ML20079E299
| ML20079E299 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/12/1984 |
| From: | Churchill B METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | THREE MILE ISLAND ALERT |
| References | |
| 83-491-04-OLA, 83-491-4-OLA, NUDOCS 8401170231 | |
| Download: ML20079E299 (21) | |
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DOCFETED U5NRC 1
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-NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
)
)
Docket No. 50-289-OLA METROPOLITAN EDISON COMPANY, ET AL. )
ASLBP 83-491-04-OLA
)
(Steam Genersttor Repair)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
i LICENSEE'S SECOND SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO INTERVENOR TMIA This second set of interrogatories and request for produc-tion of documents is filed by Licensee to Intervenor TMIA pur-suant to the Licensing Board's Memorandum and Order of November 29,.1983, which requires that discovery requests be expedi-tiously initiated such that the responses can be received.on a schedule to enable completion of discovery by January 31, 1984.
This discovery request. supplements Licensee's First Set of Interrogatories and Request for Production of Documents served on TMIA on December 15, 1933, and responded to by TMIA on January 4, 1984.
'In accordance with 10 C.F.R. 5 2.740b, Licensee requests that TMIA answer each interrogatory set forth below separately and fully in-writing, and under oath or affirmation.
Answers b&g
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must be signed by the person making them and must be served within 14 days after service of the interrogatories.
These interrogatories are intended to be continuing in nature and the answers should promptly be supplemented or amended as appropriate, pursuant to 10 C.F.R. 5 2.740(e),
should TMIA or any individual acting on its behalf obtain any new or differing information responsive to these interrogatories.
When asked in the-interrogatories below to identify a person, please state that person's full name, present or last-kn'own address, telephone number, employer, and job title.
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Where'an individual interrogatory calls for an answer which involves more than one part,-each part of the answer shall be clearly identified and correlated with the part of the
' interrogatory to which it is responsive.
Where identification of a document is requested, briefly describe the document-(e.g., book, letter, memorandum, transcript, report, handwritten notes, test data, etc.) and provide the following information as applicable:
document name,ititle, number author, date of publication'and publisher, addressee, date written or approved, and the name and address
'of the person or persons having possession of the document.
Also identif'y by page number and chapter or section number the specific 'ortion or-portions of the document upon which you p
rely.
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As used in the interrogatories and request for production of documents set'forth below, the following definitions shall apply:
" Document (s)" means all writings and records of every type i
in'the possession, control or custody of TMIA or any individual acting on11ts behalf, including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts, books,
- pamphlets, photographs, mats, bulletins,-minutes, handwritten notes, speeches, articles, transcripts, audio and video record-P ings and all other writings or recordings of any kind.
" Writ-ings" and " recordings" consist of. letters, words or numbers, or their equivalent, set down by handwriting, typewriting, print-ing,L photostating, magnetic impulse, mechanical or electrical
-recording, or other form of data compilation.
" Document (s)"
shall also mean copies of documente even though the originals thereof are not in the possession, custody, or control of TMIA.
A document shall be deemed to be within the " control" of TMIA or any individual' acting on its behalf if it has ownership, possession or custody of the document or copy thereof, from any person'or public or private entity having physical possession thereof.
"You" or "your(s)" means TMIA, its members or any person authorized to act on its behalf.
"SER" means the NRC Staff's Safety Evaluation Report on Steam Generator Tube Repair and Return to Operation, NUREG-1019, and Supplement 1 thereto.
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UPDATE OF FIRST SET OF INTERROGATORIES In its response to many of the questions in Licensee's
-First Set of' Interrogatories, TMIA responded that-it was "un-able at-this date" to provide substantive responses, and that
" fuller responses will be provided" after discovery on Licens-ee.
Other interrogatories were answered only in part.
Accord-ingly,' Licensee hereby incorporates by reference each and every interrogatory set forth in Licensee's First Set of Interrogatories to Intervenor'TMIA, and requests that TMIA up-date each and every response previously made to those interrogatories.
II.
SUPPLEMENTAL INTERROGATORIES A.
General Interrogatories 1.
(a)
For each interrogatory answer, and each subpart thereto, identify each person who participated in the prepara-
. tion of the answer, and who provided information to you upon which you relied in preparing the answer.
