ML20079F703

Response to First Set of Interrogatories Re Steam Generator Repair.Certificate of Svc Encl

ML20079F703
Person / Time
Site:	Three Mile Island
Issue date:	01/16/1984
From:	Bradford L THREE MILE ISLAND ALERT
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8401190174
Download: ML20079F703 (17)

Text

,

'h UNITED STATES OF AMERICA DOCHETED NUCLEAR REGULATORY COMMISSION US?!RC BEFORE THE ATOMIC SAFETY AND LICENSI$04 B&dhb8 A10 51 In the Matter of ) r ng g gg -

) , , . , ,

METROPOLITAN EDISON COMPANY ) Docket No. 50-289 7 ) (Steam Generator Repair)

(Three Mile Island Nuclear )

S tation,- Unit 1) )

TMIA RESPONSE TO FIRST SET OP NRC INTERROGATORIES On December 28, 1983, TMIA received a set of interrogatories and document requests - from the NRC, consisting of over thirty pages.

TMIA submits these responses a few day late due to the large number of duties and responsibilities which were required of TMIA during the preceeding three weeks, including not only discovery in the above captioned case, but also the ongoing " management" case, for which TMIA was required to present oral agrument before the Atomic Safety and Licenseing Appeal Board on January 11, 1984. TMIA apologizes for any inconvenience this may have caused the NRC Staff.

TMIA further states that Louise Bradford and Joanne Doroshow were the only individuals who participated in preparing this response, except where otherwise indicated. It is possible that technical assistance will be required to provide fuller responses at a later time, but this will be dependent largely on the cooperation of individuals who can offer free time and voluntary assistance, since TMIA has no funds to pay for expert help.

840119o174 840116

{DRADOCK 05000289 PDR g5 0

. . . - _ = . _ _

t Further, as explained to. Licensee in TMIA's response to its first set of Interrogatories, TMIA has not yet determined who its witnesses will be, if any, on any subject, or, what documents will be of fered as exhibits or used in cross-examination. Also, regarding the ability of TM1A to present witnesses on these contentions, it is very possible that the lack of funds and the inability to locate experts who can donate the required time necessary to prepare testimony will preclude TMIA from presenting an affirmative case on these contentions.

I Regarding the Request for Documents, TMIA will, as requested, cooperate with the NRC Staff to make its files on TMI-l steam generators available for inspection and copying, at a time designated.

TMIA will wait to hear from the NRC Staff as to time arrangements.

4 4

l l

i

Interrogatories

1. Specifically identify and describe in detail each technique for post repair and plant performance testing and analysis which TMIA contends would be adequate to provide sufficient assurance that-tube

-ruptures will be detected in time and prevented to avoid endangering the hbalth and safety of the public through the release of radiation into the environment beyond permissible limits.

~

At this time TMIA does not have available sufficient technical export-ise which would enable TMIA to identify adequate testing and analysis techniques as requested.

2. Specifically identify and describe in detail all empirical inform-ation for post repair and plant performance testing and analysis which TMIA contends would be adequate to provide sufficient assurance that tube ruptures will be detected in time and prevented to avoid

endangering the health and safety of the public through release of radiation into the environment beyond permissible limits.

See response to interrogatory 1.

3. Specifically identify and describe in detail all data evaluation for post repair and plant performance testing and analysis which TMIA contends would be adequate to provide sufficient assurance that tube a

ruptures will be detected in time and prevented to avoid endangering the health and safety of the public through release of radiation into the environment beyond permissible limits.

See response to interrogatory 1.

4. Specifically identify and describe in detail each proposed license condition for post repair and plant performance testing and analysis which TMIA contends would be adequate to provide suf ficient assurance that tube ruptures will be detected in time and prevented to avoid endangering'the health and safety of the public through release of radiation into the environment beyond permissible limits.

See response to interrogatory 1.

5. Specifically, what does TMIA contend makes the teqhniques used for post repair and . plant performance testing analysis inadequate to prov-ide sufficient assurance that tube ruptures will be detected in time and prevented.to avoid endangering the health and safety of the public through release of radiation into the environment beyond permissible limits?-

TMIA is unable at this time to identify and describe in detail the inf-

ormation requested because TMIA can not yet assess the adequacy of each I

of ;the techniques used, for post repair and plant performance testing i analysis. This is due to the failure of Licensee, NRC Staff, or nny of l

i their. consultants, to yet provide the detailed data re.luired to demon-i-

strate that there is reasonable assurance that tube ruptures can be detected in time and prevented.

