ML20054N028
| ML20054N028 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 07/14/1982 |
| From: | Finamore B, Weiss E HARMON & WEISS, National Resources Defense Council, Sierra Club |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8207150283 | |
| Download: ML20054N028 (21) | |
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UNITED STATES OF AMERICA / )
NUCLEAR REGULATORY COMMISSION <
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In the Matter of ) ;
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UNITED STATES DEPARTMENT OF ENERGY )
PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537 ,
TENNESSEE VALLEY AUTHORITY )
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(Clinch River Breeder Reactor Plant) )
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INTERVENORS, NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE SIERRA CLUB, PETITION FOR INVESTIGATION Pu rsuant to 4 2 U.S.C. y 2232 and b 2236, 10 CFR'332.206 and 50.100, and in recognition of the Commission's inherent f
,i supervisory authority, Intervenors Natural Resources Defense j Council, Inc. and the Sierra Club (hencef orth "NRDC" or I
"Intervenors") hereby' petition /che Commission to institute an investigation of Applicants Project Management Corporation, Department of Energy and Tennessee Valley' Authority (the 4
, ,a f
" Applicants") in order to determine whether these Applicants are fit to hold an NRC license for the Clinch River Breeder Reactor Plant ("CRBR").
I. In tr oduction I
L NRDC has uncovered two internal documents of Applicants 2!
indicating a concerted ef f ort to conceal crucial safety
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1/ These documents were recently obtained by NRDC in the course of disco'rery for the CRBR licensing proceeding. ,,
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8207150283 820714 PDR ADOCK 05000537 G PDR
information in a manner that calls into question the character of the CRBR Applicants. In addition, the Applicants' deliberate omissions call into q uestion the fundamental reliability of the information which the Commission is using to assess the safety, environmental impact, and site suitability of the CRBR.
We believe it imperative that the Commission itselt initiate and oversee an immediate investigation by the Staff into the implications of these documents. The Applicants are now importuning the Commission for the third time to circumvent the NRC Jicensing process to allow Applicants to begin work at Clinch River before the safety and site suitability issues have been resolved. If, as these documents indicate, the Applicants are systematically purgitig the technica] record of mention of uncertainty and inadeq uacies in their safety analyses, they do not meet the character requirements of the Atomic Energy Act, and thus are not fit t o h old a n NRC 3icense or obtain an exemption pursuant to 10 CFR S 50.12. Intervenors submit that an immedia te investigation by the Commission is necessary before it permits any CRBR site work or construction to Legin.
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II. The Facts and Bases f or NRDC's Petition Tne first document uncovered by NRDC, which displays a l
proposal by CRBR personnel to cover up damaging weaknesses in the Applicants' safety analysis, is a memorandum from l
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W. R. Rhyme, Chief of the Licensing Branch, to Anthony R. Buhl, Assistant Director f or Public Safety, entitled "NRC TLTM Letter" (April 6, 1977) ( At tachmen t "A"). ,
1 This letter concerns the Applicants' proposed features, or
" margins," to accomodate core melt accidents at the Clinch River plant. The acronym "TLTM" refers to " third level thermal margins," reflecting the f act that the Applicants consider CRBR core melt accidents to be incredible. Under Applicants' interpretation, such accidents need not be considered as " Class 8" accidents and included in the " design basis"2/ of the plant, which would require additional safety margins. The Rhyme memorandum demonstrates how the chief licensing of ficer proposed to convince NRC that core melt accidents are not credible.
The memo reads in part:
I believe that we should take a firm stand now to prevent or at least minimize turning TLTM evaluations into a class 8 event. [3/]
I recommend:
- 2. That we not answer a single q uestion explicitly! Rather, we update the scenario in the TLTM report where we agree that there are inconsistencies, inadeguacies, etc., i.e.,
document unreal scenarios in the report only.
Ho weve r , we should not report sensitivity studies or other information Just because NRC asked for it. Planned R&D should be adequately described in the report. [ emphasis added]
2/ The q uestion of which accidents should be within the CRBR cesign basis is a major area of dispute in the CRBR licensing proceeding.
