ML20084E710

Objections & Request for Reconsideration Re Special Prehearing Conference Order on Admissibility of Offsite Emergency Planning Contentions.Aslb Incorrectly Applied ALAB-936 to Preclude Litigation.W/Certificate of Svc

ML20084E710
Person / Time
Site:	Limerick
Issue date:	04/30/1984
From:	Ferkin Z PENNSYLVANIA, COMMONWEALTH OF
To:
References
ALAB-698, OL, NUDOCS 8405020475
Download: ML20084E710 (17)

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l UNITED STATES OF AMEllICA NUCI. EAR REGULATORY COMMISION

00. ,[ey t.fifD Before the Atomic Safety and Licensing Board *g4 g ,

In the Matter of ) "r----

Philadelphia Electric Company ) Docket Nos. 50-352 OL' - -

(Limerick Generating Station, ) 50-353 g {,

Units 1 and 2) )

OBJECTIONS AND REQUEST FOR RECONSIDERATION BY THE COMMONWEALTH OF PENNSYLVANIA REG ARDING SPECI AL PREllEARING CONFERENCE ORDER RULING ON ADMISSIBILITY OF OFFSITE EMERGENCY PLANNING CONTENTIONS Pursuant to 10C.F.R.h2751a(d), the Commonwealth of Pennsylvania hereby files objections to the Licensing Board's special prehearing conference order concerning offsite emergency planning contentions. LBP-84-18, 19 NRC (Apr. 20, 1984). The Commonwealth requests that the Board reconsider its ruling that denied admission of that part of Commonwealth-1 concerning arrangements for procurement and distribution of permanent record (thermoluminescent) dosimeters.

The Commonwealth believes the Board incorrectly applied ALAB-698 to preclude litigation or an otherwise admissible issue of concern. The Board shoulu admit Commonwealth-1 in its original form so that a complete record may be developed on the issue of whether there is reasonable assurance that adequate procative measures for o r fsite eicergency workera at LimertoX can and .4111 be taken.

8405020475 a40430 PDR ADOCK 05000352 G

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l The standard by which the admissibility of the Commonwealth's issues of concern should be judged is that set forth in 10 C.F.H. 2. 7111 ( b ) --t h a t is, the basis for the issue must be set forth with reasonable speci ficity.

See Houston Lighting & Power Co. (Allens Creek Nuclear Generating Station, Unit I), ALAB-S90, il NRC 642 (1980).

The Board, on the other hand, applies a standard that is more akin to summary disposition--that is, based on the TMI record, there is no genuine issue of material fact regarding permanent record dosimeters as means for protecting emergency workers & Limerick. In light of the standard for admissibility prescribed by NRC regulations and the inadequacy of the TMI record on this issue, the Board should reconsider its ruling on Commonwealth 1.

Commonwealth - 1 states:

I. No operating license for the Limerick Generating Station, Unita 1 and 2, should be authorized until arrangements are in place for procurement, and distribution to all offsite emergency workers identified in the state, county and municipal emergency plans as requiring dosimetry, of adequate numbers of self-reading (0-20R and 0-200R) and permanent record (thermolumincocent) dontmeters. 10 C.F.R. 60.47(b)(10), (11); NUREG-0654, Rev. 1,

" Criteria fo r Preparation and Evaluation of Radiological 16nergency Hosponse Plans and Preparednenn in .'hipport o f Nuc l enc Power P l anta" (November 19110), Criterton K.3; FKM A -IICI'-2, "Guidaneo on Off.ite Emere,eney Radiation Measurement Systems, Phase ! Airborne Rolenne" ( ' hip t emb e r 1980).

The Licenning Board admitted Commonwealth-l an it applies to nel f-read i ne, dod ime Ler s . The lloard ruled that the i,imerick emergency plann "muutplow cither Lhat the

necessary supplies [of self-reading dosimeters] are in place, or that the mechanism for acquiring and placing them exists." L B P-811 - 18 , 19 NRC at..__(slip opinion at 23-221).

