Brief Submitted by Intervenor Colemans in Response to Util Opposition to ASLB Consideration of Class 9 Accident & Certification of Issue.Aslb Is Required to Review Class 9 Accidents.Certification Is Not AppropriateML18079A788 |
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Site: |
Salem |
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Issue date: |
06/22/1979 |
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From: |
Onsdorff K NEW JERSEY, STATE OF |
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To: |
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References |
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NUDOCS 7908130251 |
Download: ML18079A788 (8) |
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Category:BRIEFS
MONTHYEARML18085A8401981-02-17017 February 1981 Brief Supporting ASLB 801027 Decision Authorizing OL Amend to Permit Storage of 1,170 Spent Fuel Elements in Facility Spent Fuel Pool.All Exceptions Should Be Denied.Aslb Has Adequately Weighed Evidence.Certificate of Svc Encl ML18082A1661980-03-24024 March 1980 Supplemental Brief Re Motion for Directed Certification & for Stay.Commission 800321 Memorandum & Order Re Black Fox Leaves No Doubt That Aslab Proposed Consideration of Question 5 Is Contrary to Directive of Commission ML18081B2181980-03-0303 March 1980 Motion in Form of Brief for Directed Certification of Class 9 Question & for Stay of Proceeding.Aslab Intercession Is Warranted Per Stds Set in Marble Hill & Skagit Proceedings. Urges Consideration of All Aspects.Certificate of Svc Encl ML19225B2451979-06-26026 June 1979 Brief by Intervenor Colemans in Support of Request That ASLB Compel Util to Suppl Answers to Interrogatories 1,3 & 6.ASLB Has Responsibility to Determine Significance of Facts Re Issues in Controversy ML19241B8311979-06-25025 June 1979 Brief in Support of Motion for Reconsideration of Contention 7 Submitted by Intervenors Colemans.Aslb Order Would Comply W/Mandate in Mn Vs NRC Re Storage of Radwaste Beyond Term of Ol.Certificate of Svc Encl ML18079A7881979-06-22022 June 1979 Brief Submitted by Intervenor Colemans in Response to Util Opposition to ASLB Consideration of Class 9 Accident & Certification of Issue.Aslb Is Required to Review Class 9 Accidents.Certification Is Not Appropriate ML19225A2271979-06-14014 June 1979 Request for Denial of NRC 790601 Objection to ASLB Consideration of Class 9 Accidents Submitted by Intervenors States of Nj & DE & Colemans.Class 9 Accidents Are Legitimate Safety Concern,Germane to Admitted Contentions 1981-02-17
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARLR-N980595, Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr1998-12-21021 December 1998 Comment Supporting Proposed Rules 10CFR50,52 & 72 Re Changes,Tests & Experiments.Pse&G Supports Comments Submitted by NEI in Their Ltr LR-N980588, Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation1998-12-14014 December 1998 Comment on Proposed Rule 10CFR50.65 Re Monitoring Effectiveness of Maint at Npps.Util Agrees with General Principle Behind Proposed Rulemaking,But However,Concerned That Proposed Rule Contain Language Open to Interpretation ML18106A8811998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide as Protective Action During Severe Reactor Accidents. Believes That Discussion Contained in SECY-98-061 Should Be Included in Draft NUREG ML18106A8731998-09-15015 September 1998 Comment on Draft NUREG-1633 Re Assessment of Use of Potassium Iodide (Ki) as Protetive Action During Severe Reactor Accidents. Believes That NUREG Should Provide Balanced Discussion on Benefits & Risks of Use of Ki LR-N980284, Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-19911998-06-12012 June 1998 Comment on PR-50 Re IEEE Std 