ML20248J340
| ML20248J340 | |
| Person / Time | |
|---|---|
| Site: | 07000025 |
| Issue date: | 10/13/1989 |
| From: | Bloch P Atomic Safety and Licensing Board Panel |
| To: | NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| References | |
| CON-#489-9303 89-594-01-ML, 89-594-1-ML, LBP-89-29, ML, NUDOCS 8910180108 | |
| Download: ML20248J340 (21) | |
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'89 DCT 13 P 4 :09 LBP-89-29 Of f.y,y i , % g i OhobeY A13 ', 1989
, UNITED STATES OF AMERICA ,
NUCLEAR REGULATORY COMMISSION SERVED OCT 1 B 1989 ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judge Peter B. Bloch In the Matter of Docket 70-25 ' N b ROCKWELL INTERNATIONAL Request to Renew CORPORATION For Ten Years g Rocketdyne Division (Special Material License ASLBP No. 89-594-01-ML Number SNM-21)
MEMORANDUM AND ORDER (Completeness of the Hearing File in Subpart L Proceedings)
On October 5, 1989, the Atomic Safety and Licensing Appeal Board issued an Order in which it strongly stated its unilateral conclusion -- made sua sponte, without any appeal by a party -- that the Presiding Officer has improperly engaged "in a form of judicial activism (i.e., discovery) l unprecedented in NRC licensing proceedings" and not j authorized by the applicable procedural rules (10 CFR Part 2, Subpart L).
The Appeal Board then directed the Presiding Officer to explain his " authority for the role he has independently 8910100100 891013 PDR ADOCK 07000025
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1 assumed in this proceeding."1 The stated grounds for the ,
Appeal Board's concern were three orders in which the Presiding Officer has asked questions of Rockwell.2 This case was assigned to the Presiding Officer on August 21, 1989, and already has a substantial history, including two filings by the Staff of record material that may now constitute the " hearing file" required by the regulations. There has been a limited appearance session in California on the evening of September 28, 1989, and a preliminary hearing conference on the following day.
Parties have been admitted and a schedule for the case has been promulgated. LBP-89-27, 29 NRC ,
(October 5, l
1 The Appeal Board's Order is of a type that obviously should be used sparingly. It is like an interlocutory appeal, which is limited even in formal proceedings to instances where a party is faced with a serious irreparable impact or by a ruling that affects the structure of the proceeding in a pervasive or unusual manner. Public Service go. of New Hamoshire (Seabrook), ALAB-271, 1 NRC 478 (1975).
Unilateral actions, unlike interlocutory appeals, have the added problem that they are taken without benefit of briefs.
When no party has raised concerns, a court or administrative body that chooses to act is out on a limb by itself. The consequence of such appellate intervention is that the presiding officer is required to spend substantial time in response and there is a chance the parties may also have to become involved -- even though they did not choose to raise the issue -- thus diverting everyone's attention from the substance of the case.
2 Those orders will be discussed below. The last of those orders may be found as Attachment A, below.
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l 1989). Three orders have been issued requesting information I from Rockwell.3 The actions of the Presiding Officer have been taken in i order to expedite this proceeding pursuant to Commission policy. Statement of Police on Conduct of Licensina Proceedings, CLI-81-8, 13 NRC 452 (1981). The Commission says, at p. 453 of its Statement, that In the final analysis, the actions, consistent with applicable rules, which may be taken to conduct an efficient hearing are limited primarily by the good sense, judgment, and managerial skills of a l presiding board which is dedicated to seeing that l the process moves along at an expeditious pace, !
consistent with the demands of fairness.
As soon as the case was assigned, the Presiding Officer determined that people who had requested to become parties (requesters) were required, to gain party status, to show that they had concerns that were germane tc the Application.
10 CFR S 2.1205(g). It was obvious from the filings of the requesters that they would need a copy of the rules of procedure (Subpart L) and of the Application, if they were to have a fair chance to comply with the requirements in the regulations. Hence, the Presiding Officer: (1) requested that the Staff serve the application and related materials on the parties and on himself'; (2) had Subpart L served on j i
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September 15, 1989; September 18, 1989; and October 4, 19P9.
'A Memorandum of August 31, 1989, announced that the l
Application had been sent to the requesters. Together with the Application, the Staff also filed related materiuls,
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I the requesters; and (3) set a deadline by which the parties 1
were expected to comply with the rules. Memorandum, August I l
31, 1989 (unpublished).
