ML20042C592
| ML20042C592 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 03/26/1982 |
| From: | Weiss E HARMON & WEISS, UNION OF CONCERNED SCIENTISTS |
| To: | |
| References | |
| NUDOCS 8203310553 | |
| Download: ML20042C592 (20) | |
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,-,c- - 03O'IM g-UNITED STATES OF AMERICAL'9g NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND* LICENSING' BOA 51D O
i "t? 29 I In the Matter of )
)
METROPOLITAN EDISON COMPANY, ET AL.) Docket No. 50-289
) (Restart)
(Three Mile Island, Unit 1) )
UNION OF CONCERNED SCIENTISTS COMMENTS SUBSEQUENT TO PRELIMINARY HEARING OF MARCH 18, 1982, CONCERNING THE " MARTIN REPORT" On March 18, 1982, the Board held a preliminary hearing to determine whether the UCS " Motion to Reopen the Record. . . "
(hereafter " Motion") of September 10, 1981, should be granted. l_/
The preliminary hearing was. essentially in the nature of a deposition, with the Board presiding. (Tr. 27, 044, 1.16-21, Weiss; Tr. 27, 051, 1.16f f, Smith 2/.
It was necessitated by the fact that the responses and affidavits produced by the NRC Staff did not dispel the questions raised by the UCS Motion and Reply 3_/ and because the Staff refused to make the cognizant authors of the so-called " Martin Report" 1/ See also Union of Concerned Scientists Reply to Staff and Licensee Opposition to UCS Motion to Rcopen the Record Oct. 30, 1981, hereafter "UCS Reply."
2_/ Unless otherwise noted, all transcript citations are to R.D. Martin.
3/ Memorandum and Order setting Preliminary Hearing, March 2, 1982, Sl. op at 3; s
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4 2 available for informal questioning by UCS, as suggested by the Board.4/
UCS will not here repeat but will incorporate the arguments set forth in its Motion and R.eply. The latter in particular sets out our views on the standards for reopening proceedings (Reply at 8-10) 5/; establishes that the pertinent substantive recommendations of the Martin Report do not appear in the drafts of the Action Plan (Id. at 11-12); that none of the'NRC previous witnesses in this case knew of the Martin Report prior to the filing of the UCS motion (pl. at 10-11). As the Board described it, the purpose of this i
brief is to present our view of how the testimony of March 18 has developed " technical basis" which'were not included in the positions presented by the previous staff witnesses.
(Tr. 27, 187, Smith). As UCS stated, our view of what the Board should consider as " technical basis" goes beyond the staff and licensee's narrow view of the meaning'of the term.
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A technical basis can be a computer model, as it was in the case of the staff's witness Jensen, or it can be four months 4/ Id. at 3-5. . 1 5/ Several months after the filing of the motion and reply, the Board Tssued its Partial Initial Decision. In our view, this should not change the standards for review since to do so would materially pre-judice UCS which had timely filed its motion. In any case, the most ,
appropriate general criterion would seem to be the materiality of the !'
evidence to the issues before the Board - a combination of the signifi-cance of the issue and the ability of the evidence to affect the decision.
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of intense investigation of the TMI-2 accident plus many years of experience in the operation and inspection of l working nuclear plants. (Tr. 27, 193 - 27, 194, 27, 042 - ,
27, 050, Weiss) . UCS has never claimed nor believed that the authors of the Martin Report had knowledge of some hitherto secret fact not available to other diligent staff members. What we have consistently argued is that the significance of the Martin Report is that a group of very ,
qualified staff members who performed the NRC's detailed ,
investigation of the TMI-2 accident, and who came to the task with years of pertinent experience reached conclusions that agree with UCS's contentions on a number of central
! safety issues raised by UCS in this proceeding and in many cases for the same technical reasons advanced by UCS.
(Reply at 10-11, 13). This is in stark contrast with the previous staff witnesses who did not closely study the TMI-2 accident, had little if any practical experience in the relationship between equipment failures and operator behavior nor particular knowledge of plant and component design and who dismissed the UCS reasoning out of hand.
