ML20090F644

Comments on Aslab 830616 Order Re NRC Awareness of Falsified Leak Rates,Separation of Individual Performance from Mgt Competence & Notification to Commission of Mgt Changes. Certificate of Svc Encl

ML20090F644
Person / Time
Site:	Three Mile Island
Issue date:	06/30/1983
From:	Blazey D PENNSYLVANIA, COMMONWEALTH OF
To:
References
NUDOCS 8307060190
Download: ML20090F644 (7)

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NUCIEAR PEGULATORY 00ttESSIOIl l2/ L l? JUL '953 > H P BEFORE 111E A10tEC SAFEIY NO LICENSING APPEAL BOARD w em- (C!/

In the lhtter of: %2" 7

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IEfROPOLITAN EDISON 00tPR U,  :

_- 77 (Three Mile Island Nuclear  : Docket No. 50-289 Station, thit No.1)  : (Restart)

C0titOINEAL1110F PENNSYLVANTA'S 00ttEIRS TO A10tiIC SAFEIY AND LICENSING APPEAL BOARD'S ORDER OF JUTE 16, 1983 In its Order of June 16, 1933, concerning the notions to reopen the record filed by the Aanodts and ihree liile Island Alert, the Atomic Safety and Licensing Appeal Board ("the Board") solicited conments on three matters which, although not specifically raised in the notions, potentially bear on their disposition. These three issues involve:

1) connents by an IEC Staff nunber that since 1980 the Staff had been aware that leak rates were falsified; 2) the NRC Staff's proposal to separate the issue of past performunce of individuals from that of nunagement competence in detennining whether restart should be inmediately effective; and 3) GPU's informing IRC Chairaan Palladino of various unnagement changes which will be effected prior to restart. The Connonwealth of Pennsylvania ("Comnoncealth") filed with the Conmission on June 2,1933 Supplanental Cotments on the Innediate Effectiveness of f

Partial Initial Decisions Regarding Management Issues (" Supplemental Ccxments") in response to the Conmission's anticipatory order of Fhy 23,

[ 1983, requesting convents on the thy 24, 1983 briefing of the Ccumission 1

by the Staff. The Connonwealth's Supplemental Contents focused specifically upon the five issues raised, but not resolved by the Staff, in its 8307060190 s30630 PDR ADOCK 05000289 g PM g$D3

.f review of GPU's managenent integrity and competence. The Comanwealth's cannents raise the same generic concerns as the issues on which the Board is now soliciting cannents and, therefore, those coments, a copy of which is attached, will serve as the basis of the Camonwealth's response to this Board's June 16, 1983 Order. In particular, the Connonwealth stated in the first paragraph of its Supplanental Cannents that:

% e Com:enwealth urges herein that the Conmission defer consideration of the imnediate effectiveness of the Licensing Board's management decision (s] pending a canplete review by the Appeal Board of the open issues raised by the Staff.

As stated consistently by Governor Bornburgh, the Conmom:ealth believes that the Conmission must provide adequate assurances that IMI Unit 1 can be operated safely before the Conmission authorizes any resuuption of operations. %e Appeal Board now has before it for review the managuent competence and integrity issues in at least the following four different contexts:

1. The final results of the NRC Staff "Prograa to Revalidate IEC Staff Position Supporting IMI-l Restart in Light of thnaganent Integrity" including those contained in the GPU v. B&W transcript and the Inspection Report Ib. 50-28V83-10.

2. He five issues identified by William J. Dircks in his menorandum of Iby 19, 1983, to the Contaission as not having been addressed by the NRC Staff in its revalidation effort, and the supplanental conments regarding these five issues transmitted by Mr. Dircks to the Conmission by

, manorandum dated June 7,1983.

3. The three Ibtions to Reopen the Record and the "three nutters not expressly raised in the motions (which] may have a bearing on this disposition" as contained in the Appeal Board's June 16, 1983 Order.

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4. The specific ra:nining outstanding issues raised by the Comnonwealth in its Exceptions to the Partial Initial Decision (Reopened Proceeding) on managanent competence and integrity filed on August 20, 1932.

