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Category:INTERVENTION PETITIONS
MONTHYEARML20237B6611987-12-0303 December 1987 Clarification of NRC Staff Response to Proposed Contentions of Susquehanna Valley Alliance & TMI Alert,Inc & Response to Amended Proposed Contentions.* Position Noted in 871116 Response Reiterated.W/Certificate of Svc ML20235A8611987-11-20020 November 1987 Amends to Suppl to Petition for Leave to Intervene for Susquehanna Valley Alliance (Sva) & TMI Alert (Tmia).* Contentions Listed ML20236R8041987-11-16016 November 1987 NRC Staff Response to Proposed Contentions of Susquehanna Valley Alliance & TMI Alert.* Contentions 2 & 6 Should Be Admitted as Issues in Proceeding.Contentions 1,3,4,5,7 & 8 Should Be Rejected.W/Certificate of Svc ML20236P8481987-11-12012 November 1987 Licensee Response to Suppl to Petition for Leave to Intervene by Susquehanna Valley Alliance & TMI Alert.* Petition for Hearing Should Be Denied.Supporting Documentation & Certificate of Svc Encl ML20235W1501987-10-0505 October 1987 TMI Alert Inc (Tmia) Authorization for F Skolnick,Member of Tmia,To Act as Intervenor Representing Organization.* Served on 871009 ML20236C0771987-10-0101 October 1987 Response to Licensee & NRC Response to Petition to Intervene.* Skolnick Appointed as Representative as Well as Member of TMI Alert & Fulfills Requirements of 10CFR2.713(b).Certificate of Svc Encl ML20235H6451987-09-25025 September 1987 NRC Staff Response to Petitions to Intervene Filed by Susquehanna Valley Alliance & TMI Alert,Inc & Petition by Commonwealth of PA to Participate as Interested State.* Notice of Appearance & Certificate of Svc Encl ML20234D2981987-09-15015 September 1987 Licensee Response to Commonwealth of PA Petition to Participate as Interested State.* Util Has No Objection to Granting Commonwealth of PA 870903 Petition If Request for Hearing Granted.Certificate of Svc Encl ML20234D3301987-09-15015 September 1987 Licensee Response to Petitions to Intervene.* Licensee Suggests That ASLB Issue Order Scheduling Special Prehearing Conference for 871015 & Directing Petitioners to File Proposes Contentions by 870930.W/Certificate of Svc ML20206R6411986-06-30030 June 1986 Petition of Commonwealth of PA for Leave to Participate as Interested State.Notice of Appearance & Certificate of Svc Encl ML20199E2301986-03-20020 March 1986 Response to TMI Alert Suppl to 851223 Petition for Leave to Intervene.Proposed Contentions 1,4 & 5 Raise Matters within Scope of Proceeding & Should Be Admitted.Proposed Contentions 2 & 3 Inadmissible.Certificate of Svc Encl ML20199E1951986-03-20020 March 1986 Response to TMI Alert,Inc 860310 Suppl to Petition to Intervene Re Proposed Amend to License DPR-50 Re Criteria for Steam Generator Tube Repair.Contentions Fail 10CFR2.714(b) Requirements.Certificate of Svc Encl ML20138A9161986-03-13013 March 1986 Petition of Aamodts,Representing Committee on Health Aspects & Mgt of Nuclear Power for Leave to Intervene & Request for Hearing ML20138B2221986-03-10010 March 1986 Demand for Full Adjudicatory Hearing on Licensee 860204 Request for Amend to License DPR-50,identified as Tech Spec Change 153,to Relax Tube Plugging Criteria.Served on 860318 ML20138A2631986-03-10010 March 1986 Demand for Adjudicatory Hearing Re Gpu 860204 Tech Spec Change Request 153,revising Tube Plugging Criteria for Steam Generators ML20205K5101986-02-25025 February 1986 Response to Mm Aamodt 860208 Petition for Leave to Intervene & Request for Hearing Re Alleged Falsification of Leak Rate Data.Certificate of Svc Encl ML20141E5711986-02-24024 February 1986 Amend to Petition of TMI Alert,Inc for Leave to Intervene & Request for Hearing to Include Encl Affidavit of Kk Pickering,Per ASLB 860212 Order ML20151T4341986-02-0404 February 1986 Petition of Jm Kidwell,1978-1979 Employee of Met Ed,For Leave to Intervene Re Alleged Falsification of Leak Rate Data at Facility.Certificate of Svc Encl ML20137P1761986-01-31031 January 1986 Response Opposing Mi Lewis 860113 Petition for Leave to Intervene & Suggested ASLB Questions.Lewis Has No Interest That May Be Affected by Inquiry.Notices of Appearance & Certificate of Svc Encl ML20137P1721986-01-31031 January 1986 Petition of Numerous 1978-79 Employees of Met Ed for Leave to Intervene.Served on 860203 ML20140F1601986-01-30030 January 1986 Response to Contentions Submitted by Util & TMI-Alert as Suppls to Petitions to Intervene.Contentions Should Be Admitted as Consistent W/Regulatory Pleading Requirements & Notice of Hearing.Certificate of Svc Encl ML20137P1511986-01-30030 January 1986 Petition of Jg Herbein for Leave to Intervene in Matter of Inquiry Into Facility Leak Rate Data Falsification.Served on 860203 ML20137P1261986-01-29029 January 1986 Petition of GP Miller for Leave to Intervene in Proceeding. Miller Can Present Testimony to Contribute to Development of Adequate Record on Issues.Notice of Appearance & Certificate of Svc Encl.Served on 860203 ML20137P1341986-01-29029 January 1986 Petition of Jg Herbein for Leave to Intervene in Inquiry Re Leak Rate Data Falsification.Petitioner Has Interest Which May Be Affected by Proceeding.Notice of Appearance Encl ML20151Y7351986-01-27027 January 1986 Petition of Mm Aamodt for Leave to Intervene & Request for Hearing.Served on 860212 ML20137N0841986-01-24024 January 1986 Answer of C Husted to Suppl to TMI Alert,Inc,Request for Leave to Intervene in Hearing Granted C Husted,Per 851206 Memorandum & Order.Contentions Should Be Recast & Issues Stated as Listed.Certificate of Svc Encl ML20137N2121986-01-24024 January 1986 Response of C Husted Supporting Util Suppl to Petition to Intervene.Util Contention That NRC Should Not Disqualify Husted