ML20133L890
| ML20133L890 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/09/1985 |
| From: | Bernabei L GOVERNMENT ACCOUNTABILITY PROJECT, JOINT INTERVENORS - WATERFORD |
| To: | NRC COMMISSION (OCM) |
| References | |
| CON-#385-173 ALAB-812, OL, NUDOCS 8508120764 | |
| Download: ML20133L890 (15) | |
Text
-
17 3 ..
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1
Before the Commission OfMEqc wSMC In the Matter of )
LOUISIANA POWER & LIGHT COMPANY ) Docket No. 0 h2iLPd.*38
)
(Waterford Steam Electric Station, ) M 5t .
I' %Ep,6. ;
Unit 3) ) g JOINT INTERVENORS' PETITION FOR REVIEW On July 11, 1985, the Atomic Safety and Licensing Appeal Board (" Appeal Board") denied Joint Intervanors' motion to reopen the record of the operating license hearing for the Waterford Steam Electric Station, Unit 3 ("Waterford") to litigate appli-cant Louisiana Power & Light Company's ("LP&L") lack of character and competence to operate Waterford and its inability to assure its safe operation in light of the quality assurance breakdown during its construction ("ALAB-812"). Louisiana Power & Light Co. (Waterford Steam Electric Station, Unit 3), ALAB-812 (July -
18, 1985).
W Joint Intervenors appeal
- rom that decision on the following grounds:
The Appeal Board's refusal to decide a portion of Joint 1)
Intervenors' Motion to Reopen on the basis of the Nuclear Regula-tory Commission ("NRCH or " Commission") Office of Investigations'
("OI") inability or refusal to provide the information necessary to an informed and public adjudicatory decision deprives Joint W The Commission granted Joint Intervenors an extension of time to August 9, 1985 to petition for review of ALAB-812. .
Intervenors of their right to have a hearing on and to have decided all material safety issues prior to Waterford's licens-ing; and
- 2) The Appeal Board's reliance on LP&L's reinspection and record review efforts to ensure the safe construction and opera-tion of Waterford 3 is unwarranted, as demonstrated by recent equipment failures at the plant since the Commission authorized
- full power operation on March 15. ,
In their response to ALAB-801 Joint Intervenors raised the issue that their rights were violated by the Appeal Board's con-sideration of information communicated to it ex parte by OI.
Joint Intervenors' Response to ALAB-801 (May 16, 1985) , at 11-12.
Joint Intervenors objected to an Appeal Board decision based on ex parte communications not subject to challenge since they expected the Appeal Board to issue a decision on the proposed
" character and competence" contention based on consideration of this OI information. Prior to ALAB-812 the Appeal Board did not inform Joint Intervenors, or even suggest, that it would refuse to decide a portion of the motion on the ground of insufficient information.
Joint Intervanors objected to the Appeal Board's reliance on LP&L's reinspection and record review efforts to verify the quality of Waterford's construction and its safe operation in its original motion to reopen and in all supporting pleadings. See Joint Intervenors' Motion to Reopen (Nov. 7, 1984), at 3,35-42,45-46; Joint Intervenors' Reply to Applicant and NRC Staff's Responses to Joint Intervanors' Motion to Reopen (Jan. 25, 1985),
at 14-15; 16-21; Joint Intervenors' Response to NRC Staff and Louisiana Power and Light Co. Responses to ALAB-801 (May 6, 1985), at 2, 3-5, 7-9, 11, 14, and 17-18.
In support of this petition for review Joint Intervenors provide examples of equipment failures occurring since grant of a full power license which demonstrate that LP&L's reinspection and record review corrective action program was inadequate to guaran-tee the plant's safe construction. Because these events occurred after the submission of pleadings to the Appeal Board, Joint Intervenors had no opportunity to present this evidence to the Appeal Board.
I. THE APPEAL BOARD'S REFUSAL TO DECIDE A PORTION OF JOINT INTERVENORS' MOTION DENIES JOINT INTERVENORS THEIR RIGHT TO A FAIR AND PUBLIC ADJUDICATION OF ALL MATERIAL SAFETY ISSUES PRIOR TO LICENSING OF WATERFORD.
