Text

Response to Coalition on Safe Power 820524 Revised Contentions.Supports Admission Only of Revised Contentions 1,2,3,4.A-E,29.B,29.G,29.H & 29.I.Certificate of Svc Encl
	ML20054F700
Person / Time
Site:	Skagit
Issue date:	06/11/1982
From:	Black R; NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	; Atomic Safety and Licensing Board Panel
References
	NUDOCS 8206170231
	Download: ML20054F700 (38)
	v • d • e

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r-06/11/82 UNITED STATES OF AMERICA NUCLEAR REGULATORY COP 911SSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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PUGET SOUND POWER & LIGHT Docket Nos. STN 50-522 c

COMPANY, ET AL.

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STN 50-523

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(Skagit/Hanford Nuclear Power Project, Units 1 and 2)

NRC STAFF RESPONSE TO REVISED CONTENTIONS OF C0ALITION FOR SAFE POWER I.

INTRODUCTION On May 24, 1982, the Coalition for Safe Power (CSP) served its revised contentions on the Board and the parties pursuant to the Board's instructions at the special prehearing conference of May 5,1962 (Tr.73).1/ These contentions revise or clarify the contentions submitted by CSP in a supplement to its petition for leave to intervene filed on April 20, 1982, pursuant to 10 C.F.R. 5 2.714(b). All of the origir a1 contentions were objected to by both Staff (Tr. 67) and Applicant (Tr. 68; Applicant's Answer to Supplemental Petitions to Intervene and Motion for Extension of Time, dated May 4, 1982) because

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The Licensing Board has determined that CSP should be allowed to intervene in this proceeding based on the allegations of interest set forth in its petition for leave to intervene dated March"6, 1982. Memorandum and Order, dated April 5,1982 OM p1G58 So]

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. they were lacking basis or specificity as required by 10 C.F.R. 9 2.714(b).2/ The Staff's response to CSP's revised contentions, which replace all of the original contentions, will be set forth below.

II. DISCUSSION ON CONTENTIONS t

Revised Contentions 1-3 (Need for Power) of 1.

Petitioner contends that Applicant will not need the power generated by the Skagit/Hanford Nuclear Project, Units 1 and 2, to serve their own loads or the loads of the region as claimed in the Application for Site Certification / Environmental Report (ASC/ER).

2.

Petitioner contends that any decision on the need for the S/HNP must await the regional forecast to be issued by the Northwest Power Planning Council in April 1983.

3.

Petitioner contends that no weight should be given to Applicant's projected load forecast as outlined in ASC/ER Section 1.1 and Table 1.1.

1 The NRC Staff has no objection to the admission of these contentions. However, to ensure consistency in discovery and evidentiary presentation, we submit that the Board should adopt the similar contention and bases as submitted by the Natural Resources Defense Council (Contentions 1-3) in its Supplement to Amended Petition, dated April 20, 1982. Further, pursuant to 10 C.F.R. 5 2.715a, NRDC, which first raised this matter in this proceeding, should be designated the " lead intervenor"

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The requirements for contentions have been discussed in the NRC Staff Response to Untimely Petitions to Intervene Filed By the Columbia River Inter-Tribal Fish Commission and the Yakima Indian Nation, dated May 25, 1982 (pp. 14-16), and need not be repeated here.

. on this issue for the presentation of evidence, conduct of cross-examination, and other procedural matters. See Statement of Policy on Conduct of NRC Proceedings, 13 NRC 452, 455 (1981).

Revised Contention 4 (Alternative Energy Sources)

Applicant has misapplied the National Environmental Policy Act (NEPA),

42 USC 4321 by rejecting the following alternatives which are available, environmentally preferable and more economical than the proposed Skagit/Hanford Nuclear Project: wind power, biomass, solar, conservation, co-generation, low-head hydro, ocean temperature differences and alcohnl fuels. Further, Applicant has followed a very narrow view of this Act by considering each alternative separately. Aoplicant must also be required to consider combinations of various appropriate technologies as alternatives to the proposed project.

The scope of the Commission's NEPA responsibilities in the context of the consideration of alternative energy sources has been delineated in federal as well as NRC case law. NEPA's " rule of reason" is the guide and it requires a "hard look" at alternatives. Natural Resources Defense Council, Inc. v. Morton, 458 F.2d 827, 834, 837-38 (D.C. Cir.

1972); Florida Power and Light Co. (Turkey Point Nuclear Generating Station, Unit Nos. 3 and 4), ALAB-660, 14 NRC 987, 1004-05 (1981).

Application of the rule "may well justify exclusion or but limited treatment of a suggested alternative." Public Service Co. of New l

Hampshire (Seabrook Station, Units 1 and 2), ALAB 422, 6 NRC 33,100 (1977). Finally, neither NEPA nor iny other statute gives the NRC the authority to reject an applicant's proposal solely because an alternative might prove less costly financially. Turkey Point, supra at 1007; Consumers Power Co. (Midland Plant, Units 1 and 2), ALAB-458, 7 NRC 155, 166-163 (1978).

If the Comission should find an environmentally pre-ferable alternative, then it must undertake a cost-benefit balancing to

. determine whether such an alternative should be implemented. Midland, supra.

In the contention, CSP has asserted that the Applicant has inade-quately considered seven (7) alternative energy sources which it contends are environmentally and economically preferrable to S/HNP.3_/ Further, it contends that the Applicant's analysis of alternative energy sources is defective because it does not consider combinations of the various alternative sources to replace the proposed facility. We will consider each of these seven alleged alternatives to determine whether the con-tention requirements of " basis and specificity" have been met in terms of a threshold showing of a reasonable environmentally preferable option.

a.

Wind Power. CSP contends that the Applicant (see ASC/ER, pp. 9.2-4 to 9.2-5) has underestimated the potential contribution of wind generation to regional resources.

It cites the Oregon Alternative Energy Development Commission's (AEDC) Final Report, Future Renewable, and a BPA statement to Congress (BPA letter to Chairman Dingell, 10/13/81) for the proposition that significant amounts of wind energy are available in the region. The Staff submits that these statements meet the requirements of basis and specificity of 10 C.F.R. 6 2.714(b). g.HoustonLightingand Power Co. (Allens Creek Nuclear Generating Station, Unit 1), ALAB-590, 3/

For purposes of the Staff response, the alternative energy sources of biomass and cogeneration which were advanced by CSP are considered together.

