ML020150584
| ML020150584 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/15/2002 |
| From: | Jaffe D NRC/NRR/DLPM/LPD4 |
| To: | Terry C TXU Electric |
| References | |
| TAC MB3063, TAC MB3064 | |
| Download: ML020150584 (17) | |
Text
January 15, 2002 Mr. C. Lance Terry Senior Vice President
& Principal Nuclear Officer TXU Generation Company LP Attn: Regulatory Affairs Department P. O. Box 1002 Glen Rose, TX 76043
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES), UNITS 1 AND 2 -
ISSUANCE OF AMENDMENTS RE: ELIMINATE REQUIREMENTS FOR POST ACCIDENT SAMPLING SYSTEM (TAC NOS. MB3063 AND MB3064)
Dear Mr. Terry:
The Commission has issued the enclosed Amendment No. 91 to Facility Operating License No. NPF-87 and Amendment No. 91 to Facility Operating License No. NPF-89 for CPSES, Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated October 2, 2001.
The amendments delete TS 5.5.3, Post Accident Sampling System and thereby eliminate the requirements to have and maintain the Post Accident Sampling System (PASS) at CPSES. In addition, the amendments revise TS 5.5.2, Primary Coolant Sources Outside Containment, to reflect the elimination of PASS.
A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely,
/RA/
David H. Jaffe, Senior Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446
Enclosures:
- 1. Amendment No. 91 to NPF-87
- 2. Amendment No. 91 to NPF-89
- 3. Safety Evaluation cc w/encls: See next page
January 15, 2002 Mr. C. Lance Terry Senior Vice President
& Principal Nuclear Officer TXU Generation Company LP Attn: Regulatory Affairs Department P. O. Box 1002 Glen Rose, TX 76043
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES), UNITS 1 AND 2 -
ISSUANCE OF AMENDMENTS RE: ELIMINATE REQUIREMENTS FOR POST ACCIDENT SAMPLING SYSTEM (TAC NOS. MB3063 AND MB3064)
Dear Mr. Terry:
The Commission has issued the enclosed Amendment No. 91 to Facility Operating License No. NPF-87 and Amendment No. 91 to Facility Operating License No. NPF-89 for CPSES, Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated October 2, 2001.
The amendments delete TS 5.5.3, Post Accident Sampling System and thereby eliminate the requirements to have and maintain the Post Accident Sampling System (PASS) at CPSES. In addition, the amendments revise TS 5.5.2, Primary Coolant Sources Outside Containment, to reflect the elimination of PASS.
A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely,
/RA/
David H. Jaffe, Senior Project Manager, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446
Enclosures:
- 1. Amendment No. 91 to NPF-87
- 2. Amendment No. 91 to NPF-89
- 3. Safety Evaluation cc w/encls: See next page DISTRIBUTION:
PUBLIC PDIV-1 Reading RidsNrrDripRtsb (WBeckner)
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Accession No.: ML020150584 *See previous concurrence OFFICE PDIII-1/PM PDIV-1/PM PDIV-1/LA PDIV-1/SC NAME JLamb* DJaffe DJohnson RGramm DATE 12/03/01 01/15/02 01/14/02 01/15/02 OFFICIAL RECORD COPY
TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION, UNIT NO. 1 DOCKET NO. 50-445 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 91 License No. NPF-87
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by TXU Generation Company LP dated October 2, 2001, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Facility Operating License No. NPF-87 is hereby amended to read as follows:
(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 91 , and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. TXU Generation Company LP shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3. The license amendment is effective as of its date of issuance and shall be implemented by March 15, 2003.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Robert A. Gramm, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: January 15, 2002
TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION, UNIT NO. 2 DOCKET NO. 50-446 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 91 License No. NPF-89
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by TXU Generation Company LP dated October 2, 2001, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Facility Operating License No. NPF-89 is hereby amended to read as follows:
(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 91 , and the Environmental Protection Plan contained in Appendix B, are hereby incorporated into this license. TXU Generation Company LP shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3. This license amendment is effective as of its date of issuance and shall be implemented by March 15, 2003.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Robert A. Gramm, Chief, Section 1 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: January 15, 2002
ATTACHMENT TO LICENSE AMENDMENT NO. 91 TO FACILITY OPERATING LICENSE NO. NPF-87 AND AMENDMENT NO. 91 FACILITY OPERATING LICENSE NO. NPF-89 DOCKET NOS. 50-445 AND 50-446 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.
