ML20135F771

Forwards Director'S Decision Re 2.206 Petitions as of Jan 1997 & Ltrs & s,In Response to Ltr from Congressman Saxton Informing That Licensee Had Not Received Decision

ML20135F771
Person / Time
Site:	Oyster Creek
Issue date:	03/06/1997
From:	Milano P NRC (Affiliation Not Assigned)
To:	Decamp W AFFILIATION NOT ASSIGNED
Shared Package
ML20135F773	List: ML20135F771 ML20135F777
References
2.206, NUDOCS 9703140027
Download: ML20135F771 (1)

Text

March 6, 1997 Mr. William decamp, Jr.

Oyster Creek Nuclear Watch P.O. Box 243 Island Heights, NJ 08732

Dear Mr. decamp:

We have received a letter from Congressman Saxton informing us that you had not received the Director's Decision regarding your 2.206 Petitions as of January 1997. In a letter to you dated February 11, 1997, we informed you that the Director's Decision had been sent to you under a cover letter dated December 11, 1996.

Enclosed is a copy of both letters. I regret any inconvenience this may have caused you.

Sincerely, (Original Signed By)

Patrick D. Milano, Acting Project Director Project Directorate I-3 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation

Enclosures:

1. Letter to Mr. decamp dated February 11, 1997 (ACN9702130037)

2. Director's Decision, DD-96-22, dated December 11, 1996 (ACN9612160383) cc: Congressman Jim Saxton Distribution (w/o enclosure)

Docket File (50-219) (w/ encl & incoming)

PUBLIC EDO# G970131 SECY# CRC-97-0186 LCallan AThadani HThompson KCyr EJordan JLieberman PNorry HMiller, RI/0MA JBlaha TTMartin SCollins/FMiraglia WTravers Q RZimmerman

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PMilano CJamerson MThadani MBoyle (MLB4)

DOCUMENT NAME: G:\EATON\ DECAMP TJ ,eceive a copy of thle document,Indcate in the box: "C" = Copy without attachment / enclosure "E* = Copy with attachment / enclosure *N* = No copy ,

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9703140027 970306 PDR ADOCK 05000219 0 PDR

y .. UNITED STATES

.[ B NUCLEAR REZULATORY COMMISSISN f WASHINGTON. D.C. 30006 4001

\***** February 11, 1997 Mr. William decamp, Jr.

Oyster Creek Nuclear Watch P.O. Box 243 Island Heights, NJ 08732

Dear Mr. decamp:

f I am responding to your letter of December 17, 1996, to Chairman Jackson regarding the petitions you filed on May 11, and June 14, 1996, pursuant to Title 10 of the Code of Federal Reaulations, Section 2.206 (10 CFR 2.206).

The Director's Decision (DD-96-22) was sent to you under a cover letter dated December 11, 1996, and responds to your concerns regarding fuel offloading at Oyster Creek Nuclear Generating Station.

Regarding your statement that you had not received a response to your Petition, we note that the project manager for Oyster Creek Nuclear Generating Station apprised you of the status of the Petition in a telephone conversation with you on July 16, 1996, and in a message left on your voice message system on October 8, 1996. As noted above, the Director's Decision that fully responds to your Petition was issued and mailed to you on December 11, 1996.

Another copy of this Director's Decision is enclosed for your use.

Sincerely, Frank J O 4id [g', Acting Director Office of Nucli r Reactor Regulation

Enclosure:

As stated

, m O F

_ _ . _ _ _ _ _ . ~ . _ _ - - - _ - - -

1 mery k UNITED STATES

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. SteeM001

,,, December 11, 1996 Mr. William decamp, Jr.

