[D�i�ld. Florek - Fvid: IN RC CONCERNS] NRC Sch�dulesVYIEN - - P�1irD-6iia-ia.-Ffo-r-el�--F�id:-[NRC--CONCERNS] NRC Sctiedules--VY IEA- - -- - - -- , - - -- P-a-g-eq

From: Diane ScrenciTo: A. Randolph Blough; Brian Holian; Cliff Anderson; Donald Florek; HubertJ. Miller;Rick EnnisDate: 5/6/04 9:40AMSubject: Fwd: [NRCCONCERNS] NRC Schedules VY IEA

Diane ScrenciPublic Affairs OfficerUSNRC, RI610/337-5330

C;SE

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;Donald.Flore- [NRCCONCERNS] NRCSche-du e VY lEA- Page 1

From: shadis@prexar.comTo: <NECNP@NECNP.ORG>, <nuclearfreevermont~yahoogroups.com>, VermontYankee Power Uprate Moderator <VermontYankeePower Uprate-owner@yahoogroups.com>,<nirsnet~nirs.org>, NRC CONCERNS <nrc-concerns@yahoogroups.com>, NucNews<NucNews~yahoogroups.com>Date: 5/6/04 9:05AMSubject: [NRC-CONCERNS] NRC Schedules VY lEA

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---I Donald Florek - Part.000 Page 1I Oonald.Florek - Part.000 Page 1 I

Here it is. One giant step for NRC; One small step for Vermont-Kind. We must havecitizen oversight other than the nuclear vision-impaired Sherman. This must be an openprocess, and NRC must be prepared to open it to a full-scale diagnostic evaluation (ISA)upon finding any serious negative indications. In any case, Thank you to all those whosupported the call for an Independent Safety Assessment. Your view, that an IndependentSafety Assessment is the right, prudent, conservative thing to do prior to goosing power onan antique reactor, has been to some degree validated by NRC. I thank you; the earththanks you.Ray

No. 04-055

NRC PROVIDES UPDATE ON REVIEW PROCESSFOR VERMONT YANKEE UPRATE REQUEST

The Nuclear Regulatory Commission today announced it will utilize a new engineeringassessment inspection as part of its review of Entergy Nuclear's request to increase the poweroutput of the Vermont Yankee nuclear power plant by 20 percent.

The NRC's intentions are discussed in the agency's reply to the Vermont Public Service Board's(PSB) request for assurances about Vermont Yankee's reliability following an uprate. Althoughthe NRC's regulatory authority does not cover reliability specifically, the agency oversees manysafety-related systems and functions that contribute to a plant's reliable operation.

"The agency remains committed to ensuring continued safe operation of Vermont Yankee. I havegiven the Governor my assurances on this," NRC Chairman Nils Diaz said.

In addition to its substantial uprate review process, the NRC has decided to also conduct a newengineering design inspection, which has been under development for several months to enhancethe Reactor Oversight Process. The inspection will provide additional information for the NRCand be responsive to the PSB's concerns. "The NRC staff considered a number of factors,including the Board's request for an independent engineering assessment, and concluded it isappropriate to conduct this engineering inspection at Vermont Yankee," Chairman Diaz said.

The NRC will use the new inspection to proactively identify any latent issues in a nuclear powerplant's design, focusing on those components and systems devoted to safety. The designinspection will include an evaluation of changes to the plant's licensing basis to ensure safetymargins remain adequate. At Vermont Yankee, the inspection process will involve three weeksof on-site inspections and more than 700 hours of direct inspection time.

The NRC's inspection team of approximately six will include experienced NRC inspectors, someof whom have not had recent oversight involvement with Vermont Yankee, and at least two

-- -

I Donald -FloreK - Part.UOO P~age 2II Donald .Florek - Part.ODO �age��

contractors with experience in reactor design. The agency will share the inspection schedule withVermont officials to facilitate state representative participation, as allowed by NRC regulationand policy.

The NRC will not approve the Vermont Yankee uprate, or any proposed changes to a reactor'slicense, unless the agency can conclude the changes can be implemented safely. The full text ofthe NRC's letter to the PSB is provided.