Remove Insert 5.0-8 5.0-8
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 91 TO FACILITY OPERATING LICENSE NO. NPF-87 AND AMENDMENT NO. 91 TO FACILITY OPERATING LICENSE NO. NPF-89 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 DOCKET NOS. 50-445 AND 50-446
1.0 INTRODUCTION
By application dated October 2, 2001, TXU Electric (the licensee)* requested changes to the Technical Specifications (TSs) for the Comanche Peak Steam Electric Station (CPSES), Units 1 and 2. The proposed changes would delete TS 5.5.3, Post Accident Sampling System, and thereby eliminate the requirements to have and maintain the Post Accident Sampling System (PASS) at CPSES. In addition, the proposed changes would revise TS 5.5.2, Primary Coolant Sources Outside Containment, to reflect the elimination of PASS.
In the aftermath of the accident at Three Mile Island Nuclear Station (TMI), Unit 2, the Nuclear Regulatory Commission (NRC or the Commission) imposed requirements on licensees for commercial nuclear power plants to install and maintain the capability to obtain and analyze post-accident samples of the reactor coolant and containment atmosphere. The desired capabilities of PASS were described in NUREG-0737, Clarification of TMI Action Plan Requirements. The NRC issued orders to licensees with plants operating at the time of the TMI accident to confirm the installation of PASS capabilities (generally as they had been described in NUREG-0737). A requirement for PASS and related administrative controls was added to the TSs of the operating plants and was included in the initial TSs for plants licensed during the 1980s and 90s. Additional expectations regarding PASS capabilities were included in Regulatory Guide 1.97, Instrumentation for Light-Water-Cooled Nuclear Power Plants To Assess Plant and Environs Conditions During and Following an Accident.
H The application was submitted by TXU Electric which transferred ownership and operating authority to TXU Generation Company LP on January 1, 2002, pursuant to an Order issued by the U. S. Nuclear Regulatory Commission (NRC) dated December 21, 2001. By letter dated January 2, 2002, TXU Generation Company LP adopted all applications previously submitted to the NRC by TXU Electric.
Significant improvements have been achieved since the TMI accident in the areas of understanding risks associated with nuclear plant operations and developing better strategies for managing the response to potentially severe accidents at nuclear plants. Recent insights about plant risks and alternate severe accident assessment tools have led the NRC staff to conclude that some TMI Action Plan items can be revised without reducing the ability of licensees to respond to severe accidents. The NRCs efforts to oversee the risks associated with nuclear technology more effectively and to eliminate undue regulatory costs to licensees have prompted the NRC to consider eliminating the requirements for PASS in TSs and other parts of the licensing bases of operating reactors.
The NRC staff has completed its review of the topical reports submitted by the Combustion Engineering Owners Group (CEOG) and the Westinghouse Owners Group (WOG) that proposed the elimination of PASS. The justifications for the proposed elimination of PASS requirements center on evaluations of the various radiological and chemical sampling and their potential usefulness in responding to a severe reactor accident or making decisions regarding actions to protect the public from possible releases of radioactive materials. As explained in more detail in the NRC staffs safety evaluations (SEs) for the two topical reports, the NRC staff has reviewed the available sources of information for use by decision-makers in developing protective action recommendations and assessing core damage. Based on this review, the NRC staff found that the information provided by PASS is either unnecessary or is effectively provided by other indications of process parameters or measurement of radiation levels. The NRC staff agrees, therefore, with the owners groups that licensees can remove the TS requirements for PASS, revise (as necessary) other elements of the licensing bases, and pursue possible design changes to alter or remove existing PASS equipment.
