ML20049K084
| ML20049K084 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 03/23/1982 |
| From: | Rozzell S BAKER & BOTTS, HOUSTON LIGHTING & POWER CO. |
| To: | DOHERTY, J.F. |
| References | |
| NUDOCS 8203290389 | |
| Download: ML20049K084 (26) | |
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'y pr25 "O 77 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY & LICENSING BOARD In the Matter of 5
5 HOUSTON LIGHTING & POWER COMPANY Docket No. 50-46 f3]
[k (Allens Creek Nuclear Generating
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ANSWERS AND OBJECTIONS TO s
DOHERTY'S THIRD SET OF INTERROGATORIES
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In response to a document entitled "Intervenors.2 j Doherty's Third Set of Interrogatories to Applicant With Regard to TexPirg Contention 31 and Quadrex Matters", Applicant answers and objects as set forth below.
As stated in response to Mr. Doherty's First Set of Interrogatories, Mr.
J. H.
Goldberg, Vice President - Nuclear Engineering and Construction will testify regarding the pertinence of Quadrex Corporation's review of engineering work at the South Texas Nuclear Project to the Allens Creek Nuclear Generating Station.
Mr. Louis J.
Sas, Vice President - Engineering with Ebasco, will testify' regarding Ebasco's engineering organization for the Allens Creek Nuclear Generating Station.
Initially Applicant notes that it has objected to E
a number of the interrogatories in this Third Set because f I they are irrelevant to the limited issue to be heard in the 8203290389 820323 DRADOCK05000ggg
reopened proceeding pursuant to the Board's Order of January 28, 1982.
For example, many of Mr. Doherty's interrogatories are directed at exploring either the details of design of the STP or the Quadrex evaluation of specific Brown & Root engineering practices -- matters which are beyond the scope of the Board's Order.
Questions concerning whether the STP is being safely designed and constructed are before the STP Board, which has deferred consideration of all Quadrex related issues until ongoing reviews of the Quadrex Report by the Applicant and the NRC Staff are completed late this year.
The Board's Order did not admit these STP-specific matters for litigation in this proceeding.
Rather, the limited issue to be explored in this reopened proceeding is how the Quadrex Report, and specifically the matters labelled (A) through (0) in Doherty's December 7, 1981 motion, reflect upon the technical qualifications of HL&P to oversee the design and construction of the ACNGS.
While Applicant has objected to a number of such interrogatories, it has also l
answered some interrogatories of questionable relevance.
Applicant's decision to answer such interrogatories should not be taken as conceding their relevance to this reopened l
proceeding.
On the contrary, Applicant maintains that the vast majority of the hundreds of obscure and pointless interrogatories contained in the six sets of interrogatories I
-__---m.
s i
thus far received from Mr. Doherty are not relevant to the I
reopened Allens Creek proceeding.
Moreover, in answering any questions hereinafter, Applicant does not admit the t
accuracy or relevance of any assumptions made by Mr. Doherty in posing such questions.
1NTERROGATORY NO. 1 Sec. 3.l(f) of the Report states in part, "For i
I Exarcple numerous differences were observed between EDS l
practices and the FSAR promises."
l (a)
Did Quadrex provide a list of these numerous differences?
If so, please provide it in your reply.
(b)
Is EDS a separate company from B&R?
(c)
When was EDS first employed by Applicant?
ANSWER 1(a). Quadrex provided no explanation beyond that which is contained in its report.
1(b). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
4
4 t-1(c). Applicant objects to this interrogatory on the ground that the information sought is not relevant to j
the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on'exPirg Additional Contention 31).
T INTERROGATORY No. 2 Has Quadrex provided Applicant additional infor-mation on its finding in Se. 3.l(f), "One group conspicuous by its absence during this design review program was Licensing.
No evidence was found of an effective Licensing Group. input to the various disciplines to assure consistency in under-standing an implementation of NRC requirements?"
(a)
What were the responsibilities of " Licensing" in the design process?
