ML20137J323

Submits New & Significant Addl Info Re Cygna Energy Svcs Independence Re Role in Design Review of Facility. Certificate of Svc Encl.Related Correspondence

ML20137J323
Person / Time
Site:	Comanche Peak
Issue date:	08/26/1985
From:	Ellis J Citizens Association for Sound Energy
To:
References
CON-#385-370 OL, NUDOCS 8508300246
Download: ML20137J323 (19)

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PMLW2D Connesg g 8/26/85 UNITED STATES OF AMERICA NUCLEAR REGULATORY COPWISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OCUETED usuc In the Matter of ' Docket Nos. 50-445ct, TEXAS UTILITIES ELECTRIC and 50-446 65 E 29 R2:03 COMPANY, ~et al .

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(Application for anmcc c: yy,,

(Comanche Peak Steam Electric Operating License)?:hEin.G sik, Station, Units 1 and 2) SM NC" CASE'S ADDITIONAL INFORMATION RE:

CYGNA'S INDEPENDENCE In CASE's 8/15/85 Proposal Regarding Design / Design OA Issues, CASE urged that the Board require Applicants to inform the Board exactly what their intentions are regarding Cygna's role in the design review of Comanche PeakL1/. In our 8/19/85 Offer of Proof of Lack of Independence of Applicants' Latest Plan (CPRT Plan) g/, we provided the Board with additional information as to the bases for our concerns. We present herein new and significant additional information which adds wcight to our concerns.

Consideration of Cumulative Effects In previous documents received from Cygna summarizing all the findings l

and open items identified by Cygna, wording such as the following (which concerns Cable Tray Supports Review Issues) has appeared g /

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/1/ See CASE's 8/15/85 Proposal Regarding Design / Design QA Issues in Response to Applicants' 6/28/85 Current Management Views and Management l Plan for Resolution of All Issues, page 4, item 8.

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/2/ At pages 19 and 20.

I g/ See CASE Attachment A hereto, first full paragraph, " Status," and CASE l Attachment B hereto, third full paragraph, " Status B" -- both of which were attached to Cygna's 6/21/85 letter 84056.072 to TUCCO's John Beck.

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"This issue should be considered in any cumulative effects evaluation for generic applications."

However, in the most recent revision f4/, that wording has been changed and removed from the individual items listed by Cygna. Instead, a new section has been added at the end of the Review Issues List for Cable Tray '

Supports which states /5f t

" Status: The additive effects of the findings described in the Review Issues List must be addressed as part of the CFRT Plan." (Esphasis added.)

It now appears that Cygna is abandoning any independent consideration of cumuistive effects and turning such review over to the CPRT instead.

CASE objects most stringently to this further deterioration of what appears at the present time to be the only semblance of an independent i

L4/ Attached to Cygna's 8/13/85 letter 84056.080 to TUGCO's John Beck.

As mentioned earlier herein, Cygna's 8/13/85 letter and its attachments provide a summary of all the findings and open ites identified by Cygna to date; as such, they offer a thumbnail sketch of the problems at Comanche Peak which Cygna has identified (in some cases, with assistance from CASE either in hearings or in CASE pleadings which Applicants have only recently provided to Cygna).

CASE believes that Cygna's 8/13/85 letter with attachments, and all future updates of Cygna's Review Issues List, should be~sent to the Boardt however, as discussed in CASE's 8/19/85 Motion for Board to Order Applicants to Supply Documents to Board, we do not believe this should be CASE's burden. (We note that in the past, the NRC Staff has sent some of this information from Cygna to the Board. CASE does not believe that this should be the Staff's burden either. In this particular instance, we believe it would be more appropriate for Cygna to forward this and future updates direct to the Board, rather than Applicants supplying them.)

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5 Compare CASE Attachment B hereto, third full paragraph, "Statust B" (which was attached to Cygna's 6/21/85 letter 84056.072 to TUGCO's John Beck), to CASE Attachment C hereto (Cygna's latest revision of the same ites), third full paragraph, "Statust B."

