ML081580466
| ML081580466 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 04/02/2008 |
| From: | Jeremy Dean, Matthews J, Musegaas P, Pruyne J, Riesel D, Sipos J, Snook R Riverkeeper, Sive, Paget & Riesel, PC, State of CT, Office of the Attorney General, State of NY, Dept of Environmental Conservation, State of NY, Office of the Attorney General, Town of Cortlandt, NY, Westchester County, NY |
| To: | Lathrop K, Lawrence Mcdade, Richard Wardwell Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01, RAS-E-107 | |
| Download: ML081580466 (19) | |
Text
DOCKETED USNRC
-'CELSIO0 April 3, 2008 (8:30am)
OFFICE OF SECRETARY STATE OF NEW YORK RULEMAKINGS AND OFFICE OF THE ATTORNEY GENERAL ADJUDICATIONS STAFF ANDREW M. CUOMO DIVISION OF SOCIAL JUSTICE ATTORNEY GENERAL ENVIRONMENTAL PROTECTION BUREAU April 2, 2008 Lawrence G. McDade, Chair Richard E. Wardwell, Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Mail Stop - T-3 F23 Mail Stop - T-3 F23 Two White Flint North Two White Flint North 11545 Rockville Pike 11545 Rockville Pike Rockville, MD 20852-2738 Rockville, MD 20852-2738 Dr. Kaye D. Lathrop Administrative Judge Atomic Safety and Licensing Board 190 Cedar Lane E.
Ridgway, CO 81432 Re: License Renewal Application submitted by Entergy Indian Point Unit 2, LLC, Entergy Indian Point Unit 3, LLC, and Entergy Nuclear Operations, Inc., for Indian Point Nuclear Generating Station, Unit 2 and Unit 3,
- DocketNos. 50-247-LR/50-286-LR:ASLBP No. 07-858-03-LR-BDO I
Dear Administrative Judges:
In response to the March 18, 2008 Order of the Licensing Board, enclosed please find joint corrections to the transcripts of the Indian Point oral argument held March 10, 11, and 12, 2008 in White Plains which are submitted on behalf of the State of New York, the State of Connecticut, the County of Westchester, New York, Town of Cortlandt, New York, and Riverkeeper, Inc.
Respectfully submitted, s/. s/ s/
John J. Sipos Janice A. Dean Joan Leary Matthews Assistant Attorney General Assistant Attorney General Senior Attorney for Special Projects Office of the Attorney General Office of the Attorney General New York State Department The Capitol 120 Broadway, 26th Floor of Environmental Conservation Albany, NY 12224 New York, New York 10271 625 Broadway, 14th floor (518) 402-2251 (212) 416-8459 Albany, New York 12233-5500 John.S ipos@oag.state.ny.us Janice.Dean@oag.state.ny.us (518) 402-9190 jlmatthe@gw.dec.state.ny.us
~/4,~LfJ~ s~f-:c-The Capitol, Albany, NY 12224 0 (518) 474-8096 S Fax (518) 473-2534 (Not for Service.Qf Papers) 0 http://www.oag.state.ny.us
2 s/ s/ s/
Robert D. Snook, Esq. Justin D. Pruyne, Esq. Daniel Riesel, Esq.
Assistant Attorney General Assistant County Attorney Attorney, Town of Cortlandt Office of the Attorney General Westchester County Sive, Paget & Riesel, P.C.
State of Connecticut Michaelian Office Building 460 Park Avenue 55 Elm Street 148 Martine Avenue, 6th Floor New York, NY 10022 P.O. Box 120 White Plains, NY 10601 (212) 421-2150 x 224 Hartford, CT 06141-0120 (914) 995-5102 driesel@sprlaw.com robert.snook@po.state.ct.us jdp3@westchestergov.com s/
Phillip Musegaas, Esq.
Riverkeeper, Inc.
828 South Broadway Tarrytown, NY 10591 (914) 478-4504 phillip@riverkeeper.org cc: Service List
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD In the Matter of ENTERGY NUCLEAR INDIAN POINT 2, LLC, Docket Nos.
ENTERGY NUCLEAR INDIAN POINT 3, LLC, and 50-247-LR & 50-286-LR ENTERGY NUCLEAR OPERATIONS, INC.
ASLBP No.
