ML19262C168
| ML19262C168 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 01/18/1980 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | ANTI-NUCLEAR GROUP REPRESENTING YORK |
| References | |
| NUDOCS 8002070045 | |
| Download: ML19262C168 (22) | |
Text
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January 18, 1980 UNITED STATES OF AMERICA y / /
NUCLEAR REGULATORY COMMISSION 'N %
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
! D o
s
,e3 7 I-
,, , 1 ^p ro U ;9 In the Matter of ) ([Qe 9M y g;.vp,h y
) g s METROPOLITAN EDISON COMPANY ) Docket No. 50-289 , 3, sg
) (Restart) i !&.
(Three Mile Island Nuclear )
Station, Unit No. 1) )
LICENSEE'S FIRST SET OF INTERROGATORIES TO INTERVENOR ANTI-NUCLEAR GROUP REPRESENTING YORK These interrogatories are filed pursuant to 10 C.F.R.
S 2.740b, which requires that the interrogatories be answered separately and fully in writing and under oath or affirmation.
Licensee recognizes that Intervenor Anti-Nuclear Group Represent-ing York (" ANGRY") may not now be able to completely answer all interrogatories propounded below. Licensee therefore requests that each of these interrogatories be answered within the time specified in S 2.740b to the extent that responsive information is presently available to ANGRY. With raspect to those interroga-tories for which complete and responsive information is not now available to ANGRY, Licensee requests that revised answers be provided prior to the close of the discovery period established in the Licensing Board's December 18, 1979 First Special Pre-hearing Conference Order.
Any reference to ANGRY shall be deemed to include all members of ANGRY. When knowledge or information of ANGRY is requested, such request includes knowledge or information of b 8 02070 Q 45 1926 205 4 (
ANGRY's members and, unless privileged, its attorneys.
The following definitions apply to each of the inter-rogatories below:
A. " Document" means all writings and records of every type including, but not limited to memoranda, tapes, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, diaries, logs, speeches, articles, transcripts and all other records, written, electrical, mechanical or otherwise.
B. " Identify" means:
(1) With respect to a natural person, name, present or last known home or business address, present or last known job title or position, and the dates of tenure in that position; (2) With respect to a document, the type of document (e.g., letter, record, list, memorandum, menorandum of telephone or face-to-face conversation, etc.), date of the document, title of the document, subject of the document, name of person who prepared the document, and name of person for whom the docu-ment was prepared or to whom it was delivered.
Interrogatories on Contention No. 4 1926 206 4-1. Explain separately with respect to (1) loss of auxiliary feedwater to the steam generators; (2) failure to correct leakage of reactor primary coolant through the PORV; and (3) throttling back of HPI, the precise manner in which ANGRY contends that the alleged action (or inaction) demonstrates
that Licensee lacks the management capability to operate a nuclear power reactor without endangering the public health and safety.
(a) In each response, define what ANGRY means by the term " management capability" (including refer-ences to the level of management which ANGRY con-tends should be held responsible).
(b) In each response, indicate the management changes necessary (i.e., organizational changes, re-vised management controls, personnel changes) which ANGRY contends would be necessary to assure the public health and safety.
Interrogatories on Contention No. 5 5-1. Describe the system (s) which ANGRY proposes be installed for rapid filtration of contaminated liquids. For each system described:
(a) Identify the principal radioactive isotopes which ANGRY contends would be removed by such system.
(b) Explain how such system would in ANGRY's view improve on the systems presently installed at TMI-l for the treatment and control of radioactive liquids, as described in Section III-D-2-b of the Final Environmental Statement for TMI-l and TMI-2 (copy attached) .
1926 207 5-2. Describe the system (s) which ANGRY proposes be installed for rapid filtration of contaminated gases. For each system described:
(a) Identify the principal radioactive isotope which ANGRY contends would be removed by such system.
(b) Explain how such system would in ANGRY's view improve on che systems presently installed at TMI-l for the control, hold-up and filtration of radioactive gases, as described in Section III-D-2-a of the Final Environmental Statement for TMI-l and TMI-2 (copy attached).
