ML20148L997
| ML20148L997 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/30/1988 |
| From: | Johari Moore NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#288-5973 CPA, OL, NUDOCS 8804050085 | |
| Download: ML20148L997 (16) | |
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UNITED STATES OF AMERICA . _
NUCLEAR REGULATORY COMMISSION '88 APR -1 P 3 :35 BEFORE THE ATOMIC SAFETY AND LICENSING ROARD grict c; Sg -w u00KEI Ni r. . t i, 3u w..
In the Matter of )
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Docket Nose 50-445-OL TEXAS UTILITIES ELECTRIC )
) 50-445-CPA (Comanche Peak Steam Electric )
Station, Units 1 and 2) )
NRC GTAFF'S RFSPONSE IN SUPPORT OF APPLICANTS' MOTION TO CONSOLIDATE PROCF.EDINGS
- 1. INTRODUCTION On March 8, 1988, Applicants filed a motion pursuant to 10 C.F.R. 6 2.716 of the Commission's regulations to consolidate the Comanche Peak Operating License and Construction Permit Amendment proceedings .
"Applicants' Motion to Consolidate Proceedings" (March 8, 1988)
[ hereinafter Appilcants' Motion]. For the reasons set forth below, the Staff of the Nuclear Regulatory Commission (Staff) supports Applicants' motion.
- 11. BACKCROUND, By order of May 2,1986, the Licensing Board designated to preside over the Construction Permit Amendment proceeding, which is the same board which presides over the Operating License proceeding, admitted Case and Meddle Cregory as consolidated intervenors in the Construction Permit amendment proceeding , and admitted a consolidated contention.
Special Prehearing Conference Memorandum and Order (Concerning Parties and Contentions), (May 2,1986) . The Staff and the Applicants appealed 8804050005 000330 5 PDR ADOCK O psi
the Licensing Board's ruling. "NRC Staff's Notice of Appeal from Atomic Safety and Licensing Board Memorandum and Order Concerning Parties and Contentions and Supporting Brief" (May 12, 1986): "On Appeal From the Special Prehearing Conference Order ( ASLBP No. 86-528-02-CPA) of the Atomic Safety and Licensing Board Entered May 2, 1986 Brief of Applicants-Appellants" (May 12, 1986). The Appeal Board certified a cues'ilon to the Commission as to whether the contention admitted by the Licensing Board was precluded from admission based on the decision in Washington Public Power Supply System (WPPSS Nuclear Project, Nos. 1 and 2), Cl.1-82-29,16 NRC 1221,1230-31 (1982). Memorandum and Order (July 2, 1986) (unpublished). The Corrmission determined that the admitted contention, which was based solely on the Applicants' past conduct, would not be sufficient to defeat a request for construction permit extension even if proven to be correct. Texas Utilities Electric Company , et al. (Comanche Peak Steam Electric Station, Unit 1),
CLI-86-15, 24 NRC 397, 402 (1986) .
Shortly after itsoonce of the Commission's decision in CLi-86-15, Consolidated intervenors filed a motion with the Licensing Board for admission of amended contentions or, in the alternative, for reconsidera-tion of the Licensing Board's previous rulings with respect to other contentions. "Motion to Admit Amended Contentions or, in The Alternative, For Reconsideration of Previously Denied Contentions" (September 30, 1986). The Licensing Board admitted Contention 2 as amended. Texas Utilities Electric Company, et al. (Comanche Peak Steam
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Electric Station, Unit 1), LBP-86-36A, 24 NP.C 575 (1986) . l- The Staff 2/ The Licensing and the Applicants appealed this ruling as well .
Board's decision was upheld. Texas Utilities Electric Company,.et al.
(Comanche Peak Steam Electric Station, Unit 1), ALAB-868, 25 NRC 912 (1987). ,
Applicants have fied the instant motion to consolidate the Cons'truction Permit Extension proceeding and the ongoing Operating License proceeding. The grounds for the motion are that: the two pro-ceedings raise common issues of law and fact, the consolidation would not ;
limit the Board's authority to structure appropriate relief with respect either to the construction permit extension or the operating license, the rights of the parties would not be adversefy affected and consolidation would not cause delay. 3/ Applicants' Motion at 1-4, The Steff agrees.