2.0 BACKGROUND
In a letter dated May 5, 1999 (as supplemented by letter dated April 14, 2000), the CEOG submitted the topical report CE NPSD-1157, Revision 1, Technical Justification for the Elimination of the Post-Accident Sampling System From the Plant Design and Licensing Bases for CEOG Utilities. A similar proposal was submitted on October 26, 1998 (as supplemented by letters dated April 28, 1999, April 10, and May 22, 2000), by the WOG in its topical report WCAP-14986, Post Accident Sampling System Requirements: A Technical Basis. The reports provided evaluations of the information obtained from PASS samples to determine the contribution of the information to plant safety and accident recovery. The reports considered the progression and consequences of core damage accidents and assessed the accident progression with respect to plant abnormal and emergency operating procedures, severe accident management guidance, and emergency plans. The reports provided the owners groups technical justifications for the elimination for the various PASS sampling requirements.
The specific samples and the NRC staffs findings are described in the following evaluation.
The NRC staff prepared this model SE relating to the elimination of requirements on post accident sampling and solicited public comment (65 FR 49271) in accordance with the consolidated line item improvement process (CLIIP). The use of the CLIIP in this matter is intended to help the NRC to efficiently process amendments that propose to remove the PASS requirements from TSs. Licensees of nuclear power reactors to which this model apply were informed (65 FR 65018) that they could request amendments confirming the applicability of the SE to their reactors and providing the requested plant-specific verifications and commitments.
3.0 EVALUATION The technical evaluations for the elimination of PASS sampling requirements are provided in the SEs dated May 16, 2000, for the CEOG topical report CE NPSD-1157 and June 14, 2000, for the WOG topical report WCAP-14986. The NRC staffs SEs approving the topical reports are located in the NRCs Agencywide Documents Access and Management System (ADAMS)
(Accession Numbers ML003715250 for CE NPSD-1157 and ML003723268 for WCAP-14986).
The ways in which the requirements and recommendations for PASS were incorporated into the licensing bases of commercial nuclear power plants varied as a function of when plants were licensed. Plants that were operating at the time of the TMI accident are likely to have been the subject of confirmatory orders that imposed the PASS functions described in NUREG-0737 as obligations. The issuance of plant specific amendments to adopt this change, which would remove PASS and related administrative controls from TS, supersede the PASS specific requirements imposed by post-TMI confirmatory orders.
As described in its SEs for the topical reports, the NRC staff finds that the following PASS sampling requirements may be eliminated for plants of Combustion Engineering and Westinghouse designs:
- 1. reactor coolant dissolved gases
- 4. reactor coolant pH
- 7. reactor coolant conductivity
- 8. reactor coolant radionuclides
- 9. containment atmosphere hydrogen concentration
- 10. containment oxygen
- 11. containment atmosphere radionuclides
- 12. containment sump pH
- 15. containment sump radionuclides The NRC staff agrees that sampling of radionuclides is not required to support emergency response decision-making during the initial phases of an accident because the information provided by PASS is either unnecessary or is effectively provided by other indications of process parameters or measurement of radiation levels. Therefore, it is not necessary to have dedicated equipment to obtain this sample in a prompt manner.
The NRC staff does, however, believe that there could be significant benefits to having information about the radionuclides existing post-accident in order to address public concerns and plan for long-term recovery operations. As stated in the SEs for the topical reports, the NRC staff has found that licensees could satisfy this function by developing contingency plans to describe existing sampling capabilities and what actions (e.g., assembling temporary shielding) may be necessary to obtain and analyze highly radioactive samples from the reactor coolant system (RCS), containment sump, and containment atmosphere. (See item 4.1 under
Licensee Verifications and Commitments.) These contingency plans must be available to be used by a licensee during an accident; however, these contingency plans do not have to be carried out in emergency plan drills or exercises. The contingency plans for obtaining samples from the RCS, containment sump, and containment atmosphere may also enable a licensee to derive information on parameters such as hydrogen concentrations in containment, and boron concentration and pH of water in the containment sump. The NRC staff considers the sampling of the containment sump to be potentially useful in confirming calculations of pH and boron concentrations, and confirming that potentially unaccounted for acid sources have been sufficiently neutralized. The use of the contingency plans for obtaining samples would depend on the plant conditions and the need for information by the decision-makers responsible for responding to the accident.