. 11 NRC 542 (1980) (the Appeal Board admitted a contention regarding biomass as an alternative when the petitioner referred to a DOE publication as a basis for the cantention). Accordingly, a contention regarding the viability of wind power as an alternative to S/HNP should be admitted as an issue in controversy.

t b.

Biomass-Cogenetation. CSP contends the Appliant has under-estimated the potential contribution of biomass-fired cogeneration in the region citing Future Renewable, p.15; Pocket Research Co., Industrial Electrical Cogeneration Potential in the BPA Service Area, p. 4-25; and a BPA(?) Phase Report issued on February 29, 1980, p. 9.

The Staff submits that a contention regarding biomass-fired cogeneration should be admitted as an issue in controversy.

c.

Solar. CSP contends that passive solar retrofits and new in-stallations should be considered environmentally and socio-economically preferable alternatives to S/HNP citing various State of Oregon and DOE publications. We submit that the requirements of basis and specificity have been met regarding a contention concerning the viability of passive solar retrofits and new installations as a cost-effective alternative to S/HNP and should be admitted as an issue in controversy.

d.

Conservation. CSP contends that conservation could provide 30 to 60 percent of the region's future electrical energy requirements.

It refers to various studies conducted over the past several years in the

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. region to examine the potential for energy conservation. This contention meets the applicable requirements for acceptance and should be admitted asanissueincontroversy.Sl e.

Low-Head Hydro. CSP contends that the Applicant's analysis of small-scale hydro projects set forth in ASC/ER Section 9.2.1.2.4 is in-adequate citing the Oregon AECD that this resource was " realistically achievable" for 410 MW in the State of Oregon. The Staff has no objection to the admission of this contention.

f.

Ocean Temperature Differences. Although CSP has advanced this resource as a viable alternative resource, it has supplied no basis or specificitytosupportit.El Accordingly, this contention regarding ocean temperature differences as an alternative to S/HNP should be

rejected, g.

Alcohol Fuels. Again, CSP has advanced this resource as a viable alternative to S/HNP, but has provided no basis or specificity to support it. Accordingly, it should be rejected.

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The issues of passive solar and conservation may be considered under the broader issue of "need for power" rather than distinct alternative energy sources since their application would reduce future energy demand requirements.

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The Staff believes that this resource is a distinctly different technology than geothermal which has been referred to in the contention's basis.

. RevisedContention5(AlternativeSites)

Petitioner contends that Applicant conducted the alternative site analysis required by 10 C.F.R. 50.20(a)(3) improperly in concluding that Hanford was the best site, As a basis for this contention, CSP basically alleges that the Applicant's alternative site analysis is inadequate because (1) it didn't give enough weight to the economic cost of wheeling the energy from the Hanford area to the major load centers west of the Cascades; and (2) it placed too much weight on the acceptability of the project by the local population in the Hanford area. The Staff submits that both of these assertions must be rejected. With respect to the economic cost (in terms of lost capacity and diminished reliability) of wheeling energy from Hanford to western Washington and Oregon load centers, it has been established that in an alternative site analysis economic co:,t comparisons are irrelevant unless an alternative site is shown to be environmentally superior. Rochester Gas & Electric Corp. (Sterling Power Project, Nuclear Unit No. 1), ALAB-522, 8 NRC 383, 395 n.25 (1978). E.PublicService Company of New Hampshire (Seabrook Station, Units 1 and 2), CLI-77-8, 5 NRC 583, 533-36 (1977) (where the Commission held that where no alternative site is "obviously superior," there is no need to consider an economic delay cost); Virginia Electric & Power Co. (North Anna Nuclear Power Station, Units 1 and 2), ALAB-584, 11 NRC 451, 456-58 (1980) (under NEPA, there is no need for Boards to consider economically better alter-natives which are not shown to also be environmentally preferable).

Since CSP has not alleged that any alternative site will be environmentally superior, a consideration of the economic cost of wheeling power from various sites in the region is irrelevant. Accordingly, this assertion must be rejected.

. CSP has ale.o contended that the alternative site analysis is flawed because it placed too much emphasis on the acceptability of the project by the local population in Hanford. However, CSP has provided no basis or specificity to support this assertion. The Applicant has noted that the factor of "An Experienced and Supportive Comunity" is only an e

additional reason (other than the environmental, geotechnical, and economical selection factors used in the Regional Siting Program) to prefer the Hanford Reservation.

See ASC/ER 9 9.3.3, pp. 9.3-12, 9.3-13.

For these reasons, this assertion must be rejected.

Revised Contentions 6 and 7 (Sabotage and Threats to Security) 6.

Petitioner contends that Applicant has failed to provide an assessment of the threat to national security posed by a major accident at the S/HNP which would decrease the government's ability to maintain adequate security on the Hanford Reservation and to continue defense-related activities.

10 C.F.R. 2.104(b)(1)(iv) and 10 C.F.R. 50.40(c) provide that a project must not be inimicable to the common defense and security.

7.

Petitioner contends that Applicant has not considered the effect of government actions on the Hanford Reservation in times of war on the S/HNP, as required by 10 C.F.R. 100.10 and 100.10(d).

Other than alleging that S/HNP will be sited in close proximity to DOE and other governmental installations on the Hanford Reservation, CSP has provided no basis or specificity to support a safety contention re-garding the interrelationship between S/HNP and DOE facilities in the event of an accident or war. Specifically, CSP has failed to allege how or why the Applicant's accident analysis (see ASC/ER Sec. 7.4) is defective with respect to other operations on the Hanford Reservation.

Nor has it been alleged how an accident at S/HNP would have any effect on other facilities in light of their radiological and other protective

measures.

In short, there is no basis, other than CSP's speculation, that an accident at S/HNP could have an effect on the safe operation and security of other Hanford facilities. Accordingly, Revised Contention 6 must be rejected.

Revised Contention 7 asserts that the Applicant has failed to assess t

the effect of war on the suitability of the site under 10 C.F.R.

i 6 100.10. However, the factors to be considered in the evaluation of a site under 10 C.F.R. 6 100.10 do not include the effects of war. CSP alludes to the fact that 10 C.F.R. 6 100.10(d) states that if

" unfavorable physical characteristics of the site exist," the design of the facility must include " appropriate and adequate compensating engineering features." In 10 C.F.R. 6 100.11(c), the " physical characteristics of the site" are defined as " seismology, meteorology, geology, and hydrology."

