ML20140C608
| ML20140C608 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 01/23/1986 |
| From: | Doroshow J THREE MILE ISLAND ALERT |
| To: | |
| References | |
| CON-#186-841 CLI-85-19, RA-EW, NUDOCS 8601280371 | |
| Download: ML20140C608 (18) | |
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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DOCg YO on '
Before the Commission -
diIN 24 y _,
In"the Matter of ) ,
i
) r.
Docket No..50 O89 f A g /{/
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GPU NUCLEAR )
)- -
(Three Mile Island Nuclear )
Station, Unit No. 1) )
TMIA'S RESPONSE TO 9
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As former members of GPU's top management, Robert C. Arnold and Edward Wallace were personally responsible for serious acts of pre-accident and post-accident wrongdoing, including the willful, knowing, and with reckless disregard for the truth, submission of a material f alse statement to the NRC. A Commission decision to allow the return of either one of these individuals to positions I
within the TMI corporate organization would constitute an egregious abuse of agency authority, particularly in view of the f act that l the Commission, the Staff, and the court in TMIA v. NRC relied l heavily on their removal to support a f avorable restart decision. l There appears to be no limit to the Commission majority's callous attitude toward the residents in this area. Between the l l
accident, the subsequent illegal release of radioactive gases from '
Unit 2, the restart struggle, and the restart itself, this ,
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community has and continues to suf fer deeply, largely due to I actions by this Commission. The return of these two people, i.
particularly Arnold who epitomizes all that ever was corrupt and
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incompetent at GPU, would add serious mental anguish to residents here, and would further jeopardize the health and safety of this 8601280371 860123
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community. It simply can not be tolerated.
The following summarizes the evidence regarding past improper and illegal conduct by Wallace and Arnold. Since the Commission is wrong in its analysis of issues other than the false NOV response, and since it is the Commission's responsibility to make a reasoned decision on this matter, TMIA has supplied a critical analysis of additional evidence reflecting poorly on Arnold's lack of personal competence and integrity.
A. False Response to the 1979 Notice of Violation and the Keaten Report -
Arnold established a task force headed by R. W. Keaten, to undertake an investigation into the accident. Arnold selected the task force members, including Wallace. NUREG 0680, Supp. No. 5 at
- 2. Keaten recalled that Wallace was "very active" Lin Keaten's task f orce meetings which were developing licensee's internal report in response to the accident. GPUN/ Alleged Improper Influence By the GPU. Upper Management Structure Causing Changes To Be Made To Their Internal TMI-2 Accident Review Report To Reflect A More Favorable Management Viewpcint, OI-1-83-012 ("Keaten Investigation"), Exh. 4 at 24 7.
Eight versions of the task force report were prepared between Sehtember 28, 1979 and December 15, 1980. NUREG 0680, Supp. No. 5 at 8-3. Arnold and GPU President Dieckamp reviewed and provided substantive comments on the task force draf ts. Id at 8-13.
Arnold was also responsible for preparing the company's _
response to the NRC's October 25, 1979 Notice of Violation ("NOV")
for regulatory violations which led to the accident. Keaten Investigation, Exh. 4 at 37. Arnold chose Wallace to "puil together" the NOV response. Id. at 247. Wallace prepared it, Arnold signed, and Dieckamp reviewed it before it was issued to the NRC. NUREG 0 680, Supp, No. 5 at 13-5.
The Keaten Report drafts contain material which demonstrates the falsity of this NOV response.
In the NOV response, Arnold, on the company's behalf, denied the regulatory violation which resulted in the largest portion of the civil penalty imposed by the NRC against the licensee. This
" citation was for operating the plant for months with high discharge line temperature readings above the pressurizer. Since high
, temperatures are a symptom of PORV leakage, licensee's Emergency .
Procedure 2202.1-5 required that upon obtaining such temperature readings, the PORV " block valve" be closed to test for leakage l which could lead to damage.
l The company f ailed to comply with these procedures. As a result, within the first few minutes of the accident, when tempera-tures started reading high, the operators, having been "desensi-l tized" by high readings under normal operating conditions, did not l
recognize high temperature readings to signal that the PORV had stuck open. 'NOV at 2. For example, shift supervisor William Zewe testified that he was influenced in his diagnosis of elevated tailpipe temperatures by the history of high temperatures. Keaten Investigation Exhs. 3 2 at 3; 2 7 at 7; NUREG 0680, Supp. No. 5 at' 8-l l 16.
l A number of changes in the Keaten draf ts relate to leakage from the pressurizer and violation of emergency procedures regarding pressurizer system failure. NUREG 0680, Supp. No. 5 at 8-12. The most significant change occurred between the October 29,-
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t .
