ML20246E343

Opposition of Intervenor Limerick Ecology Action,Inc to Motion by Licensee Philadelphia Electric Co to Set Schedule for Discovery & Hearing.* Requests That Schedule Be Replaced W/More Reasonable Schedule,As Proposed.W/Certificate of Svc

ML20246E343
Person / Time
Site:	Limerick
Issue date:	08/22/1989
From:	Elliott C LIMERICK ECOLOGY ACTION, INC., POSWISTILO, ELLIOT & ELLIOT
To:	Atomic Safety and Licensing Board Panel
References
CON-#389-9078 OL-2, NUDOCS 8908290095
Download: ML20246E343 (29)

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I h UNITED STATES OF AMERICA iN L.. NUCLEAR REGULATORY COMMISSION -p Before the Atomic Safety and Licensina B I pgggggp i

Li In the Matter of ) 1 ?AUG 221989* :: _

) Docket Nos.

50-3hh" h $ $ $n'cn Philadelphia Electric Company .) 50-353nj ::cumc g (Limerick-Generating Station, ) QT(i Units 1 and 2) )

OPPOSITION OF INTERVENOR LIMERICK ECOLOGY ACTION, INC.

TO " MOTION BY LICENSEE PHILADELPHIA ELECTRIC COMPANY-TO SET SCHEDULE FOR DISCOVERY AND HEARING" Intervenor Limerick Ecology Action, Inc. (" LEA") opposes the extremely abbreviated schedule proposed in the " Motion By Licensee Philadelphia Electric Company. to Set Schedule for Discovery and Hearing" ("PECO Motion") for the reasons set forth below:

I. PECO's Proposed Schedule Is Unreasonable While the schedule proposed by Philadelphia Electric Company

("PECO") accommodates its own interests, it does not afford LEA the minimum time required to prepare its case. It therefore does a

not satisfy the minimum requirements for hearing under the Administrative Procedure Act. and the Atomic Energy Act 1 /; nor does it advance principles o'f justice, fair play, or due process.

1/ See,e.a., Administrative Procedure Act, 5 U.S.C. Section 556(d) ("A party is entitled to present his case or defense by oral or documentary evidence, to submit rebuttal evidence, and to conduct such cross-examination as may be required for a full and true disclosure of the facts".

B908290095 090822 PDR ADOCK 05000352 PDR O

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For these reasons,. the PECO proposed schedule is also inconsistent with the Commission's directive to the Board that the remand proceedings be " expedited to the extent consistent with fairness to the carties". Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2), " Commission Order",

May 5, 1989 (slip op. at 2).2/

PECO proposes a mere thirty days for the review of all information already provided under informal discovery in this case, the preparation of all additional discovery requests, the preparation of all responses to all formal discovery, and the review of all of the additional information provided in formal discovery. It then provides only a ten day period for the submission of testimony (in LEA's case, requiring coordination between counsel in Pennsylvania and experts in California). Such a schedule completely ignores the complexity of the issues, the technical requirements involved in the necessary review of the newly revised three-volume PECO probabilistic risk assessment and i

another separate volume, a " Containment Safety Study", addressing 1

2/PECO has already signaled its intention to involve the licensing board in unfair litigation strategy by seeking an order  ;

demanding an expedited response to the PECO Motion. See, Memorandum and Order (Request for Expedited Answer), August 15, 1989, slip op. at 3 ("The requested action is not supported by good cause, nor is it fair to the parties".)

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Limerick's severe accident containment response 3/, and the need for meaningful discovery in parallel with LEA's ongoing review of these risk assessment materials.

In addition, unlike LEA's discussion infra, PECO presents

,. absolutely no specific justification for the schedule it i proposes. It merely recites, in a conclusory way, that it has informally provided information to LEA and the NRC Staff, and that "the material already provided by Licensee would constitute its evidence at hearing". PECO Motion, at 3. No wonder PECO wants a hearing schedule which would make it impossible for LEA to adequately review the material submitted and to conduct a meaningful technical review. Its litigation strategy is patent:

(1) present its own " evidence" on SAMDAs even prior to the hearing to the NRC Staff and to the licensing board (by serving e

3/ We say " newly revised" PRA because this most recent three volume PRA (provided to LEA in the middle of July, 1989) represents a substantial departure from the risk estimates which PECO presented in its 1981 Probabilistic Risk Assessment (internal accident initiators only) and its 1983 Savere Accident Risk Analysis (" SARA") (including " external events") which were reviewed by the parties, reviewed by Brookhaven National Laboratories (see NUREG/CR-3028 " Review of Limerick l Probabilistic Risk Assessment", February 1983) and formed the l core of the basis (with required corrections by Brookhaven and

). NRC staff) for the Staff's environmental assessment of severe

, accidents in the Limerick Final Environmental Statement, NUREG-0974, " Final Environmental Statement related to the operation of  ;

Limerick Generating Station, Units 1 and 2". In addition, the  !

. 3-volume PRA provided to LEA in mid-July 1989 failed to contain any analysis of the containment response to severe accidents.  ;

That analysis was contained in a separate three-inch thick report, " Containment Safety Study (Preliminary Dra f t) " . This document, for inexplicable reasons known only to PECO and its counsel, was not provided with the PRA. That document--

obviously critical in any analysis of containment mitigation j options --

was not provided to LEA until weeks later, July 24, l 1989, less than a month ago. '

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-the ASLB with its " evidence" contained in pleadings before the Commission.-itself on the. licensing issues now being resolved.by it), (2) preclude meaningful. opportunity for technical review by LEA, and' (3) stampede to hearing with an absurdly truncated

.- schedule, in hopes of obtaining the concomitant rush to judgment which'such a procedural arrangement implies.

The fact that PECO provided to LEA, some less than a month ago, crucial technical risk assessment documents does ngt meaningfully " reduce [] the amount of formal discovery needed by the parties to prepare for - hearing", as PECO claims. See PECO Motion, at 4.

The PECO documents in fact raise more questions than they

• . answer. This is because, inter alia, the risk numbers depart so significantly from the earlier [NRC Staff and Brookhaven 4

reviewed] PRA documents. LEA has concluded that it will be necessary to investigate in detail this most recent risk analysis.

As we have noted, PECO. has only recently provided LEA with the " updated" relevant PRA and other risk documents for f submission to its primary consultants, Mr. Steven Sholly and Mr.

. Robert K. Weatherwax4 / who have commenced-preliminary reviews of  ;

i those documents. Mr. Weatherwax has indicated that his review of i the PRA materials will require him to obtain from PECO (cr NUS j Corporation, consultant to PECO) the PRA computer models and 4/ The resumes or statements of qualifications-of Mr. Robert  !

