ML20126J929

Answers to NRC Second Set of Interrogatories & Requests for Production of Documents Re Health Effects of Facility & Financial Costs of Decommissioning.Certificate of Svc Encl. Related Correspondence

ML20126J929
Person / Time
Site:	Comanche Peak
Issue date:	04/24/1981
From:	Ellis J Citizens Association for Sound Energy
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8105070312
Download: ML20126J929 (12)

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UNITED STATES OF M GRICA E LEAR N TORY COMMISSION

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k BEFORE THE ATONIC SAFETY AND LICENSING BOARD 8 g e ~/

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Docket sos, 50 45 APPLICATION OF TEXA8 WILITIES I

and 50-u6 k3 OENERATING COMPANY, ET AL. FOR AN l

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PEAK STEAM ELECTRIC STATION.

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A ib UNITS fl AED #2 (CPSES)

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0F INfERROGATORIES TO, AND HEQUEST FOR THE MMTION OF DOCUMENTS FROM. INTERVENOR CASE _

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N COMES NOW CASE (Citizens Association for Sound Energy), hereinafter r todt N,

W ac CASE,.Interrenor herein, and files this, its Answers to NRC Staff's Second Set

~ ? of Idterrogatories to, and Request for the production df documents from, Intervenor.,

CASE,1 dated 3/26/.81 and received by CASE on 3/30/81.-

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ANSWERS

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Coatention 24-

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Those set forth in 10 CFR 51.20, including, but not limited to the followings

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l Realth effects of the uranium fuel cycle; health effects of low-level fl radiation freen routine and unplanned emissions from the facility; health offects of possible accidents at the facility, from the least harmful to J

the worst possible; models used to calculate low-level radiation doses; S,.,

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On April 10, 1981, in telephone conversations with Marjorie Ulman Rothschild gj' and Valentine Deale, it was a6 reed that the NRC Staff has no objection to an

.t extension of time of filing this responoe until April 24,1981 (instead of M

April 14, 1981), and CASE was granted such extension.

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THIS DOCUMENT CONTAMIS S

i-8' 507 I p-POOR QUAUTY PAGES 4

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calculation of nanber of expected cancers from operation of CPSE8; uranium cupply; water use; evacuation and emergency procedures; unresolved generic

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safoty issues; deccessissioning; transportation of low-and high-level wastes, F

storage of low-level and high-level wastes; capacity factors; discharge of f

cffluents into water; transmission. lines; herbicide usage; selection of site; l

population concentrations; meteorlogical considerations; hydrology - watershed; f

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i realistic assesasent of. expected performance of plant ecaspared to design rating; endangered species; construction costs; total costs of plant; operat-ing costs; reliability; power generating costs; external pro,1ect costs; I;

l marine environmental impacts; archeological aspets; econcmaic effects of j

the uranium fuel cycle; econcaic effects of health effects of low-level radiation frcus routine and unpalaned emissions frca the facility; alternative i

7 sources of energy ccamparisons between different possibilities; costs of lL l

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overcapacity; land use; taxation besis of the land after plant is shut down; l

Guergy conservation; excess capacity; terrestrial ecology; aquatic eco ogy

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j tir pollution; regional historic, scenic, cultural, and natural features;

. 1 and biocide vaste; right-of-way disruptions; visual impacts; chemicalsanitary and other w

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l ground water; possibility of accidents from aircraft; thsrmal eff

.f harmful to the worst possible; econcmaic effect of accidents on the surround-g l

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ing area; economic effect of accidents on ratepayers who are paying for the plant; release of radioactive vaste to watershed; side effects of transports-

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i tion of spent fuel; analysis of who will pay.,for the c'ost of nuclear vaste 3

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security costs;

' cod nuclear fuel accidents in transit t'o or frce the plant;

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affects of security as regards loss of civil liberties and loss of privacy; j

l co:st and effects of external flooding; need for power; risk comparison be.

y tween operating CPSES and not operating it; adequacy of site geology; seismic j

considerations; effect on besith of workers exposed to radiation; financial coct of health effects to workers exposed to radiation; increased fuel costs;