See also CASE Attachment D hereto, ites 29. " Cumulative Ef fect of Review issues," especially " Status."

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review of Comanche Peak. We strongly urge that the Board take whatever steps are necessary to put an immediate halt to this deterioration of independence.

Having said that, CASE aust now make the Board aware of alarming new and significant information, which has just coes to CASE's attention, which clearly indicates that maintaining any semblance of independence on the part of Cygna may be mora difficult (perhaps even impossible) than the Board or even CASE ever imagined.

Cygna's testimony on behalf of Brown & Roott It has just come to CASE's attention that hearings are to be held before the Texa9 Public Utility Commission around January 1986, regarding the Petition of Houston Lighting & Power Company (NL&P) and Central Power &

Light Company (CP&L) for a Declaratory Order Regarding the South Texas Nuclear Project (STNP). As CASE understands it, these proceedings will be basically (1) to evaluate the proposed settlement of the law suit filed by HL&P and other STNP partners against Brown & Root, and (2) to evaluate the total amounts of dollare expended at STNP which can be attributed to imprudence or inefficiency on the part of the plant's owners or contractors during "the Brown & Root era." (As the Board is undoubtedly already aware, Brown & Root was the architect / engineer and constructor for STNP from 1973-1981 and was subsequently terminated in 1981; they were fired as architect /

engineer and subsequently resigned as constructor.)

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l CASE has just learned that Mr. Eugene F. Trainor, a Senior Vice President of Cygna Energy Services Inc., has filed testimony 2n behalf of Brown & Root in the above-referenced proceedings. We are attaching some pages from his sworn affidavit /prefiled testimony (CASE Attachment E hereto)/6,/.

This is apparently the same Mr. Trainer who has been deeply and importantly involved in the Independent Assessment Program (IAP) being performed by Cygna at Comanche Peak, as indicated in the following statoesnts from Cygna's IAP g/t "The Senior Review Team was made up of Messrs. B.K. Kacyra, J.E. Ward, E.F. Trainor, and L.L. Esamersell. . . Mr. Trainor. Vice Presider.t.

Quality Assurance, of fers extensive esperience in the fields of quality assurance and management controle. . . This team, with assistance from in-house consultants, reviewed all conclusions reached by the Project Team and was the final authority within Cygna regardina the adequacy of resolutions." (Esphases added.)

There are several disturbing aspec.ts of Mr. Trainor's testimony in the STNP hearings. First, as can be noted iy reviewing pages 6 and 7 of CASE f6/ See CASE Attachment E heretot pages from Profiled Direct Testimony of Eugene F. Trainor Concerning the STP Ouality Assurance Program, Submitted on behalf of Brown & Root, Inc., August 16, 1985, in Public

. Utility Commission of Texas Docket No. 6325, pages 1, 6, 7, 77, 78, and signed affidavit page.

CASE believes that Cygna should also send a complete copy of this profiled testimony to the Licensing Boards however, as discussed in Footnote 4, CASE does not believe we should have to shoulder this burden.

12/ See Pha.es 1 and 2 Draft Final Report (regarding which hearings were l IeId in February 1984), Independent ' Assessment Program for Comanche Peak Steam Electric Station, Prepared By Cygna Energy Services, No. TR-83090-01, November 5, 1983, page 1-4, "1.3 Project organisation,"

second paragraph. This page was not revised when the report was finalised October 12, 1984 (see 10/12/84 Cygna letter 83090.19 with errata and revised pages attached, copies of which were sent to all parties).

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Attachment E hereto, he omits any reference to the fact that he was involved in Cygna's review of Comanche Peak -- although Brown & Root is the constructor at Comanche Peak (just as they used to be at STNP). This appears to CASE to be a fact which certainly should have been included, the omissica of which immediately calls into question his candor.

