ML20210E450
| ML20210E450 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 03/25/1986 |
| From: | Wagner M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#186-551 OLA-2, NUDOCS 8603270352 | |
| Download: ML20210E450 (17) | |
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March 25, 1986 UNITED STATES OF AMERICA ' f ,q)d NUCLEAR REGULATORY COMP 11SSION D 0;-
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BEFORE THE ATOMIC $AFETY AND LICENSING BO4RD _
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In the flatter of
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METROPOLITAN EDISON COMPANY, ) Docket No. 50-289 OLA ET AL. ) (Steam Generator Plugging
) Criteria)
(Three Mile Island Nuclear Station, )
Unit No.1) )
NRC STAFF RESPONSE TO TMIA'S FORMAL DEMAND FOR ADJUDICATORY HEARING ON AMENDMENT TO TMI-1 OPERATING LICENSE TO CHANGE TURE PLUGGING CRITERIA I. INTRODUCTION Three Mile Island Alert. Inc. (TMIA) has filed a " formal demand for adjudicatory bearing" 1I in connection with a February 4, 1986 request by GPU Nuclear Corporation (GPUN or Licensee) for a license amendment which would revise plugging criteria for the steam generator tubes at Three Mile Island Nuclear Station, Unit 1 (TMI-1) . - In its Petition, TMIA asks that it be pranted a full hearing on the proposed amendment for the reasons set forth therein. For the reasons discussed below, the
-1/ "Three Mile Island Alert's Formal Demand for Adjudicatory llearing on Amendment to TMI-1 Operating License to Change Tube Plugging Criteria," March 10,1986 (Petition).
-2/ This is the second amendment request pending before the NRC with respect to changing the tube plugging criteria. An earlier, separate amendment request, filed November 6, 1985, asks for permission to apply yet another plugging criteria. See pp. 3-4, infra. That ear-lier request has not been' withdrawn.
32 O g 9 pg7;ICUATED ORIGINAL 0 CertiD ed Dy T (kk
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- Petition me, ts the requirements of 10 C.F.R. I 2.714, and Tf.11A should be admitted as a party to this proceeding. TMIA also included in its Petition five proffered contentions, to which the Staff's response is pro-vided below.
II. DISCUSSION A. Factual and Procedural Backgroand 1
The Commission issued an order on July 2, 1979 directing that the TP11-1 facility remain shut down b until the Commission determined, in t
light of the March 28, 1979 accident at TBII-2, whether there is reason-able assurance that TMI-1 could be operated with no undue risk to the public health and safety. See Metropolitan Edison Co. (Three Mile Island 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 dis-covered that many of the tubes- in the steam generators at TMI-1 had been damaged and would require repair or removal from service. Licens-ce repaired the steam generators using a kinetic expansion technique for certain tubes and conventional plugging procedures .for other tubes. O In May 1983 Licensee submitted a request for an amendment to its license for a chang'e in the technical specifications for TMI-1 to permit the steam generators to be declared operable following repair by methods to 3_/ At the time of the Commissio.n's July 2,1979 Order, TMI-1 was shut down for refueling.
-4/ The Licensee conduct'ed the repairs pursuant to 10 CFR I 50.59. 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 rith the repaired steam generators.
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. be approved .by the NRC. Licensee also requested an amendment approv-ing 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 decision was isnued on October 31, 1984 which authorized Licensee to operate TMI-1 with steam generator tubes repaired by the kinetic expansion repair pro-cess. LB P-84-4 7, 20 NRC 1405. TMIA's appeal of that initial decision and its motion to reopen the record on :he basis of purportedly new in-formation subsequently were denied by the Appeal Board. ALAB-807, 21 NRC 1195 (1986).
On 1:ovember 6, 1985, Licensee submitted Technical Specification Change Request No. 14 8, seeking revision of the threshhold criteria (plugging criteria or repair limit) for determining when plugging or some other repair of degraded steam generator tubes is required . 5_/
Specifically, Licensee requested approval to revise the repair limit depth for limited are length defects based on maintaining the licensed margin of safety using an citernate analysis approach and considering improved de-
-5/ Licensee had earlier sought .to revise the repair limit depth without a change in the technical specifications , purportedly in accordance with the current wording of Technical Specification 4.19.4.a.6. See Letter from R.F. Wilson, GPITM, to John F. Stolz, NRC, January E .
