ML20010B422
| ML20010B422 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/06/1981 |
| From: | Sears J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20010B411 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8108140459 | |
| Download: ML20010B422 (18) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0tC4ISSION I
BEFORE THE ATOMIC SAFETY _Afl0 LI_ CENSING BOARD In the'. Matter of
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1 SOUTHERN CT. IFORNIA EDICSON COMPANY, h E S* '
Docket Nos. 50-361 OL 50-362 OL (San Onofre Nuclear Generating Station, Units 2 and 3)
TESTIMONY OF JOHN R. SEARS OF THE NRC STAFF ON GUARD CONTENTIONS 2.A. 2.B, 2.C, 2.D.
2.F, 2.G and 2.H RELATED TO EMERGENCY PREPAREDNESS FOR THE SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 and 3
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AUGUST 6, 1981
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Q.1 State your name and title?
A.
bohnR. Sears.
I am a Senior Reactor Safety Engineer in the Em6rgency Preparedness Licensing Branch, Division of Emergency Preparedness, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission.
Q.2 Do you have a statement of professional qualifications?
A.
Yes. A copy of my statement of professional qualifications is attached to this testimony.
Q.3 What is the purpose of this testimony?
A.
The purpose of this testimony is to address Contentions 2.A 2.B.
2.C, 2.D, 2.F, 2.G and 2.H raised by Intervenors GUARD in this operating license proceeding which are related to the emergency preparedness of the San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS 2 and 3). My testimony will examine the state of the Applicants' emergency preparedness as it affects these GUARD's contentions.
Q.4 GUARD Contention 2 states in part:
Whether there is reasonable assurance that the emergency response planning and capability of implementation for SONGS 2 & 3, affecting the offsite transient and permanent population, wiil comply with 10 CFR Sections 50,47 (a)(1) and,(b) or (c)(1) as regards:
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A.
the procedures for noti ication by Applicants of State and
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local response organizations, 10 C.F.R. Secticn 50.47(b)(5),
and for notification of and continued communication among emergency personnel by all involved organizations, 10 C.F.R.
Section 50.47(b)(6);
B.
the means for notification and instruction to the populace within the plume exposure pathway Emergency Pianning Zone, 10 C.F.R. Section 50.47(b)(5);
C.
the information and the procedures for dissemination of informa-tion to the public within the plume exposure pathway Emergency Planning Zone on a periodic basis on how they will he notified and what their initial actions should be in the event of an emergency, 10 C.F.R. Section 50.47(b)(7);
D.
the arrangements for medical services for conteminated and injured individuals,10C.F.R.Section50.47(b)(12);
F.
the capability of each principal response organization to respond and to augment this initial response on a continuous basis,10C.F.R.Section50.47(b)(1);
G.
radiological emergency response training to those who may be called
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on to assist in an emergency, 10 C.F.R. Section 50.47(b)(15);
H.
the methods, staffing, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radio-logical emergency condition within the plume exposure pathway EPZ for SONGS 2 & 3, 10 C.F.R. Section 50.47(b)(9);
With respect to Contention 2.A, have you examined the proc.dures for notification by Applicants of State and local response organizations?
A.
Yes. The applicant's procedure 1.4 entitled " Notification" provides detailed instructions for contacting offsite agencies. The procedure includes Initial Notification forms for each of the four classes of emergency, an emergency notification call-list, and a follow-up notifica :c, form. The procedure implements Emergency Plan Table 5-4 Offsite Response Agency notification and conforms to the criteria of NUREG-0654,E.
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Q.5 With respect to Contention 2.A. do the Applicants' procedures for notification of State anc local response organizations described in your response to Questh 4 above meet planning standard 10 CFR Section 4
50.47(b)(5)?
A.
Yes, as discussed in the pervious answer, the Appitcant's procedures conform to the criteria of NUREG-0654 E which are the criteria for implementing the planning standard of 10 CFR 50.47(b)(5).
Q.6 With respect to Contenticr. 2.A, have you examined the Applicants' proceJures for notification and continued communication among emergency personnel by all involved organizations?
A.
