ML20070P814

Proposed Conclusions of Law for LWA-1 Proceeding.Certificate of Svc Encl

ML20070P814
Person / Time
Site:	Clinch River
Issue date:	01/24/1983
From:	National Resources Defense Council, Sierra Club
To:
References
NUDOCS 8301260401
Download: ML20070P814 (21)

Text

,.

s January 24, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD N'

/

Before Administrative Judges /f coa g Marshall E. Miller, Chairman 088Rc Gustave A. Linenberger, Jr. f-Dr. Cadet H. Hand, Jr. . i~ M N 2 4 fg g g k G s a l ) CD In the Matter of )

)

UNITED STATES DEPARTMENT OF ENERGY )

l PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537 i TENNESSEE VALLEY AUTHORITY )

)

(Clinch River Breeder Reactor Plant) )

)

)

t INTERVENORS, NATURAL RESOURCES DEFENSE COUNCIL, INC. AND THE SIERRA CLUB, PROPOSED CONCLUSIONS OF LAW FOR THE LIMITED WORK AUTHORIZATION (LWA-1)

PROCEEDING Pursuant to 10 CFR $2.754(a), and in accordance with the Board's rulings of December 17, 1982 and January 4-5, 1983, Intervenors, Natural Resources Def ense Council, Inc. and the Sierra Club, hereby submit their proposed conclusions of law for the limited work authorization (LWA-1) proceeding in the above-l captioned case.

l 8301260401 830124 S

/

PDR ADOCK 05000537 G

PDR Q

Based upon the foregoing Findings of Fact, Which are supported by reliable, probative and substantial evidence as required by the Administrative Procedure Act and the Commission's Rules of Practice, and upon consideration of the evidentiary record with respect to contentions 1, 2, 3, .4, 5, 6, 7, 8, and 11, the Board should conclude, as a matter of law, the following:

Contentions 1(a), 3(b) and 3 (d)

1. Staf f and Applicants have not met fully their burden of proof with respect to Contentions 1(a), 3(b) and 3(d). They have not demonstrated with reasonable assurance that the CDA should be excluded from the DBA envelope for purposes of assessing the suitability of the CRBR site at the LWA-1 stage. Conseqpently, i for purposes of assessing the suitability of the CRBR site under 10 CFR { 100.11, Applicants and Staff should assume that the CDA is a DBA.

2. Staff and Applicants have failed to provide reasonable assurance that their analyses of potential CRBR accident initiators, sequences and events are sufficiently comprehensive to assure that all CDAs should be outside the design basis envelope. Specifically, Staff and Applicants have fail (1 to analyze suf ficiently the reliability and associated failure rates of the major CRBR saf ety systems designed to prevent, terminate, and mitigate CRBR core disruptive accidents. Staff and Applicants have also failed to analyze sufficiently common mode

f ailures, hu: san error, and potential systems interactions and how they can initiate, exacerbate, or interfere with the mitigation of core disruptive accidents. As a result, Staff and Applicants have not provided reasonable assurance that the proposed site is suitable for a reactor of the general size and type as the CRBR from the standpoint of radiological health, as required by 10 CFR

$ 50.10(e).

3. According to Staf f 's and Applicants' current best e st ima te s, a CRBR core disruptive accident with an upper bound probability of approximately 10-5 per reactor year would most likely result in thyroid doses far exceeding the 10 CFR Part 100 dose guideli ne values. Thus, Staff and Applicants have failed to l demonstrate that the CRBR is reasonably likely to meet or even l

approach Staf f 's CRBR saf ety objective, that there be no greater than one chance in a million (10-6) per reactor year of a CRBR radioactive release with potential consequences greater than the 10 CFR Part 100 dose gr ldelines.

4. Staff and Applicants have failed to utilize all available information and review to date in determining whether the CDA should be within the design basis envelope, and have therefore 1

not provided reasonable assurance that the proposed site is suitable location for a reactor of the general size and type i proposed from the standpoint of radiological health, as required by 10 CFR 50.10(e).

1 i

1 Contentions 2, 3(c) and ll(d)

5. The analyses of CDAs and their conseqpences by Applicants and Staf f are inadequate for purposes of licensing the CRBR, performing the NEPA cost / benefit analysis , or demonstrating that the radiological source term for CRBR would result in potential hazards not exceeded by those from any accident considered credible, as required by 10 CFR $100.11(a), fn. 1.

