View source for IA-98-164, Second Final Response to FOIA Request for Documents.App B Records Encl & Being Made Available in Pdr.App C Records Being Released in Part (Ref FOIA Exemption 4) & App D Records Being Withheld in Entirety (Ref FOIA Exemption 4)

{{Adams
| number = ML20237D292
| issue date = 08/21/1998
| title = Second Final Response to FOIA Request for Documents.App B Records Encl & Being Made Available in Pdr.App C Records Being Released in Part (Ref FOIA Exemption 4) & App D Records Being Withheld in Entirety (Ref FOIA Exemption 4)
| author name = Powell R
| author affiliation = NRC OFFICE OF ADMINISTRATION (ADM)
| addressee name = Dums D
| addressee affiliation = AFFILIATION NOT ASSIGNED
| docket = 
| license number = 
| contact person = 
| case reference number = FOIA-98-164, FOIA-98-188
| document report number = NUDOCS 9808260005
| package number = ML20237D293
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 7
| project = 
| stage = Other
}}

=Text=
{{#Wiki_filter:ip-                                NRC FORM 464 Part I                          (          U.S. NUCLEAR REGULATORY COMMISSION 1-UIAIVA                                     RESPONSE NUMBER       l f8-1998)                                      )
(                                           #
                                                 /* "% %@                                                                                           98-164/188                       2 3
RESPONSE TO FREEDOM OF
                                              =                    f,! INFORMATION ACT (FOIA) / PRIVACY
* RESPONSE
                                                                /                     ACT (PA) REQUEST                                      TYPE           Y REQUESTER                                                                                                DAIE Dennis Dums                                                                     ID PART 1. -INFORMATION RELEASED
                                         '' No additional agency records subject to the request have been located.
Requested records are available through another public distribution program. See Comments section.
Z 'APPENDICE s' --'           Agency records subject to the request that are identified in the listed appendices are already available for
                                                     . - - - . . public inspection and copying at the NRC Public Document Room.
APPENDICES Agency records subject to the request that are identified in the listed appendices are being made available for B             public inspection and copying at the NRC Public Document Room.
m ~Encioieils~iiiformation on how you may obtain access to and the charges for copying records located at the NRC Public
                                     - Document Room,2120 L Street. NW, Washington, DC.
r " APPENDICES ~-
i                gg              Agency records subject to the request are enclosed.
                                     - heciords sdj'ect to the request that contain information originated by or of interest to another Federal agency have been
                                     -- referred to that agem:y (see comments section) for a disclosure determination and direct response to you.
                                      . . - - We are continuing to process your request.
                                     ~~ See Comments.
                                                         ~~'
PART 1.A - FEES AuoUNT * ~                         You will be billed by NRC for the amount listed.                None. Minimum fee threshold not met.
f__                                   You will receive a refund for the amount listed.         y Fees waived.
                                        " 'EdW"''                                                                                                                                                <
PART l.B -INFORMATION NOT LOCATED OR WITHHELD FROM DISCLOSURE No agency records subject to the request have been located.
g- the reasons stated in Part 11.Certain information in the requested records is being withheld from disclosure pursuant to y- Washington, DC 20555-0001.This Clearly statedetermination      may on the envelope andbe   appealed in the letter thatwithin   30 daysAppeal."
it is a "FOIA/PA    by writing to the FOlA/PA Off PART 1.C COMMENTS (Use attached Comments continuation page if required) l
                                                                                                                                                                          ,h                     -
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9808260005 980821 PDR          FOIA DUMS98-164                      PDR NRC FORM 464 Part 1 (6-1998)                                     PRINTED ON RECYCLED PAPER                                 This form was designed using Informs