K. Weatherwax and Mr. Steven Sholly are attached hereto as Attachments A and B respectively.

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codes in a format which will permit the running of the codes on the computer equipment of his expert consulting firm, Sierra Energy and Risk Assessment, Inc.

Mr. Weatherwax has further concluded that the time required

. to review the new PRA, obtain and run the necessary computer models and codes (assuming prompt responses to our requests for the information), coordinate technical information exchange with LEA's other witness (es), perform the required value-impact analyses,. and prepare testimony is 22 to 24 weeks. See Attachment C.5/ Therefore, in view of the time requirements for technical review of recently supplied documents (upon which PECO intends to fully rely for its current risk estimates, and thus any cost-benefit analysis)6/ LEA requests this Board to establish a

5/ This time estimate is not a " leisurely" schedule by any means; in fact, the estimate is based upon numerous generous assumptions in favor of a tight time schedule (e.g., that the new PRA, Revision 5, dated November 1988, is complete and revisions to it are not planned during the period of analysis, that PECO or its consultant will willingly and rapidly supply in mutually acceptable computer-readable form, the full input data set, complete source code, code in executable form, and full output data sets employed to generate the base case results for the new PRA, and that no major mistakes will be uncovered in a new PRA that will necessitate a substantial redo of that analysis) .

6/ LEA will be required to conduct its own complete review

. of the newly issued PRA and containment safety study because, inter alia, the NRC staff appears to be willing for purposes of this proceeding to accept at face value the PECO newly revised

. risk analyses and containment response study. This is in stark contrasu to its previous practice of obtaining Brookhaven National Laboratory review of PECO's risk analyses, a decision which proved to be amply justified. Unlike the NRC staff, LEA is not willing to accept PECO's estimates at face value. Our skepticism is fully warranted in view of the history of the earlier PECO risk estimates. Brookhaven's review of the PRA resulted in sharp disagreement with PECO over the validity of the risk results, with the Brookhaven review estimates of core damage 5

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t a hearing schedule in accordance with the schedule proposed in Section III below, " LEA's Proposed Schedule".7/

II.

The Scope of the Severe Accident Risk Reduction -

Measures To Be Litigated In This Proceeding May Be Altered By LEA's Anticipated Filing of

Late-filed Contentions In Accordance With the Memoranda and Orders of this Board and the Commission As the Board will note, the Commission's order of July 7, 1989 indicated for the first time that the litigation in this proceeding would be limited to the "same opportunity to obtain consideration of specific SAMDAs as it would have had if its SAMDA contention had been fully litigated before the licensing Board when it was submitted. If LEA now wishc to have other SAMDAs considered, it can do so by satisfying the requirements governing late-filed contentions". Philadelphia Electric Co.

(Limerick Generating Station, Units 1 and 2), Memorandum and Order of July 7, 1989, CLI-89-10, slip op, at 3-4, n.1. This than those proposed by PECO. See, frequency and other measures of risk and Table 3 from NUREG-1068, e.g., Attachment D, Figure 1 Probabilistic Risk " Review Insights on the Assessment for the Limerick Station", August 1984.

staff review and preparation In addition, in the midst of Generating of the Limerick the NRC the NRC staff by letter of March 13, FES, PECO advised errors in the 1983 SARA consequence 1984 that it Such analysis. had discovered a history affords LEA numbers to little basis for sufficient confidence in PECO's blindly accept them for purposes of this adjudicatory proceeding.

never 7/The Board the past requested any should note delay in the that this counsel on LEA commencement 's behalf of any hearing in request a of this now eight-year old proceeding, nor did he ever board hearing because of schedule which nor undue delay was denied by the licensing recollection) any other reason. (to the best of his 6

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I Board echoed that conclusion in'its decision' limiting the scope of the litigation to certain specific SAMDAs, and rejecting various low-cost SAMDAs which were set forth in' LEA's submission-

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" List -of Primary Candidates for Severe Accident Mitigation". It

. noted that other SAMDAs would have-to be presented as late-filed contentions. See, e.g., Memorandum and Order, LBP-89-19 (July 18, 1989), slip op. at 13,17.

'In fairness to the Board and to the other parties -- in. view of its implications for scheduling in this matter -- LEA wishes to provide advance notification to the Board and parties that it is LEA's intention to file as soon as practicable a motion with' this Board to accept as late-filed contentions " the remaining elements of the risk reduction package presented by LEA as its 4

" List of Primary Candidates for Severe Accident Mitigation".8/

LEA's counsel's preoccupation with other filings in this matter following this Board's July 18, 1989 Memorandum and Order denying admission of various elements of LEA's risk reduction package--

l-8/ This list was submitted to the parties and to the Board at the first special prehearing conference in this matter on June 6, 1989. The 3ist was also submitted as part of the "Mamorandum of Limerick Ecology Action, Inc. Pursuant to Prehearing

. Conference Order of Atomic Safety and Licensing Board of June 9, 1989". At that time, LEA believed that its proposed severe accident risk reduction measures vere within the scope of its contention DES-5. LEA further believed that DES-5 was admitted into the proceeding as a result of the remand of the United States Court of Appeals for the Third Circuit in Limerick Ecoloav Action,Inc. v. U.S. Nuclear Reculatory Commission, 869 F. 2d 719 (3d Cir. 1989). While LEA still believes its position to be correct, it is apparent that the Commission disagrees; LEA

- therefore has no choice except to present to the Board a motion for admission of its other severe accident risk reduction measures as late-filed contentions.

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. including preparation of this ' opposition --

has precluded completion'of such a motion to date. However, preparation of the required expert affidavit (s) to support such a motion is nearing.

completion, and LEA expects to . file its motion within the next l

two weeks. Therefore, LEA believes that the fundamental assumptions concerning the scope of the proceeding which underlay PECO's proposed schedule are incorrect.

III. LEA's Proposed Schedule Is Realistic and Properly Accounts for the Complexity of the Issues and the Time Required for Adequate Technical Review and Analysis I

As we indicated above, LEA's experts have concluded that to properly review and analyze the critical risk assessment j documents which will be at the center of the' matters in I

controversy in this case will require a period of 22 to 24 weeks. j The issues in this proceeding travel far beyond simple issues of compliance with. specific regulatory provisions in Part 50.

