ML20072D698

Response to Pj Amico to ASLB & Analysis of PRA Testimony.Areas in Which Addl Testimony Recommended Do Not Present Issues Materially Affecting Record & Are Too Costly.W/Certificate of Svc

ML20072D698
Person / Time
Site:	Indian Point
Issue date:	06/20/1983
From:	Brandenburg B, Colarulli P CONSOLIDATED EDISON CO. OF NEW YORK, INC., MORGAN ASSOCIATES, POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
References
ISSUANCES-SP, NUDOCS 8306230376
Download: ML20072D698 (19)

Text

r-,, c UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION W

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ATOMIC SAFETY AND LICENSING BOARD

(

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Before Administrative Judges:

y$$f James P.

Gleason, Chairman 9-B Frederick J.

%on 2

g g jg83)

Dr. Oscar H.

Paris

{

omco et ** *ser.

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In the Matter of

.)

)

CONSOLIDATED EDISON COMPANY OF

)

Docket Nos.

NEW YORK, INC.

)

50-247 SP (Indian Point, Unit No. 2)

)

50-286 SP

)

POWER AUTHORITY OF THE STATE OF

)

NEW YORK

)

June 20, 1983 (Indian Point, Unit No. 3)

)

)

LICENSEES' RESPONSE TO REPORT OF PAUL J.

AMICO Consolidated Edison Company of New York, Inc. and the Power Authority of the State of New York, licensees of

-Indian Point Units 2 and 3, respectively, hereby respond to the-Letter from Paul J.

Amico to Administrative Judges (M4y 2, 1983) (Amico Letter), and to the Analysis of Proba-bilistic Risk Assessment Testimony:

Indian Point ASLB Hear-ings Commission Question 1 (June 1, 1983) (Amico Analysis),

as provided for by the Atomic Safety and Licensing Board's (Board's) Memorandum and Order of May 31, 1983.

The Board requested that Mr. Amico both summarize the issues pertaining to probabilistic risk assessment (PRA) and indicate whether additional testimony is needed for their 8306230376 830620 PDR ADDCK 05000247 aso3

resolution.

Letter from Jamma P.~Gleason, Chairman, to Mr.

Paul J.

Amico (Mar. 7, 1983).

Mr. Amico recommended addi-tional testimony in eight areas.

Amico Analysis $ 6.

These areas either (1)_are sufficiently addressed in the record, (2) do not present issues which would materially affect the record, or (3) would require an unnecessary expenditure of time and resources.

Because this proceeding is already one year behind the

- schedule originally mandated by the Commission, and because reopening the record would only further delay the submission of the Board's recommendations to the Commission, additional testimony should be taken only if the Board is persuaded that such testimony is likely to have a material impact upon the validity or accuracy of the presentations of risk already contained in the record.

The issue before the Board is not whether it possesses ultimate knowledge as to the risks posed by serious accidents at Indian Point, but whe-ther the current state of_ knowledge indicates the risks of continued plant operation to be sufficiently large to jus-tify plant shutdown.

Licensees contend that the Commission was aware of this evolutionary state of PRA technology and accepted the use of models and techniques generally avail-2 able at the start of the hearings as being sufficient to 4:

address the risk issue.

With one exception discussed below, it appears that receipt of further testimony would not have a material

impact upon the IPPSS results.

Since the excepted matter can be best handled other than by reopening the record, the licensees oppose the receipt of additional testimony on the topics raised by Mr. Amico.

Intervenors concur, for different reasons, with licen-sees' position that the record should not be reopened.

See Union of Concerned Scientists'/NYPIRG Response to Letter from P. J.

Amico, May 2, 1983 (June 10, 1983) (UCS/NYPIRG Response); Letter from Richard M. Hartzman, Esq. to Admini-strative Judges (June 10, 1983).1 1.

CRAC, CRAC2, and CRACIT Mr. Amico first suggested that the Nuclear Regulatory Commission Staff " provide a detailed technical summary of the difference between the CRAC code used for their assess-ment and the improved version CRAC 2."

Amico Analysis { 6, at 1.

Differences between the original CRAC code, developed for use in the Reactor Safety Study (RSS), and CRAC2 are described in detail in the Sandia siting study, NUREG/CR-l l

l 1.

While intervenors suggest that licensees should not l

have "a second bite at the apple," UCS/NYPIRG Response at 2, licensees maintain that the record contains adequate support l

for the conclusions that the risk assessments performed for Indian Point were valid and comprehensive and that the risk 4

i of Indian Point is very low.