5-3. Does ANGRY contend that the safety evaluation per-formed by the NRC Staff with respect to the adequacy of the TMI-l liquid and gaseous radwaste systems, as described in the January 11, 1980 Status Report on the Evaluation of Licensee's Compliance with the NRC Order dated August 9, 1979, pages C5-1 through C5-14, is inadequate to resolve the concerns identified in ANGRY Contention No. 5? If so:
(a) Describe in detail the inadequacies of the radwaste system safety evaluation performed by the NRC Staff, with special consideration given to the cost-benefit analysis made by the NRC Staff.
(b) For each inadequacy listed, set forth each and every fact and the source of each and every fact relating to or bearing upon the allegation.
(c) For each inadequacy listed, identify all documents, and the particular parts thereof, containing any evidence or information relating to or bearing upon the allegation.
926 208 (d) For each inadequacy listed, identify all
persons having any information or knowledge support-ing or relating to the allegation.
Interrogatories on Contention No. 6 6-1. Does ANGRY intend to adopt UCS' Contention No.
13? If so, answer interrogatories 6-2 through 6-4 below.
6-2. Describe the accidents which ANGRY contends are credible and not bounded by the TMI-1 design basis accidents.
6-3. Explain as to each accident identified in answer to interrogatory 6-2 the nexus between such accident and the TMI-2 accident.
6-4. Explain what ANGRY means when it contends that an accident is not " bounded" by the design basis accidents for TMI. Indicate in particular as to each accident identified in answer to interrogatory 6-2 whether the term " bounded" refers to accident events or accident consequences or both.
6-5. Describe the criteria proposed by ANGRY to be used for selecting credible accidents to be considered.
Interrogatory No. 7 7-1. With respect to each individual whom ANGRY intends to call as a witness in this proceeding:
(a) Identify by name, address and affiliation each such individual; (b) State the educational and professional background of each such individual, including occupa-tion and institutional affiliations, publications and papers; 09
(c) Identify the contention as to which each such individual will testify; (d) Describe the nature of the testimony which will be presented by each such individual, including an identification of all documents which the indi-vidual will rely upon in the testimony; (e) Identify by court, agency or other body, proceeding, date and subject matter all prior testi-many by each such individual.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE
/ . ,,
By: , ,/?n,j A;eii,')g a,
.)
' [ Geprge Fr'Trowbrid p 1800 M Street, N.W.
Washington, D.C. 20036 Tel: (202) 331-4100 Counsel for Licensee Dated: January 18, 1980 1926 210
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is 28*F.
es and the temperature rise in the condenser cooling circuits The maximum consumption of river wate '
e two units are operating at full power is 20,800 gal / minute. This is evaporated tr our natural
, orais cuulu.3 6v c. , uud uhm uv e all fcicci draf t teuerc. ':
i 2. _ Radioactive Waste In the operation of nuclear power reactors, radioactive matertal is produced by fission and by neutron activation reactions of metals and material in the reactor coolant system. Small amounts of gaseous and -liquid radio-active wastes enter the effluant strea=s, which are monitored and processed within the Station to minimize the radioactive nuclides that will ultimately be released to the atmosphere and into the Susquehanna River at low concen-trations under controlled conditions. The Limitations of 10 CFR Part 20 and the "As Low As Practicable" requiremen'ts of 10 CFR Part 50 with respect to radioactive releases will be met during the operation of the Station a- full power.
The waste treatment systems for the Station, described in the following paragraphs, are designed to collect and process the gaseous, liquid, and soli'd waste which may contain radioactive materials. These waste handling and treat-ment systems are discussed in detail in the Final Safety Analysis Report for Unit 1 (March 2,1970), in the Preliminary Safety Analysis Report for Unit 2 (March 1969), and in the Applicant's Revised Environmental Report dated December 1971.
- a. Gaseous Waste. During power operation of the facilities, radio-active materials released to the atmosphere in gaseous effluents include low concentrations of fission product noble gases (krypton and xenon), halogens (mostly iodines), tritium contained in water vapor and particulate material including both fission products and activated corrosion products. The systems for the processing of radioactive gaseous vaste and ventilation paths are shown schematically in Figures 9-11.
