ML20236F243

Responds to Re Emergency Planning Rule & Congressional Ltrs Received on Morning of NRC 871022 Meeting.Commission Stands by That Process Could Hardly Have Been More Open for Addressing Issue

ML20236F243
Person / Time
Issue date:	10/27/1987
From:	Zech L NRC COMMISSION (OCM)
To:	Atkins C, Downey T, Hochbrueckner, Markey E, Mavroules N, Mrazek R HOUSE OF REP.
References
NUDOCS 8711020060
Download: ML20236F243 (6)

Text

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["%, UNITED STATES-NUCLEAR REGULATORY COMMISSION

, 8 o WASHINGT ON, D. C. 20555 l

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October 27, 1987 1

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CHAIRMAN  !

4 The Honorable Edward J. Markey  !

United States House of Representatives Washington, DC 20515 1

Dear Congressman Markey:

I l

We have received your letter of October 23, 1987, and wish first to correct l certain misapprehensions reflected in it. Commissioner Bernthal's reference l to the Congressional letters received on the morning of the Commission's October 22 meeting was by no means " inadvertent," asl 1 every other written comment on the rulemaking Nor was thewould request befor placed those in the Publl  !

Document Room and made part of the record.One NRC staff member, asked for the letters " refused by the NRC staff."

letters by a Congressional staff member at the conclusion of the meeting, was initially unaware that the letters constituted comments on the rulemaking, j and replied that ordinarily Congressional letters are released only when the He promised, however, to look into the 3 J

Commission's reply is dispatched.The release of the documents at the clo matter.

Public Affairs office mooted the issue. Copies of the several letters from .

members of Congress and Governor Dukakis that were received just prior to Thus.it would be wholly inaccurate to Commission meeting are enclosed.

suggest that the Commission sought to conceal the letters, or that the staff refused their release.

The Commission therefore stands by its letter of October 21, in which it declared that "the Comission could hardly have structured a more open process for addressing this issue," and declined to accept the impos procedural burdens of a kind Congress has never required in informal rulemaking. Nothing that has happened in the intervening days sugges need to reconsider that response.

the October 21 response to endeavor now We believe to comp rule between NRC and nuclear utilities or other Federa  ;

judicial litigation, is wholly inappropriate for informal r based on the public rulemaking record, i Sincerely,  ;

v- [s .

Lando W. Zech, . _,

Enclosures- -

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Letters from Congressional members and Governor Dukakis 0 0(/

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October 27, 1987 f k***.*/ I CHAIRMAN :

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l The Honorable Chester G. Atkins United States House of Representatives Washington, DC 20515

Dear Congressman Atkins:

We have received your letter of October 23, 1987, and wish first to correct certain misapprehensions reflected in it. Commissioner Bernthal's reference  !

to the Congressional letters received on the morning.of the Comission's October 22 meeting was by no means " inadvertent," as your letter suggests.

Rather, it was plainly made with the understanding that those letters, like every other written comment on the rulemaking would be placed in the Publ Document Room and made part ofOne the NRC record.staffNor member, was the asked request for the for those a

letters " refused by the NRC staff."

letters by a Congressional staff member at the conclusion of the meeting, was initially unaware that the letters constituted comments on the rulemaking, and replied that ordinarily Congressional He promised,lettershowever, are to released look into the only when th i Commission's matter.

reply is dispatched.The release of 'the documents at the cl i Public Affairs office' mooted the issue. Copies of the several letters from members of Congress and Governor Dukakis'that Thus it would be whollywere inaccurate received to just prior t Commission meeting are enclosed.

suggest that the Commission. sought to conceal the letters, or that the staff refused their release.

The Commission therefore stands by its letter of October 21, in which it -J declared that "the Commission could hardly have structured a more open process for addressing this issue," and declined to accept the imp procedural burdens of a kind Congress has never required in informal rulemaking. Nothing that has happened in the intervening days suggel need to reconsider that response.

the October 21~ response to endeavor now to com We believe rule between NRC and nuclear utilities or other Feder judicial litigation, is wholly inappropriate for informal r based on the public rulemaking record.

Sincerely, W24 LandoW.Zecg,Jr.

Enclosures:

Letters from Congressional members and Governor Dukakis

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s UNITED STATES

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! ',t, NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C 20555

{  ;,E October 27, 1987

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CHAIRMAN l.

