ML20030A920
| ML20030A920 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/27/1981 |
| From: | Cutchin J, Swartz L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 8107300003 | |
| Download: ML20030A920 (18) | |
Text
O O
t Staff 7/27/81
'/ h ls O
UNITED STATES OF #1 ERICA y
[\\\\1[hkg NUCLEAR REGULATORY COMMISSION
.g
\\M LU 9 $[3Y"
(-
l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD{
g sr In the Matter of METROPOLITAN EDISON COMPANY, J
Docket No. 50-289 i
(Three Mile Island, Unit 1)
)
NRC STAFF'S REPLY FINDINGS OF FACT ON PLANT DESIGN AND MODIFICATION ISSUES (SECOND SET)
J6mes M. Cutchin, IV Counsel for NRC Staff Lucinda Low Swartz Counsel for NRC Staff Dated at Bethesda, Maryland this 27th day of July, 1981.
~
p58l A
8107300003 810727 PDR ADOCK 05000289 G
FOR
_i_
INDEX I.
Commonwe al th of Pe nnsyl va ni a......................................... 1 Board Question 6.....................................................
1 UCS Con te n ti o n 14.................................................... 3 UCS Co n te n ti o n 12.................................................... 3 II. Uni on Of Conce rned Sci enti s ts........................................ 4 U CS Co n te n ti o n 13.................................................... 4 B o a rd Q ue s ti on 6..................................................... 5 U C S Co n te n ti o n 14.................................................... 5 B o a rd Q u e s t i o n 2..................................................... 8 UCS Co n te n ti o n 12.................................................... 9 III. Corrections to NRC Staff Proposed Findi ngs.......................... 14 l
l I
\\
Staff 7/27/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of METROPOLITAN EDIS0N COMPANY,
)
Restart (Three Mile Island, Unit 1)
)
NRC STAFF'S REPLY FINDINGS OF FACT ON PLANT DESIGN AND MODIFICATION ISSUES (SECOND SET)
The Staff's replies to certain of the proposed findings of fact sub-mitted by the Commonwealth of Pennsylvania and the Union of Concerned Scientists on June 12 and July 13, 1981 are set forth below.
In addition, the Staff makes one correction to its proposed findings of fact filed with the Licensing Board on June 1, 1981.
l l
I.
Commonwealth of Pennsylvania l
Board Question 6 1.
In its proposed findings 190-206 the Commonwealth argues that either the new low level alarms in the condensate storage tanks should be required to be installed by January 1,1982 or the existing level indica-tion and alarms should be required to be powered fr m independent, vital power supplies until the new alarms are in place. The Commonwealth agrees that the existing design is adequate for restart if a loss of power alarm exists and if there is sufficient time after it occurs for the operators to check levels and take appropriate actions. However, in its view operation
. past January 1,1982 without upgrading the design is unacceptable.
It cites no justification other than claimed " uncertainties in the Staff's reasoning for permitting deferral of [the safety-grade modification]."
The Board finds the Commonwealth's arguments to be unpersuasive in view of the fact that the record does not support a finding that the upgrades are needed to provide reasonable assurance that TMI-1 can be operated with-out endangering the health and safety of the public. The modification sought is not one imposed by the Commission's Order of August 9,1979 but is one that was added by the Staff and accepted ty the Licensee. See:
Staff Exhibit I at C1-8.
Thus we decline to adopt the Commonwealth's findings 190-206.
2.
In its proposed findings 207-215 th Commonwealth notes that manual initiation of emergency feedwater may be required for certain transients and argues that because the occurrence of certain transients after the steam generators have steamed dry could cause the steam system rupture detection logic to shut off all feedwater flow to both steam generators, the Staff should be directed to verify and certify that certain actions have been taken oy the Licensee.
It is not apparent nor does the Commonwealth argue that the transient which must be postu-lated to occur following steam generator dryout has any nexus to the TMI-2 event. Moreover, a Board does not direct the Staff in the perfom-ance of its administrative functions. Carolina Power and Light Company (Shearon Harris Nuclear Power Plant, Units 1-4), CLI-80-12, 11 NRC 514, 516 (1980). Thus, we decline to adopt the Commonwealth's proposed findings 207-215.
.~. - -.
.,UCS Contention 14 3.
