ML20080U179
| ML20080U179 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 02/24/1984 |
| From: | Wilkie W CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20080U150 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8403020192 | |
| Download: ML20080U179 (19) | |
Text
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g- -* RR ATED CORRESPONDENCE DOCKETED USN.RC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION *84 liI.R -l All 47
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BEFORE THE ATOMIC SAFETY AND LICENSING' BOARD
In the Matter of )
)
CAROLINA POWER & LIGHT COMPANY)
AND NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY ) 50-401 OL
)
(Shearon Harris Nuclear-Power )
Plant, Units 1 and 2) )
AFFIDAVIT OF DR. WILLIAM H. WILKIE IN SUPPORT OF APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF JOINT INTERVENORS' CONTENTION V County of Wake )
) -SS:
State of North Carolina )
William H. Wilkie, being duly sworn according to law, deposes and says:
- 1. I am employed by Carolina Power & Light Company
("CP&L") as Principal Health Physics Specialist. My business address is Shearon Harris Energy & Environmental Center, Route 1, Box 327, New Hill, North Carolina 27562. A statement of my background and qualifications is affixed hereto as Attachment A. I have a Ph.D. degree in nuclear engineering from the Georgia Institute of Technology. I have extensive professional experience in the areas of aerosol physics, inter-nal dosiinetry, emergency preparedness,.and health physics 9403020192 840227 PDR ADOCK 05000400 g PM
l programs'in support of nuclear power operations. Therefore, I have personal knowledge of the matters stated herein and be- ,
lieve *bem-to be true and correct. I make this affidavit in
, support of Applicants' Motion for Summary Disposition of Joint Intervenors' Contention V.
- 2. . Joint Contention'V concerns the use during emergency conditions of the continuous air monitors (" CAMS") and portable air. samplers. referenced in Section 12.5.2.1.7.3 of Applicants' Final Safety Analysis Report ("FSAR"). An additional stock of portable air samplers, not described in the FSAR, is maintained off-site for use during emergencies at.the Shearon Harris Nu-
- clear. Power' Plant ("SHNPP"). -Because this equipment is similar
- to the units Applicants intend to purchase for in-plant use, these emergency portable air samplers have been included in the following discussion.
- 3. In this affidavit,- I will (1) describe how CAMS and portable air--samplers are used during emergencies, (2) define Applicants'_ program for inspecting and calibrating this equip-ment for air flow, (3) discuss the accuracy of air flow mea-
-surements, (4) summarize.the Joint Intervenors' position relat-Jed to calibration frequencies and accuracies, and (5) show that the Joint Intervenors' proposals are both impractical and un-necessary.
- 4. CAMS are large, portable instrument assemblies that are: rolled to particular plant ~ areas (normally in the reactor, auxiliary, waste processing, and' fuel handling buildings) and v ,., -
operated for long-term monitoring purposes. The primary func-tion of CAMS is to detect during normal plant operation long-term trends in airborne radioactivity that may indicate system
- deterioration that needs identification and maintenance or oodaer problems that may nee'd correction. These devices are
. equipped with audible _and visual alarms that activate on de-tection of preset levels of radioactivity. In the event of an emergency,. CAMS.may alarm.at the detection of high levels of airborne radioactivity and signal a previously unidentified ac-cident. . After an emergency condition is recognized, CAMS may
'be. moved to areas such as the control room, technical support center, and waste processing building to monitor habitability conditions during the course of the accident. However, they are classified as non-safety related equipment and are not relied on as being essential for identification of accidents or hazardous conditions or for exposure control during emergencies.
- 5. Portable air samplers are lightweight (10 to 60 l ~ pounds) devices that are transported to an in-plant or off-site i.-
location to pump a known volume of air through a filter for subsequent analysis for deposited radioactivity and calculation of concentration in air. Sampling times for these devices are l;
P typically less than 30 minutes. Decisions regarding the need
- for-respiratory protection for emergency staff and the need for protective actions for the public may be made partly on the-basis of these measurements. Portable. air samplers are the l
ll )
s 1
4 1 .
' appropriate devices for use in determining airborne
. radioactivity concentrations for several reasons. Unlike CAMS,
'the filter-heads of portable air samplers can be accurately po-sitioned to draw air from the specific region of' concern, e.g.
in'the-breathing zone for the job being monitored or planned.
