ML20215D867
| ML20215D867 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/11/1987 |
| From: | Sneider C MASSACHUSETTS, COMMONWEALTH OF |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#287-3782 OL, NUDOCS 8706190170 | |
| Download: ML20215D867 (18) | |
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' DOCKETED USHPC UN1.ED STATES OF~ AMERICA
'87 :JJN.15i A9 $1 NUCLEAR REGULATORY COMMISSION Crn' ',
.Before Administrative Judges:
D!Edi
<4;
" Helen F. Hoyt, Chairperson
.G ustave A.
Linenberger, Jr.
Dr. Jerry Harbour l
)
~In; tha: Matter ; of-
)
)
PUBLIC SERVICE COMPANY OF NEW
)
Docket Nos.
)
50-443/444-OL j
(Seabrook Station, Units 1 and 2)
)
(Off-Site EP)
)
J un e.11, : 19 87 i
)
ATTORNEY GENERAL JAMES M..SHANNON'S MOTION FOR' PARTIAL
SUMMARY
DISPOSITION ON TOH REVISED. CONTENTION VIII, SAPL CONTENTION 16, AND-NECNP CONTENTION RERP-8 Attorney: General James M. Shannon pursuant to 10 C.F.R.
S 2.749 hereby moves 'the Board to grant partial' summary disposition in favor of the intervenors on ToH Revised Contention XVIII, SAPL Contention 16 and NECNP Contention RERP-8.
In essence, these contentions provide, in part, that the NHRERP, Revision 2, fails to provide reasonable assurance j
that adequate protective measures can and will be implemented with respect to the seasonal beach population, because there.
'are no provisions, or inadequate provisions, in the RERP for I
sheltering the beach population, and because the RERP has not 8706190170 870611 M l
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developed a range of protective actions for that population as required.by 10 C.F.R.
S 50.47(b)(10).- The Attorney General contends that there is-no-issue of fact with respect to this
' ssue of whether the NHRERP, Revision 2,. provides f or i
sheltering of the seasonal beach population and that as a
-matter of law this. issue must be decided in the intervenors
. favor.
ToH Revised Contention VIII reads:
Revision 2 fails to provide adequate emergency equipment, facilities, or personnel to support'an emergency response and fails to demonstrate that adequate protective responses can be implemented in the event of a radiological emergency.
50.47(b)(1)(8)(10).
One of the stated bases' of ToH Revised VIII, is:
Basis:
In preparing the Hampton RERP, the State relies upon a " shelter-in-place" concept as a
" valuable protective action" (in] that it can be implemented quickly, usually in a matter of minutes."
RERP, pgs. II-25, 26.
The Hampton RERP acknowledges, however, that " sheltering may not be considered as a protective action on Hampton Beach during the summer."
- RERP, pg. II-25 The plan thereby fails to provide reasonable assurance that adequate and immediate protection measures will be available to the thousands of beachgoers in the event of emergency.
Under its RERP, therefore, the Town is required to rely upon evacuation as the sole means of avoiding radiological exposure to large segments of the population.
Since a " major j
portion" of radioactive material may be released within one hour of the initiating event, NUREG, pg. 17, and present estimates indicate evacuation could take up to seven and one-half hours, RERP, II-32, RERP measures for evacuation are a wholly inadequate protective response to meet an emergency.
1 l
if SAPL' Contention 16 provides:
-The New Hampshire State and local-plans do not make adequate; provisions for the' sheltering-of various-segments of..the populace in the EPZ and therefore-the plans fail to meet the requirements of-10 C.F.R.
S 50.'47(a)(1),
~
S-5047(b)(1)1and NUREG-0654 II.J.10.a. and m.
The basis: of SAPL. Contention 16 provides in pertinent part:-
Basis:
10 C.F.R.
S:50.47(b)(10) requires'that a j
range of protective actions be developed.for the plume exposure pathway EPZ.
NUREG-0654. requires that there be maps of shelter areas and the inclusion of the bases-for the choice of recommended protective actions Lf rom the plume exposure pathway during emergency conditions.
NUREG-0654 II.J.10.m. specifies that the expected level of protection to be afforded in residential ~and other' units must be evaluated.
The New Hampshire State and local plans fail to meet these requirements because there are no
- provisions for sheltering the' population in the
. beach area and no provisions for the sheltering of; the' population in the ~many camping areas in the EPZ.
