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UNITED STATES OF 'AMERICAL 1
ATOMIC ENERGY COMMISSION-i I
In-the Matter of )
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CINCINNATI GAS &' ELECTRIC COMPANY . .) .
) Docket'No. 50-358 f COLUMBUS & SOUTHERN OHIO ELECTRIC CO.
DAYTON POWER & LIGHT COMPANY ')
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(Wm. H. Zimmer Nuclear Power Station) )
INITIAL DECISION Appearances Applicant:
Troy B. Conner, Jr., Esq.
Mark Wetterhahn, Esq.
William J. Moran, Esq.
James J. Mayer, Esq.
William G. Porter, Jr., Esq.
Michael P. Graney, Esq.
Julian de Bruyn Kops, Esq.
J. Robert Newlin, Esq.
S. F. Koziar, Esq.
Regulatory S taf f :
Myron Karman, Esq. ,
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UNITED STATES OF AMERICA Y?
-;- A'IOMIC ENERGY COMMISSION
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' In the Matter of )
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CINCINNATI GAS 8e ELECTRIC COMPANY )
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COLUMBUS & SOUTHERN' OHIO ELECTRIC CO. ) Docke
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' DAY 10N POWER & LIGHT COMPANY E
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INITI AL DECISION G omen et the secreten tune tracee:m
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D I. Procedure and Background g gf ;
- 1. On April 6, 1970, the Cincinnati Gas 8: {
J Electric Company (Cincinnati), for itself and as the l l' agent for Columbus and Southern Ohio Electric Company (Columbus), and-the Dayton Power and Light Company (Dayton) ( Applicants) filed with the United S ta tes Atomic Energy Commission (Commission) an Application for authority to construct a nuclear power plant pursuant to the Atomic Energy Act of 1954, as amended (Act). l 4
S ubsequen tly , they filed 21 amendments to their Application (Item 6, Joint Exhibit A). {
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- 2. The nuclear power plant (facility), to l
be designated the Wm. H. Zimmer Nuclear Power S ta tion, employs a boiling water reactor designed to operate
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--2I-initially at therrated power of 2,436 megawatts thermal (MWt) (Staf f Safety Evaluation' Report, February- 18,_.1972,.
page l'; hereaf ter SER) .
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3.. The' proposed facility would be located on a 635 acre tract of land in Washington Township, Clermont County , -State of Ohio , approximate 1y ' 24 miles southeast
north of Moscow, Ohio (SE R , p. 7).
- 4. . When filed with the Commission, the Application for the Wm. H. Zimmer Nuclear Power Station l was assigned to the Division of Reactor Licensing (S taf f) l which had the responsibility for the safety review and evaluation of applications for construction permits and operating licenses.
- 5. During the period since April 6, 1970, the Staff conducted a technical review and evaluation of the safety of the proposed f acility using standards and criteria issued by the Commission. In the course of this review, they held many meetings with representatives of the Applicants and its principal contractor, the i General Electric Company, to discuss safety-related ]
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aspects of plant design. To this date an estimated 1,004 man-days of technical effort have been expended in conducting the review of the Zimmer Nuclear Power Station (Tr. 113, 340). ,
- 6. The Application was reviewed by the Advisory Committee on Reactor Safeguards ( ACRS) as well as the S ta f f ,
Both the S taf f and the ACRS concluded that .there r(
is reasonable assurance that the Wm. H. Zimmer Nuclear Power Station can be constructed and operated without undue risk to the health and safety of the public (SE R , p. 144). .
- 7. The Commission published on March 7, 1972, a Notice of Hearing on Application for Construction Permit (37 F. E. 4925) setting forth the findings ,
necessary to form the basis for issuance of a construc-tion permit to Applicants, and specifying the issues to be considered and decided by an Atomic Safety and Licensing Board (Board) in a public hearing. The Notice provided that in addition to considering and determining the issues pertaining to radiological bealth and sa fe ty, the Board would consider and make determinations pursuant ,
i to the Commission's Regulations in 10 CFR Part 30, i
Appemlix 0 (he rea l'l o r collec t ivel y referred to as )
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environmental aspects), for the implementation- of the National' Environmental Policy Act of 1969 (NEPA)
(42 U.S.C. A. Section 4321 et. seq.).
, 8. In addition, the Notice granted the opportunity;for' persons to file petitions for leave to intervene.with respect to the specified issues, or to make an oral or written statement in the form of a limited appearance.
