ML20197J982
| ML20197J982 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/14/1986 |
| From: | Wagner M, Matt Young NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#286-191 OLA, OLA-2, NUDOCS 8605200225 | |
| Download: ML20197J982 (26) | |
Text
CT May 14, 1986 k'{,..
i UNITED STATES OF AMERICA
'rj NUCLEAR REGULATORY COMMISSION MY15ossf DEFORE THE ATOMIC SAFETY AND LICENSING BO RD 2
Y In the Matter of
)
x
)
Docket No.
50-289 OL M GPU NUCLEAR CORPORATION,
)
)
(Steam Generator Plugging
)
Criteria)
(Three Mile Island Nuclear Station,
)
Unit No.1)
)
NRC STAFF BRIEP ON DELEGATION TO STAFF I.
INTRODUCTION At a prehearing conference held on May 7, 1986 to discuss TMIA's II April 11,1986 motion -
requesting a six month extension of time to complete discovery, the Board invited briefs on the issue of whether the Board may issue an initial decision which resolves the contested issues but which delegates to the Staff certain other matters for resolution outside the proceeding.
Tr. 216.
The NRC staff's position on this issue is set forth below.
II.
DISCUSSION A.
packground In response to TMIA's Motion the Staff filed a pleading S stating its opposition to a six-month extension of time for discovery in the OLA-1
-1/
Motion for Extension of Time or, in the Alternative, Notice of Withdraw (sic), April 11,1986 (TMIA Motion).
2_/
NRC Staff Response to TMIA's Motion for Extension of Time or, in the Alternative, Notice of Withdrawal, April 30,1980 (Staff Motion).
8605200225 860514 ~
PDR ADOCK 05000289 9
E proceeding, but not opposing a lesser extension of time, in light of the facts that (1) the Staff's SER concerning TSCR-148 would not be issued until on or. about July 31, 1986, with the Staff prepared to proceed to hearing shortly thereafter, and (2)
Licensee will be conducting confirmatory testing on some steam generator tubes in November 1986, and the Staff's evaluation of such tests will not be available before the end of January 1987. -
The Staff further stated its view that it would
'-3/
During the prehearing conference, the Board expressed concern that it had not been informed earlier that testing (to which Licensee agreed in a February 19, 1986 letter) would be performed on the steam generator tubes and that the Staff would analyze the results of such testing before acting on TSCR 148. While the timing of such tests was not mentioned earlier, the topic of testing to confirm that new corrosion is not occurring was discussed at the March 27, 1986 prehearing conference by Intervenor's counsel, Ms. Doroshow, and by NilC Staff counsel, Ms. Young.
See Doroshow, Tr. 17-18; Young, Tr. 48, 54.
During Ms. Doroshow's oral response to the Licensee's and Staff's submissions regarding Contention 1, Ms. Doroshow stated that, as to the existence of corrosion,
[T]here have been no tubes pulled from TMI-1 since the new [ eddy current} indication occurred, and since tubes were last pulled from TM I-1, the tubes have been subjected to thermal and hydraulic l
loading....
The staff has noted on the record in transcripts of meetings between the staff and GPU that there are questions which have not been resolved concerning the claim that degradation is not proceeding farther or that grain dropout has stopped or is likely to continue.
And until actual testing is done, the staff is at least, according to these transcripts, taking the position that OLA-1 is deficient, to be what they say missing a piece, a substantial piece in terms of the application for this license amendment.
(FOOTNOTE CONTINUED ON NEXT PAGE) l 1-
be able to proceed to hearing, after completion of the SER by the Staff, in advance of the receipt of the confirmatory test data, and that a Board decision could issue sometime in November 1986.
At a May 7,1986 prehearing conference convened to discuss TMIA's Motion, the parties were invited to brief the question of whether the Board could properly issue its decision in advance of the Staff's evaluation of the confirmatory test results.
Tr. 212-17.
Counsel were further requested to specifically address the case of Union of Concerned Scientists v. NRC, 735 F.
2d 1437 (D.C.
Cir. 1984), cert. denied,
sub nom., Arkansas Power & Light Co. v. Union of Concerned Scientists, U.S.
83 L.Ed. 2d 808 (January 7, 1985), as it relates to the earlier case of Commonwealth Edison Co. (Zion Station, Units 1 and 2),
Tr. 216.
