ML20211N960
| ML20211N960 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/09/1986 |
| From: | Conner T CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#386-938 OL, NUDOCS 8607110143 | |
| Download: ML20211N960 (17) | |
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i DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULA'IORY COM4ISSION 3 at to N130 FFICE OF SECR 1AkY Before the Ccmnission OCKETjigE VICl.
In the Matter of )
)
Philadelphia Electric Ccapany ) Docket Nos. 50-352 g
) 50-353 (Limerick Generating Station, )
Units 1 and 2) )
LICELMEE'S ANSWER 'IO PETITION BY FRIENDS OF THE EARTH 'IO REOPEN THE RECORD AND REQUEST EDR SANCTIONS Preliminary Statement In a petition filed June 24, 1986, intervenor Friends of the Earth
("EOE") has sought to reopen offsite emergency planning hearings in the
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operating license proceeding for the Limerick Generating Station J
j (" Limerick"). EVE also seeks to disqualify counsel for Licensee Philadelphia Electric Cmpany (" Licensee") frm the proceeding. FOE's request stas frm a memorandum frm William L. Clements, Chief, Nuclear Regulatory Ccmnission Docketing and Service Branch, dated June 2,1986, !
which is discussed below.
I Although EOE's petition is addressed jointly to the Comission and the presiding Atmic Safety and Licensing Appeal Board (" Appeal Board"),
only the comission has jurisdiction to reopen the emergency planning i
phase of hearings in which EVE participated. EDE's petition for review 4
of AIAB-836, which pertains to that phase, is now pending before the ccmnission. In any event, EVE has totally failed to show that any .
l significant safety issue exists or that any safety issue would be [
g7110143860709 G ADOCK 05000352 m PDR n g}
decided differently as a result of reopened hearings. Finally, NE has shown no basis for disqualification of Licensee's counsel or any other sanction.
Argunent I. Only 'Ihe Cmmission Has Jurisdiction To Reopen The Proceeding On EDE's anergency Planning Contention.
Because EOE has sought relief before the Appeal Board as well as the Cmmission, Licensee first discusses why only the Comission has jurisdiction to consider EDE's request for relief. As the Ageal Board noted in ALAB-836, EDE's only contention related to offsite emergency planning, EDE Contention 1, was cmbined with Limerick Ecology Action
(" LEA") Contention 24. The joint contention asserted:
1 There is no assurance that plans for evacuation of j the ten mile radius will not be i_n-AM by traffic
.I congestion in the vicinity of Marsh Creek State Park, Exton area (involving Route 100) and Valley i Forge Park, King of Prussia area. These areas j should either be included in the Emergency Planning Zone or adequate plans for traffic control and direction should be made to avoid adverse effects on EPZ evacuation.1/
In ALAB-836, the Appeal Board rejected each of LEA's and EDE's claims on appeal relating to their joint contention, except for the establishment cf an additional traffic control point.2/ The Appeal i
1_/ Philadelphia Electric Cmpany (Limerick Generating Station, Units 1 (May 7, 1986) (slip op. at 16-17
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and 2) , ALAB-836, 23 NBC n.19) .
2_/ In this regard, the Appeal Board directed that traffic control measures be established in the area of Route 100 and the
! Downingtown interchange of the Pennsylvania Turnpike. d . at
,I_d 24-26.
. _ _ . . .. _ _ . _ _ - .~- _
e Board rejected LEA's and NE's remaining arguments as to the adequacy of traffic control for areas adjacent to the EPZ,- the size of the plume exposure emergency planning zone ("EPZ"), including the role of the Federal Emergency Management Agency ("FENA") in sizing the EPZ, and emplaints as to limits upon cross-examination.5_/
Except for one issue on remand unrelated to NE's contention- and other unrelated contentions pertaining to the State Correctional Insti-tution at Graterford still pending review, AIAB-836 ruled upon all intervenors' contentions relating to offsite emergency planning and preparedness for Limerick. Petitions for review have been filed by Licensee and WE with the Ccmnission. By Order dated June 24, 1986, the Ccmnission extended the time within which it may act to review AIAB-836 until July 25, 1986.
