ML19317G603
| ML19317G603 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/24/1968 |
| From: | Greuling E, Jensch S Atomic Safety and Licensing Board Panel |
| To: | |
| Shared Package | |
| ML19317G598 | List: |
| References | |
| NUDOCS 8003200650 | |
| Download: ML19317G603 (2) | |
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UNITED STATES OF AMERICA ATCMIC ENERGY COGESSION IN 'JME MATTER OF
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FIMIDA POWER CORPORATION DOCKET NO. 50-302 (Crystal River Unit 3 Nuclear
)
GeneratingPlant)
)
Appearances Edgar H. Dunn, Jr., Esq.-
Harry A. Evertz, III, Esq.
Appearing on behalf of the Applicant Florida Power Corporation George Spiegel, Esq.
James F. Faiman, Jr., Esq.
Appearing on behalf of Intervenors City of Gainesville, Florida and Gainesville Utilities Department T. T. Turnbull, Esq.
. Assistant Attorney General Appearing on behalf of the State of Florida Gerald F. Hadlock, Esq.
Appearing on behalf of the Regulatory Staff of the Atcmic Energy Camission 5D S gb l
TN
. INITIAL DECISION Florida Power Corporation (Applicant) filed an application and five amendments thereto, under Section 104b of the At mic Energy Act of 1954, as amended (the Act), for a provisional con-struction pemit to construct a pressuri::ed water reactor designed to operate initially at pos.? levels up to 2452 megawatts (themal).
Me Proposed reactor would be located on the Applicant's 4,738-acre site located on the Gulf of Mexico about 70 miles north of Tampa, Florida, and seven and one-half miles north of the Town of Crystal River, Florida. The site affords Applicant a 4,400 foot exclusion radius. There are no residents within three and one-half miles of the proposed reactor. Withia ten miles of the proposed reactor, the population in 1967 was 3,300 and within twentymiles, the popu-lation was about 6,000. The nearest population center with more than 25,000 residents is nainasville, Florida, which is fifty-five miles from the site. A significant increase in the five-ten mile zone population density is projected for the 40-year life of the plant 1
primarily as a result of an increase in the population of the Town of Crystal River, fran slightly over 3,000 People to over 25,000 people. The site geology is characterized by limestone which has been subjected to solutioning with resulting voids and channels. The Applicant proposes a consolidationgrouting program to fill the voids and channels, to confine potential settlement-inducing zones, and to minimize solution rates. A curtain of grout arcund the foundation
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area will control groundwater. This procedure was used success-fully for the Applicant's fossil fuel plant, designated as Unit 2, which is also located on the site.
Following receipt of the application, the Cmmission Staff and the Advisory Ccannittee on Reactor Safeguards have empleted all pre 14=4nav reviews. Thereafter, the Commission issued a Notice of Hearing /for a public proceeding as required by the Act.
In.
1 addition, a prehearing conference was convened to consider proce-dural aspects for the public hearing. In accordance with the Ccanission's Notice, a public hearing was held in Crystal River, Florida, at which, in addition to the Applicant and the Commission's Regulatory Staff, there appeared as intervenor parties the City of Gainesville, Florida, the Gainesville Utilities Department,Yand the State of Florida. The Gainesville intervention was related to the jurisdictional issue whether a provisional construction pemit
'may be granted pursuant to the authority granted to the Ocmanission in Section'104b of the Act which permits such a license to be granted g General public distribution was made of this Notice of Hearing, which included publication in the Federal Register on June 1, 1968(33FR8235).
g Gainesville, in addition to its Petition for Intervention, filed a Motion to broaden the issues for consideration to include con-tentions in reference to alleged anti-trust concerns and to in-clude a claim to share in the ownership of the proposed nuclear facility. The At mic Safety and_ Licensing Board denied the motion for involving matters beyond the jurisdiction of the Board.
-4, "for a production or utilization facility involved in the conduct of research and development activities leading to a da=anatration of practical value."