6. Staff and Applicants have failed to demonstrate with suf ficient assurance that an individual located at the boundary of the CRBR low population zone, who is exposed to the radioactive cloud resulting from postulated fission product and fuel release (during the entire period of its passage) would not receive a radiation dose in excess of the guideline values specified by Sta f f for use in CRBR LWA-1 review, as requirad u nder 10 CFR $100. ll (a ) ( 2 ) .

7. Staff and Applicants have not provided reasonable assurance l

that their postulated fuel release f raction, or source term, bounds the releases f rom all credible accidents, as required by 10 CFR Il00.11(a)(fn. 1).

8. Staf f and Applicants did not use appropriately conservative assumptions in their site suitability analysis, as required by 10 CFR $100.2(b), in order to take into account the lack of experience with a reactor of the general size and type as the CRBR, which is novel in design and unproven as a prototype or pilot plant.

I

. l

9. The dose guideline values selected by Staff for use in the site suitability review are inadequate to prevent serious injury to individuals of fsite if an unlikely, but still credible, accident should occur, as required by 10 CFR Part 100.

10. Staff and Applicants have not demonstrated with reasonable assurance that the dose guideline values selected by Staff for use in the LWA-1 site suitability review are sufficiently conservative to take into account continuing uncertainty in plutonium dose and health eff ects models, as required by Commission precedent.

11. Staf f and Applicants have failed to demonstrate that CRBR is reasonably likely to achieve a level of safety comparable to current generation light water reactor plants, according to al.1 current criteria for evaluation.

12. According to S ta f f 's best est imates, the reliability of the CRBR auxiliary feedwater system is no better than 10-4 per reactor year. This level of reliability is unacceptable in terms of public health and safety. Florida Power and Light Co. (St.

Lucie, Unit No. 2), ALAB-435, 6 NRC 541, 543 (1977).

I

13. Staf f and Applicants have not performed a sufficiently searching, in-depth analysis of the environmental risks of CRBR core disruptive accidents as required by NEPA. NEPA requires agencies to ensure that the environmental impact statement contains suf ficient discussion of the relevant issues and opposing viewpoints to enable the decisionmaker to take a "hard i

l

~

i i

i l

look" at environmental f actors, and to make a reasoned decision. Kleppe v. Sierra Club, 427 U.S. 390, 410 n. 21 (1976);

Izaak Walton League v. Marsh, 655 F.2d 346, 371 (D.C. Cir. 1981);

Sierra Club v. Adams, 578 F. 2d 389, 393-6 (D.C. Cir. 1978). The agency must explicate fully its course of inquiry, its analysis, and its reasoning. If an impact sta tement is too vague, too general, and too conclusionary, it cannot form a basis for responsible evaluation and criticism. Environmental Defense Fund

v. Froehlke , 477 F. 2d 1033 (8th Cir. 1972).

14. In light of all the deficiencies outlined above, Staff's ultimate cost / benefit balancing under NEPA is arbitrary and capricious.

Contention 5(b)

15. Staff and Applicants have failed to meet the requirements of the National Environmental Policy Act, 42 U.S.C. ((4231 et seg. ("NEPA") in that they have not adequately analyzed the environmental impacts upon the Y-12 plant, and upon national security, of CRBR core disruptive accidents, particularly with regard to:

a. consideration of radiological consequences from the full spectrum of potential CRBR core disruptive accidents;

b. consideration of the extent and implications of ground contamination; and I

i 1

~7- <

c. consideration of the likelihood of evacuation of Y-12 personnel in cases whe(e potential exposure levels are below the Environmental Protection Agency Protective Guidelines.

16. Staf f and Applicants have not performed a suf ficiently searching, in-depth analysis of the impacts of CRBR accidents upon nearby facilities as required by NEPA. NEPA requires agencies to ensure that the environmental impact statement contains suf ficient discussion of the relevant issues and opposing viewpoints to enable the decisionmaker to take a "hard look" at environmental factors, and to make a reasoned decis ion. Kleppe v. Sierra Club, 427 U.S. 39 0, 410 n. 21 (1976);

I r.aak Walton League v. Marsh, 655 F.2d 346, 371 (D.C. Cir. 1981);

Sierra Club v. Adams, 578 F.2d 389, 39 3-6 (D.C. Cir. 1978). The agency must explicate fully its course of inquiry, its analysis, and its reasoning. If an impact statement is too vague, too gene ral, and too conclusionary, it cannot form a bas is f or re sponsible evaluation and criticism. Environmantal Defense Fund

v. Froehlke, 477 F. 2d 1033 (8th Cir. 1972).