I The Honorable Robert J. Mrazek l United States House of Representatives Washington, DC 20515 l

Dear Congressman Mrazek:

We have received your letter of October 23, 1987, and wish first to correct Commissioner Bernthal's reference certain misapprehensions reflected in it.to the Congressional le 3

i October 22 meeting was by no means " inadvertent," as your letter suggests. {

Rather, it was plainly made Nor with was the the requestunderstandin for those Document Room and made part of the record.One NRC staf f member, asked for the letters " refused by the NRC staff."

letters by a Congressional staff member at the conclusion of the meeting, wa initially unaware that the letters constituted comments on the rulemaking, ,

and replied that ordinarily Congressional letters are He promised, however, released to look into the only whe Commission's matter. reply is dispatched.The release of the docum  ;

Public Affairs office mooted the issue.

members of Congress and Governor Thus it wouldDukakis that inaccurate be wholly were received to just prio Comission meeting are enclosed.suggest that the Commission staff refused their release.

The Commission therefore stands by its letter of October 21, in which it declared that "the Commission could hardly have procedural burdens cf a kind Congress has never required in inform rulemaking. Nothing that has happened in the intervening days suggj need to reconsider ".nat response.

the October 21 respunse to endeavor now to com We believe rule between NRC and nuclear utilities or other Federal agencies.

that such a request, which resembles discovery between adversaries in ,

judicial litigation, is wholly inappropriate for informa based on the public rulemaking record.

Sincerely, lu. .

Lando W. Zec Jr. )

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Enclosures:

Letters from Congressional members l and Governor Dukakis II

n f zicoq#e UNITED STATES 4 g_

n NUCLEAR REGULATORY COMMISSION-WASHINGTON, D. C. 20555

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October 27, 1987

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CHAIRMAN l I The Honorable Nicholas Mavroules i United _ States House of Representatives l Washington, DC 20515 f De'ar Congressman Havroules:

' We have received your letter of October 23, 1987, and wish first to correct certain misapprehensions reflected in it. Commissioner Bernthal's reference to the Congressional letters received on tne morning of the.Comission's October 22 meeting was by no means '! inadvertent," as your letter suggests. i Rather, it was plainly made with the understanding that those letters, like l every other written comment on the rulemaking would be placed in the Public l Document Room and made part of the record. - Nor was the request for those l 1etters " refused by the NRC staff." One NRC staff member, asked for the  !

1etters by a Congressional staff member at the conclusion of the meeting, was initially unaware that the letters constituted coments on the rulemaking, and replied that ordinarily Congressional He promised, however, to look into the letters are released only when the Comission's reply is. dispatched.The release of the documents at the clos matter. ,

Public Affairs office mooted the issue. Copies of the several letters from -

~

members of Congress and Governor Thus itDukakis would be that wereinaccurate wholly received to just prior to the Comission meeting are enclosed.

suggest that the Comission sought to conceal the letters, or that' the NRC staff refused their release.

The Commission therefore stands by its letter of 0ctober 21, in which it declared that "the Commission could hardly have structured a more open process for addressing this issue," and declined to accept the impositio procedural burdens of a kind Congress has never required in. informal rulemaking. Nothing that has happened in the intervening days suggests '

need to reconsider that response. _l the October 21 response to endeavor now to comply with your request for a chronology and sumary of communications regarding the emergency We believeplanning rule between NRC and nuclear utilities or other Federal agencies. .

that such a request, which resembles discovery between adversaries in  !

judicial litigation, is wholly inappropriate for informal rul based on the public rulemaking record.

Sincerely, 1

b. ,

Lando W. Zec Jr. l

Enclosures:

Letters from Congressional members  !

and Governor Dukakis i

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jf k UNITED STATES y NUCLEAR REGULATORY COMMISSION i

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[ October 27, 1987 CHAIRMAN The Honorable George J. Hochbrueckner United States House of Representatives Washington, DC 20515

Dear Congressman Hochbrueckner:

We have received your letter of October 23, 1987, and wish first to correct certain misapprehensions reflected in it. Commissioner Bernthal's reference to the Congressional letters received on the morning of the Comission's October 22 meeting was by no means " inadvertent," as your letter suggests.

