ML20245K325
| ML20245K325 | |
| Person / Time | |
|---|---|
| Issue date: | 06/27/1989 |
| From: | Urban P NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Huyer D STATISTICA, INC. |
| Shared Package | |
| ML19317A604 | List: |
| References | |
| FRN-53FR32060, RULE-PR-52 AC61-2-01, NUDOCS 8907050092 | |
| Download: ML20245K325 (6) | |
Text
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' ef jo,, UNITED STATES
'8 ) n NUCLEAR REGULATORY COMMISSION t, -
- 4j WASHINGTON, D. C. 20555 l %,.+ June 27, 1989 TO: Darlene huyer NUDOCS PI-24 FROM: x
[ Pamela Urban OGC 15-B-18
SUBJECT:
REGULATORY HISTORY "EARLY SITE PERMITS; STANDARD DESIGN CERTIFICATIONS; AND COMBINED LICENSES FOR NUCLEAR POWER REACTORS" Enclosed are the documents of central relevance to the above rulemaking. The documents have been marked with the appropriate designator and have been marked either "PDR" or. j "CF."
Please provide me with a computer printout of the documents as soon as possible. ';
4 If you have any questions, please call me on x2-1632.
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Thank you.
Enclosures:
1 As stated i
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' DOCKET NO. P'R'-52 (53FR32060).
'In the Matter of EARLY SITE PERMITS: STANDARD DESIGN CERTIFICATION AND COMBINED LICENSES FOR NUCLEAR POWER REACTORS
- DATE DATE OF TITLE OR DOCKETED DOCUMENT DESCRIPTION OF DOCUMENT 09/28/06 09/26/88 COMMENT OF GREEN. HENNINGS & HENRY (LEWIS C. GREEN) ( 1) 09/28/88 09/24/88 COMMENT OF THOMAS L. KANE. JR. ( 2) 09/28/88 09/26/88 COMMENT OF FAITH YOUN8 ( 3) 09/29/88 09/25/88 COMMENT OF MRS. JOSEPH E. CLEMENT ( 8) 09/30/88 09/26/88 REQUEST FOR AN EXTENSION OF COMMENT PERIOD 10/01/88 10/27/88 COMMENT OF LISA TROYER ( 52) 10/03/08 09/29/88 COMMENT OF MR. JAMES A. MASSEY ( 60) 10/03/88 09/29/88 COMMENT OF INDIANA STATE 80ARD OF HEALTH (T. S. D ANIELSON. J R. . ' N. D. . M. P. H. )' ( 61) 10/03/88 09/29/88 REQUEST FOR AN EXTENSION OF COMMENT PERIOD 10/03/06 09/28/88 REQUEST FOR A 60 DAY EXTENSION OF COMMENT PERIOD 10/03/88 09/30/88 COMMENT OF SIDNEY J. GOODMAN. P. E. ( 4) 10/03/88 09/29/88 COMMENT OF NATIVE AMERICANS FOR CLEAN ENVIRONMENT (JESSIE DEERINWATER. CHAIRPERSON) ( 5) 10/03/88 09/27/88 COMMENT OF LONE STAR BREEN (LANS BAKER) ( 6) i 10/03/88 09/26/88 COMMENT OF MR. & MRS. SAMUEL KAMER ( 7) 10/05/88 09/29/88 REQUEST FOR AN EXTENSION OF COMMENT PERIOD 10/06/88 10/04/88 COMMENT OF CYNTHIA R. CROSSEN ( 9) 10/11/09 10/02/88 COMMENT OF PATRICIA R. PRATT ( 10) 10/11/88 10/03/88 REQUEST FOR A 90 EXTENSION OF COMMENT PERIOD
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DOCKET ND. PR-92 (53FR32060)
DATE DATE OF ~ TITLE OR DOCKETED DOCUMENT DESCRIPTION OF DOCUMENT l
10/11/88 10/03/08 10/11/88 10/03/88 REQUEST FOR AN EXTENSION OF COMMENT PERIOD 10/11/88 10/03/88 REQUEST FOR AN EXTENSION OF COMMENT PERIOD 10/11/08 10/06/88 COMMENT OF FRANCES WEBB ( 12) 10/13/88 10/03/98 COMMENT OF NORTHWEST ENVIRONMENTAL ADVOCATES (NINA BELL. EXECUTIVE DIRECTOR) ( 13) 10/13/88 10/09/88 COMMENT OF PETER R. MITCHELL ( 14) 10/14/08 10/05/88 COMMENT OF REED COLLEGE (LAWRENCE RUBY) ( 15) 10/14/88 10/07/88 COMMENT-0F PEACH BOTTOM ALLIANCE (JEAN 5. EWING) ( 16) 10/14/88 10/11/88 COMMENT OF STEPHAN MCCREA ( 17) 10/14/88 10/11/88 REQUEST FOR A 60 EXTENSION OF COMMENT PERIOD 10/17/88 10/14/88 REQUST FOR AN EXTENSION OF COMMENT PERIOD 10/17/88 10/10/88 COMMENT OF JAMES A. STEWART ( 18) 10/19/88 10/18/06 EXTENSION OF COMMENT PERIOD.TO NOVEMBER 7, 1988 10/19/88 10/16/88 REQUEST FOR A 60 DAY EXTENSION OF COMMENT PERIOD 10/20/88 10/18/88 COMMENT OF MARYLAND NUCLEAR SAFETY CDALITION (PATRICIA BIRNIE) ( 19) 10/20/88 10/17/88 COMMENT OF BOROUBH OF PALMYRA ENVIR. ADVISORY COMM.
