ML20081C908
| ML20081C908 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/28/1983 |
| From: | Blake E METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| References | |
| NUDOCS 8310310382 | |
| Download: ML20081C908 (20) | |
Text
00CKETED USNRC UNITED STATES OF AMERICA 13 OCT 28 P2:04 NUCLEAR REGULATORY COMMISSION CrrTE0:3[cn +
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L T ' N 3 A S E,,
BEFORE THE COMMISSION J">"
In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket 50-289
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(Three Mile Island Nuclear
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Station, Unit No. 1
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LICENSEE'S NOTICE TO COMMISSION, APPEAL BOARD, LICENSING BOARDS AND PARTIES Enclosed for information is a copy of a speech to be delivered by H.
Dieckamp at the AIF Annual Conference on November 1, 1983.
Because Chairman Palladino is scheduled also to be a speaker at this conference, Licensee, out of i
an abundance of caution, is distributing the speech in advance.
Respectfully submitted, Blake,f.,Esq.
G, Ernes L.
Jr Counsel for Licensee cc:
Attached Service List 8310310,792 831028 PDR ADOCK 05000289 go eDR
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TMI - 4 1/2 YEARS LATER A STATUS REPORT AIF 1983 ANNUAL CONFERENCE I ^
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H. DIECK AMP l-200
- T NOVEMBER 1, 1983
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I last appeared before this group, my peers, on November 12,1979
- 7 1/2 months after the accident at Three Mile Island. Today, it is 4 1/2 years since the accident. In November of 1979 we had just received the results of the Kemeny Commission. I reviewed with you then our interpretation of the accident and its und'erlying cause. I further gave you my impression of the major technical / management learnings from the accident. I cited three major learnings; the need for experience feedback, the need for increased technical capability, and the need.for deeper and broader training. The combination of INPO, NSAC, and the organizational responses of the i
nuclear plant operators themselves have effectively addressed those needs. Our own organization is vastly improved today in relationship i
to those areas of learning. In November of 1979, I also said "there can be no question but what the continued use of nuclear power requires public support and public belief in the ability to utilize this energy source safely." Today, 4 years later, I would like to review with you the status of Three Mile Island 1 and 2 and conclude with some observations and a comment again on the role of public or political support.
During the past 4 1/2. years the Company and the accident have been investigated, analyzed, and interpreted by numerous groups whose record encompasses hundreds of thousands of pages. The Company and its employees, at all levels, have cooperated fully with all of these inquiries. And they still continue.
Now let us look at the current status of TMI-l the undamaged unit, and then at TMI-2, where the accident occurred.
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TMI-l The technical and the managerial changes mandated by the accident learnings have been aggressively implemented. In the case of TMI-1 these changes have been subjected to unparalleled scrutiny by an Atomic Safety and Licensing Board (ASLB) in public hearings.
In many ways, the TMI-l ASLB proceedings were the proving grounds for many of the " lessons learned" of NUREG 0737. The results of those proceedings which were initiated by the NRC's orders of July and August of 1979 were supportive of the restart of TMI-l and have been before the NRC for decision since July of 1982.
GPU's nuclear operations have been completely restructured into one integrated organization dedicated to the cole purpose of the safe and efficient operation of the nuclear facilities of the GPU system. Four levels of management responsible for TMI at the time of the accident -- the president of Met Ed down thru the unit superintendent -- are no longer a part of our nuclear operations.
Significant numoers of experienced technical and senior managerial personnel have been added. The GPU Nuclear Corp. today includes about 2600 people of which about 640 have technical / professional degrees and an average of over 11 years of experience The structure of the organization and the qualifications of the key personnel were reviewed in depth and commented on favorably by the ASLB.
The TMI-1 operators have undergone additional training and retraining. The operating staff has been relicensed through NRC examinations conducted with the full safeguards implemented following the cheating incident and with the new more stringent pass / fail criteria. We now have 38 licensed individuals in place and ready to operate TMI-1. This complement of licensed operators exceeds all requirements and stands among the greatest number
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. available at any operating plant in the country. A full complement of shift technical advisors (STA's) is in place. The plant will be operated with 6 rotating shifts which permits one shift for training. The training staff at the TMI site has grown from 8 in 1978 to 50 today.
