ML20151S376

Transcript of NNECO Prehearing Conference on 980902 in Rockville,Md.Pp 1-22

ML20151S376
Person / Time
Site:	Millstone
Issue date:	09/02/1998
From:	NRC
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CON-#398-19488 ASB-300-443, LA, NUDOCS 9809080069
Download: ML20151S376 (24)

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5 PREHEARING CONFERENCE  : k' s . jb, i 6 NORTHEAST NUCLEAR ENERGY COMPANY : Docket No. 50-4231 1 1

7 (Millstone Nuclear Power Station : )

8 Unit No. 3)  :

9 - _-..__ _ _ _ _ _ _ _ _ _ -x l

10 11 Nuclear Regulatory Commission l l

12 Two White Flint North 13' 11545 Rockville Pike j 14 Rockville, Maryland

~15 Wednesday, September 2, 1998 16 17 The above-mentioned matter came on for prehearing 18 conference, pursuant to notice, at 9:00 a.m.

19 1

20 BEFORE:

21 THOMAS S. MOORE, Chairman, Administrative Judge 22 RICHARD F. COLE, Administrative Judge 23 CHARLES N. KELBER, Administrative Judge 24 25 APPEARANCES:

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,, 1 APPEARANCES:

2 On behalf of the Northeast Nuclear Energy Company:

-]

3 DAVID A'. REPKA, Esquire 4

5 On behalf of the Intervenor Citizens Regulatory 6 Commission:

7 NANCY BURTON, Esquire 8

9 On behalf of the NRC Staff:

10 RICHARD G. BACHMANN, Esquire 11 12 l

13 14 l

15 16 17 18 19 i

1 20 1 21 22 l 23 24 25 ANN RILEY & ASSOCIATES, LTD.

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, , 1 PROCEEDINGS J l .x -2 [9:00 a.m.]

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3 JUDGE MOORE: This is Judge Moore. With me are l 4 Judges Cole and Kelber. This is a telephonic prehearing  !

5 conference in Northeast Nuclear Energy Company, Millstone 6 Nuclear Power Station, Unit Number 3, Docket No. 50-423-LA.

7 Because we are doing this by telephone, if each  !

j l 8 party would identify themselves before they speak so the j 9 court reporter can make a record of that, we would 10 appreciate it.

11 Before we start, do any of the parties have any 1

12 questions?

13 (No response.]

14 JUDGE MOORE: What we thought we would do this 15 morning is give each party, starting with petitioner's 16 counsel, an opportunity to address very briefly the 17 contentions, and then the Board has a number of questions.

18 Ms. Burton, are you prepared to start?

! 19 MS. BURTON: Yes. Thank you, Judge Moore. I'm 20 Nancy Burton and I represent the Citizens Regulatory 21 Commission, which I will refer to here as the CRC.

1 1 22 We have presented two contentions which we have 23 submitted by supplement dated July 6, 1998. I will assume 24 you are familiar with that. ,

i . :25 JUDGE MOORE: Yes, we are.

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1 MS. BURTON

I don't really have anything further 2 to add, but I would welcome your questions.

s.

3. JUDGE MOORE: Mr. Repka, do you have anything 4 further in addition to what you stated in your filings that 5 you wish to state?

6 MR. REPKA: No, I do not at this time.

7 JUDGE MOORE: Mr. Bachmann. 1 1

8 MR. BACHMANN: No , sir, not at this time either. I 9- JUDGE MOORE: Let's turn to the Board's questions.

10 I have one and my colleagues have a number.

11- Mr. Repka, the petitioner's contention one 12 essentially challenges the capability of the RSS to perform

! 13 as advertised because it has not been tested. As a basis, 1

14 petitioners essentially assert that the applicant has erred  !

15 in the past with its design calculation and it gives a ,

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16 number of specific examples.  ;

17 Why doesn't this raise an inference that the 18 applicant again erred in this particular instance and

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19 provide the necessary support for the contention?

20 MR. REPKA: There are two points to be made.

1 21 First, the challenge to the design modification itself is 22 outside the scope because the discussion in the contention 23 and the basis relates to changes that were made subsequent i 24 to the 1986 change that is the issue in the amendment. The l

25 1986 amendment did not involve the changes to the spray i

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L, 1 function, the changes to the spray ring headers that are 1

l 2 discussed in the basis statement at all; the 1986 change did 1

3 not involve changes to piping; it was really a change only 4 in operational aspects of the system.

