ML20210G058

From kanterella
Jump to navigation Jump to search
Notice of Amends to Coc GDP-1 for Usec,Paducah Gaseous Diffusion Plant,Paducah,Ky & Coc GDP-2 for Usec,Portsmouth Gaseous Diffusion Plant,Portsmouth,Oh
ML20210G058
Person / Time
Site: Portsmouth Gaseous Diffusion Plant, 07007001
Issue date: 07/26/1999
From: Paperiello C
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20210G042 List:
References
NUDOCS 9908020281
Download: ML20210G058 (9)


Text

. ..

o . .

7590-01 P l U.S. NUCLEAR REGULATORY COMMISSION l NOTICE OF AMENDMENTS TO CERTIFICATE OF COMPLIANCE GDP-1 FOR THE U.S. ENRICHMENT CORPORATION PADUCAH GASEOUS DIFFUSION PLANT PADUCAH,KENTl!CKY DOCKET 70-7001 AND CERTIFICATE OF COMPLIANCE GDP-2 FOR THE U.S. ENRICHMENT CORPORATION PORTSMOUTH GASEOUS DIFFUSION PLANT PORTSMOUTH, , OHIO , f DOCKET 70-7002

)

The Director, Office of Nuclear Material Safety and Safeguards, has made a determination that the following amendment requests are not significant in acordance with 10 CFR 76.45. In 1

making that determination, the staff concluded that: (1) there is no change in the types or significant increase in the amounts of any effluents that may be released offsite; (2) there is no significant increase in individual or cumulative occupational radiation exposure; (3) there is no sigr.ificant construction impact; (4) there is no significant increase in the potential for, or ,

1 radiological or chemical consequences from, previously analyzed accidents; (5) the proposed changes do not result in the possibility of a new or different kind of accident; (6) there is no significant reduction in any margin of safety; and (7) the proposed changes will not result in an overall decrease in the effectiveness of the plants' safety, safeguards or security programs.

The basis for this determination for the amendment requests is shown below.

The NRC staff has reviewed the certificate amendment applications and concluded that they provide reasonable assurance of adequate safety, safeguards, and security, and compliance with NRC requirements. Therefore, the Director, Office of Nuclear Material Safety and Safeguards, is prepared to issue amendments to the Certificates of Compliance for the Paducah Gaseous Diffusion Plant and for Portsmouth Gaseous Diffusion Plant. The staff has prepared a Compliance Evaluation Report which provides details of the staff's evaluation.

l 9909020201 990724 l

1

{DR ADOCK 07007001 PDR L j

l The NRC staff has determined that these amendments satisfy the criteria for a categorical exclusion in accordance with 10 CFR 51.22(c)(19). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared for these amendments.

USEC or any person whose interest may be affected may file a petition, not exceeding 30 pages, requesting review of the Director's Decision. The petition must be filed with the Commission not later than 15 days after publication of this Federal Register Notice. A petition for review of the Director's Decision shall set forth with particularity the interest of the petitioner and how that interest may be affected by the results of the decision. The petition should l specifically explain the reasons why review of the Decision should be permitted with particular

! reference to the following factors: (1) the interest of the petitioner; (2) how that interest may be l affected by the Decision, including the reasons why the petitioner should be permitted a review of the Decision; and (3) the petitioner's areas of concern about the activity that is'the subject l matter of the Decision. Any person described in this paragraph (USEC or any person who filed l

a petition) may file a response to any petition for review, not to exceed 30 pages, within 10 days l 1

after filing of the petition. If no petition is received within the designated 15-day period, the Director will issue the final amendments to the Certificates of Compliance without further delay.

l If a petition for review is received, the decision on the amendment applications will become final in 60 days, unless the Commission grants the petition for review or otherwise acts within 60 days after publication of this Federal Register Notice.

A petition for review must be filed with the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, Attention: Rulemakings and i

1 I

Adjudications Staff, or may be delivered to the Commission's Public Document Room, the Gelman Building,2120 L Street, NW, Washington, DC, by the above date.

For further details with respect to the action see (1) the application for amendments and (2) the )

i I

Commission's Compliance Evaluation Report. These items are available for public inspection at the Commission's Public Document Room, the Gelman Building,2120 L Street, NW, Washington, DC, and at the Local Public Document Rooms.