In'a quickly developing accident with anticipated. fast release of short-duration, sheltering could be the-only realistic protective action that could be implemented.
Evacuation of all transients is supposed to be carried out,.according to1the plans, if an evacuation is ordered.
There-is, however, no realistic. description as to how this can be i
done.
Given the current status of these-plans-and the lack of availability of sheltering capability for large segments of the population, a reasonable level of assurance that adequate protective measures will be available for transients in beach or camping areas has simply not been attained.
NECNP Contention RERP-8 provides:
The New Hampshire RERP does not provide a i
" reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency," as required by 10 C.F.R.
l S 50.47(a)(1), in that the plan does not provide reasonable assurance that sheltering is an
" adequate protective measure" for Seabrook.
Nor does the plan provide adequate criteria for the l-
choice between protective measures, as required by S 50.47(b)(1)) and'NUREG-0654, S II.J 10.m.
l The NHRERP provides that "New Hampshire will_ rely on two '
l prot'ective actions for limiting the direct exposure of the general public within the Plume Exposure EPZ.
These are sheltering and evacuation."
Vol 1, S 2. 6.5, at 2. 6-4.
There can be'no dispute, however, that NHRERP, Revision 2, makes no provision.f or sheltering. the summer beach population.
The plan expressly provides'that:
" Sheltering may not be considered a feasible protective action on the seacoast beaches during the s umm er. "
NHRERP, Rev. 2, _ Vol.1, S 2.65 at 2.6-7; Seabrook RERP, Vol. 16 at II-31; North Hampton RERP, Vol. 19 at II-26; Rye RERP, Vol. 20 at II-26.
See also, Hampton RERP, Vol. 18 at II-26 (" Sheltering may not be considered as a protective action on Hampton Beach during the summer.").
The State of New Hampshire has stated in response to interrogatories propounded by the Massachusetts Attorney General that, "The RERP provides at Section 2.6.5 ( at 2.6-6) that the transient population, which includes the transient beach population, should, when sheltering is recommended, leave the EPZ."
The State of New Hampshire's Responses to Attorney General James M. Shannon's Of f-Site EP Interrogatories and Request for Production of Documents, dated March 18, 1987, at p. 32 (Response to Interrogatory No. 75).
See also, The State of New Hampshire's i
Responses to Attorney General James M. Shannon's Off-Site EP Interrogatories and Request f or Production of Documents to the 3
LState of New. Hampshire - (Set No. 2 ), dated June 4, 1987, at l
p.18, Response to Interrogatory No. 36 ("The State's position with regard to sheltering the transient beach population
. is provided..in-the State's response to Interrogatory 75 of Attorney. General Shannon's of f-site interrogatories provided on. March 18, 1987.").
.There is'only one very limited exception to this provision noted by the-State, which is:
"should a limited number of.the transient population not have access to means to evacuate, they may be requested to take shelter at the locations they are visiting.
The State of New.
Hampshire's New Response to Attorney General Shannon's No. 75, at p. 32 (emphasis added).
Although the NHRERP provides that "[e]xcept for the
-institutionalized ~ population, sheltering'and' evacuation will be implemented on. a m unicipality-by-municipality - basis 'in New Hampshire," Vol.
1, S 2.6.5, at 2.6-7, this is not the case for the seacoast beach population.
The beach populations will be directed to evacuate even in the event of. a General Emergency in which the remainder of the population in the municipality is advised to shelter.
See Vol.
4, Appendix G, at G-25, G-28; l'
l Vol. 4, Appendix F, at F-11; Vol. 4A, Appendix U at U-11.
See also, Vol. 18 at II-26, Vol. 16 at II-31, Vol 20 at II-2 6.
The I"
seasonal beach population will be directed to evacuate even in those cases where projected evacuation doses are higher than projected sheltering doses calculated for the general population.
See Vols. 4 A, App. U; Vol. 1 at 2.6-25, 2.6-26; Vol. 4, App. G.
In fact, persons on Seabrook and Hampton l'
l L
g beaches will be directed to. evacuate even bef ore projected off-site doses have been calculated and recommended' protective actions for the general population have been determined. -See Vol. 4A, App. U; Vol. 1 at 2.5-1, 2.6-25; 2.6-29; Vol. 4, App.
