ML20211D230

Proposed Findings of Fact & Conclusions of Law in Form of Suppl to Fourth Partial Initial Decision Re Remanded Contention Concerning Manpower Mobilization at Graterford. Certificate of Svc Encl

ML20211D230
Person / Time
Site:	Limerick
Issue date:	10/16/1986
From:	Vogler B NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:
References
CON-#486-1166 OL, NUDOCS 8610220142
Download: ML20211D230 (18)

Text

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o se a ll G C 000KETED U3tlRC UNITED STATES OF AMERICA '

NUCLEAR IlEGULATORY COMMISSION '86 0CT 20 P4 :17 BEFORE THE ATOMIC SAFETY AND LICENSINGtBOARD - '

O L ..ip;.s., -

In the Matter of )

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PIIILADELPHIA ELECTRIC COMPANY ) Docket Nos. 50-352

) 50-353' O b (Limerick Generating Station, )

Units 1 and 2) )

NRC STAFF'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE FORM OF A SUPPLEMENT TO THE FOURTH PARTIAL INITIAL DECISION RELATING TO THE REMANDED CONTENTION REGARDING MANPOWER MOBILIZATION AT THE STATE CORRECTIONAL INSTITUTION AT GRATERFORD The NRC staff, pursuant to 10 C.F.R. I 2.754 and this Licensing Board's Order of September 22, 1986 (Tr. 21,568-569), hereby transmits its Proposed Findings of Fact and Conclusions of Law in the form .of a partial initial decision as styled above.

Respectfully sulmitted, njamin H. Vogler Senior Supervisory Trial Attorney Dated at Bethesda, Maryland this 16th day of October,1986 8610220142 861016 PDR ADOCK 05000352 G PDR DESIGnTEDORIGINAIl{

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e UNITED STATES OF AMERICA i

NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

PIIILADELPHIA ELECTRIC COMPANY ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, .)

Units 1 and 2) )

l 4

NRC STAFF'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE FORM OF A SUPPLEMENT TO TIIE FOURTH PARTIAL INITIAL DECISION RELATING TO THE REMANDED CONTENTION REGARDING MANPOWER MOBILIZATION AT THE STATE CORRECTIONAL INSTITUTION AT GRATERFORD Joseph Rutberg Deputy Assistant General Counsel Benjamin H. Vogler Senior Supervisory Trial Attorney October 16, 1986

/

UNITED STATES OF AhERICA -

NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD BEFORE ADMINISTRATIVE JUDGES:

Helen F. Hoyt, Chairperson Dr. Richard F. Cole Dr. Jerry Harbour In the Matter of )

)

PHILADELPHIA ELECIRIC CD1PANY ) Docket Nos. 50-352-OL

) 50-353-OL (Limerick Generating Station, )

Units 1 and 2) )

) October 16, 1986 i

APPEARANCES

' Robert M. Rader, Esq. , and Nils N. Nichols, Esq. , of Conner &

i Wetterhahn, P.C. , Washington, D.C. for Philadelphia Electric Company.

Joseph Rutberg, Esq. and Benjamin H. Vogler, Esq., Office of the General Counsel, U.S. Nuclear Regulatory Commission, Washington, D.C.,

for the NRC Staff.

Theodore G. Otto, III, Esq. , Pennsylvania Department of Corrections, Camp Hill, Pennsylvania, for the Commonwealth of Pennsylvania.

Michael Hirsch, Esq., Office of the General Counsel, Federal Emergency Management Agency, Washington, D.C. , for FEMA. .

Angus R. Love, Esq., Montgomery County Legal Aid Service, Norristown, Pennsylvania for the Inmates of the State Correctional Institution at ,

Graterford, Pennsylvania. j l

i l

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

)

PIIILADELPHIA ELECTRIC COMPANY ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

NRC STAFF'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE FORM OF A SUPPLEMENT TO THE FOURTH PARTIAL INITIAL DECISION RELATING TO THE REMANDED CONTENTION REGARDING MANPOWER MOBILIZATION AT THE STATE CORRECTIONAL INSTITUTION AT GRATERFORD s

I. SCOPE OF DECISION This Supplement to the Fourth Partial Initial Decision (PID) address-es the remanded contention on manpower mobilization at the State Correc-tional Institution at Graterford (SCIG) in the event of the need for an evacuation because of an emergency at the Limerick Generating Station (LGS). On the basis of the record before it, the Board, in the context of the litigated contention, concludes that there is reasonable assurance that, in the event of a radiological emergency at the Limerick Generating

Station that requires the evacuation of the SCIG, the call-up system will l

achieve its designated purpose to notify off-duty security personnel need-a

ed to implement the evacuation.