603-1991 for Salem & Hope Creek Generating Stations.Lack of Adverse Comments to Draft RG Should Not Have Been Construed as Endorsement to IEEE 603-1991 LR-N980149, Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis1998-03-30030 March 1998 Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis ML18102B4361997-07-0707 July 1997 Comment Opposing NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Util Endorses Comments Submitted by Nuclear Energy Inst ML20132A8961996-12-0606 December 1996 Comment Supporting Pr 10CFR50, NRC Draft Ps on Restructuring & Economic Deregulation of Electric Utility Industry ML20084H9251995-06-0202 June 1995 Comment Opposing Proposed Change in State Cooperative Agreements Program Concerning NRC Intention to Reduce Scope of Work.Believes That NRC Should Maintain Environ Monitoring Program & Find Other Ways to Reduce Duplicative Svcs ML20134K5021995-02-24024 February 1995 Transcript of 950224 Enforcement Conference in King of Prussia,Pa Re C Vondra.Pp 1-136 ML20134K4971995-02-0808 February 1995 Transcript of 950208 Enforcement Conference in King of Prussia,Pa Re L Reiter.Pp 1-64 ML20134K4791995-02-0808 February 1995 Transcript of 950208 Enforcement Conference in King of Prussia,Pa Re V Polizzi.Pp 1-115 ML20134K4511995-02-0808 February 1995 Transcript of 950208 Enforcement Conference in King of Prussia,Pa Re Plant.Pp 1-93 ML20080G8321995-02-0606 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Npp.Encourages NRC to Reevaluate Regulatory Analyses in Light of Higher Costs.Concludes That Addl Rules on Shutdown & Low Power Operations Not Necessary ML20077L8631995-01-0303 January 1995 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re NPP License Renewal.Util of Belief That Proposed Rev Reflect Positive Effort Towards Establishing Regulatory Process Requirements for Continued Operation of Nuclear Facilities ML20132B2281994-08-0202 August 1994 Transcript of 940802 Enforcement Conference in Salem,Nj W/Salem Senior Nuclear Shift Supervisor Involved in 940407 Event ML20067C1591994-02-17017 February 1994 Comments on NUREG/CR-5884 Re Analyses of Decommissioning for Ref PWR Power Station ML18100A5591993-08-26026 August 1993 Comment Opposing Proposed Rule Re Whistleblower Protection ML20126F2721992-12-21021 December 1992 Comment Endorsing Positions & Comments of NUMARC & BWROG Re Draft GL, Augmented Inservice Insp Requirments for Mark I & Mark II Steel Containments,Refueling Cavities & Associated Drainage Sys ML20091Q8661992-01-31031 January 1992 Comment Opposing Draft NUREG-1022,Rev 1, Event Reporting Sys,10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting ML20072T2421991-04-11011 April 1991 Comment Re Proposed Change to 10CFR50.55A Re Inservice Testing of Containment Isolation Valves.Proposed Rule Should Be Revised to Allow Plants within Last 12 Months of Current Interval to Substitute Deferred Rv Shell Exams ML20235T1861989-02-24024 February 1989 Comment Supporting Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants, Extension of NRC Authority to BOP Portion of Plant & Misapplication of Adequate Protection Std of Backfit Rule ML20195H0331988-11-21021 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program Which Includes Random Drug Testing.Util Strongly Favors 180- Day Period for Implementation of Rule & 360-day Implementation Period for Random Drug Testing ML20153F9681988-08-17017 August 1988 Comment Opposing Proposed Rule 10CFR50 Re Licensee Flexibility During Natl Crisis.Deferral of Issuance of Final Rule Until Proper Implementation Guidance Formulated Encouraged ML20154G1421988-04-20020 April 1988 Comment Opposing Proposed Rules 10CFR50 & 73 Re Policy Statement on Nuclear Power Plant Access Authorization Program.Nrc Should Establish Program