ML20136J417
| ML20136J417 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/03/1986 |
| From: | Rothschild M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#186-720 OL, NUDOCS 8601130359 | |
| Download: ML20136J417 (16) | |
Text
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January 3, 1986 08cw{0 LW N j7j,,O p/
UNITED STATES OF AMERICA i
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of l
CAROLINA POWER AND LIGHT COMPANY AND I NORTH CAROLINA EASTERN MUNICIPAL
)
Docket Nos. 50-400 OL POWER AGENCY
)
50-401 OL (Shearon Harris Fuclear Power Plant, Units 1 and ?)
)
NRC STAFF ANSVER TO INTERVENOR WELLS EDDLEMAN'S " RESPONSE ON CONTENTION 57-C-7 (CONTAMINATED INJURED PERSONS)"
I.
Introduction On December 23, 1985 IntervenorWellsEddleman[hereafterEddleman) filed a pleading entitled "Well's Eddleman's Response on Contention 57-C-7 (Contaminated Injured Persons)" fbereafter Eddleman Responsel.
Mr. Eddleman's pleadino responds to the Atomic Safety and Licensing Board'sfhereaftertheLicensingBoard)OrderofDecember9,1985.
" Order (Concerning Arrangements for Medical Services)" [hereafter Order).
As explained in more detail, infra, in that Order the Board requested that Mr. Eddleman advise the Board and parties whether he 1/ n which wishes to renew a motion he originally filed on March 1, 1985 i
he sought to have the Board reconsider its ruling rejecting most of his 1/
" Motion To Reconsider re Contention 57-C-7" [hereafter Motion To Reconsider).
!DE o P
QSO7 00 9
PDa
(,
l 2/ in view o'f Guard v. NRC, 753 F.2d 1144 (P.C. Cir.
I Contention 57-C-7 t
l 1985).
In the event that Mr. Eddleman renewed his motion, the Board's Order directed the parties to file pleadings " addressing the pending l
motion, including consideration of... three questions" the Board posed in its Order. Order, at ?-3.
In his response, Mr. Eddleman requests that Contention 57-C-7 be admitted, in the form set forth in his response. Mr. Eddleman also requests that discovery begin immediately and that a hearing be held if there is no summary disposition of the contention.
l The Staff below responds to both Mr. Eddlemar's original motion, the l
ficard's December 9,1985, Order, and his response to that Board Order.
l l
For the reasons set forth below, the Staff submits that in accordance with the Commission's " Statement of Policy on Emergency i
l Plannint Standard 10 C.F.R. 50.47(b)(12) E it is reasonable to limit
[
contentions on this subject to issues which could have been heard before the Court's decision in Guard v. NRC, supra. -- that is whether the plans identify the existing medical facilities.
Inasmuch as that issue has l
already been resolved through summary disposition, N there are no issues l
arising from Contention 57-C-7 remaining which should be considered.
I l
2/
That contention, as originally drafted, alleged a number of l
~
l deficiencies in arrangements for medical treatment and services.
3/
50 Fed. Reg. 20892 (May 21,1985).
4/
" Memorandum and Order (Ruling On Eleven Sunnary Disposition Potions)," February 27,1985[hereafterMemorandumandOrder).
~
l
Backaround Contention 57-C-7 as originally proposed by Mr. Eddleman stated i
that:
The plan', Part 1, pp 66, 68-71, does not provide the plans of various hospitals to treat radiation victims, can treat no more than 96 as plans state, and do not provide for training or protection of emergency personnel transporting these victims to hospitals.
(SeePt1p.85-handwaving). Quite obviously, more than 96 victims could be contami-nated with radiation in an accident at Harris. Cf.
NUREG-CR 2239 p 2-43 data as adjusted per numbers on pp C-4 and C-5 thereof (corrections for Indian Pt vs. Harris) gives Harris early injury figures about 5.5% of those in the tables 2.5-1 and 2 (ibid p. 2-43) or 200 more persons (except witgjevacuation to
?S miles, 100 early injuries). -
l As the Board noted in its Order of August 3, 1984, 6_/ Contention 57-C-7 (as originally proposed) had three main subparts:
The first alleges that there will not be enough hospitals to treat " radiation victims"....