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f analysis of need for CPSES, by year, for its 40-year life as compared to 3

j what alternatives will be available during that time;. inflationary impacts

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on costs of all aspects of CPSES; inflationary impacts on the Dallas / Fort

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l Werth metroplex area of the increase in costs of electricity.due to the'

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construction and including of construction work in progress in the rate base

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l fer CPSES, as well as'such inf1stionary impacts due to the cost over-runs

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l experienced at CPSES; socioeconcaic impact of the plant upon' ideal comusuni-l-

j ties, inc}uding large influx of workers and families on a temporary basis

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l requiring building of more schools, increased police protection, etc. and i,

l offect'of leaving remaining residents to continue to pay for costs of such 8

l increased facilities when transient workers move on; operating' costs of CPSES;.b l

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power geserating costs of CPSES.

l In addition, all items listed as costs in Applicants' cost / benefit

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l coalysis not mentioned in the preceding list..

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C2%. (b) in CASE believes the only benefit to be derived from CPSES is that it w do not,elieve b

produce alectricity when it's in operation; even so, we l

that that electricity win be needed, economical, or safe. CA f

h ER, increased employment and tax revenues, as Applicants have done in t e NDInsCT nEisrITs:

page 11.o-3, Amendment 1, September 1980, section indirect

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J temporary and by permanent employees) constitute a significan

l ised as an benefit of CPSES.

win be derived by Scmerve11 and Hood Counties are also recognIncreased employmenf I

important indirect benefits of the project." tax re' enues cannot h

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j (Vennoat Yankee _

(1974)).

mate NEPA cost-benefit balance for a particular plant v

Nuclear Power' Corp., Vernont 7ankee Station, A1

.y be offset by aJ T

creased local. business activity, increased tax revenues will

r l yment the loss of local employment and wage incases (thus creating unemp o (samebusineses,

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with its attendant costs), decreased local business activity ith cspecially bars and taverns, may have to go out of business entirely w d cing

.y resulting unsuployment, possibly moving frcus the area of inccme-pro u[3 in and tax-producing businesses; other businesses will s f

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tion, building new schools for transient grkegs' families, police protec I,

i t to increased jail facilities (presentga!$liSIIs wer's not even suffic en d;

i er con' ain those individuals who engaged in civil disobedience by go ng ovin the the fence in the past, and such activities may increase t

T the area.

increased fire protection, etc., when the transient worke Ih P

benefit "ex*=adad community services and public facilities lise arraa**-

ment of S-~ Creek Reservoir)" unless and until Applicants fina(See letter of June O$

meats with the State of Texas regarding this matter.

Pro.

1980 from David J. Preister, Assistant Attorney Geners'., Environmenta h

3, 1980, tection Division, Texas Attorney General's Office, letter of July /80 Supplemen F, J l

from Billy R. Clements, Vice-President, TUGCO, and CASE's 7/1k tion of Certain to Itas 1. (CASE Contention 1) of CASE Motion for Rec sent

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as to ej time, such arrangements have not been made and there is no indicat on h,

1-V vben they win be made.

With regard to the ecological surveys which have been performed in M

1 the region of CPSES during the past several years regarding the l~

invertebrate, reptilian, avian, and floral ecumunities 9

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~ f some floral the removal of part of their natural habitat, the destruct on o b

l ical areas forever, more than outweigh any alleged benefits of such eco og I:

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C244. (b)(continued):

With rosard to Applicants' statements in 8.1.2 5 Improvement to Area

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f' Facilities (page 8.1-18 of EE),

CASE hardly sees how upgrading of Faru Roads 201 and $1,' which was necessitated by "an extensive volume of vehicle j

traffic to and fro.a the CPSES plant site""during the' early phases of project

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construction" which "resulted in significant wear to local roadways," can i

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be counted as a ". benefit" without recognizing a corresponding and offsetting -

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" cost." Further,.we do not see the creation of the Squaw Creek Reservoir j

as a great enhancement to the sport and recreational opportunities for ares I

residents when admittedly "there are other recreational reseryoirs. located within a short commuting distance from the CPSES;" recognition must also l

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be given to the negative benefit of loss of privacy, increased traffic, and increased air pollution to those on. the route to and from the Reservoir.