Mutually Agreed Upon Between Union & Util,Per Hope Creek & Salem Programs ML20154G4601988-04-18018 April 1988 Comment Opposing Proposed Rule 10CFR50 Re Notification of Inspector Visits to Facility ML18093A6331988-02-0101 February 1988 Comment Supporting Proposed Rule 10CFR50 Re Proposed Policy Statement on Integrated Schedules for Implementation of Plant Mods ML20151B3641987-02-24024 February 1987 Comment Opposing Proposed Rule 10CFR50 Re Licensing of Nuclear Power Plants Where State &/Or Local Govts Decline to Cooperate in Offsite Emergency Planning ML20079N4271984-01-25025 January 1984 Response to State of DE 840120 Motion to Withdraw Petition for Leave to Intervene.Licensee Concurs in Motion.Dismissal of Proceeding Requested.Certificate of Svc Encl ML20079K9311984-01-20020 January 1984 Motion to Withdraw Petition for Leave to Intervene & Request for Hearing Re Extension of Time for Type a Test.Certificate of Svc Encl ML20078P6771983-11-0404 November 1983 Answer to State of DE Atty General 831021 Petition for Leave to Intervene & Request for Hearing on License Amend Re Inservice Integrated Leak Tests.Notices of Appearance & Certificate of Svc Encl ML20078M1551983-10-21021 October 1983 Petition for Leave to Intervene & Request for Hearing on Proposed Issuance of Amend to License DPR-70 Re Inservice Integrated Leak Tests.Affidavit of Mailing Encl ML18087A8331983-04-12012 April 1983 Petition for Order to Show Cause Why Util Should Not Be Restrained from Restarting Facility Until Qualifications for Operation Demonstrated at Public Hearing ML18087A8341983-04-11011 April 1983 Affidavit of DG Bridenbaugh Re Delay of Facility Restart. Full Review of safety-related Equipment Must Be Completed & Appropriate Changes Implemented.Prof Qualifications Encl ML20213E3601983-03-0808 March 1983 Testimony Before Subcommittee on Energy & Environ Re Plant Licensing Concerns ML18086A9691981-10-14014 October 1981 Affidavit Confirming Validity of Util 811009 Response to IE Insp Repts 50-272/81-15 & 50-311/81-14 ML20005B6831981-08-20020 August 1981 Petition for Review of Aslab 810717 Order,Permitting OL Amend,Allowing Installation of New Storage Racks & Increasing Pool Capacity.Notice of Appearance & Affidavit of Svc Encl.Related Correspondence ML20010C1481981-08-14014 August 1981 Response in Opposition to Lower Alloways Creek Township 810803 Petition for Review of ALAB-650.Petitioner Has Raised No Issue Which Warrants Commission Consideration.Certificate of Svc Encl ML20009H2221981-08-0303 August 1981 Petition Supporting Review of Aslab Decision.Case Involves Matter That Could Significantly Affect Environ,Public Health & Safety & Involves,Important Procedural Issues & Public Policy Questions.Certificate of Svc Encl ML18086A5181981-05-15015 May 1981 Answer Opposing AC Coleman 810504 Request for Stay of Initial decision,LBP-80-27,pending Appeal.Request Untimely & Fails to Meet Requirements for Issuance of Stay. Certificate of Svc Encl ML18085A8401981-02-17017 February 1981 Brief Supporting ASLB 801027 Decision Authorizing OL Amend to Permit Storage of 1,170 Spent Fuel Elements in Facility Spent Fuel Pool.All Exceptions Should Be Denied.Aslb Has Adequately Weighed Evidence.Certificate of Svc Encl ML18085A5231981-01-13013 January 1981 Findings of Fact & Conclusions of Law in Support of 801111 Exceptions to ASLB 801027 Initial Decision Re Applicant Proposed Expansion of Fuel Storage.Certificate of Svc Encl ML18085A4091980-12-0808 December 1980 Response to Intervenors Eg & a Coleman Motion for Extension Until 810131 to File Brief in Support of Exceptions.Opposes Motion But Would Not Object to 2-wk Extension.Certificate of Svc Encl ML18085A4081980-12-0404 December 1980 Appeal from ASLB Initial Decision Granting Util Right