ML19338E500

Request for Clarification of NRC 800905 Ltr to Licensees of Operating Plants,Ol Applicants & CP Holders.Fundamental Questions Raised Re Compliance W/Lessons Learned Requirements as Condition to Restart.W/Certificate of Svc

ML19338E500
Person / Time
Site:	Three Mile Island
Issue date:	09/30/1980
From:	Weiss E SHELDON, HARMON & WEISS, UNION OF CONCERNED SCIENTISTS
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8010030111
Download: ML19338E500 (20)

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Daarms g UNITED STATES OF AMERICA USNRO NUCLEAR REGULATORY COMMISSION o 7.-

OCT - t g,2 --

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD "

Office of the Secretary '

Docheringas '6/

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In the Matter of )

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METROPOLITAN EDISON COMPANY , ) Docket No. 50-289 et al., )

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(Three Mile Island Nuclear )

Station, Unit No. 1) )

)

UNION OF CONCERNED SCIENTISTS REQUEST FOR CERTIFICATION TO THE COMMISSION The Union of Concerned Scientists has just receivea and read a document dated September 5, 1980, entitled " Letter to All Licensees of Operating Plants and Applicants for Operating Licenses and Holders of Cons truction Permits ,

Subject:

Preliminary Clarification of TMI Action Plan Requirements." This document clarifles the substance ano extends the deadlines for a great many of the TMI-2 related requirements contained first in NUREG-0 5 78, the TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations, and then incorporated into the so-called Action Plan, NUREG-0660, August, 1980. Consideration of the Commission's Order in this proceeding of Augus t 9, 19 79 in conjunction with these documents has raised two funda-mental questions which, in UCS 's view,' ought to be resolved as soon as possible. It would appear that the Commission is the appropriate forum for their resolution.

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First, it is necessary to trace some background. In 3

NUREG-0 5 78, dated July, 19 79, the staff proposed a series of new requirements intended to address the lessons learned from the TMI-2 accident. Table B-1 " Implementation of Short-Term Recommendations to Operating Plants and Plants in OL Review" (on pages B-2 to 5-6 ) of NUREG-05781/ lists all of these requirements and places them into one of two categories. All Category A items are to be completed oy January 1, 1980 In its Order and Notice of Hearing of August 9, 1979, (CLI-79-8, 10 NRC 141) the Commission specifically incorpo-rated all of the items containec in Table B-1 of NUREG-0578.

As to the Category A requirements, the Commission held tnat they mus t be completed prior to restart. (Item No. 8, 10 NRC 145) With respect to the Category 3 items, the Commis-slon made two statements. First, it noted that it had

" additional concerns which, though they need not be resol-ved prior to resumption of operation at Three Mile Island Unit 1, must be satisfactorily aodressed in a timely manner."

(10 NRC 145) It then listed the so-calleu "long-term actions" which the Director of NRR had ifentified. Item

=3 of this list is: " comply with the Category B recommenda-1/ A copy is attached.

2/ It should be noted that, in NUREG-0578, tne staff refers

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l to all items in Table B-1, bo th Categories A and 3, as "short-term," to distinguish them from further requirements not yet fully developed. (See NUREG-0 5 78, p. 3 and Tarle 3-1) There is potential for confusion resulting from the fact that the Commission has, for the purposes of its order, callec the Category E ltems "long-term actions." However, since tne Commission fully adcpted both tne substance anc deadlines of all of Table B-1, the difference in nomenclature is itself inconsequential for purposes of this discussion.

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tio ns as specified in Table B-1 of NUREG-05 78. " (Id.) Then, in Section III of the Order, the Commission orderec:

(2) the licensee shall satisfactorily complete the long-term actions listed in Table B-1 of NUREG-05 78 on the schedule set out in such table and such other long-term actions listed above as promptly as practicable. (Id. at 146)

Finally, the Commission held in Sec tion IV as follows:

If the Board determines that operation can be resumed upon completion of certain specific short-term actions by the licen-see, it shall consider the extent to which the licensee has demonstrated reasonable progress toward completion of the long-term actions descricea in this section. If it finds that the licensee has demonstratec reasonable progress, it shall recommenc resumption of operation upon completion of the snort-term actions.