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- 1979 draft, written just after issuance of the NOV, and the November 28, 1979 draft, prepared just before issuance of the NOV r response.
The October draft contained the statement "[t]he plant had operated in violation of this requir,ement for an extended period prior to the accident," which followed "[o]ne symptom of a leak was i
an indicated tailpipe temperature above 130 degrees F." However, consistent with the NOV response, the November draf t drops any reference to a " violation" contrary to the earlier task force I conclusion, stating simply "[t]he plant had operated with higher discharge pipe temperatures for an extended period prior to the Ok accident." In the NOV reponse, Arnold denied the noncompliance, arguing that the existence of one or more " symptoms" as listed in an emergency procedure did not require automatic implementation of l the associated immediate and follow up actions.
l l In addition, the October 6, 1979 Keaten Report draft contained l
l the following comments:
l l Operators may have become " desensitized" to abnormal conditions due to previous experience, some plant design features and plant conditions which existed
! just prior to the event. Leaking pressurizer relief valves produced high discharge pipe temperatures before the event. Reactor sump pump operation had become. routine due to leakage.
Task force member Van Witbeck confirmed that the task force
( believed operators, particularly Zewe, were desensitized. Keaten l
l Investigation, Exh. 7 at 57.
l However, the NOV response stated:
l Although this procedure was understood by the plant
! staff, it is not clearly written and does not reflect actual plant conditions. It will be changed.
l However, although Metropolitan Edison is concerned about the issue, there is no indication that this 1 '
procedure or the history of PORV discharge line temperatures delayed recognition that the PORV had stuck open during the course of the accident.
NOV_ Response at 35.
In support, licensee introduced the argument that the elevated relief valve discharge line temperatures were caused by a leaking code safety valve rather that the PORV. NUREG 0680, Supp. No. 5 at 8-16. The company later argued that there was general agreement among plant personnel that the code safety valves, not the PORV, were leaking and therefore diagnostic testing was determined to be
., unnecessary.-
The evidence does not support this proposition.1/ After an
- 1. Af ter a four month shut-down af ter an April 23, 1978 transient, no maintenance was done on the PORV to determine if the PORV had suf fered damage from its having recently cycled 50 times, possibly during the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> before the event. GPU v. B&W Trial Exh. 337 at 3820. This could have had an adverse effect on PORV reliability. GPU v. B&W Deposition of Keaten at 174. When the plant returned to operation af ter the four month shut down, PORV temperatures began reading 180 degrees -- 50 degrees higher than ~
permitted by procedures.
Maintenance manager Seiglitz's testimony that high temperature readings were never discussed at " plan of the day" (POD) meetings during this timeperiod, which Seiglitz and other management person-nel attended daily, is not credible. Seiglitz testified that he was not only unaware of the elevated temperature situation, but that he was unaware that 180 degrees was even an elevated tempera-ture. GPU v. B&W Deposition of Seiglitz at 5809-5810. The control room operators and shif t supervisors, however, knew that the PORV was reading high. See e.g. GPU v. B&W Testimony of Zewe at 2249; GPU v. B&W B&W Exh. 5007BB.
High PORV readings continued after a January 17 through January 31, 1979 shut down, during which time no work was done to determine if any of the three valves above the pressurizer were leaking. GPU v. B&W Testimony of Zewe at 2250-2253. When the plant reopened, PORV temperatures jumped to 200 degrees f rom a previous 110 to 120 degrees. Seiglitz, supra at 5824.
Seiglitz testified at the trial that at the February 1, 1979 POD meeting, when the identified leak rate was determined to be up, (Foqtnote continued on next page)
extensive investigation, including numerous interviews and an in-depth technical review, OI found that these views "do not appear to be supported by the weight of the f acts nor do they appear to be technically valid," and were " contradictory to other important information that was in the possession of Met Ed at the time the response was signed." Keaten Investigation, Vol. 1 at 46, 60. t Similarly, the Staff has determined that licensee willfully violated the subject emergency procedures, and that the statements contained in the NOV response were "neither accurate nor complete -
and contrary to the information in the possessir n of the licensee."
NUREG 0 68 0, Supp. No. 5 at 8-19.