1/ Contention 2 states:
The delay on construction of Unit 1 was caused by Appli-cants' intentional conduct, which had no valid purpose and was the result of corporate policies which have not been discarded or repudiated by Applicants.
2/ "NRC Staff Brief in Support of Appeal From Atorile Safety and Licensing Board Memorandum and Order Admitting Amended Conten-tions" (November 13, 1986): "On Appeal From a Memorandum and Order of the Atomic Safety and Licensing Board Entered October 30, 1986 Brief of Permittees" (November 10, 1986). .
3/ The only contention remaining for litigation in the operating license proceeding states:
The Applicants' failure to adhere to the quality assurance / l quality control provisions required by the construction ;
permits for Comanche Peak, Units 1 and 2, and the requirements of Appendix B to 10 C.F.R. Part 50. and the construction practices employed, specifically in regard to (FOOTNOTE CONTINUED ON NEXT PAGE)
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In addition, the Staff submits that consolidation would allow the Staff to make the best use of its resources.
Ill. AP.CUMENT A. Standards for Consolidation The Commission's regulations specifically permit the consolidation of proceedings if such consolidation is found to be conducive to the efficient conduct of the Board's business and to the ends of justice. 10 C.F.R. 5 2.716. This Commission regulation has been construed to mirror Rule 42(a) of the Federal Rules of Civil Procedure. Edlow international Co.
(SNM Export), CLI-77-16, 5 NRC 1327, 1328 (1977). Therefore, in judging what factors should oe considered in determining whether to order consolidation, a Board should be guided by Federal cases on this matter. M. , at 1327, 1328. See, also, Dairyland Power Cooperative (Lacrosse Boiling Water Reactor), LBP-81-31,14 NRC 375 (1981).
In deciding whether to consolidate two proceedings, the Commission and licensing boards first determine whether the proceedings involve common auestions of law and fact. The federal courts have dealt with the (FOOTNOTE CONTINUED FROM PREVIOUS PAGE) concrete work, mortar bloc ks , steel, fracture toughness testing, expansion joints, placement of the reactor vessel for Unit 2, welding, inspection and testing, materials used, craft labor qualifications and working conditions (as they may affect QA/OC) and training and organization of QA/QC personnel, have raised substantial questions as to the adequacy of the construction of the facility. As a result, the Commission cannot make the findings required by 10 C.F.R. 50.57(a) necessary for issuance of an operating license for Comanche Peak.
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specific question of whether all of the issues in the two proceedings of which consolidation is scught must be identical in order for the .
proceedings to be consolidated. As Applicants have pointed out, it has been held that identity of issues is not essential. Applicants' 14otion at 3 citing Thayer v. Shearson, Loeb, Rhodes, Inc. , 99 F.R.D. 522, 523 (W.D.N.Y. 1983): Rohm & Haas Co. v. Mobil Oil Corp. , 525 F.Supp.
1298', 1310 (D. Del . 1981) . The fact that there are other issues in the proceedings than those in common does not preclude consolidation. 5 Moore's Federal Practice i 42.02[3] (2d ed.1984). What seems to be of concern to the courts is whether the evidence to be presented in the two proceedings would overlap and whether consolidation would avoid the necessity for the parties to present duplicative testimony. See, Thayer v. Shearson, 99 F.R.D. at 523.
The Commission and Licensing Poards also consider whether the rights of the parties would be adversely affected by the consolidation, and whether the consolidation would result in unreasonable delay of one of the proceedings. Lacrosse, supra,14 NRC at 378 Alabama Power Co.
( Allan R. Barton Nucietr Plant, Units 1 and 2) and (Joseph IA. Farley Nuclear Plant, Units 1 and 2), CLi-75-12, 2 NRC 373, 374 (1975).
Consolidation has been ordered where there is not complete identity of parties, and where to consolidate the proceedings would delay one of the proceedingr to sone extent. LBP-81-31, supra,14 NRC at 377-78.