Dyster Creek Nuclear Watch P.O. Box 243 Island Heights, NJ 08732

Dear Mr:

decamp:

I as responding to the Petitions filed pursuant to Title 10 of the Code of Federal Reaulations, Section 2.206 (10 CFR 2.206), en Nay 11 and June 14,

, 1996, on behalf of Oyster Creek Nuclear Watch. In your Petitions you asked i that the U.S. Nuclear Regulatory Commission (NRC) investigate and require the

correction by GPU Nuclear of a highly inaccurate public statement in the

! " Neighborhood Update," and purportedly false public' testimony given by the j management of GPU Nuclear, and take appropriate disciplinary action.

i Your Petitions were referred to me pursuant to 10 CFR 2.206 of the 1 Commission's regulations. The NRC staff investigated the statements and

testimony as requested by the Petitions and concluded that the assertions of I 1

in the Petition are without merit. l

! For the reasons given in the enclosed Director's Decision (D0-96-22), the I i Petitions are denied. A copy of the decision will be filed with the Secretary i of the Commission for the Commission to review in accordance with 10 CFR 1 2.206(c). As provided by that regulation, the decision will constitute the i final action of the Commission 25 days after the date it is issued unless the

, Commission, on its own motion, institutes a review of the decision within that

time.

J L I have also enclosed a copy of the notice of this Director's Decision that is

being filed with the Office of the Federal Register for publication.

} Sincerely,

)

Frank fra 1 , Acting Director j . Office of Nuc ear Reactor Regulation j Docket No. 50-219 j

Enclosures:

1. Director's Decision (DD-96 22) j 2. Federal Reaister Notice i ccw/ enc 1: See next page i

4 kt Ok- MI Enclosure 2

7 FsTer Yree!X W c Kar G Weing Station cc:

Ernest L. Blake, Jr., Esquire Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW.

Washington, DC 20037 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 BWR Licensing Manager GPU Nuclear Corporation 1 Upper Pond Road Parsippany, NJ 07054 Mayor Lacey Township 818 West Lacey Road Forked River, NJ 08731 Licensing Manager Oyster Creek Nuclear Generating Station Mail Stop: Site Emergency Bldg.

P.O. Box 388 Forked River, NJ 08731 Resident Inspector c/o _ U.S. Nuclear Regulatory Commission P.O. Box 445 Forked River, NJ 08731 Kent Tosch, Chief New Jersey Department of Environmental Protection Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 Mr. Michael B. Roche Vice President and Director GPU Nuclear Corporation Oyster Creek Nuclear Generating Station P.O. Box 388 Forked River, NJ 08731 O

i s l

f i-i 7590-01-P l D0 22 l UNITED STATES OF AMERICA i NUCLEAR REGULATORY Com !SSION

0FFICE OF NUCLEAR REACTOR REGULATION 1

Frank J. Miraglia, Acting Director j In the Matter of )

GPU NUCLEAR CORPORATION

)

l 0YSTER CREEK NUCLEAR GENERATING STATION ) Docket No. 50-219

j. .

DIRECTOR'S DECISION UNDER 10 CFR 2.206 l

i i I. INTRODUCTION 1

j By letters dated May 11 and June 14, 1996, Mr. William decamp, Jr.,

l requested on behalf of Oyster Creek Nuclear Watch (the Petitioner) that the l U.S. Nuclear Regulatory Commission (NRC or Commission) take action to 4

' investigate statements made by GPU Nuclear Corporation (GPU) in the April 1996 i publication " Neighborhood Update" (the licensee's news magazine) and during sworn testimony on March 7, 1996, before the Lacey Township Zoning Board of Adjustment (the Zoning Board). The Petitioner asserts that the statements are false. The Petitioner further requests that NRC take appropriate disciplinary action against GPU management. The Petitioner's requests are being treated as Petitions pursuant to Section 2.206 of Title 10 of the Code of Federal Renulations (10 CFR 2.206).

The specific statements of concerns are (1) the statement in the

" Neighborhood Update" that GPU and the Commission agree that a license amendment request that involves the movement of spent fuel from the Oyster Creek Nuclear Generating Station spent fuel pool to the storage facility while the plant is at power "is not a safety issue but a procedural one" and (2) a

% i 2%OM  % PP - . ._ . _ .

4 sworn statement by Mr. Barton, who was the Director of the Oyster Creek Nuclear Generating Station, before the Zoning Board that it is unsafe to operate the Oyster Creek reactor without full core offload capacity. The Petitioner, furthermore, requests that if no special situation is found that prevents Oyster Creek from operating without full offload capacity, the Commission take appropriate disciplinary action against GPU management for

neaking a falso statement under oath.'

l j For the reasons stated below, I an denying the~ relief requested by the i

t Petitioner.

II. DISCUSSION i

! A. GPU statement that the movement of the fuel raises a procedural issue,

not a safety issue.