3/ The Applicants' strategy was apparently successful. Core melts are not now within the CRBR design basis,
i Despite this rather shocking attempt by the CRBR Chief of Licensing deliberately to omit crucial evidence concerning inadeq uacies and inconsistencies in its core melt safety ana]ysis, NRDC has been unable to unearth any attempt by the Applicants to correct the situation. To the contrary, a second memorandum, written a month later by the CRBR chief engineering of ficer, proposes that the same policy of distortion and omission be applied to the Applicants' analysis of severe 1
nuclear explosions in the CRBR.b!
This memorandum from the chief engineering officer of the Clinch River projectb! to the Chief of the division responsible for planning, development, coordinating and executing policies and plans in the areas of public safety, environmental af f airs, nuclear safeguards, licensing, and reliabilityb/ concerns a report numbered ANL/ RAS 77-15 prepared by Argonne National Laboratories. The Argonne report 4/ Memorandum from Donald R. Riley, Assistant Director for Engineering, CRBRP Project, to Anthony R.'Buhl, Assistant Director f or Public Safety, CRBRP Project, " Review of ANL/ RAS 77-15, SAS-3D REPORT, May 27, 1977 (Attachment "A").
5/ The Engineering Division, headed during the pertinent time by the author of this memo, is responsible for management of the design, engineering, and fabrication of systems, processes, eauipment, and facilities, including q uality, cost estimates, schedule, and research and development activities. CRBR PSAR, 1.4-5 (Am. 66, March 1982).
6/ Id.
I in question is one of the f undamental underpinnings of the CRBR accident analysis. It constitutes the principal technical documentation for the validity of the computer code (SAS-3D) used to calculate the occurrence potential, accident progressions, and nuclear explosive potential of the CRBR core.2/ The Riley memorancum calls unambiguously for the systematic deletion from the Argonne report of " negative" information that would presumably interfere with the licensing of the facility. For example:
General Comments
- 1. The subject report is not acceptable because the information is presented in a yery negative manner, particularly Chapter 2. The overall conclusion derived from Chapter 2 is that significant uncertainty exists in the Project's knowledge of all the major phenomenon which contribute to the initiation phase of a loss-o f- f low (LOF) accident for an end-of-eq uilibrium cycle (EOC) core. The report should not only present to NRC our current understanding of the LOF/EOC accident and the basis for this knowledge, but also the results and descriptions of the SAS-3D analysis. This report should be written in a straightforward, positive manner.
- 2. Any reference in this report to the need for additional work either experimental or analytical should be deletea. This type of information is not appropriate for transmittal to NRC.
7/ See CRBRP-3, Hypothetical Ccre Disruptive Accident Consideration in CRBRP, Vol. 1, Energetics and Structural Margin Beyond the Design Base, 2 Jan. 1979, Rev. 3, Aug. 1981 and 4 March 1982; see in particular pp. 1-4 and C-3.
Specific Comments Chapter 9 - This chapter which presents the conclusions should be completely rewritten.
Not only does this chapter support Chapter 2, i.e., the Project does not understand the LOF/EOC event, but it also presents to NRC a list of additional experiments which should be performed, see comments G3 and G2.
Recommendation The critical chapters 1, 2, 7, 8 and 9 shoodl be rewritten to a) present a positive, real assessment of the LOF HCDA, b) delete any reference to additional analytically (sic) or experimental work and c) incorporate the preceding commments.
Until this is accomplished, Engineering does not recommend transmittal of this report to NRC.
Memorandum, pp. 1-2, 4 (emphasis added).