Inaddition,considerationofthe"[p]opulation density and use characteristics of the site environs" under 10 C.F.R. 6 100.11(b), does not include an evaluation of site environs because of its possible characteristic as a main target by an enemy in the event of war.5/ Accordingly, this contention represents a challenge to the Commission's regulations and is prohibited by 10 C.F.R. 6 2.758 except when waived by a showing of "special circumstances" as required by 10 C.F.R. 6 2.758(b). Therefore, this contention must be rejected.

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Furthermore, 10 C.F.R. 6 50.13 states that protective measures against sabotage and armed attacks need not be provided in the design of a facility.

. Revised Contentions 8-10 (Technical Ability of Applicant and Architect-Engineer) 8.

Applicant's architect / engineer, Bechtel Corporation it not technically qualified to engage in the proposed activities and lacks the willingness and desire to carry out a quality assurance program as required by Comission regulations.

9.

Petitioner contends that Applicant does not possess the technical ability to construct the proposed project. Neither does the Applicant have the willingness and the desire to adhere to NRC regulations. Thus, the Board has no basis to conclude that the Applicant meets the provisions of 10 C.F.R. 2.104(b)(1)ii) and that the project will be constructed in a safe manner.

10.

Petitioner contends that the work force and contractors relied upon by the Applicant for the construction cf the project (ASC/ER Section 8.3.7) are not capable of, and do not desire to, constructing the project's units in conformance with NRC regulations. [ sic]

These contentions basically assert that the Applicant, the Applicant's architect-engineer (Bechtel Corporation), and the construction contractors and work force are not qualified to and incapable of constructing S/HNP in conformance with the Comission's regulations. As bases for these contentions, CSP asserts that (1) the Applicant has never participated in a project of this size, (2) Bechtel l

Corporation has been responsible for numerous safety violations in its design and construction of other nuclear projects, and (3) the work force and contractors in the Hanfard area were responsible for numerous safety violations at WPPSS Nuclear Projects 1, 2, and 4.

The Staff submits that these assertions are not relevant to establish the inadequate technical qualifications of the Applicant or its contractors. The fact that an applicant does not have experience in constructing a nuclear plant is not a sufficient basis for challenging its technical qualifications. Northern Indiana Public Service Co.

(Bailly Generating Station, Nuclear-1), LBP-74-19, 7 AEC 557, 567-68

. (1974), aff'd ALAB-224, 8 AEC 244 (1974), rev'd Porter County Chapter v.

AEC, 515 F.2d 513 (7th Cir.1975), rev'd Northern Indiana Public Service Co.

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v. Porter County Chapter, 423 U.S. 12 (1975). Similarly, the design or construction experience of contractors at other projects is not relevant to whether it has the capability or ability to do these same functions at t

this facility under an entirely different QA/QC program. The Applicant's QA/QC program is crucial in determining and evaluating whether design and construction activities are performed in accordance with the Commission's requirements. Since CSP has not alleged any defects or inadequacies in the S/HNP QA/QC program, these contentions regarding technical qualifi-cations must be rejected for lack of basis and specificity.

Revised Contention 11 Petitioner contends that Oregon state law prohibits co-applicants Portland General Electric and Pacific Power and Light from participating in this project and thus any facts pertaining to these two utilities should be dismissed.

This contention asserts a legal matter which is outside the scope of the issues to be decided by the Licensing Board pursuant to the notice of hearing and applicable NRC regulations.

It is a matter to be determined under Oregon law in Oregon courts.

It is not subject to hearing before this Board.

Cf. Public Service Co. of New Hamphire (Seabrook Station, Units 1 and 2), CLI-77-8, 5 NRC 502, 546 (1977). Accordingly, this contention must be rejected.

Revised Contention 12 (Socio-economic Effects)

Petitioner contends that Applicant has not correctly weighed the socio-economic and other benefits required by 10 C.F.R. 51.20(b) and thus has overstated the benefits of the proposed p nject.

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,... The basic thrust and basis for this contention is that recent events in the region have changed the attitudes of the majority of the region's i.

nts regarding a perceived cho e.e between "possible electrical shortages and the costs of yet another nuclear facility...."

However, speculation regarding attitudes concerning nuclear power is t

insufficient to provide the requisite basis and specificity required for i

an admissible contention.

Particularly, these assertions do not specify in a concrete manner how the direct benefits of this project (i.e.,

electrical energy) are overstated. To the extent that the overall direct benefit of the project is overstated, it will be determined in the need for power analysis.

In addition, this contention does not specify how the indirect economic benefits to the local community from this project are overstated. For these reasons, this contention must be rejected.

Revised Contention 13 (NRC Staff Ability to Evaluate Project)

Petitioner contends that NRC Staff has not completed its review of the proposed project and that the current Safety Evaluation Report is inadequate and thus there exists no basis for the Board to make a determination on the application.

This contention asserts that the NRC Staff has not issued its final supplement to the Safety Evaluation Report (SER) and, therefore, the Board has no basis to make a determination regarding those items covered in that final review -- particularly issues related to the seismic design of the plant. This assertion is true in that the Staff has not completed its safety review of this project.

However, proceedings often commence before a final SER is itsued. Moreover, the contention does not assert a litigable issue because it does not allege any specific defect or inadequacy in the Staff's review or its ability to conduct the

-. _ _. review.E Any issue concerning the adequacy of the Staff's safety review as set forth in the final supplement to the SER, must necessarily await publi-cation of that document. Accordingly, this contention must be rejected for lack of basis and specificity, and also for being premature.

t Revised Contention 14-22 (Environmental Impacts of Construction and Operation) 14.

Petitioner contends that the Applicant has underestimated the environmental cost of the S/HNP in such a way as to change the cost-benefit balance required by NEPA and 10 C.F.R. 50.20 in favor of the project.

CSP has advanced several bases for this contention.

First, it alleges that the Applicant has underestimated the existing radiological burden in the area of the proposed site.

In essence, CSP alleges that the Applicant's analysis of the background radiological characteristics (ASC/ER 5 2.8) does not discuss the results of numerous studies conducted in the Hanford area regarding radiation levels in aquatic and terrestrial sources. Additionally, CSP alleges that ASC/ER 6 2.8 does not discuss the artificial radiation in the Columbia River sediment downstream of the plant.