As a basis for the request regarding the first concern that the

{ statement in the " Neighborhood Update" is untrue, Petitioner referenced the

! following excerpts from NRC Bulletin 96-02 (NRCB 96-02), " Movement of Heavy Loads Over Spent Fuel, Over Fuel in the Reactor Core, or Over Safety-Related j Equipment," of April 11, 1996:

t

! The NRC staff audited both the initial and updated 10 CFR 50.59 i evaluations performed by the licensee (GPU Nuclear) and determined j that the proposed cask movement activities represent an unreviewed

. safety question that should be submitted to the NRC for review and I approval pursuant to the requirements of 10 CFR 50.59 and

50.90....Accordingly, as defined in 10 C.F.R. 50.59(c), if an l ' The petitioner is not asserting that the'11censee has' provided ~ false i information to the Nuclear Regulatory Commission. A licensee's obligation to i ensure the completeness and accuracy of its communications with the Commission

is set forth in 10 CFR 50.9(a). This regulation requires, in part, that l "[i'nformation provided to the Commission by an applicant for a license or by i a 1; consee or information required by statute or by the Comeission's i regulations, orders, or license conditions to be maintained by the applicant i or the licensee shall be complete and accurate in all material respects."

l

> j

! l i'

i activity is found to involve an unreviewed safety question, an

application for a license amendment must be filed with the Commission pursuant to 10 CFR 50.90.

l

GPU met with the NRC staff on November 19, 1993, to discuss plans for

using the reactor building crane to move spent fuel out of the spent. fuel pool 1

j in a transfer cask for transportation to the dry cask storage facility during power operations at Oyster Creek. During the discussions, the NRC staff

]

raised concerns regarding the use of the crane and its ability to meet the heavy load criteria of NUREG-0612 " Control of Heavy Loads at Nuclear Power

Plants." GPU indicated that this special application of the crane would be

! evaluated pursuant to 10 CFR 50.59.8 NRC stated that it would conduct an '

i audit of the 50.59 evaluation, i

j In April 1995, GPU informed NRC that the 50.59 evaluation for use of the l crane to move the transfer cask was complete. On Nay 2 and 3, June 12, and l October 12 and 13, 1995, the NRC staff conducted onsite audits and met with l GPU at Oyster Creek regarding the use of the crane. On November 2, 1995, in a 4

l telephone call between the NRC staff and Mr. Keaten, Vice President and l.

Director, Technical Functions, GPU, the NRC staff advised GPU that the staff's concerns regarding the use of the non-single-failure-proof crane to move the 100-ton transfer cask while the plant was at power had not been resolved by I

i 2 10 CFR 50.59 provides, in part, that a licensee may make changes in the i facility or procedures as defined in the safety analysis report without prior Commission approval unless the proposed change involves a. change in the

technical specifications or an unreviewed safety question. ~The regulation,

furthermore, requires the licensee to prepare and maintain a written safety 2 evaluation addressing the issue of whether the proposal involves an unreviewed i safety question. A proposal is deemed to involve an unreviewed safety j question if (1) it involves an increase in the probability or consequences of

. an accident previously evaluated; or (2) creates the possibility of a new or

! different kind of accident from any accident previously evaluated; or (3) i involves a reduction in a margin of safety as defined in the basis for any j technical specification, i

a W

1 .

_4-j its 50.59 evaluation. Specifically, the staff was concerned that the activity 1

involved the movement of loads heavier than previously considered in the final j safety analysis report (FSAR) and, therefore, might reduce the margin of l safety, and that a load drop in the reactor building might result in consequences greater than previously evaluated in the FSAR and, therefore, may i

j pose an unreviewed safety question.