The Board went on to rule that the offsite emertsency plans "need not include arrangements for the procurement and distribution of permanent record dosimeters." Id. at (slip opinion at 22). In support of its ruling the Board cited the Appeal Board's decision in Metropolitan Edison Co. (Three Mile Island, Unit 1), ALAB-698, 16 NRC 1290 (1982). In its view, that decision " compels" this Licensing Board to rule, as a matter of law, that offsite emergency planning need not include permanent record devices for emergency workers and that an issue of concern asking that an adequate supply of such devices be assured is not litigable.

The Commonwealth's emergency plan provides with regard to dosimetry (in pertinent part):

Each emergency worker will be provided two self-reading dosimeters (one CD.V-730 or one DCA-622 and one CD V-7112) and one thermoluminosiient dosimeter (TLD). The self-reading dosimeters enable the worker to monitor himself at the time of the emergency for total radiation doce received; the TLD is an independently read (by the TLD service contractor) device that is generally considered to be more dependable, accurate and precise than the sel f-r e nd i nit dosimeters. Each emerdancy worker la responsible for following the dosimetry procedures, including recordkeeping.

Appendix 16, Annex E. It should be noted that the relevant language in the state's plan has been revised since ALAll-698; however the thrust of that section regarding need for and propar use of unch type of

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dosimeter is not materially different.

The Commonwealth's' plan regarding dosimeters is based on well-established federal guidance. NUREG-06521 contemplates that emergency plans shall provide for distribution of dosimeters to offsite emergency workers, "both self-reading and permanent record devices."

Criterion K.3a. FEMA-1(EP-2, which is still effective guidance, also recommendu use of both self-reading and permanent record dosimeters. FEMA-REP-2 at 5-8 through 5-9, 7-5. Adherence to such regulatory guidance, absent other evidence, "may'be sufficent to demonstrate compliance with regulatory requirements." ALAB-698, 16 NRC at 1299.

While alternative means for controlling emergency workers' exposure may be available, it is the npplicant's burden to demonstrate the adequacy of such alternatives and whether they can be implemented. See 10C.F.R.f2.732.

In ALAB-698, all partic~s agreed that adequate supplies of two types of self-reading dosimeters--low-range CDV-730s (0-20R) and high-range CDV-7112s (0-200ll)--were available for TMI. Id. at 1295. That assumption was essential to the . Appeal llourd 's determination regarding protection for emergency workers. The Appeal Ibard stated its belief that "the distribution of Lhe Lwo self-read ing dosime ters , under Lhe npecific i n s L e ue l. io n., e,iven to emergency Workern in Lhe emergency plann, in sufficient ta ansure reasonable

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• I protection for emergency workers." Id. at 1299. Thus in THI, it was possible to determine that an alternative means of protecting emergency workers existed. In the instant proceeding, there is no record as to what dosimeLry exists for workers at Limerlek. The Board's ruling on Commonwealth-1 relieves the Applicant of its burden to ,

establish adequate means for protecting emergency workers.

The Board also fails to recognize fully the context in which the issue of provision for permanent record dosimetry was considered in ALAB-698. The issue of dosimetry for emergency workers arose late in the TMI-Restart proceeding, and was not the subject of an individual contention. As the Appeal Board noted, "the issue therefore was not

, subject to the normal process of discovery, nor was it dealt with in prefiled direct testimony." 16 NHC at 1300

n. 22. The virtues of permanent record dosimeters were therefore not fully explored on the record of the TMI Restart proceeding. Further, the litt'le record evidence that was presented in the TMI proceeding was dealt with primarily in the context of a request by PEMA to FEMA for additional dosimeters. See ALLuchments 1, 2. Only in August 1982 did FEMA notify the Commonwealth that it would not'be making additional TLDs available to the state. See Attachment 3. The lloard aboutd also be aware that the Commonwealth filed a petition for review of ALAB-698 with the Commission, but deelded to withdrhw the petition in

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view of the settlement reached with the TMI utility,  :

whereby that utility, inter alia, will supply TLDs for of fsite emergency workers for the life of that facility.

