ML19305D070

Response in Opposition to Sc Sholly 800321 Motion to Compel Answers to Certain of Fourth Set of Interrogatories Re Restart Proceeding.Certificate of Svc Encl

ML19305D070
Person / Time
Site:	Three Mile Island
Issue date:	03/31/1980
From:	Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Sholly S Atomic Safety and Licensing Board Panel
Shared Package
ML19305D049	List: ML19305D048 ML19305D051 ML19305D058 ML19305D060 ML19305D062 ML19305D065 ML19305D070 ML19305D073 ML19305D077 ML19305D082 ML19305D089 ML19305D096 ML19305D102 ML19305D108
References
NUDOCS 8004140028
Download: ML19305D070 (20)

Text

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j- -. Lic 3/31/80 C

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

• In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

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LICENSEE'S ANSWER TO INTERVENOR STEVEN C. SHOLLY MOTION TO COMPEL OF MARCH 21, 1980 On March 21, 1980, Intervenor Steven C. Sholly's Motion to Compel Licensee to respond to certain of his Fourth

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Set of Interrogatoribs was served on Licensee. Licensee op-poses the Motion to Compel.

INTERROGATORY NOS.16-008 THROUGH 16-015. l Mr. Sholly moves to compel Licensee to respond to his Interrogatory Nos.16-008 through 16-015, to which Licensee objected on March 11, 1980. The interrogatories all relate to Sholly Contention 16 admitted by the Board on January 11, 1980, in its Second Special Prehearing Conference Order, and ad-dressed by the Board in a subsequent Order of January 25,'1980, in response to Licensee's motion for clarification or modifi-

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9 The issue between Mr. Sholly and Licensee over these interrogatories is simply whether, as admitted by the Board, Sholly Contention 16 embraces security of the Three Mile Island Site generally or the peculiar threat to TMI-l's industrial security posed by insiders, the potential for which is alleg-edly increased by the greater numbers of recovery personnel working at TMI-2. Mr. Sho11y's view of the scope of his con-tention, despite Board rulings to the contrary, is that it embraces security planning at Three Mile Island generally; his interrogatories seek the broadest possible information on secur-ity planning, equipment procedures and personnel. Licensee's view, based upon the Board rulings as to the scope of Contention 16, is that the Board did not authorize or envision a wholesale ,

attack on either Unit l's or Unit 2's security planning and im-plementation, but rather allowed a very limited question as to the adequacy of TMI-l's industrial security occasioned by the unique situation of TMI-2's decontamination and recovery activ-ities taking place right next door. Employing this interpreta- ,

tion, Licensee has responded to a number of interrogatories posed by Mr. Sholly but has steadfastly resisted providing carte blanche security information unrelated to the contention.

Mr. Sholly first argues (Motion to Compel, at 1-2)

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that Licensee improperly objects to contentions based on " scope".

To the extent he would deny Licensee the right to object to any discovery request when Licensee believes the request seeks in-

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formation unrelated to a contention, i.e. , beyond the scope of-3

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a contention, Mr. Sholly is flat wrong. The Commission's Rules .

of Practice (10 CFR S 2.740 (b) (1)) explicitly provide that discovery "shall relate only to those matters in controversy which have been identified by the commission or the presiding of ficer in the prehearing order entered at the conclusion of that prehearing conference". It is not Licensee who has uni-laterally interpreted the breadth of Contention 16 as Inter-venor Sholly argues. Licensee's objections based on scope rely on the Board's rulings as to the allowability of Contention 16.

In fact, in this particular instance, Licensee was concerned about possible ambiguity and sought clarification from the Board by its motion of January 21, 1980. Thus, rather than merely waiting for discovery requests and objecting based on our understanding alone, Licensee sought and received clarifi-cation from the Board. Now that we are applying the Board's ruling on the contention, Mr. Sholly through the guise of fault-ing us for improperly interpreting the contention is in reality seeking a modification of the Board's rulings as to the scope of Contention 16.

