ML20236B333

Informs of Refund Due for Review of Applications for OLs Through 840623,in Response to Util .Revised Sheets Showing Revised OL Review Cost from CP Issuance Through 840623 & Response to Issues Raised in Encl

ML20236B333
Person / Time
Site:	Washington Public Power Supply System, Satsop
Issue date:	10/22/1987
From:	Holloway C NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
To:	Glasscock R WASHINGTON PUBLIC POWER SUPPLY SYSTEM
References
CON-FIN-A-3714, CON-FIN-A-6422, CON-FIN-B-8020 NUDOCS 8710260083
Download: ML20236B333 (13)

Text

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OCT 2 2.1987 Docket Nos. 50-460 and 50-508 Washington Public Power Supply System ATTN: Mr. R. B. Glasscock, Director Licensing and Assurance Box 1223 Elma, WA 98541-1223 Gentlemen:

Subject:

Invoiced Amounts on D0119 and 00120 for WNP-1 and WNP-3 Operating License Application Review Through June 23, 1984 On December 26, 1984, Bill Nos. 00119 for $518,385 and D0120 for

$1,394,355 were issued for the review of the applications' for operating licenses for WNP-1 and WNP-3, respectively, through June 23, 1984 By letter dated January 6,1986, the Washington Public Power Supply System (the Supply System) informed us of their position on some of the hourly charges and contractual costs on the subject bills and requested that the issues raised be reviewed by us. We have completed a reanalysis of the charges billed by thesa invoices. As a result, a refund of $4,317 is due on D0119 for WNP-1 and a $359,429 refund is due on 00120 for WNP-3. Enclosure.1 to this letter consists of revised sheets (2) showing (by program offices) the revised operating license review costs from construction permit issuance through June 23, 1984, for Staff hours and May 31, 1984,for contractual costs. These sheets reflect the adjustments made based on Enclosure 2 to.this letter as summarized in item IV. The revised costs.for operating license application review through June 23, 1984, for WNP-1 are $514,068 and for WNP-3 they are

$1,034,926.

Enclosure 2 addresses the issues raised in the letter dated January 6, 1986, and the three pages attached to it. The responses to your issues are in the order presented by you. Item III of Enclosure 2 includes a discussion of the addition of contractual: costs for WNP-1 ($4,775) and 1

WNP-3 ($2,283) for services under B8020 which should have been-included, but were not in1 the costs billed by D01_19'and 00120.

! L T Until a May 28,1987, telephone request from Mr.' D. W. Coleman, we had

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not billed the Supply System for any OL review costs beyond June 22, 1985, for WNP-1 and WNP-3 because we were waiting to see if a credit was' due the Supply System as a result of your January 6 letter. Since the Supply System requested to be billed, and we have billed you for review costs through December 20, 1986, for these unitt we have taken the necessary steps to refund the Supply System a sum cf $363,746. This refund will be done by wire transfer within the next two weeks.

A k0[oO$f PDh0

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qui 221M 2 1

We apologize for the delay in responding to your January 6,1986, letter. I Sincerely,

~ ~m Slg1RdliYt . I CJames Holtaway Jr. ]

C. James Holloway, Jr. , Chief-License Fee Management Branch Division of Accounting and Firance l Office of Administration and i Resources Administration l

Enclosures:

1. RevisedCostSheets(2)

2. Response to Issues in 1/6/86 Letter ,

i cc w/encls:  !

G. C. Sorensen )

Manager, Regulatory Programs -

Washington Public Power ]

j Supply System '

l P.O. Box 968 Richland, WA 99352 Mr. D. W. Coleman Project Licensing Manager Washington Public Power ]

Supply System j P.O. Box 968 i Richland, WA 99352

! CERTIFIED MAIL l RETURN RECEIPT REQUESTED .,

DISTRIBUTION w/encls:

PDR LPDR CJHolloway)

RMDiggs(2.

RegDocket, File's"'(2) LTremper GJohnson, DAF 0 Weiss MRodriguez, DAF t.Shea RVillafranco, NRR LFMB WNP_1 & 3 A/M Files (2)

DFioravante, NRR LFMB R/F DW/RMD2/WPPSS ARM /DAF R/F 0FFICE : ARM B

/

/LFMB M

ARM /DAF De 4: /\cn f f i

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ARM /DAF)

SURNAME :RMDiggs:jp :CJW,., oway : EBlack  : GJohnson  :  !  :  :

ff L@ __________..:

_________:____________:_....h/87 DATE :10//9'/87 :10/  : 10/0 /87 : 10/ '10/87 : /o /, ' /h2::  :

7 vy ,

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9 Enclosure 1 Washington Public Power Supply System.