Also, laboratory analysis of-the filters provides higher de-tsetion~ sensitivity and identification of specific nuclides which is-not possible with CAMS.
- 6. ~During emergency conditions, CAMS may indicate the presence of levels of airborne radioactivity that may warrant investigation. However, CAMS are not used to detern;'ne accurately airborne radioactivity concentrations, are not
. relied on to signal the requirement for respiratory protection and are not used to estimate internal exposure. Rather, CAMS
-are used to indicate a potential problem and a possible need more. accurately to define the magnitude of an airborne
~
radioactivity hazard. Should a need arise for establishing the concentration of radioactivity in air, a portable air sampler is used'as described in paragraph 5. After an appropriate vol-ume of air has been drawn, the filter is removed and taken to a Ecounting laboratory for analysis of the radioactivity collect-ed.
- 7. Air-flow rates for both the CAMS and the on-site por-
. table air' samplers-will be calibrated at least once every six
' months'rather-than annually:as alleged by the Joint Intervenors and as currently stated in Applicants' FSAR. (Applicants are
. . - . = .. -. . . .
.in the process'of amending their FSAR to reflect this change.) i Whenever mechanical or electronic faults are identified and
-whenever there is reason to believe.that the operating charac-teristics have changed, the procedure is to remove the unit from service until it is checked, repaired, and recalibrated as necessary. A central stock of emergency portable air samplers His available for.use both inside the' plant and in the environs.
These units are being calibrated under my supervision at
'six-month intervals. ' Twenty-eight of these emergency units currently are maintained in standby status at the central labo-ratory facility located approximately 2.5 miles from SHNPP.
- 8. The calibration procedures for the emergency air sam-
~
.plers that will be used at SHNPP are based on the use of Kurz electronic mass-flow meters. See " Applicants' Responses to ;
Joint Intervenors' General Interrogatories and Interrogatories on Contentions IV, V, and VI to Applicants Carolina Power &
. Light Company, Et A1. (First Set)," dated August 1, 1983, at
- 13. Kurz model 341CTis used for calibrating high-volume air samplers having flow rates between 15 and 60 standard cubic feet per-minute ("SCFM"). This instrument has an overall accu-i racy _of 1 1 SCFM according to the manufacturer's specifica-tions. This accuracy corresponds to approximately 1 4 percent for-the high-volume emergency. air samplers. Kurz model 544 is used'for calibrating low-volume air samplers having flow rates between 2 and 4 SCEM. According to the manufacturer's specifi-cations, Kurz model 544 has an accuracy of 1 2 percent over the
+
I entire scale. Each of these Kurz instruments is factory cali-brated annually using standard mass-flow meters and associated equipment traceable to the National Bureau of Standards.
g 9. The CAMS, portable air samplers, and mass-flow calibration equipment will be selected and purchased for the SHNPP health physics. program in late 1984 and early 1985, at a time nearer to the anticipated fuel-loading date, in order to ensure that the equipment selected is state-of-the-art at the time the plant begins to operate. The calibration accuracy for the air flow through these in-plant devices is expected to be at least equivalent.to that currently attained for the emergen-cy portable air samplers; i.e., approximately + 5 percent. i
- 10. Joint Intervenors' contention and their responses to
' interrogatories propounded by Applicants and the Staff have not served to establish the reasons for their apparent concern re-garding Applicants' programs for inspection and-calibration of flow rates through the CAMS and portable air samplers. Because
. - no facts, reference documents, or. explanations have been pro-vided to establish a basis-for Joint Intervenors' responses or for the contentionLitself, it is difficult to address any con-cerns that the Joint Intervenors may have.
- 11. The generally accepted practice in the nuclear power
- industry for. calibrating: air sampling' instruments is to design
' calibration' programs in accordance_with Regulatory Guide 8.25,
" Calibration and Error Limits of Air Sampling Instruments for Total Volume of Air Sampled." Applicants' calibration programs f
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meetlthe specifications in this regulatory guide which define acceptable calibration frequencies (once every 6 months), error
. limits in volume determination (less than 20 percent), and doc-
.umentation. Applicants also.use standard methods for
-calibrating air flow rates as described in the manual entitled
" Air' Sampling Instruments for Evaluation of Atmospheric Contaminants," 6th Edition,.1983, published by the American Conference of. Governmental Industrial Hygienists.
