ML20204B669
| ML20204B669 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/18/1987 |
| From: | Eric Thomas Federal Emergency Management Agency |
| To: | Shannon J MASSACHUSETTS, COMMONWEALTH OF |
| Shared Package | |
| ML20204B533 | List: |
| References | |
| OL, NUDOCS 8703250127 | |
| Download: ML20204B669 (16) | |
Text
__ - - - -_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ ____ _________
SELATED CORRESPONDtM&
3/18/87 80CMETED USNRC UNITED STATES OF AMERICA ._ . _ .
NUCLEAR REGU.ATORf COMM:SSION '87 MAR 23 P3 :16 BEFORE THE ATOMIC 3AFETY LICENSING BOA _RD l CFFT= W ' TU '
- Y*
) Docket No. 50-443 Public Service Co. of New Hampshire, ) 50-444 et al. ) (Offsite)
)
(Seabrook Station, Units 1 & 2) )
RESPONSE OF THE FEDERAL EMERGENCY MANAGEMENT AGENCY TO MASSACHUSETTS AITORNEY GENERAL JAMES M. SHANNON'S OFF-SITE EMERGENCY PREPAREDNESS INTERROGATORIES AAD REQUEST FOR PRODUCTION OF DOCUMENTS TO FEMA (SET No.1)
The Federal Emergency Managerrent Agency (FEMA) is not a party to the above-captioned proceeding and it is, for that reason, not obligated to respond to the interrogatories propounded by any intervanors. FEMA voluntarily provides l the information supplied below, but reserves the right to object to future f
discovery requests.
Interrogatory No.1:
Describe in detail your position with respect to each contention to be litigated by the Attorney General and each subpart of each such contention.
Describe in detail the reasons for your position.
Answer No. 1 FEMA has not yet developec potitions on any of the contentions admitted in this proceeding. Therefore,tyr are unable to articulate a basis for a position. However, we note that irnairically it seems likely that the numerous documents in which FEMA and the Fm!!ral Regioral Assistance Comittee (RAC) have assessed the acceptability o' the radi31c!;ical plars and preparedness b S
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2-I of the State of New Hampshire cculc~. contain our position on many of the contentions. I understand that these documents, which are listed below have been served on the parties to this proceeding, f
a) FEMA report of the deficiencies observed during the February 26, 1986 Exercise of the state and local plans to protect the public in the event of an ' accident at Seabrook, together with a cover letter dated April 4,1986 frem Edward A. Thomas to Richard H. Strome transmitting and explaining the report.
b) Final Draft Report of thin exercise of the emergency plans for Seabrook held Februiry 26, 1936, together with a cover letter dated April 30, 1986 from Edward A. Thomas to Richard H. Strome.
! c) Final Report of the exercise of the energency plans for Seabrook held February 26, 1986, together with a cover letter dated June 6,1986 fron Edward A. ~homas to Richard H. Strome.
d) Final review by FEMA and the Regional Assistance Committee l (RAC) of the ttate and local plans submitted by New Hampshire l
in December 1985, together with a cover letter dated April 30, 1986 from Edward A. Thomas to Richard H. Strome.
e) Draft FEMA and RAC Review of the state and local plans j submitted by New Hampshire in February 1936, together with a cover letter dated April 30, 1986 from Ednard A. Th3 mas to Rir.hard H. Strome.
E f) Final FEMA /RAC Review of the state and local plans submitted by New Hampshire 11 February 1986 together with -
a cover letter dated April 33, 1986 from Edward A. Thomas to Richard H. Strome, g) Draft FEliA/RAC Review of the New Hamp. shire submission of April 16,1986, together wl"h a cover letter dated June 2, 1986 from Edward A. Thomas to Richard H. Strome.
h)- Final fella /RAC Review of he New Hanpshire submission on April 16, 1986, together with a cover 1atter dated August 8, 1986 from Edward A. Thomas to Richard H. Strome.
- 1) Final FEMA /RAC Review of the state and local plans submitted by New Hampshire September 8, 1996 together with a cover letter from Edward A. Thomas to Richard H. Strome dated December 12, 1986.
