ML19269D024

Testimony After Review of Available Info.Concludes That NRC Alternative Site Evalutaion Was Inadequate & That Other Sites Are Clearly Superior.Qualifications & Certificate of Svc Encl

ML19269D024
Person / Time
Site:	Perkins
Issue date:	01/20/1979
From:	Lipkin A DUKE UNIV., DURHAM, NC
To:
Shared Package
ML19269D018	List: ML19269D017 ML19269D024
References
NUDOCS 7902260595
Download: ML19269D024 (18)

Text

J UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of ) Dockets Nos. STN 50-483

) STN 50-489 DUKE POWER COMPANY ) STN 50-490

)

(Perkins Nuclear Station, )

Units 1, 2 and 3) )

TESTIMONY BY DR. ALAN H. LIPKIN I am an Assistant Professor of Chemistry at Winston-Salem State University and my professional qualifications are set out on the attached curriculum vitae.

I have considered the information which the applicant has submitted to the Staff's request in August of 1978. This includes the sitings study dated February, 1973, and the sitings 7tudy dated January, 1978. Tho undersigned has also examined additional material obtained by the intervenors from the applicant in the discovery process which was used by the applicant in formulating the above studies.

I have also examined other information from open literature, existing records, and authoritative sources.

My opinion is set out in two sections of this document in the following manner:

1, This first section deals with an analysis of the shortcomings of the consideration by the NRC Stafff of the q90226056

Cilternative site question.

2. The seccnd section deals with an analysis includ-ing that several of the proposed sites are obviously superior to the Perkins site.

I. DEFECTS IN STAFF EVALUATION The information supplied by applicant, upon interrogatories and requests to produce filed by the intervenors, reveals that the failure of the Staff to go behind the two site studies of 1973 and 1978 has undermined their opinions.

By analyzing the information supplied by the applicant, it is obvious that the Lake Norman sites D + E and particularly N-18 and Wateree contain many favorable factors, placing them at the head of the list of favorable sites shown by the applicant in February of 1973.

It is my opinion that site N-18 and others were not proeprly. considered in the staff study. Also, nost of the information generated by the applicants' work at the time of the 1973 study was not even seen by them. Therefore, the obvious favorable characteristics of many sites were not properly considered by the staff. In particular, the N-18 site would not require an extra reservoir such as the Carter Creek reservoir requied by the Perkins site. The environmental and socioeconomic impact of the Carter Creek reservoir in itself is enought to push the Perkins site to a clearly inferior position on any scale rating the relative environmental impact of N-18 and the Perkins site.

Such a reservoir is not required at N-18 as the already constructed Lake Norman has an impoundment which extends along the northwest side of the proposed three unit nuclear plant at N-18 The fact that this impoundment is already present is certainly a critical feature in the desirability of N-18.

Therefore, the Staff analysis fails in not considering a vital element of enviornmental impact in its evaluation and testimony.

Next, the Staff evaluation omits several criticial categories of evaluation factors, which are set out in the article by David Joplin of Florida Power and Light Company published in March 1974 in Power Engineering and which is an objective criteria in the public literature located in the files of -he applicant during the discovery in this matter. This failure by the Staff to use all of the factors which are listed in said article indicates that-the evaluation is defective, The Staff evaluation and testimony fails to take into account endangered species which were identified in the final Environmental Impact Statement for the Perkins site and which are certainly required if any proper and balanced consideration of sites is to be given. Specifically, the staff analysis fails to account for the potential prosence of the bald eagle, peregrine facon and the Carolina darter, which are endangered and potentially in or near the Yadkin River at the Perkins site.

The failure to note these. presences is an additional indication that the Staff analysis is not adequate.

The Staff analysis further fails to take into t

account the effect.on water quality of the Perkins site in terms of its effect on the present level of eutrophication and pollution of High Rock Lake, which is downstream, and a comparison of this effect with the effect on Lake Norman of the N-18 site. The answers of the applicant to interroga-tories from the intervenors indicate that Lake Norman in 1973 and at the present time is obviously in a much better condition in terms of eutrophication and other pollutants.

Therefore, the effect of the withdrawal of water by the use of cooling towers would not have as great a degree of detri-mental impact as similar evaporation on High Rocke Lake.

This factor was ignored in the Staff evaluation and is an additional reasons why the evaluation and anlysis by the Staff is completely inadequate and a violation of its responsi-bilities under the Environmental Protection Act.