Date of amendment requests: February 12,1999 Brief description of amendments: The amendments propose to revise the Paducah and Portsmouth Quality Assurance Program (OAP) descriptions to include additional ways to approve suppliers for inclu.sion on the Approved Suppliers List and clarify the audit requirements applied to suppliers conducting work under the USEC QAP.

1 Basis for finding of no significance:

I

1. The proposed amendments will not result in a change in the types or significant increase in the amounts of any effluents that may be released offsite.

The proposed revisions to the OAP provide for ad jitional ways to approve suppliers for ,

1 inclusion on the Approved Suppliers List and clarify the audit requirements applied to suppliers conducting work under the USEC OAP. It does not involve any process which would change or l increase the amounts of any effluente that may be released offsite. Therefore, the proposed l change will not result in an increase in the amunnis of effluents that may be released offsite or result in any impact to the environment. l I

4

2. The proposed amendments will not result in a significant increase in individual or cumulative occupational radiation exposure.

The proposed revisions to the QAP provide for additional ways to approve suppliers for inclusion on the Approved Suppliers List and clarify the audit requirements applied to suppliers conducting work under the USEC QAP; they have no affect on occupational radiation exposure.

Therefore, the proposed change does not increase individual or cumulative occupational radiation exposure.

3. The proposed amendments will not result in a significant construction impact.

The proposed change is only a change to the QAP and does not involve any construction.

Therefore, it does not result in a significant construction impact.

4. The proposed amendments will not result in a significant increase in the potential for, or radiological or chemical consequences from, previously analyzed accidents.

The proposed revisions to the QAP provide for additional ways to approve suppliers for inclusion on the Approved Suppliers List and clarify the audit requirements applied to suppliers conducting work under the USEC QAP. It does not change any previously analyzed accidents i

and does not affect the possibility of occurrence of a criticality accident. Therefore, the l proposed change does not result in a significant increase in the potential for, or radiological or l 1

chemical consequences from, previously analyzed accidents.

5. The proposed amendments will not result in the possibility of a new or different kind of accident.

.- os The proposed revisions to the OAP provide for additional ways to approve suppliers for inclusion on the Approved Suppliers List and clarify the audit requirements applied to suppliers conducting work under the USEC OAP. The proposed change does not introduce any new or i

different kind of accident. Therefore, this change will not result in the possibility of a new or different kind of accident.

6. The proposed amendments will not result in a significant reduction in any margin of safety.

The proposed revisions to the OAP provide for additional ways to approve suppliers for inclusion on the Approved Suppliers List and clarify the audit requirements applied to suppliers ,

l conducting work under the llSEC QAP. Margins of safety are not affected by this change. I Therefore, the proposed change does not represent a reduction in any margin of safety.

7. The proposed amendments will not result in an overall decrease in the effectiveness of the plant's safety, safeguards or security programs.

The proposed revisions to the OAP provides for additional ways to approve suppliers for inclusion on the Approved Suppliers List and clarify the audit requirements applied to suppliers conducting work under the USEC QAP. These changes do not decrease the overall effectiveness of the plants' safety, safeguards, and security programs.

1 Effective date: The amendments to Certificates of Compliance GDP-1 and GDP-2 will become effective no later than 90 days after being signed by the Director, Office of Nuclear Material Safety and Safeguards.

j

f' .;a -

L., ., .

1

. Certificates of Compliance Nos. GDP-1 and GDP-2: These amendments will revise the OAPs to provide for additional ways to approve suppliers for inclusion on the Approved Suppliers List l ~ and to clarify the audit requirements applied to suppliers conducting work under the USEC OAP.

Local Public Document Room locations: Paducah Public Library,555 Washington Street, Paducah, Kentucky 42003 and Portsmouth Public Library,1220 Gallia Street, Portsmouth, Ohio l

I 45662.

' Dated at Rockville, Maryland, this 24 dcy of 1999.

FOR THE NUC R REGULATORY COMMISSION

(

k <

Carl J. Paperiello, irector Office of Nuclear Material Safety and Safeguards l

l l

I -'-..