(PATRICE MELONI) ( 201 10/21/88 10/10/08 COMMENT OF ANNETTE B. COTTRELL ( 21) 10/21/88 10/16/88 COMMENT OF MARY JANE WILLIAMS ( 22) 10/21/08 10/18/88 COMMENT OF ECOLOGY TASK FORCE (ALBERT G. COHEN) ( 23) 10/21/88 10/16/88 COMMENT OF ECOLOGY / ALERT (E. NEMETHY. SECRETARY) ( 24) 10/24/88 10/24/88 COMMENT OF ATTORNEY BENERAL OF NORTH CAROLINA (JO ANN SANFORD. KAREN E. LONS) ( 25) 10/24/08 10/20/08 COMMENT OF BRUCE CAMPBELL ( 26) 10/24/88 10/14/88 COMMENT OF JBONNER ENGINEERIN8 SERVICES (J0hN P. BONNER) ( 27)
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DOCKET NO. PR-92 (93FR32060)
'DATE DATE OF TITLE OR DOCKETED DOCUMENT DESCRIPTION OF DOCUMENT 10/24/88 10/19/88 COMMENT OF UNIVERSITY OF LOWELL (GILBERT BROWN. PROFESSOR) ( 28) 10/24/08 10/19/88 COMMENT OF EMANUEL STEIN ( 30) 10/24/88 10/18/88 COMMENT OF ROCKWELL INTERNATIONAL (R. T. LANCET) ( 31)
L 10/24/88 10/20/88 COMMENT OF INTERDISCIPLINARY THEORETICAL ECOLOGY (PETER J. BRALVER) ( 32) 10/24/88 10/19/88 COMMENT OF ALLIANCE FOR SURVIVAL i- (MARION PACK. EXECUTIVE DIRECTOR) ( 33) 10/24/88 10/20/08 COMMENT OF MARY ELLEN NOBLE ( 34) 10/24/88 10/19/88 COMMENT OF STATE OF CONNECTICUT (HORACE H. BROWN. UNDER SECRETARY) ( 35) 10/24/88 10/20/88 REQUEST FOR A 60 DAY EXTENSION OF COMMENT FERIOD 10'/24/88 10/20/88 COMMENT OF MARY BYE ( 36) 10/24/88 10/20/88 COMMENT OF MAINE NUCLEAR REFERENDUM COMMITTEE (ROBIN GLASSMAN) ( 29) 10/25/88 10/20/88 COMMENT OF SILVIO J. ONEST1. M.D. ( 37) 10/25/88 10/20/88 COMMENT OF MELBA GARBARINO ( 38) 10/25/88 10/19/88 COMMENT OF THE ABLBAMA CONSERVANCY (LE!F EASON) ( 39) 10/25/98 10/24/88 COMMENT OF NEW YORK STATE ENERGY OFFICE (HOWARD A. FROMER. GENERAL COUNSEL) ( 40) 10/26/88 10/24/88 COMMENT OF STATE OF NORTH CAROLINA (KAREN E. LONG) ( 41) 10/26/08 10/21/08 COMMENT OF GE STOCKHOLDERS' A.A. N'; CLEAR POWER (BETTY SCHROEDER) ( 42) 10/26/06 10/21/88 COMMENT OF GPU NUCLEAR (J. L. SULLIVAN. JR.. DIRECTOR.) ( 43) 10/26/88 10/2i/88 COMMENT OF U. S. CHAMBER OF COMMERCE (SUSAN C. MOYA MANABER) ( 44) 10/27/88 10/24/88 COMMENT OF MR. & MRS. MILES H0YE ( 45) 10/27/88 10/23/08 COMMENT OF EYELYN MADISON ( 46) i I
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DOCKET NO. PR-92 (EJFR32060)