07-858-03-LR-BDO1 Regdrding the Renewal of Facility Operating Licenses No. DPR-26 and No. DPR-64 for an Additional 20-year DPR-26, DPR-64 Period for INDIAN POINT NUCLEAR GENERATING UNITS 2 & 3.
Joint Corrections to Transcripts of Indian Point Oral Argument March 10-12, 2008 White Plains, New York Submitted on Behalf of the State of New York; the State of Connecticut; the County of Westchester, New York; the Town of Cortlandt, New York; and Riverkeeper, Inc.
Text in brackets [] has been deleted; underscored text has been added or corrected.
MARCH 10, 2008 PROCEEDINGS:
Page/line Correction Chairman McDade Introduction P. 7/1.8 Atomic Safety and Licensing Board P. 7/1.20 [that] then the NRC staff
Text in brackets [ has been deleted; underscored text has been added or corrected.
Page/Line Correction Questions on Westchester County's Petition P. 13 / 1.21 [AUDIENCE MEMBER] MichaelKaplowitz, Vice-Chair, Westchester County Board of Legislators, P. 13 / 1.22 [I'm] he's representing me.
P. 13 / 1.25 denied the right to be properly represented [ing].
P. 19 / 1.2 we do have [our] full faith and confidence[. And] that the State of P. 26 / 1. 8 the staff that [the] 309 Questions on New York State's Petition P.31 /1. 16 [Royceman] Roisman P.31 /1. 21 [Royceman] Roisman P. 32 /1.9 [Jody]Jodi P. 32 / 1. 11-13 Janice Dean, who is an Assistant Attorney General [in Cape] and Kit Kennedy, who is in charge of the environmental protection[s]
bureau there P. 34 / 1. 22 [state] spate P. 36 / 1.7 [in the courts] and reports P. 36 / 1. 12 [ripe] rife P. 40 / 1.3 contentions P. 42 / 1.5 or is the [renew] review at P. 45 / 1.9 Indian Point [Entergy center] Energy Center P. 49 / 1. 1 Is that [tin]
P. 53 / 1. 20 under an [sanction] accession number P. 56 / 1. 18 at[e]
Text in brackets [ has been deleted; underscored text has been added or corrected.
Page/Line Correction P. 59 / 1. 13 Commissioners P. 61/1. 6 [at] on their behalf P. 62 / 1.23 seismic information from [the] circa P. 68 / 1.24 but it would be in current licensing [space] basis P. 69 / 1. 23 is a real possibility of a more significant [termor] tremor P. 70 / 1.9 were necessary, it would begin in part 50 [space] basis, P. 70 / 1. 10 current operating [space] basis P. 71 / 1.2-3 There was a draft [NRC] AEC GDC in 1967. There was a final
[NRC] AEC GDC in 1971.
P. 71 /1.8 the [NRC] GDC '67 draft?
P. 71 / 1.24 [pushed] published P. 72 /1.8 [COL] CLB P. 73 / 1. 18 were to change, then the [accident] applicant P. 75 / 1. 1 [all].old P. 80 / 1. 14 [let] left P. 81 /1. 6 [seize] cease P. 86 / 1. 17 and am now P. 86 / 1.25 [muting] meeting P. 91 /1.25 [how] who P. 92 / 1.24 [This] Thus if you suspend the P. 92 /1.25 proceeding would [has] ,as Judge McDade pointed out_
P. 93 / 1. 19 summary [deposition] disposition Text in brackets [] has been deleted; underscored text has been added or corrected.
Page/Line Correction P. 93 /1. 22 summary [deposition] disposition P. 95 / 1. 8 Are we adopting [intention] contentions P. 103 / 1. 23 use the word "[intention] contention" P. 106 / 1. 10 [effected] affected P. 1'07 / 1. 4 [GOC] GDC P. 109 / 1. 10 statement was connected P. 109 / 14 that what there P. 109/ 1. 15 [buy-buy] abide by P. 112 / 1. 21 [GDCB adhere] GDC be adhered P. 116/1. 21 [can], can't attack the current licensing basis P. 117 / 1. 2 part of the staff [at] or Entergy P. 119 / 1. 21 action" and it carries on. ["]
P. 120 / 1. 22 (Laughter.)
P. 121 /1. 16 Unit [3] 2 P. 124 / 1. 7 further action."
P. 129 / 1. 22 [infects] affects P. 130 / 1.3 Unit [3] 2 P. 132 /1. 19 license approved, P. 135 / 1. 10 Unit [3] 2 P. 140 / 1. 17 But it is not that [they're] there P. 141/1. 1 [2.000] 2,000 P. 141 / 1. 8 I think it's "each nuclear facility" Text in brackets [] has been deleted; underscored text has been added or corrected.