In its proposed findings [216]-235 the Commonwealth argues that the pressurizer level instrumentation for TMI-1 should be powered from redundant onsite power supplies.
In support of its argument it makes numerous citations to statements and positions set forth in NUREG-0578, a document that is not itself a part of the evidentiary record of this proceeding although it is referred to in the Commission's Order of August 9,1979 and is quoted extensively in the Staff's SER and its Supplement. Moreover, the evidentiary record indicates, but the Common-wealth neglects to note, that the emergency power supply design for pressurizer level instrumentation at TMI-1 complies with the pertinent requirements of the Commission's Order Item 8.
Staff Exhibit 1 at C8-10 and Staff Exhibit 14 at 24. The Board finds that the Commonwealth has failed to support its argument that, contrary to the evidence in the record, the power supply design for pressurizer level instrumentation at TMI-1 is not adequate to provide reasonable assurance that TMI-1 can be operated withuut endangering the health and safety of the public.
Thus, we decline to adopt the Commonwealth's proposed findings [216]-235.
UCS Contention 12 I
4.
In its proposed findings on this issue, particularly in 9, 10,11,12,13,14,15,17,18,19 and 32, the Commonwealth expresses concerns about the accuracy of the Licensee's flood level calculations and complains that the Staff did not review them or present a witness to testify about them. As the Commonwealth is aware, the Licensee pro-duced a witness, Mr Croneberger, to testify about Licenste's flood level l
i
4 calculations.
If the Commonwealth had concerns about the accuracy of those calculations it could have and should have explored those concerns with Mr. Croneberger. This Board vill not assume that Licensee's flood level calculations for TMI-1 are in error or that electrical equipment that is necessary to cope with a SBLOCA has not been located above the calcu-lated flood level. There is not a scintilla of evidence in the record to support such an assumption. All the evidence related to flood levels at THI-1 supports the conclusion that electrical equipment necessary to cope with a SBLOCA will not become submerged prior to completing its safety function. That actual flood levels at TMI-2 were higher than cal-culated flood levels at TMI-1, without more, does not negate that conclu-sion. We decline to adopt the Commonwealth's findings on flood level.
5.
In its proposed findings 34(1)(a) and (b) the Commonwealth proposes that this Board direct the Staff to conduct a review of Licensee's flood level calculations, operational limitations that must be imposed and emergency procedures that should include the operational limitations. The Board notes again that a Board does not direct the Staff in the performance of its administrative functions.
Carolina Power and Light Company (Shearon Harris Nuclear Power Plant, Units 1-4;,
CLI-80-12, 11 NRC 514, 516 (1980). Thus, we decline to adopt such pro-posed findings.
II. Union of Concerned Scientists UCS Contention 13 6.
In support of its proposed finding 324 UCS cites Staff responses to UCS interrogatories and a UCS motion for summary disposition. Neither
. of these documents is in evidence. A Board may not base a decision on factual material that is not in evidence. Tennessee Valley Authority (Hartsville Nuclear Plant, Units 1A, 2A, IB and 2B), ALAB-463, 7 NRC 341, 351-2(1978). Thus, we decline to make such a finding.
i 7.
In support of its proposed finding 326 UCS cites NUREG-0585.
That document is not in evidence. We decline to adopt this proposed finding for the reasons stated in RF 6, supra.
8.
In support of its proposed findings 365, 367, and 371-3 UCS cites NUREG-0737. That document is not in evidence. We decline to adopt these proposed findings for the reasons stated in RF 6, supra.
Board Question 6 9.
In support of its proposed findings 382-3 and 392-3 UCS cites NUREG-0578. That document is not in evidence.
For the reasons stated in RF 6, supra, we decline to adopt these proposed findings.
- 10. UCS bases its proposed findings 417-21 on information in WASH-1400, a document that is not in evidence and the cited portions of which we have declined to take official notice. See:
" Confirmatory Memorandum and Order on Rulings Made at June 4,1981 Hearing Session" and Tr. 21840-41. Thus, we decline to sdopt proposed findings 417-21 for the reasons stated in RF 6, supra.
UCS Contention 14 11.
It its proposed findings 478-9 UCS cites an NRC advanced notice of proposed rulemaking. That document is neither in evidence nor a rule. We decline to adopt these proposed findings. See: RF 6, supra.