The content of Mr. Trainor's testimony is equally disturbing (see

" Conclusions," pages 77 and 78 of CASE Attachment E). However, it is even more disturbing that Mr. Trainor is testifying on behalf of Brown & Root and basically in opposition to the NRC's 79-19 Investigation and Order to Show Cause at STNP. Although CASE certainly does not wish to retty the STNP case in the Comanche Peak proceedings, this position by Cygna in the face of the NRC's 79-19 Investigation and Show cause Order is enough to cause concern on the part of anyone even somewhat knowledgeable of the NRC's 79-19, and to raise serious questions regarding Cygna's knowledge of and commitment to NRC regulations, as well as their competence and independence.

This is important to the Comanche Peak proceedings because Applicants and Brown & Root "are so intricately intertwined" that the Licensing Board ruled that the Department of Labor findings in the Atchison case "are binding in this proceeding by application of the doctrine of collateral estoppel"f8/. (It is also obvious that it is impossible to separate the interests of Brown & Root; it is one company, whether at Comanche Peak or at STNP.) Cygna's testimony and position in the STNP PUC proceedings is shocking to CASE and raises still further questions about Cygna's ability to be independent in its esvaluation of Comanche Peak.

/H/ See Board's 7/6/83 Memorandum and Order (Collateral Estoppell Atchison case), especially discussion at pages 2, 3, and 4.

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CASE asks that the Board take the information contained herein into consideration during your deliberations on the Applicants' CPRT Plan and other issues pending before the Board. CASE also urges that the Board immediately take whatever action it believes is necessary to determine the status of, and to assure as much as possible, the independence of Cygna's reviewofComanchePeak/9,/,includingCygna'scontactswithBrown& Root.

CASE will, of course, be pursuing this matter further through normal discovery channels; however, based on past experience, it will be some time before CASE has all the facts to present to the Board. The information contained in this pleading was of such importance that we thought it urgent that we get it into the hands of the Board at once.

Respectfully submitted, D, a L /AJ L a

@.) Juanita Ellis, President MSE (Citisens Association for Sound Energy) 1426 S. Folk Dallas, Texas 15224 214/946-9446 f9,/ CASE notes that the Board's 8/22/85 Memorandum (Information Concerning Cygna Independence), received just as we were completing this pleading, asks Cygna to inform the Board of Cygna's practice concerning its application of its independence guidelines to its contacts with the Comanche Peak Response Team. CASK suggests that this be expanded to include Cygna's contacts with Brown & Root and the Applicants or any of their agents.

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t CASE ATTACHMENT A 6/21/86

, Revision 10 Page 2 l

CABLE TRAY SUPPORTS -

Review Issues List supports. Support systems at these building elevations are not included in Gibbs & Hill's dynamic analyses. The sup-ports at the three elevations indicated above may require additional review.

Status: Qualification of supports within Cygna's scope is complete.

This issue should be considtred in any cumulative effects

, evaluation for generic applications.

2. Seismic Response Combination Method

References:

1. CPSES FSAR Section 3.78.2.7 l

2. Gibbs & Hill Calculation Binder 2323-SCS-215C, Sets 2-6

3. USNRC Regulatory Guide 1.92, Revision 1

4. N.H. Williams (Cygna) letter to J.B. George (TUGCO), " Cable Tray Support Design Review Ques-tions " 84056.031, dated August 31, 1984

5. Gibbs & Hill calculation response to IAP Pnase 2 questions, Cygna Technical File 83090.11.2.1.50 Summary: A. Closely Spaced Modes (101 Modal Combination) in Spectral Analysis In the response spectra analyses performed for the working point deviation generic study (Reference 2),

. Cygna noted that modal responses were not combined considering closely spaced modes as required by Refer-ences 1 and 3.