Consequently, Mr. Keaten advised the staff that GPU was considering a j plant modification, including reactor building crane ~ upgrades, that would 1

l address the staff's concerns.

j The NRC staff inspected the licensee's updated 10 CFR 50.59 evaluation

} which considered the reactor building crane upgrades. The NRC staff's l inspections included sending a team to Oyster Creek. The staff concluded that its safety concerns had been addressed and resolved. The NRC staff also

{

l determined that the licensee's planned movement of spent fuel to the dry j storage facility during plant operation was safe and in accordance with all i

j license requirements. Notwithstanding the technical acceptability of the s

j licensee's methodology and analysis in the updated 10 CFR 50.59 evaluation, i

l NRC staff determined that since the possibility of an unreviewed safety i

! question (USQ) had been involved before the licensee made modifications to upgrade the reactor building crane, GPU must submit a license amendment l application for the proposed cask movement activities. At the public meeting i

i on February 29, 1996, GPU was informed by the NRC staff that an amendment was required. When the NRC receives an amendment application, it is required to

) follow specific procedures set forth in 10 CFR 50.91.3 h

3

! 10 CFR 50.91 requires the Commission to use specified procedures when

it receives an application requesting an amendment to an operating license 4 including procedures that concern consulting the State in which the facility

.,~.n -

~ _ _ _ . _ _ . , _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ .___ _ ._ _

5

!i l

Accordingly, the staff finds, after its review and evaluation of the licensee's proposed action, that there are no safety issues preventing the f adoption of the proposal, but procedures require amendment approval before the

proposal can be implemented. .

j B. GPU statement concerning safe operation and full core discharge capability.

i j

As basis for the Petitioner's request concerning GPU statements about safety and full core discharge capability, the Petitioner sets forth excerpts i frem Mr. Barton's testimony of March 7,1994, before the Zoning Board, and l states that "the NRC ruled in February 1985 in 10 CFR Part 53 that reactors i

may safely be run without full core offload capacity." ' I i

The Petitioner quoted in a letter and enclosed, underlined in red, l

copied portions of Mr. Barton's testimony as follows:

I If we do not install the dry spent fuel storage modules by 1996, i the plant would not have the capacity of totally off-loading fuel

from the reactor to the in-plant spent fuel pools. (transcript pp.

j 94-95) j In order to operate safely we should be able to remove this fuel i

from the reactor and store it in the soent storace cool...

} (transcript p. 95) f.

i Without dry storage and without the ability to remove this fuel from the reactor, the plant would not be able to operate.

j . (transcript p. 95) 1 Mr. Barton's full testimony in context with the Petitioner's extracted 1

j quotes is as follows:

i is located and procedures concerning providing notification to the public of i the licensee's amendment, the Comission's findings or determinations regarding the amendment, and opportunity for a hearing.

i 'The Commission has stated that a full core reserve capability is not an j NRC safety requirement. 50 FR 5548, 5549 (1985) i l

_._ _ r _ _ _ _ _ _ _ _ _ _ _ __ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ ._.

1

~ '

i i

The fall of 1996 is a critical time for plant operations. If we do not install the dry spent fuel storage modules by 1996, the l

i plant would not have the capability of totally off-loading fuel from the reactor to the in-plant spent fuel pool. This is not a i

desirable operating configuratir;n, should the plant need to i conduct internal inspections of the reactor vessel that would

require fuel to be removed from the reactor. In order to operate

safely we should be able i.o remove this fuel from the reactor and j i store it in the spent fuel storage pool inside the plant, and i

after 1996 we will not have the flexibility to do that. Without l dry storage and without the ability to remove all the fuel from the reactor, the plant would not be able to operate. (transcript j p. 95) i Taken in context, it appears that what Mr. Barton is stating is that he l j

is concerned with operations management due to the inability to have full core

] off-load capability and that having full core off-load capability can in l

t certain situations enhance safety. The plant has the capacity to complete one l

more refueling operation before they will not be able to operate without dry storage capability as Mr. Barton stated. The Commission has stated a similar j

view with regard to the issue of maintaining full core reserve storage capability:

l i

{ While a full core reserve capability is not an NRC licensing or j safety requirement, maintenance of full core reserve would enhance

safety to some extent, and would also be needed to prevent extended reactor outages in the event a core must be discharged in ordertoinspectthereactorpressurevesselanyperformother l routine and unscheduled maintenance operations The December 6,1993, Zoning Board hearing testimony of Mr. Gordon Bond, f Directo'r of Nuclear Analysis and Fuel for GPU Nuclear, also supports the view i

l. that the concern is with operations management. When asked whether it is j important to maintain full core discharge capability, Mr. Bond responded as i

follows

j s The NRC's Statements of Consideration concerning the amendment of

10 CFR Parts 1 and 53 entitled, " Criteria and Procedures for Deterrining the 1 Adequacy of Available Spent Nuclear Fuel Storage Capacity," 50 FR =a48, 5549

. (1985)

-_ _ _ _ _ _ _ _ ~ _ _ _ _ _ . __ _ _ _ _ _ ___ _ _. _ __ _. _ >_. _ .. _ .__ _

i j l

l

• i.

i We believe it is. It's not required by Federal Regulations, but ,

i we believe it's prudent to allow sufficient reserve capacity in '

4 our pool to be able to offload the core any time that we may have

, to. For example, you may want to do some inspections inside the vessel, and to do that you'll need to remove all of the fuel.