1985. The Staff subsequently stated that the revised plugging cri-teria would not be approved without a license amendment. NRC Staff Response to Three Mile Island Alert's Formal Demand for Adju-dicatory Hearing on TMI-1 Operating License to Change Tube Plug-ging Criteria, April 15, 1985, at 4-5.
- feet ~ characterization capability, b 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 pri-or hearing on the amendment. 51 Fed. Reg. 459. On December 23, 1985, prior to the issuance of the Federal Register notice, TMIA filed an intervention petition. By Memorandum and - Order of February 12, 1986, the board in that proceeding provisionally granted TMIA's' petition for leave to intervene and provisionally ordered a hearing.
On February 4, 1986, Licensee submitted Technical Specification
. Change Request No.153, seeking approval of separate revised plugging criteria which would require plugging of any tube with an imperfection or crack depth over 50% throughwall and greater than .55 inches in length.
On February 28, 19P6, the NRC published in the Federal Register a notice entitled " Consideration of Issuance of Amendment to Facility Operating License . and. Proposed No Significant flazards Consideration Determination and Opportuni+v for IIcaring." ' 51 Fed. Reg. 7157. b On March 10,1986, TMIA filed its Petition in response to that. notice, seeking intervention. This Response is filed in reply to TMIA's March 10 Petition.
-6/ The proposed criteria are based on the total cross section of unim-paired tube remaining in the tube free span, rather than a consider-ation of throughwall depth alone. The criteria specify a repair limit of up to 70% throughwall depth for small defect lengths, decreasing.
to a 40% throughwall depth for longer defects.
~7/ In contrast to T.S. Change Request No. 148, the Staff has made a proposed no significant hazards consideration determination with re-gard to T.S. Change Request No. 153, and, if the Staff makes a (FOOTNOTE CONTINUED ON NEXT PAGE).
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B. TMIA's Request' for Hearing TMIA's Petition demands that an adjudicatory hearing be held on Licensee's T.S. Change Request No. 153, and appends an affidavit of TMIA member Katherine Pickering (Pickering Affidavit), on which TMIA 3 purportedly relies for standing in this proceeding. The Petition also e
identifies, by reference, certain aspects TMIA seeks to litigate and prof-fers five cententions (designated as Contentiene 1-5) for admission and litigation.
In the Pickering Affidavit, Me. Pickering states: 1) her residential address and that she resides approximately ten miles from TMI-1; 2) that I
she is a member of TMIA and TMIA Planning Council; 3) that, with re-spect to TS Change Request No.153, she authorizes TMIA to intervene on her behalf in . requesting a formal adjudicatory hearing; and 4) that she authorizes TMIA to litigate the issues raised by TS Change Request Fo.153 within the adjudicatory hearing already underway with respect to TS Change Request No.148. -I h
(FOOTNOTE CONTINUED FROM PREVIOUS PACE) final no significant hazards determination finding and the necessary
. safety findings, it will likely issue the amendment for T.S. Change Request No.153 before any hearing is held.
-8/ TMIA has filed a pleading, in the proceeding concerning T.S.
j Change Request No. 148, to " broaden the scope" of that proceeding to include litigation of T.S. Change Request No.153. TMIA's Motion To Broaden Hearing Scope, March 10, 1986.
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C. Requirements for Intervention .
To intervene and be made a party to the license amendment proceed-ing, a petitioner must~ demonstrate that it has the requisite interest, identifv aspects within the scope of the proceeding.as to which it wishes to intervene, and ultimately submit at least one . contention suitable for litigction. 10 C . F . R . 5 2. 714 .
