ML20050C115
| ML20050C115 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 04/01/1982 |
| From: | Higginbotham W, Hoover W, Preston J JOINT APPLICANTS - CLINCH RIVER BREEDER REACTOR |
| To: | National Resources Defense Council, Sierra Club |
| References | |
| NUDOCS 8204080152 | |
| Download: ML20050C115 (26) | |
Text
a s RELATED CORnDPONDECE S-4/1/82
'a2 /El -1 P4 :30 UNITED STATES OF AMERICA i~
NUCLEAR REGULATORY COMMISSION
)
In the Matter of )
)
) Docket No. 50-537 UNITED STATES DEPARTMENT OF ENERGY )
PROJECT MANAGEMENT CORPORATION C)
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TENNESSEE VALLEY AUTHORITY ) # \ 9
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APPLICANTS' RESPONSE TO rf.wif4 f NATURAL RESOURCES DEFENSE COUNCIL, INC.
AND THE SIERRA CLUB SIXTEENTH ^/ 1\ a '
SET OF INTERROGATORIES TO APPLICANTS Pursuant to 10 CFR S 2.740b, and in accordance with the Board's Prehearing Conference Order of February 11, 1982, the United States Department of Energy, Project Management Corporation, and the Tennessee Valley Authority (the Applicants) hereby_ respond to the Natural Resources Defense Council, Inc. and the Sierra Club Sixteenth Set of Interrogatories to the Applicants, dated March 18, 1982. /
- /
The Applicants' March 29, 1982 Motion for Protective Order objected to Interrogatories I.4.(a) - (d); I.5.;
II. 2. and 3., and III. 1-11.
8204080152 820401 PDR ADOCK 05000537 g PDR h0 l 1
'.- Answers to General Questions (a) -
(f)
(a) Provide the direct answer to the question ANSWER: See the direct answers below under heading "ANSUER".
(b) Identify all documents and studies, and the parti-cular parts thereof, relied upon by Applicants, now or in the past, which serve as the basis for the answer. In lieu thereof, at Applicants' option, a copy of such document and study may be attached to the answer.
ANSWER: See the direct answers below under heading
" DOCUMENTS".
(c) Identify principal documents and studies, and the particular parts therof, specifically examined but not cited in (b). In lieu thereof, at Applicants' option, a copy of each such document and study may be attached to the answer.
ANSWER: Unless otherwise indicated below in regard to the answer under the heading " DOCUMENTS"; none.
(d) Identify by name, title and affiliation the pri-mary Applicant employee (s) or consultant (s) who provided the answer to the question.
ANSWER: See the attached affidavits.
(e) Explain whether Applicants are presently engaged in or intend to engage in any further, ongoing 1
research program which may affect Applicants' answer. This answer need be provided only in cases where Applicants intend to rely upon ongoing research not included in Section 1.5 of the PSAR at the LWA or construction permit hearing on the CRBR. Failure to provide such an answer means that Applicants do
- intend to rely upon the existence of any such research at the LWA or con-struction permit hearing on the CRBR.
ANSWER: Unless not in Section 1.5 of the PSAR and the direct answer below; none.
(f) Identify the expert (s) if any, which Applicants intend to have testify on the subject matter ques-tioned, and state the qualifications of each such expert. This answer may be provided for each separate question or for a group of related ques-tions. This answer need not be provided until Applicants have in fact identified the expert (s) in question or determined that no expert will testify, as long as such answer provides reasona-ble notice to Intervenors.
ANSWER: Applicants-have not yet identified the
-expert (s) in question.
l
D Answers to Specific Questions -
- 1. Contention 5
- 1. In light of the analysis in the NASAP report, for each principal chemical and physical form in which plutonium-containing material is found in the CRBR fuel cycle:
- a. identify the chemical and physical form of such material;
- b. identify where such material is found in the CRBR fuel cycle (e.g., fuel fabrication plant, reprocessing plant);
ANSWER:
- a. In addition to that charged to the core, plutonium is synthesized in the CRBR through neutron capture of uranium-238. The resul-tant isotopic distribution of plutonium is present as the solid dioxide (PuO 2)- UPon reaction with nitric acid at the reprocessing plant, the plutonium passes into solution, is complexed, extracted, redoxed, and isolated in an acidified nitrate solution. Subs,equent_
heating decomposes the precipitated plutonium nitrate to the corresponding oxide. This product is transferred to a refabrication l l
plant, where it is reductively pelletized to !