Page/Line Correction P. 142 / 1. 7 operate [A,] a nuclear P. 142 / 1. 16 and the regulation says to operate "a" nuclear power plant P. 143 /1. 7 [SR. SPEC. AGENT MULLEN] JUDGE WARDWELL P. 148 / 1. 1 that's of importance here P. 150 / 1.20 It just seems like [there] there's a difference, P. 151 / 1. 19 proposal is strictly the combined power [outages] outputs of P. 152 / 1. 11 contain radioactive[ly] contaminants P. 154 / 1. 5 [of curves] occurs P. 154 / 1. 25 It was aerosolized_
P. 156 / 1. 12 hydro-geologically influenced P. 156/1. 18 of this effort [on] in P. 158 /1.23 one of the [A&Ps] AMPs P. 167 /1. 18 tank systems[?].
P. 168 /1. 16 applies to[;]
P. 168 / 1. 17 [field] fuel oil P. 169 /1. 7 Okay, if I could sort [of] out P. 170 / 1.23 They specifically [site] cite P. 171./1. 5 possible:
P. 171 / 1. 15 contention, supported P. 171 /1. 25 [application] declaration P. 177 /1. 3 [Adams] ADAMS P. 189 / 1. 11 And to come to Section [54-29] 54.29 Text in brackets []has been deleted; underscored text has been added or corrected.
Page/Line Correction P. 191/1. 11 [2309] 2.309 P. 201/1.3 [54.21-A. 1.(i)] 54.21(a)(1)(i)
P. 204 /1.21 [54.21-A.1.(i)] 54.21(a)(1)(i)
P. 208 /L.1 Part 54 at page [22.471] 22,471 P. 209 / 1.10 from Paul [Blanche] Blanch P. 209 /. 24 Paul [Blanche's] Blanch's P. 210/1. 18 Federal Register [22.471] 22,471 P. 210/1.24 Paul [Blanche] Blanch P. 213 /1. 3 [22-477] 22,477 P. 214 /1.24 Federal Register [22-471] 22,471 P. 215/1.9 Mr. [Blanche's] Blanch's P.215/1. 23 Mr. [Blanche] Blanch P. 221/1.4 putting up a wind farm, of conservation, P. 224 / 1. 13 Clinton was an early site P. 229 1. 21 their replies to [your's] yours P. 229 1. 24 in our Environmental [report] Repor P. 234 /1.3 Contention Eleven is that [DER] the ER P. 234 1. 5-6 Indian Point [II] 2 and Indian Point [III] 3 P. 234 1.9 [1I] 2 and [III] 3 P. 234 1.24 [conservatism] conservation P. 237 1. 10 Indian Point [II] 2 and Indian Point [III] 3 Text in brackets [ has been deleted; underscored text has been added or corrected.
Page/Line Correction P. 241 / 1. 24 [C3.IIL] (c)(3)(ii)(L)
MARCH 11, 2008 PROCEEDINGS:
P. 253 /1. 4 Cortlandt, [CT] NY P. 254/1.11 specific [intentions] contentions P. 259/1. 1 Register [28.481] 28,48 P. 264/1. 13 responsibilities under [CIRCA (phonetic)] CERCLA P. 266 /1.25 threshold. It's [a really fast and] really cast in generic terms.
P. 270/1.10 of the Code at any particular power [point] plant P. 272/1.5 [in] and P. 272 /1. 7 [residents] residences P. 273 /1.25 summary [deposition] disposition stage P. 274 / 1.4 contention, which P. 274 /1. 5 contention that was at issue in Pilgrim P. 274/1.7 inputs, Judge Lathrop, as you said and [assumption] assumptions P. 274 / 1. 14 And I would just note that to [Entergy] Entergy's P. 274 / 1. 22 "[Date] Data on recovery P. 275/1. 1 severe reactor accidents."