12.
In its proposed findings 488-90 and 547 UCS bases its argu-ments on quotations from an ACRS letter. UCS does not provide a cita-tion to the evidentiary record.
However, even if the letter is in evi-dence it cannot be treated as having been admitted for the truth of any statements it makes. The contents of an ACRS report cannot serve as the basis for findings. Arkansas Power and Light Company (Arkansas Nuclear One, Unit 2), ALAB-94, 6 AEC 25, 32 (1973). Thus, we decline to adopt these proposed findings.
13.
In its proposed finding 494 UCS states that Mr. Conran's positions with the ACRS and the NRC from 1973 through August 1978 were in the area of safeguards. UCS has misstated the record.
From February, 1973 to July,1975, Mr. Conran was a senio* staff assistant / project manager for the ACRS and was responsib:2 for coordinating activities in support of licensing reviews and preparing reports for ACRS use identifying areas requiring detailed evaluation or resolution of deficiencies. Tr. 8323 (Conran); Professional Qualifications of Conran, ff. Tr. 8372, after 15.
His work with the ACRS also involved a good deal of interaction with NRR. Tr. 8329 (Conran).
- 14. UCS states in proposed finding 495 that Mr. Conran's duties were l
" managerial rather than technical." Again this misstates the record.
As a member of the Lessons Learned Task Force, he had to be aware of and understand the technical concerns which were being raised. Tr. 8354 (Conran). He was chosen to work on that Task Force because he had a broad range of experience that could help tie together a large number of specific technical concerns. Tr. 8355 (Conran). Other attacks on l
l l
l
, Mr. Conran's qualifications are made in proposed findings 496-500. Based on Mr. Conran's statement of professional qualifications, we decline to adopt UCS' conclusions regarding Mr. Conran'a qualifications.
15.
In its proposed findings 506, 518, and 519, UCS states that Mr. Conran testified that none of the TMI-2 non-safety systems were used until after improper operation of safety systems had caused core damage.
In fact, what Mr. Conran stated was that none of the TMI-1 non-safety systems had to be used until after improper operation of safety systers. Tr. 8604-5, 8606-7. This clarification of Mr. Conran's testi-rony sup orts a finding that upgrading of non-safety systems is n d nec-essary tc protect the public health and safety and we decline to accept UCS' proposed findings on this subject.
16.
In its proposed finding 507 UCS states that no criteria for the exercise of the Staff's judgment as to the partial upgrading of certain equipment was offered. This statement is misleading. Mr. Conran par-ticipated in specific deliberations which resulted in recommendations that certain equipment be made more reliable. Tr. 8608 (Conran) He described in detail the criteria used in making those reenmmendations.
Tr. 8609-10. We decline to adopt UCS proposed finding 507, 17.
In its proposed finding 514 UCS claims that, according to Mr. Conran, a system or component that is "important to safety" within the meaning of the introduction to the GDC may not be required to meet any specific GDC, including the quality assurance provisions Appendix B to 10 CFR Part 50. UCS also states that Mr. Conran testified that although a system or component is important to safety within the meaning of GDC 1,
---m
---.-w-
. - -, - -. - - - -. -, - ~ - - -, -., -, -
-.m
- - - ~., - - - -
. its level of importance is not enough to cause any specific requirements to apply. UCS has distorted Mr. Conran's testimony.
First, Mr. Conran testified that GDC-1 applied to all systems classified as "important to safety," although the Staff, in the past, has not reviewed a licensee's quality assurance program for anything but safety-related systems.
Tr.8407,8418-20,8422-8424(Conran). Second, the witness explained that the level of importance of a certain system might be such that no specific SRP or Regulatory Guide would be issued to give detailed guid-ance on how to implement the applicable GDC. Tr. 8419 (Conran). Wa decline to adopt proposed finding 514 and UCS' distorted interpretation o' Mr. Conran's testimony.
Board Question 2 18.
In support of its proposeu findings 567-71, 585, 588-92, 599-601, 609-10 and 620 UCS cites NUREG-0660, a document that is not in evidence. We decline to adopt these proposed findings. See: RF 6, supra.
19.
In support of its proposed finding 586 UCS cites NUREG-0578, a document that is not in evidence. See: RF 6 and RF 9, supra.
