ML20072K099
| ML20072K099 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/23/1983 |
| From: | Pratt C, Sanoff B CONSOLIDATED EDISON CO. OF NEW YORK, INC., POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-SP, NUDOCS 8303300374 | |
| Download: ML20072K099 (17) | |
Text
REATCD CORRE3PONDENCB e-00CHETED -
USNRC UNITED STATES OF~AMERACA.
f ag3 g,gg pg
- 7 NUCLEAR REGULATORY COB,iMISSION
~
ATOMIC SAFETY AND LICENSING BOARD
. ' _ ' ^m f -
j es, Before Administrative Judges:
James P.
Gleason, Chairman Frederick J.
Shon Dr. Oscar H.
Paris
_________________________________x In the Matter of CONSOLIDATED EDI27N COMPANY Docket Nos. 50-247 SP OF NEW YORK, I.iC.
(Indian 50-286 SP i
Point, Unit No. 2)
POWER AUTHORITY OF THE STATE March 23, 1983 OF NEW YORK (Indian Point, I
Unit No. 3)
X LICENSEES' SUPPLEMENT TO MOTION TO IMPOSE SANCTIONS AGAINST DEAN CORREN, GREATER f
NEW YORK COUNCIL ON ENERGY AND ENERGY SYSTEMS RESEARCH GROUP, INC. FOR FAILURE TO RESPOND TO INTERROGATORIES l
l l
l Brent L. Brandenburg Charles M. Pratt CONSOLIDATED EDISON COMPANY POWER AUTHORITY OF THE NEW YORK, INC.
STATE OF NEW YORK 4 Irving Place 10 Columbus Circle New York, NY 10003 New York, NY 10019__
(212) 460-4600 (212) 397-6200 1
m l
r303300374 830323
(
PDR ADOCK 05000247
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o PDR
/
e Licensees today received-a, copy 'of the October
'~
1982 Endrgy Systems Research Group, Inc. (ESRG) study entitled The Economics of Closing the Indian Point Nuclear Power Plants.
Licensees have made an investi-gation of the degree.of similarity of the October 1982 study with that study produced by Greater New York Council On Energy (GNYCE) on March 17, 1983.
That investigation indicates that the two studies are identical.
The footnotes from both studies are attached as an example of the identica1 ness of the two documents.
The October 1982 study, apparently, was available to the public for a charge of $50 per copy.
The final y
page of the October 1982 study contains the following ordering information:
Additional copies of this report may be.obtained by remitting a check, money order, or purchase i
order in the amount of $50, made out-to " Energy Alternatives Research Fund," with the below f
mailing label to:
a Marn Davis Energy Systems Research Group 120 Milk Street Boston, Massachusetts 02109 i
l Licensees may have been the only members of the public that could not obtain this October 1982 ESRG study.
The apparent availability in October 1982 of precisely the study that GNYCE now proposes to use in this special proceeding s
I constitutes a failure to comply with the Commission's rules of discovery.
The fact that the wor'ds ". Draft Report" a.ppear
~
on the cover of the October 1982 study does not alter the fact that that study was definite enough to be offered for sale to the public and is identical to the final Report.
In any event, licensees asked GNYCE to produce the ESRG documents, draft or final.
GNYCE's non-production the October 1982 study merits.
the imposition of sanctions.
In Consumers Power Company (Midland Plant, Units 1 and 2), CCH Nuc. Reg. Rep. S 30,761 (Feb. 18, 1983), the Commission indicated the seriousness of non-disclosure of information.
A deliberate false statement or withholding of material information would warrant the imposition of a i
severe sanction.
... Moreover, we want to warn parties and their attorneys that when they engage in conduct which skirts close to the line of improper conduct, they are running a grave risk of serious I
sanction if they cross that line.
Id. at'pige 30,704.
CONCLUSION Licensees submit that the fact the October 1982 ESRG study is identical to the March 1983 study, which GNYCE proposes to use in this case, establishes a clear non-compliance - -
4 with the discovery rules which mer,its tl$e imposition
~
of sanction.
- fW6.6% h
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gm Bernard Sanoff V
Charles M.
Pratt CONSOLIDATED EDISON COMPANY Stephen L.
Baum OF NEW YORK, INC.
