ML20137F242
| ML20137F242 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 01/13/1986 |
| From: | Matt Young NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#186-759 OLA, NUDOCS 8601170485 | |
| Download: ML20137F242 (19) | |
Text
-
-. k January 13, 1986 f-p 'h),kfD UNITED STATES OF AMERICA NUCLEAR REGillATORY COMMISSION .gg diy 13 pI 10 AFAR. ,_
BEF0PE THE ATOMIC SAFETY AND LICENSING BOARD o, Ba,7ff C.y r:
YU.M[&;;}t:. e In the Matter of )
METROPOLITAN EDISON COMPANY, ET AL. Docket No. 50-289 0b
) (Steam Generator (Three Mile Island fluclear Station,) Plugging Criteria)
Unit No. 1) )
NRC STAFF RESPONSE TO TMIA'S DEMAND FOR ADJUDICATORY HEARING I. TNTRODUCTION Three Mile Island Alert, Inc. (TMIA) has filed a " formal demand for adjudicatory hearing" 1/ ni connection with a request by GPU Nuclear Cor-poration-(GPUN or Licensee) for a Ifcense amendment which would revise pluggirig criteria for the steam generator tubes at Three Mile Island Nuclear Station, Unit 1 (TMI-1). Therein, TMIA asks that it be granted a full hearing on the proposed amendment for the reasons set forth in an exhibit attached to the petition, which is a copy of a prior request for hearing on the revised tube plugging criteria, dated March 25, 1985 (hereinafter " Exhibit"). For the reasons discussed below, the petition as currently drafted fails to satisfy fully the requirements of 10 C.F.R.
'! 2.714.
1/ "Fonnal Demand for Adjudicatory Hearing on Amendment to THI-1 Operating License to Change Tube Plugging Criteria," December 23, 1985(Petition).
4
t a II. DISCUSSION A. Factual and Procedural Background The Comission issued an order on July 2,1979 directing that the TMI-1 facility remain shut down 2/ until the Comission determined, in light of the March 28, 1979 accident at TMI-2, whether there is reasonable assurance that THI-1 could be operated with no undue risk to the public health and safety. See Metropolitan Edison Co. (Three Mile Islar.d Nuclear Station, Unit No. 1), CLI-79-8, 10 NRC 141 (1979). While the facility was shut down pursuant to the Commission's order, Licensee discovered that many of the tubes in the steam generators at TMI-1 had been damaged and would require repair or removal from service. Licensee repaired the steam generators using a kinetic expansion technique for certain tubes and conventional plugging procedures for other tubes. 3_/
In May 1983 Licensee submitted a request for an amendment to its
- license for a change in the technical specifications for TMI-1 to permit the steam generators to be declared operable following repair by methods to be approved by the NRC. Licensee also requested an amendment approving the specific repair method used on the steam generators. In response to the notice of Licensee's amendment request and of opportunity for hearing, TMIA filed a petition to intervene and subsequently was admitted as a party. Following an evidentiary hearing, an initial
-2/ At the time of the Comission's July 2,1979 Order, TMI-1 was shut down for refueling.
3/
~
The Licensee conducted the repairs pursuant to 10 CFR 550.59. No license amendment was found to be necessary at that time, although it was noted by the Staff that an amendment would be required for operation with the repaired steam generators.
decision was issued on October 31, 1984 which authorized Licensee to operate TMI-1 with steam generator tubes repaired by the kinetic expansion repair process. LBP-84-47, 20 NRC 1405. TMIA's appeal of that initial decision and its motion to reopen the record on the basis of purportedly new information subseovently were denied by the Appeal Board. ALAB-807, 21 NRC 1195 (1985).
By letter dated January 31, 1985, Licensee transmitted TDR-645,
" Basis for Plugging and Stabilizing Criteria for OTSG Tubes," and requested _ approval of revised plugging limit criteria for its steam generator tubes. S Specifically, Licensee requested approval to revise the repair limit depth for limited arc length defects based on maintain-ing' the licensed margin of safety using an alternate analysis approach and considering improved defect characterization capability. Licensee proposed that-this change be made without a change in the technical specifications, purportedly in accordance with the current wording of Technical Specificatien 4.19.4.a.6, which establishes the repair limit as:
. . . the imperfection depth at or beyond which the tube shall be repaired or removed from service because it may become unserviceable prior to the next inspection. This limit is equal to 40% of the nominal tube wall thickness, unless higher limits are shown to be acceptable by analysis and approved by the flRC. (Emphasis added.)
