MEMORANDUM TO: William D. Travers

Executive Director for Operations

THRU: Samuel J. Collins, Director

Office of Nuclear Reactor Regulation

FROM: Brian W. Sheron, Associate Director

 for Project Licensing and Technical Analysis

Office of Nuclear Reactor Regulation

SUBJECT: FEBRUARY 2000 REPORT ON THE STATUS OF PUBLIC PETITIONS

UNDER 10 CFR 2.206

The attached monthly report gives the status of 10 CFR 2.206 petitions as of February 29,

2000. During the month, Director’s Decision (DD-00-01) on Connecticut Yankee and Millstone

Units 1, 2, and 3 (GT96919) was issued and the petition was closed. Two new petitions, one

on Indian Point Unit 3 (G20000062), and one on Edwin Hatch Nuclear Plant Units 1 and 2

(G2000098 and G2000056) were received for processing. Thus, there are four open petitions: 

three in the Office of Nuclear Reactor Regulation (NRR) and one in the Office of Nuclear

Material Safety and Safeguards (NMSS).

Attachment 1 provides the status of petitions for NRR and NMSS. Attachment 2 gives the

status of petitions that are in a confidential status and is for internal distribution only. 

Attachment 3 shows the age and staff hours expended on open 2.206 petitions as of February

29, 2000, including a summary of the status of 2.206 petitions exceeding the 120-day

scheduled completion goal. Attachment 4 shows the statistics for the 2.206 petitions processed

in the past 12 months.

Those parts of the monthly report not of a sensitive nature, and recently issued Director’s

Decisions, are placed in the Public Document Room and on the NRC’s external home page,

making them readily accessible to the public. The URL address is

http://www.nrc.gov/NRC/PUBLIC/2206/index.html.

Attachments: As stated

CONTACT: Ram Subbaratnam, NRR

 415-1478
Report on Status of Public Petitions Under 10 CFR 2.206

February 29, 2000

(Table of Contents)

Attachment 1

Page

Facility Petitioner/EDO No. No.

Atlas Corporation Dagget, et al./(G19990011)..................................2

Connecticut Yankee and Millstone 1, 2, and 3 Katz, Citizens Awareness Network

(CAN)/GT96919....................................................4

Indian Point Unit 2 D. Lochbaum/UCS/G1990465..............................6

Indian Point Unit 3* D. Lochbaum/UCS/G20000062............................8

Edwin Hatch Nuclear Plant Units 1 and 2* R. Kilpatrick/Campaign for Prosperous Georgia

/G20000098, G20000056.....................................9

* Denotes new addition to the list
2

Attachment 1

Report on Status of Public Petitions Under 10 CFR 2.206

Facility: Moab site of Atlas Corporation (Present

Licensee PricewaterhouseCoopers LLP,

Trustee)

Petitioner: Earth Justice Legal Defense Fund

Date of Petition: 1/11/99

Director's Decision To Be Issued by: NMSS

Date Referred to Review Organization: 1/12/99

EDO Number: G19990011

OGC Number: P-99-02

Scheduled Completion Date: TBD*

Last Contact with Petitioner: 1/6/2000

Petition Manager: Myron Fliegel

Case Attorney: J. Goldberg

Issues/Action Requested:

The petitioners request NRC to take six immediate actions to halt impacts to and to ensure the

conservation of the endangered species of fish in the Colorado River near the Atlas site.

Background:

On August 2, 1988, Atlas submitted an application for a license amendment to revise its site

reclamation plan for uranium mill tailings at its no longer operating site near Moab, Utah. On

March 30, 1994, a notice of intent to prepare an Environmental Impact Statement was

published in the Federal Register. In January 1996, the Draft Environmental Impact Statement

was published for public comment. On July 29, 1998, the U.S. Fish and Wildlife Service, in

accordance with Section 7 of the Endangered Species Act (ESA), issued a final biological

opinion for impacts to federally listed endangered species from the reclamation of the Atlas mill

tailings site. On October 12, 1998, and November 13, 1998, petitioners notified NRC of their

intent to sue under the ESA. On December 16, 1998, petitioners filed a Motion for Preliminary

Injunction against NRC in the U.S. District Court, District of Utah.