Mr. Sholly next argues (Motion to Compel, at 2-3) that his interrogatories are proper because they "are primarily aimed at discovering what steps Licensee has taken to ensure that its Site Security force is capable of preventing a sabo-tage attempt at Unit 2 (by insiders) from impacting on the safe operation at Unit 1". In support, he refers to a newspaper

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reporter's experience who was " hired and worked for a period of l

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i i time at TMI-2". ' Initially Licensee is confused by 'this rep- r

! resentation of Intervenor's primary aim when contrasted with

his earlier statement (Sholly Response to Licensee Motion to

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! Clarify, dated January 23, 1980) that Contention 16 "is lim-

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ited in scope in that it does not attempt to address the actual i

security problems at Unit 2, but rather seeks to litigate the i I

adequacy of security at Unit 1 and the adequacy of measures taken by Licensee to ensure that activities at Unit 2 do not f

f I affect the safe operation of Unit 1." Whatever Mr. Sholly's t current view is of contention 16, it is the Board's view and

l j rulings which count and the Board's rulings are clear. The j

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Board granted Licensee's motion that it "specify'that Conten-f i

tion 16 is limited to the industrial security threat posed to

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j Unit 1 by the decontamination and recovery activities underway

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at Unit 2 of tdut Three Mile Island Nuclear Generating Station",

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although not excluding the possibility that persons active in  !

the recovery operations at TMI-2 might at times be physically located at TMI-1.

Under the Board's view--not Licensee's nor one of Mr. Sholly's views--as to the scope of contention 16, as ad-

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mitted, the adequacy of security generally at Three-Mile Island ,

is not at issue, nor is Unit l's security generally at issue,

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nor Unit 2's. Contention 16 is limited in scope, Mr.-Sholly's broad interrogatories which seek all information related to TMI security planning are improper, and Licensee's objections ,

to interrogatories which seek security related information  ;

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i beyond the defined scope of Contention 16 are appropriate.

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Mr. Sho11y's reliance on Diablo Canyon to bolster his attempt to broaden the scope of Contention 16 is misplaced. t He cites from that case two selected sentences contained in the supplemental comments of Chairman Richard S. Salzman of

the Appeal Board

. . . I am unable to credit the sugges-tion that those determined to injure nuclear power plants will be significantly aided in their purposes by the limited types of dis-closure contemplated, or much hindered in their purposes if that disclosure is proscribed.

The roots of industrial sabotage will hardly wither if we withdraw such plans from all pub-lic scrutiny; rather, it is the public safety that is more likely to suffer if we do so.

5 NRC at 1411.

What Mr. Sholly fails to address is the context in which these l

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additional comments were made, the fact that Mr. Salzman's com-ments are at odds with the viewpoint of the other two members

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of the Appeal Board, Dr. Lawrence P. Quarles and Dr. W. Reed Johnson, as expressed in their own supplemental opinion, and the fact that the ruling of the Appeal Board in that case (joined in by all three members) is antithetical to the quoted

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sentences.

Although Mr. Salzman's opinion endorses " limited types of disclosure" of security-related information in an ad-

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judicatory context, the endorsement is expressly limited in scope by the "[alppropriate safeguards along the lines suggested

, in our main opinion." 5 NRC at 1411 (Additional comments of

-*/ Pacific Gas & Electric Company, (Diablo Canyon Nuclear Power Plant) , ALAB-410, 5 NRC 1398 (1977).

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Mr. Salzman).- That main opinion held that in order for secur-ity-related information to be subject to disclosure, a party .;

must demonstrate the parcicular relevancy of.the requested security information to its contention. See 5 NRC at 1404.

In addition, the Appeal Board held that in most cases, a secur-ity plan should be subject to a protective order, and.that j

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access to the plan or portions thereof should be given only l 1

to witnesses whose particular technical competence is demon- T

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strated by the party sponsoring the witness to be relevant to l

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7 the portions of the plan subject to disclosure. In summary, I

the emphasis of the Appeal Board in Diablo Canyon is on the  !

increased sensitivity of security plans to public disclosure,

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and the necessary demonstrations of relevancy which must be

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made by a party sponsoring a witness who will review a secur- ~!

ity plan or portions thereof. i

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In response to Mr. Sholly's explanation of the spe- E cific relevance of Interrogatories16-008.through 16-015, Li-censee submits the following

f INTERROGATORY No.16-008.

] In this interrogatory, Mr..Sholly requests a variety  :

of general material related to Licensee's' security plan for 4

TMI Units 1 and 2. In response to Licensee's. objection to j' this interrogatory, Mr. Sholly references ' a list . contained in

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the additional comments of Drs. Quarles.and Johnson.in the

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Appeal Board decision'in Diablo Canyon, discussed.above. Mr.

