ML20134D655

Partial Response to FOIA Request for Documents Re H Denton, W Dircks & V Stello Correspondence Concerning Facility. Forwards App a Documents.Documents Also Available in Pdr. Search for Addl Documents Continuing

ML20134D655
Person / Time
Site:	Comanche Peak
Issue date:	07/24/1985
From:	Felton J NRC OFFICE OF ADMINISTRATION (ADM)
To:	Garde B GOVERNMENT ACCOUNTABILITY PROJECT
References
FOIA-85-491 NUDOCS 8508190313
Download: ML20134D655 (2)

Text

O 1MEc K)y) .

D oq'g

/ ~, UNITED STATES '-

8' o NUCLEAR REGULATORY COMMISSION

$ E WASHINGTON, D. C. 20555 o E

%...../

JUL24 W Ms. Billie Pirner Garde Citizens Clinic Director Government Accountability Project 1555 Connecticut Avenue, NW, Suite 200 IN RESPONSE REFER Washington, DC 20036 TO F01A-85-491

Dear Ms. Garde:

This is in partial response to your letter dated July 8,1985, in which you requested, pursuant to the Freedom of Information Act (F0IA), all records relevant to and/or generated in connection with all communications between Harold Denton, William Dircks, and Victor Stello regarding Comanche Peak.

The documents listed on enclosed Appendix A are being placed in the NRC Public Document Room (PDR) located at 1717 H Street, NW, Washington, DC, in file folder F01A-85-491 under your name.

The NRC has not completed its search for and review of additional records which may be subject to your request. We will comunicate with you again when search and review are complete. -

Sin ly, h

,2/ S,

, F lton, Director Division of Rules and Records Office of Administration

Enclosure:

As stated l

l l

8508190313 850724 PDR FOIA GARDE 85-491 PDR

l l

tl Re: F01A-85-491 APPENDIX A ,

DATE DOCUMENT DESCRIPTION PAGES

1. 12/24/84 Memorandum W. Dircks to Office Directors 7 and Regional Administrators regarding the " Formation of Panel to Prepare NRC l Staff Position on Comanche Peak Hearing

. Contention No. 5"

2. 12/24/84 Memorandum W. Dircks to Office Directors 6 and Regional Administrators regarding the

" Formation of Panel to Prepare NRC Staff Position on Intimidation at Comanche Peak."

3. 02/28/85 Memorandum W. Dircks to Office Directors 7 and Regional Administrators regarding

" Panel to Prepare NRC Staff Position on  :

Comanche Peak Contention No. 5." t

]

i i

I l

. .. . E-'N

/  %, UNITED STATES 8 o ' NUCLEAR REGULATORY COMMISSION i -I WASHINGTON D. C. 20555 k . . . ..a DEC 2 4 1984 j .

MEMORANDUM FOR: Those on Attached List \

l FROM: William J. Dircks Executive Director for Operations

SUBJECT:

FORMATION OF PANEL TO PREPARE NRC STAFF POSITION  :

ON COMANCHE PEAK HEARING CONTENTION NO. 5 i t

l The staff's fonnal positions on the Comanche Peak facility are nearing completion. The ASLB Hearings, which have been in progress for three years and are expected to resume in February 1985, have resolved all contentions except Contention No. 5. This contention concerns the Applicants' i adherence to QA/QC requirements and is provided as Enclosure 1. The issue of construction OA/QC at Comanche Peak is multi-faceted and is addressed, in part, by many records, documents and in testimony from various sources including the Staff, Applicants, Intervenors, and A11egers. The background of this contention and associated records span several years. Various NRC  ;

offices have been involved, including Region IV, 01, NRR, OELD and IE.  :

I' To properly evaluate this contention and to prepare a comprehensive staff position, I am directing the fonnation of a panel composed of senior managers drawn from your offices. This panel is to be composed of the following .$

individuals:

EdwardJordan.IE(Chairperson)

Richard Vollmer, NRR Alan Herdt, R-II Robert Warnick, R-III  ;

Roger Fortuna, 01 Because of their previous association with Comanche Peak regulatory l activities, I am appointing the following advisors to the panel: .j

!i Joe Scinto, OELD Vince Noonan, NRR Thomas Ippolito, AE00 James Gagliardo, IE Brooks Griffin, OI Dorvin Hunter, R-IV Bruce Kaplan, EG8G The advisors may occasionally be asked to assist the panel when issues involving their specific area of expertise are being considered, and I reouest your support in making them available on an "as-needed basis.

