ML20214W075
| ML20214W075 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/04/1986 |
| From: | Volger B NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| CON-#486-1815 ALAB-836, OL, NUDOCS 8612100072 | |
| Download: ML20214W075 (19) | |
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- UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION - _
'55 DEC -8 P3 :1 BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of )
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PHILADELPIIIA ELECTRIC COMPANY ) Docket Nos. 50-352 '0 0 .
) 50-353 - 0 6 (Limerick Generating Station, )
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RESPONSE OF THE NRC STAFF IN OPPOSITION TO LIMERICK ECOLOGY ACTION'S APPEAL OF THE LICENSING BOARD'S SUPPLEMENT TO THIRD PARTIAL INITIAL DECISION i
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Benjamin H. Vogler Senior Supervisory Tr'M Attorney i
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NUCLEAR REGULATORY; COMMISSION BEFORE TIIE ATOMIG SAFETY _ AND LICENSING- APPEAL BOARD In the Matter of ) ,
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PIIILADELPIIIA ELECTRIC COMPANY ) Docket Nos. 50-352
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RESPONSE OF THE NRC STAFF IN OPPOSITION N TO J.lMERICK ECOLOGY ACTION'S ',
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APPEAL OF TIIE LICENSING BOARD'S t ',
SUPPLEMENT TO THIRD PARTIAL INITIAL DECISION
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Benjamin H. Vogler Senior Supervisory Trial Attorney 3
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TABLE OF GNI1!NIE fag I. I NIFITI UT IN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 II. DAU G 00ND.................................................. 2 III. DISWSSIGI.................................................. 6
- 1. Vhether the Record Supports the Need for a License Condition to Verify Licensee's Proposal................ 7
- 2. Whether the Licensing Board Erred in Limiting School j Superintendent Testitrony to the Availability of Bus Tr. i ve r s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
- 3. hhether the Licensing Board Refused to Consider LEA's Argune nt s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 IV. GNCIUS I N . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 I
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. TABLE OF AUIIUlITIES AD!INIS'MATIVE DBCISKNS P_ age, Duke Power Capany (Catawba Nuclear Station, thits 1 and 2),
ALAB-813, 22 PFC 59, 71 (1985)................................... 12 Philadelphia Electric Cmpany (Limerick Generating Station, Uni t s 1 and 2) , AIAB-836, 23 NBC 479 (1986) . . . . . . . . . . . . . . . . . . . . . . 2, 11 Philadelphia Electric Cmpany (Limerick Generating Station, thi t s 1 and 2) , IEP-85-14, 21 IN 1219 (1985) . . . . . . . . . . . . . . . . . . . . 2 Philadelphia Electric Cm pany (Limerick Generating Station, Units 1 and 2), IBP , Supplanent to '1hird Partial Initial 1, 6, Deci sion , Slip op. , (SepTenber 5, 1986) . . . . . . . . . . . . . . . . . . . . . . . . . . 12 REGUIATIGE 10 C.F.R. I 2.206................................................ 9 10 C.F.R. I 50.47................................................ 6 10 C.F.R. I 50.47(b)............................................. 9 10 C.F.R. I 50.54(a)............................................. 8 10 C.F.R. I 50.54(5)(2)(11)...................................... 9 10 C.F.R. Part 50, Appendix E.................................... 6, 9 10 C.F.R. Part 50, Appendix E.IV................................. 9 MISmUA?FJOUS NUREG-0654, Criteria for Preparation and Evaluation of Radiological Iborgency Response Plans and "reparedness in Support of Nuclear Power Plants. Novmbe r , 19 8 0 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
. ITNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DEFORE THE ATOMIC SAVETY AND LICENSING APPEAL BOARD In the Matter of )
)
PHILADELPIIIA ELECTRIC COMPANY ) Docket Nos. 50-352
) 50-353 (Limerick Generating Station, )
Units 1 and 2) )
RESPONSE OF THE NRC STAFF IN OPPOSITION TO LIMERICK ECOLOGY ACTION'S APPEAL OF THE LICENSING BOARD'S SUPPLEMENT TO THIRD PARTIAL INITIAL DECISION I. INTRODUCTION On October 20, 1986, Limerick Ecology Action (LEA) filed a brief in support of its appeal of the Atomic Safety and Licensing Board's Supple-ment to Third Partial Initial Decision (P.I.D.). This appeal involves the remanded issue of the availability of school bus drivers for the Owen J.