1.icensee stated in its letter that use of the proposed criteria does not require a change in the technical specifications and does not involve an unreviewed safety question.
4/ Letter from R.F. Wilson, GPUN, to John F. Stolz, NRC, January 31, 1985.
See BN-85-028.
U By letter of March 1,1985 Licensee proposed a staged approach for approval of its request. Subsequently, Licensee informed the Staff that, in order to avoid any potential limitations on TMI-1 readiness for restart, GPUN would proceed immediately to plug all tubes in accordance with the present repair limits of technical specification 4.19.4.a.6. 5_/
Licensee further requested that the Staff continue its review of the revised plugging criteria reouest so as to avoid unnecessary tube plugging in the future.
On March 25, 1985, TMIA filed a request for hearing (which is attached as an exhibit to the instant petition) which was opposed by Licensee and Staff on the grounds that the request was premature. The Staff also stated that the revised plugging criteria would not be approved without a license amendment and Licensee had not yet submitted a request for such amendment. NRC Staff Response, April 15,1985 at 4-5.
Accordingly, the Connission denied TMIA's March 25, 1985 request for bearing finding that it was premature and noted that TMIA could appro-priately resubmit its petition to intervene and request for hearing when the NRC publishes a notice of opportunity for hearing. Order, April 19, 1985.
On November 6, 1985, Licensee submitted Technical Specification Change Request No. 148 seeking revision of the threshhold criteria (plugging criteria or repair limit) for determining when plugging or some other repair is required.
5/
~
Letter dated March 29, 1985 from P. R. Clark, GPUN, to J. F. Stolz, NRC. See BN-85-033.
On January 6,1986, the NRC published in the Federal Register a notice of consideration of the issuance of an amendment to the TMI-1 license and offered an opportunity for prior hearing on the amendment.
51 Fed. Reg. 459. That notice described the proposed license amendment and the manner in which interested persons may request a hearing, and set February 6, 1986 as the deadline for filing intervention petitions.
On December 23, 1985, prior to the hsuance of the Federal Reoister notice, the present intervention petition was filed by TMIA.
B. TMIA's Request for Hearing In its petition, TMIA demands that an ad,iudicatory hearing be held on Licensee's amendment to revise the plugging criteria, urges that such hearing be completed before the amendment becomes effective, and requests leave to participate as an intervenor in the hearing. See Exhibit at 1-?, 13-14, 6/
TMTA asserts that it is a "public interest organization" located in Harrisburg, Pennsylvania, which represents " residents within a five county radius of TMI-1." Exhibit at 2. The petition also states that the signers of the petition are members of TMIA and " represent the organiza-tion's effort to secure hearings on the amendment." Id,. E Further, TMIA asserts it " represents persons whose interests may be affected by the 6/ Although TMIA's hearing request was filed prior to the January i
1986 notice of opportunity for hearing concerning the amendment, the Staff has treated the request as a timely, albeit early, inter-vention petition on the subsequently noticed license amendment.
7/
~
While both Joanne Doroshow and Louise Bradford are listed as signatories to the petition, only Ms. Doroshow has signed.
l !
i
-C-proceeding to grant a license amendment to change the plugging criteria."
Id.
d at 13-14 In further support of its petition to intervene, TMIA states that it has been an intervenor in the TMI-1 steam generator proceed,ing concerning the kinetic expansion repair process. M.at2.
Because the Exhibit was submittted originally to urge the Commission to grant a hearing on the proposed revision to plugging criteria despite Licensee's claim that no hearing was required, paragraphs 8-15 are devoted to a discus.:f on of why a _ revision to the plugging criterie requires a license amendment and why a prior hearing is necessary. See i_d. at 4-7. The balance of the Exhibit contains various statements to support the conclusion that a hearing is needed because the amendment raises " major safety questions." M.at8-13. Included are concerns about normal operation leakage criteria (1 22), the identification of the cause and rate of tube degradation and whether the degradation has ceased
(?! 16-25), the ability of eddy current testing to accurately detect tube defects (55 26-98, 30-32), and the need for pre-startup eddy current testing (1 29).
