ML19338D358
| ML19338D358 | |
| Person / Time | |
|---|---|
| Site: | 05000142 |
| Issue date: | 09/09/1980 |
| From: | Helwick C, Reidhaar D, Woods G CALIFORNIA, UNIV. OF, BERKELEY, CA |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML19338D359 | List: |
| References | |
| NUDOCS 8009230016 | |
| Download: ML19338D358 (20) | |
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4 U:iITED STATES OF AMERICA 5
NUCLEAR REGULATORY COMMISSION 6
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD PANEL 7
8 9
10 In Re:
)
Docket No. 50-142
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11 THE REGENTS OF THE UNIVERSITY
)
(Proposed Renewal of CALIFORNIA
)
Facility License I
12 (UCLA Research Reactor)
)
Number R-71)
)
13 14 UNIVERSITY'S RESPONSE TO SUPPLEMENTED PETITION TO 15 INTERVENE OF THE COMMITTEE TO BRIDGE THE CAP 16 17 18 19 20 DONALD L.
REIDHAAR 21 GLENN R. WOODS CHRISTINE HELWICK 22 590 University Hall 2200 University Avenue 23 Berkeley, California 94720 Telephone:
(415) 642-2822 24 Attorneys for THE REGENTS OF THE 25 UNIVERSITY CF CALIFORNIA e
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I 1i SUBJECT INDEX r
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I.
INTRODUCTION 1
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II.
GENERAL DISCUSSION: INTERVENTION IN 6
NRC LICENSING PROCEEDINGS 2
7 III.
DISCUSSION OF CONTENTIONS 4
8 A.
Incomplete And Inadequate 9
Application 5
10 B.
History of Alleged Reactor Deficiencies 9
11 C.
Safety Of Current Reactor 12 Operations 14 13
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IV.
ADDITIONAL HEAR'ING CONSIDERATIONS 17 14 15 16 17 18 19 20 21 22 23 24 25 26
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UNITED STATES OF AMERICA 5l NUCLEAR REGULATORY COMMISSION 6
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD PANEL 7
8 9
In Re:
)
Docket No. 50-142 10
)
THE REGENTS OF THE UNIVERSITY
)
(Proposed Renewal of 11 CALIFORNIA
)
Facility License (UCLA Research Reactor)
)
Nunber R-71) 12
)
13 14 i UNIVERSITY'S RESPONSE TO SUPPLEMENTED PETITION TO I
INTERVENE OF THE COMMITTEE TO BRIDGE THE GAP 15 16 17 I.
INTRODUCTION 18 19 20 On July 21, 1980 the Chairperson of the Atomic 21 Safety Licensing Board ordered a prehearing conference in 22 the above-captioned license renewal action to consider the 23 petition to intervene of The Committee to Bridge the Gap 24
("BTG"),
dated May 22, 1980.
The prehearing conference 25 order invited BTG to supplement its petition to intervene 26 and also invited The Regents of the University of California i
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(" University")
to respond to any supplemented petition 2 l submitted by BTG.
At the request of BTG the date of the 3
prehearing conference as set in the July 21 order was 4
changed.
The prehearing conference is now scheduled to be 5
held on September 25, 1980 in Los Angeles.
6 7
Pursuaat to the prehearing conference order, the 8
University hereby submits it respor.se to BTG's supplemental 9
petition to intervene.
10 II.
GENERAL DISCUSSION:
INTERVENTION IN NRC 11 LICENSING PROCEEDINGS 12 13 Intervention in NRC Licensing Proceedings is 14 governed by the provisions of the 10 Code of Federal 15 Regulations section 2.714.
According to these provisions 16 petitioner is required to supplement the petition to 17 intervene with "a list of the contentions which petitioner 18 seeks to have litigated in the matter, and the bases for 19 each contention set forth with reasonable specificity."
(10 C.F.R. S 2.714(b).)
A petitioner who has satisfied the 21 interest requirement will be granted intervention if he 22 states at least one contention within the scope of the 23 proceeding with a proper factual basis (Id.).
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1 Although the main purpose of the prehearing 2
conference is to' determine whether the test of the "one goed 3
. contention" has_been cet, where that rule is satisfied the
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. presiding officer is also charged'to consider " simplification, 5
clarification, and specification of the issues" and other 6
~ matters that will assist _in avoiding unnecessary proof and 7
in defining the matters in controversy to be determined in 8
the proceeding.