Instead, they~are questions of first impression in NRC licensing hearings. Never before have such severe accident risk mitigation ]

issues been litigated in NRC licensing hearings, and the j I

technical issues relating to risk assessment and wevere accident  ;

-mitigation based on prcbal;>ilistic risk assessment are relatively j l

new.  ;

To est'iblish a schedulce which does not afford sufficient ]

time to conduct an adequate technical review of the fundamental i

risk assessment documents in this case would deprive LEA of a meaningful opportunity to be heard. Based upon expert best 8

E h estimates of the time requirements to conduct an adequate technical review, LEA proposes the following schedule:

Filing of formal discovery requests Commence upon issuance of order Completion of discovery (including 20 weeks thereafter completion of responses to dis-covery requests as provided by NRC rules of practice)

Submission of testimony 4 weeks thereafter Motions to strike, etc. 10 days thereafter Responses to motions to strike 7 days thereafter Commencement of hearing 10 days thereafter

. IV. Conclusion For all the reasons set forth above, LEA requests that the

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Board deny the PECO Motion, and to establish a reasonable schedule in accordance with the schedule set forth above.

POSWISTILO, ELLIOTT & ELLIOTT By-Ch:tries W. Elliott 1101 Building Eastan, Pa. 18042 (215) 258-2374 Attorneys for Intervenor Limerick Ecology Action, Inc.

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i SERA Sietro EnerQy and Risk Assessment. Inc.

gggggggg ROBERT K. WEATHERWAX EXPERIENCE:

Jan.1981 - Present Prmdont, Sierra Energy & Risk Assessment, Inc.,

Rosevalle, C A July 1980 - June 1981 "imtng SMmH% Ener;;y and Resources Group, University of Califmia, Be:ieley, C A July 1977 - Dec.1980 Chief Energy Fatecaster, Calinwmia Energy Com mimon, Sacramento, C A Jan.1977 - June 1977 Staff Sc:erzt:st, Science Applications, Inc., Palo Alto, C A May 1974 - Jan.1977 Staff Scientist, School cf Engineenng, PIinceton University, Pnnceton, New Je:sey Jan.1969 - April 1974 Spm Safety Superdscr, McDonnell Douglas Aeronautics Company, Huntington Beach, CA As the founder and Prmdent of Sh Energy & Risk Assessment, Inc. (SERA),

Mr. Weatherwax is se==ily irwolved in the twin topics of (1) risk assessment and compmmn, and amnMama ccst benefit analysis; and (2) energy demand and supply assessmerrt, and pchey evalnaMnn.

He has had fifteen years of erro-ate in rinMae cafmty analysis of commerr:ial power gerv=wdnn and 2sotcpe power systems far space application. He has werxed l=oadly in the area of rmMe fuel cycle risk assessment, and in raliahiYry and failure mode assessment of complex systems. Iio has concihzted co the original development of elemests of fault tree, mque,1ce trea a.k.z-, F AST), ,ird ever:t tree analyses, arri has applied these methods in malys(is of Jight water nuclear power # ants, nuclear fuel cycles, radici?ctope ther nal generators, stracegic vmpons systems and launch veh2cles. He is an engineer by fcrmal education with a runcr in economics and has apolicd these dia-dplines in numerous systems engineering an.1 l evalnadon efforts, part:cularif related to energy demand ferecastirq ard pc] icy amamment.

Mr. Weatherwax is, perhars, best known in the f!akt of nuclar relithiliry and risk assessmerrt. for his: (1) Imd am5crship of the Raliahm"/ Amment of the Shuttle which ec:nnately farecasted the Challenger faih:re mode and pmt*N1*f of j catastroph:c faihre three ynars befcre it fa21ect, and (2) 1976 debate before the American Physical Society with Ncrman Rasmussen, PW Directr:r, on the accuracy of the Reacter Safety Sti:dy (W ASH-1400) - his Fnn, dWa3 in greater detailin a September 1975 art:cle in the Sullet:n of the Atomic Scient:sts, was subsequently adopw' by the NrrMae Regulaterf Commimon. In the fdAld of energy assessmerrt, he is rw~vmired as hav2ng developed the first series of ATTACHMENT A One Sierrogate Pic:c. Surte 270C Reseville. CA 95678-6607 916/782-5421 FAX 916/782-4528

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Robert K. Weatherwax Page Two

, methcan1S mi to accurately project future Califatnia alWHty and rwhn-al gas demand.

As a McDonnell Douglas Aeronautics Company (MDAC) Engineering Superviscr, Mr.

Weatherwax was a principal author of a pmliminary safety analysis repart for the NASA 50 kWe space station power system. He later was manager far the the Environmental Air Force WeaponsImpact M aand Risk Assessment af (AFWL) on theanalyses to pe n o m safety MDAC team salarrad of LES 8, p9 and Viking missions. Afterleaving MDAC he continued as a consultant to MDAC, and subsequently became a consultant to Teledyne Energy Systems in their support of the AFWL's space rmelaar safety s:sesidN1iHm- Other technical expetence at l M D AC, and previously at Boeing, ipHndad pw_Eu.mance of quant'raHve safety and raliaN14ty analyses of the shcrt range attack miela, NERVA, Shuttle and its payload applicaHnns program, space station and a*atad nnHaar power systems, manned nrhiHng la1m 4y and its TITAN launch vehicle, and the SPRINT II mimila.

Mr. Weatherwax has performed energy and risk analysis of fusion systems and rnclam reactar designs. At Pnnceton Untversity, he modeled pd u mance and ecst propHm of TOK A M AK fnmnn reactarconcepts and amnniarad power conversion technninnim far commeial power plants CIRCA 2000. He was also coauthcr af a rnMur phystes assessment of the value of recycling spent reactor fuelin which the proponent's analysis was independently en11ah ei without rehance upon computer modeling. While employed by Science Apphcat:cns, Inc., Mr. Weatherwax directed the pmhaHlidc risk assessment (PRA) of the Hanford (nndmr) Reservation Purex Plant. He also managed the initi,stion of the PRA of a Swedish PWR under Swedish Government sper~ m 'dp.

Since fccming SERA in 1981, Mr. Weatherwax has tmn redilr invdved with amamment of system reliab0ity anri risk. He has reviewed and evahtr ac! the PR As of the 'Mian Poinc erd popcr:ed Li.merick and Shreham light water tractor power plants. In 1983 (19 0), Mr. Weatherwax t-Mad before the *.ndian Point (Shcreham)

Atomic Safety and Liceming Bcuni rSwig the p:rtubilistic risk asumment of ..

the Irdian Point (Shzeham) Pover Plarm. Eis mo':;e ::ecent smth have dealt with the propmed Shuttle-Certour Jaunch of the Galileo and ISPM epacccrafts. In another extensive reli.Adlity effcer, Mr. Weatherwx ard M2 staff perf:rmed a detailed ammerc of the ralinHwy a:d rystna effectiveness of an ultramcic faripe detection cys:ex far use in ceep-ma cil dciHing platfccms. The analysis r:ornidmd exper:.mectalresuhr, and, drawing upon the GIDEP data base of chmrved faihc_e 84tes fer pWee pm and ruteystems, p.Qx:md macus system r214aM1"y

..evels and ac::oupanying uncertainty levnls were pinjacred.