d
. NRC FORM 464 P rtit                    U.S. NUCLEAR REGULATORY COMMISSION               F0lA/PA                        DAlt i    "TtESPONSE TO FREEDOM OF INFORMATION ACT (FOIA) / PRIVACY ACT (PA) REQUEST 98 # 88 Oeh APPENotCES '
PART ll.A - APPLICABLE EXEMPTIONS C,D             Records subject to the request that are desenbed in the enclosed Appendices are being withheld in their entirety or in part under the Exemption No (s) of the PA and/or the FOIA as indicated below (5 U S C. 552a and/or 5 U S C. 552(b))
Exemption 1: The withheld information is properly classified pursuant to Executive Order 12958
         ~~
Exemption 2: The withhelo information relates solely to the intemal personnel rules and procedures of NRC.
Exemption 3 The withheld information is specifically exempted from pubhc disclosure by statute indicated Sections 141 145 of the Atomic Ennrgy Act, which prohibits the disclosure of Restricted Data or Formerly Restncted Da'a (42 U S C.
2161 2165)
Section 147 of the Atomic Energy Act, whien prohibits the disclosure of Unclassified Safeguards Information (42 U S C. 2167) 41 U.S C., Section 253(b), subsection (m)(1), prohibits the disclosure of contractor proposals in the possession and control of an executive agency to any person under section 552 of Title 5. U S C. (the FOIA), except when incorporated into the contract between the agency and the submitter of the proposal.
Jv         Exemption 4: The withheld information is a trade secret or commercial or financial information that is being withheld for the reason (s) indicated y The information is considered to be confidential business (propnetary) information The information is considered to be propnetary because it concerns a kcensee's or appkcant's physical protection or material control and accounting program for special nuclear matenal pursuant to 10 CFR 2.790(d)(1)
The information was submitted by a foreign source and received in confidence pursuant to 10 CFR 2.790(d)(2).
Exemption 5: The withheld information consists of interagency or intraagency records that are not available through discovery dunng htigation Applicable pnvileges-Dehberative process Disclosure of predecisionalinformation would tend to inhibit the open and frank exchange of ideas essential to the deliberative process. Where records are withheld in their entirety. the facts are inextncably intertwined with the predecisional information. There also are no reasonably segregable factual portions because the release of the facts would permit an indirect inquiry into the predecisional process of the agency.
Attorney woris prcduct pnvilege. (Documents prepared by an attorney in contemplation of litigation)
Attorney-chent pnvilege (Confidential communications between an attorney and his/her chent)
Exemption 6 The withhe!d information is exempted from pubhc disclosure because its disclosure would result in a clearly unwarranted invasion of personal pnvacy.
Exemption 7. The withheld informenon er 'isists of records compiled for law enforcement purposes and is being withheld for the reason (s) indicated (A) Disclosure could reasonably be expected to interfere with an enforcement proceeding (e g , it would reveal the scope, direction, and focus of enforcement efforts. and thus could possibly allow recipients to take action to shield potential wrongdoing or a violation of NRC requirements from investigators)
(C) Disclosure would constitute an unwarranted invasion of personal pnvacy                                                                                  l (D) The information consists of names of individuals and other information the disclosure of which could reasonably be expected to reveal identities of confidential sources (E) Disclosure would reveal techniques and procedures for law enforcement investigations or prosecutions. or guidehnes that could                           )
reasonably be expected to nsk circumvention of the law (F) Disclosure could reasonably be expected to endanger the hfe or physical safety of an individual OTHER (Specify) l l
l PART ll.B - DENYING OFFICIALS Pursuant to 10 CFR 9 25(g),9 25(h), and/or 9.65(b) of the U S. Nuclear Regulatory Commission regulations, it has been determined ih:t tne information withheld is exempt from production or disclosure, and that its production or disclosure is contrary to the public int:r:st. The person responsible for the denial are those offcials identified below as denying officials and the FOIA/PA Officer for any deniils that may be appealed to the Executive Director for Operations (EDO).
DENYING OFFICIAL                                                                                                                  ^""ELLATE OFFIC L TITLE / OFFICE                                RECORDS DENIED                      gg Carl J. Paperiello                     Director. Office of Nuclear Material Safety and             Appendis C,D Safeguards                                                                                         d Appell must be made in wnting within 30 days of receipt of this response. Appeals should be mailed to the FOIA/Povacy Act Officer, US Nuclear Regulatory Commission Washington. DC 20555-0001, for action by the appropriate appellate official (s) You should clearly state on the envelope and letter that it is a "FOIA/PA Appeal "
NRc F oRM 464 Part il (6-1998)                               PRINilD ON RECYCLED PAPER                                        1rus form was cesigned usmg inf orms