Roberts and Spring-Ford School Districts in the event an emergene:
the Limerick Generating Station (LGS) requires the evacuation of thesc two School Districts. For the reasons discussed below, the NRC staff (Staff) opposes LEA's appeal and urges that the decision of the Licensing Board be affirmed.
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II. BACKGROUND
. On May 7,1986, the Atomic Safety and Licensing Appeal Board (Ap-peal Board) issued ALAB-836 II and decided all appeals from the Atomic Safety and Licensing Board's Third P.I.D. 2_/ in favor of the Licensee except for the issue of the availability of an adequate number of bus drivers to evacuate students in two school districts, b In ALAB-836 the Appeal Board reversed the Licensing Board's con-clusion that there was reasonable assurance of a sufficient number of ,
school bus drivers willing to respond in the event an emergency at the LGS required the evacuation of the Owen J. Roberts and Spring-Ford School Districts, and remanded this issue to the Board for further con-sideration. Specifically, the Appeal Board found that there was doubt raised as to the availability of bus drivers for these two school districts and thus, the Licensing Board's conclusions were not supported by the record. 23 NRC at 518-520.
l Pursuant to the Licensing Board's Order of May 22, 1986, the Li-censee submitted a proposal for the resolution of the remanded issue. O 1/ Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2), ALAB-836, 23 NRC 479 (May 7,1986).
Philadelphia Electric Company (Limerick Generating Station, Units 1
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and 2), LBP-85-14, 21 NRC 1219 (1985).
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-3/ The Appeal Board also imposed a license condition requiring the ver-ification of the establishment of additional traffic control measures in the area of Route 100 and the Downington interchange of the Penn-r sylvania Turnpike. The License condition is not relevant to LEA's appeal.
4/ See, letters dated June 27, 1986, from counsel for the Licensee to ITcensing Board and to Ralph J. Hippert, PEMA, with expanded com-ments and a revised proposed stipulation.
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4 The proposal provided for Philadelphia Electric Co. (PECo) employees to
. volunteer to serve as bus drivers in the event of an emergency at the i Limerick Generating Station. M. Affidavits from emergency prepared-ness officials of Chester County and Montgomery County, Pennsylvania were attached to the Licensee's proposal and stated that they had re-viewed the Licensee's proposal and concluded it would provide sufficient bus drivers in the event an emergency at the LGS requires an evacuation .
of the two school districts. M.
Following the submittal of the proposal with the attached affidavits by the Licensee, the Commonwealth of Pennsylvania on July 1,1986, after additional consultations with the Licensee and Chester and Montgomery County emergency planning officials concluded that the Licensee's propos-al satisfactorily resolved the question of an adequate number of bus driv-ers for the two school districts and signed the Licensee's proposed stipulation. Id. LEA objected to the proposal as a means for resolving
the bus driver issue and requested that it be permitted to conduct dis-covery and to participate in an adjudicatory hearing on the matter. b The Staff responded that in its view the Licensee's proposal provided sufficient information for the Licensing Board to conclude that there is reasonable assurance that an adequate number of bus drivers will be available in the event that an evacuation is necessary at the Owen J.
Roberts and Spring-Ford School Districts because of an incident at the
-5/ See, LEA's Response to " Licensee's Proposal For Resolution . . .
EBiool Bus Drivers for the Owen J. Roberts and Spring-Ford School Districts and Request for a Hearing", dated July 10, 1986.
- LGS. 6_/ Nevertheless, since LEA did not agree with the Licensee's
, proposal, the Staff submitted that LEA's request for an adjudicatory hearing should be granted.
On August 11, 1986, prefiled testimony in support of its proposal was filed by the Licensee. Additional testimony in support of Licensee's proposal was filed by the Commonwealth of Pennsylvsnia's Emergency Man-agement Agency (PEMA), and the Federal Emergency Mansgement Agency (FEMA). No testimony was filed in opposition to Licensee's proposal.
Hearings were held in Philadelphia, Pennsylvania on August 18 and 22, 1986. In the testimony provided by the Licensee at the hearing it set forth the terms of its proposal which generally consisted of a list of two hundred volunteer PECo employees, who agreed, in writing, to drive school buses for Montgomery and Chester counties in the event of an emergency. Boyer and Bradshaw, ff. Tr. 21,894 at 4. The Licensee also committed to make its bus driver employee volunteers available to -
Montgomery and Chester counties until provision was made by emergency
- planning authorities for bus driver personnel from other sources. Boyer, Bradshaw , ff. Tr. 21,198 at 6. Accordingly, the Licensee promised to keep its volunteer bus driver arrangements in full force and effect until notification that such volunteers were no longer required. See, Boyer, l
Tr. 21,227.
