ML20101N651
| ML20101N651 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/31/1984 |
| From: | Silverman D HOUSTON LIGHTING & POWER CO., NEWMAN & HOLTZINGER |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#185-908 OL, NUDOCS 8501040131 | |
| Download: ML20101N651 (18) | |
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UNITED STATES OF AMERICA Car;.ig NUCLEAR REGULATORY COMMISSION U3NRC BEFORETHEATOMICSAFETYANDLICENSINGBTD JAN -3 A10:18 In the Matter of
)
0FFICE U santiA n
)
00CKETING & SERVfCL HOUSTON LIGHTING AND POWER
)
Docket Nos. 50-4%W44E COMPANY E_T A_L.
)
50-499 OL
)
(South Texas Project, Units 1 )
and 2)
)
APPLICANTS' RESPONSE TO CCANP MOTION FOR RECONSIDERATION OF ASLB ORDER OF NOVEMBER 16, 1984 I.
Introduction By motion dated December 4, 1984, / Citizens Concerned About Nuclear Power (CCANP) seeks reconsideration of the Atomic Safety and Licensing Board's (Board) Fifth Prehearing Conference Order.- /
CCANP argues that the Board's Order is in error insofar as it:
(1) " dismisses 'all Quadrex-related issues'" (other than those addressing reportability ; and (2) denies CCANP's request for additional discovery on certain aspects of the NRC Staff's analysis of the report-ability of the Quadrex Report.
Motion at 1.
I The Board did not err in either respect.
Notwithstanding l'
i numerous opportunities, CCANP failed to identify a single litigable issue with respect to the Quadrex Report (other.
-*/
CCANP Motion for Reconsideration of ASLB Order of November 16, 1984 (December 4, 1984) (Motion).
~~**/
Fifth Prehearing Conference Order (November 16, 1984)
(Fifth Prehearing Conference Order).
Although objections
-to a prehearing conference order must be filed within five days after service of the order (10 C.F.R.
S 2.752(c)),
CCANP's Motion was not served until December 4, 1984 and is, therefore, untimely.
8501040131 841231 PDR ADOCK 05000498
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PDR m
r than its reportability).
Similarly, CCANP failed to avail itself of extensive opportunities for discovery.
Since it has provided no new information or argument warranting reconsidera-tion, / CCANP's Motion should be denied.
II.
Limitation of Issues to be Litigated in Phase II CCANP argues that the Board erred in limiting the issues to be litigated in Phase II for two principal reasons.
- First, it alleges that "the history of HL&P supervision of B&R design and engineering work, the history of the Quadrex Report, the Quadrex Report itself, and the response of HL&P to the Quadrex Report
." should be considered in Phase II (Motion at 6),
and that by failing to admit such matters as litigable issues, the Board " failed to consider HL&P's character and competence as required by the Commission.
Id. at 2.
Second, CCANP alleges that the limitations which were imposed on the scope of Phase II were not contemplated by the Board's Fourth Prehearing Conference Order,- / that it agreed to withdraw-its proposed Quadrex contentions based upon the anticipated scope of the Phase II proceeding as described in that Order, and that it was, therefore, deprived of its "due process rights."
Id. at 5-6.
-*/
Nuclear Engineering Co. (Sheffield, Illinois Low-Level
-Radioactive Waste Disposal Site), CLI-80-1, 11 NRC 1, 5-6 (1980).
~~**/
Fourth Prehearing Conference Order (December 16, 1981)
(Fourth Prehearing Conference Order).
An examination of the record demonstrates, however, that CCANP has mischaracterized the Board's efforts in the period between the Fourth and Fifth ? rehearing Conference Orders to obtain a reasonable definition of the issues to be liti-gated in Phase II, as required by the Commission's regulations, and has failed to identify a single litigable issue.
In the Board's Fourth Prehearing Conference Order, it described the general scope of the issues to be addressed in the three phases of this proceeding.
The Board indicated that "all aspects" of the Quadrex Report would be addressed in Phase II, but anticipated that the issues to be litigated would be influenced by the ongoing reviews of the Quadrex Report by Bechtel and the NRC Staff.
Fourth Prehearing Con-ference Order at 5.
The Board did not attempt to anticipate the potential relevance of the determinations that would be reached in its Partial In' tial Decision (PID) on Phase I issues, although it did note that "[a]ny findings made at the conclusion of Phase I will be subject to change in Phase II to reflect the information in and reviews of the Quadrex Report."
Id.