- 9. Petitions to' Intervene in the Hearing were filed by Mr..and Mrs. Arthur J. Casnelli, Dr. David B.
Fankhauser, Mr. and Mrs. J. Hal Fichter, Mr. and Mrs. R. E.
.,- Nord, and Dr. Elizabeth Seeberg as Executive Secretary of it the " Ohio Valley Group Concerned about Nuclear Pollution".
- 10. By Notice and Order da ted April 21, 1972, the Board advised each of the petitioners that their respective letters petitioning to intervene failed to meet the requirements of Section 2.714 of the Rules of i Practice. However, the Board afforded each of said j
petitioners a second opportunity to amend and supplement J l
their respective petitions.
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- 11. Mr. and Mrs. R. E. Nord asked.to withdraw,,
and the' Board agreed (Tr. 15, 57). Dr. Fankhauser, L
1' Mr. and Mrs. Fichter, and Dr. Seeberg amended their 1:
- petitions and.were permitted a third opportunity at the Prehearing Conference on'May 12, 1972, to further particularize their contentions and to state their 1
interests (Tr. 1-73). Mr. and' Mrs . A. J . Casnelli , e ,.
l failed to respond-to the Notice and did not' appear at -
. the Prehearing Conference; accordingly, the Board (
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l denied their petition in due course.
- 12. A prehearing Conference was held at .
Batavia, Ohio, near the site of the proposed facility
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on May 12, 1972, to consider all the issues before the parties, including the questions posed by the petitions ,
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to intervene, and to prepare for the Evidentiary Hearings ,
i which would'be conducted in two sessions -- one on the radiological health and safety aspects and another on 4
. the environmental aspects.
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. 13. By Order Determining Intervention issued May 22, 1972, the Board found that the petitioners
-- Dr. Fankhauser, Mr. and Mrs. Fichter, and Dr. Seeberg --
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- did not meet the basic requirements of the Rules of Practice, especially Section 2.714 thereof. Even after three opportunities, the assertions made by the petitioners were so general and unparticularized that they simply constituted generalized attacks against all-nuclear reactors.
- 14. An Evidentiary Hearing on health and 4
safety issues was held in Cincinnati, Ohio, on June 1-2, 1972 (Tr.74-405). Pursuant to the Order of the Board dated August 18, 1972, a Prehearing Conference and Evidentiary Hearing, primarily on environmental issues,
-was held on September 20, 1972, in Cincinnati, Ohio The only (Tr. 406-419, Tr. 420-453, respectively).
parties to the proceeding were the Applicants and the Staff. Therefore, this is not a contested proceeding within the meaning of Section 2.104 and Appendix A of the Commission's Rules (10 CFR Part 2),
including a
- 15. Approximately 45 persons, number of public officials made limited appearances, including all those persons who had petitioned to intervene , except Mr . and frs . Casnelli (Tr.162) .
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- 16. Applicants first submitted an Environmental Report for the Wm. H. Zimmer Nuclear Power Station to the Commission on January 15, 1971. A draf t detailed statement on environmental considerations dated June 28, 1971, was circulated to the cognizant Federal agencies and made available for comment by State and local officials and other interested parties by a summary notice of availability published in the Federal Register on July 24, 1971 (36 F. R.
13805). Following the Commission's revision of Appendix D to 10 CFR 50, issued on September 9, 1971 (36 F. R. 18071),
Applicants submitted supplements and amendments to its Environmental Report, expanding the data contained in its original report. Notices of Availability of the Applicants' Environmental Report and Supplemental Environ-mental Reports (Supplements 1, 2, and 3) were published in the Federal Register on July 24, 1971 (36 F. R. 13805) and on February 17, 1972 (37 F. R. 3556), respectively.
- 17. On May 15, 1972, the Commission issued its Draf t Environmental S tatement. Notice of the availability of the Statement was publ,ished in the Federal Register on May 17, 1972 (37 F. R. 9800), and pursuant to Sections A.6, A 7, and 'D.1 of Appendix D to 10 CFR 50, Gove rnmen t i
agencies and interested persons were given thirty days from the date of publication of the Notice to submit comments for the Commission ts considera tion. 'lederal and S ta te agencies' were provided with copies o f the Draf t Environmental Statement. Comments received from these agencies were made available to the public and were l
considered in the preparation of the Final Environmental Statement (FES) (FES, vi). The Commission issued its Final Environmental S tatement in September,1972. Notice of its availability was published in the Federal Register on September 12, 1972 (37 F. R. 18485).
