ML20099D256
| ML20099D256 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 11/15/1984 |
| From: | Hall D ILLINOIS POWER CO. |
| To: | PRAIRIE ALLIANCE |
| Shared Package | |
| ML20099D240 | List: |
| References | |
| CON-#484 OL, NUDOCS 8411200279 | |
| Download: ML20099D256 (20) | |
Text
'
~' -
- 3
1
- 1 >
- i 1 c j W RELAND CORRESPONdiliCC A
~
^
+E .
m ,
. DCCKEg -
-Il.:
k,
- m. -
. uw 4.9 i'. !
4 m o
_ - , , 1
- s .
~
- 5'ON ll2/19 p;p. - I
--UNITED: STATES.: OF. AMERICA -
-NUCLEARREGULATORYCOMMISSIONFrj6nr5{CN.Off '
~ SCcd[G.,;NCH--
- SEWO ,
t tN
- i. .
.s JIN THE MATTER OF. ) ,
- ^, - . '.
. ILLINOIS: POWER COMPANY, . 1) 4* SOYLTJiD POWER COOPERATIVE,1INC. )) -
'and WESTERN ILLINOIS' POWER 5 c)
COOPERATIVE,;INC.- .
-); -DocketiNo'.J50-46l'TOL' 1,*', .)- ' '
')/ (OperatingzLicense for Clinton )<
Powejr ? Station, ' Unitl) )' 7 NOTICE > 4 0- TO
-Hugh K. Clark, Esq., Chairman-lP.O. Box 127A:
-Kennedyville, Maryland 21645
~ '
=Dr. George A. Ferguson O- : School'of Engineering ~
Howard University .
2300 Sixth Street,-N.W.
Washington,'D.C. 20059.
Dr. Oscar.H. Paris 0 Atomic Safety and Licensing Board
-U.S. Nuclear Regulatory Commission Washington,'D.C.- 20555 ,
Executive Legal Director; United States Nuclear Regulatory Commission O Washington, D.C. 20555 s Allen Samelson Assistant Attorney General l- . ' '
Environmontal Control Division Southern Region-
'O- 500 South Second street
-Springfield, I111nois.62706
[^
. Jean Foy
, 511 West Nevada .
1 l
Urbana, Illinois 61801 O'
L i
f-
'O . o b b.
. .e
~ Prairie Alliance
- Box 2424 Station A' Champaign, Illinois.61820 c Fred Christianson U.S.-Nuclear Regulatory Commission, Clinton Power Station R.R. 3, Box 228 Clinton,_ Illinois 61727-D .;
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission
-Washington,-D.C. 20555 Atomic Safety and Licensing' Appeal Board Panel
) "U.S. Nuclear Regulatory Commission Washington, D.C. 20555 PLEASE"TAKE NOTICE that I have_today-filed with the.
Secretary of the United States Nuclear Regulatory Commission D the attached FIRST SUPPLEMENTAL RESPONSE OF ILLINOIS POWER COMPANY TO PRAIRIE ALLIANC3'S FIRST ROUND OF DISCOVERY. A copy of this' document is attached hereto and hereby served upon you.
D
/ QA h One of the Attorneys'for Applicants l
l Sheldon A. Zabel D Charles D. Fox IV Sara L. Johnson SCHIFF HARDIN & WAITE 7200 Sears. Tower 233 South Wacker Drive Chicago, Illinois 60606 D (312) 876-1000 Jack R. Newman
~
George L. Edgar
- NEWMAN & HOLTZINGER, P.C.
JD Suite 1000 1615 L Street, N.W.
Washington, D.C. 20036 (202) 955-6600 D
Dated November 15, 1984 D-
. g' . -
r., e ',3 3., . i .. . % y .c' ;-" . r ,. ._
.. y- _.; .w. . w s.,
y.. .. o ,r . , p. , .g .. c, , s
.,,u r. _- .- >. ,acep . , m;-
5 l'
p '
)
gggsPONDENCE 1:
BELNED Cwqn, um:[
UNITED STATES OF AMERICA
}' NUCLEAR REGULATORY COMMISSION; N,, 19 P1 :q IN THE MATTER OF ) LFft::E or u ..
