ML20031G538
| ML20031G538 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 10/21/1981 |
| From: | Wagner M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| NUDOCS 8110230192 | |
| Download: ML20031G538 (18) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of PEi4I4SYLVANIA POWER AND LIGHT CO.,
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Docket No. 50-387 ALLEGHENY ELECTRIC COOPERATIVE, INC.
50-388 (Susquehanna Steam Electric Station, Units 1 and 2) f4RC STAFF RESPONSE TO CITIZENS AGAINST NUCLEAR DANGERS' APPEAL ON CONTENTIONS 2, 6, and 20 Mary E. Wagner Counsel for NRC Staff October 21, 1981 Ircyc',,, _D CRICT: AL
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I.
INTR 0DIfCTION..............................................
1
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II.
STATEMENT OF ISSUES ON APPEAL.............................
2 1
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II1. ARGUMENT..................................................
3 A.
CAND's Appeal Is Interlocutory In Nature and Cannot 4
B e' Ra i s ed a t T hi s ti me...............................
3 i
A.
Surmary Dismissal of Portions of CAND Contention 2................................................
3
'- ri 2.
Licensing Board's Refusal to Defer Evidentiary Consideration of Contentions 6 and 20............
5 B.
The Licensing Board Had An Adequate Decisional Basis for Supary Dismissal of CAND Contention 2...........
6 C.
On the Herits, the Licensing Board's Refusal to Defer Evidentiary Consideration of CAND Contentions 6 and 20 was Correct.......................................
10 IV.
CONCLUSION................................................
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- TABLE OF CITATIONS PAGE CASES:
Boston Edison Coupany, et al. (Pilgrim Nuclear Generating l
Station, Unit 2), ALAB-269, 1 NRC 411 (1975).................
3, 4 Consumers Power Company (Midland Plant, Units 1 and 2),
ALAB-468, 7 14RC 465 (1978)...................................
5 Duke Power Company (Perkins Nuclear Station, Units 1, 2 and 3),
ALAB-362, 2 HRL 856 (1975)...................................
3 l
Gulf States Utilities Com an (River Bend Station, Units 1 &
l 2), ALAB-329, 3 NRC 69 976)...............................
3 l
l Northern States Power Company (Tyrone Energy Park, Unit 1),
ALAB-492, 8 HRC 251 ( O)..................................,
3 Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 & 2), ALAB-213, 7 AEC 999 (1974)..............
4 Pennsylvania Power and Light Company, et a'.
(Susquehanna Steam Electric Station, Units 1 and 2), ALAB-565.10 NRC 449 (1979) 6 Philadelphia Electric Com?any (Fulton Generating Station, Units 1 and 2), ALAB-206, 7 A EC 841 (19741.........................
4 Potomac Electric Power Company (Douglas Point Nuclear Generating Station, Units 1 and 2), ALAB-176, 7 AEC 151 (1974).......................................................
4 Public Service Company of New Hampshire (Seabrook Station, Units 1 and 2), ALAB-295, 2 NRC 668 (1975)...................
6 Public Service Company of New Hampshire (Seabrook Station, Units 1 and 2), ALAS-293, 2 NRC 660 (1975)...................
6 l
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Puerto Ri'c~o Nater Resources Authoritl (florth Coast huclear Pl ant, Uni t 1), ALAB-286 Trilif213 (1975)...................
4 I
Southern Califorr.ia Edison Co._ (San Onofre fluclear Generating ftation, Uni ts 2 and 3), ALAB-212, 7 AEC 986 (1974)..........
5 i
C0!!MISS10ti POLICV STATEMENTS:
Statement of Policy on Conduct of Licensing Proceedings, 46 FED. REG. 2BT33 (May 27, 1981)...............................
12 l
REGULATIUi45 i
l 10Ctd52.714a(b).........................................
3 l
10 CFR 92.714a(c).........................................
3 10 CFR 92.718.............................................
5 j
10 CFR 92.718(f)..........................................
10 10 CFR 92.730(f)..........................................
3 i
10 CFR 62.749.............................................
10 FEDERAL RULES:
Federal Rule of Civil Procedure 54(b)..........................
4 OTHER:
6 Moore's Federal Practice, Para. 56.21 (2d ed. 1980)..........
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10/21/81 i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY Al4D LICENSING APPEAL BOARD In the Matter of
)
PEN!iSYLVANIA POWER AND LIGdT CO.,
Docket No. 50-387 ALLEGHENY ELECTRIC COOPERATIVE, INC.