C. Requirements for Intervention To intervene and be made a party to the license amendment proceeding, a petitioner must demonstrate that it has the requisite interest, identify aspects within the scope of the proceeding as to l which it wishes to intervene, and ultimately submit at least one contention suitable for litigation. 10 C.F.R. f 2.714.
i
- 1. Interest and Standing (a) Statutory and Regulatory Requirements Section 189a of the Atomic Energy Act, 42 U.S.C. 5 2239(a), provides tFat:
In any proceeding under [the.1 Act, for the granting, suspending, revoking, or amending of any license or construc-tion permit ... the Consnission shall grant a hearing upon the request of any person whose interest may be affected by the proceeding, and shall admit any such person as a party to such proceeding.
Section 2.714(a) of the Commission's Rules of Practice also provides that
"[a]ny person whose interest may be affected by a proceeding and who desires to participate as a party shall file a written petition for leave tn intervene." Thus the pertinent inquiry under Section 189a of the Act and 10 C.F.R. 6 2.714(a) of the regulations is whether TMIA has alleged an interest which may be affected by the operating license amendment proceeding. The Commission has held that contemporaneous judicial concepts of standing are controlling in the determination of whether the t
requisite interest prescribed by both Section 189a of the Atomic Energy Act and Section 2.714 of the NRC's Rules of Practice is present.
Portland General Electric Co. (Pebble Springs Nuclear Plant, Units 1 and 2), CLI-76-27, 4 NRC 610, 613-14 (1976). There must be a showing that l
(1) the action being challenged could cause " injury-in-fact" to the person seeking to intervene and (2) such injury is arguably within the l
" zone of interests" protected by the Atomic Energy Act or the National Environmental Policy Act. 8/ Ld . See Warth v. Seldin, 422 U.S. 490 l (1975); Sierra Club v. Morton, 405 U.S. 727 (1972). Thus a petitioner t
8f 42 U.S.C. I 4321 et seg.
i i
F
~
Q ,
3 i,
, s ,
N
-8_ - ,
must " set forth with particularity" its interest in the proceeding
\
and how that interest may be affected by the outcome of the proceeding. ,
10 C.F.R. 6'2.714(a)(?).
(b) Rules of General Applicability to Organizations and Individuals An organization.may establish standing based upon ar$ injury to.
itsdf or through members of the organization who have interests which may be affected by the outcome of the proceeding. Edlow International Co., CLI-76-6, 3 NRC 563, 572-7A (1976); Public Service Co. of Indiarfa, Inc.-(Marble Hill Nuclear Generating Station, Units I and 2), ALAB-322; 3 NRC 328, 330 (1976). E When an organization claims standing based 'on the interests of its members, at least one of its members must have standing in his or her own right, the organization must identify (by name and address) specific individual members whose interests may be affected, and the organization must demonstrate that such members have authorized the organization to represent their interests in the proceeding. Houston Lighting & Power Co. (Allens Creek Nuclear Generating Station, Unit 1),
ALAB-535,9NRC377,393-97(1979); Public Service Electric & Gas Co.
(Salem Fuclear Generating Station, Units 1 and 2), ALAP-136, 6 AEC 487,
.488-89 (1973). Absent express authorization, groups may not represent other than their own memb rs, end individuals may not assert the interest -
of other persons. See Dt.troit Edison Co. (Enrico Fermi, Atomic Pover Plant, Unit No. 2), ALAB-470, 7 NRC 473, 474-75 n.1 (1978); Tennesree s
9/
~
A petitioner must particularize a specific injury that it or its members would or might sustain should it be denied relief. The -
test is whether a " cognizable interest of the petitioner might be adversely affected if the proceeding has one outcome or another."
Marble Hill, CLI-80-10, 11 NRC 436, 439 (1980).
\
i
, Valley Authority (Watts Bar Nuclear Plant, Units I and 2), ALAB-413, 5 NRC 1418, 14?! (1977).
Generally, the close proximity of a petitioner's residence is presumed sufficient to satisfy the interest requirements of 10 C.F.R.