ILLINOIS POWER COMPANY, ) DOCn E fj g ,; y p '
- _ SOYLAND POWER COOPERATIVE, )~ Docket No. 50-461NDL
} INC. and WESTERN ILLINOIS -)-
POWER COOPERATIVE, INC., )-
)
(Operating License for
~
)
. Clinton Power Station, )
Unit 1) -) i
'FIRST SUPPLEMENTAL ~ RESPONSE OF ILLINOIS POWER COMPANY TO PRAIRIE ALLIANCE'S FIRST ROUND OF DISCOVERY l
p Pursuant to Section 2.740(e) of the Rules of Prac-tice of the Nuclear Regulatory Commission, Illinois Power Company ("IP"), on behalf of itself, Soyland Power Coopera-D tive, Inc., and Western Illinois-Power Cooperative, Inc.,
the Applicants for an op'e rating license for Unit 1 of the Clinton Power Station, hereby further supplements through y September 30, 1984 its responses with respect to Conten-tion III (formerly Contention 6) provided in RESPONSE OF ILLINOIS POWER TO PRAIRIE ALLIANCE's FIRST ROUND OF DIS-D. COVERY, dated July 27, 1981, (the " Response"), as follows:
[ General Interrogatory #2. Provide documents, including research, studies, calculations, memoranda, correspondence, reports, diagrams, computer codes, and all other records, that p were relied upon by IP in answering the ques-tion, and also those which served as the basis for the answer. Identify the particular parts of such. documents that were used in formulat-ing the answer.]
D h
D ANSWER: Illinois Power will make available for inspection D
and copying the documents it relied upon in supplementing its
, responses _to these Interrogatories.
[ General Interrogatory #3. Identify by name,
[) title and qualifications the IP_ employee that has the expert knowledge required to support the answer to the question.]
ANSWER: The Illinois Power employees with the knowledge 9 necessary to. support the answers to the Interrogatories relative to this contention are:
- 1. John P. O'Brien (Interrogatories 1, 2, 3 and 9 6 (a) ) . Mr. O'Brien's title and qualifications are as stated in IP's prior Response, except that Mr. O'Brien obtained his M.B.A. degree from Illinois State University in 1983.
9 2. Dale L. Holtzscher (Interrogatories 1 and 3) .
Mr. Holtzscher's title l's Supervisor - Technical Assessment, and his qualifications are as follows:
9 Formal Education: B.S. Physics Western Illinois University, 1970 M.S. Nuclear Engineering University of Missouri, Rolla, 1972 9 Work Experience: Illinois Power Company 1981 - Present Supervisor - Technical Assessment, Nuclear Station Engineering Depart-ment 9 Supervisory responsibility for the Clinton Power Station independent safety review group. Responsible for the coordination of the TMI response program for Illinois Power.
9 9
9 Chairman of the. Licensing Review Group - II.
1978 - 1981
-Licensing Engineer,. Generation Engrg.
Dept.
Preparation of operating license application documents for the.Clinton D- Power Station. ' Responsible for.the coordination of the TMI response program for Illinois Power.
1975 .1978 -Generation Engineer, Generation Engrg. Dept.
Review of design and specifications for.Clinton Power Station. NSSS contract coordinator.
Other Experience: Northern Indiana Public Service O Company 1972 - 1975 Nuclear Systems Engineer Review of design and specifications
.for'Bailly Generating Station 9 Nuclear - 1.
- 3. Robert W. Hyndman (Interrogatory No. 5 (a)) .
Mr. Byndman's title is Supervisor - Computer Engineering and D his qualifications are as follows:
Formal Education: B.S. & M.S. Electrical Engineering University of Wyoming.
Wcrk Experience: Illinois Power Company 1983 - Present Supervisor - Computer Engineering Responsible for developing a computer engineering capability, establishing the necessary procedures and staff D
to support ine Clinton project.
D D.-
reeuri . __. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
O Other Experience 9- 1979 - 1983 Energy. Incorporated' Director of Process System Engineering.-
Responsible for the engineering, procurement,-fabrication listing and installation of computer base 9 process control. systems.
1976'- 1979 Magneto-Hydro Dynamics Montana-Energy Research and Develop-ment Institute. Assistant Director 9 of MHD' test facilities in Butte, Montana. Responsible for developing an Engineering. staff'to support construction, maintenance, operation and experiment testing of MHD compo-nents.
9 1963 - 1976 Argonne National Laboratory Supervisor of Experiment Programs.
Developed the necessary instrumenta-
-tion and. computer support personnel O to run the reactor (EBR II) experi-ment program.