.- a solid dioxide suitable for reactor use.
After loading into fuel pins, this form is placed in the CRBR core.
- b. (i) production of Pu02 in situ. (solid, dioxide): (CRBRP)
(ii) an equilibrium of plutonium complexes in acidified aqueous / organic solutions leading through thermal denitration s Pu02 : (reprocessing plants)
(iii) solid dioxide (PuO2): refabrication plant (iv) reloaded solid dioxide (Puo2): CRBR driver fuel.
DOCUMENTS:
HEF Conceptual Design Report, ORN7/CFRP-81/4.
NASAP Report, " Nuclear Proliferation and Civilian Nuclear Power," DOE /NE-0001, Volumes III, IX.
Memorandum, J. R. Longenecker to P. S. Check, HQ: E:82:012, Docket 50-537, "CRBRP Fuel Cycle,"
March 19, 1982.
- c. identify whether such material is directly weapons-usable, i.e., does not require further chemical processing; l
l I
l
O
. ANSWER:
The NASAP Report (DOE /NE-0001) contains the following statement on page 2-43 of Volume 2:
A significant difference between LMFBR MOX and recycle MOX fuel materials lies in the fact that LMFBR fuels would have plutonium concentrations of 15 to 25%, which are considered to be weapons-usable, whereas recycle fuels would contain only 4 to 6% plutonium. Consequently, it is theoretic-ally possible that a nuclear device could be made directly.from fresh LMFBR fuel without the need for chemical separation; in recycle systems, Pu02 itself is the only material that is weapons-usable. This feature would increase the vulner-ability of the LMFBR system to subnational pro-liferation threats, particularly in countries deploying only the reactors. I t would also increase vulnerability to national threats, although most nations would probably employ out-of-system facilities to recover plutonium metal.
By this definition, the Pu02 and Pu0 2/U02 fuels for the reactor core are considered to be weapons-usable. Spent blanket fuel and waste discards from reprocessing would not meet these criteria. The intermediate plutonium con-taining solutions at the reprocessing plant would not
- generally meet these criteria. Although spent core fuel elements would have a high Pu to U ratio, they are not considered to be. targets for diversion due to their very high level of radioactivity.
- d. identify what quantities of such material are considered to be of " safeguards signifi-
- /
cance,*- (i.e., give the approximate mass needed for a clandestine fission explosive (CFE);
ANSWER:
(i) If the breeding cycle is run to obtain 25 wt
% plutonium, the resultant material requires maximum level of safeguarding; i.e., that which applies to 2 kg of pluto-nium content. Lesser concentrations are subject to reduced safeguards requirements.
(ii) The same applies if Pu(NO 3 )4 solution con-tains 0.5 wt % plutonium.
(iii) Pu0 2 in quantities greater than 2 kg of Pu are accorded maximum safeguards protection.
--*/ Intervenors use the term " safeguards significance" to define a significant quantity of material in relation to the amount of nuclear material needed for a nuclear explosive. (Cf. NASAP Report, DOE /NE-0001/2, pp. 3-38 and 4 -4. ) The use of this definition is meant to avoid the need for Applicants to release details concerning
, weapons design.
-DOCUMENTS:
A DOE Special Study Report on Reactor Materials and Nuclear Explosives, DOE /DP-0003 (Confidential / National
. Security Information), pages 28-30.
- e. indicate Applicants' estimate of the time needed to convert such material into a form suitable for a CFE; ANSWER:
The minimum time scale for all of these materials will be a matter of weeks for conversion to a form suitable for a CFE.
DOCUMENTS:
A DOE Special Study Report on Reactor Materials and Nuclear Explosives, DOE /DP-0003 (Confidential / National Security Information), page 32.
- f. to the extent not provided in updating answers to Intervenors' Eighth Set of Inter-rogatories,Section VII, define the response time Applicants deem to be adequate -for detecting the diversion of an amount of such material considered to be of safeguards significance; and
ANSWER:
Applicants will provide the answer concurrent rith the updating of answers to Intervenors' Eighth Set of Interrogatories,Section VII.