With regard to Applicants' stat'ements in 8.1.2.6 Public Education (pass

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8.1-18 of the EE),

CASE believes that the " local information office...

t established in Glen Rose to provide ares residents with details pertainting' to the CPSES project in particular, and to nuclear issues in general" is primarily a public relations effort to make the plant more acceptable to the residents, to promote the use of nuclear energy as a power source, and abould more properly be called propaganda rather than public education.-

There may be scue value under the Public Education.section regarding the archeological survey of the CPSES area which was conducted in 15f(2. -

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However, the statement by Applicants that "The great majority of this his ;

torical data would have been lost beyond recovery had it not been for this' detailed survgy" is undocumented and perhaps undocusentable. Further, one

,of the reasons for this survey was that Applicants uncovered dinosaur tracks which would have perhaps been lost forever due to actions by Applicants had they not cut out the track and moved it elsewhere' to preserve it.

Applicants state in 8.13 Stannary of Benefits (page 8.1-19, September 1980 Amendment to ER),

that "A stamary description of the' benefits of the CPSES project is presented in Table 8.1-21, and 'in Section 11.1."

However, although Amendment page 8-iv indicates that thiere are new tables added, i

Tables 8.1-21 and 8.1-22,, CASE has never receiv'ed Table 8.1-22 0244. (c): 10 CFR $1.20(b) and 51.21.

C24-6. (d): See that Applicants answer all questions by Intervenors and the NRC Staff fully and completely and that all guidance and requirements of NRO regulations are complied with by Applicants and that all issues raised by Intervenors or the NRC Staff are adequately considered and resolved beforo Applicants are granted hn operating license or allowed to load fuel; 2espond fully and completely to interrogatories and requests for documents by CASE; pursue with vigor any pmblem areas or inadequacies indicated by Staff orr Intervenor's questions and con-tentions and seeing to it that such problems and inadequacies are dealt with fully and remedied; assure that adequate documentation on the part of Applicants is required and provided fo'r any and all allegations made by said Applicants; seeing to it that such documenta-tion is presented to the NRC, the Intervenors, and the public thmugh 4-

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3-C944.(d)(continued):

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these operating license pmceedings before Applicants are issued an i

operating license or allowed to load fuel. CAS3 expects the Applicants i

to be required to comply fully with all f ederal regulations and guidance j

before an operating license is granted and before Applicants are allowed to load fuel; and we believe that the NRC Staff has the responsibility to see that this is done and an overriding responsibility to assure that the public health and safety will be protected.

C244. (e).

Ahether or not, after all the costs and benefits have been adequately considered, the benefits outweigh the costs, should be the determining factor. Based on 10 CFR 51.20(b) and 51.21, CASE believes that a realistic and in-depth assessment of the actual costs directly related to CPSES must be considered in the cost / benefit analysis which Appli-cants are required to prov'ide in the ER.

All costs and besfits must be considered; thus, all are of significance and importance. CASE would recommend that the primary consideration be given to those items which have the greatest impact and the most long-lived impact. Thus, we would rank them in importance (1) Costs is teras of health and M1ars of storage and/or disposal of radioactive vastes; (2) Costs in teras of health and an11mrs of a worst-case accident at CPSES, especially with regards radioactivity released; (3) Costs in teras of health and dollars of the nuclear fuel cycles

.m (4) The manerous items which have or any have some bearing or relation to the above items (1) through (3), sued as unresolved safety issues',

decommissioning, transportation of spent fuel and low-level wastes,,

discharge of effluents into water, population concentrations, seteor-logical considerations, hydrology - watershed, groundwater, surface water, air pollution, etc.

(5) All other costs.

C244. (f). (a) 10 CYx 51.20(b) arx! 51.21; Applicants' Ihvironmental Report (ER);

and the rule of reason.