. Revised Operating License Review Costs Through June 23, 1984 FACILITY: . Washington. Nuclear 1 DOCKET NO.:. 50-460 l

l Costs Per Professional l l

Program Office Professional Staff-Hours Staff-Hour Contractual Total l l Review Staff-Hour Expended Costs Costs Costs i

1. NRR $39 4,922.0 $191,958 $46,368 $238,326 1

l l 2. .IE-HQ 36 8.0 288 --

288

(

1

3. REGIONS 36 7,622.5 274,410 -- 274,410 l i

)

4. ACRS 50 14.8 740 -- 740 i

5. NMSS 38 8.0 304 -- 304 i

TOTAL COST: $514,068 l

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-Enclosure'1 I . . . ..

. : Washington Public Power : Supply : System '-

. Revised Operating License Review Costs Through June 23, 1984 .

FACILITY: L. Washington' Nuclear 3 ,,

DOCXET N0 : 50-508l, ~

Costs Per Professional . .

Program Office- Professional Staff-Hours Staff-Hour' Contractual Total -'

Review' ' Staf f-Hour-' Expended . Costs . Costs- . Costs

1. NRR .$39 13,842.0.- $539,838 $135,779~ $675,617.

l: - 2. ~IE-HQ 36 52.0 1,872- -35,119- 36,991 lq 3.- REGIONS 36 '8,837.0 318,132 --- 31.8,132

4. ACRS 50 32.8 1,640 --; 1,640  !

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67.0 2,546 2,546

5. NMSS 38 --

TOTAL. COST: .$1,034,926-a

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. , i Enclosure'2' Responses to Issues Addressed in the Supply System's- I Letter Dated January 6,1986 For WNP-1 and WNP-3

>- On Bill Nos. D0119 and D0120 Docket Nos. 50-460 and 50.p,0_8 The responses that follow will basically: be in. the order listed in the - i Supply System's January 6, 1986.;1etter regarding. contractual costs H through May 31, 1984, and staff hours through June 23, 1984', for the review of the applications for- operating ~ licenses for WNP-1 and WNP-3:

l

1. WNP-1-(Bill No. D0119):-

A. WNP-1 contractor costs (describe work, deliverable product, i why charged and identification for some contractors): ,

1. $1,754 and $3,783 INEL Costs:

1 INEL (EG&G), FIN A6493, Evaluation of R.G. 1.97 for j

$1,754 - Nov. & Dec. 1983; $3,783 -cumulative thru i September 1983. q l

The objective of this program was to assist the Nuclear l Regulatory Comnission (NRC) staff in- the techn!. cal l evaluation of the implementation of Regulatory Guide  !

(RG) 1.97 by operating reactors (OR) and Near Term j OperatingLicense(NT0L) applicants.

Specific tasks included:  !

I 1

Evaluation of applicant response to R.G. l.97 to l assess the adequacy of instrumentation based on l multiple' criteria specified in R.G. 1.97, Revision l 2, Safety Parameter Display System Implementation. ,

l Preparation of an interim report for each applicant submittal which will include areas in full conformance with the R.G. 1.97 guidelines, evaluation of exceptions to the guidelines and identification of. exceptions for which sufficient .

justification has not been provided to permit an acceptable finding. Following NRC review of the . ,

interim report, EG&G Idaho will meet with the NRC and the licensee to resolve outstanding concerns (exceptions to the guidelines) identified in the interim report. Using all of.the information available, complete the review'and prepare a Technical Evaluation Report (TER) including .

identification of any open items and the basis-for judgments'to accept or reject the applicant's proposed exceptions of R.G. 1.97.

These charges are correct as previously billed.

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2. $8,000 by PNL (FIN 82355- ' October 1983) was for the administration of operator and~ senior operator l examinations for WNP-2 and was erroneously reported j against WNP-1_. Therefore, thelsum of $8,000 is being subtracted from the WNP-1 bill. ' .;

3. $205 by ZGAZB'(Gage-Babcock &~ Associates under FIN 88020

- October 1983 April 1984) for Fire Protection tvaluation:

The objective of.this task was to obtain qualified fire protection technical assistance in the review of the fire' protection programs for plants undergoing licensing .

reviews. 'The' specific work requirements were to (1) review and evaluate licensee's revised fire hazards-analysis and perform'on-site fire protection survey, and

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- l (2) prepare RFI; prepare'DTER; review SER; Site' Survey; {

review SSER; Hearing Testimony where applicable. About i 20% of the work was completed on.WNP-1 when deletion of.

the task was made for WNP-1.