B.
J'he Legal Standard Concerning Delegation The Commission has established standards for determining whether matters related to a controverted issue which arises in an adjudicatory procacding may be delegated to the Staff for resolution outside of the adjudicatory proceeding.
The leading case arose in the context of an operating license hearing:
As a general proposition, issues should be dealt with in the hearings and not left over for later (and possibly more informal) resolution.
See this (FOOTNOTE CONTINUED FROM PREVIOUS PAGE)
Tr. 17-18.
In ad dition,
Ms. Young also stated (1) that Ms. Doroshow's remarks pertained to a meeting where the Staff indicated it needed "further confirmation that tube corrosion had arrested" prior to acting on 148 (Tr. 48) and (2) that the Staff had requested additional assurance that the corrosion had arrested.
(Tr. 54)
Commission's decision in Wisconsin Electric Power Co.
(Point Beach Unit 2),
R AI-7 3-1,
- p. 6.
In some instances, however, the unresolved matter is such that Boards are nevertheless able to make the find-ings requisite to issuance of the license.
But the mechanism of post-hearing resolution must not be employed to obviate the basic findings prerequisite to an operating license--including a reasonable assurance that the facility can be operated without endangering the health and safety of the public.
In short, the " post-hearing"1 approach should be em-ployed sparingly and only in ' clear cases.
In doubtful cases, the matter should be resolved in an adversary framework prior to the issuance of licenses, reopening hearings if necessary.
Consolidated Edison Co. of New York (Indian Point Station,
Unit 2),
CL:I-74-23, 7 AEC 047, 951-52 (1974) (footnote omitted). 4-In Cleveland Electric Illuminating Co. (Perry Muclear Power Plant,
Units 1 and 2), ALAB-298, 2 NRC 730, 737 (1975), the Appeal Board ruled :
When governing statutes or regulations require a licensing board to make particular findings before granting an applicant's requests, a board may not delegate its obligations to the staff.
The responsi-bilities of the boards are independent of those of the staff under the Commission's system, and the boards' duties cannot be fulfilled by the staff, however conscientious its work may be.
(Footnote omitted).
4/
- Accord, Wisconsin Electric Power Co., et al. (Point Beach Nuclear Plan t, Unit 2), CLI-73-4, 6 AFC 6 (1973T; Long Island Lighting Company (Shoreham Nuclear Power Station, Unit 1), ALAB-788, 20 NRC 1102 (1984); Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit 1), ALAB-729, 17 NRC 814 (1983); Southern California Edison Co., et al. (San Onofre Nuclear Generating Station, Units 2 and 3), A LA B-717, 17 NRC 346, 380 n.57 (1983); Public Service Co.
of Indiana (Marble 11111 Nuclear Generating Station, Units 1 and 2),
ALAB-461, 7 NRC 313, 318 (1978); Cleveland Electric Illuminating Co., et al. (Perry Nuclear Power Plant, Units 1 and 2), ALAB-298, 2 NRC 730, 735-38 (1975); Commonwealth Edison Co. (Zion Station, Units I and 2), ALAB-226, 8 AEC 381, 399-400, 409-10, 414 (1974);
Vermont Yankee Nuclear Power Corp. (Vermont Yankee Nuclear Power Station), ALAB-124, 6 AEC 358 (1973).
I Similarly, in Vermont Yankee Nuclear Power Corp.
(Vermont Yankee Nuclear Power Station), ALAB-124, 6 AEC 358 (1973), cited in Perry, supra, the-Appeal Board noted that both the Licensing Board and the Staff were concerned that the applicant's quality assurance program did not fully coriply with the Commission's regulations (6 AEC at 360, 361),
and, rejecting the approach of having the Staff resolve the outstanding issues off the record, remanded the proceeding to the Licensing Board.
Id. at 362 n.2, 366-67.
Thus, it is for the Licensing Board, not the Staff, to resolve the matters at issue in the adjudicatory proceeding.
Nevertheless, certain matters may he left to the Staff for post-hearing resolution where hearings would not be helpful and the adjudicatory board can make the findings nece'ssa ry to disposition of contested issues based on the adjudicatory record.
In particular, the pendency of confirmatory Staff analyses regarding litigated issues does not automatically foreclose board resolution of those issues.