(10'C.F.R. S 2.752..)
9 10 Including the latest supplement, petitioner has 11 now submitted 179 pages of material allegedly questioning i'
12 the-propriety of a license renewal "or the UCLA Nuclear 13 Energy Laboratory reactor ("NEL reac )r").
The supolement 14 to the petition to intervene, which cc _ cains 137 unt umbered 15 pages, purports to establish 23 separate contenticis for 16' consideration by the Atomic Safety Licensing Board.
While
'17 petitioner suggests that its supplement is not nece: sarily 18 -
inclusive of its' contentions previously stated in i.ts 19 Petition, it is readily apparent that it constitutes no more 20 -
than a
detailed-restatement ~ of those contentions.
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- 21 22 Petitioner's supplement is. exceedingly repetitive, q
23 cumulative, and in large part, irrelevant to this license
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_ 24 renewal' proceeding.-
- Moreover, many ~ of the separate
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allegations. rest on incorrect factual bases, depend on 16
. misunderstanding : of the laws of physical science or mis-3
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l interpretations Lof NuclearJ Regulatory : Commission. standards 2~
and requirements, or raise matters that have long since been 3
considered and disposed ; of: by the Commission.
Indeed, many-4'
-of the allegacions 7 Which fall - into this latter category.
-l-5 amount to' no more than a historical account of past NRC 6
inspection - findings with BTG interpretative and editorial
?
7
. comments.
On the ' basis of the supplement it would not be 8
possible to develop a sound, clear and concise record in the 9
proceeding.
Instead, it is likely to broaden and unduly 10-delay consideration of the University's license renewal 11 application.-
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12 13 Neverthaless, the University recognizes the
,14 public's interest in the general safety of the NEL reactor 15 facility and is prepare.d to - demonstrate that petitioner's 16
. contentions lack substantive basis and are without merit.
17 At this stage in the proceeding, however, the University 18 limits its resconse to a recommendation of those inherently 19 incorrect ' or irrelevant contentions, and ' a request for 20
~ simplification of-the remainder of petitioner's arguments.
21 III.
DISCUSSION OF CONTENTIONS 22 23; 24-A's indicated in its. introductory pages, BTG's 25 supplemental:. contentions can be organized into three major 26-
. categories :-
- (1)- the completeness and adequacy of the 4
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1l application; (2) the history of alleged reactor 2l deficiencies; and (3) the safety of current reactor 3
operations.
The University's discussion below is organized 4
accordingly.
5 A.
Incomplete And Inadequate Application 6
7 The following contentions ara included in thic 8
category:
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10 I.
Application Grossly Inadequate 11 II.
Wrong Class of License 12 VIII.
Failure to Meet 10 C.F.R. 100 Siting 13 Criteria Regarding Radiation Release in 14 an Accident 15 X.
Inadequate Environmental Impact 16 Appraisal 17 XVII.
Inadequate Financial Qualifications 18 XVIII.
Failure to Adequately Examine Maximum 19 Credible Accident for this Reactor 20 XIX.
Physical Security Plan 21 XX.
Emergency Response Plan 22 XXI.
Safeguards Contingency Plan 23 24 None of these contentions are suitable for 25 adjudication before the Atomic Safety Licensing Board 26
("ASLB").
It is the NRC staff which determines the 5
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-completeness and adequacy of the University's application.
2 (NRC Staff -Practice and Procedure ~)igest, Supplement 1,
t 3 I section I.5.1; New England Power Co.,
et al. (NEP, Units 1 &
4l 2), LBP-?S-2 7 NRC 271, 280 (1978).)
The staff has raised 5
no objections to the adequacy or completeness of the 6
University's application.
Where questions have been raised, 7
they have been or will be answered, which the University 8
anderstands is a part of the normal license renewal process.
9 Fur th, ser a, a brief response to the contentions raised by 10
?TG reveals that they lack merit or are irrelevant to the instant proceeding.
11 12 13 1.
The whole of Contention I is redundant 14 or irrelevant and requires no separate consideration in this 15l proceeding.