Thus, the Commission's Order, while classifying the Category B ltems as "lo ng- term " , specifically required tnem to be completed according to the schedule in NUREG-0576, by January 1, 1981.

Subsequent to issuance of the Order, tne NRC publishec NUREG-0660, the "NRC Action Plan Developed as a Result of the TMI-2 Accident. " The Action Plan, inter alla incorporated all of the items contained in Table B-1 of NUREG-0578. A copy of the table from Volume 2 of NUREG-0660 entitled " Comparison of Recommendations In Office of Nuclear Reactor Regulation Lessons Learned Task Force Reports (NUREG-0578 and NUREG-0585)

With the TMI Action Plan (NUREG-0660)" is attached. It demonstra tes that the Table B-1 items were incorporated

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, directly into the Action Plan. In the most recent document, the "le tter " of September 5, the staff proposes to clarify many of the substantive requirements traceable to NUREG-0578 and, in a number of cases to extend the deadline for imple-mentation bevond January 1, 1981. For example, NUREG-0578 set a deadline of January 1, 1981 for installation of instru-mentation for detection of inadequate core cooling. (T able B-1, item 2.1.2.b) The September 5 letter would extend this de adline to July 1, 1982.3/

This sequence of events raises two questions :

1. Does the st ff have the authority to extend deadlines which were explicity incorporated into the Commission's order or August 9, 1979?

In our view, the answer to this is clearly "no." In NUREG-0 5 78, the staff stated that it hau develoged the requirements contained in Table B-1 " based upon engineering i

evaluation and qualitative professional jucgment of the safety significance of the various issues." (NUREG-0578,

p. 3) Tne staff stated:

[T]he Task Force has selected items for

'short-term action'4/ if their 1=ple-mentation would provide subs tantial, additional protection required for the public health and safety. (Ic) 1 3/ Enc los ure 5 to the September 5 letter. Item -II.F.2. A copy of the entire enclosure, which lists all of the schedule changes, is attached.

i f/ As discussed in n.2, suora the staff uses tue phrase l

"short-term" in SUREG-0578 to cover all of the T able B-1 1: ems, including both Categories A and B.

, Based upon this representation by the staff, the Commission on August 9, 1979 ordered all Table B-1 items to be implemented on the schedules proposed. Unilaterial action by the staff to extend the deadlines is, in our view, unauthorized.

2. Assuming that the original deadlines still apply to TMI-1, is it appro pria te to apply a " reasonable progress" standard to requirements scheduled to be implemented crior to the earlies t time at whicn opera-tion could be resumed?

At the time of the August 9, 1979, Commission Orcer, it was contemplated that, although the Order was immediately effective, requiring Met Ed to begin work at once on the modifications necessary, these proceedings would be comple-ted before the deadlines set for implementation of the Cate-gory B items, January 1, 1981. Therefore, the Commission authorized this Board to permit operation to resume upon completion of the Category A items and a finding of " reasonable l

progress" toward completion of the "long-term" items, including those listed in Category B of Table B-1. (10 NRC 146) l The SER for Restart of TMI-1, almost witnout exception, reviews l the Category B ltems only against the " reasonable progress" I standard. It does not conclude that tne licensee is in compliance with each particular requirement, but only states or implies at the most that reasonable progress towarc compil-ance has been made.5/

5/ See, e.g. Item 2.1.2 (Complete test program for relief and safety valves) SER p. C8-ll; item 2.1.3 (comolete new instru-mentation for inadequate core cooling) SER p. C5-21; Item 2.1. 5 . a . (install dedicated hydrogen penetrations) SER p.