Long Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1), ALAB-788, 20 NRC 1102, 1171 (1984).
In Shoreham, the Licensing Board retained jurisdiction over one part of a contention, relating to alleged deficiencies in Shoreham's primary containment, in order to review a staff analysis before making a decision on whether to permit Shoreham to operato at power levels in excess of five percent of rated power.
The Licensing Board was satisfied that it could reach a decision on all other aspects of the contention, notwithstanding the pendency of several additional Staff reviews.
A
On appeal, Suffolk County, an intervenor, argued that the pending Staff analyses must be completed and reviewed by the Licensing Board before any. decision is reached.
On the facts of that case, the Appeal Board disagreed.
Suffolk County cited five instances where confirmatory analysis was pending, and in each case the Appeal Board found that the analysis did not foreclose Board resolution of the issues "where the Board can rrche the findings requisite to issuance of the license."
20 NRC at 1171.
One of the five instances involved pending Staff review of the applicant's reassessment of its containment design in response to certain new information and Staff review of the amplified response spectra generated from that reassessment.
At the time of the hearing, the Staff had reviewed applicant's reassessment insofar as it concerned the piping systems and supports, but had not completed its review of the equipment.
The Licensing Board, without awaiting completion of the Staff's review, accepted the applicant's conclusion that the plant design could fully accommodate the newly developed spectra.
Suffolk County did not challenge the substance of that determination, but argued that the lloard should have awaited completion of the Staff's work.
For its part, the Staff was satisfied with the Board's determination, and argued to the Appeal Board that the confirmatory analysis was unlikely to indicate any problems. The Appeal Board concluded that, "[g]iven the uncontroverted evidence in the record offered by [ Applicant], and the staff's judgment regarding the expected outcome of this review, we believe the Board's resolution of the issue is reasonable." 20 NRC at 1173.
The Appeal Board's decision in Commonwealth Edison Co. (Zion Sta-tion, Units 1 and 2), LBP-73-35, 6 AEC 861 (1973), affirmed in relqvant part, ALAB-226, 8 AEC 381 (1974), also is instructive on the question of what may properly be delegated to the Staff.
The Licensing Board there four.d, and the Appeal Board agreed, that there was reasonable likelihood that certain q uality assurance matters would be satisfactorily resolved through audit procedures it had found acceptable, and delegated to the Staff the responsibility for overseeing the reinspection program.
In Zion,.an employee of one of the construction contractors (Walsh Construction Co.) testified that he and certain other persons had per-formed welding at Zion prior to having been certified for such welding.
This raised two issues, both cf which were addressed on the record:
(1) whether uncertified welders had been used; and (2) whether any unac-ceptcble welds had resulted. 6 AEC at 806.
As to the certification issue, the Zion applicant undertook a "100%
audit" review of welder certifications for all but one of the contractors performing safety-related work at Zion. 5_/
The Licensing Board and the Appeal Board found on the basis of the record that welder certifications for all firms except Walsh were satisfactory.
As to the quality of the welding work performed by Walsh, the applicant initiated an investigation of all safety-related welding by Walsh at Zion.
6 AEC nt 896.
The investigation was completed as to Unit I and the results were addressed on the record by the Licensing Board.
5_/
The remaining contractor had satisfactorily shown that its welders were properly certified. 6 AEC at 896.
i,
Where defective welds were found or welds could not be inspected because of their inaccessibility, the Licensing Board and the Appeal Board were r:stisfied on-the basis of the record that appropriate corrective action had been taken or that engineering analyses were adequate to show that safe-ty would not be compromised.
8 AEC at 399.
For Unit 2 welds, however, the audits of quality assurance docu-mentation and of the welds perforried by Walsh had not been completed at the time of the close of the evidentiary hearings, although the audit procedures were comparable to those found acceptable for Unit 1.
8 AEC at 390.
The Licensing Board closed the record in an order which also
. permitted intervenors to request a hearing concerning construction quality assurance at Unit 2 after the investigation had been completed.
In its decision, the Licensing Board found that there was a reasonable likelihood that the Unit 2 matters would be satisfactorily resolved through the audit procedures it had found acceptable.
The Appeal Board approved this procedure and result, rejecting the intervenors' argument that the Licensing Board had " improperly left the ultimate resolution of those contested matters to the applicant and staff." 8 AEC at 399-400.