DATE DATE OF TITLE OR DOCKETED DOCUMENT DESCRIPT!DN OF DOCUMENT 4 10/27/88 10/22/88 COMMENT OF WELLS EDDLEMAN ( 47) 10/27/88 10/16/88 COMMENT OF ECOLOGY / ALERT (E. NEMETHY. SECRETARY) ( 48)- l 10/27/88 10/24/88 COMMENT OF MARVIN I. LEWIS ( 49) l 10/27/88 10/23/88 COMMENT OF COMMENT / REQUEST FOR 60 DAY EXTENSION (NANCY LEE LAWRENCE) ( 50) 1 10/28/88 10/25/08 COMMENT OF ERNEST AND EVELYN CHESLOW ( 51) 11/02/88 10/28/88 COMMENT OF THE BEAR BOOKSHOP (JOHN GREENBERG) ( 53) 11/04/08- 10/27/88 COMMENT OF SUSOUEHANNA ENVIRONMENTAL ADVOCATES (GERALD R. SCHULTZ) ( 54) 11/04/08 10/22/88 COMMENT OF U. S. METRIC ASSOCIATION. INC.
(VALERIE ANTOINE. EXECUTIVE DIRECTOR) ( 55) 11/04/88 10/31/88 COMMENT OF AUDREY CLARK ( 70) 11/07/88 11/07/88 COMMENT OF NUCLEAR MANAGEMENT AND RESOURCES COUNCIL (BYRON LEE. JR.) ( $6) 11/07/88 11/07/88 COMMENT OF DEPARTMENT OF ENERGY' (THEODORE ~J. SARRISH. ASSISTANT) ( 57) 11/07/88 11/03/88 COMMENT CF STONE & WEBSTER ENGINEERING CORPORATION (R. B. BRADBURY. CHIEF ENGINEER.) ( 59) '
11/07/88 11/07/88 COMMENT OF LEBOEUF. LAMB. LElBY & MACRAE i
(HARRY H. VO!GT) ( 63) 11/07/88 11/07/88 COMMENT OF AMERICAN NUCLEAR ENERBY COUNCIL (EDWARD M. DAVIS) ( 64) >
11/08/08 !!/04/88 COMMENT OF NUCLEAR INFORMATION AND RESOURCE SERVICE (MICHAEL MARIOTTE) ( 58) 11/08/88 11/07/88 COMMENT OF HARMON. CURRAN & TOUBLEY (DEAN R. TOUSLEY. DIANE CURRAN) ( 62) 11/08/08 11/04/88 COMMENT OF URENCO (JOSEPH DISTEFAND) ( 65) 11/08/88 11/04/08 COMMENT OF ATTORNEY SENERAL OF NEW YORK (ROBERT ABRAMS) ( 66)
- 11/09/88 11/07/88 COMMENT OF BISHOP. COOK. PURCELL & REYN0LDS (JOSEPH B. KNOTTS) ( 67) l-i L___________________._
. DOCKET NO. PR-52 (S3FR32060)
-DATE DATE OF TITLE OR DOCKETED . DOCUMENT DESCRIPTION OF DOCUMENT 11/09/88 11/05/08 11/09/88 11/05/88 COMMENT.0F OH10 CITIZENS FOR RESPONSIBLE ENERGY INC (SUSAN L. H!ATT) ( 68) 11/10/88 11/07/88 COMMENT OF COMBUSTION ENGINEERING (A. E. SCHERER) ( 69)
!!/14/88 11/07/98 COMMENT OF WESTINGHOUSE ELECTRIC COPROATION (R. J. SLEMBER) ( 71) 11/14/08 11/09/88 COMMENT OF OHIO CITIZENS FOR RESPONSIBLE ENERGY INC (SUSAN L. HIATT) ( 72) 11/14/88 11/07/88 COMMENT OF GENERAL ELECTRIC COMPANY (P. W. MARRIOTT. MANAGER LICENSING) ( 73) 11/18/88 11/07/88 COMMENT OF AMERICAN NUCLEAR ENERGY COUNCIL (EDWARD M. DAVIS) ( 74) 12/05/88 11/01/88 COMMENT OF DANIEL HARRISON ( 75) 02/22/89 02/03/89 COMMENT OF SENATOR JAMES A. MCCLURE < 76) 03/15/89 03/10/89 COMMENT OF WESTINGHOUSE ELECTRIC CORPORATION (THEODORE STERN. VICE PRESIDENT) ( 77) 03/21/89 02/02/89 SECY-89-036: RULEMAKING ON EARLY SITE PERMITS.