- 1. Interest and Standing (a) Statutory and "ogulatory Requirements Section 189a of the Atomic Energy Act, 42 U.S.C. 5 2239(a), pro-vides that:
In any proceeding under [the] Act, - for the granting, sus-pending, revoking, or amending of any licence or construc-tion permit...the Commission shall grant a hearing upon the request of any person whose interest may be affected'.by the proceeding, and shall admit any suelP 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 to intervene." Thus the pertinent inquiry under Section 189a of the Act and 10 C.F.R. I 2.714(a) of the regulations is whether TPIIA has alleged i
an interest which may be affected by the operating license amendment proceeding. The Commission has held that contemporaneous judicial con-cepts of standing are contron ing in the determination of whether the reg-uisite interest prescribed by both Section 189a of the Atomic Energy Act and Section 2.714 of the NP.C's Rules of Practice is present. Portland General Electric Co. (Pebble Springs Nuclear Plant , Units 1 and 2),
CLT-76-27, 4 NRC 610, 613-14 (1976). There must be a showing.that (1)
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the action being challenged could cause "inju ry-in-fact" to the person seeking to intervene and (2) such injury is arguably within the " zone of
! interests" protected by the Atomic Energy Act or the National Environ-mental Poliev Act. S Id. See Warth v. Seldin, 422 U.S. 490 (1975);
Sierra Club v. Morton, 405 U.S. 727 (1972). Thus a petitioner 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.
I 2.714(c)(2).
(b) Rules of General Applicability to Organizations and Individuals a
An organization may establish standing based upon an injury to itself or through members of the organization who have interests which may be affected by the outcome of the proceerf!ng. Edlow International Co. ,
! CLI-76-6, 3 NRC 563, 572-74 (1976); Public Service Co. of Indiana, Inc.
(Marble Hill Nuclear Generating Station, Units - 1 and 2), ALAB-322, 3 NRC 328, 330 (1976). -0/ Fhen an organization claims standing based on the interests of its members , at least one of its members must have
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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 repre.sent their interests in the proceeding. Houston Lighting & Power Co. (Allens Creek Nuclear Generating Station, Unit 1).
9/ 42 U.S.C. 5 4321 et seq.
-10/ A petitioner _ must particularize a specific injury that it or its mem-bers would or might sus +ain should it be denied relief. The test is whether a "c'ognizable interest of the petitioner might be adversely affected if the proceeding has one outcome or another." Marble 11111, CLI-80-10,11 NRC 436, 439 (1980).
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ALAE-535, 9 NRC 377, 393-07 (1979); Public Service Electric & Gas Co.
(Salem Nuclear Generating Station, . Units 1 and 2), ALAB-136, 6 AEC 487, 488-89 (1973). Absent express authorization, groups may not repre-sent other than their own members, and individuals may not assert the interest of other persons. See Detroit Edison Co. (Enrico Fermi Atomic Power Plant , Unit No. 2), ALAB-470, 7 NRC 473, 474-75 n.1 (1978);
Tennessee Valley Authority (Watts Bar Nuclear Plant , Units 1 and 2),
ALAB-413, 5 NRC 1418,1421 (1977).
Generally, the close proximity of a petitioner's residence is presumed sufficient to satisfy the interest requirements of 10 C.F.R. 5 2.714.
Armed Forces Radiobiology Research Institute (Cobalt-60 Storage Facili-ty), ALAD-682, 16 NRC 150, 153 (1982); Allens Creek, 9 NRC at 393, citing, Virginia Electric & Power Co. (North Anna Nuclear Power Station, Units 1 and 0), ALAB-522, 9 NRC 54, 56 (1979). Nevertheless , since there is no presumption that every individual who lives near the plant will consider himself potentially harmed by the outcome of a proceeding, it is itnportant 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 St ation ,
Nuclear-1) , LB P-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 TMI-1 is located about 10 miles southeast of liarrisburg, Pennsylva-nia. NUREG-0680, TMI-1 Restart , at A-1. As noted above, the
Pickering Affidavit asserts that Ms. Pickering resides in Harrisburg, within ten miles of the TMI-1 facility, and authorizes TMIA to represent her interests in this proceedirw. The Petition identifies aspects and con-tains five proposed- contentions which identify issues sought to be litigat-ed; these issues sufficiently identify the nature of the alleged invasion of Ms. Pickering's personal interest. . Accordingly, . TMIA has satisfied the requirements for intervention in any adjudicatory proceeding concerning the present Tmendment request.
- 2. Specific Aspects of the Subject Platter of an Operating Licent.t i Amendment In addition to satisfying the standing and interest requirements of 10 C . F. R . 5 2.714, a petitioner must "also set forth with particularity. . .
the specific aspect or aspects. of the subject mitter of the proceeding as to which the petitioner wishes to intervene." 10 C.F.R.
