ML20212P151
| ML20212P151 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/04/1987 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 2331, NUDOCS 8703160005 | |
| Download: ML20212P151 (17) | |
Text
{{#Wiki_filter:m e e 'Af f (412) 393 6000 one Oxford Centre 301 Grant Street Pittsburgh, PA 15279 March 4, 1987 CERTIFIED MAIL Director of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission 1717 H Street, N.W. Washington, D.C. 20555 Re: Notice of Demand by the Environmental Protection Agency Under 42 U.S.C. 55 9601 et. seq., Nuclear DisDosal Site, Morehead, Flemina County. Kentucky
Dear Sir or Madam:
Duquesne Light Company (the " Company") has received notice under the captioned statute that it is a potentially responsible party ("PRP") for costs related to response or remedial action taken and planned by the Environmental Protection Agency (" EPA") in connection with the captioned waste disposal site. A copy of the notice from EPA and the attachments to the notice is appended as Attachment A. Upon receipt of the notice, the Company determined that the materials which were or may have been sent to the captioned disposal site were generated, received, shipped or otherwise employed by the Company in connection with the performance of government contracts. In performing these contracts, the Company employed government-owned materials. Accordingly, by contract and regulation, the government at all times retained title to the radioactive contaminants and wastes generated in these operations. The Company's contracts contained or were subject to various indemnification agreements, including indemnification against public liability authorized by the Price Anderson Act. See 42 U.S.C. 55 2014, 2210(d) (1982). The Company also may be indemnified as a processor of government-owned and furnished nuclear material produced by the Atomic Energy Commission or Nuclear Regulatory Commission (NRC) licensees who had entered into indemnification agreements in connection with the operation of production and utilization facilities. See 42 U.S.C. 55 2133, 2134, 2210(c) (1982). As a result, this company is a " person indemnified" within the meaning of the Price Anderson Act. See 42 U.S.C. 5 2014(t) (1982). O ddh# d 8703160005 870304 PDR ADOCK 05000334 If 8 ll 7 PDR l
Director of Nuclear Material Safety and Safeguards Page 2 March 4, 1987 The attached notice of demand, which may create legal liability arising out of or resulting from a " nuclear incident," may result in "public liability" within the meaning of the Price Anderson Act. See 42 U.S.C..5 2014(w). A " nuclear incident" is defined as "any occurrence. . causing. loss of or damage to property, or loss of use of property, arising out of or resulting from the radioactive, toxic, explosive, or other hazardous properties of source, special nuclear, or by-product material. ." 42 U.S.C. I 2014(q). As a PRP for costs related to response or remedial action taken and planned by EPA, the Company may be required to take affirmative and costly action. In addition, the issue of responsibility for the costs ultimately may be committed to the federal courts for determination. Because EPA's claims are premised solely upon the occurrence of a nuclear incident, any judgment against the company or expenditures required of the Company would result in public liability within the meaning of the Price Anderson Act. See 42 U.S.C. I 2014(w) (1982). In light of the foregoing, this letter, in accordance with 10 C.F.R. I 140.6, constitutes written notice of a claim for property damage arising out of or in connection with the possession or use of radioactive materials. Should you have any questions concerning this matter or should you wish to discuss the issues raised in this letter; please contact me. Sincerely yours, tw l u AL. hn D. Sieber ice President - Nuclear
jto 84g [O 4 ){ I ,,, UNITED STATES ENVIRONMENTAL PROTECTION AGENCY , M u.. ,/ a J REGION IV ~ .i I 345 COURTLAND STREET 4WD-R *.. - ~g ? ' ATLANT A. GEOR GI A 30385 .~, CERTIFIED MAIL RETURN RECEIPT REOUESTED DUQUESNE LIGHT COMPANY N 2 6 1986 1 OXFORD CENTER PITTSBURGH, PA 15279 REF: Maxey Flats Nuclear Disposal Site Morehead, Fleming County, Kentucky
Dear Sir / Madame:
The United States Environmental Protection Agency (hereinafter E.P.A.) has spent and is considering expenditures of public funds to investigate and take corrective action for the control of releases and of threatened releases of hazardous substances at the above-mentioned site. Thisactionisbeingcadn pursuant to Section 104 and other provisions of the Comprehensive _. ~, ( Environmental Response, Compensation and Liability Act of 1980 (hereinaftsrf, referred to as CERCIA), codified at 42 U.S.C. Section 9601 s.t; agg. and ~ recently amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), P.L. 99-499 (signed by President Reagan on October 17, 1986). For your information, the key term " hazardous substance" is defined at 42 U.S.C. Section 9601 (14). Potentially responsible parties (PRPs) under CERCIA include current and former owners and operators of the disposal site, persons and entities who generated or produced the disposed of hazardous substances and who made agreements for disposal of such hazardous substances at the site, and persons and entities who were involved in the transport, treatment, or disposal of hazardous substances at the site. Under Section 107(a) of CERCIA, 42 U.S.C. Section 9607(a), under SARA, and other laws, PRPs may be liable for costs incurred by the government in taking corrective actions at the site. Such costs may include, but may not be limited to, expenditures for investigation, planning, cleanup of the site and enforcement activities. By means of this letter, EPA is giving.you notice of your potential CERCIA liability and to encourage you as a PRP to undertake voluntary cleanup activities at the above-named site; specifically.the remedial investigation and feasibility study (RI/FS) and ultimately the remedial design and remedial action (RD/RA) itself. Based upon radioactive shipping records (RSR's, gathered by EPA, the Agency has reason to believe that you may be a responsible party under CERCIA, as amended. At this time approximately eight hundred thirty-two (832) PRPs have 1
i' been linked to thgMaxey Flats Disposal Site. Attachnent A is a list of such PRPs with their current addresses. Because of the large number of PRPs and the deadline discussed below for the PRPs to tmdertake the RI/FS, EPA raccamends that the PRPs at their earliest convenience organize themselves into awring nr==ittee. It is further suggested by EPA that a steering tv==ittee spokesperson be chosen as soon as practical and that the steering committee or PRPs retain an envirorumental engineering consulting firm to study the draft workplan for the RI/FS which is included as Attachment B to this notice / demand letter. The constituted steering cramnittee, PRPs, or environmental consultants are directed to call the EPA personnel indicated below for further infonaation about the Mamey Flats Disposal Site. By way of background, in 1963 the munrwiwalth of Kentucky ocumenced operation of a low-level radioactive di=preal site at Maxey Flats. Earlier in 1962, Kentucky entered into a licensing agreement with the U.S. Atcunic Energy Otsuaission to asGume regulatory pours for the manageuunnt of the low-level radioactive materials. The licensing agreement transferred title of the Maxey Plats Disposal Site to the Ocummonwealth of Fantucky and the leasing of site operations to the Nuclear Engineering Otzupany. g An estimated 4.75 millicm cubic feet of waste were deposited at Maxey Flats ( frtza the beginning of operations in 1963 to the close of diaF=1 activities in 1977. About 2.4 million curies of atmic by-product material, over 240,000 kilograms of atcznic source material, and 430 kilogres of special nuclear material wre placed in trenches, pits, and hot wils in the active diapr=1 area on-site which consists of 25 acres. Specific low level radioactive wate disposed of at Maxey Flats included items such as mntaminated paper, trash, clothing, laboratory glassware, plastic tubing, filters, ion-exchange resins, and evaporation sludges. Organic materials placed in Maxey Flats included animal tissue, paper, carrthnarti, wood, plastics, and organic chemicals (found in leachate samples wre benzene, l naphthalene, 6-n-oxtyl phthalate, and 1,4 dioxans along with others). The lesene of the Maxey Flats Disposal Site, Nuclear Engineering Otzupany, (now U.S. Ecology) made contracts or agreements with PRPs for diapr=1 of their hazardous substances frtza 1963-1977 at the site. These arrangements, contracts, or agreements are reflected by the radioactive shipping records (RSR's) collected and separated by EPA. The present voluantric/ percentage breakdoun of each PRP's contribution of hazardous substances to the Maxey Plats Disposal Site is attached to this notim/ demand letter as Attachnent C. The voluestric breakdow is being provided only for general information p2rposes. Further refinements in the volumetric breakdoms by EPA are anticipated. EPA has determined that "a release" of hazardous substances as defined by Section 101(22) of CERCIA, as anended by SARA, 42 U.S.C. 59601(22) has occurred at the Maxey Flats Diape=1 Site. Water m llected in the disposal trenches and such water, after becming contaminated, has leached out or was