Sho11y's reliance upon this: list is misplaced. This compilation

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of material which potentially could be made available to an intervenor under a protective order to enable him to pursue

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a relevant security plan contention was intended to be used as guidance to a licensing board in evaluating the propriety of disclosure of security-related materials. The list in no way detracts from the holding in Diablo Canyon that it is incumbent upon the party sponsoring a security-related con-tention and witnesses to review a security plan or portions thereof to demonstrate the relevancy to the contention of the material to which the party seeks access. Mr. Sholly has not demonstrated the relevancy of any of the information requested in Interrogatory 16-008(a) through (i) to Conten-tion 16.

Final _y, Mr. Sholly argues that his general request for information in Interrogatory 16-008 is necessary because Licensee has failed to comply with the Board's suggestion

that Licensee pose interrogatories which would serve to focus Contention 16. Licensee takes exception to Mr. Sholly's in-terpretation of the Board's conditional acceptance of Sholly Contention 16. In its January 11, 1980 Special Prehearing Conference Order, the Board agreed with the Staff's proposal that Contention 16 be admitted in the TMI-l restart proceeding

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in part because the Staff intended to seek further specifica-tion of the contention through the discovery process. The Board did not impose upon Licensee any obligation to clarify Mr. Sho11y's contention. However, Licensee specifically sought

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4 and received clarification of Contention 16 in its January 21, 1980 Motion to Clarify. In any event, the Appeal Board deci-

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sion in Diablo Canyon suggests that a general request for security-related information is inappropriate regardless-of the degree to which Licensee has requested or,obtained clari-fication of Mr. Sholly's security contention.

INTERROGATORY NO.16-009.

Mr. Sholly has requested the names and last known addresses for all employees of Licensee engaged in work on  ;

the security force at the TMI site who have resigned, been asked to resign, or quit since March 28, 1979. Because the security force at TMI Units 1 and 2 were completely separated on January 1, 1980, so that both units have separate owner- P controlled areas, protected areas and vital areas, and a separate and distinct badging system, Licensee maintains its objection to Interrogatory No.16-009 insofar as it requests the names and last known addresses of Licensee employees who left the site prior to implementation of this new security system. Such employees would not be familiar with the pres-ent security system which will be in effect upon restart of TMI Unit 1. Consequently, these employees would be unable to address subject-matter within Mr. Sho11y's Contention 16,

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namely, the impact on insider security at Unit 1 of personnel associated with decontamination and restoration at TMI-2.

Licensee also objects to Mr. Sholly's request for Licensee's

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TMI Unit 2 security employees. It is Unit l's inddstrial se-curity which is the subject of the contention. Licensee has identified one security employee at TMI Unit 1 who is no longer on Licensee's security force and who left after Janu-ary 1, 1980: Richard Gingrick, who is still employed by Li-censee, as he transferred to TMI-l Operations Division. Mr.

Gingrick's address is Metropolitan Edison Company, P. O. Box 480, Middletown, Pennsylvania 17057. ,

INTERROGATORIES NOS.16-010 and 16-014.

Interrogatory No.16-010 requests a chronological t

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list of any and all attempted, suspected attempted or threat-ened acts of sabotage, and thefts or suspected threats of security-related documents with respect to both TMI Units 1 and 2. Interrogatory No.16-014 asks Licensee to specify, describe and explain any and all occasions on which it has been cited for violation of NRC security regulations.- Licensee is grouping its response to both of these interrogatories be-L cause of Mr. Sho11y's similar characterization of the informa-

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. tion sought herein, namely, historical data. As previously stated, historical security data at TMI has no relevance to Mr. Sholly's Contention 16, which addresses a potential insider security threat at Unit 1 upon restart from personnel associ-ated with decontaminatiot. and restoration at TMI Unit 2. Mr.

Sholly's general concern in Interrogatory No.16-010 with security at TMI because of violence he associates with labor

problems is not only unrelated to Contention 16, but completely

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l unsubstantiated.

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INTERROGATORY NO.16-011.