A petition was filed on January 11, 1999, requesting the NRC to take six immediate actions

related to potential impact on endangered fish in the Colorado River due to contaminants from

the Atlas Uranium mill tailings pile. A Petition Review Board (PRB) meeting was held on

January 26, 1999, and the petitioners’ requests for immediate action were denied by a letter of

that date. In the letter, it was noted that none of the six items identified in the petition

addresses a health, safety, or environmental concern that requires emergency steps before a

complete review as provided for in 10 CFR 2.206. An acknowledgment letter for this petition

was published in the Federal Register on February 12, 1999. On May 13, 1999, the staff

received a supplement to the 2.206 petition requesting immediate action on several items: (1)

to suspend the issuance of the license amendment to permit reclamation; (2) to initiate a

supplemental National Environmental Policy Act process; and (3) to reinitiate consultation with

Fish and Wildlife Services under the Endangered Species Act. 

Earthjustice had, on January 27, 1999, petitioned the Atomic Safety and Licensing Board

(ASLB) to intervene on the Atlas Corporation’s proposal to reclaim the Moab mill tailings and on

the cleanup of contaminated groundwater, citing the impacts to the endangered fish in the
3

Colorado River and its belief that the biological opinion was erroneous. On May 27, 1999, the

NRC wrote to the petitioners, acknowledging receipt of the supplement, denying immediate

action, and notifying the petitioners that NRC was deferring action on the 2.206 petition,

pending a decision by the ASLB on the petitioners’ request for a hearing on similar issues. 

On September 17, 1999, the staff filed responses to the ASLB presiding officers’ questions of 

July 30, 1999. On September 29, 1999, the staff provided the ASLB with a copy of its 

September 29, 1999, letter to Dames & Moore, notifying that organization that it had been

selected to become the Trustee for the Atlas Moab site, since the Atlas Corporation is in

bankruptcy. Copies of both filings were sent to the petitioners. Dames & Moore subsequently

withdrew as trustee and PricewaterhouseCoopers LLP was chosen to be the trustee.

On October 18, 1999, Earthjustice filed a petition with the U.S. Court of Appeals for the 9th

Circuit, arguing that the May 27, 1999, letter and a May 28, 1999, license amendment constitute

final agency action and a de facto denial of the 2.206 petition. On November 3, 1999, OGC

filed a motion to dismiss for lack of jurisdiction with the 9th Circuit Court of Appeals. A copy of

the motion was sent to the petitioners. On November 23, 1999, the petitioner filed a response

to the NRC motion to dismiss, arguing that the rejection of its request for immediate action and

subsequent lack of action on the part of the NRC in issuing a final Director’s Decision

constitutes a final agency action. NRC filed its reply with the court to the petitioners’ response

on December 2, 1999.

On October 28, 1999, the ASLB presiding officer found the Earthjustice petition of January 27,

1999, to be timely, and entertained further argument on the issue of petitioners’ standing. On

November 16, 1999, Earthjustice requested the presiding officer to rule on whether the ASLB

has jurisdiction with respect to determining whether NRC has complied with the Endangered

Species Act. On December 6, 1999, the staff filed a response arguing that the ASLB should

deny the petitioners’ November 16, 1999, motion. 

On December 27, 1999, an Order transferring source material license SUA-917 from Atlas

Corporation to the Maob Mill Reclamation Trust was signed. The Order transfers the license to

the Trust and orders the Trust and the Trustee (PricewaterhouseCoopers LLP) to perform

reclamation of the uranium mill tailings site in accordance with the terms and conditions of the

license. The terms and conditions of the license include reasonable and prudent measures in

the U.S. Fish and Wildlife Service’s final biological opinion, as well as mitigative measures

developed by the NRC staff. The Order was effective December 30, 1999, and was published

in the Federal Register on January 3, 2000.

Current Status:

On January 13, 2000, the petitioners filed a reply with the ASLB in support of their motion

originally filed on November 16, 1999, for a preliminary ruling on jurisdiction. On February 17,

2000, the ASLB granted the petitioners’ request for hearing, and the PRB, in consultation with

the Office of the General Counsel (OGC), will decide the future course of action on this petition.

