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| {{#Wiki_filter:* UNITED STATES OF AME RI CA NUCLEAR REGULATORY COMMISSION. | | {{#Wiki_filter:* UNITED STATES OF AME RI CA NUCLEAR REGULATORY COMMISSION. |
| Before the* Atomic Safety and Licensing Board In the Matter of PUBLIC SERVICE ELECTRIC & GAS COMPANY (Salem Nuclear Station, Unit Generating | | Before the* Atomic Safety and Licensing Board Doeket No. 50-272 In the Matter of Proposed Issuance of Amendment to Facility PUBLIC SERVICE ELECTRIC Operating License |
| #1) | | & GAS COMPANY to DPR-70 (Salem Nuclear Generating Station, Unit #1) |
| ....... . , .. -* rj>* | | ~-... .......~.~. . ,.. ~~ -* |
| '* .. Doeket No. 50-272 Proposed Issuance of Amendment to Facility Operating License to DPR-70 ** * ** . THE. TOWNSHIP OF LOWER ALLOWAYS CREEK :RESPONSE TO NRC STAFF OBJECTIONS AND MorION TO STRIKE PORTIONS OF TESTIMONY FILED BY INTERVENOR TOWNSHIP OF LCMER ALLOWAYS CREEK IN RESPONSE TO QUESTIONS POSED BY THE LICENSING BOARD BY ORDER OF APRIL | | rj>* u~~~;~:i,-:::~~2~:. '* .. |
| * 19 , 1979 The Township of Lower Alloways Creek opposes the NRC Staff Motion to Strike testimony of Dr. Richard E. Webb and Dr. Ear 1 A. Gulbransen. | | ** * * . THE. TOWNSHIP OF LOWER ALLOWAYS CREEK |
| Annexed hereto is the Affidavit of Dr. Earl A. Gulbransen. | | :RESPONSE TO NRC STAFF OBJECTIONS AND MorION TO STRIKE PORTIONS OF TESTIMONY FILED BY INTERVENOR TOWNSHIP OF LCMER ALLOWAYS CREEK IN RESPONSE TO QUESTIONS POSED BY THE LICENSING BOARD BY ORDER OF APRIL |
| | * 19 , 1979 The Township of Lower Alloways Creek opposes the NRC Staff Motion to Strike testimony of Dr. Richard E. Webb and Dr. Ear 1 A. Gulbransen. Annexed hereto is the Affidavit of Dr. Earl A. Gulbransen. |
| The Attorney for Township of Lower Alloways Creek requests oral argument to oppose _the Motion to Strike the testimony of Dr. Richard E. Webb in that said Motion to Strike is in the nature of legal argument and does not require an Affidavit in rebuttal. | | The Attorney for Township of Lower Alloways Creek requests oral argument to oppose _the Motion to Strike the testimony of Dr. Richard E. Webb in that said Motion to Strike is in the nature of legal argument and does not require an Affidavit in rebuttal. |
| July 9, 1979 ial r the Intervenor r Alloways Creek I -i
| | ial r the Intervenor r Alloways Creek July 9, 1979 I |
| * UNITED' STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board , ? J>""''-'"')
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| In the Matter PUBLIC SERVICE ELECTRIC & GAS COMPANY (Salem Nuclear Generating Unit # 1) .*.* .. Docket No. 50-272 Proposed Issuance of Amendment to Facility Operating License . No. DPR-70 Earl A. Gulbransen, of full age, upon his oath deposes and says: 1.
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| * I have reviewed the NRC Staff Motion to Strike my testimony dated June 29, 1979. 2. The purpose of my testimony*was to indicate:
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| a} A melt down or explosion in the containment building could involve the spent fuel pool by means . of a pool fracture or other mechanism causing loss of water. *. ' ..... * ..
