ML20116D294
| ML20116D294 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/25/1985 |
| From: | Sinkin L Citizens Concerned About Nuclear Power, INC. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20116D285 | List: |
| References | |
| NUDOCS 8504290361 | |
| Download: ML20116D294 (31) | |
Text
_
e UNITED STATES OF.MERICA 4/25/85 prvrirD
!!UCLEAR REGULATORY COMMISSION Ulj@lc" BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
(
'85 APR 26 P3:22
)
HOUSTON LIGHTING AND
(
Docket Nos. 50-498 0 _._ _,
brNibu>[cfNh" POWER COMPANY, ET AL.
)
50-499 0 (South Texas Project,
(
gagj Units 3 and 2)
(
Citizens Concerned About Nuclear Power (CCANP)
Regggese tg Anglicge.ts god Sigif "Mgtigns ign Sugegny Disagsitign I.
Background
Issue B
in Phase I of this operating license proceeding addressed whether HL&P has taken sufficient remedi al steps to provide assurance that it now has the managerial competence and character to operate the South Texas Nuclear Project safely.
In its Partial Initial Decision issued on March 14, 1984 (LBP-84-13, 19 NRC 659),
the Board found that the record was insufficient to allow the Board to determine whether HL&P possessed sufficient managerial competence to narrant the issuance of an operating license.
PID at 55.
This was so in large part because HL&P hcd replaced its original architect / engineer / construction manager / constructor /DA/DC, E&R, with two other companies, Bechtel and Ebasco. shortly before t7e close of the Phase I record.
Since the Phase I record could not reflect the performance of Applicants,
- Bechtel, and Ebasco working together, the Board required the Staff to issue a report concerning the performance of Applicants and their main contractors since the close of the Phase I
record.
Id.
at 56.
Other parties were extended an invitation to comment on the Staff's report or file reports of their own. Id. at 57.
In the PID, the Bocrd ntated that the Staff report was "to 8504290361 850425 PDR ADOCK 05000498 1
0 PDR
4 8
be presented during the Phase I evidentiary hearings." Id. at 56.
Subsequently, the Board changed the procedure to treat the Staff affidavit as a basis for deciding "whether there existed any factual questions upon which an evidentiary hearing would be appropriate."
Fifth Prehearing Conference Order dated November 16, 1984 at 3.
The Staff filed its report in the form of an affidavit on December 21, 1984.
Applicants and CCANP filed their responsive affidavits on February 25, 1985.
On April 5,
- 1985, the ASLB issued its Nemorandum and Order (Telephone Conference Call of April 4,
1985). [ Hereinafter " April 5 Order] In said Order, the ASLB ruled that the affidavits filed by Applicants and Staff regarding the performance of Applicants and their contractors would be " treated as motions for summary disposition" pursuant to 10 C.F.F.
Section 2.749.
CCANP herein responds to the Staff and Applicant
" motions for nummary disposition."
II. Introduction The first question to be addressed is what issue (s) the affidavits filed by the Staff and Applicants seek to dispose of through a summary procedure.
In its April 5
- Order, the Board identifies the motions as relevant to Issues B and D in this proceeding. April 5 Order at 3.
Issue B states:
"Has HLLP taken sufficient remedial steps to provide assurance that it now has the managerial competence and character to operate STP safely?"
2
B 0
Issue D states in relevant part:
"In light of HL&P's prior performance in the construction of the STP do the current
[Bechtel/Ebasco]
construction OA/DC organizations and practices meet the requirements of 10 CFR Part 50, Appendi:' B: and is there reasonable assurance that they will be implemented so that construction of STP can be completed in conformance with the construction permit and other applicable requirements?"
The Board appears to further narrow the issues to encompass only the competence aspect of Issue B, excluding the character aspect.
April 5 Order at 2.
Presumably, then, Issue B as regards the character of Applicants remains an issue not addressed by summary disposition motions
- and, therefore, subject to presentation of any relevant and material evidence in Phase II.
