Nrdc'S Response to Applicant'S & Nrc'S Objections to Contentions.Urges That NRC Did Not Validly Challenge Its Contentions & That Its Contentions Should Be Admitted. Certificate of Svc EnclML19282A757 |
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Dresden, Quad Cities ![Constellation icon.png](/w/images/b/be/Constellation_icon.png) |
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01/26/1979 |
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Roisman A National Resources Defense Council |
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NUDOCS 7903060287 |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20207E0051999-03-0202 March 1999 Transcript of 990302 Public Meeting with Commonwealth Edison in Rockville,Md.Pp 1-104.Supporting Documentation Encl ML20236H9381998-06-30030 June 1998 Transcript of 980630 Meeting W/Commonwealth Edison in Rockville,Md.Pp 1-123.Supporting Documentation Encl ML20198P3001997-11-0404 November 1997 Transcript of 971104 Public Meeting W/Ceco in Rockville,Md Re Measures Established by Ceco to Track Plant Performance & to Gain Understanding of CAs Put Into Place to Improve Safety.Pp 1-105.W/Certificate & Viewgraphs ML20141K3801997-05-27027 May 1997 Order Prohibiting Involvement in NRC-licensed Activities (Effective Immediately) for Dr Baudino for Period of Five Years ML20080A6081994-10-24024 October 1994 Refers to Pierce Actions Re Util Failure to Provide Adequate Training or Guidance Concerning Applicability of Doa 300-12 While Expert Present Directing Control Rod Movements ML20070B0081994-06-20020 June 1994 Response to Order Prohibiting Involvement in NRC-licensed Activities.* Informs That Order Will Have Negative Impact on Health & Safety of Public ML20059C2351993-12-17017 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication ML20096A0641992-04-28028 April 1992 Comment Supporting NRC Elimination of Requirements Important to Safety from 57FR4166,dtd 920205 ML20059A9401990-08-0808 August 1990 Settlement Agreement.* Agreement Between Nrc,Rl Dickherber & Util ML20056B2031990-08-0101 August 1990 Memorandum & Order (Approving Settlement Agreement & Terminating Proceedings).* Settlement Agreement Between Rl Dickherber & NRC Approved & Proceedings Terminated Per 10CFR2.203.W/Certificate of Svc.Served on 900803 ML20056A4011990-07-30030 July 1990 Joint Motion of NRC Staff & Rl Dickherber for Approval of Settlement Agreement.* Requests That ASLB Approve Settlement Agreement & Upon Receipt of Signed Original Thereof,Enter Order & Terminate Proceeding.W/Certificate of Svc ML20055F5861990-07-0202 July 1990 Memorandum & Order (Further Deferral of Filing Dates).* Joint Motion of Rl Dickherber & NRC Filed on 900628 to Defer Filing Date for Responses to Answer of Rl Dickherber Until 900730 Granted.W/Certificate of Svc.Served on 900703 ML20055C2871990-02-23023 February 1990 Order Suspending License,Effective Immediately & Order to Show Cause Why License Should Not Be Revoked ML20246A0091989-05-0303 May 1989 Order Imposing Civil Monetary Penalty in Amount of $75,000, Based on Util Lack of Demonstration That AMP Splices Environmentally Qualified ML20245J0191989-04-14014 April 1989 Comment Re Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20235T9661989-03-0101 March 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Alternatives Provide No Enhancement of Reactor Safety & Will Reduce Experience Level of Senior Operators ML20235T8701989-02-28028 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Rule Will Cause Career Stagnation & Animosity Among Operators ML20235T8251989-02-28028 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Proposed Rules Provide No Enhancement of Reactor Safety ML20235T1551989-02-27027 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Education & Experience Requirements for Senior Reactor Operators & Supervisors.Alternative Provides No Enhancement of Reactor Safety & Will Reduce Experience Level of Senior