Rather, it was plainly made with the understanding that those letters, like every other written comment on the rulemaking Nor was would thebe placed request forinthose the Public l Document Room and made part of the record.One NRC staff member, asked for the letters " refused by the NRC staff." '

letters by a Congressional staff member at the conclusion of the meeting, was initially unaware that the letters constituted comments on the rulemaking, and replied that ordinarily Congressional letters are released only when the Comission's reply is dispatched. He promised, however, to look into the matter. The release of the documents at the close of the meeting by the Copies of the several letters from Public Affairs office mooted the issue.

members of Congress and Governor Dukakis that were received just prior to the Comission meeting are enclosed.

Thus it would be wholly inaccurate to suggest that the Commission sought to conceal the letters, or that the NRC staff refused their release.

The Commission therefore stands by its letter of October 21, in which it declared that "the Comission could hardly have structu' red a more open process for addressing this issue," and declined to accept the imposition o procedural burdens of a kind Congress has never required in informal rulemaking. Nothing that has happened in the intervening days suggests a Moreover, it would be inconsistent with need to reconsider that response.

the October 21 response to endeavor now to comply with your request for a chronology and summary of communications regarding the emergency We believe planning rule between NRC and nuclear utilities or other Federal agencies.

that such a request, which resembles discovery between adversaries in judicial litigation, is wholly inappropriate for informal rule based on the public rulemaking record.

l Sincerely, b W.

Lando W. Zech Jr.

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Enclosures:

Letters from Congressional members and Governor Dukakis

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. UNITED STATES L / o k NUCLEAR REGULATORY COMMISSION l ll . 8 W ASHINoTON, D. C. 20555 i .

{  ; ,I a l o, October 27, 1987

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CHAfRMAN The Honorable Thomas J. Downey United States House of Representatives Washington, DC 20515

Dear Congressman Downey:

I We have received your letter of October Commissioner23, 1987, andBernthal's wish firstreference to correct certain misapprehensions reflected in it.

to the Congressional letters received on the morning of the Comission's October 22 meeting was by no means " inadvertent," as your letter suggests. i Rather, it was plainly made with the understanding that those letters, like every other written coment on the rulemaking Nor was would be placed the request for those in the Public Document Room and made part of the record.One NRC staff member, asked for the l' letters " refused by the NRC staff."

letters by a Congressional staff member at the conclusion of the meeting, was initially unaware that the letters constituted coments on the rulemaking, and replied that ordinarily Congressional letters aretoreleased He promised,'however, look into only the when the .; '

Comission's reply is dispatched.The release of the documents at the clos matter.

Public Affairs office mooted the issue. Copies of the'several letters from members of Congress and Governor Dukakis Thus it would that were be wholly received inaccurate to just prior'to Comission meeting are enclosed.

suggest that the Commission sought to conceal the letters, or that the NRl staff refused their release.

The Commission therefore stands by its letter of October 21, in which it declared that "the Comission could hardly have structured a more open  !

process for addressing this issue," and declined to accept the impos procedural burdens of a kind Congress has never required in informal rulemaking. Nothing that has happened in the intervening days suggest need to reconsider.that response.

the October 21 response to endeavor now to comply with your request for a chronology and sumary of communications regarding the emergency We believe plann rule between NRC and nuclear utilities or other Federal agencies.

that such a request, which resembles discovery between adversaries in judicial litigation, is wholly inappropriate for informal r based on the public rulemaking record.

Sincerely, bLando6v.'A<4 W. Zech Jr.

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Enclosures:

Letters from Congressional members and Governor Dukakis

THE COMMONWEALTH OF MASSACHUSETTS m g EXECUTIVE DEPARTMENT l

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' STATE HOUSE l

MICHAEL, S QUKAXIS

"" October 20, 1987 Mr. Lando W. Zech, Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 21555

Dear Chairman Zech,

The staff recommendation currently under consideration nuclear power plants in the absence of state approved emergency response plans, requires that I once again, inshould The Commission the strongest not subjugate terms, the well voice my op to this proposed rule change. ,

being of Massachusetts citizens to the interests of a handful of utility company owners.

On February 24, 1987 I testified before the Commission to register myIn my oral a cpposition to this proposed rule change.

testimony I argued that Ccmmission approval of this proposal would ignore only the lessons learned from the radiological emergency that occurred a Three Mile Island but would undercut the basic commands of the Atomic Act and other statutes governing the NRC.

shake my firm belief that emergency response plans the public.