Although the memorandum was written in 1977, the Argonne Report is still the primary documentation of the validity of the SAS-3D code.0/ Even were the underlying technical issue not a major one as it is in this case, the fact that an Applicant (or its highest technical management personnel) would direct that NRC be kept purposely ignorant of the limitations of its safety analyses should disquality that Applicant from 4
holding an NRC license.
l l
l 8/ It is relied upon in the latest pertinent licensing documents (a) General Electric Co., "AN ASSESSMENT JF HCDA ENERGETICS IN THE CRBRP HETEROGENEOUS REACTOR CORE,"
CRBRP-GEFR-00523, Dec. 1981, p. 1-3, Chapter 3 and Appenaix A; (b) US DOE, CRBRP-3, supra n. 7; US DOE, " Final Environmental Impact Statement, Liquid Metal Fast Breeder Reactor Program (Supplement to ERDA 1535, Dec. 1975)", DOE /EIS-0085-FS, May 1982, pp. 132, 145.
These memoranda at the highest levels of the CRBR project portray an organization so determined to obtain a license on its own terms (that is, without including major f ast breeder accidents within the design basis) that it will distort the basic scientific analyses by excising the mention of uncertainty and inadeguacy.S! Such behavior simply cannot be tolerated by NRC, which has no choice but to rely on Applicants to perform and report the fundamental technical work necessary to support an application. Reliance on the work of Applicants is even more pronounced in the case of the CRBR, which presents exceedingly dif ficult technical questions of first impression to the agency. In its consideration of the potential for explosion and core melt in the CRBR, NRC cannot look to a history of licensing experience, nor can it duplicate the work done by the Applicants. The agency has little choice but to accept much of the Applicants' work.2S!
9/ The Recommendations by the Engineering Division of the CRBRP Project Of tice also raise serious questions regarding the independent scientific integrity of the Argonne National Laboratory, carticularly its Reactor Analysis and Safety Division. While it appears that Argonne adopted some of the recommendations of the CRBRP Project Office, e.g., elimination of any reference to the need for additional experimental or analytical work, NRDC is unabla at this time to determine the f ull extent of the CRBRP Project's influence on the final SAS-3D report. Despite our discovery request, the Applicants have not provided NRDC with tha earlier review draf t of the final report, i.e. Reference 3 of the Riley memorandum.
10/ The adeq uacy of the SAS-3D computer code developed at Argonne has international implications as well. This cod? was used as the basis for licensing at least one f oreign breeder reactor in addition to the CRBR.
J III. Applicable Law 1
NRC has had occasion to consider the ef fect of the omission of material information by those subject to its jurisdiction.
In Virginia Electric and Power Co. (North Anna Power Station, Units 1 and 2) LBP-75-54, 2 NRC 498 (1975), the holders of a construction permit f ailed to inf orm NRC of the opinion of geology experts that the site contained a geologic fault. Upon an order for the company to show cause why its construction permits should not be suspended or revoked for making material f alse s tatements, the Board found that the pertinent section of the Atomic Energy Act, $18612! (42 U.S.C. 32236), prohibits the j omission of material information in addition to the affirmative l
i submission of false information. The Board held as f ollows:
... In view of the Act's direct mandate with regard to the public health and safety an applicant or a licensee is accountable for an omission of material facts which are important to a health or safety review. The Commission in turn, has the responsibility under the Act to protect the public health and sa f ety. . . . It has clear ly and f orcefully stated its need for truthful and accurate information in order to discharge its responsibilities f or the public health and safety: ... nothing less than candor is l sufficient.
[ . . . .
l Section 186 must be read as contemplating
[that) a material f alse statement results it, in the light of all the circumstances, an applicant or licensee fails to make a timely disclosure of information which is important for purposes of the safety review
] of its submission./ See also 10 CFR S50.100. i
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2 NRC at 507-508 (citations omitted). There can be little doubt that references to the need for additional experimental or analytical work to support the CRBR accident analysis and sensitivity studies of the conclusions reached by the Applicants are "important to a health and safety r ev ie w" of the CRBR. Nor can it be said that the memoranda discovered by NRDC display the " candor" minimally req uired of an applicant for an NRC license. In affirming the Licensing Board's holding that the omission of material inf ormation constitutes a " material f alse statement," the Commission reiterated the overriding importance of full disclosure by Applicants: I
- While the legislative history of the Atomic Energy Act does not directly address whether omissions may be treated as statements, the language and history cf the Act make clear that the Commission's primary duty is to protect the public health and safety.