6. Specifically, what does TMIA contend makes the empirical inform-ation' collected for post repair and plant performance testing and analysis inadequate to provide sufficient assurance that tube ruptures will be detected in time and prevented to avoid endangering the health and safety of the public through release of radiation into the envir-onment beyond permissible limits?

See response to interrogatory 5.

7. Specifically, what does TMIA contend makes the data evaluation for post repair and plant performance testing and analysis inadequate to provide sufficient assurance that tube ruptures will be detected in time and prevented to avoid endangering the health and safety of the public through release of radiation into the environment beyond permissible limits?

See response to interrogatory 5.

B. Specifically, what does TMIA contend makes the proposed license conditions for post repair and plant performance testing and analysis inadequate to provide sufficient assurance that tube roptures will be detected in time and prevented to avoid endangering the health and safety of the public through release of radiation into the environment beyond permissible limits?

TM IA is unable at this date to specif y and describe in detail the in-formation requested because TMIA can not yet assess the adequacy of each license condition proposed. This is due to the failure of Licensee, the NRC Staff, or any of their consultants, to yet provide the detailed data and analysis which would be required to demonstrate that the testing and analysis are adequate to provide assurance that tube ruptures will be detected in time and prevented to avoid endangering the health and safety of the public the u release of radiation into the environment beyond permissible limits.

9. What do you contend is the specific causal relationship between the number of tubes in both steam generators which have undergone the repair process, ands (a) the increased possibility of a simultaneous rupture in each steam generator which would result in release of radiation into the environment beyond p3rmissible levels;

_4-(b) the increased possibility of a simultaneous rupture in each steam generator which could lead to a sequence of events not encompassed by emergency procedures; and (c) the possibility of a simultaneous rupture in each steam

- generat6r which could create essentially uncoolable condition conditions.

TMIA is unable at this time to identify a specific causal relationship between the number of tubes in both steam generators which have under-gone the repair process and the possibility of the various scenarios outlined in this interrogatory. This is due to the failure of NRC Staf f, Licensee, or any of their consultants, to yet provide the detailed data and analysis which would be required to demonstrate whether and under what conditions the repaired tubes will rupture. However, TMIA does maintain that because of the uniguness and extent of the corrosion damage, tbo uniguness and deforming character of the repair method used, and the extraordinary large number of tubes which were repaired, there is a possibility of a simultaneous rupture in each stea.a gener-ator which could create essentially uncoolable conditions.

10. S peci f ica lly , to what " scenario" do you refer in your Contention 1.b.? To what specific '.' sequence of events" do you refer in your Contention 1.b.?

S pecif ically , in this contention TMIA is referring to a simultaneous tube rupture in both steam generators, which would force the operator to accomplish cooldown and depressurization using at least one faulted steam generator.

11. Explain in detail the basis for your contention that, as a result of the kinetic expansion process, a simultaneous tube rupture in both steam generators in not "an incredible event."

As of this date the primary basis for this contention is a memo fron former ACRS Chairman Paul Shewmon to Ray Fraloy dated 19 September, 1982, in which he states "It isn't an incredible event for this plant, and it seems to me that it might present the operators with at least a challenge the Subcommittee could look into." This interpretation was confirmed by Richard Major in a meme to D. Moeller , Chairman ACRS

_5_

Subcommittee on TMI-1, dated 30 September, 1982, and became a concern of Chairman Edward Markey, Subcommittee on Oversight and Investigations, llouse Interior Committee in correspondence to the Commission dated 21 Janua ry , 1983 and 23 March, 1983. And the useability of plant " guidance proced ures , and training" for multiple tube ruptures, with no noted distiction between ruptures in one or both steam generators, was also recognis6d as a concern of Licensee's Third Party Review Group's analysis. See February report at page 4-5. TMIA is unable to assess the adequacy of Licensee's post repair and plant ' performanc6 testing upon which the TPRG reli6t!' to resolve the issue of multiple tube ruptures. This is due to a failure of NRC Staff, Licensee, or any of their consultants, to yet provide the datailed data and analysis which would be required to demonstrate that multiple tube ruptures, as a result of the corrosion and subsequent kinetic expansion, is an incred-ible event.