Under the Atomic Energy Act, Joint Intervenors have the right to a public hearing on all issues material to safety. 42 U.S.C. 2239(a); Union of Concerned Scientists v. Nuclear Regula-tory Commission / 735 F.2d 1437, 1444-45 (D.C.Cir. 1984). Thus Joint Intervenors have the right to adjudicate such issues in accordance with the rules es'tablished by the NRC for adjudicatory proceedings. The rules provide that they may request and have fairly considered motions to reopen the record and to litigate late-filed contentions which raise significant and possibly determinative safety issues.
Good character is one of three statutory requirements for NRC licensees and is acknowledged as material to a plant's safe operation. 42 U.S.C. 2232(a); Houston Lighting and Power Co. (South Texas Project, Units 1 and 2), 19 NRC 659 (1984). OI is the NRC office charged with investigating willful or delib-
~
erate violations of the Atomic Energy Act, NRC regulations or a company's license violations. OI has investigated allegations of such willful violations at Waterford since 1983, focusing on allegations of quality assurance ("QA") record falsification and i
l harassment and intimidation of QA and quality control ("QC")
personnel. OI has not yet completed its investigations and has not given any date by which it expects to complete them.
j
! Ccamissioner Asselstine, in dissenting from the Commission's decision to authorize full power operation of Waterford, based his decision in part on questions about LP&L's management integ-rity raised in the OI investigations.
j All such questions about LP&L's management. integrity should i be fully resolved in adjudicatory hearings prior to grant of an
! operating license to LP&L. Otherwise the Commission cannot 1
f assure, as it is required to do, that LP&L possesses the charac-ter and competence to operate Waterford safely.
OI briefed the Appeal Board several times on its ongoing l
investigations. Moreover, the Appeal Board members themselves personally reviewed investigative records in the NRC's regional 4
offices. This review was totally ex parte. The Appeal Board l
4
- afforded the parties no right to review the materials, even 1
, subject to a protective order, or to rebut the evidence pre-sented. After this review, the Appeal Board decided that it did 1
not have, and had no expectation of receiving, adequate informa- l I
F Commissioner Asselstine noted that at least one of the i integrity issues being investigated was "significant." See Tran-script of March 15, 1985 Commission Meeting, at 107.
,,.., ~ ~ n --,,--,-.--,nw.n,.n,,_,_,-~,-.,__,...,,-,-_-n-,..,_ ~ . - n_., , , , _..,__--__-,._,,.,-,,,,.__._--,n_,..n . . , . -,,n,,---,,-
tion from OI to decide Joint Intervenors' motion "within a reason-able, definite period of time." ALAB-812 at 72. Thus, the Appeal Board effectively determined that the present adjudicatory record did not support denial of Joint Intervenors' motion.
The Appeal Board could not obtain the information it needed to decide Joint Intervenors' motion since the public disclosure of information obtained by OI is restricted by the Commission's Policy concerning conflicts in the disclosure of investigatory information to adjudicatory boards and parties. 49 Fed. Reg.
36,032 (1984).
In this case the Appeal Board's adherence to this policy violates Joint Intervenors' hearing rights under the Atomic Energy Act and due process rights to have their motion to reopen decided in accordance with constitutional and NRC adjudicatory procedures. Essentially one branch of the NRC is preventing a full and fair adjudication of issues which may significantly affect Waterford's safe operation. Neither the Commission nor the Appeal Board can rake safety decisions unless all offices in the agency provide them with complete and accurate information.
This principle becomes even more important when the information withheld -- possible willful violations of the Atomic Energy Act and NRC regulations -- has potentially serious implications for safe operation of Waterford.
Further, any information on which the Commission bases a safety decision must be publicly disclosed and subject to the parties' cross-examination and rebuttal. Just as any other administrative agency, the NRC's adjudicatory process provides due process guarantees to all parties to the litigation.
-_---.---_--,-.-----_-_.-..,----_.-.----+-...--.m,_m.- _- . - .-- -- . . , - _ - - . . . . , . - . -
OI is the NRC Office specifically charged with investigating f
serious allegations of willful violations of safety regulations which reflect on a licensee's character. The Appeal Board cannot make its final decision on Joint Intervenors' motion prior to resolution of these serious charges. It makes no sense for the Commission to create a special office to investigate willful viola-tions of safety violations and then to separate these investiga-tions from its licensing decision. Certainly the Commission's hasty decision to license Waterford prior to any resolution of OI's investigations does not provide the requisite reasonable 2/
assurance of safety. .
