ML20052E515
| ML20052E515 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 05/07/1982 |
| From: | Johnson G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20052E507 | List: |
| References | |
| NUDOCS 8205110184 | |
| Download: ML20052E515 (18) | |
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5/7/82 i
UNITED STATFS OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of-
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Docket Nos. 50-413 50-414 1
(Catawba Nuclear Station, Units 1 and 2)
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NRC STAFF RESPONSE TO APPLICANTS' RENEWED MOTION FOR CERTIFICATION, AND TO PALMETTO ALLIANCE MOTION TO REQUIRE STAFF ANSWERS TO INTERROGATORIES I.
INTRODUCTION The NRC Staff has recently received five motions or pleadings related to certification to the Appeal Board of Licensing Board rulings admitting non-specific contentions and to discovery directed, in large part, to those admitted contentions. These pleadings are: " Applicants' Renewed Motion for Certification", dated April 26,1982 (Applicants' Motion), " Palmetto Alliance Motion to Require Staff Answers to Interrogatories," dated April 20,1982 (Palmetto Alliance Motion),
" Palmetto Alliance First Set of Interrogatories and Requests to Produce",
dated April 20, 1982 and directed to both Applicant and the NRC Staff, l
(Palmetto First Interrogatories), " Applicants' First Set of Interrogatories to Palmetto Alliance and Requests to Produce", dated April 9, 1982 (Applicants' First Interrogatories), and " Applicants' First Set of Interrogatories to Carolina Environmental Study Group and Requests to Produce", dated hpril 9, 1982. Given the interrelationship between l
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8205110184 820507 PDR ADOCK 05000413 G
Applicants' Motion and Palmetto Alliance's Motion, and between the discovery requests and these motions--particularly, the way in which the Licensing Board's admission of generally worded contentions has led Palmetto Alliance to frame overly broad discovery requests, and led Applicants to pose extensive interrogatories of their own, the Staff herewith responds to both Applicants' and Palmetto Alliance's motions together.
Applicants have requested the Licensing Board to immediately certify six specified rulings in its March 5, 1982 Memorandum and Order previously addressed in " Applicants' Motion for Reconsideration or in the Alternative for Certification," dated March 31, 1982 (Applicants' March 31, 1982 Motion), without having the Board reconsider its rulings based on objections thereto raised by the Applicants and the Staff.E Applicants also requested the Board to suspend or stay discovery pending resolution of the certification questions (Applicants' Motion, at 4 and n.5).
This motion was prompted by the Board's April 13, 1982 Order in which it indicated, inter alia, that it would not rule on the parties' reconsideration or certification requests until late May or early June.
In its discovery motion, Palmetto Alliance requests the Board, in the event the Staff does not voluntarily respond to Palmetto Alliance's first interrogatories, to direct the Staff to answer "on the grounds that
-1/
For the sake of brevity, these rulings / issues may b'e summarized as (1) admission of vague contentions subject to later specification following availability of pertinent Staff and Applicant documents, (2) admissi6n of vague contentions subject to specification through discovery, (3) waiver of late-filing requirements for contentions revised following provision of such information, (4) granting access to the Catawba security plan without a specific contention, (5) admission of financial qualification issues, and (6) service upon Intervenors of all pertinent Staff-Applicant correspondence.
answers to these interrogatories are necessary to a proper decision in this proceeding and that, in some part not now fully known to Intervenor, answers to the interrogatories are not reasonably obtainable from any other source." (Palmetto Alliance Motion at 1).
Palmetto Alliance also requests the Board to " direct or ' urge'" the Staff to provide various forms of assistance in the preparation of its case, including lending documents and transcripts or providing extra copies, and establishing an additional public document room for the convenience of Palmetto Alliance.
Palmetto Alliance bases its request on its limited financial resources.
Id_. at 1-2.
Finally, both Palmetto Alliance and Applicants have responded to the directions of the Licensing Board's March 5,1982 Order to complete discovery on Palmetto Alliance contentions 6, 7, 18, 25,2_/ and Carolina Environmental Study Group [CESG] contentions 13 and 17 -- contentions which were admitted subject to specification after completion of discovery -- no later than June 3, 1982, by serving extensive interrogatories and related document requests.