5 JUDGE MOORE: Mr. Repka, let me interrupt a 6 minute. Hold the rest of your thought and let me interject 7 a second question.

8 I'm troubled because we are in a 1998 license l 9 amendment for something that actually took place in 1986 10 through no fault of the petitioners, obviously, by an error 11 that occurred by the applicant by not seeking a license 12 amendment in 1986. Why should we not be looking at this as 13 if it were 1986 and all these other events then become 14 relevant, obviously?

15 MR. REPKA: We should be looking at this event as 16 if it's 1986 because, regardless of how we got here today, 17 that is the change that is in issue in this proceeding, the 18 1986 change related to the direct contention.

19 JUDGE MOORE: Then we can't ignore all of the 20 subsequent changes.

21 MR. REPKA: It's not a matter of ignoring those 22 changes. Those changes have each been analyzed 23 independently under 10 CFR 50.59. They've all been made 24 without Commission approval; no Commission approval was 25 necessary. No hearing right attaches to those changes.

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.. 1 Regardless of how we got here, legally we cannot bootstrap

- 2 into a 1986 change all the other changes for which no USQ l 3 was determined to be involved and no license amendment was 4 determined to be necessary.

5 JUDGE MOORE: In that regard, have all the 6 subsequent changes to 1986 been analyzed in the context of 1

l 7 the 1998 change that was actually made in 1986?

8 MR. REPKA: All the changes have been analyzed 9 both individually and together. In fact, the February 1998 j 10 submittal that CRC relies upon really, instead of the 11 amendment application of March that is the real issue, was 12 an integrated assessment of all the changes to the system.

13 What the company did there, at the request of the NRC staff, 14 was go through all of the changes, look for unreviewed 15 safety questions, and it was determined that the only 16 unreviewed safety question involved and the only impact that 17 really required NRC staff review and approval was the 1986 18 change.

19 JUDGE MOORE: It would probably be the better part l 20 of discretion for the applicant and/or the staff to file 21 with us that February submission because it's not in part of 22 any of the filings that have been made. All of the parties 23 refer to it. Yet we've never seen it. Is that a huge 24 document, Mr. Repka?

25 MR. REPKA: It's about a half inch thick. I'd be l ANN RILEY & ASSOCIATES, LTD.

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i. 7 1 happy to serve it on the Board.

, 2 JUDGE MOORE: If you would do that, it would be 3 appreciated.

4 Excusing my interruption that got you off the 5 track, would you go back to answering my original question, 6 the second half of your answer, as to why an inference can't 7 be drawn that in light of past errors that the applicant 8 erred this time and why doesn't that support the contention?

9 MR. REPKA: I think if you make the assumption 10 that the challenge is to the 1986 change and not to all 11 these other modifications, the contention would still fail I

12 for lack of basis. There is an allegation made that the l l

13 company has made calculation errors. Those are just general 14 statements.

15 I think the intent and the spirit of 2714, the 16 Commission's threshold on admitting contentions, is that 17 there need to be more than speculative assertions as a basis 18 for a contention; there needs to be some~ documentary support 19 for a specific problem with the change at issue, some 20 reference to expert opinion or some documentary evidence 21 that will show that the 1986 change wasn't sufficient. l 22 I don't think it's enough to say "in my opinion as 23 an intervenor the company simply is not very good at doing 24 engineering analysis." That is not a basis at all. you 25 could make that statement about any amendment.

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..a 8 1 JUDGE MOORE: But here, Mr. Repka, the intervenor

'c 2 has cited a number of specific examples, including the 1998 3 error involving the RSS system pumps. If as an evidentiary 4 matter one can draw inferences from past mistakes that a 5 current mistake was made, why is that not sufficient to 6 support a contention?

7 MR. REPKA: I think that inference, if it could be i 8 made, is just simply not strong enough. It does not have a 9 sufficient probative value. The fact is that what is j 10 referred to as mistakes could also be referred to as simply 11 operational experience as part of the pre-op, 12 post-modification testing related to the 1998 changes; you 13 learn things about systems and adjust accordingly. To me 14 that is simply not strong enough an inference to say that 15 this 1986 modification also is somehow inadequate.

16 JUDGE MOORE: In that regard, if one were to 17 assume that an inference could be drawn, as the petitioner

.18 has posited, then haven't they stated that in the f 19 application there is a failure in the information that has 20 been provided and they've given the reason why they need 21 more information, that is, the testing, if you accept their

. 22 ' inference?