The second part of 57-C-7 alleges, correctly, that i
the State ERP does not contain the plans the hospitals have for treating radiation victims...
j The third and last part of 57-C-7 alleges that the State ERP does not provide ' training or protection' for emergency workers transporting radiation victims to hospitals...
20 NRC at 401.
[
5/
" Wells Eddleman's Contentions on The Emergency Plan (2d Set),"
~
April 12,1984, at 6-7.
6/
Carolina Power and Light Company and North Carolina Eartern Municipal Power Agency (Shearon Harris P.'uclear Power Plant, Units 1 and2),LBP-84-298,20NRC389(1984).
t I
The Board rejected all of the subparts of Contention 57-C-7 except for the first part, noting that:
"The rejected... parts of contentions either call for more than regulations and guidance call for or permit, or do not address the plans."
E The Board explained its rationale for rejecting those portions of Contention 57-C-7 as follows:
In relation to the second part of 57-C-7, neither NRC regulations nor guid6nce even suppest that any ERP should contain either the plans hospitals have for treating radiation victims or the procedures and reference materials -- maps, phone nu*:bers, reports, plans -- mentioned in i V.B.2 of the State ERP:
' Applicable supporting and reference documents and i
tables may be incorporated by reference.... The l
plans should be kept concise as possibic.
The average plan should censist of perhaps hundreds of pages, not thousands.'
NUREG-0654, at 29. Neither i
l dc we see why the information referred to in i V.B.2 l
.must be in the plans before it con be detennined whether the plans conform to the evaluation criteria in i ?!.L in NUREG-0654. We would think that that determination could be made on the basis of informa-tion now in plans.
In relation to the third part of 57-C-7, the conten-tion's citation to the State ERP at 85 apparently refers to Item e-g on that pape, which discuss the training of personnel with medical duties.
Citations to sections which provide for training are not much l
support for a contention which says the plans don't provide for training.. The contention calls these l
passages 'handwaving,' but that word can hardly specify deficiencies in such a way as to make them the subject of admissible contentions. Further, 57-C-7's allegation that the State plan doesn't l
provide protection for personnel transporting radiation victims doesn't address the plans many i
j provisions for control of radiological exposure of l
l energency workers. See, e.g., i G of the State ERP.
Finally, no NRC regulation or guidance requires the
[
ERPs to provide for the mobile equivalent of what hospitals can provide for radiation treatment....
i 20 NRC at 401 a0.
i l
l
I,.
The Board stated that it was admitting "the first part of Contention 57-C-7 though in altered forn." 20 NRC at 402. Citing the Commission's I
decision in Southern California Edison Co. (San Onofre Nuclear Generating Station, Units 2 and 3), CLI-83-10, 17 NRC 578 (1983), the Board noted that it was barred from
... considering in litigation, as 57-C-7 would have us do, whether medical services available in the region of Harris are in quantity adequate to deal with the number of people who, in a radiation acci-dent at Harris, might be either contaminated and otherwise injured (' contaminated injured' in the language of NUREG-0654, 5 II.L) or simply seriously in.iured by radiation alone. The Commission accepted the thesis in San Onofre that there are likely to be so few contaminated injured that no arrangements beyond those already made under NUREG-0654, 65 II.L.1 and 3, and 10 C.F.R. Part 50, Appendix E, 6 IV.E.6, need be made, and that those seriously injured by radiation alone are so unlikely to need emergency treatment that treatment for them can be arranged ad hoc, going beyond local services if necessaryT Tan Onofre, supra, 17 NRC at 535-36.
[ footnote omitted] [ emphasis in originall.
20 NRC at 402.
Therefore, according to the Board
... we cannot admit the first part of 57-C-7 in the form in which it is presented. However, there is within that part of 57-C-7 something like a ' lesser-included' contention, namely that the EPP's should at least show what medical services are available for those seriously injured by radiation alone.
20 NRC at 403.
The contention which the Board admitted stated:
Neither the State ERP nor the county ones make clear whether the hospitals listed in Section V.B.3 of the State ERP are prepared to treat severe radiation exposure per se. Plans should include lists of local and regT6nal hospitals with the necessary capab1TTites to provide nedical services for those l
l i
l i
seriously injured by radiation alone. 1/ [ emphasis in origi nal.l.