Clearly, the Fourth Prehearing Conference Order contemplated that before Phase II would begin, the scope of l
inquiry into the Quadrex Report would be defined more specifi-cally based upon the significant amount of information expected to be available at a later date.
After the Bechtel and NRC Staff reviews of the Quadrex Report were completed, the Board proceeded, consistent with
.. 4 its Fourth Prehearing Conference Order and its responsibilities under'the Commission's regulations, to secure a specification of the issues to be litigated in Phase II:
Following the, completion of dis-covery, owe expect to have the parties delineate the particular Quadrex-related issues which they wish to litigate or believe-should be litigated.
. At a later date, we expect to set forth a schedule for.
. the filing of parti-cular Quadrex-related issues which any party (including for this purpose the State of Texas) seeks to litigate.
Memorandum and Order (June 22, 1983) at 5.
Thus, it was b
clear as early as June, 1983 that the Board would require the i
parties to define litigable issues arising out of the Quadrex Report with specificity.
Again, in May, 1984, in the course of ruling upon Applicants' motion for sanctions against-CCANP and upon two t'
RCCANP motions for additional discovery, the' Board' expressed its expectation that, following discovery, CCANP would be-able "to define more precisely the matters it wish[d] to-l litigate in Phase II."'
CCANP (as'well as-the other parties as appropriate) were instructed "to submit a list'of particular matters which they believe should be encompassedLin the-l Phase II hearings
.." so that those hearings would be h
"much more precisely defined.than was the Phase'I hearing."
Memorandum and Order (May 22, 1984) at 12-13.
In-establishing the permissible scope of the additional
' discovery _ granted to CCANP, the Board noted that'it" regarded its PID as'having "had some effect on the scope of-the issues properly open to litigation in Phase II."
Iji. at 4.
In l
i-l
=
.- particular, it concluded that "the adequa7y of HL&P's character" had been resolved by its PID except to the extent that Quadrex reportability considerations might affect that determination, and stated that it would not be "useful to 4
litigate" alleged " deficiencies in Brown & Root engineering performance-.
uncovered by the Quadrex Report
. in the context of HL&P's
. character."
Id. at 5.
The Board further noted that it had "already determined
'that there were certain deficiencies, particularly with
. respect to nuclear experience," and that "to the extent that the Quadrex Report reflecte deficiencies in the early competence of HL&P, it is merely cumulative."
Id.
The Board did grant additional discovery with respect to HL&P's " current" compe-tence.
Id. at 5, 9-11.
Although CCANP moved'for reconsideraticn of the Board's May 22 Memorandum and Order, it failed to identify any litigable issue regarding HL&P's character or competence arising out of the Quadrex Report, beyond the general assertion that_the Board had foreclosed inquiry into the " essence" of the Report. /
Instead, CCANP simply referred, without anye underlying, articulated basis, to "[t]he possibility" that-evidence could be developed to show that HL&P had misled the NRC regarding Brown & Root's engineering capabilities.
Motion ' for' Reconsideration -(June 5, 1984) at 2.
- /
CCANP. Motion for Reconsideration of ASLB's Memorandum and Order (Ruling on CCANP Motions for Additional Dis-covery and Applicants' Motion for Sanctions). dated May 22, 1984 (June 5,_1984) (Motion for Reconsidera-
' tion. (June 5, 1984) ) at 1.
a The. Board denied CCANP's Motion for Reconsideration and, in doing so, again reiterated the need for particularization of the issues to be litigated:
Nowhere have we held that.the entire Quadrex Report would perforce be subject to examination in Phase II.
Indeed, the Quadrex Report, taken as a whole, is too wide-ranging a document to be considered as a
" matter in controversy" Memorandum and Order (July 10, 1984) at 4.
It also clarified its prior statements regarding the appropriate scope of the Phase II proceeding.
In particular, the Board stated that since the Quadrex Report is "an evaluation of [ Brown & Root's] engineering practices
" Brown & Root is "no longer associated with the project," and it had "already examined [HL&P's supervision of Brown & Root engineering activities] to a considerable extent
. further inquiry into [HL&P's character].through I he fin' dings of the Quadrex Report would [not] be productive."
t Id. at 5.
The Coard concluded that CCANP's reliance on the
" circumstantial conclusions of the Quadrex Report
" and
" conjecture" was insufficient to " provoke another full-blown inquiry into HL&P's character, given the substantial evidence-of HL&P's positive character traits upon which [it] relied fin-[its] PID.
Id. at 5-6.