( . .

l . . .

l.- .. ,

July 26, 1999 3- I

! applicable USEC procedures as part of its implementation of the CARS. Therefore, ? -

indicated deletions are acceptable to the NRC staff.

The NRC staff included two editorial comments in its request for additional information regarding the USEC CARS. USEC addressed the editorial comments acceptably in its responses.

ENVIRONMENTAL REVIEW lssuance of amendments to the Certificates of Compliance GDP-1and GDP-2 revising the Quality Assurance Program (OAP) descriptions to include additional ways to approve suppliers for inclusion on the Approved Suppliers List and to clarify the audit requirements applied to suppliers conducting work under the USEC OAP is subject to the categorical exclusion provided in 10 CFR 51.22(c)(19). Therefore, neither an ersvironmental assessment nor an environmental impact statement is required for the proposed action. l CONCLUSION Based on the NRC staff's review of the information provided by USEC in its CARS and in its response to the staff's request for additional information, the staff concludes that the USEC OAP descriptions will continue to meet the NRC OA requirements specified for Paducah and PORTS in 10 CFR Part 76, specifically 976.93, " Quality Assurance." Therefore, the staff concludes that USEC can implement its proposed QAP description changes at Paducah and PORTS.

The Region lil Inspection staff has no objection to this proposed action.

Principal Contributor Jonn G. Spraul DISTRIBUTION: (control Nos. 470S and 540S)

Dockets 70-7001 and 70-7002 NRC File center PUBLIC SPB r/f Rill KO'Bnen, Rill /"Ig d f l PHiland. Rill FCSS r.f MTokar, WSchwink. NMSS r/f G \SPB\CXC5\qapeer wpd (*See previous concurrence)

OFC SPB E SPB E SPB E SPB SPB k NAME 'YFararal *DHondley *CCox *MAGalloway DATE 7/14199 7/14/99 7/14 /99 7/14199 7/ 4 I /99 C a COVERE m COVER & ENCLOSURE = NO COPY OFFICIAL RECORD COPY g 1

l i

1

l. . .

for inclusion on the Approved Suppliers List and to clarify the audit requirements applied to suppliers conducting work under the USEC QAP is subject to the categorical exclusion provided in 10 CFR 5!.22(c)(19). Therefore, neither an environmental assessment nor an environmental impact statement is required for the proposed action.

CONCLUSION Based on the NRC staff's review of the information provided by USEC in its CA s and in its responses to the staff's request for aoditional information, the staff conclu [s that the USEC QAP descriptions will continue to meet the NRC QA requirements spec' 'ed for Paducah and PORTS in 10 CFR Part 76, specifically 76.93," Quality Assurance." herefore, the staff concludes that USEC can implement its proposed QAP descripti changes at Paducah and PORTS.

The Region 111 Inspection staff has no objection to this pr osed action.

Princioal Contributor John G. Spraul l 1

DISTRIBUTION- (Con Nos. 470S and 540S)

Dockets 70-7001 a 0 7002 NRC File Centor PUBUQ SPD rM Rlll KO'Brien, Alil PHiland, Rlli FCSS r.f MTokar, WSchwink. NMSS rn TSPEhCXC5%apcer.wpd (*See previous concurrence)

/ a OFC SPB E SP$ E SPB E SPB SPB NAME *YFaraz:al dos y *CCox *MAGalloway RPierson DATE 7/14/99 7/ /99 7/14/99 7/14 /99 7/ /99 C e COVERE m COVER & ENCLOSURE m NO COPY OFFICIAL RECORD COPY i

l . e. .s CONCLUSION Based on the NRC staff's review of the information provided by USEC in its CARS and in its i responses to the staff's request for additient information,the' staff concludes that the USEC l

OAP descriptions will continue to meet the NRC OAjeq6irements specified for Paducah and PORTS in 10 CFR Part 76, specifically $76.93 " Quality Assurance." Therefore, the staff concludes that USEC can implement its proposed OAP description changes at Paducah and

! PORTS.

The Region ill Inspection staff ~ as no objection to this proposed action.

