June 16, 2003

MEMORANDUM TO: William D. Travers

Executive Director for Operations

FROM: Brian W. Sheron, Associate Director /RA/

 for Project Licensing and Technical Analysis

Office of Nuclear Reactor Regulation

SUBJECT: MAY 2003 REPORT ON THE STATUS OF PUBLIC PETITIONS UNDER

TITLE 10 OF THE CODE OF FEDERAL REGULATIONS, SECTION

2.206

The attached reports give the status of petitions submitted under Title 10 of the Code of Federal

Regulations, Section 2.206. As of May 31, 2003, there were two open petitions, which were

accepted for review under the 2.206 process: one in the Office of Nuclear Reactor Regulation

and one in the Office of Nuclear Materials Safety and Safeguards. 

Attachment 1 provides a detailed status of the open petitions.

Attachment 2 provides the status of incoming letters that the staff has been reviewing to

determine if they meet the criteria for review under the 2.206 process. 

Attachment 3 shows the age statistics for the open 2.206 petitions as of May 31, 2003.

Attachment 4 shows the age trend of closed petitions for the last 3 years. 

This report, Director’s Decisions, and other 2.206-related documents are placed in the

Agencywide Documents Access and Management System. In making these readily accessible

to the public, the staff has identified another vehicle to address one of our performance goals,

i.e., to enhance public confidence.

Attachments: As stated

CONTACT: Robert Clark, NRR

415-2297
June 16, 2003

MEMORANDUM TO: William D. Travers

Executive Director for Operations

FROM: Brian W. Sheron, Associate Director /RA/

 for Project Licensing and Technical Analysis

Office of Nuclear Reactor Regulation

SUBJECT: MAY 2003 REPORT ON THE STATUS OF PUBLIC PETITIONS UNDER

TITLE 10 OF THE CODE OF FEDERAL REGULATIONS, SECTION

2.206

The attached reports give the status of petitions submitted under Title 10 of the Code of Federal

Regulations, Section 2.206. As of May 31, 2003, there were two open petitions, which were

accepted for review under the 2.206 process: one in the Office of Nuclear Reactor Regulation

and one in the Office of Nuclear Materials Safety and Safeguards. 

Attachment 1 provides a detailed status of the open petitions.

Attachment 2 provides the status of incoming letters that the staff has been reviewing to

determine if they meet the criteria for review under the 2.206 process. 

Attachment 3 shows the age statistics for the open 2.206 petitions as of May 31, 2003.

Attachment 4 shows the age trend of closed petitions for the last 3 years. 

This report, Director’s Decisions, and other 2.206-related documents are placed in the

Agencywide Documents Access and Management System. In making these readily accessible

to the public, the staff has identified another vehicle to address one of our performance goals,

i.e., to enhance public confidence.

Attachments: As stated

CONTACT: Robert Clark, NRR

415-2297

DISTRIBUTION: See next page

Accession No.: ML031570163

OFFICE PM:PDI-1 LA:PDI-1 D:PDII D:DLPM NMSS ADPT:NRR

NAME RClark SLittle HBerkow JZwolinski PGoldberg BSheron

DATE 6/5/03 6/9/03 6/9/03

OFFICIAL RECORD COPY
DISTRIBUTION FOR APRIL 2003 REPORT ON THE STATUS OF PUBLIC PETITIONS

UNDER TITLE 10 OF THE CODE OF FEDERAL REGULATIONS, SECTION 2.206

Dated: June 16, 2003

PUBLIC

WKane, DEDR/OEDO

CPaperillo, DEDMRS/EDP

PNorry, DEDM/OEDO

JCraig, AO/OEDO

JShea, ODEO

PAnderson, OEDO

EJulian

SCollins, NRR

RLaufer

CHolden

RBorchardt, NRR

BSheron, NRR

CMohrwinkel, NRR

KCyr, OGC

LChandler, OGC

JGoldberg, OGC

JCordes, Jr., OCAA

FCongel, OE

PLohaus, STP

MVirgilio, NMSS

PGoldberg, NMSS

FBrown, NMSS

BBoger, NRR

MStein, OE

GCaputo, OI

JZwolinski, NRR

LMarsh, NRR

HBerkow, NRR

RClark, NRR

OCA

OPA

Regional Administrators

PDI-1 Reading 

SLittle

DWidmayer
Attachment 1

Status of Open Petitions

Page

Facility Petitioner/EDO No. No.