- g. identify the degree of Applicants' assurance (e.g., 99 percent confidence level) that detection will occur within the period speci-fled in subpart (e) above.
Answer:
For the Applicants, DOE can speak on the basis of 38 years of experience with materials and facili-ties like those involved in the CRBRP program.
Safeguards and security measures are continually reviewed and upgraded to meet the changing percep-tions of threats and to employ more efficient safeguards and security procedures and tech-niques. The Applicants believe that detection and response to diversion attempts will be effective.
DOCUMENTS:
Draft Environmental Statement on the LMFBR Program, WASH-1535, Vol. 4, Section 7.4-(December 1974).
Nuclear Regulatory Commission, Annual Reports to Congress:
.- NUREG-0524, FY 1978 NUREG-0690, FY 1979, Chapter 5 NUREG-0774, FY 1978, Chapter 7
- 2. In determining what constitutes an adequate safe-guards system, do Applicants conservatively or otherwise assume that a crude CFE could be designed and constructed by a small group of people (perhaps one), none of whom have ever had access to the classified literature, without necessarily using a great deal of technological equipment or conducting any experiments? (See OTA Report, Nuclear Proliferation and Safeguards, pp. 140-141 ?
ANSWER:
Although the adequacy of CRBRP fuel cycle safe-guards and licensing of fuel cycle facilities are not issues in these proceedings, Applicants assume that a crude CFE could be designed and constructed by a small group of people (perhaps one), none of whom have ever had access to the classified literature, without necessarily using'a grea,t deal of technological equipment or conducting any experiments.
4 11 -
DOCUMENTS :
OTA Report, Nuclear Proliferation and Safeguards, pp. 140-141.
Memorandum from Lee V. Gossick to Clifford V.
Smith, Jr., et al., Operating Assumption on Clandestine Fission Explosives, 3 pp. plus 1 unnumbered sheet, August 8, 1977.
- 3. In light of recent analyses and recommendations by the General Accounting Office, see GAO, Assessment of Various Aspects of this Nation's Nuclear Safe-guards Program (EMD- 80 -48) (1980) , describe what steps have been taken to coordinate nuclear threat definition policy and levels of protection pro-vided to similar nuclear materials by DOD, DOE, and NRC. To the extent differences among the three agencies still exist with respect to the application of physical security and material con-trol and accounting to facilities that possess or nandle strategic quantities of special nuclear material, specify what such differences are, with specific reference to:
- a. the internal threat to such facilities assumed by each agency including but not limited to assumptions regarding:
- 1. the number of people;
- 11. the degree of collusion; i ii, the degree of armament; iv. the. degree of taining;
- v. the degree of planning; and
- b. the external threat to such facilities assumed by each agency including assumptions regarding the factors listed in subpart (a)(1) through (a)(v) above.
ANSWER:
, The subjects of threat definition, and the appli-cation of physical protection, material control and accounting are of concern to DOE, and NRC.
Coordination is required and implemented.
The Nuclear Regulatory Commission has published its design threats in the Federal Register, title 10, 73.1(a). The text' discusses number of people, collusion, weapons, training and inside knowledge for internal and external threats.
Since the statutory responsibilities, the types of facilities, the forms of materials, and the envi-ronment in which DOE operates are not identical to
13 -
those of NRC, the details may be somewhat differ-ent. However, every effort is made to ensure that threat definitions and protective activities are equally credible and comparably effective. The factors considered by DOE include the number of people, collusion, weapons, training and inside knowledge for internal and external threats and, when appropriate, adversary characteristics.
No recent studies, other than the GAO reference listed in the question, that compare the actual performance of safeguards / physical protection at DOE, D0D, and NRC facilities are known to the Applicants. A study of the comparability of NRC regulations and DOE orders was performed in 1980-1981 and is listed below.
DOCUMENTS:
B. Keisch and A. Fainberg, " Differences in DOE and NRC Safeguards and Security Requirements and their Potential Impact on Comparability of DOE and NRC Systems," Brookhaven National Laboratory, DNL-29272, March 1981.
Federal Register, 10 CFR 73.1 (a) , quoted above.
H. R. Wagner, A Survey of Threat Studi s Related to the Nuclear Power Industry, Sandia National Laboratory, SAND-77-8254, 1977.