Operators ML20235T1231989-02-27027 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Alternatives Provide No Enhancement of Reactor Safety & Reduce Experience Level of Senior Operators ML20235S9791989-02-27027 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Both Alternatives Would Eventually Reduce to Nothing Reactor Operators Advancing to Senior Operator ML20235S8371989-02-27027 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20235S8241989-02-27027 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Proposed Rule Alternatives Would Reduce to Nothing Reactor Operators Advancing to Senior Operator ML20235T8381989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20235T7951989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Both Alternatives Do Not Provide Enhancement of Reactor Safety ML20235T7041989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20235T1361989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Alternative Provides No Enhancement of Reactor Safety & Will Reduce Experience Level of Senior Operators ML20235T0911989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Alternatives Provide No Enhancement of Reactor Safety & Reduce Experience Level of Senior Operators ML20235T0461989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Both Alternatives Would Reduce Number of Reactor Operators Advancing to Senior Operator to Nothing ML20235S9541989-02-22022 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Alternatives Provide No Enhancement of Reactor Safety & Reduce Experience Level of Senior Operators ML20205T0891988-10-28028 October 1988 Comment Opposing Proposed Rule 10CFR26 Re Fitness for Duty Program.Proposed Rule Unnecessary as Utils Have Effective Fitness for Duty Program ML20205N0941988-10-24024 October 1988 Comments on Petition for Rulemaking PRM-50-50 Re Authorization of Reactor Licensees to Depart from License Conditions & Tech Specs in Emergency Situations.Young Criticism of Inerting Practices at Plant W/O Credence ML20155A6591988-09-0303 September 1988 Comment Supporting Petition to Rescind Paragraphs (X)(Y) of Section 10CFR50.54 Re Cases of Hazardous Practices Including Util Authorizing Senior Operator to Turn Off Safety Sys in Emergency Before Sys Has Finished Job ML20247N7531988-07-28028 July 1988 Petition for Rulemaking PRM-50-53 Requesting NRC Action to Review Undue Risk Posed by BWR Thermal Hydraulic Instability.Nrr Should Issue Order Requiring All GE BWRs to Be Placed in Cold Shutdown for Stated Reasons ML20207T2351987-02-16016 February 1987 Endorsement 16 to Maelu Policy MF-114 ML20207T2281987-01-28028 January 1987 Endorsement 21 to Nelia Policy NF-277 ML20213D3501986-08-11011 August 1986 Endorsement 95 to Nelia Policy NF-187 ML20213D3491986-08-11011 August 1986 Endorsement 94 to Nelia Policy NF-187 ML20213D3461986-08-11011 August 1986 Endorsement 78 to Maelu Policy MF-54 ML20213D3421986-08-11011 August 1986 Endorsement 79 to Maelu Policy MF-54 ML20213D3791986-08-0808 August 1986 Endorsement 178 to Nelia Policy NF-43 ML20213D3761986-08-0808 August 1986 Endorsement 84 to Nelia Policy NF-201 ML20213D3691986-08-0808 August 1986 Endorsement 72 to Maelu Policy MF-64 ML20213D3681986-08-0808 August 1986 Endorsement 73 to Maelu Policy MF-64 ML20213D3591986-08-0808 August 1986 Endorsement 154 to Maelu Policy MF-22 ML20213D3521986-08-0808 August 1986 Endorsement 153 to Maelu Policy MF-22 ML20213D3511986-08-0808 August 1986 Endorsement 179 to Nelia Policy NF-43 ML20133P8521985-08-0909 August 1985 Order Imposing Civil Monetary Penalty in Amount of $50,000 Based on Violation Re Operators Not Remaining at Controls During Operation of Facility ML20063M3061982-09-0101 September 1982 Response Opposing Reopening of Record Re Comm Ed Use of 9-ton Auxiliary Hook of Main Overhead Crane Sys During 1981 Installation of High Density Spent Fuel Racks.Incident Not Relevant to Proceeding.Svc List Encl.Related Correspondence ML20063A2551982-08-18018 August 1982 Response to ASLB 820728 Order.Requests Leave to Withdraw Application W/O Prejudice.Need for Transshipment in near- Term Reduced Due to Approval of Installation of High Density Spent Fuel Racks.Certificate of Svc Encl 1999-03-02