(b)
What steps did Applicant establish prior to Quadrex to insure that this Brown & Root group did its work properly?
(c)
What has Applicant determined to have been the reason that within its own organization it did not detect that the Brown & Root licensing group was " con-spicuous by its absence", or otherwise not accomplishing its duties.. _.
ANSWER 2.
Quadrex provided no explanation beyond that which is contained in its report.
2(a).
The Licensing Group was responsible for the reviews necessary to assure Brown & Root's overall compliaace with STP licensing commitments and applicable regulatory requirements.
In this capacity their duties included overall Project coordination of preparation and maintenance of SARs and ERs, responses to NRC questions as well as Inspection and Enforcement (I&E) concerns, review of design documents for licensing consistency and review of safety concerns.
The Licensing Group also reviewed design changes against licensing commitments and the preparation of FSAR change notices which are sent to HL&P for approval.
Among the Licensing Group's other duties following submittal of the FSAR in May 1978 was review of all responses prepared by Westinghouse to NRC questions.
The Licensing Group also had an ongoing program to review engineering documents for consistency with licensing commitments.
In addition, ths Group evaluated newly released regulatory material and distributed it to the applicable disciplines; e.g.,
it automatically reviewed all newly __
released regulatory guides and transmitted this information to the appropriate disciplines and to HL&P.
2(b). HL&P Project Licensing interfaced with Brown &
Root Licensing, routinely working with that group on the development of solutions to problems, the evaluation of new criteria, and the review of Brown & Root recommendations for SAR changes.
HL&P Project Engineering provided programmatic direction and overview of Brown & Root engineering activities, including Licensing, to ensure that such activities were conducted in accordance with approved engineering procedures.
HL&P Engineering performed reviews of selected elements of the completed design, design documents and specifications to ensure that contractual requirements were met.
In addition HL&P QA audited Brown & Root engineering activities to verify compliance with the QA Program.
2(c). Applicant has made no such determination, nor has Applicant made a determination that the Brown & Root Licensing Group was not accomplishing its duties.
INTERROGATORY NO. 3 In Sec. 3.l(f) of the Reoort (p. 3-8) the Quadrex reviewer mentions that there was no evidence of an effective means to secure a timely NRC review for changes in the FSAR.
Wouldn't the Applicant be the entity in contact with the NRC for that?
ANSWER 3.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 4 With reference to Question E-5, Quadrex Assessment stated in its opinion that Westinghouse should review all issued design revisions for the Essential Safety Features (ESF) sequencer.
(a)
Was Applicant aware prior to Quadrex that Westinghouse was not?
(b)
What is the current industry practice on review of issued design revisions to safety systems?
(c)
What will Applicant's position on this be for safety systems at ACNGS?
ANSWER 4(a). Applicant objects to this interrogatory on I
the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and i l
Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
4(b). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
4(c). General Electric reviews safety-related design revisions as required by PSAR Sections 17.1.3A, 17.1.5A, and 17.1.6A and Ebasco procedures.
INTERROGATORY NO. 5 What are the professional qualifications of D. G.
Scapini, of Quadrex?
ANSWER 5.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 6 Did Applicant consider it desirable that B&R adopt a consistent requirement for design margin?
(See:
- Recort, Sec. 3.1(g), p. 3-10)
(a)
Referring to Question C-12, what is Applicant's belief as to why B&R had reinforced the inside face of the containment adjacent to the liner as stated in the "Quadrex Assessment"?
(b)
What group within Applicant's organization would oversee design margins for HVAC?
(See Question H-8)
(c)
Does Applicant agree with the Quadrex Assess-ment on this Question?
ANSWER 6.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's Janu ry 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
6(a). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
6(b). HL&P Project Engineering.
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6(c). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 7 What are the personal qualifications of Ram Bhat of Quadrex?
ANSWER 7.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 8 l
l In Sec. 3.l(g) of the Report, at p.
3-10, it states design manual or individual engineer log-books to record key bases, assumptions or decisions are especially crucial for the first designed plant for an architect-l engineer.