General Counsel 4 Irving Place Charles M. Pratt New York, NY 10003 Assistant General Counsel (212) 460-4600 POWER AUTHORITY OF THE STATE OF NEW YORK Licensees of Indian Point Unit 3 10 Columbus Circle New York, NY 10019 (212) 397-6200 Charles Morgan, Jr.
Paul F. Colarulli Joseph J. Levin, Jr.
MORGAN ASSOCIATES, CHARTERED 1899 L Street, NW Washington, DC 20036 l
(202) 466-7000 Bernard D.
Fishman Michael Curley Richard Czaja David H. Pikus SHEA & GOULD 330 Madison Avenue New York, NY 10017 (212) 370-8000 1
i e
FOOTNOTEI 1.
The basic documents on the cost impacts e
- ne Indian Point facility are listed in Refer rough 5ebelow.
Together, they present a remarkab.
etrum of assumptions, methods, and not surprising 13
.esults.
None present a documented and systematic framework for scenario explication, sensitivity analysis, and. output evaluation.
2.
Economic Impact of C' losing the Indian Point Nuclear Facility, Report by the Comptroller General of the United States, U.S.
Government Accounting Office, EMD-81-3, Washington, D.C.,
November 7, 1980.
3.
Costs of Closing the Indian Point Nuclear Power Plant, prepared for Power Authority of the State of New York, Rand Corporation, R-2857-NYO, Santa Monica, California, November, 1981.
4.
Taylor, Vince and Komanoff, Charles, An Evaluation of
" Economic Impact of Closing the Indian Point Nuclear Facility" A Report of the General Accounting Office,
)
Union of Concerned Scientists, December 3, 1980.
5.
Brancato, Carolyn Kay, "The Indian Point No. 2 Nuclear Facility," Congressional Research Service, Washington D.C.,
December 5, 1980.
t 6.
The IP-1 unit has been shut down since 1974; the NRC revoked Con Ed's operating license in 1980.
We shall not' consider this unit further in this study.
7.. An' Analysis of the Need for and Alternatives to the Proposed Coal Plant at Arthur Kill, a report to the New
-York City Energy Office and the Corporation Counsel of 4
New York, ESRG Study No. 81-21, June,1981.
8.
Referenced in Note 7.
This study was also presented as part of testimony in the 1981 New York State Energy Master Planning hearings by Dr. Richard A. Rosen.
The focus of the study was the economics of the proposed Arthur Kill plant, but the work has general applicabi-i lity to generation planning and demand related issues in- -
the region.
t 9.
Documented in Note 7 reference.
. From October 1982 Report E
S R
G
FOOTNOTES (Continued) 10.
Note that'neither the proposed.700-MW Arthur Kill unit
~
on Staten Island nor the proposed Prattsville pumped storage facility has been included in these generation dispatch runs.
Had they been, the replacement power for Indian Point would have derived from more efficient back-up units than we have assumed, thus lowering make-up, power costs.
11.
Con Edison response to NRC Staff interrogatory #24, NRC Docket 450-247SP, #50-286SP.
12.
Vol. II, p. 433.
13.
In the Low Impact case one could conceivably assume the additional coal conversions of the Astoria #3, 64, and
- 5 units, but due to unresolved controversy surrounding the feasibility of such conversions we did not.
14.
Con Edison response to NRC Staff interrogatory fl, p.
7-8, NRC Docket 450-247SP, 650-286SP.
Indeed, Con Edison's oil price assumptions are somewhat below the Mid-Range case assumption.
)
15.
1982 NYPP Report, p. 12.
16.
Con Edison FERC Forn #1, pp. 326-27.
17.
The following amounts of power were assumed available for dispatch at the listed prices:
i Megawattage Cost Power Line Years Maximum (1981 S/MWH)
NYPPfl.
1981-2000 300 49.60 LLLCOil 1981-2000 500 65.00 NYPPt2 1981-2000 800 70.00 NYPPf3 1986-2000 1000 65.00 Generally these lines will dispatch only a fraction of l
the time.
1 1 18.
Con Edison response to NRC Staff interrogatory #1, p. 9.
19.
This analysis shows that about 36% or about 3000 GWH of the make-up power would come from upstate NYPP ccm-panies.
This is the equivalent of about a 800 MW line with a capacity factor about 40%. E S
R G
FOOTNOTES (Continued) 20.