Complete state and county approved emergency plans including the necessary warning systems have been tested in two formal exercises monitored by the NRC and by the Pennsylvanic and the federal emergency management agencies.
Plant modifications have been put in place to physically and radiologically separate Units 1 and 2. Separate operating and technical staffs have been provided for each unit.
Numerous hardware and procedural modifications including those identified in the NRC's lessons learned effort and which are pre-requisites for the restart of TMI-l are now complete except for two which require some final adjustment. Out of 130 restart items requiring NRC certification, 11 items must await certification during restart testing. Ten remaining longer term items in NUREG 0737 will be completed before the end of 1984.
For some time, two problems stood in the way of our ability to 1
operate TMI-1; namely, the need to restore the steam generators af ter damage by intergranular stress corrosion cracking in late 1981, and the question of the applicability of NEPA to psychological stress.
l This past April the Supreme Court reversed an order of the Court of Appeals which would have required consideration of psychological stress. It would be difficult to contemplate the future of nuclear power'in this country absent that decision.
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The steam generators have been restored to a condition that is structurally and thermodynamically indistinguishable, by analysis and non-destructive tests, from the initial design requirements which underlie the licensing of the plant. In order to give you some feel for the magni?.ude of this job, some 30,000 tubes were resealed to the upper tube sheet by two explosive expansions; about 1200 tubes were plugged; and the eddy current inspection program looked at over 600 miles of tube. During this past September and October, the restored steam generators were tested hot, at pressure, and under simulated operating transients. The measured primary to secondary leakage was about 1 gal /hr. compared to a spec limit of about 1 gal / min. With the completion of the steam generator restoration, the plant is physically ready to proceed into operation.
Under the provisions cf the "Sholly" amendment to the Atomic Energy Act, the NRC in May of this year announced a preliminary determination that the steam generator restoration involved "no significant hazards consideration". We are currently awaiting a final determination by the NRC staff. Since there have been requests for hearings, this determination will establish whether or not hearings must be held prior to the issuance of the necessary tech spec. change to cover the steam generator restoration. The staff determination will be submitted for Commission review later this month. We see no valid basis for making steam generator hearings a restart prerequisite.
In August of 1981, the NRC established an Atomic Safety and l
Licensing Appeal Board to review and deal with any appeals from the l
l ASLB recommended decision. All major issues, plant design, emergency plans, and management have been the subject of appeals. By June of 1983 the ASLAB had completed its review of the findings of the ASLB in all areas of plant design and emergency plans. The ASLAB l
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i D i has yet to complete its review of the appeals on the management issues.
In the course of the Licensing Board hearings in 1980 and 1981, the NRC staff supported management. However in mid-May of this year the staff began to express concerns when it stated, "because of all the open issues.....the staff can draw no conclusion regarding 1
management integrity at this time." Today the "open issues" include (1) an allegation of leak rate falsification prior to the accident that has been before federal grand juries for more than 3 years, (2) concern over possible information from the GPU/B&W litigation l
records, (3) the allegations of the TMI-2 whistle blowers regarding clean up procedures, (4) the contents of two company initiated consultants reports, one on cost effectiveness and the other on operator opinions, (5) the timeliness of providing these reports to l
the NRC and the Appeal Board and (6) possible 1978 leak rate testing irregularities at TMI-1. An NRC staff review of the GPU/B&W trial records, completed in March of this year, concluded that they contained nothing new and that they contained nothing that would f
preclude the restart of TMI-1. A second review, completed in October, of the total litigation materials identifies 7 areas recommended for further investigation by the Office of -
Investigations. It is doubtful if any comoination of these items would result in the closing down of an operating plant, but, because of the political sensitivity of a TMI decision, the NRC seems bent on closing out the "open issues" prior to any decision. There j
l has been no meaningful definition of the relevance of these "open issues". The Company believes that these "open issues" do not sustain a determination to keep TMI-1 shut down. Just two weeks ago the NRC stated that under the most favorable conditions a restart decision might be delayed to mid-84 to await the pending investigations, and if hearings were required it could be delayed n
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. until mid-85 or later. Without being specific, the NRC said it would consider alternative approaches.
TMI-2 The damaged TMI-2 reactor and its fission product burden has been maintained in a safe shutdown condition. Today the fission product decay heat intensity, about 30 Kw, is insufficient to further disperse the contained radioactivity. The 44,000 curies of 0
K released to the containment building by the accident have been safely vented with negligible impact on public health. Since the krypton venting in mid-1980 there have been over 300 manned entries into the containment building.
