ML20205K869
| ML20205K869 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 04/09/1999 |
| From: | Katz D CITIZENS AWARENESS NETWORK |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#299-20231 98-736-01-LA, 98-736-1-LA, LA, NUDOCS 9904140039 | |
| Download: ML20205K869 (15) | |
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- USHRC UNITED STATliS OF AMl!RICA j NUCLEAR REGULATORY COMMISSION % APR 12 P4 :39 Ilefore the ATOMIC SAFETY AND 1.lCCENSING BOARD OE. !
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In the Matter of ) Docket No.50-029 LA
) ASLBP No. 98-736-01-LA YANKEE ATOMIC El.ECTRIC COMPANY )
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(Yankee Nuclear Power Station) ) April 9,1999 CITl/ ENS AWAREN!!SS NETWORK. INC Rl(Pl.Y TO YANKEli ATOMIC El ECTRIC COMPANY'S OHJECTION TO AND MOTION FOR RECONSIDFRATION OF A PORTION OF PREHEARING CONFERENCE ORDER Citizens Awareness Network. Inc. (CAN), hereby replies under 10 CFR Pan 2.730 to Yankee Atomic Electric Company's (YAliC) Objection and Motion for Reconsideration of part of the Atomic Safety and 1.icensing Board's Prehearing Conference Order in the license amendment proceeding on YAEC's proposed License Termination Plan (LTP). CAN joins with the New England Coalition on Nuclear Pollution in their motion as a citizen intenenor group CAN is participating in this adjudicatory process to represent the interests and protect the health and safety of our commumty.
- 1. Reply to YAEC's Motion On March 17,1999 the Atomic Safety and 1.icensing Board ( ASLAB) issued a Prehearing Conference Order (Ruling on Contentions) in which it accepted four reworded contentions from the Citizens Awareness Network (CAN) and New England t
9904140039 990409 ADOCK 05000029 eDR O eda _ g{4J
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! Coahtion on Nuclear Pollution (NCNP). On March 29,1999, YAEC filed a motion for l
! reconsideration of" Contention 4" YAEC claims therem that the ASLAB convened a l
l "soluntary undenaking into the equisalent of a regulatory requirement, in contravention
- of the goserning regulations . "'
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! YAEC claims that its "soluntary undenaking" derives from its status as an SDN5P plant, and YAEC in its motion desenbes itself as meeting the qualifications for SDMP,2 CAN submits firstly that the SDMP Action Plan is mere guidance. It is not regulation, it has not gone through a rulemaking process nor has it been released for public comment. The enchanced rulemaking process referred to by Ms. Ilogdon in the prehearing transcript addressed the Subpan (e) rulemaking, w hich though related in a manner to the SDMP, was not in fact a rulemaking on the SDMP or the SDMP Action Plan.'
Unlike an NRC regulation, it does not constitute bmding legal requirements. The l
SDMP Action Plan in fact states "It should be noted that the Action Plan itself does not contain enforceable standards and is not intended to create new rights or obligations on third panies or to preclude litigation of properly framed issues in any pending proceeding" Therefore, YAEC's commitments in its 1.TP should not be alTected by its claimed SDMP status or its "soluntary " commitments in fact, YAEC's site remediation 8
YarAce Atonue Electric Co Objection To and Alotion of Yankee Atornic Electne Co for Reconuderation of a Portion of Preheanng Conference order IbcLet No so-029-l.A 3 NUREG-1444 Site Decomnusuonmg htanagenwnt Plan. (ktober, IW3 8
Orlicial Transcnpt of Proceedings. Uruted Statc> of Arnenca Nucle 4r Regulatory Comnunion, Yankee Atonne Electric Company (Yankee Nuclear Power Stanon) Caw .No 50-029- L.A R, ASil-300-c41, Greenficid, NtA January 26, IOW pp 29 30 l
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.. i plan should be examined in light of NRC's new decommissioning rule and the requirements the ru;e establishes for site release criteria for power reactors. CAN recognizes that the NRC rule sets a higher standard for site release dose limits than i- YAEC's LTP commitment and will address this issue in our reply.