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| | *UNITED' STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board |
| * b) An explosion or melt down as posed in the Board's question could create maintenance or accessbility problems due to radioactivity* | | , ? |
| or. loss of power:.,. . ..... Sworn to and before me July, 1979. to of ,_,.. .* ,L, . , /.** .*,(./; :;,(:( / -EARL A. GULBRANSEN | | J>""''-'"') -***.' |
| .._.. !JllEN M p * ,.. "' .N'orary Publ. | | ...... |
| * I\ lTON' ICOfNewJ . . oa e:J<pfres NoV: | | . ~~*-...*:* |
| .* 1983 ' ' | | Docket No. 50-272 .....*.. |
| ... -..... | | In the Matter of:*-~ |
| --* n;. . ' "e I .. UNITED STATES OF ]\MERICA_ | | Proposed Issuance of PUBLIC SERVICE ELECTRIC Amendment to Facility |
| v"\,* .. NUCLEAR REGULATORY COMMISSION | | & GAS COMPANY Operating License . |
| * Before the* Atomic s*af*ety and Licensing Board In the Matter of PUBLIC SERVI <E ELECTRI"C | | No. DPR-70 (Salem Nuclear Generating Sta*t~on,. Unit #1) |
| & GAS CO. (Salem Gene%atin9 Station Unit fl) * * . | | .*.* .. |
| * DOCKET NO, CE;RTIFICATE OF SERVICE I hereby certify that copies of NRC Staff Objection | | Earl A. Gulbransen, of full age, upon his oath deposes and says: |
| & Motion TOLAC's in the above captioned matter have been served upon the* attached list by the Utiited States mail at the post office in Northfield, N.J., with proper postage thereon, this 10th day of July , 1979. Dated: ,Tuly *10, 1979 /s/ Carl Valore, Jr. CA:RL VALORE, Special Nuclear Counsel tor the Intervenor, the Township of Lower Alloways Creek "'-..*4,i L Gary L. Milhollin,. | | : 1. |
| Esq. Chairman, Atomic Safety & Licensing Board 1815 Jefferson Street Madison, Wisconsin 53711 Glen O. Bright Member, Atomic Safety & Licensing Board U. s. Nuclear Regulatory Washington, D. C. 20555 Dr .. James _C. Lamb, -111 ... Member, Atomic .. ety _& :, ., . * . .-... Licensing. | | * I have reviewed the NRC Staff Motion to Strike my testimony dated June 29, 1979. |
| Board Panel :'*?-,.-; .. _-:.. *: ;-.:* 313 Woodhaven Road * * * *-Chapel Hill, N. C. 27514 Chairman, Atomic Safety and Licensing Appeal Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Chairman, Aiomic Safety & Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Barry Smith, Esquire Off ice of the Executive Legal Director u. s. Nuclear Regulatory Commission Washington, D. C. 20555 Mark L. First, Esquire Deputy.Attorney General Department of Law & Public Safety Environmental Protection Section 36 West State Street Trenton, N. J. 08625 Mark J. Wetterhahn, Esquire for Troy B. Conner, Jr., Esq. 1747 Pennsylvania Avenue, N. W. Suite 1050 Washington, D. C. 20006 fiili ,, Richard Fryling, Jr., Esquire Assistant General Solicitor Public Service Electric & Gas Company 80 Park Place Newark, N. J. 07101 Keith Ansdorff, Esquire Assistant Deputy Public Advocate Department of the Public Advocate Division of Public Interest Advoca P. O. Box 141 | | : 2. The purpose of my testimony*was to indicate: |
| * Trenton, New Jersey 08601 Sandra T. Ayres, Esquire ... *. Department of the Public Advocate 520 East State Street Trenton, N. 08625 Mr. Alfred C. Coleman, Jr. Mrs. Eleanor G. Coleman 35 "K" Drive
| | a} A melt down or explosion in the containment building could involve the spent fuel pool by means |
| * Pennsville, N. J. 08070 Off ice of the Secretary Docketing and Service Section _ U. S. Nuclear Regulatory Commissio Washington, D. C. 20555 June D. MacArtor, Esquire Deputy Attorney General Tatnall Building, P. o. Box 1401 Dover, Delaware 19901 *Frederick J. Shon Atomic Safety & Licensing Board ' U.S. Nuclear Regulatory Commissi Washingtori, D-.c., 20555}}
| | . of a pool fracture or other mechanism causing loss of water. |
| | ~ *. ' |
| | |
| | ---~--~~* |
