ML20072H299
| ML20072H299 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/27/1983 |
| From: | Bauser D METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8306290399 | |
| Download: ML20072H299 (9) | |
Text
r-June 27, 1983
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UNITED STATES OF AMERICA
/[s NUCLEAR REGULATORY COMMISSION ocy C J~,V C
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6 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL' ARD 03a la E5 SEl Qed?%
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In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-FS
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(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S ANSWER TO AAMODT MOTIONS FOR PROVISION OF INFORMATION AND TO LIFT ORDER OF CONFIDENTIALITY OF REOPENED PROCEEDING By motion served June 21, 1983, the Aamodts have requested that the Board order the NRC Staff and the Depart-ment of Justice to produce a number of documents the Aamodts argue should be provided to them as a party to the TMI-l restart proceeding.
One request for documents (Item 10) appears to be directed to Licensee.
The Aamodts also request that the Appeal Board effectively rescind the Confidentiality Order issued during the 1981 reopened TMI-1 proceeding.
Licensee opposes the Aamodt motion.
In document request number 10, the Aamodts seek the
" resumes of all new employees considered in the Dircks and Dieckamp letters."
The Aamodts apparently believe that this request is clarified by their comment, "By 'new', we mean to the Restart Proceeding."
Aamodt Motion at 2.
Of the estimated 442 key personnel, including managers, technical /
professional staff and licensed operators in GPU Nuclear Corporation today who do TMI-1-related work, approximately 8306290399 B30627 PDR ADOCK 05000289 Q
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333 were not employed by Metropolitan Edison Company, the company that operated TMI-l at the time of the TMI-2 accident, prior to the accident.~1/This fact, along with other pertinent details about Licensee's commitments in the June 10, 1983 letter by Mr. Herman Dieckamp to the Commissioners, was discussed at a public meeting between Licensee and the Staff at which Mr. Aamodt was in attendance.
See Transcript of NRC Staff Meeting with GPU Nuclear Regarding TMI Unit 1, June 20, 1983, at 36-38 and attached handout at 6.
The Aamodts have as well received a copy of that transcript.
To the extent that the Aamodts now seek resumes of'at least 333 "new" employees, Licensee opposes this request as excessively burdensome, particularly in view of the absence of any accompanying justification to support the request.
Moreover, the request is untimely.
The fact that there are many individuals supporting TMI-l who were not there at the time of the TMI-2 accident has been apparent from the time Licensee presented its initial case on management in 1980-81.
To the extent that the Aamodts ' request is intended to be narrower than this, Licensee does not under-stand what the request means and, for that reason alone, opposes it.
The qualifications of senior management and technical personnel assigned to TMI-l were part of the record in the management phase of the TMI-l restart proceeding and 1/
Currently, there are.a total number of approximately 922 GPU Nuclear Corp, employees assigned to work on TMI-1.
Licensee has not determined the number of clerical and hourly workers, in addition to the approximately 333 key personnel, who did not work at TMI-l prior to March, 1979.
See Transcript of NRC Staff Meeting with GPU Nuclear Regarding TMI Unit 1, June 20, 1983, at 37-38.
were reviewed in detail by the parties and the Licensing Board.
Where changes in senior management or technical positions have taken place which might be significant to the Board and the parties, the qualifications of these new personnel have been the subject of letters from Licensee's counsel to the Appeal Board and the parties.
- See, e.g.,
Licensee counsel's letter to the Appeal Board of May 6, 1983.
As a general proposition, Licensee believes that the Aamodts must provide considerable justification for their request for sny employee resume that they seek at this stage in the restart proceeding.
See Illinois Power Company (Clinton Power Station, Unit Nos. 1 & 2), ALAB-3 4 0, 4 N.R.C.
27, 34 (1976).
In the last paragraph of their motion, the Aamodts summarily ask the Appeal Board to lift the Order of Con-fidentiality imposed by the Special Master in the TMI-l reopened proceeding on November 12, 1981.
See Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit No. 1),
LBP-82-34B, 15 N.R.C.
918, 926-27 (1982).
The issue of confidentiality was pursued by a number of parties to the reopened proceeding, including the Staff, Licensee, and attorneys who filed special appearances with the Board solely to represent the interests of three unnamed individuals, including the two individuals who cheated on the April, 1981 NRC license examinations.