CAN submits that YAEC currently does not qualify as an SDMP plant as set out 1 1
in 10 CFR part 20.1401 or under the SDMP Action Plan ' in the SDMP Action Plan summary NRC desenbes the enteria for SDMP plants, which includes " ..the NRC's general expectation that SDMP site cleanup wili be completed within a 4-year timeframe atier operations cease or 3 years aller the issuance of an initial cleanup order.. "' YAEC has been decommissioning the Yankee Rowe site since 1992 and site remediation is far from accomplished Clearly this isjust one of the ways in which YAEC's 4
, decommissioning plan fails to meet SDMP criteria Esen if YAEC and NRC StalT were to be permitted to stretch NRC guidelines to allow YAEC to qualify as an exceptional member of this group, YAEC still would not meet the essential requirements of timeliness and effectiseness. In addition, Mr. Weber in a transcript from NRC states, "So, in the program management plan, we hase ob.iectis es. responsibilities, and resources are specifically caned out in NRC budget, to support this program (SDMP). It also includes the listing of the contaminated sites. People don't like to be listed on the SDMP, because, to some, it's equisalent to being listed on EPA's Superfund list or the national
- 57 FR 13389 Apnl 16,199: Acnon Plan to Ln>ure Tmwl3 leanup o S te Decomnuaioning Management Ptan Sites, p 2
' NUCLEAR REGULATORY COMMIS$10N AGENCY Nudcar Regulator) Comminion Agtion Plan to EnwfLTitnsinCkanuo of Shc.1hNecinsMen!ngManageriwnt Plan Site,57 FR 13389 Anni in. iw:
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I priorities list "' is YAEC the equis alent of a Superfund site and if so, is the dispute over clean up an admission by YAEC that in fact the site is seriously contaminated?
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I l In addition, the SDMP Action Plan states that "[Tlhe SDMP provides a l
comprehensise strategy for NRC and licensee actisities dealing with the cleanup and closure of contaminated nuclear material facilities user which the NRC has jurisdiction. ;
I (The SDMP does not include more routine decommissioning cases such as nuclear power reactors)"" The power reactors previously allowed to decommission under SDMP were Shoreham and Fort St. Vrain. Both stations had much shorter operational lises and therefore site remediation was not as comptes as it is at Yankee Rowe, which operated for thirty one years.
Funher,10 CFR 20 Subpart (e) excludes sites, w hich :
(1) Has e been decommissioned prior to the elTective I
date of the rule in accordance with enteria identified in the Site Decommissioning Management Plan (SDMP)
Action Plan of Apnl 16,1992 (57 FR 13389);
(2) Hase previously submitted and receised Commission approval on a license termination plan (LTP) or decommissioning plan that is compatible with ;
the SDMP Action Plan criteria; or (3) Submit a sullicient LTP or decommissioning plan before August 20.1998 and such LTP or decommissioning plan is approsed by the Commission
- lbid p i
' NLCLiiAR RECELA1ORY CONI \t!5SION Aduwry Conumitee on Reactor Sat'eguards and Advi>ory ;
Comnuttee on Nuclear Waste Jomt Subcomnuttees lit Meeting thxLet Number (not applicable)
RocLulle Maryland , March 26. lW6 Work Order No NRC 587 Pages 1255
- lbid 57 i R I3359 Apnl Ib. IW2 Action Plan to 1.murg hmel) Cleanup ofilt DcV0mminigning l Wragement Plan.jhic) l l
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w w w y-b before August 20,1999 and in accordance with the criteria identified in the SDMP Action Plan, except that if an EIS is required in the submittal, there will be a prosision for day-for-day extension.
It has yet to be shown that YAliC's decommissioning plan was either written to be SDMP criteria compliant, or that it was approsed by the NRC as such. S'..ither case )
that YAEC cites in its appeal supports its claim that is has been approved to be i considered an SDMP site, and therefore grandfathered under 10 CFR 20.1401 (bX3).
. Neither case eser attempts to addresses the issue YAEC in its LTP executise summary in Revision 1 ofits LTP at page A siii makes a claim that its I.TP will meet SDMP guidelines howeser CAN has found no similar claim for its decommissioning plan.