Mr. Weatherwax's mere recanc research and devcuopaet irrErests in the area of mhaN14ctic risk assesmen. have focuaed on the adeepx y of existing fnult-tree and event-tree metho:fologtes far estimating b -pmMH147 emre andreptemntatdem

Robert K. Weather. tax Page Three of uncertainties in usk/ benefit analysis. He coWhead his insights in this regard to a 1985 NSF Peer Group review of the accuracy and utdity of PRA for civilian LW Rs. He was also involved in an AFWL project reviewing the FRA of the space shuttle /Galilan and Internat:cnal Solar Polar missions. He recently completed a compamtive pmhnhmec fmlnre analyE!s of altAmative emergency power systems for the Shoreham Power Station in Long Island, New Ycrk.

Mr. Weatherwax's experience in energy fnm-aM_ng ire'nds wctk done at Princeton Universtty, U.C. Berkeley and at the CEC where he was Chief Energy Fcrecaster.

During this time, he y L wed researchinvc1ving formulating end-use macroeconomic energy demand f-aming models and implementation of data bases for use with various end-use forecasting models. He developed the first uttlity service area vmen of a redantial end-use energy demand fn=-aming and aMarM load shape fnm-neing model As the Chief Energy Forecaster, he was 2*gusible fcr f-e_Mng electrcity and narnm1 gas requimments and peak loads far uttlity service areas used in determunng the need for power plants within Califamia. His deles irv-indad technical direction of about twenty-five . r%fA' ara-level

, profmmnnals in developing and implementing state-< f-the-art macroeconomic end-use models of enecqy consumption by fueltype and ebu peak load by economic sectcr by utihty servace area. Other dates involved evaluating the ecst effectiveness

, of cormvcGon and altamative energy opt:cns and their pcL_adal energy impact.

ED UC ATION B.S., Engineenng Science, California InMt,*e of Technology,1966 M.S., Aeronautics and Astronautics, University of Washington,1968 1

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• SERA Sierra Energy and Risk Assessment. inc.

f CAPAm71'rPR STATEMENT IN THE AREA OF RELIAmTI'Y ANALYSIS AND PROBANJSTIC P.ISK ASSESSMENT Rie m Energy and Risk Asessment, Inc. (SERA) is a Sac =amento based consulting firm Walidng in energy demand, conservation and supply assessment, ra14ahnity and pmhahnie risk analyses. SERA's employees and consultants mm- ut an epanced, mn1He+ieplinary team that prov2 des a broad spectrum of technical exppHance and %dse to private and public che The ach1caHanal backgrounds of SERA's employees and consultants loc 1ndo: engineenng, economics, system science, physics, stat:stics, ecology and . law.

Some on-going and recently completed eneMm in the _m14ahi14ty and risk area aprinda:

o Parti +aHmn in a National Science Foundation Panel that invmHrJatad and evainaraa pmhahnie_:c risk asessment and its appogate uses in the NRC power plant siting process.

o Comparative raliahnity analyses of altemative ema.wwcy power system dmigns for low-power testing of the Shoreham Nnr19Ar Power Station on Long Island, New York.

o Review and Assessment of the prphahnic:t'.ic n'.zclEer risk assessments of the Indian Point and Limerick light-waterraaet& nutdeer power plares.

o Reliability, maintainability and cwaall syster. aN-tiveruss analysis of a nonhuetive tmdng and d%gncstic system fnr nhennic inspection -

of tie ins:de of noc'ing Irgs of a tWcndeg, deep-sea, oil-dctlhng plcLS.a. n destgn. 4 o Reliabnity and safety assessments of vacous tether concepts to facuitate

• • al tcandem and space op"Hmns us'ag the Fhuttle.

o 13sessment cf reliahnitf and maintainabi'ity ch aactad=Hcs of solar-inarmel, dynamic elec::ricr..y 9mhh] sysD3 ss ftr applicatioli to the NASA space stacion.

o Review and ctitique of cm uadur propued r'<"mi<rtope-thermcelar.dc-

[ generater (RTG) mirahnMf end prebsilistic ILsk asrassments of tly3 shutt's and Centaur G Prime far the galileo and Intemational Solar Polar Wm,nns.

One Sierrogote Picza. Suite 270C Reseville. CA 956784607 916/782-5421 FAX 916/782-4528

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o Development of a prnhahnieir- risk -ment metMingy for a,T lie ahem to RTG power-system missions 2*ilidre NASA's space shuttle.

r.>._ _...'--r,t estimation of occunence ,,,,r.w.wniHan of aald **la and' upper stage en-adde faihne m .

SERA is a memberin good standing of the Govetnment, Industry Data Exchange Program (GIDEP) and has access to other major govatnment and industry L

m14mbnity data bases.

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9 PROFESSIONAL QUALIFICATIONS OJ' STEVEN C. SHOLLY J STEVEN C. SHOLLY!

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- MHB Technical Associates

%. 11723 Hannitos Avenue -

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. San Jose, California 95125

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(408) 266-2716 EXPERIENCE

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, Annaalaea - MHB Taeka *al A =aneia'*a San Jose. Sl*f6fe ~

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" AMa'a in' energy consulting firm that specializes in technical and economic aneurnente of energy production facilities, especially nuclear, for local, state, and federal governmems and private organizations. L MHB is cuc_nsively involved in rer.datory proceedin88 **d the '

preparadon of studies and reports. Conduct research, write reports, participate in disw-y. --

process in regulatory proceedings,' dcMop testimony and _other. documents for regulatory proceedings, and respond to client inquiries. Clients have included: State of California, State of

~ New York, State ofIllinois.'

February 1981; September 1985 Taeka;emi Reeen ch Anneinte and Risk Analvat - Union of Cc=.uned Scieerb Wae*= mon.