(b)
Identify all such information which was provided
-by each such person and the specific interrogatory in which such information is contained.
2.
For each person identified in your answers to-the following interrogatories as being a proposed witness, state:
(a)
The educational and professional qualifications (including a complete list of publications) of each such person;- -
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(b) JThe precise subject matter on which each such
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person is expected to testify; (c).The substance.of the facts and opinions as to.
which1each such person is expected to testify; and (d)
A summary of the grounds for any opinions iden-tified in'-subparagraph (c) above and identification of all documents upon which such person relies to substantiate such opinions.
B.
Interrogatories on Contention 1.a II-1.a-1.
For each " post repair and plant performing
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testing and analysis" which you have identified as inadequate in your response to Interrogatory 1.a-1 under Part I of this document, do you allege that such test or analysis was inade-quate in its assessment of:
(a)- The' fatigue life of the TMI-1 steam generator tubes before kinetic expansion repairs were performed and/or after kinetic expansion repairs were performed; (b)
The stress levels on'the TMI-l steam generator
-tubes before kinetic expansion repairs were performed and/or after kinetic expansion repairs were performed;
-(c) the effects of the corrosive contaminant on the stress levels on the TMI-1 steam generator tubes, and the fa-tigue life of TMI-l steam generator tubes;
-(d) the effects of changed strength and dimensions of. tubes which have-been kinetically expanded on the stress levels on the TMI-l steam generator tubes and the fatigue life of'the TMI-1 steam generators; __
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(e) ' The crack size, for purposes of determining the stress' levels on the.TMI-1 steam generator tubes, in particular u
'the effects of thermal stress, and.the fatigue life of TMI-l
' steam' generator: tubes; and-5 (f) - The crack location, for purposes of determining
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'the stress levels on the TMI-1 steam generator tubes and the
.fatigui life'of TMI-1 steam: generator tubes?
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II-1.a-2.
If yourianswer to any part of Interrogatory
.II-1.a-1~is'other than an unqualified "no",
state in detail each and every'fcet upon which you base your allegation that the particular test or analysis inadequately assesses the factors identified in that Interrogatory.
II-1.a-3.
' Explain in' detail how each fact stated in your answer to Interrogatory I'I-1.aI-2 supports your allegation that
.the test cn analysis identified in your answer to Interrogatory
.II-1.a-1Eis inadequate in the manner you allege.
II-1.a-4.
Identify each and every document which you p
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claim supports each' fact set forth in your answers to p
. Interrogatories II-1.a-1.through II-1.~a-3 above, and correlate
-each such document as specifically as possible (page and para-7 graph numb'r) with'each such fact.
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'II-1.a-S.
Do you allege that the.use by Licensee of.an
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axialiload of 1110-pounds /100*F.during the corrosion tests
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I' referred.to in TR-OO8 wes ir. proper?
If,your' answer to. Interrogatory II-1.a-5 above g
- II-1.a-6.
.is other than.an. unqualified "no",
explain why it was improper to use.that axial load during -the corrosion tests.
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II-1.a-7.
State in detail each and every fact upon which you-basefyour allegations.in-your answer to Interrogatory
' I I-1. a-6.
, II-1.a-8.
Explain'in-detail how each fact stated in:your Lanswerito Interrogatory II-1.a-7 supports your allegations.in
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' Interrogatory 'II-1. a-6'.
II-1.a-9.
Identify each and every document which you claim supports each-fact set forth in your answer to Interrogatories II-1.a-5'through II-1.a-8 above, and correlate-each such document as specifically as possible (page and para-
- graph number) with:each such fact.
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. Interrogatories on Contention 1.b II-1~.b-1.
Explain"how the alleged " history of affecting
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- other primary pressure. boundary materials" of the corrosien damage affects the: likelihood of a simultaneous tube-ruptura in
~ both steam; generators.
f II-1.b-2.
' State in detail each~and every-fact upon which youfbase your allegations.in your response to Interrogatory II-1.b-1, and explain in detail how each such fact supports the
-allegation.
II-1.b-3.
Identify each and every document which you claim supports each. fact-set forth in your answers to Interrogatories'II-1.b-1 and II-1.b-2,'and correlate each such
' document as specifically as'possible<(page and paragraph
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II-1.b-4.
