No. S-97-13
May 30, 1997
GRETA J. DICUS
COMMISSIONER
U.S. NUCLEAR REGULATORY COMMISSION
7th ANNUAL
NATIONAL RADIOLOGICAL
EMERGENCY PREPAREDNESS CONFERENCE
APRIL 22, 1997
Radiological Emergency Planning
Taking A Broader View
Good afternoon, ladies and gentlemen. As most of you are aware,
I have been involved in radiological emergency planning (REP)
issues for many years because of my previous responsibilities
with the State of Arkansas. It is truly heartwarming to see so
many of my friends and colleagues at this Annual REP Meeting and
I am delighted to join you today so that we can meet again and
share our thoughts on current issues in emergency preparedness.
I will focus my remarks on the interrelated topics of exercise
participation, incident response, outreach and assistance,
potassium iodide, new source term implications, and economic
deregulation and restructuring implications for emergency
preparedness. I will also give you my personal perspective on
most of the issues as I view them as a Commissioner of the
Nuclear Regulatory Commission.
Because of the experience I had at the State level with Arkansas
Nuclear One in interfacing and coordinating with Federal Agencies
that are involved in the various aspects of nuclear power plant
emergency response, it was very interesting and a unique
experience to serve, last summer, as the Executive Team Director
at the NRC Operations Center during a full participation exercise
for Arkansas Nuclear One. This was also an educational
experience to work from the other end of the ENS telephone!
NRC RESPONSE AND PARTICIPATION IN EXERCISES
Lead Federal Agency
I wish to begin my comments today with a review of "Lead Federal
Agency" for radiological issues. As you are aware, the nature of
the emergency, the licensee, the materials involved, and the
facilities involved are determinants utilized in the Federal
Radiological Emergency Response Plan to designate the Lead
Federal Agency (LFA). While it may seem somewhat confusing,
given that any one of five different Federal Agencies could be
designated as the LFA in response to a nuclear material incident,
the decision is generally based on the organization's normal
responsibilities.
The NRC is the LFA for any emergency at a nuclear facility
licensed by the NRC or an Agreement State or any emergency
involving radioactive materials licensed by the NRC or an
Agreement State. The DOE is the LFA for any emergency at one of
its facilities or involving transportation of DOE materials. The
DOD is the LFA for any emergency at one of its facilities or
involving transportation of DOD materials. NASA is the LFA for
emergencies involving domestic satellites that involve NASA space
missions. DOD is the LFA for domestic satellites that involve
DOD space missions.
The EPA is the LFA for those emergencies at a nuclear
facility not licensed, owned, or operated by a Federal Agency or
an Agreement State or for those emergencies involving materials
not licensed or owned by a Federal Agency or an Agreement State.
EPA is also the LFA for emergencies resulting from a foreign or
unknown source. For emergencies other than these, the Federal
Agencies would confer to determine the LFA for that particular
event. In all of these situations, FEMA is the Coordinating
Agency.
NRC Participation in Exercises
I would like to begin with a review of NRC participation in
exercises. I have been and remain a proponent of significant
involvement of Federal agencies in exercises. As a review, you
are aware that the NRC published a final rule that eliminated the
requirement for the "off year" or annual onsite exercise. While
this reduced the required frequency for exercising the licensee's
onsite emergency plan from annual to biennial performance, it
preserved the requirement for the biennial full participation
exercise. This rule requires licensees to ensure that emergency
response capabilities are maintained between exercises by
conducting drills, at least one of which must involve some of the
principal functional areas of onsite capabilities. The rule also
requires licensees to continue giving those State and local
governments that are in the plume exposure pathway the
opportunity to participate in these drills.
Even though exercises will only be evaluated every other
year at a site, the NRC remains committed to the conduct and
participation in emergency exercises. For example, during 1996,
the NRC participated fully in four exercises, participated with
Site Teams in six exercises, involved an Ingestion Team in one
exercise, an augmented team in another exercise, and was involved
in table top exercises with both of the gaseous diffusion plants.
In 1997, NRC headquarters will again participate fully in
four reactor exercises. We will also participate in one lost
source exercise, one gaseous diffusion plant exercise that is not
a table top exercise, four limited headquarters involvement
exercises, and to varying degrees, four ingestion exercises.