While technically the orders requesting information )
from Applicants may not have been authorized at the time they were issued by 10 C.F.R. S1233(a),5 the possible error 1
appears to be largely a technical one and has not harmed any ]
l party.' The Staff had served documents that constitute the bulk of the hearing file before any questions were asked.
The Staff has supplemented our record with additional documents that may well complete that file.7 It is clear that the Presiding Officer did not engage
.in discovery, which is a process authorized by the Federal Rules of Civil Procedure and other rules of procedure far use by carties.8 consisting of an EPA report, Santa Susana Field Laboratory Site ReDort, July 31, 1989. The attachments to the Application included annual reviews of radiological controls and annual environmental assessments of operations.
5 This section requires that a notice of hearing be published and the hearing file created before questions are authorized.
'The last order, which apparently triggered this action by the Appeal Board, was issued after the Presiding Officer had issued a Federal Recister Notice but before that notice l was actually published in the Register.
7 l See letter from Leland C. Rouse, dated October 3, transmitting " additional background information."
8 Black's Law Dictionarv (Fifth Edition) at 49.
i ks e i
What has been done is to exercise authority to ask !
questions designed to assure a complete record. The use of such authority is proper in proceedings of this' agency and it is not unusual, as is discussed below. It also appears to be appropriate under Subpart L, which prohibits
" discovery" by "a party or . . . participant" but which does not contain any prohibition of " discovery" by a presiding i officer. 10 CFR S 2.1231(d). Rather, Subpart L increases the burden on the presiding officer to insure that the record is complete.
Nor has the Presiding Officer independently assumed any authority. He was duly appointed and has exercised that authority conscientiously. Even if he committed a technical- i error -- which probably will have no effect because it )
- relates solely to the timina of actions taken in the proceeding -- that does not mean that he independently assumed any authority. The power to judge necessarily
- entails the power to err.
The Presiding Officer is obligated "not just to call I balls and strikes" (a phrase whose legal background will be discussed below) but to raise questions that would help to complete the record so that a fair, informed and efficient decision could be made.
Such questions, if needed to complete the record, clearly seem to be contemplated by S 2.1233(a), which provides:
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The presidipg officer also may, on his or her initiative, j
submit written questions to the parties to be answered in writing, under oath or affirmation, and supported by appropriate documentary data, informational material, or other written evidence. [ Emphasis supplied.]
of course, this authority is made contingent on questions j being asked after the NRC staff has made the hearing file
]
available.10
'The presiding officer's initiative is, of course, limited by 10 CFR S 2.1251(d), which requires him to promptly advise the commission if he independently examining issues not put in controversy by the parties.
10 The Statement of Considerations, 54 Federal Reaister 8269 (2/28/89) places a heavy responsibility on the presiding officer to control the exploration of issues raised by the parties. One portion of the Statement (Id.
at 8269) prohibits the hearing officer from requesting oral presentations before the written filings of the parties are received:
There would be no discovery. Only if the presiding officer found that the written presentations were insufficient to create an adequate record would oral presentations be permitted. [ Emphasis added.)
However, the Statement of Considerations goes on to state I that:
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Essentially, the informal hearing is designed to elicit information and resolve issues crimarilv ]
1 throuch inauiry by the cresidina officer rather l than through an adversarial confrontation between j the parties. As a consequence, the presiding l
officer has broad discretion in controlling the i manner in which the issues raised by the parties 1 are to be explored. [Emphasia added.] l When the Statement of Considerations is viewed alongside the regulations themselves, it is clear that the presiding l officer has broad authority to ask written questions. 10 CFR l S 2.1233(a).
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4 At the present time, after reflecting on the nature of the requirement for a " hearing file", the Presiding Officer needs clarification from the Staff about whether the mater-ials that have to this time been filed constitute the hear-ing file.11 This will inform everyone about whether all available data is already in the file or whether there are other installments to come. Conceivably, this may provide the Presiding Officer with a basis for amending or with-drawing questions that have already been asked.
In asking questions, the Presiding Officer does not know whether the answers will favor Rockwell or the interveners. In fact, he has no concern over who may be favored. His purpose is to complete the record.12 If Rockwell feels that questions that have been asked are not required for a complete reccrd, or if it prefers to delay responding to the questions until a later stage of the 11 If there are any materials or studies in the possession of the Staff relating to the way in which pollution on the site was deposited there, and Rockwell's responsibility or lack of responsibility for that pollution, then the Staff should include such materials in the hearing file.