12. In subpart (3) of your Contention 1.b., you refer to a LOCA (loss of coolant accident). Is the LOCA to which you refer a LOCA caused by a simultaneous rupture at is the LOCA a separate LOCA, other than a simultaneous rupture? If it is the latter, please identify the nature of the LOCA referred to.

The LOCA we refer to in this contention is a LOCA caused by a simult-aneous tube rupture.

. 13. With respect to your Contention 1.b. , on what probability assessment if any, is your contention based? If it is not based on any probability j assessment, do you contemplate conducting one, and if so, provide i particulars as to who will be conducting it and when it will be finished.

TMIA has conducted no probability assessment , nor at this time do we i

contemplate conducting such an assessment. The basis for contention 1.b.,

is stated in our response to interrogatory 11.

l 14.. With regard to your Contention 1.c. , explain in detail what it is l about the types of plugs used that supports your conclusion that plant l operation with the as-repaired steam generator cannot be conducted without endangering the health and safety of the public and specify the basis for this position.

l l

l l

-h-TMIA is unable at this time to explain in detail the information requested because TMIA cannot yet assess the adequacy of the types of plugs used to perform their intended purpose. Absent information which' would allow TMIA to adequately assess the plug retention ability, TMIA is unable to supply the information requested.

15. With regard to Contention 1.c., explain in detail what it is about the number of tubes requiring plugging that supports your conclusion that plant operation with as~ropaired steam generator cannot be conducted without endangering the health and safety of the public and specify the basis for this position.

See response to interrogatory 14.

16. With regard to Contention 1.c., explain in detail what it is about the choice of tubes to be plugged, including failure to plug 66 degraded tubes, that supports your conclusion that plant operation with the as-repaired steam generator ,cannot be conducted without endangering the health and safety of the public and specify the basis for this position.

TMIA is unable at this time to explain in detail the information requested because TMIA cannot yet assess the adequacy of the kinetic expansion repair process particularly as it impacts on the ability of subsequently plugged tubes to perform. With regard to the 66 degraded tubes which have defects less than 40% thruwall, the TPR analysis recommends that these tubes be plugged. In addition there is evidence that despite Licensee's claim that the /1. . . pl of the system will be maintained within the desired range by the addition of ammonium hyd-roxide.",. crack growth may continue. " Highly acidic crack tip envir-

onments are often found, even when the bulk solution is neutral ."

See, Knott, J.F., The Fundamentals of Fracture Mechanics, John Wiley

& Sons , 1973; p.263.

17. Explain in detail the interference which you contend the plugged tubos will have in the plant's ability to respond to transients and accidents and specify the basis for this position. Identify each such transient of accident for which you allege the plant 's ability to respond will be interfered with.

TMIA is unable at this time to explain in detail the information requ-ested because TMIA cannot yet assess the adequacy of the kinetic

expansion repair process particularly as it impacts on the ability of subsequently plugged tubes to perform.

18. Do you contend in Contention 1.d. that " Report of Third Party Review of Three Mile Island, Unit 1, Steam Generator Repair" and NUREG-1019 are inconsistent within themselves or between themselves, or both?

TMIA contends that the TPR and the SER are inconsistent between them-solves.

19. Identif y each of t' contended " inherent inconsistencies" referred to in Contention 1.d. Ex tain in detail how each of these " inherent inconsistencies" render incredible Licensee's and S taf f 's evaluations of the kinetic expansion repair technique. Provide all, facts which support your contention that the conclusions of these reports are affected..

Until TMIA receives responses to its first set of interrogatories andrequest for production of documents, it will be unable to identify all of the inconsistencies. Ilowever, examples of the types of incon-sistencies TMIA has already detected are as follows:

-- The TPR analysis supports the proposition that a " break bef ore lea k" under certain situations is possible and an acceptable scenario, Attachment 6 at p. 17-18. This is not recognised in the SER , and is e

inconsistent with the SER conclusions.

--The TPR analysis recognizes that the changed strength and dimensions of the expanded tubes is an important effect, Attachment 6 at p. 15, but seems to dismiss without revealing the basis for doing so. There is no evidence in the SER that this effect is recognized and analy 2bd.

-- The TPR analysis recommends that tubes with lesi than 40% thruwall depth should be plugged. Attachment 6 at p. 6. The SER fails to discuss this recommendation, and is inconsistent with the SER conclusions.