- 18. The record of this case, in addition to j the transcript, includes inter alia, the following substantive material: the Application, Docket No.50-35S;
~ the preliminary Safety Analysis Report (pS AR) , with amendments (Tr. following p. 333); the Applicants' Summary of the Application, with amendments (Tr. following p. 333); ;
the Safety Evaluation Report by the Division of Reactor e Licensing, as amended (Tr. following p. 358); Statements of Financial Qualifications of Applicants (Tr. following 2
- p. 338); Applicants' Environmental Report (ER), as amended (Tr. 479, Applicants ' Exhibit #1) ; S ta f f's Final Environmen tal S ta temen t (Tr. following p. 483). Sixteen witnesses were presented by the parties in support of this Applica tior.
(Tr. 322, 423).
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< 1 II. Hea'lth and' Safety AspeNts A. Design and Site
. 19. The record shows'that the Applicants have adequately described the proposed design of the f acility and have identif'ied the major elements incorporated
- therein for the protection of the health and safety of the public, for example:
(1) The design of the plant's major systems and components, which bear significantly on the acceptability of the facility at the proposed site under the site criteria guidelines e identified.in Part 100 of the Commission's Regulations, has been analyzed and evaluated by the Applicants and the Staf f a t the ultima te power of 2,540 MWt (PS AR 5 1.6 ; SER, p. 1).
. (2) In conjunction with the Staff and the ACRS, the Applicants' have identified a number of on-going investigations to support the design of certain of the plant systems (SER, pp. 126-12h,pp. 1-140, Appendix B; o
i Tr. 399-401). These investigations include:
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(a) Ase smic Design of Main Steamline
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(b) Main Steamline Sealing System.
(c) Design of the Gaseous Radwaste Sys tem.
(d) Design of a Combustible Gas Control System.
(e) Techniques for the Analyses of a Postulated Rod-Drop Accident.
(3) Geological and seismological s tudies-show that the Zimmer site is located in a seismically stable region. Structures and equipment important to safety will be design for the design-basis earthquake which has defined horizontal ground acceleration of 20 percent of gravity, which is twice as severe as the design value for the operational-basis earthquake (PSAR, E 2.5.3 ; SER, pp. 15-17).
i (4) From a foundation standpoint, the site is suitable for the construction of the structures of the facility. The behavior of the
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on-site soils under earthquake loading has been evaluated. A clay blanket will surround the recompacted soil supporting the main .
building. complex (PS AR, E 2.5.4.4; SER, pp.-17-19; Tr. 382-385).
(5) Detailed studies of L ground and River water conditions by both~ the Staf f and the Applicants show that neither normal nor accidental releases of radioactivity will endanger l drinking water supplies using the Ohio River or ground wells in the vicinity of the Zimmer site (pSAR, E 2.4; SER, pp. 4-5; 4-7).
(6) Meteorological studies have been initiated at the site beginning in June, 1971, l
to demonstrate the conservatism of the meteorological assumptions used in the calcula-tions of routine and postulated accident doses (PS AR, a 2.3.2 ; SER, p. 11).
B. Technical Qualifica tions
- 20. The Applicants have had extensive experience in the design, construction, and operation of large power proj ec ts . Their contractors, Sargent & Lundy, Engineers, which is providing architect-engineer services ; General
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Electric Company, which is furnishing the nuclear steam g - supply system; and Kaiser. Engineers, Inc., the constructor,
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have had. extensive experience within their respective scopes 'of work (SER, pp. 132,1133; PSAR, 8 1.1.2).
- 21. The Staff concluded that, based on its review,
' the Applicants retain a technically competent and safety-oriented engineering capability that'can effectively manage,. design,-. construct, and operate the facility (SE R , pp. 132-134)..
- 22. We. find that the Applicants are technically qualified to design and construct this facility.
C. Financial Qualifications
- 23. The Applicants are incorporated under the 4
laws of the State of Ohio and are authorized to transact business as public utilities therein. They are engaged primarily in the production, transmission, distribution, and sale of electric energy and the distribution and sale of natural gas in the southwestern, central and southern, 4 and west. central portions of Ohio (Tr. 338, SER, pp. 141-143).