| | * b) An explosion or melt down as posed in the Board's question could create maintenance or accessbility problems due to radioactivity* or. |
| | loss of power:.,. |
| | - EARL A. GULBRANSEN |
| | . ~ ..... |
| | Sworn to and sub~ed to before me this</'~ of July, 1979. |
| | .* ,L,~ |
| | ,_,../.** . , .._.. !JllEN M p * |
| | ,.. "' .N'orary Publ. |
| | * I\ lTON' |
| | .*,(./; :;,(:( / *7~ ICOfNewJ ' ' |
| | . . oa e:J<pfres NoV: elrs~ |
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| | * 1983 L |
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| | ... - ..... *:.~ - -* n;. |
| | . ' |
| | "e UNITED STATES OF ]\MERICA_ |
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| | '*'c.~~-.:..!.0 I .. |
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| | '"-<-~ |
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| | NUCLEAR REGULATORY COMMISSION *.v~~**.-, |
| | "'-..*4,i Before the* Atomic s*af*ety and Licensing Board In the Matter of PUBLIC SERVI <E ELECTRI"C DOCKET NO, |
| | & GAS CO. |
| | (Salem Gene%atin9 Station ** |
| | Unit fl) |
| | .* |
| | * CE;RTIFICATE OF SERVICE I hereby certify that copies of TOLAC's NRC Staff Objection & Motion in the above captioned matter have been served upon the* attached list by deposit~iri the Utiited States mail at the post office in Northfield, N.J., with proper postage thereon, this 10th day of July , 1979. |
| | /s/ Carl Valore, Jr. |
| | CA:RL VALORE, JR~, Special Nuclear Counsel tor the Intervenor, the Township of Lower Alloways Creek Dated: ,Tuly *10, 1979 |
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| | ,, |
| | fiili Gary L. Milhollin,. Esq. Richard Fryling, Jr., Esquire Chairman, Atomic Safety Assistant General Solicitor |
| | & Licensing Board Public Service Electric & |
| | 1815 Jefferson Street Gas Company Madison, Wisconsin 53711 80 Park Place Newark, N. J. 07101 Glen O. Bright Member, Atomic Safety Keith Ansdorff, Esquire |
| | & Licensing Board Assistant Deputy Public Advocate U. s. Nuclear Regulatory ~ommission Department of the Public Advocate Washington, D. C. 20555 Division of Public Interest Advoca P. O. Box 141 |
| | * Dr ..James _C. Lamb, -111 ... Trenton, New Jersey 08601 Member, Atomic .. ~af ety _& :, ., . *. .- ... |
| | Licensing. Board Panel :'*?- ,.-; . _-:. *: ;-.:* Sandra T. Ayres, Esquire ... *. |
| | 313 Woodhaven Road * * * *- Department of the Public Advocate Chapel Hill, N. C. 27514 520 East State Street Trenton, N. ~* 08625 Chairman, Atomic Safety and Licensing Appeal Board Panel Mr. Alfred C. Coleman, Jr. |
| | U. S. Nuclear Regulatory Commission Mrs. Eleanor G. Coleman Washington, D. C. 20555 35 "K" Drive |
| | * Pennsville, N. J. 08070 Chairman, Aiomic Safety & |
| | Licensing Board Panel Off ice of the Secretary U. S. Nuclear Regulatory Commission Docketing and Service Section _ |
| | Washington, D. C. 20555 U. S. Nuclear Regulatory Commissio Washington, D. C. 20555 Barry Smith, Esquire Off ice of the Executive Legal Director June D. MacArtor, Esquire |
| | : u. s. Nuclear Regulatory Commission Deputy Attorney General Washington, D. C. 20555 Tatnall Building, P. o. Box 1401 Dover, Delaware 19901 Mark L. First, Esquire Deputy.Attorney General *Frederick J. Shon Department of Law & Public Safety Atomic Safety & Licensing Board ' |
| | Environmental Protection Section U.S. Nuclear Regulatory Commissi 36 West State Street Washingtori, D-.c., 20555 Trenton, N. J. 08625 Mark J. Wetterhahn, Esquire for Troy B. Conner, Jr., Esq. |
| | 1747 Pennsylvania Avenue, N. W. |
| | Suite 1050 Washington, D. C. 20006}} |
Response Submitted by Intervernor Township of Lower Alloways Creek to NRC Motion to Strike Portions of Re Webb & EA Gulbransen Testimony Re Aslb 790418 Order. Affidavit of EA Gulbransen & Certificate of Svc Encl| ML18079A762 |
| Person / Time |