This Board was faced time and agcin in this case with I '
the need to make a choice between competing technical arguments and reasoning. While in many cases acknowledging the strength of UCS's positions, it opted on the pertinent questions to accept the positions of the staff aF articulated by the ;
previous staff witnesses on whose testimony the staff case i
! must stand or fall. Had the Board known at the time it
a 4 reached its decision that another group of staff members, qualified on the relevant implications of the accident had agreed with UCS for the technical reasons discussed more fully below, would it have reached the same conclusions on these close questions? As a practical matter, that is now the issue because after months of trying in every way to prevent UCS from questioning the Martin Report authors, the staff finally produced them pursuant to the Board's order.
The Martin Report: It's Authors, Their Qualifications, It's Preparation The authors of the Martin Report appearing on March 18, were Robert D. Martin, Thomas T. Martin, Dorwin R. Hunter, Anthony N. Fasano and Donald C. Kirkpatrick. Their prior experience and professional qualifications are attached to the NRC Response In Opposition'to Sholly and CS Motions to Reopen the Record and for.Further Relief, Sept. 30, 1981.
Briefly, Robert D. Martin is now Deputy Director of Region II. He was the leader of the Operations Team for the OIE investigation of the TMI-2 accident. Prior to that, he has 20 years of experience as a reactor operator, inspector, i license examiner and teacher of nuclear plant systems. Mr.
Kirkpatrick is an inspection specialist and nucl' ear engineer with experience in design, operation and testing. Mr. Hunter I is an Inspection Specialist, has been an operator and training l
l supervisor and has experience in design review, testing and operation of commercial PWR's. I' is certified to operate a series of naval and civilian reactors and has been working l
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. 5 in this field for over 20 years.
Thomas T. Martin is the acting Director of the Division of Engineering and Technical Inspection, Region I. His experience from 1963 includes work as a naval officer, a commercial nuclear plant engineer and a reactor inspector for pre-operational and operational plants. Mr. Fasano is the Chief of the NRC's resident section at Three Mile Island. His experience dates from 1953 and includes over 10 years as an inspector.
These men were selected to perform the NRC's intensive investigation of the operational aspects of the TMI-2 accident and wrote those portions of the OIE Report, NUREG - 0600.
(Tr, 27, 055, 27, 061, 27, 067) T' hey represent a wide spectrum of relevant experience, including plant dynamics and transients (Mr. Hunter), (Tr. 27, 061) , great skills in the area of pres ~ume'd diff'iculty with mechanical components
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(Mr. Fasano) (Tr. 27, 061) ,' accident analyses ~(Mr. Martin)
(Tr. 27, 066) , reacto'r physics, core engineering and' general engineering, (Mr. Kirkpatrick) (Tr. 27, 066), reactor engineering n familiarity with the B&W design, (Mr. R.D. Martin) (Tr, a'd 27, 067).
After completing NUREG-0600, which required 4 months of
" intense focus" on TMI-2, (Tr. 27, 055,,27, 064-27, 069) they wrote the Martin Report to express their conclusions and recommendations (Id.) They had conducted during their investigation 400 interviews and reviewed all available hard data for the first 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of the accident. (Tr. 27, 069)
6 They met together and deliberated collegially for approximately 3 days, went home to their various stations and worked separately, then met again for another two days to complete their report. (Tr. 27, 067-27, 069, 27, 173, T. Martin).
The pertinent recommendations of the Martin Report and their relationship to the UCS contentions are as follows:
Martin Report UCS Contention C. I.C. (4 ) , p.23 3 Pressurizer heater Pressurizer heater system should be associated controls classified as safety and instruments should be classified as safety shouldtbe safety grade grade C.I.C.(2), pp. 21-23 5, PORV.should receive FORV block valves, review with performance associated instruments tests to demonstrate its & controls should be use for low and high safety grade pressure boundary,. applying as is appropriate 10 C.F.R. 50, App.A.,GDC,1 13, 14, 15, and 30 PORV and all valves constituting .
reactor coolant pressure boundary should be re-evaluated for safety grade (functional and seismic) classification.
