ML022480466
| ML022480466 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/03/2002 |
| From: | Bray C, Fernandez A NRC/OGC |
| To: | NRC/OCM |
| Byrdsong A T | |
| References | |
| +adjud/rulemjr200506, 50-423-LA-3, ASLBP 00-711-01-LA, LBP-02-16, RAS 4814 | |
| Download: ML022480466 (15) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION RAS 4814 DOCKETED 09/05/02 BEFORE THE COMMISSION In the Matter of
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DOMINION NUCLEAR CONNECTICUT, INC. )
Docket No. 50-423-LA-3
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(Millstone Power Station, Unit No. 3)
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NRC STAFF RESPONSE IN OPPOSITION TO PETITION FOR REVIEW OF LBP-02-16 Antonio Fernández Cassie E. Bray Counsel for NRC Staff September 3, 2002
TABLE OF CONTENTS INTRODUCTION........................................................... 1 BACKGROUND............................................................ 1 DISCUSSION.............................................................. 3 I.
10 C.F.R. § 2.786
............................................... 3 II.
SUBPART KS REQUIREMENTS FOR AN EVIDENTIARY HEARING....... 3 III.
INTERVENORS ARGUMENTS REGARDING THE LICENSEES ALLEGED FAILURE TO REPORT THE MISSING FUEL RODS FROM UNIT 1 DO NOT SATISFY THE REQUIREMENTS OF A PETITION FOR REVIEW........... 4 IV.
THE BOARD CORRECTLY REFUSED TO CONSIDER NNECOS PRIOR CONDUCT, WHICH FELL OUTSIDE THE SCOPE OF CONTENTION 4...... 6 V.
THE ADMINISTRATIVE CONTROLS AT MILLSTONE UNIT 3 SUFFICIENTLY PROTECT AGAINST A CRITICALITY ACCIDENT....................... 8 A.
Intervenors argument regarding the complexity of the administrative controls is precluded........................................ 8 B.
The administrative controls at Millstone-1 and Millstone-3 lack commonality.............................................. 9 CONCLUSION............................................................ 10
1 On March 31, 2001, Dominion Nuclear Connecticut, Inc. (DNC) assumed ownership of Millstone Nuclear Power Station, Unit No. 3.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of
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DOMINION NUCLEAR CONNECTICUT, INC. )
Docket No. 50-423-LA-3
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(Millstone Power Station, Unit No. 3)
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NRC STAFF RESPONSE IN OPPOSITION TO PETITION FOR REVIEW OF LBP-02-16 INTRODUCTION On August 9, 2002, the Atomic Safety and Licensing Board issued a decision in the above-captioned Subpart K proceeding, deciding the reopened issue in favor of the licensee. Dominion Nuclear Connecticut, Inc. (Millstone Nuclear Power Station, Unit No. 3), LBP-02-16, slip. op.
(August 9, 2002). The Connecticut Coalition Against Millstone and the Long Island Coalition Against Millstone (Intervenors) filed a Petition for Review of the Licensing Boards decision with the Commission on August 23, 2002, Intervenors Petition for Review (August 23, 2002)(hereinafter Petition for Review), contending that the Licensing Board erred in denying the Intervenors an evidentiary hearing on the reopened proceeding. The United States Nuclear Regulatory Commission (NRC) staff (Staff), pursuant to 10 C.F.R. § 2.786(b)(3), submits its Response in Opposition to the Petition for Review.
BACKGROUND Northeast Nuclear Energy Company (NNECO) applied for a license amendment to increase the capacity of the spent fuel pool at Millstone Nuclear Power Station, Unit No. 3.1 The Intervenors filed contentions opposing the license amendment. The Licensing Board admitted three contentions, and the licensee invoked the use of Subpart K procedures. 10 C.F.R. Part 2, Subpart K. Accordingly, the Board heard oral argument. See id. In a Memorandum and Order, the Board denied the Intervenors request for a full evidentiary hearing regarding the issues in Contention 4. Northeast Nuclear Energy Co. (Millstone Nuclear Power Station, Unit 3), LBP-00-26, 52 NRC 181 (2000). The Intervenors petitioned for Commission review of the Boards denial. The Commission denied review as to Contention Four, holding the Boards denial of the evidentiary hearing to be well supported by the record. See Northeast Nuclear Energy Co. (Millstone Nuclear Power Station, Unit 3), CLI-01-3, 53 NRC 22, 26-27 (2001).