Whether YAEC can be grandfathered in under 1401 (b) or must meet the 1402 requirements, does not reliese YAEC ofits commitments made in the LTP. Rather than demonstmte a commitment and assurance that its I.TP plan can be etTective, YAEC threatens to withdraw its commitments when its methodology is questioned. YAEC in its LTP committed to a 15 millirem per year dose to the effected population. Now that the methodology for YAEC's calcolations are questioned YAEC maintains that it doesn't hase to n?cet commitments it made repeatedly in its I.TP, as well as in many public meetings, forums, and public relations campaigns, since it claims that it is an SDMP plant and its commitments were s oluntary' The licensee can not have it both ways. It must make good" on its commitments l
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If the LTP is to gain approval then YAEC must honor the commitments it made, 1
and the questions that hase arisen pertaining to methodology employed are both valid and reasonable. It is irrational that the licensee declares that since its commitment is Notuatary", it is not accountable to the regulatory requirements YAEC committed to in its LTP. Once YAEC committed in its LTP to a standart it is obligated rder law to l meet that standard. YAEC should not be permitted to pick and choose between f
d mmmissioning guidelines, regulations, and dose calculations to asoid its commitments. If the licensee can do this, it renders NRC regulations arbitrary and irrational and raises doubts about other commitments made by the licensee. {
l YAEC in its LTP repeatedly'" commits to an exposure me pass salue eil 5 j mrern3 r, yet it now claims that it cannot be forced to meet this commitment. Yankee had previously committed to an exposure rate pass salue of 30 arent'yr", the 15 i
mrent yr, commitment in the LTP is an impros ement that CAN linds laudable. The argument that YAEC now presents, that intenenors cannot have contentions surrounding J
this issue ads tied by the ASLAli, are based on faulty logic. Intenenors do not esen need to contend that YAEC in its LTP proposes to allow levels s'oose or telow either the l
' l 15 or 30 mrem per year exposure rate pass values, or that it is statutorily required, to meet cather for Contention 4 to stand. The contention stands regardless of the issues 4 surrounding Subpart (e) of 10CFR2D Intenenors nierely need to contend that Y AEC l f
' Yankee Atomk Electnc Compan) Otusstionly and Alouen oflardstAtoiss1!sstacf9EPAQylDf KeGenMdcr# ion of Portion of PrehearmgConfstroGChrdsr DocLc No So-o24.LA p i ,
'" YNPS lxenne Ternunanon Plan Remon 0,1997
" Orlicaal Trannenpt of Proceedmgs " Informal licanng - - Yankee Rowc Decomnuworung Plan".
Greenf.eki, MA. August Ib,1994 Acccuion Nonber 940whol:60 p 9 1
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L i must be able meet the 15 mrem y r lesel because this is the e.sposure rate pass value that YAEC stated that it will meet and that the methodology laid out in the LTP is not sumcient to meet this standard. This contention does not hinge on whether or not Yankee is required to meet 10 CFR 20.1402 requirements, or whether it is required to make a TEDE analysis. (YAEC would indeed be required under 10 CFR 20.1401 (d) to do a TEDE for the first 1000 peak years). The contention stems from YAEC's decision and commitments in its LTP. The Board, in its decision, properly accepts YAEC's commitment to the 15 mrent > ear TiiDE dose criteria as ruling.'2 If YAEC's commitments i ' its own LTP cannot be considered as ruling when they meet, and even if they excee gulatory standards of what use is the 111'1" YAEC presents the argument that being required to meet its oun standards is penalie.ing it.
-Yankee's soluntary undenaking in this situation...should be encouraged, not penalized. To declare...that if one commits to do more than the minimum you may be held down the road to do more than you have committed to do is to erect a powerful disincentise to makinq....such otherwise laudable and desirable but entirely gratuitous undertakings" '
Requiring that YAEC use a methodology that will in fact allow it to properly meet the standards that it has chosen, and thereby tise up to the I.TP should not been seen as a penalty. YAEC is not being asked, aut would suggest, to do more than it has committed
" LBP W-14 pp 171b
" Yankee Atonus Electns Company OtysqtinghanOlguen of br4st_b12DC.f}CCirisfumpF1fGI
.BcConkdstation of P9ttsfhrhsenngCenfstcost Order thLct No $0-029 LA p 5 i
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to do. Indeed, Yankee is being asked to do exactly what it has committed to do, in a manner that will allow it to fully meet its standards if the licensee follows its own logic, that it is not required to meet a 15 mrem /yr
.TEDE, the licensee should be required to retract and res ise its LTP since in its present ,
l form it repeatedly commits to a 15 millirem! per 3 r standard it should resubmit a sersion of the plan which accurately describes what YAEC's commitments are, what methodology it will employ to meet those commitments, and what figures, and dose L calculations the community as well, as the regulators, can be assured that YAEC will meet. . If YAEC does not intend to meet the 15 millirem per year dose commitment that L too should be explicitly stated in the I.TP. Then the ASI.AB could potentially hold e.wther prehearing conference on YAEC's revised and resubmitted LTP. In addition, it must then be determined that YAEC's LTP approval by the StalTwas premature. Since YAEC may then be forced to qualify for decommissioning under NRC's new rule (since the old rule requires LTP approval prior to Augt,t 1999), CAN believes that it is incumbent upon YAEC to stand by its 15 mrem y r commitment, or, the very minimum, meet the 25 millirem! per yr of the new NRC decommissioning rule.