B. Inclusion of Dead Load in SRSS Combination:

Gibbs & Hill design calculations typica)1y included the l dead load in the SRSS with the seismic loads. inis l issue was discovered in Phase 2 of this review, and Gibbs & Hill performed a study to quantify the impact of l this error (Reference 5). Gibbs & Hill calculations did not consider the effects of frame aspect ratios on the resultant loads. Reference 4 discusses a Cygna study on l

l Texas Utilities Generating Company l Comanche Peak Steam Electric Station

, independent Assessment Program - All Phases l

Job No. 84056 i

CASE ATTACHMENT B 6/21/85 Revision 10 Page 3 CABLE TRAY SUPPORTS Review Issues List the effects of aspect ratios for frame types within the review scope. The study results indicated the increases in resultant loads by combining the dead load witn the seismic SRSS may be larger than those predicted by Gibbs

& Hill. .

Status: A. Gibbs & Hill has revised the working point analyses to

, account for closely spaced modes in accordance with Reference 3. For a discussion of other discrepancies in the working point deviation study, see Review issue 12.

B. TUGC0/Gibbs & Hill should consider the effects of the worst case frame aspect ratio on the results of the SRSS study. The above issues should be considered in any evaluation of cumulative effects.

3. Anchor Bolt Design 9

References:

1. Gibbs & Hill calculations, " Evaluation of Detail 1, single-bolt connection," Cygna Technical File 84056.11.1.259

2. Gibbs & Hill Calculation Binder SCS-212C, Set 7 Sheet 4-11. Revision 0

3. Gibbs & Hill calculations, " Justification of the adequacy of 1" Richmond Inserts for the effects of prying action," Cygna Technical File 84056.11.1.219 Summary: A. Additional Tensile Forces Induced by Rotation of Base Angles About the Centerline of Bolt Pattern:

Gibbs & Hill has evaluated Alternate Detail 1 and a single anchor base angle using A4 loads (Reference.1).

These loads were chosen since the questions regarding design adequacy originated from discussion of the A4 design. The resolution of tnis generic issue requires an evaluation of the worst case load and geometry for all applicable supports. The geometries considered should include the effects of any generic change notices such as those for the base angle edge distance (CMC 1970) and the use of shtms under base plates (CMC 1969).

Texas utilities Generating Company Comanche Peak Steam Electric Station

,g Q , independent Assessment Program - All Phases Job No. 84056

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e CASE ATTACHMENT C 8/13/85 Revision 11 Page 4 CABLE 1 RAY SUPPORTS Review Issues List

. Reference 4 discusses a Cygna study on the effects of aspect ratios for frame types within the review scope.

.The study results indicated the increases in resultant loads by combining the dead load with the seismic SRSS may be larger than those predicted by Gibbs & ' Hill.

Status: A. Gibbs & Hill has revised the working point analyses to account for closely spaced modes in accordance with Reference 3. For a discussion of other discrepancies in the working point deviation study, see Review Issue 12.

B. TUGC0/Gibbs & Hill should consider the eff' e cts of the worst case frame aspect ratio on the results of the SRSS study.

3. Anchor Bolt Design

References:

1. Gibbs & Hill calculations, " Evaluation of Detail 1, single-bolt connection," Cygna Technical File 84056.11.1.259

2. Gibbs & Hill Calculation Binder SCS-212C, Set 7, Sheet 4-11, Revision 0

3. Gibbs & Hill calculations, " Justification of the adequacy of 1" Richmond Inserts for the effects of prying action," Cygna Technical File 84056.11.1.219 4 Brown & Root Procedure CEI-20, " Installation of Hilti Drilled-In Bolts", Revision 9..

