ML20038C167
| ML20038C167 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/07/1981 |
| From: | Silberg J CLEVELAND ELECTRIC ILLUMINATING CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8112100196 | |
| Download: ML20038C167 (17) | |
Text
r Dec mber 7, 1981 000KETED
, [2 RC UNITED STATES OF AMERICA 81 EC -8 P5:16 NUCLEAR REGULATORY COMMISSION ' n- '
Before the Atomic Safety and Licensing Board In the Matter of )
)
THE CLEVELAND ELECTRIC ILLUMINATING)
COMPANY, et. al., ) Docket Nos. 50-440
) 50-441 ,
(Perry Nuclear Power Plant, ) /W 0)h f Units 1 and 2) ) c (
APPLICANTS' ANSWER TO OHIO h O0$fh' 4
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CITIZENS FOR RESPONSIBLE ENERGY i [ I MOTION FOR LEAVE TO FILE ITS $ g /pg A H2 CONTENTION 16 (j}
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In a filing dated November 21, 1981, Ohio Citizen r)N Responsible Energy ("OCRE") seeks permission to amend its Petition to Intervene to add a new contention. The proposed l contention asserts that Applicants should include in the containment design for the Perry facility " magnesium oxide l bricks" to protect against the effects of meltdowns.
Applicants respectfully request that the Licensing Board deny OCRE's motion. At least four independent grounds compel denial of the motion:
l (1) The contention is late and its admission is not l
l justified by a balancing of the factors set forth in 10 CFR S2.714.
(2) There is no showing of the contention's
! relevance to Perry.
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(3) The contention is a challenge to Commission l
regulations.
(4) The issue is currently the subject of an -
on-going rule-making proceeding.
I. 'OCRE's Proposed Contention is Unj ustifiably Late OCRE acknowledges that the proposed contention is unti-mely. Motion, p. 2. Applicants agree. OCRE asserts that the contention should be admitted based upon a balancing of the factors set forth in 10 CFR S2.714 for determining admissibi-lity of late-filed contentions. Applicants disagree. It must be borne in mind that intervenors proposing untimely conten-tions " properly have a substantial burden in justifying their tardiness". Nuclear Fuel Services, Inc. (West Valley Reprocessing Plant), CLI-75-4, 1 NRC 273, 275 (1975).1 The most important factor in determining whether a late contention should be admitted is the intervenor's showing of
" good cause" for the delay. See Nuclear Fuel Services, Inc.,
supra at 275; Cincinnati Gas and Electric Co. (William H.
Zimmer Nuclear Station), LBP-80-24, 12 NRC 231, 237 (1980).
t OCRE asserts that good cause for its late filing can be found because the basis for the contention "was a newspaper article printed less than two weeks ago". The newspaper article (a l
1 Although West Valley dealt with a non-timely intervention
- petition rather than late fi'5 4 cententions, the same tests I apply in both situations, ygg syjvania Power & Light Co.
l (Susquehanna Steam Elec' t c St. tion, Units 1 and 2),
LBP-80-13, 11 NRC 559, v7; a,0;.
l l l
copy of which is attached hereto) summarized the status of the floating nuclear power plant concept proposed by Offshore Power Systems. OCRE's motion further claims that this newspaper article "provided OCRE with its first notice of this issue".
The test that has been used to determine good cause was recently summarized as follows:
The availability of new information appearing in previously unavailable documents has long been recognized as a valid reason for accepting new contentions or for admitting new intervenors.
Pennsylvania Power & Light Co., LBP-80-13, supra at 574 (emphasis added); accord, Indiana and Michigan Electric Co.
(Donald C. Cook Nuclear Plant Units 1 and 2), CLI-72-25, 5 AEC 13, 14 (1972). While the Wall Street Journal article is a "previously unavailable document", the one sentence reference in it to a mechanism for retarding a meltdown is certainly not
! "new information".