Yes. The Applicants' procedure 1.26 entitled " Communications" describes the communications systems that are available for emergency use, their location and their. functions. This procedure is similar to Emergency Plan Table 7-1 and 7-2, and conforms to the criteria of flUREG-0654,F.1. The Applicant's procedure 1.4 floti-fication includes instructions for follow-up notification. The follow-up notification form is similar in format to the Initial tiotification forms but has more extensive technical content. The i
Applicant's procedures for Site and General Emergencies contain instructions for the periodic disseminatfon of information on the status of onsite operations and conditions to offsite authorities.
Q.7 With respect-to Contention 2.A do the Applicants' procedures i
which you have described in your response to Question 6 above meet planning standard 10 C.F.R. Section 50.47(b)(6)?
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Yes. The implementation of the Applicant's capability for notifica-tion and continued communication among emergency personnel was demonstrated during the full-scale exercise involving the applicant and offsite organizations on May 13, 1981 to the extent that the procedures and systems employed during the Unit 1 exercise were similar to those in place for Units 2 & 3.
These procedures and systems proved to workable and effective.
Q.8 With respect to Contention 2.B, have you examined the Applicants' means for notification and instruction to the populace within the plume exposure pathway EPZ?
A.
Yes, the applican' has designed a siren system in the communities
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within 10 miles of San Onofre. As of August 1,1981, 32 of the 40 sirens and the control system had been installed and the total system is scheduled to be operational by September 1, ? 981. The Applicant has submitted a map showing siren locations with analyical results of the sound levels anticipated.
t The purpose of the sirens is to alert the public to tune in to local radio l
stations for emergency instructions.
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- Q.9 With respect to Contention 2.B do the means for notification and I
instruction to the populace within the plume exposure pathway EPZ wh,1ch you have described in response to Question 8 above meet plan-ning standard 10 CFR Section 50.47(b)(5)?
A.
Yes the means for notification and instruction to the populace satisfy the criteria of NUREG-0654, E and Appendix 3 which are the implementation criteria for 10 CFR 50.47(b)(5).
Q.10 With respect to Contention 2.C. have you examined Applicants' pro-cedures for dissemination of information to the public within the plume exposure pathway EPZ on a periodic basis as to how the public will be notified and what its initial actions should be in the event
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of an emerger.cy?
A.
Yes, an informational brochure has been mailed to residents of San Clemente, San Juan Capistrano, Capistrano Beach and Dana Point. The document provides a general outline of public notification, sheltering and evacuation procedures, and a detailed map of evacuation routes and location of reception and care facilities. The mailing was preceded by a newspaper advertisement with instructions on how to obtain a copy of the brochure for anyone who may not have received it through the mail.
New applicants for electrical service are given complete emergency planning information. A flyer has ':een printed with similar information for distribution to all park visitors.
Emergency iesponse posters have been designed for.aotels and hotels. Thei next issue of the telephone directory will have a page of emergency public notification information i
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6,A and protective action instructions. The total pubitc education prograa for the plume exposure pathway EPZ is scheduled for full operation by
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the Fall of 1981. On an annual hsis, simplified mailers and newspaper adv'ertisements will remind residents of the emergency planning educational program.
Q.11 Do the Applicants' procedures for dissemination of information which you have described in response to Question 10 above meet planning standard 10 CFR Section 50.47(b)(7)?
A.
Yes, the Applicants' procedures for dissemination of information j
satisfy the criteria of f;UREG-0654, G1 and C?, which are the implementation criteria for 10 CFR 50.47(b)(7).
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'b Q.12 With respect to Contention 2.D have you examined arrangements made by Applicants for medical services for contaminated and injured individuals?
A.
Yes, the Applicant's emergency procedures 1.8 Emergency Exposure, 1.9 Thyroid Blocking Pills,1.11 Rescue, and 1.12 Injury described in detail such arrangements.
Emergency Procedure 1.12 includes a checklist for Control Room Actions for Personnel injury, instruction for contamination injury treatment and a directional map to egress and a layout for the South Coast Community Hospital. Arrangements have also been made with the Tri City Comunity Hospital to provide medical assistance for injured and contaminated patients. The Emer-gency Plan includes Letters of Agreement uith local physicians for O
treeting eny individual suffering from an in3ury complicated by radiation contamination as a consequence of activity at San Onofre.