(b) Same as (a) above.

(c) See answer to 0244.(c). preceding.

(d) 10 CFh, including but not limited to 50.57.

(e) 10 CF2s 51.20(b) and 51.21; and the rulo of reason.

C24-7. We assume that the emphases indicated in your characterization of C AST's answer to C24-3 is meant to be your own rathe.r than an accurate representa-tion of CASE's answer'c emphases (i.e., that you simply were underscoring costs to emphasize that portion of our answer that you wished to discuss in your question). We mention this only because the change of emphasis changes the meaning somewhat of our answer.

(a) 10 CFR 51.20(b) and 51.21.

l (b) See answer to C244(d) preceding.

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h4-7, (c) By " accurate" we mean in exact or careful confomity to truth, or fidelity

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to some standard, especially as the result of care; exact; f

to fact' or truth attained by the exercise of care; correct; free j

from fault or error as judged by some standard; specifically in regard to this conten' ion, we further mean without errors of omission a

or deliberate avoidance of dealing with all costs associated with 3

5 CPSES.

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(d) See answer to C24-6(a) preceding, f

. r, (e) (a) See answer (a) preceding,

'a (b) See answer C2h-6(f)(d) preceding.

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(c) Webster's dictionatry; the rule of reason.

(d) See answer C24-6(f)(a) preceding.

)i S2 i-8. (a), We have not made a detailed analysis of these costs; h l

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1 CASE had previously been operating on the assumption that the

-)j must be considered.

(OLS), pages 5.8-1 through information contained in. Applicants' ER 3 (Section 5 8) was applicable; however, in their September'1980 j

J 5.Bk Amendment 1 to the ER, Applicants have changed their choice of de-

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commissioning to specify that. they are going for immediate dismantle-j ment, rather than a slower dismantling after a number of years, and the cost projections of Applicants have risen from $18.h million l

CASE is still in 1981 dollars to $100 million in 1980 dollars.

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evaluating these changes and vill be supplementing our responses later I

'f regarding this contention. Generally, we believe the costs estimated are too low i

cants don't know what they're.getting into with this method of dis-

'l mantling, that they don't know the costs. involved, the potential legal problems, how this is going to be paid 'for and who's going to pay for it, how they're going to physically dismantle the plant, how they're

.i going to protect their workers from radiation while dismantling the plant, etc.

J (b). By " safe" in regard to decommissioning, we mean done in a manner so f

as not to contaminate the workers at the plant with radioactivity with resultant cancers, genetic effects and injury, so as not to con-taminate the surrounding areas with radioactivity which could render 4

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such areas uninhab'itable for years, so as not to subject workers or members of the public to the threat of danger,- harm or loss, fran radioactivity or from accidents, so as not to damage or harm the flora and fauna, animal life, birds,' vater, air, or archeological j

'1 aspects. of the area.

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(c)(a)d51.20(b) and 51.21; Applicants' ER (013), Sections 5 8 and 8.2.13 10 CFR 1

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C24-8.(c)(b) Webster's dictionary; 10 CFR 50 57; the rule of reason.

C2b 9. (a) As stated in our previous response, CASE has not made a detailed analysis. See also answer to C24-5, pages 35-37, of our 4/6/81 Supplement to CASE's Answers to NRC Staff's First Set of Interrogatories to, and Requests for the Production of Documents frca, Intervenor CASE.

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(b) Any workers who might be affected by an accident with regard to the l

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onsite storage of spent fuel. See also answer (a) above.

(c)Spentfuel. Seealsoanswer(a)above.

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(d).See answer (a) above. Generpily, of lesser magnitude than occurred.

l at Three Mile Island.

y (e) See answer (a) above. Generally, of the magnitude of or greater than the magnitude of those which occurred at Three Mile Island, up to and I

including a complete meltdown of spent fuel.

l (f) The rule of reason; see also answer (a) above.