The 7, ion Licensing Board satisfied itself on the record that there was reasonable assurance that potential construction quality problems had been or would be identified and satisfactorily resolved.
Thus, a pivotal question is whether the evidentiary record is sufficient for the Licensing
F-Board to resolve the adjudicatory issue; in such a case, implementation of the decision can be properly left to the Staff. 6/
The Board has asked that Zion be addressed as it relates to the later case of UCS v. NRC, 735 F.2d 1437 (D.C.
Cir. 1984).
In UCS v. NRC, it was held that the Commission may not generically exclude from operating license hearings the results of emergency preparedness exercises where the NRC had established that such exercises were a prerequisite to full power licensing.
The NRC had promulgated an amendment to its emergency planning and preparedness regulations stating that the results of emergency planning exercises are not required to be considered by a licensing board in any initial licensing decision.
The NRC rule at issue provided, in lieu of consideration of emergency planning exercises in the hearing process, that final NRC issuence of an operating license must be preceded by satisfactory completion of an emergency preparedness exercise, and a finding that there is reasonable assurance that adequate protective measures can and will be taken in the event of a
radiological emergency.
Because the Commission in UCS v. NRC could not argue that the assessment of emergency exercises is not material to its licensin g decision, U the Court found "no 6/
See Zion, ALAB-226, s upra, 8 AEC at 399-400; TA!I-1, ALAB-729, supra, 17 NRC at 885-87; San Onofre, ALAB-712, supra, 17 NRC nt 380, n.57.
Even in such a case, however, intervenors may be enti-tied to be heard if problems arise in the implementation of the Board's decision on the delegated matter.
See Zion, ALAB-226, supra, 8 AEC at 399-400; T511-1, ALAB-729, supra,17 NRC at 887.
~7/
The Commission argued, instead, that Section 189(a) of the Atomic Energy Act, 42 U.S.C.
2011 et seq., still leaves it discretion to evaluate the exercises outside IEe hearing procedure preparatory to making its ultimate finding on the adequacy of offsite preparation.
_ to _
4 basis... for NRC's position that Congress granted it discretion to elimi-nate from the hearing material issues in its licensing decision." 735 F.2d at 1447.
The D.C. Circuit found the amendment invalid because it denied statutorily prescribed hearing rights.
735 F.2d at 1441-42.
UCS v. NRC is not inconsistent with prior Commission case law,
cited above, including Zion.
Indeed, Commission case law has always supported the resolution of contested issues through the hearing process, and not through post-hearine resolution by the Staff.
In UCS v. NRC, the court prohibited delegation of a material issue to the Staff for resolution outside the hearing process.
In Zion, where the Staff was permitted to oversee an inspection program following audit procedures found acceptable to the Board, the Board properly determined, based on the record, that there was a " reasonable likelihood" that the Unit 2 quality assurance matters would be satisfactorily resolved through the reinspection program. 8 AEC at 400.
In a recent post - UCS v. NRC decision,
the Appeal Board reaffirmed the principle of delegation of certain matters to the Staff in appropriate circumstances.
Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2), ALAB-836, 23 NRC _ (f. fay 7,1986).
There,
in response to a contention raising concerns about traffic congestion in two areas beyond the emergency planning zone (EPZ), the Licensing Board found that additional traffic control measures were necessary within one area of the EPZ so as to assure that evacuation traffic could continue to move once it reached the EPZ boundary.
Accordingly, it imposed a license condition requiring the NRC's Director j
of the Office of Nuclear Reactor Regulation (NRR) to verify plans to i
I
. 9 implement such traffic control before authorizing operation of the Limerick plant above five percent of rated power.
LDP-85-14, 21 NRC at 1250-69, 1407.
Because.of that license condition, the Appeal Board reasoned, the contention's request for " adequate plans for traffic control and direction" had been satisfied.
Slip op, at 18-19.
The Appeal Board rejected the intervenor's argument that the Board improperly delegated to the Staff the post-hearing verifiestion of these traffic centrol measures and that the Board's imposition of a license condition in response to the contention denied the intervenor's asserted righ t to cross-examination on the subject of additional traffic control.
Slip op. at 20-26.
Citing the proposition that, in general, contested isnues should be resolved through the hearing process and not be left for post-hearing resolution by the
- Staff, Louisiana Power and Light Co.