5 2.714(a)(2). 3
, TMIA states that the aspects it seeks to litigate include "those which the Licensing Board has already found sufficient regarding Tech Spec.
Change Request 148" and which apply equally to the instant proposed amendment. Petition at 1. b Indeed, TMIA has also submitte'd five preposed contentions, and, for the reasons which follow, the Staff sup-F 11/ An " aspect" is generally considered to be broader than a "conten-tion," but narrower than a general reference to the 'NRC's operating statutes. Consumers Power Co. (Midland Plants, Units 1 and 2),
LBP-78-27, 8 NRC 275, 278 (1978).
- 12/ These aspects are: cause of tube degradation, adequacy of eddy current testing, and impact on leakage criteria. Memorandum and i Order, February 12, 1986, at 7-10.
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ports admission of three of those fiv'e proposed contentions.13,/. These admissible contentions appear to identify aspects within the scope of this amendment proceeding. Consequently, the Staff is of the view that TMIA has satisfied the aspect requirement of 10 C.F.R. I 2.714.
D. TMIA's Proposed ContenHons In its Petition , TMIA proffers five contentions (designated as Contentione 1-5) for admission and litigation. In the discussion below, the Staff addresses the legal standards governing the admission of con-tentions in NRC adjudicatory proceedings, followed by the Staff's position on the admissibility of TMI A's proposed contentions.
- 1. Legal Standards Governing Admissibility of Contentions Only those contentions whin fall within the scope of issues set forth
! in the Federal Register notice of opportunity for hearing and comply 'with the requirements of 10 C.F.R. 3 2.714(b) and applicable Commission case law may be admitted for litigation in NRC licensing proceedings. See, eg, Commonwealth Edison Co. (Zion Station, Units 1 and 2), ALAB-616, 12 NRC 419, 426 (1980).
Purruant to 10 C.F.R. 8 9.714(b), a petitioner is required to fise "a list of contentions which petitiner seeks to have litigated in the matter, ar.d the bases for each contention set forth with reasonable specificity."
i 13/ Cf. NRC Staff Response To TMIA's Supplement To Petition To Inter -
vene [in T.S. Change Request 148), filed March 20, 1986, in .which
, the Staff supports admission of three of the five proffered conten-tions on T.S. Change Request 148, which are virtually identical to the contentions proffered by TMIA in this proceeding.
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_ _ _ . _ . _ . _ . _ _ . _ . _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ . _ _ _ . _ _ _ _ _ _ . . . _ _ - _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ ~ .-_ _ _ _ _ _ _ _ . - _ _ _ _ - _ . - _
A petitioner who fails to file a least one contention which satisfies the requirements of f 2.714(b) will not be permitted to participate as a party.
A proffered contention must be rejected. where:
(1) it constitutes an attack on applicable statutory.
requirements; (2) it- challenges the basic structure of the Commission's regulatory process or is an attack on the regulations; (3) it is nothing more than a' generalization regarding the .
Petitioner's view of what sp;1! cable policice ought to be; j
(41 ft seeks to raise an issue which is not proper for adjudi-cation in the proceeding or does not apply to the facility in question; or (5) it seeks to raise an issue which is not concrete or litigable.
Philadelphia Electric Co. (Peach Bottom Atemic Power Station, Units 2 and 3), ALAB-216, 8 AEC 13, 20-21 (1974). The purpose of the basis re-quirement of 10 C.F.R. 5 2.714(b) is: (a) to assure that the matter sought to be put into question does not suffer from any of the infirmities listed above; (b) to establish sufficient foundation to warrant further inquiry into the subject matter; and (c) to put the .other parties suffi-ciently on notice "so that they will know at least generally what they will have tc defend against or oppose." Id. at 20. b .
14/ The basis for contentions must be 'sufficiently detailed i specific:
(s)-to demonstrate that the issues raised are admissible had further inquiry into the matter is warranted; and (b) to put the parties on notice as to what they will have to defend against or oppose. This is particularly important where, as here, a hearing is not mandato-ry, in order to assure that an asserted contention raises an issue which clearly is open to adjudication. Cincinnati Gas & Electric Co.