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(a)
Prior to start of construction, was Applicant informed this would be Applican.t's procedure?
(b)
Will this be the procedure at ACNGS?
(c)
Did Applicant ever suggest these manuals or log-books prior to Quadrex?
If so, when, and to what B&R groups?
ANSWER 8(a). Applicant objects to this interrogatory on the ground that the informatian sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence.on TexPirg Additional Contention 31).
ACNGS is not the first nuclear plant to be designed by Ebasco.
e Moreover, Applicant objects to this interrogatory on the ground that it is unduly vague and Applicant cannot determine what information is sought.
Applicant further objects to this interrogatory on the ground that the effort and expense required to search HL&P files for such information and to otherwise search for the information sought would constitute an undue and unwarranted burden on Applicant.
8(b). Applicant objects to this interrogatory for the reasons stated in the response to Interrogatory 8(a).
J _
8(c). Applicant objects to this interrogatory for the reasons stated in the response to Interrogatory 8(a).
INTERROGATORY NO. 9 What was the reason Applicant did not cause B&R to do a failure mode and effects analysis (FMEA) as required by the NRC on the ESF?
(Question E-8)
ANSWER 9.
Applicant objects to this interrogatory on the ground that the information sought concerns a design detail of STP and is not therefore relevant to the limited issues in this reopened proceeding as identified in the Lscensing Board's January 28, 1982 Memorandum and Order (GrantingTheDohertyRenewedMotionForAdditionalhvidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 10 What was the reason Applicant did not require B&R to provide an acceptance criteria for the 'eliability for the ESF sequencer?
(See:
Question E-8, Report)
ANSWER 10.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to l
the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31'). _
INTERROGATORY NO. 11 Referring to Sec. 3.l(j), what has applicant determined to be the reason B&R had not made its 1976 pipe rupture report a control document for the STNP design?
ANSWER 11.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 12 What did Quadrex mean by, "For ESF system components, this situation is not adequate?"
(Report, Sec. 3.1(j)(2))
(a)
What is the IVC?
(b)
Have the AEW pump motors been purchased for either STNP unit?
(c)
Have the AFW pump motors been installed in l
either STNP unit?
(d)
What organizational features of the Applicant I
will prevent recurrence of the selection of pump motors which may not be qualified for postulated accident l
environments at ACNGS which were not present at the
l STNP?
(Note:
this question refers to differences in Applicant's organizations for STNP evidently prior to Quadrex, and ACNGS in the future)
ANSWER 12.
Quadrex gave no further explanation beyond that which is contained in the report.
12(a). Isolation Valve Cubicle.
12(b). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
12(c). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
12(d). As described in PSAR Section 17.1.3A, HL&P Project Engineering provides programmatic direction and overview of Ebasco engineering activities to ensure that such activities are conducted in accordance with approved
- i
engineering procedures.
HL&P Engineering performs reviews of selected elements of the completed design, design documents and specifications to ensure that contractual requirements are met.
As stated in PSAR Section 17.1.18A HL&P QA audits Ebasco activities to verify compliance with the QA Program.
In addition, the HL&P Engineering Assurance Department will review selected elements of the design for technical adequacy.
INTERROGATORY NO. 13 Prior to Quadrex had Applicant noted that the use by EDS Company of a jet surface with 10 half-angle cone might not be consistent with industry practice?
If so, what was done to bring this to EDS attention?
(See:
Question M-4 (EDS))
ANSWER 13.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memerandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
Applicant further objects to this interrogatory on the ground that the effort and expense required to search HL&P files for such information and to otherwise search for the information sought would constitute an undue and unwarranted burden on Applicant..
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INTERROGATORY NO. 14 What steps did Applicant take to be sure EDS company performed a design review (design verification) of preliminary loads transmitted to B&R, used as a basis for plant design?