) ' pe ped out. evaporation was also utilized to dispose of the a:intaminated noter. As a result of these measures (ptaping, evaporation) contaminated eseer has migrated offsite and water vapor contaminated with tritius has been-released into the atsosphere. Elevated levels of ~ radionuclides such as Strontiter 90 and Cbbelt-60 have been detected off-site. Studies have show higher-than-normal trititan levels in leaves of trees adjacent to the site. Fractures in sandstone beds outside the trench area contained contaminated leachate. The potential and actual off-site migration of contaminated leachate and radionuclides may pose an envircreental threat to local surface waters, ground eter, wells, and landowners. EPA has already expended public funds producing the draft workplan for the remedial investigation and feasibility study. Approxfinated or estimated costs of this activity and other costs recoverable pursuant to CERCIA now exceed 5130,000. It is anticipated by EPA that it will cost $1,300,000 for the goverrument to conduct the RI/PS and that the ultimate cleanup itself (reflected in the remedial design and renedial action) may cost $30,000,000 or more. The RI/FS will largely determine the scope and cost of the actual cleanup. g Accordingly, you and the other PRPs are requested to organize a steering ( consmittee and to notify EPA, in writing, at the address given below, of your ! willingness to conduct or undertake the RI/PS. See specifically Section 104' i of SARA, P.L. 99-499 which has amended Section 104(a)(1) of CERCIA. Your notification and subsequent agreenent with EPA to undertake the RI/FS must be made within ninety (90) days of your receipt of this letter. Should you fail to notify or reach an agreement within the ninety (90) day time frame, EPA will assume that you will not conduct the RI/FS and the govermeent will proceed to do the RI/FS itself. Your written responses to this notice / demand letter should indicate the appropriate name, address, and telephone ntsaber for future contact with you and should include a statament of your desire to conduct the RI/PS. itiere you are already involved in discussions with state and local authorities, engaged in voluntary action, or involved in a lawsuit regarding the site, you should continue that activity and report the status of those discussions or those actions in your letter. Please provide a copy of your letter to any other party involved in those discussions. Your written response should be sent to: R. Harold Taylor Enforcement Project Manager Investigation and Crmpliance Section anergency and Remedial aesponse Branch U.S. Envirorynental Protection Agency 345 Courtland Street, N.E. Atlanta, Ga. 30365 (404) 347-2234
9 4-Due to the seriousness of the probles at this site and the attendant ]- legal ramifir=tir =, EPA strongly urges you to respond within the time frame indicatg above. Imgal questions should be directed to Mr. James F. Bycott, Assistant Regional Counsel, at (404) 347-2641. The factual and legal di-==ims contained in this letter are intended solely for notificaticn and edificaticm purposes. They are not intended to, do not, and may not be relied upon as a final Agency positicn on any natter set forth herein. To far i1itate inFremticm requests, EPA will establish a repository of records at our Atlanta office. Once a steering ccamittee has been selected, the canittee can review the @mrtts for copying and distributicm purposes. Tb schedule & r*mants for reviewing the h==rtts, please cxxttact Mr. Taylor i at the above address. Thank you for your attention and response to this letter. Sincerely, i Patridt M. Tbbin ( Director t, Waste Management Divisicn cc: Mr. Alex Barber, Director Divisicn of Waste Panagement l l l - - ~ ., ~ -, - - - - - - -,, n y --_- - -- e,-,,