3 Moreover, full disclosure by Applicants and + licensees of all relevant data is vital if the Commission is to fulfill that duty. We think ... that " material f alse statement" l may appropriately be read to insure that the l Commission has access te true and full j inf ormation so that it can perf orm its job. I ! Virginia Electric and Power Co. (North Anna Power Station, Units 1 and 2) CLI-7 6-2 2, 4 NRC 4 80, 488, 489 (1976), aff'd, Virginia Electric and Power Co. v. NRC, 571 F.2d 1289 (1978). l i
The character of an applicant is explicitly made a criterion for issuance of NRC licenses by Section 182(a) of the Atomic Energy Act, 42 U.S.C. 32232. Candor, truthfulness, and reliability are certainly aspects of character which are directly relevant to an applicant's responsibility safely to design, construct and operate a nuclear power plant. The importance of accurate and complete information could hardly be more important than it is in the context of nuclear regulation. As stated by the Commission in Petition for Emergency and Remedial Action, CL1-78-6, 7 NRC 400, 418 (1978): Because NRC is dependent upon information from licensees, the Commission is particularly concerned that at first apparently inaccurate information was forthcoming from the licensee and sehseg uently complete information was delayed well beyond the requested date for response. In orcer to fulfill its regulatory obligations, NRC is depencent upon all of 1 its licensees for accurate and timely information. Since licensees are cirectly in control of plant design, construction, operation, and maintenance, they are the first line of defense to ensure the safety of the public. NRC's role is one primarily of review and audit of licensee activities, i recognizing that limited resources preclude 300% inspection. Our inspection system is not designed to and cannot assume such tasks [to provide full l inspection of construction activities]. Rather, we r eq u ir e that licensees themselves develop l l l I t
s
- 1 1-and implement reliable quality assurance programs which can assume the major burden of inspection.
Consumers Power Company (Midland Plant, Units 1& 2), CLI-74-3, 7 AEC 7, 11 (1974). We req uire instead a regime in which applicants and licensees have every incentive to scrutinize their internal procedures to be as sure as they possibly can that all submissions to this Commission are accurate. Under the Federal Communications Act, which also req uires a finding of good character on the part of applicants, the Federal Communications Commission may refuse to renew a license where there has been a f ailure to f ollow regulations, misrepresentations, or lack of candor by a licensee or one of its agents in dealing with the Commission. F.C.C. v. WOKO, Inc., 329 U.S. 223 (1946). Because the agency must depend upon the representations made to it by its applicants, the fact of s concealment is of ten more significant than the facts concealed. Leflore Broadcasting Company v. F.C.C., 636 F.2d 454, 461 (D.C. Cir. 1980) , q uoting F.C.C. v. WOKO, Inc., 329 1 U.S. a t 227.J2/ NRC Staff made all these points about the importance of applicant honesty and candor in the South Texas Project case. NRC Staff Memorandum on Standards for Evaluating Mangerial 12/ In the F.C.C. cases, the false representations and concealment have been held to make issuance of a license contrary to the public interest even if they have been made by agents for their own purposes rather than in furtherance of the licensee's interest. F.C.C. v. WOKO, Inc., supra; WADECO, Inc.
- v. F.C.C., 628 F.2d 122 (D.C. Cir. 1980).