P. 27(5/1.8 fortunately a [dire] dearth P. 279 /1. 7 a time because I'm this [hard-scribble] hard-scrabble P. 280 /1.20 saying it could [effect] affect Text in brackets []has been deleted; underscored text has been added or corrected.
Page/Line Correction P. 280 /1. 24 might get influenced by that, P. 280 / 1.25 smaller particles, P. 283 /1.20 [upper west side] Upper West Side P. 289/1. 12 same term that the discussion that [State] Staff references P. 289/1. 15 [Wash] WASH P. 290 /'1. 10 MACCS2 Code, not that they demonstrated P. 292 /1.23 it's increased clean-up costs P. 302 /1. 15 identified the risk [that's at the] that a fire will disable P. 302 /1. 19 was [no] not evaluated P. 306/1. 15 information is going to [effect] affect P. 306/1. 17 controlling [condition] Commission case law P. 306 /1.23 of SAMA analysis that [is's] it's P. 308/1. 1 Because again we think it's a P. 308 /1.6 would materially [effect] affect P. 308 /1. 14 consider this information or you haven't [to] considered P. 308 /1. 17 properly~has [effected] affected P. 309 /1. 17 does this [effect] affect P. 311/1. 17-21 ["In order.to reduce the earthquake risk for IP 1 and to critical conjoin in adjacent Units 2 and 3 is necessary to improve the ability of IP l's critical components to withstand the effects of an earthquake."] "In order to reduce the earthquake risk for IPI (and to the conjoined and adjacent Units 2 and 3), it is necessary to improve the ability of IPl's critical components to withstand the effects of an earthquake."
Text in brackets []has been deleted; underscored text has been added or corrected.
Page/Line Correction P. 313/1. 6 [effect] affect P. 313/1.7 thing, how it's going to [effect] affect P. 316/1. 15 [siOtuations] situations P. 319/1.17 Is that correct[>] ?
P. 326/1. 3 system by system P. 327 / 1. 13 been [s] scoped in P. 329 /1.23 [Sherman] Sherwin P. 330 /1. 17 magnitude events and that's what's then [factor] factored into P. 333 /1. 1 [MS. SUTTON:] MR. TURK:
P. 333 /1. 3 [MR. TURK:] MS. SUTTON:
P. 335/1.5 But [is] if the dose is P. 336/1.21 [burroughs] boroughs P. 337/1. 13 into question - - this is an outdated, obsolete [node] model, P. 337/1. 17 [this] the siting of this plant, that [if] this P. 337/1. 19 what New York is interested in here P. 343 / 1. 14 in here (holding up CFR).
P. 343 /1. 24 promulgated, I believe it's part [2309] 2.309 P. 344/1.8 That's our burden under [2309] 2.309.
P. 346/1. 12 [NOAA Evaluation] no - evacuation P. 346/1. 19 what the Commission said in McGuire, [CO1217] CLI-217 P. 347 / 1. 15 not [a] at the contention [of] admissibility stage Text in brackets [] has been deleted; underscored text has been added or corrected.
Page/Line Correction P. 350/1. 16 [20.13] 2013 P. 350/1. 17 [20.15] 2015 P. 351 / 1.23 of the regulation that that be [addresses] addressed, P. 354 /1. 7 [MR. SIPOS:] MR. CHANDLER P. 360 / 1. 15 [MR.] MS. SUTTON:
P. 362 / 1. 15 Is this the [new reg.] NUREG of P. 362 / 1. 18 I believe it is. The [new reg.]NUREG P. 365 / 1.9 I would note, however, that the [present] premise of P. 373 / 1.9 systems, [structure] structures, P. 373 / 1. 10 the scope of 54.21(a) and therefore [is] are subject to P. 374 /1. 4, 11 [Leahy] Lahey P. 374 / 1. 12 declaration [in] and P. 375 /1. 18 [MR.] MS. SUTTON P. 376 / 1.5, 25 [Leahy] Lahey P. 376 /1. 7 [MR.] MS. SUTTON P. 376 / 1. 12 [MR.] MS. SUTTON P. 377 / 1.13 [Leahy] Lahey P. 378 /1. 1, 17, 20, 23 [Leahy] Lahey P. 379 /1.4, 11 [Leahy] Lahey P. 379 / 1. 16 they have [filed] followed the guidance, P. 379 / 1. 18, 22 [Leahy] Lahey Text in brackets [] has been deleted; underscored text has been added or corrected.