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g ? I i ATTACHMENTS Maxey Flats Notice Letter l 1 Attachment A pink PRP Address List Attachment B white RI/FS Work Plan Attachment C blue Volumetric Ranking Printouts i
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i Section: 1 Date: 6/30/86
1.0 INTRODUCTION
1.1 SITE IDCATION AND HISTORY he Maxey Flats Disposal Site (MFDS) is located in Fleming County, . Kentucky, approximately ten miles northwest of the city of Morehead. d4. It ended in 1977 for two reasons: (1) the accumulation of precipitation in 3y the trenches, and (2) the recognition leachate migration provided by fractured sandstone layers beneath the trenches. W e site has been under Conunonwealth custodial care since May 1978. It is estimated that over 4.75 million cubic feet of waste was deposited at Maxey Flats, including more than 2.4 million curies of by-product material, over 240,000 kilograms of source material, and 430 kilograms of special nuclear material, including 64 kilograms of plutonium. The Maxey Flats Disposal Site is owned by the State of Kentucky, and is the direct responsibility of the Kentucky Department of Environmental Protec-tion (DEP), Division of Waste Management. Licensing of the site is the responsibility of the Kentucky Cabinet for Human Resources (CHR), Radiation Control Branch. Frequent monitoring of the site and its surrounds is conducted by both CHR, and by DEP through its onsite contractor, Westing-house Hittman Nuclear Incorporated. In addition, the site has been studied extensively by the Department of Energy, the Nuclear Regulatory Consission, the U.S. Geological Survey, and several universities and national y laboratories. An investigation by EPA is currently underway to determine the potential responsible parties (PRP) for the site. Several hundred agencies, labora-tories, businesses, etc. including the State of Kentucky reportedly are named on the PRP list. 1-1 AL8b/9 231/12 ~
_,_:~-_-.....~ e, S2ction: 1 Date: 6/30/86 1.2 SITE STARIS AND PROJECT TYPE Although Maxey Flats was closed in 1977, it remains under active Connonwealth custodial care. The site was proposed for the National Priority List (NPL) in 1984 and listed in the Federal Register in 1986. CERCLA investigations began in February 1985, when authorization was given by EPA to conduct a Forward Planning Study of the site. Forward Planning ' activities were completed in April 1985. A Work Assignment Modification issued in September 1985 authorized the preparation of a Work Plan to conduct a Remedial Investigation / Feasibility Study (RI/FS) of Maxey Flats. 1.3 ftENARD PIAf@ LING SRJDY FINDINGS We Forward Planning Study indicated the requirements necessary to complete the RI/FS. These are listed below. Requirements to complete a Feasibility Study: o 1. Se National Contingency Plan (NCP) requires the consideration of at least five alternatives for the management of a site. The extreme alternatives (no action and complete removal) bracket onsite alternatives that must be weighed against success in meeting appropriate standards. The Hittman report does not i include an evaluation of the no action or the off site complete removal alternatives, as required by the NCP. l 2. A public health evaluation of the no action alternative must be completed. 3. The focus of the Hittman report was the evaluation of eight concepts intended to minimize or prevent the infiltration of water into the trenches. However, there are two important aspects to management of the site that were not within the scope of this report, and have not been addressed to the level of detail that would be appropriate for a Feasibility Study. These two issues, each of which shall require further examination, are: 1-2 AL8b/9 231/12
pr Section: 1 Date: 6/30/86 C - An analysis of precipitation in the vicinity of Mros, and the development (at a planning level) of measures to manage runoff on the surface and in the trench caps. This is necessary to provide for the diversion of precipitation from the trench area to detention ponds, followed by the controlled release of this water to prevent erosion both onsite and offsite. s" Whether some kind of peripheral, subsurface wall is required at k;* the site, and if so, whether to surround the burial area with a i drainage wall that will facilitate dewatering, surround the L5 burial area with a cut off wall that will isolate the site, or surround the burial area with a combined cut off/ drainage wall 4 that will isolate the site, but peonit dewatering. c 4. A