14 _
P. de Leon, et al., Attributes of Potential Criminal Adversaries of U.S. Nuclear Programs, Rand Corp., R-2225-SL, 1978.
J. B. Stewart, et al., Generic Adversary Charac-teristics Summary Report, NRC, NUREG-0459, 1979.
Gail Bass, et al. , Motivatior and Possible Actions of Potential Criminal Adverraries of U.S. Nuclear Programs, Rand Corp., R-2554-SL, 1980.
Development of Deterrent Strategies,- BDM Corp.,
BDM/U-81470-TR, 1981.
Nuclear Regulatory Commission, Annual Reports to Congress:
NUREG-0524, FY 1978 NUREG-0690, FY 1979, Chapter 5 NUREG-0774, FV 1980, Chapter 7.
II. Contention 8
- 1. John W. Gofman argues [in Radiation and Human Health, Sierra Club Book 1981, pp 760-853] that the BEIR I, III and UNSCEAR (1977) estimates of genetic risk from radiation exposure _do not ade-quately account for many irregularly inherited t
diseases and consequently they underestimate the genetic effect of radiation exposure with respect to irregularly inherited diseases by a factor between 6 and 100. (See Gofman, supra, page 791.) If Applicants disagree with Gofman's analysis in this regard or if Applicants. disagree with Gofman's estimate of the total of all genetic and chromosomal diseases or defects (at page 849) p
J please explain precisely the nature of your disagreement.
~
II. CONTENTION 8
- 1. The Applicants disagree with Gofman's analysis of the estimate of the increase in irregularly inherited diseases as the result of radiation exposure and also with his estimate of the total genetic and chromosomal defects resulting from radiation exposure. For the purposes of this discussion, comparison is made between the estimated fre-quencies reported in Gofman, J. W., " Radiation and Human Health," Sierra Club Books, 1981, pp. 760-853, and the BEIR III Report, National Academy Press 1980, pp.71-134.
The types of genetic disorders are considered separately, although some comments will be common to all.
The points discussed are the more major ones.
A. Autosomal Dominant and X-linked Disorders The only difference between Gofman and BEIR III is in the upper estimate of the number of cases per million live births for 1 rem per person per generation.at equi-librium ' (Gofman, 400 BEIR, 200) . This difference is due to th'e doubling dose range used by BEIR III of 50-200 rads, whereas Gofman suggests a lower value of 25 rads. There is no good reason to assume 25 rads for a low dose rate expo-sure. BEIR.III takes account.of the dose rate, in obtaining a doubling. dose of 100 rads, and simply as a precautionary l
1
s tep, use a range of x2 and x1/2. The arguments of Gofman for a 25 rad doubling dose ignore dose rate effects, that have been clearly demonstrated in animal studies.
B. Recessive Disorders The estimates provided by Gofman and BEIR III are essentially the same. The only slight difference is due to Gofman's choice of a lower limit for the doubling dose dis-cussed in (A) above.
C. Chromosomal Aberrations (i) Deletions:
This category is not considered separately by BEIR 'II, but Gofman (p. 849) concludes that radiation induced deletions could occur extensively, and account for a high frequency of defects. However, there are several errors in this argument.
The majority of larger deletions - those involving several genes up to microscopic size - are cell lethal.
Cytological evidence shows this is the case for microscopic-ally observable ones (Joshi, G. P. et al, Int.J.Radiat.
Biol. 41, 161-182, 1982). Also the frequency of observable deletions in spontaneous abortuses is very much higher,than in liveborns (Carr, D. H. and Gedeon, M., in " Population Cytogenetics" Academic Press, pp. 1-9, 1977 and Jacobs, Pa.,
AmJ. Hum. Genet. 33, 44-54, 1981). It can also be shown that
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deletions involving several genes, but not microscopically observable, are also cell lethal.
Very small deletions are detectable genetically following radiation by the mouse specific locus assay (Russell, L. B., Mutation Res. 11, 107-123, 1971). They induced at a low frequency with low dose rates, and the doubling dose is 100 rads. Larger deletions, involving the selected loci, are not recovered as they are cell lethal.
The contribution of radiation-induced deletions to the category of detectable mutations is likely to be low.
(ii) Translocations BEIR III and Gofman use the human data of Brewen and Preston (Nature, 253, 468-470, 1975) for estimating the genetic effects of translocation induction. Three major factors,- considered by BEIR III, demonstrate why Gofman's is an overestimate.