*The schedule for issuance of the Director’s Decision will be set following the ASLB’s decision.
4

Facility: Connecticut Yankee and Millstone Units

1, 2, and 3

Petitioners: D. Katz, Citizens Awareness Network (CAN)

and P. Gunter, Nuclear Information and

Resource Service

Date of Petition: 11/25/96, as amended 12/23/96

Director's Decision To Be Issued by: NRR

Date Referred to Review Organization: 12/20/96

EDO Number: GT96919

OGC Number: P-96-026

Scheduled Completion Date: 2/16/2000 (completed)

Last Contact with Petitioners: 11/26/99

Petition Manager: J. Zimmerman

Case Attorney: R. Hoefling

Issues/Action Requested:

The petitioners request the staff to take the following actions: (1) immediately suspend or

revoke Northeast Utilities' (NU’s) license to operate the Connecticut Yankee (CY) (Haddam

Neck) and Millstone reactors due to chronic mismanagement; (2) investigate the possibility that

NU made material misrepresentations to the NRC concerning engineering calculations and other

information or actions relied upon to assure the adequacy of safety systems at CY and Millstone;

(3) if an investigation determines that NU deliberately provided insufficient and/or false or

misleading information to the NRC, revoke NU's operating licenses for CY and Millstone, or, if

not, keep the reactors off-line pending a Department of Justice independent investigation; (4) if

the reactors remain operating, petitioners request that they remain on the NRC's "watch list"; (5)

keep CY and Millstone off-line until NU's chronic mismanagement has been analyzed, remedial

management programs put into effect and the NRC has evaluated and approved the

effectiveness of NU's actions; (6) in the event NU decides to decommission any or all of the

reactors at issue, petitioners request the NRC not to permit any decommissioning activity to take

place until the above issues are resolved; and (7) commence an investigation into how the staff

allowed the illegal situation at NU's Connecticut reactors to exist and continue over a decade.

Background:

A partial Director's Decision (DD-97-21) addressing most of the issues was issued to the

petitioners on September 12, 1997. DD-97-21 partially granted some of the petitioners’

requests. Request (3) above was partially deferred for the Millstone plants and will be

addressed in a subsequent final Director's Decision. The licensee recently pleaded guilty to

felony counts and accepted fines that are the largest penalty, civil or criminal, in the history of

the commercial nuclear power industry. Although there are continuing investigations, they are

viewed as beyond the scope of concerns that would affect the facility license.

Because the outcome of the investigations is not expected to influence the NRC’s decision

concerning NNECO’s future operation of the Millstone reactors, the staff proposed to the Petition

Review Board (PRB) to finalize and issue the Director’s Decision by February 15, 2000. The

PRB met on November 24, 1999, and affirmed the proposed course of action.
5

Current Status:

The final Director’s Decision DD-00-01 was issued on February 16, 2000, and the petition was

closed. The NRC had earlier issued a Partial Director’s Decision (DD-97-21) dated 

September 12, 1997, which addressed all of the petitioners’ requests, with the exception of the

request that the NU operating licenses for the Millstone units be revoked if an investigation

determined that NU deliberately provided insufficient and/or false or misleading information to

the NRC. The decision on that request was deferred at the time of the Partial Director’s

Decision because several NRC investigations were underway. The Millstone facilities remained

shut down under NRC Order until NRC management had been provided evidence that the

licensee had fulfilled the intent of the two Orders. The DD concluded that, through the actions

that NRC required the Millstone facilities to complete prior to restart, and which the licensee

complied with, the intent of the petitioners’ request was met. Hence, the staff did not find the

revocation of the Millstone licenses appropriate and, as such, did not grant the final portion of

the petitioners’ request. The NRC is currently continuing to closely monitor the Millstone

facilities as agency and regional focus plants.
6

Facility: Indian Point Unit 2 

Petitioner: D. Lochbaum

Union of Concerned Scientists

Date of Petition: 9/15/99

Director's Decision To Be Issued by: NRR

Date Referred to Review Organization: 9/15/99

EDO Number: G19990465

OGC Number: -

Scheduled Completion Date: 3/31/2000

Last Contact with Petitioners: 1/31/2000

Petition Manager: J. Harold

Case Attorney: J. Goldberg

Issues/Action Requested:

The petitioner requests that the NRC modify or suspend Indian Point Unit 2's operating license

to prevent restart until the five identified issues are resolved. In lieu of license modification or

suspension, the petitioner requests issuance of a Confirmatory Action Letter or Order requiring

the petitioner’s identified issues be addressed prior to restart. Additionally, the petitioner

requests a public hearing on the petition be conducted in the vicinity of the plant prior to restart. 