to Increase Spent Fuel Pool Storage Capacity.Nepa Requires Detailed Analysis of Safety & Health Problems Posed by Reracking.Certificate of Svc Encl ML19340D3431980-11-30030 November 1980 Request for Extension to 810131 to File Brief in Support of Exceptions to ASLB 801027 Initial Decision Re Spent Fuel Pool Proceeding.Certification of Svc Encl ML18085A2791980-11-20020 November 1980 Notice of Withdrawal of Appearance as Counsel for Intervenors Coleman.Intervenors Coleman to Remain Parties to Proceeding.Certificate of Svc Encl ML18085A2501980-11-11011 November 1980 Appeal from ASLB 801027 Initial Decision.Alleges Erroneous Finding of Facts Re Contentions 2 & 6,evaluation of Eia, Acceptance of Pasedag Testimony & Rejection of Benjamin Testimony.Counsel Withdrawal & Certificate of Svc Encl ML18085A2161980-11-0404 November 1980 Exceptions & Appeal from ASLB 801027 Initial Decision. Exclusion of as Benjamin of Sandia Labs Testimony Is Arbitrary Due to Relevant Evidence Re Oxidation That Could Propagate to Older Fuel.Certificate of Svc Encl ML20062J4921980-10-21021 October 1980 Addl Testimony Presented Before ASLB to Correct & Clarify 800710 Testimony Re Loss of Water from Spent Fuel Storage Pool ML18082A7101980-07-11011 July 1980 Reply Findings of Fact & Conclusions of Law in Form of Partial Initial Decision Substituting for Licensee 800613 Findings,In Response to ASLB 800509 Order & ASLB 800626 Question 5 on away-from-reactor Issues.W/Certificate of Svc 1998-09-15
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UNITED STATES OF AMERICA NUCLEAR REG'"uLATORY COMMISSION Before the Atomic Safety and LicensL~g 3oard t/n/H In the Matter of. Docket No. 50-272 PUBLIC SERVICE FI.ECTRIC Proposed Issuance of Amend..'tlent
& GAS CO. to Facility Operating License (Salem Nuclear Generating No. DPR-70 Station, Unit #1)
IN~....RVE...~ORS I COU:.".A.i.~ I RESPONSE TO THE MOTIONS BY LI~SEE IN OPPOSITION TO BOARD CONSIDERATION OF CL.:\SS NINE ACCIDENTS AND TO CERTIFY QUESTION STA!'r.l.ZY C. VAN NESS PUBLIC ADVOCATE OF NEW ~y DEP~1E:IT CF T.!"...::. PUBLIC, ADvoc.:; ~
DIVISION OF ?UEL:= INTEREST ADVCC.:;:-:
POST OF:ICE BOX l~l 520 EAST ST.!\.TE STRE..:.T TREITCN I ~"EW ~~EY KEITE A. ONSDO~?
ASSIST~iT iJEPt.."'TY' PUBLIC ADVOC.?\.TE On the Brief 79os1 so:;;i.s- ,.
.. e PRELIMINARY STATEMENT The gravamen of Public Service Electric and Gas Company's motion to delete Board consideration of the effects of a core meltdown on the 5alem. One spent fuel pool is stated succinctly on page two of the brief in support of its appli-cation:
"[IJt is contrary to Commission regulation, policy, and established practice to include consideration of accidents more severe than the design basis accidents in any safetv or environmental analvsis."* (E:nphasis added)
This proposition while not correct, is in any event, wholl:;-* irrelevant to the Board's Order of April 18, 1979. Every single case relied '.-"pon by PSE&G Co -
to support its contention that an applicant for a license before the ~uclea=
Regulatory Commission need not include an evaluation of Class Nine *-"ccident consequences in its "safety or environmental analysis" concerned the legal obligations imP?s~. on the Commission and/or applicant eit.~er by the National Environmental Policy Act,("NEPA") 42 o.s.c. ! 4321 et sea. or the A~omic Enerqy Act, ("AEA") 42 U.S.C. ! 2018 et sea. in prepaz-ing the exhaustive technical stuc.ies which comprise t.~e documentary sufport for a license application. Ac~ordi..~gly, this entire legal argument is inapposite to Board question ~3, inasmuch as th.e April 1979 Order did not direct either t.~e licensee or staff to redo t.he environ-men~l repor= or environmental impact appraisal previously comple~ed i~ suppc:::-::
of this application.