Applicants would first point out that the idea of adding materials underneath the reactor pressure vessel to halt or retard a core meltdown is more than a decade old. In fact, t
2 A device for retarding a meltdown (sometimes called a " core catcher" or " core ladle") has been a widely discussed concept l since the early 1960's. In fact, the design of Consolidated l Edison's Indian Point Unit 2 at the construction permit stage I (its construction permit was issued in 1966) included "a l
reactor pit crucible to catch and retain the molten metal that would be produced if the fuel in the core were to melt its way through the bottom of the reactor vessel". Consolidated Edison Co. of N.Y. (Indian Point Station Unit No. 2), LBP-72-16, 5 t
AEC 43, 52 (1972). As noted in the Initial Decision at the i operating license stage, the crucible was removed from the l
(continued next page)
the very article cited by OCRE as the basis for its contention indicates that the magnesium oxide bricks have been a part of the Offshore Power design for years. The NRC Staff first recommended that material to retard a melt-down be placed beneath the reactor vessel in the draf t Final Environmental Statement (Part III) issued in May 1978.4 was discussed by the Appeal Board in August 1978 and again in the Final Environmental Statement for the Offshore plants, issued in December 1978.6 The core retarding design was also discussed in great detail in a February 1980 supplement to the Safety Evaluation Report for the Offshore plants.7 This design concept (continued) design af ter improvements were made to the emergency core cooling system. Id. Since the Indian Point Unit 2 ECCS system satisfied the Commission's regulations, the crucible was determined by the NRC Staff, the Advisory Committee on Reactor Safeguards and the licensing board not to be needed. Id.
3 The Wall Street Journal article states in part:
Through the years the NRC staff has followed the work of Offshore Power's draftsmen closely. The regulators insisted, for example, that the reactor core be surrounded by magnesium oxide bricks to keep any core meltdown for sending radioactive debris into the sea below.
4 NUREG-0127, Rev. 1. See p. xiv.
5 Offshore Power Systems (Floating Nuclear Power Plants),
ALAB-489, 8 NRC 194, 211-12 (1978).
6 NUREG-0502, Final Environmental statement Related to the Proposed Manufacture of Floating Nuclear Power Plants, Part III. (December 1978), pp. xv, App. E.
7 Supplement No. 3 to Safety Evaluation Report, by the Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission in the matter of Offshore Power Systems Floating (continued next page) was discussed in the Commission's 1979 Annual Report to Congress.8 As good cause for its lateness, OCRE implicitly argues that it should not be held responsible for the existence of the information on core retaining systems until it happened to read the W ll Street Journal article'. OCRE goes so far as to indicate that "without doubt, many other points exist suitable for litigation in this forum". Presumably, OCRE believes that similar newspaper or magazine articles, mentioning issues that have been widely known for years, would provide good cause for raising other late contentions.
Applicants respectfully suggest that a newspaper article reporting on events that took place several years ago, does not constitute new information of the kind which could support admission of a new contention. Any other result would wipe out the good cause requirement. Let us assume, for example , that the subject matter of Issue 5 in this proceeding, the scram discharge volume accident, was not already admitted as a contention. Suppose an intervenor happened to see a newspaper article three years from now which mentioned the postulated scram discharge volume accident and indicated (as in the Wall (continued)
Nuclear Plants (1-8), NUREG-0054 Supp. No. 3 to NUREG-75/100 (February 1980).
8 U.S. Nuclear Regulatory Commission, 1979 Annual Repor t, p.
99.
Street Journal article) that "through the years, the NRC Staff has followed the work of (Applicants'] draftmen closely" and
~
had years earlier required certain design changes to accomodate that postulated accident. OCRE would argue that the newspaper article was new information justifying admission of,the contention, even though the postulated accident and NRC's actions with regard to it were widely known. Applicants believe that this result would be illogical and improper. If reasonably well-informed intervenors could or should hive been aware of the core retainer concept prior to the Wall Street Journal article, then good cause has not been shown.