)
50-388
)
(Susquehanna Steam Electric Station,
)
i Units 1 and 2)
)
HRC STAFF RESPONSE TO CITIZENS AGAINST NUCLEAR DANGERS' APPEAL UN CONTENTI0liS 2, 6, and 20 1.
INTRODUCTION In a document dated September 30, 1981 entitled " Citizens Against Nuclear Dangers Appeal on Contentions 2, 6, and 20", ("CAND Appeal")
Citizens Against Nuclear Dangers ("CAND") seeks to appeal two rulings by the Atomic Safety and Licensing Board ("1.icensing Board") in the above-captioned proceeding. Specifically, CAND asks the Appeal Board to re/erse those porti']ns of the Licensing Board's " Memorandum and Order on Pending Motions" dated September 23,1981 (" Memorandum and Order") which (1) granted summary disposition to Applicants on certain parts of Contention 2 and (2) denied CAND's request that consideration af Contentions 6 and 20 at hearing be deferred until spring of 1982.
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_ In its Memorandum and Order the Licensing Board concluded that "[t]here is no issue of a material fact to be heard" with respect to those parts of contention 2 relating to the magnitude of releases and of doses resulting from releases of radioactive materials from the Susquehanna plant.M (Memorandum and Order, para. 5).
In denying CAND's motion to defer consideration of Contentions 6 and 20, the Licensing Board stated that
"[n]o justification has been demonstrated for the necessity of the deferral of consideration" of the contentions.
(!!emorandum and Order, para. 3).
II. STATEMENT OF ISSUES ON APPEAL The issues raised by CAND's Appeal are threefold:
A.
Are the matters raised by CAND appealable at this point in the proceeding?
B.
Did the Licensing Board have an adequate decisional basis for its summary dismissal of CAND Contention 2?
C.
Did the Licensing Board err in its refusal to defer evidentiary consideration of Contentions 6 and 207 For the reasons stated below, it is the Staff's position that the matters raised by the appeal are interlocutory in nature and not now appealable and that, in any event, the Licensing Board had an adequate decisional basis for its ruling on Contention 2 and did not err in its ruling on Contentions 6 and 20.
1]
CAND objects to the Licensing Board's ruling on the ground cnat it did not include an analysis of the reasons upon which its action was based.
(CAND Appeal, p. 1).
However, the Licensing Board had previously stated that, due to the number of summary disposition motions that were filed and the necessity for time to prepare for the October hearings, it would supply the reasons for its summary disposition rulings at a later date. See " Memorandum and Order on Pending Motions" August 31, 1981, slip op at 1.
Due to the clearly interlocutory nature of such rulings, CAND can claim no prejudice at' this time.
III. ARGUMENT A.
_CAND's Appe_al Is Interlocutory In Nature and Cannot_ _Be _ Raised At This Time.
1.
Sumary Dismissal of Portions of CAND Contention 2 It has long been held that proceedings can be conducted most efficiently if the right to obtain review of interlocutory orders is deferred to an appeal at the end of the case.. Boston __ Edison Company, et al. (Pilgrim Nuclear Generating Station, Unit 2), ALAB-269,1 NRC 411, 413 (1975) and cases cited at n.3 therein. The Commission's rules of practice explicitly provide that "[n]o interlocutory appeal may be taken to the Commission from a ruling of the presiding officer."
10 CFR 62.730(f).2.f The Licensing Board's ruling granting summary disposition of a part of CAND's Contention 2 does no more than exclude from consideration in this proceeding one of the issues CAND has sought to raise. As such, it is interlocutory in nature and not appealable at this time.
See, h,
Nortnern States Power Company (Tyrone Energy Park, Unit 1), ALAB-492, 8 NRC 251, 252 (1978) (appeal from order rejecting certain contentions held interlocutory); Gulf States Utilities Company (River Bend Station, Units 1 and 2), ALAB-329, 3 NRC 607 (1976) (order prohibiting broadening of issues by intervenor held interlocutory); Duke Power Company (Perkins Nuclear Station, Units 1, 2 and 3), ALAB-302, 2 NRC 856 (1975) (appeal from rejection 2]
There are two exceptions to this rule but neither aids CAND.