Permanent record dosimeters are, in the Commonwealth's view, extremely important in ensuring an emergency worker has an accurate and' reliable, and legally defensible, measurement of the actual radiological dose received by that individual over the course of a nuclear incident.

Unlike self-reading dosimeters, TLDs are read by the instrument vendor, not-by the individual worker, the utility or the state. The professional training and detachment of the TLD reader assures an accurate dose measurement for each worker. Self-reading dosimeters are also easily tampered with and accidental discharges from impact are possible. There fo r e inaccurate readouts are quite likely. TLDs are not nearly as susceptible to such faulty measurements. In FEMA's view,.it is " highly desirable that [a TLD readin's for each emergency worker] be incorporated as part of the exposure record documentation."

FEMA-REP-2 at 7-5. See also Attachment 3 at p. 2. It is therefore in the Applicant's interest as well as the State's that TLDs be provided for emergency workers.

Further, as the Appeal lioard noted, the two ne~tf-readini',

dosimeters cannot mensure doses less than 0.1111 or greater than 200R. 16 NHC at 1296. The Appea! Dourd accordingly recognized the value of permanent record dosimeters. It

_7 ctated that permanent record dosimeters represent a useful added measure of protection for emergency workers," and

" clearly would facilitate more accurate permanent Id.

recordkeeping, as well as diagnosis in special cases."

at 1301. The Appeal Board urged the TMI parties to " work together to make reasonable provision for distribution of TLDs for all offsite emergency workers in the event of an emergency. " Ibid. Should the Board reconsider and admit this issue, the Commonwealth proposes to proffer evidence an concerning the need for permanent record dosimeters, issue that was not squarely addressed in the TMI proceeding.

The Commonwealth did not raise dosimetry as an issue of concern in this proceeding merely to have the Board determine who will pay for these devices, as the Board (slip opinion at apparently believes. See 19 NRC at in a 21). Offsite emergency workers who agree to respond nuclear incident are taking a calculated personal risk for the benefit of their community. These workers have a right to a definitive measurement of their actual radiological In the case of Limerick, exposure durin[r, an emeri'.ency .

where we have no knowledge (and indeed, are beind allowed to litigate) whether there are .blequ:ite supplien of TLDs may well self-reading dostmetern'for offsito workers, be necessary to provide reanonable .innarance that emergency workern will be protected. See AI.AB-698, 16 NitC at 1299.

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It is the Commonwenith's position that it is Applicant's burden to demonstrate an alternative to NRC and FEMA. l1 guidance is available for Limerick of fsite workers 3 As this Board recognized in admitting Commonwealth-1 as to self-reading dosimeters, planning alone is not enough; rather, the issue is whether dosimeter supplies are in place, or the necessary arrangements have been made for their aoquisition and distribution. The Commonwealth has demonstrated the requisite basis for its issue of concern regarding dosimetry for emergency workers at Limerick. The Commonwealth therefore urdes the lloard to reconsider its ruling denying admission of Commonwealth-1 as it concerns permanent record dosimeters, and admit Commonwealth-1 in its original form.