3

The Staff evaluation fails to assign a proper value to water availability by ignoring completely the lack of upstream river control by the applicant on the Yadkin River. At the N-18 site, the applicant has, on the contrary, complete hydrologic control through its reservoirs on the Catawba River upstream from N-18, as well as control at the This water availability and Cowans Ford Dam for Lake Norman.

control is a factor which weighs heavily in consideration of the use of cooling towers at N-18 or at the Perkins site.

The fact that the applicant has such water control,and that the average flow at the location of N-18 is not only adequate but can be controlled by upstream dams,is a factor which must be considered in any comparison between such site and the Perkins site or any other site. The failure to account for this results in conclusions-by the Staff which are unsupportable.

The Staff analysis fails to account for the conflict of interests which applicant has at Lake Norman on account of its real estate holdings and land developments on said i

lake. The use of cooling towers at N-18 must, of necessity, result in the evaporation of water in Lake Norman and have at least some effect on the lake level as has been shown in the Final Environmental Impact Statement for High Rock Lake as the result of the use of the Perkins site. The fact that Duke Power Company engages in land development on Lake Norman is a negative factor which must be considered in comparing sites to determine if a proper environmental decision in the public' interest has been made in the comparison of N-18 with the Perkins site. The fact that the Staff did not even deal with this question again indicates the super-ficial and incomplete nature ct the Staff analysis.

Finally, the failure of the Staff to consider the use of condenser or once-through cooling at Lake Norman sites D or E eliminates from consideration two of the sites which are even more clearly superior if such lake cooling is or becomes a satisfactory alternative. The question of lake cooling is very much a matter of dispute at this time. It was improper for the staff to assume on the basis of one letter that there would never be lake cooling at sites D and E in Lake Norman for a nuclear plant.

The tests which have been done and will be done to deter-mine whether additional lake cooling may be done on Lake Norman will perhaps determine whether or not th' lake cooling can be done. Information obtained from t he applicant's file indicates that applicant's position is very emphatic and clear that it does have two more sites on Lake Norman for once-through cooling. Also, the studies which have been done up to this point indicate that the lake has sufficient capacity for such lake cooling. Even if certain State offcials..

j had indicated doubts about the likelihood of lake cooling on i Lake Norman, these doubts should not close off a consideration of these alternatives by the staff. This is especially true in that much infarmation has been developed and applicant has turned over to the intervenors a great deal of information and analysis which indicates that lake cooling is being considered by the applicant and therefore must be considered by the Staff in ruling on alternative sites.

As the Staff analysis and testimony does not deal with site N-18, there was no reason to expect such a site to show up as clearly superior in its analysis. In fact, even if the flawed criterion and ratings and imcomplete analysis of the Staff is utilized and applied to site N-18, it still becomes the clearly superior site for many of the reasons indicated above. The next section of this testimony will set out the several clearly superior sites to the Perkins sites and the reasons in support of these clearly superior sites.

II. THE OBVIOUSLY SUPERIOR SITES In March of 1974, David Jopling of Florida Power and Light Company published an evaluation method acceptable to the applicant to compare many po'_ential plant sites at one time on a weighted numerical basis. This evaluation method was dis-covered in the plant siting files of the applicant pursuant to a motion to produce in October 1928. This method allows the consideration of as many as 100 alternative sites at one time and "... functions as a tested, straigl:tforward, mathematically simple approach to making the engineer:.ng, cost, environmental and political trade-offs necessary to determine the most acceptible power plant sites."

Prior to the institution of the advance siting program, Florida Power and Light pursued the selection of one power plant site at a time. Although this method is satisfactory for a service area that is not experiencing a large growth rate, it could not take into consideration present environmental questions.

Furthermore, the National Environmental Policy Act of 1970 (NEPA) requires a full evaluation of all alternatives to a power plant proposal. It was therefore decided to evaluate the proposed Perkins site and to compare the resdits with several ,

alternate sites using this method.

The method is similar to the method used by Duke in evaluating 38 alternate sites, but was not used by Duke in evaluation of the Perkins site itself. The data collected and published by Duke in January of 1978 was used directly in the FP&L evaluation method wherever possible. However, there were two parameters that were not applicable to the Duke sites (involving sea-ports) and a total of nine parameters that were simply not included in the Duke evaluation.- Some factors omiteed by Duke include compatibility of land use, water quality impace, aquatic biological impact, and total system compatibility.