.G.
4 Although the applicants now state, in-response dated April 10, 1987 to Attorney. General Shannon's Motion f or Summary Disposition on ToH VIII and SAPL 16 and in response to
-interrogatories, that evacuation is merely the " preferred" r
protective response f or the summer beach population and that the NHRERP does not preclude sheltering of that population, that is not the case.
The NHRERP does not label evacuation the
" preferred" protective response for the beach population; it states unequivocally that " sheltering may not be a feasible protective action on the seacoast beaches during the summer."
NHRERP Rev. 2, Vol. 1, S 2.65 at 2.6-7 ( emphasis added).
Nowhere in the plan is any mention even made of the possibility of sheltering the transient beach population.
If evacuation were indeed j ust the " preferred" protective response, as opposed to being the RERP's only protective response for the summer beach population, it would have been so labelled, j ust as the NHRERP expressly labels she'Itering the " preferred protective response" for the institutionalized population and notably discusses the possibility of also evacuating that population.
See e.g., NHRERP, Rev. 2, Vol.1 at 2.6-7.
1 I )
! 3..
Whatever-applicants may1say about-the possibility.of sheltering the transient beach population, it' remains undisputed.thatithe NHRERP'does not plan such aJresponse.
- See, e.g.s Affidavit of New Hampshire Civil Defense Director Richard H. Strome,. dated' March 25, 1985 at 1 11
(" evacuation of
.the beach aree.s
. -(is in.f act, the protective measure f or d
which specific. plans have been developed)
.").
See also, Response of the Federal Emergency Management Agency to' i
Massachusetts Attorney General James M. Shannon's Off-site Emergency Preparedness Interrogatories and Request for 1
Production of Documents, dated J une 4, 1987, Appendix A,
" Current FEMA Position on Admitted Contentions on New Hampshire Plans.for Seabrook," [hereinaf ter " Current FEMA ' Position on' NHRERP Contentions"] at p.
39(2) ("We understand that the plans contain'no consideration of sheltering the ' day trippers'
").
Moreover, the very fact that the decision-making scheme set' f orth in the NHRERP. calls, -in situations where there-is a " potential for release" or a " release in progress," for the immediate evacuation of Hampton and.Seabrook beaches, even before. assessment of projected doses and recommended protective actions for the remainder of the population are determined,
- see, e.g.,
NHRERP Vol.1, S 2.6-25, Figures 2.6-6 and 2.6-7
-[ attached hereto as " Exhibit A"),
precludes any consideration of the possibility of sheltering that population.
Since1there'can be no factual dispute, therefore, that sheltering will not be considered as a protective action for 1
[
3, the seasonal beach population, the only 1ssue to be determined with respect to the above-cited bases of ToH Revised Contention VIII, SAPL Contention 16 and NECNP Contention RERP-8 is whether reliance upon evacuation, alone, as a protective response action for_this population provides " reasonable assurance that adequate protective measures can and will be taken.
This issue may be disposed of as a matter of law in favor of the intervenors.
Section 50.47(b)(10) requires, in pertinent part, that,
"[a] range of protective actions have been developed for the plume exposure pathway EPZ for emergency workers and the
_public" and that "[g]uidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place."
10 C.F.R. 50.47(b)(10) (emphasis added).
As one licensing board has noted, "[t]he principal protective actions which might be taken are evacuation, sheltering and thyroid prophylaxis.
Other protective actions include use of respiratory equipment and protective clothing."
Southern California Edison Company (San Onofre Nuclear Generating Station, Units 2 and 3), LBp-82-39, 15 NRC 1163, 1184 (1982).
NUREG-0654 provides that "[f]or the plume exposure pathway, shelter and/or evacuation would likely be the principal immediate protective actions to be recommended for the public.
The ability to best reduce potential exposure under the specific conditions during the course of an l
s,;
.s.
accident should determine the appropriate' response."
NUREG-0654, I.D.a-at p. 9.
The New Hampshire RERP clearly does not provide a range of protective actions for the seasonal. beach population within the Seabrook plume exposure EPZ;-it provides only one response option for that population--evacuation.
Thus, there~cannot be
-reasonable assurance that this only available response can i
-satisfy the requirement of NUREG-0654 that the recommended response be the one that is able to "best reduce potential exposure under the specific conditions."