Adhitionally, OI found that
. . . Met Ed's implication in their response that the procedure was not followed because of a preaccident determination by ' plant staf f' that the PORV was not leaking, was contrary to the preponderance of evidence in the nossession of the corporate officer (Footnote continued from previous page) those attending the POD meeting decided the cause to be leaking code safeties. He was unable to recall why suddenly af ter a two week shut down, perf ectly go6d code safeties would begin leaking with high temperatures, or whether there was any discussion of what may have gone wrong during the two month shut down to have caused this to happen. Seiglitz, supra at 5822, 5823, 5824.
OI's investigation discr that company personnel believ; ededits Seiglitz's the PORV unsupported was not assertion leaking, which represented the company's podition during the GPU v. B&W trial.
According to Harold Hartman, the operators suspected leakage f rom the PORV. GPU v. B&W Deposition of Hartman at 85, 120.
Former TMI-2 Superintendent Logan stated that he could not tell which of the three valves were leaking. Keaten Investigation at
- 56. Station Superintendent Miller testified that he believed the PORV was leaking. GPU v. B&W Deposition of Gary Miller at 5853.
CRO Frederick testified that some supervisors and engineers thought a code safety was leaking, and some believed it was the PORV.
GPU v. B&W Deposition of Ed Frederick at 3539.
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! having responsibility for the response, [ Arnold], and
- l the corporate individual who draf ted the response,
[Wallace]. In- summation, it appears that Met Ed's
- response in addressing this statement of noncompliance (4.A) was drafted to support a company position with little or no attempt to resolve 'or l address' conflicting information.
! Keaten Investigation at 3 (emphasis added).
j The evidence is overwhelming that in submitting the materially l false NOV reponse, Arnold and Wallace acted knowingly, willfully, and with reckless disregard for the truth.
In addition, the Keaten task force was influenced into changing their conclusion that the plant had operated in violation of this requirement for an extended period of time prior to the accident, and as OI concluded, the evidence supports that the responsibility for this change lies with Wallace who draf ted the response and was intimately involved in task force activities, and Arnold under whose supervision both the response to the NOV was prepared and the task force report was finalized. Id. at 2.
. No new information has come to light to challenge the basis for these NRC findings and conclusions. The company's argument, formulated in the context of its defense during the GPU v. B&W trial, was discredited both by evidence generated during the trial, and later by NRC investigations.
B. Harassment Of TMI-2 Engineers In 1983, NRC investigators found that GPUN, under Arnold's supervision, had engaged in deliberate circumvention of safety procedures during th.e Unit 2 clean-up, and had abdicated its responsibility to exercise oversight over, and condoned wrongdoing l
j by its contractor, Bechtel North American Corporation which had i
committed numerous violations of clean up safety procedures. Three 1
Mile Island NGS, Unit 2 Allegations Regarding Safety Related Modifications and QA Procedures (H-83-002) (Sept. 1983), cover
. memo, Attachment D. ,$'
On May 18, 1984, OI released a Report of Investigation entitled "Three Mile Island NGS, Unit 2, Allegations Regarding Discrimination for Raising Related Safety Concerns (H-83-002),
(" Harassment Report"), which evaluated reprisal charges by TMI-2 engineers Rick Parks, Larry King and Ed Gischel for reporting these violations. -
The employment of Parks and King was terminated in March, 1983, at the height of a clean up controversy surrounding the safety implications of using the previously damaged polar crane for clean up operations. Both filed Department of Labor. complaints.
DOL found that Parks was illegally fired for reporting safety violations, and ordered him rehired. Harassment Report, Exh. 102.
Larry King lost, largely by default, before a DOL investigator, but the company settled his case upon King's appeal. King v. GPUN, Civ. No. 8 4-913 ( M.D. Pa. filed July 9,19 8 4 ). Gischel, who submitted an affidavit to the NRC on April 2, 1983 alleging harassment and discrimination for raising safety concerns and who was transferred af ter continued harassment but not fired, ~ did'not file a DOL complaint. ,
Bob Arnold was directly involved in the harassment of each of these individuals.
- 1. Harassment of Rick Parks As a result of his raising safety concerns about the polar crane, Parks was requested to attend a meeting on February 22, 1
1983, with then Unit 2 director B. Kanga. NUREG 0 68 0, Supp. No. 5 at 2. King accompanied him to the meeting, during which Parks
- raised safety concerns which he had previously raised with
- . management. The next day, Parks was informed by Manager of Recovery Programs Theising that he had been relieved of his duties as Alternate Startup and Test Supervisor at TMI-2. Ibid. Both the i
DOL and the NRC Staf f have concluded that this removal was an illegal act of harassment. I_d_. at 10-17.