PoIA-BE-49 b l

./-

l.

Those on Attached List The product of the Panel's effort will be a report similar to a $$ER, that states clear staff conclusions regarding this Contention. Enclosure 2 provides the outline of a Charter for this Panel. As the first order of ,

business, the Panel will develop a working Charter which shall be submitted for my approval.

The scheduled completion of the Panel's action is January 31, 1985. I expect the Panel to establish its own schedule, consistent with the resumption of the hearing process. Enclosure 3 provides a proposed milestone sumary.

The Panel will work under the direction of Vincent S. Noonan, Director of Comanche Peak Project, and should provide periodic status briefings to the Director of Licensing.

Isissse William J.airste William J. Dircks Executive Director for Operations

Enclosures:

As stated (

cc: B. Hayes, 01 Panel Members Panel Advisors q

)istribution: i kcket File [

EDO Reading S. Treby B. Youngblood 1 T. Novak -

l S. Burwell '

I

• See attached concurrence sheets

)FC :TRT :PD:TRT :DIR:DL :0 ELD :DEPDIR:NRR :DIR:NRR :EDO 4AME RWessman:pf*:VNoonan * :DEEisenhul :JScinto * :ECase *

HRDenton * :WJ ircks Y

) ATE 212/13/84 :12/13/84 :12/17/84 :12/17/84 t

12/17/84 :12/18/84 :12NI/84 l

, OFFICIAL RECORD COPY

1

. i i

O Addressees List:

Harold R. Denton, Director Office of Nuclear Reactor Regulation Richard C. DeYoung. Director Office of Inspection and Enforcement Guy H. Cunningham, III Executive Legal Director Jack Heltemes, Director Office of the Analysis and Evaluation of Operational Data .

i James P. O'Reilly, Regional Administrator Region II i l

James Keppler, Regional Administrator Region III Robert Martin, Regional Administrator Region IV ,

[l

}

.. L i

ENCLOSURE 1 COMANCHE PEAK CONTENTION 5*

Contention 5. The Applicants' failure to adhere to the quality assurance /

quality control provisions required by the construction permits for Comanche i

Peak, Units 1 and 2, and the requirements of Appendix B of 10 CFR Part 50, and the construction practices employed, specifically in regard to concrete work, mortar blocks, steel, fracture toughness testing, expansion joints, placement of the reactor vessel for Unit 2, welding, inspection and testing, materials used, craft labor qualifications and working conditions (as they may affect QA/QC, and training and organization of QA/QC personnel, have raised substantial questions as to the adequacy of the construction of the facility.

As a result, the Connission cannot make the findings required by 10 CFR 50.57(a) necessary for issuance of an operating license for Comanche Peak.

(CFUR4A-ACORN 14-CASE 19JOINTContention) i b

f fl l

h n

l!

4 l

1 1

• Reproduced from Board Order Subsequent to the Pre-hearing Conference of April 30, 1980 (dated June 16,1980)

l

(

ENCLOSURE 2 COMANCHE PEAK CONTENTION 5 PANEL CHARTER OBJECTIVES

1) To make the staff detemination regarding the Applicants' adherence to the QA/QC requirements described in Contention 5.

2) Provide a report to management reflecting the panel's determination.

3) Provide panel testimony before the Comanche Peak ASLB.

PURPOSE The purpose of this Panel is to integrate the views and experience of senior ;

NRC managers to yield a staff detemination regarding Contention 5. t MEMBERSHIP Nelson Grace IE (Chairperson)

Richard Vollmer, NRR Edward Jordan. IE Robert Warnick, R-III Alan Herdt, R-II '

Roger Fortuna, 01 Advisors o

Joe Scinto, OELD I Vince Noonan, NRR Thomas Ippolito, AE00 James Gagliardo, IE Brooks Griffin, OI Dorwin Hunter, R-IV Bruce Kaplan, EG8G f

i l

ll

)

I

2 ACTION ITEMS '

t

1) Define criteria for judging the adequacy of the Applicants' adherence to the QA/QC requirements described in Contention 5.