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II. BACKGROkJNI)

On August 28, 1986, the Atomic Safety and Licensing Appeal Board (Appeal Board) issued ALAB-845,1 ~ In ALAB-845, the Appeal Board decided the appeals of the Inmates from the Licensing Board's Fourth PID - and the Licensing Board's earlier rejection of some of the Inmates proffered contentions. 3_/ The Appeal Board affirmed the Fourth PID in all respects except for its rejection of the Inmates' contention concerning manpower mobilization. This one contention was reversed and remanded to the Licensing Board for further consideration. The Inmates revised manpower mobilization contention alleges that:

[t]here is no reasonable assurance that the call up system to be utilized in the event of a nuclear emergency in order to mobilize the entire work force of the State Correctional Insti-tute [ sic] at Graterford will achieve its designated purpose.

Proposed Revised Contentions (May 13,1985) at 2.

In the event of an emergency requiring evaucation, the SCIG Radio-logical Emergency Response Plan (RERP) provides for the mobilization of '

its off-duty employees through a pyramiding telephone call-up system.

According to the Inmates' contention this plan could fail if the commercial telephone lines become overburdened during an emergency and thus limit the SCIG's ability to carry out its manpower mobilization plan. In sup-port of their contention the Inmates noted the previous testimony of Richard T. B rown , Chairman, Lower Providence Township Board of Su-1/ Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2), ALAB-845, 24 NRC (August 28, 1986).

-2/ Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2), LBP-85-25, 22 NRC 101 (1985).

3/ Licensing Board Order of June 12,1985 (unpublished), reconsidera-

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tion denied, Licensing Board Order of July 2, 1985 (unpublished).

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pervisors, who stated that during a past ' emergency (Hurricane Agnes),

the local commercial telephone network was overburdened and its service impaired. Tr. 18,149-150.

In the opinion of the Appeal Board:

The contention clearly raises an issue that can be the proper subject for litigation in an operating license proceeding -- the adequacy of the communications system to be used in the event of an emergency. (footnote omitted) ALAB-845 at 8.

The Appeal Board concluded that the overall adequacy of the public tele-phone network had not been directly addressed at the hearing, nor had Mr. Brown's testimony been refuted. ALAB-845 at 11. Therefore, the Appeal Board reversed the Licensing Board's rejection of this contention and remanded the matter for further action consistent with the Commis-sion's Rules of Practice and its opinion. See, ALAB-845 at 12-13. In this regard, the Appeal Board noted that some means to notify the off-duty SCIG personnel in the event of an emergency did exist, i.e.,

the telephone call-up system. It was only the adequacy of this telephone call-up system in the event of an overload that was in question. The Appeal Board, in affirming the Licensing Board's decision as to the Esti-mated Time of Evacuation (ETE) for the SCIG issue, directed the Licens-ing Board and the parties in the course of their consideration on ' remand of the Inmates' manpower mobilization contention to determine what effect, if any, the resolution of that issue had on the ETE for the SCIG.

ALAB-845 at 41.

In response to the Appeal Board's remand order, the Licensing Board held a conference call with the parties on September 3, 1986.

During the conference call the Licensing Board sought the views of the

! parties and then advised that it would hold a hearing on the remanded

4 contention in Philadelphia, Pennsylvania on September 22, 1986. The Licensing Board also advised that no prefiled testimony would be, ordered; that witness lists should be exchanged no later than September 12, 1986; and that discovery should begin immediately. O The hearing was held in Philadelphia, Pennsylvania on September 22, 1986, and pursuant to the Licensing Board's Order of September 4, no prefiled testimony was presented. A total of five witnesses presented l

" live" testimony at the hearing. Richard A. Buell, District Manager, Network Technical Services, Bell Telephone Company of Pennsylvania, and Charles A. Zimmerman, Superintendent of the State Correctional Institu-tion at Graterford, testified on behalf of the Pennsylvania Department of Corrections. Richard T. Brown, Chairman of the Board of Supervisors, i Lower Providence Township, and a Communications Technician, American Telephone and Telegraph Corporation, and William Miller, Manager, Switching Services, Bell Telephone Company of Pennsylvania, testified at the request of the Inmates. Mr. James R. Asher, Federal Emergency Management Agency (FEMA) testified on behalf of FEMA.