Allegations concerning the certification of i
16 "Part 70" information are properly subsumed under 17 petitioner's Contentions XII, Special Materials License; 18 allegations concerning an Environmental Impact Appraisal 19 repeats Contention X,
Inadequate Environmental Impact 20 Appraisal; allegations concerning vibration tests are 21,
subsumed under Contention XVI, Seismic Vulnerability; 22 allegations regardings hazards analysers are appropriately 23 coneidered under Contentions V, Too Much Excess Reactivity, 24 VIII, Failure to Meet 10 C.F.R. 100 Siting Criteria, XI, 25l Lack of Adequate Safety Features, XIV, Siting, and XVI, 26 Seismic vulnerability.
Other allegations, for example those 6
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2i that AMF is cut of the reactor business, are simply 3
irrelevant.
4 5
2.
With regard to the Contention II, Wrong 6
Class of License, the NEL reactor was licensed as a " class 7
104" facility prior to ~ December 19, 1970 and clearly is 8
still properly characterized as a " class 104" facility.
(10 9
C.F.R. S 50.21.)
BTG has misread sections 50.21 and 50.22 10 of Title 10 to derive, apparently, a "50%-commercial-contribution" 11 test for " class 103" license applicants, and misinterpreted 12 NEL - reactor financial data to its own conclusions abcut 13 whether its " test" has been met.
14 15 3.
Contention VIII is concerned with 10 16 Code of Federal Regulations section 100 Siting Criteria.
In 17 the first place, it should be noted that 10 Code of Federal 18 Regulations section 100 applies to stationary power and 19 testing reactors.
(10 C.F.R. 33 100.l(a) and 100.2.)
The 20 NEL reactor is neither a stationary power nor a testing 21 reactor under the criteria of section 50.2(r).
The NEL 22 reactor is a 100 kilowatt research reactor.
In applying 10 23 Code of Federal Regulations section 100 criteria to data 24 extracted for NEL reactor performance, a fission product 25 release postulated on any core meltdown scenario, as 26 suggested by he footnote to section 100.11, is hardly 7
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4.
Contention X alleges the inadequacy of 4
the Environmental Impact Appraisal, whithout regard to the 5
distinction between an Environmental Impact Statement and an 6
Environmental Impact Appraisal (10 C.F.R.
S 50, et seq.).
7 8
5.
Contention XII faults the University for 9
failing to apply for a Special Materials License.
The 10 University's application for this license is contained in 11 its license renewal application for the reactor (see p. 5),
12 which is the usual practice in multi-license applications 13 and is specifically authorized under the regulations.
(10 14 C.F.R.
SS 50.52, 70.21 and 70.23.)
15 16 6.
Contention XVII alleges that the 17 University is not financially qualified.
The University 18 requests that the ASLB take judicial notice of the fact that 19 the University of California is a governmental entity of the 20 State of California and is financially qualified.
21 22 7.
Contention XVIII faults the University 23 for failing to examine the ma::imum credible accident for 24 '
this reactor.
As stated earlier, the sufficiency of the 25 hazards - analysis and the various scenarios to be considered 26 in the application are matters for the NRC staff to I
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determine.
BTG's concerns in this area have been raised in 2
other of its contentions, for example, the contentions on' 3
"too much excess reactivity." seismic vulnerability," or 4
" lack of operational reliability."
In addition, a maximum 5
credible accident has not been established for Argonant 6
reactors.
7 8
8.
Contentions XIX and XXI are concerned 9
with the physical security and safeguards contingency plans.
10 Information related to the security of the facili, and 11 materials' handling is privileged information under 10 Code
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12 of Federal Regulations section 2.790.
BTG's alleged 13 concerns regarding these plans are too speculative to be 14 admitted as contentions.
15 16 9.
Contention XX alleges deficiencies in 17 the emergency response plan.
As indicated above, the 18 adequacy of the elaboration of any such plan in the 19 application is a matter for the NRC staff to determine.
20 21 B.
History of Alleged Reactor Deficiencies 22 23 Petitioner's second major contention category 24 centers around its allegation that a ".
history of 25 deficiencies in the reactor operation over the previous 26 twenty years makes it impossible for the Applicant to a
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reasonably assure that, in the future, they (sic) will 2
comply with the regulations applicable to them, and that 3
they will not endanger the public health and safety.