As far as Commission regulation prohibiting consideration of Class Nine ac=ide~~s this statement simply is erroneo~s. The only "regulation" cited by licensee is "the proposed Annex to 10 C.F.R. Part 50, Appendix D." This orooosed annex has never been finally adbpted as a NRC regulation. Moreover, by its own te.::::ns, *A~pe~di D makes the evaluation of Class Nine accidents per:nissive, not mandatory: "it is not necessary to discuss such events in the applicant's Environmental Repor"':..s."
The clear imper~ of this per:nissive language is that the Eoard is authorized bu~
not required to examine t.~e core meltdown issue.
- 1
Rather, the Board's Order merely requested some unspecified preparation for a "discussion at the hearing" on the consequences of a core meltdown on the Salem One spent fuel pool. It is clear, then, that the Board's Order of April 18, 1979 must be viewed in the same light as its Order of April 17, 1979 in which counsel for the NRC staff was requested to address certai..~ questions --
computer code errors, effects of low level radiation, method of making K-t:==*
calculations ~ and the other parties were permitted to likewise address t~ese were issues. And since both orders/entered pursuant to the Atomic Safety and Li=e1'si=g Board's express authority under 10CFR ! 2.721 and 10 CFR 2.718 to manage t.~e conduct of hearings and conduct its own examination of witnesses, the star.da=ds for compliance by staff and applicant with NEPA and substantive requ.iremen~s of the AEA are nei t.."ler relevant nor controlling. Patently, the mere opportunity afforded the parties herein to comment upon and discuss the poteatial impacts of a core meltdown on the .Salem One spent fuel pool can not be equated wi-=..'1. a req-~e-ment to prepare a full-blown environmental impact stateme..~t or a new Final sa=ety Evaluation Report on this amendment application.
In summary, then, licensee having const-">"Ucted this EIS "straw :nan" ars:-u..:nent seeKs to dismantle it by citation to cases which hold that if the NRC decides not to evaluate Class Ni..~e accidents, its failure to do so does not constitute rever-sible error. Clearly, however, this proposition does not even spea.< to t~e situation where an ASLB, chooses to examine such an ever.t. It is one -:.!:.i..-ig .tc establish that the common law indicates that t..~e Board in its disc=eticn ~eec ~ct examine ells issue. It is quite another matter to conclude from tha~ proposi~on that an AS:i:..B is prohibited from doing so. L~ fact, it can be persuasi *.rely ar-;ued that case law supporting the exercise of the Commission's discretion to forego such consideration also supports the Conmission's aut..,ority to exercise its discretion to do. Most si:nply put,discretion by defi.-iition means the power to
____ /
choose either course of action. And once having directed a Class Nine review be undertaken, it is not persuasive to argue that this review is inappropriate since the Board had the option not to have done so.
ARGUMENT CERTIFICATION OF BOARD QUESTION NO. THREE TO THE FULL COMMISSION IS NOT APPROPRIATE BECAUSE NO UNUSUAL DELAY, EXPENSE OR OTHER DETIU..'111E:m' TO THE PUBLIC INTEREST HAS BEEN SHOWN BY THE LI~NSEE Pursuant to 10 CFR S 2.730(f), certification of an interlocutory Board rul. i.ng to the Commission may only be taken "to prevent detriment to the pub.lie interest or unusual. delay or expense." This extraordinary procedure is not appropriate he.rein since Public Service has made no showing by sworn affidavit, or other"1ise, of how a discussion of Board Question No. T!lree at t.."'ie next hear-ing in the wi t.11.in proceeding will :result in "unusual delay" which would be d~':ri.mental to the public L~terest. The bald assertions of cour.Eel in licensee's br.:.*.:f t."lat "consideration of Class 9 events ..,ould cause substantial delay in deciding the narrow issues arising from Applicants' proposed amenement" (PSbr.-28) is :~ere speculation which does even address how t.~is prudent and conser..rative course of action is viewed by PSE&G as being detrimental. to the public intere~. As ""as so aptly pointed out by the Appeals Board in Public Service Comoanv of !-iew Hamoshire (Seabrook Station, Units land 2), ALAB-2il, l.NRC 478 (1975), when evidentia..ry hearings are al=eady scheduled before a licensihg boa=d (i.~tervenor Lowe= Alloways Creek has already filed extensi*1e discussions of tb.e Class li..."'le qu=~~on by t"<<o sepaxa~e wi~esses: Dr. Richard Webb and Dr. ::::arl Gu.lb=ansen wh.ose testimony can be received begL-ming at the July 10, 1979 hea=ings) ,
"cer..i.f:ication would t."ierefore, if any-...hi:i.g, cause rather than preve.."lt delay."
