ML20137A797

Amended Responses to Intervenor First & Second Set of Interrogatories.Certificate of Svc Encl.Related Correspondence

ML20137A797
Person / Time
Site:	Braidwood
Issue date:	01/09/1986
From:	Kruse G COMMONWEALTH EDISON CO., ISHAM, LINCOLN & BEALE
To:	Guild R BUSINESS & PROFESSIONAL PEOPLE FOR THE PUBLIC INTERES
References
CON-#186-725 OL, NUDOCS 8601140545
Download: ML20137A797 (20)

Text

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ISHAM, LINCOW&BEALE "" "*D h l- ,

j- COUNSELORS AT pW; ,

• ""M"2t'.D" c, All 53

romaos esmu. wm "O 8'8 "*** wasmaronomer i Eu EsTrY4 2 E E 0FFICE OF $ECntjAn - E

• ^5"S'o" " C 8""

00CMETING & SEFVla " " ~ *

• Jan M W H9, 1986 1

Robert Guild, Esq.

BPI 109 North Dearborn Street Suite 1300 Chicago, Illinois 60602 Re: In the Matter of: Commonwealth Edison Company (Braidwood Station, Units 1 and 2)~ Docket Nos. 50-456 and 50-457 OL

Dear Mr. Guild:

, Pursuant to its obligations under 10 C.F.R. 52.740 (e) ,

Commonwealth Edison Company is amending the following responses to Intervenors' First and Second Sets of Interrogatories:

l. Response to contention item 10.F contained in Applicants' response to interrogatories 58 and 59 of Intervenors' First Set of Q.A. Interrogatories which was

filed in Applicants' sixth partial response dated August 27, 1985.

2. Revised' response to contention item 3.C. contained

. in Applicants' response to interrogatories 58 and 59 of-4 Intervenors' First Set of Q.A. Interrogatories which was l filed by letter to Intervenors dated October 15, 1985.

3. Response to interrogatory 6 of Intervenors' Second Set of Q.A. Interrogatories as-it relates to the Level I Reverification Program which was filed in Applicants' second partial response dated November'22, 1985.

Enclosed with this letter are amended versions of the above referenced responses to Intervenors' interrogatories along with supporting affidavit. The amendments being made with this filing are indicated by underlining inserted material and striking-out deleted material. In addition, these responses incorporate all changes which have been made by prior filings.

l 8601140545 860109 Truly yours, i FDR ADOCK 05000456 G PDR 1/J G GAK:cg G . Kruse .

Enclosure cc: Attached Service List

, , . - - - - , ,, _ . - ,# ,, . , , , .m. .-r,,. . - , , ..~-,-=.-.-._.,_ - , -. --.. -

, Herbert Gr6:sman, Ecq., Chairman Dr. Richard F. Cole

(

t Administettivo Law Judg3 Administrativo Law Judgs Atomic Safety and Licensing Board Atomic Safety and Licensing Board

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission I Washington, DC 20555 Washington, DC 20555 Dr. A. Dixon Callihan Administrative Law Judge 102 Oak Lane Oak Ridge, TN 37830 Mr. William L. Clements Ms. Bridget Little Rorem Chief Docketing and Services 117 North Linden Street 4

United States Buclear Regulatory P.O. Box 208 Commission Essex, IL 60935 office of the Secretary Washington, DC 20555 Stuart Treby, Esq. William Little i Elaine I. Chan, Esq. Director of Braidwood Project

. Office of the Executive Legal Region III i Director United States Regulatory Commission United States Nuclear Regulatory 799 Roosevelt Road Commission Glen Ellyn, IL 60137 Washington, DC 20555 Atomic Safety and Licensing Charles Jones, Director i

Board Panel Illinois Emergency Services United States Nuclear Regulatory and Disaster Agency l

Commission 110 East Adams Washington, DC 20555 Springfield, IL 62705 Atomic Safety and Licensing Jan Stevens Appeal Board Panel United States Nuclear Regulatory United States Nuclear Regulatory Commission Commission 7920 Norfolk Avenue Washington, DC 20555 Phillips Building Bethesda, ND 20014

• Robert Guild George L. Edgar Douglass W. Cassel, Jr. Thomas A. Schmutz Timothy W. Wright, III Newman & Holtsinger, P.C.

BPI 1615 L Street, N.W.