as NRC-licensed Operator Admissible.Certificate of Svc Encl ML20140C6131986-01-23023 January 1986 Petition of Gpu Nuclear Corp for Leave to Intervene in Leak Rate Data Falsification Inquiry.Certificate of Svc Encl. Served on 860127 ML20137A8371986-01-10010 January 1986 Petition of Licensee for Leave to Intervene & Request for Supplemental Hearing.Permission to Litigate Listed Contention Re Conduct & Attitude of C Husted Requested. Certificate of Svc Encl ML20137A7621986-01-0909 January 1986 Petition of Mi Lewis for Leave to Intervene & Request for Hearing.Served on 860113 ML20210A3571985-11-12012 November 1985 Response to Util 851021 Petition for Leave to Intervene.Nrc Does Not Oppose Petition,Subj to Util Satisfying Requirements of 10CFR2.714(b) ML20210A3751985-11-12012 November 1985 Responds to TMI Alert (Tmia) 851020 Petition for Leave to Intervene.Nrc Does Not Oppose Petition,Subj to Tmia Satisfying Requirements of 10CFR2.714(b).Notice of Appearance for GE Johnson & Certificate of Svc Encl ML20138P7881985-11-0404 November 1985 Petition of D Davenport to Join in Petition of Mi Lewis for New or Expanded Contention Re Hartman Leak Rate Allegations ML20138N6561985-11-0101 November 1985 Answer Supporting Gpu Petition for Leave to Intervene in Proceeding.Certificate of Svc Encl ML20138N5701985-11-0101 November 1985 Answer Supporting TMI Alert (Tmia) Request for Leave to Intervene in Hearing.Answer Does Not Foreclose Any Position to Be Taken in Future W/Tmia in Proceeding.Certificate of Svc Encl ML20138E3491985-10-21021 October 1985 Petition of DB Bauser for Leave to Intervene.Certificate of Svc Encl ML20138E3591985-10-20020 October 1985 Petition of L Bradford for Leave to Intervene & Request for Hearing Re C Husted Integrity & Suitability to Serve as Licensed Operator Instructor or Training Supervisor. Certificate of Svc Encl ML20133H1291985-10-0909 October 1985 Answer to Mi Lewis 850919 Petition for New or Expanded Contention Re Hartman Leak Rate Allegations.Petition Should Be Denied in Entirety ML20133E8771985-10-0404 October 1985 Response to Mi Lewis 850919 Petition for New Leak Rate Contention.Board Has No Jurisdiction to Consider Petitioner Contention ML20135H9541985-09-18018 September 1985 Petition of Mi Lewis for Leave to Intervene & Request for Hearing ML20090C4901984-07-0909 July 1984 Motion for Leave to Participate as Interested State Pursuant to 10CFR2.715(c).Notice of Appearance & Certificate of Svc Encl ML20086G5271984-01-0909 January 1984 Motion to Dismiss TMI Alert,Inc (Tmia) Contentions 1.a,1.b, 1.c & 2.b.1 Re post-repair & Plant Performance Testing & Use of Sulfur Compounds in Sys.Tmia Failed to Provide Bases for Contentions ML20082F5731983-11-23023 November 1983 Motion for Leave to Participate in Oral Presentations at Commission 831205 Meeting Re Mgt Competence & Integrity. Certificate of Svc Encl ML20078N8631983-10-31031 October 1983 Response Opposing Joint Petitioners 831017 Restatement of Contentions.Licensee Agrees to Substitution of Revised Proposed Contention 1 for Original Proposed Contentions 1, 2 & 3.Certificate of Svc Encl ML20081A5071983-10-22022 October 1983 Restatement of Proposed Contentions 1,2 & 3 Re Physical & Chemical Processes Employed to Return Tubes to Design Basis. Certificate of Svc Encl ML20078F8681983-10-0606 October 1983 Response Opposing TMI Alert 830921 Suppl to Petition to Intervene.Contentions Satisfy None of Specificity Requirements.Certificate of Svc Encl ML20078F9071983-10-0606 October 1983 Response to Proposed Contentions Re Steam Generator Repair. Joint Petitioners Fail to Identify Concerns Which Warrant Consideration.Certificate of Svc Encl ML20078A3541983-09-21021 September 1983 Suppl to 830808 Petition to Intervene,Listing Contentions. Certificate of Svc Encl ML20078B8011983-09-21021 September 1983 Contentions of J Lee,N Aamodt & B Molholt Re Steam Generator Degradation & Repair.Svc List Encl ML20085D8481983-07-26026 July 1983 Response to NRC Intervention Requirements for Adjudicatory Hearing on Steam Generator Repair Amend.Petitioner Has Standing Due to Close Proximity of Residence to Plant. Certificate of Svc Encl 1987-09-25
[Table view] Category:RESPONSES & CONTENTIONS
MONTHYEARML20237B6611987-12-0303 December 1987 Clarification of NRC Staff Response to Proposed Contentions of Susquehanna Valley Alliance & TMI Alert,Inc & Response to Amended Proposed Contentions.* Position Noted in 871116 Response Reiterated.W/Certificate of Svc ML20235A8611987-11-20020 November 1987 Amends to Suppl to Petition for Leave to Intervene for Susquehanna Valley Alliance (Sva) & TMI Alert (Tmia).* Contentions Listed ML20236R8041987-11-16016 November 1987 NRC Staff Response to Proposed Contentions of Susquehanna Valley Alliance & TMI Alert.* Contentions 2 & 6 Should Be Admitted as Issues in Proceeding.Contentions 1,3,4,5,7 & 8 Should Be Rejected.W/Certificate of Svc ML20236P8481987-11-12012 November 1987 Licensee Response to Suppl to Petition for Leave to Intervene by Susquehanna Valley Alliance & TMI Alert.* Petition for Hearing Should Be Denied.Supporting Documentation & Certificate of Svc Encl ML20235W1501987-10-0505 October 1987 TMI Alert Inc (Tmia) Authorization for F Skolnick,Member of Tmia,To Act as Intervenor Representing Organization.* Served on 871009 ML20236C0771987-10-0101 October 1987 Response to Licensee & NRC Response to Petition to Intervene.* Skolnick Appointed as Representative as Well as Member of TMI Alert & Fulfills Requirements of 10CFR2.713(b).Certificate of Svc Encl ML20235H6451987-09-25025 September 1987 NRC Staff Response to Petitions to Intervene Filed by Susquehanna Valley Alliance & TMI Alert,Inc & Petition by Commonwealth of PA to Participate as Interested State.