4 (Supplemental Contentions, Introduction.)
Petitioner's 3
Contentions III, IV, VI, and IX fall into this cagetory:
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Inadequate Managerial And Administrative 8
Controls 9
IV.
Violations of NRC Regulations 10 VI.
Excessive Radiation; Violation of 11 Radiation Standards,-
Inadequate 12 Monitoring 13 IX.
Inmaequate Maintenance and Calibration 14 15 1.
In Contention
- III, petitioner 16 incorrectly asserts that the NEL suffers from " inadequate 17 managerial and administrative controls."
In support of this 18 contention, petitioner dredges up " incidents" which occurred 19 at the reactor as early as 1965.
In fact, of the ten 20
" incidents" cited by petitioner as having occurred between 21 1965 and 1979, nine occurred prior to 1974.
The University, 22 therefore, objucts to Contention III on the basis that the 23 remoteness of the " incidents" set forth have little or no 24 relevance to the operation of the reactor today.
The 25 University submits that an approp-ce timeframe for the 26' Board's consideration of this license renewal application is 10
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two. years, and, in any case, not before 1975.
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Many of the incidents wnich petitioner 4
cites were resolved long ago with the AEC or the NRC staffs.
5 Indeed, the most recent inspection referrad to in Contention 6
III occurred in 1974.
Petitioner makes no claim of cry 7
chronic, longstanding, or deliberate problems or patterns 8
which have not been resolved as a result of administrative 9
changes undertaken since 1975.
The Board should note that 10 in 1975 a new Director of Reactor Operations was appointed; 11 a reactor advisory group was constituted by the Dean of the 12 UCLA School of Engineering; and the process of in-depth 13 review of reactor operations was intensified.
This process 14 resulted, in part, in the NRC's issuance of Amendment 10 to 15 the NEL reactor license (February 5, 1976) which clarified 16
.its operating hours, restated the required stack height and 17 ventilation rate for emissions, and allowed the removal of 18 the stack nozzle.
The reactor currently operates in 19 conformity with the requirements of its license and the 20 amendments thereto.
21 22 In addition, petitioner neglects to 23 mention the results of a very recent (Fall 1979) surprise 24 inspection made by the NRC in response to petitioner's 25 concerns over purported excess Argon-41 exposures from the 26 stack effluent.
The report issued as a result of that 11
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inspection is 'at'tached as ' Exhibit A, and concludes that "No 2
items.of noncompliance ' or deviations were identified."
3 4
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In ' Contention IV, petitioner alleges 5
that the NEL ' has " consistently been cited for violations of 6
NRC ' regulations as well as violations of the provisions of 7
its own Technical Specifications. "
(Supplemental Contentions, 8
Part IV. )
'Again, as part of this " consistent pattern,*
9 petition'er cites a string of " incidents," none of which 10 occurred after.1975, and at least~ three of which are 11
. permitted under Amendment 10 to the reactor's license.
12 13 The University's objections to 14 Contention III,.above, are equally applicable to Contention 15 IV and are incorporated in its response to contention IV.
16
-17 3.
In Contencion VI, petitioner again cites 18 early violations or incidents.
The document prepared and 19 referred to by. petitioner ("The UCLA Reactor:
Is It Safe?)
'20 was the subject of a' detailed response dated January 3, 1980
-21 submitted by the University to NRC Chairman Aherne, and
' 22 entitled "The UCLA Reactor is Safe."
A copy of this 23 response is ato.aned as Exhibit B and does not support 24 peticioner's' claims.
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1 Also in Con *.ention VI, petitioner refers 2
to future emissions, the possibility of a future increase in 3
reactor use and power, and to the fact that the stack height 4
has not been increased and the stack no: le has been 5
removed.
Both the stack no: le removal and height are in 6
conformity with Amendment 10 to the University's license.
7 Moreover, any increase in reactor use or power beyond that 8
already permitted in its license would of course be subject 9
to separate NRC review and approval, and is not properly 10 part of this proceeding.
11 12 contention VI also contains the 13 allegation that the NEL reactor fails to meet the radiation 14 standards imposed by 10 Code of Federal Regulations section 15 20 ( Appendix B and 10 C.F.R. SS 20.106(b) and 20.106(b)(1) 16 and (2)).