Interrogatory No. 2 4 I'dentify and produce all documents which you nave relied, do rely, or will rely to support your position on each of these contentions. Identify the information in each document on which you have relied, do rely, or will rely and the specific subpart of each contention which that information concerns.
Answer No. 2 Since FEMA has not yet develcped a positien o1 the contentions admit-ted with respect to this proceedirg, we are unable to articulate which documents may be used in support of such a pcsition beyord our statement in our ans.wer to Interrogatory 1 supr_a. _
Interrogatory No.__3 State whether you have relie:1, do rely, er will rely on any study, cal-
4_
culatico, or analysis to support your position on each of these contentions, if so, please:
(a) Describe the nature of thn study, calculation or analysis and identify any documents that discus:s or describe the study, calculation or analysis; ,
(b) Identify the persons who Jarformed the study, calculation or analysis; (c) State when and where the study, calculation or analysis was performed; (d) Describe in detail the inf 3rmation or data that was studied, calaculated or analyzed; (e) Describe the re:ults of the study, calculation or analysis; (f) Explain how such study, calculation, or analysis provides support for your position on each of these contentiens.
Answer No._3 Since FEMA has not yet develcped a position on the contentions admit-s ted with respect to this proceeding, we are unable to articulate which dccuments may be used in support of such a resition beyond our statement in our answer to Interrogatory 1 supra.
Interrogatory No. 4 Do you intend to offer the tortimony of any expert witness with respect to any contention to be litigated t,y the Attorney General? If so, please:
(a) Identify each expert witness who you intend to present with respect to each subpart of each such contention; (b) State the substance of the facts to which each expert witness is i
expected to testify; I
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.' .5-(c) State the substance of tne opinion or opinions to which each expert witness is expected to testidy; (d) Provide a sucinary of the grounds for each opinien to which each expert witness is expected to testi'y; (e) State whether the facts a14 opinions'l'isted in response to the foregoing are contained in any docament; (f) State whether the opinion af any expert witness is based in whole or in part on any scientific rule or principle, and, if so, set forth such rule or principle; (g) State whether the opinien M any expert witness is based in whole or in part on any code or regulatior, governmental or otherwise, and, if so, identify each such code or regulation and the specific section or portion thereof relied upon; and (h) State whether the opinion of any expert witness is based in whole or in part upon any scientific or engiceering :ook o, otner publication, and, if so, idantify the book or publication.
Answer No. 4 a) FEMA has not yet identified the witnesses it intends to have tettify with respect to any of the content. ions admitted in this proceeding and can therefore neither describe the subt?.ance of their testimony nor describe any document which such witnesses may rely upon beyond the documents referenced in response to Interrogatory 1 syyy Interrogatory No. 5_
Do you intend to offer the teritimony of any non-expert witness with respect to any contention to be litigated by the Attorney General? If so, please:
(a) Identify each non-expert witness who you intend o present with respect to each subpart of each such contention; (b) State the substance of the facts to which each non-expert witness is expected to testify; and (c) State whether the facts '.isted in resp:nse to the foregoing are contained in any document, and proctce the same.
Answer No. 5 a) FEMA has not yet identifiet the witnessas it intends to have testify with respect to any of the content'ons admitced in this proceeding and can therefore neither describe the substance of their testimony nor describe any document which such witnesses may rely upon beyond the documents referenced in response to Interrogatory 1 suory,.
Interrogatory No. 6 Identify and produce all docununts in wnich ycur or any agent on your behalf have assessed the adequacy o' state and local emergency plans with respect to any contention to be li:igated by the Attorney General. Include in your response any documents con':erning steps which have been taken or will be taken by the State of New :i.impshire or the Applicants to address inadequacies in any past or curren: local plans.
Answer No.__6 All publicly available documents in which FEMA or an agent on our behalf has assessed the adequacy of state and local plans with respect to the New Hampshire Radiological Erergency Response plans are listed in response to Interrogatory 1 mg. FEtiA and its agents have not specifically assessed the adequacy of the state and local emergency plans with respect to any contentions.
,,._r-,..-m , , , . ,
FEMA has no documents concerning the steps which have been taken
~
will be taken by the State of New hanpshire or the Applicants to address
,- the inadequacies uncovered in the ct.rrent local New Hampshire RERP, other than the. progress reports served on the parties by the New Hampshire Attorney General.