[Table view] Category:PLEADINGS
MONTHYEARML20056A4011990-07-30030 July 1990 Joint Motion of NRC Staff & Rl Dickherber for Approval of Settlement Agreement.* Requests That ASLB Approve Settlement Agreement & Upon Receipt of Signed Original Thereof,Enter Order & Terminate Proceeding.W/Certificate of Svc ML20063M3061982-09-0101 September 1982 Response Opposing Reopening of Record Re Comm Ed Use of 9-ton Auxiliary Hook of Main Overhead Crane Sys During 1981 Installation of High Density Spent Fuel Racks.Incident Not Relevant to Proceeding.Svc List Encl.Related Correspondence ML20063A2551982-08-18018 August 1982 Response to ASLB 820728 Order.Requests Leave to Withdraw Application W/O Prejudice.Need for Transshipment in near- Term Reduced Due to Approval of Installation of High Density Spent Fuel Racks.Certificate of Svc Encl ML20054K6511982-07-0101 July 1982 Response Supporting Applicant 820616 Motion for Reconsideration or Clarification of Notice of Hearing.Aslb Should Render Final Decision on Basis of Supplemental SER & ASLB Former Findings.Certificate of Svc Encl ML20054G0051982-06-16016 June 1982 Motion for Reconsideration or Clarification of Hearing Scheduled for 820713 by ASLB 820609 Notice of Hearing. Further Evidentiary Sessions Unnecessary & Improper.Final Decision Proper.Certificate of Svc Encl ML20041E2101982-03-0505 March 1982 Motion to Enter Stipulated Protective Order to Govern Util Production of Proprietary & Confidential Info. Certificate of Svc Encl ML20040G3571982-02-0101 February 1982 Request for Extension of Time to Answer Contention 1. Transcript of Special Prehearing Conference Needed to Complete Evaluation.Contention 2 Being Withdrawn.Related Correspondence ML20010C2861981-08-13013 August 1981 Motion for Partial Initial Decision Approving Installation of Five Spent Fuel Storage Racks.Facility Must Begin to Shift Fuel to Prepare for Next Refueling Outage No Later than 810901 Unless Racks Are Approved.W/Certificate of Svc ML20010B2991981-08-0606 August 1981 Response in Opposition to Applicant Motion for Partial Initial Decision Re Issue of Sliding & Tilting of Proposed Spent Fuel Racks During Seismic Events.Certificate of Svc Encl ML19346A3791981-06-12012 June 1981 Answer Opposing Quad-City Alliance for Safe Energy & Survival,Citizens for Safe Energy & Older Americans for Elderly Rights Petitions to Intervene.Contentions Irrelevant.W/Notices of Appearance & Certificate of Svc ML19246C0671979-05-22022 May 1979 NRDC Response in Opposition to Comm Ed Motion for Reconsideration Or,In Alternative,For Clarification or Referral Re Adequacy of Safeguards for Spent Fuel Shipments. Motion Is Unwarranted & Inconsistent w/10CFR73 ML19246C0701979-05-18018 May 1979 NRDC Staff Scientist Statement Re Safeguards for Spent Fuel Shipments.Proposed Rule to Protect Spent Fuel Shipments Against Sabotage,Presented in 790429 Memo to Commission,Is Most Likely Adequate.Certificate of Svc Encl ML19241A9891979-05-17017 May 1979 State of Il Opposition to NRC 790504 & Comm Ed 790507 Motions for Reconsideration &/Or Clarification & Referral of ASLB 790419 Memo & Order Admitting Contentions 6 & 11 ML19241A9781979-05-10010 May 1979 NRDC Opposition to NRC Motion for Reconsideration of ASLB 790419 Memo & Order Following Special Prehearing Conference.Certificate of Svc Encl ML19269D9271979-05-0707 May 1979 Applicant Motion for Reconsideration of 790419 Memo & Order of Clarification of 780419 Order Re Physical Security of Snm.Supporting Documentation & Certificate of Svc Encl ML19282A7571979-01-26026 January 1979 Nrdc'S Response to Applicant'S & Nrc'S Objections to Contentions.Urges That NRC Did Not Validly Challenge Its Contentions & That Its Contentions