The State of Florida generally supported the application on the econmic grounds of more jobs, more electricity and more taxes, but alsoaddedaconcernrespectingeffectsonthefishandwh.1dlife in the area. In addition, many persons made limited appearances, as pemitted by the Cassaission's Rules of Practice, by sulunitting cral statements which in most instances supported the application, but in other instances presented concerns respecting the themal pollution, and other enviromental aspects of the construction and, if authorized, the operation of the proposed reactor.
g The State of Flcrida introduced several persons who presented unsworn statments that may be considered to the same effect as if presented by way of limited appearances. Statements
- were made by Nan =a4=1 P. Reed, on behalf of the Honorable Claude R. Kirk, Jr., Governor of the State of Florida; and by T. T. Turnbull, Esq., Assistant Attorney General of Florida on behalf.of the Honorable Spessard L. Holland, U. S. Senator fr a the State of Florida; George A. Smathers, U. S. Senator fr a the State of Florida; the Honorable William C. Cramer, Congressaan, 8th District of Florida and the Florida Air and Water Pollution Control Cossaission. Statenents were~also presented by Bandolph Hodges, Director, Florida Board of Con-servation; R. W. Wood, Chief, Fisheries Division, Florida Game and Presh Water Fish Cceanission; B. Kenneth Gatlin, on behalf of the Florida Public Service Cannission; Edwin G. Williams, M.D.,
on behalf of Wilson Sowder, M.D., State Health Officer, Florida -
State Board of Health. Limited appearraces were made by William B. Waack; Howard Zeller, Federal F. ster Pollution Control Admin-1stration; Lowell Bryant, Citrus Cmnty, Florida; Kenneth D.
Morrison, on behalf of the Florida Audubon Society; Robert S.
Sholtes, Professor of Environmental Engineering, University of
' Florida; Mrs. Helen C. Morrison, appearing for Norten L. Holmes; and David A. Gavin, on behalf of the Crystal River Council.
. The nuclear steam supply system consists of a light water mod-i ersted and cooled pressurized irater reactor (PWil) which transfers heat to two once-through steam generators from which steam passes to the turbine generator. The reactor core is comprised of 177 fuel assemblies containing low-enrichment uranica dioxide pellets within ziresloy tubes. Reactivitycontmlvdlbeaccomplishedbyacca-bination of 69 contal rod cluster assemblies and by liquid poison (boric acid) in the reactor coolant. The 69 control rod assemblies are withdrawn and inserted by a rack and pinion drive assembly.
Neutron flux level, high or low reactor system pressure, high cool-ant temperature, or low coolant flow can initiate a reactor trip through the reactor protection instrumentation which de-energizes the magnetic clutches on the control rods and scrans the reactor.
Erternal neutron detectors and 52 in-core detector assemblies will be provided to monitor neutron flux distributions. The nuclear steam teupply system is essentially identical in design to that of the Duke Pbwer Company's Oconee Nuclear Station, Units 1, 2 and 3, and the Metropolitan Edison's Three Mile Island Station, pre-viously authorized for construction by the Ccumtission.
y The recognition that the Applicant's proposed reactor is essen-tially identical in design to previously authorized reactor projects is a substantial basis for the Intervenor Gainesville contention that there is little actual research and development involved in this project and thus cannot be authorized t.s a Section 104b facility. The Act requires that such a project be one that will lead to a demonstration of the practical value of nuclear power. The Commission view is that the demonstration must occur and must continue presumably for much of the expected 40-year life of the facility.
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The proposed plant incorporates numerous systems, cmponents, and features required for the protection of plant personnel and the 1
public. The contaimant consists of a steel-lined, prestressed l
concrete cylinder with a shallow deed roof and a flat foundation slab designed to withstand a contmiment pressure of 55 pounds per square inch. The contaiment structure vill have adequate capability i
for a suitable in-service surveillance program. Provision is also made for esponents that are expected to assure contaiment integrity under unlikely but hypothesized accident conditions. Plant design also includes dtvices expected to serve as protection against clad melting in further hypothesized reactor coolant system failures.
Among the important considerations respecting the hypothesized accident conditions is the proposed use of an iodine firing additive which vill,be mixed with the containment spray water to remove iodine fra the contaiment stanosphere after a loss-of-coolant accident.
Two sprays are provided and it is calanlated that either spray has the design capability to remove sufficient iodine fra the. contaiment atmosphere 'to reduce potential doses at the site boundary to Part 100 limits, or less. The Applicant has selected sodium thiosulfate as the additive. However, there are research programs which include alterns.te chemical solutions, one of which was considered at the hearing and contains a mixture of sodium thiosulfate and sodium hydruide. Wbile the removal fu.: tors needed to meet site guidelines appear to.be available.under laboratory conditions, the stability
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_7 and campatibility of the additives under acc~ident conditions have not yet been proven.