- 12. Although Joint Intervenors have stated that Appli-cants' compliance with Regulatory Guide 8.25 would not satisfy
.. their. concerns with respect to the frequency of calibrating CAMS and portable air samplers, - they have failed to explain the basis for their belief that the guidelines of Regulatory Guide 8.25 are inacequate. Joint Intervenors did state that "ALRA
-[ sic] requires m'inimization of exposure. Monitoring accuracy is necessary to' provide assurances that ALARA will be achieved.
Calibrations every sixth month are inadequate to assure this."
" Joint-Intervenors Response to Applicants' Interrogatories and Request 1for Production of Documents to Joint Intervenors (First Set),"fdated March 29, 1983, Response to Interrogatory V-3.
This response indicates that Joint Intervenors do not under-L stand the purpose or implementation of the ALARA criterion.
.The.~ implementation'of an effective ALARA program depends pri-marilyf on engineering design analysis, procedure review, job planning, and' training, and only secondarily on measurements made while work is being performed, as the Joint Intervenors
g, .
e - apparently contend. Furthermore, ALARA applies strictly to '
routine plant operation.and not to-major accident situations l and emergency procedures. The contention as stated refers only tolthe availability and use of CAMS and portable air samplers
". . . in the event of an emergency," not during routine op-erations.
- 13. -Joint Intervenors have also stated that CAMS and por-table air samplers should be calibrated to within.1 5 percent and that Regulatory Guide 8.25 is inadequate because it allows a cu'mulative error in air flow calibrations of 1 20 percent.
It is Joint Intervenors' position that a monthly calibration
' would be adequate unless any unit is observed to deviate more than 5 percent from the previous calibration.
- 14. The validity of Joint Intervenors' position with re-spect to monthly calibrations must be evaluated by asking if '
implementation could reasonably be expected to result in an im-provement in the capability for meeting program objectives. In this context, the reference obj'ectives are-(1) the ability to make sound decisions regarding.the need for respiratory protec-tion inside the nuclear plant, and (2) the ability to form rea-sonable recommendations concerning actions to protect the pub-L l lic from accidental releases of radioactivity to the environment.-
- 15. -It is very-unlikely that any improvement in Appli-cants' -ability to protect the"public or its plant personnel during an emergency would result from ensuring that CAMS and 1 1
. o portable air samplers are always within + 5 percent of the cal-ibrated flow rate. As discussed in paragraphs 4 and 6, CAMS provide qualitative information on the relative levels of radioactivity concentration in air and are set to alarm on de-tection.of unexpected or unnoticed increases to levels that may be'potentially significant. An alarm does not automatically
.: signal a. hazardous condition but merely indicates a need for -
evaluation by a health. physicist.
- 16. . Joint Intervenors' belief that a 20 percent deviation ;
with regard to tdun portable air samplers is too great is also without merit. A 20 percent deviation from the calibrated 4
value in the air flow rate through portable air samplers will have no significant influence on decisions regarding respira-to'ry. protection. In the first place, respiratory protection within CP&L nuclear plants usually is specified whenever the measured concentration in the. breathing zone is greater than 25 percent of th'e maximum permissible concentration ("MPC") values listed-in 10 C.F.R. Part 20, Appendix B, Table 1, Column 1.
'usis is a very conservative approach to int'ernal exposure con-
. trol. In the second place, internal doses are calculated using
~ bioassay procedures that are completely independent of the mea-surements of airborne concentration. If significant internal exposure may have occurred during emergency conditions, then,
.at the' discretion of emergency management specialists, bioassay
. procedures 1may be specified to quantify the internal dose com-
-mitment. -Internal doses cannot be accurately determined using A
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portable air samplers regardless of how accurate the air flow is known to be.
- 17. Applicants' position regarding their approach to air-borne radioactivity monitoring has been endorsed by the Nation-al Council on Radiation Protection and Measurements ("NCRP"), a recognized authority in the field, which has stated:
Instruments used for the monitoring of contaminants in air or effluents should have high' sensitivity because the amount of radio-active material is usually small. Since the measurements are frequently only qualitative, the instruments need not be highly accurate.