1959 - 1963 General-Electric Staff engineer responsible for the 9 control system of the Nuclear Reactor Test Facility.
- 4. John G. Cr'% (Interrogatories 1, 3 and 5) .
Mr. Cook's title is Assistant Power Plant Manager and Acting 9
Plant Manager and his qualifications are as follows:
Formal Education: B.S. Engineering Physics University of Illinois, 1969 9 M.S. Nuclear Engineering University of Illinois, 1970 0
_4_
9
e, _
1, ~ jf , ~. ,
-o -
,y i
r M.B.A.
. Golden Gate University,?l976:
'j f e -
' Registered Professional Engineer,'
Ilinois,~1976..
ji ETraihings- CPSELicensed' Operator Training-Pro-
- gram -
(I! ' .;General;Ph' y sics Corp. Mitigating-
-1 Reactor Core Damage'Trainingi
? Work Experience:~ . Illinois Power, Company; "
L 1983 - Present: ; Assistant PowerJPlant Manager, Clinton '
- Power L S tation~. (Responsibilities _
~
() ~ '
include) overall'.. supervisioni of - the
- Operations, Chemistry and Radwaste Departments.at Clinton: Power. Station.
.. 1977 1983= : Supervisor -: Technical, Clinton;
()2 1 Power Station.:
-Supervised the.a'ctivities of the'
. Nuclear Results Engineers assigned
'to ClintonEPowernStation.
() - 1975 -11977' Training Coor'dinat'or Supe'rvised Training Instructors in:
the_ preparation of: training courses,
- interfaced with outside contractors-who were presenting training, taught 1
() courses related to the Clinton Sta-
-tion.
Other Experience: EU.S. Navy 1970 - 1975 Instructor U.S. Navy. Nuclear Power O School Taught. courses in heat transfer, reactor physics and core design to naval personnel.
()- . .[ General Interrogatory #4. Explain whether IP is presently engaged in ~or intends to engage
, Lin any further research or work which may 3- affect the answer..; Identify such research or work.]
(>f g
O 9-ANSWER: . Illinois Power.is continuously engaged in monitor-ing information that mayl affect the design, construction or operation' of thp' Clinton Power Station, ' including its control room. Unless otherwise noted, or unless new information indicates the need_for further investigation, IP does not plan to conduct further research which may affect the answers relative to_a particular interrogatory.
. [ General Interrogatory 'f 5. State the names, addresses,-titles, and qualifications of the l persons IP intends to call as witnesses or O .; experts _for the answer and the subject matter which they. intend to-testify about.]
ANSWER:' Illinois Power presently plans to provide its list of witnessen on Contention III on November 15, 1984 in a separate. filing. ,
[ General Interrogatory 46. Provide the com-puter codes, in machine readable source code, of any computer models or simulations relevant O to the question asked.]
ANSWER: Except as otherwise noted', Illinois Power has no computer codes relevant to Interrogatories 1, 2, 3, 5 and 6.
8 INTERROGATORIES
[1. Describe and provide IP's, BWR Owners.
Group's, and any other research and studies pertaining to the CPS central water level monitoring system.]
ANSWER: The primary studies prepared by the BWR Owners' Group. ("BWROG") on the BWR water level measurement system g - ( "WLMS " ) are contained in the two proprietary reports:
O
L f
Iz SLI-8211; " Review of BWR Reactor Vessel Water
' Level Measurement Systems," prepared by S. Levy, Inc., July 1982.
.SLI-8218; " Inadequate Core' Cooling Detection in Dolling Water-Reactors," prepared by
,j S.: Levy,LInc., November 1982.
'The first report is an in-depth evaluation offthe WLMS used for BWR/2 through BWR/6 product lines. This report g identifies several potential concerns.related to WLMS indica-tion accuracy 1during_ severe accident / transient' conditions and recommends modifications to enhance _ system capability.
g It further recommends that a plant; specific evaluation of the WLMS be performed to evaluate-the possible effect of each recommendation on each plant.
- g. The second' report evaluates the ability of the WLMS to detect inadequate core cooling ("ICC"), discusses alternative ICC detection devices, and provides a risk assess-g ment comparison of_the effectiveness of reducing core melt frequency for~ alternate ICC devices and the modified WLMS.