In addition, the NRC staff considers radionuclide sampling information to be useful in classifying certain types of events (such as a reactivity excursion or mechanical damage) that could cause fuel damage without having an indication of overheating on core exit thermocouples. However, the NRC staff agrees with the topical reports contentions that other indicators of failed fuel, such as letdown radiation monitors (or normal sampling system), can be correlated to the degree of failed fuel. (See item 4.2 under Licensee Verifications and Commitments.)
In lieu of the information that would have been obtained from PASS, the NRC staff believes that licensees should maintain or develop the capability to monitor radioactive iodines that have been released to offsite environs. Although this capability may not be needed to support the immediate protective action recommendations during an accident, the information would be useful for decision-makers trying to limit the publics ingestion of radioactive materials. (See item 4.3 under Licensee Verifications and Commitments.)
The NRC staff believes that the changes related to the elimination of PASS that are described in the topical reports, related SEs and this proposed change to TSs are unlikely to result in a decrease in the effectiveness of a licensees emergency plan. Each licensee, however, must evaluate possible changes to its emergency plan in accordance with 10 CFR 50.54(q) to determine if the change decreases the effectiveness of its site-specific plan. Evaluations and reporting of changes to emergency plans should be performed in accordance with applicable regulations and procedures.
The NRC staff notes that redundant, safety-grade, containment hydrogen concentration monitors are required by 10 CFR 50.44(b)(1), are addressed in Item II.F.1 of NUREG-0737 and Regulatory Guide 1.97, and are relied upon to meet the data reporting requirements of 10 CFR Part 50, Appendix E, Section VI.2.a.(i)(4). The NRC staff concludes that during the early phases of an accident, the safety-grade hydrogen monitors provide an adequate capability for monitoring containment hydrogen concentration. The NRC staff sees value in maintaining the capability to obtain grab samples for complementing the information from the hydrogen monitors in the long term (i.e., by confirming the indications from the monitors and providing hydrogen measurements for concentrations outside the range of the monitors). As previously mentioned, the licensees contingency plan (see item 4.1) for obtaining highly radioactive samples will include sampling of the containment atmosphere and may, if deemed necessary and practical by the appropriate decision-makers, be used to supplement the safety-related hydrogen monitors.
The TSs include an administrative requirement for a program to minimize to levels as low as practicable the leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident. The program includes preventive maintenance, periodic inspections, and leak tests for the identified systems. PASS is specifically listed in TS 5.5.2 as falling under the scope of this requirement. The applicability of this specification depends on whether or not PASS is maintained as a system that is a potential leakage path.
The licensee has stated that a plant change might be implemented such that PASS would not be a potential leakage path outside containment for highly radioactive fluids (e.g., the PASS piping that penetrates the containment might be cut and capped). The modification will not, however, be made during the implementation period for this amendment. The licensee has proposed to add the following phrase to the reference to PASS in TS 5.5.2:
...(until such time as a modification eliminates the PASS penetration as a potential leakage path).
The above phrase makes clear that TS 5.5.2 remains applicable to the PASS as long as it is a possible leakage path and reflects that the actual modification of the piping system may be scheduled beyond the implementation period for this amendment. Requirements in NRC regulations (10 CFR Part 50, Appendix J) and other TSs provide adequate regulatory controls over the licensees modification to eliminate PASS as a potential leakage path. Following the modification to eliminate PASS as a potential leakage path, the licensee may elect (in order to maintain clarity and simplicity of the requirement) to revise TS 5.5.2 to remove the reference to PASS, including the phrase added by this amendment.
The elimination of PASS affects the discussion in the Bases section for TS 3.3.3, Post Accident Monitoring Instrumentation. The current Bases mention the capabilities of PASS as part of the justification for allowing both hydrogen monitor channels to be out of service for a period of up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Although the licensees application included possible wording for the revised Bases discussion for TS 3.3.3, the licensee will formally address the change to the Bases in accordance with the Bases Control Program.