The Appeal Board in its decision acknowledged its inability to make a decision on Joint Intervenors' motion to reopen given the ongoing and incomplete nature of the OI investigations. The current adjudicatory record does not therefore provide reason-able assurance that LP&L possesses the character and competence to operate Waterford safely.
Joint Intervenors urge the Commission to take review on the ground that the Appeal Board's refusal to decide their motion to reopen presents an important constitutional and public policy issue concerning the Commission's ability to make licensing deci-sions prior to resolution of outstanding investigations on adjud-icatory matters.
2/ In comments to the Commission, Joint Intervenors chal-lenged the Commission decision to license Waterford prior to OI's resolution of the outstanding integrity issues. See Transcript of March 15, 1985 Commission Meeting, at 88-89.
A/
At least one other NRC adjudicatory board has similarly FOOTNOTE CONTINUED
II. THE APPEAL BOARD'S RELIANCE ON LP&L'S REINSPECTION AND RECORD REVIEW PROGRAM TO ENSURE THE SAFE CONSTRUCTION l AND OPERATION OF WATERFORD IS UNWARRANTED IN LIGHT OF THE LARGE NUMBER OF RECENT EQUIPMENT FAILURES SHOWING REMAINING HARDWARE PROBLEMS. l The Appeal Board relies throughout ALAB-812 on LP&L's rein-spection and record review program for assurance that Waterford has been constructed and can be operated safely. See, e.g.,
ALAB-812 at 19; 21; 24-28; 32; 37-39; 41; 44; 49; 53; 55; 60-61; and 64-65. A number of significant equipment failures have occurred at Waterford since the commission authorized its full power operation which demonstrate that hardware problems persist at Waterford and LP&L's corrective actions do not ensure its safe construction and operation. The following are the most significant:
- 1) In early May, Waterford was shut down after a faulty
- valve in the containment spray system leaked radioactive water into the containment building. See "Waterford 3 still shut down after radioactive leak found," New Orleans Times-Picayune, May 13, 1985, attached and incorporated herein as Exhibit 1.
- 2) On May 8, 1985, snubbers and steam line supports were damaged, after operators heard a loud noise when opening the A side steam supply valve. See NRC PNO (May 13, 1985), attached and incorporated herein as Exhibit 2.
FOOTNOTE 4 CONTINUED found that OI's refusal to provide it with presumably probative and useful information prevented it from fully deciding the issue before it. Long Island Lighting Co. (Shoreham Nuclear Power Station, Unit 1), LBP-85-18, 21 NRC (June 14, 1985), slip op.
at 6-8.
t
- 3) On June 4, 1985, lead deposits discovered in Waterford's steam generator forced a three week slowdown of start-up test-ing. See Cunningham, "Waterford 3 tests slowed by deposits," New Orleans Times-Picayune, June 4, 1985, attached and incorporated herein as Exhibit 3.
i 4) On July 18, 1985, intense vibrations caused damage to a large rotor in the turbine generator system and caused a minimum three week shutdown of the plant. Four days. earlier a computer problem in the turbine's control panel automatically shut down the reactor. See Cunningham, "N-plant repairs will take 3 weeks," New Orleans Times-Picayune, July 23, 1985, attached and incorporated herein as Exhibit 4.
These significant equipment failures demonstrate LP&L's cor-rective action program does not deserve the unquestioning endorse-ment it received from the NRC Staff and the Appeal Board. LP&L's inability or refusal to detect the continuing stream of problems plaguing the plant since authorization of its full power opera-tion prove convincingly the inadequacy of LP&L's corrective efforts.
Certainly the effectiveness'of its program can be better judged by its actual results (and failures) than by the paper program.
5/
During its ascension to full-power operation, Waterford experienced several reactor trips due to the failure to maintain the correct steam generator water levels. Joint Intervenors cannot determine from the Licensee Event Report whether these trips were due to equipment or operations' personnel failures.