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| Site: |
Salem  |
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| Issue date: |
07/09/1979 |
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| From: |
Valore C
VALORE, C. |
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| References |
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| NUDOCS 7908080007 |
| Download: ML18079A762 (5) |
|
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[Table view]
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Motion for 30-day Extension to File Testimony Re Consequences of Water Loss from Spent Fuel Storage Pool. Urges Postponement of 800422 Evidentiary Hearing, Accordingly.Notice of Appearance & Certificate of Svc Encl
ML18081B0861980-02-14014 February 1980
Request for Taking Official Notice of White House 800212, Fact Sheet,President'S Program on Radwaste Mgt, Due to Relevancy of First Bullet,Page 2 & Third Bullet,Page 6.W/ Certificate of Svc & Fact Sheet
ML18081A8881980-01-10010 January 1980
Opposition to Intervenors Coleman 791018 Request for Action Under 10CFR2.206.NRC Fulfilled Statutory Duty Per Endangered Species Act.No New Matters Raised by Intervenors Request
ML18081A8171979-12-18018 December 1979
Opposition to Public Advocate of State of Nj 791106 Request to Reopen Intervenors Coleman Contention 9.Appeal Is Proper Procedure If Intervenors Dissatisfied W/Aslb Initial Decision.Certificate of Svc Encl
ML18081A7471979-11-13013 November 1979
Response in Opposition to Public Advocate of State of Nj 791030 Supplemental Argument Supporting Motion for Reconsideration of Colemans Contention 13.Colemans Failed to Demonstrate Relevance of Claim.Certificate of Svc Encl
ML18081A6971979-10-30030 October 1979
Supplemental Argument on Behalf of Intervenors Coleman to Reopen Coleman Contention 13 Re Reracking of Spent Fuel Pool.Actual Figures of Radiation Exposure During Reracking of Peach Bottom Nuclear Station Never Received
ML18081A4181979-10-18018 October 1979
Petition Seeking NRC Issuance of Show Cause Order for Suspension &/Or Revocation of Ols.Operation of Facility Would Threaten Local Existence of short-nosed Sturgeon. Affidavit & Certificate of Svc Encl
ML18081A4871979-10-18018 October 1979
Seeks Show Cause Order & Suspension or Revocation of OL for Unit 1 & Stay or Licensing & Suspension or Revocation of CP for Unit 2.No Eia Performed Re Impact on Endangered Fish Species.Certificate of Svc Encl
ML18079A9711979-09-20020 September 1979
Applicant Comments on Request of Intervenors Coleman for Issuance of Order to Show Cause for Stay
ML18079B0891979-08-31031 August 1979
Opposes Intervenors Coleman 790801 Request That ASLB Reopen Record for Newly Discovered Evidence Re Contentions 2 & 6. Insp Document Has No Relevance & No Significance to Proceeding
ML19249B8201979-08-31031 August 1979
Petition to Amend 790802 Motion for Issuance of Show Cause Order & Stay of Licensing Procedure.Adds Addendum 7A & Contentions 8-10.Certificate of Svc Encl
ML19209C3871979-08-31031 August 1979
Motion,Submitted by Intervenors Coleman,That NRC Amend Request for Order to Show Cause & Stay Licensing.Seek Addl Contentions Re Cost/Benefit Analysis,Seismic Analysis & Class 9 Accidents
ML18081A4141979-08-31031 August 1979
Seeks Denial of Intervenors Coleman 790802 Motion for Reconsideration of Contention 13 Re Release of Radioactive Matl.No Justification for Late Filing.Criteria for Compliance W/Operation Objectives Defined in 10CFR50,App I
ML18079B1161979-08-29029 August 1979
Request by Intervenors Coleman That ASLB Accept Addl Argument on ASLB Question 4 Re Consideration of Class 9 Accidents.Nrc Admits That TMI Accident Was Class 9. Certificate of Svc Encl
ML18079B1151979-08-27027 August 1979