17. In light of all the deficiencies outlined above, Sta f f ' s ultimate cost / benefit balancing under NEPA is arbitrary and capricious.

. Contention ll(b) and ll(c)

18. Staf f and Applicants have failed to comply with NEPA in their analyses of the somatic ef f ects associated with CRBR routine releases, in that their analysis fails adequately to consider and discuss in the environmental impact statement the substantial uncertainties surrounding its cancer risk estimator, as evidenced by the range of expert opinion regarding the appropriate cancer risk estimator value. Natural Resources Def ense Council, Inc. v. Nuclear Regulatory Commission, 68 5 F. 2d 4 59 (D.C. Cir. 1982).

Contentions 6(b)(1) and 6(b)( 3)

19. Staf f and Applicants have failed to meet the requirements of the National Environmental Policy Act of 19 69, 42 U.S . C.

Sections 4321 et seq. ("NEPA") in that their analysis of the environmental impacts of the fuel cycle associated with the CRBR f ails adequately to consider and discuss:

a. the potential impacts of reprocessing CRBR spent fu el at plants other than the proposed Developmental Reprocessing Plant; such as the Savannah River Plant, or the Hanford PUREX facility. Discussion of those alternatives, admitted by Applicants and Staf f to be reasonably foreseeable ones, must be searching, rather than superficial. Environmental Defense Fund v. Tennessee Valley Authority, 371 F.Supp. 1004, aff'd 492 F.?d 466 (D. Tenn. 1973); Sierra Club v.Froehlke, 359 F.

-9 Supp. 1289 (D. Tex. 1973). In its consideration of alternatives under NEPA, the agency must go beyond mere

~

assertions and indicate its basis for them, so that an informed and adequately explained judgnent is presented for review. Silva v. Lynn, 48 2 F . 2d 1282, 1287 (1st Cir.

1973). Staf f's obligation to consider the environmental impacts of alternative reprocessing f acilities is not i

satis fied by absolute reliance on Applicants' assertions and 1

commitments, without additional independent analysis. Sierra Club v. Alexander, 484 F. Supp. 455, aff'd 633 F. 2d 206 (N.D.N.Y. 1980);

b. uncertainties associated with radiological releases f rom the Development Reprocessing Plant, and with potential radiological releases from CRBR waste management" activities. NEPA requires an agency to disclose environmental costs -- including uncertainties concemaing such costs -- in a manner that proves to the public that the agency has properly considered the environmental costs of its action. National Resources Defense Council v. Nuclear i

Regulatory Commission, 685 F. 2d 459 (D.C. Cir. 1982);

c. the radiological impacts of accidental releases from reprocessing plants, both to the whole body and to other organs.

l l

l . __ ,_ _. - .-

. 20. Staff and Applicants have not performed a sufficiently searching, in-depth analysis of the environmental risks of the CRBR fuel cycle facilities as required by NEPA. NEPA re quire s agencies to ensure that the environmental impact sta tement contains suf ficient discussion of the relevant issues and opposing viewpoints to enable the decisionmaker to take a "hard look" at environmental factors, and to make a reasoned decision. Kleppe v. Sierra Club, 427 U.S. 390, 410 n. 21 (1976);

Izaak Walton League v. Marsh, 655 F.2d 346, 371 (D.C. Cir. 1981);

Sierra Club v. Adams, 578 F.2d 389, 393-6 (D.C. Cir. 19 78). The agency must explicate fully its course of inquiry, its analysis, i

and its reasoning. If an impact statement is too vague, too general, and too conclusionary, it cannot form a basis for responsible evaluation and criticism. Environmental Defense Fund

v. Froehlke, 477 F. 2d 1033 (8th Cir. 1972).

21. In light of all the deficiencies outlined above, Staff's ultimate cost / benefit balancing under NEPA is arbitrary and capricious.