Principal Contributo Joh l

l l

{

l l

i l

DISTRIBtJTION: (Control Nos. 470S and 540S) l Dockets 70-7001 and 70-7002 NRC File Cente. PUBLIC SPB r/f Rlli KO'Bnen, Rill Philand, Rlll FCSS r.f MTokar, WSchwink, NMSS r/f l

OFC SPB E SPB E SPD . E SPB SPB 4 vr 4 Wp NAME YFaratal DHoadley CCoxf MAGallo*ay RPierson DATE 7/ lk /99 7/ /99 7/ / /99 7// 19 9 7/ /99 C = COVERE = COVER & ENCLOSURE = NO COPY OFFICIAL RECORO COPY 9

F l, ,.,.- , July 26, 1999 l

Mr. Jrm:s N. Adkins Vice President, Production U.S. Enrichment Corporation l 2 Dem6cracy Center 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

PADUCAH AND PORTSMOUTH GASEOUS DIFFUSION PLANTS: QUALITY ASSURANCE PROGRAM CHANGE ACCEPTANCE (TAC NOS. L32108 AND L32109) l l

Dear Mi Adkins:

This refers to your applications dated February 12,1999, requesting amendments to the Certificates of Compliance for the Paducah and Portsmouth Gaseous Diffusion Plants for the revised Quality Assurance Program descriptions; our related request for additional information dated March 18,1999; and your responses to that request dated April 16,1999. {

Our review of your applications and your responses to our request for additional information  ;

indicates that they are acceptable. Our Certificate Evaluation Report and the corresponding l Federal Register Notice for the revised Quality Assurance Programs are enclosed. As you develop the required implementing procedures, please ensure that they include the United States Enrichment Corporation supervisory / oversight supplier controls noted in your responses to Item 2 of our request for additionalinformation.

If you have questions regarding this letter or its enclosures, please contact Mr. Charlie Cox for Paducah at (301) 415-6755 or Mr. Yawar Faraz for Portsmouth at (301) 415-8113.

Sincerely,

/sf Melanie A. Galbway, Chief Enrichment Section Special Projects Branch Division of Fuel Cycle Safety and Safeguards, NMSS Dockets 70-7001,70-7002 Certificates GDP-1, GDP-2

Enclosures:

As stated cc:

Mr. Steven Toelle, USEC Mr. Randall DeVault, DOE DISTRIBUTION: (Control No. 550S)

Docket 70-7001 NRc File Center PUBLIC Alli o'Bnen. Alli NMSsrM NMSS Dir. ote. rn FCSSrM FCoBr# SPB rM PHiland, Rlli G \SPB\CXC5\oapitr wod _

(*See previous concurrence)

OFC SPB E SPB E SPB E SPB E SPB E SPB E NAME 'YChen *DHoadley *CCox *JSpraul *MAGalloway *RPierson DATE 7/19/99 7/1/99 7/19/99 7/21/99 7/ 21 /99 7/21/99 C = COVER = E COVER & ENCLOSURE Na NO COPY OFFICIAL RECORD COPY

r ,

,, s , <* .

Mr. Jim:s N. Adkins Vice President, Production U.S. Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

PADUCAH AND PORTSMOUTH GASEOUS DIFFUSION PL NTS: QUALITY ASSURANCE PROGRAM CHANGE ACCEPTANCE (TAC'NOS. L32108 AND L32109) j

/

Dear Mr. Adkins:

/

l This refers to your applications dated February 12,1999, rec [uesting amendments to the Certificates of Compliance for the Paducah and Portsmouth Gaseous Diffusion Plants for the revised Quality Assurance Program descriptions; our,related request for additional information dated March 18,1999; and your responses to that, request dated April 16,1999.

/

Our review of your applications and your responses to our request for additional information indicates that they are acceptable. Our Certificate Evaluation Report and the corresponding Federal Registration Notice for the Paducah and Portsmouth Gaseous Diffusion Plants for the l revised Quality Assurance Programs.are attached. As you develop the required implementing procedures, please ensure that they include the United Statra Enrichment Corporation supervisory / oversight supplier c,ontrols noted in your respon=es to item 2 of our request for additionalinformation.

/

p if you have questions regarding this letter or its enclosures, please contact Mr. Charlie Cox for Paducah at (301) 415-6755 or Mr. Yawar Faraz for Portsmouth at (301) 415-8113.