(William II. Zimmer Nuclear Power Station), ALAB-305, 3 NRC 8,12 (1976); Gulf States Utilities Co. (River Bend Station, Units 1 and 2), ALAB-183, 7 AEC 222, 226 (1974).
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- 2. Proposed Contentions
, TMIA's proposed Contention 'l states:
CONTENTION 1. Neither the Licensee nor the NRC Staff
!. have (sic) demonstrated that allowing degraded tubes to re-3 main in service under the proposed revised plugging. criteria j will provide reasonable assurance that TMI-1 can operate without endangering the public health and safety, because the form and rate of new tube degradation has not been j . determined.
Contention 1 allegen that there in no renannabla maauranca that TMI-1 con operate without endangering the health and safety of the public, because the form and rate of "new tube degradation" has not been deter-
-mined. Although TMIA does 'not state what it means by "new tube degradation," the issue of "new tube degradation" has been raised by TMIA previously, in the context of a motion to' reopen the record in the previous Steam Generator Repair proceeding, where TMIA claimed that corrosion had been reinitiated. b The Staff assumes that TMIA is using the term consistently with its prior use.
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-15/ Subsequent to the kinetic repair - of the steam generator tubes at TMI-1, during eddy current testing (ECT) following - hot functional tests in 1984, some 327 tubes had indications of- greater than' 40%
throughwall degradation. This gave rise to ~a concern as to whether there was a new corrosion process occurring in the steam generator, or whether the previous intergranular stress corrosion cracking (IGSCC) -was continuing. Applicant determined that ' the new ECT .
indications were the result of intergranular attack '(IGA) pitting that occurred at the same time as the IGSCC in 1981, but that was not previously ~ detectable. The Appeal Board in the Steam Generator Repair proceeding, in' response ' to TMIA's motion to reopen the record, ruled that the asserted "new tube degradation" being identi-fled was due to IGA ~ and was not in fact new degradation, but grain dropout resulting from previously identified degradation. ALAB-807, 21 NRC 1195,1207. That ruling does not, however,- bear on wheth- ,
er Tf11A has raised a litigable issue for the purpose of admissibility-'
of Contention 1.
. If the Staff's assumption regarding TMIA's use of the term "new tube degradation" is correct, the Staff is of the opinion that the conten-tion raises an issue within the scope of the proceeding, is adequately specific and is supported by a minimally sufficient basis. The Staff sup-
- I. orts admission of the contention provided that the referenced "new tube degradation" is as indicated above and the contention is limited to the
! basin asserted.
TMIA's proposed Contention 2 states:
CONTENTION 2. Neither the Licensec nor the NRC Staff have (sic) demonstrated that allowing. degraded tubes to re-main in service under the proposed revised plugging criteria will provide reasonable. assurance that TMI-1 can operate without endangering the public health and safety, because the testing technique relied upon to define degraded tubes in (sic) inaccurate and inconclusive, in light of .the particular method of degradation, is uncertain.
j Contention 2 asserts that the testing techniques relied on (eddy cur-l 1
rent testing) to define degraded tubes is inaccurate and inconclusive in i
light of the "particular method of degradation." Because of the vague-ness. of the wording of the contention, the Staff is uncertain as to what TMIA neans by "particular method of degradation" -- whether TMIA is referring to IGSSC, or to IGA, or asserting that another (unspecified) nothod of degradation has occurred or is occurring. Thus, it is not clear whether TMIA is raising a sluestion as to the method of degradation,
- as well as challenging ~the testing technique. In short, this contention, t as currently worded, is not sufficiently specific nor supported by partic-ularized bases to give adequate notice of the issues which are to be liti-gated by this contention. Consequently, the Staff believes Contention 2, I
a's drafted, should be rejected for falhtre to put the parties on notice as to what will be litigated.