This charge is correct as previously billed.

4. $1,753 by INEL and not BNL' (FIN A3714 - September 1983) was for LWR Systems Corrosion:

Safety analysis reports and special submittals provided  ;

by applicants contain detailed information related to 1 methods to mitigate the corrosion degradation of components and. subsystems of nuclear plants. Since there ,

were a. number of methods to achieve,the objective of -

minimal degradation, it was necessary to evaluate a  :

variety of proposed programs in relation to plant-  ;

specific conditions. The' objective of this FIN was to obtain expert technica1' support to assist the staff in the evaluation of proposed ' programs; the development of-specific licensing positions', both new and modified y existing positions, along with.their bases, and the ' ')

. preparation of presentations for the Advisory Committee onReactorSafeguards.(ACRS),as. required,in'the specific areas designated below.

Specific work requirements:

Task 1 - Using Standard Review Plans 4.5.1, 4.5.2, 5.2.3..

5.4.2.1, 6.1.1, 9.1.2, 9.1.3, 10.3.6,.10.4.1, 10.4.6 and 3 10.4.8, review and assess the corrosion degradation j potential of components, and the materials / fluids 1 '

compatibility in the systems. Review and assess the

),

,I 3 ( ep

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)

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y l1 m conformance to current licensing criteria for the control l of corrosion' of. the ' primary coolant systemi- ESF, j containment spray systems, spent fuel pool . cooling-

. q systems, and the steam generator; Task 2 - Provide a written-evaluation' of the'above:to be . 1 used as input to the branch SER. .

.1 This charge is appropriatejas. previouslytbilled.

5. $34,098 by 'INEL (FIN A6422 - cumulative costs through t September 1983) was OL Final Safety Analysis Report L

(FSAR) Acceptance-Review' +

-;1 The objective of tthisLprogram was to provide 1 technical expertise to. assist. the Nuclear Regulatory Commission)

'(NRC).staffinconductingacceptance' reviews.'for R l Operating License'.(0L) applications. The detailed 1 steps ij L involved in conducting an acceptances reitiew areLfound in -

l- (a) NRC Reg. Guide 1.70, " Standard Format and. content' of . I Safety Analysis Reports for Nuclear. Power Plants," . . ' O November 1978, and (b) NUREG-0800, " Standard -Review Plan

for the Review of Safety Analysis. Reports .for Nuclear. ,  !

Power Plants, LWR Edition," July '1981.' Work'on WNP-1-and

WNP-4 FSAR began December 1981 and the. Safety ' Analysis

l t Report was completed and fomarded with questions'to.NRC d i- in January 1982 by the contractor, j

-(

These costs are appropriate for WNP-1.

Based on the review of the contractual cost concerns for WNP-1 and the findings resulting from NRR'_s_ review ofithem, thei contractual costs for 00119 for Litems 1.A.l' through A.5 above -l will be. reduced by $8,000 as specified in A.2.

B. WNP-1 NRR Staff Hours: ,

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1. The 539.5 hearing-hours were not included in those. d

!. charged to the Supply' System on: Bill No. 00119. i Therefore, no bill adjustment.is needed for these hours..

L 2. There was concern .that' of. 287.5 ho,urs there were several j items of CP' costs which appear inappropriate!as 0L- review I

charges:-

Of the 287.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, only 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />.were charged to the Supply System. The remaining 203.5' hours;were non-regular and hearing hours so they. were not. b'illed.

For the 84 billed hours: ,

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(1) 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> !in .1975 was' a reporting code error as Eval'.

.& Q2.(CP)'when the review was really Post-CP review and should have been reported as R-18. j (2) The'34 hours3.935185e-4 days <br />0.00944 hours <br />5.621693e-5 weeks <br />1.2937e-5 months <br />'in 1976l(32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />)landg1982(2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />). j were 'also a' reporting code cirror; 32 nours were'R25

- Eval. and SER (0L)'and.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> were E22 -

Acceptance Review (OL).

Based on the above, of the 287.5,' only 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> were billed and are' appropriate. Therefore, no adjustment to  ;{'

the bill is:necessary.for this-item.-

3. The' concern forfthel694.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> was that'these hours that~

'were reported against TAC's' are hours. spent in-review, evaluationiand preparation ~ of licensing actions for unanticipated events.at. operating facilities,.and;.

considering the WNP-l's status!they are not appropriate.