(transcript p. 32) l Accordingly, the staff finds that the statements and remarks of Mr. Barton in l their context are not false or misleading.

l t

V. CONCLUSION l The NRC staff has reviewed the statements made by GPU in the April 1996 4

l

" Neighborhood Update" (the licensee's news magazine) and the testimony of GPU managers before a local Zoning Board and concluded that the assertions raised 4

j by the Petitioner are without merit and that there is no basis to take any i

j action against GPU. Accordingly, the Petitioner's requests are denied.

I A copy of this Director's Decision will be filed with the Secretary of i

i 3 the Commission for the Commission to review as stated in 10 CFR 2.206(c).

! This Decision will become the final action of the Commission 25 days after issuance unless the Commission, on its own motion, institutes a review of the

! Decision within that time.

i

! FOR THE NUCLEAR REGULATORY COMMISSION Frank F Mir a, Acting Director Office of Nuc ear Reactor Regulation Dated at Rockville, Maryland, this 11th day of December 1996

~ ~

!* We believe it is. It's not required by Federal Regulations, but

. we believe it's prudent to allow sufficient reserve capacity in

.- our pool to be able to offload the core any time that we may have to. For example, you may want to do some inspections inside the vessel, and to do that you'll need to remove all of the fuel.

j (transcript p. 32)

Accordingly, the staff finds that the statements and remarks of Mr. Barton in j their context are not false or misleading.

t j V. CONCLUSION j The NRC staff has reviewed the statements made by GPU in the April 1%G l " Neighborhood Update" (the licensee's news magazine) and the testimony of GPU i ,

j managers before a local Zoning Board and concluded that the assertions raised by the Petitioner are without merit and that there is no basis to take any j action against GPU. Accordingly, the Petitioner's requests are denied.

l A copy of this Director's Decision will be filed with the Secretary of 3

the Commission for the Commission to review as stated in 10 CFR 2.206(c).

This Decision will become the final action of the Commission 25 days after issuance unless the Commission, on its own motion, institutes a review of the i

Decision within that time.

FOR THE NUCLEAR REGULATORY COP 911SSION OrTritantofsnedby Frank J. Miraglia Frank J. Miraglia, Acting Director Office of Nuclear Reactor Regulation Dated at Rockville, Maryland, this 11th day of December 1996

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7590-01-P 4

U.S. NUCLEAR REGULATORY C0fetISSION j GPU NUCLEAR CORPORATION OYSTER CREEK NUCLEAR GENERATING STATION i

i DOCKET NO. 50-219 i

ISSUANCE OF DIRECTOR'S DECISION UNDER 10 CFR 2.206 Notice is hereby given that by letters dated May 11 and June 14, 1996, I

Mr. decamp, on behalf of Oyster Creek Nuclear Watch.(Petitioner), requested

NRC, pursuant to 10 CFR 2.206, to investigate and correct a highly inaccurate public statement in the " Neighborhood Update" (the licensee's news magazine) and apparently false public testimony given by GPU management at a local l zoning board hearing and to take appropriate disciplinary action in the j natter. Specifically, Petitioner's concerns relate to (1) the statement that l GPU and the Commission agree that a license amendment request that involves j the movement of spent fuel from the Oyster Creek Nuclear Generating Station a

i spent fuel pool to the storage facility while the plant is at power "is not a j safety issue but a procedural one" and (2) whether there is some special j factor at Oyster Creek that would indeed justify Mr. Barton's sworn statement t

] that it is unsafe to operate the Oyster Creek reactor without full core a

j offload capacity. If no special situation is found that prevents 0yster Creek from operating without full offload capacity, Petitioner requests that the

, Commission take appropriate disciplinary action against GPU Nuclear management

! for making a false statement under. cath. - - -

a

As a basis for the request regarding the first concern that the statement in the " Neighborhood Update" is untrue, Petitioner referenced the f

following excerpts from NRC Bulletin 96-02 (NRCB 96-02) of April 11, 1996:

j i

i 4

]i.

i l-1, 8 3 .g. .