-E Research : -aci=te and risk . analyst for ' public interest group based in . Cambridge,

Massachusetts, that r,pccializes in e='aing the Impact of advanced technologies oc society,

, "' priodpeDy in the areas of arms control and cacrgy. Technical work focused on nuclear power

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plant safety, with emphasis on prob 3Elinic risk assessment, radiological emergency planning and prepandness, and generic safe:y issues.- Conducted research, prepared repsts and stu!Jes, g perddysted in! administrative proc edirqs before the U.S. Nuclear Regulatory Coenaussion, 7: developed tastiracay, an2 lysed NRC ruis malring proposajs anx! draft ecports and ;meparad 7 monuncats theron, and responded to icquiries trum sponsors, the ge.neral public, and ths i %: meda; Pascipated as a member cf the Panel on ACRS Effectiveness (1985), ti;e Paned on

!_' L" - Regalatory Urcs of Probabilistic Risk Asseument (Pett Review of NUREG luP,1984),

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. Invited Observer to NRC Peer Review meetings on the source term ressser,sment (BM12104; 1933-1984), and the Independent Advisory Corarnittee ce Nuc! car Risk for the Nuders Risk Tade Force af the Nationt.1 Association ofInsurance Conr.missioners (1984).

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January 1980 January 1981 Proieet Director and Research _ Coordinator - Three Mile Tsfand Public interest Ressee-C=nter. Harrisburr. Pennsylvania Provided administrative direction and coordinated research projects for a public interest group

• based in Harrisburg, Pennsylvania, centered arcund. issues related to the Three Mile Island Nuclear Power Plant. Prepared fundraising proposals, tracked progress of U.S. Nuclear Regulatory Commission, U.S. Department of Energy, and General Public Utilities activities concerning cleanup of Three Mile faland Unit 2 and preparation for restart of Three Mile Island Unit 1, and monitored developments reisted to cmergency planning, the financial health of General Public Utilitics, and NRC rulemaking actions related to Three Mile Island.

July 1978 - January 1980 Phief Rinineiral Process Onerator - Wastewater Tratment Pfant. Derry Townshin Monicipal Authority. Hersbev. Pannevivania Chief Biologica! Process Operator at a 2.5 million gallon per day tertiary, activated sludge, wastewater treatment plant. Responsible for biolosical process monitoring and control, including analysis of physical, chemical, and biological test results, process fluid and mass flow rnanagement, micro-biological analysis of activated sludge, and maintenance of detailed process logs for input into state and federal reports on treatment process and effluent quality. Received certification from the Commonwealth of Pennsylvania as a wastewater treatment plant operator.

Member of Water Pollution Contrel Association of Pennsylvania, Central Section,1980.

July 1977 -July 1978 Wnstewater Treatment Plant Onerator - Borouzh of Lemovne.1_rmovne. Pennsvivanis Wastewater treatment plant operator at 2.0 millien gallon per day secondary, activated sludge, wastewater treatment plant. Performed tasks as assigned by supervisors, including simple physical and chemical tests on wastewater streams, maintenance and operatica of plant l equipment, and maintenance of the collectlon system.

September 1976 Juns 1977 Fen, e Ter.cher West Shore school DistrirQ,[gp MIR Fermvlwni=

Taught Earth and Space Science at ninth grade !cuct. Developed and implemented new course E materials on plate tectonics, environmental Scofogy, and space science. Sewed as Assistar1 l- Coach of the district gymnast!.cs team.

September 1975-June 1976 1 ,

I Science Tearb-r . Carlisle Area School District &gjitl e, Penwivania _

.f ,

TautAt Earth and Space Science and En1ironmental Scieuce at ninth grade level. Developed and implemented up tourse materials on plate tectonirs, environmental geology, noir.c i pollution, water polle.clon, and ersergy. Served as Advisor '.o tbc Sc!ence Projects Club.

f I

I 2-j

eg EDUCATIO_N:

B.S., Education, majors in Earth and Space Science and Genera! Science, minor in

~

Environmental Education, Shippensburg State College, Shippensburg, Pennsylvania,1975.

Graduate' coursework in Land Use Planning, Shippemburg State CoDege, Shippensburg, Pennsylvania,19771978.

PUBt ' CATIONS:

1. " Determining Mercalli Intensities from Newspaper Reports," Journal of Geolorical Edomeinn.

Vol 2S,1977.

.e;

2. A Critiane of: An Independent Aneement of Evacuation Times for T! tree Mile faad Nuclear

" cwa Pl=P Threc Mile Island Public Interest Resource Center, Harrisburg,' Pennsylvania, Janunty 1981.

3. A Brief Review and ('riticue of the Rockland County Radiolomicsl Emercency Preswedneu

. E. lag, Union of Concerned Scientists, prepared for Rockland County Emergency Planning Personnel and the Chairman of the County Legislature, Washmgton, D.C., August 17,1981.

4. The Narauiry for a Promnt Public Alertine Canability in the Plume Exoo<ure Pathway EPZ at Nuefew Power Plant _ Sites. Union of Concerned Scientists, Critical Mass Energy Project, Nuclear Information and Resource Service, Environmental Actior., and New York Public In-terest Research Group, WaaMagton, D.C., August 27,1981.

• 5.

Union of Concerned Scientists, Inc., Comments on Notice of Proposed Rulemaking, Amendment to 10 CFR 50, Appendix E, Section IV.D.3,* Union of Concerned Scientists, Washington, D.C., October 21,1981.

• 6.

"The Evolutioc of Emergency Planning Rtises,"in The Indian Point Book A Briehydq i Stimr Ionarisansdivi.Infar Niet Nuclear Power Plants, Anne Witte, editor, Unha of

' Coricerk:d Leientisti (Washiopon, D.C.) and New York Public Ieterest Research Group (New York. NY),1987, 7

"Unkan of Concerned Scientists r".ommca:s, Froposed RW, V CFP. Patt 50 Emerpacy Pisaning and Peptredens: Exercises, ClariGcation of Regulatior.s,46 F.R. 61134,' Ur. ion cf Cmccrued Scientists, WuMqron, D.C., January 15,1M2.

• 1 1 . S.

Tett! mot y of Robert D. Polkrd and Steven C. Shoty before the Subcommittee o's Encrgy and the Fmvironmeht, Comnunet; on Interior and Insdr Affairr, U.S. House of Representa:rver.,

Middletown, Pecr.syPaait, March 29,1981, avausble from the Union of Concerned Scientists.

G.

'Unica of Concerned Sciez.tista Detailed Canat:nts un Petition for Rulemtlirg "oy Citizen's Task Ir'orce, Emeresency 71anning,10 C' I R Parts 50 and 70, Dc.cket No. l'RM 50 31, 47 F.R.

1%39,* Union of Concerned Scientists, Washingtor, D.C., May 24,1962.

10. Supplements to the Testimony of E!!yn R. Weiss, Esq., General Counsel, Union of Ccmar.rud Scientists, before Ge Subcommittee on Energy Conservation and Power, Committee on Energy 3-

"7 1

I and Commerce, U.S. House of Representatives, Union of Concerned Scientists, Washington, D.C, August 16,1982.

11.