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c, C24-10.<10CFR51.20(b)and51.21;theruleofreason.

k Contention 25 s,

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1 p7' C25-8. CASE objects to this question as being self-evident. Your question C25-2 was: " State specifically the requirements in 10 CFR Part 50, Appendix l

,C, which you contend have not been met because of what you contend to be Applicants' lack of financial qualifications to operate the proposed l

facility." (Enphasis added.) The quotations are from -- guess what --

p' 10 CFR Part 50, Appendix C1 The elimination cf unnecessary questions such as this on the part of the NRC Staff v'ould help speed up the licens-g ing process considerably for all parties and the Licensing Board -- if that were.

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the true intent of the proposed NRC rule changes to expedite the hearing '

process.

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C25-9 upply documentation to prove that they are financial.ly sound and healthy, that they will be around and still in business by the time CPSES is to be deccanmissioned and will have funds available to pay for such decommission-ing, that they have met all requirements of the Atomic Energy Act, as amended, 10 CFR-50 5 and 10 CFR 50, Appendix C and have accurately demonstrated that they have t(s)(4),

'true financial integrity, stability, and qualifications to operate CPSES.

Answer all questions by Intervenors and the NRC Staff fully and completely,

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i and supply all requested pertinent documentation requested by Intervenors and the NRC Staff.

i Applicants have not answered CASE's questions fully and ccupletely; we currently have a Motion to Compel complete ansvers before.the Board in this. regard.

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C25-9A(continued):

From Applicants' ansvers to CASE's questions regarding this contention, it is obvious that they intend to respond only to the NRC Staff's questions and requests and to stonewall on any questions fr'em CASE. This position by Applicants is clearly contrary to NRC regulations, specifically 2 7kO(b)(1) and 10 CFR Part 50, Appendix C.

(Se'e CASE's 3/17/81 Motion to Compel and J

to Require Supplementation of Responses to CASE's Fourth Set of Interrogatories to Applicants, pages 2 through 13 for further details regarding this con-tention.) Applicants' self-proclaimed statement that they have provided the financial information to enable the NRC' to make the findings required by 10 CFR 50 57(a)(k) regarding the Applicants' financial qualifications a

is not sufficient to prove that Applicants are financially healthy. Other k

pertinent evidence and information must also be considered (see particularly y'

last paragraph 'of page 6 continued on page 7 of CASE's above-referenced 3/17/81 Motion to Canpel).

10 CFR Part 50, Appendix C, only states that "...it will ordinarily be suffi.cient to show at the time of filing of the application, availability s

of resources sufficient to cover estimated operating costs for each of the first 5 years of operation plus the estimated costs of permanent shui,-

down and maintenance of the facility *in safe condition."

(Emphasis added'.)

Clearly, these operating license proceedings are not ordinary -- Applicants fs are being~ challenged, based on sworn testimony of three of the six Applicants 1

'T themselves, regarding their financial qualifications, in addition to being C.

chauenged -(in Contention 24(a)) regarding their cost estimates of decem -

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.missioning CPSES. Applicants must go beyond th'e narrow boundaries they.

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have attempted to impose in order to prove their financial qualifications y~

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to operate CPSES.

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fM It is impossible for CASE to reconcile the financially sound condition

,c, the Applicants claim in the operating license hearings with the deteriorating, i.e unsound' financial condition which lacks financial integrity claimed by the j

Texas Utilities companies in rate hearings. ' Having heard the sad songs of -

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impending doom and financial disaster of the Texas Utilities companies for '

C the past seven years as an Intervenor in DP&L rate hearings, CASE believes' y?

it is absolutely essential to make the Applicants prove conclusively that

.L, they are indeed financially healthy and can in fact do the things referenced J'

in paragraph one of this answer, and that such proof be provided before f

Applicants are allowed to load fuel and before an operating license is 4:

issued.

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(b).See that those things referenced in (a) above are done. Respond fully K

and completely to interrogatories and requests for documents from CASE;'

i pursue with vigor any problem areas or inadequacies indicated by Staff J

or Intervenor's questions and contention and see to it that such problems.,.