Response to ASLB Question 4 Re Class 9 Accidents.Tmi 790328 Accident Was Class 9,constituting Successive Failures of Operator Procedures & Equipment.Testimony in Present Proceedings Requires Wide Latitude.Certificate of Svc Encl
ML18079B0881979-08-21021 August 1979
Response to ASLB Question 4,submitted on Behalf of Intervenors Coleman.Alleges TMI Accident Was Class 9 Accident.Accident Posed Significant Risk to Health & Safety of Population & Environ.Certificate of Svc Encl
ML18079B0611979-08-20020 August 1979
Responds to Question 4 of ASLB 790710 Order.Forwards C Kepford Rept on TMI Accident.Prof Qualifications & Certificate of Svc Encl
ML18081A4111979-08-10010 August 1979
Requests That ASLB Order Extension Until 790831 for Response to Intervenors Coleman Request to Reopen Consideration of Contentions 2 & 6
ML18079B0461979-08-0303 August 1979
Forwards Re Webb 790723 Rept, TMI Accident:Was It Class 9 Accident, in Response to ASLB 790710 Question 4
ML19208C3681979-08-0202 August 1979
Requests Issuance of Order to Show Cause & Stay of Licensing Per 10CFR2.202 & 2.206.NRC Has Failed to Act on Info Re PA-NJ-MD Grid,Cost/Benefit Analysis,Expansion of Spent Fuel Pool & Lessons Learned Re TMI
ML18079B0851979-08-0202 August 1979
Request by Intervenors Coleman That ASLB Reconsider Dismissal of Contention 13.Intervenor State of Nj Supports Motion.Util Is Obliged Per 10CFR50 to Explore Alternatives to Spent Fuel Pool Expansion
ML19225D1441979-08-0202 August 1979
Request That NRC Issue Order to Show Cause & Request to Stay Licensing.Requests Intervenor Status.Submits List of Contentions & Partial List of Resouce Documents.Certificate of Svc Encl
ML18079B0871979-08-0101 August 1979
Request by Intervenors Coleman That ASLB Reopen Record Re Contentions 2 & 6.Intervenor State of Nj Supports Motion. Experiences at Northern State Power Co Are Pertinent to Proceedings
ML18079A7621979-07-0909 July 1979
Response Submitted by Intervernor Township of Lower Alloways Creek to NRC Motion to Strike Portions of Re Webb & EA Gulbransen Testimony Re ASLB 790418 Order. Affidavit of EA Gulbransen & Certificate of Svc Encl
ML18079A8311979-07-0606 July 1979
Request Submitted by Util for Denial of Intervenors Coleman 790625 Request for Reconsideration of Dismissal of Coleman Contention 7.NRC Must Remand Matter to Aslb. Certificate of Svc Encl
ML18079A8291979-07-0606 July 1979
Request Submitted by Util for Denial of Intervenors Coleman 790626 Request That ASLB Compel Licensee to Suppl Responses to Interrogatories 1,3 & 6.Questions Have No Relation to Grid Strap Problem
1984-01-25
[Table view] |
Text
- UNITED STATES OF AME RI CA NUCLEAR REGULATORY COMMISSION.
Before the* Atomic Safety and Licensing Board Doeket No. 50-272 In the Matter of Proposed Issuance of Amendment to Facility PUBLIC SERVICE ELECTRIC Operating License
& GAS COMPANY to DPR-70 (Salem Nuclear Generating Station, Unit #1)
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- * * . THE. TOWNSHIP OF LOWER ALLOWAYS CREEK
- RESPONSE TO NRC STAFF OBJECTIONS AND MorION TO STRIKE PORTIONS OF TESTIMONY FILED BY INTERVENOR TOWNSHIP OF LCMER ALLOWAYS CREEK IN RESPONSE TO QUESTIONS POSED BY THE LICENSING BOARD BY ORDER OF APRIL
- 19 , 1979 The Township of Lower Alloways Creek opposes the NRC Staff Motion to Strike testimony of Dr. Richard E. Webb and Dr. Ear 1 A. Gulbransen. Annexed hereto is the Affidavit of Dr. Earl A. Gulbransen.
The Attorney for Township of Lower Alloways Creek requests oral argument to oppose _the Motion to Strike the testimony of Dr. Richard E. Webb in that said Motion to Strike is in the nature of legal argument and does not require an Affidavit in rebuttal.
ial r the Intervenor r Alloways Creek July 9, 1979 I
- UNITED' STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
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Docket No. 50-272 .....*..