Under the circumstances, the subject of NE's motion to reopen is currently pending before the Ccmnission. Conversely, it is well settled that the Appeal Board does not retain jurisdiction over issues it has decided and therefore lacks jurisdiction on a mott.on to reopen the record on decided issues, absent a reasonable nexus to sme discrete 3/ Id. at 16-23.
4/ Id. at 26-32.
5/ Id. at 32-36.
1 6/ The Appeal Board reversed the finding below of reasonable assurance as to a sufficient number of bus drivers willing to respond during i an emergency at Limerick, insofar as the Spring-Ford and Owen J. l Poberts School Districts are concerned. Id. at 72.
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issue still pending before it.1/ Thus, only the Ccanission has juris-diction over N E's motion.
II. The Distribution Of The legal Monograph Was Not An Ex Parte Ccmnunication.
ME cites a recently published legal monograph as cause to disqual-ify Licensee's counsel and reopen the instant proceeding. Licensee addresses the disqualification motion first because it involves the root issues as to why receipt of the legal nonograph by certain NRC enployees did not constitute an ex parte ccmnunication or a basis for reopening.
The legal monograph cited by ME is a generic analysis of basic sergen-cy planning and preparedness issues comn to all proceedings and was not, in its transmittal to certain NBC ernployees, associated with any particular proceeding.8/
l Just like any other law review type article, the legal mnograph was widely distributed by the Washington Iegal Foundation to potentially interested readers in Congress, the Administration, major corporations, foundations, the nuclear industry and the media, as well as to the NRC and FDiA. It was also publicly available to any number of other i potentially interested individuals. Like a law review article, it was l
l 7/ See generally Iouisiana Power & Light Conpany (Waterford Steam Electric Station, Unit 3) , ALAB-792, 20 NBC 1585,1588-89 (1984) ,
clarified on reconsideration, ALAB-797, 21 NBC 6, 8 (1985);
Metropolitan- Edison Ccmpany (Three Mile Island Nuclear Station, Unit No. 1) , ALAB-766, 19 NBC 981 (1984); Waterford, supra, ALAB-753,18 NBC 1321,1329-30 (1983) .
l 8_/ See R. Rader, "Offsite Dnergency Planning for Nuclear Power Plants:
A Case of Governmental Gridlock" (Washington Imgal Foundation, April 1986) (hereinafter " legal monograph") . Mr. Rader is a nenber of the firm of Conner & Wetterhahn, P.C., counsel for Licensee.
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an exposition of the state of the law with recomendations for inprovements based upon the author's insights from particular cases.
Also like a law review article, the legal monograph discussed recent decisions as a means of dmonstrating why basic changes in the law applicable to all proceedings should be effected. The legal monograph is indistinguishable frcm the hundreds of law review texts and similar journals found on the shelves of judges' libraries and in their chambers.
Thus, the legal monograph was not an g parte comunication irre-spective of whether or not it was received by certain NPC ertployees. To be g parte under the rule, the ccumunication must present facts or argument in an effort to persuade the decisionmaker as to the outccme, i.e., the " merits," in a particular proceeding. None of this is present here. The monograph discusses nothing but the facts of record in the i cases discussed and expresses points of view on issues of generic application. Scme of the subjects discussed, for exanple, reduction of the 10-mile plume exposure emergency planning zone and environmental analysis of severe accidents, have been the subject of Ccarmission rulemaking and policy statements.
To consider such material as g parte is specious. Otherwise, the Comission's adjudicatory personnel could not read trade publications, NPC staff papers or even the public press, all of which comonly discuss the viewpoints of the nuclear industry, opponents of nuclear power and I the NPC Staff. Reductio ad absurdum, a member of a board or. a Ccarmis-l sioner could not even discuss such generic subjects with a colleague.