Explain how the alleged " uniqueness and
' deforming character of the repair method used" affects the
' likelihood of a simultaneous-tube-rupture'in both. steam genera-tors.
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.II-1.b-5' State in' detail each and ever'; fact upon which you: base your allegations:in;your response;to Interrogatory-
-II-1.b-4, :and explain in detail how each such fact supports your allegation.
.II-1.b-6.
. Identify each and every document which you claim. supports each fact set forth in your answers to
' Interrogatories II-1.b-4 and II-1.b-5, and correlate each such document as specifically aszpossible (page and paragraph number) = with each such fact.
~II-1.b-7.
Explain how the "large number of. tubes which were repaired". effects the likelih'ood of.a simultaneous tube i
~ rupture'inLboth! steam generators.
II-1.b-8.
State in' detail each and every fact upon which-t
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you base-your allegations in your response to Interrogatory II-1.b-7,.and explainfin. detail ~how each such fact supports your allegation.
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II-1.b-9.-
Identify each and every document which you.
claim: supports each fact set.forth-in your answers to Interrogatories II-1.b-7 and II-1.b-8, and correlate each such
. document as specifically as possible (page and paragraph 4-number) with each such fact'.
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II-1.b-10.
Explain your understanding of the Commission's May 5, 1983 response to Congressman Markey discussing the Shewmon Memorandum, and how that May 5, 1983 response affects your contention that the Shewmon Memorandum supports Contention 1.b.
II-1.b-11.
Explain how Licensee's TDR-406 section 2.1.3.1 provides support for the possibility of simultaneous tube rup-tures in both steam generators.
II-1.b-12.
State.in detail each and every fact upon which you base your allegations in your response to Interrogatory II-1.b-11, and explain in detail how each such fact supports
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your allegations.
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II-1.b-13.
Explain how the Third Party Review Group's February 16 report at page 4 supports Contention 1.b.
II-1.b-14.
State in detail each and every fact upon which
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you base your allegations in your response to Interrogatory II-1.b-13, and explain in detail how each such fact supports your allegations.
II-1.b-15.
Explain how SECY-82-72 dated February 18, 1982, pages 2 to 3, supports Contention 1.b.
II-1.b-16.
State in detail each and every fact upon which you base your allegations in response to Interrogatory II-1.b-15, and explain in detail how each such fact supports your allegation.
II-1.b-17.
Identify each and every document which you claim supports each fact set forth in your answers to.....
Interrogatories II-1.b-10 through II-1.b-16, and correlate each such document as specifically as poscible (page and paragraph number) with each such tact.
D.
Interrogatories on Contention 1.c II-1.c-1.
Do you allege that the kinetic expansion repair weakened the tubes such that plugs.will not be able to hold and give a good seal?
II-1.c-2.
If the answer to the preceding Interrogatory is other than an unqualified "no":
(a)
Identify each type of plug which you allege will not be able'to hold and give a good seal;
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(b). State in detail each and every fact upon which you base your allegation that each such type of plug will not be able to hold and give a good seal; and (c)
Explain in detail how each fact stated in your answer to (b) above supports your allegation that each such type of plug will not be able to hold and give a good seal.
II-1.c-3.
Identify each-and every document which you claim supports each fact set forth in your answers to Interrogat'ories II-1.c-1 and II-1.c-2 above, and correlate each such. document as specifically as possible (page and paragraph number) with each such fact.
II-1.c-4.
Define and explain the extent to which you allege a plug must be able to " hold."
II-1.c-5.
Define and explain the extent to which you allege a plugLmust be able to "give a good seal."
Include in
-your answer your definition of a " good seal.".._
II-1.c-6.
Provide the factual, legal, and regulatory basis for your responser to Interrogatories II-1.c-4 and
-II-1.c-5 above.
II-1.c-7.
Identify each and every document which you claim supports each fact set forth in your answers to m-Interrogatories II-1.c-4 through II-1.c-6 above, and correlate
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each such document as specifically as possible (page and para-graph number) w$th each such fact.
E.
Interrogatories on Contention 1.d II-1.d-1.
What do you mean by "any independent analysis" which you allege appears not to have been done by either the Third Party Review Group or the NRC Staff?