The Staff believes that the studies and news articles referenced by CSF in support of this contention are insufficient to establish the requisite basis and specificity needed to frame a concrete litigable issue. 1Pe Applicant's analysis of background radiation levels y

An issue concerning the Staff's ability to conduct the review would be outside the scope of matters to be determined in this proceeding.

See'Comonwealth Edison Co. (Byron Nuclear Power Station, Units 1 and 2), LBP-80-30, 12 NRC 683, 690 (1980).

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a acknowledged the fact that:

The background radiation levels on the Hanford Reservation have been monitored routinely since the Federal Government initiated activities in the early 1940s. Tests have been conducted involving agriculture produce in adjacent areas, wildlife and plant life in the Reservation, Columbia River fish, and humans (both those associated with on-site Hanford Reservation activities and those living and r

working away from the Reservation). The results of these tests and measurements constitute an unusually large amount of cata which is available for review. ASC/ER Q 2.8, p. 2.8-1.

The Applicant's analysis then proceeded to evaluate background radiation levels in the areas of the atmosphere, Columbia River, foodstuffs, wildlife, and soil and vegetation. ASC/ER 6 2.8.

CSP has not alleged in any way how the Applicant's analysis is inadequate or how the references cited impact that analysis. We believe that basis and specificity are not provided by merely referencing documents and articles and asserting that they haven't been discussed when clearly much background information has been reviewed and assessed in the consideration of ambient radiation levels.

CSP also asserts that the Applicant has underestimated the cumulative effects of radiation of S/HNP and WPPSS 1, 2 and 4 which are nuclear projects cur.ently under construction on the Hanford Reservation.

The only basis asserted for this contention is that CSP has read the pertinent literature and believes that Applicant's analysis is inadequate. This assertion is clearly inadequate to provide the necessary basis and specificity. Similarly, CSP's statement that it

" believes" that the Applicant's conclusion regarding the primary and secondary impacts of a major accident is " entirely wrong" is without basis or specificity.

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. In summation, this contention must be rejected because CSP has supplied neither basis nor specificity to support it.

15.

Petitioner contends that Applicant incorrectly concludes that "none of the areas to be disturbed by the proposed project have significant value" thus understating the environmental cost in the analysis required by 10 C.F.R. 51.20(b).

f CSP contends that the Applicant has not shewn that construction in the proposed intake / discharge area will either (a) be limited to one acre, or (b) will not have a significant negative impact on the area.

CSP has alleged no facts to support its conclusion that construction of the intake / discharge cannot be limited to one acre, nor has it set forth facts to support its belief that biota in the area will be significantly impacted by these construction activities. Again, unfounded and unsup-ported " beliefs" will not provide foundation for an admissible contention and, accordingly, this contention must be rejected.

16.

Petitioner contends that Applicant has failed to show that there are adequate measures to ensure that damage to the environment and living organisms is minimized during construction, a position Applicant uses to meet the requirements of NEPA and 10 C.F.R. 51.20(a).

CSP basically contends that the environment cannot be protected during construction without a concrete plan to minimize impacts.

However, this contention completely ignores the Applicant's Construction Impact Control Program (CICP), set forth in ASC/ER Q 4.5, which will be implemented to ensure that good construction practices will be employed in order to limit adverse impacts on the environment. CSP has alleged no inadequacies in the CICP other than it has " reason to believe" that such

. practices will not be satisfactory.

In addition, CSP has not specified any sensitive biota or habitat in the area which require a special measure of care.8_/ Accordingly, this contention should be rejected because it is without basis and specificity.

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17. Petitioner contends that Applicant has failed to provide evidence that construction and operation of the Skagit/Hanford Project will not 3

irreparably harm rare, threatened and endangered species of vegetation namely Rorippa calycina var. columbiae, Astragaulus sclerocarpus and Cryptantha leucopaea as required for a finding of the environmental cost under NEPA and 10 C.F.R. 51.20(b).

CSP contends that. endangered and threatened species of vegetation have not been adequately quantified and it has not been demonstrated that they can be protected. To the contrary, the threatened species (Rorippa calycinaandcolumbiae)1/ havebeendescribed(ASC/ER,pg.4.1-8)andit has been concluded that construction activities might temporarily reduce the population but not threaten it.

(Id.) CSP has referenced no documents or provided any basis which indicate that the description and conclusion is inadequate.

In addition, CSP alleges the Oregon Swallowtail butterfly, a

" species of interest," depends on tarragon located around the Old Hanford Townsite and the Applicant has not indicated how it intends to protect the tarragon. However, this assertion fails to provide any basis or 1

specificity, particularly any facts to establish that tarragon will be

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The Applicant has indicated that none of the lost or displaced animal species is considered to be rare, threatened or endangered and that none of the converted acres has any ecological significance. ASC/ER, pg. 4.1-3.

See also S/HNP DEIS 5 4.2.14.

The Applicant has noted that decommissioning requirements or guidelines have not been formulated by the NRC and, therefore, a present evaluation of the final deconmissioning plan or technique chosen and the impacts thereof would amount to speculation.

-10/ For example, NEPA analyses should consider the reasonable and foreseeable cumulative effects of plarned construction projects in a given area on the local population.

See M. ASC/ER 58.3; S/HNP DEIS 5 4.2.6.

. In the absence of NRC guidelines and a final, approved decommissioning plan, consideration of environmental impacts would be futile, speculative and outside the " rule of reason" mandated by NEPA.

These decommissioning environmental impacts will be assessed when a final plan is approved and license termination is authorized pursuant to 10 C.F.R. 6 50.82. CSP has provided no basis or specificity to demonstrate that decomissioning impacts must be considered during this licensing action because it will tilt the cost-benefit balance in favor of rejection of the application. Accordingly, this contention must be denied.

Revised Contentions 23-24 (Irdustrial Facilities)

23. Petitioner contends that the Applicant has failed to conduct an assessment of the potential impact of surrounding nuclear and chemical facilities on the S/HNP and its ability to continue operation in the case of an event at these facilities and the consequences of loss of operability as required by 10 C.F.R. 100.10.

CSP basically asserts that Applicant hasn't adequately considered l

accidents at the Fast Flux Test Facility, the future hazardous waste dump, and the N-reactor and their impact on S/HNP. However, CSP has provided no basis for this contention. Section 2.2 of the S/HNP Preliminary Safety Analysis Report (PSAR) analyzes industrial, transportation, and military installations and operations (including nuclear facilities and operations) in the vicinity of the S/HNP, and the design for S/HNP accounts for the potential effects from those facilities and operations.