(emphasis added.) See 5 5.2.2 of " Instrumentation and Moni-toring Methods for Radiation, Protection," NCRP Report 57, Washington, D.C. (1978).
- 18. The final point of thin affidavit concerns Joint In-tervenors'. statement regarding frequency of inspections. Joint Intervenors have stated:
Applicants intend to calibrate and inspect continuous air' monitors and portable air sam-plers only once annually.
However, CAMS normally are inspected daily for proper operation during use and are response checked approximately weekly using radioactive sources. .Therefore, this equipment would be readi-ly available and would function properly during an emergency.
Portable air samplers used in the routine health physics pro-gram are inspec*.ed each time the equipment is used. The emer-gency portable air samplers undergo a thorough inspection dur-ing the semiannual calibration. These units are not expected L t ,
l to deviate from the previous calibration because they are kept in a standby mode and are stored in a controlled environment.
- 19. In summary, Applicants' use of CAMS and portable air samplers is appropriate and adequate to ensure worker health and safety. Applicants use approved techniques to calibrate CAMS and portable air samplers, and the instruments are accurate enough to provide the information necessary for inter-nal exposure control. Calibration of CAMS and portable air samplers once a month to + 5 percent accuracy would not result in any improvement in Applicants' ability to protect the health and safety of Plant personnel or the public during an emergency
. situation.
V b ." , f. W William H. Wilkie Subscribed and sworn to before me this 29 6 day of February, 1984.
Y A. $
Nota Public
~
My Commission expires: 9QTr!TO
/
/
Attachment A BIOGRAPHICAL DATA DR. WILLIAM H. WILKIE
' EDUCATION Als TRAINING 1967-1970 Georgia Institute of Technology, Atlanta, GA Nuclear Engineering / Biology / Radiological Physics Specialization Ph.D.
1960-1962 Vanderbilt University, Nashville, TN Physics / Mathematics / Health Physics Specialization M.S.
1957-1960 North Carolina State University, Raleigh, NC Nuclear Engineering / Engineering Mathematics B.S. (high honors)
Graduate study one semester 1955-1957 Maryville College, Maryville, TN Mathematics / Physics (no degree) 1984 Chem-Nuclear Systems, Inc., Columbia, SC
" Regulatory Awareness--Radioactive Waste Packaging, Transportation, and Disposal" 1979 Oak Ridge Associated Universities and Department of Energy , Oak Ridge, TN
" Health Physics in Radiation Accidents" 1976 Institute for Advanced Technology, Washington, DC
" Data Communications Systems" i
1967 University of Tennessee, Knoxville, TN Biology 1962 Oak Ridge Institute of Nuclear Studies, Oak Ridge, TN
" Advanced Radioisotope Technology"
.1971-1981 Tennessee Valley Authority, Muscle Shoals, At l- Numerous courses in computer training, management, systems develop-ment, etc.
CERTIFICATION American Board of Health Physics PROFESSIONAL ORGANIZATIONS Health Physics Society International Radiation Protection Association 1
Attachment A BIOGRAPHICAL DATA DR. WILLIAM H. WILKIE PROFESSIONAL ORGANIZATIONS (cont.)