On November 16, 2000, NNECO notified the NRC that it was unable to account for two spent fuel rods in the Millstone-1 spent fuel pool. Intervenors used this information as a basis for their Motion to Reopen and to Vacate. The Commission remanded to the Board the Motion to Reopen and to Vacate. Northeast Nuclear Energy Co. (Millstone Nuclear Power Station, Unit No.
3), CLI-00-25, 52 NRC 355, 357 (2000). Although the Board initially denied the Motion to Reopen, on reconsideration it determined to grant it. Specifically, the Board reopened Contention 4 to explore whether there [was] any commonality between procedures involved in the Unit 1 event and the Unit 3 procedures supporting the revised Unit 3 SFP storage configuration. See Millstone, LBP-02-16, at 6. The Board viewed the primary issue before it as whether DNC could implement proper administrative controls for monitoring spent fuel rods at Unit 3, given the incident that occurred at Unit 1.
The Board determined that an evidentiary hearing was unnecessary in this action, holding that the licensees failing to report the missing fuel rods at Unit 1 to the Board was peripheral at best to the central issue of whether DNC could implement adequate administrative controls for the SFP at Unit 3. See Millstone, LBP-02-16, at 15-16. Additionally, the Board recognized that events occurring at Unit 1 had little bearing on the ability of Unit 3 to implement administrative controls, because there is little commonality in the units procedures. See id. at 9-10. The Board concluded that the administrative controls, for the SFP at Unit 3, would sufficiently protect against a criticality accident. See id. at 13. The Intervenors seek Commission review of the Boards ruling.
DISCUSSION I.
10 C.F.R. § 2.786 A petition for review may be granted in the discretion of the Commission, giving due weight to the existence of a substantial question with respect to the following considerations: (i) a finding of material fact is clearly erroneous or in conflict with a finding as to the same fact in a different proceeding; (ii) a necessary legal conclusion is without governing precedent or is a departure from or contrary to established law; (iii) a substantial and important question of law, policy, or discretion has been raised; (iv) the conduct of the proceeding involved a prejudicial procedural error; or (v) any other consideration which the Commission may deem to be in the public interest.
10 C.F.R. § 2.786(b)(4)(i)-(v); see Advanced Medical Sys., Inc., CLI-93-8, 37 NRC 181, 184 (1993).
The Commission exercises its power to review a boards factual findings carefully. See Louisiana Energy Serv., L.P. (Claiborne Enrichment Center), CLI-98-3, 47 NRC 77, 93 (1998). Moreover, when reviewing a boards decision, the Commission will attach significance to a licensing boards evaluation of the evidence and to its disposition of the issues. Id.
II.
SUBPART KS REQUIREMENTS FOR AN EVIDENTIARY HEARING The Commissions regulations establish a high threshold for obtaining an evidentiary hearing in a Subpart K proceeding. The rule states:
No issue of law or fact shall be designated for resolution in an adjudicatory hearing unless the presiding officer determines that:
(1) There is a genuine and substantial dispute of fact which can only be resolved with sufficient accuracy by the introduction of evidence in an adjudicatory hearing; and (2) The decision of the Commission is likely to depend in whole or in part on the resolution of that dispute.
2 As the Commission noted when it promulgated the final rule, [the Nuclear Waste Policy Act criteria for granting an evidentiary hearing require] a finding that adjudication is necessary to resolution of the dispute and [place] the burden of demonstrating the existence of a genuine and substantial dispute of material fact on the party requesting adjudication. Hybrid Hearing Procedures for Expansion of Spent Nuclear Fuel Storage Capacity at Civilian Nuclear Power Reactors, 50 Fed. Reg. 41,662, 41,667 (1985).
10 C.F.R. § 2.1115(b)(1)-(2). Any issues not meeting this test have to be disposed of by the Board promptly by written order subsequent to the oral argument. 10 C.F.R. § 2.1115(b)(1)-(2).