Additionally, the NRC Regions will participate in other exercises
that have been designated as Site Team Only, limited/Site Team
exercises, and/or ingestion team exercises. The exercises were
selected in consultation with the participating parties using a
variety of criteria including schedule spacing, regional
preference, and frequency of licensee and State participation in
accordance with the goals of the State Outreach Program.
Proposed New Jersey Exercise
Members of the NRC staff recently attended a preliminary
planning meeting for a plume, ingestion, and recovery exercise
that is scheduled for the Salem nuclear power plant in New Jersey
in the spring of 1998. As you know, the NRC feels strongly that
any exercise at an NRC-licensed facility in which Federal
participation is requested should be coordinated through the NRC
as Lead Federal Agency (LFA). While still in the preliminary
planning stages, this exercise presents interesting opportunities
for Federal participation. There are two objectives, in
particular, that merit our strong support. The first objective
will address the New Jersey desire to fully integrate Federal
capabilities into the New Jersey concept of operations and
emergency response plan for radiological emergencies. New Jersey
would also like to work with Federal representatives to review
and modify their own plan to generate a generic State plan which
could then be communicated to other States for their
consideration and plan review.
Secondly, New Jersey has expressed a desire to have
augmented FEMA participation, as well as DOE Federal Radiological
Monitoring and Assessment Center (FRMAC), as players in this
exercise. The NRC staff's preliminary assessment is that this
may require establishment of a FEMA facility (Disaster Field
Office (DFO)) as well as a FRMAC. The focus would be to exercise
the radiological and nonradiological support in a radiological
event where the NRC is LFA. This element is also of interest to
the NRC as it was a focus of the Susquehanna Federal Field
Exercise #3 (FFE-3) that was prematurely canceled in 1992.
Furthermore, New Jersey has expressed an interest in examining
the Stafford Act and Price-Anderson Act implications on a nuclear
power plant accident.
The scope of this effort is negotiable at this point.
However, we are encouraged by the efforts of New Jersey,
Delaware, and the utility and, specifically, their early requests
for Federal participation. They have demonstrated a willingness
to work together with the Federal government to make this an
enhanced training experience. Further planning meetings will be
scheduled in the near future. Following preliminary consideration, this option will be presented to the Federal
Radiological Preparedness Coordinating Committee (FRPCC) for
their formal consideration as soon as possible. The tentative
date for the ingestion and recovery portion of this exercise is
in May 1998.
The NRC has also developed a guidance document for Large
Scale Tabletop Exercises, NUREG-1514. This document has been
used successfully by many State organizations to allow an
opportunity for senior managers to consider issues not normally
addressed in the plume phase exercises. Most recently, the NRC
staff participated in an exercise in Delaware in which the
Governor and Lieutenant Governor also participated. We encourage
all State organizations to consider this option as a way to
accomplish some of the exercise goals associated with exercise
play without the resources commitment required for full
participation exercise.
Incident Response for Portsmouth and Paducah Gaseous Diffusion
Plants
On March 3, 1997, the Department of Energy (DOE) transferred
the regulatory oversight of the Portsmouth, Ohio and the Paducah,
Kentucky Gaseous Diffusion Facilities to the NRC. The NRC and
the DOE have signed a Memorandum of Understanding that commits
each organization to coordinate with each other to respond to
emergencies at the gaseous diffusion plants. DOE has adopted a
two-tier emergency classification system for these sites in order
to maintain consistency with the NRC classification scheme for
fuel facilities. The NRC response to emergencies will take into
account the special characteristics of the hazards intrinsic to
these facilities. The primary concern at these facilities
involves the chemical effects of releases rather than
radiological effects of the product. A supplement to the
Response Technical Manual is being developed for use in response
to emergencies at the gaseous diffusion plants. The NRC intends
to build relationships with the States and local agencies to
ensure an effective response to emergencies at these facilities.
Implications for NRC Oversight of DOE Facilities
The assumption of oversight for the DOE gaseous diffusion
plants has been a challenge to the NRC and an opportunity to gain
further understanding of emergency response planning in general
because of the issues concerning emergency response with the
oversight of DOE facilities and issues related to DOE
contractors. This experience has raised more questions than
answers. The following questions have arisen in agency
discussions for which answers have yet to be determined.
1. What are the parameters and the implications for emergency
response at other DOE facilities for which the NRC will
assume oversight in the future?