DESIGN CERTIFICATIONS. AND COMBINED LICENSES 03/21/09 03/17/09 COMMENT OF NUCLEAR POWER OVERSIGHT COMMITTEE (JAMES O'CONNOR. CHAIRMAN) ( 78) 03/21/89 03/17/89 COMMENT OF COMBUSTION ENGINEERING (SHELBY BREWER. PRESIDENT) ( 79) 03/21/89 03/21/89 COMMENT OF NUCLEAR MANAGEMENT AND RESOURCES COUNCIL (BYRON LEE. JR. PRESIDENT) ( 80) 04/10/89 04/06/89 COMMENT 0F GEORGE BENNETT ( 81) i 04/10/89 04/07/89 FEDERAL REGISTER NOTICE - FINAL RULE 04/24/89 04/19/B9 COMMENT OF SENERAL ELECTRIC COMPANY (BERTRAM WOLFE. VICE PRESIDENT) ( 82) 05/15/89 05/10/09 COMMENT OF WESTINGHOUSE ELECTRIC CORPORATION {
(THEODORE STERN. VICE PRESIDENT) ( 83) 10/11/8(' 10/03/88 C0KMENT OF WAL8 RIDGE J. POWELL ( 11) l.
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Secretary, Docketing and Service Branch 00-, ' VV hp United States Nuclear Regulatory Commission / 'y Washington, D.C. 20555 1
Re: Proposed rule on early site permits, standard design certifications, and combined licenses !
August 23, 1988 Federal Register 32060 et seg.
Dear Sir:
We have only now heard of this proposed rule, and will not have time to analyze it in detail in order to file comments by October 24, 1988. That comment period should be extended by at least sixty days, in order to let the citizens be heard.
Preliminary comments are set out below. )
Apparently this new rule would eliminate the right of the state:in which a 1 nuclear power plant would be situated to' block construction of a reactor at a site i which cannot be safely and quickly evacuated. That would be intolerable.
Bureaucrats in Washington are not the people to decide whether a site can be i safely evacuated. That should be decided by the state and local officials. There i is no legitimate national interest in forcing upon the people a reactor at a site
. )
which cannot be safely evacuated. " Theonly real interest which could lead to this ;
new rule is .the interest of politics, evidenced by campaign contributions from the I nuclear' industry. This proposal is especially offensive, coming as it does from an l administration which preaches the doctrine of state's rights. I The idea of certifying a standard design could be a sensible idea, if it were sensibly implemented. But this proposal would permit certification of designs only slightly improved over existing designs. Because that will be less expensive than l developing a really advanced design which will fully satisfy the goals of safety with I passive safety features and without reliance Tupon "probabilistic' risk assessment,"'
this proposal will, actually: discourage development 'of advanced designs. Standard- l ized design certification'should be reserved for really advanced new designs.1 Further, this proposal would not require a formal adjudicatory hearing for a design certification. That would be a great mistake. This whole subject is much too complicated to be dealt with in a rule-making procedure.
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GREEN, HENNINea & HENRY i
U.S. Nuclear Regulatory Commission September 26, 1988-Page Two Apparently ,this proposal wouldEseekt'to limit 1what1the NRCa might: require . p afters the reactor"ist builteto improve its safety. That is probablyaillegall and is certainly foolish. Nobody should attempt now to limit what the government can do in the future to improve the safety of these devices.