$ 2.714. Armed Forces Radiobiology Research Institute (Cobalt-60 Storage Facility), ALAB-682,16 NRC 150,153 (1982) (hereafter "AFRPI"); Allens Craek, 9 NRC at 393, citing, Virginia Electric & Power Co. (North Anna Nuclear Power Station, Units 1 and 2), ALAB-522, 9 NRC 54, 56 (1979). El Nevertheless, since there is no presumption that every individual who lives near the plant will consider himself potentially harmed by the outccme of a proceeding, it is important that the nature of the invasion of an individual's personal interest be identified. Allens Creek, 9 NRC at 383. Accordingly, it has been found that persons who live near the site have standing to intervene if they allege a potential for injury from operation of the facility. Northern Indiana Public Service Co.
(Bailly Generating Station, Nuclear-1), LPP-80-22, 12 NRC 191, 195-96 (1980), affirmed, ALAB-619,12 NRC 558, 564-65 (1980).
(c) Interest and Standing of Petitioner in This Proceeding TVI-1 is located about 10 miles southeast of Harrisburg, Pennsylvania.
NUREG-0680, TMI-I Pestart, at A-1. As noted above, TMIA a:serts that 10/ In the past, residential distances of up to 50 miles have been found to be not so great as to necessarily preclude a finding of standing in licensing proceedings. See e.g., Tennessee Valley Authority (Watts Bar Nuclear Plant, Units I and 2), ALAB-413, 5 NPC 1418, 1421 at n.4 (1977); Portland General Electric Co. (Trojan Nuclear Plant),
ALAB-496, 8 NRC 308 (1978) (40 miles); North Anna, ALAP-146, 6 AEC 631, 633-34 (1973) (residency within 30-40 miles sufficient to show interest in raising safety questions).
-.10 -
i (1) it is a public interest organization whose members live in a five county radius of the facility, (2) it represents persons that may be l adversely affected by the proposed amendment and (3) it has been admitted as an intErvenor in another TMI-1 steam generator amendment proceeding.
Exhibit at 1-?,13-14 However, TMIA has failed to identify these members, apart from Ms. Doroshow and Ms. Bradford, to demonstrate specifically the geographical proximity of its members to TMI-1 and to demonstrate its authority to act on the behalf of specific members who may possess stand-
.ing in this proceeding. E See Allens Creek, ALAB-535, supra. Without an explicit identification of its members who possess standing on the basis of their geographical proximity to TMI-1 and without a specific indication that TMIA is authorized to represent those members in this
. proceeding, TMIA fails to satisfy the requirements for intervention in L any adjudicatory proceeding concerning the present amendment request.
While proximity to a large source of radiation can establish a l petitioner's interest, AFPRI, supra at 153, TMIA must sufficiently ident-k' ify'(by name and address) at leas +. one member who resides near the plant,
! has standing and has authorized TMIA to represent its interest. General l
assertions that a petitioner's members live near a facility are not
-11/ While TMIA asserts that Ms. Doroshow and Ms. Bradford are members of TMIA and represent TMIA's effort to obtain a hearing, TMIA does not state where these members reside nor does the petition contain Ms. Bradford's signature as evidence that she authorized the filing of this petition. Based on information external to the petition, the Staff concedes that Ms. Bradford once resided in Harrisburg and may do so nov. Thus, the defective claim of derivative standing could be cort 9:ted if Ms. Bradford still resides in the vicinity of the plant and there is an affirmative showing that she authorizes TMIA to intervene on her behalf.
sufficiently particularized to support a finding of. standing. See Public Service Co. of Oklahorra (Black Fox Station, Units 1 and 2),
ALAB-397, 5 NRC 1143, 1150 (1977); Mississippi Power & Light Co. (Grand Gulf Nuclear Station, Units 1 and ?), ALAB-130, 6 AEC 423, 425 (1973).
The fact that TMIA has been admitted in other proceedings concern-ing TMI-I does not relieve TMIA of its obligation to demonstrate that the requirements of intervention are met for this proceeding. While such prior intervention suggests that TMIA may ultimately be able to demon-strate that it has standing here, a separate showing for this proceeding must be made. EI In addition, TMIA's assertion that it represents
" persons" whose interests may be affected by the amendment must be rejected absent express authorization from such persons. See Fermi, AL AB-470, supra at 474-75 n.1; Watts Bar, ALAB-413, supra at 1421.