2) Conduct a records review. The Panel members should examine and analyze the following records.

a. CAT Report #

b. CYGNA Reports

c. Hearing Records /Sumary Depositions  !

d. O! Reports

e. Enforcement Actions

f. SALP Reports l' g. Reg. IV Inspection Reports

h. TRT Reports -

1. Special Review Team Report i

l i

To make the workload manageable, sumaries of records or briefings to the panel by key individuals associated and familiar with the records may be requested.

3) Routinely interface with the Comanche Peak Intimidation Panel and consider input provided by that Panel. '

a

4) For each type of records (a.-i.) the team members will prepare a i

sumary of findings highlighting problem areas and root causes, as e related to Contention #5.

5) The panel, as a body, will consider the finding sumaries, briefings provided by key NRC personnel, and other relevant information to develop the staff position on Contention #5 in the format of an SSER.

6) The panel will be required as necessary to provide both written and  !

oral testimony before the ASLB.

a  ;

i 4

i y -- _ .- m 2.- .. -s y - .. ,w _., , . - ,,.ym ,..m-,. .- y.., ,

.. !f

)

ENCLOSURE 3 CONTENTION 5 PANEL SCHEDULE December January P

Initial Panel Meeting Obtain relevant documents ,

Document Reviews Consolidate Individual (Developed hy Panel, consistent views, Develop Panel with resumption of hearings at consensus the end of January 1985) l Prepare Panel Report Report Staff Position to Management r Prepare Testimony for ASLB ,

t f

I cu > >

/ 'o,

, UNITED STATES

! n NUCLEAR REGULATORY COMMISSION '

i, h k W ASHINGTON, D. C. 20555 I

S.,

• • • • • , f DEC 2 41984  :

)

l MEMORANDUM FOR: Those on Attached List '

FROM: William J. Dircks Executive Director for Operations

SUBJECT:

FORMATION OF PANEL TO PREPARE NRC STAFF POSITION ON INTIMIDATION AT COMANCHE PEAK As the work of the Comanche Peak Technical Review Team (TRT) is nearing completion, the staff must evaluate all issues involving intimidation and .

harassment at Comanche Peak. The ASLB hearings, which have been in progress for three years and are expected to resume in February 1985, have resolved all contentions except Contention No. 5. This contention concerns the ,

Applicant's adherence to QA/QC requirements. As part of developing the staff position on this Contention, the staff must evaluate whether intimidation or harassment against employees or contractors occurred in the past or is now occurring, and make a detemination concerning the effects of any such intimidation on the overall QA/QC Program at Comanche Peak. i.'

L To properly evaluate the intimidation issue and to prepare a comprehensive ,

staff position, I am directing the fomation of a panel, composed of senior managers individuals:drawn from your offices. This panel is to be composed of the following s

JamesGagliardo.IE(Chairperson)

Jane Axelrad. IE James Lieberman, DELD Dorwin Hunter, Region IV i 0,

Because of their previous association with Comanche Peak regulatory  !

activities, I am appointing the following individuals as advisors to the panel: .

Brooks Griffin, OI Thomas Ippolito, AEOD ,

Joseph Scinto, OELD Vincent Noonan, NRR Bruce Kaplan, EG&G i The advisors may be asked to assist the panel when issues involving their i specific area of expertise are being considered, and I request your support in  !

making them available on an "as-needed" basis.

The product of the Panel's effort will be a report similar to a SSER, that states clear staff conclusions rega, ding the occurrence of intimida-tion and harassment at Comanche Peak. The Charter for this Panel is provided h as Enclosure 1. The Charter provides the scope and objectives of the Panel but allows sufficient flexibility to enable the Panel to expand its scope, if Dl

• i I

Those on Attached List 1 The scheduled completion of the Panel's action is January 31, 1985. I expect the Panel to meet at least once per week and more frequently, if necessary.

Enclosure 3 provides a proposed milestone schedule. '

The Panel will work under the direction of Vincent S. Noonan Director of Comanche Peak Project, and should provide periodic status briefings to i the Director of Licensing.

F7:N.'.2:: J. .'..: s William J. Dircks Executive Director for Operations i

Enclosures:

As stated  !

cc: B. Hayes, OI DISTRIBUTION:

f Panel Members r Advisors i Docket File 50-445/446 EDO Reading .

S. Treby B. Youngblood T. Novak S. Burwell l I

CPTRT '

JGagliardo i 1

12/ /84 *See attached concurrence sheet  !