Indeed, the Board has already accepted various matters to be heard relevant to the character issue in Phase II. See tiemorandum and Order (Phase II Hearings on Quadre::-Report Issues),
LDP-85-6 dated February 26, 1985 [ Hereinafter February 26, Order] at 17-19, 23, 24.
At the same time, these observations on the applicability of summary disposition to the character issue apply equally well to the applicability of summary disposition to the competence issue (B) and the OA/DC issue (D).
To avoid summary disposition, the Board states that "CCANP will have to identify specific significant material facts in controvers; facts which would undermine the conclusions reached by the Applicants or Staff in their affidavits or tend to demonstrate a lack of competence of HLSP or its contractors in implementing the OA/DC program for construction." April 5 Order at 5-6.
In its February 26 Order, the Board delineated various matters to be heard relevant to the competence issue in Phase II.
O
e s
February 26 Order at 19-20, 23,
- 24. These matters clearly " tend to demonstrate a lack of Ecurrent] competence," April 5 Order at 6,
in that HLt
; B, Cr'i ter i on V -- the condition of the hardware reflects a lack of competence, and -- the absence of a specification to protect the hardware represents a failure to implement an effective quality assurance program. 3. I&E 83-03 records that there was no hold point for DC inspection on bending of anchor bolts. This open item was closed by addition of an inspection point in the procedure. See I&E 83-11. CCANP contends that: -- NRC erred in not issuing a violation in that this finding represents a violation of Appendix B, Criterion X and -- this episode clearly represents an abuse of the "open item" system since no further information was required to know that the absence of a hold point was unacceptable. -- the absence of the procedure evidences weakness in the QA/DC program implementation. 4. ILE S3-11-01 records that computer print outs identifying maintenance which had not been performed in a timely fashion were not transmitted to the field personnel responsible for maintenance. This open item was closed by addition of a procedure to 15 transmit the print outs to the field personnel. See I&E 83-18. CCANP contends that the absence of this procedure reflects adversely on the competence of Applicants. 5. I&E 83-15-02 records an absence of a procedure to govern i QC marking of materi als received on site. This open item is closed out by adoption of a new procedure to require DC inspection and verification of such materials prior to marking.-Sep I&E 83-24. CCANP contends that: -- NRC erred in not issuing a violation in that this i finding represents a violation of Appendix B, Criterion X and -- this episode clearly represents an abuse of the "open item" system since no further information was required to j know that the absence of a procedure was unacceptable. -- the absence of such a procedure evidences a poorly 4 implemented quality assurance program. 6. I&E 83-15-04 records that quality control records were under the control of construction. This open item was closed by returning control of the weld data cards to QC. Egg ILE 83-21 i CCANP contends that: -- NRC erred in not issuing a violation in that this finding represents a violation of Appendix B, Criterion XVII and -- this episode clearly represents an abuse.of the j "open item" system since no further information was required to l know that qual i ty records in control of construction was i unacceptable. -- construction controlling quality records in clear l f 16 i' w s i i 1 J j evidence of a disfunctional DA/DC program. i '7. ILE 84-03-02 records that quality records have been i l placed in the document room used for litigation, a room not i qualified to store quality records. HLLP was apparently unaware that some of the records could be the only available record l I because it assumed if such records were not originals, then they i l were not the only available record. In fact, for thousands of quality records no original exists. This open item is closed out by the return of the quality documents to the plant GA vault. Up to CO,000 records are removed. f, CCANP contends that l -- NRC erred in not issuing a violation in that this 1 j finding represents a violation of Appendix D, Criterion XVII, [ -- this episode clearly represents an abuse of the i i "open item" system since no further information was required to t i know that removal of quality records to an unqualified storage I l place was unacceptable. I -- HLLP put its litigation needs ahead of assuring the I j oreservation of quality records for STNP, I -- the fact that destruction of said records could have { i i placed the operating license at entreme risk demonstrates gross [ l j negligence on the part of Applicants, i i -- not recogni:ing the possibility that a copy might be f i l the only avail abl e