Applicants also submit that OCRE's showing on the other balancing factors of 10 CFR S2.714 is similarly flawed. OCRE states that it has no other means to protect its interests on i this issue. In fact, as discussed in Part IV below, there is an existing rulemaking proceeding which is considering preci-sely the same issue. While OCRE asserts that "the mechanism of using magnesium oxide bricks may be an issue with particu-larized aspects and thus not suitable for a generic l
9 Unlike the facts surrounding OCRE's proposed electromagnetic pulse contention, there is nothing in the Wall Street Journal article which could reasonably have " induced substantial fresh doubts in intervenors' minds about the safety l of Perry." Compare Memorandum and Order Concerning Ohio Citizens for Responsible Energy's Motion for Leave to File a Contention About Electromagnetic Pulses (dated October 2, 1981), p. 2. Certainly, a one sentence reference to a three year old design change has little in common with a lengthy technical article in Science.
rulemaking," it provides no basis for this speculation, which is in any case contradicted by the existence of a generic rulemaking.
As to the third factor, the ability to assist in developing a sound record, OCRE's own motion provides no indication of any particular expertise or knowledge on the subject. As OCRE states, it "has not fully investigated the utilization of this material or of its mechanism". Other than having found one sentence in a newspaper article that mentions a device known for over a decade, OCRE has provided no basis for concluding that it will bring any particular expertise or knowledge on this topic to this proceeding.10 The fourth factor, representation of petitioner's interest by existing parties, does not aid OCRE. The NRC Staff, an existing party in this proceeding, is examining the specific issue raised by the contention in the generic rulemaking.
The fifth factor also cuts against OCRE. By adding a new contention, the issues in this proceeding are obviously broadened. Whether or not it would delay the proceeding is speculative.
10 Particularly where the NRC Staff is conducting a parallel investigation (here, a generic rulemaking), some greater level of knowledge of the subject matter of the contention should be required. See Special Prehearing Conference Memorandum and Order, LBP 81-24, 14 NRC 175, 218 (1981) ("Certainly an intervenor wishing to introduce an issue into a hearing and thereby parallel the review already being conducted by staff should have greater degree of knowledge about the alleged deficiency.")
l
.On balance, Applicants believe that denial of OCRE's proposed contention is required.
II. OCRE Has Not Shown The Contention's Relevance To Perry Unless the proposed contention is relevant to the Perry facility, it cannot be admitted. The only indication that OCRE-has considered the relevance of the Offshore design to the
! Perry facility is its rhetorical question:
If this method is available to protect against meltdowns at. sea, should/could not it be used likewise as a further contain-ment measure at PNPP?
i A number of significant differences exist between the Offshore design and the design for Perry (and other on-shore plants) i which make OCRE's comparison irrelevant. For one thing, the i
Offshore design is unique in that it does not include the i
massive concrete basemat provided beneath the reactor vessel in land-based reactors.11 The absence of a basemat means that a melt-through of the barge on which the reactors floating would occur fairly rapidly.12 Another major difference'is that the l
potential consequences of a core-melt accident at an offshore plant would be greater than those at a land-based plant. The core retaining system was needed to reduce the potential consequences at offshore plants to the levels at land-based 11 Supp. 3 to Safety Evaluation Report, supra n. 7 at p. 7.
l The Perry facility on the other hand has a 12.5 foot thick I
concrete basemat. Final Safety Analysis Report, Table 3.8-9..
I l 12 Supp. 3 to Safety Evaluation Report, supra n. 7 at p.7.
f l
i J _ , - _ , . . . _ - . , ~ _ _ . . . , . . . _ . . _ . , . - , ~ . . . , . _ _ - . _ . . . - - , - - _ _ . . . _ _
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ones. See Offshore Power Systems (Floating Nuclear Power Plants), CLI-79-9, 10 NRC 257, 258 (1979); ALAB-489, supra, at 211; NUREG-0502, supra, pp. 2-4, 2-5. Thus, the fact that the NRC staff recommended the addition of a core retarding device in offshore is not a basis for considering a similar addition at a land-based plant such as Perry.