See NRC Staff counsel (Swartz) letter to Board, dated September 18, 1981, and attached Proposed Protective Order; NRC Staff Brief on
Need for Protective Order, September 24, 1981; Licensee's September 25, 1981 Response to Board Order Dated September 14, 1981 in the Matter of Confidentiality; Memorandum with Respect to Public Disclosure of Identities of Involved Individuals, September 28, 1981.
The Staff, Licensee and counsel representing the three unnamed individuals supported maintaining the confidentiality of individuals whose training and testing records and experiences were discussed on the record.
The Aamodts and TMIA initially opposed the requests for confidentiality.
Licensee suggested the use of a letter designation system to effectively protect individuals' testimony as well as employment records from public disclosure and associated publicity, while at the same time ensuring that information about these individuals relevant to the reopened proceeding would be available in a comprehendible form to the parties.
All of the parties, including the Aamodts, subsequently approved a stipulation on confidentiality, which also was approved and endorsed in an Order by the Special Master.-2/ See Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit 1), ALAB-658, Nov. 19, 1981.
This stipulation specified that a letter designation system would be used to identify certain present and former Licensee employees.
The reopened proceeding was conducted according to that Order.
Certain individuals voluntarily agreed to testify only because the stipulation protected their identi-ties from public disclosure.
2/
Attached hereto, for the convenience of the Appeal Board, is a copy of the Special Master's Order and the stipulation.
~
The Aamodt request at this juncture to overturn the order on Confidentiality ought to be rejected for the simple reason that the basis provided by the Aamodts for the Appeal Board to take such action not only is vague, but logically does not support the request made.
The Aamodts state only that the Order should be overturned "in order to discuss the information concerning staffing provided in the Dircks and Dieckamp letters."
Aamodt Motion at 4.
It is totally unclear what information the Aamodts are referring to here.
There are only two individuals of which Licensee is aware who are identified by letter rather than name in the attach-ment to the Dieckamp letter (June 10, 1983 letter from Herman Dieckamp to Governor Thornburgh of Pennsylvania).
Those two individuals are Messrs. DD and H.
Mr. DD publicly identified himself during the reopened proceeding as Mr. Husted.
While Mr. 3's identity remains undisclosed to the public,-3/this fact cannot possibly have any relevance today, since Mr. H will not be utilized as a licensed operator.~4/ See June 10, 1983 letter from H. Dieckamp to Governor Thornburgh, attached to June 10, 1983 letter from H. Dieckamp to the NRC Chairman Palladino.
In addition, no indication is given by the Aamodts as to why, even if they need to refer now or in the future 3/
As a part of the stipulation agreement, the Special Master and designated counsel or representative (s) of the parties, including the Aamodts, received a " key" which identified letter-designated individuals by name.
4/
The Aamodt request for disclosure of the identities of individuals other than Mr. H has no foundation whatsoever.
to individuals protected by the Confidentiality order, they cannot continue to use the letter-designation system, which worked extremely well during the reopened proceeding.
In sum, there is absolutely no basis for the Aamodts' request that the Order on Confidentiality be rescinded.
On the other hand, there continues to be a substantial and mutually agreed upon basis for utilizing a letter-designation system to protect certain individuals' identities from public dis-closure.
Accordingly, the Aamodts' motion should be denied.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE
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4 Ernest L.
Blake, Jr., P.C.
Deborah B. Bauser Counsel for Licensee 1800 M Street, N.W.
Washington, D.C.
20036 i
(202) 822-1215 Dated:
June 27, 1983
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LIC 11/13/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of '
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Docket No. 50-289 METROPOLITAN EDISON C0!!PANY
)
.(Restart)
)
(Three Mile Island Nuclear
)
Station, Unit. No. 1)
)
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To Service Lis t:
Enclosed is a copy of a' confidentiality Stipulation and related Order agreed to by the parties and approved by Judge Mklhollin on November 12, 1981, which Licensee is serving' at Judge Milhollin's request.
.f Sincerely,
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Ernest L'.
Blake, Jr.
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Counsel for Licensee Enclosures l
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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of
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DOCKET NO. 50-289
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METROPOLITAN EDISON COMPANY
)
)
(Three Mile Island Nuclear
)
(Res tart)
Station, Unit 1)
)
(Reopened Proceeding)
)
ORDER It is hereby ordered by Gary L. Milhollin, Administrative Judge and Special Master that for the durat ion of these proceedings all parties sip,natory to the attached Stipulation will be bound thereby and subject thereto.