This interrogatory' asks Licensee to explain how its physical protection system and security organization protects against internal sabotage. In effect, Interrogatory No.16-011 asks Licensee to fully describe its security plan end how the plan effectively protects against all potential internal se-curity threats at TMI. Licensee reiterates its well-worn j- objection to the scope of Mr. Sholly's inquiry, and his fail-ure to comply with the relevancy and specificity requirements set forth in the Appeal Board decision in Diablo Canyon, dis-  !

cussed above. Furthermore, an interrogatory which requests all information pertaining to a contentionf not to mention.infor-mation beyond the contention's scope, is improperly broad.

INTERPOGATORY NO.16-012.

Licensee is asked to specify the date by which it

will implement the physical search requirements of 10 CFR 73.55 (d) (1) . Again Mr. Sholly makes no attempt to connect his in-

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quiry to activities associated with the TMI-2 recovery program.

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As Mr. Sholly is apparently well aware, and as Licensee dis-cussed in its Response to Interrogatories (Third Set) of Steven.

C. Sholly, dated March 17, 1980, NRC's security regulations are

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I currently subject to proposed modifications,-see, e.g., 44 Fed.-

Reg. 68184 et seg. (November 28, 1979), and are being-evaluated by the Commission. Licensee can only say that it intends to comply ~with all applicable NRC security requirements when these requirements are finalized by NRC.

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INTERROGATORY NO.16-013.

This interrogatory asks Licensee to unequivocally state that all unoccupied TMI vital areas are locked and pro-tected by an active intrusion alarm. system and is unrelated to Sholly Contention 16. In his Motion to Compel, Mr. Sholly

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acknowledges that this interrogatory "is clearly related to Licensee's ability to protect TMI-2 against sabotage." This

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issue is, however, beyond the scope of Mr. Sholly's contention, which is not concerned with security at Unit 2. Licensee again emphasizes that Mr. Sholly's security contention is ,

limited to insider security at Unit 1, insofar as it might be affected by decontamination and restoration work in connection

with Unit 2.

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INTERROGATORY NO.16-015.

Licensee's extensive requests concerning security force training at TMI do not relate to his contention. Although Mr. Sholly has limited his focus in'this interrogatory to in-sider security generally, this issue is still beyond the subject of Contention 16. As stated above, Mr. Sholly's contention is limited to insider security at Unit 1, insofar as it might be I

affected by decontamination and restoration work in connection with Unit 2.

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HUMAN FACTORS ENGINEERING INTERROGATORIES (CONTENTION 15).

Mr. Sholly's Motion to Compel, takes issue with Licensee's objections to a number of Mr. Sholly's interrog-

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atories- on the ground that "information on training and-procedures are subject to discovery under Contention 15."

Motion to Compel at 11. In reaching this conclusion, Mr.

Sholly refers Licensee to a report prepared for"the NRC by

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the Essex Corporation, NUREG/CR-1270, Volume 1, entitled

" Human Factors Evaluation of Control Room Design and Opera-tor Performance at Three Mile Island-2" (the "Essex Report") .  ;

Licensee agrees with Mr. Sholly's understanding of the scope of the Essex Report. However, Licensee takes issue with l

Mr. Sholly's conclusion that Contention 15 encompasses all  :

5 of the issues raised in that report.

Licensee concurs with Mr. Sholly's observation that human factors engineering has been ably defined in the Essex Report and that human factors evaluation can be and were in the Essex Report _ applied to training and procedures.

Motion to Compel at 9. However, Contention 15, by its'own terms, does not include within its scope .the issues of oper- l ator training and procedures. Rather, Contention 15 is self-limited to particular issues included in one of the two' general 4

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following interrogatories: 15-006, 16-009.(sic; 15-009],- =

15-010,15-025 through 15-028,15-030, 15-033,,15-036 through 15-038,15-041, 15-042,15-044, 15-049,15-061 through 15-068, and 15-070 through 15-075.