The only two members identified in the petition are Joanne Doroshow and Louise Bradford, the listed signers of the Exhibit. There is no explicit indication that either resides within the geographical proximity of the plant nor is there an explicit indication that Ms. Bradford has authorized the filing of the petition since it does not contain her
-H/ It has been held that a petitioner's participation in a prior pro-ceeding with regard to a facility is not sufficient to establish that petitioner's interest with regard to a separate proceeding for that same facility. Philadel Power Station, Units 2 and 3)phia Electric
, LBP-75-22, Co. 451, 1 NRC (Peach Bottom 454-55 Atomic (1975);
Wisconsin Electric Power Co. (Point Beach Nuclear Plant, Unit 1),
LBP-73-26, 6 AEC 612, 616 (1973).
12 -
signature. Consequently, at present TMIA has not adequately demonstrated standing through the interest of at least one member. b
- 2. Specific Aspects of the Subject Matter of an Operating License Amendment Proceeding (a) Regulatory Requirements In addition to satisfying the standing and interest requirements of 10 C.F.R. G 2.714, a petitioner must "also set forth with particularity ...
the specific espect or aspects of the subject matter of the proceeding as to which the petitioner wishes to intervene." 10 C.F.R. ? ?.714(a)(2). b (b) Aspects of Petitioner in this Proceeding By virtue of the resubmittal of its prior demand for hearing, TMTA presently relies heavily on arguments which do not pertain to the
-13/ TMIA's current failure to adequately demonstrate that at least one member who lives near the plant authorized the filing of the petition does not defeat the grant of intervenor status to TMIA. -
Under 10 C.F.R. Q 2.714(a)(3), a petition for leave to intervene may be amended, without prior approval of the presiding officer, at any time up to fifteen days orior to a special prehearing conference held pursuant to 10 C.F. $ 2.715a or, if no speciti prehearing conference is held, fifteen days before the first prehearing confer-
,, ence. The Appeal Board has stated that petitions that suffer from inarticulate draftsmanship or procedural or pleading defects may be amended if they contain curable defects. North Anna, ALAB-146, 6 AEC 631, 633-34 (1973). See also Wisconsin Public Service Corp.
(Kewaunee Nuclear Plant), LEF78 R, 8 NRC 78, 82 (1978). Since Section 2.714(a)(3) does not limit the reasons for amendment, and assuming the defect is curable, the petition could be amended to include a member affidavit which would satisfy the standing requirement or provide evidence that Ms. Bradford still resides in Harrisburg and authorizes the filing of the petition. See e.g.,
Fermi, LBP-79-1, 9 NRC 73, 77 (1979).
-14/ An " aspect" is generally considered to be broader than a
" contention," but narrower than a general reference to the NPC's operating statutes. Consumers Power Co. (Midland Plants, Units 1 and 2), LBP-78-27, 8 NRC 275, 278 (1978).
1 I
i l
l
4 requested amendment and which have been made moot by intervening events.
The petition does not contain an explicit listing of specific aspects of the subject matter of the proceeding, but contains lengthy arguments as to why the amendment involves " major safety questions" which require a prior hearing. Since Licensee has requested an amendment to its technical specifications to allow the use of revised plugging criteria and the Staff has noticed an opportunity for prior hearing, TMIA's arguments regarding the need for a prior hearing are of little significance. See Exhibit at !! 8-15.
A perusal of the petition does not readily disclose what aspects TMIA seeks to raise regarding this amendment. However, as far as the Staff can discern, included among TMIA's arguments that the proposal to revise plugging criteria raises major safety questions which require a prior hearing are four assertions: 1) normal operation leakage criteria will be impacted by the amendment (122), 2) the proper identification of the cause of tube degradation and whether such degradation has been arrested affects the eppropriateness of the revised criteria (?! 16-25),
(3) eddy current testing does not support the amendment because it does not accurately detect tube defects (55 26-28, 30-32), and (4) eddy current testing is needed prior to the restart of TMI-1 (i 29). l All but the fourth concern El raise matters arguably within the subject matter of this proceeding. The rate of tube leakage, the accuracy of eddy current testing in the measurement of tube defects and l
_1_5/
5 Any question as to the need for eddy current testing prior to restart of the plant is now moot since the plant has already commenced operation.
a O'
., l the cause and rate of tube degradation may be relevant to the appro-priateness of the revised plugging criteria.16_/ Consequently, TMIA has 1 identified at least one aspect within the scope of the amendment pro-ceeding which is sufficient to put the parties on notice with respect to contentions it may draft. Consequently, the Staff is of the view that TMIA has satisfied the aspect requirement of 10 C.F.R. Q 2.714.