The two proceedings in question here involve the same facility and thus the same licensee and many common issues of law and fact. The parties to the two proceedings are identical. There is no indication that
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either proceeding would be substantlafly delayed by the consolidation.
Therefore, consolidation is warranted.
B. The issues involved in the Construction Permit Amendment Proceeding and the Operating License Proceeding Are Substantially the Same Applicants argue that the issues in the CPA and OL proceedings are subs'tantially the same. Applicants' Motion at 5. The Staff agrees. As Applicants point out, Contention 2 in the CPA proceeding has two parts, both of which must be established for Intervenor to prevail on the claim that there was no good cause for the extension. First, the M. at 5-6.
contention alleges that the delay in the construction of Unit 1 was due to a corporate policy of iritentionally violating Commission requirements to speed up the construction of Unit 1. Second, the contention alleges that e this corporate policy has not been discarded or repudiated.
The Licensing Board Interpreted Contention 2 in light of the ellegations which were already admitted in the proceeding, and set them forth in Appendix A to its order. LBP-86-36A, supra, 24 NRC at 583.
The issues raised with respect to the first par t of the contention are that ,
Applicants deliberately failed to take positive action to improve their i QA/OC program in the face of criticism of the program, and that ;
Applicants have failed to properly design their plant. See LBP-86-3fiA, ,
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i 24 NRC at 583. Specifically , Intervenor argues that Applicants dia not design the Comanche Peak plant in accordance with fundamental j engineering principles, they ignored criticisms of the design, and l Applicants have failed to comply with NRC requirements. Id_. at 584. As stated above, the second part of Contention 2 of the CPA proceeding i
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l alleges that Applicants have not repudiated their earlier policies. M. at 584. The bases for this portion of the contention are that the people in !
management positions responsible for the original policy are, for the most part, still in place. Next, intervenor alleges that the program being ,
implemented by Applicants for the identification and correction of deficiencies is, in fact , a continuation of the original policies. M. at 584. The issues specifically raised concern whether the CPRT Is truly independent of TUEC, and whether the CPRT methodology is technically correct and being implemented correctly. M.at584-585.
Contention 5 in the OL proceeding challenges the Applicants' implementation of their QA/QC program for construction in certain specified areas. This contention has been broadened during the proceeding to include plant design issues as well . Texas Utilities Generating Co. , et al. (Comanche Peak Steam Electric Station, Units 1 and 2), LBP-83-81,18 NRC 1410,1413-16 (1983). Both Contention 2 and Contention 5 will require the Board to hear much of the same evidence.
For example, there could be instances where evidence of the adequacy of a alven portion of the historical QA/OC program might be offered to resolve a particular issue. Such evidence could relate to both the first part of Contention 2 and to Contention 5.
Applicants have pointed to what they consider to be one significant difference between Contention 2 and Contention 5. Applicants' Motion at
- 8. This difference arises from their position that ,t opticants' past management practices are not propert. considered under Contention 5.
M. As Applicants noted, the Licensii . Board does not .%rce with this position. .i d .
The Staff has previously argued that although management
character and competence is not an issue under Contention 5 on which the Board must make specific findings , issues concerning management activities with respect to specific deficiencies have been raised by the evidence in the record on Contention 5. See, "NRC Staff Reply to i Applicants' Petition For Directed Certification of Licensing Board Order of October 2, 1985" (November 6, 1985). This evidence could also be relevant to the first part of Contention 2. In addition, if it is necessary to present evidence on the root cause of a particular problem in order to determine whether the corrective action being taken is sufficiently comprehensive, and if that cause were determined to involve management practices, evidence could be presented relating to past management practices in connection with the resolution of Contention 5. This evidence could thus be relevant to both Contention 5 and to the first part of Contention 2. The Staff agrees with Applicants that consolidation would eliminate disputes as to the admissibility of such evidence in relation to Contention 5.