The petition identified five issues, which are as follows: (1) Apparent Violation of Station Battery

Design and Licensing Basis; (2) Apparent Failure to Adequately Correct Circuit Breaker

Problems; (3) Apparent Unreliability of Emergency Diesel Generators; (4) Potential Unjustified

License Amendment for Under-Voltage and Degraded Voltage Relay Surveillance Intervals; and

(5) Apparent Errors and Non-Conservatism in Individual Plant Examination. A telephone

conference was held on September 22, 1999, between the petitioner and the Petition Review

Board (PRB), offering the petitioner an opportunity to articulate, in more detail, the basis for the

petition and to allow the staff to ask the petitioner clarifying questions. There were two additional

issues provided during the telephone conference call. They are: (1) Indian Point Nuclear

Generating Unit No. 2's (IP2) ability to cope with a station blackout scenario with current

procedures; and (2) the incorporation of licensing commitments into plant procedures. 

Background:

In a public meeting held in Region I on September 14, 1999, to discuss a plant trip at IP-2 from

full power on August 31, 1999, ConEd described the complications of the events that led to the

trip and provided a copy of their recovery plan. This plan detailed actions that ConEd viewed as

necessary to complete prior to plant restart. On September 15, 1999, the staff received a 

10 CFR 2.206 petition from the Union of Concerned Scientists (UCS) on IP2. A PRB meeting on

the petition was held on September 22, 1999. An acknowledgment letter and Federal Register

notice on the petition were issued on October 8, 1999. The PRB accepted the petition as a valid

one pursuant to 10 CFR 2.206. The PRB determined that the petitioner’s issues had been

identified by the licensee in their September 14,1999, meeting and plant restart was contingent

upon implementation of the recovery plan, which would resolve the petitioner’s issues. The PRB

concurred that several issues in the petition as well as others not addressed need to be resolved

prior to restart, thereby partially granting the petition. The PRB also made a decision to request

a licensee response to the issues raised in the petition to aid the staff in preparing the

acknowledgment letter to the petitioner. The licensee’s response dated September 24, 1999,

provided information, on the docket, which the staff had already acquired through its ongoing

inspection effort. An additional request for additional information was issued on October 1,

1999, and the licensee responded by letter dated October 6, 1999. The staff used this
7

information in part to prepare the acknowledgment letter which was issued on October 8, 1999. 

The staff determined the immediate enforcement actions the petitioner requested were not

appropriate because the short-term actions in the licensee’s recovery plan adequately

addressed some of the petitioner’s issues and all of the restart issues. However, had the

licensee not adequately addressed these issues, the staff would have considered enforcement

actions. The unit was restarted on October 13, 1999.

The petitioner, in a letter dated October 12, 1999, expressed dissatisfaction that the

acknowledgment letter failed to address his safety concerns on the station battery design and

licensing basis and the adequate correction of breaker problems. The staff responded to those

concerns by letter dated October 25, 1999. The staff determined that the issues raised in the

petitioner’s October 12, 1999, letter did not change the conclusion of the October 8,1999,

acknowledgment letter. However, the staff plans to factor the supplemental information into the

final decision on the petition. 

Current Status: 

The Region I Augmented Inspection Team follow-up inspection report was received on

December 21, 1999. An extension to the scheduled completion date was requested to allow

incorporation of details of enforcement action from the August 31, 1999, event and to evaluate

the February 15, 2000, event in which IP-2 experienced a steam generator tube failure, for any

commonalities. The current date of completion for issuance of the Director’s Decision is 

March 31, 2000. 
8

Facility: Indian Point Unit 3

Petitioner: D. Lochbaum, UCS

Date of Petition: 2/10/2000

Director's Decision To Be Issued by: NRR

Date Referred to Review Organization: 2/10/2000

EDO Number: G20000062

OGC Number: -

Scheduled Completion Date: 7/10/2000

Last Contact with Petitioners: 2/16/2000

Petition Manager: G. Wunder

Case Attorney: J. Goldberg

Issues/Action Requested:

The petitioner requests that the NRC order the licensee to conduct assessments of the Indian

Point 3 corrective action program and work environment and to take appropriate action in

response to these assessments. The petitioner further requested that these orders be closed

before the NRC allows the transfer of the Indian Point 3 license. As the basis for the requested

action, the petitioner cited allegations by Ms. Rebecca Green, formerly a member of the

licensee’s Operations Review Group, that her work environment was not safety-conscious. The

petitioner also cited various inspection reports, which identified shortcomings in the licensee’s

corrective action programs, as well as a letter informing the licensee of a potential violation of 

10 CFR 50.7 involving discrimination against an employee. 

Background:

A Petition Review Board (PRB) meeting was held on February 16, 2000. The petitioner was

provided with an opportunity to address the PRB in an open session to articulate the petition,

and did so with the licensee present.