Fi rs t,
a petitioner may appeal from a Licensing Board Order " wholly denying a petition for leave to intervene."
10 CFR 92.714a(b). The intervention ri.ghts of CAND, however, have not been " wholly denied", since CAND remains as a party and other CAND contentions remain to be litigated.
The second exception permits parties "other than the petitioner" to appeal an order admitting the petitioner to the proceeding on the grounds that the petition should have been wholly denied.
of a contention held interlocutory); Puerto Rico Water Resources Authority (North Coast Huclear Plant, Unit 1), ALAB-286, 2 NRC 213, 214 (1975) (appeal by intervenor from order granting intervention and ruling on certain contentions dismissed as interlocutory); Boston Edison Company (Pilgrim Nuclear Generatir.g Station, Unit 2), ALAB-269,1 NRC 411, 413 (1975) (order rejecting contention but not ending intervenors' participation in the proceeding held interlocutory);
Pacific Gas and Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 and 2), ALAB-213, 7 AEC 999, 1000 (1974) (order rejecting certain contentinns held interlocutory in nature); Philadelphia Electric Cct. (Fulton Generating Station, Units 1 and 2), T '.B-206, 7 AEC 841, 842 (1974) (order rejecting one contention out of several held interlocutory); Potomac Electric Power Company (Douglas Point Nuclear Generating Station, Units 1 and 2), ALAB-176, 7 AEC 151 (1974) (order granting intervention but rejecting certain contentions held interlocutory).E y
In this respect, summary disposition of an issue is similar to summary judgment in a civil acticn. When a civil action involves multiple claims or multiple parties, Federal Rule of Civil Procedure 54(b) determines whether an adjudication in that action is final for purposes of appeal. Under Rule 54(b), when the court enters an order summarily adjudicating one or more but less than all of the claims, such an adjudication is interlocutory, unless the court makes an express determination of "no just reason for delay" (e.g., that an immediate appeal would not unnecessarily extend the process of litigation or multiply appeals) and for the entry of judgment.
6 Moore's Federal Practice.
156.21, at 56-1271-74 (2d ed. 1980). Absent this determination and direction, the interlocutory order is non-appealable unless made so by some special statute. Id.
. Moreover, the Appeal Board in this very proceeding has explicitly recognized the interlocutory nature of, and refused to entertain, such an appeal. On June 2,1981, CAND sought an appeal frem the Licensing Board's grant of suramary disposition of another contention. The Appeal Board dismissed the appeal as interlocutory in nature, and one which must await the L; dnsing Board's " initial decision" at the end of the case. Memorandum and Order, July 8,1981, (slip op. at 2). Accordingly, the Appeal Board never reached the merits of the Licensing Board's decision. Similarly, #AND's instant appeal of the summary dismissal of parts of Contention 2 is interlocutory in nature and not proper at this time.
2.
Licensing Board's Refusal to Defer Evidentiary Consideration of Contentions 6 and 20 The scheduling and conduct of evidentiary sessions is committed to the Licensing Board's discretion by Commission rules.
As a 4
general rule, the Appeal Board will entertain review of scheduling dec.'sions "only where confronted with a claim of due process." Consumers Power Company (Hidland Plant, Units 1 and 2), ALAB-468, 7 NRC 465, 468 (1978); see also Southern California Edison Co. (San Onofre Nuclear Generating Station, Units 2 and 3), ALAB-212, 7 AEC 986 (1974). No such claim can seriously be made here.
The Licensing Board's scheduling decision is clearly interlocutory and not appealable at this stage in the proceeding. The question decided by the Licensing Board concerns the time at which it should take evidence on the adequacy of emergency planning.
CAND asserts that the " existing incomplete state and county plans make it impossible to logically evaluate r-g-
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I However, CAllD cites no legal barrier to the taking of evidence on the l.
emergency planning issues; instead, it simply offers a conclusion that the plan is " unworkable". As the Appeal Board explained in Public Service Company of New Hampshire (Seabrook Station, Units 1 and 2),
ALAB-293, 2 NRC 660, 661 (1975):
6 In the absence of any limitation in a relevant statute or regulation, I
we are fully satisfied that the Board below reached the right result in concluding it is not legally precluded from now taking evidence l
on the... issues within its domain.... The only serious question is whether, all things considered, it should do so. This is scarcely the kind of question which might warrant our intervention.