23 MR. REPKA: The problem again, though, is that you

24. accept the inference to jump immediately to basis without 25 even asking what the contention is. In other words, we are ANN RILEY & ASSOCIATES, LTD.

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9 y 1 putting the cart before the horse because the argument is as 2 that.the company's engineering capabilities are no good;

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3 therefore this application is bad. However, nowhere in the 4 contention does it state exactly where the 1986 modification 5 is bad.

6 To state it another way, if the issue is testing, 7 then it's incumbent upon the contention to address what 8 aspect of the testing. As a matter of fact, the February 9 submittal goes into some description of both the 1986 10 testing of the system, which did in fact test all alignments  ;

11 both for the spray function and the recirculation function, 12 and then also describes the 1998 testing related to the l

13 subsequent changes.. .

l 14 Again, we have a contention that ignores the  ;

15 testing that was done and is described in the documents and i

16 therefore fails the primary requirement for a contention,

17. which is to address some specific aspect of the amendment 18 and state how it is bad, and then provide the basis of why 19 you think it's bad. I think that even if you could draw the 20 inference, you still don't solve the problem on 21 admissibility of the contention.

22 JUDGE COLE: Mr. Repka, this is Judge Cole. I 23 have a couple of questions.

24 On page 6 of your filing of July 27, your response l 25 to the contentions, the bottom of that page you refer to a  ;

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1 ' February submittal. That is the February 16, 1998,

,. 2 submittal from NECO to the staff identified as B17050; is l cT  ;

'# 3- that correct?

4 MR. REPKA: That is correct. That's the submittal  :

5 that is referenced in the CRC contention. That is what I  ;

6 also described earlier as the integrated safety assessment 7 that was submitted to the NRC staff on the RSS generally as 8 part of the restart review process.

9 JUDGE COLE: That is also the document that you  ;

10 are going to send us a copy of?

11 MR. REPKA: Yes, it is.

12 JUDGE COLE: That's the half-inch document you 13 referred to?

14 MR. REPKA: That's correct.

15 JUDGE COLE: At the bottom of that page you say, 16 here the document does show the testing that has been 17 performed and does not show any affirmative support for the 18 proposed contention. The document you are referring to 19 there is also that same document; is that correct, sir?

20 MR. REPKA: That's correct. Section 7 of that 21 document addresses testing.

22 JUDGE COLE: With respect to the March 3, 1998, 23 licensing amendment, I'm trying to find out where Attachment 24 2 begins.

25 MR. REPKA: Let's see if I can help.

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, 1 JUDGE COLE

I know where Attachment 1 is, and

'?;y '2 then I have a page that talks about Attachment 1, page 1, 3 list of regulatory _ commitments.

4 MR. REPKA: The very next page should be a divider 5 page that says Attachment 2 Markup, 1986 FSAR Pages.

6- JUDGE COLE: That's not in my document. The first ,

7 page that I have is Amendment 18, 6.2-15, date'd March 1986.

8 MR. REPKA: You have a missing page between there. t 9 It's a divider page with the docket number, and it says 10 Attachment 2.

11 JUDGE COLE: That is the first actual page of 12' Attachment 2 minus the divider page?

13 MR. REPKA: .That's correct.

14 JUDGE COLE: All right, sir. They have various 15 pages that are just taken from different amendments that 1

16 relate to the 1986 FSAR pages that were marked up, correct? '

17 MR. REPKA: That's correct. It takes the 1986 18 FSAR and the revision bars relate to those changes being i 19 made as a result of the 1986 mod.

20 JUDGE COLE: These pages are as they would have 21 appeared in 1986, the 1986 change?

22 MR. REPKA: That's correct.

23 JUDGE COLE: If we were to look at the FSAR of 24 today, which is September 1998, would these pages be 25 significantly different or any different at all?

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l. 1 MR. REPKA: I believe they would be different. I 2 wouldn't be able to characterize significant or not. They 1

l 3 would reflect all the FSAR changes as necessary to reflect l

4 subsequent changes. Not all changes require a FSAR l

5 revision, but other than stating that I think it would be 6 different, it would be hard for me to qualitatively describe 7 that.