i FOIA-98-164/188 APPENDlX B RECORDS BEING RELEASED IN THEIR ENTIRETY NO. DATE     DESCRIPTION /(PAGE COUNT)
: 1. 3/19/98   Fax Cover Sheet to K Panther from B Bouck (1 page)
: 2. 3/18/98   45 degrees 10 MHz 3/8" NRC Demo (7 pages)
: 3. 3/18/98   0 degrees 10 MHz %" NRC Demo (8 pages)
: 4. 3/17/98   VSC-24 Owners Group, Confirmatory Testing of Final Structural Weld (11 pages)
: 5. 3/17/98   P-Scan Automated Ultrasonic Examination of MSB Structural Lid-To-Shell Welds (33 pages)
: 6. 3/16/98  Painted and 150 degrees F (7 pages)
: 7. 3/13/98   Painted 200 degrees F (7 pages)
: 8. 3/12/98  0 degrees 10 MHz % (7 pages)
: 9. 2/27/98  45 degrees 10 MHz 3/8"(7 pages)
: 10. 2/27/98  0 degrees 10 MHz %"(7 pages)
: 11. 2/18/98  Initial Flaw Comparison Table Ambient - No Paint (7 pages)
: 12. 2/2/98   NDT Ultrasonic System Calibration Report (4 pages)
: 13. 12/15/97 Manual Ultrasenic Examination for Planar Flaw Sizing (31 pages)
: 14. 11/19/97 Ultrasonic Examination Report (4 pages) l   15. Undated  Ambient - After Paint Flaw Comparison Table (7 pages) l
: 16. Undated  ANO, photographs (26 pages)
: 17. Undated  Diagram (1 page)
: 18. Undated  Diagram (1 page) l

1 l                                     19. Undated  Image, Probes and Gates, item 45PSL10.9 (1 page)
: 20. Undated  Image, Probes and Gates, item OP-SH-10.3 (1 page)
: 21. Undated  Projected Dose Rate During NDE on MSB (7 pages) l
: 22. Undated  P-Scan Indication Summary Report Form, Search Unit 0 degrees 10 MHz
                                                    %" (3 pages)
!                                     23. Undated  P-Scan Indication Summary Report Form, Search Unit 45 degrees Circ (1 l                                                   page) l                                     24. Undated  Spent Fuel Removal and Dry Storage Operations (2 pages) i
: 25. Undated  Raytheon Engineers & Constructors (7 pages)
: 26. Undated  0 deg - All Flaws - 200 deg F (1 page) l                                     27. Undated  0 deg - All Flaws - 200 deg F (1 page)
: 28. Undated 0 deg - All Flaws - 200 deg F - NRC Demo (1 page)
: 29. Undated 0 deg - All Flaws - 200 deg F - NRC Demo (1 page) i
: 30. Undated 0 DEG - All Flaws - Ambient (1 p. ige) l
: 31. Undated 0 deg - Zone 1 Flaws - 200 deg F (1 page) i                                    32. Undated 0 deg - Zone 2 Flaws - 200 deg F (1 page) l                                    33. Undated  0 deg - Zone 3 Flaws - 200 deg F (1 page) l
: 34. Undated  0 deg - Zone 4 Flaws - 200 deg F (1 page)
L l                                    35. Undated  0 deg - 150 deg F (1 page) l
: 36. Undated  45 Degree - Al Flaws - 200 deg F (1 page)
: 37. Undated  Ambient - After Paint Flaw Comparison Table (28 pages) l
: 38. Undated  Fioures (6 pages)
: 39. 4/20/98  SNC Document No. VMSB-98-001 Guideline Requirements for the Time-Of-Light Diffraction Ultrasonic Examination of the VSC-24 Structural Lid to Shell Weld (15 pages)

e FOIA 98164/188 )
l l
l                                                      APPENDIX C                                                                                              l L                                   RECORDS BEING WITHHELD IN PART i
NO. DATE        DESCRIPTION 4PAGE COUNT)/ EXEMPTION I
: 1. 7/26/94      Licensing Correspondence / Commitment Tracking Record Summary (1 page) (EX. 4) attaching 7/26/94 Itr to NRC from D Rogers 4 (4 pages) l                              (Release)
: 2. Undated      Palisades Photographs (29 pages) (Releasing 27 pages) EX. 4
: 3. 3/18/98       EPRI Fax Message (1 page) (Release) attaching P-Scan User's Group Association, Inc. Generic Procedure for Ultrasonic Through Wal! Sizitig in Pipe Welds (16 pages) EX. 4 1
i
                                                                                                                                                              )