In my view, the Commission now stands poised to disregard its manda protect the public health and safety. l in would not only serve to jeopardize the public health and safety of peop e Massachusetts but would signify a willingness to run roughshod over theThe traditional interests of sovereign states.

this proposed rule ~ change. /

I urge the Commission to reject its staff's r commendation, r

[Since[ rely,

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i October 20, 1987 Zech, Jr.

The Honorable Lando W.

Chairman Nuclear Regulatory Commission 1717 H Street, N.W.

Washington, D.C. 20555

Dear Mr. Chairman:

As you know, we have strongly supported yourWe also to efforts amend the Commission's emergency planning regulations. i ion ig in .

strongly approved of the approach proposed by the comm ss l March and the efforts of the Commission's staff We therefore d~in were. deve tion for op that-approach for your consideration. surprised ff proposal, and a final commission rule on this matter. deficient.

we believe that the recommendation is seriou d as a It is also seriously at odds with what we had lviewe . to get major purpose of the Commission in proposing h minds its ruofe:State l the Commission out of the business of reading t eon repeated  !

and local officials. Yet the staff proposal contemplates h expressed that purpose.

hearings mind-reading.

that will amount to lengthy exercises in j the "likely response of ...(State and loca b nt

d. differently probed 4,n hearings in which such officials will be a ill se entirely or will testify that they intend to respon from respond.

the way in which the utility applicantldpredic "the precise actions which state and local i governments y

vernments.

wou take" would be " resolved in individual adjud cator proceedings" that frequently will not include those had understood go These are precisely the sorts of inquiries that we the Commission wished to avoid. i v iff n.

b Zech, Jr.

The Honorable Lando W.

October 20, 1987 Page 2 The inquiries come about under the proposal because the staff is reluctant to engage in assumptions and to circumscribe It is adjudicatory hearings so as to make the rule workable.

of course the case that where states and localit only is, a utility plan before it.it will be most difficult to establish the )

preparedness without some understanding -assum I officials with respect to the plan.

assume that such officials will use their best efforts in theBu event of an accident. Will the officials make Willuse  ;

leaves unanswered such questions asWill the officials develop their own?

of the utility plan? Exactly how will l they they do so?

carry out either in an actual emergency?All these questio boards to resolve in hearings that may wellhearings such be boycotted by the inevitably .

officials whose conduct is at issue, l ,

will be unwieldy and inconsistent with any sense of an ord i regulatory process.

will be provided to licensing boards and hearing participants illas  !

to how they are to proceed in such hearings or a Finally, given that licensing boards will have available to ,

them only a utility plan (which state and local officials and an probably will ignore and thus view as irrelevant) understanding that such officials will do their best ad hoc in an emergency, it will be difficult to make the findingEven thata adequate protective measures can and will be taken.

> hearing demonstrating that the utility plan isUnder exceptionally these strong may well not support such a finding.

circumstances, the staff recommendation may effectivelyi restore d to the veto threat that the original proposed rule was des gne remove.

One possible cure for these problems is to make the assumptions and to establishAsthe elements of guidance to assumptions, that are the Commission now missing from the rule. h could reasonably provide that it should be assumed not onlyf t at states and localities will exert their best efforts in times otha an accident but also (1) and (ii) that until they to plan and prepare for the accident, develop their own plan, the they will utility's, if anrely on the only accident plan These occurs.

available, i.e._,

assumptions are dictated by common sense, are consistent d by wi previous commission decisions, and undoubtedly are suppor the rulemaking. record.and hearing participants, the commissio

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The Honorable Lando W.

October 20, 1987 ,

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i is feasible at available that where it can be shown that emergency ill be sufficientplann to State and local officials, these showings,w ill b,e adequate.