9/ Insofar as the information presented in this petition for review is deemed improperly submitted in support of a Peti-tion for Review, Joint Intervenors request that their request be j construed as a Motion to Reopen the Record on their proposed character and competence contention on the ground of newly-discovered evidence.
s
Joint Intervenors request the Commission to take review of the Appeal Board's decision because plant failures since authori-zation of full power operation have demonstrated that the Appeal Board's reliance on LP&L's reinspection program to ensure Water-ford's safe constrution is unwarranted and endangers the public safety.
III. CONCLUSION.
For the foregoing reasons, Joint Intervenors respectfully request that the Commission take review of ALAB-812.
Respectfully submitted,
/ ///'A w Lyhd'q Bernabei Geprge Shohet Government Accountability ProjecL 1%55 Connecticut Avenue, N.W. '
$ite 202 Washington, D.C. 20036 (202) 232-8550 Attorneys for Joint Intervenors DATED: August 9, 1985
. EXHIBIT 1 "Waterford 3.Still Shutdown After Radioactive Leak Found, " The Times -Picayune (May 13, 1985) l
~
Mendsy Mov 13.19s5 METRO NEWS
- s. . . '
Watsrford 3 still shut down ,
sfter radioactiveleak found i
'[he Waterford 3 nuclear power shortly aAer 5 p.m., Lt. Joe Car- now going into the utuity's power plant at TaA remained shut down della, a spokesman for the St. supply. By June, Fort estimated ,
Sunday as workers tried to repair Charles Parish Sheriff's Omco, Waterford 3 will have sold $23 1 a faulty valve that leaked radioac- said. million worth of electriety durms tive waterinside the containment When the leak was discovered, h test phase, building, a Louisiana Power & the plant was runmag at 80 per. A St. Rose man who fell into a Light Co.oscial said. cent of its destaned capacity, om- sump of boiling water at h plant
,,Although repairs were expected cals said. It was slowly shut down Friday night remained in criticial
~
to be completed late Sunday, the durms h day, Cook said. condition Sunday at Ochener company did not plan to imme- The. valve was leaking about Foundation Hospital.
distely reactivate the reactor. 6 gallons per minute, Cook said. Francia Quinn. 61,132 Petrie LP&L spok=' nan Jim Foit said. Water from the valve was recy- Drive, St. Rose, received second-While the reactor is shut down, cled in the system in the building, degree burns over 49 percent of cesipany crews will inspect other he said, his body when he shpped on an va)ves and other pipes in the con-tainment building, which con. It is the second time the plant oil spot ,and fell into the sump.
the reactor, Fort said. haa been shut down in recent The accident was unrelated to months, Cook said, and the third the leak that forced the shut-Wowever, Fort said the plant would be producing electricity time ometals called an unusual down, omeials said. ,
eventeme The sump contained water back up to 80 percent of its .
Fort ' it is fairly routine for from a coupling that had broken .
capacity by N unusual events to be declared loose tn a steam line between a The cosupany stiu plans to go durmg a' plant's beginning opera- feed pump and the generator's into coaunercial operation at the turbme. Fort said.
end of June, he said. . Si*"- ,
Though the plant is not in An Ochener spokesman sai,d -
'The shutdown of the nuck
=n narcial operation Fort said, Quinn was in the hospital's criti-power plant began at 6 a.m. Set- it la producing electricity that ts- cal care unit.
- urday when a leak was W
- by. plant monitors, Ken Cook,
, LP&L nuclear licensing usanager, asid. The leak was traced to a sshe in a sprey systent insade the cientainment buildmg.
'As a result of the leek, LP&L declared an " unusual event" at
! tr.e plant, the term apphed to the l
%t i.f four emergency designa.
, a at nurisar power plants.
Se emergency wds canceled j
==
l
-j : . . - - EXHIBIT 2 '
C 0F EVEt.T OR UNUSUAL OCCURRENC f - '
This prelimir.ary notsi .ution constitutes EARLY notice of' events of P0blBLE safety or public interest significance. The infonr.ation is as initially received without verification or eveluation, and is basically all that is known by NRC staff on this date. t FACILITY: Louisiana Power & Light Company Licensee Emergency Classification:
Waterford Unit 3 X Notification of Unusual Event Killona, Louisiana Alert Docket No. 50-382 - Site Area Emergency g g3[56 General Emergency Not Applicable
SUBJECT:
STEAM HAMMER IN STEAM SUPPLY LINE TO EMERGENCY FEEDWATER PUMP At approximately 4:35 p.m. (CDT) on May 8, 1985, the emergency feedwater pump AB was started for monthly surveillance. The operators notices a loud noise when opening the A side steam supply valve and assumed it was the opposite line (B side) check valve slamming shut.