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areas of human factors engineering and evaluation which were in-fact separately analyzed in the Essex Report, namely, human

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factors engineering of control room design and human-factors evaluation of operator performance. Contention 15 states:

It is contended that the design of the Unit 1 Control Room, instrumentation, and controls .. ,

is such that operators cannot. maintain system ,

variables and systems within prescribed oper-ating ranges during feedwater transients and ,

LOCA's. It is further contended that this >

violates the provisions of GCD 13 regarding instrumentation and controls. It is contended i that in view of the numerous operating diffi-culties encountered with Unit 2, and the sim-ilarities in design and construction between Units 1 and 2, a thorough human factors engi-neering review of Unit l's Control Room is called for in order to provide assurance that the operator-instrumentation interface is such that the operators can exercise adequate con-trol over the reactor and prevent off-site '

consequences from anticipated operational oc-currences and postulated accidents. It is further contended that in order to assure max- -

imum protection for the public health and safety, the human factors engineering review and any necessary changes recommended as a result of this review must be completed prior

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to restart. Sholly Final Contentions, dated

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October 22, 1979, at 45-46. [ Emphasis supplied.]

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Although Contention 15 uses the term " human factors engineering," the focus of Mr. Sholly in his contention is exclusively on Unit 1 Control Room design. Contention 15 does not refer to operator training and procedure. Similarly, in his explanation for the basis of his contention, included in his October 22, 1979 filing, Mr. Sholly refers to " examples of control room design inadequacies" contained in NUREG-0600 specifically relating to instrumentation, e.g., the location of fuel handling exhaust mon.itors,.the PORV closure indication,

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9 and core cooling instrumentation. Thus, Mr. Sholly's conten-

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tion is limited to the adequacy of the design of the Unit 1 Control Room, instrumentation and controls, for purposes of safely operating the reactor. Contention 15 does not include

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within its scope other related issues, such as human resources development, as defined in the Essex Report, or operator train-ing and procedures. Licensee relied on the clear wording of Contention 15 and the specific bases provided by Mr. Sholly for the contention in limiting its own interrogatories to Mr.

Sholly to control room design and operator-instrumentation interface.

Mr. Sholly cannot now use the Essex Report, which postdates the filing and acceptance of Contention 15, to broaden the defined scope of inquiry in this proceeding.

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Nevertheless, this is precisely the effect sought by. Mr. Sholly's Motion to Compel, and his response to Staff interrogatories, dated January 31, 1980. By referencing the Essex Report, Mr.

Sholly subtly seeks to expand the scope of his contention to include the issues of operator training and procedure. Licensee does not concur with Mr. Sholly's conclusion that because the Essex Report includes all issues contained within the two gen-eral areas of human engineering design and evaluation, and human resources development, Contention 15 perforce also in-cludes all of these issues.

In addition to resisting Licensee's objection to cer-tain of his interrogatories related to human factors engineering,

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Mr. Sholly's Motion to Compel encompasses the following inter-rogatories, to which Licensee responds.

INTERROGATORY NO.15-024.

Licensee is asked to specify each instance where the

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operating procedures specify a different measurement than that

displayed in the control room. Licensee reiterates its objec-t! ^. to Mr. Sholly's focus upon operating procedures, rather than the adequacy of the control room design during operation of the reactor.

INTERROGATORY NO.15-031.

This interrogatory asks whether the window separating the shift supervisor's office in the Unit 1 control room from the control room area is bullet-resisting as per 10 CFR 73.55

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(c) (6) . Interrogatory No.15-031 relates only to a general matter of security at TMI, not to Contention 15 which is con-  !

cerned with Unit l's control room design. Mr. Sholly suggests that because his Contention 16 is security-related, Licensee

should therefore answer this interrogatory pursuant to that Contention. Without disputing Mr. Sholly's method of asking for security information within the rubric of an entirely dif-ferent contention, Licensee would resist this interrogatory in any event, as it relates to TMI-l security generally, rather than to the limited scope of Mr. Sholly's security contention, as previously discussed. I

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INTERROGATORY NO.15-032.

This interrogatory requests the identity and copies of any and all Licensee Event Reports (LER's) and NRC inspec-tion reports which identify as a causitive factor human error, operator error, or other similar cause. Licensee has taken  ;

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account of Mr. Sholly's statement that "[a}s written, this interrogatory does not limit the request to TMI-1; that is what was intended, and Licensee need not provide such a listing for TMI-2." However, even if Licensee assumes that this inter-rogatory is limited to LER's and NRC inspection reports at Unit 1, the interrogatory remains extremely overbroad in that it fails to relate the information sought to the substance of Contention 15, namely, Unit l's control room design. Licensee therefore objects to producing for Mr. Sholly's review material totally extraneous to his contention.

INTERROGATORY NO.15-034.