The Applicants and Mr. Eddleman conducted discovery on the admitted contention. Subsequently, Applicants filed a motion for summary dispost-tion of the narrowed version of Contention 57-C-7. E/ The Staff, through FEPA,supportedApplicants' motion.El Mr. Eddleman did not oppose the Applicants' motion, which the Board granted. El In its Memorandum and Order, the Board recognized the existence of the Guard decision, supra, El and provided a copy of it to the parties. The Board stated that the decision did not appear to affect its summary disposition ruling on this contention. Order at 2.
On March 1, 1985, Mr. Eddleman filed a motion requesting that the Board reconsider its ruling on Contention 57-C-7, as it had been originally submitted, or as it might be modified in light of the Guard 7/
The exact wording of the contention was not contained in the Board's August 3, 1984 Order, but was a0 reed upon by the parties and approved by the Board.
" Order Approving Joint Stipulation Codifying Certain Admitted Contentions" (December 6,1984).
D/
" Applicants' Motion For Summary Disposition of Eddleman 57-C-7,"
~
January 2,1985.
9/
" FEMA Staff Response To Applicants' Motion For Sumary Disposition i
of Eddleman 57-C-7," February 1, 1985.
l M/ Memorandum and Order, supra.
i 11/ As explained in more detail infra, in the Guard decision, the U.S.
Court of Appeals for the District of Columbia Circuit vacated and
~~
remanded to the NPC that part of its interpretation of 10 C.F.R. 50.47(b)(12) which stated that a list of treatment facilities constituted adequate arrangements for medical services for individuals who might be exposed to dangerous levels of radiation at locations offsite from nuclear power plants.
decision. El In Mr. Eddleman's Motion to Reconsider, supra, he stated
~that:
I understand the D.C. Circuit Court of Appeals has issued an opinion in case 84-1091(12 February 1985) reversing the Nuclear Regulatory Consnission decision in San Onofre (on which this Board evidently relied in limiting the admission of contention 57-C-7) that a list of hospitals able to treat contaminated injuredradiationvigmsinandemergencyresponse plan is sufficient Motion To Reconsider, at 1.
Ouoting from the Guard decision, Mr. Eddleman concluded that
"[t]his would appear to void the Board's ruling limiting admission of 57-C-7 due to NRC's San Onofre decision." M. Therefore, Mr. Eddleman asked the Board "to reconsider and admit Contention 57-C-7 as originally drafted (or appropriately modified consistent with the Court of Appeals decision.)" M.
In their responses to Mr. Eddleman's March 1 Motion, the Applicants and the Staff took the position that a ruling on Mr. Eddleman's motion would be premature, in light of the likelihood of forthcoming generic Commission guidance to 1.icensing Boards concerning the Court's ruling. El Accordingly, the Board did not take any action at that time.
(
M / Motion To Reconsider. supra.
13/ Mr. Eddleman apparently is referring to the Commission's decision
~
in San Onofre, supra.
M/ "NRC Staff Pesponse To Intervenor Eddleman's Motion for peconsidera-tion," March 13, 1985; " App 1tcants' Response To Intervenor Eddleman's Motion for Peconsideration of Eddleman 57-C-7," March 15, 1985.
l l
y III. Discussion In his Response, supra, Mr. Eddleman answers the first two questions posed by the Beard in its Order E by asserting that Contention 57-C-7 should be admitted, "but not as drafted, since the Guard v. NRC decision specifies it better." Response, at 1.
According to Mr. Eddleman, the contention should read:
The plan, except for a list of hospitals, does not provide for medical treatment of contaminated injured persons as required by NRC and other applicable rules, e.g(. 10 CFR 50.47(b)(12), GUARD v. NRC (753 F;Cd 1144 1985). The plan does not provide for training or protection from contamination for emeruincy personnel transporting these victims to medical treatment. There may wel,1 be more early radiation injuries and contaminated injured persons than the plan Cr' existing medical treatment arrange-nents for contaminated injured persons can handle.
All these problems need to be solved in order to (7
..., assure effective protective action for contdminated
.. injured people and protection from spreading
' contamination via injured persons requiring redical treatment..
Response, at 1.
5
'15/v,'The Board specified the following three questions for the parties to address.
1.
Should Eddleman 57-C-7 now be admitted as originally drafted except for the ' list' issue already resolved by summary disposition or in some other modified form?
2.
If so, state exactly how such a contention should be wurfed.
