 Chestnut Street Washington, D.C.
20555 Philadelphia, Pennsylvania 19105 Dr. Walter H. Jordan Eugene J. Bradley, Esquire Administrative Judge Philadelphia Electric Company 881 West Guter Drive 2301 Market Street Oak Ridge, Tennessee 37830 Philadelphia, Pennsylvania 19101 Gary L. Milho111n, Esquire Raymond L. Hovis, Esquire 1815 Jefferson Street Stack and Leader Madison, Wisconsin 53711 35 South Duke Street York, Pennsylvania 17401 Dr. Linda W. Little Administrative Judge W. W. Anderson, Es'. ire L.W. Little Associate Deputy Attorney Gcneral 1312 Annapolis Dr., Suite 214 Department of Justice Raleigh, North Carolina 27608 Capitol Annex Harrisburg, Pennsylvania 17120 Atomic Safety and Licensing Board Panel Karin Carter, Esquire U.S. Nuclear Regulatory Commission Department of Environmental Resources Washington, D.C.
20555 Commonwealth of Pennsylvania 505 Executive House Atomic Safety and Licensing Appeal Harrisburg, Pennsylvania 17120 Board Panel U.S. Nuclear Regulatory Commission Senator Allen R. Carter, Chairman Washington, D.C.
20555 Joint Legislative Committee on Energy Post Office Box 142 Gary J. Edles, Esquire Suite 513 Senate Gressette Building Atomic Safety 6 Licensing Appeal Columbia, South Carolina 29202 Board Panel _
U.S. Nuclear Regulatory Commission John B. Griffith, Esquire S ecial Assistant Attorney General P
Washington, D.C.
20555 Tawes State Office Building (C-4)
Judith Johnsrud Annapolis, Maryland 21401 Environmental Coalition on Nuc1 car Power 433 Orlando Avenue Docketing and Service Section State Co1{ege, Pennsylvania 16801 Office of the Secretary U.S. Nuclear Regulatory Commission Hs. Sue Reinert Washington, D.C.
20555 j
Ecology Action Box 9Y Frederick M. Broadfoot, Esquire Oswego, New York 13126 Richard Fryling, Jr., Esquire Public Service Electric & Gas Company Troy B. Conner, Jr., Esquire 80 Park Place Conner & Wetterhahn Newark, New Jersey 07101 1
1747 Pennsylvania Avenue, N.W.
Washington, D.C.
20006 Honorable Mark I. First j
Deputy Attorney General 36 State Street L
Trenton, New Jersey 08625 I
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~ 3-Lawrence Sager, Esquire
- Bernard M. Bordenick, Esquire Office of the Executive. Legal Director Sager & Sager Associates U.S. Nuclear Regulatory Comaission 45 High Street.
Pottstown, Pennsylvania 19464 Washington, D.C.
20555 Robert H. Yarschuk, Esquire Robert Adler, Esquire Bucks County Solicitor-505 Executive House Administration Building, Roon 521 Post Office Box.2357 Doylestown, Pennsylvania 18901 Harrisburg, Pennsylvania 17120 Samuel M. Snipes, Esquire Honorable Mark Cohen 49 South Main Street 512 - D-3 Main Capital Building Yardley, Pennsylvania 19067 Harrisburg, Pennsylvania 17120
. William Harner, Esquire Ms. Marjorie Aamodt f
67 Market Street R.D. #5 Salem, New Jersey 08079 Coatesville, Pennsylvania 19320 Paul W. Rosenberg, Esquire Mr. Thomas Gerusky i
2323 South Broad Street Bureau of Radiation Protection Trenton,,New Jersey 08610 Dept. of Environmental Resources Post Office Box 2063 Honorable Michael Parkowski Harrisburg, Pennsylvania 17120 Deputy Attorney General Department of Natural Resources Mr. Marvin I. Lewis 7
and Environmental Control 6504 Bradford Terrace Tatuall Building Philadelphia, Pennsylvania 19149 Dover, Delaware 19901 Ms.- Jane Lee Mr. Richard A. Uderitz R.D. 3; Box 3521 Vice President - Nuclear Department Etters, Pennsylvania 17319 Public Service Electric and Gas Co.
J Post Office Box 570 - T15A Walter W. Cohen, Consumer Advocate Newark, New Jersey 07101 Department of Justice Strawberry Square, 14th Floor Peter Buchsbaum, Esquire Harrisburg, Pennsylvania 17127 Robert D. Westreich, Esquire Department of the Public Advocacy Thomas J. Germine Division of Public Interest Advocacy Deputy Attorney General i
520 East State Street Division of Law - Room 316 Trenton,ppyJersey 08625 1100 Raymond Boulevard Newark, New Jersey 07102 Mr. William J. Laputka, Township Manager Allen R. Carter, Chairman Falls Township Board of Supervisors Joint Legislative Committee on Energy i'
285 Yardley Avenue Post Office Box 142 Fallsington, Pennsylvania 19054 Suite 513, Senate Gressette Building Columbia, South Carolina 29202 i
Mr. David A. Caccia f
RD #2, Box 70-A Robert Q. Pollard Sewell, New Jersey 08080 609 Montpelier Street Baltimore, Maryland 21218 1
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Nb. Frieda Berryhill, Chairman Coalition for Nuclear Power Plant Postponement 2610 Grendon Drive Wilmington, Delaware.1980S Gail Phelps ANGRY 245 W. Philadelphia Street York, Pennsylvania ~ 17401 William S. Jordan, III, Esquire Harmon-& Weiss 1725 I Street, N.W., Suite 506 Washington, D.C.
20006 John Levin, Esquire Pennsylvania Public Utilities Comm.
Box 3265 Harrisburg, Pennsylvania 17120 Jordan D. Cunningham, Esquire Fox, Farr and Cunningham 2320 North Second Street Harrisburg, Pennsylvania 17110 Louise Bradford Three Mile Island Alert 1011 Green Street Harrisburg, Pennsylvania 17102 Ms. Ellyn R. Weiss Harmon & Weiss 1725 I Street, N.W., Suite 506 Washingtop,,,p.C.
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Mr. Steven C. Sholly Union of Concerned Scientists 1725 I Street, N.W., Suite 601 Washington, D.C.
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