This report concludes that if the appropriate recommenda-
, tions of SLI-8211 are incorporated into the WLMS, following a-plant specific evaluation, then there is no significant additional risk reduction achieved by providing additional y and diverse ICC detection devices. .
The Nuclear Regulatory Commission ("NRC") has sponsored evaluations of the WLMS. One report, NUREG/CR-3652,
-s D
3
" Eval'uation of Instrumentation for Detection of Inadequate-Core Cooling in Bolling ~ Water Reactors," Oak Ridge National.
Laboratory - April 1984, concludes that_use of multiple, redundant cooling level measurements, with' overlapping ranges, can- be a ~ reliable basis ' for indication of approach' to an ICC condition when considered in correlation with the other l '. -
_ control and safety systems. The_NRC referred to another report, EGG-REP-6396 (proprietary) prepared under NRC contract by EG&G/ITI in'its evaluation of SLI-8211'and'SLI-8218.
.IP is currently finalizing its Clinton-specific evaluation of the WLMS. The Clinton WLMS design, as. modi-fled by the rerouting of sensing lines and relocation of ;
flow orifices, satisfies the recommendations of SLI-8211.
An interim report on the,Clinton-specific WLMS evaluation was issued to the NRC via the letter U-0749, dated October 10, l 1984.
[2. What has IP done to address the need for level monitoring to the dome in BWRs?
Provide relevant documents.]
ANSWER: The present CPS WLMS shutdown range monitoring devices i are capable of measuring reactor water level up to the dome of the reactor vessel.
[3.a. What instrumentation is proposed for 3 detecting inadequate core cooling in case of an abnormal occurrence? Provide relevant documents.]
b I -
S
q;
^
c ANSWER: IP' intends to utilize the reactor vessel WLMS, as described in CPS FSAR Sections 7.4 and~7.5, to determine the adequacy'of core cooling. The appropriateness of using,this system to detect inadequate core cooling is discussed-in the BWROG: Sponsored Report SLI-8218, " Inadequate Core Cooling Detection in. Boiling Water Reactors," prepared by S. Levy, Inc., November 1982.
[3.b. Has this instrumentation been tested?]
ANSWER: The WLMS to be used at CPS was developed by GE and.
, is typical of that used in currently operating BWRs. Operat--
ing experience and: testing demonstrated the instrumentation performance to be proper, accurate, and reliable.
[3.c. If so, describe and provide the test and 9 studies which have been conducted per-taining to the efficiency of this in-strumentation.]
ANSWER: Generic studies of the WLMS are described in response 9 to Interrogatory No. 1 related to this contention. A Clinton -
specific evaluation is also discussed in that response. The GE tests and studies concerning water level instrumentation 9 are not in the possession, custody, or control of Illinois ..
Power. They are in the possession of GE.
[3.d. Does IP plan on following the NRC's recom-mendation of further instrumentation, 9 specifically incorporation of core-exit thermocouples for BWRs? If so, provide l
the plan. If not, provide the documents and studies justifying IP's position, and all other relevant documents and
, studies.]
9:
i
)I ANSWER: IP~ understands that the NRC is still reviewing'the question'of core-exit thermocouplesDfor BWRs. In January of.
'1982, the BWROG agreed.to sponsor programmatic evaluations.
h .of BWR WLMS designs and-ICC detection and hardware. 'In July _ .
of 1982, the BWROG submitted the results of_its evaluation of BWR WLMS designs to the NRC in SLI-8211, entitled " Review i.
) of BWR Reactor Vessel Water? Level Measurement.Sirstems", which -
is' discussed in the Answer to Interrogatory No. l'above.
( The BWROG also_ sponsored preparation of'SLI-8218, f "
D' entitled " Inadequate Core Cooling Detection in Boiling Water Reactors", which is also discussed ~in the' Answer to Interro-gatory No. 1. SLI-8218 concluded that if_.the improvements D= to the WLMS identified in SLI-8211 were made and if adequate Emergency Procedures were provided to plant operators, then additional instrumentation to monitor for ICC would not be D warranted. ~
The NRC Staff has designated these issues as Unre-solved Safety Issue A-50, " Reactor Vessel Level Instrumenta-D- tion in BWRs". On October 26, 1984, the NRC issued a Generic Letter .(84-23) to all BWR licensees, which indicated the requirements for resolving this issue. IP fully satisfies D all requirements expressed in this letter.