Should Be Admitted. Certificate of Svc Encl ML19274D6911979-01-26026 January 1979 Memorandum Re State of Il Contentions.Withdraws Contentions 10-12,14,15 & 17 & Submits Revised Contentions 3,10,& 11. Related Correspondence,Stipulation of Contentions,State Law & Certificate of Svc Encl ML19289C9321979-01-12012 January 1979 Applicant'S Answer & Motion to Strike Re Contentions Filed by Petitioners to Intervene Nrdc,Citizens for a Better Environ & State of Il.Contentions Fail to State Claim for Which Relief May Be Granted.W/Certificate of Svc ML19263B5221979-01-0202 January 1979 State of Il Contentions Re Amends to Operating License for Transport of Spent Fuel Between Units.Contentions Assert Applicant'S Submittals Are Insufficient.W/Affidavit & Certificate of Svc ML19269C3001978-12-28028 December 1978 NRDC & Citizens for a Better Environ Statement of Contentions.Asserts Action Would Violate Nepa,Provide No Adequate Analysis of Alternatives & Increase Exposure of Workers to Radiation.W/Certificate of Svc ML19259A9271978-12-19019 December 1978 Reply by NRDC & Citizens for Better Environ to Suppl Brief of Commonwealth Edison Co.Asserts That Util Errs in Claiming That Only Direct Personal case-by-case Authorization of Litigation Can Confer Standing.Certificate of Svc Encl ML19263B5291978-12-0606 December 1978 NRDC & Citizens for a Better Environ Contentions Re Util'S License Amend Re Transport of Spent Fuel Between Units. Asserts Proposed Action Violates NEPA ML20064E5051978-10-30030 October 1978 Request by Comm Ed for Leave to File a Response to NRDC Brief Which Argues That Organizations May Show Standing to Participate in NRC Proceedings Merely by Alleging That They Represent Anonymous Members.Cert of Svc Encl ML20064E2511978-10-23023 October 1978 Natural Resources Defense Council Response to Commonwealth Edison'S & Staff'S Answers to Petition for Leave to Intervene.Intervenor Urges Bd to Establish a Schedule for Briefing Challenges to Contentions ML20062B4171978-10-10010 October 1978 Request for Leave to File Response to Applicant Contention Re Constitutionality of Forced Disclosure of Group Members Names in Order to Operate within State ML20064B9371978-09-18018 September 1978 Applicant'S Answer to Petition for Leave to Intervene Re Proceeding Filed 780908 by Attorney Gen of St of Il.Includes Notices of Appearance for M.I.Miller,J.R.Rowe,& P.P.Steptoe. Includes Designation of Person Upon Whom Svc Shall Be Made ML20058K5131973-12-13013 December 1973 Requests for Decision Re Immediate Derating of Nine BWRs & Implementation of Procedures to Be Followed for Consideration of Any Subsequent Action Concerning Safety Issue Raised About Plants 1990-07-30
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Docket Nos. 50-237 (Amendments to Operating Licenses) f0]2j 50-265 NATURAL RESOURCES DEFENSE COUNCIL RESPONSE TO APPLICANT AND STAFF OBJECTIONS TO CONTENTIONS Introduction At this stage in the proceeding the Board is in a position to rule on the admissibility of a contention based upon the adequacy of the statement or basis of the contention or based upon a showing that regardless of the facts adduced as a matter of law the contention is incorrect.1 The applicant objections are consistent with these principles. The Staff objections are not. In the preamble to its brief, the Staff cites Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, 55 L.Ed.2d 460, 485 (1978), for the proposition that there is a threshhold evidentiary requirement which must be met before an agency is required to develop a case with respect to a contention. Of course, no such threshhold test applies to the admissibility of a contention which is judged 1/ As we noted during the conference phone call, the Board's jurisdiction tc decide the admissibility of more than one contention, much less reach the legal merits of any contention, is dependenr upon an expansion of the limited powers now delegated to this Board.