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Resp,ectfully submittep, h

Zori G. Ferkin Assistant Counsel Commonwealth of Pennsylvania P. O. Box 8010 1625 North Front Date: hgr{l*9)d,l(,(y I Indeed, by noting c lie C ommo nw e a l t li ' s partleipation in the litigation underlying ALAll-698 (19 N I(C at (alip opinion at 21), Lho llo a rd scoms to imply t lia t that slec t a lo n is binding for these purposea u nilc r ros judicata principlen. R e s_ .j iitl i c a l_1! n o c o w w i t a t e s identiLy o l' p a r t l e t6 as_well as of Identity n1 l a n it o s be t w ooit two p i o v e e d l ii n a . S e t' Montana ~v. U n i t e d _ S t_a_t e n_ , 440 U.S. 147(1979)1 _ A l a b a m a _p o w e_r_,C o .

l ( .l o H U p li H . Farley Noelcar P l a til , U ti l t a I a iid' 2 ) , A l, A ll- l ll 2 , 7 ABC 210, f.E.m,!s.n,t!ad,, o n u t lj e r, y, r o u n d o , C 1, l - 7 4 - 1 2 , / ABC 2LM(1974). Ne i t tie r a l t hest p re reclu la lle s in present in l lt i t6 cane.

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i ENNSYLVANIA EMERGENCY MANAGLMEN1 Act!NCY

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Mr. Robert Adamcik S(R,iggytm!;iCT4 Acting Regional Director Federal Emeegency Management Agency Region III, Curtis lluilding 6th and Walnut Structa Philadelphia, Pennsylvania 19106

Dear Mr. Adamcik:

During the final development of the Commonvcalth of Pennsylvania Radiological Emergency itesponne Plan lor Fixed Nuej e .c Facility Incidents, we identified in our August 31, 1981 letter to tir. Adict tiro maAr nhort in11 r. In requir.ite donimetry for emorr.ency i.t.

workern pursuant to Fedora t pinnaing nLanJards and evaiuat s on ci iies At that time uc requested TEllA to provide, or arrange for the provision of, the following douimetry requirements for emergency vorhcrn concerned with the Threc flile Island Nuclear Station, Suuquehannt S t eau r.lin.i r ic Stat ion, Pench llot tom Atomic l'ower St at irm and the lie.n cr V.illef l'o.r e i Station.

QUANTITY DESCR I P,_1]g,N, 5,054 CD V 730 Dosir.:oter (0-20r) 11,184 TI.1) (Thermalumineneent ,l.' iu ime t e r )

The following important conniderationr. relasIve to the i equest

' were also cited:

n. During the inittai planning el fort we opted for dintribution of donimetry at the t ime of c: ergency nince fewer t ot al ienource.. uontil be r ei,o s i cil .m.1 NUREG-0654 doen not specif y the type of d intribut ion,

b. The curranl plan van ch:niged to predint e ihui lon of donimetry before Ihe er.'rgency on the banin of Federal ch :ervat lonn an.! reco.c.enil.i t i on 6 cited in (1) 1,u.y tyw and (2) ,l.3,cl r e,ty e o f Penna.ylvan ia l<r.P Sit e-spec t f ic t o Threo illie Inland Fixert Nuc lea r l'ac il ii v

I ilt . Ruhrrt Adamcik l January 7, 1982 l Page Two

c. The rationale for FEMA to identify the CD V 730 as a possible national resource to meet Stato itERP donimetry needs,

d. The rationale for Federal procurement of all TLD RERP donimetry necdn.

In the State Plan we have specified that a nuf f LeLent nupply of pornonal donimetry wLit he incued to cach rink county to permit pre-distribution of two scif-rcading and one permanent-record dosimeter each emergency porher. Whtic we have enough CD V 742 Dos (metern (0-200r),

there is the shortal;n of CD V 730s and T!.Ds indicated also. Our decision to opt for three docimeters for cach emergency worker in haneil on paracrnph 7.3b, page 7-5 of the FDIA document ent it led " Guidance on Of fsite Emergoney Radint ion !!casurement Systemn, Phnue I, Airborne Reicase," dated September 1980, short titl e , FEtlA-REP-2. While it is indicated in the abstract. that thn document "providen interim guidance to State and local agenetus," we have received no of f leial notification that the guidance has been canec11cd, modified or supceneded.