The evening of March 9, King called Parks at home.
Affidavit of Rick Parks -at 44. King explained that recent conversations with
! then GPUN President Arnold indicated that Arnold was attempting to i '
implicate Parks on conflict of interest charges related to an outside business interest in order to fire him. Ibid.
5 On March 10, Parks went to the NRC to discuss the Arnold-King conversation, telling the NRC that this was another management act to intimidate or remove from TMI anyone who tried to stop them f rom p l
violating govarnment and industry standards. I_ d . at 45. NRC I
personnel-told Parks that the NRC ,would not get involved because i this was an employer-employee labor matter. Ibid. Later that day,
! Operations Manager Chwastyk told Parks that management knew he had I gone to the NRC and would get him. He recommended Parks see a
_I_d_. a t 4 7.
i lawyer.
i On March 17, Parks met with Kanga, who warned Parks not to go j public with his concerns. d a t 51.
I_d. Kanga told Parks that he i
"had to send a report to' Bob Arnold describing how the issue ...
I had been handled," and that Parks had "put Bechtel in a bad light
! with a client" and thus " stood a good chance of getting fired." -
Ibid. These threats constituted illegal acts of harassment and
intimidation. NUREG 0680, Supp. No. 5 at 10-5, 10-18. Parks was then replaced as the primary Sight Operations Department representative on the TWG for the Reactor Building Polar Crane Project. NUREG 0 68 0, Supp. No. 5 at 10-2. This act was also illegal. M. a t 10-5.
On March 22, Parks filed a DOL complaint, publicly announcing this step on March 23. See Harassment Report, Exh. 103. After the complaint was filed, Arnold called a meeting at which it was decided to suspend Parks with pay. NUREG 0680, Supp. No. 5 at 10- .
- 5. On March 24, Parks was illegally placed on leave of absence with pay. Ibid.
The NRC Staff found that the activities of GPUN, in which Arnold was directly involved as President, constituted harassment for which GPUN was directly responsible. Id. at 10-19.
- 2. Harassment of Larry King ~
Larry King was hired by GPU as Plant Operations Director for Unit 1. King and his staff, including Parks, represented a threat to Arnold and GPU management plans to meet unrealistic deadlines for use of the polar crane for the head lif t program at Unit 2. In order to rid themselves of that threat, GPU and Arnold embarked upon a campaign to remove King f rom the clean up project, and seized upon King's interest in a consulting firm as, a means of accomplishing that goal.
l King's employment we erminated by Arnold on March 23 on the grounds that King was engaged in activities with a consulting firm which amounted to a conflict of interest. Harassment Report, cover memo. King's suspension and termination came af ter King raised i
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safety concerns regarding the TMI-2 recovery program, and as a result of inquiries made by the individual in charge of the program that was the subject of King's safety concerns. Ibid According to Parks, the timing of King's suspension was parti-cularly significant in that " Larry King had not made any secret that two weeks before he had requested a meeting with a Mr. Clark, Vice President of GPUN, to discuss with Clark his safety concerns about the way work was being conducted on the Island." Parks Af qp-davit at 29. Clark was to meet King on site on February 25. ,
Despite the fact that King was suspended the prior day, King-and Clark did meet on February 25 af ter Clark and Arnold decided to i
reinstate King's pay. Arnold claims that King's pay was reinstated in order to encourage King to divulge his safety concerns so the
- l. company could deal with them. However, King had been very vocal l
l about his safety concerns for several months and the company had i
ignored them. Arnold's belated concern is hardly genuine-King never returned to work, at TMI, being officially l terminated on March 23. At the time of King's suspension and termination by Arnold, there was insufficient evidence to justify l
l such actions. Id. , cover memo, 74. OI further faulted Arnold in concluding that his suspension of King became immediately effective ,
l even though King could have been conf ronted on this matter in a scheduled meeting the next day with then GPUN Executive Vice President Phil Clark. Ibid.
Arnold says he did not reflect, in any prolonged way, whether the suspension of King without pay would be misunderstood by the I
organization as it related to management retaliation of King for raising safety concerns. Harassment Report at 74.