• • Nonconcurrence per Axelrad and Lieberman #

.FC :TRT :PD:TRT :DIR:DL :0 ELD :DEPDIR:NRR :DIR:NRR AME . . :RWessman:pf*:VNoonan

. : . . . . . . . . . . . . : *. . . . . . . . . . . . : . . . . . . . . . . . . : . . . . . . . . . . . . : .: . ..... ... ._ . . . . . . : .y . . . . .

DGEisenhut* :JLiebernarf*:ECase* :HRDentorf W OTE . . :12/13/84

. . . _ _ _ :12/. . . 1384

12/17/84 :12/ /84 :12/17/84 :12/18/84 :12////84 0FFICIAL RECOR) COPY i

i Addressees List:

Harold R. Denton, Director Office of Nuclear Reactor Regulation Richard C. DeYoung, Director Office of Inspection and Enforcement Guy H. Cunningham, III, Executive Legal Director Jack Heltemes, Director ~

Office of the Analysis and Evaluation of Operational Data .

James Keppler, Regional Administrator Region III Robert Martin, Regional Administrator Region IV 0

ENCLOSURE 1 1

Comanche Peak Intimidation Panel Charter

.1 OBJECTIVES: '

l The objectives of the pinel are:

1) To determine whether intimidation or harassment against employees or l contractors occurred in the past or is now occurring at Comanche Peak;

2) To determine the extent of the above conditions if they exist (ed) and to identify the circumstances surrounding the events including the personnel involved, the duration, the reasons for its occurrence and the applicant's management corrective actions or recommendations for correc-tive actions.

3) To evaluate any other indicators of poor management practices or attitude toward the identification and correction of quality problems.

PURPOSE:

The panel will provide as products: J

1) A position on the intimidation question to NRC upper management;

2) Input to the Comanche Peak Contention 5 Panel. The Contention 5 Panel will determine the effects of any intimidation on the overall QA/QC Program at Comanche Peak.

MEMBERSHIP:

James Gagliardo, IE (Chairperson)

Jane Axelrad, IE James Liebennan, DELD Dorwin Hunter, Region IV BruceKaplan,EG&G(Advisor)

Brooks Griffin, 01 (Advisor)

ThomasIppolito,AEOD(Advisor)

Joseph Scinto, OELD (Advisor Vincent Noonan NRR (Advisor i

i

-1P' +7 * ~ ~ # '" '" * #

ACTION ITEMS 1. Define criteria for determining whether intimidation or harassment occurred.

2. Conduct as appropriate a review of relevant data bases:

a. EGEG report on intimidation (9/84)

b. Transcript of EG&G Intimidation Study Team briefing of i NRC, applicant's, and intervenor's lawyers

c. Enforcement packages related to intimidation.

d. Depositions related to intimidation and harassment. (A sumary will be sought or prepared as required)

e. Proposed Findings on intimidation (staff, applicants and intervenors).

f. Transcripts of current ASLB hearings related to intimidation.

g. Office of Investigations reports on intimidation and status of '

outstanding allegations. (8. Griffin should provide briefing on theabove) l

,i

h. Infomation on Department of Labor Hearings related to the subjects of concern.

3. Interface with CP Contention 5 Panel routinely.

4. Based on the above data and any other relevant data reviewed by the 1 l

panel, develop a position which meets the stated objectives. '

5. Prepare an SSER on intimidation, and provide testimony as required at ASLB hearings.

L

,,, ,- ,--w, ~ -

3 2

\

ENCLOSURE 2 Intimidation Panel Schedule December January Initial Panel Meeting Obtain relevant documents i Document Reviews Consolidate Individual (Developed by Panel, consistent views, Develop Fare' with resumption of hearings at consensus the end of January 1985) v Prepare Panel Input to QA/QC Panel f Prepare Panel Report on Staff's Position i

. T

. - h4 p

[~\e UNITED STATES NUCLEAR REGULATORY COMMISSION i

g

.) wanworow, o. c. rosss

\....*/

FEB 2 81985 [

MEMORANDUM FOR: Those on Attached List  !