With the aid of a television " quick look" in the summer of 1982 and a recent sonar mapping of the void region above the remaining fuel debris, we have been able to determine that the upper portion of virtually all fuel elements across the full core diameter suffered severe damage to the point of disintegration. The associated fuel volume has resulted in a bed of rubble that begins at about 5 feet below the hold down structure. In March of 1982 we reached an agreement with the U. S.
Department of Energy that will permit shipment of the TMI-2 fuel to a DOE facility for storage and ultimate disposal.
Over one million gallons of contaminated water from the reactor and the auxiliary building have been decontaminated and continue to be safely stored on the island. The removed fission products are
.being shipped offsite. More than 200 radioactive waste shipments containing more thar. 400,000 curies of Strontium and Cesium have been completed without hazard to the general public along the 2700 mile transportation route. During August of this year the last of the highly contaminated resins that contain the fission products removed from the accident contaminated water was shipped off site.
Over three quarters of the floor space of the plant's auxiliary
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. buildings has been decontaminated such that worker access is minimally restricted.
While more than 95% of the fission products dispersed outside the primary system by the accident have been captured and removed, the remainder constitute a significant decontamination problem. The general radiation level within containment is about 100 mrem /hr but considerable effort ic going into reducing this general radiation level and the particulate contamiaation, in order to be able to reduce the worker encumberance from respirators and protective clothing.
The immediate tasks that lie ahead in the cleanup program are the removal of the reactor vessel head, the removal of the core hold down and plenum structure, removal of post accident support systems (tanks) from the fuel storage pool, improvement of the reliability of the fuel transfer mechanism, installation of refueling canal water decontamination and clarification systems, fabrication of various tools for fuel removal, and provision of canisters to accept the damaged fuel.
The Company is dedicated to conducting the clean up in a manner which will protect the health and safety of the public and which will minimize the time that the plant can pose a potential threat to its neighbors. Shortly af ter the accident, we acquired the services of Bechtel in order to be better able to apply the requisite range of technical and managerial competence to the task. In mid-1982 we formed an integrated team of Bechtel and GPU personnel to manage the clean up program. Earlier this year Westinghouse was awarded the subcontract for the reactor defueling. We are working closely with USDOE contractors and experts, numerous specialty contractors, and the National Laboratories to ensure the application of the nation's technologicalexpertise. Nevertheless it is a difficult management
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. task to integrate and direct this far-flung and recently acquired spectrum of technical resources.
Because of the nature of the TMI-2 clean up task we established a number of special organizational elements for the specific purpose of assuring the public health and safety. Beyond the normal organizational capabilities, checks and balances, and independent safety reviews appropriate to nuclear work, we have added the following elements:
1)
A Safety Advisory Board (SAB) composed of 10 out-standing scientists from around the country with a broad diversity of backgrounds including medicine, nuclear, space, sociology, etc. The charter of this eminent group is to review the TMI-2 cleanup program quarterly with the specific purpose of identifying potential problems of public and worker safety.
2)
A Technical Assistance and Advisory Group (TAAG) funded by the DOE and made up of experienced nuclear specialists from around the nation to assist in technical assessments and to ensure utilization of the national resource of applicable technology.
3)
A General Office Review Board (GORB), a mixture of in-house and out-of-house specialists to provide independent evaluation of critical safety issues.
GPU has maintained this structure for each of its nuclear plants. It is not a license requirement at TMI.
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, The TMI-2 clean up has since March of this year been under the cloud of a broad range of allegations asserted by 4 employees. The written affidavits as well as the media comments presented charges that the company has taken seriously. Prior to the publication of these charges the Company asked two outside technical consultants to investigate alleged safety issues. After publication, the Company formed a broader investigation team headed by an experienced investigator who had no prior contract relationship with the Company. His report is due shortly. It is significant to note that the allegations do not identify even one operation that was conducted unsafely.
The procedural coverage of the polar crane refurbishment is the focal point of the bulk of the specific allegations. The polar crane is ultimately a critical path item in the TMI-2 clean up program because it must be available to remove the reactor head and the vessel internals that stand in the way of fuel removal. A considerable effort has gone into the refurbishment of the polar 1
crane. The plans for the requalification of the necessary lead carrying capacity have been reviewed by inside and outside experts in the field. The effort has also been reviewed in great detail by the NRC staff. We are still awaiting approval to proceed with the requalification load testing.