Concentrations of various solutes, such as hydrogen and boron, in the primary coolant are maintained at specified values, and the buildup of fission and activatien products is limited by withdrawing coolant at a normal rate of 45 gpm (the letdown stream). A side stream from this coolant is. cooled, depressurized, and diverted to the makeup and purification system and, system,as necessary, Figure 12. to the boron management system or the liquid waste disposal Normally, the vent valves on the makeup and purification system equipment are closed and the system is operated at positive pressure.
By this procedure the inventories of noble gases in the coolant increase to steady-state values except in the case of long-lived krypton-85. Only the coolant that is diverted to the boron control system is normally degassed.
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Figure 11 - GASEOUS RADIOACTIVE WASTE COLLECTION SYSTEMS, THREE MILE ISLAND UNITS 1 AND 2 I
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III-16 i Gases stripped from the recycled reactor coolant together with cover gases ,
are collected, co= pressed, and stored in pressurized tanks for radioactive decay. With the exception of long-lived krypton-85, the gases will decay to a small fraction of the original amount prior to being released. The gas is filtered through high efficiency particulate filters and charcoal adsorbers and released to the atmosphere through the auxiliary building vent stack.
The holdup system was evaluated based on the Applicants' statement that a minimum holdup of 30 days will be used.
Additional sources of radioactive gases which are not concentrated enough to permit collection and storage include the auxiliary building exhaus t, the turbine building exhaust, the reactor building containment air, and the main condenser air ejectors, which remove radioactive gases which have collected in the condenser as a result of primary to secondary system leakage. The air ejector exhaust from the main condenser of Unit 1 is discharged through the turbine building exhaust without treatment. The ejector exhaust from Unit 2 is routed through demisters to the auxiliary building filter train and released to the station vent.
6 The auxiliary building is maintained at a slightly negative l pressure with respect to ambient pressure. All the exhaust air is '
filtered through high efficiency particulate filters (HEPA) prior to being discharged through the auxiliary building vent stack. Areas within the auxiliary building which have possible contamination have the capability to be exhausted through charcoal adsorbers in addition to REPA filters. l The steam generators are once-through units with no blowdown and with full flow demineralizers on the condensate return. Turbine building '
ventilation is discharged to atmosphere without treatment through roof-mounted exhaust fans. !
Calculations of expected normal discharges of noble gases and iodines are summarized in Tables b and 5. The bases for these calcula- L tions are presented in Table 8. -
i
- b. Liquid Wastes. All equipment relevant to the liquid waste processing system is duplicated in the two units except the miscellaneous vaste evaporator which is located in Unit 1 and shared by Unit 2. A notable dif ference between the two units is the method of condensate decineralization.
Unit 1 uses Powdex; whereas, Unit 2 uses deep-bed desineralizers. Due to the constraints on vaste processing in the miscellaneous waste subsystem, we assumed in our evaluation that 10% of the deep-bed regenerant solution and 100% of the Powdex sluice water will be released to the environment without tr ea tment .
In both units a make-up and purification system maintains the quality and boron concentration of the primary coolant. A stream is continuously " letdown," cooled, demineralized in a mixed bed ion exchanger, _
1926 216 4
.+:
L fi e
Y Table 4 y
- 4 ANTICIPATED ANNUAL RELEASE OF RADIOACTIVE NUCLIDES IN l CASEOUS EFFLUENT FROM THREE MILE ISLAND UNIT 1 (..
Discharge Rate (Ci/yr)
- Gas Steam Auxiliary '
Containment Processing Generator Building .
System Leak Leak Total l Isotope Purge 1 2 2 1 e Kr-83m 5 5 10 Kr-85m -
665 10 10 705 Kr-85 20 2 3 5 Kr-87 -
9 9 18 y Kr-88 -
53 6 5 66 -
Xe-131m 2 10 10 20 Xe-133m 890 860 850 2740 Xe-133 140 '
15 15 30 Xc-135 20 20 40 Xe-138 - -
.04 - .01 .08 .13 I-131
- .01 .08 .09
_- I-133 N
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,A III-19 79 filtered, and fed to the make-up tank from which it is returned to the }
reactor. When the boron concentration is being lowered, a " bleed" stream from the " letdown" stream is directed to the coolant waste system. This stream is processed through a demineralizer, filter and evaporator. The !