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- 24. The three companies 1(Applicants) will own,
-as tenants in common, undivided interest in the facility
, with each company having h fixed-percentage share of ownership. Cincinnati is responsible.for the design, construction, and operation of the f acility and is authorized to act as the agent for Columbus and Day' ton
't' in all. phases of design, construction, and operation including licensing (SER, . p. 142).
25.- The Applicants' electric revenues for 1971.were nearly $440,000,000. Each of the Applicants expects to finance the facility by a combination of accepted methods including internal and long-term financing. An analysis by the Staf f, of the Applicants' financial statements over a three-year period (1968-1970) indicates a sound financial position, sound financing, significant resources, steady increase over the period /
in the level of operating revenues and plant investment, and a continued sustained level of earnings (SER, pp. 141-142).
i- 26. The record shows that the Applicants air financially qualified to design and construct the facility.
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D. Common Defense and Security I 27.. The activities to be. conducted by the Applicants under'the construction permit will be within the jurisdiction of the United States. All o'f their ;
directors and principal of ficers are United States citizens, None of the Applicants is owned, controlled, or dominated by.an alien, a foreign corporation, or a
' foreign government (SE R , pp. 140-141).
- 28. The-activities to be conducted do not involve any Restricted Data, but Cincinnati has agreed to safeguard any such data which might become involved in accordance with the Commission's Regulations.
Cincinnati will be accountable and responsible for the physical protection of fissionable material. The Staff I
has concluded that the act'ivity to be performed will not l be inimical to the common defense and security (SER, pp. 140-141).
29, We find that the issuance of a construction to the common permit for this facility will not be inimical !
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defense and security.
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- 30. In view of the findings 19 - 29, above, which relate to the issues listed by the Commission in {
its Notice of Hearing dated' March 3, 1972, we conclude that the Staf f's review has been adequate to support the proposed findings to be made by the Director of Regulation.
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. III. Environmental Aspects
- 31. The need for power in the region served by the Applicant has been analyzed (FES, X-1) .
Applicants' fodecasts and conclusions are supported by those of the Staf f and the Federal Power Commission (FES, Fig. X-2, pp. B-18, B-23). Alternative means of meeting the forecast demand were evaluated. The feasible ones included . power purchase and installation of base-load fossil-fueled capability, and installation of peaking capability as well as alternative fuel for the base-load fossil-fueled facility. The Applicants concluded and the Staf f's evaluation found that each of these alternatives has significantly higher economic cost and significantly greater adverse environmental effects than construction and operation of the proposed f acility (FES, XI 1-7).
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- 32. The S taff has concluded that the' select' ion of the site was the result of a detailed study and sorting )
of the ~few remaining potential sites along the particular
'section of the Ohio River and that, at this time, any new 4
site would have a greater. environmental impact and would result in substantial additional economic penalties (FES, XI 7).
- 33. The irretrievable commitment of the land involves the loss of potential production and habitat of approximately 300 acres of wooded area, primarily of
. shrubs and trees of non-timber quality. Much of this land was formerly cropland, with potential yield of corn being approximately $7,000 annually. The S taf f concluded that because the land was infrequently used for recreation pursuits, the effect of withdrawal of this land from such use is insignificant (FES, IVB 3). The Staff determined that the impact caused by the removal of habitat is not regarded as the dominant, even appreciable, impact on life systems (FES, IVB 4).
- 34. The record shows that the facility is needed in order for the Applicants to meet the forecast !
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of electrical power demand and that construction of the'
- facility.at this site is the best available economic and environmental alternative. ,
- 35. There is'some unavoidable environmental impact to-the site during construction. Shoreline excavation, dredging, pile driving, and surface drainage will cause a temporary disturbance of the water drainage patterns resulting in increased siltation affecting a relatively small area of the River. Because of the comparatively short duration of these activities, no appreciable impact on the overall River ecosystem is f expected (FES,.IV 1).
- 36. The Applicants have taken and agree to continue action to prevent sosi erosion during construction-by methods such as retaining vegetation and trees, where possible, and by reseeding those areas that.have been brought to their final grade (Tr. 516-524). This temporary impact during construction must be balanced against a byproduct of the operation of the settling pond over the life of the facility. Annually an estimated 2,000 l tons of silt will be removed from the Ohio River in the i
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cooling tower-basin by virtue of.the operation of the cooling tower. This material will be used in such a manner as to prevent it from re-entering the River (Tr. 527-528).