[g an'd inadequacies are dealt with fully and' remedied; make sure that adequate documentation on the part of Applicants is required and pro-vided for any and all allegations made by said Applicants; see to it w

that such documentation is presented to the NRC, the Intervenors,,and

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C25-9.(b)(continued):

the public through these operating license proceedings before Appli-cants are allowed to load fuel or are issued an operating license.

CASE expects the Applicants to be required to comply fully with all y federal regulations and guidance before an operating license is granted i

and before Applicants are allowed to load fuel; and we believe that the NRC Staff has the responsibility to see that this is done and

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an overriding responsibility to assure that the public health and safety vill be protected.

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C25-10.(a) 10 CFR 2 740, 2 7h0b and 2 7kl(d).

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Q' (b) By " prove" we mean to establish or ascertain by argument, documenta-tion or other evidence, to demonstrate or show, to ascertain or establish the genuineness or validity of, to verify. See C25-9(a) preceding for more specifica as to how this applies to CPSES and this contention.

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(c) See ansvers C25-9(a) and C25-10(b) preceding.

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~~P l (d)By"'financialintegrity"wemeanhavingtheabilitytopayone's 411gations on a timely basis, to pay _a reasonable return to one's

$9;.7 investors, to borrow money at a reasonable rate, to maintain a good

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credit rating, and to maintain flexibility within one's dealings y,

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in the financial community and in obtaining, capital; in the context

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of this contention, "one's" would equal " Applicants'."

,p,i CASE sought to ascertain this very specific information regarding

.h each of the Applicants in its Fourth Set of Interrogatories to Appli-W cants, Questions 3, 4, 5, 6, 7, and 8.

Applicants' apparent inability 4

or refusal to answer Question 3 vith a simple "yes" or "no" and the f

evasive, inemplete ansvers which were given to Qdestions 3 through 8 f 3-were a major reason for the necessity of' filing CASE's 3/17/81 Motion 7N.

to Compel and to Require Supplementation of Responses to CASE's Fourth C

i Set of Interrogatories to Applicants. The manner in wh'ich these very specific, simple, and important questions were answered adds further credibility to CASE's contention. PleasereadCASE's3/17/81 Motion to Compel referenced above in its entirety, with particular attention.

to pages 5 through 8.

It concerns CASE very much to realize that we have not yet received theansverstoour2/17/81FourthSetofInterrogatoriestoApplicants; although we have now received an answer frm Applicants. to our Motion to Compel which we filed on 3/17/81, we have not yet received any ruling frca the Board on our Motion to Ccapel; we assume that should the Board rule favorably on our Motion, it will still be some little time before Applicants supplement their ansvers. We are not bringing this up to complain about the Board's being slov in answering. To t,he 1

l contrary, ve believe that the time taken with the process has been very lC '

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C25-10. (d)(continued):

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. reasonable and necessary and preserves the rights of all parties.

We are concerned because this points up the totally inadequate, unreasonable I

i procedures'which have been suggested under the timetable proposed j

in the March 18, 1901 FEDERAL REGISTER, pages 17216 through 17218

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" Proposed rule change: Expediting the NRC Hearing Process." We would

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hope that the NRC Staff would join CASE and other concerned or62nizations l

and individuals in opposing these proposed rule e aanges which throw all semblance of fairness and due process empletely out the window and which, j

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j if enacted, would reduce this hearing process to an utter and complete farce.

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(e)'The Atomic Energy Act, as amended, 10 CFR 50 57(a)(4), 10 CFR 50, s,,.

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Appendix. C,10 CFR 2 740, 2 7h0b and 2 7kl(d), when taken cumulatively 7

and, CASE believes,. in the context in which they were intended. See l

CASE's 3/17/81 Motion to Compel and to Require Supplementation of 9,

l Responses to CASE's Fourth Set of Interrogatories to Applicants, i

especially pages 5 through 8 (Questions 3 through 8) and pages 10 i

through 13 (Ccaments regarding Contention 25). See also answers C25-9(a) and'(b) preceding.

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3.e (f)(a)SeeC25-10(a) preceding.