'Ihe Conmonwealth believes that' the Appeal Board should review and decide or otherwise establish a process to bring to a close and decide all of these and other issues related to GPU management competence and integrity. 'Ihe public is entitled to a coherent disposition and explanation of all these issues by the Conmission in any decision regarding GPU's mmaganent integrity and conpetence. To the extent that the Appeal Board can simplify and structure the outstanding issues for the Comnission, it will be doing an enormous service, not only for the parties, but also for the public.

'Ihe IEC has preenpted the area of health and safety. It is the NRC's statutory responsibility to undertake all necessary staff analysis and reviews, to inpose all necessary conditions on licenses and to decide all disputed issues related to the safe design and operation of a nuclear generating unit. When the NRC Staff raises issues of safety as it has done here, the NRC Staff should wrk to focus and resolve the issues. Neit.her intervenors nor interested states should have to carry the burden of organizing or focusing relevant safety and legal issues for hearina and resolution.

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In sunmary, it is the responsibility of the IEC, in all of its component parts--the Staff, the Atanic Safety and Licensing Board, the l Atomic Safety and Licensing Appeal Board, and the Conmissioners themselves--to assure the public that a licensed facility has been safely designed and can be safely operated by the licensee. 'Ihe NRC has taken a first step toward focusing these issues by deciding on June

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I 28, 1983: (1) to postpone voting on restart of TII Unit 1 until issues of runaganent competence and integrity have been resolved and (2) to e consider issues of unployee wrongdoing and managanent integrity together l

! rather than separately. It is incunbent upon the component parts of the IEC to now follow the IEC's initiative.

Conclusion

'Ihc present record and related decisions do not assure the public 1

in Central Pennsylvania and elsewhere that 'IMI Unit 1, if allowed to restart by the Conmission, will be safely operated and pose no threat to its neighbors. The Connonwealth urges the Appeal Board to take whatever

action it deans necessary to foreclose the risk of any hazard and to assure the public that, if 'aII Unit 1 is allowed to restart, it will pose no risk to the health and safety of the conmunity surrounding it.

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t Respectfully cahnitted, I

FDR 'DE CottDNEAIJDI 0F PDUSYLVANIA bW W-DOUGIAS'R. BIAZET.

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'J 505 Executive House, P.O. Box 2357 Ilarrisburg, Pennsylvania 17120 (717) 787_-7060 June 2, 1983 Mr. Samuel J. Chilk Secretary U. S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1)

Docket No. 50-289 (Restart)

Dear Mr. Chilk:

Enclosed are copics of two documents which constitute the Corenonwealth's comments on the May 24 Commission meeting:

(1) a letter dated June 2, 1983, from the lionorable Dick Thornburgh, Governor, Commonwealth of Pennsylvania, to Chairman Palladino; and (2) the Commonwealth of Pennsylvania's Supple-mental Comments on the Immediate Effectivenesc of Partial Initial Decisions Regarding Management Issues.

Very truly yours, Qx, J .

Robert W. Adler Assistant Counsel RWA:jh Enclosures (2) cc: See Certificate of Service

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THE GOVERNOR June 2, 1983 Dr. Nunzio J. Palladino Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Chairman:

I am writing because of suggestions that the time has come for your commission .to authorize restart of the Unit I nuclear generation station at Three Mile Island.

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Nearly four years ago, I asked this commission to postpone any decision regarding Unit I restart because a number of serious health, safety, environmental, operational, management and other issues had yet to be resolved. 1 believe the commission acted in the public interest at that time by post-poning its restart decision.

Nearly two and one-half years later, on Nov. 24, 1981, I repeated to this commission my concern that any action by the .

NRC to allow restart of TMI Unit 1 be preceded by adequate assurances that this facility gan be operated safely.

Today, more than four years af ter the March 28, 1979 accident at the nearby TM1 Unit 2 facility, 1 must advise you that while progress has been made, adequate safety assurances have not been fully provided with regard to Unit 1, either-to me or to the people of this area.

My reservations are now principally focused on the poss-ibility, to which this Commonwealth has objected, that THI-1 would be operated by persons found to have cheated on their qualifying examinations, the possibility, raised by engineering

. technicians and others, that the radiation cleanup of the damaged TMI-Unit 2 may.not be proceeding as safely as it should, and the. possibility, raised last month by_the NRC staff itself, that the' levels of operator competence and integrity at TMI may not be as.high as those which the public is entitled to expect.