Again, petitioner relies on a 1975 finding of 17 violation and, further, cites sections of NF.c Regulatory 18 Guide 1.109 and 10 Code of Federal Regulations part 50 19 which, by definition and scope are applicable only te power 20
- reactors, not research reactors such as the UCLA NEL 21 reactor.
Whether power reactor radiation standards should 22 apply to research reactors, such as NEL is properly a j
23 question of rule making and not properly the subject of this 24 proceeding.
(Potomac Electric Power Co.
(Douglas Point 25 Nuclear Generating Station, Units 1 & 2), ALAB-218, 8 AEC 79 R
26 (1974).)
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4.
Contention IX is an allegation that the 2
University has not adequately maintained its equipment or 3
calibrated its monitoring instruments properly.
Again, the 4
violations upon which petitioner bases its conclusions date 5
from 1968, 1974 and 1975.
6 7
Petitioner's allegation that the 8
requirement for conducting heat balance calibrations are no 9
longer in the University's Technical Specifications is 10 untrue--(see Application, Technical Specifications, V.4.2, 11
- p. V/4-1).
Additionally, petitioner incorrectly characterizes 12 the University's attempt to make all annual calibration 13 tests uniform at 14 month intervals as a " relaxation. "
In 14
- fact, all
" annual" calibration and testing with the 15 exception of the heat balance has been on a 14-month basis.
16 17 C.
Safety of Current Reactor Operations 18 19 Petitioner's third major contention category is 20 based upon allegations that ".
inherent problems of the 21 reactor, such as age, seismic vulnerability, location in a 22 densely populated area, etc.,
indicate that the reactor 23 cannot be operated in a manner that will not be inimical to 24 the public health and safety."
(Supplemental Contentions, _ _
25 Introduction.)
The following contentions fall within this 26 category:
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6 1l V.
Too Much Excess Reactivity i
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VII.
Lack of Operational Reliability i
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XI.
Lack of Adequate Safety Features 4
XIII.
Inherent Problems in Argonant Reactors 5
XIV.
Siting 6
XV.
Reactor is Too Old 7
XVI.
Seismic Vulnerability 8
XXII.
Technical Specifications Inadequate 9
XXIII.
Procedural Contentions 10 11 1.
Contentions V, XI, XIII, and XVI contain 12 allegations that amount to the general charge that continued
- 13 operation of the reactor poses serious public health and 14 safety risks.
The University disputes any such conclusions 15 and is prepared to demonstrate their ~1ack of me: cit.
16 17 2.
Contention VII of the Petition alleges a
_ _ 18 4 persistant pattern of numerous unscheduled shutdowns, 19 abnormal occurrences and accidents."
(Supplemental Contentions, 20 Part VII.)
There are no standards in law or in the 21 regulations for raising a presumption of unsafe reactor 22 operation by reference to a particular number of shutdowns 23 or
" abnormal occurrences."
In fact, such occurrences 24 provide evidence that the reactor systems are functioning 25 properly.
26 15
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1 3.
Contention XIV contains allegations that 2
are properly subsumed elsewhere (seismic vulnerability), or 3
are irrelevant (the 10 C.F.R. 100 Siting Criteria).
4 5-4.
Contention XV alleges that the present 6
age of the NEL reactor poses an unacceptable hazard for the 7
proposed license renewal period.
Petitioner has confused 8
concerns expressed by the Director for upgrading and 9
modernizing the facility with concerns (not expressed) for 10 the safety of the facility.
Petitioner also incorrectly 11 asserts that the age of the reactor has a bearing on the 12 ability to get spare parts for it.
Indeed, the NEL reactor 13 was custom-built and the vendor, even if still in the 14 business of assembling reactors, would not be stocking 15
" spare parts."
Parts for the NEL reactor are often 16 fabricated and repairs " customized" to update and improve 17 upon reactor safety.
13 19 5.
Contention XXII alleges that the 20 technical specifications included in the application 21 unacceptably reduce safety standards.
The relevant safety 22 aspects are already the subject of other contentions, and 23 thus contention XXII is redundant and should not be 24 considered separately.
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Contention XXIII of petitioner 2
speculates about matters which are not the subject of this 3
Contention XXIII is irrelevant 4
to this proceeding.
5 6
IV.