Testimony of Steven C. Shelly. Union of Concerned Sciendsts, Washington, D.C., on behalf of the New York Publie Interest Research Group, Inc., before the Special Committee on Nuclear Power Safety of the Assembly of the State of New York, hearings on Legislative Oversight of the' Emergency Radiologic Preparedness Act, Chapter 708, Laws of 1981, September 2,1982.

12.

" Comments on ' Draft Supplement to Final Environmental Statement Related to Construcdon and Operation of Clinch River Breeder Reactor Plant',* Docket No. 50 537, Union of Concerned Scientists, Washington, D.C., September 13,1982,

• 13.

" Union of Concerned Scientists Comments on ' Report to the County Commissioners', by the Advisory Committee on Radiological Emergency Plan for Columbia County, Pennsylvania,"

Union of Concerned Scientists, Washmgton, D.C, September 15,1982.

14

" Radiological! Emergency Planning for Nudear Reactor Accideatt.," presented to Kernenergic Ontmantcld Congress, Rotterdam, The Netherlands, Union of Concerned Scientists, Washington, D.C., Occober 8,1982.

15.

" Nuclear Reactor Accident Consequences: Implications for Radiological Emergency Planning,"

presented to the Citizen's Advisory Committee to Review Rockland County's Own Nuclear Evacuation and Preparedness Plan and General Disaster Prep tredness Plan, Union of

. Concemed Sciendsts, Washington, D.C., November 19,1982.

16.

Testimony of Steven C. Sholly before the Subcommittee on Oversight and Investigations.

C)mmittee on Interior and Insular A6 airs, U.S. House of Representatives, Washington, D.C, Union of Concerned Scientists, December 13,1982.

17.

Testimony of Gordon R. Thompson and Steven C. Sholly on Cornmission Question Two, Contentions 2)(a) and 2.1(d), Union of Concerned Scientists and New York Pubhc Interent Research Group, before the U.S. Nuc!c tr Regulatory Commission Atomic Safety and Licensing Board,in the Matter of Ccuscudated Edison Company af New York (Indian Poins Unit 2) and the Power Authority of the State of New York (Indian Point Unit 3), Decket Nos. 50 2474P and 50-286 SP, December 23,1982.

• 12.

Tertimony of Staen C. Shony on the Coascquences of Accidents at Indian Point (Commt.sicu Question Dr e .md Bord Questics 1.1, Valon of Concernud Scientists and New York Public Intenust Research Group, bl.i. arc the U.S. Nucicar Regulatory Commission Atomic Safety and Licensing Ber.rd,it the Matter of Consolidated Edisx Company of New York (Indian Point Urdt 2) and the Pour Authori,y of the State of New York (Indian Point Unit 3), Docket Nos.

50-247-SP and 50-286-SP, February 7,1983, as corrected February 16,1963 *

19. Techr.ony of Ste*cn C Sholly on Commission Question Five, ' Union of Concerned Scientists and New York Pub;ic Interen Research Group, before the U.S. Nuchar Re$ntr. tory Commirion Atow;e Safety and Licetti:q Bord, in the Matter of Consolidated Edison Company of New York (Indian Point Unit 2) and the Power Authority of the Stato of New Ycrk (Indian Point Unit 3), Docket Mos. 50 7474F and 30-2S6-SP, March 22,1983. *

20. " Nuclear Reactor Accidents and Accident Consequences: Planning for the Worst," Union of Concerned Scientists, Washington, D.C, presented at critical Mass '83, March 26,1983.

e*P

l- . l

}

I

21. i Testimony of Steven C Shouy on Emergency Planning and Preparedness at Commercial Nudcar Power Plants, Union of Concerned Scicatists, Washington, D.C., before the  !

i Subcommittee on Nuclear Regulation, Committee on Environment and Public Works, U.S.

Senate, April 15,1983, (with " Union of Concerned Scientists' Response to Questions for the f i

Record from Senator Alan K. Simpson,* Steven C Sholly and Michael E. Faden). l

22. "PRA: What Can it Really TcIl Us About Public Risk from Nuclear Accidents?,* Union of Concerned Scientists, Washington, D.C., presentation to the 24th Annual Meeting, Seacoast Anti-Pollution 1.eague, May 4,1983.

23.

"Probabilistic Risk Assessment: The Impact of Uncertainties on Radiological Emergency Planning and Preparedness Considerations," Union of Concerned Scientists, Washington, D.C, June 28,1983.

24

" Response to GAO Questions on NRC's Use of PRA,* Union of Concerned Scientists, Washireton, D.C, October 6,1983, attachment to letter dated October 6,1983, from Steven C Sholly to John E. Bagnulo (GAO, WuhinSton, D.C.).

25.

The Imnact of

• External Evente on Radiolodcal Emercencv R esnonse P!stnine Consideration. Union of Concerned Sciemists, Washington D.C, December 22, 1983, attachment to letter dated December 22,1983, from Steven C. Sholly to NRC Commissioner James K. Asselstine.

?

26. Sizewell 'B' Public Inquiry, Proof of Evidence on: Saferv and Wute Man .rement imeticarices of the Sizewc!! PWR. Gordon Thompson, with supporting evidence by Steven Sholly, on behalf of the Town and Country Planrdng Association, February 1984, induding Annex G, *A review of Probabilistic Risk Analysis and its Application to the Sizewell PWR,* Steven Sholly and Gordon Thompson, (August 11,1983), and Annex 0, " Emergency P!anmng in the UK and the US: A Comparison,' Steven Sholly and Gordon Thompson (October 24,1983).

27, Testimony of Steven C. Sholly on Emergency Planning Contention Number E!cven, Union of Concerned Scientists, Washingtoc, D.C, on behalf of the Palmetto Alliance and the Car 911na Environ nental Study Group, before the U.S. Nuclear Regulatcry Commision Atomic SrJhty and Licensing Board, in the. Matter el Duke Pcwcr Compey, et. a!. (Catawba Nvicar Station, Unit: 1 and 2), Dceket Nos. 50413 aad 5G.414. April 16,1984.

• 29.

" Risk Indirstes Rc!synt to Assesslag Nodear Aceldent liability Premitca,* in Etdicijngtg

&GML12.ddAdem:ndent Adv'.sen Commhee to the WE,Jggitar RNr Tg,jq.fprg, Decnnber II,1984, . steven C Shoily, Union of Concerned Scientists, Washington, D.C 29.

- " Union of Coneuned Scientists' and Nuclear Inforraation and Rcrource Service's .*oint Comments on NRG Proposal to Bar from 1.iccasing Proceedings th: ConsideraCon of I'arthqvaic E!Iccts on Emergency Plannleg,' Union of Concerned Sciertists (*nd Nockar Information and Re.ource iervice, Washiry; ten, D.C, Dim Carrr.n rmd E!!p P. Weiss (with input from Steven C Sholly), Febarry 28,1985.