It should be further noted that Mr. Amico's report is not part of the record, was not submitted under oath, and has not been subject to cross-examination by any of the parties.

Accordingly, it cannot serve as a basis for find-ings, conclusions, or recommendations in this proceeding.

L

2239, " Technical Guidance for Siting Criteria Development,"

(1982).(Appendix E).

Mr. Amico also suggested that the Staff " evaluate the l

potential effects on their final analysis of using CRAC 2 and should provide a reasonable justification of why they should not re-do their analysis using CRAC 2, since it is supposedly a more accurate code than CRAC, or else should provide the results of a re-analy[s]is using CRAC 2."

Amico Analysis 5 6, at 1.-

Further analysis will not provide the Board with new information to aid them in rendering a judg-ment because (1) differences between CRAC and CRAC2 are already described in documents available to the Board, (2)

Staff has already provided their reasons for using CRAC, (3) the codes have been demonstrated to be virtually identical in results, with any differences due to input assumptions rather than the codes, and (4) licensees presented testimony based upon the most accurate code available.

CRAC2 provides a more realistic model of several para-meters of potential importance in consequence assessment than does CRAC.

However, Staff does not " anticipate that we would see significant differences at all between the CRAC and CRAC-II [ sic] for these particular calculations that have been made."

Tr. at 8622 (Blond).

With the sole excep-tion of emergency response modeling and assumptions, bench-mark tests designed to evaluate the differences in these

5-I

' codes confirm Staff's position.1 Furthermore, Staff modified CRAC in assessing the Indian Point risk to update important evacuation response assumptions and models.

See Joint Testimony of Sarbeswar Acharya and Roger M. Blond Regarding Calculational Methodology of the CRAC Code at III.C.B-4 to III.C.B-6.

Additionally, the CRACIT code used in licensees' analy-sia does incorporate the more accurate parameter modeling included in CRAC2, and allows long duration releases to be modeled as a series of " puffs," which Staff agrees is a more i

realistic model.

Tr. at 8647 (Blond).

It is, thus, the most accurate and realistic consequence model presented at the proceeding.

Mr. Amico acknowledges that "the real significant con-tributor" to Staff's and licensees' consequence results is the emergency response assumptions-used by Staff for regional disasters, not the details of the computer codes.

In fact, Mr. Amico states that "this issue is the only sig-nificant issue in the ex-plant consequence analysis."

Amico

_ Analysis i 4, at 14 (emphasis added).

?

1.

D.C. Aldrich, et al.,

International Standard Problem for Consequence Modeling:

Results, in Proceedings

- of the International ANS/ ENS Topical Meeting on Probabilis-tic Risk Assessment at 787 (Sept. 20-24, 1981).

2.

MARCH 1.1 and MARCH 2.0 Mr. Amico recommended consideration of the MARCH 2.0 code rather than the MARCH 1.1 version for the containment analysis.

Amico Analysis $ 6, at 1.

Both Staff and licen-sees used versions of MARCH in their analyses of serious accidents.

Because both parties are aware of limitations in this code, their assessments were supported by additional analyses, including the use of supplemental computer codes.

See Indian Point Probabilisitc Safety Study (IPPSS) at 4.1-1 to 4.1-13; NUREG-0850, " Preliminary Assessment of Core Melt Accidents at the Zion and Indian Point Nuclear Power Plants and Strategies for Mitigating Their Effects" at 3-1, Vol. 1 (1981).

While an improved computer code would update-the current model, thereby limiting the additional analyses now required of containment analysts, additional

, testimony at this time based upon a code still undergoing peer review will not clarify or improve the record which is before the Board.

Mr. Amico also questions the use of the CORRAL 2 code as opposed to NAUA 4 in calculating radioactive releases.

Amico Analysis I-6, at 1-2.

Unlike NAUA, CORRAL does not fully consider natural fission product removal processes

-such as agglomeration and steam condensation on aerosols.

?

Thus, the Indian Point release fractions as computed in the IPPSS and by the Staff are conservatively overstated.

This leads to a substantial overstatement of risk in both IPPSS

and Staff analyses, particularly for early fatalities.

See Testimony of Dr. Sarbeswar Acharya Regarding NRC Staff Assessment of Accident Consequences and Risks at III.C.A-20 to III.C.A-21 (Acharya Testimony).