In addition, the Applicant has recently signed a contract for training of both onsite and offsite per sorinel who may be involved with a potentially cor.taminated and injured persort by the Radiation Management Corporation. The Applicant has written agreements with the Scudder Ambulance Company and the Superior Ambulance Company :
transporting injured and contaminated personnel. The Emergency Plan at Section 6.5.2 requires that two persons trained in first aid will be onsite at all times.
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I Q.13 With respect to Contention 2.D do Applicants' arrangements for
.me' cal services for contaminated and injured individuals di described in your respon.se to Question 12 above, meet planning standard 10 C.F.R. Section 50.47(b)(12)?
A.
Yes, the Applicant's arrangements for medical services satisfy the criteria of NUREG-0654, L 1, 2 and 4 which are the implementa-tion criteria for 10 C.F.R. 50.47(b)(12).
Q.14 With respect to Contention 2.F have you examined the Applicants' provisions to respond to an emergency and to augme,nt any initial response on a continuous basis?
A.
Yes, Section 5 of the Emergency Plan describes in detail the onsite
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emergency organization and its augmentation and extension offsite.
The Watch Engineer is initially designated as the Site Emergency Coordinator. When an abnormal situation arises, it is his responsi-bility to deter;nine the classification of the situation and to implement the Emergency Plan. There is continuous 24-hour communication capability between San Onofre and Federal, State and local response organizations to ensure rapid transmittal of accurate notification information and emergency assessment data.
The Site Emergency Coordinator has the authority to declare the emergency and to make the necessary notifications and recommendations to offsite authorities.
Station staff emergency assignments have been made. Call-out for augmentaticn of on-shift capabilities would i
be made,immediately upon declaration of the emergency. The Applicant
m ies that all required personnel would be present within 60,. minutes, and qualified personnel necessary to perform the
~ functions listed in flUP.EG-0654, Table B-1, under capability for 30 minutes, would be present within 30 minutes.
Q.15 With respect to Contention 2.F, does the Applicants' capability to respond to an emergency and to augment this initial response on a continuous basis described in your response to Question 14 above meet planning standard 10 C.F.R. Section 50.47(b)(1)?
A.
Yes, the Applicant's capability to respond to an emergency and to augment his staff satisfies the criteria of NUREG-0654, A & B, which are the implementation criteria to meet the planning standard 10 CFR 50.47(b)(1)?
Q.16 With respect-to Contention 2.G have you examined the Applicants' radiological emergency response training provided to those who may be called on to assist in an emergency?
A.
Yes, the Applicant's Emergency Plan in Table 8-1 lists the personnel involved and the requirements for both initial and periodic re-training on the scope, responsibilities and functioning of the Emerger.cy Plan and Emergency Implementing' Procedures with specific instruction on those aspects applicable to the particular person's responsibility. These areas include emergency response coordina-tion ar.d direction, accident assessment, radiological monitoring, repair and damage control, rescue and first aid.
I have been I
informed by the Applicant that the initial training on the Emergency Plan is in progress and will be completed prior to fuel loading. In
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i addition, the Applicant has described to me the training provided
.through the Applicant's support by the Radiation Management
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Cortar. Lion.for over 300 personnel from offsite organizations,
.ncluding physicians and hospital emergency room personnel, ambulance personnel, police and firemen.
Q.17 With respect to Contention 2.G, does the radiological emergency response training provided by the Applicants which you have de-cribed in response to Qu'estion 16 above meet planning standard 10 C.F.R. Section 50.47(b)(15) ?
A.
'Yes, the radiological emergency response training provided by the Applicants satisfus the criteria of NUREG-0654, 0 which are the implement-tation criteria to meet the planning standard of 10 CFR 50.47(b)(15).
Q.18 With respect to Contention 2.H, have you examined the methods, stafThg, systems and equipment available to Applicants for assessing and monitoring actual or potential offsite consequences
'f a radiological emergency condition within the plume exposure pathway EPZ for SONGS 2 and 37 A.
-Yes, radiological monitoring systems to monitor radioactivity levels in all of the important process and effluents points are described in Section 11.5 of the PSAR. Additional listings of equipment available at the station for both ir ;.ial and continuing assessment of emergency situations are in Tables 7-3 through 7-7 and Appendix D I
of the Emergency Plan.