Four parameters used by Duke were simply entered as a sum of money in their evaluation, a method not suggested or discussed in the FP&L rating method. This monetary figure was tacked onto the end of the Duke evaluatien as a " money penalty" ($ penalty)

and was not included in the rating methodology suggested by FP&L.

, The four monetary figures were converted-to rating points by averaging the figures presented and assigning points

based on the deviation from the average. Weighting factors were determined by observation of the Duke report in conjunction with the FP&L method. The weighting factors c f the additional nine parameters were estimated using Duke's report. Rating points were assigned by comparing the sites and assigning point values in the manner of both methods.

Evaluation points are arrived at by multiplying of both methods.

Evaluation points are arrived at by multiplying WEIGHTING FACTORS RATING POINT SCALE Weight Criteria Rating Criteria 1 Least Important 1 Very Poor Site 2 Moderately Important 2 Poor Site 3 Highly Important 3 Fair Site 4 Good Site 5 Very Good Site the weighting factor times the rating points.

Generally in choosing a plant location, a company must seek to achieve an optimum balance among many,-often compet-ing, factors. The use of numerical parameters allows this type of equilibrium situation to be quantitatively evaluated. By assigning a weighted rating (evaluation points) to each parameter in an objective manner, one is able to determine the overall site quality.

In assigning a value to the capibility of cooling system parameter it was necessary to consider the type of cooling unit envisioned (reservoir, direct discharge, cooling tower, use of surface waters, etc.) each having its own set of requirements. The evaluation must show that the site has

.2 e

characteristics which enable some type of cooling system to be developed.

The proximity to the load center is ideally near the center of the region or area which will be most likely to utilize its electrical output. Area generation furthers system reliability by reducing reliance on lo ng distance transmission lines with their cost and right of way problems.

The use of large amounts of land for a plant is more convenient if there are relatively few owners. Otherwise land acquisitions p.roblems could be more expensive. Besides the land availibility,-the compatibility of land use must also be considered as evidenced by zoning regulations, long range plans for the area,and desirable public use of the area.

Of particular interest today is the consumption of natural resources of a given site area. It is necessary for a power plant to utilize water and land resources without making final, complete and unalterable-commitments of the total of these resources to the plant's operation. A plant may consume water by altering it with chemicals, dissolved solids, or by evaporating it which prevents its immediate re-use without purification or condensation. A plant, although using a constant amount of land, can perminantly destroy certain important qualities of the surrounding area during its tenure, particularly if the land is of environmental importance.

Rail and highway transportation are important for low-cost -shipment- of -heavy-equipment. The-_ ease _of relibility and cost of transportation affect first the construction of the l

plant and th;n its operation. Future deversification of fuel sources are also considered in evaluating a plant site.

Nuclear plant sites are evaluated particularly in terms of the possibility of earthquakes or geological disturbances.

A sound soil foundation to support the plant is of crucial importance.

The cost and difficulty in obtaining transmission lines was considered as well as the quipment needed to install high voltage corridors. A new p3 ant should be as close as possible to existing facilities.

Today, the environmental impact is of extreme importance.

Some effects, particularly during construction, are transitory in nature. However, it was necessary to consider the impact of a permanent installation on the quality of water. air, and noise and even the general appearance of the plant in its new setting. Each of these parameters were considered individually and in conjunction with the effect of wildlife both in the water and on land. ,There should also be access to a reliable supply of high quality water for domestic and personal use.

The Atomic Energy Commission's present siting policies do not favor either an urban setting or urban proximity of nuclear plants'. Each site must have an exclusion zone of almost a mile in radius from the plant in every direction on land. Furthermore, neighboring populations generally will not be well disposed towards a nearby siting of a heavy industrial facility. The height of cooling towers, boilers, stacks, and tall buildings can be objectionable. Build-up of a dense population after construction of the plant was also taken into consideration.

The relative desirability of a new plant's socio-economic effect depends considerably upon the existing socio-economic personality of the area. The new plant is a sizeable addition to the local tax base, and the peripheral commercial activity caused by the new plant increases that tax base.

These parameters are at least partially offset by the necessity for an increased demand for services such as water, roads, traffic control, police, fire and health protection.