II-1.d-2.
If no independent analyses (as defined in your answer to' Interrogatory II-1.d-1) was performed by either the Third Party Review Group or the NRC Staff, do you allege that this fact renders the " Report of Third Party Review of Three Mile Island, Unit 1, Steam Generator Repair ("TPR") or the Staff's Safety Evaluation Report ("SER") incredible documents in their evaluation of "the kinetic expansion repair technique including leak tightness and load carrying capabilities"?
II-1.d-3.
Explain how each of the alleged inconsistencies identified in your response to Interrogatory 1.d-3 in response to the first set of interrogatories and in response to Inter-
'rogatory 1.d-3 in Part I above undermines or is inconsistent with the evaluation in the TPR and SER of the " kinetic expan-sion repair technique, including leak tightness and load carrying capabilities".
III-1.d-4.
Identify each'and every document which you i
i claim ^ supports each fact set forth in your answers to Interrogatories II-1.d-1 through II-1.d-3 above, and correlate-E each such document as specifically as possible (page and para-graph number) with each such fact.
II-1.d-5.
Describe the relationship between the "Rockwell Hardness Tests" and tests to evaluate toughness.
II-1.d-6.
State in detail each and every fact upon which
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you base your allegations in your response to Interrogatory II-1.d-5, and explain in detail how each such fact supports the allegation.
II-1.d-7.
'Do1you claim that Licensee should have performed the "Rockwell Hardness Tests" on any corroded tubes:
(a) 'before the expansion repair; and (b) after the expansion repair.
II-1.d-8.
If your answer to Interrogatory II-1.d-7 is
.other'than an unqualified "no",
state in detail each and every fact upon which you base such' allegation, and' explain in detail how each such fact supports the allegation.
LII-1.d-9.
Identify where in TPR you allege that the Third Party Review Group "seems to reject the axial symetric assump-
' tion analyzing str' esses in the transition zone", and explain.
why you think the allegation to be true.
II-1.d-10.
-Identify each and every document which you
. claim supportsteach fact set forth'in your answers to Interrogatories.II-1.d.5 through II-1.d.-9 above, and correlate,
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i, eachsuchdocumen[tasspecificallyaspossible(pageand
. paragraph number) with each such fact.
II-1.d-11'.
Do you allege that the fact that post repair testing assumptions are based on a cool-down failure mode (a) has any relevance to the alleged " failure to an-nlyze crack resistance on the, basis of toughness as opposed to hardness"; and
-(b) undermines Licensee's analysis of crack resistence?
4 II-1.d-12.
If your answer to Interrogatory II-1.d-11(b) state in' detail'each and is other than an unqualified "no",,
every fact upon which you base your allegation, and explain how
'each-such fact supports those allegations.
II-1.d-13.
Identify each and every-document which you claim supports each fact set forth in your answers to 1
' Interrogatories II-1.d-11 and II-1.d-12, and correlate each
-such document as specifically as possible (page and paragraph number) with each such fact.
II-1.d-14.
Do you allege 4 hat the fact that the post repair = testing assumptions are basedjon a cool-down failure mode (a) has any relevancb to the alleged-failure to dif-ferentiate the effect of thermal' btress on small.versus large cracks; and (b) undermines Licensce's analysis of thermal stress?
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If your answer to Interrogatory II-1.d-14(b) is other than an unqualified "no",
state in detail each and every fact upon which you base your allegation, and explain how each such fact supports that allegation.
II-1.d-16.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories II-1.d-14 and II-1.d-15, and correlate each such document as specifically as possible (page and paragraph number) with each such fact.
F.
Interrogatories on Contention 2.a II-2.a-1.
How does the Staff's statement at pages 7 and 8 of the SER that "the sodium thiosulfate concentration of 4 to 5 ppm is the contaminant which 'most likely' caused the OTSG deg-radation" support your allegations. that:
(a).the " causative agent" has not been properly iden-tified; (b) that the " source of initiation" has not been properly identified; and (c) that "the conditions under which initiation of the IGSCC: originally occurred" have not been properly identi-fied?
II-2.a-2.
State in detail each and every fact upon which you. base your allegations in your answer to Interrogatory II-2.a.-1 above, and explain in detail how each fact supports your allegations...-
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II-2.a-3.