With respect to HL&P's "early" competence, the Board
[
~ reiterated its conclusion that certain deficiencies existed,
- but. determined that "further evidence on early ' deficiencies
.i l
l
_7_
of HL&P would be at best cumulative."
Id. at 6-7.
The Board recognized that "the only competence question of con-tinuing materiality is whether HL&P and its current con-tractors are competent to finish construction of and/or to operate the facility." Id. at 7.
Following the Board's July 10 Memorandum and Order, the parties were required to specify the particular issues they believed should be litigated in Phase II.
Despite the fact that CCANP had this additional opportunity to demonstrate to the Board that there were litigable character and competence issues to be addressed, it provided no more than a " laundry list" of general topics concerning the Quadrex Report rather than a stutement of issues sufficiently drawn to permit adjudication. /
The pattern is unchanged to this date.
At the October 16, 1984 prehearing conference convened to identify the issues to be heard in Phase II, CCANP's counsel stated its desire 4
to "go into the underlying factual issues on each of the specific findings," made a " global request
[to] go into each matter discussed.in the Quadrex Report
" and
~*/
CCANP Specification of Particular Matters for Considera-tion in Phase II Hearings (October 1, 1984) (CCANP Specification of Issues) at 1-4.
Although it vaguely requested'"further clarification" regarding the issues the Board deemed appropriate for litigation, CCANP included in its list topics it now claims have been improperly fore-closed from consideration.
For example, CCANP listed among the " issues" it wished to litigate, the "[ilmplications for HL&P's [c]haracter and [c]ompetence" of the "[s]ub-stance" of the Quadrex Report.
Specification of Issues at 1, 3.
Thus, it cannot argue that uncertainty regarding the scope of the issues deemed appropriate for litigation by the Board caused it to omit any particular matter.
Instead, CCANP simply failed to identify the matters it wished to litigate with sufficient specificity to warrant adjudication.
t, concluded that he had nothing "to add beyond what [was]
present.
" in the CCANP Specification of Issues.b!
Even in its current Motion, CCANP continues to' rely upon unspecified and unsupported allegations regarding the " chaotic and life threatening" design process at STP and fails to pro-vide any factual basis for those allegations.
Motion at 7.
Although CCANP cites the Board's statement that HL&P's over sight of Brown & Root's engineering effort "may theoretically
.have some bearing on an overall assessment of HL&P's character it has not identified any aspect of HL&P's performance in that regard that reflects adversely on its character. $/
Id. at 5.
-*/
Fifth Prehearing Conference Transcript (October 16,.1984)
(Tr.) at 10756, 10758 and 10759.
i i
--**/
CCANP also takes issue with the Board's conclusion'that it had "already examined those activities to a considerable
- extent,
[and that] further inquiry into [that] sub-ject.
. would'[not].be productive."
Motion at Sr.
CCANP argues, in particular, that the Board overstated the extent to which the Phase I record addressed HL&P's. oversight _of Brown & Root engineering,'and that the one " minor" inquiry into such activities cited by the Board could not justify its refusal to consider HL&P's record in that regard in Phase II.
Id..at 5-6.
CCANP is in error.
The Board's one record eference, which was cited by way of example, i
is not the only evidence in the Phase I record regarding HL&P's oversight of Brown & Root engineering.
Other testimony addressing those activities was presented in the context of descriptions of HL&P's overall Project manage-ment and QA organizations.and activities..
16-21,g.,_Goldberg E.
and Frazar, ff.JTr. 906, at 1-2, 5-14, 30-31;' Tr.
1150-51, 2512 (Goldberg), 5119-20 (Oprea).
Other witnesses
. testified about concrete placement (including:Cadwelding and reinforcing bar: installation) and described HL&P Engineering's activities related to such' work.
U El..,
Murphy et al. (Contentions), ff. Tr. 6522, at 53-57, 61,'65; Saltare111 et al.,
ff. Tr. 7536, at 4-5; Tr.
6621,'6990-92, 7205 67-THernandez).
, _.,,,. _ _ _ ~... _ -, _...,. _., _, _., _. -
, _, _,., _. ~... -, _, _, _ _,...... - -
_x Pursuant to 10 C.F.R.
S 2.752 (a) (1), NRC licensing boards are required to convene a prehearing conference in order to consider, among other things, the "[slimplification, clarification, and specification of the issues
." to be litigated.
Licensing boards are also required, after the prehearing conference, to " enter an order.
. which limits the issues or defines the matters in controversy to be deter-mined in the proceeding." /
10 C.F.R.
S 2.752(c).