As far as counsel is aware, there are two documents which relate to the legal monograph's status before the Ccunission. In a letter dated
2 o-May 19, 1986 to the Washington Legal Foundation, Alan S. Rosenthal, 5 Chairman, Atmic Safety and Licensing Appeal Panel, stated that he
" appreciated your courtesy in sending me a copy" of the monograph, but did not, however, suggest that any g parte canunication had been made.1/ The second document is a memorandum dated June 2, 1986 frm William L. Clements, Chief, Docketing and Service Branch, forwarding a copy of the legal monograph to the boards and parties in this and two i
l other cases. Mr. Clements' memorandum states only that the Office of I
the General Counsel finds that the monograph falls within the prohibi-tion of 10 C.F.R. S2.780 because it " presents arguments on several issues which are currently in litigation in the above-mentioned proceed-ings." 'Ihe menorandum provided no analysis or opinion frm the Office of the General Counsel supporting its conclusion. As noted, Licensee
- finds the legal monograph indistinguishable frm public statements by
- industry spokesmen, anti-nuclear groups, Congressmen and other various groups and individuals, including intervenors in NPC licensing proceedings.
The prohibition against g parte cmmunications is contained in 10 C.F.R. 52.780. As the Appeal Board is aware, the Ccmmission has i
9/ Mr. Rosenthal complained that Mr. Rader had not disclosed his representation of utilities in proceedings before the NBC and, in particular, his association with the Limerick proceeding. Mr.
Rader's original subnission of the monograph to the Washington Legal Foundation for publication in fact included a biographical i sketch which stated that his law practice includes the licensing of '
nuclear power reactors. The Foundation misplaced this page, as it i was not included in the final publication. Although requested by 4
Mr. Rader to send out the biographical information to anyone who had been sent the monograph, the Foundation has not done so.
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recently proposed a new regulation governing ex parte comunications to clarify the rights and obligations of parties and Cmmission adjudica-tory enployees under the rule.10/ The proposed rule provides consider-able insight because it expressly states that prohibited ex parte comunications " relevant to the merits of the proceeding"E excludes, inter alia:
Comunications regarding generic issues involving public health and safety or other statutory respon-sibilities of the agency (e.g., rulemakings, con-gressional hearings on legislation, budgetary planning) not associated by the Cmmission adjudica-tory enployee or the interested person with the resolution of any proceeding under this subpart pending before the NRC.R/
Ac noted in the proposed rule, this exclusion corresponds to the exclu-sion under the existing rule of comunications concerning "[g]eneral health and safety problems and responsibilities of the Camission."El In explair.ing its proposed reworded exenption for discussion of generic health and safety issues, the Cm mission makes it clear that the proposed rule, like the rule previously proposed in 1979, was intended to allow an exposition of differing views on generic health and safety issues as long as the comunication was not "a means of circumventing 1,0/
0 See Revision to Ex Parte and Separation of Functions Rules Applicable to Fonnal Adjudicatory Proceedings, 51 Fed. Reg.10393 (March 26,1986) . The Camission has exten. led the coment period in the rulemaking proceeding. 51 Fed. Reg.19067 (May 27,1986) .
M/ 10 C.F.R. 52.780(a), as proposed, 51 Fed. Reg. at 10401.
M/ 10 C.F.R. 52.780(f) (4) , as sproposed, 51 Fed. Reg. at 10401.
the adjudicatory process."El In other words, a discussion off the record with adjudicatory employees of generic health and safety issues, such as emergency planning and preparedness, is permissible as long as neither the writer nor adjudicatory enployee " associates" the ccumunica-tion with the resolution of specific issues in a pending proceeding.E The legal monograph is precisely this kind of permissible generic discussion. Whether or not one shares the views expressed, it is evident to any disinterested reader that the author's objective is not j to influence the outccane of any particular proceeding, but rather to j discuss a basic restructuring of the roles of the NBC and FEMA in evaluating and approving offsite emergency plans, in part, by eliminat-ing hearings before the NBC or reducing the areas of contention in l hearings. The monograph is therefore indistinguishable frcan any number of similar articles in law reviews, trade and industry journals, or legal and scientific publications to which the Ccannissioners and their adjudicatory splayees routinely have access and presumably read as a matter of scholarly interest. It would be unfortunato if vigorous debate over the Comnission's regulatory requirements in such publica-tions were to be stifled by the constant threat of accusations that an g parte comnunication has been made.
'Ihe Appeal Board long ago determined that a licensing board man-ber's authorship of a publication which generically discusses I
l 1_4/ 51 Fed. Reg. 10397.