- Explain.how the statement by the NRC Staff at
.a page 8 of-the SER that the failure scenario has not been clear-ly established qupports your allegations that:
(a) the." causative agent" has.not been properly
. identified;
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(b) the." soured af initiati~on" has not been properly n
identified; and
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the " conditions under which initiation of the (c)-
ICSCC: originally occurred" have not been properly identified.
II-2.L-4.
Stat,e. in detail.,each arid every fact upon which you base the~ allegations in your answer to Interrogatory
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II-2.a-3, and explain in detail 6how each fact supports your al-2 legations..
II-2.a-5. ' Explain how the "three previo'us contaminations p
which.may have caused' corrosion"' recognized at page'8 of the SER supports your'(allegations that:
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(a)-,thel"causativ'eagent"hasnotbeenhroperly s
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(b) thit the " source of initiftion"chas not been 1
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..(c). that the " conditions under which th,e initiation of the IGSCC originally occurred" have nSt,been' properly iden-tified.
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II-2.a-6.
$ tate in detAli,each and'every fact upon which
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lyou. base your, allegations 'in /y'our answe$ to Interrogatory t-v II-2.a-5,'and explain in detailshow each fact stated.in your answer.supporti,yobr allegations.
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II-2.a-7.
Explain how Mr. Dillon's comment at page 12 of his report regarding " inconsistencies in the cracking environ-
. ment" which "certainly invite questions", his concerns about contradictions regarding the cracking solution chemistry, and his suggestion that a corrosion test be conducted in a cold high oxygen and high concentrate sulfate environment support your allegations that:
(a) the " causative agent" has not been properly identified; (b) the " source of initiation" has not been properly identified; and (c) the " conditions under which initiation of the IGSCC originally occurred" have not been properly identified.
II-2.a-8.
State in detail cach and every fact upon which you base your allegations in your answer to Interrogatory II-2.a-7, and explain in detail how each fact stated in your answer supports your allegations.
II-2.a-9.
Explain how Mr. Mcdonald's comments at pages 18 through 24 of his report discussing the possible role of a polysulfur species, observation of the sulfur deposits of an unknown form in the system, and the possible introduction of thiosulfate in the system sometime earlier than September 1981 support your allegations that:
(a) the " causative agent" has not been properly identified; _
r (b) the " source of initiation" has not been properly identified; and (c)
.the " conditions under which initiation of the IGSCC originally occurred" have not been properly identified.
II-2.a-10.
State in detail each and every fact upon whien you base your allegations in your answer to Interrogatory II-2.a-9, and explain in detail how each fact stated in your answer supporta your allegations.
t II-2.a-11.
Identify each and every document which you claim supports each fact set forth in your answers to Interrogatories II-2.a-1 through II-2.a-10, and correlate each such document as specifically as possible (page and paragraph number) with each such fact.
II-2.a-12.
Do you allege that the failure to definitively establish which form of sulfur causes the IGSCC in the TMI-1 OTSG would undermine "the reliability of any proposed clean-up process, procedures meant to eliminate corrosive environment, or the reliabilit.y of the Licensee and Staff stress analysis as to when corrosion would rooccur?"
II-2.a-13.
If your answer to Interrogatory II-2.a-12 is other than an unqualified "no",
state in detail each and every fact upon which you base your allegations, and explain in de-tail how each fact stated in your answer supports your allega-tions.
II-2.a-14.
Do you allege that the cracking of the TMI-1 OTSG did not occur during cool-down?
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II-2.a-15.
If your answer to Interrogatory II-2.a-14 is other than an unqualified "no", explain in detail each and every fact upon which you base your allegation and explain how each such-fact supports your allegation.
II-2.a-16.
Identify each and every document which you claim 1 supports each fact _ set forth in your answers to Interrogatories II-2.a-12 through II-2.c-15, and correlate each such document as specifically as possible (page and paragraph number) with each such fact.
H.
Interrogatories on Contention 2.b.2 II-2.b.2-1.
Do you claim that the estimate of 20 to 50%
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sulfur remaining in the TMI.1 OTSG fails to take into account that piping and components of less than one inch in diameter were not flushed during the cleaning process?