The NRC's Office of Investigations recently issued a very critical report on the degree of procedural compliance on the polar crane and other activities at TMI-2. The report is critical of the Company, Bechtel, and the NRC site staff. We must and do agree that i
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. disciplined procedure adherence is critical to safety. However, the report finds many faults on the basis of second guesses on safety classifications and reflects little if any insight into the R&D nature of the clean up program and the need for the exercise of reasonable judgment on the part of the Company and the NRC site staff. We have yet to achieve an understanding with the NRC that the cleanup program is not the same as an operating power reactor in terms of the applicability of regulatory guides and standards.
Beyond the polar crane, the affidavits assert a broad range of allegations including harassment. The general allegations are being seriously investigated to ensure that the organization benefits from a full understanding of the indicated issues and their underlying causes. While our investigations are not yet complete, we recognize that the expressed concerns reflect the. newness of the organization, the need to better define responsibilities, the number of problems that must be addressed and resolved with unconventional solutions, the procedural transition attendant to combining the GPU and Bechtel organizations, and the need to improve supervisory skills. During most of 1983, these management problems will have been the subject of considerable effort and progress. We would be the last to suggest that the organization is perfect or that the effectiveness of the organization cannot be improved. These continuing challenges are part of an unprecedented tauk.
The investigations of the allegations of the whistle blowers and the resulting reluctance of the NRC to process approvals is resulting in at least a 6 months schedule loss on the polar crane requalification.
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, Early this year we completed an extensive review of the clean up program cost and schedule. While the program inherently involves many potential unknowns, the program plan had the benefit of about 3 years of experience and hopefully more realistic plans. The new estimate was constrained by a range of funding assumptions which were considered reasonable in relation to the expect.ed funding sources and which were also reasonable in terms of the physical and practical limitations on resource' application. The resulting program logic and schedule, barring unforeseen problems, indicated the start of core removal by January 1985 and completion by mid-1986. A considerable further effort is required to remove fuel particles from throughout the primary system and to complete the balance of the planned decontamination program which was scheduled for mid-1988. The cost estimate remained at about $1 billion.
By the end of 1983 we will have expended about $400 million at TMI-2 in the 4 3/4 years since the accident. We will spend about $75 million in calendar 1983. The base case program assumed that we could maintain a $100 million level in real terms for 1984 and
' future years.
i In 1981, Pennsylvania Governor Thornburgh proposed a cost sharing formula for the funding of the cleanup. The plan envisioned an equal split of the then remaining cost of $760 million between local and national interests.
On a local level, GPU's customers were to provide $50 million per year. They currently provide $34 million per year. In mid-October the Pennsylvania Public Utility Commission declined action on the balance pending further indication of support from others or the restart of TMI-1. The States of New Jersey and Pennsylvania were to provide $7.5 million per year. Pennsylvania is n
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providing $5 million annually; the Governor of New Jersey has requested $1.8 million for the 1984 budget.
On a national level, the Governor proposed equal $190 million shares for the federal government and the nuclear industry. The federal government, through DOE's R&D program, will spend about $159 million in TMI related activities, of which about $85 million will l
offset cleanup costs at the site. DOE off-site support of fuel and l
waste disposal is of significant value but is not fully reflected in I
the cleanup cost estimate.
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.Aside from a $1 million annual R&D program conducted by the Electric Power Research Institute, there has been no nuclear industry funding of the TMI cleanup or TMI research activities. The Edison Electric Institute, which represents the nation's investor-owned utilities has, for some time, encouraged its members to participate in the funding of the TMI cleanup. Initially, the EEI Board recommended a funding program that would have provided $192 i
million from the nation's utilities through federal mandate. When i
efforts to achieve legislative support failed in 1982, the Board of EEI passed a resolution.that sought a voluntary program of l
participation in the TMI cleanup. In its essence, the voluntary program which requires a minimum level of $100 million to be pledged could generate $150 million over a six year period if all EEI member companies chose to participate. To date, 34 of the 124 EEI companies
.have committed $64 million. Twelve companies have elected not to participate, comprising about $7.2 million of the total.