See also, 10 C.F.R. Part 2, Appendix A, II(b) and (c).
Thus, the Board properly sought to define and narrow the issues to be liti-gated in Phase II, a process in which CCANP has been either unwilling or unable to cooperate.- /
-*/
-Furthermore, in NRC proceedings, a party seeking to litigate a specific issue must set forth a contention and describe the bases for such a contention with
" reasonable specificity."
10 C.F.R. S 2. 714 (b).
Even where specific contentions are not requirec (as in.the case of an interested state pursuant to 10 C.F.R.
S 2. 715 (c) ), a participant is still required to frame new issues to be litigated with " sufficient detail and preciseness" to warrant adjudication.
Gulf State Utilities Co. (River Bend Station, Units 1 and 2), ALAB-444, 6 NRC 760, 768 (1977).
In River Bend, 6 NRC at 770, the Appeal Board cited favorably the requirement imposed by the Licensing Board that the State of Louisiana, participating as an interested state, identify issues which are "rele-vant, material and narrow enough to permit evidentiary determination in an adjudicatory setting."
--**/
CCANP asserts that the Board "already knew what issue
[it] wanted to litigate" since the Board had previously acknowledged that "CCANP apparently wishes to liti-gate the design engineering questions raised by.the Quadrex Report under the umbrella of [ Issue Al."
Motion at 9.
CCANP has reiterated on numerous occasions its general position that the " questions" raised by the Quadrex Report are somehow relevant to HL&P's character and competence.
It has failed, however, to specifically identify such
" questions"_or to describe how they affect the Board's determinations on HL&P's character and competence.
_ - _- ~ _-_--
.. - ~. _ - -
r CCANP's second principal basis for challenging.the i
f Board's determination that no Quadrex-related matters (apart j
i from reportability) warrant litigation in Phase II is that the imposition of such limitations deprived it of its due j
process ri'ghts.
In particular, CCANP points to the fact that its proposed Quadrex contentions were withdriwn based upon the " broad" inquiry into the Report envisioned by the Board's Fourth Prehearing Conference Order, that the Board subsequently imposed limitations on litigation of the Quadrex
{
Report not anticipated by the agreement among the parties which led to the withdrawal of CCANP's contentions and that, therefore, it was unfairly deprived of its right to litigate the Quadrex Report.
Motion at 3, 8.
Even if CCANP believed'that the Board's Fourth Prehearing Conference Order had authorized a broad inquiry into the Quadrex Report, / by the time that it was required to submit a list of issues to be litigated in Phase.II, CCANP, as noted 1
above, had been-repeatedly informed that a reasonable degree I
of specificity would be required in defining Phase II issues L
and had been provided numerous opportunities to identify such issues._ Given-CCANP's failure to formulate any such issues, f
'-*/
Although broad discovery pertaining to-the Qua' rex Report d
was,-in fact, available, CCANP did not choose to exercise its discovery rights.
The State of Texas, however, did
~
p exercise its discovery rights and obtained answers to numerousLinterrogatories from Applicants and the NRC Staff, and deposed HL&P's Vice' President, Nuclear Engineering and Construction.
it cannot fairly _ argue that it has been denied due process on the basis of the withdrawal of its proposed contentions over two years ago.
As a result, there is no basis for the Board to reconsider its decision to eliminate from the scope of Phase II all Quadrex-related matters other than reporta-bility questions.
III. Board Denial of CCANP's Additional Discovery Requests CCANP also requests.that the Board reconsider its decision denying further discovery from the NRC Staff regarding the bases for the Staff's determinations on the reportability of the Quadrex Report pursuant to 10 C.F.R.
S 50.55(e). I CCANP argues that "[t]he extent of HL&P's J
failure to notify and report is a clear reflection on its character," that the Staff " fell far short" of providing the information requested by the Board regarding the bases for its reportability determinations, that if CCANP would have sought discovery earlier "such discovery would have been objectionable," and that "no prejudice" will result from the additional discovery sought.
Motion at 11-12.
Contrary to CCANP's allegation that HL&P's reporting of the Quadrex findings pursuant to section 50.55(e) reflects
- /
'In particular, CCANP requests additional discovery regarding the Staff's "most recent determination of whether designs reviewed by.
. Quadrex.
. were or were not released for construction and.
the new classification system used by the Staff in its brief on the reportability issue."
Motion at 1.