II-2.b.2-2.
If your_ answer to Interrogatory II-2.b.2-1 is other than an unqualified "no",
explain in detail each and every fact upon which you base this allegation.
II-2.b.2-3.
Do'you' allege that the failure to flush piping and components of less than one inch in diameter cignif-icantly. increases the likelihood of corrosion?
II-2.b.2-4.
If your answer to Interrogatory II-2.b.2-3 is other than an unqualified "no",
state in detail each and every fact upon which you base your allegation, and explain in detail how each fact stated in your answers supports the allegation.
II-2.b.2-5.
Identify each and every document which you
- claim supports each fact set forth in your' answers to 18-W
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' Interrogatories II-2,b.2-1 through II-2.b.2-4, and correlate each such document as specifically as possible (page and para-graph number) with each such fact.
III. REQUEST FOR PRODUCTION OF DOCUMENTS Pursuant to 10 C.F.R.
$ 2.741, Licensee hereby requests that.TMIA respond in writing to the following request for pro-duction of documents and produce the original or best copy of each requested document at the office of the undersigned, Shaw, Pittman, Potts & Trowbridge, 1800 M Street, N.W.,
- D.C.
20036 or at another place mutually convenient to the parties.
Licensee requests that-TMIA produce each and every document identified or described in the answers to the Interrogatories in sections I and II above, unless those documents were prepared by Licensee or the NRC Staff with respect to the TMI-1 steam generator repairs.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE I
BY:
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P.C.
Ge6Vge F. Trowb51dge, Bruce W.
Churchill',
P.C.
Diane E.
Burkley Wilbert Washington II Counsel for Licensee 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 DATED:
. January 12, 1984.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before'the Atomic Safety and Licensing Board in the Matter of
)
)
Docket No. 50-289-OLA
~ METROPOLITAN EDISON COMPANY, ET AL. )
ASLBP 83-491-04-OLA
)
(Steam Generator Repair)
(Three. Mile Island Nuclear
)
Station, Unit No. 1)
)
CERTIFICATE OF SERVICE I hereby. certify that copies of " Licensee's Second Set of Interrogatories and Request for Production of Documents to In-tervenor TMIA" were served this 12th day of January, 1984, b'y deposit-in the U.S.
mail, first class, postage prepaid to those
- on'the attached Service List.
Es W
Bdted W.
Churchill, P.C.
-Dated:
January 12, 1984
.b
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic 6afety and Licensing Board In'the Matter of
)
).
.. METROPOLITAN EDISON COMPANY, ET AL. )
Docket No. 50-289-OLA
-)
ASLSP 83-491-04-OLA (Three' Mile Island Nuclear
)
(Steam Generator Repair)
Station,' Unit No. 1)
)
SERVICE LIST Sheldon J. Wolfe Atomic Safety and Licensing
~
Administrative Judge Board Panel Chairman, Atomic Safety and U.S. Nuclear Regulatory Commission
. Licensing Board Washington, D.C.
20555 U.S.-Nuclear Regulatory Commission Docketing and Service Section (3)
Washington, D.C.
-20555 Office of the Secretary U.S. Nuclear Regulatory Cocmission Dr. David L. Hetrick Washington, D.C.
20555
~
. Administrative Judge Atomic Safety and Licensing Board' Joanne Doroshow, Esq.
-Professor of Nuclear Engineering
. Louise Bradford University of Arizona Three Mile Island Alert, Inc.
Tucson, Arizona 85271 315 Peffer Street Harrisburg, Pennsylvania 17102
- Dr. James C. Lamb, III
' Administrative' Judge Jane Lee' Atomic Safety and Licensing Board 183 Valley Road 313 Woodhaven Road
'Etters, Pennsylvania 17319 Chapel Hill,. North Carolina 27514 Norman Aamodt Richard J.
Rawson, Esq.
R. D.
5, Box 428 Mary E. Wagner, Esq.
Coatesville, Pennsylvania 19320 Office of Executive Legal Director m
U.S. Nuclear' Regulatory Commission Washington, D.C.
20555
' Atomic Safety and Licensing Appeal Board. Panel U.S. Nuclear Regulatory Comission
. Washington, D.C.
20555 i
I