III. Proposed Contention 16 Constitutes an Impermissible Challenge to Commission Regulations The predicate for OCRE's contention is that "an enhanced margin of safety" is needed to protect against the event of a core meltdown. Because this scenario necessarily involves a challenge to NRC regulations, the contention is inappropriate in this proceeding. See 10 CFR S2.758.
The U.S. Court of Appeals for the District of Columbia Circuit rejected essentially the identical argument in Union of Concerned Scientists v. Atomic Energy Commission, 499 F. 2d 1069 (D.C. Cir. 1974). In that case, an intervenor sought to raise a core meltdown contention.
In contention 2(b), petitioner urged that the "true maximum hypothetical accident that can be assumed for this reactor [is] a meltdown of the entire fuel core, with subsequent breaching of of the containment due to penetration of the melted fuel and subsequent interaction with ground water, releasing radioactivity in quantities many orders of magnitude above the release set forth in the [FSAR]."
449 F. 2d at 1089. The Commission rejected the contention
. . . as a challenge to the [ Interim Acceptance Criteria for Emergency Core Cooling Systems) for the simple reason that the accident [the intervenor] would l - 1
oostulate could only occur upon failure of the ECCS. If the criteria are met, the ECCS is presumed to be effective, in which case a LOCA would not escalate into a melt-down of the fuel core.
Id. The intervenor in Union of Concerned Scientists argued that it was appropriate to postulate a meltdown because the Commission's siting regulations, 10 CFR Part 100, assume a substantial core meltdown. The Court rejected this argument, pointing out that siting analyses raise very different ques-tions from the performance of reactor safety systems.
It was open to petitioner to challenge the manner in which the Staff performed this site criteria analysis, but that would
, raise a question quite different from the maximum credible accident for purposes of analyzing ECCS performance. The AEC has chosen to employ a most conservative (drastic) assumption in determining site suitability because site selection is the most critical decision. Once a site has been approved, however, it is entitled to indulge more realistic assumptions, such as the assumption that an ECCS meeting the
[ Interim Acceptance Criteria] will work effectively. That assumption may be wrong, but the forum for challenging it was correctly held not to be the licensing hearing but the rule making.
499 F. 2d at 1090. Here, as in Union of Concerned Scientists, the meltdown scenario presupposes a failure of the ECCS. Since OCRE has not even claimed that the Perry ECCS does not meet the Commission's current ECCS regulations, 10 CFR 550.46 and Appendix K to Part 50, the scenario must involve a challenge to NRC regulations. Since OCRE has not met the requirements for such a challenge in 10 CFR S2.758, the contention cannot stand.
L
U One other possible predicate for the core reaching the containment could be a postulated reactor pressure vessel failure. Such a scenario is, of course, inappropriate as the basis for a contention in the absence of special circumstances.
Special Prehearing Conference Memorandum and Order, LBP-81-24, 14 NRC 175, 227 (1981). No such special circumstances have been claimed.
Since a core meltdown of the type that might arguably justify the addition of a core retaining device involves either a postulated ECCS failure or pressure vessel failure, the contention is improper and should be denied.13 IV. The Proposed Contention is the Subject of An On-going Rulemaking Proceeding and Should Not Be Admitted The Commission currently has underway a generic rulemaking proceeding one of whose issues is the specific contention 4
raised by OCRE. Pursuant to the Douglas Point rule, a contention which is the subject of an on-going rulemaking proceeding should not be admitted.
13 In offshore Power Systems, CLI-79-9, supra and ALAB-489, supra, a core melt accident was allowed to be postulated notwithstanding the fact that it presupposed non-compliance with the ECCS criteria. In those cases and the analogous situation in Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit 1), CLI-80-16, 11 NRC 674 (1980), compliance with ECCS criteria was held not to preclude the use of inconsistent assumptions on ECCS performance "for other purposes" (such as Part 100). CLI-79-9, 10 NRC at 257. Here, OCRE's contention would require the use of inconsistent assumptions on ECCS performance for the same purpose, i.e., prevention against core meltdown. Such a postulation would be inappropriate.