5. Hilti, Inc., " Architects & Engineers Anchor and Fastener Design Manual" g

6. TUGC0 SDAR CP-80-12. " Reduced Allowable loads for Hilti Kwik-bolts" l

l Texas Utilities Generating Company a

Comanche Peak Steam Electric Station Men - Independent Assessraent Program - All Phases Job No. 84056 i

4 CASE ATTACHMENT D 8/13/85 Revision 11 Page 72 CABLE TRAY SUPPORTS Review Issues List support aspect ratios. Justification was not provided to indicate that the chosen aspect ratios would provide the critical configuration to evaluate all components of the .

support design. The determination of aspect ratios was l based on an assumed frame width based on supported tray width and the maximum frame height. The frame width determination assumed that: (a) trays were installed with a minimum 6" horizontal spacing, (b) the distance between the side rail of a tray and the vertical hanger flange was a minimum of 3", and (c) all trays on a support were 24" or less in width..

Cygna's support walkdown noted that trays were installed with spacings as small as 1" between adjacent trays, and 0" between tray siderails and the hanger flange. Reference 4 indicates that cable tray installations at CPSES allow a maximum. tray Nidth of 36". g Status: Gibbs & H111/TUGC0 should provide justification for the aspect ratios used for support designs.

29. Cumulative Effec' of inview Issues

References:

None Summary: In this Review Issues List, a number of the cited issues may lead to small unconservatisms when occurring singly in a support design. Such unconservatisms may usually be neglected. However, since several of these issues pertain to all cable tray support designs on a generic basis, their effect can be cumulative, such that many small unconservatisms may be significant. Therefore, any reevaluation of support designs should consider the cumulative effect of all pertinent Review issues.

Status: The additive effects of the findings described in the Review Issues List must be addressed as part of the CPRT Plan.

Texas Utilities Generating Company

{ g , Comanche Peak Steam Electric Station ggg ..,.,.g Independent Assessment Program - All Phases Job No. 84056

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CASE ATTACHMENT E Public Utility Commission of Texas Docket No. 6325 Direct Testimony of Eugene F. Trainor f

Concerning the STP Quality Assurance Program Submitted on behalf of :

' Brown & Root, INC.

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l August 16,1985 Cygna Energy Services Management Services, Division 286 Congres's Street Boston, MA 02210 617/338-4500 1

i r,----- - . i- ,. ,, .-c.,e-.-,.--,_.--,-----.w - - - - - - - - - -

i DIRECT TESTIMONY OF EUGENE F. TRAINOR CONCERNING THE STP QUALITY ASSURANCE PROGRAM SUBMITTED ON BEHALF OF BROWN & ROOT, INC.

4 I. BACKGROUND AND QUALIFICATIONS Q1. Please state your name and occupation.

A1. Eugene F. Trainor. I am a Senior Vice President of Cygna Energy Services, Inc., an engineering and management con-sulting firm located at 286 Congress Street, Boston, Mas-sachusetts.

Q2. Please describe your educational background. f I

i A2. I graduated in 1953 from the United States Coast Guard Academy at New London, Connecticut, where I received a Eachelor of Science degree in General Engineering. I sub-sequently received a Master of Science degree in Manage-ment from Rensselaer Polytechnic Institute, Troy, New York, and a certificate in Executive Management from Northeastern University, Boston, Massachusetts. I re-ceived training in Naval nuclear power plant testing and operations at the Mare Island Naval Shipyard, Vallejo, California.

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In May of 1980 I. joined Cygna Energy Services, then known as Earthquake Engineering Services, as Vice President and l

Principal with the initial assignment to establish manage-ment and quality assurance consulting services for the firm. Cygna Energy Services, which at present is a f

broad-based, multi-service consulting engineering firm, was founded in 1973 and specialized initially in structur-al and seismic engineering. Its entry into the nuclear industry was the seismic evaluation of the Humboldt Bay nuclear power plant for Pacific Gas & Electric in the early 1970's. In 1980, a corporate decision was made to l

expand its services to cover all facets of the energy in-dustry and to become, in effect, a " mini" Architect /

Engineer.