The one-step licensing process which is proposed appears to be simply an ef-
. fort to circumvent the statute. Even for a standardized design, theV one-stepr 0processe appears to, be_ Illegal, and is certainly foolish. The people have a right to be heard on these matters, at each step, and the entire process will benefit from citizen input. The': thirty da'y' timelperiod for7 citizens: to'requestt a- hearing,' and to J assemble their entire case in order to obtain a hearing, is a sham. The citizens could not possibly meet that requirement. Nobody should have to prove his entire case in order to obtain a hearing. Nobody should have to try to assemble his en-tire case in thirty days, j Further, apparently it is proposed to extend this one-step process to the reactor designs which already exist, not merely the advanced standardized designs. 4 There is no legitimate -reason to do that, and every reason not to do that. That l would provide further disincentive to research and development of advanced, safe J designs.
I (This'. entire 7 rule should be; scrapped.;
Very trul urs, l
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Lewis C. Green LCG:ggi cc: The Honorable John C. Danforth l The Honorable Christopher Bond The Honorable William Clay The Honorable John Buechner The Honorable Richard Gephardt i
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00CKE Secretary, Docketing and ServiceBranch BR AE" U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Sir:
I wish to express my opposition to the plan of the Nuclear Regulatory Commission to change the licensing proceedure-for nuclear plants to a one-step action. .I am dismayed that such a plan would.even be-considered.
I am also against the inordinately swift time schedule set for hearings on this one-step plan.
Surely an action of this importance requires more time
.for public consideration and input. The very rush of the hearings casts some doubt on the purpose of_the one-step plan which would effectifvel'y.dliminhte'thed publicis?involvemen61' 4n nucleariplant! construction".7 Thepast history of nuclear power' plant problems both in our nation and internationally should prove that total societal involvement is. crucial to the sucessful and safe placement and' construction as well as the need for such dangerous facilities.- Frequently public studies have made important changes in plans of the nuclear industry and public involvement has often discovered-serious difficulties in the nuclear industries activities.
I urge an extension of the 60 day limit on hearings and look very unfavorably on the one-step licensing of nuclear power plants as it would be turning control away from the public and giving it to the industry - which has a bad history of safety and costs.
Respectfully,
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Thomas L. Kane CC: Senator John Glenn Senator Howard Metzenbaum Representative Douglas Applegate l
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., (201) 444-0283 September'30, 1988 2 :22 0Fr.m:
Dear Secretary lfor.NRC:
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,y The Nuclear Regulatory Commission (NRC) richly. deserves'to be known as Nobody Really Cares.
Once more, they are trying.to sell'out the public safety on behalf-of the'short term financial. interests of the nuclear establishment.
The: proposed One-Step Licensing Rule,.as outlined in the enclosed NIRS Legislative alert, is another prime example.
of the NRC's corruption.
'I protest!
Sincerely, 1 f.
/ ray . 'pc Sidney J. Goodman, P.E.
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Environment
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Box 51-B Route 2, Vian, Oklahoma 74962 .p e ,
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September 29, 1988 !
F f b Samuel Chilk, Secretary
.hF p Docketing & Service Branch U.S N.R.C.
Washington, DC 20555 Greetings, I am writing on behalf of our organization to protest the proposed rule (10 CFR Part 52, Early Site Permits; Standard Decign Certifica-tions; and Combined Licenses for Nuclear Power Reactors) appearing in the August 23, 1988 FEDERAL REGISTER, beginning on page 32060.
NACE is an environmental group with a membership approaching 500 and we are greatly concerned over the hazards created in the world by the nuclear industry in general and are presently very much alarmed by your suggestion that Congress pass legislation authori-zing a one-step licensing process. We also think that your present proposed rule stretches your statutory authority and would impose a combined construction and operating license IN ADVANCE to any company seeking to build another reactor in this country.
The very idea of issuing "early site permits" good for 20 years is a conflict of terms. There is also evidence in the proposed rule that your agency intends to avoid every possible backfit to new !
reactors. There is no reason to extend new provileges to the current !
failed generation of nuclear reactors.