-- The TPR analysis finds it hard to substantiate a firm conclusion that defects below a certain size range will not propagate due to flow-induced vibrations. Attachment 6 at p. 16-17. This is not recognized in the SER , and is inconsistent with the SER conclusions.

-u-

-- The TPR analysis recognizes the importance of understanding the effects of multiple tube ruptures, Attachment 6 at p. 4-5. This is not analyzed as a seperate issue in the TPR itself, or in the SER.

19. Identify each of the contended " inherent inconsistencies" referred to in Contention 1.d . Explain in detail how each of these " inherent inconsistencies" render incredible Licensee's and Staff's evaluations of the kinetic expansion repair technique. Provide all facts which support your contention that the conclusions of these reports are affected.

4 See response to interrogatory 18.

20. Explain in detail how the use of axial symetric stress analysis renders incredible Licensee's and Staf f's evaluations of the kinetic expansion repair technique and specify the basis for this position.

In September of 1983 representatives of TMIA spoke with Dr. George Sih, Director , Institute of Fracture and Solid Mechanics, Lehigh Oniversity, at that time Dr. Sih told us that the most dangerous d i rocl i on for cracks to run may not necessarily be in a direction normal to axial symetric stress.

21. With regard to Contention 1.d., what do you contend to be the difference between toughness and hardness? Explain in what ways you contend the Staf f's SER conclusions are af f ected by this dif ference. .

While hardness can be defined as the " resistance of a metal or other material to indentation, scratching, abrasion, or cutting," see, the McGraw-Hill Dictionary of Scientific and Technical Terms, 2d Ef. 1974, "the resistance of a material to rapid crack propagation is said to be a material's ' fracture toughness' and may be said to control failures by fast fracture, [or cracking]... See, Knott J . F . , The Fundamentals of Fracture Mechariics, John Wiley & Sons, 1973, introductory chapt ers.

k As can readily4seen from these definitions, toughness is the critical test with regard to crack propagation.

s

23. Explain in detail how the failure to analyze crack resistance on the basis of toughness as opposed to hardness renders incredible Licensee's and Staf f 's evaluations of the kinetic expansion repair technique and specify the basis for this position.

See response to interrogatory 21.

_9_

24. Explain in detail how failure to differentiate in its analysis between the effects of thermal stress on small versus large cracks renders incredible Licensee's and Staff's evaluations of the kinetic expansion repair technique and specif y the basis for this position.

TMIA representatives were told by Dr. Sih that under thern..1 stress small cracks are more likely to propagate than large c' racks oecause small cracks store more energy proportionate to their size than large cracks.

25. Set forth in detail the basis for your contention that there is no assurance that the source of initiation of corrosion has been properly identified and state specifically why the Staf f's SER and attachments thereto do not provide such assurance.

At pages 7-8 of the SER, the Staff concludes, without support, that "

"the sodium thiosulfate concentration of 4-5 ppm is the contaminant which 'most likely' caused the OSTG degradation", yet states at page 8 that the failure scenario has not been clearly established, and recognizes three previous contaminations which may have caused corrosion. The Staff also fails to deal with comments from its own consultants challenging aspects of this conclusion, such as Mr .' Dillon's comment at pige 12 of his report regarding " inconsistencies in the cracking environments," which "certainly invite questions," ignores his concerns about contradictions regarding the cracking solution chemistry, and rejects Mr. Dillon's stiggestion at page 29 of the SER that a corrosion test be conducted in a cold, high oxygen and high concentration sulfate environment. The Staff also fails to deal with Mr. Macdonald's comments at pages 18-24 of his report where he does not rule out other corrosion possibilities, stating that another polysulfer species must be present in the system, that thiosulfate could have been introduced in the system sometime earlier than September, 1981. Thus while acknowledging that the failure scenario is s peculative, the Staff ignores questions raised by their own consultants, and while recog-nizing inconsistencies, concludes with no supporting analysis that they are irrelevant concerns. See GER at page 7-8.

10-

26. Set forth in detail the basis for your conclusion that there is no assurance that the source of initiation of corrosion has been properly identified and state specifically why the data in the Staf f's SER and attachments thereto do not provide such assurance.

See response to interrogatory 25.

27. Set forth in detail the basin for your contention that ,there is no assurance that the conditions under which initiation oricf nal occurred have been properly identified and stato specifically why the Staf f's SER and attachments therto do not provide such assurance.