Q FOIA-98-164/188 APPENDIX D                                                                        j RECORDS WITHHELD IN THEIR ENTIRETY j
J l
NO. DATE       DESCRIPTION 4PAGE COUNT)/ EXEMPTION
: 1. 9/8/95    P-Scan User's Group Association, Inc. Generic Procedure for the                                        I Ultrasonic Examination of Ferritic & Austenitic Pipe Welds (18 pages) EX.
4
: 2. 4/17/98    Palisades Nuclear Plant,10 CFR 72.48 Safety Evaluation (2 pages) EX. 4
: 3. 4/17/98    Palisade: Nuclear Plant,10 CFR 72.48 Safety Evaluation (3 pages) EX. 4
: 4. 4/23/98    palisades Nuclear Plant,10 CFR 72.48 Safety Evaluation (5 pages) EX. 4
: 5. 4/21/98    Development of Flaw Acceptance Criteria for VSC-24 Dry Storage Cask Structural Lid to Shell Weld (9 pages) EX. 4
: 6. 4/21-24/98 Evaluation of MSB Structural Lid Weld UT Examination (10 pages) EX. 4
: 7. 4/21/98    Introduction to Time-of-Flight Diffraction Methodology (10 pages) EX. 4
: 8. 4/21-24/98 Radiation Safety Information For Time of Flight MSB Structural Lid UT Examination (5 pages) EX. 4
: 9. 4/21/98    Palisades Nuclear Plant, Time-Of-Flight Diffraction Ultrasonic Examination of VSC-24 Dry Fuel Storage Cask Structural Lid to shell Weld (15 pages) EX. 4
: 10. 4/24-24/98 Time of Flight Diffraction UT Demonstration Detailed Schedule (3 pages)
EX.4
: 11. 4/21-24/98 Time-Of-Flight Diffraction UT Demonstration (8 pages) EX. 4
: 12. Undated    Base on 0 Datum at CL of Valve (1 page) EX. 4
: 13. Undated    DFS UT Examiner of OJT Program (8 pages) EX. 4 l   14. Undated    Explanation of Formulae Used in the Regression Spreadsheet (4 pages) l                  EX.4
: 15. Undated    Flaw Depth, Mechanical Versus TOFD (52 With Paint) UT (8 pages) EX. 4
(

e
: 16. Undated    List of Regression Analysis Performed on DFS TOFD UT Data (Tabular followed by Plot) (31 pages) EX. 4
: 17. Undated    Time of Flight Diffraction UT Demonstration: UT Examination of MSB in the MTC (9 pages) EX. 4
: 18. Undated    Time of Flight Diffraction UT Demonstration Dry-Run Briefing Checklist (4 pages) EX. 4
: 19. Undated    TOFD Demonstration 1 (2 pages) EX. 4 l
l l
I

  .                                 i
          ~                                                                                                     '
CUB CITIZENS' ETILITY BOARD 16 N. Carroll St., Suite 300 . Madison, WI 53703     .
(608)251-3322 . FAX (608) 2517609        -
R)f#lPA RELNEST CW N0*               9%Ljf April 14,1998                                                    Date Recd:           #go gf            ~
A*n O!!:       ,,,_foo/ -
Fl0*W Om;
                                                                                                                                     ~
Mr. Russell Powell                                                              ~ ~~~                 -
Branch Chief FOIA/LPDR Nuclear Regulatory Commission Washington, D.C.
l 20555 Re:      Freedom ofInformation Act Request