Inasmuch as the analytical tools and models used in PRA are currently undergoing continuous development and refine-ment, Mr. Amico's reasoning could be used to defer any Board decision indefinitely because there undoubtedly will be further revisions on these models in the future beyond those identified by Mr. Amico.

3.

Source Term Developments The licensees agree with Mr. Amico that the present Commission ~and industry (IDCOR),1 research regarding source terms is important, and that "[i]f this work shows a source term reduction on the order of a factor of ten, as is the, personal belief of Witness [ Robert] Bernero, this will cause a substantial impact on the results."

Amico Letter at 2; see Amico Analysis $ 6, at 2.

Sandia National Laboratories performed sensitivity studies to evaluate the impact of source term reductions upon the potential consequences of i

l reactor accidents.

They concluded that "[m]ean early fatal-ities are decreased dramatically (about two orders-of-4 l

1.

IDCOR is the Industry Degraded Core Rulemaking.

I t

I l

c

magnitude) by a one order-of-magnitude decrease in source term SST1."1 NUREG/CR-2239 at 1-3.

4 The NAUA 4 and CORRAL differences discussed above are but a part of larger fission product behavior issues.

Licensees presented the testimony of two noted experts in the field of radiation chemistry, Dr. William Stratton and Dr. Walton Rodger,2 regarding detailed, plant-specific cal-culations of fission product behavior for the two most important accident sequences at Indian Point.

See Licen-sees' Testimony of William R.

Stratton, Walton A.

Rodger, and Thomas E.

Potter on Question One at 68-86.

Based upon the more realistic source term calculations of Drs. Stratton and Rodger, a smaller Emergency Planning Zone may be war-ranted.

d. at 6.

Staff testified that these calculations were " reasonable," and that they had neither data nor infor-mation indicating that the calculations were wrong.

Tr. at 12,585, 12,589 (Bernero).

i 1.

This source term would be associated with a rela-tively rapid release of radioactivity.-

.2.

Dr. Stratton, a - member of the Advisory Committee on-Reactor Safeguards from 1966 to 1975, was also on the staff reporting to the President's Commission on the Accident at Three Mile Island.

Dr. Rodger is the lead contractor for IDCOR's section on Fission Product Transport and is the 1981 recipient of the American Institute of Chemical Engineers Robert E. Wilson Award.

I L.

While the use of more realistic source terms will have a major impact upon certain presentations of risk in the record, the Stratton, et al. testimony provides a sufficient basis for the Board to consider fission product behavior issues in making its findings on the Commission's Questions as of the present time.

Awaiting further Commission and industry research would unduly prolong this proceeding.

Additionally, there is no reason to delay, as Mr. Amico suggests, a final decision based upon the results of ongoing research because, notwithstanding the current overestimation of the source term in the IPPSS and Staff presentations, the risk of the plants is already demonstrated in the record to be extremely low.

This conclusion is reached by both Staff and licensees, despite differences in source term calcula-tions.

More realistic source terms would only reinforce that conclusion.

4.

Stress and Aging Factors Failure rates used in the IPPSS appropriately account for aging and stress effects.

Because failure rates are derived from data on a broad mix of equipment of various ages both at Indian Point and other nuclear power plants, any failures due to' aging are embedded in these failure rates.

Tr. at 7380-82 (Bley).

Stress effects are expli-E citly considered in determining failure / success probabil-l l

ities.

The use of a constant factor, as raised by Mr.

Amico, would be an oversimplification of these effects.

See

Tr. at 7033-35 (Shon, Kaplan, Bley).

Therefore, the risk analysis presented to the Board provides an adequate treat-t ment of aging and stress effects upon nuclear power plant i

equipment, and the receipt of further evidence on this topic would not have a material impact on that analysis.

5.

Sabotage Mr. Amico also proposed that the Board receive

"[e]xpert testimony on the significance of sabotage."

Amico Analysis { 6, at 2.

In its " Policy Statement on Safety Goals for the Operation of Nuclear Power Plants," the Com-mission stated, with respect to the possible effect of sabo-tage or diversion of nuclear materials, that "[a]t present there is no basis on which to provide a measure of risk on these matters.

It is the Commission's intention that every-i thing that is needed shall be done to keep such risks at their present,.very low, level; and it is our expectation that efforts on this point will continue to be success-ful."