number of other issues should also receive further attention: Review of options for stabilizing the trench contents - Review'of options for design of trench caps Review of options for dewatering the site Review of costs associated with each option selected above - Requirements for a monitoring program 5. Verifiable cost estimates must be developed for feasible alternatives. o Requirements to complete a Remedial Investigation: 1. It has recently been discovered that leachate is escaping from one or more trenches west of the site through a fracture in one of the underlying sandstone layers. Other fractures are suspected on the west face. No investigation has been conducted to locate any such fractures to the south or the east. The extent of contaminant transport from these fractures must be characterized, and this information incorporated into the feasibility study in order to recommend an appropriate remedial action. 1-3 AL8b/9 131/12
_m___ m w 4 Section: 1 Date: 6/30/86 2. The fact of subsurface leachate transport from burial trenches has important implications for the construction of a peripheral cut off wall. In particular, plans for the construction of a periph-eral wall must include provisions to contain this leakage, and must include contingencies to manage any such leakage that may jeopardize the integrity of the wall, or the safety of construc-tion workers. If leakage can be stopped at its source in the trenches, there may be no need for a peripheral wall. 3. The rate of intrusion of ground water from the north needs to be characterized in order to properly evaluate the need for and design of a north cut off wall. 4. Information requirements for a public health evaluation of the no action alternative must be identified, and the information obtained. 5. The quality of the rainfall record for Maxey Flats and vicinity must be determined in order to select the most appropriate form of analysis. o All current maintenance activities at the MFDS shov'.d be continued while the RI/FS is underway. 1.4 OVERVIEW Although Maxey Flats has been studied since the beginning of operations, the intensity of study increased since problems associated with infiltration into the trenches were recognized in the early 1970's. The literature that has resulted served as a basis for the Forward Planning Study Final Report, and will serve an important role in the Work Plan and RI/FS as well. Because so much is already known about Maxey Flats, the focus of the Work Plan and of the RI will be on the risk assessment. The 1-4 AL8b/9 231/12
Section: 1 4 Date: 6/30/86 t g: RI/FS will be conducted by considering two basic areas. Area 1, which is I defined by the fence that surrounds the restricted zone, includes the burial trenches and a treatment and evaporation system that is used to handle leachate removed from the trenches. Area 2 lies outside the fenced area and includes the environs of the disposal site. Area 2 includes two j detention ponds that receive 85% to 90% of surface runoff from Area 1, the 'd hillsides that surround the burial site on three sides, and the water-courses that ultimately receive surface runoff and subsurface flow from Area 1 and Area 2. Area 2 includes State owned and privately owned property. Sampling and data analyses that have been conducted by the State since completion of the Forward Planning Study Final Report suggest that the leakage of leachate to the west may be more extensive than had previously been thought, and that there may be leakage to the south as well. Although some field work will be conducted in Area 1,'the focus of the Remedial Investigation will be to characterize the extent of contamination in Area 2, particularly in the hillsides. In 1983, the Kentucky Department of Environmental Protection funded a study of alternatives for the long-term management of Maxey Flats. Although this study (Hittman 1983b) makes a substantial contribution to the FS, it does not directly address the complete removal and the no action alternatives which require examination under the National Contingency Plan. 'Itus, the RI will also be designed to identify and collect the information that will be required to evaluate these alternatives to nunagement of the site. 1-5 AL8b/9 231/12