Obiection to Massachusetts Interro y.ory 6 FEMA objects to this Interrogatory as 1 relevant and unduly burdensome to the extent that this Interrogatory requests documents in the possession of FEMA which concerns steps which have been.taken by the State of New Hampshire or the Applicant to addrit:ss inadequacies in any past local plans.
The information requested is irreliriant since p.evious plans are not in contention in this licensing hearit). It wou',d be unduly burdensome for FEMA to assemble the information shee these do:uments may well date back to 1981 and are not the type which :EMA regularly maintains. Assembling this infomation would require axtra search of FEMA's records and possibly records of other Federal agencies to produce the information requested.
Interrogatory _No. 7 Are peak sumer day evacuation time est1m.Ites for the populations within two miles, five miles and ten miles of the Seabrook Plan *, longer than the average two-mile, five-mile, and ten-mile EPZ evacuation time estimates for nuclear power plants in this country?
Answer No. 7_
FEMA objects to this Interrogatory as irrelevant and unduly burdensome.
The information requested is irrelevant since the licensing criteria imposed by regulations of the NRC do nct require that emergency response plans at
g any plant be better than those at any other plant, but rather that they pro-vide reasonable assurance that appropriate action will be taken to protect the public. It would be unduly burdenseme for F.EMA to assemble the infor-mation requested since it is not tre type which' FEMA regularly maintains and because it requires extra search of FEMA's records and records of other Federal agencies to produce tre information requested.
Interrogatory No. 8 Please provide the names of all nuclear power plants that have longer evacuation time estimates for populations located within two miles, five miles and ten miles of those plants than does the Seabrook reactor. Include those respective time estimates for each plant.
Answer No.__8 FEMA objects to this Interrog.itory as irrelevant and unduly burdensome.
The information requested is irrel tvant since the ifcensing criteria imposed by regulations of the NRC do not r! quire that emergency response plans at any plant be better than those at n1y other plant, but rather that they pro-vide reasonable assurance that .1ppr)priate action will be taken to protect the public. It would be unduly burdensome for FEMA to assemble the infor-mation requested since it is not the type which FEH1 regularly maintains and because it requires extra search of FEMA's records and records of other Federal agencies to produce tre information requested.
Interrogatory No. 9 Is population density greater for the tress within two miles, five miles, and ten miles of the Seabrcck Plant than thi average population densities for areas within two m'les, five miles and ten miles of all other nuclear reactors in tnis catrtryi
Answer N_o. 9 FEMA objects to this Interrogatory as irrelevant and unduly burdensome.
The-information requested is irrelevant since the licensing criteria imposed by regulations of the NRC do not require that emergency response plans at any plant be better than those at any other phnt, but rather that they pro-vide reasonable assurance that appopriate action will be taken to protect the public.
It would be unduly bt.rdensome for FEl% to assemble the infor-mation requested since it is not the type which FEMA regularly maintains and because it requires extra search of FEMA's records and records of other Federal agencies to produce the information requested.
Interrogatory No. 10 Please provide the names of all nuclear sower plants in this county that nave higher population densities in the areas'within two miles, five miles and ten miles of the plants t1an does the Seabrook reactor.
Answer _ No. 10 FEMA objects to this Interrogatory as irrelevant and unduly burdensome.
The information requested is irrelsvant since the licensing criteria imposed by regulations of the NRC do not rNuire that emergency response plans at any plant be better than those at any other plant, but rather that they p.o-vide reasonable assurance that appropriate a: tion will be taken to protect the public.
. It would be unduly burdensome for FEMA to assemble the infor-nation requested since it is not the type which FEMA regularly nafntains and because it requires extra sea. ch of FEMA's records and records of other Federal agencies to produce t.be information requested.
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Interrogatory No.11 1s there a larger summer trant. lent population with two miles five miles or ten miles of the Seabrook plant than there is within two miles, five miles, or ten miles of all atter operat'fno reactors in this country'/
Answer No. 11 FEMA objects to this Interrogatory as f reelevant and unduly burdensome.