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I The Applicant is training the Health Physics Shift Foreman to perform dose assessments. There are at least 2 Senior Health Physics technical hersonnel, qualified to perform dose assessments, whose driving time from home to San Onofre is less than 30 minutes.
The Applicant's Emergency Implementation Procedure 1.22, Emergency Dose Projections - Airborne Release, for Unit 1 is presently under study and revision to apply to Unit 2 and 3.
Hand calculations are
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employed in this procedure. The Applicant is installing a Health Physics computer system which will process aeteorological data and data from radiation monitors to calculate dose at various distance's from the plant. This automated system is scheduled to be fully operational by July 1982 and will be available for connection to offsite
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Q.19 Do the methods, staffing, systems and equipment, available to Applicants for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition described in your response to Question 18 above meet planning standard 10 C.F.R.
Section 50.47(b)(9)?
A.
Yes, the methods, staffing, systems and equipment for monitoring releases and assessing consequences satisfy the criteria of NUREG-0654, I which are the implementation criteria to meet the planning standard of 10 C.F.R. 50.47(b)(9).
Q.20 What is your assessment of the Applicant's capability to implement the procedures and activities which you have described in this i
testimony?
i A.
I have reviewed the implementing procedures and, in my judgment, they provide adequate and clear direction to the person called
'upon to implement them. The Applicant has an ongoing training prbgramwhichIhaveexaminedandfoundacceptable. This training program provides assurance that the procedures will be followed.
Additional confirmation of the Applicant's ability to implement the emergency preparedness program is provided through the Offic'd-of Inspection and Enforcement's Emergency Preparedness Appraisal Program (EPAP) which is an onsite inspection and verification process, and the conduct, by the Applicant of an onsite exercise, both of which are scheduled far before the time expected for issuance of the operating license for San Onofre 2 & 3.
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JOHN R. SEARS RESUME'
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Prior to 1952, I was employed in field jobs in various aspects of mechanical engineering.
In 1952, I joined Brookhaven National Laboratory as a Reactor St.ft Supervisor on the Brookhaven Graphite Reactor. While at Brookhaven, I completed a series of courses given by the Nuclear. Engineering Department in nuclear engineering.
These ccurses were patterned on the ORSORT programs.
In 1956. I was appointed Project Engineer on the Brookhaven Medical Research Reactor.
I was a member of the design group, participated in critical design experiments, wrote specifications, coauthored the hazards report, was re,ponsible for field ipspection and contractor s
About three liaison, trained operators and loaded and started up the reactor.
months after start-up, in 1959, following the successful completion of proof tests
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and demonstration of the reactor in its design operating mode for boron capture therapy of brain cancer, I accepted a position as reactor inspector with the Division of Inspection, U. S. Atomic Energy Commission.
In 1960. I transferred, as a reactor inpsector, to the newly-formed Division of Compliance.
I was responsible for the inspection, for safety and compliance with license requirements, of the licensed reactors and the fuel faorication and fuel processing plants. which use more than critical amounts of special nuclear material, in the Eastern United States.
In September 1968. I transferred to the Operational Safety Branch, Directorate of Licensing. My responsibility included development of appropriate guides for evaluation of operational aspect of license applications and staff assistance in review of power reactor applicants submittals in the areas of Organization and Management.
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. Personnel Qualifications, Training Programs, Procedures and Administrative Control, Review and Audit, Start-up Testing Programs Industrial Security and Emergency Planning.
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2 The Branch was reorganized as the Industrial Security and Emergency Planning Branch in April 1974 to place increased emphasis and attention upon areas of physical security and emernency planning.
In 1976 I transferred to the Divison of Operating Reactors as the sole reviewer
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responsible for review of emergency planning for all the operating reactors in the United States.