During Lhn October 1981 ASL.li llearingn for the fintainehanna Steam 1:Loctric Plant. TRIA testified that Jt would not nupply the unmet donimetry needs of the State. It wan f urt her indicated that cirher the Stnto or the utility should finanec the purchase of thin doninctry.

In view of FDIA's strong recommendation for predint ribut ion of don imet t y ,

this dogmatic position sens surprining sinec nn anuwer to our August 31 1ceter has never been received. In renponne to anot her qucntion, PEllA testifJed there was no rottuirement in NilREG-0654 for tuo nel f-rending dosimeters na entled for in the State Plan. During nuhncquent crour.-

examination, however , TK Li was questioned regarding FC:1,\ .1;l'.p-2 and testified that thin docinacnt van not being continued , t hough in f act -

it had not been cancelled.

11h11c thn nworn statements made by FCilA nt the referenced ASLB licarings may not be conclusive, they are a naLLor of public record and in the nbnence of any other nLatement o f ron l'DIA aie of conento to us. To clarify thenn mattern l'ask that the following he provided ley your of fice or Fella Nat ional:

n. A formal reply to our letter of Annoni ll, 19til to Vernon Adler, then llegion Ill, Directer, Pinnn mul preparedneun ulvinion,

b. A delinitice wt it i en otalement an i o whet bei the guidaner in Pl71A-RI:l' 2 relat ive lo the sci f-rend ing .and permancni-record donimet ern in LLill val bl .

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Hr. Robert Adamcik l l January 7, 1982 l Page Tlirce

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j c. T C . the F191A-l(El'-2 guidanec is no lonr,er to be followed, clien what specifically is the i FDIA requircment for predistributed donimetry- -

I to offsito cmergency workers.

Sincoroly.

4 I DeWitt C. Smlth,.ir. ,

Director 1

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[wu%q Td Federal Einergency Maiutgeinent Agency 5 Region 111 Gih & Walnut Streets Philadelphin, l'ennsylvania 19 06 f*&E0 QAN 101002 -

Lt. Con. Dellitt C. Smith, Jr.

Director g M7 g A10:

Pennsylvania Daargency llan:q',cyont  !

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P.O. Ilox 3321 3R 43SEAT'!. .-

Ilarrisburg, PA 17105

Dear Conoral Smith:

11o have received your letter of January 7,1902 In which you requecteil l'l'ilA assistanco in the proviaton of dosinatry for energency workers locateti around four (4) nuclear power plant sites in Pennuylv nia. In the satne letter you nico inquired as to whether the guidance on docir.ictry contained in the publication ontitled " Guidance on Of fsite Emergency ltinlintion Heasureuent Systema, Phaco 1 - Airborno 1:elcano," also known ao FI'.51A-l'EP-2 still j a valid or if it hno boon superseded by sor.ie other guidance.

Your qucutions reflect issuen which are of national .tnterest anil policy. There-f ore, as your 1ctter suggesto, and an uc did with your letter of Aul;unt 31, 1981, we are forwarding your Iceter to our contral office with the requent that they reply directly to you. You should receive their reply shortly. I'le.m..

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let us know if you do nnt._

We look forward to continuing our nutual efforto in improvin: our radiologieni

. energency preparedness capabilition. Picano contact me if we can be of addi- i tionni nooictanco.

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)EHORANDUM FORT Walter P. Pierson ootkfD s

Chier i

Natural and Technological Hazards Division . '84

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• Office of Natural and Technological' 4 e)

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j SUBJECTS. Request. by the-Commonwealth of Pennsylvania for Radiological' -

l Emergency. Preparednese (REP) Dosimetry Equipment Assistance and. Guidance on FEMA-REP-2.

l j This is in reply to your memorsoduer subject se above ,,

J Fed ral Emergency Management. Agency (FEMA) Headquarters recognizes the acute l

chartaga of CDV-73D donimeters.in a number of the States. for use in. supporting' tha REP program Based upon a. recent survey or oll States ,by the Emergency l rens Office,. there are n,o known surplualCDV-730'e in .any Han:gement Pr l

State. Alse,. has ne plans < to procure additional quantities for: .

either. Civil Defense or REP.