For example, the design of S/HNP accounts for protection i

against internal and external (eg. tornado) missiles 1/ which would l -

envelop consideration of missiles generated from an explosion at any of the nearby industrial facilities.

In addition, S/HNP provides control room protection against radiation from design basis accidents at the facility and these habitability systems E would also provide protection from radiation releases at more distant facilities. CSP has not alluded to or identified any deficiencies in these analyses or in the design of i

S/HNP. Consequently, this contention should be rejected for lack of specificity and basis.

24. Petitioner contends that the Applicant has failed to conduct an assessment of the potential impact of the S/HNP on nuclear facilities and activities located on the Hanford Reservation and the ability of these operations to continue in the event of a major accident at the S/HNP as required by 10 C.F.R. 51.20 and 10 C.F.R. 100.10.

The Applicant has analyzed the effects of a major accident at S/HNP.

See ASC/ER @ 7.4.

CSP has provided no basis for concluding that such an accident would affect the operation of other facilities on the Hanford Reservation or that the cost of cessation of continued operation of these facilities would be significant in relation to the other costs associated with a major accident which are described in the ASC/ER. Since CSP has l

not provided an adequate basis for requiring consideration of potential impacts upon operation of other facilities, this contention should be rejected.

11/ See Section 3.5 of the PSAR and Section 3.5 of the S/HNP Safety Naluation Report (SER), NUREG-0309.

a 12/ See Sections 6.4 of the PSAR and SER.

' Revised Contention 25 (Geology)

Petitioner contends that the present geology and seismic studies presented by Applicant in Section 2 of the PSAR are inadequate and do not meet the requirements of 10 C.F.R. 100 Apptadix A.

Applicant has not changed the seismic design of the project to reflect the local geology and seismology and thus the S/HNP is not properly designed to withstand the potential seismic events of the site.

t As basis for this contention, CSP has referenced NRC Staff Questions 231.1, 231.2, 231.3, and 220.10.I3/ These staff questions pertain to the Applicant's analysis of (a) linements within a five-mile radius of the site, (b) the Cold Creek syncline, (c) a report concerning structures and geophysical anomalies within the Pasco Basin (Rockwell Hanford Operations,1981, RH0-BWI-ST-14, Myers, C.W., and Price, S.M.), and (d) plant design foundation on 200 feet of sand rather than hard rock.

However, these initial Staff concerns have been responded to by the Applicant in PSAR Amendment 24, dated April 2, 1981. Accordingly, the underlying basis for this contention that the Applicant's geological analysis did not consider the above items has been mooted by the PSAR amendment. Since responses to the Staff questions have been provided, CSP must identify with particularity the deficiencies in those responses.

At this juncture, therefore, this contention is without basis and must be rejected.

-13/ CSP has refered to NRC Staff Question 220.10 to support a concern regarding the plant foundation on sand instead of rock. We believe, however, that this concern is reflected in Staff Question 241.1.

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Revised Contention 26 Petitioner contends that electrical equipment, other than that supplied by General Electric, will not be qualified to IEEE 344-1975 and Regulatory Guide 1.100, and thus the plant will not conform to current standards of safety and regulations.

This contention pertains to the environmental qualification of safety related electrical equipment. The NRC issued a proposed rule,

" Environmental Qualification of Electrical Equipment for Nuclear Power Plants," in the Federal Register on January 20,1982(47 Fed. Reg.2876) with the coment period to expire on March 22, 1982. The Commission will publish a final rule on this subject matter after consideration of the comments. By letter dated April 15, 1982 (Robert V. Meyers, Vice President, Puget Power to Harold R. Denton, Director, NRR), the Applicant committed to comply with the requirements of the final rule. Details of the electrical equipment qualification program will be described in the appropriate sections of the S/HNP FSAR.

Based on the Applicant's commitment to comply with the requirements of the final rule on the environmental qualification of electrical equipment, the basis for this contention no longer exists. Accordingly, the contention should be rejected.

Revised Contention 27 Petitioner contends that Applicant has not considered the takeover and completion of the terminated nuclear projects 4 and 5 of the Washington Public Power Supply System as an environmentally, economically preferable alternative to the proposed project as required under NEPA and 10 C.F.R. 51.20(a).

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. As discussed earlier in our response to Revised Contention 5, the economic preferability of an alternative site need not be considered under NEPA unless the site is established to be environmentally preferable. CSP has advanced no basis in this contention regarding whether the purchase and completion of WPPSS 4 and 5 is environmentally preferable to S/HNP.

In fact, CSP has asserted no basis for this f

contention other than the Applicant's response to NRC Staff Question 230.01 on this matter is " wholly inadequate." Without some environmental justification for the consideration of the purchase of the WPPSS units, l

the Commission's NEPA responsibilities do not require it to consider the alleged economic ramifications to rate payers or the utility of this alternative.

See eg. North Anna, supra. Accordingly, the contention must be rejected for lack of basis and specificity.

Revised Contention 28 (Emergency Planning)

Petitioner contends that Applicant has failed to meet the requirements of 10 C.F.R. 50 Appendix E (II) in not supplying the necessary information.

The alleged bases for this contention are defective because CSP has not considered the information contained in PSAR Appendix 13A as updated by Amendment 24 to PSAR, dated April 2, 1981.

In this amendment, information pertaining to contacts made with local, State and Federal agencies as required by 10 C.F.R. Part 50, Appendix E.II.B., is provided in PSAR Appendix 13 69 5.4, 7.3, 7.4 and Appendix A.

PSAR Appendix 13A 9 7.0 contains preliminary protective measures and procedures for each EPZ as required by 10 C.F.R. Part 50, Appendix E.II.C.

Onsite emergency first aid and decontamination facilities are described in PSAR Appendix

. 13A 9 7.5.1 as required by 10 C.F.R. Part 50, Appa dix E.II.D.

Compliance with 10 C.F.R. Part 50, Appendix E.II.G and H is documented also in PSAR Appendix 13A. See PSAR Appendix 13A, Table 4.

In short, it is apparent that CSP has not considered the most recent information contained in the PSAR with regard to emergency planning and failing that, this contention must be rejected for lack of basis.