Competence and Corporate Character, Houston Lighting and Power Company, et a l. (South Texas Project, Units 1 & 2) Docket Nos. 50-498, 50-499, May 6, 1981. As the Staff concluded after discussing several F.C.C. cases: [I]n the regulation of the nuclear industry, the NRC is dependent upon the applicant to provide thorough and accurate information, the fact any information would be concealed is far more significant than the specific nature of the fects concealed. IV. Conclusion For all the reasons stated above, Intervenors hereby petition the Commission to initiate and oversee an immediate investigation into the implications of the above-cited 3 documents for the character of the Applicants for the Clinch River Breeder Reactor. We req uest that the Commission postpone its consideration of Applicants' recently submitted third exemption req uest under 10 CFR $50.12 until completion of this investigation. i 4
Respectfully submitted, Ellyn Rg W6iss bN ( HARMON & WEISS 1725 Eye Street, N.W. Washington, D.C. 20006 (202) 833-9070
- Y Barbara A. F16amor e
^
S. Jacob Scherr Natural Resources Defense Council, Inc.
- 1725 Eye Street, N.W.
. Washington, D.C 20006
- (202) 223-8210 Attorneys for Intervenors Natural Resources Defense Council, Inc.
l and-the Sierra Club Dated: July 14, 1982 Washington, D.C. ( - - _ - - . . - _ .
g //-d / #/77 dbI ATTACHMENT A*
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__-=. File: 05.04 April 6,1977 Anthony R. Buhl, Assistant Director for Public Safety HRC TLTii L..TTER I believe that we should take a firm stand new to prevent or at least minimize turning TLTM eviluations into a class 8 event. I recorrnend:
- 1. That we re-emphasize that TLTil features are in the design base and give their description, design criteria, initiatica secuences, etc. , in the PSAR, i.e. , decur::ent real hardware in the PSAR.
- 2. That we not answer a single. question explipitly! Rather, we .-
update the scenario in the TLTM report where we agree that
. there are inconsistencies, inadequacies, etc. , i.e. , document unreal scenarios in the report only. However, v.e should not report sensitivityrstudies or other inforr.ation just because NRC asked for it. Planned R&D should be adequately described in the report. '
- 3. k'e should object officially to the NRC class 8 approach and the blacL7. ail i.: plied.
- 4. We should not unconditionally comit to the 24 hour criteria.
There is some legal precedent in that the DC Cocrt of Appeals refused to review a petition that the AEC consideration of class 9 accidents was inadequate at the Shoreham Plant. Whatever approach is decided, I believe that it should be decided quickly at the Riley/Buhl/ Caffey level. CEIGIEG SIG y;1.:.12 2. IGE W. R. Rhyne, Chief PS:L:77:425 Licensing Branch cc: D. B. Howard J . 7. N'.1 c....d o,,,,,, A. H. Hah ;en i ce1 g __.
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ENERGY RESEARCH AND DEVELOPMENT ADMINISTRATION " " ' 15 # -* I CLINCH RIVER BREEDER REACTOR PLANT PROJECT OFFICE G, /4 ? -* P. O. BOX U
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s OAK RIDGE, TENNESSEE 37830 File No. 10.08.03 MAY 2 7 577 Anthony R. Buhl, Assistant Director for Public Safety REVIEW OF ANL/ RAS 77-15, SAS- 3D REPORT
References:
- 1) Memo PS:SE:77-556, A. R. Buhl to D. R. Riley,
" Review Of ANL/ RAS-77-15," dated May 18, 1977.
- 2) Memo PS:SE:77-478, A. R. Buhl to D. R. Riley ,
et al, " Review Of ANL SAS-3D Report," dated April 18, 1977.