Any violations of said Stipulation should be reported to Judge Milhollin, and may be-dealt with in any manner by Judge Milhollin pursuant to the enforcement powers invested in him by the Atomic Safety and Licensing Board.
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- 2 4 2-GEry A. Milhollin Admihistrative Judge and Special Master t
. UNITED STATES OF AMERICA N,UCLEAR REGULATORY. COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
.)
In the Matter of
)
DOCKET No. 50-289
)
METROPOLITAN EDISON COMPANY
)
)
(Res tart)
(Three Mile Island Nuclear
)
(Reopened Proceeding)
Station, Unit I)
)
)
STIPULATION The partie's to this reopened proceeding, on their own behalf or by counsel, as indicated below, stipulate that l.
With the additionalf information provided pursuant to paragraph 3 below, it appears that the lettering system adopted by Licensee and used by the parties to date is capable of permitting an adequate evidentiary hearing on the.
issues in this proceeding and sh,ould be retained and used throughout this proceeding, including any appeals, except that the stipulation shall not pertain to the identity of any individual who has voluntarily agreed or hereafter agrees to make his/her identity known in this proceeding.
2.
A Protective Order should be issued requiring non-disclosure of any name of any person who is identified by letter rachar than by name, should that person's name be disclosed during this proc'eeding, including any appeals.
3.
Subject to the Protective Order referred to in paragraph 2 above, Licensee shall provide to the Special OfY}TC 3Tb i
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saster, counsel for the NRC. staff, counsel for the Ctmmonwealth, Mrs. Aamodt and counsel for the Aamodes and the two undersigned representatives of TMIA, a key which identifies by name and job title all Licensee employees and ox-employees (excepting "YY") which heretofore have been designated by letter or number.
This key shall be provided exclusively for use by participants in this captioned proceeding bafore the Special Master and appeals therefrom.
The key provided shall be retained by the undersigned representatives and-counsel for their use and the use of those assisting them in the course of this proceeding.
In order to assure the effectiveness of this stipulation, no copies of the keys shall be made and their use by those other than the undersigned shall be restricted to i
the absolute minimum necessary for hearing preparation and for i
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subsequent appeals.
Licensee further agrees to' drop the lettering system throughout the proceeding for all employees other than its past and present control room operators, shift foremen, shif t supervisors, shift technical advisors, -and individual. "VV" and
'with respect to these' individuals, each individual's
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, job classification will be identified.
Licensee further agrees to review all documents it has provided in the course of discovery and to provide as soon as possible to all participants in the proceedings, subject to the Protective Order referred to in paragraph 2 above, material (other than names and job classifications) which has been deleted, such as dates, in furtherance of the lettering system.
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4.
If thosa parsons id;ntified in the Licensse's lettering sys tem as "0", "VV" and "W" (and such o ther.....
I persons as may be subsequently determined by the Special Master to merit an in camera proceeding for their testimony) are called to testify in this reopened proceeding, their testimony will be taken in camera, without public notice, and at a place to be agreed on by the parties and the Special Master, so as to minimize risk of disclosure of their identities.
5.
When in, camera session's of this proceeding are scheduled, the parties shall not disclose the fact, tium and place of such sessions to anyone, before or during the' session.
6.
Such in camera sessions will be conducted' f
before Special Master Milho111n.
7.
The testimony in the in camera sessions would continue the use of the lettered system and the transcripts of in camera sessions would be made available to the public
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without restriction.
8.
Should the name of any person who is i
identified by letter or by number in the Licensee's 4
i lettering system be disclosed ~ during testimony of any witness, that person's name will be excised from the record I
and will not be disclosed by any party or the NRC staff.
9.
The NRC staff or any of its employees or subordinate bodies will not' disclose the name of any person i
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idsntified by letter in the Licensoo's lottering system in
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The individuals 'desighated as "0", "W" and "W" hereby waive any objections previously stated in this proceeding to further testimony in this proceeding by each of them, subject to the other provisions of this s tipula tion.
The involved individuals and the Licensee agree that they will withdraw their appeal of the Licensing Board's November 6,1981 decis, ion, except for those portions of the opinion characterizing conduct of counsel.
Respectfully submitted, MM M M94.-
Michael F. McBride LeBOEUF, LAMB, LEIBY, & MacRAE i
1333 New Hampshire Ave., N.W.
Suite 1100
. Washington, D.C. 20036 (202) 457-7500
' Attorney for Two of Three Involved Individuals s
&x E O David E. Cole SMITH & SMITH, P.C..
l Riverside Law Center 2931 North Front Street PA.