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before any evidentiary presentation has been made. A number of staff objections are based upon evidentiary disputes which are premature at this time. When evidence is adduced, NRDC will be more than able to meet any threshhold test. The admission of a contention is a precondition to rule an evi-dentiary presentation because it triggers discovery rights from which some of the evidence may be developed.
Contention 1 Contention 1 is challenged by-the Staff on the theory that it conflicts with Commission policy. In fact the contention is based on Commission policy. The contention rests upon completion of the programmatic EIS being prepared by NRC and the' one being prepared by DOE. The NRC policy statement was written when only NRC was doing a programmatic review and only relates to that review. The DOE review is related to a proposed programmatic solution to interim storage. That proposed solu-tion dces not inc.ude transshipment. The NRC policy statement specifically authorized challenges to individual actions based on the absence of the programmatic review where it could be shown, inter alia, that the proposed action would " tend to significantly foreclose the alternatives available with respect to any other individual licensing action of this type" or would not be necessary to keep reactors cperating where their operation was needed for system reliability, econcmics or control of 2/ Our comments en specific contentions are intended to incor-porate by reference comments on these same contentions filed by the Illinois Attorney General.
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pollution. 40 Fed. Reg. 42801, 42802 (last column), September 16, 1975. Our contentions 1(c), 2, and 3 all address these factors.
If Applicant expends funds now to transship its spent fuel, it will have used funds that could have been spent to expand at-reactor storage capability. Transshipment only makes sense if the Applicant plans to ship to an away-from-reactor storage facility (AFR) in the future. The cost-benefit analysis of such an AFR will appear more favorable as compared to at-reactor storage if, as proposed here, Applicant has already sunk costs in anticipation of the availability of an AFR. Today, without transshipment, DOE has concluded that (DOE /ET-0055, p. 3):
It is assumed that there would be economic and other advantages to the utilities of keeping their spent fuel at their own reactor sites rather than shipping it to interim AFR storage basins.
That is a advantage of at-reactor storage which we seek to p;eserve. Transshipment may destroy that advantage and Contention 1 seeks to pursue the issue.
3/ The Staff appears to ignore the possibility that on-site expansion of spent fuel storage includes building an additional pool and not merely compaction. Their ignorance is unjustified inasmuch as we pressed this cptien in our comments on the spent fuel GEIS. See September 15, 1978, letter from Anthony Z. Roisman to Clifford Smith and attached Analysis of Space Available for Storage of Spent Fuel at Existing Operating Reactor Sites.
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Contention 2_
The Staff objection is cased upon their belief that when all the evidence is presented the Staff will be able to demonstrate that no impact str.tement is required. Of course that is a basis for admitting the contention so that Intervenors and the Staff can join issue. The basis for our belief that major impacts will occur if transshipment is allowed is fully articulated in the contention. Staff takes issue with the reference to the dangers of proceeding with waste half-measures prior to having a permanent waste disposal solution. We refer-ence these dangers because they are part of the residual environmental risk created by the decision in Natural Resources Defense Council v. Nuclear Reculatory Commission, 524 F.2d (D.C. Cir. 1975); Project Manacement Cor; oration (CRSR), ALAB-330, 3 NRC 613, 619-20, reversed on another issue CLI-76-13, 4 NRC 67.