Mr. Michael H. Dworkin, ChairmanVermont Public Service Board1 12 State Street, Drawer 20Montpelier, Vermont 05620-2701

Dear Mr. Dworkin:

I am responding on behalf of the U.S. Nuclear Regulatory Commission (NRC) to your lettersdated March 15 and 31, 2004, regarding the request by Entergy Nuclear Vermont Yankee, LLC,and Entergy Nuclear Operations, Inc. (Entergy), to amend the Vermont Yankee Nuclear PowerStation license to increase the power level of the facility. In those letters, the Vermont PublicService Board requested that the NRC conduct its review of the proposed power uprate in a waythat would provide Vermont a level of assurance about plant reliability equivalent to anindependent engineering assessment. The NRC has decided to conduct a detailed engineeringinspection that we believe will be appropriate for addressing our oversight responsibilities and isalso responsive to the Board's concerns. This inspection will be performed as part of a newengineering inspection program that the NRC has been developing to enhance the ReactorOversight Process.

NRC regulations and its oversight process focus on ensuring nuclear safety, whether the facilityis operating at power or shut down. The NRC's statutory authority does not extend to regulatingthe reliability of electrical generation. The NRC recognizes, however, that there is some overlapbetween attributes that result in safe operation and those that contribute to overall plantreliability.

The Commission understands that the Board is concerned about the reliability of VermontYankee following an increase in power level, especially in light of operational issues that haveoccurred at some other plants that have recently implemented extended power uprates. The NRCrecognizes the importance of these issues and is taking steps to ensure that they are satisfactorilyaddressed to maintain safety. For example, in response to instances of steam dryer cracking atsome boiling water reactors, outside technical experts are assisting NRC staff in performing anaudit of General Electric's analyses related to steam dryer performance and specific issues relatedto Vermont Yankee. We continue to engage the industry to ensure resolution of these issues andwill consider additional regulatory action, if needed.

I Donald Florek - Part.000 Page 3 1I D�naldFlorek - Part.OO0 Page 3�

The NRC's established review process for power uprate applications is independent, thorough,and comprehensive. A description of the review process is enclosed. Engineering assessmentshave always been an integral part of the NRC's safety activities. Under our current ReactorOversight Process, NRC resident inspectors and regional specialists routinely evaluate the workperformed by the licensee's engineering organization to determine whether engineering analysesadequately support safe operation. Over the past several months, the NRC has been developing anew engineering inspection program which we intend to pilot at selected plants. The NRC staffconsidered a number of factors, including the Board's request for an independent engineeringassessment, and concluded it is appropriate to conduct this engineering inspection at VermontYankee. This new engineering assessment inspection incorporates the best practices of theexisting and past engineering inspections. The NRC will use this inspection to verify that designbases have been correctly implemented for a sampling of components across multiple systemsand to identify latent design issues. The inspection process uses operating experience, riskassessment, and engineering analysis to select risk-significant components and operator actions,and will ensure that adequate safety margins exist. Although the specific sampling ofcomponents is still being developed, it will include components from multiple systems that arepotentially affected by a power uprate such as the emergency core cooling systems, thecontainment system, power conversion systems, and auxiliary systems. The inspection will beperformed by a team of approximately six inspectors, including some NRC inspectors who donot have recent oversight experience with Vermont Yankee and at least two contractors withdesign experience. Three weeks of on-site inspection and over 700 hours of direct inspectiontime will be conducted. This level of effort exceeds that of the biennial safety system designinspection. The Commission believes it is appropriate for addressing the NRC's oversightresponsibilities and is also responsive to the Board's concerns. The NRC staff will inform theState of Vermont of the schedule for this inspection to facilitate participation by Staterepresentatives, consistent with NRC policy.

The NRC Advisory Committee on Reactor Safeguards (ACRS) will also review the VermontYankee power uprate request. The ACRS is a statutory committee that reports directly to theCommission and is structured to provide a forum where experts representing many technicalperspectives can provide advice that is factored into the NRC's decision-making process. TheNRC staff will provide the results of its review efforts, including relevant inspection findings, tothe ACRS for review. After the ACRS completes its review, it will make an independentrecommendation regarding whether the proposed power uprate amendment should be approved.

