ML20063B167
| ML20063B167 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/24/1982 |
| From: | Axelrad M HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL |
| To: | NRC COMMISSION (OCM) |
| References | |
| ISSUANCES-OL, NUDOCS 8208250248 | |
| Download: ML20063B167 (21) | |
Text
1 s ?!
Okh 00CMETED <
USNRC l
-UNITED STATES OF AMERICA Nf NUCLEAR REGULATORY COMMISSION g pg y y y BEFORE THE COMMISSION gTT..
0FFICE Or 5ECiiiiAt 00 00CnElis ~ & SERV!CL
- In the Matter-of )
)
HOUSTON LIGHTING & POWER ) Docket Nos. 50-498 OL
)
South Texas Project, )
Units 1 and 2 )
LICENSEES' RESPONSE TO CCANP " PETITION TO SUSPEND CONSTRUCTION OF THE SOUTH TEXAS PROJECT" I. STATEMENT On August 4, 1982 Citizens Concerned About Nuclear Power (CCANP)- petitioned the Nuclear Regulatory Commission (Commission) for an order which, inter alia, would immedi-ately suspend construction of the South Texas Project (STP).
CCANP asserts that such an order is appropriate because th'e
" Design Review of Brown and Root Engineering Work for the South Texas Project" prepared by Quadrex Corporation in May 1981 (Quadrex Report) revealed flaws in the Project design.
HobNton Lighting & Power Company (HL&P), Project Mana-ger, acting,for itself and the other co-owners, opposes the l
Petition and requests that it be denied summarily by the j Commission. CCANP recognized but declined to follow the required procedure of filing a petition with the Director of )
l Nuclear Reactor Regulation pursuant to 10 C.F.R. S 2.206, and CCANP's arguments in favor of Commission review are l
~
B208250248 820024 8 ,
DR ADOCK 05000 .
l l
l without merit. If, instead, the Commission refers the Petition to the Director, it should be denied because the legal pre-requisites for the requested relief are not pres-ent, there is no merit to the substance of CCANP's claims, and CCANP will have a full opportunity to present its posi-tion regarding the Quadrex Report before the Licensing Board considering the application for operating licenses.
II. BACKGROUND The Quadrex Report was the result of one of the first actions taken by HL&P's newly appointed Vice President for Nuclear Engineering and Construction in early 1981. It was not performed as an audit pursuant to the STP QA program.
Instead it fulfilled HL&P's separate objective, which was to begin to assess the statur of Project engineering by ob-taining an independent review of a sample of Brown & Root
, _ engineering responses to known unique nuclear industry issues and problem areas. ,
Upon receipt of the Report, HL&P conducted an immediate review with the assistance of Brown & Root. Two items were found to be potentially reportable to the NRC, and written reports thereon were filed under 10 C.F.R. S 50.55(e) and submitted and served upon the Licensing Board and the par-ties in the operating license hearing. A third item was '
x .
orally reported to the NRC, but, as confirmed in writing, was subsequently determined not to be reportable under 10 1/
C.F.R. S 50.55 (e) .
Since Quadrex performed its review, a number of signifi-
' cant changes have taken place at STP, with the result that the Quadrex Report no longer addresses the design process being utilized at STP and that the design work examined by Quadrex is being carefully reviewed prior to release for construc-tion. Responsibility for architect-engineer functions was reallocated from Brown & Root to Bechtel Power Corporation (Bechtel) in September 1981. Immediately thereafter Bechtel commenced a detailed review of Project design. Review of the Quadrex Report was given a high priority and a special Bechtel task force performed a preliminary assessment of_the Guadrex findings. In March, 1982, the report of the Bechtel task force ("An Assessment of the Findings in the Quadrex 4
Corporation Report Dated May 1981") was provided to the NRC Staff, the Licensing Board and the parties. The Bechtel task force found that two-thirds of the Quadrex findings required no further action or would be resolved by 1/
In a recent I&E Report the NRC-Staff reviewer noted that he is currently reviewing each item in the Quadrex Report for reportability and that no addi-tional potentially reportable items have been identi-fied based on data contained in the Report. I&E Re- ,
port 82-02 (June 3,1982) at 14. ~
completion of previously planned design activities. It also found one additional item potentially reportable under 10 C.F.R. S 50.55 (e) , but subsequent evaluation determined that the item was not reportable. In addition to its preliminary assessment of the Quadrex findings by this special task force, Bechtel has been proceeding with a comprehensive review of the entire STP design, including the preparation of a detailed report on the Quadrex findings.