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g (b) Webster's dictionary; the rule of. reason.

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(c) The Atanic Energy Act, as amended,10 dFR 50 57(a)(4), and 10 CFR 50, Appendix C.

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(d) The Atmic Energy Act, as amended,10 CFR 50 57(a)(4), and 10 4

i CFR 50, Appendix C,10 CFR 2 7h0, 2 740b and 2 7hl(d).

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(e)SeeC25-10(e)above.

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Respectfully submitted, b

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rs.) Juanita Ellis, President CASE (Citizens Association for^ Sound Energy).

1426 S. Polk v

Dallas, Texas 75224 214/946-9446 i

21h/941-1211, work, part-time, usually l

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h/2h/81

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i UTE.; alA1 OF AMERICA NUCLEAR REGULATJRY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of 1

I APPLICATION OF TEXAS UTILITIES 1

Docket Nos. 50-445 GENERATING COMPANY, ET AL FOR AN 1 and 50-446 OPERATING LICENSE FOR COMANCHE 1

PEAK STEAM ELECTRIC STATION 1

UNITS #1 AND #2 (CPSES) 1

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CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of I

CASE's Answers to NRC Staff's Second S,et of Interrogatories to, and Request l

for the Production of Documents from,.Intervenor CASE have been sent to the names listed below by First Class Mail this 24th day l

of April

,.198 1

• with Certificate of Mailing receipt.

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m.

• Valentine B. Deale, 2sq., Chairman David J.

Preister, Esq.

Atomic Safety 'nd Licensing Board Assistant Attorney General a

c 1001 Connecticut Avenue, N. W.

Environmental Protection Division /

Washington,.D. C.

20036 P. O. Box 12548, capitol Station.g Austin, Texas 78711

-r, Dr. Forres t J. Remick, Member 9.'

Atomic' Safety and Licensing Board Mr. Richard Fouke r

H-

-- 305 E. Hamilton Avenue 1668-B Carter Drive i

' State College, PA 16801 Arlington, TX 76010 3

.Dr. Richard Cole, Member Atomic Safety and Licensing BoardP

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Atomic Safety and Licensing Board Panel

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U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission t

Q Washington, D. C.

20555 Washington, D. C.

20555

• Nicholas S. Reynolds, Esq.

Ato.mic Safety and Licensing -

i a.

Debevoise & Liberman U. $.ppeal Panel

A 1200'- 17th St., N. W.

Nuclear Regulatory Commissio'n i~

Washington, D. C.

20036 Washington,.D. C.

20555 N

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• Marj orie Rothschild Docketing and Service Section f

. Counsel for NRC Staff Office of the Secretary i

U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Washington, D. C.

20555 f

f Mr. Geoffrey M. Gay Arch C.. McColl, III, Esq.

t,,_

West Texas Legal Services 701 Commerce Street, suite 302 100 Main Street (Lawyer.s Bldg.)

Dallas, u 75202 i

Fort Worth, TX 76102 Pre o A en e D A^n A J

Yw Dallas, H 75219 rs.~) Juanita Ellis, President

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J ASE (CITIZENS ASSOCIATION FOR SOUND ENERGY)

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t STATE OF TEXAS )

t Juanita Ellis, being duly sworn, deposes and says:

That she is President of CASE (Citizens Association for Sound Energy),

i and knows the contents of the foregoing CASE's Answers to NRC Staff's Second Set of Interrogatories to, and Request for the Production of Documents frcan, Intervenor CASE I

and that the same is true of her own knowledge and belief.

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/M tin t, 'L4i.) h)". D puitaEllis ~

r.

SWORN To and Subscribed k

s.

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before me on this 2hth day

.of April _

1981.

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l Notary Public ev

.P My Ccanmission Expires:

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(SEAL)'

s The oiiginal of this page is being mailed under separate cover, First Class Mail, j

tothe, Secretary, U. S. Nuclear Regulatory Ccanmission, Washington, D. C. 20555, j

Attention:' Chief,. Docketing and Service Section, on this 2kth day of April l

i 1981.

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