The NRC will not approve the Vermont Yankee uprate, or any proposed change to a plantlicense, unless the NRC staff can conclude that the proposed change will be executed in a mannerthat assures the public's health and safety. In response to your request, the NRC staff has taken aclose look at proposed inspections and technical reviews to ensure that they will identify andaddress potential safety concerns for operating at uprated power conditions. The staff hasconcluded that the detailed technical review, prescribed in the Extended Power Uprate ReviewStandard, coupled with the normal associated program of power uprate and engineeringinspections, will provide the information necessary for the NRC staff to make a decision on thesafety of operation of Vermont Yankee under uprated power conditions. The Commissionbelieves that the results of NRC reviews and inspections, particularly the new engineering

I Donald Florek - Part.000 Page41I Donald Florek - Part.000 �age��

inspection, will assist in addressing the Board's concerns regarding the future reliability ofVermont Yankee. The NRC staff is prepared to meet with the Board to explain further our reviewprocess and scope, including the engineering assessment inspection.

Sincerely,

IRA/

Nils J. Diaz

Enclosure:Established NRC Power Uprate Review Process

Established NRC Power Uprate Review Process

The NRC's established review process for power uprate applications is independent, thorough,and comprehensive. A team of engineers with specialties in a minimum of 17 different technicalareas will review the Vermont Yankee power uprate application. The NRC plans to expend about4000 hours to perform a comprehensive assessment of the engineering, design, and safetyanalyses related to the uprate. The NRC's "Review Standard for Extended Power Uprates"guides the staff in its review of the application. The Review Standard also provides guidance fordetermining when and what type of audits should be performed at the plant or vendor sites, aswell as for performing our own confirmatory analyses and independent calculations tosupplement the review.

The NRC's review of the power uprate application also includes on-site inspections. NRCinspections will review selected activities and modifications made to allow operation at higherpower levels to verify that changes to plant systems will support safe plant operation and are inaccordance with Vermont Yankee's licensing and design bases. The NRC will use InspectionProcedure 71004, "Power Uprates," as well as a number of our baseline inspection procedures toinspect issues specifically related to power uprate. These inspections will assess changes thatcould impact the integrity of barriers (e.g., higher flow rates which could increase vibration atspecific support points), safety evaluations, plant modifications, post maintenance andsurveillance testing, heat exchanger performance, and integrated plant operation. Additionally,our other baseline inspection activities, while not specifically directed at power uprate activities,will provide additional information about Vermont Yankee's ability to operate safely at a higherpower level.

The NRC will adjust, as necessary, our technical review, audit plans, confirmatory analyses, orinspection activities if any issues are identified which may have a bearing on our decision on theVermont Yankee power uprate application. For example, a recent examination of the steam dryerat Vermont Yankee identified cracks on both interior and exterior structures of the steam dryer.The steam dryer is an important component in the process for converting steam to electricalenergy, but is not used to mitigate any accidents. The NRC is interested in steam dryer cracking

I Donald .Florek - Part.OUU Page 5Donal.F~oek -PartAUO

Pge--

because of the potential for parts to break loose and impact the performance of safety-relatedequipment. Entergy has indicated that the cracks are in low-stress, low-steam flow areas of thedryer and not in the areas where cracks were observed at other plants that implemented extendedpower uprates. NRC inspectors monitored Entergy's steam dryer inspection activities, and wewill thoroughly review Entergy's follow-up actions as part of our evaluation of VermontYankee's request to operate at a higher power level.

Assessment of engineering has always been an integral part of the NRC's safety mission. In the1990s, the NRC performed extensive reviews at plants across the country to determine iflicensees were operating plants in accordance with their design bases. As part of this review, twoteam inspections were conducted at Vermont Yankee in 1997. One of these inspections was ledby staff from NRC headquarters and included six contractors. In 1998, the NRC conducted anengineering inspection, as well as a team inspection to address operability issues resulting fromVermont Yankee's configuration improvement program. Under our current Reactor OversightProcess, NRC resident inspectors and regional specialists routinely evaluate the work performedby the licensee's engineering organization to determine whether the engineering analysesadequately supports safe operation. Our inspectors conduct both routine engineering inspections,as well as an in-depth team inspection every two years. Since the Reactor Oversight Process wasimplemented in 2000, the NRC has conducted two such safety system design team inspections.