Contentions 5(a) and 7(c)

I 22. The requirements of the National Environmental Policy Act of 19 69, 42 U.S.C. $ $4321 e t jggg. ("NEPA") and the Commission's rules concerning alternative siting analysis have not been met, in the following respects:

-11

a. Staff's alternative siting analysis accorded varying

, weights to the various factors from one site to at:other.

l This " floating weight" or " judgment" style of comparison does not afford confidence that the objectivity of the comparative analysis is legally sufficient.

b. Staff's interpre tation of NRC Regulatory Guide 4.7 --

that no consideration need be given to relative population

! densities for sites with densities below the 500 person per square mile trip level -- has no support in the Regulatory Guide itself or any other Commission rule or guidance. Quite the contrary, this view is flatly contradicted by the clear implications of the Reg. Guide and the Proposed Rule on Alternative Sites, FSFES Appendix K, which indicate that relative population densities below the 500/mi.2 trip level are significant and a valid basis for comparison.

c. Staf f's position that substantial relative diff erences (up to a f actor of 24) in overall radiological risks among I

sites (as measured by simultaneous consideration of population densities and atmospheric dispersion characteristics as a surrogate for radiological risk) can be considered insignificant because of its judgment that the absolute risk involved is sufficiently low, has no basis in law or Commission practice. The re is no authority for the j proposition that the alternative site analysis, which the Appeal Board has termed " the most important environmentally l

l

. .related task the staff has," Florida Power and Light Co. (St.

Lucie, Unit No. 2), ALAB-435, 6 NRC 541, 543 (1977); Bo ston Edison Co. (Pilgrim Nuclear Plant, Unit 2), ALAB-479, 7 NRC 774, 791 (1978), can be obviated with respect to radiological risk by a Staf f finding that the risk is low.

d. Under the Commission's 1976 decision in this case, if l any of the alternatives are "substantially better" than che Clinch River site considering environmental and institutional factors, this Board must reject the LWA-1 application for the proposed site. Similarly, if the analysis of alternative sites does not measure up to NEPA standards, the LWA-1 application currently in question must be denied. As the Appeal Board has stated, " Approval may not be given to an FES which treats in such a cavalier and misleading f ashion one of the most important questions which NEPA requires to be considered." St. Lucie, supra, 3 NRC at 840; Pilgrim, supra, 7 NRC at 782.

l e. Staf f 's alternative siting analysio does not satis fy the requirements of NEPA as a matter of law for the following l

re asons t I

i (1) Staf f treats all population densities below l

500/mi.2 as ' comparable", When in fact the re a re substantial actual diff erences (up to a factor of 5).

(2) Staff terms as "similar" atmospheric dispersion values for the various sites which actually

diff er by f actors of 2 to 6.

(3) Staff treats as " insignificant" diff erences in overall accident dose consequences (radiological risk) of up to a factor of 24.

l (4) Staff treats terrestrial impact advantages of alternative, already cleared and leveled s ites as unimportant.

(5) Staff treats aquatic and water quality impact advantages of sites on larger rivers as unimportant.

Thus, Staf f has systematically minimized or completely ignored any real advantages of the alternative sites, and maximized the importance of any disadvantages. Such an approach cannot constitute an alternative siting analysis sufficient to comply with NEPA.

1

23. Based on the Findings of Fact above, the Board should conclude, as a matter of law, that the Hartsville, Yellow Creek, Hanford, INEL, and Savannah River sites are all "substantially better" than the proposed Clinch River site considering all l

l relevant environmental and institutional f actors, and that the sought-af ter LWA-1 should not issue on that basis.

1 Contention 7(a) and 7(b)

24. The re quirements of the National Environmental Policy Act of 19 69, 42 U.S.C. ((4321 et seq. ("MEPA") and the Commission's rules concerning consideration of alternatives have not been met, in the following respects:

a. Litigation of the issue of Whether CRBR will meet its programmatic objectives in a timely fashion was explicitly determined to be within the scope of this proceeding by the Commission's 1976 decision in this case. (CLI-76-13, 4 NRC 67, at 78, 92). Staff's failure to consider Whether CRBR would meet its programmatic objectives in a timely fashion (as soon as possible) is in derogation of the Commission's 1976 decision.

b. Staff's treatment of the " timing objective" as primarily a means to exclude alternatives to the proposed action is an abuse of the timing factor Which renders the considerati3n of alternatives in this proceeding a nullity.

c. The weight to be accorded to the various f actors in any consideration of whether or not alternatives to CRBR are "substantially better" is not dicta ted by NEPA, Commission rules, or the Commission's 1976 decision in this case.

"Whether an alternative is a reasonable one -- or Whether it has been adeq:uately considered -- is in the end a matter of sound judgment dependent on the facts and circumstances of each s ituation. " Boston Edison Co. (Pilgrim Nuclear Plant,

f Unit 2), ALAB-479, 7 NRC 774, 779 (1978), citing Vermont Yankee Nuclear Power Corp. v. NRDC, 435 U.S. 519 (1978).