- record, despite knowing of the long and l
l troubled history of document control on this
- project, I
demonstrates incompetence on the part of Applicants, and i -- the removal of the records and the fact that no one j stopped their removal evidences a nonfunctioning quality I l l 17 l l l l l l assurance program. I l This sample of closed It<E open items demonstrates again that l l there are numerous significant material facts in controversy j I which meet the criteria set forth by the Board for deafeating summary disposition. l l CCANP contends that the above comple creates a material l issue of fact as to whether every item opened and then closed l since the close of the record in Phase I reflects a lack of I i Applicant competence and/or a failure to implement an effective I quality ascurance program. C. NRC/ Applicant Affidavits l 1. 10 C.F.C. 50.55(E) - The Staff affidavit does not upecifically address the Applicants' 50.55(e) performance during I l the time period in question. There is a reference to " positive l l l indications of improvement in the functional area of corrective l l ection and reporting," Staf f Af f. 424, but nowhere does the Staff l conclude Applicants' 50.55(e) program in aduquate. Applicants cita Staff #24 and the SALP report to tupport f their position that their 50.55(e) program is adequate. App. Aff.
- 15.
I CCANP contendu that challenges to the adequacy of this prop-am are found in the followings i ? a. Item A.1 above at page 6 reviews an episode where a f 50.5'(n) notification was clearly called for because design J drawings were being reviced without DA review but no 50.55(n) t report was made when the CAR was issued or subsequently. [ l b. Item A.5 ebove at page 9 reviews an episode where a j i l t l 19 l l i 50.55(e) notification was clearly called for but not made until more than two weeks later. c. It<E 80-12 records that an HL&P procurement document aucit found significant deficiencies (10/02). Deficient documents were corrected but no analysis was done to see if the prnblem was generic. A later audit (4/83) found the same problem and noted the repetition. Yet no 50.55(e) notification was forthcoming from the Applicants. HLLP said Bechtel was responsible, but HL&P audits had provided enough information to proceed with a 50.55(e) had HL&P upper management bothered to review the OA audits for their substance. d. On one occasion, NRC di scovered that a consultant 's report had improperly failed to identify deficiencinc in a vendor program. The inspector concluded that "[13f the NRC incpector had f not identified this deficiency, apparently 02DG9Df9CmlD9 Ek 91Y CEldD!d 2iCM219Lel 51221 J9.1. Dig would have romained 109tgilgd at STP." (emphasis added) The NRC further found that "Ci3f the question of Lightening the high strength bolts had not been raiund by the NRC inspector, ibHCR b2Wld bevP bfED AD VDOGGORifbl? 1021A11811902 DBDRd 90 90 1DG9CCRGA dRM190 dCEW109." (emphasis added) a drawing that had been released for construction. Dotpite thoco quito onplicit hinte from the incpector, App 11 canto failed to file 6 50.55(e) notification on the incpector's findings. o. On more than one occacion, NRC han found that a GO.55(o) report was closed by HLLP and that now evidenco showud the report should not have been cloued but HL!,P did not act to reopen the 50.55(o). 19 ... - ~ -.-.., _ ) i E I i l For
- example, in ILE 83-02, the NRC found so many
- errors, q
discrepancies, etc. in the anchor bolt verification program that NRC cuestioned "the acceptability of the licensee's anchor bolt intergrity verification program performed to resolve a 50.55(e) reportable deficiency." But HLLP refused to take the hint and i reopen the 50.55(e) in question. l l In ILE 83-08, NRC reviewed a report prepared for BOR by a j 3 consultant on a matter where a 50.55(e) had been reported and i closed out baced on HLLP's intention to have the independent j j verification done by the consultant. The NRC review revealed that f l the consultant's report was inadequate to cloce out the 50. 55 (e), j i i but HLLP once again did not reopen the 50.55(e) report. L In-83-16, NRC discovered that the consultant's review in a j fact did not e> tamine the vendor QA programs in question. NRC i-later concluded that "Cc3uch an evaluation and audit provides i t
- little, if any, asuurance of material delivered to STP," Sgg ILE i
I IEC 03-20.