In addition, CSP alleges that the Applicant has failed to consider the pro-nuclear attitudes of local residents and their disregard for exposure to radiation in its emergency planning procedures. This allegation must also be rejected because CSP has provided no basis for its speculation that local residents have a " disregard for exposure to radiation."

Revised Contention 29 Petitioner contends that the cost-benefit analysis performed by the Applicant is wholly falsified. This cost-benefit analysis does not represent an analysis " conducted fully and in good faith" (See Calvert Cliff Coordinating Committee v. U.S.A.E.C., D.C. Cir., 1971 at p.11). In doing so Applicant has wrongfully concluded that the proposed project benefits outweigh the cost, and that the proposed project is cheaper than other alternatives such as coal.

CSP has set forth several bases for ti.is contention. Our response will consider each in turn.

a. CSP alleges that the cost of S/HNP does not account for the cost of design changes due to TMI requirements and other required safety changes. This assertion must be rejected because it has no basis or specificity. For instance, the Staff has concluded that the Applicant has supplied sufficient information to show compliance with the

. TMI-related requirements that are relevant to the issuance of a construction permit. Sees /HNPSERSupplementNo.2,NUREG-0309(October 1981). CSP has not specifically alleged how these requirements have not been accounted for in the cost projections.

t

b. CSP alleges that the Applicant has overestimated the reliability d

of the proposed project by assigning a capacity factor of 70 percent when operating experience of BWRs shows a capacity factor of no more than 60 percent. The Staff submits that this contention meets the basis and specificity requirements and should be admitted as an issue in controversy.

1

c. CSP alleges that the Applicant has " underestimated the effects of low-level radiation emissions on the health of the population near the project and facilities related to the fuel cycle" because it did not

" include the chemical and radiation hazards of the zirconium cladding production [ facility]inAlbany,[0regon]." The Staff does not i

understand this contention.

It first refers to low-level radiation health effects and then discusses chemical hazards and emissions.

In any event, we believe this contention should be rejected for lack of specificity and basis because CSP has failed to specify with particularity why chemical emissions and nuclear waste from the Albany, Oregon facility (which is approximately 200 miles from the site) should be considered.

. d. CSP alleges that costs are underestimated for dewatering, erosion control and soil stabilization due to foundation excavation. This contention should be rejected for lack of basis and specificity.

Although the Applicant may have to excavate in order to provide a suitable foundation, CSP has not alleged with particularity why or how t

the above costs are not accounted for or may be a significant factor in f

the cost / benefit ratio.

e. CSP has alleged that the costs of nuclear waste disposal and storage are underestimated citing an increase in the cost of low-level waste burial at the U.S. Ecology site. However, this recent price increase does not establish the inadequacy of the Applicant's assumed escalation factor in its long-term projections of cost over the life of S/HNP. Accordingly, this contention should be rejected for lack of basis and specificity,

f. CSP has alleged that the Applicant has misrepresented reprocessing as a current and viable technology and therefore inadequately assessed its cost. This contention is without basis because the Applicant has taken no credit for reprocessing in the fuel cycle costs. See ASC/ER Table 8.2.2.

Accordingly, the contention must be rejected.

l f

g. CSP has alleged that the cost of decommissioning is inadequately considered because it fails to consider the potential cost of decomissioning the project in the case of an accident. Since the l

1

. Applicant has not included decomissioning costs in its cost projections (Compare,ASC/ERTable8.2.2.toS/HNPDEIS, Table 6.3,pg.6-7),the Staff has no objection to a contention on this matter which is worded as follows:

The Applicant's cost projections to be included in the cost / benefits ratio is inadequate because it sets forth no value for the costs of decomissioning S/HNP at the end of its operating i

life. These decommissioning costs, when considered in the cost / benefit analysis, will result in an unfavorable balance requiring rejection of the application.

h. CSP contends that the Applicant's cost projections are inadequate because it assumes a construction period of seven years / unit when existing construction experience indicates a time-frame of 8.9 years / unit is more appropriate, citing NUREG-0030, " Nuclear Power Plants, Construction Status Report." The Staff submits that this contention meets the requirements of basis and specificity and should be admitted.

1. CSP contends that the Applicant's nuclear cost projections are i

inadequate because it has underestimated (1) the fixed charge rate, (2) the interest rate, and (3) the capital cost escalation when these costs are compared to the coal alternative. The Staff submits that the requisite basis and specificity have been provided to support this contention. However, we suggest the following rewording:

j The Applicant's nuclear cost projections set forth in ASC/ER Tables 8.2-1 and 8.2-2 underestimate (1) the fixed charge rate, (2) the interest rate, and (3) the capital cost escalation rate.

Insummation,RevisedContentions29(B),29(G)(asreworded),

29(H), and 29(I) (as reworded) should be admitted as issues in 1

. controversy. However, we would suggest the designation of the National Wildlife Federation /0regon Environmental Council as the " lead intervenor" on contentions 29(B) and (G) pursuant to the NRC Policy Statement, supra, and 10 C.F.R. 5 2.715a.

Revised Contention 30 Petitioner contends that Applicant underestimates somatic and genetic effects of radiation released from the proposed project during normal and abnormal operating conditions thus entirely underestimating the cost of the plant in the cost-benefit analysis required by 10 C.F.R. 50.21(b).

As basis for this contention, CSP states that the Applicant has failed to consider (a) the radiation dose to nuclear workers at the project, (b) the effect of routine and accidental releases of radiation of children in utero, (c) the existing radiological and other health burdens of people residing in the Hanford area, (d) the complete history of artificial radiation in the land, water, and biota of the Hanford area and the Columbia River, and (e) the complete meteorological and other characteristics of the site necessary to determine the raciation exposure pathways. As basis for the above assertions, CSP has refered to several publications which state generally that radiation health effects are cumulative, there-fore, existing radiological burdens must be considered as well'as the age of the individual when irradiated.

The Staff submits that reliance on these general statements is insufficient to provide the basis required to make a threshold showing that the health effects models used by the Applicant do not adequately consider or account for existing radiological burdens, the age of individuals, or certain site characteristics. We recogr.ize that the F

I

4 effects of radiation on living systems have been subject for decades to intensive investigation and consideration by individuals and select committees.