Waltz Mill Pennsylvania Site Viacom, Inc.

G20020629.................................................... 1

Davis-Besse Nuclear Power Station Congressman Dennis Kucinich

G20030048.................................................... 3
Attachment 1

Report on Status of Public Petitions Under 10 CFR 2.206

Facility: Waltz Mill Pennsylvania Site 

Petitioner: Viacom, Inc.

Date of Letter: October 30, 2002 

Director’s Decision to be Issued by: NMSS

EDO Number: G20020629

Proposed DD Issuance: 06/20/03

Final DD Issuance TBD

Last Contact with Petitioner: 05/01/03

Petition Manager: Patrick Isaac (NRR) / Derek Widmayer (NMSS)

Case Attorney: Jack Goldberg

Issues/Actions requested:

That the NRC issue an order to Westinghouse Electric Company LLC, the holder of

license SNM-770 on the Waltz Mill, Pennsylvania Site, which would require

Westinghouse’s cooperation in the decommissioning of the Westinghouse Test Reactor

(WTR) license TR-2. In particular, the order would require Westinghouse to:

(1) provide certain radiological survey data to NRC which NRC has requested. The

survey data in question determines what residual radioactivity remains in-situ. 

(2) accept under SNM-770 certain residual byproduct materials now held under Viacom

license TR-2 and located at the WTR.

Background:

Viacom is the current holder of NRC facility license TR-2 which authorizes possession,

but not operation, of the WTR. To complete the Final Decommissioning Plan, two

provisions still need to be accomplished. These are determining the residual

radioactivity remaining in-situ and preparing the necessary amendments for and

requesting the transfer of the remaining residual radioactivity and WTR facilities to the

SNM-770 license.

At the time the decommissioning plan was approved, Westinghouse was the NRC

licensee under both TR-2 and SNM-770, and so the transfer of the residual radioactive

material from one materials license to another, held by the same licensee on the same

site, was straightforward. Viacom now holds the TR-2 license while Westinghouse

holds the SNM-770 license. Westinghouse’s and Viacom’s decommissioning

responsibilities to each other at the Waltz Mill Site are set forth in an Asset Purchase

Agreement. By refusing to accept the transfer to the SNM-770 license, Viacom alleges

that Westinghouse is in violation of 10 CFR 50.5. 

Westinghouse submitted a response to the petition on December 20, 2002. Viacom has

indicated that they will not respond to the Westinghouse response at this time.
-2-

On February 20, 2003, a public PRB meeting was held in Rockville, Maryland with the

petitioner and both licensees (Viacom and Westinghouse Electric Company). During

the meeting, lawyers and staff personnel from both companies provided additional

information to support their position. 

At the March 6, 2003, closed PRB meeting, the staff agreed to accept the petition for

review under 2.206.

There are several reasons why it took the staff 4 months to determine whether this

petition met the criteria for review under 2.206. First, the petition involves complex legal

and contractual issues. Second, the staff had to await both parties’ responses to the

petition, which took the parties several months, and then had to review and evaluate the

responses prior to engaging in the public PRB meeting. The petitioners were not

available to meet with the PRB until February 20, 2003. Following the public PRB

meeting, there was still some uncertainty among the cognizant staff groups and

management regarding acceptance of these issues as a petition. Finally, at the

March 6, 2003, closed PRB meeting, agreement was reached to accept the petition for

review under 2.206.

On March 13, 2003, a letter was sent to the petitioner and both licensees (Viacom and

Westinghouse Electric Company) informing them that the petition met the acceptance

criteria for review under 2.206 and would be reviewed in accordance with Management

Directive 8.11. A Federal Register notice was published on March 27, 2003.

Westinghouse sent a letter to the NRC on March 26, 2003, indicating their intent to file a

supplement to their December 20, 2002, response to the Viacom petition. 

Westinghouse stated in the letter that the supplement would be provided by May 5,

2003. Viacom sent a letter to the NRC on March 28, 2003, objecting to NRC

consideration of this Westinghouse supplement. 