In current dollars, in 1983', the make-up power costs for. the Mid-Range scenario would be about S542 million.
~. -
To' compare with the Con Edison calculations provided on
"~
discovery for that year, however, the nuclear fuel, nuclear operations and maintenance costs (O&M) and nuclear spent fuel disposal costs would have to be subtracted, yielding a total Mid-Range impact of S327 million, or 3.8 cents per'KWE.
(See Table 2 referenced in note #14.)
The comparable High-Impact value will be about S367 million, and the Low-Impact value is $235 million.
In contrast, the RAND report claims that a reasonable upper and lower limit of $455 million and
$425 million, respectively, is appropriate, which can be compared to the Con Edison value of $506 million.
The largest single cost item that separates the Con Edison and Rand Estimates from the High-Impact or Mid-Range Impact cases here is a roughly $50-100 million differential for nuclear OEM.
The justifica-tion for the ESRG assumptions on OEM can be found in Section 3.4 below.
Secondly, different capacity factor assumptions among all parties account almost completely for the remainder of this cost differential.
21.
The 20% figure was estimated by Dr. Lewis Perl of NERA, a consultant to Con Edison and other utility companies in Revised Direct Testimony, Pennsylvania Public Utility Commission Docket #I-80100341.
22.
Response to Greater New York Council on Energy, interrogatory #23 (Con Ed), Table 6B, p.8, and $4 (PASNY).
23.
The New York utilities appear to assume a 0% real esca-lation rate ~.
Other observers assume rates above our High Impact case assumption (e.g., Lewis Perl, op.
cit., Table 11 testified to over 5% real escalation rates).
24.
Based on a reloading cycle of 18 months with one-third l
assembly replacement (implying an average age of 27 months) and a fixed charge rate of 15% (Con Ed & PASNY average):
27/12 x.15 =.34 l..
l 25.
Cited in Note 2.
l l
26.
- See, e.c., App. D, Refs. D-4 and D-8.
l l
27.
NES, Inc., " Decommissioning Study of Prompt l
Dismantlement of Indian Point Unit 2",
April, 1982, p.
- 9. E S
R G
I FOOTNOTES (Continued) 28.
Reference cited'in Note 27'.
29.
Cited in California Energy Commission, " Nuclear Economics"., November, 1980, p. 56.
30.
Steam-Electric Plant Construction Cost and Annual Production Expenses, USDOE, various years esp. 1973 and 1979.
31.
Con Ed response to interrogatory #2 of GNYCE's First
~
Set.
32.
PASNY response to interrogatory #2 of GNYCE's First Set.
33.
Cited in Note 2, pp. 20-21.
i 34.
Con Ed response to interrogatory til of GNYCE's First Set.
35.
New York Times, March 31, 1982,,p.A25. " Tubes at 40 A-Plants Assailed".
Steam-generator replacement has already occurred at the Surry #1 and #2 units in Virginia.
Similar replacements are underway or planned at Turkey Point and Palisades nuclear stations.
\\
36.
Cited in Note 3, Table 10.
37.
PASNY response to interrogatory til of GNYCE's-: Furst Set.
Annual required revenue in constant dollars is assumed
+
38.
to decrease at an annual raate of -1.5%, -1.0%, and i
. -Q.5% for the Low, Mid, and High Impact scenarios,
respectively, based on scenario load growth assumptions and a decrease in the unit cost of electricity in the Con Ed service area of 0.7%/ year (Energv Master Plan
[
II, State Energy Office of New York, August 1981,
- p. 170).
39.
Indeed, in the later years of the Low Impact case the.
costs of generating power from the nuclear stations exceeds the make-up costs.
In this case, on economic grounds, the plant would be voluntarily retired some-time after 1990. E S
R G
' FOOTNOTES (Continued) 40.
The required revenue simulation used in this study employs statistically' estimated measures of ncrmal plant operation.
Abnormal events of low probability such as a catastrophic accident are, of course, not reflected.
Cost estimates here would be related to such imponder-ables as the worth of human lives (a moral as well as economic concept), probability of losing lives, psycho-lo'gical costs, etc.
t 41.
There is abundant popular literature on nuclear risks (see, e.g., Countdown to a Nuclear Moratorium, Environ-mental Action Foundation, 1976).