FROM: William J. Dircks Executive Director for Operations !l

'l

SUBJECT:

PANEL TO PREPARE NRC STAFF POSITION ON COMANCHE PEAK '

HEARING CONTENTION NO. 5 On December 24, 1984, I established the subject panel and provided initial guidance regarding its charter. Since that time, the charter and the panel composition have been clarified to reflect a broader range of expertise and to accomodate agency priorities. This memorandum reflects the panel's ,

charter and changes.

i To properly assist the Director, Comanche Peak Project in evaluating Contention 5 and to assist him in the preparation of a comprehensive staff position on Contention 5 a panel composed of senior managers has been formed. The panel is composed of the following individuals: j-EdwardJordan,IE(Chairperson)

Richard Vollmer, IE ,.

Alan Herdt, R-II L Robert Warnick, R-III James Sniezek, DEDROGR Ashok Thadani, NRR ,

This contention concerns the applicant's adherence to QA/QC requirements and is provided as Enclosure 1. The issue of construction QA/QC at Comanche Peak i is multifaceted and is addressed, in part, by many records, documents and in i testimony from various sources including the staff, applicant, intervenor, and allegers. The background of this contention and associated records span several years. Various NRC offices have been involved, including Region IV, ,

01, NRR, OELD and IE. Because of their involvement with Comanche Peak regu-latory activities. I am appointing the following personnel as resource support to the panel in their areas of expertise:

Joe Scinto, OELD Vince Noonan, NRR Thomas Ippolito, AEOD

• James Gagliardo IE Brooks Griffin, OI Dorwin Hunter, R-IV Chet Poslusny, NRR*

Ted Sullivan, NRR*

?

• Administrative and technical support as requested by Panel Chairman N, ';' t i d

I 1

! I 1:

l 1

These individuals may be asked to assist in this effort when issues involving their specific area of expertise are being considered, and I request your support in making them available on an "as-needed" basis.

h n

The product of this effort will be the assistance to the Director, Comanche Peak Project, in preparing a position that integrates the staff findings and (

conclusions regarding this Contention. In addition this effort may require 1 panel members, or the panel as a whole, to be prepared to testify concerning panel reconmendations in support of the staff position on Contention 5 as identified by the Director, Comanche Peak Project. Enclosure 2 provides the charter for the panel.

The work schedule of the panel as developed by the Director, Comanche Peak j Project is to be consistent with the hearing schedule and shall be closely a coordinated with ELD. '

The panel will work under the direction of Vincent S. Noonan, Director, 4 Comanche Peak Project, and should provide periodic status briefings to the Deputy Director NRR. ,

l lSignesWillian j. Birth 1

William J. Dircks i Executive Director for Operations

Enclosures:

As stated f

cc: Panel Members Panel Resource Personnel T. Murley j J. Martin '

Distribution I l

WJDircks i EJordan i DEisenhut EDO Reading File Central File CPTRTReadingFile(Annette) ,

'} ,

FC :IE :CPP/DIR :MRR :NRR/DIR :EDO .1t/#:  :

....:............:...__.......:............:............:.....W.J....:............:........-..

IAME :EJordan l

VSNoonan :DGEisenhut :HDenton :WJDircks  :  :

....:............:............:............:............:x.m......:............:...........

LATE : 2 #2 /85  : 2 # 2 /85  : 2/ 2f85 :2 h5/85 :W// //85  :  :

0FFICIAl. RECORD COPY

I l

ADDRESSEES FOR MEMORANDUM DATED ns a a 25 Victor Stello, Jr, DEDROGR i Harold R. Denton, NRR .

James Taylor IE  :'

Guy H. Cunningham, III, ELD Clemens J. Heltemes, AEOD Nelson Grace, RII James Keppler, RIII Robert Martin, RIV Ben Hayes. OI 4

i r

i 1

I I

i h

1 l

i 1

l i,

ENCLOSURE 1 COMANCHE PEAK CONTENTION 5* ,

I Contention 5. The Applicants' failure to adhere to the quality assurance / ,

quality control provisions required by the construction permits for Comanche j Peak, Units 1 and 2, and the requirements of Appendix B of 10 CFR Part 50, and i the construction practices employed, specifically in regard to concrete work, mortar blocks, steel, fracture toughness testing, expansion joints, placement of the reactor vessel for Unit 2, welding, inspection and testing, materials used, craft labor qualifications and working conditions (as they may affect QA/QC) and training and organization of QA/QC personnel, have raised substantial questions as to the adequacy of the construction of the facility. As a result, .

the Commission cannot make the findings required by 10 CFR 50.57(a) necessary for issuance of an operating license for Comanche Peak.