11 -
While the Staf f conceded that the " timing" of King's 1
suspension and termination was " poor," it was not improper. NUREG I 0680, Supp. No. 5 at 10-20. Yet these findings are totally -
contradictory to those regarding Parks. King became involved in the polar crane controversy to support Parks, against whom management retaliated.
It hardly makes sense that GPU management, including Arnold, would act harshly against Parks for his polar crane dissent, while
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simultaneously ignoring the outspoken support of his boss and most powerful benefactor, King.
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- 3. Harassment of Ed .6 s :hel Ed Gischel suffered a sttoxe in July, 1982 and returned to work on a part time basis in Octooer, 1982. Harassment Report, Synopsis at 2. Upon being examined by the company doctor in November, 1982, his unrestricted access status was approved with the doctor noting that Gischel was making a good recovery from the stroke. Harassment Report at 29. There was no indication at that time that Gischel's disabilities af fected his work performance.
Ibid. His evaluation was signed by King and reviewed by J. Barton without comment. Id. a t 3 0. See also, id. a t 41.
During the next few months, particularly the spring of 1983, Gischel was intimately involved in raising sat.et*/ concerns relative l
to the refurbishment of the polar crane. NUs1C i580, Supp. No. 5 at 10-11. During that same time period, Arnola, along with GPU Board Chairman Kuhns, required Gischel to take a nesuropsychological l
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examination which did not become a requirement until after Gischel had raised these safety concerns. Harassment Report, cover memo.
Within two weeks of Gischel's filing of an affidavit with the NRC alleging discrimination against him for raising safety concerns, Arnold notified Gischel that the exam was a condition for continuation of Gischel's present assignment. Id. at 35, Exh. 23.
OI f aulted Arnold in pursuing this empl'oyment requirement "despite the f act that Mr. Gischel's supervisors did not consider that his physical impairments seriously affected his work performance . . and was in conflict with the medical opinion furnished by both Mr. Gischel's personal physician and a GPUN contract physician . . that he was fit to perform his assigned duties at TMI-2." Ibid.
. In addition, during an April 22 telephone conversation, Arnold told Gischel that if he testified before upcoming Congressional subcommittee hearings, "the differences between Mr. Gischel and Mr.
Arnold would become irreconcilable." Harassment Report at 37.
Gischel considered this an unmistakable threat to fire him. Ibid.
He was eventually transferred after continued harassment.
- In conclusion, Arnold was directly involved in the harassment of employees who refused to remain silent. Arnold's actions were widely known at TMI. By these actions, Arnold contributed to an atmosphere of fear and intimidatipn making individual disclosures of safety violations impossible. He clearly is unfit to return to TMI. .
C. Response to Post-Accident Cheating of James Floyd Bob Arnold was responsible for the company's failure to discipline James Floyd for post-accident cheating.
discipline James Floyd for post-accident cheating..
Arnold expressly rejected the disciplinary recommendations of Station Superintendent Gary Miller and Met Ed Vice-President John Herbein who were responsible for investigating Floyd's cheating.
At Arnold's insistence, Floyd was assigned, instead, to a special group charged with obtaining a better understanding of the accident, assuming responsibility for " technical interface" with Bechtel and the Department of Energy's Research and Development program an TMI-2. See, TMIA Exh. 54, Testimony in Restart Hearings
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( Arnold), Tr. at 23,620-621; 23,738; 23,773.
Arnold claimed at the restart hearings that this was a demotion and would be viewed as such by Floyd and the organization as a whole. Arnold Testimony, supra. However, there is not evidence to support this.
At the time these decisions were made, Floyd,was not told that he had been reassigned for disciplinary reasons. Id. at 23,775-6. No documentation exists to support the company's assertion that the reassignment was disciplinary, . or that it was connected with Floyd's training performance which had been historically poor. See TMIA Exhibits in Restart Proceeding,
("TMI A Exh.") Nos. 5 3, 5 4, 62, 66, 71, 72. In f act, the only written record of Floyd's reassignment characterizes it as temporary and as motivated by the valuable contribution which he could make to the Accident Investigation Group. TMIA Exh. 54.
See also, Metropolitan Edison Co., (Three Mile Island Nuclear Station, Unit No.1) 15 NRC 918,1012-1013 (198 2).
Arnold's belated characterization of this reassignment as a
" demotion" was considered " incredible" by the Special Master.
I 15 NRC at 1013.