American Nuclear Society Sigma Xi HONORARY SOCIETIES Phi Kappa Phi Sigma Pi Sigma Tau Beta Pi EXPERIENCE (Active in the field of health physics for 23 years) 1983- Carolina Power & Light Company, Raleigh, NC Principal Health Physics Specialist 1981-1983 Electricity Supply Commission, Cape Town, South Africa -
Regional Senior Health Physicist Consultant
.1971-1981 Tennessee Valley Authority, Muscle Shoals, AL Staff Health Physicist 1970-1971 University of Pittsburgh, Pittsburgh, PA Assistant Professor of Health Physics, Graduate School of Public Health Technical Director, Radiation Medicine Department, Presbyterian-University Hospital 1968-1970 Technical Analysis Corporation, Atlanta, GA Systems Development Engineer (part time) 1962-1967 Oak Ridge National Laboratory, Oak Ridge, TN Research Associate PREVIOUS CONSULTING Radiological Assessment Systems for Nuclear Power Technology for Energy Corporation
.0ak Ridge National Laboratory Advanced Research Corporation 2
., - \
Attachm:nt A
. ~
BIOGRAPHICAL DATA DR. WILLIAM H. WILKIE s
BOOKS AIS PUBLICATIONS m Wilkie, W.(H., W.. J. Millsap, and J. Walmsley, " Planning Bases for Radiological E.wergency Response 'Near the Koeberg Nuclear Power Station," Escom Report, April'1983
'"Operat ons 94anual--Tycerberg Radiation Casualty Facility," Escom/
Tygerberg Hospital Report,1983
" Upgrading -Environmental Radiation Data," USEPA Report EPA
'520/1-80-012, Augu'st 1980 Wilkie, W. ' H., and M. S. Robinson, " Browns Ferry Nuclear Plant Emergency ' Dose Assessment Procedures for Atmospheric Releases of Radioactivity," TVA Report OHS-20-80-03,' April 1980 Robinson, M. S. , and . W. H. Wilkie, " Browns Ferry Nuclear Plant Emergency Dose Assessnent Procedures for Liquid Releases of Radio-m activityi" TVA Report 0HS-20-80-04, Aprf1 '1930
's Wilkie, W. H.,' S. M. Ncison, arid ii. S. Robinson, " Technical Bases for Emergency Dose Assessment Procedures for Liquid Releases of
, Radioactivity," TVA Report' OllS-20-80-06, May 1980
- Wilkie, W. H., and M. S. Robinson, " Technical Bases for Emergency
_ Dose Assessment Procedures for Atmospheric. Releases of Radio-activi_ty," TVA Report 0HS-20-80-05, May 1980 LWilkie, W. H.,' and M. S. Robinson, "Sequoyah Nuclear Plant Emer-gency Dose Assessment Procedures for Atmospheric Releases of Radio-
- s. activity,"' TVA Report 0HS-20-80-01, April 1980 Robinson, M.: S., and W. H. 'Wijkie, "Sequoyah Nuclear Plant Emer-gency Dose Assessment Procedures for Liquid Releases of Radio-activity,"sTVA Report OHS-20-80-02, April 1980 r " America 1 National . Standard; for Internal Dosimetry for Mixed Fis-
- sion and. Activatici Products," ANSI N343-1978
~ 4 "The Ter.nessee Valley Region Study: Potential Year 2000 Radiologi-cal Dose- to Population. Resulting from Nuclear Facility Operations,"
a '
00E/ET-0064/2,~ June 197,9 Garry , S. M. , and W. 'H. ilkie, "The' Use of Environmental Monitor-
~ 1ng Data in sDetermining Background Radiation Doses," Population
' Exposures, USAEC Report CONF-741018 (1974) 8 v
4
^
's -
, ~ _ __ . . _ - . _ _ _ _ _ - _ _ _ . _ _ _ _. _ _
Attachm:nt A BIOGRAPHICAL DATA DR. WILLIAM H. WILKIE BOOKS AND PUBLICATIONS (cont.)
Wilkie, W. H., "The Interdiscip11 nary Nature of the Radiological Impact of Nuclear Plant Effluents on the Environment," Proceedings of TVA Task Force on Water Resources Research Meeting--The Growing Need for Interdisciplinary Research,1974 Fish, B. R. and W. H. Wilkie, "The Fluid Dynamics of the Spherical Particle: (1) Tabulation of Settling Velocity, Reynolds Number, Drag Coefficient, Relaxation Time, and Acceleration-Distance in Air and Water," USAEC Report ORNL-TM-4100 (1973)
Wilkie, W. H., "The Spatial and Tempore' Capture Distribution for Neutrons in a Coaxial, Two Medium, Liquid Scintillation Detection System," Advanced Research Corporation, Atlanta, GA, February 1970 "Biohazards of Aerospace Nuclear Systems, Final Report," T. C.