The Staff Safety Evaluation includes the discussion of the f
l necessity of an adequate demonstration of the efficacy of the iodine firing additive, and is,as follows:
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"...without iodine reduction the exclusion boundary 2-hour dose and the low population distance total dose ex-ceed Part 100 guidelines by factors of 3 3 and 1.6 respec-tively, for TID-148% yrelease assumptions and the proposed lesi rate at 0.25Mday. The spray system with additive is proposed to bring the design basis loss-of-coolant accident doses within Part 100 guidelines."
l "We have also calculated the potent'ial doses fr a this
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accident assuming that both sprays were not operable to deter-mine the iodine removal factors which must be achieved to meet 10 CPR Part 100 pridelines for thyroid doses. Our calculations indicate that (1) the 2-hour thyroid dose at the exclusion
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,j/ Be Staff statement is to the effect that the stability and compatibility of chemical additives to entrap radioactive iodine has not been proven under accident conditions. The Staff, however, does not submit a specific conclusion rela-tive to this lack of proven cheniical ability to control the iodine releases. It may be assumed the Staff view is that it is enough that something vill be later~ considered by the Staff that will acc eplish this' necessary control of radio-active gaseous iodine. S e Board cannot accept this assump-tion for decisional purposes in this public hearing proceeding.
_j/ Be validity of the TID-14844 calculations is under Ca mission review in an unrelated proceeding and will not be analyzed again here. It may be added, however, that the TID-14844 fomula is based upon optimistic assumptions, and even that theoretical exercise contains mention that radioactive releases could be much verse, even 6 times greater, in the case of larger, which are possible, releases of solids.
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boundary of 4400 feet woul a factor of 3 3 higher than the 300 rem guideline dose and (2) the course-of-the-accident thyroid dose at the low population distance of 5 miles would be a factor of 1.6 higher than the 300 rem guideline dose if the sprays were inoperable. As discussed in Section 6 3 of this report, we believe that the experimental work perfonned to date and the research and development pro-gram outlined by the applicant provide reasonable assurance that reduction factors on the order of those described above can be achieved."
The foregoing Staff review expresses the hope that the necessary iodine reduction factors can be achieved. Upon the basis of this record, however, it appears that even this hope is open to some question. At the haring, the Staff submitted references to reports on chemical additives prepared by oak Ridge National Laboratory. The work which has been undertaken to this time lends doubt whether the sodium thiosulfate alone, or sodium thiosulfate including a solution of sodium hydroxide vill achieve the necessary iodine reduction factors.
These two chemical additives are those considered by the Applicant here, based upon the record made at the hearing, although the appli-cation and the analysis made by the Staff referred to the proposed j The Staff thus recognizes that if the chemical spray additives do not work under accident conditions that the radioactive thyroid doses at the exclusion boundary would be approximately 990 rem, rather than the guideline value of 300 rem.
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9-j use of sodium thiosulfate.
The Oak Ridge National Laboratory reports indicat'e that neither of the Applicant's proposed cheatical additives for sprays vill achieve the necessary reduction factors.
'!he data developed by ORNL are to the effect that both soditan thiosulfate and sodium thiosulfate with soditan hydroxide undergo radiation decaposition which Matits their useful life when ex-posed to genua radiation during recirculation' cooling of the reactor.
The decaposition ' products include colloidal sulphur, hydioge.n sulfide, hydrogen and oxygen, the latter two from net water radioly-sis. In addition, radiation will destroy approvimately 97% of sodium thiosulfate's ability to react with iodine by exposure to 0
1 x 10 roentgens, whereas radiation will destroy apprnrimately 43% of the ability of sodium thiosulfate mixed with sodium hydrox-ide.to react with iodine. Important also are the data that
' more than twice the hydrogen gas is produced by sodium' thiosulfate 4
i mixed with sodium hydroxide under radiation than by sodium 8/ At the hearing, inquiry was made why the Applicant was apparently proceeding with only, sodium thiosulfate for' the chemical additive, when fram a review of other pro-ceedings, other applicants presumably had abandoned sodium thiosulfate because it was ineffective. The Applicant here then stated that the solution it intended to use ihcluded sodium thiosulfate and sodium hydroxide, i
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. thiosulfate, alone, although the volumes of gas for both are sizeable enough for concern.