20.
In support of its proposed findings 622 and 623 UCS cites the so-called "Kemeny Report," a document that is not in evidence.
For the reasons stated in RF 6, supra, we decline to adopt the proposed findings.
l f
(
l
I
-g-UCS Contention 12 21.
In its proposed finding 633 UCS states that certain deadlines, if met, would have permitted completion of the Staff's review well before the conclusion of the Till-1 restart hearings. UCS provides no citation to the record to support such a speculation. We decline to so conclude.
22.
In its proposed findings 635-39 UCS complains that the Staff failed to inform UCS of the Staff's position on the scope of the environ-mental qualification issue. This Board has pointed out to the parties on several occasions that it is the responsibility of each party, not of the Board or anyone else, to keep itself informed of matters that occurred at the hearing while it was not present.
See, for example: Tr. 2528.
23.
In its proposed finding 643 UCS refers to the contents of UCS Exhibit 40. That documenc was received in evidence solely to demonstrate that there is such a document. Tr. 22078 (Chairman Smith). Thus we decline to find that the document " identifies literally dozens of safety-related components for which environmental qualification has not been established."
23a. In its pro, nosed findings 644 UCS states that "t?,e Staff chose to stand on the proposition that a recurrence of the 'TMI-2-type situation' is not 'possible'" and that the Board rejected that position.
UCS has misinterpreted the record.
In explaining the Staff's position, Staff counsel, Mr. Cutchin, noted that the purpose of the hearing was to determine whether "the prevention of a recurrenct: of the THI-2-type situation has been demonstrated to be possible." Tr. 21913 (Cutchin).
The Board did not reject this position. Tr. 21914-22.
UCS attempts to
(
. =
. make a similar argument in proposed findings 646. We decline to adopt these findings.
24.
In support of its proposed finding 645. UCS citas several sec-tions of NUREG-0578. That document is not in evidence. We dec.)ine to adopt this proposed finding for the reasons stated in RF 6, supra.
~
25.
In proposed finding 647 UCS cites statements made by the NRC Staff counsel. Such statements are not evidence in this proceeding and we decline to adopt this proposed finding for the reasons stated in RF 6, supra.
26.
In proposed finding 654 UCS cites statements made by Mr. Pollard at a time when he was cross-examining Staff witness Rosztoczy and participating in an essentially legal discussion with the Board.
Tr. 21909-10 (Pollard). Mr. Pollard was not subject to cross-examination on the statements he made and those statements cannot be used as evidence in this proceeding. We decline to adopt this proposed finding inasmuch as it relies on non-evidentiary material. See RF 6, supra.
26a.
In its proposed findings 655, 657-660, 666, 671, 672, and 691 UCS is concerned with environmental qualification of equipment for all design basis accidents. The Staff, with the Board's approval, limited its analysis and testimony on Contention 12 to accidents that are clear and close analogs to the TMI-2 event. Tr.19487 (Tourtellotte), Tr.
19487-88(ChairmanSmith). We decline to adopt those UCS proposed findings wi.. h seek to go beyond the limitations we have placed on UCS Contention 12.
27.
In its proposed finding 660 UCS refers to the contents of UCS Exhibit 40. That document was admitted into evidence solely for the pur-l
pose of demonstrating that such a document exists. Tr.22078(Chair-manSmith). We decline to adopt this proposed finding which seeks to rely on the substance of UCS Exhibit 40.
See: RF 23.
28.
In its proposed finding 667 UCS makes no citation to the record in support of its conclusions. We decline to adopt this proposed finding on this ground.
29.
Proposed finding 671 also refers to UCS Exhibit 40. We decline to adopt this proposed finding for the reasons stated in RF 23 and 27, supra.
30.
In its proposed finding 679 UCS cites NUREG-0737 in support of its statement that the " Licensee and Staff ignored the fact that NUREG-0737 describes the necessary qualification criteria for incore thermocouples and other accident monitoring equipment." Because NUREG-0737 is not in evidence in this proceeding, we decline to adopt this pro-posed finding.
See:
RF 6, supra.
31.
In its proposed finding 680 UCS states that the " suction line for the decay heat removal pumps have a valve inside containment which is interlocked with a pressure switch...so that it cannot be opened if reactor coolant pressure is too high." No citation to the record is given. This statement, however, which cannot be supported by reference to the record, is necessary for UCS' conclusions in this proposed find-ing. We, therefore, decline to adopt proposed finding 680.