Palmetto Alliance's interrogatories, not suprisingly, are at least as broad as the generally worded contentions to which they relate, and seek
-2/
Palmetto Alliance Contention 25 deals with financial qualification issues, which are now barred by Commission regulation, and reversal or certification has been requested by the Staff and Applicants based on this ground.
See, e.g., "NRC Staff's Response to Applicants' Motion for Certification of Certain Rulings in Licensing Board's Pre-hearing Conference Order," dated April 20, 1982, at 13-16.
No discovery has been served on this contention to date, although, if served, the' arguments set out herein would certainly apply as well to discovery on this contention.
information and legal positions which in numerous instances have no readily definable limits. Applicants' discovery served on both Palmetto Alliance and CESG, while specific, is understandably co-extensive with the breadth of Intervenors' contentions.
These discovery requests confirm the Staff's view that the Licensing Board's admission of general, non-specific statements as contentions, to be made specific after discovery, was erroneous. Therefore, the Staff urges prampt action by the Board, particularly on its rulings on the required specificity for admissible contentions, either to reverse its rulings, or to certify those rulings to the Appeal Board. The Staff also believes suspension or stay of discovery on Palmetto Alliance contentions 6, 7,18, and CESG 13 and 17 pending either reversal by the Board or resolution of the pertinent certification questions by the Appeal Board is appropriate.
Further, it would be inappropriate for the Licensing Board to direct the Staff to answer Palmetto Alliance's first interrogatories since Palmetto Alliance has made no showing that " answers to the inter-rogatories are necessary to a proper decision in the proceeding and that answers to the interrogatories are not reasonably obtainable" from Appli-cants, public documents and other sources.
10 CFR Section 2.720(h)(2)(ii).
Similarly, Palmetto Alliance's related document requests fail to meet the threshold requirements of 10 CFR Section 2.744.
Finally, Palmetto Alliance's request for assistance must be denied as contrary to law.
II. DISCUSSION
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A.
The Scope of Pending Discovery Demonstrates the Need for Prompt Reversal or Certification of the Board's Rulings Admitting Vague Contentions The extensive discovery requests recently served by Applicants and Palmetto Alliance are illustrative of the complications introduced into this proceeding by the admission of general, non-specific statements as contentions, to be made specific only af ter discovery. These discovery requests also show the wisdom of long-standing Commission practices requiring that contentions be reasonably specific prior to their admission and that discovery be limited only to those matters so placed in controversy.
10 CFR Sections 2.714(b), 2.740(b)(1);
Northern States Power Co. (Prairie Island Nuclear Generating Plant, Units 1 & 2), ALAB-107, 6 AEC 188, affirmed, CLI-73-12, 6 AEC 241, aff'd sub nom., BPI v. AEC, 502 F.2d 424 (D.C. Cir.,1974). Applicants' discovery, as predicted in Applicants' March 31, 1982 Motion, at 40, seeks to produce the specificity lacking in the Palmetto Alliance and l
CESG contentions.
In turn, Palmetto Alliance has used its vague contentions as a basis to undertake a wide-ranging search for 1
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information without any clearly defined purpose or limitations.E The unnecessary breadth and burden of this discovery is one of the bases put forward by the Staff as grounds for certification of the Board's specific rulings in "NRC Staff's Response to Applicants' Hotion for Certification of Certain Rulings in Licensing Baord's Prehearing Conference Order", dated April 20, 1982, at 7.
The fact that the pre-dicted consequences are about to occur confirms the Staff's view that reversal or certification is warranted.
Applicants have requested immediate certification of the Licensing Board rulings to the Appeal Board, on the grounds that such certification is within the Licensing Board's discretion under 10 CFR Section
-3/
Palmetto Alliance's Interrogatory 13, addressing its Contention 7, illustrates the breadth and burden of this discovery:
13.
For each activity under license by NRC or AEC conducted by Duke Power Company or its contractors and subcontractors involving any nuclear facility or operation, including but not limited to Catawba, identify each deficiency, as defined in 10 C.F.R. Section 50.55(e), which represents a significant breakdown in any portion of the Quality Assurance program conducted in accordance with the requirements of Appendix B to 10 C.F.R. Part 50; identify the Appendix B criteria to which it relates; describe in detail the respects in which the deficiency reflects a noncomplit.nce with the requirements of Appendix B criteria; the 10 C.F.R. Part 50 Appendix A General Design Criteria to which each relates, if any and the respects in which it reflects noncompliance; the report number and date, if any; the names, titles, addresses and telephone numbers of each person responsible for the deficiency, its discovery, its reporting, ar.d its corrective action; a detailed description of the deficiency and its safety implication; a detailed description of its corrective action.