- BLR, Dechtel, and HLLP all failed to detect the j
consultant's " error." (It appears that the consultant may have j done o>: ac tl y what HLLP asked to be done.) In spite of this additional discovery about thu consultant *c report, the 50.55(e) l was not reopened. I l f. $ce A.9 at page 6-7 above. 4 l
- o. Egg D.1 at page 25 below.
t h. See D.2 at page 25-26 below. 1 I i 2. Noticos of Violation j I j Staff affidavit #19 states that in recponse to NRC noticos i { of violation the " licensee has acted promptly on each of these i and the resporite appear to be adequate with regard to correctivo l s J 20 l I l actions and recurrence controls." ;,gg glgg App. Aff. #16. a. ILE 33-02 dated May 18, 1980 contains a notice of violation regarding the retrieval of records. On July 18,
- 1983, NPC rejected as inadequate part of HLLP's June 16, 1983 response to this NOV.
A major issue of contention was HLLP's inability to find certain documents and the importance of those documents. In the Applicants' rejected response, George Oprea statest "The red-lined drowings referred to were gggd cg gett Of Abf DC9G925 Of d91EC910109 bb1Mb b9115 09kld b9 19519d4 kW1 09E9 091 09GQsE2C11y ysgd 19 idg0ttiy tbg 19GA1190 91 lb9 h911a $b31 09tg iggggg." (emphasis added) The NRC rejected this charactcritation of the redlined drawings, citina the BLR TRD, which had already been cited in ILE C 3-r.C. On September 19, 1983, Applicantr. again tricd to respond to the NOV and again NRC rejected their response. In this latest I t tter. Oprea states: "OE ELOLEQ LO 9MC OCLGLOLL E9E90Eg to the notice of violation, the red-lined drawingt were in-procesc, nonpermanent documents 10tgodqd 19 GMid9 09CE90091 19 19Get1909 of A0Gb9c b9tta " (emphasis added) The NRC responded on October 1, 1930 by ctating1 "The DLR redlined drawings ucce thg only dgqymgetetLgn m of the anchor bol t population considered by DbR for dimensional verification." (caphasic added) Over roughly a five month period, Applicanto recponded to a notico of violation first by ignoring information provided in the l NOV and mirrepresenting the importance of c r i t i c til documente. 4' l hpplicants then misrepresented their original re:ponso while still downplaying the significance of the documents. Applicants n< a d e these reuponues rather than admit they could not find tho 21 l 1 critical documents and go forward with alternative appropriate corrective action. NRC had to state three times that the documents-were critical. This episode undermines the conclusions noted above reached by the Staff and Applicants and creates a genuine issue of fact as to the adequacy of Applicants' responses to NOVs. b. I&E 83-13 dated December 5, 1983 contains a notice of violation regarding record retention. On January 1, 1984, HLLP responded to the NOV by saying the records could still not be located, but they might be in the record backfit process. This response simply means HL&P had no retrievable index for records in the backfit program. hardly an adequate renolution of the NOV. Applicants also failed to identify the need for such an inden as part of a recurrence control corrective action in responne to the NOV. c. ILE 83-22 dated January 5, 1984 contains two notices of violation regarding failure to take corrective action. The cover letter from the NRC states: "The failure of management and the quality assurance programs of Houston Lighting and Power, Drown &
- Root, Dechtel Power Corporation, and Ebasco Services, Inc. to i
identify and correct nonconforming problems indicates l poscible significant weaknesses in the quality assurance program i mpl einentati on and management involvement at the South Tenas Project." On February 2,
- 1984, HLLP responded by abandoning any 1
further attempts, even with Bechtel and Ebasco in place, to. carry 1 l out the safety related activity in question (on site fabrication } of anchor bolts). The tone of the response is decidedly snide i i ("To preclude further dissertations on this subject ") in the i 22 x fact of a stern admonishment from NRC regarding OA implementation and management involvement. As a parting shot, HL&P criticizes the NRC NOV claiming HL&P's methods were acceptable. On March 23, 1984, NRC responded by advising Applicants that a consulting expert to NRC " emphatically" rejected Applicants' claim. While abandoning efforts to perform a safety related task could be considered a "resclution" of an
- NOV, it is hardly available on a regul ar basis.