Intervenors have asserted that their petition meets the criteria in section 2.786 and contend that, in accordance with section 2.115, the Board should have ordered an evidentiary hearing. But, as discussed below, the Intervenors have failed to raise a substantial question with respect to any of the considerations in section 2.786 so as to warrant Commission review of the Boards Order.
Further, the Intervenors have not shown that Subpart Ks requirements to grant an evidentiary hearing have been met.2 Accordingly, Commission review should be denied.
III.
INTERVENORS ARGUMENTS REGARDING THE LICENSEES ALLEGED FAILURE TO REPORT THE MISSING FUEL RODS FROM UNIT 1 DO NOT SATISFY THE REQUIREMENTS OF A PETITION FOR REVIEW.
Throughout the Petition for Review, Intervenors raise the issue of the licensees obligation to notify the Board, the Staff and the Intervenors themselves about the ongoing investigation regarding the missing fuel rods at Millstone Unit 1's spent fuel pool. See Petition for Review, at 6-9.
Based on these notification obligations, the Intervenors argue that the Board erred in considering the licensees reporting delay separately from the licensees alleged prior bad conduct. See Petition for Review at 7, 8; see also infra at 7. In fact, many of the major arguments in the petition are based on the Boards dismissal of this issue below. We discuss each of Intervenors arguments in turn.
First, Intervenors request that the Commission review the Boards decision denying an evidentiary hearing based on Intervenors belief that the licensee had an obligation to report the events at Millstone, Unit 1 to the Board. However, Intervenors fail to point out that, as the record 3 Early in the oral argument, Intervenors counsel mentioned the issue of Board notification regarding the events at Unit 1. Tr. 712. However, a careful reading of the transcript shows that Intervenors counsel was addressing the requirement to supplement discovery, as opposed to the separate and distinct issue of a partys obligation to notify the Board pursuant to McGuire.
Compare id. with Tr. 725-26 (citing Duke Power Co. (William B. Mc Guire Nuclear Station, Units 1 &2), ALAB-143, 6 AEC 623, 625 (1973)).
reflects, it was not they who raised this issue in the proceeding below.3 Tr. 716-27. Rather, the Board raised the issue and questioned the parties regarding their Board notification obligations.
Id. As the Commission has previously noted, intervenors may not raise issues on appeal that they did not raise before the Presiding Officer. See Hydro Resources, Inc., CLI-00-8, 51 NRC 227, 243 (2000); see also Philadelphia Elec. Co. (Limerick Generating Station Units 1 and 2), ALAB-845, 24 NRC 220, 235 (1986). As the record reflects, in the instant case, it was the Board that raised the issue of Board notification and only after substantial questioning from the Board did Intervenors counsel concede that the licensee may have had a duty to report the events at Millstone, Unit 1 to the Board. Tr. 725. In any event, the Board resolved the issue it raised at oral argument by deciding that any issue regarding Board notification was peripheral at best to the licensees ability or willingness to carry out SFP administrative controls adequately. See LBP-02-16 at 15-16.
Furthermore, it is important to point out that the proceeding below was reopened for the sole purpose of determining whether the loss of the spent fuel rods at Unit 1 bore on the licensees ability or willingness to locate fuel in Unit 3. See Board Memorandum and Order Reopening Proceeding at 15. Therefore, any issue regarding if and when obligations to notify the Board of the events at Unit 1 arose has no bearing on the substantive issues of the reopened proceeding.
Consequently, Intervenors reliance on that issue as the basis for their Petition for Review is misplaced.
Second, Intervenors rely on their argument that the licensee did not report the events at Unit 1 to the NRC staff in a timely manner. As with the issues surrounding Board notification, this issue is beyond the purview of the reopened proceeding and, as the Board put it, is only of peripheral importance. Moreover, the issues associated with notification of the NRC were resolved through the enforcement process, which recently culminated in the issuance of a Notice of Violation and Imposition of Civil Penalty to the licensee. See Letter from Hubert J. Miller to J. Alan Price, dated June 25, 2002 (ADAMS accession number ML021760787). The licensee did not request a hearing and paid the civil penalty. See Letter from J. Alan Price to Frank Congel, dated July 19, 2002 (ADAMS accession number ML022250677).