Current Status:

This is a new petition. The PRB concluded that the petition meets the threshold for processing

under 10 CFR 2.206 and the PRB concluded that the details provided in the petitioner’s request

are found sufficient to warrant further inquiry. An acknowledgment letter will be prepared for

issuance by mid-March 2000. 
9

Facility: Edwin Hatch Nuclear Plant Units 1 and 2

Petitioner: S. Barzcak/R. Kilpatrick, Campaign for

Prosperous Georgia

Date of Petition: 2/3/2000, as amended 2/22/2000

Director's Decision To Be Issued by: NRR

Date Referred to Review Organization: 2/24/2000

EDO Number: G20000098, G20000056

OGC Number: -

Scheduled Completion Date: 3/31/2000

Last Contact with Petitioners: 2/14/2000

Petition Manager: L. Olshan

Case Attorney: J. Goldberg

Issues/Action Requested:

The petitioners, in their letter dated February 3, 2000, requested that the NRC shut down the

Hatch units, not allow operation of a high-level waste storage facility at that site, and not grant

license renewal. As a basis for these claims, the petitioners cite issues related to ongoing

groundwater problems, a cracked core shroud, and a mounting waste problem near the banks of

the Altamaha River. The petitioners also assert that insufficient notice of events at Hatch is

provided to the public. The petitioners submitted a supplement dated February 22, 2000, which

raised additional issues. All the issues were discussed during the Petition Review Board (PRB)

meeting conducted on February 28, 2000. The actions requested by the petitioners include: 

(a) shutting down Hatch; (b) cleaning up contaminated areas; (c) retrieval of particulate radiation;

(d) decontamination of all equipment, material and buildings on site; (e) compensation of

contaminated workers and the public; (f) irreversible revocation of the plant license; and 

(g) halting the dry cask storage project.

Background:

An initial PRB meeting was held on February 14, 2000, and the petitioners, in accordance with

Management Directive (MD) 8.11, were provided with an opportunity to make a presentation to

amplify and clarify the original submission in an open session of the PRB meeting. The

petitioners requested, and were granted, additional time until February 18, 2000, for

supplementing the petition with any additional information. The petitioners responded with a

supplement dated February 22, 2000. A second PRB meeting was held on February 28, 2000.

Current Status:

This is a new petition. After discussing all of the issues raised, the PRB ultimately decided at the

February 28, 2000, meeting to reject the petition. There were three issues identified at the PRB

which required staff review: (1) environmental monitoring and Radcon related to personnel and

offsite releases; (2) vulnerabilities of Lake Sinclair dam to a Charleston-type earthquake; and (3)

the dumping of contaminated sludge at the site. Of these, the last issue was determined to be

outside the scope of the PRB, since Hatch Units 1 and 2 are in an agreement state, and NRC

does not have jurisdiction in that matter related to the National Pollutant Discharge Elimination

System (NPDES). The PRB recommended that the petitioners’ request in this regard be

directed toward the State agency having jurisdiction. The other two issues were subsequently

satisfactorily resolved by the staff after research showed that they had been dispositioned by a

previous agency action. Since the issues have been dispositioned, the PRB recommended that

the staff comprehensively answer all of the issues raised in the petition and issue a one-step

acknowledgment/close-out letter. 
1

Attachment 2

Report on Status of Public Petitions Under 10 CFR 2.206 with

 Petitions Involving the Office of Enforcement (OE),

the Office of Investigations (OI), the Inspector General (IG), and

the Department of Justice (DOJ), and Other Sensitive Information

<< ---- NOT FOR EXTERNAL DISTRIBUTION----->>

Facility: Connecticut Yankee and Millstone

Units 1, 2, and 3

Petitioners: D. Katz, Citizens Awareness Network (CAN) and P. Gunter,

Nuclear Information and Resource Service

Date of Petition: 11/25/96, as amended 12/23/96

Current Status:

DOJ provided a press release announcing fines for 19 violations of the Atomic Energy Act and 

6 violations of the Clean Water Act. DOJ and OI conducted investigations related to potential

actions against individuals. Because the ongoing investigation was not expected to influence

any NRC decision concerning NNECO’s future operation of Millstone reactors, the staff agreed

to provide a final Director’s Decision by February 15, 2000. The Petition Review Board met

November 24, 1999, and affirmed the proposed course of action. DD-00-01 was issued on

February 16, 2000, and the petition was closed .