3.
How should any admitted contention be addressed under the Commission's May 16 Statement of Policy?
a.
Would any discovery be necessary?
b.
Could disputed matters be resolved by affidavits, without a hearing?
Order, at 3.
e
{.N
?,
Contention 57-C-7 in all of its various forms, essentially alleges deficiencies in arrangements for medical treatment and services pursuant to 10 C.F.P. ! 50.47(b)(12)..That regulation provides that offsite emergency response plans for nuclear power reactors must make arrangements for medical services for contaminated injured individuals. Specifically, emergency planning standard (b)(12) provides:
(b) The onsite and offsite emergency response plans for nuclear power reactors must meet the following standards:
(12) Arrangements are made for medical services for contaminated injured individuals.
NUREG-0654 (Section II.L.) sets forth the planning standard and evaluation criteria for 10 C.F.R. 50.47(b)(12).Section IV.E.6. of Appendix E to 10 C.F.R. Part 50 provides that adequate provisions shall be made and described for emergency facilities and equipment, including
" arrangements for transportation of contaminated injured individuals from the site to specifically identified treatment facilities outside the site boundary."
Thescopeofsection50.47(b)(12)wasanissueincontroversyin the adjudicatory proceeding on the adequacy of the emergency plans for the San Onofre Nuclear Generating Station, Lnits 2 and 3. E l The Comission certified to itself the issue of the interpretation of planningstandard(b)(12). CLI-82-27, supra. The Commission, in 16/ Southern California Edison Co. (San Onofre Nuclear Generating Station, Units 2 and 3), ALAB-680, 16 NRC 127 (1982); LBP-82-39, 15 NPC 1163, 1186-1200, 1244-1257, 1290 (1982).
interpreting 50.47(b)(12), determined, inter alia, that (1) Planning standard (b)(12) applied to individuals both onsite and offsite; (2) " contaminated injured individuals" was intended to include seriously irradiated members of the public; and (3) the reouirement for adequate medical arrangements for such injured individuals would be. satisfied by a list of area facilities capable of treating such injuries.
In Guard v. NRC, the Court vacated the Commission's interpretation of planning standrd (b)(12) to the extent that a list of treatment facilities was found to constitute adequate arrangements for medical services for offsite individuals exposed to dangerous levels of radiation, j
753 F.2d at 1146, 1150.
The Court did not review any other aspects of the Commission's interpretation of planning standard (b)(12). The Court also afforded the NRC sdbstantial flexibility in its reconsideration of planning standard (h)(12;) to pursue any rational course, 753 F.2d at 1146.
Possible further Commission action might range from reconsidera-tion of the scope of the phrase " contaminated injured individuals" to imposition of " genuine" arrangements for members of the public exposed todangerouslevblsofradiation.
Id.
In its Statement of Policy, supra, the Commission provided interim guidance uni.il it " determines how it will respond to the Court's remand."
50 Fed. Rg., supra, at 20893. According to the Commission's Statement of Policy, "until the Commission concludes its Guard remand and instructs its boards and its staff differently," it is reasonable to limit contentions on this subject "to issues which could have been heard before the Court's decision in Guard v. NRC" (50 Fed. P_eg. 20894) -- that is, whether the~ plans identify the existing medical facilities.
i
/
. 3 Subsequent to the issuance of the Commission's Statement of Policy, other Licensing Boards have had occasion to rule on the admissibility of contentions concerning arrangements for medical services for contami-nated injured individuals. The Licensing Board in Vogtle E noted:
That which is litigable under 10 CFR 50.47(b)(12) is limited as a result of the Commission's ruling in San Onofre, CLI-83-10, supra, the partial reversal of the San Onofre decision in Guard v. NRC, 753 F.2d 1134 (D.C. Cir. 1985) and the Commission's Statement of Policy on Emergency Planning Standard 10 CFR 50.47(b)(12), supra, which indicates that there will
-be further action by the Commission in the matter either by rulemaking or ger generic action.
femphasis in original). -
In Vogtle, the Board determined that:
-17/ Georgia Power Company (Vogtle Electric Generating Plant, Units 1 and2),"MemorandumandOrder(RulingonJointIntervenors' Proposed Contentions on Emergency Planning," August 12, 1985, at 22-73 (unpublished).