12 When a hearing is accompanied by extensive publicity there is pressure on the Applicant to answer questions rather than to assert its right not to answer them. This makes the presiding officer's discretionary decision about whether or not to ask questions a particularly important one. Hence, the presiding officer has been particularly careful to reflect on questions before they are asked and to concult in advance with the technical adviser, who is an experienced physicist and a seasoned veteran of NRC pro-ceedings.
,,'6.. -w.
b proceeding, it already has-been issued a general invitation to file motions for reconsideration.13 Rockwell, which has experience in NRC 1.'.tigation,
' appears to be 'well represented in: this proceeding. Its principal representative is Mr. R.T. Lancet of its licensing department. Its principal spokesperson at the preliminary hearing and limited appearance session was Dr. Joseph Mills
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of its nuclear safeguards review panel. It also enjoys the legal advice of Mr. Richard Seamans, counsel.for Rockwell, who was present'at the preliminary hearing. Tr. 255.
I. The Role of Presiding Officers in Asking' Questions The purpose of this section of this memorandum is to address the Appeal Board's assertion that the Presiding Officer's " activism" is " unprecedented in NRC licensing proceedings."
A. Court Precedent It is a well-established principle of administrative law, with respect to the Nuclear Regulatory Commission and l all other agencies, that an agency is a representative of the public interest and cannot "act as an umpire blandly calling balls and strikes for adversaries appearing before i 13 Such a motion may be filed within ten days of the service on Rockwell of this Memorandum and Order.
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1 it. . . . Scenic Hudson Preservation Conference v. Federal Power Commission. 354 F. 2d 608 (2nd Cir.) 1965 at 620.
The principle applies to bankruptcy proceedings, where a referee in bankruptcy is expected to apply his expertise and is not simply an umpire calling balls and strikes.
He has an affirmative responsibility for the proper handling of the estate . . .
1 It, of course, applies to the Federal Power Commission.
Scenic Hudson, suora; Jsbrandtsen Co. v. United States, 96 F. Supp. 883, 892 (S.D.N.Y. 1951), Aff'd by eaually divided court, sub nom, A/S.J. Ludwia Mowinckels Rederi v.
Isbrandtsen Co.. Inc., 342 U.S. 950, 72 S.Ct. 623, 96 L.Ed.
706 (1952). It applies to the United States Nuclear Regulatory Commission. Calvert Cliffs Coordinating Committee. Inc. v. U.S. Atomic Enerav Commission 449 F.2d 1109 (C.A.D.C. 1971) at 1119, fn. 21.I' Before discussing the applicable NRC cases, it is appropriate to discuss some of the language in scenic Hudson, suora, that explains the court's adoption of the
" balls and strikes" principle:
" . . . The thread running through this case has been that the applicant is entitled to a license l'The court appears to extend the Commission's responsibility to public safety interests as well as to NEPA.
Computerized research (using Westlaw) into federal court reports indicated that the phrase " balls and strikes" occurs in 21 relevant modern cases, none of which cast any doubt on the viability of the Scenic Hudson principal.
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upon making a prima facie case. My own personal regulatory philosophy compels me to reject this approach. This Commission of its own motion, should seek to insure that a full and adecuate record is cresented to it. A regulatory commission can insure continuing confidence in its decisions only when it has used its staff and its own exoertise in a manner not possible for the uninformed and poorly financed public. With our intimate knowledge of other cystems and to a' lesser extent of their plans, it should be possible to resolve all doubts as to alternative sources. This may have been done but the record doesn't speak.
Let it do so. [ Emphasis supplied.]
For the [ administrative process) to be successful in a particular field, it is imperative that controversies be decided as ' rightly' as possible, independently of the formal record the parties themselves produce. The ultimate test of the administrative [ process) is the policy that it formulates: not the fairness as between the parties of the disposition 5 of a controversy on a record of their own making.
The policy requiring the NRC to protect the public health and safety anu the environment in its proceedings is far stronger than any of the other contexts in which that idea has been applied. All that is necessary is to be present at hearings and limited appearance statements and to observe the difficulty that the most capable, best informed of the inexperienced interveners endure. Nuclear energy is a difficult subject. In addition, studying the regulations is also difficult, even for somewhat experienced judges; it is especially difficult for the uninitiated.
f 15 Citing Landis, The Administrative Process 39 (1938),
a pre-NEPA authority.