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. 37. The Applicants have agreed to the Staff recommendations that they will control and minimize soil erosion to the Ohio- River. in site and transmission line
- construction, maintain dust control, and seed and land-scape cleared areas to hasten return of the construction site to a stabilized condition (FES, iii-iv(a)-iv(c);
Tr. 516).
- 38. The Board finds that in view of findings 35, 36, and 37, above, the construction activities will have an insignificant impact on the environment.
- 39. The Applicants are taking steps to make the power plant structures and surrounding area attractive and aesthetically pleasing (FES, III A; Tr. 500). Trees 4 that do oct interfere with construction will be saved and additional planting will be carried out to provide an architecturally pleasing appearance (Tr. 526). Mbile the large size of the cooling tower will have some visual e
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impact, this impact is small in comparison to the environmental-benefits of,this cooling, alternative
, '(Tr.'499, 500, 539-541). In addition, the' Applicants-have agreed to' consider alternatives for making the tower.
aesthetically more acceptable-(Tr. 541).
- 40. The facility will require three 345 KV transmission lines to accommodate its electrical output.
Two of the lines use existing towers and rights-of-way - ,
and for this reason are not expected to have any additional environmental impact. The routing and type of transmission structures for the third (Zimmer-Brent) line were chosen af ter considerable study of alternatives and with due regard to environmental considerations (FES, III 2, 3, 4; Fig. III-2).
- 41. The Board finds that the transmission line and the cooling tower will have a visual impact near the facility (Tr. 499, 500; FES, III 2, 3, 4).
- 42. During routine operation of the facility, small quantities of radioactive materials will be released to the environment. These radioactive materials will ;
contribute an extremely small increment to the natural
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' background Lradiation dose that area residents now
. receive. Since variations'in the natural background may be expected'to exceed the'small. increment of dose contributed by the facility, the incremental increase will'be unmeasurable in itself an'd will constitute no-meaningful risk. Taking into account direct radia tion
- - exposure, the ingestion of radionuclides from food or water, and biological accumulation f actors, there would 1
be no meaningful risk from the extremely small incremental radiation-dose-from the operation of the facility (FES, V-22).
- 43. The Board finds that no deleterious effects on the' environment are to be expected'from the release of radioactive effluents during operation of the f acility.
- 44. Alternatives to the natural draft cooling tower, including once-through cooling, cooling ponds, spray canals, dry cooling towers, and forced draf t' cooling towers, have been considered and rejected by both the Applicants and the Staff for a combination of i
. technical, environmental,and economic reasons (ER, 8 9.4.1; FES , X I-8) . While infrequent occurrences of fogging and icing at short distances may occur as a result of the
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. expected (FES, V-B).
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_45. The cooling tower requires approximate 1y' ;
12,000-gpm of makeup water for blowdown and to replace f
the consumptive losses due to evaporation (Tr 498). '
The Staff has concluded that the consumptive wa ter use represents only about 0.2 percent of the extreme low River flow, and this would not have a significant impact on the Ohio River (FES, E 5.A).
- 46. In order to control microbh logical growths which would otherwise foul the condenser tubes, Applicants plan to add chlorine intermittently to the closed cycle turbine condenser cooling water system.
During these short periods of time, Applicants will maintain the chlorine concentration in the circulating system to a maximum of 0.5 ppm by monitoring and controlling the feed rate (FES V-1).
- 47. The dissolved minerals in the blowdown stream will be the same as those already in the River, i
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an'd <the resulting concentration will be limited by the control of blowdown rate. The Staff has' concluded that
, it is extremely.unlikely that chemical effects will be-deleterious to the . biota (FES , V-ll) .
- 48. The Board finds tha t among the feasible
, alternatives for cooling the facility, the cooling tower has the'least adverse environmental. impact.
- 49. Applicants will be required to undertake
- both a radiological and an environmental monitoring-program-(FES, iv-d). Applicants are in the process of developing a comprehensive environmental baseline study
> - program (Joint Exhibit B, Item 26) for the implementa-tion during construction of the facility. The S taf f is l
being consulted on this program as it is being . developed.