The relevant contention in Vogtle (which was comprised of various statements from Joint Intervenors' filing) stated as follows:
Applicants fail to show that adequate emergency facilities and equipment to support the emergency response are provided and maintained as required by 10 CFR 50.47(b)(8).
For example, the Burke County plan shows the county has only four emergency medical response vehicles. The Burke County Hospital, which the Plan says will handle the treatment of both radiation-contaminated and noncontami-nated injuries, has a bed capacity of only 52. Such facilities are unlikely to be sufficient to service a large number of injured in the ' event of t fairly serious radiological accident or of an accident external to the plant which results in injury to the plant, such as an earthquake or a nuclear attach, where non-plant related injuries vill also be rampant.
I_d., at 20-21.
l_8/ For the information of the Board, the Comission, on May 20, 1985 published for comment a petition for rulemaking [50 Fed. Reg. P0799
-(May 20, 1985)] on the issue of medical arrangements.
... it would serve no useful purpose to generally litigate the question of what constitutes adequate arrangements for medical services for contaminated injured individuals until the Comission has ruled on the matter. We do accept the Comission's guidance indicating it would be acceptable at this time to litigate the subject, as it pertains to issues which could have been heard before the Court's decision in Guard, i.e., as to whether the plans identify existing treatment facilities. To the extent the proposed contention goes beyond the matter of whether the plans identify the medical facilities capable of treating the injured and contaminated it is nonlitigable and rejected.
Vogtle, supra, at 23-34. El Application of the above principles here leads to the conclusion that it is reasonable to limit Mr. Eddleman's Contention 57-C-7 to issues whicn could have been heard before the Court's decision in Guard v. NRC.
The only such issue, (as originally raised in Contention 57-C-7 and reframed by the parties) focused on the adequacy of lists of hospitals with capabilities to provide treatment for persons suffering radiation injuries. As previously stated, that issue has already been resolved through summary disposition. El The Comission's Statement of Policy also requires applicants to comit to full compliance with the Comission's ultimate response to the Guard remand. Applicarts have in fact made such a comitment.
"Appli-cants' Response To The Licersing Board's Order (Concerning Arrangements
--19/ Accord, Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1), " Memorandum and Order Denying Suffolk County's and State of New York's Motion To Admit New Contention," August 21, 1985 (unpublished).
20/ Specifically, that issue concerned whether the State emergency plans and those of the County should include lists of local and regional hospitals with the necessary capabilities to provide medical services for those injured by radiation alone.
= _.
For Medical Services)," December 30,1985,[hereafterApplicants' Response) at 8-9 and Attachments A and 8.
As the Staff noted in responding to Intervenor Eddleman's Motion for Reconsideration, supra, the other portions of Contention 57-C-7 were properly rejected. E Mr. Eddleman has provided no additional bases which would support admission of those portions of Contention 57-C-7 previously rejected by the Board.
If anything, the modification in wording now proposed by Mr. Eddleman is more broad and vague than the language originally proposed. As set 4rth in his Response, the only reference to training of transportation workers is the broad allegation that "[t]he Plan does not provide for training or protection from contamination for emergency personnel transporting these victims to medical treatment."
Response, at 1.
Not only does this statement lack the necessary basis and specificity required by 10 C.F.R. G 2.714, but it is not accurate.
The Board itself found that the plans provide for training of transpor-tation workers.
20 NRC at 402.
Accordingly, the Staff concludes that (in answer to the Board's first and second cuestions as set forth in its Order supra), Eddleman Contention 57-C-7 should not now be admitted as originally drafted or in some modified form.
With respect to the third question posed by the Board in its Order, Mr. Eddleman essentially asserts that discovery and a hearing is required (Response, at 2-4) and that " resolution by affidavit would violate the right to a hearing (unless summary disposition motion (s) succeeded)"
-21/ NRC Staff Response To Intervenor Eddleman's Motion for Reconsideration, supra, at 2-3 citing Shearon Harris, LBP-84-298, 20 NRC at 400-404.
r
(: '
(Response, at 3). El In view of the Staff's position, the Staff would not reach the third ouestion posed by the Board which assumes the existence of a viable contention appropriate for consideration.