C8-27; item 2.1.6.b. ( impleme nt plant modifications as a result of shielding review) SER p. C8-33; Item 2.1. 8. a (implement modifications for pos t-accident sampling) SER p. C8-42.

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,y However, it is now clear that this proceecing, including Commission review, will not be completed before January 1, 1981. Under these circumstances, it appears clear that the

" reasonable progress" standard as applied by the staff is no longer appropriate. Certainly as to Category 3 and other "long-tern" requirements scheduled to be completed prior to restart, the SER should conclude, and this Board should insist as a condition to restart. that full compliance witn the lessons-learned requirements has been shown. To do otherwise would, as a practical matter, constitute a walver of the Commission-adopted deadline for compliance.

In view of the fact that these issues appear to be appropriately answered only by the Commission, UCS requests the Board to certify them to the Commission for its direc-tion.

Respectfully submitteo, ,

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HAR140N & WEISS 1725 : Street, N.W.

Suite 506 Washington, D.C. 20006 (202) 833-9070 DATED: September 30, 1980

TABLE B-1. IMPLEMENTATION OF SHORT-TERM RECOMMENDATIONS FOR OPERATING PLANTS AND PLANTS IN OL REVIEW Position Sect. Abbreviated Position Implementat{on No. Title Description Cateoory 2.1.1 Emergency Power Supply Complete implementa- A Requirement tion.

2.1.2 Relief and Safety Valve Submit program descrip- A Testing tion and schedule.

Complete test program. By July 1981b 2.1.3.a Direct Indica. inn of Complete implementation. A Valve Position '

2.1.3.b Instrumentation for Develop procedures and A Inadequate Core Cooling describe existing instr.

New instr. design, sub- A cooling meter installation, and implementation schedule.

Complete new instr. B installation.

2.1.4 Diverse Containment Complete implementation. A Isolation 2.1.5.a Dedicated H2 Control Description and imple- A Penetrations mentation schedule.

Complete installation. B a Impicmentation complete by January 1,1980, or prior to OL Category A:

Category B: Implementation complete by January 1, 1981.

D Relief and safety valve testing shall be satisfactorily completed for all plants prior to receiving an operating license after July 1,1982.

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JABLE 8-1 (Continued)

Sect. Position Abbreviated No. Position Title Descriotion Implementat{on Catecory 2.1.5.b Rulemaking to Require Inerting BWR Containments Inert Vermont Yankee

• and Hatch 2.

Design and equipment

• to inert new Mark I and II containments.

Inert new Mark I and

• II containments.

2.1.5.c Combustible Gas Control Recombiner Rulemaking to require

• capability of installing recombiners.

Review procedures and B bases for recombiner use.

2.1.6.a Systems Integrity for High Radioactivity Immediate leak A reduction program.

Preventive maintenance A program.

2.1.6.b Plant Shielding Review Complete the' design A review.

Implement plant B modifications.

" Category A:

Category 8: Implementation complete by January 1, 1980, or prior to OL Implementation ccmplete by January 1,1981.

" Implementation schedules will be established by the Commission in the course of the immediately effective rulemaking. The Task Force recommends that the rulemaking process be initiated promptly.

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TABLE B-1 (Continued)

Position Sect. Abbreviated Position Implementatjan No. _

Title Descriotion Category 2.1.7.a Auto Initiation of Complete imp.lementation A Auxiliary Feed of control grade.

Complete implementation B for safety grade.

2.1.7.b Auxiliary Feed Flow Complete implementation. A Indication 2.1.8.a Post-Accident Sampling Design review complete. A Preparation of A revised procedures.

Implement plant B modifications.

Description of proposed A modification.

2.1.8.'b High Range Effluent Installation complete. B Monitor 2.1.8.c Improved Iodine Complete implementation. A Instrumentation 2.1.9 Transient & Accident Complete analyses, **

Analysis procedures & training.

a Category A: Implementation complete by January 1,1980, or prior to OL Category 8: Implementation complete by January 1, 1981.