On the other hand, most economic impact assessments are silent on the question of nuclear hazards (e.g., Refs. 2 and 3).
42.
Bohi, Douglas R., Analyzing Demand Behavior: A Study of Energy Elasticities, John Hopkins, Baltimore, 1981,
- p. 1.
43.
Ibid., p. 57 ff.
44.
This is apparently confirmed in Ref. 2, Table 3-13, p.58, where satisfactory interest ratios are found under passthrough ratemaking.
The caveat "apparently" is necessary due to a lack of documentation on data, assumptions, and methodology in that study.
Ref. 3 refers to that exercise as a " black box" (p. 35) but nevertheless manipulates various Ref. 2 tables in an attempt to cull out " business costs" (everything but fuel-related cost it appears).
This exercise cannot be considered scientifically interesting.
l 45.
The issues are reviewed in Ref. 3 (pp. 38-45) and in J. Stutz ind P. Rackin, Electricity Requirements in New York State.
Volume III: Employment Impacts of the
_ Conservation Policy Base Case Alternative, Energy Systems Research Group, Inc., ESRG 79-12/3, July, 1979.
i The latter offers a concrete quantitative assesment of the secondary effects of conservation in New York uti-lizing a regional model based on input / output tech-niques.
46.
Martin L.
Baughman et al., Direct and Indirect Economic, Social,and Environmental Impacts of the Passace of the California Nuclear Power Plant Initiative, Center for Energy Studies, University of Texas at Austin, FEA/G-76126G1, April 1976.
However, as pointed out in Ref. 3 (p.40), there are questions about the validity of this report and its relevance to an Indian Point closing.,
E S
B G
FOOTNOTES (Continued) 47.
J.H. Savitt, Electri6 Energy Usage and Regional Economic
"~
Redevelopment, Final Report, EPRI, 2S-18 7, Palo Alto,
California, August, 1976.
48.
These are the ESRG study cited in hef. 6 and the New York State Energy Office's State Energy Master Plan and Long-Range Electric and Gas Report, Albany, 1980.
-l I
l l
l D
i I
i l
l l
l l E S
R G
i
~
agpenditures for make-up generation go,in part to-for fgn coffe~
What are the changes in expenditu patterns implied by a plant clos
?
What are the onomic repercussions locally ill i d ced conservation and health'.and and nationally?
ract the negative repercussion of safety benefits un These are significant questions higher e ctricity costs.
th cannot be answered toda I
i i
l l
?
l
=-
b-l t
l t.
'. From March 1983 Report l
I l
E S-R G
=
FOOTNOTES
/
e cost impacts of closing the The basic documents on th' India'n Point facility are listed in References 2 through
~l~
1.
Together, they preaant a remarkable spectrum of assumptions, methods, and not surprisingly, results.
5 below.
None present a documented and systematic framework for scenario explication, sensitivity analysis, and output evaluation.
Economic Impact of Closing the Indian Point Nuclear Report by the Comptroller General of the 2.
- Facility, Government. Accounting Office, United States, U.S.
EMD-81-3, Washington, D.C., November 7, 19 80.
l Costs of closing the Indian Point Nuclear Power Plant, prepared for Power Authority of the State of New Yor 3.
November, 1981.
f Taylor, Vince and Komanoff, Charles, An Evaluation of
" Economic Impact of Closing the Indian Point Nuclear 4.
Facility" A Report of the General Accountino Office, Union of Concerned Scientists, December 3, 1980.
Brancato, Carolyn Kay, "The Indian Point No. 2 duelear
" Congressional Research Service, Washington 5.
Facility,.
D.C.,
December 5, 1980.
the NRC Th.e IP-1 unit has been shut down since 1974; We shall revoked Con Ed's operating license in 1980.
6.
not consider this unit further in this study.
f An Analysi-s of the Need for and Alternatives to the
~
Arthur Kill, a report to the New 7 '.
Proposed Coal Plant at York City Energy Office and the Corporation Counsel of 1981.
New York, ESRG Study No. 81-21, June, This study was also presented.as, Referenced in Note.7.
part of testimony in the 1981 New York State Energy 8.
Rosen.
The Master Planning hearings by Dr. Richard A.
focus of the study was the economics of the proposedbut th Arthur Kill plant, lity to generation planning and demand related issues in 9
the' region.