(a) Brewen and Preston used acute exposures, a dose-reduction factor is required.
(b) The observed translocation frequency is for males only. The transmission of translocations induced in oocytes is very low. For a population estimate it is appro-priate to divide the male rate by two.
- (c) .The unbalanced produc.t of translocation segregation largely represents the category of genetic dis-orders. The probability of recovering this in the next
. generation is 0.06 of the induced frequency, and the induced frequency must be corrected by this factor.
(iii) . Trisomy - 21 The data are so equivocal that conclusions are difficult to draw. The dose estimates are very uncertain, and the factors other than radiation that could influence the results were not considered. A separate estimate for this category is not warranted.
D. Irregularly Inherited Diseases This is the most difficult category of disorders for which a spontaneous and induced frequency can be deter-mined. The spontaneous frequency given by BEIR III is based on the British Columbia population survey (Trimble, B. K.
and Doughty , J . H. , Ann. Hum. Genet. (Lond.) 38,199-223, 1974). This is a valid estimate, based on the best availa-ble data.
The difference in estimates between BEIR III and Gofman revolve around the concept of the " mutational component" of these disorders. BEIR III define this clearly and apply it accordingly. The " mutational component" is the proportion of the incidence of these disorders that would vary directly with the mutation rate. A value of 5-50% is quite legitimate, with 50% being an excessive miximal limit based on data from animal experbuents (e.g., Spalding, j. F.
I
. . et al, Genetics, 897-906, 1969). The value of 100% used by Gofman is not warranted.
The overall estimate of BEIR III for the increase in equilibrium value of genetic disorders as the result of 1 rem of radiation to the population per generation includes an experimentally well-documented maximal value, and cannot be considered an underestimate.
DOCUMENTS:
See those discussed in the ANSWER above.
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l UNITED STATE 5 0F AMERICA NUCLEAR REGULATORT CORRISSI0ai In the satter of ,)
Department of Energy ,) '
PROJECT RANAGEMENT CORPORATI0ei and,)
TENNESSEE VALLEY AUTHORITY ,)
AFFIDAVIT Of willias A. Higinbothee, being duty sworn, deposes and l says as follows:
l l
- 1. That he is caployed as Senior Scientist, Department of Nuclear i Energy, Brookhaven National Laboratory, and that he is duly authorized to answer interrogatories numbered 1.1c,1.1g,1.2, I.3 in the Sixteenth set.
- 2. That the above-sentioned and attached answers are true and correct to the best of his knowledge and belief.
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.t-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1
In the setter of ,)
Department of Energy ,)
DOCKET No. 50-537.
PROJECT M AN AGEMENT CORPORATION and,)
TENNESSEE VALLEY AUTHORITY f)
AFFIDAVIT OF Major General William W. Hoover, USAF, being duly sworn, deposes and says as follows:
- 1. That he is emplcyed as Deputy Assistant Secretary for Military Application, U.S. Department of Energy, and that he is duly authorized to answer interrogatories numbered I.1d, I.1e in the Sixteenth set.
- 2. That the above-mentioned and attached answers are true and correct t
to the best of his knowledge and belief.
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- - ,,- Signature
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SUBSCdIBEDandSWORNtobeforemethis [ day of l
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Notary Public [
,W My Commission expires '7 - / ,19 f2 9
UNITED STATES GF AMERICA NUCLEAR ftEGULATORY COMMISSION l
In the matter of l!
i U.S. ENERGY RESEARCH AND DEVELOPMENT h ADMINISTRATION ;L
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PROJECT MANAGENENT CORPORATION and .
) I TENNESSEE VALLEY AUTHORITY )
AFFIDAVIT OF R. JULIAN PRESTON, Ph.D.
R. Julian Preston, Ph.D. , being duly sworn, deposes and says as follows:
l.
That he is employed as Senior Research Scientist, Biology Division, Oak Ridge National Laboratory, and that he is duly authorized to execute the response on behalf of the Applicants to the NRDC's '
March 18. 1982, Interrogatory II, Contention 8. Item 1.
- 2. That the above-mentioned and attached response to NRDC's Interrogatory is true and correct to the best of his knowledge and belief. .
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R. Jultin Preston, Ph.D. .