In a'ddition, Arnold continually f ailed to acknowledge that i Floyd cheated. See, e.g., Deposition of Arnold by B&W, GPU v. B&W, Tr. at 461 ("Floyd did not cheat"). In addition, his credibility ,
was attacked by Judge Owens during the GPU v. B&W trial, ,
l particularly with regard to his refusal to admit under oath that he was aware of Floyd's past pattern of training problems. GPU v.
B&W, Trial Tr. at 1732.
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Floyd's cheating was covered up by company officials, including Arnold, for two years. NUREG 0680, Supp. No. 5 at 7-11. -
'The Staf f considered the cover up of Floyd's cheating and the subsequent false certification to the NRC to " demonstrate disregard of management responsibilities." Id at 7-11, 13-4.
Arnold's performance in connection with the company's response to Floyd's cheating, including false statements under oath, l constitute reason enough for his permanent bar f rom TMI activities.
D. Leak Rate Palsification.
The Commission has never examined the role of Bob Arnold in l leak rate falsification at Units 1 or 2. Contrary to the Commission's stated interpretation of the plea bargain struck l between the. company and the Justice Department, the U.S. Attorney did not clear top GPU management, including Arnold. By holding the corporation liable for the criminal falsification of safety tests, the U.S. Attorney necessarily implicated, top managem'ent. The U.S.
Attorney stated as much to the court. Transcript of Proceedings, Change of Plea and Sentencing, U.S. v. Met Ed, (Feb. 28, 29, 1984) at 6 8-6 9.
The Justice Department was prepared to prove that Arnold's ;
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close associate and immediate subordinate, John Herbein, likely knew of leak rate falsification months before the accident.
Statement of Fact Submitted by the U.S. Attorney.at 13. Because of his close association with Herbein, it is likely Arnold understood and condoned the company's leak rate practices.
Even if he lacked direct knowledge, his f ailure to ensure company compliance with the law in operation of its nuclear reactor is reason enough for precluding his further involvement with TMI.
The suggestion that the mere absence of a knowing and purposeful violation by upper managers such as Arnold can be used as a benchmark for assessing their qualifications for continued employment must be rejected. The falsification was Arnold's responsibility, among others, and he should be disqualified f rom associating with TMI again.
e 4
E. Conclusion ,
Bob Arnold was directly .j.7 plicated in and/or responsible for all sorts of wrongdoing at TMI. As acknowledged by GPU Chairman
' Kuhns, "a'll roads led to Bob Arnold." Keaten Investigation, Exh.
14 at 85-86. Further, both Wallace and Arnold willingly, knowingly, and at least with reckless disregard for the truth, submitted a material f alse statement to the NRC in connection with the company's 1979 NOV response. Neither should be allowed to return to TMI.. ,
Respectfully submitted, THREE MILE ISLAND ALERT, INC.
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/ ch o By: te n/A Dated: January 23, 1986 oanne Doroshow 1
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9 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Commission In the Matter of )
)
GPU NUCLEAR ) Docket No. 50-289
)
(Three Mile Island Nuclear )
Station, Unit 1) )
CERTIFICATE OF SERVICE I hereby certify that cop was served this 23rd, day of gggIA's Response
.-~ _-2, 1986, by depositto CLI-85-19 in the U.S. mail, first class, postage prepaid, or hand-delivered where possible, to all parties on the service list below.
, f anne Doroshow SERVICE LIST Nunzio J. Palladino, Chairman U.S. Nuclear Regulatory Comunission Washington, D.C. 20555 Marjorie and Norman Aamodt 180 Bearcub Road Thomas M. Roberts, Comunissioner Lake Placid, NY 12946 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section Office ~of the Secretary James K. Asselstine, Cosumissioner U.S. Nuclear Regulatory 1 U.S. Nuclear Regulatory Comunission Comunission j Washington, D.C. 20555 Washington, D.C.. 20555 ]
Frederick Bernthal, Commaissioner .
U.S. Nuclear Regulatory Connaission Ellyn R. Weiss, Esq.
Washington, D.C. 20555 Harmon & Weiss -
2001 S Street, N.W.
Lando W. Zech, Jr. , Comunissioner Washington, D.C. 20009 U.S. Nuclear . Regulatory Connaission Washington, D.C. 20555 Thomas Y. Au Assistant Counsel Conunenwealth Jack Goldberg, Esq. of Pennsylvania Office of Executive Legal Director Dept. of Environmental Resources U.S. Nuclear Regulatory Comunission Bureau of Regulatory Counsel Washington, D.C. 20555 Room 505 Executive House
, P. O. Box 2357 Harrisburg, PA 17120 a
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