N Subsequently, at a:40 p.m. (CDT) on May 9,1985, it was observed that snubbers and several steam line supports were damaged.
The licensee is evaluating the cause of the event.
No press release is planned by the licensee, m-
't The state of Louisiana was notified. '
This information is current as of 2:00 p.m. May 13, 1985. !;
CONTACT: W. A. Crossman, FTS 728-8151. II DISTRIBUTION:
H. ST. MNBB Phillips E/W Willste MAIL: i Chmn Palladino ED0 NRR IE NMSS D0T: Trans Only Com. Zech PA DCS l OIA RES DMB (Original) i Comm. Roberts MPA AEOD ,
Comm. Asselstine ELD VIB INP0 Com. Bernthal NSAC SECY Air Rights !
i ACRS SP CA PDR Regions: Licensee: '
(ReactorLicensees)
DRSP gut W RA WACrossman/lk RDP in S /g3/85 )
.) qb s\
'ph5Q46~850513 m )
'l
EXHIBIT 3 Cunningham, Waterford 3 Tests Slowed By Deposits The Times-Picay'tg (June 4, 1985)
Waterford 3
. tests slowed .
by deposits By LYNN CUNNINGHAM Staff writer Lead deposita discovered this ~
weekend in Waterford 3's genera-tor have forced a three-week delay at the Taft plant, which
, was on the verge of full-power production.
The lead came fmm solder that was exposed to moisture, accord-ing to Ken Cook, s Louisiana Power &Light pokesman Co. for Cook said the company, which a owns the $2.73 billion reactor, is concerned that additional buildup might cause electrical shorts in the generator and require more expensive and lengthy repairs in the future if not taken care of immediately.
The repairs will delay the plant's testing schedule, which was about to enter the final phaw before commercial operation.
However. LP&L spokesman Janas Fort said the company was still shooting for a late June or early July commercial startug i
t l
[ .
e b
i _
EXHIBIT 4 Cunningham, N-Plant Repairs Will Take Three Weeks,"
The Times-Picayune (July 23, 1985)
N-plant .
repasrs will take 3tveeks .
By LYl5N CUNNINSNAAS
- Staff writer The Waterford 3 nuclear reac- Fort saia LP&L had not yet d,etermined the caus,e of the tor in St Charles Parish will be shut down for three weeks while vibrations, but had discovered er,,gmyJ s us.u technicians replace equipment imparable damage, to the largest damaged by intense vibrations rotor m the turbine g prom A.17 system. A spare rotor, m,stock enerator at that closed the plant last Thurs- -
day, a utility spokesman said. the plant, was being prepared for of magnets in the power produc-installatiori, Fort said. ng electrical generator. The tur-James Fort, a spokesman for th2 reactor's owner, Louisiana Thursday's Waterford 3 shut- bine is not in the plant s radioac-Power & Light Co., said it is not down was one of a number of tive area.
known whether the outage will mish,aps to plague the enormous James Wilson, a Nuclear Regu-dilay the pending commercial turbine generator system since latory Commission engineer wh-cperation of the $2.73 billion testing began in December. On supervises Waterford 3's comph,o, Tcft plant. July 14, for example, a computer ance with regulations, said Mon-Waterford 3, which will furnish problem in the turbine's contrd day that the agency is very slectricity to LP&L customers in panel circuit automatically shuc much interested in the Waterford 43 parishes, was scheduled to go Waterford 3 down. 3 problem, but remains in the dark nt 1 L &L res out what into commercial service last week "All plants have problems dur-efter a seven-year delay and run- ing testing," Fort said, "It's part
~
- 8$Vilson said the turbine genera-ning 11, times over its budget. of the plan. The turbine genera-LP&L is asking the Louisiana tor has been sitting for six or tor at Waterford 3 is a standard Public Service Commission for iece of Westinghouse e ipment seven years waiting for Waterford emergency treatment of,ita record 3 to be completed. It's been het is installed at nucIsar and
$468 million rate increase maintamed, but it's a piece of other plants throughout the request, most of which will go to " H d other lant own-equipment that requires the plant [7,'"$h the same equipment pay off the debt it incurred to to be running in order to test it."