Clark, B. R. Fish, W. H. Wilkie, J. L. Thompson, R. H. Boyett, and G. W. Royster, Jr., SC-CR-69-3291 (1969)
Wilkie, W. H., and D. S. Harmer, " Theoretical Modulation Transfer Functions and Dosimetry of Fast-Neutron Radiography," Biomedical Sciences Instrumentation-Volume 6, Instrument Society of America, Pittsburgh, PA (1969)
Wilkie, W. H., and B. R. Fish, " Scintillation Extrapolation Dosim-etry of Small Beta-Emitting Sources," Solid State and Chemical Radiation Dosimetry in Medicine and Biology, IAEA, Vienna, Austria (1967)
" Environmental Studies: Radiological Significance of Nuclear Rocket Debris," (A series of reports involving classified research)
USAEC Reports ORNL-TM-1053 (1965), ORNL-TM-1159 (1966), ORNL-TM-1686 (1966)
Wilkie, W. H., and R. D. Birkhoff, " Measurement of Spectral Distri-bution of Positron Flux in an Infinite Copper Medium Containing Cu-64," Phys. Rev., g , A1133 (1964)
More extensive report on the positron research published as USAEC Report ORNL-3469 (1963) 4
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EEI ATED CaanE3i'UllDMCE
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, UiNer i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION *g4 WR 'I Oll I47 s jc BEFORE THE ATOMIC SAFETY AND LICENSING BOARD LIFli.i0:S(r4GCChti ,'
CRAliCH cf In the Matter of . )
)
CAROLINA-POWER & LIGHT. COMPANY ) Docket Nos. 50-400 OL AND' NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
Plant, Units 1 and 2) )
... CERTIFICATE OF SERVICE
~
., I hereby-certify,that copies of all the documents listed on the. attached Document List were served this 27th day of
. February,'1984, by deposit in the U.S. mail, first class,
~
postage prepaid,.to the parties on the attached Service List.
i /
2/ W Pamela H. Anderson
.Datedr , February 27, 1984 W
- i
4
. . . - +
DOCUMENT LIST
- 1. " Applicants' Motion for Summary Disposition of Joint Intervenors' Contention V (Continuous Air Monitors and Portable Air Samplers)"
- 2. " Applicants' Statement of Material Facts As To Which There Is No Genuine Issue To Be Heard On Joint Contention V," and
- 3. " Affidavit of Dr. William H. Wilkie" and Attachment A Affixed thereto.
l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
- Plant, Units 1 and 2) )
SERVICE LIST Janes L. Kelley, Esquire -John D. RunPJ.e, Esquire Atanic Safety and Licensing Board Conservation Council of North Carolira U.S. Nuclear Regulatory Ccmnission 307 Granville Road Washington, D.C. 20555 Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atanic Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Ccmnission P.O. Box 12607 Washington, D.C. 20555 Raleigh, North Carolina 27605 l
Dr. Janes H. Carpenter Dr. Richard D. Wilson Atanic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory h i=sion Apex, North Carolina '27502 Washington, D.C. 20555 Mr. Wells Eddlenan Charles A. Barth, Esquire 718-A Iredell Street Janice E. Moore, Esquire Durhan, North Carolina 27705 Office of Executive Legal Director U.S. Nuclear Regulatory Ccmnission Richard E. Jones, Esquire Washington, D.C. 20555 Vice President and Senior Counsel Carolina Pcwer & Light Canpany Docketing and Service Section P.O. Box 1551 Office of the Secretary Raleigh, North Carolina 27602 U.S. Nuclear Regulatory Ccmnission Washington, D.C. 20555 Dr. Phyllis Ictchin 108 Bridle Run Mr. Daniel F. Pead, President Chapel Hill, Forth Carolina 27514 CHANGE /ELP 5707 Waycross Street Dr. Linda W. Little Raleigh, North Carolina _ "27606 Governor's Waste Managernent Board 513 Albernarle Building 325 North Salisbury Street Raleigh, North Carolina 27611 1
- + - =
r::
Bradley W. Jones,-Esquire U.S. Nuclear _Regtlatory Camrission Region II
'101 Marrietta Street Atlanta, Georgia .30303 Ruthanne G.'. Miller, Esquire Atanic Safety and Licensing Board Panel
~
U.S. Nuclear Regulatory Crweiasion Washington, D.C. 20555 Mr. Robert P. Gruber Executive Director Public Staff - NCUC P.Os Box 991
-Raleigh, North Carolina 27602 b
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