8 JUDGE COLE: CRC has identified and listed 18 9 modifications that have been done to the system since 1986.

10 MR. REPKA: That's correct.

11 JUDGE COLE: Some of those involved some hydraulic 1

12 changes, did they not, sir? '

13 MR. REPKA: When you say hydraulic changes, you 14 mean changes to system flow?

15 JUDGE COLE: Yes.

16 MR. REPKA: That would be true. Certainly some of 17 the 1998 changes relate to system flow, predominantly 18 related to the spray function, not the recirculation phase l

19 functions.

20 JUDGE COLE: Particularly the one with the 21 installation of orifices that control the flow?

22 MR. REPKA: That's correct, but the primary impact 23 of that is on the injection function, not the recirculation 24 phases; the spray function.

25 JUDGE COLE: With a change in the hydraulics of ANN RILEY & ASSOCIATES, LTD.

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• 13 1 the system, are you saying this would have no impact at all I s 2 .on the way the flow behaved in 1986?

3 MR. REPKA: I'm trying to understand your 4 question. -Did the subsequent changes alter the flow as 5 described in 1986? You'll see a discussion of that in the 6 February document. I fear I.may be getting out of my depth.

7 So I'd rather not state definitively, but there were changes 8 and there are changes in flow as a result of the subsequent 9 changes. That's correct. You'll see a chart in the 10 February submittal that shows the original design flow and 11 then it shows the numbers for the 1998 flow.

12 JUDGE COLE: Thank you.

13 MR. REPKA: What is important to recognize is that 14 all 18 changes are addressed and described in the February 15 submittal. The direct injection change from 1986 is just 16 one of those changes and the only one determined to involve 17 an unreviewed safety question.

18 JUDGE COLE: All right, sir. I understand that.

L 19 That's all the questions I have for now.

20 JUDGE KELBER: This is Judge Kelber. In this 21 document which we are going to receive, whatever document 1 22 discusses all the calculations, do you know if these were l

23 based on design values, system tests or model tests?

24 MR. REPKA: The flow numbers?

l 25 JUDGE KELBER: Yes.

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14 1 MR. REPKA: My understanding is -- again, I

- 2 suppose the document will speak for itself -- that there 3 were full system tests in both the spray alignment and the 4 recirculation phase alignments in 1986. At that point it 5 was preoperational; the change involving direct injection 6 was a preoperational change.

7. JUDGE KELBER: These system tests were done in 8 1986 and you say the calculations were based on the results 9 of those tests?

10 MR. REPKA: Correct. Then in 1998, in conjunction 11 with the subsequent changes and pre-restart of the unit, 12 additional tests were performed, and at that point a 13 combination of test data and analysis was used to vcci / :he 14 flows.

15 JUDGE KELBER: There were later tests done this 16 year or last year? 3 17 MR. REPKA: Correct. You will see a description 18 of testing in Section 7 of the document.

19 JUDGE KELBER: Yes. You mentioned that.

20 I'm confused about one item on this, on the pump 21 curve, and I'm not sure whether this is in the document that 22 is coming to us or not. In the brief dated May 22 you state 23 the changes which led to this amendment were based on 24 preoperational test experience. You just repeated that.

25 But in Insert A it says that the reanalysis utilizes a ANN RILEY & ASSOCIATES, LTD.

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15 1 revised degraded containment pump curve. In the reanalysis

, 2 were the values used based on preoperational testing or on

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3 the design curve as supplied by.the manufacturer?

4 MR. REPKA: I cannot answer that question.

5 JUDGE KELBER: Would that be in that document?

6 MR. REPKA: I don't know.

7 JUDGE KELBER: Thank you very much, Mr. Repka.

8 I have some question for the intervenor. Given 9 the evident distrust of the licensee's competence, how would 10 you propose to audit system tests? Do you have some special

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11 competence at your command to audit such tests?

12 MS. BURTON: I'm sorry, sir. I didn't catch the 13 beginning of your question.

14 JUDGE KELBER: Given the fact that the contention 15 is based on your distrust of the licensee's competence, how 16 do you propose to audit the tests? The licensee claims they 17 perform tests and analyses based on these tests. What 18 special competence would you have at your command to audit 19 any such tests?

20 MS. BURTON: I'd like to respond to that, first of 21 all, by addressing a statement that was made by Mr. Repka in 22 which he was suggesting that CRC is merely speculating as to 23 the propensity of the applicant to present flawed 24 calculations and flawed engineering.