Page/Line Correction P. 380 / 1.6 with now, then you won't know what [you] you've got as you're P. 380 / 1. 14, 16, 25 [Leahy] Lahey P. 381 / 1.8 program, and that's Entergy's burden. Our [expect] expert has P. 381 /1. 17 [Leahy] Lahey P. 381 / 1. 18 one paragraph on [pages] page 126 P. 382./1. 1 down to is a dispute between experts.
P. 382 /1. 17, 19 [Leahy] Lahey P. 383 / 1.6, 14, 22 [Leahy] Lahey P. 383 /1. 19 [MR.] MS. SUTTON P. 386 / 1. 10 [werer] were recessed, P. 388 /1.18 correct when they say that they have [gotten] got in their P. 391 /1. 18, 22 [Leahy] Lahey P. 393 /1.7 [Leahy] Lahey P. 395 /1. 20 facilities. It's [giving] given experience and aging.
P. 401 /1. 7 contention number [5] 25, P. 401 /1. 14 [Leahy] Lahey P. 402 /1. 3, 9, 14 [Leahy] Lahey P. 403 1. 3, 8, 22 [Leahy] Lahey P. 404 / 1. 5, 22 [Leahy] Lahey P. 404 /1. 25 requirements. But he also discusses the [sharpey] Charp test P. 406 / 1. 17 [Leahy] Lahey Text in brackets [] has been deleted; underscored text has been added or corrected.
Page/Line Correction P. 406 /1. 25 stainless steel. And even the welds of the [in-course] in-core P. 407 /1. 3 [Leahy] Lahey P. 407 /1. 6 these loads can damage the [course] core P. 407 /1. 9, 13, 18 [Leahy] Lahey P. 408 /1. 4, 9, 25 [Leahy] Lahey P. 409 1.4, 10, 15 [Leahy] Lahey P. 409 /. 16 [serous] serious P. 410 1. 11 [Leahy] Lahey P. 412 1. 10 [along] on the same date as its reply.
P. 415 /1. 14 regulation, [5413] 54.13 P. 440 1. 20 Unit 1 [spend] spent fuel pool P. 441 1.4 accurate [dada] data P. 441 / 1. 5 was [prepared] repaired P. 452 / 1.24 56 Federal Register [64-967] 64,967, P. 453 / 1.20 doesn't have to be made in the relicense [goes] does not go to the P. 453 / 1.21 mitigation of the environmental impacts [or] of a postulated P. 453 /1.22 or a severe accident, should it occur P. 454 / 1.7 [meteorological] radiological emergency preparedness plan for Indian P. 454 / 1.20 under the Part 51 regulations P. 454 / 1.21 appendix [subpart] B to subpart [appendix] A P. 454 / 1. 24 also gets to the heart of* yes, it was studied Text in brackets []has been deleted; underscored text has been added or corrected.
Page/Line " Correction P. 455 /1. 15 environmental impacts of a nuclear facility P. 455/1. 17 us has failed to comply with the [updated] updating requirements P. 455 /1.22 the incorporation by reference of the [Wood] Witt report, P. 456 /1.8 [one is producing] once it sunsets, P. 459 /1.4 [sound] stated P. 460 /1.2 [Roni] Rani Franovich in her statement on the 19th of P. 460 /1.7 to that ten-year obligation [,] we had discussed earlier, P. 460 1. 11 2006, they really "kicked" it off "in earnest." That is P. 469 1.24 [permanent] permit in effect, P. 472 / 1.3 This is where I would not ask you to do the P. 472 1. 10 And the [DEIS] analysis P. 472 1. 24 Dilks. He has demonstrated [in] with great specificity and P.488/1. 10 issues means that they have [weighed] waived their legal P. 491 /1.23 as a sovereign state, is at this time unable to [see] cede P. 492 /1.5 now [that] and New York P. 492 /1. 13 individual [intervenor] intervenors P. 493 / 1. 21 excused. We would then start with [Portland] Cortlandt at 4:00 P. 493 /1.22 o'clock. Anyway, I believe [Portland] Cortlandt would be next at Text in brackets [] has been deleted; underscored text has been added or corrected.