The Bechtel design review process is receiving close scrutiny by the NRC Staff. The comprehens.ive review is part of the process of transfer of architect-engineer responsi-bilities from Brown & Root to Bechtel which was described to the NRC Staff at a meeting on October 6, 1981. Thereafter the Staff wrote to HL&P on October 20, requiring submission of a written statement regarding Bechtel's qualifications, its OA/QC program and the plans for the transition from Brown & Root to Bechtel. In response there was a second meeting on December 10, 1981, and HL&P submitted a document entitled " Transition Program Description" on December 11.
The NRC Staff reviewed the Transition Program Description, and found the program acceptable in a letter dated February ,
l 12, 1982.
On February 12, 1982 the NRC Administrator for Region IV sent HL&P a letter pursuant to 10 C.F.R. S 50.54 (f) ,
e
requesting, inter alia, a description of the proposed program for resuming safety-related work and the corrective actions for issues raised in the Quadrex Report. The letter required that the requested information be submitted at least 60 days prior to the scheduled resumption of safety-related work. HL&P replied in a series of letters describ-ing the STP organization, the program for resolution of Quadrex concerns and the program for resumption of safety-related work. The final letter in this series (ST-HL-AE-
-833, dated May 14, 1982), provided a description of the program for resuming construction, updated the construction schedule, and stated that prior to release of any design documents for construction, Bechtel will address the " Quad-
. rex issues" associated with such documents. A letter from Region IV dated June 17 stated NRC's concurrence with the resumption of safety-related construction in accordance with the May.14_HL&P program. Pursuant to that program, non-safety-related construction resumed in June, and safety-related construction work was resumed on August 6.
The comprehensive design review, the review of Quadrex concerns and the resumption of construction are the subject of intense NRC Staff scrutiny. The Staff has stationed a resident' inspector at the Bechtel design offices in
s Houston to perform continuous surveillance of the Bechtel design review process, in, addition to the resident inspector previously stationed at the STP site. Region IV is also monitoring the resolution of the Quadrex findings, as part of its continuing oversight of the Bechtel design review.
In at least six Inspection Reports this year, the Staff has described aspects of its inspection of the Bechtel engi-neering review, including the resolution of the Quadrex findings. See I&E Reports 82-01 (March 26, 1982), 82-02 (June 3, 1982), 82-03 (April 22, 1982), 82-04 (June 3, 1982), 82-08 (July 2, 1982), and 82-09 (July 8, 1982).
Thus, resumption of construction at STP is based on designs that have been carefully reviewed by Bechtel, including ~ detailed consideration of the Quadrex find ings.
The design review process has been reviewed and approved by the NRC Staff and both the design review and resumption of construction are under continuous NRC Staff surveillance.
III. ARGUMENT A. The Petition Should Be Summarily Denied for Failure I to Comply With NRC Procedures.
As the Petition recognizes, the Commission's regula-tions require that petitions seeking,. inter alia, the suspension of licenses be filed with the Director of Nuclear.
l i
Reactor Regulation or the Director of Inspection and En-forcement, an appropriate. The regulations provide for sue sponte Commission review of the Director's decisions. ,
Petition at 5; 10 C.F.R. S 2.206. However, CCANP eschews that procedure and instead demands direct consideration of its Petition by the Commission. While the Commission has inherent authority to consider the CCANP Petition, the cases cited by CCANP are not precedents for such review. More-over, as we describe below, such an unusual step would be especially inappropriate in this case because (1) utilizing NRC Staff expertise and procedures for the initial consid-eration of the broad and complex technical issues involved would be of particular value to the Commission, and (2) there is no threat to the public health and safety war-ranting Commission intervention at this point.
.The only cases cited by CCANP involving petitions 2/
regarding individual licensees are Midland and Indian 3/
l Point 7 In neither case did the Commission directly en-tertain a petition regarding the subject license, rather r
both cases concerned Commission review of Director's deci-2/. Consumers Power Co. (Midland Units 1 and 2), CLI-73-38, i
6-AEC 1082 (1973).