See response to interrogatory 25.

28. On what specific evidence do you rely for contending tht.t the risk associated with cleaning is a " substantial risk"? Define " substantial risk."

TMIA has relied upon the report of Staff consultant Mr. Dillon as the basis for its contention that the rist associated with cleaning is a substantial risk. At page 12 of his report Dillon states "The risk of cleaning is that a relatively large inventory of sulfur compounds (5 5

ppm or more) will be put into solution. Some significant fraction of the sulfur attached to primary system surfaces is in a reduced form-sulfide or free sulf ur. During oxidation of the sulfur / sulfide to sulfate, intermediate oxidation states will be involved, some of which are likely to be crack inducing species. Axial stress levels in the tubes will be high at the proposed cleaning process temperature.

The conditions for IGSCC are present if the necessary sulfur species are present."

29. What specific evidence do you rely on for contending that the risk associated with simply "living with a large S inventory in the system" is a " substantial risk"?

See Dillon report at page 13: "There are possible hazards in leaving sulf ur in the oxides. Some coolant chemistry condition could rapidly and unexpectedly put sulfur in solution where it might escape early detection."

i

30. . What specific inadequacies. do you believe exist in the cleaning proceas as applied, the post-cleaning testing program or the results of the' cleaning process and post-cleaning testing as reflected in TR-008 and NUREG-1019? +

31. .What specific evidence do you rely on to chal$enge the results of the cleaning process and post-cleaning testingas-reflected in TR-008 and NUREG-1019? s

32. What specific inadequacies do you believe' exist in t'he cleaning process as applied and/or in the conclusion' of TR-008 and NUREG-1019 regarding steps taken to ensure that reinitiation of corrosion will not-occur? '

At this time TMIA is unable to identify all inadequacies of the

'k cleaning process and the post-cleaning testing. This is due to 'the failure of the NRC Staff, Licensee, or any .of their consultants,. to l yet' provide the detailed data and analysis which would be requised g i

to demonstrate that there is reasonable assurance that the cource.

of the corrosion has been properly identified and eliminated, llowever, there are specific examples of the idadequecies of the el aning process and the post-cleaning testing contained withini th SER and TR-008 In its supplement to the SER at 14, the taff,comes to the conclusion that flushing of pipes less than 1-inch diameter,'isinot warranted. Licensee's'TR-008 at 30 states "The lower. limit for lithium r

• was increased from .2 ppm to 1.0 ppm. This was done becauseg litihium -

d may have - an inhibiting effect on crack initiation and propagation."

(emphasis added) There is no discussion regarding post-cleaning tests.

which would support a conclusion that the addition of lithium to the !-

coolant has had an inhibiting effect on the borr6 dent, particularly at , ; ,7 the crack' tip, .this is significant, . especially since the Licenee has not stated the length of the cracks with less than 40% thruwait indications which both Licensee and NRC Staff have ebncludedineed ll "

not

' ^

be removed from service, I -

ll4 t

t i

a ,

i, '

'o

' (

33. In what specific ways do you contend that the Report of the Third Party Revies and/or NUREG-1019 are not " credible documents in their

- evaluation of the causative agent, clean up, or procedures to prevent contaminant reintroduction. . ."? Specif y the basis for your position.

The staff is unable to state unequivocaly that administrative contro11s will prevent the introduction of foreign chemicals into the RCS.

NUREG-1019; See also above response.

34. What specific " inherent inconsistencies" do you contend exist between the Report of the Third Party Review and NUREG-lG19? What do you contend to be the significance of each such alleged inconsistency?

See response to interrogatory 19,

35. What specific " basic assumptions and conclusions" do you contend "ruat improperly on axial symetric stress analysis"?

Licensee and TPRG have relied on an axial symetric stress test conducted by EPRI as a basis for their " leak before break" theory, however, the EPRI analysis is flawed in that it relies on a limited data base. TMIA can find no evidence in the documents of other stress tests having been conducted. See, TR-008 at 6 and 10; SER, Attachment 6, at 17.

36.- What specific evidence do you rely on for contending that axial symetric stress analysis would not be applicable to all cracks?

See response t'o interrogatory 20.

't 13 7 . -With regard to Contention 2.c., what do you contend to be the dif ference between toughness and hardness? Explain in what ways you

!T, contend the Staf f's SER conclusions are af fected by this dif f erence.