C.I.C. (3) , pp. 22-23 5, PORV block valve chould same as,above be upgraded to functional safety grade equipment C.I.b(6) pp. 19-20 10 Provide a ' lock-in' feature Modify TMI design so on the ESFAS such to prevent that operator action inappropriate operator defeat cannot prevent the of the ESF equipment completion of an automatically-initiated safety function i
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C. I. a (1) , p.12 14 In core thermocouples All systems which can should be designated cause or be called upon safety grade to mitigate an accident should be classified safety-grade C.I.a(17). p.17 3 and 14, Upgrade pressurizer described above heater level and temperature instruments and displays to safety grade The Martin Report authors have never had any discussion with anyone responsible for preparing the Action Plan concerning the technical bases for TMI-2 their recommendations or any reason why they were not accepted. Ltr. 27, 070-27, 074.)
The testimony was limited to discussion of the bases the Martin Report authors had'for their recommendations when they were prepared. (Tr. 27, 095-27,101).
When they used the word " safety-grade," it connoted a
" spectrum of specific design and implementational requirements,"
a " substantial quality upgrade in the engineers design and installation requirements" (Tr. 27, 102) of the entire system in question, including instruments, controls, etc.
(Tr. 27, 125-6, 27, 133, 27, 149.) " Functional" safety grade means that the system in question should be able to perform its intended function as well as to retain its physical integrity. (Tr. 27,125). These definitions and their implications are remarkably similar to what UCS has
! contended throughout this proceeding. There can be no l
question-but that simply providing a connection to emergency l
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- 8 power supplies does not constitute the substantial quality improvement envisioned.
Pressurizer Heaters, UCS Contentions 3, 4 Martin Report recommendation C.I.c.(4), p. 23 (" problem" stated, page 20) , Partial Initial Decision ("PID"), 748-757, UCS Proposed Findings ("PF") 38-71, UCS Reply Findings
("RF") 59-65.
The impact of the testimony of March 18, 1982, must be considered in concert with the UCS findings and reply findings and the PID, in order to identify the heart of the issues in controversy. In view of the limitations on the time and length of this brief, we ask the Board to review those findings as it considers the issues.
The Martin Report ("MR") recommends classifying the
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pressurizer heaters as safety' grade. (M)R. at 23). The
" problem" this responds to is the failure of'non-safety
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grade equipment to function properly during the accident.
"The accident has shown that such equipment is required to be functional to mitigate circumstances encountered and/or to allow for diversity of action." (M.R. 20, Tr. 27, 085).
This non-safety equipment such as pressurizer heaters was used and was necessary to be used. (Tr. 27,'087). The pressurize heaters failed not only during the accident but had a hictory of failure from tripping in the circuitry apparently related to their lack of environmental qualification.
(Tr. 27,087-27,090)
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l The thrust of the testimony was that it is extremely difficult, as UCS contended, to control prenbute with the RCS in a solid water condition and that operatcrs should not be forced to contend with either those problems or with the
" distraction" of trying to get a bubble back into the pressurizer while they are in the middle of an accident. (Tr. 27,092-27,094, 27,104,, Hunter) . Based on the accident investigation and much relevant background and experience, the maintenance of a bubble in the pressurizer is critical. (Tr. 27, 104-5,
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Hunter) The authors keyed on natural clirculation (Tr. 27,104, Hunter). They were concerned about the operator having to cope over prolonged periods with complicated: actions'as are required in solid operation, which would have "substantially.
aggravated" the TMI-2 situation. (Tr. 27,104; See also Tr.
2 7,10 7, ~ Hunter ,~ (it requires "100%" of cperator.
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2 7,10 6',-
a'ttention.)). 6/ --
In addition, during solid operation, there is a likelihood of lifting the safety valves.which one.wants to avoid since there is always a chance they won't reseat. This makes the bubble "very very important for routine, normal operations."
(Tr. 27,107-8, Hunter) .