17110 Harrisburg,506 (717) 232-0 Attorney for One of Three Involved Individuals 4,
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~SHAW, PITTMAN, POTTS &
TROWBRIDGE e
By MW N4 r/,
Partner 1800 M Street, N.W.
Washington, D.C. 20036 (202) 822-1000 Attomeys for Metropolitan Edison Company N./f ft.
Lucinda Low Swartz Office of the Executive LegaI' Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 (301) 492-7519 Counsel for the NRC Staff A.
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.,y Joanne Doroshow
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Louise Bradfotd TMI Alert, Inc.
314 Pfeffer Street Harrisburg, PA 17102 (717) 232-3070
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Tohn W Clewett The Christic Instituta 1324 North Capitol Street Washington, D.C.
(202) 797-8106 Counsel for the Aamodt Family o
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6' },%1 Robert W. Adler Assistant Counsel 505 Executive House P.O. Box 2357 Harrisburg, PA 17120 (717) 787-7060 Attorney for the Commonwealth of Pennsylvania Approved:
Date Approved:
hssyfh fW. /R /1W
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v Gary L. Milho111n Administrative Judge and Special Master i
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4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289 SP
)
(Res tart)
(Three Mile Island Nuclear
)
S tation, Unit No.1) _
)
CERTIFICATE OF SERVICE I hereby certify that copies of the " Order," :nd
" Stipulation" dated November 12, 1981, were ser' red this 13th day of November,1981, by hand delivery uoan the i
persons identified by one asterisk and by deposit in e
the United States mail, firse class, postage prepaid, J.to the other parties on the attached Service List.
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'Deborah B.
Bauser l
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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In the Matter of i
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
SERVICE LIST Ivan W. Smith, Esquire John A. Imvin, Esquire Assistant Counsel mair: nan Atomi.c Safety and Limosing Board Nmsylvania Public Utility Cbanission U.S. Nuclear Regulatory Camf.ssion P.O. Box 3265 Washington, D.C. 20555 Harrisburg, kunsylvania 17120 Dr. Walter H. Jordan Karin W. Carter, Esquire
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Atomi.c Safety and Limnsing Bobert Adler, Esquire.
Assist e t Attorney General Board Panel 881 West Outer Drive 505 Executive House P.O. Box 2357 Oak Ri.dge, Tennessee 37830 Harrisburg, Pemsylvania 17120 Dr. Linda W. Little Atcmi.c Safety ad Licensing John E. Minnich mairman, Datphin Gotnty Board Board Panel of Cami.ssioners 5000 Hermi.tage Drive Datphin Cotnty Cburthouse Raleigh, Ibrth Carolina 27612 Front and Market Streets l
i Jees R. Tburtellotte, Esquire '
Harrisburg, Pennsylvania 17101 Office of the Executive Ingal DLrector U.S. Nuclear Regulatory CWasion Waltar W. Cohen, Edquire Constmar Advocate Washington, D.C. 20555 Offim of Consuner Advocate 1425 Strawberry Square Docketing md Service Secticn Harrisburg, Pennsylvania 17127 Offim of the Secretary U.S. Nuclear Regulatory canniasion Washingtcn, D.C. 20555
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Jordm D. Ctnningham, Esquire Ibbert Q. Pollard 2320 North Seccnd Street 609 &ntpelier Street Harrisburg, Pennsylvmia 17110 Baltimore, Mary 1md 21218
- m. Iouise Bradford Olancey Kepford Judith H. Johnsrud
'IME Alert Enviremental Coalition on Nuclear Power 1011 Green Street Harrisburg, Pemsylvania 17102 433 Orlm do Avenue State College,1%nnsylvania 16801 Ellyn R. Weiss, Esquire Harnon & Weiss Marvin I. Iawis 1725 Eye Street, N.W., Sutta 506 6504 Bradford Terrace Washingtcn, D.C.
20006 Philadelphia,1%nnsylvania 19149 Marjorie M. Aamodt s
Steven C. Sholly Unicn of Cbncerned Scientists R. D. 5 1725 Eye Street, N.W., Suite 601 Coatesville, Pennsylvmia 19320 Wishington, D.C. 20006
'Ihomas J. Germine, Esquire Gail B. Phelps Deputy Attorney General DLvision of Iaw - Room 316 ANGRY 245 West Philadelphia Street 1100 Raymond Boulevard York, Pennsylvania 17404 Newark, New Jersey 07102 j
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i, Willian S. Jordan, III, Esquire
. Michael McBride, Esquire Harman & Weiss IeBoeuf, Ianb, Imiby & MacRae 1725 Eye Street, N.W., Suite 506 1333 New Hanshire Avenue, N.W.