15/ Such adjudicatory issues "are to be resolved solely on the basis of the factual record and applicable law and policy." Id.
adjudicatory issues does not require his disqualificaticn. In the Midland proceeding, the Appeal Board held that a law review article by a licensing board msnber which analyzed the inpact of the National Environmental Policy Act on reactor licensing did not evidence any personal bias or prejudgnent of enviromental issues before the board in that case.E Like the legal monograph, the law review article in Midland questioned the workability of NBC licensing procedures.E But the Appeal Board concluded that a board msnber's expression of such views were not disqualifying:
Reviewing the entire law review article, . . . we find no evidence of prejudgment of any facts in issue. Nor do we find any appearance of prejudg-ment. All that we find is an individual who may have certain crystallized views -- indeed, who may possess an " underlying philosophy" - on the appli-cetion of NEPA to the Cmmission's licensing pro-cess. Previous decisions of this Board and the Ca mission have explicitly recognized this situation asnondisqualifying.18]
16f Consumers Power Cmpany (Midland Plant, Units 1 and 2), AIAB-101, 6 AEC 60 (1973).
-17/ As the Appeal Board observed, "the article expressed skepticism regarding whether the requirments of NEPA could be fulfilled in the existing licensing process." Midland, supra, ALAB-101, 6 AEC at 65. The Appeal Board ruled that "the exposition of such thoughts [by a hearing officer in a published article) was sanctioned by the Supreme Court" in United States v. Morgan, 313 U.S. 409 (1941) (Secretary of Agriculture not disqualified frcm participating in proceeding on remand where he had publicly 1 criticized the court decision ordering the remand) and FIC v.
Cement Institute, 333 U.S. 683 (1948) (permitting PIC members to participate in a proceeding despite previous expression of views in reports to Congress and in Congressional testimony on the subject of the hearing). M.
18] d at 66 (footnote cmitted) .
I_d.
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_ 10 _
More recently, the Appeal Board quoted this passage frm Midland with approval in rejecting the same argument in the Shoreham proceeding.E!
If authorship of a law review article on reactor licensing issues does not disqualify a board nonber frcxn hearing the case, it is surely unobjectionable for the member to read such an article off the record in the course of a licensing proceeding. NBC Ccmnissioners and administra-tive judges are not flabby creatures any more than judges . . . . Both may have an underlying philosophy in approaching a specific case . ... Both are . . . men of con-science and intellectual discipline, capable of judging a particular controversy fairly on the basis of its own circumstances."20/
The legal monograph is also analogous to position papers prepared by the NBC Staff which discuss individual proceedings in the context of principles or policies generically applicable to all nuclear power plants. In the Three Mlle Island proceeding, the Ccmnission rejected an intervenor's allegation that the Ccmnission's review of such documents constituted an ex parte ccumunication by the Staff. The Ccmnission stated:
Finally, SKY-82-111, 111A and 1118 involve proposed energency response capability requirements for all plants. Nothing in these documents relates uniquely to 'IMI-1. Discussions of "[g]eneral health and safety problens and responsibilities of the Com-missions" are not ex parte. 10 CFR 2.780(d) . These generic discussionls which did not arise frcan and l
l 19,/ See Iong Island Lighting Ccxnpany (Shoreham Nuclear Pcuer Station, l Unit 1) , ALAB-777, 20 hTC 21, 34 (1984) . l l
2_0/ Midland, supra, ALAB-101, 6 AEC at 64, quoting United States v. '
Morgan, 313 U.S. at 421.
are not directly related to the Postart proceeding, are not ex parte.21/
i Assuming arguendo that the legal monograph were encmpassed by Section 2.780, Mr. C1m ents has already furnished a copy of the document to each of the parties and board mernbers in the proceedings deemed to be affected.b Further action is unjustified and unnecessary.
III. NE Has Not Met 'Ihe Requirments For Reopening A Closed Record.
i NE's request to reopen the proceeding on offsite emergency plan-ning is deficient on its face. Its thrust is sinply to state strong disagreement with the views expressed in the legal monograph which, as noted, has been distributed to a wide range of potentially interested l
readers in the private and public sectors, including the NRC. Nowhere does ME explain how the opinions and conclusions expressed in the monograph constitute a significant safety matter. Nor does EE even state what " evidence" it wishes to present which it believes would change the outcme of the proceeding. In short, NE has failed to assert, much less demonstrate, the existence of any significant safety matter and it has not dernonstrated why the outcme of reopened hearings 1,
would be any different.