109 North Dearborn Street Suite 1000 Suite 1300 Washington, D.C. 20036 Chicago, IL 60602 i

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f 0632H/ January 9, 1986-l

e i CONTENTION ITEN 10.F

10. Contrary to criterion I, " Inspection" of 10 C.F.R. Part 50, Appendix B, Conunonwealth Edison Company has failed to ensure that a program for inspection of activities t affecting quality was established and executed by or for the organization performing the activity to verify conformance'with the documented instructions, procedures, and drawings for accomplishing the activity.

F. Electrical contractor, Comstock, inspected and accepted a junction box which was later detemined to have deficiencies in the location of the anchors used for ,

mounting of the junction box. Anchors were accepted even though they were 3" from the required location specified by Sargent & Lundy drawing 20E-1-3571.

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RESPONSE

j The NRC conducted a routine safety inspection on March 25 through May 3, 1985. The inspection involved selective examination 3

of procedures and representative records, observations, and

interviews. The results of the inspections are documented in report

numbers 50-456/85-15 (DRP); 50-457/85-016 (DRP).

The report noted that L.K. Comstock inspected and accepted a junction box with an incorrectly located expansion anchor. This inspection was performed by a junction box / equipment inspector. A second inspection of the junction box was then performed by another L.K. Comstock junction box / equipment inspector who confirmed the incorrect expanision anchor location and documented this on NCR i

4139. Sargent & Lundy is now performing an engineering evaluation to determine dispositioning of NCR 4139.

0628H/ January 9, 1986

• CONTENTION ITEN 10.F In reponse to this finding all junction box inspection activity of by the junction box / equipment inspector involved, was halted until an evaluation could be made. ,All seven safety-related junction boxes which had been inspected by the O.C. Inspector who f ailed to identify the discrepancies documented in NCR 4139 were identified and located. One had been removed because of unrelated rework. All six remaininz Junction boxes were reinspected by another LKC OC Inspector. AZZ/ddfdty/tdZdEdd/jdddEldd/5dddd In dpdd E dd / By/ E hd / ddWidd E/lddydd E s t/ t d/ E d EdI/ d f / d dded 7 /ed ed td iddpdd E dd / My / ddd EMd t/ E/ Kl/ tend Edd R/ in dpdd En t . The matter is being reviewed by Conmonwealth Edison and Coestock.

0628H/ January 9, 1986

s' 6 CONTENTION ITEM 10.F REFERENCES

1. NRC Inspection Report Numbers 50-456/85-015 (DRP);

50-457/85-016 (DRP) (pages A0003386-3409).

2. L.K. Comstock NCR 4139 (pages 00002517-2526a).

3. L.K. Comstock memorandum from R. Seltmann to L. Tapella, dated 5/31/85 (page 00002723). -

4. D. L. Farrar letter to J. G. Keppler, dated 6/21/85

Enclosure:

Reponse to inspection report numbers 50-456/85-015 and -

50-457/85-016 (pages AC003410-415).

5. Licensing file on Item 85-15-08, Cont. 10.F (pages A000869508726).

4 0628H/ January 9, 1986

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0 CONTENTION ITEN 10.F

-MANES AND ADDRESSES

W. J. Kropp NRC Region III R. N. Gardner NRC Region III

J. G. Keppler NRC Region III J. W. Gieseker Conunonwealth Edison Company L.J. Tapella Conunonwealth Edison Company R. Seltman L. K. Comstock 1

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0628H/ January 9, 1986

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i l CONTENTION ITEN 3.C

3. Contrary to criterion II, " Quality Assurance Program," of

10 C.F.R. Part 50 Appendix B, Commonwealth Edison Company l has failed to establish a quality assurance program which j complies with the requirements of Appendix B and which is documented by written policies, procedures, and '

instructions. Commonwealth Edison Company has failed to assure that its Q.A. Program provides controls over activities affecting quality and that such activities are accomplished under suitably controlled conditions and are not appropriately verified for quality by inspection.

' C. The applicants electrical contractor (Comstock) utilised l Level I Quality Control Inspectors for inspection and i acceptance of electrical welds. This involved fourteen i different Level I Inspectors over four years (Inspection

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Report 85-06, Exhibit 11).