Seventy-eight companies remain to commit themselves one way or the other. EEI remains confident that they will achieve the targeted amount. In a recent letter to Governor Thornburgh, Charles Dougherty, Chairman of EEI, said that the commitment made to the TMI l
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. Cleanup by EEI is "as strong as ever and we hope that our industry will reach its goal of at least $100 million by the end of this year....As we have indicated, the industry is working very hard to deliver on its commitment".
The need for and value of participation in TMI Cleanup has been recognized by the US and worldwide nuclear industry. Discussions are in progress with foreign utilities for possible future participation. Efforts must and will continue to generate financial support from that sector which stands to benefit from the TMI experience. A preferred annual spending level of $100 million per year requires completion of the rate making in Pennsylvania and a l
combined total of about $40 million/ year from the utility industry I
and the USDOE.
At year end 1983 the program is facing a critical decision. None of the participants has denied its intention to contribute to the funding, but the anticipated funds are not yet in hand. We continue to be hopeful that we will not be forced to reduce the effort. The 1983 problems with whistle blowers and investigations which divert I
management attention and constrain approvals, the need to further solidify the GPU/Bechtel organization, and the problems of trying to accomplish an unprecedented task in a hostile radioactive environment are continuing indications of the challenge of the cleanup program. The 1983 problems along with the funding uncertainty result in an inability today to maintain the hoped for schedule that we embarked on at the beginning of this year. Despite l
these problems, the safe and expeditious clean up of TMI-2 must be completed and it is in everyone's interest.
As I think back over the past four and one-half years, I am left with the following thoughts:
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We have had to learn that the political institutions of our society are unprepared to respond immediately and positively to the regulatory and financial challenges of an event like the TMI-2 accident. The immediate public and political reaction to the accident was one of betrayal and anger. Those emotions were understandable but they were not a good foundation for positive response. As a result it took a couple of years to get past bankruptcy as a solution, to get rates that were in equilibrium with costs, and to get to the point where the Company could be seen in public with important policy makers.
2.
While the accident produced many learnings which the industry and its nuclear regulator have responded to aggressively, there continues to be a reluctance to accept the view that the cleanup program also presents a learning opportunity that should not be lost as well as a challenge to the manageability of nuclear power that inherently impacts the entire industry. The Thornburgh funding plan of 1981 was a bold and rational initiative. There continues to be a need for all of the parties at interest to close the ranks and turn that plan into a working reality. The continuing development of nuclear power requires an improved ability of the industry to join together in solutions. The insurance response to the accident was a positive step, but TMI-2 clean up does not have the benefit of today's more appropriate coverage.
3.
We have becn very disappointed in our limited ability to reach an understanding with the NRC on how to jointly serve the public interest in the TMI-2 cleanup. There is
V s a crying need to recognize the need to balance the safety of overly constrained progress and the unsafety of delay. We need to jointly redefine the continuing hazard of TMI-2. The i
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30Kw of TMI-2 after glow-today does not pose the same potential hazard as a power reactor operating at 3000Mw. The cleanup program is best characterized as R&D. The cleanup program requires procedural control and does pose worker and public safety considerations, but it also needs the recognition that the Company and the NRC must make judgments that may well not be reflected in existing regulatory guides or design criteria. In many ways the recent adverse report of the Office of Investigations on clean up procedures reflects the fact that this need has not yet been adequately recognized.
4.
Despite the extended duration, the TMI-l restart ASLB process was a fair one that afforded all parties the opportunity to make their case in a disciplined atmosphere and before an objective body. On the other hand there is little evidence that it did much if anything for public confidence in the Company or the NRC. There was almost no public attendance and our surveys indicate very little public awareness of ~the process. We are most disappointed that the ASLB hearings did little to convey, beyond the board itself, the major organization, training, procedure, and hardware changes that we have implemented.
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Lastly, we are now learning about the difficulties of making a high profile decision in the presence of public and derivative political uncertainty about nuclear power. Almost 5 years after the accident scraps of information concerning the pre-accident operating organization and practices are being cited as the basis for uncertainty about the integrity
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o of the current organization. There seems to be an inability or an unwillingness to apply minimum common sense, leave alone technical judgment, to discriminate between reasonable practices in 1978 vs improper motivations. This kind of indecision not only undermines our credibility but also that of the NRC.