- 3) W. R. Bohl, et al, "An Analysis Of The Unprotected Loss-of-Flow Accident In The Clinch River Breeder Reactor With An End-of-Equilibrium - Cycle Core," ANL/ RAS 77-15 Draft, dated Mpy 1977., --
- 4) W. R. Bohl, et al, "An Analysis of Transient Undercooli'ng and Transient -
Overpower Accidents Without Scram in the Clinch River Breeder Reactbr", ~ ANL/ RAS 75-29, dated July 1975. This memorandum satis'fies commitment EN0200PS assigned in Reforcace ((2). Reference l ', ,:hich rcplaced commitment EdOl93PS assigned in e U Engineering has reviewed the subject document, see Reference (3), as requested in References (1) and (2), and provided verbal comments to PSD (Gilbert) on May 23, 1977. This memorandum transmits these comments for your information: General Comments 1. The subject report is not acceptable because the information is presented in a very negative manner, particularly Chapter 2. The overall conclusion derived from Chapter 2 is that significant uncertainty axists in the Project's knowledge of all the major phenomenon which contribute to the initiation phase of a loss-cf-flow (LOF) accident e O I h
A. ,R. auhl MAY 2 7 G77 for an end-of-equilibrium cycle (EOC) core. The report should not only present to NRC cur current understanding of the LOF/EOC accident and the basis for this knowledge, but also the results and Jescriptions of the SAS-3D analysis. This report'should forward, positive manner. be written in a straight-
- 2. Any reference in this report to the need for additionsI work either experimental or analytical should be deleted.
This type of information is not appropriate for transmittal to NRC.
- 3. All acronyms should be defined the first time they are used.
- 4. The Project Office should only receive those documents ,,
for review which contain the appropriate tables and - figures, and numbered pages. Specific Co==ents
- 1. Chapter 1 - The beginning of this Shapter should incluse a discussion of the basis for analyzing only the LOF/EOC accident versus the other accidents described in Reference (4), e. g., transient-over-power (TOP) accidents and the LOF beginning-of-cycle (30C) accident. , -
- 2. Chapter 2.1 - Delete the second paragraph, it detracts from the chapter.
- 3. Figure 2.2 - The last question on the logic flow is vague. This should be replaced with specifics or deleted.
- 4. Chapter 2.1 - On the second page, the report states, i
I "The question of initial fuel dispersal still has significant uncertainties associated with it and must be left as a major branch point in the analysis". A brief description of the exper'= ental results which show fuel dispersion shou,ld be provided at this point. s. e
- O
A. R. Suhl ! AY 0 7 G77
- 5. Chapter 2.1 - Cn the fifth page, the concept of " sodium removal race" from positive-vcid-worth region is presented.
This concept is nc: discussed in this report, therefore, this reference to the rate shculd be deleted or the appropria:e discussion included.
- 6. . Chapter 2.3 - On the second page, Henry's experiment using argon has been used as justific~ation for the Fauske slosh scenario. A brief description of the results of Henry's experiment should be provided.
- 7. Chapter 2.4.1.4 - The conclusions drawn from the TREAT tests described speculation, in this section were based on engineering e.g. the phenomenon of fuel dispersal by fission gas is highly ancertain. This report should not speculate on the results - either the test information is useful or it is unacceptable.
- 8. Chapter 2. 4.1 - In the second paragraph of the first page, a set .
of four " relevant technical issues" are defeined. These issue.s were not addfessed, in the , report and, therefore, should be deleted from the report. 9. Figure 2.10 - There is no obvious trend on this figure,_ the only obvious fact is the material becomes brittle at high temperatures. The text should be more specific.
- 30. Table 7. 4 - The energy expansion volume of 2.1 X 10 cc should be related to a CR3RP design feature.
11. Chapter 8 - This chapter does not contribute anything to the report, cherefore, it should be combined with Chapter 2, as appropriate, or deleted.
- 12. Chapter 8.1 item (a) - The last two sentences of this item which refer to the need for additional experimental work should be deleted, see General Comment #4.
- 13. Chapter 8.2 item (c) - Delete, or reword on a positive note. It appears certain that this effect must tend to mitigate consequences rather than exacerbate them.
The 33 channel vs 10 channel results prove this case.
- 14. Chapter 8.2, item (e) - Delete the last sentence.
e e e O I
v A. R. Buhl MAY 3 7 377
- 15. Chapter 5.2 item (f) - Delete this section. The report is based on the reference cora design and should net speculate on any other designs i.e., AFMS.
- 16. Chapter 9 - This chapter which presents the conclusions should be completely rewritten. Not only does this chapter support Chapter 2, i e., the Project does not understand the LOF/EOC event, but it also presents to NRC a list of additional experiments which should be performed, see comments G1 and G2.