3/
~
Consolidated Edison ~Co. (Indian Point Units 1,.2 and 3), CLI-75-8, 2 NRC 173 (1975).
l l
l
sions. Indeed, subsequently the Commission amended 10 C.F.R. S 2.206 to prohibit petitions for review of Direc-tor's decisions, so that under the current regulations even the petitions filed in those cases would no longer be entertained by the Commission, 10 C.F.R. S 2.206 (c) (2)
(1982). The other cases cited by CCANP are also inapposite.
In Petition for Emergency and Remedial Action, CLI-78-6, 7 NRC 400 (1978) virtually all licensees were affected and the Commission employed informal rulemaking (notice and comment) not adjudicatory procedures. The last case cited by CCANP, U.S. Energy Research and Development Administration (Clinch River Breeder Reactor Project), CLI-76-13, 4 NRC 67 (1976),
. involved Commission review of an Appeal Board decision.
Not only is there no Commission precedent for bypassing the Director, but the Commission has explicitly declined to do so in the past. In Northern Indiana Public Service Co.
(Bailly Generating Station, Nuclear -1) , CLI-78-7, 7 NRC 429 (1978), petitioners attacked a Director's decision on the l grounds that the Staff's prior positions in the licensing i
proceeding showed it could not be impartial toward the petitioners' positions. Id. at 432. The Commission denied l the petitioners' request for de novo review by the Commis-sion and affirmed-the Director's decision. The Court of Appeals affirmed the Commission decision. In upholding the l
i
+
9 e requirement-that such petitions be filed with the Director, the Court cited the importance to the Commission of having the benefit of Staff expertise and the value to the Com-mission of utilizing Staff administration. Porter County Chapter v. NRC, 606 F.2d 1363, 1372 (D. C. Cir. 1979). his Commission policy of reliance on Staff oversight of a li-censee was recently manifested in Cincinnati Gas and Elec-tric Co. (W. H. Zimmer Nuclear Power Station, Unit No. 1) ,
CLI-82-20, 15 NRC (July 30, 1982). There the Commission rejected a Licensing Board's exercise of sujt sponte author-ity, noting that the NnC Staff investigation w~as adequately addressing the relevant issues. Thus, even if CCANP's fac-tual allegations worc accurate the Petition still should have been addressed to the Director for decision.
However, CCANP's factual allegations are not accurate.
The CCANP Petition is virtually identical to the petition filed with the Commission and subsequently withdrawn by Citizens for Equitable Utilities (CEU) on October 29, a
1981.-4/
The many material changes in circumstances that have occurred over the nine months since CEU filed its petition are ignored by CCANP. One example is CCANP's rationale for 4/ CEU later withdrew from the operating license proceed-ing. Its June 10, 1982 letter cited among the reasons for such withdrawal " constructive steps taken by HL&P
.affecting the safety and efficiency of the Project."
! (Letter from Mrs. Buchorn of CEU to Mr. Jordan of HL&P).
j i
l 1
1 I
seeking Commission (as opposed to Director) consideration of its Petition: that "[t]he Staff has made no effort to secure for itself any special review authority over re-sumption of safety-related work. . . . Petition at 5.
As' outlined in the background discussion above, con-trary to CCANP's assertion, the Staff has exercised special review over the resumption of safety-related work. In addition to the resident inspector at the construction site, the Staff has also stationed a resident inspector at Bechtel's design office in Houston. It is performing a continuing review of the disposition of the Quadrex findings and plans to issue its own report on the disposition of those findings.
It required HL&P to submit its program for safety-related construction 60 days in advance of its plans for resumption of construction, specifically requiring that HL&P explain how Quadrex concerns would be taken into account. It was only after the Staff reviewed this information that it concurred in the resumption of safety-related construction.
Thus, the Staff's review of resumption of construction at STP has, in fact, been extraordinarily intense.-5/
-5/ Since CCANP is fully aware of all of the actions taken by the Staff, it is curious that it. chose to ignore them completely in the Petition filed with the Commis-sion. CCANP also chose to ignore a number of highly relevant documents. See note 8, infra.
- _ _ _ _ _ . - - - _ . _ _ - - _ - _ _ _ _ - - - _ _ - - - - ~ .
The facts in this case highlight the reasons that the Commission requires such petitions to be filed with the Director. At issue are complex and Icngthy technical re-ports. The Staff has detailed knowledge of the underlying facts; has reviewed the Quadrex Report and Bechtel's pre-liminary assessment; has interviewed HL&P, Bechtel and Quadrex personnel who participated in those reviews; has monitored the Bechtel design review; and has reviewed HL&P's plans for resolution of the individual Quadrex findings prior to resumption.of affected construction work. For just such reasons the regulation provides for this special knowl-edge to be applied in a Director's decision, with the Com-mission retaining authority for sua'sponte review of that decision.