With these data so far developed, it is somewhat difficult to share the Staff's hope that further research and development vill produce better results which must be had in order to provide con-trol of radioactive gaseous iodine.
It is the view of the Board that this necessary control of radioactive gaseous iodine is as vital to design criteria considerations and determinations as the data for containment integrity and the fuel elements, and warrants i
review in a public hearing in a contested case. b In that view, i
it is reccumnended that -a condition be added to the construction pemit hereinafter authorized to provide that further data be pre-sented when further research and development has occurred to
_p] In ORNL 4228, cited by the Staff, is the determination that:
"The results obtsined to date in the study of the various proposed spray solutions indicate that radiolytic H is 2
produced in quantities sufficient to be of concern in the proposed spray system."
This hydrogen hazard was not developed on the record in this proceeding. While the Staff reminds us that further rnudies are being made to detemine the suitability of chemical addi-tives, the fact that studies are being made is no assurance that all proolems regarding the additives vill be solved. The premise of undergoing studies for the Staff conclusions is not valid.
(
g See Florida Power & Light Company, Docket Nos. 50-250 and 50-251, I
Commission Memorandum and Order; dated August 4,1967 1
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establish the necessary control of radioactive iodine,11/ and before l
or at the time that a ree,uest is made for an operating license.
Both the Applicant and the Staff have enumerated eight items on which both assert, in substance, that "...further infomation and data are needed" and that such additional data vill be acquired fr a research and develojaent projects. The distinction between a program to develop needed additional data, on the one hand, and precise research and develoIment programs, on the other, appears to be maintained and should not be combined or confused. Without a separate classification, however, the eight items are:
b) Once-through steam generator; a
) Control rod drive unit; c
In-core neutron detectors; d
Core thermal and hydraulic design; e
Bnergency core cooling and core barrel check valves; f
Xenon oscillation control; g) Use of sodium thiosulfate for iodine removal; and h) Fuel rod failure mechanisms during loss-of-coolant accident.
At the hearing, Applicant's manufacturer candidly recognized that actual research and development areas included only the use of sodium thiosulfate for iodine removals and the core thermal and hydraulic designs. We agree with that recognition of the amount of g The addition by the Commission of the condition, as requested, vill yet pemit the Applicant to go forward with the major and basic construction while further concentration can be directed to the necessity of devising a process or mechanism to control the gaseous radioactive effluents. The record at the present time is inadequate in this regard.
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. research and developent involved in this proceeding. The other items may thus be classified as ordina:y improvement considera-tions not involving any great expansion of reactor technology, and on this basis, may be considered as not pertaining to research and developent.
Applicant has identified the nuclear personnel who vill assist in design and construction. These include both Applicant's employees, reactor manufacturers and consultants. Adequate training and experi-ence are shown by this evidence for Applicant to proceed. Appli-cant has also testified in reference to its proposed quality assur-ance control program which is to be effective for the manufacture and the construction of the reactor.
In this respect, Applicant has also shown the program for the developent of specifications. The necessity of attaining the objectives sought by this program involves both adequate specifications, measured by code standards so far as feasibic, and competent and alert personnel who can determine whether conformance is had with the specifications. Applicant is aware that the nuclear technology demands better specifications and a more active surveillance program than for fossil fuel power plants. While a licensee should be free, as Applicant implies, to develop its own quality assursace and control program, we find added confidence in
'beexpectedperformancefromthecontinuin6reviewofspecifications,
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. manufacture of components and construction of the project by the inspection staff of the Constission.
It is understood that both the Applicant and the Staff vill render adequate reporting for the record of the developments, the manufacture and the construction involved in this project. Applicant has also outlined in general scope its intended program for training proposed operators of the project, if authorized.
The financial prograr. for this project includes provisions similar to those for ! flicant's regular construction undertakings.
We find that Applicant has adequate plans for financing this reactor facility, including both the construction and intended operation.