Indeed, the.NHRERP's provision to evacuate the seasonal beach population even when evacuation doses are projected to be higher than sheltering doses virtually ensures that for some accident scenarios the I
protective' action best able to reduce exposure--sheltering--will not be recommended.
Moreover, the Section 50.47(a)(1) requirement, that there be " reasonable assurance of adequate protective measures," by its own terms mandates that the NHRERP provide more than one response option.
As the San Onofre licensing board noted, I
there can often be constraints, such as " inadequate lead time due to the imminence of the passage of a plume, or.
. severe weather conditions," which would make sheltering (or some other protective action) a preferred alternative to evacution.
Southern California Edison Company, supra at 1184.
See also Consolidated Edison Co. (Indian Point, Units 2 and 3)
I
_9_
!Q-a.-
LBP-83-68, 18 NRC 811, 990-91 (1983).
This reasoning applies LWith even greater force to the' instant case where,~as stated in the basis to.ToH-Revised Contention VIII, one must assume that "a ' major portion' of radioactive material.may be released within one hour of the. initiating event, NUREG-0654, pg. 17, 1
.and present estimates indicate evacuation could take up.to i
seven and one-half-hours, RERP, II-32."
See also NHRERP, Rev.
2, Vol. 6; Vol.
4, App. F.
Under such circumstances, to rely
.on evacuation as the. sole protective response is completely inadequate.
Using similar reasoning, FEMA, whose findings constitute a rebuttable presumption, has found with respect to these sheltering contentions, as a matter of fact, that the NHRERP Rev. 2 does not provide the requisite " reasonable assurance that adequate protective measures can be taken.
Current 1
FEMA Position on NHRERP Contentions, pp. 38-39.
Fema has I
concluded that:
[U] sing the standard guidance for the j
initiation and duration of radiological releases, 1
and the current New Hampshire RERP including ETE, it appears that thousands of people could be unable to leave during an accident at Seabrook i
involving a major release of radioactivity without adequate shelter for as much as the entire duration of that release.
Therefore, until these issues are resolved even if all the i
other inadequacies and deficiencies cited in the RAC Reviews of the New Hampshire Plans, and the Review of the Exercise of these plans were to be I
corrected, FEMA would not be able to conclude that the New Hampshire State and local plans to protect the public in the event of an accident at the Seabrook Nuclear Power Plant are adequate to meet our regulatory standard that such plans
" adequately protect the public health and safety u4, A., by~providin~gfreasonable assurance that ' appropriate protective measures'can be taken offsite in the' event of a radiological emergency." -(See,. 44 CFR.350.5(b)).' Id. at 39 (emphasis added). Therefore, the. Board should grant this motion for partial summary disposition.on Hampton Revised Contention'VIII, SAPL Contention 16,'and NECNP Contention RERp-8 and should enter a' i finding in favor of the intervenors. Respectfully submitted, JAMES M. SHANNON Attorney General M"0 S - EL'h By: Carol S. Sneider Allan R'. Fierce Donald S. Bronstein-Assistant Attorneys General Department of the Attorney. General One;Ashburton: Place, Room 1902 Boston, MA 02108 (617) 727-2265 Dated:- June 11, 1987 i l l-p i 10: a E.(.., 1 STATEMENT OF MATERIAL' FACTS NOT IN DISPUTE' i i 1. .NHRERP, Rev. -2 generally relies on two protective actions, sheltering and evacuation, for_ limiting the direct exposure'of the general public within the Seabrook Station ' Plume Exposure-EPA. 2. Revision.2 of NHRERP provides that " sheltering may not be considered a feasible protective action on the' seacoast beaches during the summer." 3. 'NHRERP, Rev. 2 provides that the seacoast beach population'will be' directed to evacuate even in the event of'a . General' Emergency in which.the remainder of the general population in:a municipality in which a beach is located will be instructed-to' shelter. 4. .In'accordance with NHRERP, Revision 2, the seasonal beach-population will be directed to evacuate even in those cases where, for the general population, projected evacuation doses are calculated'to be higher than projected sheltering
- doses.