Enclosure

Raymond ShadisStaff Technical AdvisorNew England CoalitionPost Office Box 98Edgecomb, Maine 04556207-882-7801

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I Donald.Florek - Mime.822 Page I iI Dnd.Fre =_ Mm.82 Pae

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<font color-"#000080"><b>Here it is. One giant step for NRC; One smallstep for Vermont-Kind.&nbsp; We must have citizen oversight other thanthe nuclear vision-impaired Sherman. This must be an open process, andNRC must be prepared to open it to a full-scale diagnostic evaluation(ISA) upon finding any serious negative indications.&nbsp; In any case,Thank you to all those who supported the call for an Independent SafetyAssessment. Your view, that an Independent Safety Assessment Is theright, prudent, conservative thing to do prior to goosing power on anantique reactor, has been to some degree validated by NRC.&nbsp; I thankyou; the earth thanks you.<br>

II Donald-Florek - Mime.822 Page 21lI Dn___.ork _ ___ Page 2 _________I

Ray<br><Ib></font>&nbsp;<br>No. 04-055<br>&nbsp;<br><br><div align="center1><b>NRC PROVIDES UPDATE ON REVIEW PROCESS<br>FOR VERMONT YANKEE UPRATE REQUEST<br><br><Ib><Idiv>&nbsp;<br><br>The Nuclear Regulatory Commission today announced it will utilize a newengineering assessment Inspection as part of its review of EntergyNuclear's request to Increase the power output of the Vermont Yankeenuclear power plant by 20 percent. <br><br'The NRC's intentions are discussed in the agency's reply to the VermontPublic Service Board's (PSB) request for assurances about VermontYankee's reliability following an uprate. Although the NRC's regulatoryauthority does not cover reliability specifically, the agency overseesmany safety-related systems and functions that contribute to a plant'sreliable operation.<br><br>'The agency remains committed to ensuring continued safe operation ofVermont Yankee. I have given the Govemor my assurances on this,' NRCChairman Nils Diaz said.<br><br>In addition to its substantial uprate review process, the NRC has decidedto also conduct a new engineering design Inspection, which has been underdevelopment for several months to enhance the Reactor Oversight Process.The Inspection will provide additional Information for the NRC and beresponsive to the PSB's concems. 'The NRC staff considered a number offactors, Including the Board's request for an Independent engineeringassessment, and concluded it Is appropriate to conduct this engineeringinspection at Vermont Yankee.' Chairman Diaz said.<br><br'The NRC will use the new inspection to proactively Identify any latentIssues in a nuclear power plant's design, focusing on those componentsand systems devoted to safety. The design inspection will include anevaluation of changes to the plant's licensing basis to ensure safetymargins remain adequate. At Vermont Yankee, the inspection process willinvolve three weeks of on-site inspections and more than 700 hours ofdirect inspection time.<br><br>The NRC's inspection team of approximately six will include experiencedNRC Inspectors, some of whom have not had recent oversight Involvementwith Vermont Yankee, and at least two contractors with experience Inreactor design. The agency will share the inspection schedule withVermont officials to facilitate state representative participation, asallowed by NRC regulation and policy.<br><br>The NRC will not approve the Vermont Yankee uprate, or any proposedchanges to a reactor's license, unless the agency can conclude thechanges can be implemented safely. The full text of the NRC's letter tothe PSB is provided.<br><br'&nbsp;<br><br>Mr..Michael H. Dworkin, Chairman<br>Vermont Public Service Board<br>112 State Street, Drawer 20<br,Montpelier, Vermont 05620-2701<br><br>Dear Mr. Dworkin:<br><br>I am responding on behalf of the U.S. Nuclear Regulatory Commission (NRC)to your letters dated March 15 and 31, 2004, regarding the request by

- - . . __ - --- ---I Donald -Florek - Minne.822 Page 3:1I Donald .FIorek - Mime.522 Page