/
r-
. adversely on its character, both the NRC Staff / and Appli-t cants- / etermined that all matters identified in the Quadrex d
Report which were reportable pursuant to section 50.55 (e) have, in fact, been reported.
Though further inquiry might theoretically disclose some error in the Staff's analyses, the existence of such an error would not reflect adversely on HL&P's character (particularly in light of the subjective nature of those analyses).
Thus, the Board properly concluded that even if it were to disagree with the concurring opinions of the Staff and Applicants, "the failure to have reported would not reflect adversely on HL&P's character.
and that the additional information sought by CCANP has "no bearing on HL&P's character.
Memorandum and Order
-(July 10, 1984) at 8; Fifth Prehearing Conference Order at 9.
CCANP also argues that the Staff's brief on reportability issues did not include the information requested by the Board in its June 22, 1983 Memorandum and Order, and that it could not anticipate that the Staff would fail to provide the requested information.
Motion at 11.
The Board had i
requested the Staff "to provide further analysis of its determination that most items under the Quadrex Report [were]
-*/
NRC Staff Response to Licensing Board Memorandum and Order Regarding the Reportability of the Quadrex Report (August 24, 1984)- (Staff Brief) at 10.
--**/
Applicants' Response to NRC Staff Brief on the Report-ability of the Quadrex Report (September 28, 1984) at 1.
4
--..,_,,4--
+ - -
V
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not reportable, including the basis for its conclusion that various designs had not been ' released for construction' (within the meaning of 10'C.F.R. S 50.55 (e) (1) (ii)). "
Memorandum and Order (June 22, 1983) at 6..In responding to the Board's inquiries, the Staff identified specific rationales in support of its conclusion that "all reportable Quadrex-related items were in fact reported" pursuant to section 50.55 (e).
Staff Brief at 10.
It did not, however, describe the bases for its previous conclusion that the various designs had not been released for construction, because it concluded that to revisit its original evaluation process would require an extremely time consuming " reexamination of not only the Quadrex work packages, but a winnowing out from all South Texas drawings of those relevant to each work package."
Id.
Rather than engage in that exercise, the Staff provided the Board with additional, specific bases supporting its reportability determinations.
Id. at 8.
Thus, although it did not provide every aspect of the information requested, the Staff, nevertheless, supplied sufficient information to inform the Board and the parties regarding the bases for its reportability determinations and fairly responded to the Board's June 22, 1983 Memorandum and Order.
As a result, CCANP's allegation that the Staff " fell L
far short" of complying with the Board's instructions is without merit.
CCANP also argues that had it sought discovery from the Staff, such discovery would have been objectionable "on the L
grounds that the Staff was working on a brief on just those matters."
Motion at 12.
Apparently, CCANP's argument in this regard is based at least in part upon its belief that Applicants had raised a similar objection to an interrogatory propounded by the State of Texas.
However, CCANP is mistaken.
Applicants objected to the specific interrogatory in question based, in part, upon the fact that to respond would have required them to provide their legal positions prematurely. /
Unlike the discovery which CCANP now requests, the interrogatory in question called for legal conclusions rather than the factual bases for the Staff's reportability determinations.- /
In any event, CCANP's argument that its discovery re-quests "would have been objectionable" is pure speculation and cannot excuse it from its failure to request discovery against the Staff in a timely fashion despite the extensive opportunity provided by the Board for it to do so.
- /
Applicants' Answers and Objections to State of Texas' First Set of Interrogatories to Applicants on Quadrex (August 26, 1983) (Applicants' Answers) at 26.
- /
In response to another interrogatory, Applicants provided a factual discussion of the bases for their reportability determinations under section 50.55(e).
Applicants' Answers at 21-25.
- / In the Board's June 24, 1982 Memorandum it established a 90 day discovery period following receipt of Bechtel's-and the Staff's evaluations of the Quadrex Report and imposed no limitations on the scope of discovery aside from those prescribed by the Commission's Rules of Practice.
In its discretion, the Board subsequently granted CCANP an additional 90 days of discovery and stated that "[nlo further requests for extensions of discovery time by CCANP on the Quadrex Report
. will be entertained by us, absent the most extraordinary circumstances."
Memo-randum and Order (May 22, 1984) at 6-7.
CCANP, however, sought no discovery during either of the periods made available to it.
Under the circumstances, the Board properly concluded that CCANP has " forfeited" its right to take additional discovery.
Fifth Prehearing Conference Order at 10.
L.
. Finally, CCANP argues that no prejudice will result from granting it the additional discovery it requests.
Motion at 12.