-~ ~ i Section2 2 Date: 6/30/86 2.0 INITIAL SITE EVALUATICN 2.1 SITE DESCRIPTION Many of the studies that have been conducted at Maxey riats are sunnarized in this section. W e information taken free these studies is used to characterize the source and the site. W e source is defined as the area within the restricted zone, including the trenches and the evaporator, I while the site encompasses the area outside the restricted zone which may be affected by the source itself. W e extent of material presented in this chapter is intended to demonstrate that a great deal is known about the source in particular, and to illustrate that Phase 1 of the reasibility l Study (an assessment of alternatives for management of the trenches), requires with only minor data collection. This is discussed further in Sections 3, 4, and 5. Less is known about the site in regard to possible contamination by toxic pollutants. mis question is of particular importance to the Public Health Evaluation, and will be the subject of the Remedial Investigation, and of Phase 2 of the reasibility Study, as will be discussed in subsequent chapters of the Work Plan. 2.1.1 E2NIROtMENTAL SETTI?G The Maxey flats Disposal Site (MFDS) is located in northeastern Kentucky, about 10 miles northwest of the city of Morehead. Maxey Flats is a plateau that is about 300 feet higher than the surrounding valleys. The disposal site occupies a spur of the Maxey flats plateau. The main body of the plateau lies to the north, Rock Lick Creek to the south, Drip Springs Hollow to the west and an unnamed hollow and creek to the east, commonly referred to as No Name Hollow and No Name Creek. Streams in Drip Springs Hollow and No Name Hollow drain into Rock Lick Creek, which joins Fox Creek approximately two miles downstream. A vicinity map is presented in rigure 2-1, and a site map in rigure 2-2. 2-1 AL8b/8 231/14
) l -n-4 _N o 5 4 ENTUCKY I + ~ K = SCALE IN MILES 'Q fit 32 MAXEY FLATS HILLS 8ORO 64 INGO 5 MILLS SHARKEY 32 j MOREHEAD 60 i FARMERS 1 SOURCE: ZEHNER,1983 REMIl FIGURE No, VICINITY MAP MAXEY FLATS DISPOSAL SITE 2-1 FLEMING COUNTY, KENTUCKY }
I } ENF0RCEMENT C0NFIDENTIAL DRAFT Page: 9 10/01/05 Ho:<ey Flots Tronsoctional Dotobose Generator Ronking List'by Volume.of W,2ste Alphabetic.21 Order C9eeser.!!ste ' ' ~ Total Cubic Feet Percent ____ft11_I9191__ G9atrih119e 690!L DULUTH INT'L AIRPORT - 10.71' 'O.0001 472 DUQUESNE LIGHT COMPANY 5593.)4' O.0672 111 DUQUESNE LIGHT COMPANY. P f TTRRl!Rmt 91096.40 1.0945 21 E.I. DU PONT DE NEMOURS & COMPANY 8624 11' d.1036 98 EAST KENTUCKY PAVING 4.00 < 0.0001 499 EASTERN AIRLINES, INC. '24 00 '0.0'003 439 EATON RESEARCH CENTER L 51.00 0.0006 399 EDGEWOOD ARSENAL 4 00 < 0.0001 499 ELECTRO NUCLEONICS 14 00 0.0002 462 ELGIN NATIONAL WATCH COMPANY 44 00 0.0005 406 CLI LILLY AND COMPANY. 52.00 0.0006 397 CMORY UNIVERSITY 1944.00 0.0234 160 CPA - CINCINNATI 44 10 0 0005 405 CPA, PERRINE, FLA 93.60 0 0011 362 C030 RESEARCH 1 ENGINEERING COMPANY ~ 2.00 < 0.0001 510 ETHYL CORPORATION 30.00 0.0004 429 F.C. SMITH CLINIC 2.00 < 0.0001 510 FANSTEEL INC. 346.00 0.0042 275 FELC RCSEARCH INSTSITUTE 22.50 0.0003 443 FERRO CORPORATION 11.27 0.0001 469 FINLEY C. WATTS 359.00 0.0043 272 i o
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~ ENFORCEMENT CONFIDENTIAL ~, 4 DRAFT Page: g 10/01/85 4 Noxey Flots Transactional Dotobose u Generator Ronking List by Volume of Woste Ronk Order E92R20% !!992 Total Cubic Feet Percent t, ___.!!51 Tgigl._ G90tIlbt gn Rgn! i GENERAL DYNAMICS CORPORATION (ELECTRIC BOAT DIV.)784905.42 9.4304 1 MONSANTO RES. CORP. (NOUND LAB.) i 673843.90 8.0960 2 .} NUCLEAR NATERIALS 1 EQUIPNENT CORPORATION 573491.95 6.8903 3 WESTINGHOUSE ELECTRIC CORPORATION (BETTIS) .457437.00 5.4959 4 7. E if*..NWPORTNEWSSHIPBUILDING1DRYDOCKCO 447818.32 5.3804 5 CHARLESTON NAVAL SHIPYARD 392716.00 4.7183 6 PORTSMOUTH NAVAL SHIPYARD 376732.61 4.5263 7 CAROLINA POWER 1 LIGHT COMPANY 304459.00 3.6580 8 y,. .J GENERAL ELECTRIC COMPANY 200281.09 3.3675 9 T#, " U.S. ARMY ?? 232371.00 2.7919 10 j ATCOR, INCORPORATED 150656.93 1.8101 11 WE3TINGHOUOE ELECTRIC CORPORATION 139968.00 1.6817 12 PHILADELPHIA ELECTRIC C0ttPANY 131283.92 1.5773 13 . p. NUCLEAR ENGINEERING COMPANY, INC. 129746.99 1.5589 14 CADICLOGICAL SERVICE COMPANY, INC. 124377.00 1.4943 15 'JE3TINGHOUCE ELECTRIC CORPCRATION (UALTZ MILLS) 117751.97 1.4147 16 DABC0Ct. : UILC0t 'LYNCHBURG. V6; 116387.25 1.3934 17 NIAGARA MJHAWr, PCUCR CORPORATI0t* 114506.25 1.3753 13 NORFOLc. f. MAL 3 lIF YARD 112722.00 1.3543 17 NUCLEAR FUEL SEiNICES, INC. 111359.77 1.3379 20 DUQUE3NE LIGHT COMPANY, PITTSBURGH 91096.40 1.0945 21 l A /L -}}