Current Status:

On May 20, 2003, the staff received Westinghouse’s supplement to their

December 20, 2003, response to the Viacom Petition. This supplement informed the

NRC that the radiological survey data referred to in the first of the requested actions in

the Viacom Petition would be made available to Viacom on May 27, 2003. Although

Viacom’s letter dated May 23, 2003, complained that Westinghouse was not

forthcoming with this data, the NRC staff determined that the availability of this data was

immaterial to the decisions being made pursuant to the 2.206 process. A proposed

Director’s Decision is in concurrence and is scheduled to be issued by June 20, 2003.
-3-

Facility: Davis-Besse Nuclear Power Station

Petitioner: Congressman Dennis Kucinich

Date of Letter: February 3, 2003 

Director’s Decision to be Issued by: NRR

EDO Number: G20030048

Proposed DD Issuance: 6/06/03

Final DD Issuance TBD

Last Contact with Petitioner: 4/07/03

Petition Manager: Dan Collins (NRR)

Case Attorney: Jack Goldberg

Issues/Actions requested:

That the Nuclear Regulatory Commission (NRC) immediately revoke FirstEnergy

Nuclear Operating Company’s (FirstEnergy) license to operate the Davis-Besse Nuclear

Power Station (DBNPS) for the reasons given in the background. 

Background:

On March 5, 2002 during a refueling outage, FirstEnergy performed inspection of the

DBNPS reactor pressure vessel head penetration (VHP) nozzles in accordance with

NRC Bulletin 2001-01. During this inspection, the licensee discovered cracks in several

VHP nozzles. Subsequent to the machining process to repair VHP Nozzle 3, the nozzle

was observed to displace, or tip in the downhill direction as the machining apparatus

was withdrawn. The displacement led DBNPS personnel to examine the region

adjacent to VHP Nozzle 3. The licensee discovered a cavity with a surface area of

approximately 20-30 square inches. Upon further examination, the licensee identified

that the cavity extended completely through the 6.63 inch-thick carbon steel reactor

pressure vessel (RPV) head down to a thin internal liner of stainless steel cladding. 

Although the exposed cladding withstood the primary system pressure during previous

plant operation, it was not designed to be a reactor coolant system pressure boundary. 

Boric acid corrosion of the carbon steel RPV head was the primary contributor to the

RPV head degradation.

In response to the licensee's identification of extensive damage to the pressure

boundary material of the RPV head on March 5, 2002, the NRC dispatched an

Augmented Inspection Team (AIT) to Davis-Besse on March 12, 2002, to examine

conditions that led to the head degradation. The NRC also issued a Confirmatory

Action Letter (CAL) to the licensee on March 13, 2002, which stated that NRC approval

is required for restart DBNPS. The CAL also documented a number of actions that the

licensee must implement before the NRC will approve a restart. The NRC also

enhanced monitoring of corrective actions at Davis-Besse, as described in NRC

Inspection Manual Chapter 0350, “Oversight of Operating Reactor Facilities in a

Shutdown Condition with Performance Problems,” to provide the required oversight

throughout the plant's shutdown and restart. The AIT follow-up special inspection report

(50-346/02-08) dated October 2, 2002, cited a number of violations of the Davis-Besse

operating license and NRC regulations.
-4-

Using information from various publicly available documents (such as NRC inspection

reports, newspaper articles, and reports published by the Union of Concerned

Scientists) to support his case, the Petitioner offers the following five basic arguments,

in various forms, on why the Davis-Besse operating license must be revoked:

1. NRC regulations and guidelines require revocation of the Davis-Besse license.

2. Revocation of the Davis-Besse license is necessary to hold FirstEnergy

accountable for its violations of NRC regulations and its own operating license.

3. If the NRC doesn’t revoke the Davis-Besse license, NRC isn’t appropriately

using the authority granted it by Congress.

4. Revocation of the Davis-Besse license is necessary in order to ensure that

FirstEnergy is complying with all NRC regulations and guidelines.

5. Revocation of the Davis-Besse license is required in order for there to be

consistency in the manner that the NRC enforces its regulations.

The staff issued an acknowledgment letter on February 10, 2003, to inform the

Congressman that the PRB has determined that the petition meets the acceptance

criteria for review under 2.206. The acknowledgment letter also informed the Petitioner

that, pending completion of the NRC’s investigative process, the NRC does not have

sufficient basis to immediately revoke the Davis-Besse operating license. Thus, the

Petitioner’s request for immediate revocation of the license was denied. 

The staff called the Petitioner’s staff on February 14, 2003, to explain the 2.206 process

and to offer an opportunity to address the PRB. The Congressman's staff indicated that

they do wish to address the PRB but need more time to prepare for the presentation. 