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! Page 2... Letter to Palladino Left unresolved, these kinds of questions also could seriously jeopardize the substantial progress we have made in ensuring that the Unit 2 cleanup will be adequately funded under

.the cost-sharing plan I advanced in 1981.

I'believe, in fact, that all of these concerns bear on the safety assurances I have directed this Commonwealth to seek since 1979.

A prompt, thorough and effective investigation and public resolution of those issues raised in the Commonwealth's appeal of August 20, 1982, and those raised by your staff and by workers at the plant itself, is absolutely essential before this commission seriously entertains any action with regard to restart.

Before these issues are resolved, I w?uld find it dis-turbing, indeed, for the commission to take action on restart.

I would find it particularly inappropriate for the commission to take such action prior to hearing this Commonwealth's appeal on the operator cheating issue.

On behalf of all who live within the shadow of Three Mile Island, all who believe that public health and safety must be

-the first concern of those who see a future for commercial nuclear power, and on behalf of the integrity of the commission and the regulatory process it represents, I once again urge you and your colleagues to postpone any decision on restart until these issues have been satisfactorily. addressed and resolved.

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Governor /

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cc: Commissioner'Gilinsky Commissioner Ahearne Commissioner Roberts Commissioner Asselstine-

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- o UNITED STATES OF AMERICA

?!UCLEAR REULA70IN CG@lISSIG!

BEFORE TI!E CGCIISSION In the Matter of:

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METPOPOLITAN EDISON CGfMW, ")

) Docket tb. 50-289 (Three Mile Island tbclear ) (Restart)

Station, Unit No. 1) )

COFNotMEALTil OF PENNSYLVANIA'S SUPPIR4E!EAL CGODES Otl TIIE IhMEDIATE mwnVI2ESS OF PMCIAL INITIAL DECISIONS REMtDItU MANTGET ISSUES This document is subnitted in response to the Cmmission's Fhy 23, 1983 Order soliciting caments on the Fby 24, 1983 Carmission briefing.

Since the Comnonwalth believes tlut the open issues raised by the Staff in the Jby 24 briefing and in the May 19, 1983 manorandun fran William J. Dircks to the Conmission have a direct bearing on the restart management issues currently pending before the Atamic Safety and Licensing 7ppeal Board, these cauments are respectfully subnitted as supplemental innediate effectiveness ccmnents for the Cannission's consideration.

The Camonwealth urges herein that the Cannission defer consideration of the inunliate offectiveness of the Licensing Board's managanent decisions pending a carplete review by the Appeal Board of the open issues raised by the Staff.

On August 20, 1982, the Comenwalth filed comnents regarding the inmediato effectiveness of the ASLB Partial Initial Decision (PID) on operator cheating issues (Reopened Proceeding) (dated July 27, 1982).

These connents argued that the integrity of those responsible for the operation of TMI-l was critical to plant safety, and that individuals with a demonstrated lack of integrity should not be permitted to cperate (Of[ '

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tin plant. The Ccamorrmalth's ccrments also argued that a decision on restart must be predicatcd upon reasomble assurances regarding the adequacy of GPU's operator training program. Issues raised recently by the Staff renew these concerns-and pose additional uncertainties regarding the ability 'of GPU to operate 'IMI-l safely. Most importantly, the Staff states that it "can draw no conclusion regarding management integrity at this time." The Gammonwalth's argument that integrity is critical to plant safety is particularly ccupelling with respect to the Licensee's top management officials, who have the ultirrate responsibility in the GPU organization'for casuring that public health and safety is protected. The Conmonwalth will not support the restart of 'IMI-1 until it receives adequate assumnces frcm the Comnission that the management of GPU Nuclear Corporation in willing and able to operate the plant in a safe and ccupotent manner. Tie public deserves no less.

The nexus of the five issues raised by the Staff to matters that are currently pending in the restart proceeding is addressed below.

1. The veracity of the IIartran allegations. The PID on managenent issues addressed the liart2 nan leak rate allegations briefly, at itSO4-505. Insed on the limited information available to the Board in Supplements to the Staff's Restart Evaluation Report, the Board concluded that.there was "no basis to conclude that restart should not be permitted until the DCLT investigation is conplete." _Id.1505.