(Question M-8 (EDS))
ANSWER 14.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
Applicant further objects to this interrogatory on the ground that the effort and expense required to search HL&P files for such information and to otherwise search for the information sought would constitute an undue and unwarranted burden on Applicant.
l INTERROCATORY NO. 15 l
Would Applicant's QA/QC have been in a position to be certain the pipe rupture loadings supplied by EDS to B&R l
would be applied in other than the vertical direction?
l (See:
Quadrex Assessment, Question C-4, Report) l l
(a)
Did this Applicant know B&R had used the EDS loadings contrary to EDS instructions?
(b)
Does Applicant believe the Quadrex Assessment on this question accurate?
ANSWER 15.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
15(a). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
Applicant further objects to this interrogatory on the ground that the effort and expense required to search HL&P files for such information and to otherwise search for the information sought would constitute an undue and unwarranted burden on Applicant.
15(b). Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 16 What are the personal qualifications of R.
- Koppe, of Quadrex Corp.?
ANSWER 16.
Applicant objects to this interrogatory on the ground that the information sought is not relevant.to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
INTERROGATORY NO. 17 Referring to Interrogatory 15, above, how does Applicant anticipate being able to prevent a recurrence of this failure to follow instructions?
ANSWER 17.
Without conceding any failure on STP, as described in PSAR Section 17.1.3A, HL&P Project Engineering provides programmatic direction and overview of Ebasco.
engineering activities to ensure that such activities are conducted in accordance with approved engineering procedures.
HL&P Engineering performs reviews of selected elements of the completed design, design documents and specifications to ensure that contractual requirements are met.
As stated in PSAR Section 17.1.18A HL&P QA audits Ebasco activities to verify compliance with the QA Program.
In addition, the HL&P Engineering Assurance Department will review selected elements of the design for technical adequacy.
INTERROGATORY NO. 18 Referring to Question M-19, was Applicant aware of any engineering significance to out-of-plane loading in pipe whip, prior to Quadrex?
(a)
Prior to Quadrex did Applicant attempt to appraise either EDS or B&R of this facet of pipe con-struction?
(b)
What facet of Applicant QA/QC will examine Ebasco work in this area at ACNGS?
(c)
What is the basis for believing Applicant will not inadvertently permit the same omission?
ANSWER 18.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified..
in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
Applicant further objects to this interrogatory on the ground that the effort and expense required to search HL&P files for such information and to otherwise search for the information sought would constitute an undue and unwarranted burden on Applicant.
18(a).
Applicant objects to this interrogatory for the reasons stated in Interrogatory 18.
18(b).
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
18(c).
Applicant objects to this interrogatory for the reason stated in the response to Interrogatory 18(b).
INTERROGATORY NO. 19 What is the disagreement as to the requirement to l
meet superpipe stress limits mentioned in Question M-9, and adverted to in Recort, Sec. 4.5.2.1(d),
p.
4-39?
I
ANSWER 19.
Quadrex provided no explanation beyond that which is contained in the report.
INTERROGATORY NO. 20 What completed pipe rupture analysia outside containment analysis had B&R accomplished prior to termination on the project?
Any?
(See:
Sec.
4.5.3, p. 4-41, Report)
ANSWER 20.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
Applicant further objects to this interrogatory on the ground that the effort and expense required to search HL&P files for such information and to otherwise search for the information sought would constitute an undue and unwarranted burden on Applicant.
INTERROGATORY NO. 21 l
What awareness did Applicant have that B&R had no TRD to identify the essential components of potential targets in the pipe rupture scope?
See:
Sec. 4.5.3.l?
, t
ANSWER 21.
Applicant objects to this interrogatory on the ground that the information sought is not relevant to the limited issues in this reopened proceeding as identified in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
Applicant further objects to this interrogatory on the ground that the effort and expense required to search HL&P files for such information and to otherwise search for the infor-mation sought would constitute an undue and unwarranted burden on Applicant.
INTERROGATORY NO. 22 What purchased equipment may be unsuitable due to lack of pipe rupture analysis?
(See:
Recort, Question M-25, Quadrex Assessment)
ANSWER 22.