2. Will DOE support of emergency response to NRC licensed
facilities be affected when the NRC assumes oversight of DOE
and its support infrastructure?
3. Will agreements associated with DOE support for emergency
response to States and local governments require alteration,
transfer or some other modification?
As you can see, this may be the tip of the iceberg with
respect to issues that may need to be addressed as the transition
from DOE self- oversight to NRC external oversight progresses.
Any insights or perspectives that you may have on this subject
will be appreciated.
Non Nuclear Power Plant Emergencies
As you would expect, I support our activities in
radiological emergency planning (REP) for nuclear power plants.
But more importantly - I strongly support emergency planning
activities for non-nuclear power plant incident responses. This
is the area where injuries and deaths to members of the public
have occurred. This should also be a visible and active part of
our focus on incident response. Let me explain why.
NRC staff has no record of any nuclear power plant operation
or incident in this country, including TMI, that resulted in
exposure of members of the public in excess of applicable 10 CFR
Part 20 dose limits for the public. In contrast, there is a
history of radioactive materials incidents that have resulted in
overexposure of the members of the public. Some of these
overexposures were of sufficient magnitude to cause acute
radiation injuries. The following examples illustrate this
point.
The California Hip Pocket Incident
In 1979, an industrial radiographer was employed at a
temporary job site in California. When he left the site, he
failed to properly secure the radiography camera and, what is
most important, failed to conduct a radiation survey of the
camera to confirm that the multi-curie 192Ir source was properly
secured. The source fell out of the camera and it was later
picked up and handled by other workers at the site who were
unaware that it was radioactive. Several persons suffered
localized radiation injuries as a result. One worker placed the
source in a hip pants pocket resulting in a very serious
localized radiation dose, 1.5 million rem surface dose and 60,000
rem at 1 cm depth.
The Indiana, Pennsylvania Incident
In 1992, a waste disposal company reported finding a
radiation source in waste. The NRC investigation revealed that in November 1992 a clinic in Indiana, PA treated an elderly
patient with high dose brachytherapy using a 4 Ci 192Ir source.
The treatment was terminated early because of equipment problems.
Unbeknownst to the operators, the source wire had broken and the
source remained in the patient. A radiation survey of the
patient at the end of the treatment to confirm that the source
was safely secured was required but was not performed. The
patient went from the clinic to a nursing home where she died 5
days later. The catheter (containing the source) was removed by
nursing home personnel and disposed of as biohazard waste. The
source was discovered during routine radiation surveillance of
waste by the waste disposal company. The additional dose
received by the patient was a contributing factor in the
patient's death. As many as 94 persons were exposed to the
source including clinic staff, nursing home staff, residents and
visitors and waste disposal company employees. Doses to the
public ranged from 0.034 to 2.57 rem.
The Texas Lost Source Incident
In 1996, industrial radiography devices in storage in Texas
were stolen for sale as scrap metal. The devices subsequently
changed hands between scrap metal firms. As a result of the
multiple handling of the devices, the lock box of one of the
devices was broken off and the 35 Ci 60Co source fell to the
ground near a scrap yard office in Houston, Texas. Scrap yard
employees and investigating police officers and the family of the
scrap yard owner, including two young children were exposed.
Results of cytogenetic studies of blood samples taken following
this incident suggested that no one received a dose in excess of
10 rem but one worker received a much larger dose to his
extremities as a result of handling the source.
The Scrap Metal Issue
On over 200 occasions, radioactive sources have been found
in metal scrap intended for recycling. On 26 occasions,
radioactive sources were inadvertently smelted by metal mills in
the United States and Canada resulting in contamination of the
mills, products, and mill byproducts. On other occasions,
unshielded sources have been found in scrap yards and landfills.
The finding of radioactive sources and devices in the public
domain and the inadvertent smelting of radioactive materials into
commercial products may result in public health and safety
hazards requiring the mobilization of State and Federal emergency
response resources. Also, accidental smeltings of radioactive
materials in other countries have resulted in contaminated
products that cross international borders. These smeltings were
not detected when they occurred and, as a result, radioactively
contaminated products were introduced into commerce.