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'-6/ See, Response of NRC Staff to Licensees Proposal for Resolution of Reinanded Issue Regarding the Availability of School Bus Drivers for the Owen J. Roberts and Spring-Ford School Districts, July 17, 1986.
After reviewing the Licensee's proposal, emergency planning officials
. for Chester County, and Montgomery County, Pennsylvania, the Common-wealth of Pennsylvania, and FEMA testified favorably and in support of the Licensee's proposal. Campbell-Bigelow, Tr. 21,229-233; Hippert ,
Tr. 21,267; Asher-Kinard, ff. Tr. 21,279 at 4. In the opinion of the FEMA witness, the Licensee's proposal provided a ratio of four volunteer drivers for every potential unmet bus driver need while a one-to-one ra-tio between bus driver volunteers and unmet bus driver needs would have been satisfactory. Asher and Kinard, ff. Tr. 21,279 at 3, Kinard, Tr. 21,284.
Dr. Roy C. Claypool, District Superintendent, Owen J. Roberts School District, Chester County, Pennsylvania, testified that the School District's emergency plan indicates a shortage of bus drivers. (Claypool, Tr. 21,312). Dr. William A. Welliver, Superintendent, Spring-Ford Area School District, Montgomery County, Pennsylvania also advised that his School District's plans indicated a shortage of bus drivers. (Welliver, Tr. 21,312-313). However, both witnesses stated that they have dis-cussed their bus driver surveys with their respective county emergency planning representatives and have been advised that in the event of an emergency requiring an evacuation of their School Districts their unmet bus driver needs will be satisfied by their respective counties.
(Claypool, Tr. 21,316; Welliver, Tr. 21,318). Neither witness expressed any reservations about the use by their respective counties of Licensee's volunteer bus drivers to meet their needs provided they were properly licensed by the State of Pennsylvania. (Claypool-Welliver, Tr. 21,321).
Both Dr. Claypool and Dr. Welliver testified that they were satisfied that
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in the event an emergency at Limerick required the evacuation of their students there would be a sufficient number of hus drivers available to carry out the evacuation. (Claypool-Welliver, Tr. 21,348-349).
Based upon the Licensee's proposal and the evidentiary record, the Licensing Board concluded that there will be an adequate number of bus drivers to effectuate an evacuation of the Owen J. Roberts and Spring-Ford Area School Districts in the event of a radiological emergency at the LGS. Supplement to Third Partial Initial Decision, slip op.
at 20-21 (September 5,1986). The Licensing Board also determined that 4
the Licensee's arrangements, in conjunction with plans and resources al-ready in place that would be utilized by the county and school district authorities, met the requirements of 10 C.F.R. 5 50.47, and Appendix E to 10 C.F.R. Part 50, as well as the criteria of NUREG-0654, and pro-vides reasonable assurance that adequate protective measures for those school districts can and will be taken in the event of a radiological emer-gency. _Id . LEA filed a notice of appeal from the Licensing Board's de-cision , and thereafter on October 20, 1986, filed the present brief in support of its appeal, i
III. DISCUSSION LEA's brief, while sometimes difficult to follow, cites what the Staff believes to be three rqafor areas in which it asserts the Licensing Board erred in its Supplement to the Third P.I.D.: (1) failure to impose a license condition, such as the one proposed by LEA b ot assure that the 7/ See, LEA Proposed Findings of Fact . . . , at 13, August 29, 1986.
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Licensee and local emergency planning officials carry out the proposal to ;
. provide additional volunteer bus drivers; (2) limiting the testimony of the t two District School Superintendents to the availability of bus drivers for the two school districts in question; and (3) ignoring LEA's arguments and proposed findings. The Staff does not believe that any of LEA's allegations have merit and will discuss each of them in turn below:
- 1. Whether the Record Supports the Need for a License Condition to Verify Licensee's Proposal LEA argues that the record supports the issuance of a license condition dealing with PECo's proposal to provide volunteer bus drivers
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because: (1) there is no evidence that the Licensee's proposal has been
, adhered to or that there will exist a pool of trained, licensed and enrolled bus driver volunteers (Brief at 3); all the record offers is the Licensee's promise that it will live up to its commitment (Brief at 6); 8,/ and, 4
finally, that without a license condition there is no guarantee that local ;
emergency planning officials will use the volunteer bus drivers for the purposes envisioned in the proposal (Brief at 7).