! The Board has considered all of the proposed findings of fact and conclusions of law presented by the parties. Those not incorporated di-rectly or inferentially in this Supplement to the Fourth PID are rejected as unsupported by the record of the case or as being unnecessary to the 3

rendering of this Supplement to the Fourth PID. Therefore, as discussed below, this Licensing Board finds, in the context of the litigated conten-l tion, and, on the basis of the record before it that there is reasonable 1

4/ Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2), Order at 1 (September 4,1986).

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assurance that, in the event of a radiologleal emergency at the Limerick Generating Station that requires the evacuation of the State Correctional Institution at Graterford, the call-up system will achieve its designated purpose to notify any off-duty security personnel needed to implement the evacuation.

1 III. FINDINCS OF FACT

1. The central office (switching station) that serves the SCIG is located at Collegeville, Pennsylvania. The switching system at Collegeville is called a No. 2 ESS, which is an electronic switching sys-tem. The Collegeville central office is presently scheduled to be upgrad-ed to a more modern digital switching system in February,1987. The new electronic digital system is called a remote No. 5 ESS from a Host USS. Buell, Tr. 21,388-389.

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2. Bell of Pennsylvania (Bell) engineers its central offices, such as Collegeville, to provide a grade of service that it estimates will be i

required for a particular period. Each office is engineered to last ap-proximately two to three years before it will have to be upgraded to han-die additional load , if needed, and to utilize the most up-to-date telecommunications equipment. The line load is based on the number of cus,tomers Bell expecta to be able to serve from a particular central office and the known load that those customers have placed on the switching system. Bell keeps track of the loads generated each year during the busy season of the year. Business customers generate a heavier calling demand during the business day than residential customers. M.

at 21,389-390. Telephone usage from 10:00 PM to 6:00 AM is never the

busiest part of the day. In fact, there is minimal telephone use during

these hours. ,Id . at 21,409-410, Brown , Tr. 21,532, 21,532; Miller, Tr. 21,548, 21,551. The telephone system is designed for a busy hour on a busy day in the busy season, which is normally in the winter.

Buell, Tr. 21,424,

3. Bell's engineered objective is to provide a dial tone within three seconds to ninety-seven percent of its customers. Therefore, a phone system overload situation occurs when the system cannot supply a dial tone to ninety-seven percent of its calling customers within three sec-onds. Id. at 21,432.

4. Dell also maintains an emergency service or Class A lines so that in the event of an overload it is possible to give Class A line cus-tomers priority on a dial tone. Such Class A lines are available at the Collegeville Station. Id. at 21,392-393. A Class A line gives priority for obtaining a dial tone; however, there is no way to guarantee a dial tone at all times. Id. at 21,428. Although Class A lines do not guarantee a dial tone, it does increase one's chances of getting a call through in an overload situation, because the Class A line will get service before the non-Class A lines. Id. at 21,459.

5. At the present time the SClO does not have any Class A lines.

Zimmerman, Tr. 21,458. Although the SCIO has not needed such a ser-vice in the past, after considering the testimony of Mr. Buell, Mr. Zimmerman indicated that he would be willing to get such service.

Id.

6. At the time of Hurricane Agnes in 1972, there were dial tone delays. Brown , Tr. 21,518; Miller, Tr. 21,540. Although Mr. Brown testified that there were dial tone delays of up to one-half hour during Hurricane Agnes (B rown , Tr. 21,518), Mr. Miller, who was also in

Pottstown at the time of Hurricane Agnes,l' did not recall experiencing

, delays as long as one-half hour (Miller, Tr. 21,541). Mr. Miller stated that he never had to wait that long for a dial tone. Id.

7. Some of the delays in obtaining dial tones in the Pottstown area during Hurricane Agnes were caused by damaged equipment, shorted lines or lines under water. Brown , Tr. 21,535. The telephone switching equipment that was in use during Hurricane Agnes was a five cross bar electromagnetic arrangement. Today, digital remote computerized equip-

ment is used. M.at21,532.