YAEC further argues that since the use of the " gardener" critical group would not etTeet the dose since the dose that must be met is the 25 millirem /per year rather than the
' 15 millerem YAEC "soluntanly committed to We do not agree that the use of the ;
gardener would necessarily fall below the 25 millirem. In any case, YAEC committed in l its LTP to meet 15. " rem per > ear standard repeatedly.
1 In StatT Responses to Frecuently Asked Ouestions Conceming Decommissionine of Nuclear Powet Reacton" the NRC sta'Tcommerts on the "aserage member of the w : cal group" "The entical group is an indisidual or relatisely homogeneous group of individuals expected to receised the highest exposure within the assumptions of the particular scenario. The aserage member of the critical group is represented by the aserage of the doses for all members of the critical group, which in turn is assemed to represcut the most likely exposure situation. For example, the critical group for a scenario in which people work inside a building would be the group of regular employ ees working in a building that has been decontaminated. If the site were conserted to residential use, the critical group could be people whose occupations in.olve resident farming at the site, not an aserage of all the residents on the site."
indeed NRC Staff go further than the " gardener" scenario and YAEC in its commitments to the community goes further than the " gardener" scenario. YAEC contends that Contention 4 should be reiected as "10 C F R. 20.1402 does not require the calculation of a TEDE for the member of the critical group who is atypically exposed"."' l 1
CAN's contentions do not address calculating atypical exposure. The scenario addressed in the contention contemplates the family farm scenario set forth in YAEC's LTP.
YAEC, in its matic,n, attempts to disregard the hours that would be spent in the field by a farmer. YAEC twhts CAN's contentions in an attempt to make it appear t!iat an atypical member of the critical population would be exposed to residual radiation
" Starf Responnes to Frequent)) A> Led Questsons on Decomnus&inmg of Nuclear Power Reactors l
Nt' REG 1628
" Ibid B 8
" Yacice Atonuc Elccarw Co Objection To and Motion of Yankee Atonuc 13ccinc Co for Reconsideration ;
of a Ponnwi of Prehcanng Conference order Docket No 50-U:9-1.A page 7 l
r 10 l.
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- from din for 88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br /> per 3 ear v 'e they were gardening, when in fact the most typical of family farmers, the critical population themselses, would spend considerably more time in contact with the din.
YAEC further contends that in order for Contention 4 to be admissible, CAN's s
contention should hase assened that the aserage member of the critical group is a full-l time gardener Mr. Austin, Chief of the 1.ow Lesel Waste and Decommissioning Projects Branch, came to our community in August of 1994 and told us that
" Yankee Rowe has proposed a standard of 30 millirem per year exposure from all reasonable pathways,30 millirem is about one tenth of the natural background radiation. That exposure rate would be calculated bued on human intrusion on the site, mcludmg a pmtulatedfamdyfarm bemg corutrusted on the sue growmg crops, 25 percent ofthe cropa l cornumed on thefarm, postulated dnnLing well, in which we would i
assume that a person drinks 2 liters a day of the groundwater. We sum up all these exposures and their proposal is that the sum be 30 millirem or less.'"(Emphasis added) j in a letter from Don Davis, YAEC CEO, to Mr. Adam 12ipson, Chair of the Franklin Regional Planning Ikard, dated January 5,1998, Davis assens that "In the LTP, Yankee has committed to limit the dose from re>idual plant related radioactivity to less i
than 15 millirem' yr."" Davis states that this dme includes all exposure pathways. Ilis j example is " .if a person were to build a house on the Yankee site, farm the land...""