14 Potomac Electric Power Co. (Douglas Point Nuclear Generating Station, Units 1 and 2), ALAD-218, 8 AEC 79, 85 (1974).
On October 2,1980, the' Commission published a notice that it is considering amending its regulations to determine to what extent commercial nuclear power plants should be designed to cope with reactor accidents beyond those considered in the current " design basis accident" approach. -
45 Fed. Reg. 65475 (1980). The notice identified eighteen specific considerations as well as the issue of whether such considerations should be backfitted on existing plants. One of the issues raised by the rulemaking identifies precisely the core meltdown retarding device which is the subject matter of the contention.
- 9. Should the NRC require incorporation into containment design, a core retention system to mitigate the consequences of core meltdown by, for example , increasing resistance to molten core debris pene-tration and thereby substantially reducing gas, vapor and aerosol generation to less than that which occurs when core debris is allowed to interact with concrete?
Assuming a core retention system is required, do you favor a device that delays melt-through of the containment basemat, or a device that permanently retains core debris within the containment building? If you favor delay of core melt-through, do you recommend refractory materials (such as Mg0, Zr0 to protect the containment concrete bale) mat, or do you recommend some other means? If you favor permanent retention of core debris, do you recommend using refractory materials in combination with cooling systems that rely either on natural convective cooling or forced pumping of coolant around the extremities of the refractory material, or do you recommend some other concept? Would you respond differently for different contain-ment types? If so, what differences would you recommend? How do your recommendations affect other safety considerations?
45 Fed. Reg. 65476-77. The notice clearly indicates that core retention systems would go beyond present NRC requirements.
Unlike the case of Sunflower's hydrogen generation contention,15 the pendency of the Degraded Core Rulemaking should serve to exclude consideration of the magnesium oxide bricks contention. The hydrogen generation issue had been specifically ruled by the Commission to be an appropriate issue for litigation withstanding the Commission's contemplation of the Degraded Core Rulemaking. Metropolitan Edison Co.,
CLI-80-16, supra.16 No such ruling exists concerning core retaining devices. Nor is the Part 100 route which was invoked i
to support admission of the hydrogen generation contention available in the present case. Hydrogen generation rates in excess of 10 CFR 550.44 values could theoretically cause containment breach above ground, thus leading to offsite doses in excess of the guideline values in 10 CFR S100.11(a). The core retention system however is only invoked by OCRE to " keep any core meltdown from sending radioactive debris into the
! 15 See Special Prehearing Conference Memorandum and Order,
! supra, 14 NRC at 207-8.
16 The Commission held that the issue could be litigated if there was "a credible loss-of-coolant accident scenario entailing hydrogen generation, hydrogen combustion, containment breach or leaking and offsite radiation doses in excess of Part 100 guideline values". CLI-80-16, 11 NRC at 675. No such showing was made regarding Sunflower's hydrogen generation contention. Special Prehearing Conference Memorandum and Order, supra, 14 NRC at 208. Nor has OCRE even suggested such a scenario with respect to the present contention.
[ ground] below" and is unrelated to the airborne pathway associated with the Part 100 guideline doses.
If OCRE has a position which it wishes to advance with regard to core retention devices, the appropriate forum is the on-going Degraded Core Rulemaking. OCRE has apparently not taken advantage of that opportunity by participating the generic proceeding. This would be a far more sensible approach than litigating an essentially generic issue in individual licensing proceeding. As the U.S. Court of Appeals for the Second Circuit said in connection with another generic issue:
[I]t would be absurd that the issue of the environmental effect of uranium mining in Wyoming should have to be separately considered on every application to con-struct nuclear pl' ants from Maine to California. Rather the idea that a licensing agency should endeavor to identify environmental issues common to many applications and handle them in
" generic" proceedings would seem to benefit all parties, particularly the poorly-financed environmental groups.
Ecology Action v. United States Atomic Energy Commissicn, 492 F. 2d 998, 1002 (1974). The same logic should apply here.