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i Surely all the arguments that other agencies should not merely call balls and strikes are dwarfed by the need of the NRC not to just call balls and strikes in any proceeding affecting public health, safety and the environment. !
Consequently, Congress took the unique step of adding independent expertise to the Atomic Safety and Licensing Boards, thus assuring a mix of technical background from which knowledgeable questions might be asked and knowledgeable conclusions reached.
B. NRC Precedents NRC precedent broadly adopts the Scenic Hudson rule that a Licensing Board is not just an arbiter of balls and strikes. For example, in Cleveland Electric Illuminating Co..et al. (Perry Nuclear Power Plant, Units 1 and 2) ALAB-443, 6 NRC 741 (1977) at 751-52, the Appeal Board approved of the Licensing Board's discretionary decision to admit a report into evidence even though no party had made a timely request that it do so. In Pennsylvania Power & Licht Company and Allecheny Electric Cooperative. Inc.
(Susauehanna Steam Electric Station, Units 1 and 2), ALAB-641, 13 NRC 550 (1981), at 552, the Appeal Board refused to hear an interlocutory appeal ' relating to Board questions l
l'At that time, the standard for interlocutory appeal (on motion of a party) was whether " absent immediate appellate review, [it would] threaten a party with serious irreparable harm or pervasively affect the basic structure
l and stated that it would not have heard an appeal even if the licensing board had " raised the issue on its own motion."
In Metropolitan Edison Comoany, et al., (Three Mile Island Nuclear Station, Unit 1) 19 NRC 1193 (1984) at 1248, the Appeal Board spoke approvingly of a Licensing Board that required licensee to produce additional evidence . . . .
"17 l
II. Responsibility of the Presiding Officer The decision about whether or not to ask questions or to wait to see whether the parties will develop the record adequately for themselves is rarely an easy decision due to the complex nature of the extended proceedings that licens-ing judges preside over. To act too soon might prejudice of the proceeding" and the Appeal Board did not consider a broadening of issues in the proceeding to constitute such harm.
17 See also Texas Utilities Generatina Company, et al.
(Comanche Peak Steam Electric Station, Units 1 and 2), LBP-83-69, 18 NRC 1084 at 1086 (1983) (Granting a motion for reconsideration and stating, "We must assure that relevant and material evidence bearing on the admitted contention is sufficiently well developed so that we can prepare a reasoned decision resolving the issues before us.");
Cleveland Electric Illuminating Corrany, et al., (Perry Nuclear Power Plant, Units 1 & 2). LBP-83-3, 17 NRC 59 (1983) (The Board independently dcules a motion for summary disposition even though interveners failed to respond.);
Duke Power Comnany (Catawba Nuclear Station, Units 1 and 2),
LDP-75-34, 1 NRC 626 at 655 (1975) ("[ A] Board must, in order to carry out its public interest obligations, ensure that the parties place on the record sufficient facts on which to i base a reasoned conclusion.").
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the rights of the parties to pursue their own caso. To wait too long, especially when it appears that certain gaps in the record might not be filled by the parties independently, might be to invite lengthy delay that can be avoided if the presiding officer's concerns are voiced earlier.
There have been positive results when a presiding officer injected himself into operating license and license amendment proceedings when his judgment and the judgment of other Board members called for it. For example, in the course of an evidentiary hearing in the Comanche Peak operating license case, the Board took an extensive role in asking questions for Citizens for Sound Energy (CASE), which seemed unable to conduct efficient and effective examina-tions of witnesses.
Prior to the Board questioning in Comanche Peak, no one
-- not the Staff or the Applicants or the Board --
understood the allegations of serious engineering defects being made by Jack Doyle, a career engineer who had once >
worked for Texas Utilities. As a result of the questioning, extensive safety deficiencies were identified, confirmed by the Staff and, ultimately, resolved by the Applicants.
Texas Utilities Generatina Comoany, et al., (Comanche Peak j
Steam Electric Station, Units 1 and 2) 18 NRC 1410 (1983).