2.751a(d), and that the articulation of the Licensing Board's reasoning i
in its March 5,1982 Order would provide the Appeal Board with an adequate basis for review. Applicants' Motion at 6, n.6.
Although the Staff would agree with each of these arguments, it does not necessarily agree with the conclusion Applicants have reached.
The Appeal Board has exhibited reluctance to accept certification where it appears that a Licensing Board decision on the matter for which certification is sought could obviate the need for immediate appellate review.
See Toledo Edison Co. (Davis-Besse Nuclear Power Station),
ALAB-297, 2 NRC 727, 728-29 (1975). Thus, despite the clear articulation of the Licensing Board's position on the admission of vague contentions in its March 5,1982 Order, it is nevertheless true that appellate review could be obviated were the Licensing Board on reconsideration to reverse itsel f.
Moreover, the Licensing Board has indicated it will rule in late May or early June. Thus, it would seem unlikely even in the event of immediate certification to the Appeal Board that an Appeal Board ruling would come before the Licensing Board could act on reconsideration.
Even in the event that reversal upon reconsideration is not forthcoming, the Licensing Board could still certify the rulings to the Appeal Board at that time -- a delay of only several weeks. Therefore, unless the Licensing Board is now convinced that it will not reverse itself, the Staff believes the better course is for the Licensing Board to reconsider its rulings in the first instance.
B.
Suspension, or Alternatively a Stay, of Discovery on Palmetto Alliance Contentions 6, 7, 18, and CESG Contentions 13 and 17 is Warranted Pending Resc,lution of the Board's Specificity Rulings 1.
The Extensive Discovery Made Necessary by the Admission of Unacceptably Vague Contentions is Burdensome and May Prove Unnecessary The Staff urges the Licensing Board to suspend the conduct of discovery on Palmetto Alliance contentions 6, 7 and 18 and CESG contentions 13, and 17, pending reconsideration of the Board's speci-ficity rulings, or pending resolution of these issues by the Appeal Board, should the Licensing Board sustain its prior rulings, and/or certify its rulings to the Appeal Board.
Suspension of discovery would obviate, at least temporarily, the substantial burden on Staff, Appli-cants, and Palmetto Alliance of answering numerous detailed interroga-tories and attendant document requests in circumstances in which there is considerable likelihood that such answers will prove to be unnecessary.Al Further, given the possibilities for objection to the discovery as served, the Board is likely to become embroiled in discovery controversies which may otherwisebeavoided.EI
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The Staff also notes that CESG would be similarly temporarily relieved from answering the discovery request directed to it by Applicants.
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The numerous objections and request for a protective order against Applicants' discovery contained in " Palmetto Alliance Responses to Applicants' First Set of Interrogatories and Requests to Produce",
dated April 28, 1982, illustrate this point.
r The presiding officer, pursuant to 10 CFR Section 2.718 and the Commission's Statement of Policy in Conduct of Licensing Proceedings, CLI-81-8, 13 NRC 452, 455-456 (1981), has both the authority and responsibility to manage and supervise discovery in a manner which avoids unnecessarily numerous or burdensome interrogatories or which is likely to delay, rather than expedite, the hearing process. Suspension of this discovery would prevent unnecessary diversion of both party and Board resources and thus would be an entirely justifiable exercise of the Board's discretion to regulate the proceedings before it.
In the event the Licensing Board sustains its earlier rulings and/or certifies its rulings to the Appeal Board, the Staff believes a stay of discovery on 0.he vague contentions pending Appeal Board review on certifi-cation is warranted. The Staff agrees with Applicants that, although denial of a stay of discovery would not cause irreparable injury, the weight of the factors considered in an application for a stay pending appeal, under 10 CFR Section 2.788, favors a stay of this discovery.E Both the Applicants' March 31, 1982 Motion and "NRC Staff's Objections to Licensing Board's March 5,1982 Order on Admission of Contentions" make a strong showing that discovery is not available for the purpose of framing adequately specific contentions.