An analysis of the results of this program will be reported to the Staff semiannually. This preopera tional sampling of the physical, chemical, and biological
. parameters of the environment is being developed to
, establish baseline conditions upon which possible operational
, effects can be evaluated. The objectives of the monitoring-
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programs are1to disclose a y. changes which may occur.in .
the land and water ecosystem as a result of facility operation (FES, V-14; Tr. 515-518).
- 50. The Applicants will conduct a preoperational radiological environmental monitoring program to determine -
background radiation prior to station startup to assure 1
tha t anticipated radiological _ releases are within l
established guidelines and subsequently to determine 1 the radiological effects of station operation on'the environment. The S taf f has concluded tha t 'this program is' adequate to determine any radiological effects on the environment from the operation of the facility (FES, V-18).
- 51. Applicants will conduct a comprehensive weather data collection program at the site prior to s tation operation. The preoperational program is already underwa y (ER, @ 7.2 ; Tr. 491-493).
- 52. The Board finds on the basis of the evidence presented that Applicants have described adequate pre-operational radiological and meteorological monitoring programs and that details of the operational radiological
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and'other monitoring programs can reasonably be left for i determination in connection with the operating license.
- 53. Any fuel that is shipped to or from the site will be in accordance with the Regula tions and requirements of the Commission and the Department of Transportation (FES, V-g; Tr. 521). Under normal shipping conditions, no release of any radioactive ma terials will occur; and under the very severe accident conditions postulated, only slight releases are expected.
The Staf f has estimated tha t if approxima tely 90,000 persons reside along an assumed 300-mile route over which irradiated fuel might be transported, these persons might receive, under normal conditions, an annual cumulative dose of about 0.01 man-rem (FES, V-26).
Under severe transportation accident conditions, persons within 100 feet or so of the accident might receive doses as high as a few hundred mrem (FES, VI-7).
- 54. The Board finds that the transportation of new fuel to the facility or spent fuel and radio-active wastes from the facility will have an insignificant impact on the environment.
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- 55. The Final Environmental Statement for the facility, issued September, 1972, has considered l alternatives and made a cost-benefit assessment. The l
Board finds that the consideration of alternatives and I; cost-benefit assessment by the Staff is adequate. l
- 56. Any proposed findings submitted by the .
L parties hereto, which are not incorporated directly
'or inferentially in this Decision are herewith rejected as being insupportable in law or fact, or as being unnecessary to the rendering of this Initial Decision.
CONCLUSIONS
- 57. The Application and the proceeding thereon comply with the requirements of the Act and the Commission's Regulations.
- 58. Upon consideration of the entire record in this proceeding and the findings set forth above, this ,
Board concludes that the Application and the record of the proceeding contain sufficient information, and the review of the Application by the Staff has been adequate, to support the , findings proposed to be made by the Director of Regulation on Items 1 - 4 of the Commission 's Notice of Hearing on this Docket.
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- 59. :In accordance with Appendix.D to Part 50'of-the Commission 's Regula tions , the Board concludes as
'follows:
- a. The environmental review. conducted by the Commission's Regulatory Staff pursuant to Appendix D has been adequate.
- b. The requirements of Section 102(2)'(C) and (D) of-NEPA and Appendix D have been complied with in this proceeding.
- c. Upon independently considering the final balance among the factors contained in the record of this proceeding, a permit should be granted for the construction of the Wm. 11 ,
Zimmer-Nuclear Power Station, subject to the conditions listed and set forth in the Final Environmental Statement, page 111, paragraph 8"a" through "d", which are incorporated herein by
. reference and made a part of this Decision.
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ORDER
- 60. Based on its findings and conclusions taking into account radiological and environmental phases of the IIcaring and pursuant to the Atomic Energy Act and
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i the Commission's Regulations, IT.IS ORDERED that the Director of Regulation issue a construction permit to the Applicants
. for the construction of.the Wm. H. Zimmer Nuclear ~ Power Station to include the conditions set forth above. IT.IS FURTHER ORDERED in accordance with 10 CFR 2.760, 2.762, !
2.764, 2.785, and 2.786 of the Commission's Rules of Practice that this Initial Decision shall constitute the
~ final decision of the Commission subject to the review thereof pursuant to the above-cited rules.
BY THE ATOMIC SAFETY AND LICENSING BOARD i is Dr.'Hughk.Paxton, Member G4 Dr. E(gene Greul[ng, Member
/NM kJ Jo . FarmakiSes, Esq., Chairman Issued at Washington, D. C.,
this 19th day of October, 1972.
.