t There simply is no evidence to support LEA's allegations or concerns as set forth above. LEA's doubts about the cetual existence of -
the volunteer driver pool and fears of PECo withdrawing the drivers at sometime in the future has no record support and amounts to nothing I
. more than pure speculation on LEA's part. Similarly, LEA's concern that local emergency planning officials will convert the drivers to other'uses
~8/ Additional support for the need for a license condition can be found, LEA alleges, in the fact that " Licensee will say or appear to do any-thing to satisfy the NRC, but the folicw through in the real work-a-day world is something else." Brief at 4.
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l and thereby deplete the available pool of volunteer drivers is likewise without foundation. The record in this remanded proceeding is replete with comments from local county emergency planning officials, the Director of Emergency Plens and Preparedness for the Commonwealth of Pennsylvania and FEMA officials that they have, inter ella, discussed and or reviewed the proposal with the Licensee, are satisfied with it, and feel that it resolves any potential shortfall of bus drivers for the two school districts in question. See, e.g., Campbell-Bigelow , Tr. 21,229-233, Hippert, Tr. 21,267; Asher-Kinard, ff. Tr. 21,279, Kinard, Tr. 21,284.
None of the planning authorities have requested that additional conditions be imposed upon PECo in order to have reasonable assurance that the drivers will be provided. In addition, the State Police of the Common-wealth of Pennsylvania were conducting Class 4 drivers license b tests on Licensee's volunteers at the time of the hearing and considerable dis-cussion took place on the record concerning the number of volunteers .
that had passed the test, the schedule for future tests and the total number of volunteers that would be tested. See, eg, Boyer, Tr. 21,198, 21,217. Indeed, LEA cross-examined the Licensee on this point. Tr. 21,193, 21,197-198, For LEA to express doubts that the vol-unteer bus driver pool even exists defies the record and logic.
Moreover, pursuant to 10 C.F.R. I 50.54(q), a Licensee is re-quired to " follow and maintain in effect emergency plans which meet the 9/ In Pennsylvania, a Class 4 drivers license is required for the opera-tion of a school bus. There are three prerequisities for obtaining the Class 4 license: (1) possession of a Class 4 learner's permit (FOOTNOTE CONTINUED ON NEXT PAGE) l
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standards in 5 50.47(b) of this part and in Appendix E to this part."
. Any change to such plans which would reduce their effectiveness would require prior submission to the NRC. Thus, should PECo, at some future time, decide to alter its commitments made on this record with respect to the availability of volunteer bus drivers in such a way as to reduce the effectiveness of the emergency plans, PECo would be obligated to seek NRC approval before making such a change. b In addition, should LEA's concerns materialize, it could avail itself of the long standing pro-cedures available to it under 10 C.F.R. I 2.206. The imposition of a license condition dealing with the subject of this proceeding is unneces-sary. Likewise, LEA's concern that Licensee's proposal is not permanent is similarly without merit. As Mr. Timothy R. S. Campbell, Director, Department of Emergency Services. "Sester County, Pennsylvania, stated in addressing the changeable nature of emergency planning in response to an inquiry from LEA as to whether the Licensee's proposal was a perma-nent or temporary solution to the bus driver problem:
A. [ Campbell] Mr. Stone [ LEA counsel], emergency planning is a dynamic thing. Solutions are neither permanent nor l temporary. They are solutions that work the day they i are put into effect, that is, the day when the incident j happens.
(FOOTNOTE CONTINUED FROM PREVIOUS PAGE
, which requires passing a physical examination; (2) classroom and vehicle training; and (3) passing a driver's examination administered by the State Police. Boyer and Bradshaw, ff. Tr. 21,189 at 3.
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-10/ See, generally, 10 C.F.R. Part 50, Appendix E.IV with regard to requirement that each Licensee shall conduct an exercise with offsite authorities biennially. Of course the NRC could itself take appropri-ate enforcement action should it determine that PECo's plans no long-er provide the requisite reasonable assurance. See, 10 C.F.R.
I 50.54(5)(2)(11).
. What may be a permanent solution yesterday may be, by
. changes of personnel and whatever, a temporary solution today and an unworkable one the day after. This is one tool. - ILicensee's proposal] I repeat, one tool of many, that we will use to meet the unmet needs of municipali-ties and school districts in Chester County.