,/ Sincerely,

/ Melanie A. Galloway, Chief

/ Enrichment Section

,' Special Projects Branch

/ Division of Fuel Cycle Safety and Safeguards, NMSS

/

Dockets 70-7001,70-7002 Certificates GDP-1, GDP-2

Enclosures:

As stated cc:

Mr. Steven Toelle, USEC Mr. Randall DeVault, DOE DISTRIBUTION: (Control No. 550S)

Docket 70 7001 NRC File Center PUBuc Rill O'Bnen. Rill NMSSrM S I'R M NMSS Dir. ofc. r4 FCSSrM FcoBrM SPBrM PHiland. Rill G \SPB\CXC5\qapitr wpd ("See previous concurrence) 1[d OFC SPB E SPB E SPB E SPB b NAME *YChen *DHoadley *CCox ay #

[M O DATE 7/19/99 7/1/99 7/19199 7/ /99 7/t t /99 C = COVER = E- COVER & ENCLOSURE Na NO COPY OFFICIAL RECORD COPY

,s .

, 6- i vertificates of Compliance Nos. GDP-1 and GDP 2: These amendments will revise the OAPs to provide for additional ways to approve suppliers for inclusion on the Approved Suppliers List and .to clarify the audit requirements applied to suppliers conducting work under the USEC QAP.

Local Public Document Room locations: Paducah Public Library,555 Washington Street, Paducah, Kentucky 42003 and Portsmouth Public Library,1220 Gallia Street, Portsmouth, Ohio 45662.

Dated at Rockville, Maryland, this day of 1999.

FOR THE NUCLEAR REGULATORY COMMISSION J

f5/

Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards DISTRIBUTION: (Control Nos. 470S and 540S) _. -. .._,

Dockets 70-7001 and 70-7002 NRC FILE CENTER d PUBLIC NMSS r/f FCSS r/. K'OBrien, Rlli DHartland, Rlll NMSS Dir. Off. r/f KWinsberg, OGC CCox PHiland, Rill JJacobson, Rill FCOB SPB r4 G:\SPB\CXC5\qapfrn.wpd $PRGRL ( See previous concurrence)

OFC SPB SPB E SPB E SPB I FCSM / NMSSt. s M NAME 'YFaraz:al *DHoadley 'MAGalloway k ETenEyfk CPhe o DATE 7/14/99 7/14/99 7/14 /99 7/7 l /99 7/ N 9 7/ '$/99 C = COVER E m COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY I

l

o

,, .'. .4

- OAP. Therefore, the overall effectiveness of the safety, safeguards, and security programs is not decreased.

7 Effective date: The amendments to Certificates of Compliance GDP-1 and GDP-S ill become offective no later than 90 days after being signed by the Director, Office of Nuclear M rial Safety and Safeguards.

Certificates of Compliance Nos. GDP-1 and GDP-2: These a ndments will revise the OAPs to provide for additional ways to approve suppliers for inclusion on t Approved Suppliers List and to clarify the audit requirements applied to suppliers conducting rk under the USEC QAP. l Local Public Document Room locations: P ucah Public Library,555 Washington Street, l Paducah, Kentucky 42003 and Portsm th Public Library,1220 Gallia Street, Portsmouth, Ohio 45662.

Dated at Rockville, Maryland, is day of 1999.

FOR THE NUCLEAR REGULATORY COMMISSION Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards DISTRIBUTION: (Control Nos. 470S and 540S)

Dockets 70 7001 and 70-7002 NRC FILE CENTER PUBLIC NMSS r/l FCSS r/f K'OBrien, Rill DHertland, Rill NMSS Dir. Off. r/f KWinsberg, OGC CCox PHiland, Rlli JJacobson, Rill FCOB SPB r/f G:\SPB\CXC5\qapfm.wpd ("See previous concurrence)

OFC SPB SPfl E SPB E SPB FCSS NMSS NAME 'YFaraz:al 6 diey *MAGalloway RPierson ETenEyck CPaperiello DATE 7/14/99 L'h 7/ /99 ' 7/14 /99 7/ /99 7/ /99 7/ /99 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY h

a

. l

' suppli:rs conducting work under ths USEC OAP with no d:creas3 ir ,te. <iven:ss of the )

/  !