6/ The witness refers specifically to the critical need for the bubble in a loss of offsite power event. In context, it is apparent that he is saying that we must look beyond merely what happened at TMI-2 where there was no loss of offsite power and both increase reliability and connect to on-site power. These are both standard for safety-grade equipment. Ironically the Action Plan does not address the quality and environmental qualification problems. Thus, the provision of a connection alone means that non-functioning heaters connected to on-site power-precisely what UCS contended.
10 In contrast, the PID relied heavily on the availability of pressure. control via the HPI pumps in a water-solid condition, despite UCS's testimony about the serious safety disadvantages thereof. (PF 60) UCS testified about the important safety advantages of making the system which the operator is familiar with sufficiently high-quality be that 3 it can be relied upon. (Tr. Hearing, 8185-6, Pollard) . This was a general basis that pervaded the Martin Report, (Tr.
27,092ff, 27,106ff, 27,137, 27,145-6) and is a technical basis that reflects knowledge of the relationship between operators and equipment during an accident and under normal conditions. UCS also talked about the need to prevent unnecessary opening of the safety valves, as these witnesses did.
Moreover, the connection of the heaters to on-site power does nothing to even address the reason why the heaters failed during and prior to the accident. One test or even several tests of pressure control in a water solid condition, as required by the PID at 755 will not alleviate these fundamental problems. During 'an accident, reliance on this mode for cooling is a serious detriment to safety, given the other demands on the operator and the probability of lifting the safety valves. There should be no question but that maintaining a bubble in the pressurizer is important to safety, as UCS contended.
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PORV and Block Valve, UCS Contentio'n 5 Martin Report becommendations C. I.C (2) and C. I .C. (3) pp 21-23, PID 744-791, UCS PF 148-240, UCS RF 66-77.
The Martin Report recommendations were based on the clear and significant role of the PORV in the accident (Tr.
27, 119), both in terms of its initial malfunctioning and subsequent malfunctions (Id.) The " driving impetus" was that any valve which is part of the reactor coolant boundary should be re-evaluated as safety grade. (pd.) In addition, th3 PORV is used for overpressure protection at both low and high temperature (and pressure) (Tr. 27,120-27,121). For the latter functional use, clearly an "important function,"
(Tr. 27,121, 1.3-4) you seek redundancy (Tr. 27,121-27,122).
For the PORV particularly what was sought was clearly " functional" safety grade. (Tr. 27,125). As far as its role in the RCS pressure boundary, a valve failure introducing a break in the RCS in that unique location with unique consequences deserves prompt attention. (Tr. 27,124).
As for the block valve, it actually lost power during the accident. (Tr. 27,128-9, 27,129-130, Hunter). Operation of these valves was critical to many of the operational maneuvers.
(Tr. 27,132). Loss of control of the block valve is of vital concern because if the PORV fails to close, the break could not be isolated and if the PORV failed to open, the required operational maneuvers could not be performed. (Tr.
27,131-2).
- These questions were all raised by UCS. While the Board appeared to agree that the non-safety PORV is inconsistant l
12 with GDC 14, it ordered no action to correct this (PID 785-786), yet this was the very reason why the Martin Report i .
l recommended prompt attention to the PORV. (Tr. 27,124).
The Board apparently disagreed that the PORV fr. needed for overpressure protection at lowtemperature, accepting witness Jensen's argument that it is a " backup" to operator action. (PID 790). But see our response to the Affidavit of Walton L. Jensen, Jr. , UCS Reply at 19-22, and attachment demonstrating that, as the Martin Report authors recognized, (Tr. 27,117) and UCS argued, (PF 198-207) the PORV presents a potential single failure when needed to protect against overpressureization at low temperatures.
There are transients for which operation action is needed in less than 10 minutes', thus, according to NRC criteria, the PORV is not a back-up. (UCS Reply at 20-22) .
Moreover, this function cannot physically be performed by the safety valves. (Pollard, ff.Tr. 9027 at 5-10, 5-11) .