* Notice of Appearance & Certificate of Svc Encl ML20234D2981987-09-15015 September 1987 Licensee Response to Commonwealth of PA Petition to Participate as Interested State.* Util Has No Objection to Granting Commonwealth of PA 870903 Petition If Request for Hearing Granted.Certificate of Svc Encl ML20234D3301987-09-15015 September 1987 Licensee Response to Petitions to Intervene.* Licensee Suggests That ASLB Issue Order Scheduling Special Prehearing Conference for 871015 & Directing Petitioners to File Proposes Contentions by 870930.W/Certificate of Svc ML20206R6411986-06-30030 June 1986 Petition of Commonwealth of PA for Leave to Participate as Interested State.Notice of Appearance & Certificate of Svc Encl ML20199E2301986-03-20020 March 1986 Response to TMI Alert Suppl to 851223 Petition for Leave to Intervene.Proposed Contentions 1,4 & 5 Raise Matters within Scope of Proceeding & Should Be Admitted.Proposed Contentions 2 & 3 Inadmissible.Certificate of Svc Encl ML20199E1951986-03-20020 March 1986 Response to TMI Alert,Inc 860310 Suppl to Petition to Intervene Re Proposed Amend to License DPR-50 Re Criteria for Steam Generator Tube Repair.Contentions Fail 10CFR2.714(b) Requirements.Certificate of Svc Encl ML20138A9161986-03-13013 March 1986 Petition of Aamodts,Representing Committee on Health Aspects & Mgt of Nuclear Power for Leave to Intervene & Request for Hearing ML20138B2221986-03-10010 March 1986 Demand for Full Adjudicatory Hearing on Licensee 860204 Request for Amend to License DPR-50,identified as Tech Spec Change 153,to Relax Tube Plugging Criteria.Served on 860318 ML20138A2631986-03-10010 March 1986 Demand for Adjudicatory Hearing Re Gpu 860204 Tech Spec Change Request 153,revising Tube Plugging Criteria for Steam Generators ML20205K5101986-02-25025 February 1986 Response to Mm Aamodt 860208 Petition for Leave to Intervene & Request for Hearing Re Alleged Falsification of Leak Rate Data.Certificate of Svc Encl ML20141E5711986-02-24024 February 1986 Amend to Petition of TMI Alert,Inc for Leave to Intervene & Request for Hearing to Include Encl Affidavit of Kk Pickering,Per ASLB 860212 Order ML20151T4341986-02-0404 February 1986 Petition of Jm Kidwell,1978-1979 Employee of Met Ed,For Leave to Intervene Re Alleged Falsification of Leak Rate Data at Facility.Certificate of Svc Encl ML20137P1761986-01-31031 January 1986 Response Opposing Mi Lewis 860113 Petition for Leave to Intervene & Suggested ASLB Questions.Lewis Has No Interest That May Be Affected by Inquiry.Notices of Appearance & Certificate of Svc Encl ML20137P1721986-01-31031 January 1986 Petition of Numerous 1978-79 Employees of Met Ed for Leave to Intervene.Served on 860203 ML20140F1601986-01-30030 January 1986 Response to Contentions Submitted by Util & TMI-Alert as Suppls to Petitions to Intervene.Contentions Should Be Admitted as Consistent W/Regulatory Pleading Requirements & Notice of Hearing.Certificate of Svc Encl ML20137P1511986-01-30030 January 1986 Petition of Jg Herbein for Leave to Intervene in Matter of Inquiry Into Facility Leak Rate Data Falsification.Served on 860203 ML20137P1261986-01-29029 January 1986 Petition of GP Miller for Leave to Intervene in Proceeding. Miller Can Present Testimony to Contribute to Development of Adequate Record on Issues.Notice of Appearance & Certificate of Svc Encl.Served on 860203 ML20137P1341986-01-29029 January 1986 Petition of Jg Herbein for Leave to Intervene in Inquiry Re Leak Rate Data Falsification.Petitioner Has Interest Which May Be Affected by Proceeding.Notice of Appearance Encl ML20151Y7351986-01-27027 January 1986 Petition of Mm Aamodt for Leave to Intervene & Request for Hearing.Served on 860212 ML20137N0841986-01-24024 January 1986 Answer of C Husted to Suppl to TMI Alert,Inc,Request for Leave to Intervene in Hearing Granted C Husted,Per 851206 Memorandum & Order.Contentions Should Be Recast & Issues Stated as Listed.Certificate of Svc Encl ML20137N2121986-01-24024 January 1986 Response of C Husted Supporting Util Suppl to Petition to Intervene.Util Contention That NRC Should Not Disqualify Husted as NRC-licensed Operator Admissible.Certificate of Svc Encl ML20140C6131986-01-23023 January 1986 Petition of Gpu Nuclear Corp for Leave to Intervene in Leak Rate Data Falsification Inquiry.Certificate of Svc Encl. Served on 860127 ML20137A8371986-01-10010 January 1986 Petition of Licensee for Leave to Intervene & Request for Supplemental Hearing.Permission to Litigate Listed Contention Re Conduct & Attitude of C Husted Requested. Certificate of Svc Encl ML20137A7621986-01-0909 January 1986 Petition of Mi Lewis for Leave to Intervene & Request for Hearing.Served on 860113 ML20210A3571985-11-12012 November 1985 Response to Util 851021 Petition for Leave to Intervene.Nrc Does Not Oppose Petition,Subj to Util Satisfying Requirements of 10CFR2.714(b) ML20210A3751985-11-12012 November 1985 Responds to TMI Alert (Tmia) 851020 Petition for Leave to Intervene.Nrc Does Not Oppose Petition,Subj to Tmia Satisfying Requirements of 10CFR2.714(b).Notice of Appearance for GE Johnson & Certificate of Svc Encl ML20138P7881985-11-0404 November 1985 Petition of D Davenport to Join in Petition of Mi Lewis for New or Expanded Contention Re Hartman Leak Rate Allegations ML20138N6561985-11-0101 November 1985 Answer Supporting Gpu Petition for Leave to Intervene in Proceeding.Certificate of Svc Encl ML20138N5701985-11-0101 November 1985 Answer Supporting TMI Alert (Tmia) Request for Leave to Intervene in Hearing.Answer Does Not Foreclose Any Position to Be Taken in Future W/Tmia in Proceeding.Certificate of Svc Encl ML20138E3491985-10-21021 October 1985 Petition of DB Bauser for Leave to