At the outset I referred back to my November 1979 comment about the need for public support. Today it is increasingly evident that the NRC is severely hampered by a lack of public and thus political support. I can't help but contrast TMI with the DC-10 that crashed in Chicago, killing over 270 people, a few months after the TMI accident. That accident involved training, procedures, maintenance, management, etc. The Air Transport Safety Board determined the causes and the FAA recertified the airplane and the company within a few months. Nobody called for the dismissal of the top corporate officers. There are no continuing investigations 4 years later. Why should it be so different for TMI and nuclear power?
Let there be no mistake, I am not calling for a relaxation of safety. But I am calling for the kind of political support necessary for the NRC to handle safety matters on their technical merits only.
Three Mile Island is certainly a special case, but it doesn't take much imagination to see a growing number of other examples wherein the NRC will have difficulty acting without strong political This will not occur until the politician senses public support.
support for nuclear power. Our performance must merit that public support.
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4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-289
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(Three Mile Island Nuclear
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Station, Unit No. 1)
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SERVICE LIST Nunzio J. Palladino, Chairman Administrative Judge U.S. Nuclear Regulatory Commission John H. Buck Washington, D.C.
20555 Atomic Safety & Licensing Appeal Board Victor Gilinsky, Commissioner U.S. Nuclear Regulatory Commissior-U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge Thomas M.
Roberts, Commissioner Christine N. Kohl U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Appeal I
Washington, D.C.
20555 Board U.S. Nuclear Regulatory Commissior James K. Asselstine, Commissioner Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Administrative Judge Ivan W. Smith, Chairman Frederick Bernthal, Commissioner Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commissior -
Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge Administrative Judge Gary J. Edles, Chairman Sheldon J. Wolfe Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board U.S. Nuclear Regulatory Commissior U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 i
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- Administrative Judge Mr. Henry D. Hukill Gustave A. Linenberger, Jr.
Vice President Atomic Safety & Licensing Board GPU Nuclear Corporation U.S. Nuclear Regulatory Commission P.O. Box 480 Washington, D.C.
20555 Middletown, PA 17057 Administrative Judge Mr. and Mrs. Norman Aamodt Gary L. Milhollin R.D.
5 Atomic Safety & Licensing Board Coatesville, PA 19320 1815 Jefferson Street Madison, Wisconsin 53711 Ms. Louise Bradford TMI ALERT Docketing and Service Section (3) 1011 Green Street Office of the Secretary Harrisburg, PA 17102 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 John Clewett, Esq.
The Christic Institute Atomic Safety & Licensing Board 1324 North Capitol Street i
i Panel Washington, D.C.
20002 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Ms. Gail Phelps ANGRY /TMI PIRC Atomic Safety & Licensing Appeal 1037 Maclay Street l
Board Panel Harrisburg, PA 17103 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Ellyn R. Weiss, Esq.
Harmon & Weiss Jack R. Goldberg, Esq. (4) 1725 Eye Street, N.W., Suite 506 Office of the Executive Legal Washington, D.C.
20006 Director U.S. Nuclear Regulatory Commission Michael F. McBride, Esq.
Washington, D.C.
20555 LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Douglas R. Blazey, Esq.
Suite 1100 Chief Counsel Washington, D.C.
20036 Department of Environmental Resources Michael W. Maupin, Esq.
l 514 Executive House Hunton & Williams i
P.O. Box 2357 707 East Main Street Harrisburg, PA 17120 P.O. Box 1535 Richmond, VA 23212 John A. Levin, Esq.
Assistant Counsel David E.
Cole, Esq.
Pennsylvania Public Utility Smith & Smith, P.C.
Commission 2931 Front Street P.O. Box 3265 Harrisburg, PA 17110 Harrisburg, PA 17120 Dr. James C.
Lamb, III Dr. David L. Hetrick 313 Woodhaven Road Professor of Nuclear Engineering Chapel Hill, N.C.
27514 University of Arizona Tucson, Arizona 85271 Mary E. Wagner, Esq.
Office of Executive Legal Director U.S. Nuclear Regulatory Commission Jane Lee 183 Valley Road Washington, D.C.
2uS55 Etters, PA 17102 n
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t Joseph Gray, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Steven C. Sholly Union of Concerned Scientists 1346 Connecticut Avenue, N.W.
- 1101 Washington, D.C.
20036 James M.
Cutchin, IV, Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 a