48 Fed. Reg. 10,772, 10,773 (Mar. 14, 1983).

Thus the commission has, as a matter of policy, acknowledged that explicit treatment of sabotage in risk quantification stud-ies is presently beyond the state-of-the-art, but that pre-s'ent regulatory requirements, such as those employed at Indian Point, are sufficient to keep such risks acceptably low.

These requirements are included in extensive and 4

s,

,n

=

_. 4 detailed Commission regulations and procedures v/hich ade-quately address the issue of nuclear power plant security.1 Sabotage was specifically excluded from the IPPSS because the project team determined that it was not appro-priate in a study that was to be made public.

Tr. 7042, j

7050, 7147 (Garrick).

As Mr. Amico recognized, Amico Analysis { 6, at 2, it would obviously be inadvisable to present testimony on sabotage and security issues specific to Indian Point.

Thus, testimony in this area would not aid the Board in assessing the level-of risk at these plants.

Licensees continue to believe that testimony such as that suggested by Mr. Amico would be inappropriate in a public forum, and should certainly not be explored initially by the Commission on other than a generic or rulemaking basis.

6.

Point Estimates Mr. Amico suggested that the licensees "present the level 1-(point estimate) risk curves for external initiators and total risk rather than just the level 2 (confidence i

1.

See, e.jt., 10 C.F.R. Part 34(c) (physical security plan required); 10 C.F.R. Part 73 (physical protection of plants and materials); Reg. Guide 5.7 (Entry / Exit Control for Protected Areas, Vital Areas and Material Access Area);

I Reg. Guide 5.14 (Use of Observ'ation (visual surveillance)

Technique in Material Access Areas); Reg. Guide 5.43 (Plant Security Force Duties); Reg. Guide 5.44 (Perimeter Intrusion Alarm System); Reg. Guide 5.54 (Standard Format and Content of Safeguards Contingency Plans for Nuclear Power Plants);

NUREG 0464, " Site Security Personnel Training Manual."

4

-.,,,.. -.. -, -. - -,,, _ _ -, =..,.

i level) curves for these items."

Amico Analysis $ 6, at 2.

In presenting Level 2 risk curves, Which include an explicit quantification of uncertainty, licensees have submitted to the Board a complete picture of the risk at Indian Point.

By~ calculating. uncertainty in a manner that is at the " fore-front" of the methodology, Tr. at 8614 (Blond), the authors of IPPSS have been responsive to the Lewis Committee and other revicwers of the RSS who advocated a frank presen-tation of uncertainty.

Submitting point estimates, Which I

have no precise definitions, see Tr. at 8247 (Kaplan), would not contribute to the Board's recommendation to the Commis-sion regarding "[w3 hat-risk may be posed by serious acci-dents at Indian Point 2 and 3."

In re Consolidated Edison Company of New York, Inc., 14 N.R.C.

610, 612 (Sept. 18, i

1981).

While it may not be " appropriate" to compare point estimates provided by Staff with risk curves provided by licensees, see Acharya Testimony at III.C.A-39 n.*,

III.C.A-43 to III.C.A-45, such a comparison is not necessary to answer the Commission's question.

Staff-has presented its assessment of the health risk at Indian Point, based on point estimates, and has concluded

~

that the risk is not high, Direct Testimony of Frank H.

E Rowsome to Contention 1.1 and Board Question 1.1, at 2, that it is within the range of risks posed by other nuclear power 4

4 plants, and that it meets the Commission's preliminary l

safety goals.

Direct Testimony of Frank Rowsome and Roger f

m

1 13 -

Blond Concerning Commission Question 5, at [A333, B-3, B-13, B-16.

Licensees presented a more complete analysis of the risk and arrived at the same conclusions.

The record is complete regarding the level of risk posed by serious acci-dents at Indian Point.

7.

Safety Goal Comparisons The information is already available for the direct comparison recommended by Mr. Amico, Amico Analysis $ 6, at 3, by the Staff of their results with the Commission's pre-liminary safety goals.

Staff estimates of core melt fre-quencies are in Table 1 of the Staf f's testimony on damage state likelihoods.

Direct Testimony of Frank H.

Rowsome Concerning Damage State Likelihoods at Table 1 (row labeled

" grand total").

Staff estimates of societal risk within 50 miles have also been presented, see Direct Testimony of Frank H.