• f

'X. "SrWre, Aa.iderit Source Terms:A P ctr.ratation to 6e Commissioner.s on de Statw4a Rt. view of the NRC's Sontce Term Renssesamt nt Strdy by the Union of Concerned Sciertists," Union of Concerned Scientists, Washing;on, D.C, April 3,1985.

• 5 l

L___--__ _

,q,, -

'.(

31.-

" Severs Accident Source Terms for Light Water Nuclear Power P! acts: A Presentation to the Ibois Department of Nuclear Safety on the Status of a Review of the NRC's Source Term Ramamanment Study (STRS) by the Union of Concerned Scientists," Union of Concerned Scientists, W=ahbaaa D,C., May 13,1985, J

. ' 32. ,

The % ce Term Beh=#- A Review of the Cin e a R==i= for Predactinn *2;az e Aceld-set * =ce

T-. . with 5xdel Emahaa6 on the NRC L-am Term R===anniant Pmm mo (NUREn.

Y 028 Union of Concarned Scientists Cambridge, Massachusetts, Steven C. Shully and Gordon

, Thompson, January 1966.:

33.

< . Direct Testimony of Dale G. Bridenbaugh, Gregory C. Minor, Lynn K. Price, and Steven C.

Sholly on behalf of State of Connecticut Department of Public Utility Control, Prosecutorial Division and Division of Consumer Counsel, regarding the prudence of expenditures on Millstone Unit III, February 18,1986.-

34.

I nplications of the Chernobyl-4 Accident for Nuclear Escrgency Planning for the State ofNew York, prepared for the State of New York Consumer Protection Board, by MHB Technical Associates, June 1986.

b

35. . Review of Vermont Yanfrae Contsiament hfetr Studv and Analysis of Caethane L O fuuan for the Vc =r Yaakar Nncle=r "6 ~ P!nat prepared for New England Coahtion on Nuclear Pountion, Inc., December 16,1986.

~ 36.

> Affidavit of Steven C. ShoDy before the Atemic Safety and f I-- bg Board, in the matter of Public Service Company of New Hampshire, et al., wie Seabrook Station Units 1 and 2 oft site Emergency Planning Issues, Docket Nos. 50-443-OL & 50 444-OL, January 23,1987.

37.

- Direct Testimony of Richard B. Hubbard and Steven C. ShoDy on behalf of California ,Public Utilities Commission, regarding Diablo Canyon Rate Case, PGAE's Failure to Establish hs Committed Design OA Program, Application Nos. 84 06-014 and 85-08-025, Exhibit No.10,935,

. March,1987. .

38.

Testimony of Gregory C. Minor, Steven C. Sholly e,t. at on behalf of Suffolk County, regardig

'2 LILCO's Receptien Centers (Planning Basis), before the Atomic Safety and Licersing Boari in the matter of Long Island Lighting Ccmpany, Shoreham Nuclean Power S;ad.m Unit 1, DschrA 0 ' No.50 322 OL4, April 13,196,7.

39.

. Rotmttal Testimony of Gregery C. blinor and Steven C. 3hony on behalf of Stff#e Cormty rL5erding LILCO's Reception Centers (Addressing Testimany sf Lewis G. Hulme.n), Docket No. 50-32LOL-3, May 2,19ir!.

h 40.

- Revit.w of Selected Ispects of NUREG 1150, " Reactor Risk Referr9cc Document,* prfgared i

for the Ihe,is Department of Nuclear Safoty by MRB Tedaical Associates, Septensber 1987.

41. Direct Te:tiraooy of Richard B. Hubbard and Steven C. Sho0y on b.:hs1f of rJe Pennsybania Office of Constuner Advocate, befort the Penaryivacia ."ublic Utility Coranission, Evaluaria of Beaver Yaky Unit 2 Plant Castr, OCA Statement 6. Docket No. RWO652, October 23,1987.

I 4'l Final Deance. e6.m,. e yaetors Aff-rei== the r*me of Beavec VaHey Powcr Statica Unit i prepared for Fr.r.r.ih i a Office of Consumer Advocate, by MHB Technical Associates, OCA ExhibitO October 1987.

6-

1. j

r; c.. -

1

..f 43.

Surrebuttal Testimony of Richard B. Hubbard and Steven C. Sholly before the Pennsylvania Public Utility Commission, on behalf of the Pennsylvania Office of Consumer Advocate,

. regarding Evaluation of Beaver Valley Unit 2 Plant Costs, OCA statement 61, Dodet No. R-

, 870651, Decembor 7,1987.

44. . Tastimony on Diablo Canyon Rate Case, D=:= O=-"'v Ma=== Supplemental and Robuttal i

Tcathnomy of Richard B. Hubbard and Steven C. Shouy, on behalf of the California Public

. Utilities t'a==i== Division of Ratepayer Advocates, Application Nos.84 06 014 and R$.08 025, Eubibit No.16,690, Scpeceber 19f8.

"/' 45.

Testimony'on Dhblo Canyce Rate Canc, Evolurina of OA Ran=!= =r=:a ' And hQ tr a ..._:- " - a v m W ! = _ u = m on n.v u .. === As A Marf at Tool Volumes I and H Supplemental and Rt.buttal Testimony of Richard B. Hubbard and Steven C. Shouy on behalf of. the California Public UtHitics Commission, Division of Ratepayer Advocate, J-Application Nos. 84-06-014 and 85 08-025, Prhihh No.16,650, September 1988.

' Available from the U.S. Nuc! car Regulatory C== - % PubUc Document Rooin, lobby,1717

. H Street, N.W., WasMagton, D.C.