condensate from the evaporator passes through a mixed bed decineralizer '
to a storage tank from which it may be recycled or discharged. The concentrated boric acid (evaporator bottoms) is stored for re-use in
a subsequent core cycle or sent to the radioactive waste drucming station for off-site disposal. -
During the 1_st portion of the core cycle, when the boron ;i concentration is the lowest, the entire " letdown" stream is also passed through a deborating demineralizer to effect reduction of boron content, ,
rather than by use of a " bleed" stream. This mode of operation does not produce a vaste stream directly; however, this deborating bed is regenera-ted, and the neutralized regenerants and rinses are. processed through the !
miscellaneous vaste system. No other demineralizers processing radio-active streams are regenerated except the main condeur-te demineralizers in ,
Unit 2, mentioned above. Other waste-water containing boric acid from !
reactor shutdowns, startups, and refueling operations is also processed through the coolant waste disposal system equipment.
Wastes collected in the containment and auxiliary building drains, lab and sampling drains, demineralizer resin and filter precoat sluice water, 1 deborating bed regenerants, and decontamination and other miscellaneous wastes are processed in the miscellaneous waste system. These wastes are j yj collected, filtered, and evapora ted. The condensate from this evaporator
!Fy' is passed through a polishing deminerall .r and then routed to recycle or , y.
to hold-up for discharge. Bottoms from this evaporator are stored in the '
concentrated waste tank until they can be processed through the waste ,7 drumming station.
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Laundry wastes will be collected, filt red, monitored, and [
normally routed with the sanitary wastec. The turbine building drains I are monitored and discharged to the cooling tower effluent stream. From an accu =ulative leak rate of 5 gpm from all systems in the turbine building p that contain secondary coolant we expect less than .05 Ci/yr.
Controlled discharges will be made from the radwaste systems into the cooling tower effluent stream. This flow is 36,000 gpm on an annual average basis f or the combined units. Unit 1 can discharge waste at up to
- I 30 gpm while Unit 2 can achieve a maximum of 50 gp
- 1. Activity monitors and flow controllers will maintain approximate activity levels. Discharges can-not be made from both units simultaneously. No discharge will be made unless the cooling tower effluent flow is at least 5000 gpm.
Based on the assumptions noted above and shown on Tab' d, the releases from the primary sources for norual operation were es' culated to be less than 3 Ci/ year per unit. To compensate for treatment equipment 1(26 219
1 III-20 Table 6 ANTICIPATED ANNUAL RELEASE OF RADIOACTIVE MATERIAL IN THE LIQUID EFFLUENT FROM THREE MILE ISLAND UNIT 1 Nuclid e Curies /yr Rb-86 0.00055 <
Sr-89 0.00044 Y-90 0.000c5 Y-91 0.0099 Zr-95 0.00007 Nb-95 0.00007 Mo-99 . 0.037 Tc-99m 0.037 Ru-103 0.00005 :
Rh-103m 0.00005 Sb-124 0.00005 j Te-125m 0.00003 -
Te-127m 0.00032 i Te-127 0.00035 f Te-129m 0.0016 Te-129 0.0010 Te-131m 0.00074 Te-131 0.00014 Te-132 0.019 I-130 0.0013 l I-131 1.8 ,
I-132 0.020 l I-133 0.21 I-135 0.025 Cs-134 0.21 Cs-136 0.083 Cs-137 0.17 Ba-137m 0.16 Ba-140 0.00048 La-140 0.00042 Ce-141 0.00007 Ce-144 0.00005 Pr-143 0.00007 Pr-144 0.00005 Nd-147 0.00002 Na-24 0.00007 P-32 0.000C7 Cr-51 0.0011 Fe-55 0.0010 Fe-59 0.0006 Co-58 0.0097 Co-60 Ni-63 0.0012 0.00009 j g}{Q - W-185 10005 W-187 0.00058 Np-239 0.00035 , s. TOTAL % 3.0 Tritium-1,000 Ci/yr . A
- E III-21 Table 7 4 ANTICIPATED ANNUAL RELEASE OF RADIOACTIVE MATERIAL IN LIQUID EFFLUENTS FROM THREE MILE ISLAND UNIT 2 Nuclide Ci/yr Nuclide Ci/vr 3 I
[ Rb-86 .0012 Pm-147 .000054 Sr-89 .0041 Na-24 ) Sr-90 .000089
.00012 -
P-32 .00048 6 i Sr-91 .000018 Cr-51 .0088 Y-90 ;
.000072 Mn-54 .000036 Y-91 .0082 Fe-55 .011 Zr-95 .00072 Fe-50 .0054 ;
Nb-95 .00080 Cs-58 .095 i Mo-99 .032 Co-60 .013 j Tc-99m .030 Ni-63 .011 Ru-103 .00048 Zn-65 .000054 ! Ru-106 .00014 W-185
.00045 '
Rh-103m .00048 W-18 7 .00082 i Rh-106 .00014 Np-239 Sb-124 .00075 ',
.00036 Sb-125 -
.000036 TOTAL % 5.0 Te-125m .00034 !