Based on the f acts and circumstances in this case, the ove r-arching weight which Applicants and Staff have given the timing f at' tor is an unwarranted distortion of the I

consideration of alternatives.

d. As a matter of law, a more complete and thorough steam generator testing program would be a "substantially better",

less risky alternative than the presently planned program.

Applicants' and Staf f's rejection of that alternative on the basis of their emphasis on the timing factor is an inappropriate distortion of the consideration of alte rnatives,

e. As a matter of law, inclusion of a core catcher in the CRBR design would be a substantially better alternative than not including that design feature in light of the likelihood and consequences of core melt accidents at CRBR. S taf f's assertion that a core catcher would not contribute much to the informational objectives because it would not be likely to be used is re j ec ted, since design, construction, and testing of a core catcher would provide informational benefits.

f. As a matter of law, inclusion of a no-vent containment / confinement system in CRBR would be a substantially better alternative than the proposed action in

l l

terms of reducing radiological conseqpences of accidents to the public.

g. As a matter of law, Sta ff 's analys.'.s of the economic feasibility objective is arbitrary and capricious, since Staff wrongly considers the actual cost of CRBR to be irrelevant to the question whether CRBR demonstra tes the economic feasibility of LMFBR operation in a utility environment. Staf f's test -- in which CRBR will have met its economic feasibility objective no matter how expensive -- is l

legally insuf ficient.

h. As a matter of law, Staf f's analysis of technical l performance and reliability objectives is insufficient.

Sta f f 's te st -- in which CRBR would be found to have met those objectives by providing infornation even if the plant were a technical failure (i.e. steam generator explosions or l highly energetic CDAs within the five-year demonstration period) is legally insufficient.

25. In its consideration of alternatives under NEPA, the agency must go beyond mere assertions and indicate its basis for them, so that an informed and adequately explained judgment is presented f or review. Silva v. Lynn, 482 F. 2d 1282, 1287 (1st Cir. 1973). The Staf f's obligation to consider the environmental impacts of alternative design approaches is not satis fied by absolute reliance on Applicar ts' assertions and commitments,

l

_17-without additional independent analysis. Sierra Club v.

Alexander, 484 F. Supp. 455, aff'd 633 F. 2d 206 (N.D.N.Y. 1980);

I Contentions,4 and 6(b)( 4)

26. The requirements of the National Environmental Policy T.ct i of 1969, 42 U.S.C. $$ 4321 et seq. ( "NEPA" ) have no t been me t, in l

l the following respects:

a. Staff's analysis does not support a conclusion that saf egua rds risks at the CRBR and associated fuel cycle f acili t L's are no greater than " comparable" licensed and unlicensed f acilities, in particular because Staff failed i adequately to examine risks throughout the CRBR fuel cycle.

b. Staf f has f ailed independently to analyze the submissions of Applicants, in violation of NEPA's requirements. Greene County Planning Board v. Federal Power Commission, 455 F.2d 412 (2d Cir.), cert. denied, 409 U. S .

8 49 (1972); Sierra Club v. Alexander, 484 F . Supp. 455, 466-67 ( N . D . N .Y . ) , aff ' d 633 F.2d 206 (2d Cir., 1980).

c. Staf f has f ailed to take into account all relevant costs in its cost / benefit balancing. See Sierra Club v.

Froehlke, 359 F. Supp. 12889 (W.D. Tex. 1973); Chelsea Neighborhood Association v. U.S. Postal Service, 516 F.2d 378 (2d Cir. 1975); Boston Edison Co. (Pilgrim Nuclear Power Station, Unit 2), ALAB-632, 13 NRC 91 (1981); 10 CFR Section i

St.52(c)(3).

l l

l

d. Staff's analysis of saf eguards risks and consequences has consistently understated safeguards risks and overstated the eff ectiveness of saf eguards programs and does not support a conclusion that safeguards risks and consequences for the CRBR and its supporting fuel cycle are reasonably low.

27. Staf f and Applicants have not performed a suf ficiently searching, in-depth analysis of the saf eguards risks of the CRBR and its associated fuel cycle f acilities as required by NEPA.