32.
Proposed finding 683 relies on UCS Exhibit 39 which was not received in evidence. See Tr. 22076, 23105-106. We decline to adopt this propos~ed finding for the reasons stated in RF 6, supra.
33.
In proposed finding 684 UCS relies on UCS Exhibit 40. As noted above UCS Exhibit 40 was admitted solely to demonstrate the existence of the document. Tr. 22078 (Chairman Smith :. Because the contents of that exhibit are not evidence in this proceeding we decline to adopt proposed finding 684. See: RF 23, 27.
33a. In its proposed finding 687 UCS states that the Staff "used an accident profile, calculated by 'another branch' which calculated that the equipment had to operate fcr 20.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />." UCS has misstated the record. Mr. La Grange, a witness for the Staff, testified that a SBLOCA ends when the temperature reaches the original temperature inside containment. Tr. 21956 (La Grange). The profile used by the Staff in t
evaluating the environmental qualification of the equipment in the TMI-1 containment building for a SBLOCA indicated that the temperature returns to its original level after 20.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Tr. 21957 (La Grange);
Temperature / Pressure Graph, ff. Tr. 21954. The calculations performed to arrive at this profile assumed a single failure, i.e., that one diesel did not start. Tr. 21958 (Rosztoczy). We decline to adopt this portion of UCS proposed findings 687.
34.
In proposed finding 690 UCS quotes a Staff witness as basing "a conclusion that spray will not actuate in a SBLOCA upon a feeling that
'maybe there is a little margin' in the calculation." UCS has misstated the record. As explained in the Staff's proposed finding 15 (NRC Staff Proposed Findings of Fact and Conclusions of Law Regarding Board Question UCS Contention 12), the Staff's witnesses did not consider the effect of chemical spray to be an environmental effect of a SBLOCA because the licensee stated that sprays are not actuated during a SBLOCA and because I
it has been determined that the pressure peak during a SBLOCA would be about 26 psig and the sprays would not come on until about 30 psig. We decline to adopt UCS' proposed finding 690.
35.
In its proposed finding 691 UCS states that "[i]t is not possi-ble to have all three fan coolers cperating if one diesel generator nas failed." UCS, however, provides no citation to the record.
In addition, UCS quotes Mr. La Grange and Mr. Rosztoczy as stating that the Licensee's profile assumed operation of three fan coolers.
Upon a careful examination of the referenced transcript pages, we find no record of such statemen n.s.
In fact, the record indicates that, for a SBLOCA, the Licensee assumed the loss of one diesel generator (worst case) which results in one reactor building fan coil unit be'ng available for cooling. Rosztoczy, ff. Tr. 21867, Attachment 2 (May 18, 1981 Letter from Licensee) at 1.
We decline to adopt this finding.
- 36. Again in proposed finding 695 UCS refers to the contents of UCS Exhibit 4U. We decline te, adopt this finding fcr the reasons stated in RF 23, 27, 29, and 33, supra.
37.
In its proposed finding 701 UCS makes statement for which it provided no citations and for which we can find no evidence on the record.
We therefore decline to adopt that finding.
38.
In its proposed finding 702 UCS cites UCS Exhibit 39 in support of its statements. As noted above, UCS Exhibit 39 has not been received in evidence and we therefore decline to adopt this proposed finding.
39.
In its proposed finding 712 UCS states that "[t]he Conax con-nectors in question are in the containment" and cites UCS Exhibit 39 for
su;oort. UCS Exhibit 39, inasmuch as it has not been received in evi-dence, cannot be used as support and the statement concerning the Conax connectors is a necessary basis for UCS' conclusions. We therefore decline to adopt this proposed finding.
III. Corrections to NRC Staff's Proposed Findings 1.
Proposed finding 197 states that Mr. Conran " emphasized that failure or off normal operation of non-safety systems cannot by itself adversely affect...."
It should state that "non-safety systems would not necessarily by itself adversely affect...."