The evidence concerning the extent and adequacy of the Applicants' 1 programs to correct previously identified deficiencies and to determine whether there is reasonable assurance that Comanche Peak can be operated safely would be the same in many respects as the evidence offered to show whether Applicants have repudiated their alleged policy of
] Ignoring NRC requirements. The bases for Contention 2 specifically refer to aspects of the CPRT program, such as the adequacy of the reinspec-tict efforts, which will be looked at by the Staff and by the Board to determine whether Comanche Peak's structures, systems and components are designed and constructed so as to perform their safety functions.
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_9 The evidence of repudiation and the evidence concerning the actions taken tiy Applicants to insure compliance with NRC requirements would of necessity be the same. Therefore, it would be duplicative to have two proceedings in which the same evidence would be heard. If there are some issues which would not necessarily be common to a decision on both contentions, these issues could be accommodated in the consolidated proceeding since the parties are the same. Thus, consolidation is warranted.
C. Consolidation Would Not Cause Substantial Delay of Either Proceeding One of the factors to be considered in determining whether two proceedings should be consolidated is whether one or both of the proceedings would be delayed by consolidation. The Staff agrees with Applicants that consolidation should not result in the delay of either proceeding . Discovery has been continuing in both proceedings. The Staff sees no reason why di=covery on both Contention 2 and Contention 5 could not continue using the litigation schedule in place for the OL proceeding. As discussed above, the evidence to be presented on the two contentions is very similar. Therefore, discovery on both contentions should be very similar. There is room in the litigation schedule for the disposition of issues relating to both contentions should a party wish to file motions for summary disposition, as Applicants argue. Applicants' Motion at 19. There is no indication that consolidation would delay a 1
hearing in either proceeding to the extent that consolidation would not be appropriate.
D. Consolidation Would Result in The Efficient Use of the Parties' Resources Due to the similarity of the evidence to be presented in these two proceedings, consolidation would result in the efficient use of the parties' resources. Here, the parties to the two proceedings are identical. Many of +he witnesses for these parties would be the same for large portions of bc ! contentions. Also, consolidation would result in a joint hearing which would reduce the drain on all of the parties' resources. As far as the Staff is concerned, consolidation would provide the means for the Staff to make optimal use of the resources which are available to it for the Comanche Peak project. Thus, the Staff submits that consolidation is appropriate and warranted.
IV. CONCLUSION For the reasons set forth above, the Staff concludes that Applicants' motion for consolidation of the Comanche Peak CPA and OL proceedings should be granted.
Respectfully submitted, Ybk&W Janice E. Moore Counsel for NRC Staff l
Dated at Rockville, Maryland this 30th day of March,1988 l
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D0LKEIED
'J5NRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ,
p .-) P3 :35 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFICE Of bnt IASY 00CKEithG & SEI'VICL ON# #
in the Matter of )
)
TEXAS UTILITIES ELECTRIC ) Docket Nos. 50-445-OL COMPANY, ET AL. ) 5 0-446-O L
) 50-445-CPA (Comanche Peak Steam Electric )
Station, Units 1 and 2) )
NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney enters an appearance in the above-captioned matter, in accordance with 9 2.713(b),
10 C.F.R. , Part 2, the following information is provided:
Name: Bernard M. Bordenick Address: U.S. Nuclear Regulatory Commission O ffice,- of the General Counsel Washington, D.C. 20555 Telephone Number: (301) 491-1529 Admissions: United States Supreme Court United Sttres Court of Appeals for the D.C. Court D.C. Court of Appeals i
Names of Party: NRC Staff l
Respectfully submitted, k
Bernard M. Bordehick Counsel for NRC Staff 1
Dated at Rockville, Maryland this 30th day of March,1988 l
- 00CKEiE0 UdNiiC 1B APR -1 P3 :36 0FFICE Or SE Citt i An f 00CKEliNG & SERVICI.
BRANCH UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of I
)
TEXAS UTILITIES ELECTRIC ) Docket Nos. 50-445-OL COMPANY, ET AL. -
) 50-446-OL
) 50-445-CPA (Comanche Peak Steam Electric )
. Station, Units 1 and 2) )
NOTICE OF WITHDRAWAL Notice is hereby given that effective March 31, 1988, I will withdraw my appearance in the above captioned proceeding. All mail and service lists should be amended to delete my narr,e after that cate.