Rowsome to Contention 1.1 and Board Question 1.1, at 2-3; Testimony of Dr. Sarbeswar Acharya Regarding NRC Staff Assessment of Accident Consequences and Risks at Tables III.C-8 and III.C-9, as have estimates of risk to individuals within one mile of the plant with supportive medical treatment.

Testimony of Dr. Sarbeswar Acharya Regarding NRC Staff Assessment of Accident Consequences and Risks at Figure III.C.50.

8.

Pressurized Thermal Shock The Board has received sufficient testimony regarding the importance of pressurized thermal shock (PTS)' to the n

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risk at Indian Point.

Licensees presented the low frequency of vessel failure from all causes, of which PTS is only a subset.

They also presented a conservative approximation of the probability of extension without arrest of cracks in the vessel.

See Licensees' Testimony of Dennis C. Richardson and Dennis C.

Bley on Board Question 1.4, at 2, 3.

Because the Indian Point plants have not reached a level in which the Commission's screening criterion for acceptability regarding PTS would suggest the problem even needs further analysis, Staff concluded that the "present and continuing acceptability of PTS risk is assured."

Dr. Hugh W. Woods and Raymond W.

Klecker on Board Question 1.4, at 10.

Addi-tional testimony on this issue will not add to the Board's state of knowledge concerning the risk at Indian Point, nor-materially affect presentation of that risk.

?

Conclusion For the foregoing reasons, the Board should not delay the completion of this proceeding by reopening the record.

sp tfully su d,

J f

g Brent L j andenburg [] F arles Morgh -rJr.

Assistant General Coun1el Paul F.

Colarulli Joseph J.

Levin, Jr.

CONSOLIDATED EDISON CO.

OF NEW YORK, INC.

MORGAN ASSOCIATES, CHARTERED Licensee of Indian Point 1899 L Street, N.W.

Unit 2 Washington, D.C.

20036 4 Irving Place (202) 466-7000 New York, New York 10003 Stephen L.

Baum General Counsel Charles M.

Pratt Assistant General Counsel POWER AUTHORITY OF THE STATE OF NEW YORK Licensee of Indian Point Unit 3 10 Columbus Circle New York, New York 10019 (212) 397-6200 Bernard D. Fischman Michael Curley Richard F.

Czaja David H.

Pikus SHEA & GOULD l

l 330 Madison Avenue New York, New York 10017 (212) 370-8000 Dated:

June 20, 1983 l

t

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

James P.

Gleason, Chairman Frederick J.

Shon Dr. Oscar H.

Paris

)

In the Matter of

)

)

CONSOLIDATED EDISON COMPANY OF

)

Docket Nos.

NEW YORK, INC.

)

50-247 SP (Indian Point, Unit No. 2)

)

50-286 SP

)

POWER AUTHORITY OF THE STATE OF

)

June 20, 1983 NEW YORK

)

(Indian Point, Unit No. 3)

)

)

CERTIFICATE OF SERVICE I hereby certify that on the 20th day of June, 1983, I caused a copy of Licensees' Response to Raport of Paul J.

Amico, to be served by first class mail, postage rapaid on the following:

James P. Gleason, Chairman Charles M.

Pratt, Esq.

Administrative Judge Stephen L.

Baum, Esq.

Atomic Safety and Licensing Board Power Authority of the 513 Gilmoure Drive State of New York Silver Spring, Maryland 20901 10 Columbus Circle New York, New York 10019 Mr. Frederick J.

Shon Administrative Judge Janice Moore, Esq.

Atomic Safety and Licensing Board Counsel for NRC Staff U.S.

Nuclear Regulatory Office of the Executive Commission Legal Director Washington, D.C.

20555 U.S.

Nuclear Regulatory Commission Washington, D.C.

20555 Dr. Oscar H.

Paris Administrative Judge Brent L.

Brandenburg, Esq.

Atomic Safety and Licensing Board Assistant General Counsel U.S.

Nuclear Regulatory Consolidated Edison Company Commission of New York, Inc.

Washington, D.C.

20555 4 Irving Place New York, New York 10003 Docketing and Service Branch Office of the Secretary Ellyn R. Weiss, Esq.

U.S.

Nuclear Regulatory Commission William S. Jordan, III, Esq.

Washington, D.C.

20555 Harmon and Weiss 1725 I Street, M.W.,

Suite 506 Joan Holt, Project Director Washington, D.C.