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SERA Sierro Enerny end Risk Assessment,Inc. i

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j ATTACm0DIT I j TASKS AND SCHEDULE The schedule for all of these tasks is referred to a point of receipt of Authority To P;cceed (ATP) frem the addressee for a compis,te PRA review.

g TASK WEEKS

1. Ccmpleta review of new and existing material. l

a. Complate initial PRA review ATP - +2 Weeks

b. Reviewassociateddocumentsje.g.,

prior PRA Revisione and crit. ques thereof) +4 Weeks

c. Review SARA and ccmpare and centraat to PRA +3 - +6 Weekt

d. Prepars data requests on analyses +2 - t6 Weeks

^

2. Perform detailed review of new PHA

a. Install PRA computer cede on SERA machine el - +4 Weeks

b. Replicate base cave results +5 - +8 weeks

c. Perform sensitivity analyses +6 - +R Weeks

d. Review dr.ta request responses +6 - +10 Weeks ec . Revise PRA assessment as needed +6 - +10 weeks

3. Ivaluate potential design and operational changee:

a, Identify and define list of potential r.edif,1 cations (in ecordination with EEE) +10 Weeks

b. Assess impact of potential changes by rerunning PRA cede system +10 - +16 weeks

4. Valte/Impset analyses

a. cetermine ecs: cf meltdewn +16 Weeks

b. Estimate ecst of possible changes (in close ccordinatien with EKE) +10 '14 Weeks ATTACHMENT C

i ATTAemnruT 1

> (Concluded) t

e. Perform benefit cost analyses to select set of alternatives (in coordination with MKB and attorney) +16 - +18 Weeks

5. Testimony Preparation

a. Prepara draft testimony +17 - +20 Weeks b.. Review testimony with MHB and attorney

+20 - +22 Weeks

c. Finalise and submit testimony +22 +24 weeks e

e

_ _ _ _ _ _ _ _ . _ . _ _ - - - - - - - - - - - - - - - - - - ' ^ ~ ^ - ' - - - ~ ~

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NUREG-1068 l.

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.. Review Insigats on the Probaailistic Risk Assessment for the Limerick Generating Station Manuscript Completed: August 1984 Date Published: August 1984 Division of Safety Technology

. Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 p>* *= am ,

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Table 3 Risk Review of Limerick Risk Index PEC01/p/ Review 2/p/ Comment Early fatalities 3.3E-4 5.0E-3 3/, 4/

(per plant year of operation)

Latent cancer fatalities 2.8E-2 5.0E-2 4/, }/,

(per plant year of operation)

Person rems (per plant 295 700 year of operation) 1/ Estimates are obtained from Limerick SARA

-2/ Estimates are obtained from Limerick FES (Table L.la).

See the FES for the uncertainties associated with these estimates.

3/ Estimates are based on supportive medical treatment.

-4/ Estimate are based on crediting those plant modifications which are dicussed in Section 5.

}/ Estimates include thyroid cancers.

p/ Estimates correspond to " population to 50 miles" case.

uncertainties in the values of various input parameters such as hardware failure data, human error data, frequency of accident initiators (especially loss of offsite power), large and medium LOCAs, fires and seismic events. These sources of uncertainties also exist in the Reactor Safety Study. Some of these sources of uncertainties are still dominant sources because of (1) no data on large LOCAs, (2) relatively sparse data base on severe earthquakes in the eastern United States, and (3) inadequacies in quantifying certain human errors during accident scenarios. There is also large uncertainty attributed to varying degrees of systems success / failure modeling assumptions, complete-ness, statistical and arithmetic errors. The impact on the frequency of core damage from this kind of uncertainty is believed to be within range of uncer-O tainties that have been quantified for Limerick.

Both the applicant and BNL have performed sensitivity analyses and have identified potential sources of uncertainty and treated them using the appli-cable state-of-the-art methodologies. Figure 1 shows a perspective on the range of uncertainty associated with the core damage frequency, as estimated by the applicant and BNL. Note that BNL's estimate of the fifth to the 95th percentile probability range for the frequency of core damage from transients and LOCAs spans almost 2 orders of magnitude (7E-6 to 3E-4 per reactor year) and is greater than the corresponding estimate by PECO.

To provide a perspective on the range of uncertainties on various contributors to the core damage frequency, the staff has provided Table 4 which gives esti-mates of uncertainty and the mean values of the class of accident sequences Limerick RER 2-10

i UNITED STATES OF AMERICA 1 NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board .

.' I c}/ tO D In the Matter of )

' D

Philadelphia Electric Company

)50-35f' $N ggG?sh D[

Docket Nos. 50-35 p'd

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(Limerick Generating Station, ) ;fh ED}4}@$9

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l CERTIFICATE OF SERVICE i i

The undersigned counsel certifies that a true and correct copy of " Opposition of Limerick Ecology Action, Inc. to ' Motion By Licensee Philadelphia Electric Company to Set Schedule for Discovery and Hearing" was served upon the following persons on l l

, August 21, 1989 by first class mail, postage prepaid, except I where by Federal Express as marked with an asterisk, on the following persons:

• Samuel J. Chilk Secretary j U.S. Nuclear Regulatory Commission Washington, D.C. 20555

• Morton B. Margulies, Esq.

Chairman, Atomic Safety and i Licensing Board l

. U.S. Nuclear Regulatory '

Commission Washington, D.C. 20555 l

L i

l l

Frederick J. Shon p Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission

,- Washington, D.C. 20555 Dr. Jerry Harlour Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Ralph Hippert Atomic Safety and Licensing Pennsylvania Emergency Board Panel Management Agency U.S. Nuclear Regulatory B151 -

Transportation Safety Commission Builcing Washington, D.C. 20555 Harrisburg, PA. 17120 4-

• Joseph Rutberg, Esq. Michael B. Hirsch, Esq.

Ann Hodgdon, Esq. Federal Emergency Management Counsel for NRC Staff Agency Office of the General. Counsel 500 C. Street, S.W.

U.S. Nuclear Regulatory Room 840-Commission Washington, D.C. 20472 Washington, D.C. 20555

• Docketing and Service Atomic Safety and Licensing Section Appeal Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington,D.C. 20555 Washington, D.C. 20555 Edward J. Cullen, Esq.

• Mark J.Wetterhahn, Esq.

Philadelphia Electric Co. Robert C. Rader, Esq.

.. 2301 Market Street CONNER AND WETTERHAHN, P.C.

Philadelphia, PA. 19101 1747 Pennsylvania Ave., N.W.

Washington, D.C. 20006 Gregory Dunlap, Esq.

Office of the General Counsel David Stone Commonwealth of Pennsylvania Limerick Ecology Action, Inc.

P.O. Box 11775 P.O. Box 761 Harrisburg, PA. 17108 Pottstown, PA. 19464 Angus Love, Esq. Robert L. Anthony 107 E. Main Street Box 186 Norristown, PA. 19401 Moylan, PA. 19065

y

, . '.. s

• j

,.r, j

l Frank RJ. Romano: -

1 Chairman-Air and Water Pollution-. '!

~ Patrol.

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• m '61 Forest Avenue-

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Ambler, PA.' 19002.' -

)

RobertLJ.J'Sugarman, Esq..

101 N. Broad Street

-16th' Floor-  !

Philadelphia,.PA. 19107 4.

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'POSWISTILO, ELLIOTT & ELLIOTT-

.n Y I Charles W.'Elliott i 1

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1101 Northampton Street 1 Easton, PA.- 18042 x

(215) 258-2374

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