606.5 of these hours were billed on D0119; 88 were }

non-regular hours.and were not billed. The 606.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> have been reduced to 578.5 because 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />s-in 1977 and 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />' in 1978 were. for generic studies and 15 hour1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />sLin I 1977werefor-licensing'assistantwork(Rushbrook)which should not'have been billed. The 578.5 were for activities on post-CP-issuance.0L review work that was '

assigned TAC numbers for statistical purposes,-but is chargeable as OL review.

l- An adjustment of.28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />'is appropriate'for the hours ,

billed on D0119. l

4. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in 1977 coded as reactor operator: exams. These two hours were for the review of the licensee's B&W simulator proposal .for training operators and not .the administration of e' examinations. Therefore, they were appropriate.

5. The3. hours (2in1982and1,in,1983)werecodingusage'.

errors in.that the 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> were for SafetyL Evaluation and SER (0L) and~should.have beenLreported.as such and using

. Code R-25.- The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> was Environmental Evaluation and Q1_'s(0L)'andcarriesCodeE-23.

No change in hours bille'd on' 00119 is required for this Rem.

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, 6. There were 54.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> in 1984' identified as PostLACRS (0L) which the Supply System views as;not being OL review costs. Of these 54.5, only'18 were reported as Post ACRS (0L)., The balance of 36.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> were' Evaluation and Q1's/SER (0L). _The 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> were miscoded'in.that they were also Safety Evaluation and Q1's (OL).for which the '

code.is R-23. These hours were correctly billed as OL review costs.

Based on a review of the Su'pply' System's concerns on the hours j billed ,to WNP-1. and the findings resulting from NRR's review of them as addressed in items'I.B.1 through B.6 above, an adjustment of 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> is due the Supply. System as discussed )

in B.3. Of the 1581 hours0.0183 days <br />0.439 hours <br />0.00261 weeks <br />6.015705e-4 months <br /> q'uestioned by the Supply System,-

only 718.5 of these hours were included in -Bill No. D0119 and ,

all of these.were correctly billed except for the 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />.- 1 The' costs.in 00119 will-be' adjusted for these 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> at.$39  :{

per hour for a sum of $1,092.

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II. WNP-3-(Bill No. 00120_)_: -

A. WNP-3 contractor costs (describe work, deliverable product, and identification of some contractors): j

\

1. $1,753 for BNL costs:

1. I See item I. A.4 under WNP-1 of this enclosure. This j charge is appropriate as previously billed.

2. $6,071 has been deleted since NRC no longer has sufficient records to identify the contractor'for this l charge. Therefore, an adjustment of $6,071.is-being l made.

3. $18,722 by BNL (FIN A3702; September 1983) was for.the review of auxiliary feedwater system reliability.-

The purpose of this project was to evaluate the Auxiliary-Feedwater System (AFWS) reliability Studies, submitted by_

utilities, for accuracy and completeness in accordance with the guidelines in Standard Review Plan Section 10.4.9 and NUREG-0611 and 0635. Using fault tree, event-tree or other logic techniques, BNL determined the probability for system deficiency / failure under various-transient conditions.

Thisfeeisapplicableaspreviouslybilledi Based on a review of the contractual costs for WNP-3 in items II.A.1, 2 and 3 above, an adjustment of $6,071 is necessary.

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B. WNP-3 NRR Staff Hours

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1. On page 2 of the January 6.1986 letter, the Supply - I System stated that 9,135 of the 22,961 hours0.0111 days <br />0.267 hours <br />0.00159 weeks <br />3.656605e-4 months <br /> billed on Bill No. D0120 were prior. to issuance of the construction -

permit for WNP-3 'on April 11, 1978. ]

The 22,961 hours0.0111 days <br />0.267 hours <br />0.00159 weeks <br />3.656605e-4 months <br /> charged on'the bill as-OL review have been reduced to 13,842 to delete'9,119 hours0.00138 days <br />0.0331 hours <br />1.967593e-4 weeks <br />4.52795e-5 months <br /> as construction permit review time - see-Attachments A'and B

-to this-enclosure. Therefore, an adjustment of $355,641 is .due the Supply System (9,119 hours0.00138 days <br />0.0331 hours <br />1.967593e-4 weeks <br />4.52795e-5 months <br /> 0 $39 per hour). .]