Licensee did not object to this interrogatory insofar as it asks how operators will know the status of the PORV on the pressurizer and whether the means to indicate the status are single-failure proof. Licensee intends to respond to this portion of the interrogatory.

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INTERROGATORY NO.15-053.

In this interrogatory, Licensee is asked "to what ex-tent must critical operating parameters be inferred from changes in associated parameters, rather than such parameters being available directly at the control panel." It further requests l

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discussion on the resulting potential for operator error and operator training to prevent error. Licensee reiterates its original objection that this interrogatory is overly broad in failing to identify the operating parameters in which Mr.

Sholly is interested, and the relationship of those parameters to the TMI-2 accident.

INTERROGATORY NO.15-069.

Mr. Sholly's request in this interrogatory for phys-ical and medical standards imposed upon control room and senior reactor operators unrelated to the design and layout of the control room is beyond the scope of Sholly Contention 15. Al-though the issues cited in Mr. Sholly's Motion to Compel, "the operator's environment and the operator / operator interface,"

may fit within the overall subject of human factors engineer-ing as defined in the Essex Report, these issues do not pertain to Contention 15.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE Aw '

Am/N.s Y G[orge F Trowbridgd Dated: March 31, 1980

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, Lic 3/31/8d UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Answer to Intervenor Steven C. Sholly Motion to Compel of March 21, 1980," dated March 31, 1980, were served upon those persons on the attached Service List by deposit in the United States mail, this 31st day of March, 1980.

b/ . ' x N * /./

G[orgeF. Trowbridge[

Dated: March 31, 1980

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-UNITED STATES OF AMERICA i NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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METROPOLITAN EDISON COMPANY

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) Docket No. 50-289

) (Restart).

(Three Mile Island Nuclear )

Station, Unit No. 1) )

SERVICE LIST Ivan W. Smith, Esquire John A. Levin, Esquire Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Comm Board Panel Post Office Box 3265 U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 ~

Karin W. Carter, Esquire f Dr. Walter H. Jordan Assistant Attorney General l' Atomic Safety and Licensing 505 Executive House Board Panel Post Office Box'2357 l E81 West Outer Drive Harrisburg, Pennsylvania 17120 Oak Ridge, Tennessee 37830 l John E. Minnich

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Dr. Linda W. Little Chairman, Dauphin County Board

Atomic Safety and Licensing .of Commissioners Board Panel Dauphin County. Courthouse

. 5000 Hermitage Drive Front and Market Streets Raleigh, North Carolina 27612 Harrisburg, Pennsylvania- 17101

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James R. Tourtellotte, Esquire (4)- Walter W. Cohen, Esquire

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Office of che Executive Legal Director Consumer Advocate.

U. S. Nuclear Regulatory' Commission Office.of Consumer Advocate Washington, D.C. 20555 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 Docketing and Service Section (21)

Office of the Secretary.

U. S. Nuclear Regulatory Commission Washington, D.C. 20555

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Jordan D. Cunningham, Esquire Karin P. Sheldon, Esquire Attorney for Newberry Township Attorney for People Against T.M.I. Steering Committee Nuclear Energy-2320 North Second Street Sheldon, Harmon & Weiss Harrisburg, Pennsylvania 17110 1725 Eye Street, N.W.,. Suite 506

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Washington, D.C. 20006 Theodore A. Adler, Esquire Widoff Reager Selkowit: & Adler Robert Q. Pollard Post Office Box 1547 609 Montpelier Street Harrisburg, Pennsylvania 17105 Baltimore, Maryland 21218 Ellyn R. _ Weiss, Esquire Chauncey Kepford

• Attorney for the Union of Concerned Judith H. Johnsrud Scientists Environmental Coalition on Sheldon, Harmon & Weiss Nuclear Power 1725 Eye Street, N.W., Suite 506 433 Orlando Avenue Washington, D.C. 20006 State College, Pennsylvania 1680)

Steven C. Shelly Marvin I. Lewis 304 South Market Street 6504 Bradford Terrace Mechanicsburg, Pennsylvania 17055 Philadelphia, Pennsylvania - 19149.

Gail Bradford Marjorie M. Aamodt R. D. 5 Holly S. Keck ,

Coatesville, Pennsylvania

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19320 Legislation Chairman Anti-Nuclear Group Representing York 245 West Philadelphia Street York, Pennsylvania 17404 i

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