8. The time period from 10:00 PM to 6:00 AM has never been the i

busiest hour. Miller, Tr. 21,548. During Hurricane Agnes the resulting overload occurred in the daylight hours. M.at21,549. Telephone traf-fic between 10:00 PM and 6:00 AM is so negligible that you cannot com-pare telephone usage at this time and the daylight hours. _Id. at 21,550.

9. There are presently ten lines working between the SCIG and j the Collegeville Station. There are also ten additional lines from SCIG through Collegeville to Philadelphia, which is part of the Commonwealth of Pennsylvania network. Finally, there is a private line from SCIG to the i State Police. The private line is not switched at Collegeville, but runs i

directly to the State Police and would not be affected by an overload.

Similarly, the ten Commonwealth network lines that run through the Collegeville Station to Philadelphia would not be affected by an overload i

at Collegeville. Buell, Tr. 21,390-391, 21,440.

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10. In conducting an evacuation of SCIG there is sufficient staff on duty to carry out the evacuation of the Inmates without the need for the J

additional call-up of off-duty personnel during the 6:00 AM to 10:00 PM time period. Only during the 10:00 PM to 6:00 AM shift would off-duty i

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I Staff hage to be called in to assist in the evacuation.' Approximately fif-teen percent of the off-duty Staff would have to be called during this period. Zimmerman, Tr. 21,451, 21,469.

11. All employees at SCIG are trained in Inmate custody, care and control. Id. at 21,453.

12. In the event it becomes necessary to call in off-duty personnel during the 10:00 PM to 6:00 AM shift, the SCIG could utilize the call-in system that is outlined in its Radiological Emergency Response Plan (RERP). Id. at 21,454'. This pyramid call-up system is the same for all institutions in the Commonwealth and it is in place at the SCIG for the call up of administrative and management staff. Id. In addition, there is an in-house telephone system in the SCIG control center which is used for notifying the majority of off duty correctional officers. 5,/ d. Both systems have been utilized during incidents at the SCIG. Id. at 21,454, 21,473. The SCIG usually utilizes the in-house telephone system to call its administration and management people at home. In this manner the SCIG has direct communication with its administrative and management j personnel. These people have telephone lists of their employees. In addition, and as a practical matter, SCIG found that, because the , staff is scattered throughout several calling areas and because some of the calls are long distance calls and chargeable to the SCIG employee, the long i

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'-5/ By letter dated October 1,1986, Theodore G. Otto, III, Chief Coun-set to the Pennsylvania Department of Corrections, advised the Li-censing Board and the parties that the SCIG Radiological Emergency Response Plan has been changed to reflect the manpower call-in pro-cedure which were discussed at the hearing held on September 22, 1986.

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distance calls shou'd be and are in fact liandled from the SCIG control center. Id. at 21,454.

13. At present, there are sixty-six telephone lines coming into the SCIG. I_d d . at 21,456, Commonwealth Ex.1, p. 1. In addition to the' foregoing and in the remote event the SCIG experienced telephone delays that prevented a timely call-up, SCIG management staff also have pagers.

,ld, at 21,459, Commonwealth Ex.1, p. 2. Besides the dedicated line to the State Police, there is also a radio system that can be used to alert personnel. The SCIG could also utilize the personnel coming in on the evacuation buses because they are trained correctional officers from other state correctional institutions. The additional correctional personnel com-ing in on the buses, called up from other correctional institutions to as-sist in an evacuation at SCIG, could make up a large portion of the required off-duty personnel needed to evacuate the prison. Because these personnel would be called on the Commonwealth network, they would not be affected by any local telephone congestion at Collegeville Station.

Finally, there is the combined law enforcement assistance network (CLEAN) that could be used to notify off-duty personnel. Zimmerman, Tr. 21,460-462.

14. The SCIG telephone call-up system is routinely tested. M.

at 21,462. However, because of incidents at the institution, the call-up system is also utilized and tested under real conditions.

M. During these actual call-ups there has never been any indication that the system would not operue as anticipated. M.at21,462-463.

15. In the opinion of Superintendent Zimmerman, the SCIO call-up system as planned and actually used meets the estimated evacuation time estimates of one-to-two hours for the calling of off-duty personnel and l

two-to-three hours for the calling of off-dt ty personnel in adverse condi-tions. M.at21,468.

16. When the SCIG has a power outage, the in-house telephones sometimes fall to work and the institution relies on radio for internal com-munication. However, as the power failure does not affect outside tele-phone lines, the ability to call out from the . institution is not impaired.