The total system compatibility goals are system reliability, safety and efficiency in the short, intermediate and long term. The plant setting was considered against these goals.

The FP&L site rating system, as outlined, is one of the foundation stones of effective environmental planning.

The use of this method has conclusively shown that there are m a n_y sites clearly superior to the Perkins plant. (See attached chart which is incorporated by reference as Exhibit 1)

It is recommended that Duke Power reevaluate the original 38 sites plus the Perkins site using the FP&L method prior to making a final decision on the location of the new nuclear power plant.

See Key Page 2 PLANT SITE EVALUATION LAKE LAKE LAKE TUCKER- BADEN WATEREE FISHING PERKINS PARAMETER WEIGHTING NORMAN (D) NORMAN (E) NORMAN (N-18 ) TOWN LAKE CREEK FACTOR R EP R EP R EP R EP R EP R EP R EP R EP C$82{nkisysfer deve opmeht 3 5 15 5 15 5 15 4 12 5 15 5 15 5 15 ( 5) (15)

Proximity to 5* 5 3* 3 4* 4 2* 2 1* 1 (5) (5) load center- (1) 5* 5 5* 5 Land availability 5 5 3 3 5 5 5 5 5 S 1 1 (3) (3) 1 5 5 Compatibility (3) (9) (3) (9) (2) (6) (3) (9) (3) (9) (2) (6) of land use (3) (3) (9) (3) (9)

Resourse _ _ _

consumption _ _ _ _

. Water 3 5 15 5 15 5 15 5 15 5 15 5 15 5 15 (2) (6) consumption (1) 3* 1* 1 5* 5 4* 4 3* 3 2* 2 (2) (2)

-atkSEaggQ d 3 4* 4 (2) (6) (2) (6) (2) (6)

Ee a "N (3) (2) (6) (2) (6) (2) (6) (2) (6) (2) (6)

Accessibility _ _ _ _ _

. To rail transportatior (1) 4* 4 3* 3 5* 5 2* 2 4* 4 1* 1 5* 5 (2) (2)

. To highway 5 5 5 5 5 5 5 3 3 1 1 6 5 (3) (3) transporta tf or 1 5 2

Ma9ptos 10 2 1 2 5 10 (1) (2) cons 1EIon 2 1 2 1 2 5 10 5 1 Cost of trans- 3* 6 (3) (6) mission CNXN (2) 3* 6 3* 6 3* 6 4* 4 5* 10 3* 6 Environmental - - - - - -

impact - -

1. Water quality impact (3) ( 5) (15) ( 5) (15) ( 5) (15) (4) (12) (3) (9) (4) (12) (4) (12 ) (1) (3)

. terestrial bic-logical impact 3 5 15 5 15 0 0 2 6 2 6 4 12 5 15 (3) (9)

'. Aquatic biolo-gical impact (3) (3) (9) (3) (9) (3) (9) (3) (9) (3) (9) (3) (9) (4 ) (12) (2) (6)

. Construction 5 5 5 5 5 5 5 5 5 5 5 5 (5) (5) effects 1 5 5

. Aesthetics (1) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3)

~ Air, quality impact 2 5 10 5 10 5 10 5 10 5 10 2 4 5 10 ( 5) (10)

EXHI BIT 1 Pa e 1 of 2 _

PLANT SITE EVALUATION (Continued)

PARAMETER WEIGHTING LAKE LAKE LAKE TUCKER- BADEN WATEREE FISHING PERKINS FACTOR NORMAN (D) NORMAN (E) NORMAN (N-18) TOWN LAKE CREEK R EP R EP R EP R EP R EP R EP R EP R EP

g. Noise impact (1) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3)

h. Transmission system routine (2) (5) (10) ( 5) (10) (4) (8) (4) (8) (4) (8) (4) (8) (4) (8) (4) (8)

1. Impact on fuel deliv. corridors (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3) (3)

Process water supply 3 3 9 3 9 5 15 3 9 5 15 5 15 0 0 (1) (3)

Population Density 2 4 8 5 10 4 8 5 10 5 10 5 10 5 10 (5) (10)

Socioeconomic -

impact - - - -

a. Cotmunity Senrices 2 5 10 5 10 5 10 5 10 5 10 5 10 5 10 ( 5) (10)

b. Area Economy 2 5 10 5 10 5 10 5 10 5 10 3 6 5 10 (5) (10)

System Compatibility (3) (5) (15) (5) (15) (5) (15) (5) (15) (5) (15) (5) (15) (5) (15) (3) (9) 50** 200 202 196 189 175 180 19.1 148 TOTALS KEY TO EVALUATION TABLE R -

Ratings EP -

Evaluation Ratings 8 -

Numbers with an

• or ( ) were taken directly from Duke Power's Summary Report dated January,'78 8* - Numbers with an

• were derived from Duke Power's Money Eata (8) -

Numbers with ( ) were assigned by consultant Allan H. Lipkin, Ph.D.