Intervene.Certificate of Svc Encl ML20138E3591985-10-20020 October 1985 Petition of L Bradford for Leave to Intervene & Request for Hearing Re C Husted Integrity & Suitability to Serve as Licensed Operator Instructor or Training Supervisor. Certificate of Svc Encl ML20133H1291985-10-0909 October 1985 Answer to Mi Lewis 850919 Petition for New or Expanded Contention Re Hartman Leak Rate Allegations.Petition Should Be Denied in Entirety ML20133E8771985-10-0404 October 1985 Response to Mi Lewis 850919 Petition for New Leak Rate Contention.Board Has No Jurisdiction to Consider Petitioner Contention ML20135H9541985-09-18018 September 1985 Petition of Mi Lewis for Leave to Intervene & Request for Hearing ML20090C4901984-07-0909 July 1984 Motion for Leave to Participate as Interested State Pursuant to 10CFR2.715(c).Notice of Appearance & Certificate of Svc Encl ML20086G5271984-01-0909 January 1984 Motion to Dismiss TMI Alert,Inc (Tmia) Contentions 1.a,1.b, 1.c & 2.b.1 Re post-repair & Plant Performance Testing & Use of Sulfur Compounds in Sys.Tmia Failed to Provide Bases for Contentions ML20082F5731983-11-23023 November 1983 Motion for Leave to Participate in Oral Presentations at Commission 831205 Meeting Re Mgt Competence & Integrity. Certificate of Svc Encl ML20078N8631983-10-31031 October 1983 Response Opposing Joint Petitioners 831017 Restatement of Contentions.Licensee Agrees to Substitution of Revised Proposed Contention 1 for Original Proposed Contentions 1, 2 & 3.Certificate of Svc Encl ML20081A5071983-10-22022 October 1983 Restatement of Proposed Contentions 1,2 & 3 Re Physical & Chemical Processes Employed to Return Tubes to Design Basis. Certificate of Svc Encl ML20078F8681983-10-0606 October 1983 Response Opposing TMI Alert 830921 Suppl to Petition to Intervene.Contentions Satisfy None of Specificity Requirements.Certificate of Svc Encl ML20078F9071983-10-0606 October 1983 Response to Proposed Contentions Re Steam Generator Repair. Joint Petitioners Fail to Identify Concerns Which Warrant Consideration.Certificate of Svc Encl ML20078A3541983-09-21021 September 1983 Suppl to 830808 Petition to Intervene,Listing Contentions. Certificate of Svc Encl ML20078B8011983-09-21021 September 1983 Contentions of J Lee,N Aamodt & B Molholt Re Steam Generator Degradation & Repair.Svc List Encl ML20085D8481983-07-26026 July 1983 Response to NRC Intervention Requirements for Adjudicatory Hearing on Steam Generator Repair Amend.Petitioner Has Standing Due to Close Proximity of Residence to Plant. Certificate of Svc Encl 1987-09-25
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20210B8491999-07-21021 July 1999 Exemption from Certain Requirements of 10CFR50.54(w),for Three Mile Island Nuclear Station Unit 2 to Reduce Amount of Insurance for Unit to $50 Million for Onsite Property Damage Coverage ML20206D4141999-04-20020 April 1999 Exemption from Requirements of 10CFR50,App R,Section III.G.2 Re Enclosure of Cable & Equipment & Associated non-safety Related Circuits of One Redundant Train in Fire Barrier Having 1-hour Rating ML20206T7211999-02-11011 February 1999 Memorandum & Order (CLI-99-02).* Denies C George Request for Intervention & Dismisses Subpart M License Transfer Proceeding.With Certificate of Svc.Served on 990211 ML20198A5111998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50.65 Re Requirements for Monitoring Effectiveness of Maintenance at Nuclear Power Plants.Proposed Rulemaking Details Collaborative Efforts in That Rule Interjects Change ML20154G2941998-09-17017 September 1998 Transcript of 980917 Public Meeting in Rockville,Md Re License Transfer of TMI-1 from Gpu Nuclear,Inc to Amergen. Pp 1-41 ML20199J0121997-11-20020 November 1997 Comment on Pr 10CFR50 Re Financial Assurance Requirements for Decommisioning Nuclear Power Reactors.Three Mile Island Alert Invokes Comments of P Bradford,Former NRC Member ML20148R7581997-06-30030 June 1997 Comment on NRC Proposed Bulletin 96-001,suppl 1, Control Rod Insertion Problems. Licensee References Proposed Generic Communication, Control Rod Insertion, & Ltrs & 961022 from B&W Owners Group ML20078H0431995-02-0101 February 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Lowpower Operations for Nuclear Reactors ML20077E8231994-12-0808 December 1994 Comment Supporting Proposed Rules 10CFR2,51 & 54 Re Rev to NRC NPP License Renewal Rule ML20149E2021994-04-20020 April 1994 R Gary Statement Re 10 Mile Rule Under Director'S Decision DD-94-03,dtd 940331 for Tmi.Urges Commissioners to Engage in Reconsideration of Author Petition ML20065Q0671994-04-0707 April 1994 Principal Deficiencies in Director'S Decision 94-03 Re Pica Request Under 10CFR2.206 ML20058A5491993-11-17017 November 1993 Exemption from Requirements in 10CFR50.120 to Establish, Implement & Maintain Training Programs,Using Sys Approach to Training,For Catorgories of Personnel Listed in 10CFR50.120 ML20059J5171993-09-30030 September 1993 Transcript of 930923 Meeting of Advisory Panel for Decontamination of TMI-2 in Harrisburg,Pa.Pp 1-130.Related Documentation Encl ML20065J3461992-12-30030 December 1992 Responds to Petition of R Gary Alleging Discrepancies in RERP for Dauphin County,Pa ML20065J3731992-12-18018 December 1992 Affidavit of Gj Giangi Responding to of R Gary Requesting Action by NRC Per 10CFR2.206 ML20198E5581992-12-0101 December 1992 Transcript of Briefing by TMI-2 Advisory Panel on 921201 in Rockville,Md ML20210D7291992-06-15015 June 1992 Exemption from Requirements of 10CFR70.24 Re Criticality Accident Requirements for SNM Storage Areas at Facility Containing U Enriched to Less than 3% in U-235 Isotope ML20079E2181991-09-30030 September 1991 Submits Comments on NRC Proposed Resolution of Generic Issue 23, Reactor Coolant Pump Seal Failure. Informs That Util Endorses Comments Submitted by NUMARC ML20066J3031991-01-28028 January 1991 Comment Supporting SECY-90-347, Regulatory Impact Survey Rept ML20059P0531990-10-15015 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal ML20059N5941990-10-0404 October 1990 Transcript of 900928 Public Meeting in Rockville,Md Re Studies of Cancer in Populations Near Nuclear Facilities, Including TMI ML20055F4411990-06-28028 June 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re Revs to FSAR ML20248J1891989-10-0606 October 1989 Order.