M.at21,485-489.

17. Based upon his experience at SCIG and elsewhere, Superinten-dent Zimmerman is of the opinion that the SCIG telephone call-up system will work as planned, regardless of the potential for congestion at the local Collegeville switching station. Superintendent Zimmerman noted that the SCIG call-up system has worked well in other actual emergencys and that the lines that run to other areas on the Commonwealth network, the use of pagers and radios and the dedicated line to the State Police all tend to reinforce this opinion. M . at 21,502-503. In addition, the off-duty personnel will be called in during the " alert" stage of an emer-gency, which is prior to the general emergency stage when sirens are sounded to warn the public of the emergency. Id. at 21,506. Finally, as noted earlier, telephone use from 10:00 PM to 6:00 AM, the only, period when off-duty SCIG personnel will need to be called, is minimal.

18. Other nuclear power plant emergency plans utilize commercial phone lines in the same manner as they are ut!!ized at SCIG. In fact, Mr. Asher, FEMA, is unaware of any nuclear plant that does not utilize commercial telephone lines as a means of notifying off-duty emergency workers. Asher, Tr. 21,554.

19. FEMA uses commercial telephone lines in a call down system very similar to what has been utilized at SCIG for the notification of

off-duty personnel and, in Mr. Asher's experience, there has never been.

an instance in which FEMA has been unable to notify its off-duty person-nel by means of commercial telephone lines. Id. at 21,556-557.

20. The SCIG plans for the notification of off-duty personnel will be implemented at the " alert" stage of any emergency. At this particular time, the general public will not have been notified that there is a prob-l lem and the telephone lines should not be overburdened. d. at 21,560.

21. Based upon his review of the testimony and knowledge of the SCIG plans, Mr. Asher is satisfied that there is reasonable assurance that in the event of a radiological emergency at Limerick any off-duty person-nel needed to implement the plan can and will be notified. _Id. at 21,555.

Conclusion

22. Based on the evidentiary record before us, this Licensing Board, in the context of the litigated contention, has reasonable assur-ance that, in the event of a radiological emergency at the Limerick Gener-

,i ating Station that requires the evacuation of the State Correctional I Institution at Graterford, the call-up system will achieve its designated purpose to notify any off-duty security personnel needed to implement the evacuation. In addition, as a result of a review of the record developed I

in connection with the litigated contention, we see no reason to require any modification to the existing ETE for the SCIG.

,i IV. CONCLUSIONS OF LAW j

In reaching this decision, the Board has considered all the evidence i

of the parties and the entire record of this proceeding of the remanded issue including all proposed findings of fact and conclusions of law pre-

! sented .by the parties. Based upon a review of that record and the

O, foregoing Findings of Fact, which are supported by reliable, probative and substantial evidence, the Board, with respect to the remanded con-tention in controversy before us, reaches the following conclusion pursu-ant to 10 C.F.R. I 2.760a:

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In the event of a radiological emergency at the Limerick Gen-1 erating Station that requires the evacuation of the State Cor-rectional Institution at Graterford , . there is reasonable assurance that the call-up system will achieve its designated purpose to notify any off-duty security personnel needed to implement the evacuation.

V. ORDER WHEREFORE, in accordance with the Atomic Energy Act of 1954, as l amended, and the Rules of Practice of the Commission, and based on the foregoing Findings of Fact and Conclusions of Law, IT IS ORDERED that:

Pursuant to 10 C.F.R. I 2.760(a) of the Commission's Rules of Prac-tice, this Partial Initial Decision will constitute the final decision of the Commission forty-five (45) days from the date of issuance, un-less an appeal is taken in accordance with 10 C.F.R. I 2.762 or the 2

Commission directs otherwise. See also 10 C.F.R. Il 2.764, 2.785

and 2.786.

Any party may take an appeal from this decision by filing a Notice

of Appeal within ten (10) days after the service of this decision.

l Each appellant must file a brief supporting its position on appeal within thirty (30) days after filing its Notice of Appeal (forty (40) days if the Staff is the appellant). Within thirty (30) days after the period had expired for the filing and service of the briefs of all

! appellants (forty (40) days in the case of the Staff), a party who is not an appellant may file a brief in support of or in opposition to i

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the appeal of any other party. A responding party shall file a sin-gle, responsive brief regardless of the number of appellant briefs filed. See 10 C.F.R. I 2.762(c).