• • Analyses, procedural changes, and operating training shall be provided by all operating plant licensees and applicants for operating licenses following the schedule in Table B-2.

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TABLE B-1 (Continued)

Position Sect. Abbreviated Position No. Implementat{on Title Descriotion Catecory 2.2.1.a Shift Supervisor Complete implementation. A Responsibilities ~

2.2.1.b Shift Safety Engineer Shift technical advisor A on duty.

Complete training. B 2.2.1.c. Shift Turnover Complete implementation. A Procedures 2.2.2.a Control Room Access Complete implementation. A Control 2.2.2.b Onsite Technical Establish center. A Support Center Upgrade to meet all B requirements.

2.2.2.c Onsite Operationai Complete implementation. A Support Center

'2.2.3 Rulemaking to Revise Tech. Spec. change.

• LCOs for Safety System Availability a

Category A: Implementation complete by January 1,1980, or prior to OL Category B: Implementation complete by January 1,1981.

• Implementation schedules will be established by the Commission in the course of the immediately effective rulemaking. The Task Force recommends that the rulemaking process be initiated promptly.

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i COMPARISON OF RECOMMENDATIONS IN OFFICE OF NUCLEAR REACTOR REGULATION LESSC.es LEARNED TASK FORCE REPORTS (NUREG-0578 AND NUREG-0585)

WITH THE IMI ACTION PLAN (NUREG-0660)

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Impact on TMI Action Plan

a. Recommendation is adequately covered in the Action Plan.

b. This' recommendation (or some part thereof) may not be explicitly included in the Action Plan but it is intended that, when the action is undertaken by the lead office, this specific recommendation will be taken into consideration.

' c. The NRC staff or Commission dose not agree with tha recommendation or the recommendation

, is beyond the purview of the NRC. The Action Plan does not account for this '

reconnendation.

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THI-2 tESSONS LEARNED Sil0RT-TERM RECOMMENDATIONS (NUREG-0578)

NUREG-0578 Related THI Section Number Section Title Action Plan Task Status 2.1.1 Emergency power supply requirements for the pressurizer heaters, II.E.3.1,. a .

power-operated relief valves and block valves, and pressurizer II.G.1 level indicators in PWRs.

2.1.2 Performance testing for BWR and PWR relief and safety valves. II.D.1, II.D.2 a l 2.1.3.a Direct indication of power-operated relief valve and safety II.D.3 a l valve position for PWRs and BWRs.

2.1.3.h Instrumentation for detection of inadequate core cooling in I.C.1, II.F.2 a PWRs and DWRs.

2.1.4 Containment isolation provisions for PWRs and BWRs. II.E.4.2 a 2.1.5.a Dedicated penetrations for external recombiners or post-accident II.E.4.1, II.B.8 a purge systems.

2.1.5.b Inerting DWR containments. II.B.7, 11.8.8 a 2.1.5.c Capability to install hydrogen recombiner at each light water II.E.4.1, II.B.8 a nuclear power plant.

2.1.6.a Integrity of systems outside containment likely to contain III.D.1.1, a radioactive materials (Engineered Safety Systems and Auxiliary II.B.8 Systems) for PWRs and BWRs.

, 2.1.6.b Design review of plant shielding of spaces for post-accident 11.8.2, 11.0.8 a

( operations.

2.1.7.a Automatic initiation of the auxiliary feedwater system for PWRs. II.E.1.2 a 2.1.7.b Auxiliary feedwater flow indication to steam generators for PWRs. II.E.1.2 a

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THI-2 LESSONS LEARNED Sil0RT-TERM RECOMMENDATIONS (NUREG-0578) (Continued) i NUREG-0578 i Section Number Section Title Related IMI Action Plan Task Status 2.1.8.a Improved post-accident sampling capability. II.8.3, II.B.8 a 2.1.8.b Increased range of radiation mon! tors.

II.B.8, II.F.1, a 111.0.2.1 2.1.8.c Improved in plant iodine instrumentation.