While we recognize that the Commission's practice is generally to refer such petitions to the appropriate Direc-tor ~(see e.g., Consumers Power Company (Big Rock Point
. Plant) , DD-82-0 5, 15 NRC __, (June 15, 1982)), in this case we believe the appropriate action is to deny summarily CCANP's Petition without referral to the Director. The Petition makes clear that CCANP does not seek review of its i
! Petition by the Director and, as our discussion above dem-l l onstrates, the matters alluded to in the Petition are L
f already receivingfclose scrutiny by the NRC Staff. However, should the Commission decline to dismiss the Petition sum-marily, the appropriate course would be to refer it to the Director for his action pursuant to S 2.206. He should then deny it for the reasons set forth below.
B. There is no Legal or Factual Basis for the Relief Sought by CCANP CCANP has provided no legal or factual basis for the five elements of relief it has requested (see Petition at
- 12) and, if the Petition is referred to the Director, it should be denied on such grounds. Three of the five ele-ments entail immediate suspension of construction or prohi-bition of further construction until certain reviews are completed. Such action would not be lawful.
6/
The Administrative Procedure Act (APA)~ prohibits sus-pension of a license without written agency notice and op-portunity to demonstrate compliance. 5 U.S.C. S 558(c)
(1977). The only exceptions-to this prohibition are cases of willfulness and those in which the public health, in-L l terest, or safety requires immediate action. Id,.; 42 U.S.C.
2239 (1973); 10 C.F.R. S 2.202. Neither exception is applicable here. HL&P's actions are in accordance with NRC
-6/ The APA.is applicable to NRC proceedings. 42 U.S.C.
S 2231 (1981).
r requirements and there is no imminent threat to public health or safety. The issue here is the adequacy of design, and unlike a potential construction deficiency that may be concealed by subsequent construction, the design is fully documented and can be reviewed at any time before or-after construction. In fact, ic Porter County Chapter, supra, 606 F.2d at 1370, petitioners' claims included an issue regarding 4
safety-related design and the Court-held that such an issue could be left for review in the eventual operating license proceeding. Thus the circumstances which might justify an immediate suspension are not present here.
Neither is there any basis for instituting a proceeding to consider suspension of construction. As the Commission has emphasized:
.. . . it has always.been recognized that summary administrative action substantially curtailing existing rights -- here, the right to construct a nuclear power plant pursuant to a validly issued construction permit -- is a " drastic procedure.". . .
Such action, unless warranted by compel-ling safety considerations, can bave seri-ous consequences. Unwarranted suspension of construction of a needed generating plant is contrary to the public interest. More-over, a period of enforced suspension of construction may result in layoffs and consequent-hardship for employees at the site. And, obviously, an extended suspen-sion may generate substantial additional costs which the consumer may ultimately bear through increased electricity rates.
~ Midland, supra, at 1083 (citations omitted).
_m . , . . , . , -- _ _- %
(
CCANP has not made the slightest showing that there are violations or potential hazards to the public that would be sufficient grounds for suspension of construction. See 10 C.F.R. S 2.206 (a) (1) . Certainly there are no " compelling safety considerations" involved here that would warrant the extreme ~ action of suspending construction. At most what is in issue is the adequacy of some aspects of design. Design issues which arise during construction or are left unre-solved at the construction permit stage are routinely con-sidered in the subsequent regulatory review.
Indeed, as discussed further below, the issues CCANP seeks to raise are already a planned part of the operating license hearing, in which CCANP is a participant.
Furthermore, the fact that Quadrex made some findings in early 1981 would not support the suspension of construc-tion under present circumstances. Since the time that Quadrex performed its review, Bechtel has been engaged as architect-engineer and has been performing a comprehensive design review. The review of the strbctures, systems or components comprising the entire Plant is considering the applicable Quadrex findings. Construction work is being resumed methodically through a phased process and is pro-ceeding only on the basis of designs reviewed in the
-- ~ , ,v, .-r-, - - - - - . n .