Mitzil A. ' Young Counhel for NRC Staff Dated at Rockville, Maryland this 30th day of March,1988
5973 .
OOCKETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION . ..
'88 APR -1 P3 :35 I BEFORE THE ATOMIC SAFETY AND LICENSING BOARD -
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in the Matter of ) [., _
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TEXAS UTILITIES ELECTRIC ) Docket Nos. 50-4 45 -O L COMPANY, ET AL. ) 50-446-OL
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(Comanche Peak Steam Electric )
Station, Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF'S RESPONSE IN SUPPORT OF APPLICANTS' MOTION TO CONSOLIDATE PROCEEDINGS", "NOTICE OF APPEARANCE" for Bernard M. Bordenick and "NOTICE OF WITHDRAWAL" for Mitzi A. Young in the above-captioned proceedina have been served on the following by deposit in the United States mall, first class, or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's Internal mail system, this 30th day of March,1988:
Pcter B. Bloch, Esq. , Chairman
- Mrs. Juanita Ellis Administrative Judge President, CASE Atomic Safety and Licensing Board 1426 South Polk Street U.S. b.uclear Regulatory Commission Dallas, TX 75224 Washington, DC 20555 Renea Hicks, Esq.
l Dr. Kenneth A. McCollom Assistant Attorney General Administrative Judge Environmental Protection Division l 1107 West Knapp P.O. Box 12548, Capital Station Stillwater, OK 74075 Austin, TX 78711 Elizabeth B. Johnson Robert A. Wooldridge, Esq.
! Administrative Judge Worsham, Forsythe, Samples Oak Ridge National Laboratory & Wooldridge P.O. Box X, Building 3500 2001 Bryan Tower, Suite 3200 Oak Ridge, TN 37830 Dallas, TX 75201 l
j Dr. Walter H. Jordan Joseph Gallo, Esq.
l Administrative Judge Hopkins & Sutter i
881 West Outer Drive Suite 1250 l
Oak Ridge, TN 3783'i 1050 Connecticut Avenue, N.W.
Washington, DC 20036 l
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Billie Pirner Garde Mr. W. G. Counsil GAP . Midwest Office Executive Vice President 104 E. Wisconsin Avenue - B Texas Utilities Generating Company Appleton, WI 54911-4897 400 North Olive Street, L.D. 81 Dallas, TX 75201 William L. Brown, Esq.* Anthony Z. Roisman, Esq.
U.S. Nuclear Regulatory Commission Suite 600 611 Ryan Plaza Drive, Suite 1000 1401 New York Avenue, NW Arlington, TX 76011 Washington, DC 20005 Asst. Director for Inspec. Programs William H. Burchette, Esq.
Comanche Peak Project Division Mark D. Nozette, Esq.
U.S. Nuclear Regulatory Commission Heron, Burchette, Ruckert P. O. Box 1029 S Rothwell, Suite 700 Granbury, TX 76048 1025 Thomas Jefferson Street, N.W.
Washington, DC 20007 Lanny Alan Sinkin James M. McGaughy Christic institute GDS Assoc. inc.
1324 North Capitol Street 1850 Parkway Pl. , Suite 720 Washington, DC 20002 Marietta, GA 30067 Robert D. Martin
- Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Board Panel
- 611 Ryan Plaza Drive, Suite 1000 U.S Nuclear Regulatory Commission Arlingtua, TX 76011 Washingto% DC 20555 Robert A. Jablon, Esq. Atemic. Satety.and Licensing Appeal Spiegel S McDiarmid Board Panel
- 1350 New York Avenue, N.W. U.S. Nuclear Regulatory Commission Washington, DC 20005-4798 Washington, DC 20555 t
Jack R. Newman, Esq. Robert M. Fillmore
! Newman S Holtzinger, P.C. Worsham, Forsythe, Samples Suite 1000 s Wooldridge l 1615 L Street, N.W. 2001 Bryan Tower, Suite 3200 l Washington, D.C. 20036 Dallas, Texas 75201 Docketing and Service Section*
Office of the beucthry l U.S. Nuclear Regulatcry Commission l Washington, DC 20555 l @bbb b i Janit.s E. Mnore Counsel for NRC Staff l
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. 00CKETED USHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 88 APR -1 P3 US
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD r; roc U :: r a ~ -
00CKI.isi.. ~ :!