==Dear Mr. Powell:==

Pursuant to the Freedom ofInformation Act,5 U.S.C. 522, as amended and 10 C.F.R.
Part 9.41, the Wisconsin Citizens' Utility Board (CUB) requests the following documents:
: 1.       Please provide any and all documents that contain information on the results of the demonstration of the UT examination of the VSC-24 structural-lid weld, which began in March, 1998, at Arkansas Nuclear One.                                                                               ]
i For purposes of this request, please consider " documents" to include reports, studies, test        f results, correspondence, memoranda, meeting notes, meeting minutes, working papers, graphs,                  J charts, diagrams, notes and summaries of conversations and interviews, computer records,                     )
electronic mail and any other form of written communications including internal NRC                           j memoranda.                                                                                                     i Pursuant to and in compliance with 10 C.F.R. 9.41 of the agency's regulations and 5 U.S.C. 552 governing requests for waiver of fees, CUB puts forth the following information.
CUB was incorporated pursuant to Chapter 181,1979, of the Wisconsin Statutues. CUB is exempt from Federal income tax under Section 501(c)(4) of the Internal Revenue Code. CUB is also exempt from Wisconsin franchise tax.                                                                   l The restricted fund (public interest fund) is exempt from Federal income tax under Section 501(c)(3) of the Internal Revenue Code. The fund is also exempt from Wisconsin income taxes.
The public interest fund was established on February 1,1981, and reorganized on April 28,1986                  i to correspond to the new stmeture of the CUB. The fund engages in charitable, scientific, literary and educational activities on behalf of CUB.
i 496/.osco 7z                                                                                        ;

er CUB has 26,000 members who are residential ratepayers in Wisconsin. CUB represents the more than two million residential ratepayers in the state. CUB's purpose continues to be the statutory purpose set forth under sec.199.02, Wis. Stats.:
                                                   ...to promote the health, welfare and prosperity of all the citizens of this state by ensuring effective and democratic representation of individual farmers and other individual residential utility consumers before regulatory agencies, the legislature and other public bodies and by providing for consumer education on utility service costs and on benefits and methods of energy conservation.
CUB seeks the regnested information to become informed of the results of the demonstration of the UT examination of the VSC-24 stmetural-lid weld. A Wisconsin utility's plans for loading VSC-24 casks with high level radioactive waste will be affected by the results of the demonstration. CUB intends to use the information to assist it in its panicipation in any proceedings before Wisconsin regulatory agencies, and as part of CUB's ongoing effon to educate the public owuclear energy issues in Wisconsin.
The information sought, is not, to the best of our knowledge, in the public domain. The general public in Wisconsin has displayed great interest in nuclear energy issues and have a direct interest in information regarding the operational performance of the VSC-24 cask. A Wisconsin utility currently uses the VSC-24 cask to store spent nuclear fuel near the shore of Lake Michigan.
CUB has demonstrated its ability and commitment to inform the public on all important nuclear energy issues in Wisconsin. CUB provides this information free of charge through newsletters, educational pamphiets, and correspondence to its members, other residential ratepayers, legislators, and policy makers, and has neither a commercial nor a private interest in the agency records sought.
t Under the amended fee waiver standard, CUB is clearly entitled to a full waiver of all search, review and duplication fees. This standard calls for such a waiver, "if disclosure of the information is in the public interest because it is likely to contribute significantly to the public understandmg of the operation or activities of the government and is not primarily in the commercialinterest of the requester." 5. U.S.C. 552(1)(4)(A)(iii).
In light of the foregoing, CUB meets this standard on its face. CUB has no commercial interest in this matter, but rather seeks this information to help the general public and state regulatory agencies better understand the role of the federal government in regulating the nuclear power industry.
I For the reasons cited above, CUB's request falls squarely within the Congressional intent in enacting the Freedom ofInformation Act and the fee waiver provision. CUB, therefore, asks that the NRC grant a full fee waiver for this FOIA request.
t
(
2

              =
Thank you for your anticipated cooperation. If you have any questions in regards to this request, please feel free to contact me at your earliest convenience. Please contact me before acquiring and sending the requested information if the fee waiver is not applied.
Sincerely, N
Dennis Dums Research Director 3

CITIZENS' UTILITY BOARD
* 16 N. Carroll St., Suite 300 = Madison, WI 53703 = (608) 251-3322
* FAX (608) 251-7609 MM                             '
April 27,1998                                                       Q3 eNot          _
W - /# E ,. ,,
DgeRedh              ir- # 9 e .
Mr. Russell Powell                                                  Ate m M                Po+I:
FOIA/ Privacy Act Oflicer                                           Rdded0nt                          __
Nuclear Regulatory Commission Washington, D.C.
20555 Re:      Freedom ofInformation Act Request