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j . 1 plant went through in these past two years with the ICRVP, 2 the Independent Corrective Action and Verification Program.

3 It became very well established in the course of that review 4 that there was a high preponderance of calculation and 5 engineering errors that were cropping up in a very 6 troublesome way. So I'm not presenting mere speculation 7 about that it's well documented, and the documentation went 8 on for months and months and months, and it was one of the 9 issues that was of high concern in the whole restart 10 process.

11 With respect to expertise that CRC could bring to 12 bear in analysis of test results, I think that I can assure 13 you that we have engineering expertise that would be capable 14 of reviewing the test data and analyzing it in a manner that 15 would be of assistance in this forum.

16 JUDGE KELBER: Given that and given the fact that 17 you have the documents which we do not have that apparently 18 contain the test data, would you be able to perform an audit 19 before we went any further to decide whether or not it 20 satisfies your needs and supply any documentation if it does 21 not?

22 MS. BURTON: Let me say this. Again, I think I 23 have to say I may be somewhat out of my depth here. I 24 personally do not have this document, but I was assisted by 25 a consultant in this information. My understanding was that ANN RILEY & ASSOCIATES, LTD.

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? ., 1 Bolton's review of that report led him to conclude that s 2 there hadn't been actual testing that was considered to be 3 necessary. I think my answer to that would be that I would 4 want to go back and discuss this with the consultant, and if 5 the test hasn't been done, if we have a difference of 6 opinion as to that, then we would want to inquire further.

7 JUDGE KELBER: Would you just hold for a moment, 8 please.

9 Would you' mind submitting the consultant's report?

i 10 MS. BURTON: It was an oral report. l 11 JUDGE KELBER: If it's nossible, a written summary 12 would be useful, if the consultanta would agree to that.

13 MS. BURTON: A written summary analyzing the 14 February 16th data?

15 JUDGE KELBER: Yes.

16 JUDGE MOORE: This is Judge Moore. Judge Kelber, 17 do you have any other questions?

18 JUDGE KELBER: No , I'm through.

19 JUDGE MOORE: Judge Cole.

20 JUDGE COLE: No.

21 JUDGE MOORE: We have no further questions. Let's 22 discuss for a moment scheduling.

23 Speaking hypothetically now, Mr. Repka, if 24 petitioner's contentions were admitted, in light of the 25 Commission's August 1998 policy statement taking a very dim ANN RILEY & ASSOCIATES, LTD.

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?' 18 1 view of summary disposition, would you nevertheless be of s 2 the view that this case would be prime for summary 3

I 3 disposition if a contention were admitted?

4 MR. REPKA: Yes, I would be of that view. I think 5 this case is a good example of where summary disposition 6 would be useful to determine whether there is indeed any 7 genuine issue and whether there is indeed any technical 8 support for a position that the amendment is inadequate.

9 JUDGE MCORE: Mr. Bachmann, would you be of the 10 same view?

11 MR. BACHMANN: Yes, sir, the staff would be. In 12 fact, it appears that there is really only one contention 13 here and therefore were summary disposition to be granted, 14 obviously it would take care of the entire hearing process.

15 JUDGE COLE: Mr. Bachmann, this is Judge Cole.

16 When you said there appears to be only one contention, I-17 assume you are saying that one and two are essentially very 18 close together and essentially the same issue.

19 MR. BACHMANN: Yes, that's what I'm saying.

20 JUDGE COLE: Thank you.

21 JUDGE MOORE: Ms. Burton, I don't know if you've 22 had an opportunity to review the Commission's August 1998 23 policy statement, but is your view that of counsel for the 24 applicant and the staff, that summary disposition would be l 25 useful in this case?

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-g 1 MS. BURTON: I think that it's premature to make

?? 2 that conclusion. I would request that we have an  !

v  !

3 opportunity for discovery.

4 ' JUDGE MOORE: I understand your position. If a 4

5 contention were admitted and the applicant and/or the staff 6 were to file summary disposition, then, Ms. Burton, under 7 the Commission's summary disposition rules you have an 8 opportunity in responding to the motion for summary 9 disposition to point out very specifically what precise 10 discovery you need in order to be able to respond to the j 11 motion for the summary disposition. Would not' discovery 12 confined and narrowed like that meet your purposes?