Further, a delay would not substantially harm Intervenors, and, as noted in our reference to the Commission's Statement of policy, above, the public interest in 6/
See Applicants' Motion, at 4, n.5.
eliminating unnecessary litigation and expense favors a stay in these circumstances.
Thus, in the unique circumstances of this case, a short delay in the conduct of this discovery may in the long run be more in keeping with the Commission's Statement of Policy than proceeding with ill-defined discovery basedonill-definedcontentions.1/ Going forward prior to resolution of underlying specificity objections to the Board's March 5,1982 Order will inevitably lead to delay far beyond the intended deadlines for conclusion of this discovery.
The Staff believes these reasons alone would suffice to justify suspension of discovery pending reconsideration, or alternatively, a stay pending resolution of an appeal. However there are additional reasons, as discussed below.
2.
A Short Delay in Discovery Would Not Affect the Prehearing Schedule as Affected by Delays in Issuance of Staff Reports An additional practical reason for advocating suspension of this discovery is the change in the Staff's schedule for issuing its review Z/
The Commission there stated:
"The purpose of discovery is to expedite hearings by the disclosure of information in the possession of the parties which is relevant to the subject matter involved in the proceeding so that issues may be narrowed, stipulated, or eliminated and so that evidence to be presented at hearing can be stipulated or otherwise limited to that which is relevant.
The Conunission is concerned that the number of interrogatories served in some cases may place an undue burden on the parties, particularly the NRC Staff, and may, as a consequence, delay the start of the hearing without reducing the scope or length of the-hearing.
documents. By memorandum of April 20, 1982, from R.L. Tedesco, Assistant Director for Licensing, Division of Licensing, to various division directors, the Staff proposed to defer issuance dates for the Draft Environmental Statement from May 1982 to August 1982, and for the Safety Evaluation Report from August 1982 to February 1983. These and other changes noted in the attached memorandum were proposed, in part, as a result of a six-month slippage in Applicants' construction completion date recommended for use by the Staff in a March 26, 1982 letter from Duke Power Company (see attachment), and, in part, because the Staff is awaiting answers to questions posed by the Staff to Applicants. The Staff has, in fact, now determined that it is necessary to delay issuance of the DES until August 1982, and of the SER until February 1983. The 1
Applicant's construction completion date is now projected to be February 1984.
Since it is likely that delays of from three to six months in issuance of Staff analyses will delay the start of the hearing in this proceeding, a short delay in discovery on the contentions involved here will not have a significant impact on the commencement of the hearing.8/
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While noting the likely impact of the resolution of the certification questions on the Board's schedule for filing revised contentions, to the extent the Board ultimately adheres to its schedule for filing revised contentions 30 days after the relevant Staff document becomes available, the three month delay for the Draft Environmental Statement indicates that any discovery which might finally be required on the subject contentions could be completed prior issuance of such documents.
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In sum, suspension of discovery on Palmetto contentions 6, 7 and 18 and CESG contentions 13 and 17 pending reconsideration of the specificity objections raised by the Staff and Applicants, or stay of such discovery pending an Appeal Board ruling on certification, would prevent unwarranted diversion of party resources to unreasonably broad and burdensome discovery, avoid inevitably protracted disputes over the propriety and scope of such discovery and the consequent involvement of the Board and potential for delay to these proceedings, and would not have any significant impact on the timely completion of the prehearing schedule.
C.
Palmetto Alliance's Request for Board-Directed Discovery Against The Staff Is Improper Under 10 C.F.R. Section 2.720(h)(2)(ii) and 2.744 The Staff's opposition to being required to answer the numerous interrogatories and document requests Palmetto Alliance has directed to it will inevitably involve the Board in deciding additional discovery matters.
As noted above, Palmetto Alliance has moved to require the Staff to answer Palmetto First Interrogatories.9/ The Staff believes that a direction to the Staff to to provide responses to Palmetto First Interrogatories is inappropriate because Palmetto Alliance has failed to demonstrate that answers to these interrogatories are either necessary to a proper decision in this proceeding or are not reasonably available from other sources.