Contention 3 The Staff asserts with respect to 3(a) and (b) objections which go to the adequacy of an evidentiary basis for the conten-tion. As the 5taff ite. elf states, at this time it is premature to determine the evidence for this contention. What is ripe is our clear articulation of our contention -- inadequate consider-ation of alternatives -- and the listing of possible alternatives which are not on their face unreasonable. We have done that.
Combining Contentions 3 (c) and 9 is not objectionable to us.
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Contention 4 The Staff objection is to the factual merits and not the legal adequacy of the contention. The portion of 4 (b) emphasized by the Staff and the applicant was merely intended to disclose that our experts believe the level of worker exposures are 10 times higher than safe. That is a measure of perception of the residual risk of merely meeting the regulation, not a call to change the regulation.
Contention 5 Part of the alleged need for the proposed action is the assertion of the need to maintain a full core discharge capability. Because full core discharge capability is not a regulatory requirement, retaining that capacity is only desir-able if it is itself beneficial. The practice of other utilities confirms that the full core reserve is neither desirable nor required.
Contention 6 In opposing Contention 6 applicant and Staff rest upon the allegation that current regulations concerning security protection for special nuclear material do not cover shipments of spent fuel. However, at no time does the Commission exempt frem consideration the pctential health and safety effects of
' sabotage directed against such shipments. Clearly there is a health and safety problem requiring security =casures. In its
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6 draft EIS on spent fuel storage policy (DOE /EIS-0015-D) the DOE, although concluding the risks are small, nonetheless addressed sabotage of spent fuel shipments as relevant to any spent fuel storage policy. In adopting the exemption to the requirements of Part 73 contained in S 73.6, th3 AEC did not make any finding that there is no sabotage danger associated with spent fuel in transit -- a finding which it could not make.
Thus it left open for litigation in any proceeding the question of whether such a danger does exist and its impact on the public health and safety, NRDC is entitled to raise this issue, particularly in the absence of any data from-the applicant on how it intends to cope with this problem.
Contention 7 Staff objects to the lack of specificity of a contenticn which is itself based upon a lack of specificity of the appli-cation. Without data on emergency planning and an ER we cannot assess the adequacy of the emergency planning and the environ-mental impacts. To date there.is virtually no evidence from the applicant on environmental issues and none on emergency planning.
Contention 8 This contention tracks the scandards developed by the NRC for consideration of interim spent fuel handling proposals and identifies how those standards are not met by the proposed action. If it is insufficiently precise, the Staff should
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coject to the Commission which adopted the standards.
Conclusion For the reasons provided here and in the filing of the State of Illinois, the contentions should be admitted.
Respectfully submitted, s
Anthony 7) R @ man /
Natural Resources Defense Council 917 15th Street, N.W.
Washington, D.C. 20005 (202)737-5000 Dated: January 26, 1979
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COMMONWEALTH EDISON CO., et al. : Docket Nos. 50-237
- 50-249 (Amendments to Operating Licenses) : 50-254 50-265 CERTIFICATE OF SERVICE I hereby certify that copies of NRDC RESPONSE TO APPLICANT AND STAFF OBJECTIONS TO CONTENTIONS were mailed today, January 26, 1979, to the following:
Secretary of the Commission Gary L. Milhollin, Esq.
U.S. Nuclear Regulatory Commission 1815 Jefferson Street Washington, D.C. 20555 Madison, Wisconsin 53711 Attention: Docketing and Service Mrs. Elizabeth B. Johnson Executive Legal Director Union Carbide Corporation U.S. Nuclear Regulatory Commission Nuclear Division Washington, D.C. 20555 P.O. Box x Oak Ridge, Tennessee 37830 Philip P. Steptoe Isham, Lincoln & Beale Dr. Quentin J. Stober One First National Plaza Fisheries Research Institute 42nd Floor University of Washington Chicago, Illinois 60603 Seattle, Washington 98195 Susan N. Sekuler Assistant Attorney General 138 W. Randolph Street Suite 2315 Chicago, Ill. 60601
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