Last, Intervenors argue that they should have been notified of the events at Unit 1, pursuant to the licensees obligations to update their interrogatory responses. See Petition for Review at 3.
As with the two previous issues, this issue does not provide a sufficient basis to grant the Petition for Review. First, and most importantly, this issue fails to raise any substantial questions regarding any of the findings or conclusions made by the Board. A discovery dispute between an intervenor and a licensee is irrelevant to a Commission determination of whether to review a board order.
IV.
THE BOARD CORRECTLY REFUSED TO CONSIDER NNECOS PRIOR CONDUCT, WHICH FELL OUTSIDE THE SCOPE OF CONTENTION 4.
Generally, the scope of a contention is restricted to the scope of the licensing proceeding.
See Duke Energy Corp. (Oconee Nuclear Station, Units 1, 2, & 3), CLI-99-11, 49 NRC 328, 333 (1999). The scope of the contention in this reopened proceeding is the relationship of the Unit 1 event to administrative procedures for operation of the Millstone-3 reconfigured pool.
The Commission remanded the Intervenors Motion to Reopen to the Board for its reconsideration. Upon reconsidering, the Board granted the motion. The Board indicated that, given the loss of the fuel rods at Millstone-1, there was cause to reopen the record on Contention 4, to the extent it bears upon both the adequacy of administrative controls at the Millstone-3 SFP and DNCs ability or willingness to implement such controls successfully. Dominion Nuclear Connecticut, Inc. (Millstone Nuclear Power Station, Unit 3), LBP-01-17, 53 NRC 398, 408 (2001).
The Board expressly limited the scope of the reconsideration, however, to the procedures or controls for management of the SFPs and their modes of execution that may be common to Millstone-1 and Millstone-3. Id.
The Intervenors argue, under 10 C.F.R. § 2.786(b)(4)(iii), that the Board committed a substantial error when it failed to consider NNECOs past safety culture. They contend the Board should have considered NNECOs alleged past criminal conduct and violations of the regulations governing nuclear power plants. See Petition for Review, at 7. Additionally, the Intervenors allege the Board erred in failing to consider the notoriety NNECO achieved by engaging in retaliatory employment practices against nuclear whistleblowers and fostering a work environment that was not safety conscious. Id.
Notwithstanding Intervenors arguments, the Board did not err in refusing to consider allegations of NNECOs prior bad conduct. The Commission has held that poor character or prior bad acts will not be considered unless the prior conduct is within the scope of the proceeding or, in this instance, within the scope of the reopened contention. See Dominion Nuclear Connecticut, Inc. (Millstone Nuclear Power Station, Units 2 and 3), CLI-01-24, 54 NRC 349, 365 (2001).
Contrary to the Intervenors demand that past bad conduct be considered, not every licensing action throws open an opportunity to engage in a free-ranging inquiry into the character of the Licensee. Georgia Power Co. (Vogtle Electric Generating Plant, Units 1 and 2), CLI-93-16, 38 NRC 25, 32 (1993). Rather, for character to be considered, the character issues must directly relate to the licensing proceeding. See id.
The character issues raised by the Intervenors do not relate to the ability of NNECO and DNC to implement administrative controls for the SFP. In fact, Intervenors simply rely upon generalized allegations that, in the past, NNECO violated federal requirements governing nuclear power plants. As the Commission has noted, allegations of management improprieties or poor integrity... must be of more than historical interest: they must relate directly to the proposed licensing action. Georgia Institute of Technology (Georgia Tech Research Reactor, Atlanta, Georgia), CLI-95-12, 42 NRC 111, 120 (1995). Other than the issue regarding the loss of control of two fuel rods, which the Board properly included in its analysis, the Intervenors have not presented for the Boards consideration any additional evidence of poor conduct directly relating to the pending licensing action associated with the spent fuel pools. Thus, the Board did not err when it refused to consider generalized allegations of poor conduct falling outside the narrow scope of the reopened issue. The Intervenors allegations do not satisfy any of the standards in § 2.786, and the Commission should deny review.