10 C.F.R. Section 2.720(h)(2)(ii).
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The Staff views this motion as a filing with the presiding officer pursuant to-10 CFR Section 2.720(h)(2)(ii) insofar as it seeks to require Staff answers to its interrogatories.
In support of its motion, Palmetto Alliance provides no basis for its assertion that answers to these interrogatories are necessary to a proper decision, and states only that "in some part not now fully known to Intervenor, answers are not reasonably obtainable from any other source." Palmetto Motion at 1.
Service of the identical interrogatories upon Applicants seems to belie this argument. The answers to at least 37 of Palmetto First Interrogatories may be supplied either by Applicants or by information available in the NRC Public Document Room.1S/ Moreover, were the Palmetto Alliance contentions adequately specific, as required by the regulations, virtually all of Palmetto First Interrogatories would be objectionable as not seeking relevant information, with many of these being subject to further objections as overly broad, unduly burdensome, vague, calling for legal conclusions, and not reasonably calculated to lead to admissible evidence. Twenty-one of Palmetto's interrogatories
---10/ These Interrogatories are:
(Contention 6:
Interrogatories 12,13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25), (Contention 7:
Interrogatories 6,7,8,11,12,13,14,15,16,17),
(Contention 18:
Interrogatories 6, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18); (Contention 43:
Interrogatory 3). Numerous additional interrogatories ask for Staff positions which will become available publicly with the publication of the Staff's environmental statement and safety evaluation report and may not be finalized before then.
are objectionable in whole or part on relevancy grounds even based on thegenerally-wordednon-specficcontentionsadmitted.E/
In short, it is the Staff's view that most, if not all, of the interrogatories directed to the Staff in Palmetto First Interrogatories are objectionable.
In any event, Palmetto Alliance has not demonstrated that Staff responses to the interrogatories are necessary to a proper decision or that the information is not or will not become available from another source so that requiring Staff responses is appropriate pursuant to 10 C.F.R. % 2.720(h)(2),
The Staff also notes that Palmetto First Interrogatories include an incidental request for production of those documents which may be identified in Staff answers to the interrogatories. While a party need not apply to the Board for an order directing production of Staff documents, Palmetto Alliance appears to have done so. However, this action is both premature and unwarranted under Commission Rules of Practice. Under those rules, a document request to the Staff must (1) be for documents not available under 10 C.F.R. Section 2.790 (i.e., not in the Public Document Room), (2) " set forth the records or documents requested, either by individual item or by category, and describe each item or category with reasonable particularity" and (3) state why that record or document is relevant to the proceeding." E l This, Palmetto
-11/ These interrogatories are:
(Contention 6:
Interro'gatories 1, 2, 4, 5, 6, 7, 11, 13, 14, 15, 23); (Contention 7:
Interrogatories 16, 17, 18); (Contention 18:
Interrogatories 7,9,10,11,19,20);
(Contention ~43:
Interrogatory 7).
-12/ 10 C.F.R. Section 2.744(a); Pennsylvania Power and Light Company (Susquehanna Steam Electric Station, Units 1 and 2), ALAB-613, 12 NRC 317, 323 (1980).
Alliance has clearly failed to do. No attempt is made to identify documents at all, much less to describe them with particularity; this is left to the Staff in response to the interrogatories.
There has been no indication as to why any documents are relevant to the proceeding.
Moreover, Palmetto Alliance has not attempted to differentiate documents which may be in the Public Document Room from any other documents within its request. As noted by the Appeal Board in Susquehanna, id. at 323:
With limited exceptions, Commission regulations make Staff documents that are relevant to licensing proceedings routinely available in the NRC Public Document Room, 10 C.F.R. 2.790(a).
The contemplation is that these "should reasonably disclose the basis for the Staff's position," thereby reducing any need for formal discovery.
Absent a proper request for documents, the Staff is under no obligation to address specific objections pursuant to 10 C.F.R. Section 2.744(b),
and the Board is not required to make specific findings as to the proprietyofthedocumentrequest.E
-13/ A document need not be produced over the Staff's objection unless the document is shown to be relevant, not exempt, or if exempt, that its disclosure is necessary to a proper decision in the proceeding, and not reasonably obtainable from another source.