The petitioner informed the staff on March 12, 2003, that a supplement would be issued

in lieu of a presentation to the PRB.

The petitioner submitted a supplement to the original petition on March 27, 2003, to

address the following additional concerns:

a. boric acid dust may have corroded electrical systems & cable trays

b. as-built design may not conform to design or licensing bases

c. training of personnel may not meet licensing basis

d. DBNPS does not have ability to detect I gpm leakage within 1 hour

e. procedures instituted by NRC may not uncover or address other systems

that may be degraded i,e., RCP seal gasket leakage 

f. The O350 Panel will end and the plant will return to normal monitoring

under the ROP before Lessons Learned Task Force recommendations

regarding the ROP are implemented

g. The OI investigation must be completed before NRC allows DBNPS to

restart
-5-

A closed PRB meeting was held on April 2, 2003, to discuss the additional information

provided by the petitioner’s March 27, 2003, supplement to the original petition. The

staff decided that no immediate action was warranted, that the supplement should be

consolidated with the existing petition, that no new allegations were presented by the

petitioner, and that an acknowledgment letter was not necessary. 

Laura Gerke of the Office of Congressional Affairs contacted the petitioner’s staff and

explained that we have received the supplement to the petition, understand the

arguments being made and determined that a clarifying conference call is unnecessary. 

She also indicated that the proposed DD is scheduled to be issued within 120 days from

the date of the original acknowledgment letter which was issued on February 10, 2003.

On April 11, 2003, the staff received the licensee’s response to the petitioner’s

supplement dated March 27, 2003. The information provided supported the staff’s early

conclusion that the supplement should be consolidated with the existing petition, and

that no new allegations were presented by the petitioner.

Current Status:

The proposed DD was issued on June 6, 2003. The petitioner has 30 days to respond

prior to the development of a final director’s decision.
Attachment 2

Status of Potential Petitions Under Consideration

Facility: Maine Yankee

Petitioner: Randall Speck, Special Counsel for the State of Maine

Date of Letter: November 15, 2002

Responsible Office: NMSS

PRB meeting: To be scheduled 

Issues/Actions requested:

That the NRC conduct a hearing on the efficacy of indefinite, long-term spent fuel

storage at Maine Yankee.

Resolution:

The petitioner has also requested a hearing, pursuant to 10 CFR 2.202, regarding the

October 16, 2002, safeguards order and interim compensatory measures. On

December 10, 2002, the staff sent a letter to the petitioner stating that a decision on the

acceptability of the 2.206 petition will be held in abeyance until the staff makes a

determination on the hearing request. 

Facility: Indian Point Units 2 and 3

Petitioner: Richard Blumenthal, Attorney General of the State of Connecticut

Date of Letter: April 24, 2003

Responsible Office: NRR

PRB meeting: May 8, 2003 

Issues/Actions requested:

That the NRC take the following immediate actions:

1. Order the IP-2 licensee to conduct a full review of the facility’s vulnerabilities,

security measures and evacuation plans and to suspend operations, revoke the

operating license, or adopt other measures resulting in a temporary shutdown of

Units 2 and 3 per 10 CFR 2.202.

2. Require the licensee to provide information, as contemplated by 10 CFR

2.204(a), documenting the existing security measures which provide the Indian

Point facilities with protection against terrorist attacks.

3. Immediately modify the licensee’s operating license for Units 2 and 3 to

mandate, at a minimum, a defense and security system sufficient to protect the

entire facility, including the containment and spent fuel storage buildings, control

room and electric equipment, from land or water based terrorist attack as

required by 10 CFR 73.55.
-2-

4. Order the revision of licensee’s Emergency Response Plan and the Radiological

Emergency Response Plans of the State of New York and the nearby counties,

in order to account and prepare for possible terrorist attacks. These revisions

must encompass not only realistic and catastrophic effects of a terrorist attack

on the Indian Point facilities, but also a comprehensive response to multiple

attacks in the region which may impair the efficient evacuation of the area. 

Examples of such attacks include destruction of the regional road and bridge

system, loss of power to passenger railroads, and other events that deny use of

necessary infrastructure.