Recommendation The critical chapters 1, 2, 7, 8 and 9 should be rewritten to a) present a positive, real assessment of the LOF HCDA, b) delete any reference to additional analytically or experimental work and c) incorporate the preceding comments. Until this is accomplished, Engineering does not reco==end transmittal of this report to NRC. If there are any questions, please congact Mr. S. Brown of-my staff. . M s A
. / i Donald R. Ril f, Assistant Director i
for Engineering
- EN:R:77-220 , CRSRP Proj ect l
9 o e e e e I
a . O CERTIFICATE OF SERVICE I hereby certify that copies of INTERVENORS, NATURAL RESOURCES DEFENSE COUNCIL, INC., AND THE SIERRA CLUB, PETITION FOR INVESTIGATION were delivered by hand this 14th day of July 1982 to: The Honorable Nunzio J. Palladino Chairman U.S. Nuclear Regulatory Commission Washington,1 D.C. 20555 The Honorable James K. Asselstine Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 The Honorable Victor Gilinsky Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 The Honorable John F. Ahearne Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 The Honorable Thomas F. Roberts Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Daniel Swanson, Esq uire Stuart Treby, Esquire Bradley W. Jones, Esq u ire Office Of Executive Legal Director U.S. Nuclear Regulatory Commission Maryland National Bank Building 7735 Old Georgetown Road Bethesda, Maryland 20814 R. Tenney Johnson, Esq u ire Leon Silverstrom, Esq u ir e Warren E. Bergoholz, Jr. , Esq uire Michael D. Oldak, Esq u ir e L. Dow Davis, Esquire Office of General Counsel U.S. Department of Energy 1000 Independence Ave., S.W. Washington, D.C. 20585
e George L. Edgar, Esq u ire Irvin N. Shapell, Esq uire Thomas A. Schmutz, Esq u ir e Gregg A. Day, Esq uire Frank K. Peterson, Esq u ir e Morg a n , Lewis & Bockius 1800 M Street, N.W. Washington, D.C. 20036 Docketing & Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 (3 copies) Leonard Bickwit, E sq . Office of General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 And by mail, postage prepaid, to the tollowing: Marshall E. Miller, Esq u ire Chairman Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission 4350 East West Highway l Bethesda, Maryland 20814 Mr. Gustave A. Linenberger At mic Safety & Licensing Board U.S. Nuclear Regulatory Commission 4350 East West Highway Bethesda, Marylano 20814 Dr. Cadet H. Hand, Jr. Director ' Bodega Marine Laboratory l University of California P.O. Box 247 l Bodega Bay, California 94923 $ Atomic Safety & Licensing Appeal Board j U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 1
e . . e-Herbert S. Sanger, Jr., Esq u ir e Lewis E. Wallace, Esq uire James F. Burger, Esq u ire W. Walker LaRoche, Esq uire Edward J. Vigluicci Office of the General Counsel i Tennessee Valley Authority 400 Commerce Avenue Knoxville, Tennessee 37902 William M. Leech, Jr. , Esq uire Attorney General William B. Hubbard, Esq uire Chief Deputy Attorney General Lee Breckenridge, Esq uire Assistant Attorney General State of Tennessee Office of the Attorney General 450 James Robertson Parkway Nashville, Tennessee 37219 Lawson McGhee Public Library 500 West Church Street Knoxville, Tennessee 37902 William E. Lantrip, Esq uire City Attorney Municipal Builcing P.O. Box 1
- Oak Ridge, Tennessee 37830 Oak Ridge Public Library Civic Center Oak Ridge, Tennessee 37820 Mr. Joe H. Walker 401 Roane Street Harriman, Tennessee 37748 Commissioner James Cotham .
Tennessee Department of Economic and Community Development Andrew Jackson Building, Suite 1007 Nashville, Tennessee 32219 7 - -
- M t*
Bsrbara A. Finamore
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