II.B.8, 111.0.3.3 a 2.1.9 ~

Analysis of design and off-normal transients and accidents. I.C.1 a 2.2.1.a Shift supervisor's responsibilities.

I.A.1.2, I.C.3 a

, 2.2.1.b Shift Technical Advisor.

I . A.1.1 a U 2.2.1.c Shift and relief turnover procedures.

i I.C.2 a 2.2.2.a Control room access.

I.C.4 a 2.2.2.b Onsite Technical Support Center.

III.A.1.2, a III.A.2.2 2.2.2.c Onsite Operational Support Center.

III.A.1.2, a II.A.2.2 2.2.3 Revised limiting conditions for operation of nuclear power plants I . B .1. 3 b based upon safety system availabfif ty.

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i=h5'* 5 ne Summary of Changes anc New Recuirements WI-2 Ac-ion ?lan Implemen ation mments & Changes from Senecuie Item 1 Title Previous Guidance P-evious in1s Occument I. A. l.1 STA a. Suomit documentation snowing that None 01/01/81 licensee meets recuirements of October 30, 1979, letter.

c. Description of STA program to be None 01/01/81 provided by 1/1/81.

I.A.3.1 Revise Scope Recuires simulator testing for

& Crit. for reactor operator applicants.

Licensing a. Plants having simulator None 06/01/80 Exams Commence

c. All other plants None 10/01/80 Commence I.C.1 Short Term a. Requires reanalysis and prepara- Early 12/31/81 Accicent of tion of new Procedures for 1980 Procecures Inacecuate Core Cocling anc Review Transients anc Accicents I.C.6 Procecure Action Plan requirement not None 01/01/81 for verifying previously issued performance of operating activities 11.3.1 RCS Vents 1. Adds item 8: "The probaci' ity 01/01/81 01/01/82 of a valve failing to close, once opened, should be minimi:ed."

2. Adds to item 11: " environ-mental qualification."

3. Adds item 12: " Provisions to test operability of the RC Vent-System should be part of the

! design."

4. Deleting from the position that the system must be safety grade and must meet single failure criteria of IEEE 279-1971.

2- Enclosure 5 Comments & Changes from icnecule

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• Title Previous Guicance Previous inis Uccument II.3.2 21snt 1. Adds Control reem, 750, sample 01/0U51 01/01/S2 Shielding station / analysis area as area that must ce consicerec vital areas ensures areas will be evaluated per position. 1

2. Acds several areas to be eva- l luatec for access - ensures these areas are not overlooked and provides reasons for their exclusion as vital areas.

3. Provides for censidera-ion of several systems as potential hig.ily radioactive systems -

ensures a full systems inter-action evaluation.

4. Docucientation - information regarding source terms, systems reviewee, vital areas, codes, other mods provides reviewer with enough information to con-duction evaluation of the scope, tecnnical aspects, and depth of the facility effort.

II.3.3 Postaccicent Requires consideration of passive 01/01/81 01/01/82 Samping flow restrictions to limit reactor

, coolant loss er containment air leak from a rupture of the sample line.

II.S.4 Training for 3/28/80 iatter required initiation See ccmments column Mitigating of training by 5/1/S0 with sucmittal Core Damage for NRC review by 8/1/80. NUREG-0660 indicated initiation of training by 4/1/81. This new clarification ,

is consistant with NUREG-0660 and adds requirement for licensee submittal by 1/1/81.

II . O.1 SRV Testing Adds Block Valve Testing. None 07/01/82 .