* Grants Intervenors 891004 Motion for Permission for Opportunity to Respond to Staff Correspondence.Response Requested No Later That 891020.W/Certificate of Svc.Served on 891006 ML20248J1881989-10-0303 October 1989 Motion for Permission for Opportunity to Respond to Staff Correspondence in Response to Board Order of 890913.* Svc List Encl ML20248J0301989-09-29029 September 1989 NRC Staff Response to Appeal Board Order.* Matters Evaluated in Environ Assessment Involved Subjs Known by Parties During Proceeding & Appear in Hearing Record & Reflect Board Final Initial Decision LBP-89-7.W/Certificate of Svc ML20247E9181989-09-13013 September 1989 Order.* Requests NRC to Explain Purpose of 890911 Fr Notice on Proposed Amend to Applicant License,Revising Tech Specs Re Disposal of Accident Generated Water & Effects on ASLB Findings,By 890929.W/Certificate of Svc.Served on 890913 ML20247G0361989-07-26026 July 1989 Transcript of Oral Argument on 890726 in Bethesda,Md Re Disposal of accident-generated Water.Pp 1-65.Supporting Info Encl ML20247B7781989-07-18018 July 1989 Certificate of Svc.* Certifies Svc of Encl Gpu 890607 & 0628 Ltrs to NRC & Commonwealth of Pa,Respectively.W/Svc List ML20245D3651989-06-20020 June 1989 Notice of Oral Argument.* Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from ASLB 890202 Initial Decision Authorizing OL Amend,Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890620 ML20245A5621989-06-14014 June 1989 Order.* Advises That Oral Argument on Appeal of Susquehanna Valley Alliance & TMI Alert from Board 890202 Initial Decision LBP-89-07 Authorizing OL Amend Will Be Heard on 890726 in Bethesda,Md.W/Certificate of Svc.Served on 890614 ML20247F3151989-05-22022 May 1989 NRC Staff Response to Appeal by Joint Intervenors Susquehanna Valley Alliance/Tmi Alert.* Appeal Should Be Denied Based on Failure to Identify Errors in Fact & Law Subj to Appeal.W/Certificate of Svc ML20246Q2971989-05-15015 May 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20246J6081989-05-12012 May 1989 Licensee Brief in Reply to Joint Intervenors Appeal from Final Initial Decision.* ASLB 890203 Final Initial Decision LBP-89-07 Re Deleting Prohibition on Disposal of accident- Generated Water Should Be Affirmed.W/Certificate of Svc ML20247D2761989-04-20020 April 1989 Transcript of 890420 Briefing in Rockville,Md on Status of TMI-2 Cleanup Activities.Pp 1-51.Related Info Encl ML20244C0361989-04-13013 April 1989 Order.* Commission Finds That ASLB Decision Resolving All Relevant Matters in Favor of Licensee & Granting Application for OL Amend,Should Become Effective Immediately.Certificate of Svc Encl.Served on 890413 ML20245A8381989-04-13013 April 1989 Transcript of Advisory Panel for Decontamination of TMI-2 890413 Meeting in Harrisburg,Pa.Pp 1-79.Supporting Info Encl ML20245A2961989-04-13013 April 1989 Transcript of 890413 Meeting in Rockville,Md Re Affirmation/Discussion & Vote ML20248H1811989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* W/Certificate of Svc.Served on 890411.Granted for Aslab on 890410 ML20248G0151989-04-0606 April 1989 Valley Alliance/Tmi Alert Motion for Leave to File Appeal Brief out-of-time.* Requests to File Appeal Brief 1 Day Late Due to Person Typing Document Having Schedule Problems ML20248G0261989-04-0606 April 1989 Susguehanna Valley Alliance/Tmi Alert Brief in Support of Notification to File Appeal & Request for Oral Argument Re Appeal.* Certificate of Svc Encl ML20248D7211989-04-0404 April 1989 Memorandum & Order.* Intervenors Application for Stay Denied Due to Failure to Lack of Demonstrated Irreparable Injury & Any Showing of Certainty That Intervenors Will Prevail on Merits of Appeal.W/Certificate of Svc.Served on 890404 ML20247A4671989-03-23023 March 1989 Correction Notice.* Advises That Date of 891203 Appearing in Text of Commission 890322 Order Incorrect.Date Should Be 871203.Certificate of Svc Encl.Served on 890323 ML20246M2611989-03-22022 March 1989 Order.* Advises That Commission Currently Considering Question of Effectiveness,Pending Appellate Review of Final Initial Decision in Case Issued by ASLB in LBP-89-07. Certificate of Svc Encl.Served on 890322 ML20236D3821989-03-16016 March 1989 Valley Alliance & TMI Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of 2.3 Million Gallons Of....* Certificate of Svc Encl.Served on 890316.Granted for Aslab on 890316 ML20236D3121989-03-15015 March 1989 Licensee Answer to Joint Intervenors Motion for Extension of Time to File Brief on Appeal.* Motion Opposed Based on Failure to Demonstrate Good Cause.W/Certificate of Svc ML20236D2901989-03-11011 March 1989 Valley Alliance/Tmi Alert Motion for Extension of Time to File Brief in Support of Request for Appeal in Matter of Disposal of 2.3 Million Gallons of Radioactive Water at Tmi,Unit 2.* Svc List Encl ML20236A3761989-03-0808 March 1989 Licensee Answer Opposing Joint Intervenors Motion for Stay.* Stay of Licensing Board Decision Pending Appeal Unwarranted Under NRC Stds.Stay Could Delay Safe,Expeditious Cleanup of Facility.Certificate of Svc Encl ML20236C2441989-03-0808 March 1989 NRC Staff Response in Opposition to Application for Stay Filed by Joint Intervenors.* Application for Stay of Effectiveness of Final Initial Decision LBP-89-07,dtd 890202 Should Be Denied.W/Certificate of Svc ML20235V2641989-03-0202 March 1989 Notice of Aslab Reconstitution.* TS Moore,Chairman,Cn Kohl & Ha Wilber,Members.Served on 890303.W/Certificate of Svc ML20235V2161989-02-25025 February 1989 Changes & Corrections to Susquehanna Valley Alliance/Three Mile Island Alert Documents Submitted on 890221.* Certificate of Svc Encl 1999-07-21