) 5. The NHRERP, Rev. 2, makes no provision for sheltering the seasonal beach population, except for those persons on the . beaches who have no means of evacuating. 6. Evacuation Time Estimates provided in the NHRERP, Revision 2, indicate that evacuation of the beaches within the Seabrook plume exposure EPZ could take up to seven and a half hours.
- ?'
auw 4 6 l { PIant Safety , Plant Status System Degraded ygs Close Hampton and y Seabrook Beaches Prognosis or Potential and Control Access for Failure? 4 Potential for NO Close Hampton and Release of L Seacrook Beaches Release in Progresa? and Control Access YES U tmmediately Recommend Evacuation of Hampton and Seabrook Beaches and Recommend Sheltenng A Two Mile Radius and Five Miles Downwind U Evaluate Doses Per Fsure 2.6 7 FIGURE 2.6-6 Precautionary Decision Criteria for Seasonal Populations vcl. 1 2.6-25 Rev.2 8<
? l. I A 1 B protecw Doses Projected Dose SOTH NO e . PAG TM r " ' * * *' E ** ' # ^ 0 * "Y' No Actiori Reguted I P A Q,, or wnote sooy l j ..o l yES FOR ONE OR BOTH C 2 o Can E.acuation ygg Time to Release ne comoieved Peter to Plume Arrival Time ~ a Recommend Evocuation 4,,,, a Plume Exposure Time a Deley Time Action Time Offsite Contraints NO y YES 3 y p FOR SHELTER Con ens ONL y Acte B*em D*'o'* NO _ Conduct Monitoring Recommend SheRet C ttw Plume ese Passed? ~ end Decontemenetton G YES DRF * =- FOR BOTH EVACUATION DRF we ' AND SHELTER 4 WHOLE 800y wnsen patn.sy THyROlo is more importsett I H Recommend Shelter SHEL TER 1 s er or NOT DECISNE NOT DECISIVE ner or ...t.r......... _ E.acuenon pro.eos ene most ....... n o. t.. m.., ~ Based upon more Detaileo Protection to, A A*'Y *88 Wnole eody7 thyr EVA CUA TCN EVACUA TCN r Recommend Evocuation 2 FIGURE 2.6-7 Decision Criteria for Selecting between Evacuation and Sheltering Recommendations for the Governor Vol. 1 2.6-26 Rev. 2 S/36 a
I xk i DOLKETET s PC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '87 JN 15 A9 :51 I Om. ' ; " 'n In the Matter of ) 00CKM K ',th wy ) PUBLIC SERVICE COMPANY OF NEW ) Docket No.(s) 60-443/444-OL HAMPSHIRE, ET AL. ) (Seabrook Station, Units 1 and 2) ) ) ) CERTIFICATE OF SERVICE I, Carol S. Sneider, hereby certify tnat on June 11, 1987 I made service of the within correspondence, by mailing copies tnereof, postage prepaid, of first class mail, or as indicated oy an asterisk, by Federal Express mail, to:
- Helen F. Hoyt, Chairperson
- Gustave A. Linencerger, Jr.
Atomic Safety & Licensing Board Atomic Safety & Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Builoing East West Towers Building 4350 East West Hignway 4350 East West Hignway Third Floor Mailroom Ihird Floor Mailroom Bethesda, MD 20814 Bethesda, MD 20d14
- Dr. Jerry Harcour
- Sherwin E. Turk, Esq.
I Atomic Safety & Licensing Board Office of tne Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatory Commission East West Towers Building Tenth Floor l 4350 East West Hignway 7735 Old Georgetown Road l Third Floor Mailroom Betnesda., MD 20d14 Bethesda, MD 20814 I l
- H.
Joseph Flynn, Esq.
- Stepnen E.
Merrill Assistant General Counsel Attorney General Office of General Counsel George Dana Bisoee { Federal Emergency Management Assistant Attorney General i Agency Office of tne Attorney General 500 C Street, S.W. 25 Capitol Street Washington, DC 20472 Concord, dd 03301 l l l i 1 l I I l
- g!
.}
- Docketing and Service Paul A.