The information requested is irrelevant since the licensing criteria imposed by regulations of the NRC do not require that amergency aesponse plans at any plant be better than those at any other' plant, but rather that they pro-vide reasonable assurance that appropriate action will be taken to protect the public.
It would be unduly burcensome for FEMA to assemble the infor- .
mation requested since it is not the type which FEHA regularly maintains and because it requires extra searci of FEHA's records and records of other Federal agencies to produce tne inforrra-1on requested.
Interrogatory No. 12 Please attentify all nuclear power plants in this country that have a larger sumer transient population :han does the Seabrook Plant for the areas located within two miles, fits miles, or ten mfles of the plant, and for each of those reactors indicatt what provisions, if e.ny, have been made to shelter the transient populittion; where such population is sit-uated with respect to that reactor; the averate dose recuction factor of shelters used for that population; evacuatlan time estimates for that pop-ulation if it were to be evacuates; the location with respect to the transient population of any shelter *ng they will be expected to use; whether that population is predomaantly a beach population; whether suf-
ficient sheltering capacity exists te shelter the entire transient popula-tion; and if sufficient capacity dots not exist to enable the sheltering of the entire population, state for what percentage of the population
- sufficient sheltering capacity exists.. -
Answer No._12 FEMA objects to this Interrogntory as irrelevant and unduly burdensome.
The information requested is irrelevant since the licensing criteria imposed by regulations of the NRC do not require that emergency response plans at any plant be better than those at any other plart, but rather that they pro-vide reasonable assurance that appropriate action will be taken to protect the public. It would be unduly burdensome for FEMA to assemble the infor-mation requested since it is not the type which FEMA regularly maintains and because it requires extra searc1 of FEMA's records and records of other Federal agencies to produce tie informatici requested.
Interrogatory No. 13 Will emergency planning for the area within ten miles of the Seabrook Plant effectuate less " dose reduction" than the average dose reduction for all other nuclear plants in this couitry, assuming comparable radiological releases in the event of an accident?
Answer No. 13 FEMA objects to this Interrogatory as irrelevant and unduly burdensome.
The information requested is irrelevant since the licensing criteria imposed by regulations of the NRC do not require that eirergency response plans at any plant be better than those at any other plant, but rather that they pro-vide reasonable assurance that apprcpriate action will be taken to protect the public. It would be unduly burdensene for FEMA to assemble the infor-
i 12 - 1 mation requested since it is not tte type' which FEMA regularly maintains and because it requires extra search of FEMA's records and records of other Federal agencies to produce tre informatten requested.
Interrogatory No.14 ,
Compare the average dose reduction expectee to be effectuated for the summer transient beach population within ten miles of the Seabrook Plant to the average does reduction expected to be effectuated for persons within ten miles of all other reactors in this country, assuming comparable radio-logical releases in the event of an accident.
Answer No. 14 FEMA objects to this Interrogatory as irrelevant and unduly burdensone.
The information requested is irrelevant since the licensing criteria imposed by regulations of the NRC do not recuire that emergency response plans at any plant be better than those at try other plant, but rather that they pro-vide reasonable assurance that apprcpriate action will be taken to protect the public. It would be unduly burcensome for FEMA to assemble the infor-mation requested since it is not tre type which FEMA regularly maintains and because it requires extra search of FEMA's records and records of other federal agencies to produce tra information requested.
Interrogatory No.15 Please provide the basis for ycur response to interrogatories 13-14 and any documents relevant to your responses.
Answer No. 15 FEMA objects to this Interrogttory as irrelevant and unduly burdensone.
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The information requested is irreinant since the licensing criteria imposed by -regulations of the NRC do not recuire that emergency response plans at any plant be better than those at try other plant, but rather that they pro-vide reasonable assurance that apprcpriate action will be taken to protect the public. It would be unduly burcensome for FEMA to assemble the infor-mation requested since it is not tre type wh'ch FEMA regularly maintains and because it requires extra searcF of FEMA's records and records of other Federal agencies to produce tFe information requested.
Interrogatory No. 16 ,
Do homes within the Seabrook ten-mile EPZ have on the atarage a lower dose reduction factor than do homes around a'l other nuclear reactors in this country.