Government responses to these incidents can sometimes be
significant. For example, following the 1983 Mexican incident,
2,500 pieces of contaminated cast iron pieces and between 500 and 900 tons of contaminated rebar that had been exported to the U.S.
were identified, recovered and returned to Mexico. This was
accomplished with the assistance of the 50 State radiation
control and emergency response programs at a cost to them of more
than 7.9 professional staff-years and $233,000 in out-of-pocket
expenses. Needless to say, to do this required diversions of
critical, limited resources from other, scheduled program
activities.
Given these "example incidents," one can readily perceive
the significant potential health and safety issues associated
with radioactive materials entering the public domain in an
uncontrolled manner. Therefore, radiological emergency planning
should focus on radioactive material events, as well as nuclear
power plant events. It is for these reasons that I was pleased
to learn that an exercise is planned for Region I that involves
the NRC, EPA and local states in a lost source scenario.
REALISM IN SCENARIOS
The next subject that I would like to discuss is realism in
scenarios. Over the years that I worked with the emergency
response efforts of Arkansas, I came to understand the sequences
of events that were necessary to drive an emergency response
exercise to the General Emergency classification. These
sequences were all too often as extraordinary as they were
predictable. Since I became a Commissioner, my perceptions
regarding emergency response scenarios have remained unchanged.
The exercise scenarios often contain technical
inconsistencies which may result in passivity among the
participants, frustrate the diagnostic process, and frequently
produce negative training. Exercise scenarios rarely, if ever,
utilize current and historically significant incidents to build
upon. Most seem to rely on failure mechanisms that may be
"miraculous" at worst and disconnected at best. In contrast,
historically significant events often include human error,
instrumentation failure, and machine/human interface problems.
Drill scenarios, however, seldom take advantage of these concepts
to exacerbate the consequences.
While the players may be kept guessing and analyzing the
event in the early going of an exercise, how often do we hear
"the essence" of the residual scenario discussed by the players
because the exercise scenario must achieve an "expected
condition" in order to cover the objectives and mobilize the
offsite players? I recognize that this "speculation" speaks well
of the abilities of the exercise participants, but I continue to
wonder about the utility of the preprogrammed nature of the
scenario and the benefit to the participants.
Another significant weakness of exercise scenarios is their
continuing failure to address the plant's accident management
capabilities. When was the last time any of us noted an
opportunity for a success path in which some action by the
participants was permitted to return a vital component to
service, find an inventive way to address a particular limiting
condition, or mitigate the consequences of the event? What was
the effect upon the participants when they were informed that
their actions and inventiveness were of no consequence because
the preprogrammed scenario had run its defined course? What
positive training objective was accomplished?
Unfortunately, the quality of exercise scenarios has
declined over the years. Certainly, some of this may be
attributed to scenario predictability and conditioning of the
participants. However, from a larger perspective, I believe that
exercise objectives and limited resources are also partly
responsible for this decline.
Exercising the radiological emergency response plan is a
time and resource consuming activity for all organizations
involved. It will not be a small task to improve the utility of
these exercises, factor in potential opportunities for success
paths, still meet exercise objectives, and observe increasing
budget limitations. But I believe this is preferable to the
current situation in which emergency responders become
increasingly complacent, question the utility of their efforts,
and potentially experience "negative training" as a result of
their participation. I strongly encourage the scenario
developers to pay more attention to the quality of their efforts
and to the overall safety objective of preparing emergency
responders for a potential future event. One that I sincerely
hope never occurs.
Potassium Iodide Issue
The use of KI by the general public as part of radiological
emergency response planning has been the subject of much
controversy, within the NRC, among the States, and
internationally, as well. The existing Federal policy on the
stockpiling and distribution of potassium iodide was published in
the July 24, 1985 Federal Register. This policy "recommends the
stockpiling or distribution of KI during emergencies for
emergency workers and institutional(ized) persons, but does not
recommend requiring predistribution or stockpiling for the
general public."
In September 1989, the American Thyroid Association
requested that this policy be revisited as it relates to the
stockpiling and distribution of KI for use by the general public.
Upon evaluation, the staff of the Federal Radiation Protection
Coordinating Committee (FRPCC) reaffirmed the existing policy.
Partly in response to a petition for rulemaking submitted to the
NRC in September 1995, the FRPCC again revisited this issue. While in the view of the FRPCC staff, this latest evaluation did
not identify new information that seriously challenged the
existing policy, several recommendations were made that were
adopted (with modification) by the FRPCC, together with a plan to
publish a revised policy statement.