V. Conclusion For all of the reasons set forth above, Applicants respectfully request that OCRE's proposed Contention 16 not be admitted as an issue in this proceeding.
Respectfully submitted SHAW, PITTMAN, POTTS & TROWBRIDGE By % M Jay [E Sijlberg 18C%sM St'reet, N.W.
Dated: December 7, 1981 l PAGE 37 MttDAY, NtnFMRElt 13, 1911
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The finnHng plant kies, owe tanker
,, unh, a.d h ,, ,an, w , and rottishuis, and the espisat of newag, nne aswl the end of this renlary.'says Ar-
, group to wiarhet a pteror rk plastic, polyvinytkleriefkiurble, enrms ty thnne samhers." One detrarler years. calls inr at kast etgM pnwer pinets amt gwtinge frorn the Daninas phtforms. ' ther tsnehaa, a willity spekrsman.
l whkh can be made in very thin sheets Itke wrapping paper and al. gors a far as to say W noeof perrhase ac- la t* nonnM enokluvun la*m, k a te enrybg wudy we M derMe whe,e i, Tennere pwned out of tlw jednt vensesre.
tendy has led to the development of lightweight mkrophimes for the caeming by shrifts is "one of the mnst Mg by dnrh en HlimM islaml The piams mid ptsee un plaet, clinkes unoht inchale weg but EMfshore pean Systems pressed phend hea milkant pnaartd misrepresratitinas of uw a te 88 hiamg tic also ts an sensttive si il no nut et see, chee enough to shore to te cent with Hs appilcation for en fdRC enanutartur l g'isetsa that Itran telephone ten ,ran . ,m operators,u.se.
= hen a persen enins Th.e y,,,,,,,,,,,,,,,w,,,,,,d ,,,,,,,,,ene,s,,,,,,,,,,n,,,,,,es, uwway or to a derdged alrhe lug liceny.
In Cambridge. Mass., twn brothers Inst Derernt er fewmed a er i e ,a ord su oinns bei t- . ~s-sh-,e -w - s=d
,, wrent ~'by a ca.g esl.sggh s,,mt I,,noa agg_ty,ii.e ,
,.The s . _rscompany a_mg . has roM I 8 'I in. ei naa, in ~ s-~aa+ - i-l coff'pany to PIpkMt the pntentialla plegricctric teramtes. The firm
- ninM inw Wase reviusiung h nw san, lar m thriw armt in panhnre pl.ints. Crew d N# *U Plezo Electrk Prfwfurts lac., went pubisc la Juter at 50 cents a share =ay cenpseks in wher andetnes dn. (The quarters *<aaM have heds. lorhers and shno- p"iam"s m"'"e"d oel n"I si "I"'I"Im""t n uk'n s"*n W" han found se hrm buyers. Flevertheless. Off lerh ers l'w IN P*le. Finished plants wouM tw *" shnn rewr suti eeems persinded skal the and le over thefounter trading its sturk has oned for as much as 52.75 r,,,,n,btwa i,tselfIisn't new asut harmless is regidredla*ed in la St'es ce the Atlamle or Gulf renas Hnding a IAration nacient Inniness out rolve someday and
, , ,gers That snands a sha*e. (The price now is 51;81 bht I tha
,,,,,gh, eucpt that umar piirrhage annimt. yleded by Hw wumes that innight them. The plants' deMgwrs say lhete are ,p,,l,,its 18 TFftMS OF TRADING VOISMF and rapid prke esralation. Ing in flw thrin snahestry ran cause onaswat ghist fartary an Rlount Island wHB w pg,,
As feltU "manufartering Nreme hr l&nty M places slimg Use AGanHr anal Gulf
- I'lern Elertrk "prohahiy holds the all time rerord for an ven- et>cm that doel generatty happn
- stwitarmed Imwn plants eneld he a newl e ohne wy ed b anrnn% w Others enuht N "Tliat manufacturing 4 -