V.
THE ADMINISTRATIVE CONTROLS AT MILLSTONE UNIT 3 SUFFICIENTLY PROTECT AGAINST A CRITICALITY ACCIDENT.
A.
Intervenors argument regarding the complexity of the administrative controls is precluded.
The Intervenors argue, pursuant to 10 C.F.R. § 2.786(b)(4)(i), that the Board erred in making a finding of material fact that DNC can be relied upon to implement complex administrative controls. The foregoing issue has been raised and adjudicated.
Under the original scope of Contention 4, Intervenors alleged that the administrative controls to be instituted at Millstone-3 were more complex than previous controls. See Millstone, LBP-00-26, 52 NRC at 191. Intervenors contended that NNECO would not be able to carry out more complex administrative controls without increasing the potential for a criticality accident. See id. The Board resolved this issue, determining that the administrative controls were sufficient and that NNECO could adequately implement them. See id. at 200. The Board stated, We find that NNECO has demonstrated that it can adhere to administrative controls, with adequate safety margin and defense-in-depth, without posing an undue or unnecessary risk to plant workers or the public. Id. The Commission accepted the Boards factual analysis and denied the Intervenors earlier petition for review as to Contention 4. See Millstone, CLI-01-3, 53 NRC at 26-27. Intervenors 4 At the April 2, 2002 oral argument, the Board did not revisit the complexity of the administrative controls issue. See Millstone, LBP-02-16, at 5-6. Rather, the Board only addressed whether there was any commonality between the administrative controls at Millstone-1 and Millstone-3. See id.
5It should be noted that the comparison is between the new Millstone-3 administrative controls and the pre-decommissioning Millstone-1 administrative controls.
are precluded from again seeking to raise this very issue in the instant Petition for Review, as final judgment on this issue has been rendered.4 B.
The administrative controls at Millstone-1 and Millstone-3 lack commonality.
The Intervenors argue, pursuant to 10 C.F.R. § 2.786(b)(4)(i), that the Board erred in finding the incident at Millstone-1--the loss of control of two fuel elements-- had no bearing on DNCs ability to implement administrative controls at Millstone-3. Although the Commission has the authority to reject or modify a licensing boards factual findings, it will not do so lightly. Louisiana Energy Serv. (Claiborne Enrichment Center), CLI-98-3, 47 NRC 77, 93 (1998).
The Board carefully analyzed the commonality of administrative controls between Millstone-1 and Millstone-3.5 See Millstone, LBP-02-16, at 9-13. Initially, the Board recognized that the administrative controls used at the Millstone-3 SFP are more sophisticated than the controls used at Millstone-1. See id. at 9. The Board found that the controls on fuel inventory at Millstone-3 provide for a redundant set of inventory data through a computer generated record which echos the information maintained on index cards. Id. The dual record-keeping helps to ensure that Millstone-3 adequately tracks all fuel assemblies and avoids the occurrence of misplaced fuel rods, such as at Millstone-1. Id. Thus, the administrative controls at Millstone-3 for tracking fuel are considerably more detailed and reliable than the procedures that resulted in the inability to account for two fuel rods at Millstone-1. Id.
In addition, experts have provided testimony that the administrative controls at Unit 1 and Unit 3 have little in common. The weaknesses associated with Unit 1 are not evidenced at Unit 3.
See Cerne Affidavit ¶ 11 (filed on March 18, 2002). For example, Unit 1 permitted fuel rods to be stored outside the fuel racks in the SFP. See Bellamy Affidavit ¶ 5 (filed on March 18, 2002). Unit 3, however, does not permit fuel rods to be stored in any location other than the designated fuel racks. See Cerne Affidavit ¶ 11. Furthermore, the NRC Senior Resident Inspector, who inspected and supervised NRC inspectors during Millstone-3 refueling activities, attested, the entire body of administrative controls employed in the refueling operations that I have inspected contains both the procedural specificity and the redundancy necessary to preclude a single human error from presenting a challenge to nuclear safety at Millstone Unit 3. Id. at ¶¶ 14, 17; see also Millstone, LBP-02-16, at 10-11.