==Dear Mr. Powe'l:==

Pursuant to the Freedom ofInformation Act,5 U.S.C. 522, as amended and 10 C.F.R.
Part 9.41, the Wisconsin Citizens' Utility Board (CUB) requests the following documents:
: 1.       Please provide any and all documents that contain information on the results of the                  -
demonstration of examination techniques of VSC-24 lid welds, which began in April,1998, at Palisades nuclear plant.
For purposes of this request, please consider " documents" to include reports, studies, test           l results, correspondence, memoranda, meeting notes, meeting minutes, working papers, graphs, charts, diagrams, notes and summaries of conversations and interviews, computer records, electronic mail and any other form of written communications including internal NRC memoranda.
Pursuant to and in compliance with 10 C.F.R. 9.41 of the agency's regulations and 5 U.S.C. 552 governing requests for waiver of fees, CUB puts forth the following information.
CUB was incorporated pursuant to Chapter 181,1979, of the Wisconsin Statutues. CUB is exempt from Federal income tax under Section 501(c)(4) of the Internal Revenue Code. CUB is also exempt from Wisconsin franchise tax.
1 The restricted fund (public interest fund) is exempt from Federal income tax under Section             J
[     501(c)(3) of the Internal Revenue Code. The fund is also exempt from Wisconsin income taxes.
The public interest fund was established on February 1,1981, and reorganized on April 28,1986            ,
to correspond to the new structure of the CUB. The fund engages in charitable, scientific, literary and educational activities on behalf of CUB.
L y9ogygo,n<g-                        a caansa--

1 l a . . .
CUB has 26,000 members who are residentia! ratepayers in Wisconsin. CUB repa:sents the more than two million residential ratepayers in the state. CUB's purpose continues to be the statutory purpose set forth under sec.199.02, Wis. Stats.:
                        ..to promote the health, welfare and prosperity of all the citizens                         ,
of this state by ensuring effective and democratic representation of                          -
individual farmers and other individual residential utility consumers               ,
before regulatory agencies, the legislature and other public bodies and by providing for consumer education on utility service costs and l                     on benefits and methods of energy conservation.
CUB seeks the requested information to become informed of the results of the demonstration of examination techniques of VSC-24 lid welds at the Palisades nuclear plant.
The examination techniques were being tested to determine their usefulness in identifying the acceptability of VSC-24 lid welds. Demonstration of examination techniques of VSC-24 lid welds were also conducted at the Arkansas Nuclear One plant during March,1998. The results of those tests are the subject of FOIA/PA 98-164. A Wisconsin utility's plans for loading VSC-24 casks with high level radioactive waste will be affected by the results of the demonstrations.
CUB intends to use the information to assist it in its participation in any proceedings before Wisconsin regulatory agencies, and as part of CUB's ongoing efTort to educate the public on nuclear energy issues in Wisconsin.
The information sought, is not, to the best of our knowledge, in the public domain. The general public in Wisconsin has displayed great interest in nuclear energy issues and have a direct interest in information regarding the operational performance of the VSC-24 cask. A Wisconsin utility currently uses the VSC-24 cask to store spent nuclear fuel near the shore of Lake Michigan.
i CUB has demonstrated its ability and commitment to inform the public on all important nuclear energy issues in Wisconsin. CUB provides this information free ofcharge through newsletters, educational pamphlets, and correspondence to its members, other residential ratepayers, legislators, and policy makers, and has neither a commercial nor a private interest in the agency records sought.
Under the amended fee waiver standard, CUD is clearly entitled to a full waives uf all
;           search, review and duplication fees. This standard calls for such a waiver, "if disclosure of the l           information is in the public interest because it is likely to contribute significantly to the public'
;           understanding of the operation or activities of the government and is not primarily in the i         ' commercial interest of the requester." 5. U.S.C. 552(1)(4)(A)(iii).
In light of the foregoing, CUB meets this standard on its face. CUB has no commercial       ,
interest in this matter, but rather seeks this information to help the general public and state regulatory agencies better understand the role of the federal government in regulating the nuclear power industry.
2 j

For the reasons cited above, CUB's request falls squarely within the Congressional intent in enacting the Freedom ofInformation Act and the fee waiver provision. CUB, therefore, asks that the NRC grant a full fee waiver for this FOIA request.                                           -
Thank you for your anticipated cooperation. If you have any questions in regards to this'    ,
request, please feel free to contact me at your earliest convenience. Please contact me before       -
acquiring and sending the requested information if the fee waiver is not applied.       ,
Sincerely, W
Dennis Dums Research Director                                             .                                  .
e 9
0 3}}