l NRC at 486.
In addition to the aforementioned standa=d for certification, licens~
cites t.~e =ase of Pub~i= Se:::vice Comoa.~v of India~a (!<!ar~le Hill Nuclear Generati~g Station, Onits l and 2), ALAB-405, 5 NRC 1190,1192 (1977) in support of its application for ter.ni...~ation of the ongoing licensing board hearings a:id aut..~ori.zatic~
e .. ------ - .
for an immedia~e appeal. This reliance on PS of Indiana is misplaced. In some unspecified fashion,it is claimed that consideration of Board Question No. Three will affect "the basic structure of the proceeding i.."'l. a pervasive or unusual.
manner" (PSbr.-28}. This unfounded assertion appears to relate agai~ to the specious arguI:ient that licensee has raised pertaining to the non-requirement for preparation of a full environmental impact statement on Class NL""le events. Si.:.c::i a Board order entailing mont.."is of technical studies and expert reports might be deemed to constitute an action which could legitnately be characterized as affecting the proceedings in a pervasive or unusual manner. In contrast, however, this Board's order, issued only three wee.ks prior to the scheduled start of the
~earings, obviously contemplated some very limited preparation and discussion that would contribute to but not alter the basic focus of the instant proceeding.
Finally, it should be noted t.."iat the licensee has shown no prejudice which will result from the Board's inquiry into the question a Class Nin~ accident at the Salem One plant. The absence of such prejudice is part.ic.Uarly signi.::icant when weighed agai..."'l.st the substantial public benefits which wil.l accrue review and from this comprehensive/-full disclosure of all the potential consequences of stor:L.""lg massive amounts of radioactive wastes 80 feet from an active core.
_c;_
'I
- CONCLUSION For all the foregoing reasons, the Board should consider a Class Nine accident at the Salem plant and should not certify this issue to the full Cormnission for interlocutory review.
k~~~;ou~.
KEITH A. ONSDORFF ~M ASSISTANT DEPUTY PUBLIC 'ADVOjj/
KAO/lme UNITED STAT.ES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safetv and Licensing In the Matter of Docket No. 50-272 PUBLIC SE..ttVICE ELECTRIC Proposed Issuance of AmendI:le~t
& GAS CO. to Facility Ope=ati.ng License (Sal~~ Nuclear Generating No. DPR-70 Station, Unit #1)
CERTITICATE OF SERVICE I hereby certify that copies of Intervenors, Coleman, Response to the Motions by Licensee in Opposition to Board Consideration of Class NL~e Accidents and to Certify Question, in the above captioned matter have been served upon t.~e pa~..ies to this proceedings by deposit in the United States ma'"
at the post office in Trenton, N.J., with proper postage thereon, this 22nd day of June, 1979.
lf ~-. "]£,/
....i-/ n0 11 t- c..o~v::~"'"L LJ.~-
KEITH .'\. ONSOORFF 1J ,
ASSIST.ANT DEPUTY PUBLIC ..;..,~ci::A'!'E KAO/l.rn.e
~at=d: June 22, 1979