build Waterford 3. The turbine is powered by **""e f nd out the cause' On Monday, a team of LP&L high-pressure steam that is end Westinghouse technicians created from contact with fission-continued to survey the demare generated heat. The steam turns c;used by the vibrations, Fort the rotor, which activates a series said. The vibrations, Fort said, were felt by control room techni- See WATERFORD, next page cians 21 feet below ground and 120 feet away from the turbme generator.
While workers at Waterford 3 Am== ambled the turbine's hous-ing and probed the huge equip-ment, parts of the electrical gen-crator were still being examined et the Pittsburgh operations of Westinghouse Electric Co., man-ufacturer of the parta. Fort said LP&L espects to get the parts back sometime this week.
,e. y_ . . . _.
4- ,. 7 ,
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOAla$thETED JSNRC In the Matter of 3
%5 AUG -9 P4 :38 LOUISIANA POWER AND LIGHT COMPANY ) Docket No. 50-382
) CFFiCt C; H & -
(Waterford Steam Electric Station, ) 00ChLTmG & SEi<V! '
ERAtlCH Unit 3) )
Joint Intervenors' Petition for Review has been served this 9th day of August, 1985 by mailing a copy, first class, postage prepaid to the following:
Christine N. Kohl, Chairman Dr. Harry Foreman, Director Atomic Safety and Licensing Administrative Judge Appeal Board University of Minnesota U.S. Nuclear Regulatory Box 395, Mayo Commission Minneapolis, MN 55455
. Washington, D.C. 20555 Dr. W. Reed Johnson *E. Blake, Esq.
Atomic Safety and Licensing B. Churchill, Esq.
Appeal Board Shaw, Pittman, Potts & Trowbridge U.S. Nuclear Regulatory 1800 M Street, N.W.
Commission Washington, D.C. 20036 Washington, D.C. 20555 Howard A. Wilbur Luke B. Fontana, Esq.
Atomic Safety and Licensing 824 Esplanada Avenue Appeal Board New Orleans, LA 70116 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Sheldon J. Wolfe, Esq., Chairman Malcolm Stevenson, Esq.
Administrative Judge Monroe & Lemann Atomic Safety and Licensing 1424 Whitney Building Board New Orleans, LA 70130 U.S. Nuclear Regulatory Commission Washington, D.C. 20555
r Dr. Walter H. Jordon Mr. Gary L. Groesch Administrative Judge 2257 Bayou Road 881 West Outer Drive New Orleans, LA 70119 Oak Ridge, TN 37830 Brian P. Cassidy Ian Douglas Lindsey, Esq.
Regional Counsel 7434 Perkins Road FEMA Suite C John W. McCormack Baton Rouge, LA 70808 Post Office and Courthouse ~
Boston, MA 02109 William J. Guste, Jr., Esq. Atomic Safety an;d Licensing Attorney General for the Appeal Board Panel State of Louisiana U.S. Nuclear Regulatory 234 Loyola Avenue Commission 7th Floor Washington, D.C. 20555 New Orleans, LA 70112 Atomic Safety and Licensing Docketing and Service Section Board Panel Office of the Secretary U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 2L555
- Nunzio J. Palladino, Chairman Carole H. Burstein, Esq.
U.S. Nuclear Pegulatory 445 Walnut Street Commission New Orleans, LA 70118 Washington, D.C. 20555
- Thomas M. Roberts, Commissioner *Sherwin Turk, Esq.
U.S. Nuclear Regulatory Office of Executive Legal Director Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555
- Frederick Bernthal, Commissioner
- James K. Asselstine, Commissioner U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555
- Lando W. Zech, Jr., Commissioner U.S. Nuclear Regulatory Commission Washington, D.C. 20555
- Hand-delivered lAs e e- u
'v Tynne Yernabei SL&
/
/