In the past five years, what was essentially an in-house quality assurance service has expanded to be a significant part of Cygna's business. In addition to my managerial role, I have participated in an active consulting role with such assignments as the review for Northern States

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Power of its Spare Parts Program at its Prairie Island Nuclear Power Station as well as an evaluation of the im-plementation of the Quality Assurance Program at that sta-tion. Other assignments have included the evaluation of i

the proposed Operations Quality Assurance Program to be i

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e used by Houston Lighting & Power at its South Texas Project and participation as a member of the Senior Review i

Team for the independent design review of the Grand Gulf Unit 1 plant for Mississippi Power & Light and Fermi 2 for i Detroit Edison. My most recent assignment has been the j_ evaluation of the adequacy of the Quality Assurance pro-gram implemented by Brown & Root at the South Texas Project.

Q4. What is the purpose of your testimony?

A4. The purpose of my testimony is to summarize the results of Cygna's evaluation of the Quality Assurance (QA) program implemented by Brown & Root at the South Texas Project (STP). The testimony is divided into three parts. The first part considers the written QA program that Brown &

Root developed for STP, including the manuals, procedures, and instructions that defined how the QA program was to function and how the safety-related work was to be carried out at STP. The-second part evaluates how well Brown &

Root actually implemented the written QA program at STP.

The third part addresses a special inspection--known as the 79-19 Investigation--performed by the Nuclear Regula-tory Commission (NRC) at STP in late 1979 and early 1980.

As a result of the 79-19 Investigation, on April 30, 1980,

imposed by Part V of the Order or the entire enforcement

! Package of April 30, 1980.

Q33. Have you prepared a report documenting your conclusions abut the Order to Show Cause?

A33. Yes. Our report is entitled " Analysis of the Order to Show Cause." It is submitted herewith as APPENDIX C and is made a part of this testimony.

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VI. CONCLUSIONS Q34. What are your overall conclusions with respect to the QA program implementod by Brown & Root at STP?

A34. Brown & Ro'ot developed an adequate written QA program for STP that satisfied regulatory requirements and was gener-ally consistent with normal practice in the industry at that time. In addition, the written QA program was effec-tively implemented by Brown & Root at STP from 1975 to 1981. Neither of these basic conclusions is undermined by the NRC's 79-19 Investigation and' Order to Show cause.

The evidence indicates that the 79-19 Investigation re-sulted from political and media pressure and from a desire to restore public confidence in the integrity of the NRC and the vigor of its enforcement program. The 22 items of j l l

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t noncompliance resulting from the 79-19 Investigation were generally inaccurate, invalid, insignificant or

! . unwarranted. The Order to Show Cause does not fairly rep-resent the prior enforcement record at STP and was, in our opinion, completely unwarranted. In short, the NRC's en-forcement action does nothing to dissuade us from our con .

clusion that Brown & Root's STP QA program was in fact well conceived and well implemented.

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l AFFIDAVIT -

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DISTRICT OF COLUMBIA: ,

i CI'I'l OF WASHINGTON:

Before me, the undersigned notar'f public, this day personally appeared EUGENE F. TRAINOR, to me known, who being duly sworn according to law, deposes and says:

"My name is Eugene F. Trainer, I am of legal age and a ,

resident of the Commonwealth of Massachusetts. The foregoing testimony, including the appendices and exhibits thereto, is true and correct to the best of my knowledge, information and

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belief, and the opinions stated therein are, in my judgment and based upon my professional experience, true and correct."

/_, ~_ 2G EUGENE F. TRAINOR

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. Subscribed and sworn to before me this b day of August, 1985. t ufm. u>a i

l Notary Public My Commission Expires: '

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N BELATED CON UNITED STATES OF AMERICA 00tME TEf'

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NUCLEAR REGULATORY COMMISSION '

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'85 RJG 29 P12:08 In the Matter of }{

II GFFfct CE SE W W TEXAS UTILITIES ELECTRIC }{ Docket Nos. 50-445 00CxElmG & SLA i COMPANY, et al. }{ and 50-446 eRANCH (Comanche Peak Steam Electric }{

Station, Units 1 and 2) }{

CERTIFICATE OF SERVICE By my signature below, I hereby certify that true and correct copies of CASE's Additional Infomation re: Cygna's Independence have been sent to the names listed below this 26th day of August ,198 5, by: Express Mail where indicated by

• and First Class Mail elsewhere.