Entergy Nuclear Vermont Yankee, LLC, and Entergy Nuclear Operations, Inc.(Entergy), to amend the Vermont Yankee Nuclear Power Station license toincrease the power level of the facility. In those letters, the VermontPublic Service Board requested that the NRC conduct its review of theproposed power uprate in a way that would provide Vermont a level ofassurance about plant reliability equivalent to an Independentengineering assessment. The NRC has decided to conduct a detailedengineering inspection that we believe will be appropriate for addressingour oversight responsibilities and Is also responsive to the Board'sconcerns. This Inspection will be performed as part of a new engineeringInspection program that the NRC has been developing to enhance theReactor Oversight Process. <br><br>NRC regulations and Its oversight process focus on ensuring nuclearsafety, whether the facility Is operating at power or shut down. TheNRC's statutory authority does not extend to regulating the reliabilityof electrical generation. The NRC recognizes, however, that there Is someoverlap between attributes that result In safe operation and those thatcontribute to overall plant reliability. <br><br>The Commission understands that the Board is concerned about thereliability of Vermont Yankee following an increase In power level,especially in light of operational Issues that have occurred at someother plants that have recently Implemented extended power uprates. TheNRC recognizes the Importance of these issues and is taking steps toensure that they are satisfactorily addressed to maintain safety. Forexample, in response to Instances of steam dryer cracking at some boilingwater reactors, outside technical experts are assisting NRC staff inperforming an audit of General Electric's analyses related to steam dryerperformance and specific Issues related to Vermont Yankee. We continue toengage the industry to ensure resolution of these Issues and willconsider additional regulatory action, if needed.<br><br'The NRC's established review process for power uprate applications isIndependent, thorough, and comprehensive. A description of the reviewprocess is enclosed. Engineering assessments have always been an integralpart of the NRC's safety activities. Under our current Reactor OversightProcess, NRC resident Inspectors and regional specialists routinelyevaluate the work performed by the licensee's engineering organization todetermine whether engineering analyses adequately support safe operation.Over the past several months, the NRC has been developing a newengineering inspection program which we intend to pilot at selectedplants. The NRC staff considered a number of factors, including theBoard's request for an Independent engineering assessment, and concludedit is appropriate to conduct this engineering Inspection at VermontYankee. This new engineering assessment Inspection Incorporates the bestpractices of the existing and past engineering Inspections. The NRC willuse this inspection to verify that design bases have been correctlyimplemented for a sampling of components across multiple systems and toIdentify latent design issues. The Inspection process uses operatingexperience, risk assessment, and engineering analysis to selectrisk-significant components and operator actions, and will ensure thatadequate safety margins exist. Although the specific sampling ofcomponents is still being developed, it will Include components frommultiple systems that are potentially affected by a power uprate such asthe emergency core cooling systems, the containment system, powerconversion systems, and auxiliary systems. The inspection will be

. - . E.-.- . - --- - - -M �- - . ____ - . 3

I Li-onala.1--loreK - Mirne.822 Page 41I UOfl�ld.HO��K - MIme.b� Page 41

performed by a team of approximately six I6spectors, Including some NRCinspectors who do not have recent oversight experience with VermontYankee and at least two contractors with design experience. Three weeksof on-site inspection and over 700 hours of direct Inspection time willbe conducted. This level of effort exceeds that of the biennial safetysystem design inspection. The Commission believes it is appropriate foraddressing the NRCs oversight responsibilities and Is also responsive tothe Board's concerns. The NRC staff will Inform the State of Vermont ofthe schedule for this inspection to facilitate participation by Staterepresentatives, consistent with NRC policy.<br><br>The NRC Advisory Committee on Reactor Safeguards (ACRS) will also reviewthe Vermont Yankee power uprate request. The ACRS is a statutorycommittee that reports directly to the Commission and is structured toprovide a forum where experts representing many technical perspectivescan provide advice that is factored Into the NRC's decision-makingprocess. The NRC staff will provide the results of Its review efforts,Including relevant inspection findings, to the ACRS for review. After theACRS completes its review, it will make an Independent recommendationregarding whether the proposed power uprate amendment should beapproved.<br><br>The NRC will not approve the Vermont Yankee uprate, or any proposedchange to a plant license, unless the NRC staff can conclude that theproposed change will be executed In a manner that assures the public'shealth and safety. In response to your request, the NRC staff has taken aclose look at proposed inspections and technical reviews to ensure thatthey will identify and address potential safety concerns for operating atuprated power conditions. The staff has concluded that the detailedtechnical review, prescribed In the Extended Power Uprate ReviewStandard, coupled with the normal associated program of power uprate andengineering inspections, will provide the Information necessary for theNRC staff to make a decision on the safety of operation of Vermont Yankeeunder uprated power conditions. The Commission believes that the resultsof NRC reviews and Inspections, particularly the new engineeringInspection, will assist in addressing the Board's concerns regarding thefuture reliability of Vermont Yankee. The NRC staff Is prepared to meetwith the Board to explain further our review process and scope, includingthe engineering assessment inspection.<br>&nbsp;<br><br>Sincerely,<br><br><b>/RAI<br><br'</b>Nils J. Diaz<br><br>Enclosure: <br'Established NRC Power Uprate Review Process<br><br><div align="center">Established NRC Power Uprate Review Process<br><br></div>The NRC's established review process for power uprate applications isindependent, thorough, and comprehensive. A team of engineers withspecialties in a minimum of 17 different technical areas will review theVermont Yankee power uprate application. The NRC plans to expend about4000 hours to perform a comprehensive assessment of the engineering,design, and safety analyses related to the uprate. The NRC's 'ReviewStandard for Extended Power Uprates' guides the staff In its review ofthe application. The Review Standard also provides guidance fordetermining when and what type of audits should be performed at the plant