III. CONCLUSION TMIA's petition to intervene adequately identities aspects within the scope of the proceeding as to which TMIA wishes to intervene but does not properly establish TMIA's interest and standing as required by 10 C.F.R. 6 2.714. Absent a proper amendment of the petition to establish interest and standing, the instant petition is defective.
Respectfully submitted, Mi 2A un Counsel for NRC Staff Dated at Bethesda, Marylard this 13th day of January,1986.
-16/ Licensee argues that the adequacy of eddy current testing and the identification and arrest of the 1981 tube degradation were decided by the Appeal Board when it denied TMIA's appeal of, and motion to reopen, the kinetic expansion proceeding. Licensee's Answer to Request for Hearing by Three Mile Island Alert, Inc., January 7, 1986, at 3-5. However, Licensee does not assert that litigation of these issues would be precluded in the instant proceeding.
o
f 9 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
METROPOLITAN EDIS0N COMPANY, ET AL. Docket No. 50-289
) (Steam Generator Plugging (Three Mile Islan'd Nuclear Station,) Criteria)
Unit No. 1) )
CEPTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO TMIA'S DEMAND FOR ADJUDICATORY HEARING" and NOTICES OF APPEARANCE OF MITZI A. YOUNG AND MARY E. WAGNER in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as
- indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mail system, this 13th day of January,1986:
- Sheldon J. Wolfe, Chairman Bruce W. Churchill, Esq.
Administrative Judge Shaw, Pittman, Potts & Trowbridge Atomic Safety & Licensing Board Panel 1800 M Street, NW U.S. Nuclear Regulatory Commission Washington, DC 20036 Washington, DC 20555
- Dr. Oscar H. Paris
- Atomic Safety & Licensing Board Administrative Judge Panel Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555
- Frederick J. Shon
- Atomic Safety & Licensing Appeal Administrative Judge Board Panel Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Joanne Doroshow
- Docketing & Service Section The Christic Institute
~
Office of the Secretary 1324 North Capitol Street U.S. Nuclear Regulatory Commission Washington, DC 20002 Washington, DC 20555 Louise Bradford 1011 Green Street Harrisburg, PA 17102 c'd 7&r Mitzk A". Young ' #
Counsel for NRC Staff 1
i
ECU;;r 19 g , ../
UNITFD STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ~86 nc-dW IS pl *10 BEFORETHEATOMICSAFETYANDLICENSINGBOARDkp.g c e.
Y$he Nk, In the Matter of )
)
METROPOLITAN EDISON COMPANY, ET AL.) Docket No. 50-289
) (Steam Generator Plugging
) Criteria)
~
(ThreeMileIslandNuclearStation,)
Unit No. 1) )
NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance in the above-captioned matter. In accordance with 10 C.F.R. 9 2.713(b), the following information is provided:
Name - Mitzi A. Young Address - U.S. Nuclear Regulatory Commission Office of the Executive Legal Director Washington, DC 20555 Telephone Number - (301) 492-7837 Admission - U.S. Court of Appeals, D.C. Circuit U.S. District Court, District of Columbia District of Columbia Court of Appeals Name of Party - NRC Staff Respectfully submitted, o
Counsel for NRC Staff Dated at Bethesda, Maryland this 13th day of January,1986.
aa %:
'86 JAN 15 P1 :11 GFFic: 0; n cy ,.
00CMETING'i SEY$"r UNITED STATES OF AMERICA BRANCH NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
) Docket No. 50-289 METROPOLITAN EDISON COMPANY, ET AL. (Steam Generator Plugging Criteria)
(Three Mile Island Nuclear Station )
Unit No. 1) )
NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance on behalf of the NRC Staff in the captioned matter. In accordance with 10 C.F.R. 62.713(b) the following information is provided:
Name -
Mary E. Wagner Address -
U.S. Nuclear Regulatory Commission Office of the Executive Legal Director Washington, DC 20555 Telephone Number -
Area Code (301) 492-8659 Admission - Court of Appeals, State of New York District of Columbia Court of Appeals Name of Party -
NRC Fiaff U.S. Nuclear Regulatory Commission Washington, DC 20555 s j Mary E M '
Counse Wagner for NRC l Staff Dated at Bethesda, Maryland this 13th day of January 1986
, _.