See response to interrogatory 21.

38. What specific inadequecies do you contend result from "the failure to analyze crack resistance on the basis of toughness as opposed to

^^ hardness"?

~

Toughness is the critical test with regard to rapid crack propagation, therefor the probability of tube failure by fast fracture cannot be assessed.

39. What specific evidence do you rely on for contending that

" hardness ....has no relation to crack resistance" e

liardness is defined as the " resistance of a metal or other material to indentation, scratching, abrasion, or cutting," see, the Mcgraw-

' hill Dictionary of Scientific and Technical Terms, 2d Ed. 1974,

_13_

clearly toughness is the better test for determining the tube resistance to cracking.

40. Where specifically in the Report of Third Party Review do you contend there is a "f ailure to dif f erentiate. . . betwee the effects of th'ermal stress on small versus large cracks"? What do you contend _

to be the specific consequences of this alleged failure? What specific evidence do you rely on to support this aspect of you contention?

TMIA notes that the TPR fails to address the issue of thermal stress on stress on small versus large cracks and given Dr. Sih's theory on small versus large crack behaviour, TMIA finds this failure to be a serious inadequacy of the TPR.

22. Identify by page number each place place in the Staf f's SER where fou believe crack resistance is analyzed on the basis of hardness as opposed to toughness.

TMIA has observed that the SER very little information on any of the taats which were performed on the tubes and relies on summaries of tests performed by Licensee and Staf f consultants to support the conclusions of the SER, for this reason TMIA cannot provide the inf-ortiiallon requested .

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In tha Matter'of , )

)

METROPOLITAN EDISON COMPANY j Docket No. 50-289

) (Steam Generator Repair)

(Three Mile Island Nuclear Station, Unit.1) )

AFFIDAVIT OF LOUISE BRADFORD I, Louise Bradford, being forst duly sworn, deposes and says that:

1. I'am one of two volunteer members of Three Mile Island Alert, Inc., who represent that organization as an -intervening party in the above-captioned action.

2. I have read the foregoing responses to interrogatories, and' the same are true to th best of my knowledge.

t O

[oniLA LOUISE BRADFORD

[/

m DATED: 16 January, 1984 Sworn and subscribed before me on this 'to d day of January, 1984.

- mfb if1A / ~'

ld NOTARY PUBLIC, h,ts:ca f! E . Fe, !btw Pi&Ee u, (cm:s tra L%a f ,:cos s ,n36 iMhw#4._ M M

UNITED STATES OF AMERICA NOCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

l CERTIFICATE OF SERVICE I hereby certify that copies of the attached TMIA RESPONSE TO FIRST SET OF NRC INTERROGATORIES dated January 16, 1984, j we, 9 served this.16th day of January, 1984, by deposit in the U.S. Mail, first class, postage prepaid, or hand l

delivered where possible, to those on the attached service list.

LOUISE BRADFORD jV

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION-Before the Atomic Safety and Licensing Board In the Matter of )

)

METROPOLITAN EDISON COMPANY, ET AL. ) Docket No. 50-289-OLA

) ASLBP 83-491-04-OLA (Three Mile Island Nuclear ) (Steam Generator Repair)

Station, Unit No. 1) )

' SERVICE LIST Sheldon J. Wolfe> ,

Administrative Judge Chairman, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Docketing and Service Section Washington, D.C. 20555 Office of the Secretary U.S. Nuclear Regulatory Commission Dr. David L. Hetrick Washington, D.C. 20555 Administrative Judge _

Atomic Safety and Licensing Board ,

Professor of Nuclear Engineering George F. Trowbridge, Esq. ,

University of Arizona Shaw, Pittman, Potts & Trowbridge Tucson, Arizona 85271 1900 M St., N.W.

Washington, D.c. 20036 Dr. James C. Lamb, III Administrative Judge Jane Lee Atomic Safety and Licensing Board 183 Valley Road 313 Woodhaven Road Etters, Pennsylvania 17319 Chapel Hill, North Carolina 27514 Norman Aamodt Richard J. Rawson, Esq. R. D. 5, Box 428 Mary E. Wagner, Esq. Coatesville, Pennsylvania 19320 Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 2055S t

_ _ _ _ _ . _ _ _ _ _ _ . . _ _