" Yankee Atonne Electnc Co Objection lo and Alotion of Yankee Atomic Electric Co for Recondderation of a Punion of Preheanng Conference order Docket No Su-029-l.A page 8 "O Ecaal Transcnpa of Proceedmgs -Infonnel licaring - Yankee Rowe Decomnussioning Plan",
. Greentwid. \1A. Auttunt 10,1994 Accesdon Number 94090n01ab page 9
" leter Enclosure utkd -YAEC Responsen to 1 rankha Regional Council of Gos ernments Questions on YNPS Laceme Tenrunstson Plan" from Don Dam. Y AEC Cl O. Io Adam Laipu>n, Chair Franklin Regional Plannmg Board January 5,19918, p 12
- ibid
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First, the family living on the " postulated family farm" is not atypically exposed and the l'
i calculation for the TEDE should be for this family who a the critical group. According l
to a Massachusetts Department of Food and Agriculture publication, Massachusetts leads i New England in direct sales of farm products. Further,80' of Massachusetts' 5,574 I
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farms are indisidual or family owned and oser 93. n ercent are small farms ' A family t
farm is a reasonable and typical scenano for the region.
l Secondly, since the family is consuming 25*. of their crops, one must assume that the remaining 75% of the crops grown on this family farm are sold. YAEC's LTP l
scenario of 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per we :k gardening (person gardening i percent of their time during a four month growing season) 2 does not equate to a family farm. CAN contends that the LTP calculations should be based on a farmer farmmg the land 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> per day,5 days p-r week. This equates to 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of farming per week. Atypically exposed, and
' unprotected by esen the assumptions in the family fant scenarm, is the postebied 2-l l year-old child playing in the soil as her parent farms.
Esen if YAEC did not use the scenano of a family fann referenced in its LTP l
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(which CAN would protest since a family farm is :)pical of this region and since YAEC I-already committed to a farm scenario), typical people spend more than 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> per week 3'-Farm & AtarLet Report", hianachusetta Departrnent ofIood and Agnculture, Vol 76 No 2, February 1,% / I
- 5760 hrs /3 r s 0 0157 6 his garderung a ) cars Anunung 4 4 memh growmg sc4>on (52 wccLs/> car)s
() carl 12 month 4 s 4 month growmg scawn - 17 3 wecks growmg wawn therefore,57 6 hrs /17 3 wecks io growing scawn 5 I hrs per weck
,. l 12 e
1 l- in the soil tilling, planting, weeding, watering, and han estmg not only segetables but i
!' also flowers. It is more than reasonable for a person to spend at least 2 percent of their time oser a 4 month growing season. This means that the LTP should at a minimum, assume a person living on a family farm would garden at least 30 hour3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> a week, and that l any person gardens 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per week or more.2i i
NRC rules and regulations are not mutable and anomalous. YAEC should act
'arbitranly pick and choose from these regulations at will when it is held accountable to l
its commitments for site remediation The rules and regulations were established to assure necessary public and environmental protections into the regulatory scheme.
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.Neither the 25 mremlyr dose, nor the 100 mrem /> r dose, are mentioned in YAEC's LTP.
The only dose repeatedly referred to throurhuur the LTP is the 15 mrent'yr. Such doses as the 25 mrem /yr or 100 mrem'yr were not mentioned at the NRC meeting held on Janwy 13,1998 in Buckland, Massachusetts ' or any presious public meetings. See LTP sections 2.1,2.4.3,2.4.4,4.4.3. CAN contends that NRC and the ASLAB must require Yankee Rowe's LTP to adhere to a "no more than 15 mrent yr" release criteria.
The experience of our community in relating to this licensee and the NRC Staffis i
that whateser commitments that these parties hase made to our community since 1991
" E700 hrst p a 0 02 = 175 2 hrn garderung m a year, anunung a 4 month growmg neason Therefore 175 2 hrs'l7.3 weeks in growing season - 10 I hrs per week
The OtEcsal Transcript of Proceedmgs Uruted States of America Nuc! car Regulatory Comnuwon
- Pubiac Meeting tYankee Mclear Power Station txenne Terr uution Plan. Shelburn. Ma. h.nuary 13, IWW i
o . l3 4
ate mutable. We experience oursches as repeatedly participating in a shell game, in which escry time we attempt to hold YAEC to its own commitments that it makes to our community-whether 1015 millitern: per 3 r . 25 millirem per yr., or 30 millirem per yr.-it )
changes with the support of NRC StatT, CAN would like the YAEC to do as it says it will do. CAN is asking only for simple fairness and adequate assunmces that our community which is sutTering can be protected from radioactise contamination of our 1
children and our natural resources.