New York City College,1950 - Mechanical Engineering Argonne International School of Reactor Technology,1961 - Reactor Control Course GE BWR System Design Course,1972 Popo-U.S. Army, 1974 - Course in Industrial Defense and Disaster Planning Instructor at DCPA, 1976, 1977 - Course in Emergency Planning Director,1962 - Reactor Program, Atoms for Peace Exhibit, Bangkok, Thailand
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Director,1966 - Atoms for Peace Exhibit, Utrecht, Holland
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I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
-f BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of SOUTHERN CALIFORNIA EDISON COMPANY,
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50-362 OL
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(San Onofre Nuclear Generating Station, )
Units 2 and 3)
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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF TESTIMONY ON GUARD CONTENTI0flS 2.A, 2.B 2.C, 2.D, 2.F. 2.G, AND 2.H C0flCERflING EMERGENCY PREPAREDNESS FOR THE SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or as indicated by a double asterisk by express delivery service or as indicated by an asterisk by depasit in the Nuclear Regulatory Commission internal mail system, this 10th day of August,1981:
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- James L. Kelley, Esq., Chairman
- David R. Pigott, Esq.
Administrative Judge Samuel B. Casey, Esq.
Atomic Safety and Licensing Board John A. Mendez, Esq.
l U.S. Nuclear Regulatory Commission Edward B. Rogin, Esq.
Washingtor.
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20555 Of Orrick, Herrington & Sutcliffe l
A Professional Corporation Dr. Cadet H. Hand, Jr.,
600 Montgomery Street Administrative Judge San Francisco, California 94111 c/o Bodega Marine Laboratory University of California Alan R. Watts, Esq.
P. O. Box 247 Daniel K. Spradlin Bodega Bay, California 94923 Rourke & Woodruff 10555 North fiain Street Mrs. Elizabeth B. Johnson, Suite 1020 Administrative Judge Santa Ana, California 92701 Oak Ridge National Laboratory P. O. Box X, Building 3500
- Richard J. Wharton, Esq.
Oak Ridge, Tennessee 37830 University of San Diego School t
l of Law Alcala Park Janice E. Kerr, Esq.
San Diego, California 92110 J. Calvin Simpson, Esq.
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Lawrence Q. Garcia, Esq.
Mrs. Lyn Harris Hicks l
California Public Utilities Commission GUARD l
5066 State Building 3908 Calle Ariana San Francisco, California 94102 San Clemente, California 92672 l
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- Charles R. Kocher, Esq.
A. S. Carstens James A. Beoletto, Esq.
2071 Caminito Circulo Norte Southern California Edison Company Mt. La Jolla, California 92037 2244 Walnut Grove Avenue Rosemead, California 91770
- Atomic Safety and Licensing Board Panel David W. Gilman U.S. Nuclear Regulatory Commission Robert G. Lacy Washington, D.C.
20555 San Diego Gas & Electric Company P. O. Box 1831
- Atomic Safety and Licensing Appeal San Diego, California 92112 Board Panel U.S. Nuclear Regulatory Commission
- Phyllis M. Gallagher, Esq.
Washington, D.C.
20555 1695 West Crescent Avenue Suite 222
- Secreta ry Anaheim, California 92701 U.S. Nuclear Regulatory Commission ATTN: Chief, Docketing & Service
- Charles E. McClung, Jr., Esq.
Branch Fleming, Anderson, McClung & Finch Washington, D.C.
20555 23521 Paseo De Valencia Suite 308A
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- Laguna Hills, California 92653 Donald F. Hassell Counsel for NRC Staff 4
- 4..e, y
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EPZ CONTENTION ADMITTED BY ASLB ORDER ON THE RECORD OF AUGUST 4, 1981 (TR. 6803)
The eraergency response plans fail to meet the requirements of 10 C.F.R. 6 50.47(c)(2) because local emergency planning officials have arbitrarily established the boundaries of the Plume Exposure EPZ in that they have mechanically applied a 10 mile boundary and that the Interagency. Agreement (IAEP) among all local jurisdictions defines the EPZ by drawing compass lines on a map of the area.
In determining the exact size of the EPZ, emergency planr.ing officials have failed to consider the following local conditions:
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topography 2.
meteorology 3.
evacuation routes 4.
demography 5.
jurisdictional boundaries 6.