11omver, the Staff Restart Evaluation Report only ' stated, that it had identified "a number of apparent problems related to procedure adherence." Id. 1504, quoting Staff Ex. 13 (Restart Evaluation Report,

! Supplement 2) , at 9-10. In fact, as reported to tie Ccomission in the l

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May 24, 1983 briefing, the Staff had concluded by Apr.il of 1980 that Licensee's personnel had falsified leak rate data prior to the T4I-2 accident. Tr. 13-16 (Martin). The significance of potential evidence regarding the intentional falsification of safety-relatcd test data is far greater than " apparent problema related to procedure adherence," as reported by the Staff in the Restart Evaluation Report and relied upon by the Licensing Board in the PID. There is also reason to question the Staff's conclusion, as quoted and relied upon by the Licensing Board, that "there appears to be no r direct connection with the Unit 2 accident." Id. 1504. First, falsification of test data by Licensee personnel goes directly to the issue of management integrity, which as argued above, is critical to plant safety. Second, it is apparent frm the GPU v. B & N court proceeding that at least B&W's attorneys felt that the leak rate falsification issue provided evidence that the 24I-2

' accident resulted, in part, frm GPU managcznent cicficiencies. Third, the leak rate issue is relevant to GPU's maintenance practices, which were liti-gated before the ASLB. The general issue of GPU's failure to correct plant safety-related maintenance problems was addressed squarely in the Restart Proceeding. The Licensing Board's decision on these issues was clearly based on inccxtplete evidence. The Staff's treatent of the Hartman evidence may have

,i naterially affected the Licensing Board's decision in the case. Therefore, the PID should not be made inmodiately effective until these issues are resolved.

2. Statements on the record of the GPU v. B&W court proceeding.

Although the Staff's references to the B&W transcript are somewhat vague, it is clear that at least part of the information under review by the Staff is relevant to issues in the Restart Proceeding. Page 2, note 1 of the Dircks manorandum indicates that the Staff is reviewing information relevant to the integrity of Licensee's program for the

requalification of licensed operators. The adequacy of Licensee's operator training anci , retraining programs was addressed in the original managarent PID ($tlG3-276), the April 28, 1982 Pcport of the Special Master (tt238-251) and the July 27, 1982 PID (Peopened Proceeding (St2321-47)). The new information alluded to by the Staff is clearly relevant to these decisions, and to the overall question of whetinr there is reasonable assurance that GPU's licensed operators are adequately trained to operate TMI-l safely. Until these questions are adequately resolved, neither the August 27, 1981, nor the July 27, 1982 PID should becme immediately effective.

3. The Parks and King allegations. Short-term order item 6 l of the Conmission's August 9,1979 Order and Notice of 11 earing required the Licensee to " demonstrate his managerial capability and resources to l

operate Unit 1 while maintaining Unit 2 in a safe configuration and carrying out the planned decontamination and/or restoration activities..."

Thus, the nanagment cmpetence and integrity of the Licensee to operate i

Unit 1 safely are clearly linked in the Postart Proceeding to management capabilities at Unit 2. The issues raised in the polar crane affidavits, in turn, plainly challenge both the management integrity and cmpetence of the Licensee to conduct the Unit 2 clean-up. The following broad allegations in the Parks and Gischel affidavits are particularly disturbing:

"I am sutmitting this statcment to express my personal knowledge and concerns that the 1

management of'Three Mile Island-Unit 2 ('IMI) has sacrificed its own system of safety-related checks and balances for TMI cleanup activities i in onler to meet unrealistic time schedules and in the process equipment has been modified and snap judgments made without proper engineering l . -

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i analysis, quality assurance (QA) steps have intentionally been skipped and totally circunvented, rules and documents luve been

, changed aftdr the fact to justify QA violations, and those who have defended the nonnal system of nuclear industry checks and balances have faced pressure, intimidation and retaliation which stripped them of the authority to function as viable members of the managenent team. I '

am among those who have suffered this fate.

Quality Assurance violations include many other issues of which I am aware but do not have persona 1 knowledge."

(Parks) .

" Based on my observations, I believe that the TMI-2 accident was due to a " people" problon that must have begun before the accident, and still exists... The present mentality at the Island emphasizes shortcuts, expediency and disdain for professional standards."