The total possible points is 250.

I EXHIBIT 1 -

Page 2 of 2

'..

• CURRICULUM VITA ALAP HARVEY LIPKIN 2635 Glenhaven Lane, Winston-Salem, North Carolina 27106 (919) 924-2688 Born: May 7, 1942, Lcs Angeles, California Military Service: Served Honorably in the U.S. Marine Co ps, August, 1960 to August, 1964.

Education:

Graduated, Birmingham High School, Van Nuys, California Military Training: Attended several schools while in the service. Some were:

Atomic Biological & Chemical Warfare School, Administration, Avionics Clerical School, Typing, Navigation as well as college classes from the East Carolina University Extension School during the night which led to acceptance at E.C.U.

after dischstge, 1963-1964.

A.B. (Chemestry), East Carolina University, Greenville, North Carolina, 1967.

Ph.D. (Organic Chemistry), University of South Carolina, Columbia, South Carolina ,

1971. Thesis: Quinolizones as Precursers to Lupin Alkaloids, 1973.

Post Doctroal Fellew: Organisch Chemi Institut, Universitat Zurich, Zurich, Switzerland, 1973. Research: Biogenesis of the Alkaloidal Content of the mushroom Aminita muscaria.

Academic Experience Assistant Professor of Chemistry, Winston-Salem State University, Department of Natural Science, 1973 - present. Teaching: General Chemistry I & II, Organic Chemistry I & II, Investigations-6 Research in Chemistry, and Seminar in Chemistry. Research Grant: . National Inctitute of Health ($83,700 during the period 1977 - 1980), Decarboxylative Cyclization. Other Research interests:

Transient anions as Nucleophiles. Pyridones as Alkaloidal Precursers.

Assistant Professor of Chemistry, Salem College, Winston-Salem, North Carolina.

Taught Organic Chemistry for a semester as temporary replacement for faculty member, 1975.

Educator: East Forsyth High School, Winston-Salem, North Carolina. Tuaght Chemistry, Physics, and Physical Science, 1972 - 1973.

Educator:- Forsyth Technical Institute,.Winston-Salem,'N.'.

C Taught Chemistry and Chemistry for Police Cadets, 1972 - 1973.

Post Doctoral Fellow: Organic Chemi cal Institute, University of Zurich, Switzerland, with Professor Dr. Conrad Hans Eugster. Investigated the Biogenetic Pathways of the Alkaloidal content of the " Sacred Mushroom" (thought to be the

" Soma" of the Hindu RgVeda), 1971 - 1972.

Teaching Assistant: University of South Carolina. Taught General and Organic Chemistry in the Laboratory. Assisted with Spectroscopy Course. Taught Nurses Chemistry at Orangeberg General Hospital, 1969 - 1970.

Actfdemic Experience (Continued):

Assisted in the Laboratory Laboratory Assistant: East Carolina University.

with General, Analytical, and Organic Chemistry, 1965 - 1967 Non-Academic Professional Experience-Senior Pa rtner and Glassblower, The Public Glassblower, Reynolda Manor Shopping Involved in management, book and record keeping, Center, Winston-Salem, N.C.

and the creation of high-qua14ty glass sculpture for exhibition and resale to the public, 1976 - present. This establishment deals in retail novelty glass, wholesale glassware, glass sculpture, and scientific glassware.

Consultant: King's Laboritories, Inc., Blythewood, S.C. , Consultation with Mr. J. A. Montgomery ,' Pl esident, concerning Organic Synthetic procedures and specialty scientific glassware,197G - present.

Consultant: Marsha3 ton Research Laboratories, Inc., King, N.C. Consul tation with Mr. Dean Flemmens, President, concerning Organic Synthetic procedures and specialty scientific glassuare,1976 - present.