II.E.1.1 AFW System Extension of short-term schedule for 01/01/81 07/01/81 Evaluation operating reactors.

a. Short-term -

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Enclosurt 5 Ccaments & Changes frem Senecule Item # Title Previcus Guicance Previous inis Occument II . E. 4.1 Cecicated 1. We now state that tne design of Hydrogen the decicated penetrations Penetrations sncule ce based on 10 CFR 50.44

2. The system design information requested by Oct. 1, 1930 was not specified to ce suomittec.

a. Su:mit cesign None 10/01/80

b. Imolement 01/01/81 6/30/81 II.E.4.2 Containment Adds requirements: Nene. 07/01/81 Isolation 1. Reduce pressure se coint for Oepend- containment isolation of non-acility essential lines to the minimium comoatacle with ncrmal opera-tions by 07/01/81.

2. Containment purge valves that do None 01/01/81 not satisfy the operability set forth in CSB STP-6-4 or the Staff's Interim Position of October 23, 1979, must seal close all valves and check every 24 hcurs by January 1, 1981.

II.F.1(1) Ncble Gas Requires the ncble gas effluent 01/01/81 10/01/81 Effluent monitor to be designed to the Monitor seismic criteria of tne duct or vent to ahich it is attachec.

II.F.1(2) Samcling and Requires consiceration of con:r:1- 01/01/81 10/01/81 Analysis of limg humidity at the point of Plant entran:e to the adsorber to below Effluents 80%.

II.F.1(3) Containment Refer to clarification: 01/01/81 10/01/81 High Range 1. Item 3 - recuirement for factor of 10 overlaa for split range high range radiation monitors-ensures accurate reading cacability in transition area.

2. Item 4 - recuirement for locat-ing raciation monitors in a manner to accurately reflect accident conditions provices representative sampling; precludes inaccuracies.

3. Item 5 - For SWRs requirement for monitoring both primary and l

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nclosure 5 1

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,,,e 4 7f.j, Comments & Changes from Schedula f

Previous Gutcance previcus . .-inis Document seconcary containmen:s provices essential accioent monitoring 4

and control information. '

Documentation Reauired - recuire- I ment to provide monitor manufac-turer, model numcer, and plant i layout drawings-for evaluators to determine dated / technical comoliance.

.F.l(4) Containment 1. Now require Suoatmospneric con-Pressure 01/01/81 01/01/81 Monitor tainments to be acte to monitor to 5 psia was 10 psia in 10/30/79 letter.

2. Accuracy and response time recuirements now specified -

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were not.in 10/30/79 lettar.

Requirements for continuous dis-play and recording now added -

were not mentioned in 10/30/79 letter.

.F.1(5) Containment 1. Now both wide and narrow range Water Level enannels snali conform to pro- 01/01/31 01/01/31 posed RG 1.97 Rev. 2 10/30/79 letter stated that requirement for wide range. Narrow range had to meet RG 1.89.

2. Accuracy requirements now speci-fied, were not discussed in 10/30/79 letter.

3. Documentation Raquired on minimum water levels in containment wnich satisfy NPSH requirements and the specific elevations of safety- '

related equipment are new requirements.

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.F.1(6) Containment Hydrogen If H. indication is not avaliable 01/01/81 10/01/81 continuously it must be available

' Monitor within 30 mins. of initiation of safety-injection. Accuracy recuire-ments for instruments now specified.

Provisions for selectively monitoring H

at different locations in the con-t$inmentarerequired.

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Enclosure 5 OcT.ments a ha ges frem Scaecule Item # Title Previcus Guidance Prev 1:us Tr.is 2ccument II.F.2 I..s t. f:r .' lev requirement that instrumer.:s Detection of be qualified in accordance with Inaceouate Reg. Guice 1.97, Rev. 2 Core Cecifcg a. Design Description

o. Installation 01/01/81 01/01/81 j 01/01/81 7/1/82 )

i II.K.2.10 Safety-Grade a. New request for final design Anticipatory submission None 06/30/81 Trip b. Install Safety Grade 1/1/81 6/30/81 anticipatory trip II. K. 2.13 Thermai Schedule change Mechanical 10/1/80 .1/1/81 Report II.K.3.5 Autcmatic trip Schecule Extension of RCP during a. Submittec LOCA b.