Indeed, there has been much debate about the exact extent of the effects of very low levels of radiation that result from nuclear power plant effluents. However, to account for the uncertainty in estimating these health effects from both offsite and occupational radiation exposures, the NRC has used somatic (cancer) and genetic risk estimators that are based on widely accepted scientific information and s

are based on conservative assumptions. See S/HNP DEIS $9 4.2.12.3 and 4.2.12.4.

Because of these assumed conservatisms, contentions regarding radiation health effects must be specific and allege how the analyses did not consider the asserted factors and why consideration of the factors would change the results. CSP fails to meet this burden of basis and specificity in this regard by its sweeping statements and broad generalizations.

Accordingly, this contention must be rejected.

Revised Contention 31 Petitioner contends that the radiation monitoring system is inadequate and thus will understate the dose to the public received from routine and abnormal releases of low-level radiation from the proposed project. Applicant should be required to use the "Spiderwort Strategy" which would provide significantly improved information.

As basis for this contention, CSP states that the Applicant's milk monitoring system relies on models that are outdated and obsolete and

(_

should rely on the "Spiderwort Strategy." According to CSP, "Spiderwort, Tradescantia, is a highly sensitive indicator of somatic mutations which yields results within 8 to 12 days from exposure." As Staff understands s

-e i

1

. this contention, CSP alleges that the organism Spiderwort, when exposed to a low-level of radiation, will show a mutation within 8 to 12 days and, therefore, can be used as a sensitive monitoring system. However, this allegation establishes nothing except that the Spiderwort is sensitive to low-levels of radiation.

It does not demonstrate that the radiation t

monitoring equipment used in the Applicant's Radiological Environmental Monitoring Program (REMP) are not as sensitive to radioactive effluents and, therefore, inadequate to measure low-level radiation.

In fact, this contention fails to establish that the "Spiderwort Strategy" would provide information with respect to the type (i.e., radionuclides),

frequency, and duration of radioactivity which would be required for an effective monitoring program. Accordingly, this contenion has provided no basis for requiring the use of the "Spiderwort Strategy" and, hence, it should be rejected.

Revised Contention 32 Petitioner contends that Applicant underestimates the doses and effects caused by the release of radiation in the event of an accident at the S/HNP and thus wrongly concludes the benefits of the facility outweigh the costs under 10 C.F.R. 51.20(b).

As basis for this contention, CSP asserts that the Applicant failed to include certain effects (eg., early illnesses, respiratory impairment, l

hypothyroidism, temporary sterility in males, permanent sterility in l

females, in, utero effects, and genetic effects) in its assessment of the primary effects of an accident. CSP also takes issue with the use in the accident analysis of the standard man as a receptor of the radiological dose and its failure to consider the accidental release of liquid effluent on

u..

. the surface and groundwater supply of the downstream population. However, CSP's assertions are without basis.

It has specified no reason or relied on any documents to establish a foundation for its allegations of error.1S/

As stated earlier, CSP's " beliefs" are insufficient to support a contention.

Accordingly, this contention must be rejected.

t f

Revised Contention 33 Petitioner contends that Applicant has not met the requirements of 10 C.F.R. 50.34(f)(1)(i), NUREG 0718 Rev.1, Action Item II.B.8(1) requirements, and has no intention of meeting these requirements.

The essence of this contention is that CSP contends that because of the completed nature of the S/HNP design and the fabrication of components, there is no reasonable assurance that the probabilistic risk assessment (PRA) program will be used to influence system design development as required by 10 C.F.R. % 50.34(f)(1)(i).

This contention must be rejected for two reasons.

First, the requirements of Section 50.34(f)(1)(i) note that:

The outcome of this study and the NRC review of it will be a determination of specific preventive and mitigative actions to be implemented to reduce these risks.

-~~14/ CSP has referred to a reference entitled " Risk Assessment: Pebble Springs Nuclear Plant," testimony before the Oregon Energy Facility Siting Council, March 31, 1978, by Richard B. Hubbard, but it is unclear what the testimony alleged.

. As discussed in S/HNP SER Supplement No. 2, p. II-6, the specific preventive and mitigative actions could be " improvements in maintenance, procedures, operator training, operating feedback, and... additional quality assurance activities [which] would improve reliability of core and containnient cooling systems." Accordingly, design changes may not be t

needed as a result of the evaluation of the PRA study.

Secondly, if the PRA study does indicate a need for design changes, 10 C.F.R. 5 50.55(e) requires the Applicant to report design deficiencies which could adversely affect the safety of operations and 10 C.F.R. 5 50.109 gives the Commission authority to require backfitting in a facility if it finds that such action will provide substantial, additional protection which is required. These regulatory provisions give the necessary assurance that needed design changes will be imp'emented.

Accordingly, this contention should be rejected as without basis because design changes may not be needed as a result of the PRA study and, if they are needed, the NRC has the necessary regulatory authority to require them.

Revised Contention 34 Petitioner contends that Applicant underestimates the probability and effects of an accident at the S/HNP thus falsely concluding that the benefits outweigh the costs in the analysis required by NEPA and 10 C.F.R. 51.20(b).

As basis for this contention, CSP has listed some of the published comments and criticisms of the Reactor Safety Study (RSS) which has been used by both the Applicant (See ASC/ER, Sec. 7.4) and the Staff (S/HNP DEIS 9 4.2.12.4) in their respective accident analyses. The RSS provides

. a methodology for a probabilistic assessment of the risk from reactor accidents. As stated in the S/HNP DEIS, pg. 4-204, 205:

The assessment methodology used is that described in the Reactor Safety Study (RSS) published in 1975 (NUREG-75/014, formerly WASH-1400).* In 1980, the sets of accident sequences that were found in the RSS to be the dominant contributors to the risk in the prototype BWR (Peach Bottom Unit 2) were g

updatedorrebaselined(NUREG-0715). The method for this effort is similar to that described in d

RSSMAP (NUREG/CR-1659, Vol. 1). The rebaselining was done largely to incorporate peer group comments (NUREG/CR-0400) and better data and analytical techniques resulting from research and development after the publication of the RSS. Entailed in the rebaselining effort was the evaluation of individual dominant accident sequences as they are understood to evolve. The earlier technique of grouping a number of accident sequences into the encompassing release categories, as was done in the RSS, was largely elimi.1ated from this rebaselining effort. Further discussion of the rebaselining is included in Appendix E.

-*/

Because this report has been the subject of considerable controversy, a discussion of the uncertainties surrounding it is provided later in this EIS.