[4.a. Will an accoustical monitoring system be used at CPS, pursuant to NUREG 0737 II.D.3?
g . .
p
=
[4.b. If so, how will this qualify as a direct
=
monitoring instrument? Provide docu-ments explaining the accoustical monitor-ing system and how it qualifies as a direct monitoring system, if it does.
[4.c. Have any studies been made to assure that reliability and accuracy can be maintained, given specific conditions of BWR, for instance, core vibration that could result in deterioration of devices and/or spurious signals? If so, describe and provide such studies. If not, ex-plain why not.]
n ANSWER: Since the portion of Contention III (formerly Con-tention 6) relating to acoustical monitoring has been with-drawn, Illinois Power will not update its response to this Interrogatory.
T5.a. What plans, if any, exist for providing a safety parameter display system for use in the main control room? Describe
, and explain any such plans.]
ANSWER: A Safety Parameter Display System ("SPDS") is planned for the CPS Control Room. The SPDS requirements, design and funct onal description are contained in the following docu-ments:
Safety Parameter Display System Requirements Document;
- Safety Parameter Display System Functional Description; and Safety Parameter Display Design Document (cur-rently being revised).
' iip
- The SPDS is befng implemented as a part of the Display Control and Performance Monitoring Systems ("DCS/PMS ")
-11_
m
__ . ,. . ~ , . . . . . . . . . . . . . . . _ . . . . , . -. . . . . ., . , . . . . . -
currently installed in the main control room. The DCS/PMS is the plant processing computer system. The Number 5 cathode ray tube in the NUCLENET (principal plant console) has been designated as the SPDS display.
Implementation of the SPDS display will be accom-plished by the installation of a permanent display in the DCS and an Alarm Initiated Display (" AID"), which will be _
automatically displayed on all nine NUCLENET DCS displays .
when an alarm of any AID parameter occurs. Radioactivity alert is indicated on the Number 5 cathode ray tube with the secondary information available from the Area Radiation Monitor / Process Radiation Monitoring System.
g The SPDS code, which is not complete, will be part of the DCS/PMS software. Detail programming is scheduled _
4 for completion by January '085, with testing and system inte-gration to follow. Flow diagrams for the SPDS modules are g ;
available in rough draft form for inspection.
[5.b. Provide a list of all meetings of BWR .
Owner's TMI Group and industry contrac-tors where control room design and in- '
O strumentation for CPS was discussed.
Provide the agendas for these meetings, ,
and the documents produced from these meetings.]
ANSWEP: A listing of the meetings of the BWR Owners' 'fMI Group and its Control Room Subcon.mittee held since IP previously ,
responded to this Interrogatory is set forth below:
0 O
[ CD 5
July 30, 1981 Committee Meeting f()
July 31, 1981 BWROG Control Room Committee Meeting August 26, 1981 BWROG Control Room Committee Meeting N with NRC kO Il August 12, 13, 1981 BWROG General Meeting ij October 20, 21, 1981 BWROG Control Room Committee Meeting b
l l November 18, 1981 BWROG Special General Meeting e0
_ January 20, 21, 1982 BWROG General Meeting b
kg February 25, 26, 1982 BWROG General Meeting r
E March 3, 1982 BWROG Executive Meeting 7 O E March 10, 1982 BWROG Control Room Committee Meeting
[- March 24, 25, 1982 BWROG General Meeting March 31, 1982 Control Room Improvement Meeting
[_
g O g May 12, 13, 1982 Control Room Improvement Meeting May 26, 27, 1982 BWROG General Meeting
~
July 20, 1982 Control Room Improvement Committee hO F
Meeting E August 4, 5, 1982 BVROG General Meeting August 19, 20, 1982 Control Room Improvement Committee
[
Meeting TO P September 28, 29, 1982 BWROG General Meeting T
October 14, 1982 Control Room Meeting F
$ November 4, 5, 1982 Control Room Improvement Meeting
- a. O k December 7, 8, 1982 BWROG General Meeting E
I gO E
W
3 January 12, 13, 1983 BWROG Control Room Improvement Commit-tee Meeting March 2, 3, 1983 BWROG General Meeting May 25, 26, 1983 BWROG General Meeting 9
August 10, 11, 1983 BWROG General Meeting October 18, 20, 1983 Control Room Design Review Training Meeting 9 October 26, 27, 1983 BWROG General Meeting January 25, 26, 1984 BWROG General Meeting March 28, 29, 1984 BWROG General Meeting
- May 3, 1984 Control Room Design Review May 4, 1984 Meeting with NRC on Task Analysis for Control Room Design Review June 6, 7, 1984 BWROG General Meeting 2
August 22, 1984 BWROG General Meeting
[6.a. Describe rully the planned instrumenta-tion for monitoring accident conditions.]