,s It. is: important. to. note that the CDV-742: doelmster is recommended: for use. - -

in-conjunctioni with the-CDV:-730' dosimetere in order-to. provide. a redundant l

calf-reading capability anda an adequate road-out range extending, above the i

i emergency worker PAG.'s for whole body gamma radiation exposure. The CDV-742

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dosimeter can be substituted. for the CDV-730 dosimeter where there are chartages The primary advantage of the CDV*730 dosimeter is that a more ccourate reading can. be made. for low. exposures. However,. if the dosimeter l

l ic assigned. to. an individual and remains with hir throughout the duration of j

j th > emergency,. then the.CDV-742. is adequate for a self-reading dosimetric device

W3 note that the State of Pennsylvania has an inventory of 112,872 CDV-742.

I d:cimeters. The quantity in the State oppears to be more than sufficient so that the number. required to* Inset the REP requirements should be available within i tho State.

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[ In developing radiation measurement and dosimetry ayettnaa.. FEMA-REP-2 guidance cncouraged Stator to use existing instrumentation and, resourcer wherover-l possible. This document oloo indicated that the higher radiation levels are of more concern.. Therefore, the use of two CDV-741'r, if neconeary,. in a very logical. choice.to provide instrument.ution for the potentially higher exposurra that emergency workarn could possible accrue.. However, the CDV-742 can be accurat.cri read in the dose range for below tho- maxinur umargancy workur PAG. fCHA Huedquartora concuro with thu Hugional. position that unif readingThis duulmetryin considered duvicou should be distributed, at least to county and or local. levela.

uneential ao thut rapid finni diutribution to individuni emergency workoro enn be r.indo in a timely manner.

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• l Thermoluminsecent. dosimetersThe (Tt.D)

Inteirey haveTaskforce nok and will not be Emergency on Orraite made ave 11ab by TEMA roc State and local use.

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Instr-tdim for Nuclear Incidevits, in exasairdng the requirement.s for ,

I h6try, reconsumd a TLD syntau over other sannsesrumeid, systems such as riin badg% for administrative docummtat. ion of each individttels exposure to. '

radid% Fils badge tr60-ru uey assve sw a substitute for thurmoluminsweent

+=a6Lara, assuming riin badge services including enlibratimes and reeding een

- be satisfactorily provided. Ilse swir-rweding daalueters weis es c - , M mo

that indivizausia could keep tracic, on a curreed basis, os"their radiation The discussion regarding the need for non-esir--

exposure was being received.8 ** Im in Towwi on pages 5-G and 5.-9 or TEMA4tEP-2.

reading devices for = '

The TLD permanent E.cd dagicos were so-: - c _J an page 7-5 se theFDM preferabia still means for exposure record d+~ rLd4m for all emergency workara. '

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creid=rs this a highly desirable procedure and will continue te m Although the FDW-REP-2 document. dated Septseber 1980 ontitled, " Guidance , ,,

on offsits E . p ,ci Rodinf im Hessurement. Systems, Phsee T, Airborne Release" la being considered for revision, primarily in terza of updating avmiinhle j infor-"im regarding plunne airborne rdat~ fine montoring* methods,,this cLemt '

is, considered to be FDM guidance in the ' area of personnel desi

netry. .

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In --ey we wi* Le eWim that it to nut FOR polity to. procure and grant.

f emergency inst,rusentakian to, the States for use in REF.

• However, Wwre instruses>-

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t.akian exista for civil..dersaae purposes,. it usy be used also for REP' providiner ika.aesi1=hility;for Cisil..Defeneeria not adversely offected. *

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD U$$([0

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In the Matter of )

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PHILADELPHIA ELECTRIC COMPANY ) CRt' '

Docket Nos{FO p

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(Limerick Generating Station, )

Units 1 and 2) ) .