13 MS. BURTON: I think that I would need to say 14 that, no , I am not familiar with the August 1998 policy 15 statement. I would want to review it. But if we did have 16 the opportunity for full discovery where it seemed to be 17 pertinent and necessary, then that would seem to be 18 appropriate.

19 JUDGE MOORE: And with interrogatories and 20 document discovery and perhaps a deposition, you are 21 prepared to be able to complete that in a relatively short 22 order, something on the order of 30 to 40 days?

I 23 MS. BURTON: That would assume, of course, 24 cooperation on the other side. ]

25 JUDGE MOORE: Certainly. I recognize it's ANN RILEY & ASSOCIATES, LTD.

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., 1 difficult,'because we are speaking strictly hypothetically

<s 2 whether a contention were to be a admitted, but you are 3 fully prepared to be able to do that in a relatively short 4 span of time?

5 MS. BURTON: Yes.

6 JUDGE MOORE: Mr. Repka and Mr. Bachmann, if a 7 contention were admitted, is a two-week time period in which 8 to submit a motion for summary disposition too tight a 9 schedule for you?

10 MR. REPKA: I think that is a little on the tight l

11 side.

12 JUDGE MOORE: Thirty days is something that you 13 could live with?

14 MR. REPKA: Certainly, i

15 JUDGE MOORE: Until we receive the document that 16 you are to submit to us, Mr. Repka, we think that would be 17 very helpful in assessing the papers that have already been 18 filed. You all refer to it and we are the only ones that 19 don't know what is in it. So that may cast a totally 20 different light'on this entire intervention contention 21 matter for us.

22 Having said that, because of Board schedules, it 23- will be the end of this month before we will be able to 24 issue a second decision on the contention because various 25 members of this panel will all be gone over the next several ANN RILEY & ASSOCIATES, LTD.

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98 21 l- weeks. So if you would go ahead and submit immediately that es 2 document to us, Mr. Repka, then by the end of the month we

-- 3 will address the contention and get something out and set a 4 schedule if a contention is admitted, and we will set a 5 schedule in that order.

6 Do the parties have anything else?

7 MR. REPKA: Yes. Let me make one other 8 hypothetical observation. Under 2714 (a) the applicant would ,

9 have the opportunity to appeal to the Commission a decision 10 to admit a contention. I have no idea whether we would 11 appeal such an order without seeing an order, but I'm 1

12 assuming the schedule would allow that opportunity. For .

1 13 example, if a contention is granted and we choose not to l 14 pursue ai. appeal, then we would go forward on the schedule  ;

1 15 as proposed. However, if we do want to pursue an appeal on l

16 the admissibility of the contention, then the schedule would )

17 be stayed in some way pending Commission resolution on the 18 admissibility question.

19 JUDGE MOORE: That would be your request, that you 20 don't want them to proceed simultaneously?

21 MR. REPKA: Yes.

22 JUDGE MOORE: Mr. Bachmann.

)

23 MR. BACHMANN: Yes, sir. 1

.24 JUDGE MOORE: Do you have a comment on that? l 25 MR. BACHMANN: It seems like a reasonable approach ANN RILEY & ASSOCIATES, LTD.

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Ji 22 1 to take, sir.

l ,*

2 JUDGE MOORE: Ms. Burton.

~~)

- 3 MS. BURTON: Well, we're in the area of

-4 speculation.

5 JUDGE MOORE: Admittedly so.

-6 MS. BURTON: I think I would want to address that.

7 JUDGE MOORE: All right. If the parties have 8 nothing further, we will conclude this.

9 MS. BURTON: This is Nancy Burton for CRC. I I

10 assume I will be copied on the February report, the full 11 report.

12 MR. REPKA: Yes, you will be.

13 JUDGE MOORE: Mr. Bachmann, anything further?

14 MR. BACHMANN: Nothing from me, sir. I have a 15 copy of the February report.

L 16 JUDGE MOORE: Mr. Repka, do you have anything l l 1 i 17 further?

l 18 MR. REPKA: Nothing further.

19 JUDGE MOORE: We thank the parties for their 20 indulgence, and that will conclude the conference.

i 21 [Whereupon at 9 :35 e .m. , the prehearing conference l 22 was concluded.]

l 23 l

24' 25 ANN RILEY & ASSOCIATES, LTD.

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'~'-

g before the United States Nuclear Regulatory Commission in the matter of:

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CASE NUMBER: 50-423-LA PLACE OF PROCEEDING: Rockville, MD ,

1 l

were' held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.

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