20006 Indian Point Project New York Public Interest Research Charles A.

Scheiner, Co-Chairperson Group Westchester People's Action 9 Murray Street Coalition, Inc.

New York, New York 10007 P.O.

Box 488 White Plains, New York 10602 Jeffrey M.

Blum, Esq.

New York University Law School Alan Latman, Esq.

423 Vanderbilt Hall 44 Sunset Drive 40 Washington Square South Croton-On-Hudson, New Y rk 10520 o

New York, New York 10012 Ezra I.

Bialik, Esq.

Charles J.

Maikish, Esq.

Steve Leipzig, Esq.

Litigation Division Environmental Protection Bureau The Port Authority of New York New York State Attorney and New Jersey General's Office One World Trade Center Two World Trade Center New York, New York 10048 New York, New York 10047 Andrew S.

Roffe, Esq.

New York State Assembly Albany, New York 12248

e Marc L.

Parris, Esq.

Atomic Safety and Licensing Eric Thorsen, Esq.

Board Panel County Attorney U.S.

Nuclear Regulatory Commission County of Rockland' Washington, D.C.

20555 11 New Hempstead Road New City, New York 10956 Atomic Safety and Licensing Appeal Board Panel Phyllis Rodriguez, Spokesperson U.S.

Nuclear Regulatory Commission Parents Concerned About Indian Washington, D.C.

20555 Point P.O.

Box 125 Honorable Richard L.

Brodsky Croton-on-Hudson, New York 10520 Member of the County Legislature Westchester County Renee Schwartz, Esq.

County Office Building Paul Chessin, Esq.

White Plains, New York 10601 Laurens R.

Schwartz, Esq.

Margaret Oppel, Esq.

Zipporah S.

Fleisher Botein, Hays, Sklar and Hertzberg West Branch Conservation 200 Park Avenue Association New York, New York 10166 443 Buena Vista Road New City, New York 10956 Honorable Ruth W. Messinger Member of the Council of the Mayor George V.

Begany City of New Y rk Village of Buchanan o

District #4 236 Tate Avenue City Hall Buchnnan, New York 10511 New York, New York 10007 Judith Kessler, Coordinator Greater New York Council Rockland Citizens for Safe Energy on Energy 300 New Hemstead Road j

c/o Dean R.

Corren, Director New City, New York 10956 New York University 26 Stuyvesant Street David H.

Pikus, Esq.

New York, New York 10003 Richard F.

Czaja, Esq.

Shea & Gould Joan Miles 330 Madison Avenue Indian Point Coordinator New York, New York 10017 New York City Audubon Society 71 West 23rd Street, Suite 1828 Amanda Potterfield, Esq.

New York, New York 10010 New York Public Interest Research Group, Inc.

Richard M. Hartzman, Esq.

9 Murray Street, 3rd Floor Lorna Salzman-New York, New York 10007 l

Mid-Atlantic Representative l

Friends of the Earth, Inc.

David R.

Lewis, Esq.

208. West 13th Street Atomic Safety and New York, New York 10011 Licensing Board Panel U.S.

Nuclear Regulatory Stanley B.

Klimberg, Esq.

Commission General Counsel Washington, D.C.

20555 New York State Energy Office 2 Rockefeller State Plaza Albany, New York 12223

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e Mr. Donald Davidoff Andrew P. O'Rourke Director, Radiological Emergency Westchester County Executive Preparedness Group 148'Martine Avenue Empire State Plaza White Plains, New York 10601 Tower Building, Rm. 1750 Albany, New York 12237 Craig Kaplan, Esq.

National Emergency Civil Liberties Committee 175 Fifth Avenue, Suite 712 New York, New York 10010 Michael D.

Diederich, Jr.,

Esq.

Attorney-At-Law 11 South Highland Avenue (Route 9W)

Nyack, New York 10960 Steven C.

Sholly Union of Concerned Scientists 1346 Connecticut Avenue, N.W.

Suite 1101 Washington, D.C.

20036 Spence W.

Perry Office of General Counsel Federal Emergency Management Agency 500 C Street, S.W.

Washington, D.C.

20472 l

Stewart M. Glass Regional Counsel Room 1349 Federal Emergency Management Agency 26 Federal Plaza l

New York, New York 10278 l

Melvin Goldberg Staff Attorney New York Public Interest Research Group 9 Murray Street New York, New York 10007 Jonathan L.

Levine, Esq.

f P.

O.

Box 280 Q

New City, New York 10958

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