I cannot say if someone dies tomorrow on PECo's list that that reduces the usability of the system or not. I see it as one tool. I do not use the term " permanent," "short-term" or "long-term"; I use one of many solutions.
Campbell Tr. 21,237-238.
Finally, it is instructive to note that we are dealing with providing bus drivers for only two school districts and the evidence supports the finding by FEMA that there is a four to one ratio of volunteer drivers to every potential unmet bus driver nced. Kinard, Tr. 21,284. Thus, in view of the foregoing, the record herein clearly does not support LEA's allegations concerning the need for a license condition in order to verify and assure the continued viability of the Licensee's volunteer bus driver proposal.
- 2. Whether the Licensing Board Erred in Limiting School Superintendent Testimony to the Availability of Bus Drivers LEA alleges that the Licensing Board Chairman incorrectly pre-vented the School Superintendents from testifying as to anything beyond the " simple number of drivers" that would be needed for the two school districts. Brief at 10. Moreover, LEA maintains that it was up to these witnesses to " speak for themselves" and that the Licensing Board Chair-man erred in limiting their testimony. Id. Both allegations are
! incorrect.
The Licensing Board prohibited LEA from examining the school superintendents on issue that were beyond the scope of the remand order
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in ALAB-836. The Licensing Board had to continually remind LEA that
. the purpose of the remanded proceeding was to determine whether there was a sufficient number of bus drivers to evacuate the Spring-Ford and Owen J. Roberts School Districts in the event of an emergency at LGS.
Hoyt, Tr. 21,327, 331-32, 334, 336, 337. Nevertheless, LEA attempted repeatedly to inquire about the availability of buses (without drivers) and about the superintendent's responsibilities in areas that were beyond the scope of ALAB-836, such as driver training. See eg Tr. 21,330-331, 335-337. However, LEA was permitted by the Licensing Board to inquire into matters within the scope of the ALAD-836 remand. Such matters as j to whether the superintendents were satisfied with the Licensee's propos-al and related matters were examined by LEA. Tr. 21,323-24, 340,
! 342-43. In Staff's opinion, review of the record does not reveal an error
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by the Licensing Board in confining LEA's inquiries to the scope of ALAB-836.
- 3. Whether the Licensing Board refused to consider LEA's arguments Throughout its appeal brief, LEA complains that the Licensing i Board rinde no effort to answer LEA's allegations or otherwise explain its lack of comments concerning LEA's position. Brief at 4, 10, 13, 14 and 15. At page fourteen of its brief, LEA complains:
Judge Hoyt interferes with LEA's legitimate questions about the 1985-1986 school year . . . Then she goes on to ask the same sort of questions from her point of view ,
at Tr. 21262 at 15. --- LEA must ask the question: is this fair and objective or is the Judge betraying here
- some personal agenda -- . Brief at 14, (citations omitted) .
Besides this unjustified ad hominem, it is clear from the forego-ing that LEA disagrees with the Licensing Board's Supplement to the
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Third P.I.D. and is unhappy with its conclusions. However, this argu-
, ment, in and of itself, is not sufficient grounds for an appeal and will not support LEA's arguments for the imposition of a license condition. b Finally, with regard to LEA's complaint that the Licensing Board made no effort to respond to its specific arguments, Brief at 4, Staff notes that the Licensing Board in its Supplement to the Third P.I.D. states:
In reaching this decision, the Board has considered all the evidence of the parties and the entire record of this
?roceeding on the remanded bus driver availability issue,
- neludin ; all proposed findings of fact and conclusions of law filed. by the parties. Based upon a review of that record and the foregoing Findings of Fact, which are j supported by reliable , probative and substantial evi-dence, the Board, with respect to the issue in contro-versy before us, reaches the following conclusion 6
pursuant to 10 C.F.R I 2.760a: ... ((Supplement to the Third Partial Initial Decision, Slip op, at 20-21, September 5,1986) (emphasis added).
The Staff is aware of no basis which would bring into question the accu-racy of the Licensing Board's statement. As noted earlier, disagreement with the Licensing Board's indings and conclusions without more is not a proper basis for appeal. ALAB-813, supra. LEA complains, but fails to point out any errors or abuse of discretion by the Licensing Board in this regard.