5. If, after conducting a full review of the facility’s vulnerabilities, security measures

and evacuation plans, the NRC cannot sufficiently ensure the security of the

Indian Point facilities against terrorist threats, or cannot ensure the safety of New

York and Connecticut citizens in the event of an accident or terrorist attack, the

Commission should take prompt action to permanently retire the facility.

Resolution:

A closed PRB meeting was held on May 8, 2003, to discuss whether the petition

satisfies the criteria for review under 10 CFR 2.206. The petition manager made a

presentation to the PRB which included the following topics; summary of request for

immediate actions, bases for requested actions, immediate action determination, and

the need for support from various NRC offices. 

The PRB decided that no urgent action was necessary and that the petition manager

should contact the petitioner and offer the petitioner an opportunity to give a

presentation to the PRB either by telephone or in person. The PRB also recommended

that security issues regarding potential terrorist attacks be handled separately from the

issues associated with the emergency response plan by addressing the security issues

in a partial Director’s Decision.

On May 30, 2003, the petitioner requested that he be given the opportunity to address

the PRB prior to its determination as to whether or not the petition meets the criteria for

review under 10 CFR 2.206. The petitioner stated that he would be providing a

supplement to the petition during the week of June 2, 2003. Upon receipt of the

supplement and initial review by the staff, the meeting date for the presentation will be

finalized with the petitioner. The meeting is expected to take place in mid-June.
-3-

Facility: Indian Point, Units 2&3

Petitioner: Madelyn Wils, Manhattan Community Board 1

Date of Letter: April 28, 2003

Responsible Office: NRR

PRB meeting: N/A 

Issues/Actions requested by the resolution:

1. That consideration be given to closing the Indian Point Nuclear Power Plant and

arranging for alternate, clean sources of energy for the region.

2. That the NRC not renew the Indian Point Nuclear Power Plant operating

licenses.

Status:

While this letter and accompanying resolution is dated April 28, 2003, NRR did not

receive it until May 12, 2003. A closed PRB meeting will be scheduled to discuss this

letter.

Facility: Indian Point, Units 2&3

Petitioner: Robert LoPinto, Queens Community Board 7

Date of Letter: May 1, 2003

Responsible Office: NRR

PRB meeting: N/A 

Issues/Actions requested by the resolution:

1. That the NRC convene an independent panel to review whether the facility

should be temporarily closed based on the facility’s vulnerabilities, security

measures and evacuation plans, and make recommendations on how best to

minimize the facility’s risk to surrounding communities.

2. Mandate, at minimum, immediate deployment of the following security measures:

a. Obtainment of a permanent no-fly zone - for both private and commercial

aircraft - from the Federal Aviation Administration in the air space within

10-nautical miles of the Indian Point facility;

b. A defense and security system sufficient to protect and defend the no-fly

zone;

c. A defense and security system sufficient to protect the entire facility,

including the containment and spent fuel storage buildings, control room

and electrical equipment and transmission lines, from a land or water

based terrorist attack.
-4-

3. Order the immediate review and comprehensive revision of licensee’s

Emergency Response Plan and Westchester County’s Radiological Emergency

Response Plan in order to account and prepare for possible terrorist attacks.

Status:

While this letter and accompanying resolution is dated May 1, 2003, NRR did not

receive it until May 12, 2003. A closed PRB Meeting will be scheduled to discuss this

letter.

Facility: St. Lucie Units 1 & 2

Petitioner: Thomas Saporito, National Environmental Protection Center

Date of Letter: May 6, 2003

Responsible Office: NRR

PRB meeting: May 19, 2002

Issues/Actions requested:

That the Nuclear Regulatory Commission (NRC):

1. Issue a Confirmatory Order requiring the immediate shutdown of both units.

2. Deny the licensee’s April 18, 2002, request for relief from NRC Order (EA-03-

009) requiring specific inspections of the reactor pressure vessel head and

associated penetration nozzles on the licensee’s reactor vessels.

3. Hold public hearings before the agency’s Atomic Safety and Licensing Board

Panel (ASLBP) to allow for the public’s participation in ascertaining the safety

implications which should be considered and explored concerning continued

operations at the licensee’s facility with respect to NRC Order (EA-03-009) and

any effects that relaxing the inspection requirements of the agency’s Order may

have on the overall environmental and public safety.

Resolution:

A closed PRB meeting was held on May 19, 2003, to discuss whether the petition

satisfies the criteria for review under 10 CFR 2.206. 