Te-127m .0C36 ) Te-127 .0034 Tritium 1,000 C1/yr Te-129m .014 ;; Te-129 .0088 Te-131m .0012 , Te-131 .00021 Te-132 .050 . I-130 .0013 ( I-131 2.7 ' I-132 .052 i I-133 .20 I-135 .021 Cs-134 .54 Cs-136 .15 Cs-137 .41 Ba-137m .39 Ba-140 .0030 , La-140 .0032 Ce-141 .00066 Ce-143 .00002 Ce-144 .00045 Pr-143 .00039 Pr-144 .00045 Nd-147 .0C014 1926 221
III-22 Table 8 ASSUMPTIONS USED IN DETERMINING RELEASES OF RADIOACTIVE EFFLUENTS AT THREE MILE ISLA!O Unit 1 Unit 2 - 2535 2772 Reactor Power, MWt Plant Capacity Factor 0.8 0.8 ' Fuel with Def ective Cladding , % 0.25 0.25 20 f Leak of Primary Coolant into Steam Generators, gpd 20 , Leak of Primary Coolant to the Auxiliary Building, gpd 40 40 , Frequency of Containment Purge, times /yr 4 4 Waste Gas Holdup f or Decay, days 30 30 Cold Shutdowns, thnes/ year. 2 2 Coolant Volumes Degassed and Processed During Cold Shutdowns and Normal Operations 5 5 ! Miscellaneous Waste Processed, gallons / year 600,000 600,000 l 1 1926 222
.:f,E$iW T$5$!?N$ EiN?Y5'5 5b5 m Q, 8Q III-23 ag p' downtime and expected operational occurrences, the values shown in Tables 6 ' 6 and 7 for the waste systems have been normalized to 3 curies per year for f Unit 1 and 5 curies per year for Unit 2.
. "-l!' Uc :cs. ""ac f olicwing tj-r c.; of ;;11d -o .ill bu i g
eated in Unit 1 (Unit 2 wastes that require solidification will be trans- i 7 fe ed to Unit 1): b I (1) Compressible wastes - paper, rags, clothing, and charcoal filters (2) Incompressible wastes - metal parts from inside the reactor, l i W-vires, cable and spent filter car %idges. f (3) "vaporator concentrates. 0 (4) Spt t resins and used filter precoat. N n. it All solid aste will be packaged and shipped to a licensed burial ;f4-ground in accordance vi AEC and DOT regulations. Based on plants presently o : _ in operation, it is expec ed that approximately 300 to 600 drums of solid : waste will be transported f-site each year. _
- 3. Chemical and Sanitary astes f:
i _ The chemicals used in sig. ificant quantities at the Station are listed in Table 9. s
< r
- a. Demineralizer Regeneration Solutions. Sulfuric acid and sodium [
hydroxide solutions are used for regene ting resins in the two-stage feed [i water demineralizers used for both Units and 2. These materials are d' disposed of on a batch basis; each batch, r a given unit, consists of i 2,000 pounds of sulfuric acid and 1,300 poun of sodium hydroxide diluted } in 70,000 gallons of water. The resulting sol tion of sodium sulfate, with i* a pH between 6 and 9, is released every three da s at a controlled rate over E a 4-hour period (about 300 gpm flow rate). The v te solution is diluted I with the 36,000 gpm cooling water effluent of the ced-draft cooling towers b prior to discharge to the river. The amounts listed n Table 8 are the total
' i quantities of acid and base used annually for the two its at the Station.