(Waterford Steam Electric Station, Unit 3), ALAB-732, 17 NRC 1076, 1103-04 (1983), - the Appeal Board noted that findings in the emergency planning area are generally predictive in nature, and that an emergency 8_/
In Waterford,
the Appeal Board concluded that post-hearing verification by the Staff of the installation and testing of the siren warning system, completion of letters of agreement for vehicles and drivers, and certain details of the Emergency Support Organization was proper.
See also Pacific Gas and Electric Co. (Diablo Canyon Nuclear Power Plant, Units 1 and 2), ALAB-781, 20 NRC 819, 832-35 (1984) (certain deficiencies in county public information program and the emergency communication system can be resolved after hearing,
-Cf. Cincinnati Gas & Electric Co. (Wm.
through license condition).
H. Zimmer Nuclear Power StaIIon, Unit No. 1), ALAB-727, 17 NRC 760, 773-74 (1983), where the Appeal Board determined that, among other things, the adequacy of applicant's emergency communications systen had not been shown on the record.
In that circumstance, it was concluded that intervenors were entitled to a hearing on the adequacy of an alternative system, which was not described in the emergency plan.
plan need not be final in every detail, just sufficiently developed to permit the "reasonoble assurance" finding required by the Commission's regulations.-
" Consequently, in some instances post-hearing verification by the staff of emergency planning measures is not an improper delega-tion ai decisionmaking authority to the staff."
Slip op, at 21.
Since the delegation was proper, the intervenor was not entitled to any cross-examination on the plans for additional traffic control.
- d. at 23.
Where delegation is properly made, there are means available to address subsequent developments.
The Zion case is instructive in that regard.
There, the Appeal Board endorsed the procedural mechanism used by the Licensing Board to bring to light and resolve any problems which might be revealed by the quality assurance audits.
The Licensing Board's order closing the record permitted the intervenors, as well as other parties, to request (or the Board to order) a hearing concerning construction quality assurance matters at Unit 2,
whether or not the matters were explicitly included within the intervenors' quality assurance contentions.
The order also directed Staff and the applicant to promptly sond copies of all future correspondence regarding construction quality assurance matters for Unit 2 to the intervenors and Board members.
The Appeal Board reasoned:
This order represented a satisfactory method of assuring on-the-record resolution of QA [ quality assuranec} matters concerning Unit 2.
The record as it stood at the close of the evidentiary hearings was satisfactory to permit findings that all QA natters had been satisfactorily resolved for Unit 1, and that there was a reasonable likelihood that the Unit 2 matters would also be satisfactorily resolved.
The order required the intervenors to be given access to all information developed by the staff after the close of the hearings and bearing upon the QA status of Unit 2, and it afforded them ample
opportunity to seek a reopening of the record to include such information.
No party requested such a hearing.
Having failed to avail themselves of this opportunity, the intervenors cannot successfully contend that the record was inadequate for the Board to have resolved the Unit 2 QA issues, or that the Board improperly delegated its responsibility to do so.
8 AEC at 400.
In summary, the Commission's case law permits the Licensing Board to delegate certain matters to the Staff for post-henring resolution.
UCS v. NRC is not inconsistent with this case law but makes it clear that material issucs in controversy must be resolved on the record in the hearing process.
Regarding what matters may be properly delegated to the Staff, the pendency of confirmatory Staff analyses regarding liti-gated issues does not forec5se Board resolution of contested issues if the record is sufficient for the Board to make the findings requisite to the issuance of a license or amendment.
In this case, the Board could follow the course of the Zion Board by holding the hearing and resolving the issues based on the hearing record but providing for the opportunity to reopen the record for a hearing on the results of the confirmatory tests.
A second possibility is for the Board to hold the hearing but defer issuance of a decision until the confirmatory tests are completed and, based on the results of the tests, decide whether any further hearings are necesFary before issuing 8 l
decision. U Finally, the Board could defer the entire hearing until after
(
the confirmatory tests are completed.
The Staff continues to believe that the hearing can be conducted before the confirmatory tests are completed.