(CFUR 4A-ACORN 14-CASE 19 JOINT Contention) 1 l

i l

l l

e

, N I

I

• Reproduced from Board Order Subsequent to the Prehearing Conference of l April 30, 1980 (dated June 16,1980) i L

ENCLOSURE 2 COMANCHE PEAK CONTENTION 5 PANEL CHARTER I. PURPOSE j The purpose of this panel is to assist the Director, Comanche Peak  !

Project, to evaluate in an integrated manner the information developed ;l by the staff which bears upon QA/QC and overall plant quality. The objectives are:

'! 1 1

A. To assist the Director, Comanche Peak Project to make the staff determination regarding the findings required by 10 CFR 50.57(a) l as related to Contention 5.

B. To provide an integrated review and feedback to the Director,  !

Comanche Peak Project, on information bearing on Conter. tion 5 along with the identification of problem areas and appropriate recomendations for NRC actions or proposed solutions.

C. To be prepared to testify as needed individually or as a panel, concerning panel recomendations in support of the staff position .[

on Contention 5 as identified by the Director.

II. MEMBERSHIP

]

Edward Jordan IE (Chairperson)

Richard Vollmer IE l Alan Herdt, R-II '

Robert Warnick, R-III l James Sniezek, DEDROGR Ashok Thadani NRR l III. PANEL SCOPE  !

A. Under the guidance of the Director, Comanche Peak Project the panel shall become familiar with and consider findings of past and current NRC staff activities and applicant actions in response to NRC findings as they relate to the matters addressed in i Contention 5. Specifically, the panel shall consider the results of:

1) Region IV inspections

2) CAT inspections

l u

3 OI investigations y 4 Technical Review Team inspections [

5 Enforcement actions t 6 Special Review Team inspection 7 SALP reports [

8 Staff analysis of CYGNA Report 9 Staff sumary of the Hearing Record Additionally, the panel may examine the result of other staff activities which may bear on their findings related to Contention 5 i if directed to do so.  !

B. The Director, Comanche Peak Project will arrange for staff members -

to brief the panel on findings related to Contention 5. The Director will also set up meetings with the intervenor and the '

applicant to discuss matters which they respectively believe are most significant as related to Contention 5. Any such meetings will be open to the public. The panel should properly characterize the collective concerns raised by the staff, intervenor and applicant and review / comment on the applicants plan to address these concerns. The panel should then advise the Director, Comanche Peak Project on its recomendations.

C. During conduct of panel activities, the panel should advise the Director, Comanche Peak Project of areas where it appears additional NRC activity may be warranted in order to address the issues raised in Contention 5.

IV. PANEL OPERATING PROCEDURES 1

A. Panel meetings will be held as established by the Chairperson. The '

Director, Comanche Peak Project will arrange all meetings with the applicant, intervenor or allegers. Meetings with NRC staff and staff consultants shall be considered predecisional.

B. A quorum for conduct of panel business will consist of four members.

In the temporary absence of the Chairperson, the Chairperson may designate an acting Chairperson.

C. Briefings by the principal NRC reviewers in each of the areas identi-fied in Section III.A will be obtained. Reviewers will sumarize the scope of their reviews, deficiencies noted, root causes of such deficiencies and applicant corrective actions. Likewise, the reviewers are to discuss those areas where no deficiencies were found.

D. The panel should analyze the infomation presented by NRC reviewers contained in source documents which the panel reviews, obtained by discussions with the applicant, intervenor and staff and observed during site reviews in arriving at its recomendations regarding Contention 5 and should continually provide feedback to the '

Director, Comanche Peak Project.

i l

- - . - . _ - . . .-.._._~....,.___.__._m

s . . . .

E. The panel should keep apprised of the ongoing agency activities related to Contention 5 and promptly identify conflicts or problems to the Director, Comanche Peak Project.

V. RECORD AND REPORTING A. The panel will work under the direction of Vincent S. Noonan, Director of the Comanche Peak Project, and should provide periodic status briefings to the Deputy Director, NRR.

B. The panel shall keep such records of activities to assist it in arriving at recomendations regarding Contention 5, as requested by the Director. Such records shall be considered predecisional until staff testimony regarding Contention 5 is provided to the ,

Hearing Board.

l 1

f

- - -