In the Matter of ) 2Mk
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TEXAS UTILITIES ELECTRIC ) Docket Nos. 50-445-CPA COMPANY , ET _AL. _
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(Comanche Peak Steam Electric )
Station, Units 1 and 2) )
CERTIFICATE OF SERVICE i hereby certify that copies of "NRC STAFF'S RESPONSE IN SUPPORT OF APPLICANTS' MOTION TO CONSOLIDATE PROCEEDINGS", "NOTICE OF APPEARANCE" for Bernard M. Bordenick and "NOTICE OF WITHDRAWAL" for Mitzi A. Young 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 mall system, this 30th day of March,1988:
Petcr B . Bloch , Esq. , Chairraan* Mrs. Juanita Ellis Administrative Judge President, CASE Atomic Safety and Licensing Board 1426 South Polk Street U.S. Nuclear Regulatory Commission Dallas, TX 75224 l Washington, DC 20555 Renea lilcks, Esq.
Dr. Kenneth A. McCollom Assistant Attorney General Administrative Judge Envirortmental Protection Division i
1107 West Knapp P.O. Box 12548, Capital Station l Stillwater, OK 74075 Austin, TX 78711 Elizabeth B. Johnson Robert A. Woofdridge, Esq.
Administrative Judge Worsham, Forsythe, Samples Oak Ridge National Laboratory & Wooldridge P.O. Box X, Building 3500 2001 Bryan Tower, Suite 3200 Oak Ridge, TN 37830 Dallas, TX 75201 Dr. Walter li. Jordan Joseph Gallo, Esq.
l Administrative Judge Hopkins G Sutter l 881 West Outer Drive Suite 1250 l Oak Ridge, TN 37830 1050 Connecticut Avenue, N.W.
Washington, DC 20036 l
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Billie Pirner Garde Mr. W. G. Counsil CAG Midwest Office Executive Vice President 104 E. Wisconsin Avenue - B Texas Utilities Generating Company Appleton, WI 54911-4897 400 North Olive Street, L.B. 81 Dallas, TX 75201 William L. Brown, Esq.* Anthony Z. Rolsman, Esq.
U.S. Nuclear -Regulatory Commission Suite 600 611 Ryan Plaza Drive, Suite 1000 1401 New York Avenue, N.W.
Arlington, TX 76011 Washington, DC 20005 Asst. Director for inspec. Programs
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William H. Burchette, Esq.
Comanche Peak Project Division Mark D. Nozette, Eso.
U.S. Nuclear Regulatory Commission Heron, Burchette, Ruckert P. O. Box 1029 6 Rothwell, Suite 700 Granbury, TX 76048 1025 Thomas Jefferson Street, N.W.
Washington, DC 20007 Lanny Alan Sinkin James M. McGaughv Christic Institute GDS Assoc. Inc.
1324 North Capitol Street 1850 Parkway Pl. , Suite 720 Washington, DC 20002 Marietta, GA 30067 Robert D. Martin
- Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Board Panel
- 611 Ryan Plaza Drive, Suite 1000 U.S Nuclear Regulatory Commission Arlington, TX 76011 Washington, DC 20555 Robert A. Jablon, Esq. Atomic Safety and Licensing Appeal Spiegei S McDiarmid Board Panel
- 1350 New York Avenue, N.W. U.S. Nuclear Regulatory Commission Washington, DC 20005-4798 Washington, DC 20555
- Jack R. Newman, Esq. Robert M. Fillmore Newman S Holtzinger, P.C. Worsham, Forsythe, Sampics
- Suite 1000 S Wooldridge l 1615 L Street, N.W. 2001 Bryan Tower, Suite 3200 Washington, D.C. 20036 Dallas, Texas 75201 j
Docketing and Service Section*
Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555 t
-k/b b (M < Mb.
Janice E. Moore j
Counsel for NRC Staff l
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