11/ See, ge.., In the Matter of Duke Power Company (Catawba Nuclear Etiition, Units 1 and 2), ALAB-813, 22 NRC 59, 71 (1985).
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CONCLUSION IV.
. In view of the above, the Staff submits that LEA's appeal herein is without merit and the Licensing Board's decision should be affirmed.
Respectfully subnitted, "df n -
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Benjamin H. Vogler Senior Supervisory Trial Attorney Dated at Bethesda, Maryland this 4th day of Decenter,1986 e
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USHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION'86 DEC -8 P3 :Q BEFORE THE ATOMIC FAFETY AND LICENSING APPEAL BOARD EONfi n. 3 : n. (f In the Matter of )
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PHILADELPHIA ELECTRIC COMPANY ) Docket Nos. 50-352 i ) 50-353 (Limerick Generating Station, )
Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of " RESPONSE OF THE NRC STAFF IN OPPO-SITION TO LIMERICK ECOLOGY ACTION'S APPEAL OF TIIE LICENSING BOARD'S SUPPLEMENT TO THIRD PARTIAL INITIAL DECISION" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail sys -
tt.n, this 4th day of December,1986:
Helen F. Hoyt, Chairperson (2) Mr. Edward G. B auer, Jr.
Administrative Judge Vice President & General Counsel Atomic Safety and Licensing Board Penel Philadelphia Electric Company U.S. Nuclear Regulatory Commission 2301 Market Street Washington, D.C. 20555* Philadelphia, PA 19101 Dr. Richard F. Cole Troy B. Conner, Jr., 1*sq .
Administrative Judge Mark J. Uctterhahn, Esq.
Atomic Safety and Licensing Board Panel Conner and Wetterhahn U.S. Nucicar Regulatory Commission 1747 Pennsylvania Avenue, N.W.
l Washington, D.C. 20555* Washington, D.C. 20006 Dr. Jerry Harbour Ms. Phyllis Zitzer , President Administrative Judge Ms. Maureen Mulligan Atomic Safety and Licensing Board Panel Limerick Ecology Action
, U.S. Nuclear Regulatory Commission 762 Queen Street Washington, D.C. 20555* Pottstown, PA 19464 4 Mr. Frank R. Romano Charles E. Rainey, Jr., Esq.
I Air and Water Pollution Patrol Chief Assistant City Solicitor G1 Forest Avenue Law Department, City of Philadelphia Ambler, PA 19002 One Reading Center 1101 Market Street, 5th Floor Philadelphia, PA 19107
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Thomas Gerusky, Director Barry M. Hartman
. Bureau of Radiation Protecticn Governor's Energy Council
, Dept. of Environmental Resources P.O. Box 8010 5th Floor, Fulton Bank Building 300 N. 2nd Street Third and Locust Streets IIarrisburg, PA 17105 IIarrisburg, PA 17120 Director Spence W. Perry, Esq.
Pennsylvania Emergency Management General Counsel Agency 3 Federal Emergency IWanagement Agency Basement, Transportation & Safety Room 840 Building 500 C Street, S.W.
Harrisburg, PA 17120 Washington, D.C. 20472 Robert L. Anthony Gene Keny Friends of the Earth of the Senior Resident Inspector Delaware Valley U.S. Nuclear Regulatory Commission 103 Vernon Lane, Box 186 P.O. Box 47 Moylan, PA 19065 Sanatoga, PA 19464 Atomic Safety and Licensing Timothy R. S. Campbell, Director Board Panel Department of Emergency Services U.S. NucIcar Regulatory Commission 14 East Biddle Street Washington, D.C. 20555* West Chester, PA 19380 Davis Wersan Atomic Safety and Licensing Appeal Consumer Advocate Board Panel (8)
Office of Attorney General U.S. NucIcar Regulatory Commission 1425 Strawberry Square Washington, D.C. 20555*
IIarrisburg, PA 17120 Docketing and Service Section Jay Gutierrez Office of the Secretary Fegional Counsel U.S. Nuclear Regulatory Commission USNRC, Region I Washington, D.C. 20555' G31 Park Avenue King of Prussia, PA 19406 Angus R. Love, Esq.
Montgomery County Legal Aid Theodore G. Otto, III 107 East Main Street Chief Counsel Norristown, PA 19401 Pennsylvania Dept. of Corrections P. O. Box 598 l
, Camp 11111, PA 17011 I
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BenJp(nin II. Vogler /
l Senfor Supervisory Trial Attorney i
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