Applicant objects to this interrogatory on i
the ground that the information sought is not relevant to l
the limited issues in this reopened proceeding as identified l
in the Licensing Board's January 28, 1982 Memorandum and Order (Granting The Doherty Renewed Motion For Additional Evidence on TexPirg Additional Contention 31).
Applicant l
j l t
further objects to this interrogatory on the ground that the effort and expense required to search HL&P files for such information and to otherwise search for the infor-mation sought would constitute an undue and unwarranted burden on Applicant.
Respectfully submitted, OF COUNSEL:
A Tf^
J.
Gregory Copeland BAKER & BOTTS Scott E.
Rozzell 3000 One Shell Plaza 3000 One Shell Plaza 4
Houston, Texas 77002 Houston, Texas 77002 LOWENSTEIN, NEWMAN, Jack R.
Newman REIS & AXELRAD Alvin H.
Gutterman 1025 Connecticut Ave.,
N.W.
David B.
Raskin Washington, D.C.
20036 1025 Connecticut Ave., N.W.
Washington, D.C.
20036 ATTORNEYS FOR APPLICANT HOUSTON LIGHTING & POWER COMPANY.
STATE OF TEXAS COUNTY OF HARRIS S
BEFORE ME, the undersigned authority, on this day personally appeared J.
H. Goldberg, Vice President - Nuclear Engineering & Construction for Houston Lighting & Power Company, who upon his oath stated that the foregoing answers to "Intervenor Doherty's Third Set of Interrogatories Re Quadrex" were prepared under his supervision and direction, and that all statements contained therein are true and correct to the best of his knowledge and belief.
/J.
H. Goldberg SUBSCRIBED AND SWORN TO BEFORE ME by the said J. H. Goldberg, on thise23ad day of March, 1982.
crui. bcd/LIr Ngftary Public, State of Texas My Commission Expires G-S-fY_
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S
S HOUSTON LIGHTING & POWER COMPANY S
Docket No. 50-466 S
(Allens Creek Nuclear Generating S
Station, Unit 1)
S CERTIFICATE OF SERVICE I hereby certify that copies of the Applicant's Answers to Doherty's Third Set of Interrogatories Re Quadrex in the above-captioned proceeding were served on the following by deposit in the United States mail, postage prepaid, or by hand-delivery this 23rd day of March, 1982.
Sheldon J. Wolfe, Esq., Chairman Hon. Charles J. Dusek Atomic Safety and Licensing Mayor, City of Wallis Board Panel P. O. Box 312 U.S. Nuclear Regulatory Commission Wallis, Texas 77485 Washington, D.
C.
20555 Hon. Leroy H. Grebe Dr.
E.
Leonard Cheatum County Judge, Austin County Route 3, Box 350A P. O.
Box 99 Watkinsville, Georgia 30677 Bellville, Texas 77418 Mr. Gustave A. Linenberger Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D. C.
20555 Washington, D. C.
20555 Susan Plettman Richard Black David Preister Staff Counsel Texas Attorney General's Office U.S. Nuclear Regulatory P.
O. Box 12548, Capitol Station Commission Austin, T;xas 78711 Washington, D. C.
20555 l
l
Bryan L. Baker Brenda McCorkle 1118 Montrose 6140 Darnell Houston, Texas 77019 Houston, Texas 77074 J. Morgan Bishop W. Matthew Perrenod 11418 Oak Spring 4070 Merrick Houston, Texas 77043 Houston, Texas 77025 Stephen A. Doggett Wayne E. Rentfro P.
O. Box 592 P. O. Box 1335 Rosenberg, Texas 77471 Rosenberg, Texas 77471 John F.
Doherty William Schuessler 4327 Alconbury 5810 Darnell Houston, Texas 77021 Houston, Texas 77074 Carro Hinderstein James M.
Scott 723 Main, Suite 500 13935 Ivy Mount Houston, Texas 77002 Sugar Land, Texas 77478 D. Marrack 420 Mulberry Lane Bellaire, Texas 77401
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I Scott E.
Rozzell
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