The Intervenors failed in their Petition for Review to meet their burden of indicating specific findings of fact that are clearly erroneous and explaining why the findings are clearly erroneous.
The Boards findings of fact are well supported by expert testimony and deserving of deference from the Commission.
CONCLUSION The Staff submits that the Boards rulings are consistent with Commission precedent, common methods of regulatory analysis, and are well grounded in law and fact. Intervenors have failed to demonstrate the existence of a substantial question with respect to any of the considerations specified in 10 C.F.R. § 2.786. Therefore, the Petition for Review should be denied.
Respectfully submitted,
/RA/
Antonio Fernández Counsel for NRC Staff
/RA/
Cassie E. Bray Counsel for NRC Staff Dated at Rockville, Maryland this 3rd day of September, 2002
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of DOMINION NUCLEAR CONNECTICUT, INC.
(Millstone Power Station, Unit No. 3)
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Docket No. 50-423-LA-3
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CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF RESPONSE IN OPPOSITION TO PETITION FOR REVIEW OF LBP-02-16 and NOTICE OF APPEARANCE FOR CASSIE E. BRAY in the above-captioned proceeding have been served on the following by deposit in the NRCs internal mail system, or by deposit in the U.S. Postal Service as indicated by an asterisk, this 3rd day of September, 2002. Additional e-mail service has been made this same day as shown below.
Charles Bechhoefer, Chairman Administrative Judge Atomic Safety and Licensing Board Mail Stop: T 3F-23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 (E-mail copy to CXB2@nrc.gov.)
Dr. Richard F. Cole Administrative Judge Atomic Safety and Licensing Board Mail Stop: T 3F-23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 (E-mail copy to RFC1@nrc.gov.)
Dr. Charles N. Kelber Administrative Judge Atomic Safety and Licensing Board Mail Stop: T 3F-23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 (E-mail copy to CNK@nrc.gov.)
Office of the Secretary ATTN: Rulemaking and Adjudications Staff Mail Stop: O 16C-1 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 (E-mail copy to HEARINGDOCKET@nrc.gov.)
Office of the Commission Appellate Adjudication Mail Stop: O 16C-1 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Lillian M. Cuoco, Esq.*
Dominion Nuclear Connecticut, Inc.
Millstone Power Station Building 475/5 Rope Ferry Road (Route 156)
Waterford, Connecticut 06385 (E-mail copy to Lillian_Cuoco@dom.com.)
Nancy Burton, Esq.*
147 Cross Highway Redding Ridge, CT 06876 (E-mail copy to nancyburtonesq@hotmail.com.)
Adjudicatory File Atomic Safety and Licensing Board Panel Mail Stop: T 3F-23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 David A. Repka, Esq.*
Counsel for Dominion Nuclear Connecticut, Inc.
Winston & Strawn 1400 L. Street N.W.
Washington, D.C. 20005-3502 (E-mail copy to drepka@winston.com.)
Diane Curran, Esq.*
Harmon, Curran, Spielberg & Eisenberg 1726 M Street, N.W., Suite 600 Washington, D.C. 20036 (E-mail copy to dcurran@harmoncurran.com)
Michelle McKown, Esq.
Atomic Safety and Licensing Board Panel Mail Stop: T 3F-23 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 (E-mail copy to MRM@nrc.gov)
/RA/
Cassie E. Bray Counsel for NRC Staff
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of
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DOMINION NUCLEAR CONNECTICUT, INC. )
Docket No. 50-423-LA-3
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(Millstone Power Station, Unit No. 3)
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NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney enters an appearance in the above-captioned matter. In accordance with 10 C.F.R. § 2.713(b), the following information is provided:
Name:
Cassie E. Bray Address:
Office of the General Counsel, 0-15D21 U.S. Nuclear Regulatory Commission Washington, DC 20555 Telephone Number:
(301) 415-8554 Fax Number:
(301) 415-3725 E-mail Address:
CEB4@NRC.gov Admissions:
State of Arizona Respectfully submitted,
/RA/
Cassie E. Bray Counsel for NRC Staff Dated at Rockville, Maryland this 3rd day of September, 2002