tinte stork." says Juan t' arks Srbkttowski. pre 5hlent o OTC whem W of terWatney parn. The hiM cuest. malsa N M W W weten an rense is not ridng to he et murh aw." pre ~l I et Inc., the llenver Investment beaker that look the cmnpany . Conskler, for Hample, the recent pw- Ing If 1 meiest piams were allinunred pr, Malee may le tne odri. Whue Ortshnre erts Anthon) Itoisman, a govermneM law-I , chase af Westoste $avings & than by Mer rtpty Irw their stem, and each respdrraf h _
Eibik; lie company, fotspded by Erk and llenry Holm. etwy graituates Savinrs & f of oan. thenthigt<ui Tirar h. ramsegrtinn prenne hawil un drtarte.1 NRC the *al r erne plants
, IB*er
- '*l'hil lH*Al8 th8' e tiv ca'ru'wpiakes.r'*Inrli hr 8fferic the durbg the aftshnte baules et W Massa-tHisrtts inntiliite of Techmdory, hadds patents on pectorbrtric Cam Even tiw=gh wesid.,le pmsed a Sz ewi revk a ed hs design. Ikdh the N?tC and the
=
paa has in the nrit slu nineihs el Jhes year, neericar inskestry agree lhat settanre agF 8">9 r tere l>cm in he sissmg remgh in 197m. -1 dem't know whit the helt thry re relays Qual roulq$ terropne smal[,.lnespetiglye y,pjaremetits fnr the Wl'hSl3,ml an eart lpptake eevi e howettapa al- gning to de with it."
etertromagnete Merenry esperas the merger w hag de,chww.,t ,crde,n,.e.co.4 swHrhrs in. p,..ns-.**
telephone cuchantes. .Ie The rompany alsa
- + + ,wn n, , anne ges tw ,w,iti nOsivi offet les, _ __ _
_.=
4
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
THE CLEVELAND ELECTRIC ILLUMINATING ) Docket Nos. 50-440 COMPANY, et. al. ) 50-441
)
(Perry Nuclear Power Plant, )
Units 1 and 2) )
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants' Answer To Ohio Citizens For Responsible Energy Motion For Leave To File Its Contention 16" were served by deposit in the U. S.
Mail, First Class, postage prepaid, this 7th day of December 1981, to all those on the attached Service List.
i G f Jay fi Si berg l
Dated: December 7, 1981 i
l f
UNITbDSTATESOFAMERICA-NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
) .
THE CLEVELAND ELECTRI.C ,, ) Docket Nos. 50-440 ILLUMINATING COMPANY Et Al.) 50-441
)
(Perry Nuclear Power Plant, )
Units 1 and 2) )
SERVICE LIST Peter B. Bloch, Chairman . Rob'ert. Aleiander' Atomic Safety and Licensing Board OCRE Interim Representative U.S; Nuclear Regulatory Commission 2030 Portsmouth.. Street.f2-Washington, D.C. 20555 ,
Houston,_ Texas 77098 Dr. Jerry R. Kline Daniel D. Wilt, Esquire Atomic Safety and Licensing Board Wegman, Hessler & Vanderburg U.S. Nuclear Regulatory Commission Suite 102 Washington, D.C. 20555 7301 Ch'ippewa Road .
Brecksville, Ohio 44141 Mr. Frederick J. Shon .
Atomic Safety and Licensing Board Terry Lodge, Esquire U.S. Nuclear Regulatory Commission 915 Spitzer Building Washington, D.C. 20555 Toledo,, Ohio 43604 Atomic Safety and Licensing Mr. Tod J. Kenney Board Panel 228 South College, Apt. A U.S. Nuclear Regulatory Commission Bowling Green, Ohio 43402 Washington, D.C. 20555 Donald T. Ezzone, Esquire Atomic Safety and Licensing Assistant Prosecuting Attorney Appeal Board Panel Lake County Administration Center U.S. Nuclear Regulatory Commission 105 Center Street Washington, D.C. 20555 ~Painesville, Ohio 44077 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission _
Washington, D.C. 20555 James H.' Thessin, Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555
_ __ __