As the Appeal Board is aware, the ccanission has recently adopted a j new rule in 10 C.F.R. 52.734 which institutionalizes the three tradi-i i tional requirements for reopening a closed record:
j 21/ Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit 1) , CLI-83-3,17 NBC 72, 74 (1983) .
,2_2 2 / Both the existing rule in 10 C.F.R. 52.780(b) and the proposed rule (Footnote Continued)
o 1
(1) The motion must be timely, except that an exceptionally grave issue may be considered in the discretion of the presiding officer even if untimely presented.
(2) The motion must address a significant safety or environmental issue.
(3) The motion must demonstrate that a materially different result would be or would have been likely had the newly proffered evidence been considered initially. 2_3/3 Even if ME's request is deemed timely, it clearly fails to meet the remaining two criteria for reopening. First, ME has failed to assert any significant safety issue. It is true that " workable emergen-cy plans to protect the health and lives of the public in the area surrounding the Limerick plant in the event of a nuclear accident are essential,"E but this unrearkable proposition does not shw hw the distribution of the legal nonograph created any significant safety issue. No evidence of any safety problen has even been alleged EI (Footnote Continued) in subsection (c) state that a written ex parte ccumunication shall be served on the parties and placed E the public record of the proceeding.
_2_33 / 10 C.F.R. S2.734 (a) (1)-(3) . The criteria stated in the regulation derive frm long accepted standards under NBC case law. See Cleveland Electric Illuminating Cmpany (Perry Nuclear Pwer Plant, Units 1 and 2) , CLI-86-07, 23 NFC 233, 235 (1986). Licensee believes tnat the regulation is controlling, even though it became effective several days after the filing of the petition by EE, because the Camission and its adjudicatory boards, like courts, are required to follw the procedural rules in place at the time they are called upon to act. Thorpe v. Housing Authority, 393 U.S.
268, 281-82 (1969).
M / E E Petition at 2.
"'"25/ See 10 C.F.R. S2.734(b). In Pacific Gas and Electric Cmpany (Diablo Canycn Nuclear Power Plant, Units 1 and 2), ALAB-775, 19 (Footnote Continued)
Further, there is no showing by FOE that the outcme of the prt>-
ceeding would be different if hearings were reopened. Its claim that the hearings and the appellate process were smehow affected is untena-ble. The monograph was published well after empletion of hearings and the issuance of the Licensing Board's decision on ME's single mergency planning contention. There is no evidence that any member of either the Licensing Board or Appeal Board in the Limerick proceeding has even read the legal monograph, nuch less read or been influenced by it prior to j
decisionmaking.E In view of Mr. Clments' letter, the Cmmissioners
- have presumably received appropriate guidance frm the Office of the General Counsel as to any possible restriction under 10 C.F.R. S2.780 applicable to the monograph.
In any event, NE has failed to show any relationship whatsoever between its claims before the Appeal Board and the Cmmission on its
, contention and any discussion in the monograph. Hence, NE has not demonstrated that any different result or conclusion would be reached if hearings were reopened.
l (Footnote Continued)
NBC 1361, 1366-67 (1984), the Appeal Board stated that, at a minimurn, "new material in support of a motion to reopen nust be set forth with a degree of particularity in excess of the basis and specificity requirements" for admitting contentions and "must be tantamount to evidence," i.e., "it must possess the attributes set forth in 10 C.F.R. 2.RT(c) defining admissible evidence for adjudicatory proceedings."
26/ To our knowledge, the Cmmissioners and the Chairmen of the Appeal Board and Licensing Board Panels were the only adjudicatory enployees to whcm the monograph was distributed. The exact date is j unknown, but it is believed that the monograph was mailed to those !
4 individuals on or about May 1, 1986.
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l Conclusion For the reasons discussed above, EOE has failed to meet the re-quirements for reopening the proceeding and has shown no basis for
'l disqualifying Licensee's counsel.
Respectfully subnitted, 4
CDNNER & WEITERHAHN, P.C.
T% %.Guw,3r.[NU Troy B. Conner, Jr.