Moreover, it is apparent that the Martin Report authors agree with the general position espoused by UCS that if particular equipment is in fact to'be used in accident mitigation as the emergency procedures call for'in the cast of the PORV, (UCS PF 224, 227) they should be safety grade so that they are reliable and can be relied on. (Tr.
27,132, 27,134, 27,154-5). Operators don't trust non-safety equipment. (Tr. 27,152 (T. Martin). Nor is it an acceptable substitive to rely on the safety valves, as the Board has
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suggested. (PID 753). It is a " basic precept" that sr.fety systems - including safety valves should not be unnecessarily challenged. (Tr. 27,113, 27,107-8, Hunter). See also UCS PF 188, 208-214. If they fail to reseat, the loss of coolant cannot be stopped.
The Martin Report author's evidence, in combination with earlier UCS evidence should convince the Board that the PORV and block valve should be directed to comply with GDC 14 and that the PORV should be made " functional" safety grade. This is even more unimportant if bleed-and-feed is to be relied upon as the system which compensates for the problems with assuring maintenance of natural circulation, the lack of high points vents non-safety-grade emergency feedwater system and non-safety-grade. pressurizer heaters.
The basic equipment used for bleed and feed, including the PORV, must be safety-grade. The safety valves have simply never been tested or qualified to perform the many openings and closings that would be called for under bleed and feed and the current testing program cannot simulate these conditions.
(PF 210-211).
ESFAS Lock-In, UCS Contention 10 Martin Report Recommendation C.l.b. (6) , pp 19-20, PID 722-747, UCS PF On this issue, the Martin Report authors testifyed to ,
the following pertinent propositions:
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- 1. If the operator has to become intimately involved in performing manuevers during an accident he is no longer able to objectively review the situation. .
(Tr. 27, 140-1)
- 2. The recommendation - like UCS's - was for a physical hardware lock-in device to
" prevent" interference with the " operation" of ESF equipment. (Tr. 27,141, Hunter).
This comes from people familiar with the capabilities of and complications presented to operators during accidents. None of the previous witnesses on this subject could claim similar expertise.
- 3. Interlocks to perform this general task are used at other plants and are not a particular source of failure (Tr. 27,142-27,144, Hunter), in contrast to tne unsupported fears of the previous witnesses.
(PID 741).
- 4. Such a system could be over-ridden under pre-determined management controls. (Tr.
27,142, Hunter). This responds to the licensee's fear about permanently " locking out" the operator. (PID 743, 744, 746) 7/
The weight given to these recommendations should be much greater than thatiacc6rded the testimony given by previous witnesses who never even considered Mhe' implications of the accident. (UCS PF 263-266).
7/ In any case, UCS never advocated permanent lock-out of the operator--just interlocks which prevented him.from terminating the operation of ESF until pre-determined conditions stipulated in the design basis are met. UCS PF 274,301-302. And no witness was ever able to give one example of any harm that might result from such a lock-in system. UCS PF-271-285.
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. 15 Incore Thermocouples Pressurizer .
, Level and Temperature Instruments, UCS Contentions 14 Martin Report Recommendations, C.I.a(1), p. 12, C.I.a (17), p . 17 ,
PID 971-1004, UCS PF 472-549 No extensive discussion will be offered on these subjects.
The bases for making the pressurizer safety-grade, discussed above, apply equally to its instrumentation, since it is the functioning of the equipment, in this c as e , the pressurizer ,
that is important. (Tr . 2 7,126 , 1.16-20, 2 7,149 ) See also Tr . 2 7,149-50 : the operators during the accident didn 't believe the indications from non-safety instr uments ; Tr . 2 7,15 2 : this additionally complicated the accident. The same would not be true in the future.