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Station, Unit No. 1) ) .
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PEOPLE AGAINST NUCLEAR ENERGY REQUEST FOR HEARING ON LICENSE AMENDMENTS AND CONDITIONS REQUIRED PRIOR TO RESTART OF TMI-l In the accompan ing response to the Licensee's Motion
- with Respect to the Psychological Health Issue, People Against Nuclear Energy (PANE) discusses the Licensee's .
argument that the Three Mile Island Unit No. 1 restart hearing was discretionary, an'd therefore not part of the 1
" existing agency review process" in which psychological ,
/
health issueo must be considered pursuant totthe National Environmental Policy,Act. We point out that both the Licensing Board and the NRC Staff have concluded that various license amendments are required prior to restart in. order to assure the public health and safety. ,
Under Section 189(a) of the Atomic Energy Act, 42 U.S.C.
2239(a), PANE is entitled to a hearing on such license modifi-cations if it requests one, assuming it meets all other standing requirements. We prefer to view the restart 95o3 5
1 I I F206070006 B20603 -
PDR ADOCK 05000289
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4
, proceeding as the hearing r,equired by the Atomic Energy Act with respect to the various license modifications.
The restart hearing should be treated as non-discretionary and as the existing agency review process in which NEPA issues are considered. If the restart hearing is treated
.t in that manner, this hearing request is unnecessary.
If the restart hearing is considered to have been entirely discretionary, PANE and all other persons with standing have a right to a separate h' earing under the Atomic Energy Act prior to implementation of the license amendments and modifications that.are' conditions of restart. In the event the Commission decides to treat the restart hearing as having been entirely discretionary, and if it rules that NEPA issues need not be considered in the restart i
hearing, PANE hereby requests a hearing under Section 189(a) of the Atomic Energy Act on all license mmendments, conditions, or modifications arisins;out of the restart hearing.
l 2 In the resultant hearing, PANE expects to address the issue of the psychological health damage and community impact that would be caused if the license amendments, conditions, or modifications were granted and restart were allowed to l 1 I
proceed. Those issues were held to be cognizable under NEPA in People Against Nuclear Energy v. U.S. Nuclear Regulatory Commission, Docket No. 81-1131 (filed May 14, 1982).
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d In connection with this hearing request, PANE refers the Commission to its original Petition to Intervene in the restart proceeding and to its original contentions, both of which are attached (without affidavits). We also note that the restart Licensing Board has already ruled that PANE has satisfied the NRC's standing requirements. Metropolitan Edison Co. (Three Mile Island Nuclear Station, Unit No. 1),
LBP-79-34, 10 NRC 828, 850 & n. 17 (1979).
Finally, we emphasize that we are not seeking to duplicate the restart hearing that has gone before. Rather, we are seeking recognition of the fact that since the Atomic Energy Act requires hearings, if requested, with respect to proposed license amendments, such hearings constitute the " existing agency review process" for NEPA purposes. In this case the restart proceeding may have begun as a discretionary hearing, but when the point was reached that license amendments, i
l modifications, and conditions were at issue and became l conditions of restart, all interested parties were entitled to a hearing as a matter of right, and they were entitled to litigate all relevant issues, including those arising under s'
NEPA. The right_to litigate those NEPA issues cannot be eliminated by the slight-of-hand of continuing to pretend
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- l. that _he res.Lart hearing was discretionary.
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PANE requests a prompt ruling from the Commission on this request and the accompanying filing in order to permit prompt judicial review should that be necessary.
Respectfully submitted, WW ,JR William . Jordan, III '
Date: June 3, 1982 HARMON & WEISS i
1725 I Street, N.W.
Suite 506 Washington, D.C. 20006 (202) 833-9070 f
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' UNITED STATES OF AMERICA .' .
NUCLEAR REGULATORY COMMISSION ,
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METROPOLITAN EDISON COMPANY, a . ... . . .. . .
' , '.' et -n1, .- ) Docket ' No. 50-289 .: l A ' . < .
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'!'PEOPLE AGAINST NUCLEAR ENERGY
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- DRAFT CONTENTIONS t~ * ## #*- .7
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Pursuant .to 10 CFR 2.714 (b) and the Atomic Safet:y~ and ~ .I ". ,)
Licensing Board's Order of September 21, 1979, People Against'
- ' Nuclear Energy '(PANE) submits the following draft ' contentions: '
1.) Renewed operation of Three Mile Island, Unit 1.. ,. ".- . , . ' . .