2. 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> in 1981 as Hearing (CP) were not charged to the

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Supply System in D0120. l l 1 3,. 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> in 1981. for R Safety- Acceptance Review (0L).

were inputted with the incorrect year in that these were l- h.ours in 1982 by Rothberg. .

The number of hours are l l correct as previously billed, i I~ 4. 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> in 1982 for E Environmental FES (OL) were i miscoded in that they were for E23 - Environmental l Evaluation and-Q1's (OL). The number of hours are-1 l correct as previously billed.

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5. 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> in 1983 for E Environmental Acceptance Review (0L) were actually for 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> on E-23 l Environmental Evaluation and Q1's (0L) and 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br />'for .  !

R Safety Evaluation and Q1's (OL). The hours billed

~1 are correct.

6. 39 hours4.513889e-4 days <br />0.0108 hours <br />6.448413e-5 weeks <br />1.48395e-5 months <br /> in 1983 as Hearings -(0L) were not charged to the Supply System in 00120.

Based on a review of the 137 hours0.00159 days <br />0.0381 hours <br />2.265212e-4 weeks <br />5.21285e-5 months <br /> questioned by the Supply System in items II.B.2 through B 6 above, we find that 59 of-the hours were not billed to the Supply System and, while the remaining 78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br /> were incorrectly coded or entered under the .

l' wrong year, they are correct as billed. Therefore, the total-

, cost' adjustment for hours is that $355,641Laddressed in item-II.B.1 for the 9,119 hours0.00138 days <br />0.0331 hours <br />1.967593e-4 weeks <br />4.52795e-5 months <br />. ,

III. In addition to the Supply System's concerns, the NRC's review of the contractual costs for WNP-1 and WNP-3 ha's revealed that the

! following costs are chargeable to the Supply' System, but were not included on Bill Nos. D0119 and 00120. Consequently, the adjustments are being made. For FIN No. B8020-(Gage-Babcock Associates, Inc.), a sum of $4,775 was expended for WNP-1 and a' sum of $2,283 was expended for WNP-3'through September 1983 on reviews' associated with fire. protection concerns.

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IV. Sumation of adjustments for WNP-1 and WNP-3:

Facility Hours Contractual Total Adjustment WNP-1 28 hrs x $39 = $1,092 ($8,000 - B2355} ~$4,317 ($9,092. <

+ 4,775 - B8020 less 4,775)  !

l WNP-3 9,119 hrs x $39 ($6,071) $359,429

= $355,641 + 2,283'- 88020 ($361,712less 2,283) j

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Based on the. above adjustments for WNP-1, a refund of $4,317 is due the Supply System on Bill No. 00119, and for WNP-3, a refund ,

of $359,429 is due the Supply System on Bill No. D0120. Jointly, i the refund is $363,746.

Attachments:

A - Review of OL Charges  !

for WNP-3 B - Backup Data for OL Charges By Years for WNP-3 i

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Review of OL Chgar es for Wt1P-3, 11/ITlW- 6723784 I

Total Hours Expended 23,417 j from 11/14/74 - 6/23/84 1 1

Hours Prior to CP iss'uance. -9,504 (1974-1978)*

Hours for Post CP Hearings and Administration .\

(1978 - 19R4) -71 )

13,842 Hours Previously Charged to Licensee 22,961 for OL Review I l

Hours Overcharged 9,119 l (Licensee's Estimated Hrs. Overcharged 9,13 9 ,  ;

( A Between NRR and Licensee Overcharged Hrs. 19 l

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l *0ne fee for CP application to be charged l l1 1

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Attachment A to Enclosure'2 l

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• i BACKUP DATA l

1. Hours -

• . a

.j 1974-1977 -9,093.5 - Pre CP time

• i 1978 (thru 4/11) 66 - CP Related*

344.5 - CP Hearings

• 1978 (Remainder)-

100 - TAC Related (Post CP Lic. Review)-

1 9 - Post CP i

'J )

8 - Administration *- i 1979 -

• l 4.5 - Post CP b 1980 - , 17.5 - Post CP 1981 - 20 - Hearings * '

101 - Post CP 1 38 - OL Acceptance Review (Should be 1982)1  ;

i k 1982 , 2,234 - OL Related

.(

'12 - Post CP I 1983 10,284.5 - OL Related-

39. - Hearings

• c 1984 (thru 6/23) 1,041.5 - OL Related 4 - Hearings

• TOTAL 23,417

- 9,575*

13,842

• Deletions from OL Review 4

Attachment B to Enclosure 2 - '

si

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