The common technical and logical thread running through all of the Martin Report .Reco^m mendations beco.mes quite clear throughout this general section of the testimony, Tr. 27,144-27,156. That is, if instrumentation or equipment is beneficial or important, it should be safety grade so .that it can be relied upon. (E.g. Tr. 27,154-5, 27,145-6).8/ This is irregardless of whether there is another theoretical way of controlling the plant--such as water-solid operation. In f act, many of the pertinent suggested upgrades were precisely to avoid water-solid operation . (E.g. Tr. 27,149-50) This is probably the key point which the previous staff witnesses 8,/ The f act that the operators are told to use -equipment i in their emergency procedures is part of the reason. Tr.
l 27,156. This , of course, was a major point made by UCS. (UCS PF 210, 215 -216, 219, 2 25 , 22 7, re : PORV)
16 disregarded in their reliance on theory over practice and history: if a system is used to perform important functions, it should be highly reliable, hence saf ety-gr ade . 9/
This is also the general thrust of UCS Contention 14.
Systems actually used to mitgate accidents ( and TMI-type accidents in particular ) or which can cause accidents should be safety grade .
The Staff witness on this subject had no direct experience with TMI-1, nor knowledge of the plant systems. (UC.S PF 493 ) .
In our review, his general qualifications were extremely weak (UCS PF 493-524). At best, he constructed a facially logical meaning of the terms safety-grade and important-to-safety which has little or no relationship to actual conditions during an accident or the stresses f aced by operators during such conditions.
Staff Witnesses Jensen and Sullivan We have briefly described above a comparison of the relative experienco and qualifications of Mr. Conran and the Martin Report authors. The Board should see generally, the UCS Proposed Findings on Contention 14, UCS PF 472-549.
The Staff 's witness in both the pressurizer and PORV issues was Mr . Jensen . He had very little knowledge of the accident 9/ The testimony also casts doubt on Mr . Conran 's understanding of safety-grade as applying only to equipment " required "
for " critical" safety functions. (PID 976). Could all of the authors of the Martin Report be wrong and Mr. Conran rig ht ? One must conclude so to sustain the Staff position both with respect to how the term has been applied in the past and what lessons should be learned from the accident.
Comparing Mr . Conran 's pertinent qualifications (UCS PF 493-524) with those of these witnesses , we suggest that the answer is clear.
A
. 17 (UCS PF 21-23, 69), did not consider the conditions present
- cparing the accident (UCS PF 65), and has experience almost entirely'in computer modeling. Nether did Mr. Sullivan , the Staf f 's w'i tness an UCS Contention 10, base his testimony as an evaluation of the accident and its implications. (UCS PF
-~263-266, 273). Thus, their " technical bases " were abstract
_< ' nd theoretical in contr ast to the practical bases presented a
a in 'tl e< Martin Report and in the testimony of March 18, 1982.
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[ ,Almobt without exception, each time one of the Martin Report authors described a recommendation, he related it directly
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operators and component f ailures in real plants . These are credibl'e dechnical bases--more credible than computer models, particularly when one considers that the licensee 's and staff 's basic position now is that the TMI-2 accident taught us to focus on the role of operators .
1 Conclusion Until now, t h'is Board has only heard from those who
'soug ht to justify-the d_ecisions made in the Action Plan ,
-Q one group of witnesses hermetically sealed from the lessons
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7: s s r,
. learned as seen by the OIE investigation team. (Tr. 27,191 ff'.
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l- .-. ) Weiss ) . : . Their testimony was prepared after the Action Plan f
! , was written l af ter portions were hardened and UCS was the "N
s .
., "advers ary " . Now the. Board has heard from another group y i;.
rof w'itnesses who reached conclusions reraarkable similar to i.+
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' ! UCS 's , of ten for the same reasons, who reached them af ter
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. 18 intense investigation of the accident and years of practical eNoerience and before the positions had become adversary. They had no interest at the time the recommendations were made I
. in " disproving " UCS . The Board should weigh this testimony r and the recommendations heavily . [
UCS urges the Board to re-open the record. l Respectfully submitted, ,
! Ellyn' R. Weiss '
Harmon & Weiss 1725 I Street, N .W .