Washingtcm, D.C.
20006 Washington, D.C. 20036
- Professor Gary L. Milhollin David E. Cole, Esquire l
1815 Jefferson Street Smith & Smith Madison, Wisconsin 53711 Riverside Law Center 2931 North Front Street Harrisburg, Pennsylvania 17110 e
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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 copies of " Licensee's Answer to Aamodt Motions for Provision of Information and to Lift Order of Confidentiality of Reopened Proceeding" were served this 27th day of June, 1983 by hand delivery upon the parties-identified by an asterisk and by deposit in the U.S. mail, first class, postage prepaid, to the other parties on the attached Service List.
M b.
Deborah B.
Bauser i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal Board In the Matter of
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)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289 SP
)
(Restart)
(Three Mile Island Nuclear
)
{
Station, Unit No. 1)
)
SERVICE LIST l
Administrative Judge Administrative Judge Gary J. Edles, Chairman Ivan W.
Smith, Chairman Atomic Safety & Licensing Atomic Safety & Licensing Board Appeal Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge Administrative Judge Walter H. Jordan John H. Buck Atomic Safety & Licensing Board Atomic Safety & Licensing 881 West Outer Drive Appeal Board Oak Ridge, TN 37830 U.S. Nuclear Regulatory Commission Administrative Judge Washington, D.C.
20555 Linda W. Little Atomic Safety & Licensing Board Administrative Judge 5000 Hermitage Drive l
Christine N. Kohl Raleigh, NC 27612 Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing U.S. Nuclear Regulatory Board Panel l
Commission U.S. Nuclear Regulatory Washington, D.C.
20555 Commission Washington, D.C.
20555
- Jack R. Goldberg, Esquire (4) f Office of the Executive Atomic Safety & Licensing Legal Director Appeal Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission I
Washington, D.C.
20555 Washington, D.C.
20555 i
Docketing & Service Section (3)
Douglas R.
Blazey, Esquire Office of the Secretary Chief Counsel l
U.S.
Nuclear Regulatory Department of Environmental Commission Resources Washington, D.C.
20555 514 Executive House P. O. Box 2357 Harrisburg, PA 17120 vr+----
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John A. Levin, Esquire Ms. Gail Phelps Assistant Counsel ANGRY /TMI PIRC Pennsylvania Public Utility 1037 Maclay Street Commission Harrisburg, PA 17103 Post Office Box 3265 Harrisburg, PA 17120 Jordan D. Cunningham, Esquire Fox, Farr & Cunningham Mr. Henry D.
Hukill 2320 North Second Street Vice President Harrisburg, PA 17110 GPU Nuclear Corporation Post Office Box 480 Ellyn R. Weiss, Esquire (1)
Middletown, PA 17057 William S. Jordan, III, Esquire (l)
Harmon & Weiss Michael F. McBride, Esquire 1725 Eye Street, N.W.,
Suite 506 LeBouef, Lamb, Leiby & MacRae Washington, D.C.
20006 1333 New Hampshire Avenue, N.W.
Suite 1100 Mr. Steven C.
Sholly Washington, D.C.
20036 Union of Concerned Scientists 1346 Connecticut Avenue, N.W.
I Ms. Louise Bradford Dupont Circle Bldg., Suite 1101 TMI ALERT Washington, D.C.
20036 1011 Green Street Harrisburg, PA 17102 Chauncey Kepford Judith H. Johnsrud Mr. Norman Aamodt Environmental Coalition on R. D.
5 Nuclear Power Coatesville, PA 19320 433 Orlando Avenue State College, PA 16801 John Clewett, Esquire The Christic Institute David E. Cole, Esquire l
1324 North Capitol Street Smith & Smith, P.C.
Washington, D.C.
20002 2931 Front Street l
Harrisburg, PA 17110 l
Michael W. Maupin, Esquire Hunton & Williams Administrative Judge 707 East Main Street Gary L. Milhollin i
Post Office Box 1535 Atomic Safety & Licensing Board Richmond, VA 23212 4412 Greenwich Parkway, N.W.
Washington, D.C.
20007 i
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