Documented in Note 7 reference.
9.
i
- \\
E S
R G
~
o o
FOOTNOTES (Continued) s.
Note that neither the proposed 700-MW Arthur Kill unit 10.
on'Staten Island nor the proposed Prattsville pumped storage facility has been included in these generation Had they been, the replacement power dispatch runs.
for Indian Point would have derived from more efficient back-up units than we have assumed, thus lowering make-up, power costs, Con Edison response to NRC Staff interrogatory 624, 11.
NRC Docket f50-247SP, #50-286SP.
12.
Vol. II, p. 433.
In the Low Icpact case one could conceivably assume the 13.
additional coal conversions of the Astoria #3, #4, and
- 5 units, but due to unresolved controversy surrounding the feasibility of such conversions we did not.
i Con Edison response to NRC Staff interrogatory fl, p.
14.
7-8, NRC Docket $50-247SP, 550-286SP.
Indeed, Con Edison's oil price assumptions are somewhat below the
(
Mid-Range case assumption.
15.
1982 NYPP Report, p. 12.
Con Edison FERC Form fl, pp. 326-27.
16.
The following amounts of power were assumed available 17.
for dispatch at the listed prices:
Megawattage Cost
. Power Line Years Maximum (1981 S/MWH)
NYPPfl 1981-2000 300 49.60 LLLCOil 1981-2000 500 65.00 NYPPi2 1981-2000 800 70.00 1
NYPPi3 1986-2000 1000 65.00 1
~ ~
Generally these lin'es will dispatch only a fraction of I
I the-time.
Con Edison response to NRC Staff interrogatory fl, p. 9.
(
18.
t This analysis shows that about 36% or about 3000 GWH of 19.
the make-up power would come from upstate NYPP com-This is the equivalent of about a 800 MW line panies.
with a capacity factor about 40%.
. i S
R G
FOOTNOTES (Continued)-
(:
\\
In. current dollars, in 1983, the make-up power costs for.the Mid-Range scenario wodld be about $542 million.
~
20.
~
To compare with the Con Edison calculations provided on
"~
discovery for that year, however, the nuclear fuel, and nuclear operations and maintenance costs (OEM) nuclear s' pent fuel disposal costs would have to be subtracted, yielding a total Mid-Range impact of '$327 (See Table 2 referenced million, or 3.8 cents per KWH.The comparable High-Impact value will be in note #14.)
about $367 million, and the Low-Impact value is $235 the RAND report claims that a million.
In contrast, reasonable upper and lower limit of $455 million and.
S425 million, respectively, is appropriate, which can be compared to the Con Edison value of $506 million.
The largest single cost item that separates the Con Edison and Rand Estimates from the High-Impact or Mid-Range Impact cases here is a roughly $50-100 The justifica-million differential for nuclear OEM.
tion for the ESRG assumptions on OEM can be found in Secondly, different capacity factor Section 3.4 below.
assumptions among all parties account almost completely for the remainder of this cost differential.
I The 20% figure was estimated by Dr. Lewis Perl of NERA,-
a consultant to Con Edison and other utility companies 21.
in Revised Direct Testimony, Pennsylvania Public Utility Commission Docket fI-80100341.
' Response to Greater New York Council on Energy, interrogatory.623 (Con Ed), Table 6B, p.8, and #4 22.
(PASNY).
-._The New York utilities appear to assume a 0% real esca-23.
Other observers assume rates above our lation rate.
l High Impact case assumption (e.g., Lewis Perl, on.
}
Table 11 testified to over 5% real escalation cit.,
rates).
Based on a reloading cycle of 18 months with one-third (implying an average age of 27 24.
3 assembly replacement and a fixed charge rate of 15% (con Ed & PASNY months) j, average):
27/12 x.15 =.34.
83 25.
Cited in Note 2.
26.
- See, e.g., App. D, Refs. D-4 and D-8.
" Decommissioning Study of Prompt NES, Inc.,
Dismantlement of Indian Point Unit 2", April, 1982,
/
27.
i p.
- 9. )
E S
R G
FOOTNOTES r
(Continued)
(_;,,.,
Reference cited in Note 27.'
I
~1.
28.
Cited in California Energy Commission, " Nuclear 29.