The concentrations in the second column of the Table, ho ever, occur in the 36,000 gpm cooling water effluent only during the batch d charge from a i single unit, since the two units discharge their batches at ifferent times.
- b. Condensate polisher Regeneration Solutions. The e densate 7 polishers for Unit 1 are the wound element filter type precoated with f powdered resin. The spent resin is washed out and discharged to t e sludge E m en.c a t hm;c nther tM- 5-! g; regener'w %= nn en ganne, H n x
1926 223 i-
?
January 18, 1980 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
) (Restart)
(Three Mile Island Nuclear ) Station, Unit No. 1) ) CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's First Set of Interrogatories to Intervenor Anti-Nuclear Group Repre-senting York", were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 18th day of January, 1980. A Robert p. Zahler Dated: January 18, 1980 1926 224
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
~
In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
) (Restart)
(Three Mile Island Nuclear ) Station, Unit No. 1) ) SERVICE LIST Ivan W. Smith, Esquire John A. Ievin, Esquire Chairman Assistant Counsel Atomic Safety and Licensing Pennsylvania Public Utility Cm m'n Board Panel Post Office Box 3265 U.S. Nuclear Pegulatory Cmmission Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 Karin W. Carter, Esquire Dr. Walter H. Jordan Assistant Attorney General Atomic Safety and Licensing 505 Executive House Board Panel Post off h Box 2357 881 West Outer Drive Harrisb_rg, Pennsylvania 17120 Gak Ridge, Tennessee 37830 Pcber. L. Knupp, Escuire Dr. Linda W. Little Assistunt Solicitor Atomic Safety and Licensing County of Dauphin Board Panel Post Office Box P 5000 Hernitage Drive 407 North Front Street Raleigh, North Carolina 27612 Harrisburg, Pennsylvarda 17108 James R. Tourtellotte, Esquire John E. Minnich Office of the Executive Iegal Director Chair::nn, Dauphin County Board U. S. Nuclear Regulatory Cmmission of Ccrmissioners Washington, D.C. 20555 Dauphin County Courthouse Front and Market Streets Docketing and Service Section Harrisburg, Pennsylvania 17101 Office of the Secretary U. S. Nuclear Regulatory Camission Walter W. Cohen, Esquire Washington, D.C. 20555 Consumer Advocate Office of Consu:rer Achtx: ate 14th Floor, Strawberry Square Harrisburg, Pennsylvania 17127 1926 225
Jordan D. Cunningh n , Escuire Pcbert Q. Pollard Attorney for Newterry Township Chesapeake Energy Alliance T.M.I. Steering Comnittee 609 Pontpelier Street 2320 North Second Street Baltimore, Maryla.M 21218 Harrisburg, Pennsylvania 17110 Chauncey Kepford Theodore A. Adler, Esquire Judith H. Johnsrud Widoff Peager Selkowitz & Adler Environmental Coalition on Nuclear Post Office Box 1547 Pcwer Harrisburg, Pennsylvania 17105 433 Orlando Avenue State College, Pennsylvania 16801 Ellyn R. Weiss, Esquire Attorney for the Union of Concerned Marvin I. Iewis Scientists 6504 Bradford Tarrace Sheldon, Harnon & Weiss Philadelphia, Pennsylvania 19149 1725 Eye Street, N.W., Suite 506 Washington, D.C. 20006 Parjorie M. Aamodt R. D. 5 Steven C. Sholly Coatesville, Pennsylvania 19320 304 South Market Street Mechanicsburg, Pennsylvania 17055 Gail Bradford Holly S. Keck Iagislation Chaiman Anti-Nuclear Group Pepresenting York 245 West Philadelphia Street York, Pennsylvania 17404 Karin P. Shelden, Esquire Attorney for People Against Nuclear Energy Sheldon, Harnen & Weiss 1725 Eye Street, N.W., Suite 506 Washington, D.C. 20006 1926 226
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