Considering the Applicant's position that it can present all the evidence necessary to resolve the contentions in its favor to the satisfaction of the Board without the results of the confirmatory tests, and the Staff's belief that those tests will support resolution of the contentions in Applicant's favor, the Staff suggests that the Board not await the completion of the tests beforc holding a hearing, but rather hold the hearing after the issuance of Steff's SER.
hith respect to the question of whether the Board should issue its decision before the completion of the confirmatory tests, the Boa rd should issue its decision only if the Board can make the findings necessary to resolve the issues in contention on the basis of the evidentiary record.
The Staff believes that because of the Board's interest in the results of the confirmatory tests, the Bcard may wish to 9/
This approach is similar to that which the Appeal Board ruled should have been taken in the Byron operating license proceeding.
Commonwealth Edison Co. (Byron Nuclear Power Station, Units 1 and 2),
ALAD-770, 19 NRC 1163, 1166-78 (1984).
In Byron, the Licensing Board denied an operating license application based on its conclusion that the record on quality assurance (QA) deficiencies was not adequate to enable the Board to resolve the QA issues in applicant's favor.
The Staff had informed the Licensing Board that upon completion of an ongoing QA reinspection program, the Staff would evaluate the results and not recommend issuance of an operating license until it was satisfied with the reinspection program and its results.
The Licensing Board issued the decision while the reinspection program was in progress in order to allow the applicant the opportunity to immediately appeal the adverse decision.
The Appeal Board held, however, that the Licensing Board should have awaited the results of the reinspection program and held a further l
hearing since it was " central to a finding of reasonable assurance of proper facility construction."
_Id_. at 1175.
l l
defer issuance of its decision until it has the Staff's evaluation of those tests in hand.
III.
CONCLUSION As discussed above, the pendency of confirmatory analysis by the Staff need not, of itself, preclude the issuance of an initial decision.
A decision to delegate a matter to the Staff can be made if the unresolved matter is such that the Board is nevertheless able to make the findings requisite to resolution of the admitted contentions.
If the Board is unable to make such findinr;a, it should defer isruance of its initial decision until the record is adequate to support such findin gs.
Specifically, the Staff suggests that the Board not await the completion of the confirmatory tests before holding the hearing.
Rather the Staff believes that the Board can hold the hearing, after the issuance of Staff's SER, and may issue an initial decisien if the Board believes it can make the requisite findings to resolve the contested issues on the evidentiary record d eveloped.
In view of the Board's expressed interest in the '
results of the confirmatory tests, however, the Board may wish to defer issuance of its decision until after completion of those tests.
Respectfully submitted, e
Mar E. Wagner Cou el for NRQ Staff Mitz
. Young Counsel for NRC Staff Dated at Bethesda, Maryland this 14th day of May,1986
O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC S AFETY AND LICENSING BOARD In the Matter of
)
)
Docket No. 50-289 OLA-1 GPU NUCLEAR CORPORATION,
)
)
(Steam Generator Plugging (Three Mile Island Nuclear
)
Criteria)
Station, Unit No.1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF BRIEF ON DELEGATION TO STAFF" in the above-captioned proceeding have been served on the following by deposit in in the Nuclear Regulatory Commission's internal mail system, or, as indicated by an asterisk, by hand delivery, or, as indicated by a double asterisk, by deposit in the United States mail, first class, postage prepaid, this 14th day of May,1986:
- Shelden J. Wolfe, Chairman
- Bruce W. Churchill, Esq.
Administrative Judge Shaw, Pittmen, Potts & Trowbridge Atomic Safety & Licensing Board Panel 1800 M Street, NW U.S. Nuclear Regulatory Commission Washington, DC 20036 Washington, DC 20555
- Thomas Y. Au, Esq.
- Dr. Oscar H. Paris Office of Chief Counsel Administrative Judge Department of Environmental Resources Atomic Safety and Licensing Board Panel 505 Executive House U.S. Nuclear Regulatory Commission P.O. Box 2357 Washington, DC 20555 Harrisburg, PA 17120
- Frederick J. Shon 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 Atomic Safety & Licensing Appeal
- TMI Alert Board Panel 315 Peffer Street U.S. Nuclear Regulatory Commission Harrisburg, PA 17102 Washington, DC 20555
- Louise Bradford Docketing & Service Section 1011 Green Street Office of the Secretary Harrisburg, PA 17102 U.S. Nuclear Regulatory Commission Washington, DC 20555
$V&
- (~
Mary E/ Wagner Counset for NRC ltaff
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