SUBSCRIBE and SWORN to before me this J/ . ay of March,1982.
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_ 2Ab /2)MM-Notary Public My Commitsior. Epiecs /.;;if 23,1984
d 7 UNITED $1ATES OF AMERICA NJCLEAR REGULATORY COMMISSION In the matter of -
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Department of Energy ,)
DOCKET NO. 50-537 PROJECT MANAGC> LENT CURPORATION and,)
TENNESSEL VALLEY AUTHORITY ,)
Aff1 DAVIT OF Michnet Lawrence, being duty swurn, deposes and says as follows:
1 That he is employed as Acting Director, Office of Nuclear Fuct Cycle, U.S. Department of Energy, and that he is duty authorised to answer interrogatories numbered 1.1a,1.1b a
in the Sixteenth set.
- 2. That the above-mentioned and attached answers are true and correct to the best of his knowledge end belief.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION r
)
In the Matter of )
)
UNITED STATES DEPARTMENT OF ENERGY )
)
PROJECT MANAGEMENT CORPORATION ) Docket No. 50-537
)
TENNESSEE VALLEY AUTHORITY )
)
(Clinch River Breeder Reactor Plant) )
)
CERTIFICATE OF SERVICE l
Service has been effected on this date by personal l delivery or first-class mail to the following:
- Marshall E. Miller , Esquire Chairman Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission i Washington, D. C. 20545 Dr. Cadet H. Hand, Jr.
Director l
Bodega ~ Marine Laboratory {
University of California P. O. Box 247 J Bodega Bay, California 94923
- Mr. Gustave A. Linenberger Atomic Safety & Licensing Board U. S. Nuclear Regulatory Commission Washington, D. C. 20545
- Daniel Swanson, Esquire
- Stuart Treby, Esquire Office of Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C. 20545 (2 copies)
E~ . _ _ _ _ _ _ _ _ _
-2.
- Atomic Safety & Licensing Appeal Board U. S. Nuclear Regulatory Commission Washington, D. C. 20545
- Atomic Safety & Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D. C. 20545
- Docketing & Service Section Office of the Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20545 (3 copies)
William M. Leech, Jr., Attorney General William B. Hubbard, Chief Deputy Attorney General Lee Breckenridge, Assistant Attorney General State of Tennessee Office of the Attorney General 450 James Robertson Parkway Nashville, Tennessee 37219 Oak Ridge Public Library Civic Center Oak Ridge, Tennessee 37820 Herbert S. Sanger, Jr., Esquire Lewis E. Wallace, Esquire W. Walter LaReche, Esquire James F. Burger, Esquire Edward J. Vigluicci, Esquire Office of the General Counsel Tennessee Valley Authority 400 Commerce Avenue Knoxville, Tennessee 37902 (2 copies)
- Dr. Thomas Cochran Barbara A. Finamore, Esquire Natural Resources Defense Council 1725 Eye Street, N. W., Suite 600 Washington, D. C. 20006 (2 copies)
Mr. Joe H. Walker 401 Roane Street Harriman, Tennessee 37748 Ellyn R. Weiss Harmon & Weiss 1725 Eye Street, N. W., Suite 506 Washington, D. C. 20006
I 3-Lawson McGhee Public Library 500 West Church Street Krioxville, Tennessee 37902 William E. Lantrip, Esq.
Attorney for the City of Oak Ridge Municipal Building P. O. Box 1 Oak Ridge, Tennessee 37830 Leon Silverstrom, Esq.
Warren E. Bergholz, Jr., Esq.
U. S. Department of Energy 1000 Independence Ave., S. W.
Room 6-B-256, Forrestal Building Washington, D. C. 20585 (2 copies)
- Eldon V. C. Greenberg Tuttle & Taylor 1901 L Street, N. W., Suite 805 Washington, D. C. 20036 Commissioner James Cotham Tennessee Department of Economic and Community Development Andrew Jackson Building, Suite 1007 Nashville, Tennessee 37219 p
fWW' i ///
Geo4e L. p hr Attorney mr y
Proj ect Management Corporation DATED: April 1, 1982
- / Denotes hand delivery to 1717 "H" Street, N.W., Washington, D. C.
- / Denotes hand delivery to indicated address.
- /' Denotes hand delivery to 4350 East-West Highway, Bethesda, Md.
.