Mark J. Wetterhahn Nils N. Nichols t
- July 9, 1986 l
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1
r 00LKETED USNRC UNITED STATES OF AMERICA g 3.10 N1:30 NUCLEAR REGULATORY COMMISSION lA In the Matter of ) {FF{
9 Q3fpyg$g,
) BRANCH i
Philadelphia Electric Company ) Docket Nos. 50-352
) 50-353 s (Limerick Generating Station, )
Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Answer to Petition by Friends of the Earth to Reopen the Record and Request for Sanctions," dated July 9, 1986 in the captioned matter have been served upon the following by deposit in the United States mail this 9th day of July, 1986:
Samuel J. Chilk, Secretary Christine N. Kohl, Chairman Office of the Secretary Atomic Safety and Licensing U.S. Nuclear Regulatory Appeal Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 a Lando W. Zech, Jr. <
Chairman U.S. Nuclear Dr. Reginald L. Gotchy Regulatory Atomic Safety and Licensing Commission Washington, Appeal Board D.C. 20555 U.S. Nuclear Regulatory Commission Thomas M. Roberts, Washington, D.C. 20555 Commissioner U.S. Nuclear Regulatory Gary J. Edles Commission Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board U.S. Nuclear Regulatory James K. Asselstine, Commission Commissioner Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l Frederick M. Bernthal, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i
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Helen F. Hoyt, Esq. Atomic Safety and Licensing Chairperson Appeal Panel Atomic Safety and U.S. Nuclear Regulatory Licensing Board U.S. Commission Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Docketing and Service Section Office of the Secretary Dr. Richard F. Cole U.S. Nuclear Regulatory Atomic Safety and Commission Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory
! Commission Ann P. Hodgdon, Esq. Counsel Washington, D.C. 20555 for NRC Staff Office of the Executive Dr. Jerry Harbour Legal Director Atomic Safety and U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Angus Love, Esq.
107 East Main Street Atomic Safety and Licensing Norristown, PA 19401 Board Panel U.S. Nuclear Regulatory Robert J. Sugarman, Esq.
Commission Sugarman & Hellegers Washington, D.C. 20555 16th Floor, Center Plaza 101 North Broad Street Philadelphia Electric Company Philadelphia, PA 19107 ATTN: Edward G. Bauer, Jr.
Vice President & Director, Pennsylvania i General Counsel Emergency Management Agency 2301 Market Street Basement, Transportation
! Philadelphia, PA 19101 and Safety Building Harrisburg, PA 17120 Mr. Frank R. Romano 61 Forest Avenue Kathryn S. Lewis, Esq. City of Ambler, Pennsylvania 19002 Philadelphia Municipal i
Services Bldg. 15th and JFK Mr. Robert L. Anthony Blvd. Philadelphia, PA 19107 Friends of the Earth of the Delaware Valley 106 Vernon Lane, Box 186 Moylan, Pennsylvania 19065 f
4 s
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4 Charles W. Elliott, Esq. Spence W. Perry, Esq.
325 N. 10th Street Associate General Counsel Easton, PA 18042 Federal Emergency Management Agency Phyllis Zitzer, Esq. 500 C Street, S.W., Rm. 840 Limerick Ecology Action Washington, DC 20472 P.O. Box 761 762 Queen Street Thomas Gerusky, Director Pottstown, PA 19464 Bureau of Radiation Protection Barry M. Hartman, Esq. Department of Environmental Deputy General Counsel Resources Commonwealth of 5th Floor, Fulton Bank Bldg.
Pennsylvania Third and Locust Streets P.O. Box 11775 Harrisburg, PA 17120 Harrisburg, PA 17108 James Wiggins Jay M. Gutierrez, Esq. U.S. Senior Resident Inspector Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission 631 Park Avenue P. O. Box 47 King of Prussia, PA 19406 Sanatoga, PA 19464 l
Timothy R.S. Campbell Mr. Ralph Hippert Director Pennsylvania Emergency
- Department of Emergency Management Agency Services B151 - Transportation
! 14 East Biddle Street Safety Building West Chester, PA 19380 Harrisburg, PA 17120 Theodore G. Otto, Esq.
Department of Corrections Office of Chief Counsel P.O. Box 598 Lisburn Road Camp Hill, PA 17011 g
Nils N. Nichols