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Conclusion:
1 For the foregoing reasons oflaw, regulations, and fact: (1) YAEC's Motion for ,
Reconsideration should be denied.
Respectfully Submitted,
! i d[5eisirah B Katz, pros for CAN I
l tJNITl!D SI ATliS Ol' ANil RICA 00CKETED UbWlC Nt:Cl.1:.AR RI Gl'l.A~ LORY COMN11SSION liefore the A ION 11C sal l: 1 Y AND 1.1C1 NSING llOARD 99 App 12 p4 :40 Admimstrata e Judges Charles llechheefer. Chairmen Og- .
Dr. Thomas S lilleman AbI '
T Thomas D Murphy in the Matter of ! Docket No 50-029-1.A I
YANKlili ATOMIC lit.!!CTRIC COMPANY ) ASI.llP No 99-754-01 -1.A.R i Yankee Nuclear Power Station) >
1.ieense 'lerminanon Plan i Sened Apnl 9,1999 CI:R Til lC A TI: OF SERVICI: I OR CJIJ/FNS AW ARl NFSS NE133)Rh'S RI PI Y T() Y Al:C'S MOTION 1, Deborah 11 Katz, on behalf of Citizens Awareness Network. Inc., certify under Cs penalty of perjury that on Apnl / ,1999, copies of the enclosed papers were sersed on the parties below by mailing them postage pre-paid U S Postal Senice Pnont) 2-Day Mail Oneinal and two copies to- One contto Rulemakings and Adjudications Staff Ollice of Commissmn Appellate Adjudication (Mail Stop 016-Cl ) ( Mail Stop o- 16-C l )
U S Nuclear Regulatory Commission 1J.S Nuclear Regulatory Commission I White Fhnt North I White l'hnt North 11555 RoeLulle Pike i1555 Rockulle Pike RoeLulle, MD 20852-2738 Rockulle. MD 20852 2738 Tel 301-415-1675 Tel 301-415-21x4 One cops to Jons.han M lilock. Counsel for i homas G Dignan, Jr . lisq New lingland Coahtion on Nuclear Pollution Ropes A Gra)
P O Ilos 566 One International I" ace j
l Putney, VT 05346-0566 llosion. M A 02110-2624 Tel 802 387-2646 'l el 617-9517511 l
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2 o one cops to:
. One corw each to Atomic Safety and 1.icensmg lioard Thomas S filleman, Administratise Judge, Charles llechhoefer, Chairman, and Atomie Safets and 1.icensing floard l
l Thomas hturphy, Admimstratise Judge 704 I)audson Street iNtail Stop T 3 F23) Raleigh, NC 27609 U S. Nuclear Regulatory Commissmn 2 White iImt North Diane Curran l
! i1545 Rocksille Pike ilarmon, Curran, Spielberg & liisenberg Rockulle, N1D 20852-2738 2001 'S' Street, N W , Suite 430 l Tel 301-415 7399 Washington, D C. 20009 Tel 202-328-6374 i
Adam 1.aipson James L Perkins, President New England Coalition on Nuclear Pollution Franklin Regional Council of Gosernments l
P O. Ilos 545 425 hiain Street l
Brattleboro , VT 05302 Greenlield, N1 A 01301 l
Tel. 802-257 0336 ~1el 413 774 3167 l Ann 11. Ilodgdon, and hiartin I.. /obler l Ollice of General Couna:1 Washington, DC 20555
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Deborah 11 Kat/, Cits/ ens Awaren ' . twork i
l The followine persons were prosided couneigopges of CAN's filing Das ed Rothstein U S liPA Region i Suite 1100 RCA I Congress Street iloston, N1A 02114-2023 Ted liolen, listi linuronmental Protecuan Diusion Ollice of the Attorney General 200 Portland Street lioston, A1A 02114