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l d t; ). Attachment l i cc: .The Honorable Thomas M. RobertsThe H , x The Honorable Kenneth M. Carr \ ,l The Honorable Kenneth C. Rogers 3RE ~ ~ ~ '" ~~ - - ~ - ~ - - ~ -~ a .. l .yv a l 3, < f .i = ) ..\f. - ' L , g' ' PROPOSED LANGUAGC .); l'OR EMER0ENCY PREPAREDNE of N. .s ,In thf, seconda c entence .of paragraphdd(c)(1)(iii) , "and the staff's proposal, after " based upon the plan," a the assumption and showings ovelined in this paragraph." ,c 4% / s' Strike' the last sentence of the paragraph and .a. .N

l "In making its determination on w :s x9 substitute in lieu thereof:

hj , i the m, . the adequacy.hc a utility plan, the NRC will recogn ze , .M n c'eality that (1) in an actual egergency state and local f \ pover$ dant officials w'ill exercise their best efforts to (ii) such r p}otect>the health and safety of the public, 1 and offic'Iala will exercise their.best efforts to prepare k,i until such officials develop

• plan for an emergency, and (iii) 4'r .I a plan 1e$'their own, such officials will rely on the u tility

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t. demonstrated on a case-by-casa basis that emergency the geographiyalflocation of.the i preparedness is feasible at ,, o i

J .k facility and that,edequate resources are'ava' lable to to state 4 and local of ficidh:, " such showings wiU, be suf ficient j h ' i ill be a O.hh M\. ,, establish that state and local best et' orts w s; ~ ' y\ adequate." .. ,/c' k" T h a1 , 4 .s , -l ., . ll6 6 [. j , \ ' f t -k , L ^ j -t l ';[ fc - ),_ ') . .h t =' = = ev'0'cs = cat- c as o'. c a. ev.= . =g C . at **Oct i Acacq ,e.

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+- , Sech, Jr.

O ' Honorable Lando W. Chairman U.S. Nuclear Regulatory Commission Washington, DC 20555

Dear Chairman Zech:

e- the Nuclear Regulatory Commission issued a In March of this year, its emergency planning proposed rule Ithat would support this amendinitiative to resolve the current regulations. You personally deserve impasse on emerge'ncy planning.

substantial credit for this effort. final rule. 'I am disturbed, however, by several aspects of the d.

sincerely I

hope that these concerns will be addresse its recommendations on the final As the Commission final staff notes in rule "gives the appearance of addressingfully rule, the proposed impasse without ill be found acceptable the emergency planningissue--whether utility plans win a particular case."

difficult on the basis of an adjudicatory record i hout any This creates the prospect of lengthy litigation w t l t in the certainty as to the ultimate licensability of the p an face of non-cooperation by state and local officials.

t tial I hope the Commission will be uncertainty. solve able to avoid the current this po enIt wou problem.

were to adopt a rule that did not With kind regards, I am sincerely, Quent n N. Burdick Chairman QNB:db:et y-

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• Almh0 TON.0C 20010.4178 October 21, 1987 Honorable Lando Zech, Jr.

Chairman Nuclear Regulatory Commission 1717 H Street, N.W.20555 Washington, D.C.

Dear Mr. b Knowing that the Commission is scheduled to receive relative a to briefing, tomorrow, from the staff on SECY 87-257,to first apologize for the I want I would also like to request the emergency planning rule, '

last-minute nature of this letter. i docket and made  !

that available this letter to interested be noted on the Commiss on s parties. h ,

While' I do not wish to prejudge the decision of t e stions in .

Commission, my, review of the SECY paper raises som my mind thatwith the staff in your discussions.

raise d rule, it ised upon  ;

As I understand the Commission's original proposeits acknowledged that l

the assumption "that all affected state andl ing throughout the would continue to cooperate in emergency p annThe Commission t als The life of the license."its 1980 regulations were not tion.designed nor possible state and local vetoes of full power operawas intended t proposed rule, as I understood it, to the Shoreham and of a full situation that has arisen with respect fully Seabrook plants by, in essence, permitting the issuance power operating license in the f ace of the refusal toby state delineated participate in the emergency planning exercise in the proposed rule. h Now, the Commission's staff, after consultation with t ed a v Federal Energy Management Agency, hashrecommende does not appear to ,

the proposal contained in SECY-87-257, inherent whicin the Commission'st 198 correct the regulatory First, problemsthe Staff's recommendation doesdnot spell ou local amendments.

how the NRC is to deal with a situation in which Hence, state an officials argue that utilize the utility's plan.

it may be extremely emergency, but will not following the Staff's recommendation, i difficult to reach the conclusion that adequate prot a

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The Honorable Lando Zech october- 21, 1987.