An_swer_ _N_o._ _16 FEMA objects to this Interrogatory as irrelevant and unduly burdensone.
The information requested is irrelevant since tFe licensing criteria imposed by regulations of the NRC do not recuire that emergency response plans at any plant be better than those at any other plar.t. but rather that they pro-vide reasonable assurance that apprcpriate actiCn will be taken to protect the public. It would be unduly burdenseme for FEMA to assemble the infor-mation requested since it is not the type which FEMA regularly maintains and because it requires extra search of FEMA's records and records of other Federal agencies to produce the trfornati:n requested.
Interrogatory No. 17 Conpare the average dose reduction factor :f h:mes within the Seabrook
_ _ _ _ _ _ . _ _ _ _ _ . . . _ _ _ _ . _ . . _ . , _ - , _ _ _ _ . - _ _ , _ ~ _ - _ _ , - _ -
0: :n j 14 -
ten-mile EPZ beach area to average cose reduction factors of homes around other reactors.
Ans_wer_No._17 FEMA objects to this Interrogatory as irrelevant and unduly burdensone.
The information requested is irrelevant since tre licensing criteria imposed by regulaticos of the NRC do not require that emergency response plans at any' plant be better than those at ar.y other plant, but rather that they pro-vide reasonable assurance that apprcpriate action will be taken to protect the public.
It would be unduly burcenseme for FEMA to assemble the infor-mation requested since it is not tre type which FEMA regularly maintains 4
and because it requires extra search of FEMA's records and records of other Federal agencies to produce the frformation requested.
Interrogatory No.18 Please provide the basis for ycur responses to interrogatories 16-17 and any documents relevant to your resgenses.
Answer No. 18 FEMA objects to this Interrogatory as irrelevant and unduly burdensone.
The information requested is irrelevant since the licensing criteria imposed by regulations of the NRC do not require that emergency response plans at any plant be better than those at any other plart, out rather that they pro-vide reasonable assurance that appropriate acticn will be taken to protect the public. It would be unduly burdenseme for FEMA to assemble the infor-mation requested since it is not the type which FEM regularly maintains and because it requires extra search of FEMA's records and records of other Federal agencies to produce the informati:n requested.
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I declare, under penalty of perjury, that the foregoing responses to the Massachusetts Attorney General's Irterrogatories and Request for Production-of Documents are true.
j/' '
Edward A. Thomas, Divisjon Chier Natural & Technological Hazards Region I Federal Emergency Management Agency Dated March 18, 1987
, Boston, Massachusetts
% - _ . . . _ . - _ . _. _ , . - . . , _ _ . , , , . _ . _ . . - , . . . . . . , _ __,r_, _ . . _ . . _ _ _ _ _ , , _ _ - . , _ _ , _ _ ...,._______-_,,r_-_ _- _ . -- - .
F' c:
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, OBJECTION The Federal Emergency Management Agency (FEMA) objects generally to the foregoing interrogatories to the extent that they call for the production or disclosure of the contents of draf t or privileged documents, except to the extent that such documents have already been identified or disclosed in the foregoing answers. See 0 C.F.R. 5 2.740(b)(1); cf. 10 C.F.R. . 2.790(a).
In addition, FEMA objects.to interrogatories 6 through 18 for the reasons set.forth'above.
Respectfully submitted, Yk= 2h - -~
H.oJ6sepf flynn f Assistast General Counsel Federal Emergency Management Agency 500 C Street S.W.
Washington, D.C. 20472 J
d 1
M 00CKETED USHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '87 MAR 23 P3 :14 DEFORE THE ATOMIC SAFETY AND LICENSING IMdh;, dNiki.
iiRANCH In the Matter of )
) Docket Nos. 50-443 OL PUBLIC SERVICE COMPANY OF ) 50-444 OL NEW HAMPSHIRE, eM. ) Off-site Emergency Planning
)
(Seabrook Station, Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of THE FEDERAL EMERGENCY MANAGEMENT
, AGENCY'S (FEMA) RESPONSES TO INTERROGATORIES FILED BY (1) THE TOWN OF HAMPTON, (2) SAPL, (3) NECNP, AND (4) THE MASSACHUSETTS ATTORNEY GENERAL in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or (*) through by deposit in the Nuclear Regulatory Commission's internal mail system , or (") overnight delivery this 18th day of March,1987:
Heleil Hoyt, Esq. , Chairman
- Gustavo A. Linenberger, Jr.*
Administrative Judge Administrative Judge Atomic Fafety and I.icensing Board Atomic Safety and Licensing Doord U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. Jerry Harbour
- Ms. Carol Snelder, Fsq."