NEPA requires agencies to ensure that the environmental impact statement contains suf ficient discussion of the relevant ir. sues and opposing viewpoints to enable the decisionmaker to take a "hard look" at environmental f actors, and to make a reasoned dec is ion. Kleppe v. Sierra Club, 427 U.S. 39 0, 410 n. 21 (1976);

I Izaak Walton League v. Marsh, 655 F.2d 346, 371 (D.C. Cir. 1981);

Sierra Club v. Adams, 578 F. 2d 389, 39 3-6 (D.C. Cir. 1978). The agency must explicate fully its course of inquiry, its analys is, and its reasoning. If an impact statement is too vague, too gene ral, and too conclusionary, it cannot f orm a bas is f or responsible evaluation and criticism. Environmental Defense Fund

v. Froehlke, 477 F. 2d 1033 (8th Cir. 1972).

28. In light of all the deficiencies outlined above, S ta f f ' s ultimate cost / benefit balancing under NEPA is arbitrary and capricious.

CEPJfIFICATE OF SERVICE I hereby certify that copies of INTERVENORS' PROPOSED FINDINGS OF FACT AND INTERVENORS' PROPOSED CONCLUSIONS OF LAW FOR THE LIMITED WORK AUTHORIZATION (LWA-1) PROCEEDING were served this 24th day of January 1983 by hand

• and by first class mail upon: N y

/

• Marshall E. Miller, Esq. k sed Chairman 4 wmc Atomic Safety & Lic ising Board ~

~

U.S. Nuclear Regula .ory Commission J

~2 JAN 2 419n3 d 4350 East West Highway, 4th flood- '

j Bethesda, MD 20814 c mn +c. -n' c, .n G Gustave A. Linenberger sp/

" i~

Atomic Safety & Licensing Board _ Im U.S. Nuclear Regulatory Commission

( 4350 East West Highway, 4th floor Bethesda, MD 20814

• Daniel Swanson, Esq.

Stuart Treby, Esq.

Bradley W. Jones, Esq.

Office of Executive Legal Director U.S. Nuclear Regulatory Commission Maryland National Bank Building 7735 Old Georgetown Road Bethesda, MD 20814

• Atomic Safety and Licensing Appeal Board

[ U.S. Nuclear Regulatory Commission 1717 H Street, NW, Room 1121 Washington, D.C. 20555 l

• Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission 1717 H Street, NW, Room 1121 Washington, D.C. 20555

• Docketing & Service Section Of fice of the Secretary U.S. Nuclear Regulatory Commission 1717 H Street, NW, Room 1121 Washington, D. C . 20555 (3 copies) l

• Indicates hand delivery.

l

o Ccrtificats of Servics - 2

• R. Tenney Johnson, Esq.

Leon Silverstrom, Esq.

Warren E. Bergholz, Jr., Esq.

Michael D. Oldak, Esq.

L. Dow Davis, Esq.

Of fice of General Counse?

U.S. Department of Energy 1000 Independence Ave. , SW, Rm. 6A245 4

Washington, D.C. 20585

• George L. Edgar, Esq.

Irvin N. Shapell, Esq.

Thomas A. Schmutz, Esq.

Gregg A. Day, Esq.

l Frank K. Pe terson, Esq.

Morgan, Lewis & Bockius 1800 M Street, NW, 7th Floor

Washington, D.C. 20036 l

Dr. Cadet H. Hand, Jr., Director Bodega Marine Laboratory University of California

P.O. Box 247 Bodega Bay, CA 94923 l (Federal Express Mail)

Herbert S. Sanger, Jr., Esq.

Lewis E. Wallace, Esq.

James F. Burger, Esq.

W. Walker LaRoche, Esq.

Edward J. Vigluicci, Esq.

Office of the General Counsel Tennessee Valley Authority 400 Commerce Avenue l

Knoxville, TN 37902 William M. Leech, Jr., Esq.,

Attorney General William B. Hubbard, Esq.,

Chief Deputy Attorney General Michael D. Pearigen, Esq.

State of Tennessee Office of the Attorney General 450 James Robertson Parkway Nashville, TN 37219 Lawson McGhee Fablic Library 500 West Church Street Knoxville, TN 37219 l

I

e

~

Csrtificata of Scrvica - 3 William E. Lantrip, Esq.

City Attorney Municipal Building P.O. Box 1 Oak Ridge, TN 37830 Oak Ridge Public Library Civic Center Oak Ridge, TN 37820 Joe H. Walker 401 Roane Street Harriman, TN 37748 Commissioner James Cotham Tennessee Department of Economic and Community Develooment And rew Jackson Building, Suite 1007 Nashville, TN 32219

$ w Barbara A. Finamore d

. _ . _