[ . .
f-p transition program. Thus, even if CCANP's characterization of_the_Quadrex findings were taken as a true description of the design as it was in spring of 1981, there would be no 7/
basis for stopping current construction activities.-
Moreover the entire process is being closely monitored and inspected by the NRC Staff. The Staff has reviewed the details of HL&P's plans and has concurred in them. The report cited by CCANP, and several additional relevant docu-ments-8/ known to CCANP but not cited by it, have been 7/
- A Section 2.206 cetition should not be permitted to
~
force consideration of a technical issue in a less appropriate forum. Pacific Gas and Electric Co.
(Diablo Canyon Nuclear Power Plant, Units 1 and 2)
CLI-81-6, 13 NRC 443 (1981); Consolidated Edison Co.
(Indian Point, Units 1, 2 and 3), CLI-76-8, 2 NRC 173, 177 (1975). It is the licensee's risk that the operating license hearing will result in a finding that the design is not acceptable in some regard; accordingly, no separate hearing on such issues is re-quired. -Porter County Chapter, supra, 606 F.2d at 1370.
8/ See An Assessment of the Findings in the Quadrex Cor-poration Report Dated May 1981, March 1982 (Bechtel's preliminary assessment of the Quadrex Report); Transi-tion Program Description dated December 11, 1981 (describing the design review being performed by Bechtel); I&E Reports 82-01, 82-02, 82-03, 82-04, 82-08 and 82-09 (describing Staff review of the Bechtel design review process, -including the Quadrex Report);
letter dated March 22, 1982 from G. W. Oprea, Jr. (HL&P) to John T. Collins, Regional Administrator, Region IV (ST-HL-AE-8 09 ) (describing the_ organizational structure and relationships among HL&P, Bechtel and Ebasco Ser-vices,- Inc. (the' constructor) with respect to (Footnote continued on page 16)
reviewed by the NRC Staff as well as Bechtel and HL&P, and each has found it acceptable to proceed with construction in accordance with the plan described in HL&P's letters to the Staff. This further demonstrates-the lack of present basis for the-suspension of construction sought by CCANP.
A second element of the relief requested by CCANP is "an independent third party review of the Brown & Root de-sign." In addition to lacking regulatory basis, such re-quest obviously chooses not to consider the detailed review
-being conducted by Bechtel as an " independent third party review." There is, however, no basis for CCANP's position.
Bechtel is a highly qualified architect-engineer; the com-prehensive review it has undertaken encompasses the design
.of the entire Plant (not just the portion reviewed by Quadrex); Bechtel's review process has been described in the Transition Program Description, reviewed and found acceptable by the NRC Staff, and considered at the operating license hearing; and the NRC Staff, including an NRC resident
-8/ (Footnote continued from page 15) responsibilities for quality assurance, design review, and design verification); letter dated April 22, 1982 from G. W. Oprea, Jr. to John T. Collins (ST-HL-AE-821)
(describing the HL&P program to disposition Quadrex findings); and letter dated May 14, 1982 from G. W.
Oprea, Jr. to John T. Collins (ST-HL-AE-833) (describing HL&P's program and schedule for resuming safety related construction work).
inspector at Bechtel's offices, is maintaining continuing surveillance over the conduct of Bechtel's design review.
Bechtel had no role in the development of the design it is now reviewing. The fact that Bechtel will assume respon--
sibility for the design upon its completion of the review does notLreduce its " independence"; if anything, it provides additional incentive to assure a thorough review. When the foregoing facts are taken into account -- particularly in view of the additional considerations that the NRC Staff is performing its own review of the Quadrex Report and that the .
Quadrex Report will be considered in the next phase of the operating license hearing-9/ -- a less suitable candidate for additional review can scepcely be imagined.
The final element of relief sought by CCANP is a hear-ing on one Quadrex concern-(adequacy of classification of systems and components as non-safety related) and the adequacy of the foregoing " independent third party review of the Brcwn and Root design." As CCANP recognizes at page 13 of its Petition, the existing Licensing Board is planning an early hearing on all aspects of the Quadrex Report. It has already conducted a hearing this year, in which CCANP participated, on Bechtel's qualifications and the adequacy
-9/ .See Fourth Prehearing Conference Order (December 16, 1981) at 5.
=
of the transition program, including the Bechtel design re-view process. Thus, the hearing sought by CCnNP is, in substance, already planned.or accomplished. CCANP addi-tionally seeks to suspend construction until such hearing is completed, but, as discussed above, has provided no basis for such relief.