The NRC staff audited both the initial and updated 10 CFR 50.59 '

{

evaluations performed by the licensee (GPU Nuclear] and determined thM the proposed cask movement activities represent an unreviewed safety question that should be submitted to the NRC for review and approval pursuant to the requirements of 10 CFR 50.59 and i

50.90....Accordingly, as defined in 10 CFR 50.59(c), if an activity is found to involve an unreviewed safety question, an

! . application for a license amendment must be filed with the

Commission pursuant to 10 CFR 50.90.

+

As a basis for the Petitioner's other concerns, the Petitioner sets

(

l forth the relevant excerpts from Mr. Barton's testimony of March 7,1994, and states that "the NRC ruled in February 1985 in 10 CFR Part 53 that reactors

{ may safely be run without full core offload capacity."

4 i

Notice is hereby given that by a Director's Decision (DD 96- 24 dated i

j Dece$er 11, 1996, the Acting Director, Office of Nuclear Reactor Regulation.

l has denied the Petitions. The staff concluded that the issues raised by the i

l. Petitioner are without merit and that there is no basis to take disciplinary

action against GPU, as explained in the "Directo.*'s Decision Pursuant to 10 CFR 2.206" (DD 96 22), the complete text of which follows this notice and is l

l available for inspection at the Commission's Public Document Room at 2120 L Street, W, Washington DC, and at the local public document room located at 4

l Ocean County Library, Reference Department,101 Washington Street, Tom's l River, NJ.

l FOR THE NUCLEAR REGULATORY COMISSION

! Frank J. NG(glh, ting Director i Office of Nuclear Reactor Regulation 1 -

1 Dated at Rockville, Maryland,

[:

this11th day of December 1996.

Attachment:

00-96-22 I

k i- ~

+ ' '

fnr -

EDO Principal Correspondence Control FROM DUE:.03/12/97 EDO CONTROL: 'G970131 DOC DT: 02/10/97 Rnp. Jim Saxton FINAL REPLY:

LTO:

Chairman Jackson

FOR SIGNATURE OF : ** GRN **

CRC NO: .97-0186 Office Director 4

DESC:

ROUTING:

4 OYSTER CREEK NUCLEAR PLANT Collins dtCAMP, JR.) Jordan 4

Thompson  !

Norry.-

, Blaha Cyr, OGC DATE: 02/27/97- Miller, RI <

Lieberman, OE

, ASSIGNED TO: CONTACT: '

i I

_NRR Collins SPECIAL INSTRUCTIONS OR REMARKS:

Ra: pond direct to constituent with cc'to Rop. Saxton. (Ref. GT96452)

ACTION NRR RECEIVED: FEBRUARY 27, 1997 NRR ACTION: DRPE:VARGA DUE TO NRR D! RECTOR'S OFFl:E NRR ROUTING: COLLINS MIRAGLIA BY M~) J '1'77 THADANI /

ZIMMERMAN MARTIN TRAVERS B0HRER

. . . .. .. -.. - .. .-. . , ~ . - ~ . . . , ~ . . . . . . . - .

OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET PAPER NUMBER: CRC-97-0186 LOGGING DATE: Feb 25 97' ACTION OFFICE: EDO

., AUTHOR:' REP JIM SAXTON AFFILIATION: U.S. HOUSE OF REPRESENTATIVES ADDRESSEE: CHAIRMAN JACKSON LETTER DATE: Feb 10 97 FILE CODE: IDR-5 OYSTER CREEK

SUBJECT:

OYSTER CREEK ACTION:' Direct Reply DISTRIBUTION: CHAIRMAN l l

SPECIAL HANDLING: OCA TO-ACK

' CONSTITUENT: WILLIAM DECAMP  !

1 NOTES: '

DATE DUE: Mar 12 97 SIGNATURE: . DATE SIGNED

• l AFFILIATION: I i

i l

l EDO -- G970131