The intervention by Gainesville is limited to the jurisdictional issue under Section 104b of the Act. Gainesville contends, in effect, that it is unjustifiable to conclude that this reactor facility with its expected substantial electric generating capacity, and the intention to coordinate the electric supply as a necessary 1
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. additionb to Applicant's service, all with a very sizeable cost needing extensive financing, should yet be considered a research and development project. Gainesville asserts in its proposed find-
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ings that the pressurized vata" concept for a nuclear power facility has long been accepted as valid, that different items of hardware for a project, such as differing means of control of the nuclear activity and detection instrumentation, are not changes in tech-nology but rather are mere developments from the established J2] After the close of the hearing, Gainesville filed a motion to add to the record a statement issued by the Applicant's presi-dent concerning the usefulness of nuclear power generation, in general, and of this project in particular. The statement was in printed fom which was given public distribution in the hearing room, although the president did not appear to orally present the statement as indicated at the prehearing conference that he would. Gainesville asserts that the comnercial value, and not merely the research and development aspects, of this reactor project are shown by the statement. Applicant opposes the receipt of the president's statement upon the ground that a delay will occur in the proceeding to receive the statement, and that if the president were asked questions that would elicit such statements as were made in the printed fom, Applicant's l
counsel vould object to the making of such statements. The Board concludes that whatever be the basis of objections to keep a statement from being made, the issue here concerns a statement freely made for public consideration, and concerns in some respects the value of this nuclear power project for commercial purposes. The statement, of course, does not estab-lish that a demonstration has' occurred that the project has practical value.
Nevertheless, the Board overrules the objec-tion by Applicant, and grants the motion by Gainesville. The statement made by Applicant's president and described in the notion is received in evidence and may be identified as l
Gainesville Exhibit No. 2.
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. principles for this type of facility. Gainesville asserts, also, there are only two items that can be classified as research and developsent and even as to those, it implies that the basis is not substantial. The Constission view, however, respecting the Section 1Mb authority is that demonstration must be shown of the P N tical value of the particular type and the specific nuclear power project before a proposal is beyond the scope of Section 1&b.
Since this project has obviously not operated, and there do not exist years of operating experience from which to detemine the economics of the project, there has not yet been a demonstration of the practical value of this power facility, and therefore,
_ $ Applicant's statement is succinct on the demonstration aspects of the proposed facility and is as follows:
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"At least until reactors of comparable size have demonstrated by operation their reliability,' technical feasibility and economic competitiveness with other types of generating facilities, the Crystal River... reactor must be considered
' developmental'."
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,3 consistent with the Ceautission's rulings, this proposal qualifies for a Section lO4b license.
Concerning the final issue for detennination, the Board coc-cludes that the evidence is adequate and it is found that the
, Applicant is not owned, controlled or drainated by any alien, for-eign corporation or foreign government, although it is to be noted that the specific owners of the stock are in no way identified.
l The Board has considered the several proposed findings and con-clusions submitted by the parties and the Board has substantially accepted all of the findings which have identified the significant and probative facts. The Beard has differed with the Applicant and the Staff in reference to the research and development list of j
eight items and particularly the proposed finding regarding sodium lj In Duke Power Company, Docket Nos. 50-269, 50-270, and 50-287, Ccanaission Decision, issued January 3,1968, it was held that:
"... our view that the 'research and development' about which Section 104 b. speaks encompasses as ' development' a demonstration that will provide a basis for comunercial evaluation. Such 'ccamiercial evaluation', in tenns of i
earlier relevant declarations, means an evaluation of the economic competitiveness of the nuclear facility with conventional power plants.
"In the context, then, of the statutory language and our construction of it, until there has been a ' demonstration of the practical value of such facilities for industrial or l
consnercial purposes', utilization facilities which will provide a basis for comunercial evaluation in connection l
therewith (i.e.,
leading to' such ' demonstration') may be l
licensed under Section 104 b."
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thiosulfate. The Board has differed with all the parties in reference to some of the conclusions asserted within the pro-posals of facts in reference to the foregoing items, and has also differed with Gainesville respecting the Section lO4b issue.
Specif'm rulings on the proposed findings and conclusions, in accordance with the Administrative Procedure Act, are as follows:
Applicant's proposed findings of fact numbe:td 1 through 20, inclusive, and 23 through 27, inclusive, have been accepted in substance.. Proposed findings of fact numbered 21, except insofar as reference is made to the therinal and hydraulic programs and to iodine removal system, and 22 (rejected because it consists of conclusions and not facts) have been rejected and denied for lack of evidence in the record to support these findings.