Economics", November, 1980, p. 56.
Steam-Electric Plant Construction Cost and Annual Production Expenses, USDOE, various years esp. 1973 and 30.
\\
1979.
Con Ed response'to interrogatory #2 of GNYCE's First 31.
Set.
PASNY response to interrogatory f 2 of GNYCE's First Set.
32.
i Cited in Note 2, pp. 20-21.
33.
Con Ed response to interrogatory til of GNYCE's First l
34.
Set.
I 31, 1982, p.A25. " Tubes at 40 35.
New York Times, MarchSteam-generator replacement has
}
A-Planrs Assailed".
already occurred at the Surry il and 42 units in Similar replacements are underway or planned Virginia.
ar Turkey Point and Palisades nuclear stations.
4 36.
Cited in. Note 3, Table 10.
f pASNY response to interrogatory fil of GNYCE's Furst l
37.
Set.
Annual required revenue in constant dollars is assumed to decrease at an annual raate of -1.5%, -1.0%, and 38.
-0.5% for.the Low, Mid, and High Impact scenarios, respectively, based on scenario load growth assumptions and a decrease in the unit cost of electricity in the Con Ed service area of 0.7%/ year (Energy Master Plan II, State Energy Office of New York, August 1981,
- p. 170).
in the later years of the Low Impact case 5he i
- Indeed, costs of generating power from the nuclear stations 39.
In this case, on economic :
exceeds the make-up costs.
. grounds, the plant would be voluntarily retired some-time after 1990.
. E S~
R G
s FOOTNOTES
[
(Continued)
The required revenue simulation used in this study
'l
~.
40.
employs statistically estimated measures of normal plant Abnormal events of low probability such as a operation.
catastrophic accident are, of course, not reflected.
Cost estimates here would be related to such imponder-ables as the worth of human lives (a moral as well as economic concept), probability of losing lives, psycho-lo'gical costs, etc.
There is abundant popular literature on nuclear risks 41.
Countdown to a Nuclear Moratorium, Environ-(see, e.g.,
mental Action Foundation, 1976).
On the other hand, most economic. impact assessments are silent on the Refs. 2 and 3).
question of nuclear hazards (e.g.,
A Study of Bohi, Douglas R., Analyzing Demand Behavior:
42.
Enercy Elasticities, John Hopkins, Baltimore, 1981,
- p. 1.
43.
Ibid., p. 57 ff.
is apparently confirmed in Ref.
2, Table 3-13, This p.58, where satisfactory interest ratios are found under 44.
Th'e caveat 'apparently" is passthrough ratemaking.
necessary due to a lack of documentation on data, Ref.~3 assumptions, and methodology in that study.
but refers to that exercise as a " black box" (p. 35) nevertheless manipulates various Ref. 2 tables in an a:ttempt to cull out " business costs" (everything but l
fuel-related' cost it appears).
This exercise cannot be considered scientifically interesting.
and in
--The issues are reviewed in Ref. 3 (pp. 38-45)
Raskin, Electricity Requirements in New 45.
J. Stutz and P.Volume III: Employment Impacts of the York State.
Conservation Policy Base Case Alternative, Energy Systems Research Group, Inc., ESRG 79-12/3, July, 1979..
The latter offers a concrete quantitative assesment of the secondary effects of conservation in New York ut.i-lizing a regional model based on input / output tech-niques.
y-Direct and Indirect Economic, 4
Martin L. Baughman et alg, Social,and Environmental Imoacts of the Passage of the I
46.
Initiative, Center for
, California Nuclear Power Plant Energy Studies, University of Texas at Austin,
]
However, as pointed out in FEA/G-7612661, April 1976.there are questions about the validity of Ref. 3 (p.40),
this report and its relevance to an Indian Point
\\
closing.
. E S
R G
4 FOOTNOTES (Continued)
J.R. Savitt, Electric Energy Usage and Regional Economic b~._
47.
Redevelopment, Final Report, EPRI, ES-187, Palo Alto, California, August, 1976.
These are the ESRG study cited in Ref. 6 and the New 48.
York State Energy Office's State Energy Master Plan and Long-Range Electric and Gas Report, Albany, 1980.
?
e e
i I
e I
~ : T-4 4
i
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E S
R G
.