(Giochel).

Although the issues raised in the Parks and Gischel affidavits relate solely to 31I-2, the generic managanent issues are precisely the same as those raised in the Restart Proceeding. In the Restart Proceeding, GU argued that deficiencies in its Quality Assurance / Quality Control procedures and attitudes have been corrected through the use of new management structures and procedures. Evidence tlut these new procedures may not have worked at TMI-2 is certainly pertinent to a detennination of whether or not the procedures are working and will work at TMI-l in the event of a restart.

Substantial plant modifications have been made to support restart, all of which require the application of QA/QC procedures.

The polar crane allegations are relevant to the Restart Proceeding for a number of additional issues. The Commission clearly linked GPU's l

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managarcnt capabilities and resources to operate Unit 1 safely to their capability and resources to conduct the decontamination at Unit 2.

GPU's primary response to this critoria was an acknowledgcTent that it lacked sufficient technical capabilities and resources to conduct the Unit 2 decontamination simultaneously with a safe restart of Unit 1.

'Ib meet this deficiency, GPU argued that it had employed the significant technical resources of Bechtel. The recent evidence regarding Unit 2 indicates that the Bechtel-GPU interface is far fran adequate and calls into question GPU's arguments in the context of the Restart Proceeding.

bbreover, the new evidence tends to indicate that GPU is devoting superior talent and FeSources to its restart managCment than to its Cleanup mnagcment. This is inconsistent with the Comtonwealth's position that a safe and expeditious. cleanup at Unit 2 is parancunt, and that Unit 1 restart should be permitted only if consistent with this primary goal.

Second, it is inportant to note that there are significant conmon mnagement links between TMI-l and TMI-2. Both organizations report directly to the Office of the President of GIU Nuclear Corporation (Pobert Arnold). Both the Parks and Gischel affidavits allege that Mr.

Arnold and other roembers of his office were directly involved in the allegedly improper management activities, including alleged nnnagemer.t harassacnt and intimidation of dissenters within the carpany. Fbrcover, the technical allegations raised in the affidavits relate pri2rarily to quality assurance and quality control. Again, QVQC deficiencies were a significant issue in the Restart Proceeding. GPU's evidentiary response was that it lud centralized its technical and engineering ONQC resources above the levels of individual plant nanagement. Groups such 1

as the General Office Review Board (OORB) and the Division of Nuclcar

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f l Assurance, both of which bear tle fundamental OVoC review responsibilities

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! within the corporation, function independent of the onsite Unit 1 and Unit 2 ortjanizations and are supposed to regulate OVOC at 1rth units.

Breakdowns in OVQC procedures at Unit 2 are therefore related to l I potential deficiencies at Unit 1. (There are many other examples of

! technical resources cconon to both units and which have an indirect ,

responsibility for quality assurance, such as the Division of 'Ibchnical Services in the GPU 11tclear Corporation.)

Third, GPU presented evidence during the F.estart Proceeding tint

quality assurance deficiencies would to remedied by new onsite procedures.

Altluugh different personnel rny serve these functions at Unit 1 and Unit 2, evidence of breakdowns in the procedures at Unit 2 indicate that 4

GPU's new mnagement structure has not necessarily resolved managarent difficulties at the Island. One example is the Plant Operations Pcview t

Ccmnittee (PODC), which is intended to serve as a day-to-day quality assurance review canmittee at the Island. The effectiveness of tiu Unit 2 POPC was challenged strongly in the Parks affidavit. Another t

example is the " ombudsman" procedure, which was established to ensure that concerned cmpany enployees have an opportunity to resolve safety-related problems without fears of reprisals or intimidation by campany i

management. It is evident that the ombudsman procedure did not work, i

or was not allowd to work, at Unit 2.