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'. CONTENTION 3. Neither the Licensee nor the NRC Staff have (sic) demonstrated that allowing. degraded tubes to re-main in service under the proposed revised plugging criteria,
, which could contribute to the frequency of leakage during plant operations, is consistent with the requirements of l
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CDC 32, " Inspection of Reactor Coolant Pressure Boundary," pro-vides that components of the reactor coolant pressure boundary must be designed to permit 1) inspection and testing of important features and 2) an appropriate material surveillance program for the reactor pressure ves-sel. TP. IIA has demonstrated no nexus between the requirements of GDC 37 and the instant proposed revised steam generator tube plugging
] criteria. Indeed , the Staff can see no nexus whatsoever between the i GDC 32 requirements and the instant amendment request, which does not affect existing inspection and surveillance programs. Thus, Contention 3 should be rejected for failure to raise an issue within the scope of this proceeding.
4 TMIA Contention 4 states:
CONTENTION 4. Neither the Licensee nor the. NRC staff have (sic) demonstrated that allowing degraded tubes to re-main in service under the proposed revised plugging criteria, is consistent with the requirements of GDC 31, in that the criteria does not take into account environmental effects, in-cluding possible environmental corrosion even in the absence
- of active corrosion mechanisms.
Contention 4 asserts that allowing degraded tubes to remain in ser-i i vice under the proposed revised plugging criteria has not been shown to I
be consistent with GDC 31, because the proposed criteria do not take into I account environmental effects even if there are no active corrosion 1
mechanisms.
As framed , the contention raises an issue within the scope of the
] proceeding, is adequately specific and is supported by a minimally i
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sufficient basis . Accordingly, the Staff supports the admission of Contention 4.
i TMIA Contention 5 states:
CONTENTION 5. Neither the Licensee nor the NRC Staff have (sic) demonstrated that allowing degraded tubes to re-main in service under the proposed revised plugging criteria is consistent with Reg. Guide 1.121, which requires that plugging criteria take into account variations in tube thick-ness due to possible corrosion.
Contention 5 alleges that it has not been demonstrated that allowing tubes to remain in service under the proposed revised plugging critoria is consistent with Reg. Guide 1.21, which provides that plugging criteria must contain an operational degradation allowance to take into account veriations in tube thickness due to possible corrosion.
As framed, the contention raises an issue within the scope of the proceeding, is adequately specific and is supported by a minimally'suffi-
. cient basis. Accordingly, the Staff supports the admission of Contention 5.
i III. CONCLUSION TMIA's Petition establishes TMIA's interest and standing as required i by 10 C.F.R. I 2.714, and adequately identifies aspects as to which TMIA wishes to intervene. Accordingly, TMIA should be admitted as a party in i
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, 16 this proceeding. Proposed Contentions 2 and 3 are inadmissible in.their present form and should be rejected. However, Contentions 1, 4 and 5 raise matters within the scope of the proceeding, and supported with min-imally adequate bases, and should be admitted for litigation.
Respectfully submitted, k
2 f.farv E. Nastner /l Cou'nselhor"NRC @taff -
Daterl at Bethesda, Maryland this 25th day of March,1986 I
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TINITED STATES OF AMERICA NUCLEAR REGULATORY- COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING DOARD in the Matter of )
)
PIETROPOLITAN EDISON CCPIPANY, ) - Docket No. 50-289 OLA-2 ET AL. ) (Steam Generator Plugging (Three Mile Island Nuclear ) Criteria)
Station, Unit No.1) )
CERTIFICATE OF SERVICE I hereby certify that copics of "NRC STAFF RESPONSE TO TMIA'S FORMAL DEMAND FOR ADJUDICATORY HEARING ON AMENDMENT TO TMI-1 OPERA-TING LICENSE TO CIIANGE TUBE PLUGGING CRITERIA" in the above-captioned proceeding have been served on the following by. deposit 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 express mail, this 25th day of Pfarch,1986:
- Sheldon J. Wolfe, Chairman
- Bruce W. Churchill, Esq.
Administrative Judge Shaw, Pittman, Potts a. 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 -
- Frederici: J. Shon Atomic Safety & Licensing Appeal Administrative Judge Board Panel Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission j U.S. Nuclear Regulatory Commission Washington, DC 20555 i Washington, DC 20555
- Joanne Doroshow Docketing & Service Section 1 TMI Alert Office of the Secretary i 315 Peffer Street U.S. Nuclear Regulatory Commission i fiarrisburg, PA 17102 Washington, DC 20555 l
- Louise Bradford l 1011 Green Street I Harrisburg, PA 17102 l Mary /7. Wagnero Coup for NRC Staff
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