The Board asked many written questions in Comanche Peak, including: LBP-85-32, 22 NRC 434 (1985) (extensive I
questions about the proposed comprehensive review of the '
, >e 1
design and construction of the plant); LBP-84-46, 20 NRC 1403 (1984) (Board expresses concern that Applicants' answer to a previous question about welding repairs was not responsive.); LBP-85-37, 22 NRC 601 (1985) (paint quality) ;
LBP-86-36A, 24 NRC 575 (1986) (quality assurance and trending) ; and LBP-83-43, 18 NRC 122 (1983) at 150-153 (questions asked by the Board prior to the appointment of the Board chair).
It should be noted that the Comanche Peak case was resolved through a voluntary settlement among the parties, i
thus saving enormous expenditures on further litigation and possible attendant delay. It appears probable that the Board questions contributed to increased understanding among the parties that helped to establish the conditions for settlement.
In Consumers Power Company (Bic Rock Point Plant) LBP-82-97 (1984), the Licensing Board reached conclusions adverse to Consumers Power as a result of extensive questions that it asked concerning fuel pool criticality.
Although the Licensing Board was correctly reversed, on legal grounds that had not been argued before it, the Appeal Board reviewed the extensive questioning conducted by the Licensing Board without a hint of disapproval that the questioning had occurred. ALAB-725, 17 NRC 562 (1983) at 564-566.
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In one aspect of the Point Beach Tube Sleeving Amendment Case, an intervenor was declared in default when it refused to show up.for a scheduled prehearing conference and refused to answer the Board's questions about the validity of its excuse. Wisconsin Electric Power ConDany (Point Beach Nuclear Plant. Units 1 and 2) LBP-82-108, 16 NRC 1611 (1982). At least two sets of substantive questions also were asked: LBP-81-39, 14 NRC 819 (1981) ; LBP 81-44, 14 NRC 850 (1981).
In the Point Beach case,.the Board appears to have effected great speed through its questioning. The Federal Recister notice of the appointment of the Board occurred on August 25, 1981 and an authorization of a license amendment to conduct certain tube sleeving experiments was published on November 5, 1981. LBP-81-55, 14 NRC 101.7 (1981) at 1019.
The questions asked were very helpful in reaching a rapid and proper determination in this case.1s 18 ALAB-696, 16 NRC 1245 (1982) at 1262-1264 closely reviewed Board procedures despite the fact that reversible error had not occurred. In the course of that review, the Board was never criticized for asking questions of its own.
It was-advised that a "show cause order" procedure was not necessary and that the Board should not purposely deviate i from Commission procedural rules, which contain'enough flexibility in themselves to permit expedition.
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t III. Conclusion The Staff will be asked to clarify the status of the hearing file, including whether or.not it is currently.
. complete and, if not, when.it may be made. complete.
IV. ORDER For all the foregoing reasons and based on consideration of the entire record'in this matter, .it is, this 13th day'of October 1989, ORDERED:
A.- The Staff of the Nuclear Regulatory Commission shall clarify the status of the hear 3ng file in this case within ten days of receipt of this Order.
B. The Staff of the Nuclear Regulatory Commission shall include in the hearing file any materials or studies in its. possession (that'are not already in the hearing file)
.that' relate'to the way in which pollution at the Santa Susana facility was deposited there and to Rockwell's responsibility or lack of responsibility for that pollution.
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Presiding Officer,
.k Peter B. Bloch
(
Administrative Judge Bethesda, Maryland Attachment A: Memorandum and Order (Request for Information), October 4,.1989.
, 1 r____-__2_-_-__ -- - - _ . . _
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.P i-October 4, 1989
89 GCT -5 P1 :03 UNITED STATES OF AMERICA . _ ,
NUCLEAR REGULATORY COMMISSION
[0b 1 -
HA N + -
ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judge -
Peter B. Bloch SERVED OCT - 51989 In the Matter of Docket 70-25~~/kb-ROCKWELL INTERNATIONAL Request to Renew CORPORATION Rocketdyne Division For Ten Years (Special Material License ASLBP No. 89-594-01-ML Number SNM-21)
MEMORANDUM AND ORDER (Request for Information)
After reviewing the Affidavit of Robert T. Lancet, filed by Applicants on September 27, 1989, I have some additional concerns and questions.
I have preliminarily and tentatively reached the following numbered conclusions, subject to further 4
consideration should any of the parties submit contrary j filings or argament, that:
1.