k) ANSWER: The planned instrumentation for monitoring accident
- and the Reg. Guide 1.97 compliance report dated September 9,
%i 1983. Illinois Power is completing the design and installa-f tion of the instrumentation changes required to comply with Reg. Guide 1.97, and is completing a plant specific ICC study, p; which is described in the interim report, IP letter U-0749,
- dated October 10, 1984.
[6.b. Provide documentation of in-house, in-dustry and contractor studies that relate 2
=
/
9.
to IP's compliance to NRC directives'of additional' instrumentation for' monitoring 0- accident conditions- (the installing.-of extended range monitors and improving.
post-accident sampling capability). . Pro-vide the substance of design changes.]
ANSWER: Illinois Power.will make available for inspection and copying the in-house, industry and contractor studies within its possession which relate to.IP's compliance with NRC directives of additional instrumentation for monitoring O
accident conditions.
-ILLINOIS R COMPANY O sy:;
D.P. Hall Vice President Sheldon A.'Zabel Charles D. Fox IV Sara L. Johnson O SCHIFF HARDIN & WAITE' 7200 Sears Tower Chicago, Illinois 60606 '
(312) 876-1000 Jack Newman C) George L. Edgar NEWMAN & HOLTZINGER, P.C.
' Suite 1000 1615 L-Street, N.W.
c, "*""!"l'"6686-Dated: November 15, 1984 O
O O
=
STATEbFILLINOIS ).
) ' SS
, . COUNTY.OF MACON )-
D. P. Hall, being duly: sworn, deposes and says that he=is Vice President-of Illinois-Power Company, one of the Applicants in this proceeding; that he-has read, or.~has knowledge of, the foregoing First Supplemental. Response of Illinois. Power Company to' Prairie Alliance's:First Round of Discovery; and'that the same are true and correct to the
, best of his knowledge, information, and belief.
I
=
D.P. Hall SUBSCRIBED and SWORN to before me- this /fd6 day of h ,vl a , 1984.
I y ,
kllM}A .- YblA oJ Notary Pablic WCoWon Expires N.In.h 7
b 1
M
w.
CERTIFICATE OF SERVICE ILhereby' certify that an original and two con-
~
3 formed copies of the foregoing document were served upon the following:
Secretary of.the Commission United States Nuclear Regulatory Commission
-)
~
Washington, D.C. 20555 Attention: Docketing and Service' Branch and that one copy of the foregoing document was' served upon each of the following:
']
Hugh K. Clark, Esq.,. Chairman P.O. Box 127A Kennedyville, Maryland 21645
) Dr. George A. Ferguson School of Engineering ,
Howard University
. 2300 Sixth Street, N.W.
Washington, D.C.
l ') . Dr. Oscar H. Paris l Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Executive Legal Director 9 United States Nuclear Regulatory Commission washington, D.C. 20555 Allen Samelson Assistant Attorney General Environmental Control Division 3 . Southern Region
! -500 South Second Street Springfield, Illinois 62706 Jean Foy 511 W. Nevada 3 Urbana, Illinois 61808 7 6
4h Prairie Alliance Box 2424
) StationA Champaign, Illinois 61820 Fred Christianson U. S. . Nuclear Regulatory Commission.
RR 3, Box 228 I Clinton,-Illinois 61727 Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D.C.1 20555 O Atomic Safety and Licensing
- Appeal. Board Panel U. S. Nuclear-Regulatory Commission Washington, D.C. 20555 in ea h-case by deposit in the United States Mail, postage B-prepaid-on November 15, 1984.
- W W&
One of the Attornsys fof-Applicants Sheldon A. Zabel g Charles D. Fox IV Sara L. Johnson SCHIFF HARDIN & WAITE 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 9 (312) 876-1000 -
Jack R. Newman George L. Edgar NEWMAN &'HOLTZINGER, P.C.
D Suite 1000 1615 L Street, N.W.
Washington, D.C. 20036 (202) 955-6600 D
D-