IT IS SO ORDERED.

THE A'IG11C SAFE 1Y AND LICEh5ING BCRT HeIen F. Hoyt, Qiairperson A311NISIRATIVE JtIXE Richard F. Cole A311NISIRATIVE JtIXE Jerry Harbour A311NISTRATIVE JLEGE Dated at Bethesda, Maryland this day of 1986

0 00tKEH D

'JSNPC i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 86 ET 20 P4

17 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

' un: O urvr 00CKETwa A . ' 9 Vin -

In the Matter of )

)

PHILADELPHIA ELECTRIC COMPANY ) Docket Nos. 50-352

) 50-353 (Limerick Generating Station, )

Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE FORM OF A SUPPLEMENT TO THE FOURTH PARTIAL INITIAL DECISION RELATING TO THE REMAND-ED CONTENTION REGARDING MANPOWER MOBILIZATION AT THE STATE CORRECTIONAL INSTITUTION AT GRATERFORD" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system this 16th day of October,1986:

Helen F. Hoyt, Chairperson (2) Mr. Edward G. Bauer, Jr.

Administrative Judge Vice President & General Counsel Atomic Safety and Licensing Board Panel Philadelphia Electric Company U.S. Nuclear Regulatory Commission 2301 Market Street

] Washington, D.C. 20555* Philadelphia, PA 19101 Dr. Richard F. Cole ' Troy B. Conner, Jr. , Esq.

Administrative Judge Mark J. Wetterhahn, Esq.

Atomic Safety and Licensing Board Panel Conner and Wetterhahn U.S. Nuclear Regulatory Commission 1747 Pennsylvania Avenue, N.W.

Washington, D.C. 20555* Washington, D.C. 20006 Dr. Jerry Harbour Ms. Phyllis Zitzer, President l Administrative Judge Ms. Maureen Mulligan 4

Atomic Safety and Licensing Board Panel Limerick Ecology Action

U.S. Nuclear Regulatory Commission 762 Queen Street Washington, D.C. 20555* Pottstown, PA 19464 Mr. Frank R. Romano Charles E. Rainey, Jr. , Esq.

Air and Water Pollution Patrol Chief Assistant City Solicitor i 61 Forest Avenue Law Department, City of Philadelphia Ambler, PA 19002 One Reading Center 1101 Market Street, 5th Floor Philadelphia, PA 19107 l

Thomas Gerusky, Director Bar'ry M. Hartman Bureau of Radiation Protection Governor's Energy Council Dept. of Environmental Resources P.O. Box 8010 5th Floor, Fulton Bank Building 300 N. 2nd Street Third and Locust Streets Harrisburg, PA 17105 Harrisburg, PA 17120 Spence W. Perry, Esq.

Director General Counsel Pennsylvania Emergency Management Federal Emergency Management Agency Agency Room 840 Basement, Transportation a Safety 500 C Street, S.W.

Building Washington, D.C. 20472 Harrisburg, PA 17120 Robert L. Anthony Gene Kelly Friends of the Earth of the Senior Resident Inspector Delaware Valley U.S. Nuclear Regulatory Commission 103 Vernon Lane, Box 186 P.O. Box 47 Moylan, PA 19065 Sanatoga, PA 19464 Atomic Safety and Licensing . Timothy R. S. Campbell, Director Board Panel Department of Emergency Services U.S. Nuclear Regulatory Commission 14 East Biddle Street Washington, D.C. 20555* West Chester, PA 19380 Atomic Safety and Licensing Appeal David Wersan Board Panel (5)

Consumer Advocate U.S. Nuclear Regulatory Commission Office of Attorney General Washington , . D. C. 20555*

1425 Strawberry Square liarrisburg, PA 17120 Docketing and Service Section Office of the Secretary Jay Gutierrez U.S. Nuclear Regulatory Commission Regional Counsel Washington, D.C. 20555' USNRC, Region 1

.631 Park Avenue Angus R. Love, Esq.

King of Prussia, PA 19406* Montgomery County Legal Aid 107 East Main Street Theodore G. Otto, III Norristown, PA 19401 Chief Counsel Pennsylvania Dept. of Corrections P. O. Box 598 Camp Hill, PA 17011 l

/) h J s Ah Rutberg b1 l u%y Assistant Oegeral Counsel

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