Thus, there is neither a legal nor a factual basis for granting CCANP any of the relief it seeks.
IV. CONCLUSION The Petition should be summarily denied by the Com-mission because CCANP has explicitly and willfully refused to utilize the procedures for review by NRC officials that are expressly made available under the NRC regulations. If the Petition is referred to the Director of Nuclear Reactor
./
Regulation for consideration pursuant to 10 C.F.R. S 2.206, it should be denied on its merits since, as detailed above, there is no legal or factual basis for any of the relief sought by CCANP.
(.
m iI . _ _
Respectfully submitted, Jack R. Newman Maurice Axelrad Alvin H. Gutterman 1025 Connecticut Avenue, N.W.
Washington, D. C. 20036 Finis E. Cowan Thomas B. Hudson, Jr.
3000 One Shell Plaza Houston, TX 77002 DATED: August 24, 1982 Attorneys for HOUSTON LIGHTING
& POWER COMPANY, Project Manager LOWENSTEIN, NEWMAN, REIS of the South Texas Project
& AXELRAD acting herein on behalf of itself 1025-Connecticut Ave.,NW and the'other Applicants, THE Washington, D.-C. 20036 CITY OF SAN ANTONIO, TEXAS acting by and through the City BAKER & BOTTS Public Service Board of the City 3000 One Shell Plaza of San Antonio, CENTRAL POWER Houston, TX 77002 AND LIGHT COMPANY and CITY OF AUSTIN, TEXAS
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of )
)
HOUSTON LIGHTING & POWER ) Docket Nos. 50-498 OL COMPANY,-ET AL.
-~
) 50-499 OL
)-
South. Texas Project )
Units 1 and 2 )
CERTIFICATE OF SERVICE ,
'I hereby certify that copies of " Licensees' Response to i CCANP ' Petition to Suspend Construction of the South Texas Project'" have been served on the following individuals and entities by. deposit in the United States mail, first class, postage prepaid, or by arranging for delivery as indicated by asterisk, on this 24th day of August, 1982.
Chairman Nunzio J. Palladino* Dr. James C. Lamb, III U.S. Nuclear Regulatory Commission Administrative Judge Washington, D. C. 20555 313 Woodhaven Road Chapel Hill, NC 27514 Commissioner Victor Gilinsky*
U.S. Nuclear Regulatory Commission Frnest E. Hill Washington, D. C. 20555 Aaministrative Judge Lawrence Livermore Laboratory Commissioner John F. Ahearne* University of California ,
U.S. Nuclear Regulatory Commission P.O. Box 808, L-46 Washington, D. C. 20555 Livermore, CA 94550 Commissioner Thomas M. Roberts
- Mrs. Peggy Buchorn ,
U.S. Nuclear Regulatory Commission. Executive Director Washington, D. C. 20555 Citizens for Equitable Utilities, Inc.
Commissioner James K. Asselstine* Route 1, Box 1684 U.S. Nuclear Regulatory Commission Brazoria, TX 77422 Washington, D. C. 20555 Brian Berwick, Esq.
Charles Bechhoefer, Esq. Assistant Attorney General '
Chairman, Administrative Judge for the State of Texas Atomic Safety and Licensing Environmental Protection Board Panel Division U.S. Nuclear Regulatory P.O. Box 12548, Capitol Station
' Commission Austin, TX 78711 Washington, D. C. 20555
A.
William S. Jordan, III, Esq. Atomic Safety and Licensing Harmon & Weiss Appeal Board-1725 I Street, NW U.S. Nuclear Regulatory
~ Washington, D. C. 20006 Commission !
Washington, D. C. 20555 e :Kim Eastman, Co-coordinator Barbara A. Miller Atomic Safety and Licensing Pat Coy Board
-Citizens Concerned About U.S. Nuclear Regulatory Nuclear Power Commission
.5106 Casa Oro' Washington, D. C. 20555 San Anto: 3, TX .78233 '
Docketing and Service Section*
Lanny Sinkin Office of the Secretary ;
2207-D Nueces U.S. Nuclear Regulatory ,
Commission
~
Austin, TX 78705 Washington, D. C. 20555 Jay M.'Gutierrez, Esq. i Office of the Executive '
Legal Director U.S. Nuclear Regulatory Commission Washington, D. C. 20555 s
Maurice Axelrad'
-. - -