10 C.F.R. Section 2.744(d). The Staff reserves its right to offer more specific objections and assertions of privilege to both Palmetto Alliance's interrogatories and document requests and to seek a protective order if, in fact, the Licensing Board determines, pursuant to 10 C.F.R. 5 2.720(h)(2)(ii), that Staff responses to this Palmetto Alliance discovery should be provided.
D.
Assistance to Intervenors is Limited by the NRC Appropriation Act for FY 1982 While the Staff appreciates that Palmetto Alliance may have limited financial resources, and recently supported service of all Staff-Applicant correspondence upon Intervenors in the interest of procedural fairness (see Staff Response of April 20, 1982, at 16 et_ seq.), the type of assistance Palmetto Alliance has requested, particularly provision of free copies of transcripts and establishment of a special public document room designed primarily to service Intervenors, in the Staff's' view is clearly contrary to Section 502 of the Energy and Water Development Appropriation Act for FY 1982, P.L. 97-88. This provision prohibits use of appropriated funds "to pay the expenses of, or otherwise compensate, parties intervening in regulatory or adjudicatory proceedings...."
It would also be contrary to the Comptroller General legal opinion (No. B-200585) of December 3,1980, stating that a similar provision, Section 502 of the Energy and Water Development Appropriation Act for FY 1981, P.L.96-367, prohibits the NRC from paying for " litigation expenses that would inevitably have been paid by the non applicant party."
46 Fed. Reg. 13681 (February 24,1981).
Neither the Staff nor the Board is authorized to provide this type of assistance. See, Staff Response, at 16-19. The Appeal Board decision in Susquehanna, ALAB-613, 12 NRC at 336, relied upon by Intervenors, preceded the Appropriation Act prohibition against use of appropriated funds to pay the expenses or otherwise compensate intervenors, and in any case would not control an Act of Congress on the same matter.
In any event, the Appeal Board in Susquehanna did not pass on the legality of the establishment of a special public document room to serve specific intervenors or of the
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Staff's actions in that case of voluntarily lending extra copies of transcripts to intervenors, but merely recounted such actions to counter intervenors' claims that they hcd been inappropriately denied access to information. ALAB-613, 12 NRC at 336-337. Clearly, Susquehanna does not establish that the " assistance" from the Staff that Palmetto Alliance here seeks is either necessary or appropriate.
Consequently, the Board must deny Palmetto Alliance's request for direction to the Staff to providesuchassistance.b III. CONCLUSION In summary, the wide-ranging and unnecessary discovery recently served by both Palmetto Alliance and Applicants confirms the Staff's view that prompt reversal or certification to the Appeal Board of the Licensing Board rulings admitting non-specific contentions is warranted.
Moreover, Palmetto Alliance's discovery against the Staff does not meet the requirements of 10 C.F.R. Sections 2.720(h)(2)(ii) and 2.744, particularily insofar as Palmetto Alliance has made no showing that the
-14/ The Staff acknowledges that the Licensing Board, in Carolina Power and Light Company (Shearon Harris Nuclear Power Plant, Units 1 and 2), Order, March 16,1982 (Slip Op. at 2-3), arranged with the assistance of the Local Public Document Room Branch, for the Public Library in Chapel Hill, North Carolina, to receive and update the application, FSAR and ER in that proceeding.
(A Public Document Room already exists in the Wake County Public Library, in Raleigh, North Carolina). However, the Staff does not consider this facility to be a Local Public Document Room, as such. Moreover, the Shearon Harris Board noted in an Order, dated April 2,1982 that a " full-fledged Public Document Room" had not been established by the Beard's earlier order.
Thus, Shearon Harris is not precedent for directing the establishment of such an additional complete facility, with the attendant expense, as requested by Palmetto Alliance in this proceeding.
In any event, Palmetto Alliance in the Catawba proceeding simply has shown no basis for establishing an extra local Public Document Room solely for their convenience.
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Finally,- the' Board mus't deny Palmetto Alliance's request for
't l3 difections to the Staff to @ rov.Ne special assistance to Palmetto s
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Al,Tfan:e in the development of its' case as such special assistance is s
. prohib'ited by law.
-s 1
g Respe tfully submitted, a
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s George E.' Johnson Counsel for NRC Staff s.
Dated at Bethesda, Maryland this 7th day of May, 1982.
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