Federal Express where indicated by **

• Administrative Judge Peter B. Bloch

• Nicholas S. Reynolds, Esq.

U. S. Nuclear Regulatory Commission Bishop, Liberman, Cook, Purcell 4350 East / West Highway, 4th Floor & Reynolds Bethesda, Maryland 20814 1200 - 17th St., N. W.

Washington, D.C. 20036

• Judge Elizabeth B. Johnson Oak Ridge Natioral Laboratory

• Geary S. Mizuno, Esq.

P. O. Box X, Building 3500 Office of Executive Legal Oak Ridge, Tennessee 37830 Director U. S. Nuclear Regulatory

• Dr. Kenneth A. McCollom, Dean Commission Division of Engineering, Maryland National Bank Bldg.

Architecture and Technology - Room 10105 Oklahoma State University 7735 Old Coorgetown Road Stillwater, Oklahoma 74074 Bethesda, Maryland 20814

• Dr. Walter H. Jordan Chairman, Atomic Safety and Licensing 881 W. Outer Drive Board Panel Oak Ridge, Tennessee 37830 U. S. Nuclear Regulatory Commission Washington, D. C. 20555

• Administrative Judge Herbert Grossman U. S. Nuclear Regulatory Commission 4350 East / West Highway, 4th Floor Bethesda, Maryland 20814

• • = all being sent in package to Judge B10ch l

Chairman Ranem Hicks, Esq.

Atomic Safety and Licensing Appeal Assistant Attorney General Board Panel Environmental ~ Protection Division U. S. Nuclear Regulatory Commission Supreme Court Building Washington, D. C. 20555 Austin, Texas 78711 Mr. Robert Martin Anthony Z. Roissan, Esq.

Regional Administrator, Region IV Trial Lawyers for Public Justice U. S. Nuclear Regulatory Commission 2000 P Street, N. W., Suite 611 611 Ryan Plaza Dr., Suite 1000 Washington, D. C. 20036 Arlington, Texas 76011 Mr. Owen S. Herrill Lanny A. Sinkin Staff Engineer 3022 Porter St., N. W., #304 Advisory Committee for Reactor Washington, D. C. 20008 Safeguards (MS H-1016)

U. S. Nuclear Regulatory Commission Dr. David H. Boltz Washington, D. C. 20555 2012 S. Polk Dallas, Texas 75224 Robert A. Wooldridge, Esq.

Worsham, Forsythe, Sampels William Counsil, Vice President & Wooldridge Texas Utilities Generating Company 2001 Bryan Tower, Suite 2500 Skyway Tower Dallas, Texas 75201 400 North Olive St., L.B. 81 Dallas, Texas 75201 Thomas G. Dignan, Jr., E.sq.

Ropes & Gray Docketing and Service Section 225 Franklin Street (3 copies) Boston, Massachusetts 02110 Office of the Secretary U. S. Nuclear Regulatory Commission

• th. Nancy H. Williams Washington, D. C. 20555 Project Manager Cygna Energy Services Ms. Billie P. Garde 101 California Street, Suite 1000 Covernment Accountability Project San Francisco, California 1901 Que Street, N. W. 94111-5894 Washington, D. C. 20009 Mark D. Nosette, Counselor at Law Heron, Burchette, Ruckert & Rothwell 1025 Thomas Jefferson Street, N. W.,

Suite 700 '

Washington, D. C. 20007 i

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l 0 m ~ Nth $ At 1 >

. p s.) Juanita Ellis, President GSE (Citizens Association for Sound Energy)

1426 S. Polk Dallas, Texas 75224

, 214/946-9446

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