The following incidents, disclosed by Applicants, have in common t ,1at they were contributed to by a material o !
defect or other design error that may have been caused by careless engineering: (a) 9/23/88, " improper material se-lection by designer"; (b) 6/20/88, " material incompatibility"; (c) 2/18/06, " material defect" (appears to w
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)
-2 -
have resulted from improper plugging of the drain line --
not clear the extent to which this is an engineering error);
(d) 9/26/85, " material failure" (not clear whether this i resulted from improper engineering or even whether the disposition represented proper engineering -- see the similar incident on 2/18/86); (e) 4/13/84, " incompatible material", (f) 7/1/82, failure of a gasket seal -- with
{
prescription for regular inspections but no indication of i engineered gasket life or replacement period, (g) 5/22/81 (apparently inadvertently omitted from Table 1), sodium leak due to intergranular stress corrosion cracking apparently I caused by direct contact between mineral fiber insulation and the pipe, with "no sheet metal oven between", (h) 8/5/72, " design error resulted in fatigue failure of thermowell" (failure of engineer to consider properly forces resulting from flow-induced vibration), (i) 2/6/71, cause of incident not clear but solution is to re-engineer the system to delete a hot trap, and (j) 9/28/70, " material failure" (bellows seal valve to be replaced by a stem freeze seal type valve).
2.
This may represent a pattern of events that should have been trended.'
'The Application is required by 10 C.F.R. S 70.22(f),
including footnote 2 to that section, to comply with 10 C.F.R. Part 50, Appendix B, particularly 1 XVI, which requires prompt identification and correction of conditions adverse to quality and -- for significant conditions --
determination of the cause of the condition and corrective
- 3. The reports given may also show patterns with respect to procedure errors and operator errors, possibly due to training, quality assurance deficiencies or personnel selection. There appears to be insufficient information on the forms to know whether any systematic errors of these types exist.
There is no indication on the forms that serious attention has been given to trending.
I respectfully request that similar reports (unusual occurrences, NCRs, RDs, environmental non-conformance reports, etc.) for events that occurred during the past 20 years, involving releases of radioactive materials, should be filed within one month, regardless of whether or not the standards of 10 C.F.R. SS 20.105 and 20.106 have been exceeded. Applicants may file other comments on this memorandum within one month as well.
Interveners may desire to litigate a concern derived from my inquiries. To do so, they may file their concern within 28 days or, if it relates to Applicant's response to this memorandum, within 15 days of the filing of that response.
Respectfully ORDERED, Peter B. Bloch Administrative Judge action to preclude repetition.
l F '
UNITED STATES.0F AMERICA NUCLEAR REGULATORY COMMISSION In the Matter ofI I I
ROCKWELL INTERNATIONAL CORPORATION I Decket No.is) 70-25-ML i
(Rocketdyne Division, Special I Nuclear Materials License SNM-21) l I
CERTIFICATE OF SERVICE l
! hereby certif y that copies of the f orecoina LB M&O (COMPLETENESS OF ...)
have been served upon the followino persons by U.S. mail, first class, except as otherwise noted and in accordants with the requirements of 10 CFR Sec. 2.712.
Administrative Judge Administrative Judoe
. Christine N. Konl, Chairman 6. Paul Dollwerk. III Atomic Safety and Licensing Appeal Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washinoton, DC 20555 Administrative Judoe Administrative Judge Howard A. Wilber Peter B, Bloch Atomic Safety and Licensing Appeal Presiding Officer Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Administrative Judge Gustave A. Liner.berger, Jr.
Special Assistant. Office of the General Counsel Atomic Safety and Licensina Beard U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Wasnington, DC 20555
- R.T. Lancet Director Rockwell International Corporation *Jon Scott Rocketdyne Division 6 Roundup Road 6633 Canoon Avenue Bell Canyon, CA 91307 Canoaa Park. CA 91304
- Estelle Lit
- Jerome E. Raskins, et. al.
18233 Bermuda Street c/o 18350 Los Alimos Northridge, CA 91326 Northridge, CA 91326
4 c,9 + '
'i Docket ~No'.(s)70-23 nL ;
.LB MhD (COMPLETENESS OF ...) {
- -(
.
- Cecell a- . LRiddle-Senior Librarian
.Chatsworth Bran'ch Library.
21052 Devanshire Street'
=Chatsworth, CA 91311 Dated ~at Rockville,-Md. this 16 day.of October'1989 Office i the Secretary of the Commission ;
-i
- Copies have been served upon these persons by Federal Express.
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