Consultant: Occasionn1 consultation with EnCas Analytical Laborutcries, ..inston-Calem, ".C., with Dr. Charles Ganz, president, concerning specialty glassware and senpling procedures, 1977 - present. Also: Consulted concerning specialty sci;ntific glassware by Cibs-Geigy Corp. , Greensboro; F.J. Reynolds Research, Jinston-Jalem; Ffizer Cbcmical Corp., High Point; U.C. x&T University Department of Physics and Department of Cheristry, Greensboro; UUCG Departscnt of Physics; and Appalachian State University, Departrent of Chemistry and Phyr.ics, 1C76-present.

Activated Metals, Inc. , 3eviervillc , Tenn. A su ner position Analytical Chemist:

prior to attending graduate school. Hired by Mr. A.J. Ling, Fresident, to set up routine analytical procedures for certain metals, 1967 Honors and Other Experience:

Chairman: Southern Chess Administration, 1974 - 1977 The largest establishment for the promotion of rated Chess Tournarents in the Southeast.

Vice President: N.C. Chess Association, 1974 - present. The official national Chess Organization representing the State of N.C.

N.C. Delegate: United States Chess Federation, 1974 - present. The official ,

national Chess organization of the U.S.A.

Chess Tournament Director: official of the U.S. Chess Federation. Directed nationally rated Chess Tournaments throughout the Southeast, 1974 - 1977 State of H.C. Reserve Co-Champion in Chess, 1975 Chess Champion in High School and of Marine Corps Attack Squadron 242, 1962 Spoke on television, f.n public libraries, schools and universities, as well as Winston-Salem's Nature Science Center on Chess, Glassblowing, and Science.

Third Place Overall: Associated Artists of Winston-Salem Annual Juried Art Exhibition, 1975 Ulass Sculpture; " Red Dragon".

Honors also von at other juried exhibitions for glass sculpture.

Clubs and OrPanizations:

American Chemical Society American Society for the Advancement of Science Society of the Sigma'Xi (Honorary Research Fraternity)

U.S. Chess Federation N.C. Chess Association Southern Chess Administration American Scientific Glassblowers Society Associated Artists of h'inston-Salem Publications:

"The Syr. thesis of Anacyrine", Journal of Organic Cheristry, j?, 1823, (1972)

"The S: enthesis c f Lar.prolobine", Journal of Organic Chenistij y, 242 (1970)

"The 14ushroc~ m e ason", S .C . ,!ildli fe , Cctober 1971 "The l'.acic :.ushroom", v.C. Uildlife , July 3972 6

d CERTIFlCATE OF SERVICE I hereby certify that copies of Testimony of Alan H. Lipkin and Dr. Miguel A. Medina, Jr.

in the above-captioneo matter have been served on the follow-20th day of ing by deposit in the United Statesand mail /t'his Air Express January , 19 79.

Elizabeth S. Bowers, Esq. Charles A. Barth, Esq.

Chairman, Atomic Safety Counsel for NRC Regulatory Staf f and Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Dr. Donald P. deSylva Jr., Esq.

Associate Professor of William A. Raney, Marine Science Special Deputy Attorney General Rosenstiel School of Marine State of North Carolina and Atmospheric Science Department of Justice University of Miami Post Office Box 629 Miami, Florida 33149 Raleigh, North Carolina 27602 Dr. Walter H. Jordan William L. Porter, Esq.

881 West Outer Drive Associate General Counsel Oak Ridge, Tennessee 37830 Duke Power Company Post Office Box 2178 Chairman, Atomic Safety Charlotte, North Carolina 28242 and Licensing Board Panel U.S. Nuclear Regulatory Mr. Chase R. Stephens Commission Docketing and Service Section Office of the Secretary Washington, D.C. 20555 U.S. Nuclear Regulatory Chairman, Atomic Safety Commission and Licensing Appeal Board Washington, D.C. 20555 U.S. Nculear Regulatory Commission Mr. J. Michael McGarry, III Washington, D.C. 20555 Debevoise and Liberman 700 Shoreham Building 806 Fifteenth Street

, Washington . . 005 tb William G. Pf ef f erkorh' '" ~/] /

Attorney for Intervenors U y PFEFFERKORN & COOLEY, P.A.

Post Office Box 43 202 West Third Street Winston-Salem, N.C. 27101 Telephone: (919) 725-0251