On the contrary, further discovery could delay the Board's determination regarding what reportability matters, if any, should be addressed in Phase II, as well as the sub-mission of testimony on any such issues admitted.
Furthermore, such delay is unwarranted in light of the fact that even if the requested discovery revealed some theoretical error in the Staff's analysis, such an error would not reflect adversely on HL&P's character.
Thus, CCANP has failed to provide any basis for the Board to reconsider its decision denying additional discovery from the NRC Staff.
IV.
Conclusion CCANP has requested that the Board reconsider its decision to eliminate from the Phase II proceeding all Quadrex-related matters (other than those addressing reportability, upon which it deferred ruling).
CCANP has failed, however, to identify a single litigable issue arising out of the Quadrex Report, despite the fact that it has been informed by_the Board on numerous occasions that particularization of the issues to be litigated would be required prior to initiating Phase I' hearings.
Furthermore, CCANP has not provided any basis for the Board to reconsider fts denial of additional discovery from the Staff.
CCANP has failed to submit a single discovery
I i request or to adequately explain why it could not have t
obtained the desired information at an earlier date, despite extensive opportunities to do so.
Moreover, requiring the Staff to respond to such discovery would delay initiation of Phase II hearings, if any are to be held, even though the requested'information would have no bearing on HL&P's character.
Accordingly, CCANP's Motion should be denied in all respects.
Respectfully submitted,
,/
p Jack R. Newman Maurice Axelrad Alvin H. Gutterman 4
Donald J. Silverman 1615 L Street, N.W.
)
Washington, D.C.
20036 t
Finis E. Cowan
-r
+u 3000 One Shell Plaza Houston, Texas 77002 Dated:
December 31, 1984 NEWMAN & HOLTZINGER, P.C.
ATTORNEYS FOR HOUSTON LIGHTING 1615 L Street, N.W.
& POWER COMPANY, Project Manager Washington, D.C.
20036 of the South Texas Project acting herein on behalf of itself and BAKER & BOTTS the other Applicants, THE CITY 3000 One Shell Plaza OF SAN ANTONIO, TEXAS,' acting by Houston, Texas 77002 and through the City Public Service Board of the City of San Antonio, CENTRAL POWER AND LIGHT COMPANY, and CI'rY OF AUSTIN, TEXAS is -
i lI.*
s Y
s
,S' UNITED STATES OF M4 ERICA UEU*,j D NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOA *85 JM -3 N0 :18 In the Matter of
)
0FFICE OF SECRGARY
)
00CKF. Tit 4G & SERVICf.
HOUSTON LIGHTING & POKER
)
Docket Nos. 50-498 b$f "
)
50-499 OL
)
. South Texas Project, Units 1 )
(
and 2)'
)
CERTIFICATE OF SERVICE I hereby certify that a copy of the'" Applicants' Response To CCANP Motion For Reconsideration Of ASLB Order of November 16, 1984" dated December 31, 1984, has been served on the following individuals and entities by deposit in the United States mail, first class, postage prepaid, on'this 31st day of' December, 1984.
Charles.Bechhoefer, Esq.
Brian Berwick,-Esq.
Chairman, Administrative. Judge Assistant Attorney General Atomic Safety and Licensing for the State of Texas
~
Board Panel Environmental Protection U. S. Nuclear Regulatory Commission
= Division Washington, D.C.
.20555 P. O. Box 12548, Capitol Station Austin, TX 78711 Dr. James C. Lamb, III
-Administrative Judge
' William'S, Jordan, III, Esq.
313 Woodhaven Road.
Harmon, Weiss & Jordan
. Chapel' Hill, NC 27514 2001 S Street, N.W.
Washington, D.C.
20009
- Ernest E. Hill Administrative Judge Kim Eastman, Co-coordinator.
Hill Associates Barbara A. Miller 210 Montego Drive-Pat Coy Danville, California 94526' Citizens Concerned About Nuclear Power-Mrs.LPeggy Buchorn 5106 Casa Oro
~ Executive Director.
San Antonio, TX 78233
' Citizens for Equitable Utilities, Inc.
Lanny Sinkin Route 1,-Box-1684 Nuclear Information and Brazoria', TX 177422
-Resource Service Fourth Floor
' Robert G. Perlis, Esq.
1346 Connecticut Ave., N.W.
Office.of the' Executive Legal Washington, D.C.
20036 Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555-
(;
Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D.C.
20555
. Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington,_D.C.
20555 Docketing and Service Section Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Ph
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L l
.