Page Two Second, the Staff'sinterpretation recommendation seems of the " realism to bedoctrine," premised upon an overly restrictive first, that the utility, and then the which NRC, appears to requireread the minds of how state and local governm f that respond:in the future and then litigate the ef festiveness oto do in ins response. This would appear difficult / local there is no officials andcommunication the utility. between the state'and or f

I do not believe that Congress regarded the concept othe utilities read utility plans as including a request that ill ,

minds of how non-cooperating state and local of ficials w respond and'then litigate the effectiveness of that response Certainly, this was7not d as over the emergency planning rule which have resu supporting the Commission's proposal.

I request that this letter be circulated to your four fellow. i Document Commissioners as well as be placed'in the NRC's Publ c Room.

cerely, J IN BREAUX nited States Senator l

- _ . . _ - - - __1_ ._ __-- ___m __________m___ _ __._.__ __-

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Congress of ti)e Uniteb States ]

Qouse of . Representatives j Elasf;(ngton,33E. 20515 l l

l October 23, 1987 The Honorable Lando W. Zech, Jr.

Chairman U.S. Nuclear Regulatory Commission 1717 H Street N.W.

Washington, D.C. 20555

Dear Chairman Zech:

1 On September 22, 1987 we wrote to you requesting that the Commission keep a public log of all written and verbal communications regarding the Commission's draft emergency planning rule. On October 13, 1987 the Commission issued a staff paper (SECY-87-257) which included a draft Federal Register notice and recommended that the Commission proceed with this rulemaking.

Yesterday we received your letter refusing our request. We note that you stated that the Commission "could hardly have structured a more open process." Yet yesterday we learned, as a result of an apparently inadvertent comment by Commissioner Bernthal during your briefing from the staff, that the Commission has received several letters from other Members of Congress urging the Commission to change its proposed emergency planning rule so as to effectively facilitate to an evenMoreover, greater degree the when at least one licensing of Seabrook and Shoreham.

staff member attempted on our behalf to obtain copies of such letters, his request was refused by the NRC staff. Only later, when we learned that the letters had been released by the NRC to the press, were copies provided to us.

We emphatically do not agree with your assessment that the Commission's solitary action of issuing its draft rule for public comment -- an action required by administrative procedure --

ensures that this process is fully open to public scrutiny. If persons at senior levels of the Commission have had communications with parties outside the NRC regarding this rulemaking, the public has evtry right to know about those communications. There should be no question that the Commission's decision is based on any l

l information other than that in the public record. This matter l becomes all the more significant in light of the revelation that the Commission has indeed received communications advocating a l rulemaking even less protective of the public than the one l

recommended by the staff.

- The Honorable Lando W. Zech, Jr.

. Page 2 October 23, 1987 As such, we renew our original request to you of September 22, 1987, and strongly urge you to reconsider your reply. In addition, we ask that you provide us with a chronology of all communications (written and verbal) since October 13, 1987 on the subjects of the Commission's proposed emergency planning rule or the emergency planning aspects of the licensing of the Seabrook or Shoreham nuclear plants between (1) any Commissioner, member of any Commissioner's staff, General Counsel or any staff of the Office of General Counsel, or the Executive Director for Operations or any staff of his Office, and (2) any employee or representative of (a) any utility or nuclear / utility trade association, or (b) the White House, ForDepartment of Energy, each communication, OMB, please FEMA, or other Federal agency.

provide the names of the participants, the date of each communication, a detailed summary, an indication of who initiated the communication and why, and any documents pertaining to such communications. For the purpose of this request, the word

" documents" includes but i s not limited to all handwritten or typed communications, documents, drafts, memoranda, letters, refers to all notes, and so forth; and the word " communications" written (as per the above) and/or verbal communications including all conversations, meetings, and telephone calls.

In light of the fact that only rule, 10 we days wouldhave elapsed expect that since this the latter Commission issued its draft request would not require an extensive effort on the part of the Commission. Accordingly, because we believe that the public and the process will benefit by full disclosure of all communications prior to the commission voting on this issue, we ask that you provide a full response to this more limited request no later than Tuesday, October 27, 1987.

Thank you for your cooperation in this matter.

Sincerely, Edward J. Markej Nicholas Mavroules Member of Congre s Member of Congress N

Geor{p'J p ochbrueckner Chester G. Atkins Member of Congress Member of Congress

@ 6t Rdde r t J .' M r zG e k Member of Congress LAL Thomas J. Dowr[ey Member of Cong ess f'

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