(Emphasis in the original, footnote and citations omitted.)
See also, Public Service Company of New Hampshire (Seabrook Station, Units 1 and 2), ALAB-295, 2 NRC 668 (1975).
The Appeal Board in this case has previously refused to entertain an appeal by CAND from a scheduling ruling. ALAB-563, 10 NRC 449 (1979).
In so doing, the Appeal Board referred to the " manifestly interlocutory" character of a scheduling ruling and held that the appeal was foreclosed by the Commission's Rules of Practice. Again, CAND's appeal of the Licensing Board's ruling on the taking of evidence on contentions 6 and 20 is interlocutory in nature and not proper at this time.
B.
Tne Licensing Board Had an Adequate Decisional Basis for Summary Dismissal of CAND Contention 2.
Apart from the fact that the Licensing Board's ruling granting partial summary disposition of CAND's Contention 2 is interlocutory in nature and not appealable as of right at this time, the Licensing Board had before it an adequate decisional record for its partial summary disposition ruling.
7-On March 6,1979, the Licensing Board admitted Contention 2 which alleges:
The residual risks of low-level radiation which will result from the release from the facility of radionuclides, and particularly from the release of cesium-137 and cobalt-60, into the Susquehanna 1
River, and the health effects of chlorine discharged into the river, have not been, but must be, adequately assessed and factored into the NEPA cost-benefit balance before the plant is allowed to go into operation.
Applicants filed partial motions for summary disposition on Contention 2 on August 13 and 25, 1981. Those motions addressed, respectively, the magnitude of radioactive releases (source term) and the magnitude of the doses resulting from the radioactive releases. The Staff submitted responses supporting Applicants' motions on September 8 and 14,1981. The NRC Staff also submitted its own summary disposition motion on Contention 2 (filed September 3,1981) which went further than Applicants' motions in establishing that that portion of Contention 2 which relates to low-level radiation presents no issue of material fact. By its Memorandum and Order of September 23, 1981, the Licen4ng Board approved Applicants' motions, stating that "[t]here is no issue of a material fact to be heard with respect to the contentions." (slip op. at 3).
In support of their motions, Applicants submitted " Statements of Material Facts As To Which There Is No Genuine Issue To Be Heard", together with supporting affidavits. The Staff's motion and response were similarly supported. Those documents demonstrate conclusively the correctness of the Licensing Board's ruling.
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As to that portion of Contention 2 that questions the magnitude of the low-level radioactive releases from the Susquehanna Steca Electric Station ("Susquehanna"), the affidavit of John C. Dodds submitted in support of Applicants' motion sets forth the material facts not in dispute.
The Staff supported the material facts as set forth in that affidavit.
It shows, inter alia, that the expected amounts of radionuclides released from Susquehanna are minute and constitute small fractions of the maximum permissible concentrations under 10 CFR Part 20.
(Affidavit of John C.
Dodds, dated August 24,1981, at 4-5).
As to the issue of the magnitude of doses to the public resulting from the release of radionuclides, the affidavit of Frazier L. Bronson submitted in support of Applicants' motion sets forth the material facts not open to dispute. The Staff supported the material facts as set forth in that affidavit. The doses to the maximally exposed individual from liquid radioactive releases cited by the Applicants are less than the annual dose design objectives contained in 10 CFR Part 50, Appendix 1.
(Staff Affidavit of Edward F. Branagan, Jr. dated September 14, 1981
("Branagan Affidavit"), at 1-2).
Further, the Applicants' estimate of population doses within a 50-mile radius of the facility due to exposure to radioactive liquid releases from Susquehanna (i.e., about 0.06 person-rem) is a small fraction (less than 0.001 percent) of the corresponding population dose from natural background radiation (i.e., about 160,000 person-rem).
(Branagan Affidavit at 3). The Staff also estimated population doses within a 50-mile radius of the facility from exposure to liquid radioactive releases
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(Branagan Affidavit at 3).O By document entitled "... Notice of Appearance for the Purpose of Presenting Direct Testinoqy and Motions Before the ASLB", dated September 12, 1981, (" Notice") CAND stated its opposition to Applicants' motions as follows:
The Applicants (sic) recent motion for summary disposition on the part of Contention 2 discussed herein does not even come close to responding to the issues the citizens have raised in these proceedings. We object to their mis-directed motion and further move the ASLB to deny the Applicants' motion on Contention 2 for reasons cited above and other relevant statements made on the record. There surely is an issue of material fact involving abortior,and the Berwick nuke!