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j An NRC inspection of the Braidwood Construction Assessment 1

j Program (BCAP) activities conducted by Mr. R. N. Gardner on February i

4 through March 4, 1985 identified the concern referred to in this f

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subcontention with regard to Comstock weld inspections. The results

• i of the NRC inspection were reported in Report Numbers 50-456/85-006 l l

and 50-457/85-006. Although the focus of the inspection activity was on the BCAP Program, the thrust of the above concern was  ;

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directed against the overall acceptability of Comstock Level I weld

i inspections performed from 1979 through 1983. Specifically, the NRC inspector concluded that Comstock had utilized Level I Q.C. l i

i Inspectors for both inspection and final acceptance of electrical  !

1 welds in contravention of the requirements of ANSI N45.2.6-1978 -

which required, as a minimum, a Level II certification for Quality ,

i j control (Q.C.) inspection personnel who determine weld acceptance .

based on inspections conducted by Level I inspectors. It would [

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0627N/ January 9, 1985 i

. CONTENTION ITEM 3.C 1

appear that the NRC inspector believed that under Comstock Weld Procedure A.8.3, Comstock Level II inspectors' method of accepting wel 's was unclear and that Level I inspectors were doing both the inspection and final acceptance of the welds in question. The NRC Inspection Report indicated that this practice involved fourteen different Comstock Level I Q.C. inspectors over a four year time period. However. subsequent review has shown that E.C. Ernst , the orizinal electrical contractor at Braidwood (which was replaced by LKC in the sprina of 1979). also used Level I inspectors.

NRC Region III issued a notice of violation with respect to this matter on March 8, 1985. Commonwealth Edison Company does not agree with the proposed violation because the actual use of the Comstock Level I and Level II inspectors for visual weld inspections 4

between 1979 and 1983 was consistent with ANSI N45.2.6-1978. It is unclear whether E.C. Ernst's use of Level I inspectors was a violation of the apolicable requirements. During this time, the activity of Comstock Level I inspectors was limitad to the gathering and recording of inspection data sad Level II inspectors were making the final decision on weld acceptance based on the evaluation of the inspection checklist generated by the Level I inspectors. Although the Comstock Procedure did not describe clearly the objective criteria used by the Level II inspector to accept the welds in v2estion, this circumstance did not detract'from the fact that both Levels of inspectors were functioning in a manner consistent with ANSI N45.2.6-1978. ANSI N45.2.6-1978 specifically provides that Lovel I Q.C. inspectors are qualified to perform weld inspections, examinations and tests to predetermined or specific requirements,

! 0627H/ January 9, 1985

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4 CONTENTION ITEM 3.C provided that they document their findings on inspection checklists

[ which include sufficient information to serve as a basis for the

! final review and acceptance of the weld by Level II inspectors. The review by a Level II inspector of a Level I's weld inspection i i'  !

checklist to determine final acceptability of the weld is a i k.

longstanding requirement of the Comstock program as documented in Comstock Weld Procedure 4.8.3.

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At the time of NBC's inspection, the Braidwood Site Quality 1

} Assurance Department was conducting a follow-up survalliance (No.

i j - 4178) with respect to Wald Inspection Procedure 4.8.3. Surveillance  !

! i j No. 4178 was a follow-up to Geneesi office Audit 84-122 which was l

j conducted in September 1984. The audit had determined that l l l

, Procedure 4.8.3, Rev. F, was inadequate in that the inspection i j checklist .ns formulated could not be completed by a Level I  !

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inspector without the implication that the Level I inspector was '

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passing judgment on the acceptability of observed conditions. That i

$ is, the lack of documented objective evidence on the Procedure j checklist made it unclear as to the method used by the Level II  !

l inspector for establishing weld acceptability. It was recosmonded i that either the procedure be revised to define precisely the limited nature of the Level I's involvement or that only Level II Inspectors i be used to conduct visual weld inspections. In December 1984, it was decided to use Level II inspectors only to conduct future visual l weld inspections. The Surveillance also required that a progree be

established to re-evaluate past weld inspections performed in the

! first instance by Comstock Level I inspectors and accepted i

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0627H/ January 9, 1985

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CONTENTION ITEN 3.c l subsequently by Level II inspectors. Edison is prosently initiating f a program to verify the acceptability of.the welds inspected by LKC and E.C. Ernst Level I insoectors et/tdeed. r s

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I 0627N/ January 9, 1985 l

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C0missaIO't IT8N 3.C RsFERENCES >

1. NRC Inspection Report Numbers 50-456/85-06, 50-457/85-06; March

, 8, 1985 (pages A0003250-3275).