Fritzsene, Esq. U.S. Nuclear Regulatory Office of the Public Advocate Commission State House Station 112 l Washington, DC. 20555 Augusta, ME 04333 j Rooerta C. Pevear Diana P. Randall . State Representative 70 Collins Street Town of-Hampton Falls SeaorooK, NH 03874 Drinkwater Road Hampton Falls, NH 03844 Atomic Safety & Licensing Rooert A. Backus, Esq. Appeal Board. Panel Bacxus, Meyer & Solomon U.S.. Nuclear Regulatory 116 Lowell Street l Commission P.O. Box bl6 Washington, DC 20555 Manchester, NH 03106 Atomic Safety & Licensing Jane Doughty H Board Panel Seacoast Anti-Pollution League U.S. Nuclear Regulatory 5 Market Street Commission Portsmouth, NH 0J801 Washington, DC 20555 Paul McEachern, Esq. J. P. Nadeau Matthew T. Brock, Esq. Board of Selectmen Shaines & McEachern 10 Central Road 25 Maplewood Avenue Rye, NH 03870-P.O. Box 360 Portsmouth, NH 03801 Sandra Gavutis, Chairperson Calvin A. Canney Board of Selectmen City Manager RFD 1, Box 1154 City Hall Rte. 107 126 Daniel Street E. Kingston, NH 03827 Portsmouth, NH 03801 Senator Gordon J. Humphrey Angelo Macniros, Chairman U.S. Senate Board of Selectmen l Washington, DC 20510 25 Hign Road (Attn: Tom Burack) Newoury, MA 10950 Senator Gordon J. Humpnrey Peter J. Matthews 1 Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton) NeWouryport, MA 01950 Donald E. Chick William Lord Town Manager Board of Selectmen Town of Exeter Town Hall 10 Front Street Friend Street Exeter, NH 03d33 AmesDury, MA 01913
l' ~ L Brentwood Board of Selectmen Gary W. Holmes, Esq. RFD Dalton Road Holmes & Ellis Brentwood, NH 03d33 47 Winnacunnet Road dampton, Nd 03041 Philip Anrens, Esq. Diane Curran, 8sq. Assistant Attorney General darmon & Weiss Department of the Attorney Suite 430 General 2001 S Street, N.W. State House Station #6 Wasnington, DC 20009 Augusta, ME 04333
- Tnomas G. Dignan, Esq.
Richard A. Hampe, Esq. R.K. Gad III, Esq. Hampe & McWicholas Ropes & Gray 35 Pleasant Street 225 Franklin Street Concord, NH 03301 Boston, MA 02110 Beverly Hollingworth
- Edward A. Thomas 209 Winnacunnet Road Federal Emergency Management Hampton, NH 03842 Agency 442 J.W. McCormack (POCH)
Boston, MA 02109 William Armstrong Micnael Santosuosso, Cnairman Civil Defense Director Board of Selectmen Town of Exeter Jewell Street, RFD 2 10 Front Street South Hampton, Nd 03827 l Exeter, NH 03833 Robert Carrigg, Cnairman Anne S. Goodman, Cnairperson Boaro of Selectmen Board of Selectmen Town 6 fice 14-1b NewmarKet Road c Atlant.f.c Avenue Durham, NH 03824 North Hampton, NH 03862 Allen Lampert Sneldon J. Wolfe, Chairperson Civil Defense Director Atomic Safety and Licensing Town of Brentwood Board Panel 20 Franklin Street U.S. Nuclear Regulatory Commission Exeter, Nd 03833 Wasnington, DC 20555 Dr. Emmeth A. Luebke Cnarles P. Graham, Esq. Atomic Safety & Licensing Board McKay, Murpny a Graham U.S. Nuclear Regulatory Old Post Office Square Commission 100 Main Street East West Towers Building Amesoury, MA 01913 4350 East West Hignway Third Floor Mailroom I Bethesda, MD 20814 Judith d. Mizner, Esq. Silvergate, Gertner, Baxer, Fine, Good & Mizner 88 Broad Street Boston, MA 02110 "li ...y ~ .;.i< Rep. Edward: Jj f Markey,: Chairman' U.S..' House'of Representatives:- Subcommittee on' Energy. ' Conservation and Power-s Room F2-316' House' Office' Building. A n n e x =.N o. '2,.. - Washing ton,.:. DC'. 2 0515 - Attn: LindatCorreia- .h w :s. n avD Carol S. Sneicer j . Assistant. Attorney. General-June.11,1987k, Dated: ( i I l g.;, i. 1 l e 4- .}}