OAP. Therefore, the overall effectiveness of the safety, safeguards, ano , #., r6 grams is not decreased. /

7 I

/ l Effective date: The amendments to Certificates of Compliance GDP-J'and GDP-2 will become

/

effective no later than 90 days after being signed by the Director,,0ffice of Nuclear Material ,

Safety and Safeguards.

l

,/

/

/'

/

Certificates of Compliance Nos. GDP-1 and GDP-2: Tfiese amendments will revise to the OAPs to provide for additional ways pliers to approve for inclusionsup/

on the Approved Suppliers List and to clarify the auditnts requirerne/

applied to suppliers conducting work under

/

the USEC QAP. /

/

/

Local Public Document Room locations: Paducah Public Library,555 Washington Street,

/ 1 Paducah, Kentucky 42003 and Portsmouth Public Library,1220 Gallia Street, Portsmouth, Ohio 45662. ,!

/

/

Dated at Rockville,' Maryland, this day of 1999.

/

/ FOR THE NUCLEAR REGULATORY COMMISSION

/

Carl J. Paperiello, Director Office of Nuclear Material Safety and Safeguards DISTRIBUTION: (Con:rol Nos. 470S and 540S)

Dockets 70-7001 and 70-7002 NRC FILE CENTER PUBLIC NMSS r/f FCSS r/l K'OBrien, Rill DHartland, Rlli NMSS Dir. Off. r/f KWinsberg, OGC CCox PHiland, Rill JJacobson, Rlli FCOB SPB r/f G:\SPB\CXC5\qapfrn.wpd OFC SPB SPB E SPB E SPB FCSS NMSS NAME YFa N DHoadley MAbay RPierson ETenEyck CPaperiello DATE 7/ /// /99 7/ /99 7/ /k/99 7/ /99 7/ /99 7/ /99 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY l l

., i- 'e .

Mr. James N. Adkins ,

Vice President, Production j U.S. Enrichment Corporation l 2 Dem6cracy Center I 6903 Rockledge Drive Bethesda, MD 20817

SUBJECT:

PADUCAH AND PORTSMOUTH GASEOUS DIFFUSION P TS: QUALITY ASSURANCE PROGRAM CHANGE ACCEPTANCE (TAC S. L32108 AND ,

L32109) l 1

Dear Mr. Adkins:

This refers to your applications dated February 12,1999, request' g ameridments to the Certificates of Compliance for the Paducah and Portsmouth G eous Diffusion Plants for the revised Quality Assurance Program descriptions; our related quest for additional information dated March 18,1999; and your responses to that request ated April 16,1999.

Our review of your applications and your responses to ur request for additional information indicates that they are acceptable. Our Certificate aluation Report and the corresponding Federal Registration Notices for the Paducah an ortsmouth Gaseous Diffusion Plants for the revised Quality Assurance Programs are attac d. As you develop the required implementing procedures, please ensure that they include e USEC supervisory / oversight supplier controls noted in your responses to item 2 of our r uest for additionalinformation.

If you have questions regarding this le er or its enclosures, please contact Mr. Charlie Cox for Paducah at (301) 415-6755 or Mr. Y war Faraz for Portsmouth at (301) 415-8113.

Sincerely, Melanie A. Ga-lloway, Chief l

, Enrichment Section l Special Projects Branch i Division of Fuel Cycle Safety

/ and Safeguards, NMSS I

/

Dcckets 70-7001, 70-7002 Certificates GDP-1, GDP-2

Enclosures:

As stated cc:

Mr. Steven Toelle, USEC Mr. Randall DeVault, DOE DISTRIBUTION- (Control No. 550S)

Docket 70-7001 NRC File center PUBUC Alli O'Bnen. Alll NMSSrM NMSS Dir. Ofc. r/f FCSSrM FCOBrM SPB rM PHiland, Hill GTSPB\CXC5\qnpitr wpd OFC SPB E SPB E SPB E SPB NAME $fhen *DHoadley MAGalloway RPierson DATE 7/ @ /99 7/1/99 7/ 99 7/ /99 7/ /99 l L C = COVER = E- COVER & ENCLOSURE N= NO COPY OFFICIAL RECORD COPY