2. Letter (R.F. Warnick to C. Reed) and Notice of Violation, March, j 8, 1985 transmitting Reference 1 (pages A0003250-3275).

3. Letter (D.L. Farr to J.G. Keppler), response to Notice of Violation, May 6, 1985 (pages A0003276-3289).

f  ;

4. Letter (D.L. Shamblin to F. Rolan - BR/pCD 85-309) Level I Inspections, April 2, 1985 (pages A0014004-14005).

l 5. /JSI M45.2.6-1978 (pages A0013781-A0013788). i t

6. L.K. Comstock Wrok procedures 4.8.3 and 4.13.1 (peges 00002582-2630).

I 7. NRC Inspection Report Nos. 50-456/84-07; 50-457/84-07; July 20, 1984 (pages A0002059-2073).

8. NBC Inspection Report Nos. 50-456/80-12; 50-457/80-11; October I l 23, 1980 (pages A0000692-698).

9. NRC Inspection Report Nos. 50-456/83-19; 50-e57/83-17; i (pages A0001732-1749).

10. NRC Inspection Report Nos. 50-456/84-19; 50-457/84-18; (pages A0002341-2363).

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11. Ceco QA Audit Report' No. QA 84-122 (pages B0005400-30005416).  !

4 12. L.K. Comstock Work procedures 4.13.1 (pages 00002653-00002667).

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13. Licensin8 file on Itum 85-006-02, Cont. 3.C (pages A0006572-6615).

14. CECO QA Surveillance No. 4178.

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! 0427H/ January 9, 1985 l

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' CONTENTION ITEM 3.C  ;

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MAMES AND ADDRESSES i

R. N. Gardner NRC Region III I W. Forney NRC Region III [

R. 7. Warnick NRC Region III l

. M. J. Wallace Conunonwealth Edison Company I

't D. L. Shamblin Comunonwealth Edison Company i G. Marcus Conunonwealth Edison Company I i

J. Gieseker Conunonwealth Edison Company ,

E. Fitzpatrick Conunonweatth Edison Company [

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T. Quaka Conunonwealth Edison Company  !

L j R. Soltaann L. K. Comstock and Company Inc. l t

i j F. Rolan L. K. Comstock and Company, Inc. i l <

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. l 0427H/ January 9, 1985

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SPECIFIC INTERROCATORY 6 LEVEL I REVERIFICATION PROGRAN Conunonwealth Edison (Ceco) has instituted the Level I reverification Frogram (LRP) to provide additional confidence in the adequacy of welds

inspected by L. K. Comstock (LKC) and E.C. Ernst weld luspectors W62d fddpedEldde during the time they were certified as Level I inspectors.

i In December of 1984. CBCo directed LKC to use only Level II inspectors as

, weld inspectors. The LRP is designed to demonstrate that welds inspecht-d i

. i by LKC and E.C. Ernst Level I weld inspectors contain no design l

significant deficiencies. i f

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] An NRC inspection of the Braidwood Construction Assessment Program

! (BCAP) activities conducted by Mr. R. N. Gardner on February 4 through i

March 4, 1985 identified a concern with regard to LKC weld inspection.

j The results of the NRC inspection were reported in Inspection Report j

l 50-456/85-006 and 50-457/85-006. This issue, contained in contention f Item 3.C. focuses on the fact that, under the provisions of ANSI N45.2.6-1978, when a Level I weld inspector inspects a weld a Level II i ,

! weld inspector must review the Level I's in2pection checklist to l l l determine final acceptability. The lack of documented objective evidence on the weld inspection checklists prepared by the LKC Level I inspectors

! i leaves unclear the method used by the Level II inspector to establish weld acceptability. In order to address the acceptability of the welds i t

inspected by LEC Level I inspectors, Ceco decided to perform the LRP.

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! While this orotram was beina developed Ceco detemined that E.C. Ernst f Level I inspectors had also inspected welds and therefore those  ;

i l insoections were included within the scope of the pronram.

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t 0626H/ January 9, 1986  ;

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f CECO is developing a project management procedure to define the scope of LRP. The program will provide for:

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1. Determining the LKC and E.C. Ernst inspectors who were certified as Level I weld inspectors.

L j 2. Determining, from completed inspection checklists, the '

population of welds inspected by each Level I inspector during the t!me he was certified as a Level I.

l 3. Defining the sampling process to be used for the selection of ,

inspection checklists. These checklists identify the component to be reinspected.