CAND also stated that it intended to present testimony by a Mr. John A.
Griffin, Sr., who would " address primarily the moral and ethical issues involved in the aftermath of abnormal releases of radiation to the environment from an accident at Berwick, that in turn will threaten women of childbearing age with the risk of bearing an abnormal child" (Notice, p.
1), and "show that abortion is on absolutely unacceptable solution to a very real radiation health problem, in the event of an atomic catastrophe at Berwick". (p. 2).E y
Dr. Branagan submitted an earlier affidavit concerning the merits of this aspect of Contention 2.
(Branagan Affidavit at 3). That affidavit addressed the amount of radionuclides to be released to the Susquehanna River from the facility, the potential doses the public may receive from those releases, and the possible risks to the public health from those doses, y
No such testimony or affidavit by Mr. Griffin has been filed with the Licensing Board.
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<e CAND has failed to address the issues raised in its own contention.
In addressing itself to the " moral and ethical issues" resulting from "a very real radiation health problem". CAND is assuming that such a problem exists, rather than presenting the Licensing Board with facts supporting its contention. As a result, CAND did not contest any of the facts set forth in Applicants' summary disposition motions.
Instead, CAND rests on the fact that the Environmental Impact Statement "does not even consider
[the] fundauental human problem" of abortion. CAND's assertion that the Environmental Impact Statement must address " moral and ethical considerations" does not address the issue as framed by CAND itself and provides no dispute with the material facts as set forth in Applicants' motion for summary disposition.
Under Commission Rules, these material facts are deemed to be admitted unless controverted by the opposing party.
10 CFR 92.749(a). Therefore, the material facts submitted by Applicant must be deemed to be admitted.
Based upon the above, the Licensing Board's order granting partial summary disposition of Contention 2 is clearly supported by the record.
Although CAND is correct that the Licensing Board has deferred giving its reasons for its rrling, this is a matter which is clearly within the scheduling discretion of the presiding officer.
C.
On the Merits, the Licensing Board's Refusal to Defer Evidentiary Consideration of CAND Contentions 6 and 20 Was Correct The authority to establish the order and timing of the presentation of evidence at a hearing is delegated to the presiding officer by Commission Rules of Practice.
It was clearly within the discretion of the Licensing Board to deny CAND's motion to defer evidentiary consideration
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of +5e contentions on energency planning until the spring of 1982.N CAND offered no good reason why the Licensing Board should have postponed the receipt of evidence on Contentions 6 and 20 and can offer no good reason why the Appeal Board should overturn the Licensing Board's decision. The purported,iustification for CAND's motion, as set forth in its moving papers, was as follows:
The existing plans are strickly (sic) on paper. The reactors are not scheduled to be operational until mid-1983. That means in actuality 1984 or 1985. There is no compelling need to rush by leaps and bounds through a public hearing before the plans are properly organized, fully explained to the communities, and feed-back received from the local agencies responsible for implimentation.
Holding public hearings on the Emergency Plans now would be premature and unwise, and any such action will be appealed. The Citizens will present witnesses on these contentions but await a decision on this motion before proceeding with preparing testimony.
(enphasis in original).
The above-quoted remarks are not relevant to the contentions at issu"..
Contention 6 challenges the sufficiency of the notification and evacuation provisions of the emergency plan proposed by Applicants; Contention 20 challenges the regulatory compliance of emergency plans submitted by Litzerne County and the Commonwealth of Pennsylvania.
CAND has the right to attempt to demonstrate, in the course of the hearing, that the emergency plans are inadequate as alleged in Contentions 6 and 20. Nevertheless, CAND does not claim prejudice in the preparation of its case on these contentions because of the proposed timing of the hearings on those conteations.
It does not y
CAND gives no rationale for its designation of next spring as the proper time for receipt of testimony on the contentions; CAND fails to demonstrate that any of its current objections will be met by
. next spring, or any other time.
i have a right to defer consideration of its contentions pending " feedback" from local agencies.