4.0 VERIFICATIONS AND COMMITMENTS As requested by the NRC staff in the notice of availability for this TS improvement, the licensee has addressed the following plant-specific verifications and commitments.
4.1 Each licensee should verify that it has, and make a regulatory commitment to maintain (or make a regulatory commitment to develop and maintain), contingency plans for obtaining and analyzing highly radioactive samples of reactor coolant, containment sump, and containment atmosphere.
The licensee has made a regulatory commitment to develop contingency plans for obtaining and analyzing highly radioactive samples from the RCS, containment sump, and containment atmosphere. The licensee has committed to maintain the contingency plans within its Radiological Emergency Response Plan or Chemistry Procedures. The licensee will implement this commitment by March 15, 2003.
4.2 Each licensee should verify that it has, and make a regulatory commitment to maintain (or make a regulatory commitment to develop and maintain), a capability for classifying fuel damage events at the Alert level threshold (typically this is 300 .Ci/ml dose equivalent iodine). This capability may utilize the normal sampling system and/or correlations of sampling or letdown line dose rates to coolant concentrations.
The licensee has made a regulatory commitment to develop a capability for classifying fuel damage events at the Alert level threshold. The licensee has committed to maintain the capability for the Alert classification within its Emergency Plan Implementing Procedures (EPIPs). The licensee will implement this commitment by March 15, 2003.
4.3 Each licensee should verify that it has, and make a regulatory commitment to maintain (or make a regulatory commitment to develop and maintain), the capability to monitor radioactive iodines that have been released to offsite environs.
The licensee has verified that it has the capability to monitor radioactive iodines that have been released to offsite environs. The licensee has committed to maintain the capability for monitoring iodines within its EPIPs. The licensee has implemented this commitment.
The NRC staff finds that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitments are provided by the licensees administrative processes, including its commitment management program.
Should the licensee choose to incorporate a regulatory commitment into the emergency plan, final safety analysis report, or other document with established regulatory controls, the associated regulations would define the appropriate change-control and reporting requirements.
The NRC staff has determined that the commitments do not warrant the creation of regulatory requirements which would require prior NRC approval of subsequent changes. The NRC staff has agreed that Nuclear Energy Institute (NEI) 99-04, Revision 0, Guidelines for Managing NRC Commitment Changes, provides reasonable guidance for the control of regulatory commitments made to the NRC staff. (See Regulatory Issue Summary 2000-17, Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff, dated September 21, 2000.) The commitments should be controlled in accordance with the industry guidance or comparable criteria employed by a specific licensee. The NRC staff may choose to verify the implementation and maintenance of these commitments in a future inspection or audit.
5.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Texas State official was notified of the proposed issuance of the amendments. The State official had no comments.
6.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no
significant hazards consideration, and there has been no public comment on such finding (citation and date). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
7.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: J. Lamb Date: January 15, 2002
Comanche Peak Steam Electric Station cc:
Senior Resident Inspector Jim Calloway U.S. Nuclear Regulatory Commission Public Utility Commission of Texas P. O. Box 2159 Electric Industry Analysis Glen Rose, TX 76403-2159 P. O. Box 13326 Austin, TX 78711-3326 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mr. Roger D. Walker Regulatory Affairs Manager TXU Generation Company LP P. O. Box 1002 Glen Rose, TX 76043 George L. Edgar, Esq.
Morgan, Lewis & Bockius 1800 M Street, N.W.
Washington, DC 20036-5869 Honorable Dale McPherson County Judge P. O. Box 851 Glen Rose, TX 76043 Office of the Governor ATTN: John Howard, Director Environmental and Natural Resources Policy P. O. Box 12428 Austin, TX 78711 Arthur C. Tate, Director Division of Compliance & Inspection Bureau of Radiation Control Texas Department of Health 1100 West 49th Street Austin, TX 78756-3189 April 2001