(TMI 1) would..- cause severe psychological distress to PANE'a' '..
members and other persons living in the' vicinity of the ., .
reactor.
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The accident at Unit 2 has already impaired.the
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. health and sense of well being of these' individuals, as evi
, ..l denced by their feelings of increased anxiety, tension and
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fear, a sense of helplessness and such ' physical disorders as' ' . .; ,
skin rashes, aggravated ulcers, and skeletal and muscular .
problems. . :-
Such manifestations of psychological distress have been seen in the aftermath of other disasters. The '
.- 1 possibility that TMI Unit 1 will reopen severely aggrayates .
these problems. As long as this possibility exists, PANE's
memb rs and other parsons living in the communitics cround the plant will be unable to resolve and recover from the '. ."
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, trauma which they have suffered. Operation of Unit I wo d.
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be a constant reminder of the terior which they felt during , ,
the accident, and of the possibility that it will happen
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again. 's
- Thedistresscausedbythiseverpresentspectrs)E ' . p.$.- ,
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of disaster makes it impossible for the NRC to operate TMI 1 ;,.I
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. ....,L-without endangaring the public health and safety. ,.
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2.3 ' Renewed operation of TMI 1 would cause severe hm
to the stability, cohesiveness and well being of the communitie:
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in the vicinity of the reactor. Co=munity institutions have t
a15cady been weakened as a result of a loss of citizen l -
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. confidence in the' ability of these institutions to function . . ..:. .. .
properly and in a helpful manner during a crisis. The
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potential for a reoccurrence of the accident will further stress the community infrastructure, causing increased loss
- ~ .
of confidence and a breakdown of the social and political . ..
order. Sociologists such as Kai Erikson have documented . .
similar phenomena,in other communities following:, disasters.'i...
The perception, created by the accident,that the com- J. '. .
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munities near Three Mile Island are undesirable locations' . . ' ' ' ,' -
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for businsss and industry, or for the establishment of law ,
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or medical practice, or homes compounds the damage to the viability of the communities. Community vitality depends upon the ability to attract and keep persons, such as t
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teachers, doctors, lawyers, and businesses critical to I
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. cconomic and social health. The potential for another t -
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,i accident, should TMI 1 be al1. owed- to operate, would compou
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and make permanent the damage, trapping the residents in ' ,e*: . .
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- s. r disintegrating and dying communities and discouraging the influx of essential growth. ..
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3.) . ... . , .
Evacuation ~ planning done by Metropolitan E n j.,-
'and the
. ar Regulatory Commission le ina
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ate to
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..' '.as'ure s the safety o . .
e public, p cularly those persons . . . - -
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./. :living within a five mile r .
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of the plant. . .
. Operation of :9...
2 TMI.1 should not esumed until a p1 . . . . -
in place'for.the . . ; ..i-.,
evacuatic .- -
the public in the maximum area whic : :e : ., ;. -
onld be f ected by an accident. '
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. .. Respectfu'lly submitted, '
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Karin P. Sheldon - ..
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William S. Jordan,Tic III .[:b_l
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Sheldon, Harmon & Weiss 1725 "I" Street, N.E U Suite 506 : -
i Washington, D.C. 20' 4 -
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b UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION'
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
METROPOLITAN EDISON COMPANY, )
et al., ) Docket No. 50-289 (Ynree Mile Island Nuclear )
Station,. Unit No. 1) )
)
PEOPLE AGAINST NUCLEAR ENERGY PETITION TO INTERVENE By Order and Notice of Hearing dated August 9, 1979, .
the Nuclear Regulatory Commission ordered the Metropolitan Edison Company to maintain Unit 1 of its Three Mile Island nuclear power plant ("TMI-1") in a cold shutdown condition ,
pending completion of hearings before a specially constitu-ted Atomic Safety and Licensing Board. The purpose of these hearings is to resolve a series of issues identified by the Commission as determinative of whether resumption of opera-tion at .the plant would be consistent with the public health and safety.
The order establishes that the procedures in subpart A of 10 CFR Part 2 will govern the TMI-l proceedings. Pursuant to 10 CFR 2.714, People Against Nuclear Energy (PANE) hereby petitions to intervene as a party.
(1) The Nature of PANE's Right Under the Atomic Energy Act to be Made a Party to the Proceeding.
PANE's right to intervene is established by Section 189a of the Atomic Energy Act, 42 U.S.C. 2239(a) which recuires the fl ( L- Q)v 'f
o g ve~
Commission to admit as a party "any person whose interest may be e affected by the proceeding." In this proceeding, PANE seeks to intervene on behalf of the following named persons, all of whom are members of the organization and have specifically authorized PANE to represent their interests:
John M. Garver, Jr.
114 Park Circle Road Middletown, PA.
James B. Hurst 617 Briarcliff Road Middletown, PA.
Barbara G. Coates 360 High Street Highspire, PA.
Donald E. Hossler 501 Vine Street Middletown, PA. "
Marcella J. Heicher 326 Second Street Highspire, PA.
Morris Field 504 Hemlock Hall Middletown, PA.
Genevieve Burner Emerick -
489 Willow Street Highspire, PA. ,
Donald H. Konkle 320 Elm Court Middletown, PA.
Paola Louise Kinney 12 Ray Road Middletown, PA. ,
Joyce Ann Corradi 2 South Nissley Drive Middletown, PA.
Elizabeth Mae Chavey 114 Donald Avenue Middletown, PA.
h Affidavits which attest to these facts from the PANE members listed above are attached to this petition.
(2) The Nature and Extent of the Petitioner's Property, Financial or Other Interest in the Proceeding.
All of the named PANE members have a cognizable interest in the proceedings which may be affected by its outcome. They all live within 5 miles of the Three Mile Island facility. In the af termath of the accident at TMI-Unit 2, Petitionef s mental and emotional health. would be adversely af fected by the operation of a nuclear power plant in such close proximity. Such'a concrete, direct interest clearly establishes standing. Consumers Power Co. (Palisades Nuclear Plant) LBP-79-20 July 24, 1979.