I Donald.FloreK - Mime.622 Page-51Donald. Horek - MImeA322 Page �I

or vendor sites, as well as for performing our own confirmatory analysesand independent calculations to supplement the review. <br><br>The NRC's review of the power uprate application also includes on-siteinspections. NRC inspections will review selected activities andmodifications made to allow operation at higher power levels to verifythat changes to plant systems will support safe plant operation and areIn accordance with Vermont Yankee's licensing and design bases. The NRCwill use Inspection Procedure 71004, 'Power Uprates,' as well as a numberof our baseline inspection procedures to inspect Issues specificallyrelated to power uprate. These inspections will assess changes that couldimpact the integrity of barriers (e.g., higher flow rates which couldincrease vibration at specific support points), safety evaluations, plantmodifications, post maintenance and surveillance testing, heat exchangerperformance, and Integrated plant operation. Additionally, our otherbaseline Inspection activities, while not specifically directed at poweruprate activities, will provide additional Information about VermontYankee's ability to operate safely at a higher power level.<br><br'The NRC will adjust, as necessary, our technical review, audit plans,confirmatory analyses, or inspection activities If any issues areidentified which may have a bearing on our decision on the Vermont Yankeepower uprate application. For example, a recent examination of the steamdryer at Vermont Yankee identified cracks on both Interior and exteriorstructures of the steam dryer. The steam dryer Is an Important componentin the process for converting steam to electrical energy, but is not usedto mitigate any accidents. The NRC Is interested In steam dryer crackingbecause of the potential for parts to break loose and Impact theperformance of safety-related equipment. Entergy has Indicated that thecracks are In low-stress, low-steam flow areas of the dryer and not inthe areas where cracks were observed at other plants that Implementedextended power uprates. NRC Inspectors monitored Entergy's steam dryerinspection activities, and we will thoroughly review Entergy's follow-upactions as part of our evaluation of Vermont Yankee's request to operateat a higher power level.<br'<br>Assessment of engineering has always been an Integral part of the NRC'ssafety mission. In the 1990s, the NRC performed extensive reviews atplants across the country to determine If licensees were operating plantsIn accordance with their design bases. As part of this review, two teaminspections were conducted at Vermont Yankee In 1997. One of theseInspections was led by staff from NRC headquarters and included sixcontractors. In 1998, the NRC conducted an engineering Inspection, aswell as a team inspection to address operability Issues resulting fromVermont Yankee's configuration Improvement program. Under our currentReactor Oversight Process, NRC resident Inspectors and regionalspecialists routinely evaluate the work performed by the licensee'sengineering organization to determine whether the engineering analysesadequately supports safe operation. Our inspectors conduct both routineengineering inspections, as well as an In-depth team Inspection every twoyears. Since the Reactor Oversight Process was Implemented In 2000, theNRC has conducted two such safety system design team Inspections.<brP<br><div align="right">Enclosure<br><br><x-sigsep><p></x-sigsep></div>

I Donald.Florek - Mime.822 -Page -61I Doald.ore - Mme.22 Pge 1

Raymond Shadis<br>Staff Technical Advisor<br'New England Coalition<br'Post Office Box 98<br>Edgecomb, Maine 04556<br>207-882-7801

<br>

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<br><tt><hr width="500"><b>Yahool Groups Links</b><br><ul><li>To visit your group on the web, go to:<br><a href="http://groups.yahoo.comlgrouplnrc.concemsr>http:./groups.yahoo.comrgroup/nrc_concemsl/<a><br>&nbsp;<li>To unsubscribe from this group, send an email to:<br><a href="mailto:nrc concems-unsubscribe@yahoogroups.com?subject=Unsubscribe">nrc concems-unsubscribe@yahoogroups.com</a><br>&nbsp;<li>Your use of Yahoo! Groups is subject to the <a href="http://docs.yahoo.com/info/termsr>Yahoo! Terms of Service</a>.<lul><At></br>

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I Donald.Florek - Mime.822 Page 7 1

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