Page/Line Correction Questions on the Town of Cortlandt's Petition P. 496 / 1. 13 they have been very [obstructive] instructive P. 496 / 1. 16 of our contentions, Technical Contention [and Contention] 2 - on P. 496 / 1.25 and also appear P. 498 / 1. 1 course [of] in and of itself P. 498 / 1.3 Environmental Impact Statement [proceeds] precedes [and] such P. 500 /1. 2 report are generally promises to carry out [our] programs as P. 504 / 1. 1 [trust] thrust of the Sans'oucy affidavit P. 505 /1. 9 - 11 facility; [and] there is a considerable concern that we examine the issues of not licensing this facility [for] or relicensing [its] this facility.
P. 507 /1. 7 and indicate[s] that in that instance P. 509 /1. 3 pool issue, then we would elect to proceed under [23.5] 2.315.
Questions on the State of Connecticut's Petition P. 510 / 1.3 [started] stated yesterday P. 510 / 1. 14 [the] Westchester County P. 511 /1. 14 [effect] affect P. 512 / 1. 1 a significant amount P. 512 / 1.3 [west] east P. 516 / 1.24 [changed] changes P. 520 / 1.23 [for seeding] proceeding P. 522 /1. 22 [SR. SPEC. AGENT MULLEN] JUDGE WARDWELL Text in brackets [] has been deleted; underscored text has been added or corrected.
Page/Line Correction P. 524 / 1.2 [2-335] 2.335 MARCH 12, 2008 PROCEEDINGS:
Questions on Riverkeeper, Inc.'s Petition P. 529 / 1. 14 [Daronoco] Daronco P. 534 / 1. 16 [Philip] Phillip P. 537 / 1. 1 [and] of P. 537 / 1. 9 admissibility [and]
P. 537 / 1.20 [simple] simply P. 538 / 1. 13 pool[s]
P. 544 /1.4 that this was a P. 544 /1.6 the[y]
P. 544 / 1. 11 [this] that P. 544 / 1.22 broaden P. 545 / 1.2 position that P. 546 / 1.23 [2206] 2.206 P. 550 / 1.8 [2206] 2.206 P. 552 / 1.4 [2206] 2.206 P. 557 / 1.4 [3.206] 2.206 P. 557/ 1. 13 [206] 2.206 P. 557 /1. 16 says P. 568 / 1. 5 unsuc'cessful Text in brackets []has been deleted; underscored text has been added or corrected.
Page/Line Correction P. 568/1. 11 it seems to me for P. 568 /1.24 referenced P. 575 /1. 15 [operated] uprate P. 580/1.6 [float] flow P. 584/1.9 CHECWORKS, P. 586/1. 10 [estrangement] entrainment P. 588/1.7 [MR. TURK] MR. TAFUR P. 589 /1. 12-13 entrainment and impingement P. 589 / 1. 14 entrainment and impingement P. 590 / 1. 13-14 entrainment and impingement P. 590/1. 19 levels [and] of impingement entrainment P. 595 / 1. 14 [FAQ] Fact P. 595 / 1. 17 entrainment and ,impingement P. 595 /1. 20 analysis is, P. 595 / 1. 21 submit it:
P. 605 /1.23 DEC P. 610/1. 17 [intentionally cause an] intentionally caused P. 610 / 1. 19 intentional P. 611/1. 16 caused attacks P. 612/1.25 [be] we have to do that P. 612/1. 14 [an amenable] a meaningful
.Text in brackets []has been deleted; underscored text has been added or corrected.
Page/Line Correction P. 613/1. 16 that's [a] Baltimore P. 615/1. 13 consequences P. 616/1. 19 you[r]
P. 623 / 1.25 says P. 623 /1. 1 [NUREG CR 6295] NUREG/CR-6295 P. 627 / 1.25 [balder] bald or P. 629/1.11 [difference is] differences P. 640 / 1.25 outlined P. 647 /1.21 [find] fine Capitalization Consistency Note:
If "Applicant," "Agency," and "Commission" are to be capitalized, then so, too, should "State" and "County" be capitalized.
Dated: April 2, 2008
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