The Connonwealth does not wish to inply that any firm conclusions i

can be drawn at this time on the basis of the affidavits. Tlu motives of the individuals bringing the clurges and the veracity of their allegations invc not been clullenged. Nor ins GPU been given a proper opportunity to rebut these claims. Howver, the issues raised have

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, l cxtrcrnely inportant potentini ramifications regarding the overall managanent integrity and cmpetence of GPU lbclear CorIrration. Tlnse l issues struld to fully aired prior to restart. 'the Licensing Board's managment PID cannot be given inTnediate effectiveness under these circumstances. j

4. Concerns raised by the BETA and PJIR reports. A large i

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number of issues and open questions in tle GPU consultants' reports relate to issues before the Appeal Board, and (rntradict or qualify many of the conclusions reached in the management PID. Although it would be ingossible to catalog tiu nexus between each item in these i

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reports to the Postart Proceeding at this time, deferral of the t

( Cmmit.sion's armediate effectiveness decision on the management PID is warranted pending an in-depth review of these issues by the Staff, the parties, and the Appeal Board. The conmonwalth is particularly concerned with allegations in the BerA report regarding plant maintenance, quality assurance, and operator training, all of which are critical to f plant safety.

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5. Failure to Notify the Conmission or Appeal Board of Pelevant and Material Infonnation. The Conmonwealth is perhaps nost concerned by the Staff's allegation regarding the Licensee's failure i j to prunptly notify the NIC of potentially relevant and material

! information .

It is a fundamental principle of NIC regulatory policy k that Licensee's have an affirmative duty to ccine forward with all e

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potentially relevant infontation. Duke Pow r Co. (William B. f tCuire IMclear Station, Units 1 & 2), AIAB-143, 6 AIC 623 (1973); Georcia Power Co. (Alvin W. Vogtle Nuclear Plant, Units 1 & 2), AIAB-291, 2 tac 404, 408 (1975); Duke Power Co. (Catawin IMclear Station, Units 1 & 2), AIAB-355, 4 tmC 397, 406 at n.26 (1976); Consumers Power Co. (Midland Plant, Units 1 & 2) , CL.T.-74-3, 7 Nic 7,11 (1974) ; Petition for Dicrgency and Penedial Action, CLI-78-6, 7 NBC 400, 418 (1978); Virginia Electric and Ibwer Co. (tbrth Anna Pomr Station, Units 1 and 2), CLI-76-22, 4 NPC 480 (1976), aff'd sub. nom. Virginia Electric and Ibwr Co. v. IMclear Regulatory Conmission, 571 F.2d 1289 (4th Cir.1978) . A potential failure by Licensee's upper nanagment to ccuply with this fundanental principle of IEC law and policy would bear grave consequences in terms of Licensee's nunagement integrity. Again, this issue warrants a conplete investigation prior to any final decision on the innediate effectiveness of the Licensing Board's management PID.

CONCLUSION For the foregoiry reasons, the Connenwealth urges the Conmission not to grant inuediate effectiveness to the Licensing Board's nanagement PIDs until the five issues raised in the thy 24, 1983 Conmission briefing and the tby 19, 1983 Dircks Menorandum are fully investigated, on the record of the Restart Proceeding.

Eesp2ctfully subnitted, BOBERT W. ADLER lf Assistant Counsel 03nnenwealth of Pennsylvania Dated: June 2, 1983

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UNITED STATES OF T4 ERICA NUCLFAR REIRJI1 DORY COMISSION BEEDRE TIE COMISSION In the Patter of: -

MEITOPOLI'IAN IDISON COMPANY, )

) Docket No. 50-289

('Ihree Mile Island Nuclear ) (Restart)

Station, Unit No.1) )

!' CERTIFICATE OF SERVICE I hereby certify that copies of the Ccanonwalth's letter to the Secretary of the Camission, with attachnents, wre served on I the persons on the attached service list this 2nd day of June,1983.

Persons identified by an asterisk wre served by Federal Dcpress.

All other persons wre served by deposit in the U. S. Fail, first class, postage prepaid.

JMif~.Ct Robert W. Idler l

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I UNITED STATES OF MERICA NUCLEAR REGUIATORY 03NISSION BEFDRE THE ATOMIC SAFETY AND LICENSIIU APPEAL BOND In the Matter of: ,

!EfROPOLITAN EDISON CG4 PAIN,  :

(Three Mile Island Ibclear  : Docket No. 50-289 Station, Unit Ib.1)  : (Restart)

CERTIFICATE OF SERVICE, This is to certify that the foregoing "Camxnmalth of Pennsyhrania's Caments on the Atomic Safety and Licensing Appeal Board's Order of June 16, 1983" was served on the persons on the attached service by deposit in the U.S. mail, first class postage prepaid.