1/1/81 2/15/81 Mocifications (if necessary) 1/1/82 3/1/82 II.4.3.12 Anticipatory Schedule Extension for Submitta Trip Upon //1/80 10/1/80 Turbine Trip i

!!.K.3.27 Cc.mmen Schedule Extension for Submittal

Reference for 10/1/30 1/1/81 Vessel level Instrumentation II.K.3.30 Revised SB Specify Schecule LOCA Methocs a. Outline of Secpe & Schedule b.

None 10/1/80 Medel Justification 1/1/82 1/1/82

c. New Analysis None 1/1/83 II.K.3.57 Identify water Schedule extension scurces prior 10/1/80 1/1/81 to actuation of A05 III.A.I.1 Emergency New Rule 3reparecenss 09/01/80 04/01/S1 III.A.1.2 Upgrade New requirements contained in imergency 01/01/81 04/01/52 NUREG-0696 supersede original Supcort requirements. 5:necule slipped Facilities 15 months.

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'.-. UNITED STATES OF AMERICA D NUCLEAR REGULATORY COMMISSION M gg5EIS 9 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD @

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In the Matter of )  %

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- - ', N METROPOLITAN EDISON ) Docket No. 50-289 COMPANY, et al., )

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(Three Mile Island )

Nuclear Station, Unit )

No. 1) )

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CERTIFICATE OF SERVICE I hereby certify that copies of " Union of Concerned Scientists Request for Certification to the Commission" was mailed postage pre-paid this 30th day of September 1980 to the following parties:

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Secretary of the Commission (21) Mr. Steven C. Sholly U.S. Nuclear Regulatory Commission 304 South Market Street Washington, D.C. 20555 Mechanicsburg, PA 17055 Attn: Chief, Docketing & Service Section James A. Tourtellotte, Esq. (4) Jordan D. Cunningham, Esq.

Office of the Exec. Legal Director Fox, Farr & Cunningham U.S. Nuclear Regulatory Commission 2320 North Second Street Washington, D.C. 20555 Harrisburg, PA 17110 Karin W. Carter, Esquire Frieda Berryhill Assistant Attorney General Coalition for Nuclear Power 505 Executive House Postponement P.O. Box 2357 2610 Grendon Drive Harrisburg, PA 17120 Wilmington, Delaware 19808 Daniel M. Pell Walter W. Cohen, Consumer Adv.

32 South Beaver Street Department of Justice York, Pennsylvania 17401 Strawberry Square, 14th Floor Harrisburg, PA 17127 1

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Cert. of Service l Docket No. 50-289 Robert L. Knupp, Esquire Chauncey Kepford Assistant Solicitor Judith H. Johnsrud County of Dauphin Environmental Coalition on P.O. Box P Nuclear Power 407 North Front Street 433 Orlando Avenue Harrisburg, PA 17108 State College, PA 16801 John A. Levin, Esquire Robert Q. Pollard Assistant Counsel Chesapeake Energy Alliance Pennsylvania Public Utility 609 Montpelier Street Commission Baltimore, Maryland 21218 Harrisburg, PA 17120 Theodore Adler Marvin I. Lewis Widoff, Reager, Selkowit: 6504 Bradford Terrace

& Adler Philadelphia, PA 19149 3552 Old Gettysburg Road Camp Hill, PA 17011 Ms. Marjorie Aamodt Ivan W. Smith, Chairman RD #5 Atomic Safety & Licensing Board Ccatesville, PA 19320 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Walter H. Jordan Dr. Linda W. Little 881 W. Outer Drive 5000 Hermitage Drive Oak Ridge, Tennessee 37830 Raleigh, North Carolina 27612 George F. Trowbridge, Esquire Ms. Jane Lee Shaw, Pittman, Potts & R.D. #3, Box 3521 Trowbridge Etters,' Pennsylvania 17319 1800 M Street, N.W.

Washington, D.C. 20036

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a Ellyn'R. Weiss i