In the Matter of:*-~
Proposed Issuance of PUBLIC SERVICE ELECTRIC Amendment to Facility
& GAS COMPANY Operating License .
No. DPR-70 (Salem Nuclear Generating Sta*t~on,. Unit #1)
.*.* ..
Earl A. Gulbransen, of full age, upon his oath deposes and says:
- 1.
- I have reviewed the NRC Staff Motion to Strike my testimony dated June 29, 1979.
- 2. The purpose of my testimony*was to indicate:
a} A melt down or explosion in the containment building could involve the spent fuel pool by means
. of a pool fracture or other mechanism causing loss of water.
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- b) An explosion or melt down as posed in the Board's question could create maintenance or accessbility problems due to radioactivity* or.
loss of power:.,.
- EARL A. GULBRANSEN
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Sworn to and sub~ed to before me this</'~ of July, 1979.
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"e UNITED STATES OF ]\MERICA_
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NUCLEAR REGULATORY COMMISSION *.v~~**.-,
"'-..*4,i Before the* Atomic s*af*ety and Licensing Board In the Matter of PUBLIC SERVI <E ELECTRI"C DOCKET NO,
& GAS CO.
(Salem Gene%atin9 Station **
Unit fl)
.*
- CE;RTIFICATE OF SERVICE I hereby certify that copies of TOLAC's NRC Staff Objection & Motion in the above captioned matter have been served upon the* attached list by deposit~iri the Utiited States mail at the post office in Northfield, N.J., with proper postage thereon, this 10th day of July , 1979.
/s/ Carl Valore, Jr.
CA:RL VALORE, JR~, Special Nuclear Counsel tor the Intervenor, the Township of Lower Alloways Creek Dated: ,Tuly *10, 1979
,,
fiili Gary L. Milhollin,. Esq. Richard Fryling, Jr., Esquire Chairman, Atomic Safety Assistant General Solicitor
& Licensing Board Public Service Electric &
1815 Jefferson Street Gas Company Madison, Wisconsin 53711 80 Park Place Newark, N. J. 07101 Glen O. Bright Member, Atomic Safety Keith Ansdorff, Esquire
& Licensing Board Assistant Deputy Public Advocate U. s. Nuclear Regulatory ~ommission Department of the Public Advocate Washington, D. C. 20555 Division of Public Interest Advoca P. O. Box 141
- Dr ..James _C. Lamb, -111 ... Trenton, New Jersey 08601 Member, Atomic .. ~af ety _& :, ., . *. .- ...
Licensing. Board Panel :'*?- ,.-; . _-:. *: ;-.:* Sandra T. Ayres, Esquire ... *.
313 Woodhaven Road * * * *- Department of the Public Advocate Chapel Hill, N. C. 27514 520 East State Street Trenton, N. ~* 08625 Chairman, Atomic Safety and Licensing Appeal Board Panel Mr. Alfred C. Coleman, Jr.
U. S. Nuclear Regulatory Commission Mrs. Eleanor G. Coleman Washington, D. C. 20555 35 "K" Drive
- Pennsville, N. J. 08070 Chairman, Aiomic Safety &
Licensing Board Panel Off ice of the Secretary U. S. Nuclear Regulatory Commission Docketing and Service Section _
Washington, D. C. 20555 U. S. Nuclear Regulatory Commissio Washington, D. C. 20555 Barry Smith, Esquire Off ice of the Executive Legal Director June D. MacArtor, Esquire
- u. s. Nuclear Regulatory Commission Deputy Attorney General Washington, D. C. 20555 Tatnall Building, P. o. Box 1401 Dover, Delaware 19901 Mark L. First, Esquire Deputy.Attorney General *Frederick J. Shon Department of Law & Public Safety Atomic Safety & Licensing Board '
Environmental Protection Section U.S. Nuclear Regulatory Commissi 36 West State Street Washingtori, D-.c., 20555 Trenton, N. J. 08625 Mark J. Wetterhahn, Esquire for Troy B. Conner, Jr., Esq.
1747 Pennsylvania Avenue, N. W.
Suite 1050 Washington, D. C. 20006