END OF STATUS REPORT

<<<---NOT FOR EXTERNAL DISTRIBUTION--->>> 

 
1

Attachment 3

AGE AND RESOURCE EXPENDITURES FOR AGENCY 2.206 OPEN PETITIONS

As of February 29, 2000

ASSIGN

ED

ACTION 

OFFICE

PETITIO

N

NUMBE

R

OGC

NUMBER

FACILITY AGE

(months)

*

Schedule

d

Completio

n Date

Resources

Expended

by Action

Office

(HOURS)

1

Resources

Expended

by OGC

(HOURS)1

Comments if not meeting

the Agency’s 

120-day Completion Goal

NMSS G1999001

1

P-99-02 ATLAS CORPORATION 12 TBD2 5 38.5 Earthjustice filed a petition

with the U.S. Court of

Appeals for the 9th Circuit

regarding the staff’s de facto

denial of the 2.206 petition. 

ASLB granted the

petitioner’s request for a

hearing on Feb 17, 2000.

NRR G1990465 - INDIAN POINT UNIT 2 4 3/31/2000 467.5 9.5 Incorporation of

additional enforcement

action from 8/31/99

event into the DD.

NRR G2000006

2

 - INDIAN POINT UNIT 3 - 7/10/2000 13.0 1.0

NRR G20000098,

G20000056

 - HATCH UNITS 1 AND 2 - 3/31/2000 29.0 3.0 -

1

 Staff professional time only; does not include management or administrative time.

2 Projected completion date (Please see Attachment 1 for explanation).

*Age calculated from the date of the acknowledgment letter.
1

Attachment 4

Report on Status of Public Petitions

Under 10 CFR 2.206 for DDs Issued and/or Closed During the Last 12 Months

Petition Number Assigned Facility Petition DD Age Com

men

ts

Action Date Date at Closure1,2

Office

GT977724 NRR D.C.Cook 10/9/97 2/11/99 14 Partly

Granted

G980233 NRR Vermont Yankee 4/10/98 2/10/99 8 Denied

G199980707 NRR Diablo Canyon 11/24/98 3/12/99 2 Denied

G980199 NRR Browns Ferry 4/5/98 3/29/99 11 Denied

G19980622 NMSS FUSRAP 10/15/98 3/26/99 3 Denied

G19980678 NRR Perry 11/9/98 4/18/99 4 Denied

G980592 NRR River Bend 9/25/98 4/18/99 5 Denied

603 NRR Millstone 8/21/95 7/27/99 45 Partly

Granted

G19990173 OE Seabrook 3/31/99 8/3/99 3 Denied

GT97181 NRR Connecticut Yankee 3/11/97 9/9/99 29

Partly Granted

G19980767 NMSS Enviro Care of Utah 12/30/98 7/12/99 5

Granted

G19990201 NRR Millstone 3/31/99 9/28/99 4 Denied

G19990224 NRR Nine Mile Point 1 & 2 4/5/99 10/28/99 4

Denied

G19990268 NRR Nine Mile Point 1 5/24/99 11/28/99 5 Denied

GT96919 NRR Millstone 1, 2 & 3 11/25/96, as 

amended 12/23/96 2/16/2000 37 Partl

y

Gra

nted

1) Age calculated from the date of the acknowledgment letter.
2

2) Goals: Acknowledgment letter issued within 5 weeks from date of receipt; DD issued within 4 months of

acknowledgment letter.
PDII-2 DOCUMENT COVER PAGE

DOCUMENT NAME: 

I:\PERSONALWEB\NRC\PUBLIC\2206\2000\February\edo200002.wpd

ORIGINATOR: Ram Subbaratnam

SECRETARY NAME: Doreen Turner

SUBJECT: Monthly Status Report for 2.206 Petitions- September 1999

*****ROUTING LIST*****

 NAME DATE

 1. E. Dunnington / /00

 2. R. Subbaratnam / /00

 3. H. Berkow / /00

 4. P. Goldberg, NMSS / /00

 5. S. Black/J.Zwolinski / /00

 6. B. Sheron / /00

 7. S. Collins / /00

 8. Secretary - Dispatch

CAN THIS DOCUMENT BE DELETED AFTER DISPATCH? yes_X__ no___