F .bA .  %%A boUGLAS R.VIAZEY \

Chief Counsel \

Departmentofkvironmental sources Date: June 30, 1983 l

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UNITED STA*IES OF AMERICA NUCLEAR REGUIAIORY C0tHISSION BEFORE THE A'I0tEC SAFEIY AND LICENSitU APPEAL BOARD In the Ibtter of:

METROPOLITAN EDISON COMPAIN,  :

(Three Mile Island Nuclear  : Docket No. 50-289 Station, Unit No.1)  : (Restart)

SERVICE LIST Docketing and Service Section George F. Trowbridge, Esquire Office of the Secretary Shaw, Pittman, Potts & Trowbridge U.S. Nuclear Regulatory Conmission 1800 M Street, N.W.

Washington, D.C. 20555 Washington, D.C. 20006 Judge Gary J. Edles, Chairnun Joseph R. Gray Atomic Safety & Licensing Appeal Board Office of the Executive Ingal Director U.S. Nuclear Regulatory Conmission U.S. Nuc1 car Regulatory Conmission Washington, D.C. 20555 Washington, D.C. 20555 Judge John H. Buck Ellyn R. Weiss Atomic Safety & Licensing Appeal Board Harmon & Weiss U.S. Nuclear Regulatory Conmission 1725 Eye Street, N.W., Suite 506 Washington, D.C. 20555 Washington, D.C. 20006 Judge Reginald L. Gotchy Karin P. Sheldon, Esquire (PAIE)

Atomic Safety & Licensing Appeal Board Hannon & Weiss U.S. Nuclear Regulatory Conmission 1725 Eye Street, N.W., Suite 506 Washington, D.C. 20555 Washington, D.C. 20006 Judge Christine Kohl Henry D. Hukill, Vice-President Atomic Safety & Licensing Appeal Board GPU Nuclear Corporation U.S. Nuclear Regulatory Conmission P. O. Box 480 Washington, D.C. 20555 Middletown, Pennsylvania 17057 Ivan W. Smith, Esquire, Chairnun Ms. Marjorie M. Aamodt Atomic Safety and Licensing Board Panel R.D. #5 U.S. Nuclear Regulatory Conmission Coatesville, Pennsylvania 19320 Washington, D.C. 20555 AIURY/'IMI PIRC l, Dr. Walter H. Jordan 1037 Maclay Street Atomic Safety and Licensing Board Panel Harrisburg, Pennsylvania 17103 881 West Outer Drive Oak Ridge, Tennessee 37830 Dr. Chauncey Kepford & Judith Johnsrud Environmental Coalition on Nuclear Power Dr. Linda W. Little 433 Orlando Avenue Atomic Safety and Licensing Board Panel State College, Pennsylvania 16801 5000 Hennitage Drive Raleigh, North Carolina 27612 Steven C. Sholly thion of Concerned Scientists 1346 Connecticut Avenue, N.W.

! Dupont Circle Building, Suite 1101 l Washington, D. C. 20036

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Ms. Imuise Bradford IMI Alert .

l 1101 Green Street Harrisburg, Pennsylvania 17102 John A. Irvin, Esquire Assistant Counsel ->

Pennsylvania Public Utility Conmission P. O. Box 3265 liarrisburg, Pennsylvania 17120 Jordan D. Cunningham, Esquire Attorney for Newberry Township T.M.I. Steering Conmittee 2320 North Second Street liarrisburg, Pennsylvania -17110 Administrative Judge Gary L. Milhollin Atomic Safety & Licensing Board 4412 Greenwich Parkway, N.W.

Washington, D.C. 20007 Michael F. McBride, Esquire ImBoeuf, Iamb, Iriby & MacRae

. 133 New llanpshire Ave. , N. W. Suite 1100 t Washington, D. C. 20036 David E. Cole, Esquire Smith & Smith, P.C.

2931 N. Front St.

liarrisburg, Pennsylvania 17110 Michael W. Maupin, Esquire

, ilunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia .23212 John Clewett

'Ihe Christic Institute 1324 North Capitol Street Washington, D. C. 20002 W

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