After careful deliberation, the PRB decided that no immediate action was necessary,

that the petition provided no bases for enforcement action, and that no new safety

issues were raised. The PRB also determined that a public hearing before the ASLBP

under the 2.206 process was not the proper forum to ascertain the safety implications of

the relief request filed by the licensee. According to the Atomic Energy Act of 1954, the

public does not have the right to intervene in licensing activities associated with relief or

exemption requests. The public, however, under 10 CFR 2.202, does have the right to

request a hearing with regards to the issuance of NRC Order (EA-03-009), but the

deadline for requesting a hearing on this Order has expired.
-5-

For these reasons, the PRB decided that the petition did not meet the criteria for review

under the 2.206 process. The petition manager will notify the petitioner that the request

will not be reviewed under the 2.206 process. The petitioner’s concerns will be

addressed as controlled correspondence. No further action is required.

Facility: Quad Cities Nuclear Power Station, Unit 2

Petitioner: Mike Mulligan

Date of Letter: March 30, 2003

Responsible Office: NRR

PRB meeting: May 28, 2003 

Issues/Actions requested:

That the Nuclear Regulatory Commission (NRC):

1. Order the plant to annunciate in the main control room all primary containment

and Low Pressure Core Injection (LPCI) seal-in relays that can prevent the

operation of safety-related equipment without the immediate observation by the

operating staff. The plant modifications are to be completed within 6 months.

2. Investigate other Quad Cities safety systems that may have the same potential

concern, including the generic implications for the industry.

3. Investigate Region III to determine if the Region has adequate resources to

properly assess safety issues and why this issue was not discovered by Region

III.

4. Re-evaluate the effectiveness of the Reactor Oversight Process.

Resolution:

Closed PRB meetings were held on May 28, and June 2, 2003, to discuss whether the

petition satisfies the criteria for review under 10 CFR 2.206. The PRB decided that no

immediate action was necessary. However, at the May 28 meeting, the PRB decided

that additional information was needed to determine if the petition raised an issue that

had not been previously considered by the staff, either at Quad Cities or another plant. 

During the May 28 meeting, it was determined that the petition manager would contact

Region III with EEIB support to gather more information regarding the details of the

Licensee Event Report 0300100 and the regulatory requirements for periodic testing of

electric power and protection systems. In particular, the staff needed to determine if the

current licensing bases for Quad Cities required continuous indication of “bypassed” or

“deliberately rendered inoperative” safety systems in the main control room. During this

meeting, the PRB also decided that action items “3” and “4” identified above will be

referred to the OIG for disposition.

During the June 2, 2003, meeting with Region III personnel present, the PRB

determined that the petition provided no new information. The staff has previously
-6-

reviewed the issue of control room indication of “bypassed” or “deliberately rendered

inoperative” safety systems on a generic basis and specifically for Quad Cities in

accordance with the requirements of IEEE 279 -1968. The current configuration of the

control room annunciators for Quad Cities was also approved by the Detailed Control

Room Design Review Final Summary Report dated May 1, 1985.

Since the petitioner did not raise any new issues, the PRB has determined that this

petition did not meet the criteria for review under 10 CFR 2.206. The petition manager

will notify the petitioner that the request will not be reviewed under the 2.206 process. 

The petitioner’s concerns will be addressed as routine correspondence. No further

action is required.
Attachment 3

AGE STATISTICS FOR AGENCY 2.206 PETITIONS

ASSIGNED

ACTION

OFFICE

FACILITY Incoming 

petition

PRBmeeting1

Acknowledgment 

letter / 

days from

incoming2

Proposed DDissuanceDate/ age3

Scheduled

date for

final DD/

age 4

Comments if no

Com

NMSS Waltz Mill Site 10/30/02 02/20/03 02/28/03

118

06/20/03

112

TBD See Viacom petitio

explanation.

NRR Davis-Besse 02/03/03 N/A 02/10/03

7

06/06/03

116

08/10/03

1) Goal is to hold a PRB meeting, which the petitioner is invited to participate in, within 2 weeks of receipt o

often a delay of up two weeks from the date that the letter is issued until it is received by the reviewing o

2) Goal is to issue acknowledgment letter within 5 weeks of the date of incoming petition.3) Goal is to issue proposed DD within 120 days of the acknowledgment letter.4) Goal is to issue final DD within 45 days of the end of the comment period.
Attachment 4