SAI report 7.
land characteristics i
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_ - _ _ - UNrm ase anse NJCLEAR REGUL%ORY CO2 MISSION
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A'IO:4IC SAFEIT AND LICESSItEpp BEFORS ADMINISTRATIVE JUDGES Ja:ms L. Kelle,. 01 airman Elizabeth B. Joh'6'sg r 1 M M Cadet H.. Hand
- U3h!.C-0 ELD
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Docket Nas. 50-361-OL In the Matter of
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50-362-00 SOUrdERN CALIFORNIA EDISCN CDMPANY,
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(San Onofre Nuclear Generating
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Station, Units 2 and 3)
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August 7, 1981
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ORDER (Modifying an Issue Concerning Earthquakes and Dnergency Planning) e At the time of our hiling of July 29, 1981, the Board had in hand menorandtru to'it from Darrell G. Eisenhut of the NRC l
f the June 11, 1981 13, 1981 letter That nenorandtrn transmitted to us a copy of the May Staff.
from Fobert L. 'Ibdesco of the NRC Ste.rf tis Mr. Robert Dietch and Mr. D. W Gilman (Vice-Presidents of Southern California Edison Company and San Diego Gas and Electric Company, respectively). 'Ihat letter set forth in detail the Staff's view of the matters to be ensidered by the Applicants
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concerning the evaluation of the effect of earthquakes on their emergency Specifically, the Ibard noted that the Applicants were told, "For plans.
i purposes of this evaluation, as a planning ' basis you may assume that the plant experiences earthquake effects no nore severe than the Safe Shutdown Earthquake.h '1he Board Order of July 29, 1981 stated our reasons for pastulating an earthquake in excess of the SSE and we are not, saayed from that position.
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i We have listened to oral arguments, concerning our Order and have Our concerns still focus upon received written memoranda from the' parties.
the questions we raised in the Order, mmely, "What steps could be taken by the Applicants and responding jurisdictions to carry out evacuation in a timely manner and/or protect those in the EPZ pending evacuation" following a damaging earthquake.
29,1981 may It row appears, however, that tie Board order o' aly have posed such cevere consequences resulting frczn the hypothesized earthquake that evacuation and/or protection of those in the EPZ would be virtually inpossible, n at was not our intention. %e Board's intent was, a site specific inquiry to examine the impact of a major earthquake,.
We Board, acconpanied by a radioactive release, ppcn the emergency plans.
does rot know Wat magnitude earthquake would be reqdired to cause a
" breach of centainment" and " collapse of bridges and overpasses 'and surface We therefore breaks rendering the highways tenporarily inpassable."
present the following revised issue.:
his assumed
,. Assume a major earthquake in the SONGS area.
earthquake causes extensive structural damage to the accompanied by radiolcgical releases requiring evacuation in the In these circumstances d at steps plume exposure pathway of the EPZ.could be taken by the applican carry out evacuation in a timely manner and/or protect those i EPZ pending evacuation? resources, could be brought in to assist in th would federal assistance te acconplished?
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I h t the physical In posing the' foregoing the Board wishes to learn w a i ; se0erity beyord the cons'equences of earthquakes, in a scale of increas ry to mmunication i
SSE, would be upon the emergency plans as they relate i
ould become,a evacuations up to some presu.cd point where evacuat cn w T
A paint of beginning physical irrpassibility in any reasonable time frene.
nitude earthquake should relate to the presumed consequences of an SSE mag i tions and highways.
upon evacuation and the recessary related mmun ca l
i g for such an Pursuant to the Staff's earlier instructions, p ann n Sequentially, ss.
earthquake presumably either is conplete or in progre d conselpences from that level of planning, we wish to examine the presume s they relate to the of a series of increasingly rore severe earthquakes a f
Our questions are designed only to, test the adequacy emergency plans.
there is reasonable assurance the emergency plans and to determine whetherill be taken at S that adequate protective measures can ard w l
i l releases severe event of a major earthquake accompanied by radio og ca l
enough to initiate the em rgency evacuation p an.
EDR TrlE RIOMIC SAFEIT NO LICENSIN3 BOARD
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Jqmeg L. Kelley, Chairman AD:4INISTRATIV3 JUDGE Dated at Bethesda, Maryland this 7th day of August 1981.
Chairman Palladino cc:
Cbmissioner Gilinsky Comissioner Bradford Comissioner Ahearne
- Iconard Bickwit, Jr., GC e
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