Furthermore, abandoning this task to an outside contractor reduces the level of Applicant oversight on a task known to be difficult to control for quality. The likelihood of recurrence is increased, not reduced. The above response examined represent 30% of all Applicant responses to NOVs and create a significant question of fact regarding the promptness and adequacy of Applicants' responses to NOVs. 5. Upper Management Involvement Staff affidavit #38 states that: "HLLP has demonstrated excellent involvement in both transition and restart activities. HL&P has also adopted a progressively more aggressive approach to dealing with quality-related issues since mid-1982. This appears to coincide with the addition of new experienced nuclear people in management positions at the corporate level and on-site. Certain I:ey personnel uere shifted within the licensee organi:ation, greatly enhanting the positive attitude and direct management involvement at STP. These changes have also resulted in greated licensee involvement in the construction and quali~ty aspects of the project." a Staff affidavit C19 states in part: i "The licensee has adopted a progressively more aggressive approach to dealing with qulaity-related issues since mid-1902. This appears to coincide with 23 5 ':.I i \\" the addition of new people in management positions at the corporate level and on-site. Certain key personnel were shifted within the licepsee organization, greatly enhancing the positive attitude and direct management involvement at STP. These changes have also resulted in greater licensee involvement in the construction and quality aspects of the project." ggg glac App. Aff. #5 - 12 CCANP contends that the record of the project reviewed in this response so far contradicts the conclusions contained in the .y. sabove referenced statements. As further evidence undermining these conclusions, CCANP point to I&E 83-12 at 11 which states that HL&P upper management does not review OA audi ts f or substance. This finding sounds very much like the abdication of responsibility found in HL&P prior to the Orde to show cause, contradicts the idea of management involvement in quality aspects of the project, and undermines in general the concit1sions noted above. s The same I&E report noteds that HL&P leaves it up to Bechtel to review NCR's for possible 50.55(e) notification (whi l e insisting HL&P be permitted to screen such determinations, Sgg I&E 82-10 at 5). This abdication of responsibility again has a familiar ring to it. Ii 4. SAFETEAM The Staff affidavit describes the " Safe Team" at STNP but offers no opinion as to its adequacy. Staff Aff. #20. Apparently, NRC now refers at least some allegations to this team to investigate, rather than conducting its own investigations. Staff Aff. #21; App. Aff. #17 (1 ). Applicants describe and characterize the efforts of the 24 + SAFETEAM. App. Aff. 17-20. SAFETEAM was created in October 1984, after the close of discovery for Phase II. The records of SAFETEAM investigations are not provided to the PDR by NRC or Applicants. (There is a short NRC letter dated August 27, 1984 which may refer to a particular SAFETEAM investigation into possible falsified
- records, but the letter does not identify the team and was written before the SAFETEAM existed.)
Comgare App. Aff.
- 17 (1) (d). Without discovery or access to public documentation of the efforts of this group, CCANP cannot offer any response to Applicant /NRC affidavits on this subject, other than to express a concern that the NRC may be abdicating its responsibility to conduct investigations to Applicants.