(3) The Possible Effect of an Order Which May be Entered in the Proceeding on the Petitioner's Interest.
I The effect of an order allowing the resumption of operations at TMI-1, even assuming implementation of the so-called "short term actions" identified on pages 5-8 of the Order and Notice of Hearing and committment to the "long-term actions" contained on i
pages 7-8, would be to unreasonably threaten the physical, mental and emotional well being of the named PANE members.
(.4 ) The Specific Aspects of the Subject Matter of the Proceedings as to l
Which Petitioner Wishes to Intervene PANE will take the position that the Nuclear Regulatory Commission has the obligation, as part of its duty to protect.
the public health and safety, to prevent impairment of the mental health and stability of the communities in which nuclear plants are located. PANE will contend that its members and the
q*- -
g community surrounding Three Mile Island have suffered a unique trauma as a result of the accident at Unit 2 of the facility, and consequently, that operation of Unit 1 poses a threat to the stability and health of the area. For this reason, Unit 1 cannot be operated without endangering the health and safety of the public.
Respectfully submitted People Against Nuclear Energy By their Attorney:
u '
Karin P. Sheldon Sheldon, Harmon, Roisman & Weiss 1725 I Street, N.W.
Suite 506 Washington, D.C. 20006 (202) 833-9070 DATED: September 14, 1979 l
t I
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tlNITMD STATM8 uF AMMRICA NUCLEAR RMGULATORY COMMlSSTUN nw BEFORE THE ATOMIC SAPMTY AND 1.lCHNSING BOA C S I.E In the Matter of ) -4 A10 :27
.E2 METRO'POLITAN EDISON COMPANY ) Docket No. 50-20') W
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(Three Mile Island Nuclear )
Station, Unit No. 1) )
CERTIFICATE OF SERVICE I hereby certify that on this 3rd day of June, 1982, copies of the foregoing motions, PEOPLE AGAINST NUCLEAR ENERGY REQUEST FOR HEARING ON LICENSE AMENDMENTS AND CONDITIONS REQUIRED PRIOR TO RESTART OF TMI-l and PEOPLE AGAINST NUCLEAR ENERGY RESPONSE TO LICENSEE'S MOTION WITH RESPECT TO PSYCHOLOGICAL HEALTH ISSUE, have been mailed, first class, postage paid, to the following:
Ivan'W. Smith, Chairman Judge John H. Buck Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Appeal Board Panel c . S . Nuclear Regulatory U. S. Nuclear Regulatory Commis sio n Commi,ssion Washington, D.C. 20555 Washing ton D.C. 2 0555 Dr . Walter H . Jordan Judge Christine.N. Kohl i Atomic Safet'y and Li' censing Atomic Safety and Licensing l Board Panel AppealBoard Panel i 88]. West Outer Drive ll .S . Nuclear Regulatory
} Oak Ridge , Tennessee 37830 Commission W ashing ton , D.C. 20555 Dr. Linda W. Little l Atomic Safety and Licensing Thomas Roberts, Commissioner l
Board Panel U.S. Nuclear Regulatory 5000 Hermitage Drive Commission Raleigh, North Carolina 27612 Wash ing ton , D.C. 20555 i Professor Gary L. Hilhollin Nunzio.Palladino, Chairman 1815 Jef f erson Street U.S. Nuc} car Regulatory Madison, Wisconsin 53711 Commission Washington, D.C. 20555 Judge Gary J. Edles, Ch airm an Atomic Safety and Licensing Mrs. Marjorie Aamodt Appe al Board R.D. #5 U.S. Nuclear Regulatory Coalsville, Pennsylvania 19320 i
Commission W.is h i ng ton , D.C. 20555 1
2 Robert Adler, Esq. Mr. Marvin I. Lewis Assistant Attorney General 6504 Bradford Terrace 505 Executive House Philadelphia, PA 19149 P.O. Box 2357 Harrisburg, Pennsylvania 17120 Louis Bradford Ms. Gail B. Phelps Three Mile Island Alert 245 West Philadelphia Street 325 Peffer Street York, Pennsylvania 17404 Harrisburg, PA 17102 David E. Cole, Esq. Mr. Robert Q. Pollard Smith & Smith, P.C. 609 Montipelier Street
[
2931 North Front Street Baltimore, Maryland 21218 Harrisburg, PA 17110 Jordan D. Cunningham, Esq. Counsel for NRC Staff Fox, Farr & Cunningham Office of Executive Legal 2320 North Second Street Director Harrisburg, PA 17110 U.S. Nuclear Regulatory Commission Thomas J. Germaine, Esq. Washington, D.C. 20555 Deputy Attorney General Division of Law - Room 316 George F. Trowbridge, Esq.
1100 Raymond Boulevard Shaw, Pittman, Potts &
Newark, New Jersey 07102 Trowbridge 1800 M Street, N.W.
Dr. Judith H. Johnsrud Washington, D.C. 20036 Dr. Chauncey Kepford Environmental Coalition on Docketing and Service Section Nuclear Power Office of the Secretary 433 Orlando Avenue U.S. Nuclear Regulatory State College, PA 16801 Commission Washington, D.C. 20555 Judge Reginald L. Gotchy Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Victor Gilinsky, Comuissioner John A. Levin, Esq. U.S. NRC Assistant Counsel Washington, D.C. 20555 Pennsylvania Public Utility Commission James Asselstine, Commissioner P.O. Box 3265 U. S. NRC Harrisburg, Pennsylvania 17120 Washington, D.C. 20555 John Ahearne, Commissioner U.S. NRC Washington, D.C. 20555
br. Steve Brooks MichaoI l*. Mcit r ido , 1:sy .
Public Information and I.ellocu I , I.a mb , i.eiby 6, Macitac Resource Center 1331 New Ilampshi ro Avenue , N.W.
1037 Maclay Street :uite 1100 lla r risbu rg , l'A 17103 W.ishington, 1) . C . 20036 Mr. llenry D. liukill Vice President CPU Nuclear Corporation P. O. Dox 480
. Middletown, PA 17057 June 3, 1982 /
Willialg::$. Jordan, III s
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