4. Describing the reinspection process. This includes determining ,

j whether the component has been subsequently reworked or deleted  !

i or is inaccessible. If, for these reasons, a component cannot

{ be reinspected, a substitute component will be randomly l 1

selected. For components selected, welds will be reinspected by a currently certified Level II weld inspector other than the original inspector. The identity of the original inspector

will not be provided to the reinspector.

5. Defining the acceptance criteria for the weld reinspections.

l The reinspection will use the LEC visual weld inssection criteria currently in effect dt!Estid/Ekt/ded/fd/dffedt/dt l EM/Eldd/EM /etigiddl/tdd$ddtidd/ded/perferedd///deditleddl l Iddpedfled/dtitdtid/te/dlettip/ded/ldtetp ME/t M /dtigiddl Ideped tidd / td(d!Neddt d /dlll/ M / p MWided/ ld/ tM/ pMj dd t WNdedded.

6. The results of the reinspections will be recorded on a weld ~

j basis. The results of the program will be expresed in terms' of i the number of discrepancies, if any, which are design t i significant.  ;

f 7 Sample expansion will occur after the existence of a design I l significant discrepancy is established.

At the present time, it has been determined that seventeen fedttddd inspectore were certified by LEC and E.C, Ernst as Level I

{

l weld inspectors. Of these M fed N edd, thirteen didWed  ;

inspectors actually performed weld inspections. A review of the LKC QC  !

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flies indicated that the thirteen didend inspectors generated approximately M 114000 inspection reports. l l

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e Because this program is still being developed, there are as yet no prellainary or final conclusions. When the program is complete, it will enable CECO to make a statement regarding the existence of design sionificant discrepancies in components or equipment inspected by LKC and E.C. Ernst Level I inspectors and the ability of the inspected components to meet their intended design function.

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i 0626H/ January 9, 1986

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UNITED STATES OF AMERICA c NUCLEAR REGULATORY COMMISSION-BEFORE THE ATOMIC' SAFETY AND-LICENSING OM I3 Afl:33 In the Matter-Of: Tl

'fkr COMMONWEALTH EDISON COMPANY )

} Docket Nos. 50-456 (Braidwood Station, ) 50-457 Units 1 and 2) )

AFFIDAVIT OF JAMES W. GIESEKER I, James W.-Gieseker, being first duly sworn, depose and state as follows:

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1. I am employed by Commonwealth Edison Company  ;

as a Project Construction Department Field Engineer at-Braidwood j Nuclear Station. '

2. My business address is Braidwood Nuclear Power  ;

Station, Braceville, Illinois 60407.  !

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3. I participated in the preparation of the Common- '

wealth Edison Company's (Edison) original response to Intervenors' '

i contention item 10.F. dated August 27, 1985,- Edison's revised response to contention item 3.C. dated October 15, 1985 4

and Edison's response concerning the Level I Reverification  :

Program' dated November *22, 1985.

4. The following amendments made to Edison's i

! prior responses for contention item 10.F., 3.C. Land its  :

I description of the Level I Reverification Program are true i

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and correct to the best of my- knowledge and belief. ,

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5. In the response to contention item 10.F -

filed on August 27, in the third paragraph the second' sentence .

is deleted and replaced with the following: "All seven j

' safety-related' junction boxes which had been inspected by t

the Q.C. Inspector who failed-to identify the discrepancies ,

documented.in NCR 4139.were identified and' located. One had

) been removed because of unrelated rework. . All six remaining -

l junction boxes were reinspected ~by'another LKC Q.C. Inspector."

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6. In the revised response to contention item 3.C.

filed on October 15, 1985, the following insertions are made:

a. At the end of the first paragraph the following sentence is inserted: "However, subsequent review has shown that E. C. Ernst, the original electrical contractor at Braidwood (which was replaced by LKC in the spring of 19~9), also used Level I inspectors."

b. In the second paragraph, after the second sentence the following sentence is inserted: "It is unclear whether E. C. Ernst's use of Level I inspectors was a violation of the applicable requirement."

c. In the last paragraph, in the final sentence the last two words, "at issue", are replaced by the words " inspected by LKC and E. C. Ernst Leiel I inspectors."

l 7. In the Edison description of the Level I l

Reverification Program filed on November 22, 1985 the following amendments are made:

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a. In the first sentence of the first paragraph, the words " weld inspections" are deleted and replaced

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1 by the words "and E. C. Ernst weld inspectors".

b. In the third sentence of the first paragraph, the words acronym "LKC".