5. Allegations of Unjust Termination Staff affidavit #21 notes that on at least one occasion NRC received an allegation of termination for engaging in protected activities. (The original Staff affidavit #21 showed two such incidents but in the corrected version the " Terminated for Bad Attitude" item was dropped though the text below still says "allegers.") There is no I&E report available on this incident or these incidents. It appears NRC may have abdicated its responsibility to investigate such cases to DOL or OSHA. 6. SALP Report The Staff affidavit finds no difference between the most recent SALP and the one issued two years earlier. Staff Aff. #22. Applicants' affidavit highlights the favorable ratings by combining them. App. Aff. #15. 25 But a closer reading of the SALP reveals that the 1 ratings were given in areas of very limited work (piping), limited NRC review (electrical), and minimal NRC Staff interaction (li censi ng). On the other
- hand, the 3 ratings are in areas where historically there was a concern about poor performance (soi l s and foundations, corrective action, and material control) and where currently tasks are major and critical (corrective action and mat er i al control).
That the NRC believes that if the Applicants take corrective action "we could e::pec t to see improvement in these Ethree3 areas" is little more than a tautology. The NRC has already seen such hopes dashed on numerous previous occasions. 7. NRC Oversight Despite the NRC Staff performing an in depth QA/QC inspection for each incremental construction activity prior to its restart," Staff Aff.
- 30, NRC still had to write an NOV on Applicants' concrete pour on the Unit 1 containment dome. See I&E 83-11-01.
There is only so much NRC can do to cover for Applicants incompetence. D. Response to ILE Bulletins 1. In response to IEB 80-19, HL&P stated on August 26, 1980, that a review by HLLP found no usage of a certain type of relay e at STNP. Then on July 1,
- 1983, a relay of just that type caused problems during seismic testing.
On August 3, 1983, Applicants sent a letter to NRC amending 26 _, _, - ~ their original IEB response to note the use of such relays and their planned replacement. Obviously, the transition team cannot find every mistake HLbP made in the past. Had the seismic test not triggered the fault in the relay, the faulty relay might still be in place despite the IEB. There is no record of a 50.55(e) notification regarding Applicants' failure to identify suspect material pursuant to an IEB. 2. In response to IEB 83-06, Applicants stated to the NRC that no Tube-Line material for safety related word was used at STNP. In ILE 84-12, an NRC inspector reviewed the documents relevant to IEB 83-06 and discovered safety-related Tube-Line material was used at STNP. Apparently Applicants are still making the same mistakes in 1983. Furthermore, the package reviewed by NRC had already been reviewed by
- Bechtel, so apparently the addition of Bechtel to the project is no help in this area.
- Finally, there is no record of any 50.55(e) reports being filed regarding Applicant twice failing to identify suspect material pursuant to an IEB.
E. Generic Issues A review of the I&E files shows that lack of vendor controls and problems surrounding anchor bolts appear and persist throughout the ILE history sicne the close of Phase I. Both of these problems reflect adversely on Applicants' competence and their QA/DC program. 27 4 IV. Conclusion This response to Applicant /NRC " motions for summary disposition" clearly demonstrates that the genuine issues of fact regarding Applicants' competence and the adequacy of Applicants' OA/DC program are numerous and significant. The motions for summary d i sposi t i on shoul d, therefore, be denied. Applicants should be required to go forward with meeting their burden of proof on these issues and CCANP should have full rights to cross examine and introduce evidence. Respectfully submitted, e /' sk. Lanny Sinkin Representative for Intervenor, Citizens Concerned About Nuclear Power, Inc. 3022 Porter St., N.W.
- 304 Washington, D.C.