We vigorously oppose this proposed rule and ask for a 60 day exten- '
sion on the comment period to give ample time to the research and ,
study of this proposed rule, In lieu of the fact that no new reactors !
have been applied for since 1978, it seems that there is ample time to study this proposed rule issue. l Since ly, b -
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J ssie DeerInWater '
hairperson 1 Cc Congressman Mike Synar Senator David Boren Native Americans for a Clean Senator Don Nickles Environment ._
Principal Chief Wilma Mankiller P.O. Box 1671 Nuclear Information Resource Service Tahlequah, OK 74465 NACE file g)b
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LONE STARiGREEN " U R h
908 E. 56th' St., Austin, Texas 78751 --- ('d FA 3.ncG> ;m A* "-m r L 7215 Creekside Drive Austin, TX- 78752 September 27, 198 T T 3 P 2 4
Secretary, Docketing crrv.,_
and Service Branch DOCK [ nw2 ?w U.S. Nuclear Regulatory Commission M M" ~
Washington, DC 20555
Dear Secretary:
I am writing on behalf of Lone Star Green ( Austin), a local group of people working on a variety of Green issues in the community.
It has come to our attention that the NRC has proposed a number of changes in the rules for certification and licensing of nuclear power plants (Aug. 23, 1988, Federal Register, p. 32060 et seq.). We find the comment deadline of October 24, 1988, unreasonable and request the period for comments be extended for I
an additional 90 days to allow the public to submit comments after having an opportunity for discussion in the community.
We are gravely concerned that the proposed rules severely restrict participation by citizens, community groups, and local governments in decisions affecting the local health and environ-ment. It simply is not fair to so sharply limit our role, as to effectively shut us out of the process. To the contrary, the local level should have absolute veto power over these decisions:
grassroots democracy places power over health and environment matters in the local community.
Specifically, we oppose the proposed early site permit pro-cess, which will practically eliminate state and local participa-tion in siting decisions. As an alternative we propose that each )
potentially affected community have veto power over siting per- 1 mits.
Second, we oppose the proposed rule change that will severely restrict future backfit orders to remedy safety problems. As an alternative, we propose that all reactors must be made as safe as possible, regardless of cost. If nuclear reactors are too expen-sive to be made safe, they should be shutdown; if the nuclear industry can't make them safe, they should not make them at all.
This is especially true in light of the Price-Anderson protection that the industry has been given, which severely limits liability for the consequences of an unsafe reactor.
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. Third., we oppose the proposed standard design certification rule. Such.a rule would institutionalize defective;and inferior designs. As an alternative we propose that every design present--
ed must be significantly. safer than every existing facility and must demonstrably eliminate'all problems-discovered up to that time in previous designs. No design snould be institutionalized unless use.of.that design is accompanied by a' waiver of Price-Anderson protection and accompanied by a' bond to cover all po-tential damages that could result from acute or chronic adverse effects on the health and environment from failure of the design to perform as promised.
Fourth, we oppose'the proposed one-step licensing process, which appears to be an attempt to circumvent the requirements under the Atomic Energy Act of hearings at both construction and operation licensing. As an alternative, we propose more hearings be added to the process, that progress hearings be held quarter-ly, and that all hearings be held in the affected local com-munities.
Sincerely, Lang Baker, for Lone Star Green (Austin) cc: Hon. J. J. " Jake" Pickle, U.S. Congress Sen. Lloyd Bentson, U.S. Senate Sen. Phil Gramm, U.S. Senate
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i 00CKi W s RL Secretary N*
Docketing and Service Branch U.S. Nuclear Regulatory Commission Washington D.C. 20555 ,
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Dear Sir /Ms.,
I am. coordinator of the Susquehanna Environmental Advocates, a northeast Pennsylvania environmental group with 50 members and an extensive background in the nuclear power issue. I am working in this instance to strenously oppose the proposed one step-licensing rule, for the following reasons:
- 1. Citizens rights to intervene in'the licensing process should be expanded not abridged. The rule is obviously written to. curtail public participation.
- 2. There is no need for the early site permit procedure or the standard design certification procedure. They are both thinly disguised efforts tc make it easier for the nuclear power industry to obtain licenses. This is hardly surprising since you seem to think that your mission is to promote nuclear power.
- 2. The rule would enable the current generation of reactors-with unquestionable design defects - to be licensed under the new procedure.
- 4. The rule would effectively preclude citizen participation in licensing hearings.
- 5. This rule would sidestep state and local evacuation plan requirements.
Sincerely,
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Gerald R. Schultz cc: Rep. Paul Kanjorski Sen Arlen Specter NIRS GERALD R. 5CHULTZ ATTORNEY AT LAW 9A g _,
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