The proposed revision to the Federal policy would continue
to recommend stockpiling and distribution of KI for use by
emergency workers and institutionalized persons. The decision
for stockpiling and use of KI for the general public would be
left to the discretion of the State and, in some cases, local
governments. Any State, or in some cases, local governments,
which select the use of KI as a protective measure for the
general public may so notify FEMA, and may request funding for
the purchase of an adequate supply of KI. The Commission has not
yet considered these recommendations at a policy level. However,
we expect to do so before the revised policy statement is issued
in its final form.
Implications of the New Source Term
Currently, operating plants have used source term
information that dates back to research and studies conducted
prior to 1962. The "old source term" which is still used and
referenced today was published in TID-14844, "Calculation of
Distance Factors for Power and Test Reactors" in 1962. More
recently, the staff has published NUREG-1465, "Accident Source
Terms for Light-Water Nuclear Power Plants" which takes into
account research into severe accidents and radionuclide
behavior. The NUREG-1465 source term contains a more realistic
description of release timing and radionuclide composition. The
revised source term describes different release fractions of core
inventory, chemical and physical forms of important species, and
natural removal processes that reduce the quantity of radioactive
material that may be released to the environment. The accident
source term is utilized to calculate design basis accident dose
consequences.
Under the new framework, doses at the low population zone
will still be calculated from the plume passage over the course
of the accident. Radiological doses are calculated using the
total effective dose equivalent (TEDE) methodology as defined in
10 CFR Part 20, which considers the effects of a dose to all
organs. The calculated doses would be compared to a dose
acceptance criterion of 25 rem TEDE for the exclusion area
boundary for any two hours (the two-hour period that produces the
highest dose) following the onset of an accident, and a 25 rem
TEDE dose for low population zone for the duration of the
accident (taken to be 30 days). This approach provides a
coherent regulatory framework for evaluating the radiological
consequences of design basis accidents using the revised source
term and, in essence, a conversion of existing reactor siting
criteria to new dose terminology.
While the application of the revised source term has been
focused on advanced and evolutionary reactors, the Commission
recently provided instruction to the staff to further evaluate
the use of the "new source term" in NUREG-1465 for operating
reactors. The staff will begin by rebaselining two power plants,
one a boiling water reactor (BWR) and the other a pressurized
water reactor (PWR). This effort is intended to obtain a better
understanding of the postulated release of fission products into
the containment atmosphere during an accident and, using the new
methodology, the associated consequences. Upon completion of the
rebaselining, the staff will commence work on a number of pilot
projects with several licensees to gain an understanding of the
potential benefits and impacts associated with using the new
source term. Upon completion of the rebaselining projects and
coincident with the conduct of the pilot projects, the staff will
commence rulemaking, if appropriate, to address issues that may
affect the use of the new source term methodology.
Some of the areas for which the industry and NRC staff see
potential implications include: containment isolation valve
timing, mitigation system actuation timing, allowable leak rate
changes, and filtration unit simplification. Other areas
potentially affected include radiological consequences, equipment
qualification, and post accident sampling. As you will note, the
focus at this point appears to be predominately equipment
related. No decisions have been made, at this time, by the
Commission regarding the approval of changes. We would like to
understand the results of the rebaselining efforts before
proceeding further.
Finally, could the use of the new source term impact the
size of the plume exposure emergency planning zone? Will the use
of the new source term provide a basis for reexamination of the
present policy governing emergency planning zones? As a
regulatory agency, the NRC is obligated to evaluate any submittal
for change and to fairly evaluate the merits and the potential
impact on public health and safety. The NRC has received two
submittals in the past that requested a reduction in the size of
the plume exposure emergency planning zone based upon site-specific accident analyses. While these were not approved at
that time, I would not be surprised to see future requests for
similar actions upon completion of the evaluation of the use of
the new source term at the operating reactor facilities. This is
an issue that we may have to address in the future. Certainly,
consideration of these issues will require public input.
Economic Deregulation: Implications for Emergency Preparedness
The issue of a competitive market for electric utility
services is upon us. A day does not pass without new information
in trade magazines, newspaper articles, and information on
Congressional activities that include some mention of industry
restructuring, mergers, agreements with States, and other
inventive ideas on new approaches for the provision of electrical energy to our homes and businesses. The competitive market is
here; however, the timing for full implementation and the
implications on State and Federal regulatory structures have yet
to be determined. There is, as in any time of change, a great
deal of uncertainty and concern.