Respectfully submitted, b
-r % h er ~
James M. Cutchin, IV Counsel for NRC Staff
' WYL E) c ucinda Low Swartz q
Counsel for NRC Staff Dated at Bethesda, Maryland this 27th day of July,1961 l
t
{
i
UNITED STATES OF AMERICA NUCLEAR REGULATORY C0lV4ISSION BEFORE THE ATOMIC SAFETY.AND LICENSING B0AkD In the Matter of i4ETROPOLITAH EDIS0N COMPANY,
)
(Three flile Island, Un t 1)
)
i CERTIFICATE OF SERVICE I hereby certify that. copies of "NRC STAFF'S REPLY FINDINGS OF FACT ON PLANT DESIGN ANDM ODIFICATTON ISSUES (SECOND SET), dated July 27, 1981 in the above captioned proceeding have been served on the following by depsof t in the United States mail, or as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, this 27th day of July,1981:
- Ivan W. Smith, Esq., Administrative Ms. Marjorie M. Aamodt Judge R.D. #5 Atomic Safety & Licensing Board Panel Coatesville, PA 19320 U.S. Nuclear Regulatory Commission Washington, D.C.
20S55 Mr. Thomas Gerusky Bureau of Radiation Protection Dr. Walter H. Jordan, Administrative Dept. of Environmental Resources Judge P.O. Box 2063 881 W. Outer Drive Harrisburg, Pennsylvania 17120 Gak Ridge, Tennessee 37830 Mr. Marvin I. Lewis Dr. Linda W. Little, Administrative 6504 Bradford Terrace Judge Philadelphia, Pennsylvania 19149 5000 Hermitage Drive Raleigh, North Carolina 27612 Metropolitan Edison Company ATTN:
J.G. Herbein, Vice President George F. Trowbridge, Esq.
P.O. Box 542 Shaw, Pittman, Potts & Trowbridge Reading, Pennsylvania 19603 1800 M Street, N.W.
Washington, D.C.
20006 ft. Jane Lee R.D. 3; Box 3521 Karin W. Carter, Esq.
Etters, Pennsylvania 17319 505 Executive House P. O. Box 2357 Walter W. = Cohen, Consumer Advocate Harrisburg, Pennsylvania 17120 Department of Justice Strawberry Square,14th Floor Honorable Mark Cohen Harrisburg, Pennsylvania 17127 512 D-3 Main Capital Building Harrisburg, Pennsylvania 17120
Thomas J. Germine Deputy Attorriey General Division of Law - Room 316 1100 Raymond Boulevard Newark, New Jersey 07102 Allen R. Carter, Chairman John Levin, Esq.
Joint Legislative Committee on Energy Pennsylvania Public Utilities Com.
Post Office Box 142 Box 3265 Suite 513 Harrisburg, Pennsylvania 17120 Senate Gressette Building Columbia, South Carolina 29202 Jordan D. Cunningham, Esq.
Fox, Farr and Cunningham Robert Q. Pollard 2320 North 2nd Street 609 Montpelier Street Harrisburg, Pennsylvania 17110 Baltimore, Maryland 21218 Louise Bradford Chauncey Kepford 1011 Green Street Judith H. Johnsrud Harrisburg, Pennsylvania 17102 Environmental Coalition on Nuclear Power 433 Orlando Avenue State College, Pennsylvania 16801 Ms. Ellyn R. Weiss Harmen & Weiss Ms. Frieda Berryhill, Chairman 1725 I Street, N.W.
Coalition for Nuclear Power Plant Suite 506 Postponement Washington, D.C.
2000G 2610 Grendon Drive
~
Wilmington, Delaware 19808 Mr. Steven C. Sholly Union of Concerned Scientists Gail P. Bradford 1725 I Street, N.W.
Suite 601 ANGRY 245 W. Philadelphia St.
Washington, D.C.
20006 York, Pennsylvania 17401
- Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Comissicr Washington, D.C.
20555 a
- Atomic Safety and Licensing Board Panel Lob 1 (t s[
U.S. Nuclear Regulatory Comission 1.ucinda low Swartz Washington, D.C.
20555 Counsel for NRC Staff
- Secretary U.S. Nuclear Regulatory Comission ATTN: Chief, Docketing & Service Br.
Washington, D.C.
20555 William S. Jordan, III, Esq.
Harmon & Weiss 1725 I Street, N.W.
Suite 506 Washington, D.C.
20006
-