"and E. C. Ernst" are inserted after the

c. At the end of the second paragraph the following sentence is inserted: "While this program was being developed CECO determined that E. C. Ernst Level I inspectors had also inspected welds and therefore those inspections were included within the scope of the program. "

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d. In subpoint 1 of the third paragraph the words "and E. C. Ernst" are inserted after the acronym, "LKC".

e. In subpoint 5 of the third paragraph the remainder of the subpoint after the second "the" in the second line is deleted and replaced by the words "LKC visual weld inspection criteria currently in effect".

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f. . In the fourth paragraph, . wherever the word

" fourteen" appears.it is replaced with the word

" seventeen"_and wherever the' word " eleven" appears it

'is replaced by the word " thirteen".

g.- In the first' sentence'of the fourth paragraph the' words "and E. C. Ernst" are inserted af ter the acronym "LKC".

h. In the last sentence of. the fourth paragraph the number "11,000" is replaced with the number "9,000".

i. In the last sentence of the--fifth paragraph the words "and E.C. Ernst" are inserted after the acronym.

"LKC"-.

Further affiant sayeth not.

O4ML4to. 01 W-- .

JpdesjW. Gieseker Subscribed to and Sworn before me this C/tk day of Mt,AJ@,tR 1986 g 4 OY k W[Md G My commission expires on Ic/3cl &c3

i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In The Matter of )

COMMONWEALTH EDISON COMPANY )

) Docket Nos. 50-456 (Braidwood Station. ) 50-457 Units 1 and 2) )

CERTIFICATE OF SERVICE I, Gary A. Kruse, one of the attorneys for Commonwealth Edison Company, certify that copies of (1) Applicant's amendment to its response to contention item 10. F which was originally filed in Applicant's sixth partial responses to Intervences' First Set of Q.A.

Interrogatories dated August 27, 1985; (2) Applicant's amendments to its revised response to contention item 3.C. which was originally filed by letter to Intervenors' dated October 15, 1985; (3) Applicant's amendments to its description of the Level I Reverification Program originally filed in Applicant's second partial response to Intervenors' Second Set of Q. A. Interrogatories dated November 22, 1985; and (4)

Supporting affidavit of James W. Oleseker have been served in the above-captioned matter on those persons listed in the attached Service List by United States mail, postage prepaid, this 9th day of January, 1986.

G{jlA.Kruse ISHAM, LINCOLN & BEALE Three First National Plaza suite 5200 Chicago, Illinois 60602 (312) 558-7500 DATED: January 9, 1986 i

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H rbert Gr30sman, E;q., Chairman Dr. Richard F. Colo Administrative Law Judge Administrative Law Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555 Dr. A. Dixon Callihan Administrative Law Judge 102 Oak Lane Oak Ridge, TN 37830 j Mr. William L. Clements Ms. Bridget Little Rorem Chief, Docketing and Services 117 North Linden Street United States Nuclear Regulatory P.O. Box 208

, Commission Essex, IL 60935 Office of the Secretary Washington, DC 20555 Stuart Treby, Esq. Willita Little Elaine I. Chan, Esq. Director of Braidwood Project Office of the Executive Legal Region III Director United States Regulatory Commission United States Nuclear Regulatory 799 Roosevelt Road Commission Glen Ellyn, IL 60137 Washington, DC 20555 Atomic Safety and Licensing Charles Jones, Director Board Panel Illinois Emergency Services United States Nuclear Regulatory and Disaster Agency Commission 110 East Adams Washington, DC 20555 Springfield, IL 62705 Atomic Safety and Licensing Jan Stevens Appeal Board Panel United States Nuclear Regulatory

United States Nuclear Regulatory Commission Commission 7920 Norfolk Avenue Washington, DC 20555 Phillips Building Bethesda, ND 20014

• Robert Guild George L. Edgar Douglass W. Cassel, Jr. Thomas A. Schmutz Timothy W. Wright, III Newman & Holtsinger, P.C.

BPI 1615 L Street, N.W.

109 North Dearborn Street Suite 1000 Suite 1300 Washington, D.C.. 20036 Chicago, IL 60602 0633H

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