ADDITIONAL HEARING CONSIDERATIONS 7
8 If the Board determines at the prehearing 9
conference that this matter should proceed to hearing, the 10 University requests that consideration be given at the 11 conference to certain procedural matters, such as what will 12 constitute appropriate service of documents, scope and 13 conduct of any necessary discovery, scheduling and 14 accommodation of any site tours,' and location, time and 15 appropriate security for the actual hearing.
The University 16 will be prepared to explain and elaborate its concerns in 17 each of these areas, as necessary, at the prehearing 18 conference.
19 Dated:
September 9, 1980 20 DONALD L.
REIDHAAR 21 GLENN R. WOODS CHRISTINE HELWICK 22 By 24 Glenn R.
Woods 25 26 By Christine Helwick~
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- yAMt '. g' UNITED STATES "
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- E' NUCLEAR REGULATORY COMMISSION
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~I REGION V q ~ o 1990 N. CALIFORNIA 800LEVARD g
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SulTE 202, WALNUT CREEK PLAZA O
WALNUT CREEK, CALIFORNIA 94596 00T 12 1979 Docket No. 50-142 4-University of California at Los. Angeles Los Angeles, California 90024.
Attention:
Dr. ' Harold V. Brown t..
Environmental Health and Safety Officer Gentlemen:
Subject:
NRC Inspection of UCLA Research Reactor This-refers to the special inspection conducted by Mr. J. B. Baird of this office on September 27-28, 1979, of activities authorized by NRC License No.
R-71, and to the discussion of our findings held by Mr. Baird with Mr. N.
Ostrander and other members of the staff at the conclusion of the inspection on September 28, 1979.
Areas examined ~during this inspection are described in the enclosed inspection report.
Within these areas,. the inspection consisted of selective examinations of procedures 'and representative records, interviews with personnel, and observations by: the inspector.
No items of noncompliance w.ith NRC requirements were identified within the
-scope of thels inspection.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2. Title
~ 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.
If this report contains any information that you believe to be proprietary, it is necessary that you submit a written application to this office, within 20 days of the date of this letter, requesting that such information be withheld from public' disclosure.
The application must include a full statement of the reasons why it is claimed that the information is proprietary.
The application should be prepared so.that any proprietary information identified'is contained in an enclosure to the application, since the'~ application without the enclosure will also be placed in the Public Document Room.
If we do not hear from you in this regard within the specified period, ~ the. report will be'placed in the Public Document Room.
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University _of ' California at Los Angeles-OCT 22 gg
.b Should you have any questions concerning this. inspection, we will-be glad to discuss them with you.
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_ Sincerely,-
, f.
W 1
H. E. Book, Chief Fuel Facility and Materials Safety Branch
Enclosure:
IE-Inspection Report No. 50-142/79-04 i
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EXHIBIT "
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PAGE A OF~ //
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r U.S. tlUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT 50-142/79-04
!eport flo.
50-142 R-71 locket No.
Licensee flo.
Safeguards Group g
University of California at Los Angeles j
Los' Angeles, California 90024 acility Name:
UCLA Research Reactor (Argonaut-100KW) f nspection at:
UCLA Campus n'shectionConducted: September 27-28, 1979
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6.w alro, Kadiation dpecialist DatE( Cighed Date Signed Date Signed 1
./O [/ 9 /'7 9 1.M 7
1pproved by:
H. E. Bool2, Chief, Fuel Facility and Materials D' ate signed
. Safety Branch' ssummary:
Inspection of September 27-28, 1979 (Recort No. 50-142/79-04)
Areas Insoected:. Special, unannounced inspection to evaluate UCLA based group's concerns;of excessive Argon-41 exposures from the stack effluent.
The concerns and' allegations included:
(1) failure to adequately maintain restricted area on"the roof around the stack, (2) application of a reactor use factor without considering whether the time of use is during the time of public occupancy of surrounding areas, (3) underestimation of occupancy factor
-for adjacent areas, and (4) failure to evaluate concentration of Argon-41 inside adjacent b0ildi,ng.
n1
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The inspection activities involved 13 inspector-hours by one NRC inspector.
tions were identified.
DUPLICATE DOCUMENT Entire document previously entered into system under:
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'k ANO No.,of'pages:,
EXHIBIT "
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