Suite 506 t Washington, D .C . 20006 (202) 833-9070 DATED : March 26, 1982 l 6
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of ) '
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
) (Restart)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
CERTIFICATE OF SERVICE I hereby certify that on this 26th day of March 1982, a copy of the Union of Concerned Scientists Comments Subsequent To Preliminary Hearing of March 18, 1982, Concerning the " Mar tin Report" was mailed first class postage pre-paid to the following :
Ivan W. Smith, Ch airm an. Judga John H.. Buck Atomic Safety and Lic~ensing Atomic ~ Safety and Licensing Board Panel - Appeal Board Panel U . S . Nuclear Regulatory O '. S. Nuclear ' Regulatory Commission- Commission Washington, D.C. 20555 ~ ~ ~
Washington D.C.~20555 Dr . Wal ter H. Jordan Judge Christine N. Kohl Atomic Safety and Licensing Atomic Safety and Licensing Board Panel AppealBoard Panel 881 West Outer Drive U.S. Nuclear Regulatory Oak Ridge, Tennessee 37830 Commission Washington, D.C. 20555 Dr. Linda W. Little Atomic Safety and Licensing Thomas Roberts, Commissioner Board Panel U.S. Nuclear Regulatory 5000 Hermitage Drive Commission Raleigh, North Carolina 27612 Washington , D .C . 20555 Professor Gary L. Milhollin ~ Nunzio .Palladino, . Chairman 1815 Jefferson Street U.S. Nuclsar Regulatory . j Madison, Wisconsin 53711 Commission-Washington, D.C. 20555
. Judge Gary J. Edles, Ch airm an Atomic Safety and Licensing Mrs . Mar jorie Aamodt Appeal Board R.D. #5 U.S. Nuclear Regulatory Coalsville, Pennsylvania 19320 Commission Washington, D.C. 20555
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Robert Adler, Esq. Mr. Marvin I. Lewis Assistant Attorney General 6504 Bradford Terrace 505 Executive House Philadelphia, PA 19149 P.O. Box 2357 Harrisburg, Pennsylvania 17120 Louis Bradford Ms. Gail B. Phelps Three Mile Island Alert 245 West Philadelphia Street 325 Peffer Street York, Pennsylvania 17404 Harrisburg, PA 17102 Walter W. Cohen, Esq. Mr. Robert Q. Pollard Office of Consumer Advocate 609 Montipelier Street 1425 Strawberry Square Baltimore, Maryland 21218 Harrisburg, Pennsylvania 17127 Jordan D. Cunningham, Esq. Counsel for NRC Staff Fox, Farr & Cunningham Office of Executive Legal 2320 North Second Street Director Harrisburg, PA 17110 U.S. Nuclear Regulatory Commission Thomas J. Germaine, Esq. Washington, D.C. 20555 Deputy Attorney General Division of Law - Room 316 George F. Trowbridge, Esq.
1100 Raymond Boulevard Shaw, Pittman, Potts &
Newark, New Jersey 07102
~
Trowbridge
- 1800 M Straet, N.W.
Dr. Judith H. Johnsrud Washington, D.C. 20036 Dr. Chauncey Kepford -
Environmental Coalition on Docketing and Service Section Nuclear Power Office of the Secretary 433 Orlando Avenue U.S. Nuclear Regulatory State College, PA 16801 Commission Washington, D.C. 20555 Judge Reginald L. Gotchy Atomic Safety and Licensing Mr. Eric Van Loon Appeal Board Panel . Union of Concerned Scientists U.S. Nuclear Regulatory 1384 Massachusetts Avenue Commission Cambridge, MA 02238 Washington, D.C. 20555 Victor Gilinsky, Commissioner John A. Levin, Esq. U.S. NRC -
Assistant Counsel Washington, D.C. 20555 Pennsylvania Public Utility Commission Victor Gilinsky, Commissioner P.O. Box 3265 U.S. NRC Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 John Ahearne, Commissioner Peter Bradford, Commissioner U.S. NRC U.S. NRC Washington, D.C. 20555 Washington, D.C. 20555 Mr. Steve Brooks Public Information and & df ' C Resource Center EllydFR. Weiss lo37 Maclay Street Harrisbureo PA 17103