Administrative Judge Assistant Attorney General Atomic Safety and Licensing Board Office of the Attorney General U.S. Nuclear Regulatory Commission One Ashburton Place,19th Floor Washington, DC 20555 Boston, MA 02108 Deverly liollingworth Richard A. Ilampe, Esq.
200 Winnacunnet Road New Hampshire Civil Defense A gency llampton, Nil 03842 107 Pleasant Street Concord, NH 03301 Sandra Gavutis, Chairman Calvin A. Canney, City Fanager Daard of Selectmen City liall RFD 1 Box 1154 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03601 gS d
l Stcphen E. Merr!11 Paul McEachern, Esq.
Attorney General Matthew T. Brock, Esq.**
George Dana Bisbee Shaines a McEachern Assistant Attorney General 25 Maplewood Avenue Office of the Attorney General P.O. Box 360 25 Capitol Street Portsmouth, NII 03801 Concord, NH 03301 Roberta C. Pevear Angie Machiros, Chairman State Representative Board of Selectman Town of flampton Falls 25 Ifigh Road Drinkwater Road Newbury, MA 09150 Hampton Falls, NH 03844 Allen Lampert Mr. Robert J. Harrison Civil Defense Director President and Chief Executive Officer Town of Brentwood Public Service Co. of New I!ampshire 20 Franklin Street P.O. Box 330 Exeter, NH 03833 Manchester, NH 03105 Charles P. Graham, Esq. Robert A. Backus, Esq.**
McKay, Murphy and Graham Backus, Meyer & Solomon 100 Main Street 116 Lowell Street Amesbury, MA 01913 Manchester, PH 03106 Diane Curran, Esq.** Philip Ahren, Esq.
Ilarmon & Weiss Assistcnt Attorney General 2001 S Street, NW OfHee of the Attorney General Suite 430 , State House Station #0 Washington, DCd 20009 Augusta, ME 04333 Edward A. Thomas Thomas G. Dignan Jr. , Esq."
Federa! Emergency Management Agency Ropes & Gray 442 J.W. McCormack (POCil) 225 Franklin Street Boston, MA 02109 Boston, MA 02110 H.J. Flynn, Esq. William Armstrong Assistant General Counsel Civil Defense Director Federal Emergency Mana[rement Agency Town of Exeter 500 C Street, SW 10 Front Street Washington, DC 20472 Exeter, NH 03833 Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel
- Board
- U.S. !!uclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Jane Doughty Docketing and Fervice Section*
Ecacoast Anti-Pollution League Office of the Sceretary 5 Market Street U.S. Nuclear Regulatory Commission Portsmouth, NH 03801 Washington, DC 20555
k Maynard L. Young, Chairman William S. Lord Board of Selectmen Board of Selectmen 10 Central Road Town Hall - Friend Street South Ilampton, NH 03287 Amesbury, MA 01913 Michael Santosucsso, Chairman Peter J. Matthews, Mayor Board of Selectmen City Hall South flampton, NH 03287 Newburyport, MN 09150 Mr. Robert Carrigg, Chairman Judith H. Mizner, Esq.
Board of Selectmen Silverglate, Gertner, Baker Town Office Fine and Good Atlantic Avenue 88 Broad Street North Hampton, NH 03862 Boston, MA 02110 R. K. Gad III, Esq. Mrs. Anne E. Goodman , Chairman Ropes & Gray Board of Selectmen 225 Franklin Street 13-15 Newmarket Road Boston, MN 02110 Durham, Nil 03824 Gary W. Holmes, Esq. Honorable Gordon J. Humphrey Holmes & Ellia United States Senate 47 Winnacunnet Road 531 Hart Senate Office Building flampton, Nil 03842 Washington, DC 20510
,k SW Sherwin E. Turk Counsel for NRC Staff