20008 (202) 966-1241 Dated: April 25, 1985 Washington, D.C. l l l I 28 m UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ( ) HOUSTON LIGHTING AND ( Docket Nos. 50-498 OL POWER COMPANY, ET AL. ) 50-499 OL (South Texas Project, ( Units 1 and 2) ( MATERIAL FACTS AS TO WHICH THERE IS A ENUINE ISSUE IO BE HEARD Pursuant to 10 C.F.R. Section 2.749(a), CCANP hereby submits, in conjunction with its Response to Applicants and Staff Mot i on s for Summarv Disposition," a statement of material facts as to which there is a genuine issue of fact. (1) There are numerous and significant material issues of fact regarding the competence of Applicants. Among such items are: -- all open I&E items since the close of the Phase I record, particularly those discussed in the attached Motion at items III.A.1-8,10,12, -- all closed I&E items since the close of the Phase I
- record, particularly those discussed in the attached Motion at l
l items III.B.1,2,4,7, and ( -- other significant items discussed in the attached motion, particularly III.C.1.c,d,e,g,h; III.C.2.b,c; III.C.3; III.C.6; III,D.1,2 4 (2) There are numerous and significant material issues of fact regarding the adequacy of the current OA/DC program implementation at STNP. Among such items are: -- all open I&E items since the close of the Phase I record, I i 1 particularly those discussed in the attached Motion at items III.A.1-12, -- all closed I&E items since the close of the Phase I
- record, particularly those discussed in the attached Motion at items III.B.1,2,3,5,6,7 and
-- other significant items discussed in the attached motion, particularly III.C.1.a-h; III.C.2.a-c; III.C.3; III.C.6; III,D.1,2 l l 2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICEN3ING BOARD CCD.ETE UShRC In the Matter of ( 50-TUS EB 26 P3:23 HOUSTON LIGHTING AND ( Docket Nos. POWER COMPANY, ET AL. ) 50-499 OL (South Texas Project, ( GFFU P E 'l it Units 1 and 2) ( 00CKEIWG & SEPYIU BRANCH CESI1EIC6IE OE _CESVICE I hereby certify that copies of CCANP MOTION TO FILE CCANP
RESPONSE
TO APPLICANTS AND STAFF
" MOTIONS FOR
SUMMARY
DISPOSITION" OUT OF TIME and of CCANP RESPONSE TO APPLICANTS AND STAFF
" MOTIONS FOR
SUMMARY
DISPOSITION" were served by hand delivery
(*)
or deposit in the U.S.
- Mail, first class postage paid to the following individuals and entities on the 25th day of April 1985.
- Charles Bechhoefer, Esquire Brian Berwick, Esquire Chairman Asst. Atty. Gen.
Atomic Safety and Licensing Board State of Texas U.S.
Nuclear Regulatory Commission Environmtl. Protection Washington, D.C.
20555 P.
O.
Box 12548, Capitol Sta.
- Dr.
James C.
Lamb, III Administrative Judge
- Oreste Ress Pirfo. Esquire 313 Woodhaven Road Office of the Exec. Leg. Dir.
Chapel Hill, North Carolina 27514 U.S.
Nuclear Regulatory Comm.
D.C.
20555
- Ernest E.
Hill Administrative Judge
- Jack R.
Newman, Esquire Hill Associates 1615 L Street, NW, Suite 1000 210 Montego Drive Washington, D.C.
20036 Dan vi l l e,,
California 94526 Melbert Scnwarz, Esquire Baker and Botts Mrs. Peggy Buchorn 300 One Shell Plaza Executive Director, C.E.U.
Houston, Texas 77002 Route 1,
Box 1684 Brazorta, Texas 77422
- Atomic Safety and Licensing Ed.
U.S.
Nuclear Regulatory Comm.
William S.
Jordan, III, Esq.
Washington, D.C.
2055S Harmon, Weiss & Jordan 2001 S Street, N.W.,
Suite 430
- Atomic Safety and Licensing Washington, D.C.
20009 Appeal Board U.S.
Nuclear Regulatory Comm.
Pat Coy Washington, D.C.
20555 i
5106 Casa Oro l
San Antonio, Texas 78233
- Docketing and Service Section Office of the Secretary Ray Goldstein U.S.
Nuclear Regulatory Comm.
1001 Vaughn Bldg.
Washington, D.C.
20555 l
807 Brazos l
_ dhy.f h ___________
Lan y E)nkin l