CERTIFICATE OF SERVICE I hereby certify that copies of " Objections and Request for Reconsideration by the Commonwealth of Pennsylvania" 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 Commonwealth of Pennsylvania's internal mail system, this 30th day of April 1984:

Lawrence Brenner (2) Docketing and Service Section Administrative Judge- Office of the Secretary Atomic Safety and Licensing U. S. Nuclear Regulatory Board Commission U. S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Richard F. Cole Mark J. Wetterhahn, Esq.

Administrative Judge Conner and Wetterhahn Atomic Safety and Licensing 1747 Pennsylvania Avenue , N.W.

Board Washington, D.C. 20006 U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 . Board Panel U.S. Nuclear Regulatory Commission Washing ton , D.C. 20555 Peter A. Morris Ann P. Hodgdon , Esq.

Administrative Judge Benj amin H. Vogler , Esq.

Atomic Safety and Licensing Counsel for NRC Staff U. S. Nuclear Regulatory. Office of the Executive Legal Commission Director

Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 I

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7 Atomic Safety and Licensing Philadelphia Electric Company .

Appeal Panel ATTN: Ed ward G. Bauer , Jr.

U. S. Nuclear Regulatory Vice President &

Commission General Counsel Washington, D.C. 20555 2301 Market Street Philadelphia, Pa. .19101 Frank H. Romano # David Wersan , Esq.

61 Forest Avenue Assistant Consumer Advocate Ambler, Pa. 19002 Office of Consumer Advocate 1425 Strawberry Square Harrisburg, Pa. 17120 .

1 Robert L. Anthony Steven P. Hershey, Esq.

Friends of the Earth of Community Legal Services, Inc.

the Delaware Valley Law Center West P . O . Box 18 6 5219 Chestnu.t Street 103 Vernon Lane Philadelphia, Pa. 19139 Moylan, Pa. 19065 Marvin I. Lewis Angus Love, Esq.

6504 Bradford Terrace 101 East Main Street Philadelphia, Pa. 19107 Norristown, Pa. 19104.

Joseph H. White, III Phyllis Zitzer 15 Ardmore Avenue Limerick Ecology Action Ardmore, Pa. 19003 P . O . Bo x 761 -

Pottstown, Pa. 19464 Charles W. Elliott, Esq. Sugarman, Denworth & Hellegers Brose and Postwistilo 16th Floor Center Plaza 1101 Building 101 North Broad Street 11th & Northampton Sts. Philadelphia, Pa. 19107 Easton, Pa. 18042 Jacqueline I. Ruttenberg # Director, Pennsylvania Keystone Alliance Emergency Management Agency 3700 Chestnut Street B-151, Transportation and Philadelphia, Pa. 19104 Safety Building Harrisburg, Pa. 17120 e p D

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'Thom as G3r u' sky , Director Martha W. Bush, Esq. I Bureau of Radiation Kathryn S. Lewis, Esq.

Protection City of Philadelphia ,

Department of Environmental Municipal Services Bldg. '

Resources 15th and JFK Blvd.

5th Floor, Fulton Bank Bldg. Philadelphia, Pa. 19107 Third and Locust Streets Harrisburg, Pa. 17120 Spence W. Perry, Esq.

Associate General Counsel Federal Emergency Management Jay M. Gutierrez, Esq. Agency U. S. Nuclear Regulatory 500 C Street, S.W., Rm. 840 Commission Washington, D.C. 20472 Region I 631 Park Avenue Gregory Minor ,

King of Prussia, Pa. 19406 MHB Technical Associates 1723 Hamilton Avenue San Jose, CA 95125 Timothy H. S. Campbell Director Department of Emergency Services 14 East Biddle Street West Chester, Pa. 19380 Zori G.

Kw'L Ferkin Assistant Counsel Governor's Energy Council Apd/ 30 litk j

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