From the NRC perspective, we have two significant concerns.
First, provisions must be made to assure adequate financing and
maintenance of sufficient resources to assure safe and complete
decommissioning of the facility. Second, the owners and
operators of the facility must maintain adequate financing and
sufficient resources to safely operate the reactor facilities and
meet regulatory requirements to assure the public health and
safety. One of the fundamental requirements includes the
maintenance of an emergency plan that will be capable of
protecting the public health and safety.
There are two areas that currently cause concern for safety
of the operational reactors that have implications for emergency
response. The first one of these is the potential reduction of
resources. As licensees move into the competitive market,
increasing emphasis will be placed on cost effective operations
and minimization of nonoperational support expenditures.
Certainly, emergency response and preparedness efforts do not
reduce operating costs; rather, it could be perceived as a burden
that does not enhance the facility's cost competitive posture in
relation to other energy competitors in the market. With this
concern, the NRC will have to reevaluate its programs to ensure
that fundamental responsibilities such as emergency planning are
not neglected. With respect to this concern, I believe that
there is some hope. The Commission has noted that many of the
reactor facilities which have outstanding operating and safety
records are also some of the most cost effective operating
facilities. Safety in operation and maintenance of reactor
facilities can be compatible with cost-effective operation.
The second significant concern is electrical grid
reliability. As the competitive market unfolds, new independent
power providers will come to the grid with electrical energy to
sell. Old, familiar providers will also come to the grid selling
their product. Under the current regime, utilities are rewarded
with recovery of costs for investments in plants and equipment
such that an adequate margin is maintained in the grid to ensure
that peak load conditions in the summer and winter are handled
without the necessity of rolling brownouts and blackouts. Over
the years, because of the costs of capital and the structures in
each State to obtain recovery of costs, the country has seen a
continued downward trend in the margins available to support peak
load conditions.
What incentive will there be in the competitive market to
maintain margins on the national and regional electrical grids?
Who will be responsible for ensuring an adequate margin exists?
Why is this important?
The NRC believes that grid reliability is a significant
safety issue. In fact, there will be a Commission Briefing on
this very subject tomorrow. In terms of evaluating the risk to
safe operations and the risk of an accident, grid reliability is
very important. The risk of the loss of offsite power is
factored into numerous design basis accident analyses. The
presumption of a given reliability level provides the comfort
that should the unforeseen occur, the reactor facility would be
positioned to cope with an expected level of transients. These
transients include perturbations on the grid and loss of offsite
power. When the margins on the electrical grid shrink, then the
risk for the loss of offsite power increases. Without the excess
margin, grid voltage and frequency stability may decrease when
minor disturbances occur. Last summer, this country experienced
two significant disturbances on the Western Grid. These
disturbances resulted in the tripping of plants across many
States with subsequent initiation of the emergency onsite power
sources. While some may believe that grid disturbances are
unavoidable, the reduction in margin increases the likelihood
that reactor facilities will lose offsite power and emergency
equipment will be challenged unnecessarily. An answer for this
concern has yet to be determined.
Conclusion
Although NRC has done a great deal to address the emergency
preparedness issues that confront the agency and the nuclear
industry, we need to do more to ensure that we have positioned
ourselves to prepare for changing missions and budget, deal with
economic pressures being faced by the nuclear industry, and
improve the regulatory framework. We must also recognize that,
historically in the United States, the greatest health impact on
members of the public or radiation workers is from lost and/or
misuse of radioactive materials not subject to 10 CFR Part 50
requirements. Emergency response and planning personnel must
consider this fact in future activities. Finally, greater effort
must be devoted to ensuring that emergency response exercises are
realistic in relation to actual events and allow responders to
respond in a realistic fashion.
It is my opinion that the NRC can help with the efforts to
maintain a workable framework for emergency preparedness through
our regulatory efforts, and achieve a high degree of credibility
demanded by the public by arriving at its decisions in a fair and
open process.
We are also aware that FEMA is undergoing a significant
review of its radiological emergency preparedness program with
the goal of improving the efficiency and effectiveness of the
program. The NRC fully supports this effort.
Thank you for your attention. I would be pleased to answer
any questions that you might have at this time.