Finally, the Conraission's recent " Statement of Policy on Conduct of Licensing Proceedings", 46 FED. REG. 28533 (ftay 27, 1981) provides some guidance with respect to the Licensing Board's autnority to regulate hearing procedures. The Commission there stated:
The Commission's Rules of P actice provide the board with substantial authority to regulate hearing procedures.
In the final analysis, the actions, consistent with applicable rules, which may be taken to conduct an efficient hearing are limited primarily by the good sense, judgment, and managerial skills of a presiding board which is dedicated to seeing that the process moves along at an expeditious pace, consistent with the demands of fairness.
The Licensing Board's ruling on the scheduling of litigation of Contentions 6 and 20 is consistent with this Commission guidance, has not been shown to be unfair to, or result in undue burdens on, CAND, and was correct on the merits.
IV.
CONCLUSION The orders CAND seeks to appeal are interlocutory in nature and an appeal must await an initial decision in this proceeding.
In any event, th'e Licensing Board had an adequate decisional record on which to base its summary dismissal of CAND Contention 2 and did not err on the merits of its ruling with regard to the presentation of evidence on CAND Contentions 6 and 20.
For these reasons CAND's appeal should be dismissed in all respects.
Respectfully submitted,
'f7
,<. }v ary E. Wagner v
Cou sel for C Staff Dated at Bethesda, Maryland this 21st day of October,1981
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMI_C SAFE _TY AND LICENSING APPE_AL_ BOARD In the Matter of PENNSYLVANIA POWER AND LIGHT CO.
)
Docket ho. 50-387 ALLEGHENY ELECTRIC COOPERATIVE, INC.
50-388 (Susquehanna Steam Electric Station.
)
Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO CITIZENS AGAINST NUCLEAR DANGER 5' APPEAL ON r+NTENTIONS 2, 6 and 20", dated October 21, 1981 in the above-captioned proc. " ling have been served on the following by deposit in the United States mail, or as indicated by an asterisk thr ugh deposit in the Nuclear Regulatory Commission's internal mail system this 21st day of October,1981:
Dr. Judith H. Johnsrud Co-Director Environmental Coalition on Nuclear Power 433 Orlando Avenue State College, Pennsylvania 16801
- Dr. John H. Buck, Member, Administrative Judge Mr. Thomas H. Gerusky, Director Atomic Safety and Licensing Appeal Board Bureau of Radiation Protection U.S. Nuclear Regulatory Commission Department of Environmental Washington, D.C.
20555 Resources Commonwealth of Pennsylvania
- Mr. Thomas S. Moore, Member, P. O. Box 2063 Administrative Judge Harrisburg, Pennsylvania 17120 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Ms. Colleen Marsh Washington, D.C.
20555 Box 538A, RD#4 Mountain Top, Pennsylvania 18707 Jay Silberg, Esq.
Shaw, Pittman, Potts and Trowbridge Mr. Thomas J. Halligan 1800 M Street, N.W.
Correspondent: CAND Washington, D.C. -20036 P. O. Box 5 Scranton, Pennsylvania 18501 Bryan A. Snapp, Esq.
Pennsylvania Power & Light Company Two North Ninth Street Allentown, Pennsylvania 18101 4
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2-James P. Girason, Chairman Susquehanna Environmental Administrative Judge Advocates
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513 Gilmoure Drive c/o Gerald Schultz, Esq.
Silver Spring, Maryland 20901 P. O. Box 1560 Wilkes-Barre, PA 18703
- ilr. Glenn 0. Bright, Administrative Judge G. Rhodes Atomic Safety and Licensing Board Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 52 Washington, D. C.
20555 Shickshinny, Pennsylvania 18655 Dr. Paul W. Purdom, Administrative Judge Robert W. Adler 245 Gulph Hills Road
. Department of Environmental Resources Radnor, Pennsylvania 19087 505 Executive House
- Atomic Safety fe Licensing Board Panel P. O. Box 2357 s
Harrisburg, Pennsylvania 17120 U.S. Nuclear T,egulatory Comission Washington, D.C.
20555
- Atomic Safety & Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Secretary U.S. Nuclear Regulatory Commission ATTN: Chief, Docketing & Service Branch Washington, D.C.
20555 Mr. DeWitt C. Smith, Director Pennsylvania Emergency Management Agency Transportation and Safety Building Harrisburg, Pennsylvania 17120 g/sep)( R. Gray j Counsel for NRC Sta
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