Accordingly, the BWR rebaselining effort was in response to the comments which are used by CSP as basis for this contention. CSP responds by stating it has " reason to conclude" that the rebaseling effort is inadequate and the " risks of an accident are significantly underestimated by the Applicant." Such unsupported statements cannot support a contention and, accordingly, this contention must be rejected.

~

. Revised Contention 35 Petitioner contends that Applicant underestimates the potential and significant costs of an accident in section 7.4 of the ASC/ER as required by 10 C.F.R. 51.20 [ sic].

The general thrust of this contention is that the Applicant's accident analysis set forth in ASC/ER 6 7.4 has underestimated the t

economic costs of contamination of the Columbia River and other water supplies, clean up and decommi:sfoning costs of S/HNP, and impacts on adjacent nuclear and industrial facilities.

However, the Applicant's accident analysis did consider a probability distribution of mitigation costs (ASC/ER, Figure 7.4-9) which included decontamination factors and factors pertaining to indirect costs due to loss of use of property and incomes.

Id., pg. 7.4-19.

The probability distribution shows that at the extreme end of the accident spectrum, mitigation costs could approach five billion dollars but that the probability of occurrence is exceedingly small (1x10-9 occurrences perreactoryear). See also S/HNP DEIS Table 4.39, pg. 4-213; Table 4.47, pg. 4-21'i; pg. 4-215. The Staff notes that the accident analysis probability distribution of economic costs does not include t

costs of decontamination of the facility itself and the costs of replacement power. However, those impacts are included in the risk l

considerations.

_Id., pg. 4-215. Accordingly, it is apparent that the accident analyses did factor in some of the economic costs referred to by CSP. CSP has not alleged how that analysis is inadequate.

To the extent that CSP has referred to economic costs that may not have been evaluated, it has provided no basis why such costs should be considered under NEPA's

" rule of reason." NEPA does not require the consideration of environmental

_ effects or consequences which are deemed only remote and speculative possibilities. Public Service Electric and Gas Co. (Hope Creek GeneratingStation, Units 1and2),ALAB-518,9NRC14at38-39(1979).

CSP has advanced no reason why the identified economic costs are either significant or should not be considered remote and speculative e

possibilities.

In addition, CSP has asserted no basis or specificity to support a claim that the costs of " preventing the liquid pathway of radioisotopes to the Columbia River "should be assessed in light of the Staff's conclusion that liquid pathway consequences present no uniquely large contribution to risk and measures could be taken, if necessary, to isolate liquid contaminents (such as tritium) before they could contaminate the river. S/HNP DEIS, pg. 4-218.

For these reasons, therefore, this contention should be rejected.

III. CONCLUSION As discussed above, the Staff supports the admission of CSP Revised l

l Contentions 1, 2, 3, 4.A.-E., 29.B, 29.G (as reworded), 29.H. and, 29.I (as i

j reworded) as issues in controversy in this proceeding. We submit that all the other contentions must be rejected for the reasons stated.

Respectfully submitted, 41 QL Richard L.

ack Counsel for NRC Staff Dated at Bethesda, Maryland this lith day of June, 1982.

l

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PUGET SOUND POWER & LIGHT Docket Nos. STN 50-522 COMPANY, ET AL.

STN 50-523 (Skagit/Hanford Nuclear Power Project, Units 1 and 2)

CERTIFICATE OF SERVICE I hereby certify that copies of NRC STAFF RESPONSE TO REVISED CONTENTIONS OF C0ALITION FOR SAFE POWER in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this lith day of June,1982.

John F. Wolf, Esq., Chairman Kevin M. Ryan, Esq.

Administrative Judge Assistant Attorney General Atomic Safety and Licensing Temple of Justice Board Panel Olympia, WA 98504 3409 Sheperd Street Chevy Chase, MD 20015 Mr. Gustave A. Linenberger*

Administrative Judge Warren Hastings, Esq.

Atomic Safety and Licensing Associate Corporate Counsel Board Panel Portland General Electric Company U.S. Nuclear Regulatory Commission 121 S.W. Salmon Street Washington, DC 20555 Portland, OR 97204 Dr. Frank F. Hooper Administrative Judge Atomic Safety and Licensing Mr. Lloyd K. Marbet Board Panel c/o Forelaws on Board School of Natural Resources 19142 S. Bakers Ferry Road University of Michigan Boring, OR 97009 Ann Arbor, MI 48190

. _. ~... _ _

. Rober vwenstein, Esq.

Coalition for Safe Power Lowenstein, Newman, Reis, Axelrad Suite 527, Governor Building

& Toll 408 Southwest Second Avenue 1025 Connecticut Avenue, N.W.

Portland, Oregon 97204 Suite 1214 Washington, D.C. 20036 James W. Durham, Esq.

Portland General Electric Company 121 S.W. Salmon Street, TB17 Mr. Nicholas D. Lewis, Chairman Portland, OR 97204 Washington State Energy Facility Site Evaluation Council Docketing and Service Section 4224 6th Avenue, S.E.

Office of the Secretary Mail Stop PY-11 U.S. Nuclear Regulatory Comission Olympia, WA 98504 Washington, D.C. 20555 F. Theodore Thomsen, Esq.

Perkins, Coie, Stone, Olsen

& Williams Richard D. Bach, Esq.

1900 Washington Building Rives, Bonyhadi & Drumond Seattle, WA 98101 1400 Public Service Building 920 S.W. 6th Avenue Portland, OR 97204 Atomic Safety and Licensing Ralph C. Cavanagh Board Panel

Attorney for the Natural Resources U.S. Nuclear Regulatory Commission Defense Council, Inc.

Washington, DC 20555 25 Kearny Street San Francisco, CA 94108 Atomic Safety and Licensing Appeal Board

Terence L. Thatcher U.S. Nuclear Regulatory Commission Pacific Northwest Resources Washington, DC 20555 Center Law Center, 1101 Kincaid Eugene, OR 97403 S. Timothy Wapato James B. Hovis, Esq.

Columbia River Inter-Tribal Yakima Indian Nation Fish Commission c/o Hovis, Cockrill & Roy 8383 N.E. Sandy Blvd., Suite 320 316 North Third Street Portland, Oregon 97220 P.O. Box 487 Yakima, WA 93907 d24[

RicMarc L. Blkyk Counsel for NM Staff ru

ML20054F700

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