In the event that the Board decides to admit Contention 57-C-7 in some form, the Staff concurs in the response of the Applicants to the third question posed by the Board. E I IV. Conclusion For the reasons set forth above, the Staff objects to Mr. Eddleman's Contention 57-C-7, and urges that the contention (as originally drafted or as revised by Mr. Eddleman in his Response) be denied.
Respectfully submitted,
' *: ' I
/ Itl i
(7'/T Marj ie U. Rothschild Counsel for NRC Staff Dated at Bethesda, Maryland this 3rd day of January,1986
-22/ Mistakenly characterizing the Ccmmission's Policy Statement as a rule change, Mr. Eddleman also asserts that the Commission's Statement of Policy, supra, should have no force and effect for various reasons, including the lack of notice and comment.
Contrary to Mr. Eddleman's assertion, while notice and comment procedures are required for rulemaking, such procedures are not L
required for issuance of a policy statement by the Connission since k
policy statenents are not rules.
Vermont Yankee Nuclear Power Corp.
(Vermont Yankee Nuclear Power Station), CLI-76-14, 4 NRC 163 (1976).
23/ Applicants' Response, at 12-13.
L
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE AT0 pre SAFETY AND LICENSING BOARD In the Matter of
)
)
CAROLINA POWEP AND LIGHT COMPANY AND )
NORTH CAP 0 LINA EASTERN MUNICIPAL
)
Docket Nos. 50-400 OL POWER AGENCY
)
50-401 OL
)
(Shearon Harris Nuclear Power Plant,
)
Units 1 and 2)
)
I hereby certify that copies of "NRC STAFF ANSWER TO INTERVENOR WELLS EDDLEMAN'S " RESPONSE ON CONTENTION 5'7-C-7 (CONTAMINATED INJURED PERSONS)"
in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or deposit in the Nuclear Regulatory Commission's internal mail system (*), this 3rd day of January, 1986:
James L. Kelley, Chairman
- Richard D. Wil' son, M.D.
Administrative Judge 729 Hunter Street Atomic Safcty and Licensing Board Apex, NC 27502 U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Glenn 0. Bright
- Travis Payne, Esc.
Administrative Judge 723 W. Johnson Street Atomic Safety and Licensing Board P.O. Box 12643 U.S. Nuclear Regulatory Commission Raleigh, NC 27605 Washington, DC 20555 Dr. James H. Carpenter
- Dr. Linda Little Administrative Judge Governor's Waste Management Building Atomic Safety and Licensing Board 513 Albermarle Building U.S. Nuclear Regulatory Commission 325 North Salisbury Street Washington, DC 20555 Raleigh, NC 27611 Daniel F. Read John Runkle, Esq. Executive Coordinator CHANGE Conservation Counsel of North Carolina P.O. Box 2151 307 Granville Rd.
Raleigh, NC 27602 Chapel Hill, NC 27514 Steven Rochlis Spence W. Perry, Esq.
Regional Counsel Associate General Counsel FEMA Office of General Ccunsel 1371 Peachtree Street, N.E.
FEMA Atlanta, GA 30309 500 C Street, SW Rm 840 Washington, DC 20472
Atomic' Safety and Licensing Appeal Bradley W. Jones, Esq.
Board Panel
- Regional Counsel, USNRC, Region II U.S. Nuclear Regulatory Commission 101 Marietta St., N.W. Suite 2900 Washington, DC 20555 Atlanta, GA 30323 Robert P. Gruber Executive Director Thomas A. Baxter, Esq.
Public Staff - NCUC John H. O'Neill, Jr., Esq.
P.O. Box 991 Shaw, Pittman, Potts & Trowbridge Raleigh, NC 27602 1800 M Street, N.W.
Washington, DC 20036
- Wells Eddleman' Atomic Safety and Licensing Board
- 806 Parker Street U.S. Nuclear Regulatory Consnission Durham, NC 27701 Washington, DC 20555 Richard E. Jones, Esq.
Dr. Harry Foreman, Alternate Associate General Counsel Administrative Judge Carolina Power & Light Company P.O. Box 395 Mayo P.O. Box 1551 University of Minnesota Raleigh, NC 27602 Minneapolis, MN 55455 H.A. Cole, Jr., E.q.
' Special Deputy Attorney General Antitrust Division Office of Attorney General 200 New Bern Avenue Raleigh, NC 27601 W
$V Stua'rt A. Treby Counsel for NRC Staff L