1 The 3egulatory Staff proposed findings of fact numbered 1 through 16, fnclusive, and both 18 and 19, have been accepted.
Finding of fact numbered 17 (except insofar as reference is made to core thermal and hydraulic design and the use of sodium thio-sulfate for iodine removal) (in addition, the last two sentences of proposed finding 17 are rejected because they consist of con-clusions and not facts) has been rejected and denied for lack of evidence in the record to suppcrt this finding.
Intervenor Gainesville proposed findings of fact numbered l
1, 2, 3, ha, kb, 4c, he, Af, kg, 5, 6, 7, 8, and 9 have been accepted in substance. Findings of fact numbered kd and kh have
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been rejected and denied for lack of evidence in the record to support these findings.
Applicant's and the Reguletory Staff's conclusions of law have been accepted except by way of the recommendation to the Commission for the addi. tion of a condition in reference to sodium thiosulfate, all as set forth in this Initial Decision. Intervenor Gainesville's conclusions of law have been denied because the asserted conclusions are contrary to the interpretations of the law by the Commission.
Upon consideration of the entire record of evidence in this proceeding, with the proposed findings of fact and conclusions of law and contentions made by the parties, and also based upon the findings and deteminations hereinabove set out, this Atomic Safety and Licenring Board further concludes that:
1.
In accordance with the provisions of 10 CFR Section 50 35(a)
(a) The Applicant has described the proposed design of the facility, including, but not limited to, the principal architectural and engineering criteria for the design and has identified the major features or components incorporated therein for the protection of the health and safety of the public; l
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. (b) Such further technical or design information as may be requird to coatplete the safety analysis and which can reasonably be left for later consideration vill be supplied in the final safety analysis report, except that it is reccamended to the Cesatission that a condition be attached to the authority or license for construction of the proposed nuclear facility that data be developed upon a record made at a public hearing in this contested case concerning the use of either a chemical spray as an " iodine fixing addi-tive" or other devices for purposes of controlling the release of radioactive iodine as a consequence of the maximum credible accident; (c) Safety features or components which requi:e research and development have been described by the Applicant and the Applicant has identified, and there vill be conducted, a re-search and development program reasonably designed to resolve any safety questions associated with such features or components; and t
(d) On the basis of the foregoing, there is reasonable l
assurance that (1) such safety questions vill be saticfac-torily resolved at or before the latest date stated in the application for coutpletion of construction of the proposed facility, and (ii) taking into consideration the site criteria contained in 10 CFR Part 100, the pztposed facility can be
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constructed and operated at the proposed location without undue risk to the health and safety of the public, provided that it be established that either a chemical spray or other devices can be used to reduce the quantities of iodine that are computed to be released in the event, though unlikely, of a maximum credible accident.
2.
The Applicant is technically qualified to design and construct the proposed facility.
3 The Applicant is financially qualified to design and construct the proposed facility.
k.
The issuance of a pemit for the construction of the facilities will not be inimical to the censoon defense and security or to the health and safety of the public.
5 Se proposed Crystal River Unit 3 facility is a utiliza-tion facility involved in the conduct of research and development activities leading to the demonstration of the practical value of such facility for industrial or commercial purposes.
6.
The Applicant has sustained its burden of proof as to the jurisdiction of the Board and all other matters pertinent to its application.
7 He application is properly filed under and licenses may be issued under Section 104b of the Act.
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,. WHEREFORE, IT IS ORDERED, pursuant to the Act and the Constis-
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sion's Regulations, that, subject to reviev by the Constission upon its own motion or upon the filing of exceptions in accordance with the Rules of Practice, 10 CFR Part 2, the Director of Regulation is directed to issue to Florida Power Corporation a provisional con-struction permit pursuant to Section 104b of the Act substantially in the fom of Appendix A to the Notice of Hearing in this proceed-ing within 10 days from the date of issuance of this Decision.
IT IS FURTHER ORDERED, in accordance with 10 CFR Section 2 764, good cause not having been shown to the contrary, this Initiai~
Decision shall be inntediately effective.
This Decision is issued by a quorum of the appointed Atcatic l
Safety and Licensing Board and is so issued due to the unavaila-bility because of illness, as shown in the record, of the third appointed member of the Board.
ATOMIC SAFEfr AND LICENSING BOARD a
fr f Eug Greuling A
w Samuel W. Jensch, Chai g Issued:
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