ML20138D870
| ML20138D870 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/09/1985 |
| From: | Dignan T, Gad R ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| CON-#485-457 OL-2, NUDOCS 8512130316 | |
| Download: ML20138D870 (24) | |
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'2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
Docket Nos. 50-445-2 TEXAS UTILITIES GENERATING
)
50-446-2 COMPANY et al.
)
)
(Application for an (Comanche Peak Steam Electric
)
Operating License)
Station, Units 1 and 2)
)
)
APPLICANTS' ANSWERS TO CASE'S INTERROGATORIES TO APPLICANTS (November 15, 1985)
Pursuant to 10 C.F.R. 5 2.740b, the Applicants submit these responses to " CASE's Interrogatories to Applicants (November 15, 1985)," which were served in hand on November 15 and 16, 1985.
Enlargement of the time to respond to December 9, 1985, was granted by Order of the Board announced on December 2, 1985.
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I Introduction In each case where an answer or partial answer is i
made, it is without waiver of the antecedent objection or partial objection, if any.
In each case where an objection or partial objection is made, the Applicants hereby request a protective order in the event that a motion to compel is made.
The Applicants have ignored " Instructions" 1-2 and 4-6 to the extent that the same are inconsistent with the Rules of Practice.
Interrogatory No. 1 1.
Identify all the mechanisms by which a possible failure to fully comply with an NRC rule, regulation, or procedure or any plant procedure (hereinafter collectively identified as
" deficiencies" cr " deficiency") at CPSES could have been iccatified since June 30, 1984, whether part of the CPRT or not.
In your answer cite with specificity the written procedures, if any, applicable to each mechanism identified.
Also identify each type of written record made with
-respect to each mechanism.
Objection (Partial):
The Applicants object to this interrogatory insofar as, by the breadth of the terms "all the mechanisms by which a possible failure.
could have been identified
.," the question-calls for
speculation.
The Applicants further object to this interrogatory on the ground that, except insofar as it calls for information about CPRT or any procedure first employed since July 1, 1984, it is untimely.
See Tr.
7507-18 (June 7, 1983).
The Applicants respectfully refer CASE to, inter alia, CASE's First Set of Interrogatories (7/7/80), Nos.
1-4, 15, CASE's Second Set of Interrogatories (12/1/80), Nos.
3-6, CASE's Ninth Set of Interrogatories (4/5/82), Nos. 15-18, CASE's Tenth Set of Interrogatories (4/20/82), Nos.
3-5, CASE's Eleventh Set of Interrogatories (5/7/82),
Nos. 2-29 and 30.
Answer (Partial):
The Applicants are unable to answer this interrogatory in the same breadth in which it is
- framed, i.e., "all-the mechanisms by which a possible failure could have been identified.
With respect to established systems for such identification, the Applicants submit the following information: I
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SYSTEM PROCEDURES DEVIATION RECORD TYPE CPRT CPRT Program Plan and:
CPP-010 Deviation Report (DR)
(QOC)
CPP-020 Out of Scope Observation (QOC)
DAP-2 Deficiency / Issue Resolution Report (DIR)
(DAP and C/S/M TRT Issues)
Appendix E
[ Fed to Project NCR by Memo)
(TRT Issues)
Design TNE-AD-5 TUGC0 Nuclear Engineering Deficiencies Design Deficiency Report and Errors (TDDR)*
(Includes Input from 4
CPRT-DAP-DIRs and from SAFETEAM)
Test Deficiency CP-SAP-16 Test Deficiency Report (TDR)
Non-conformance (Includes Input from Reporting CPRT Testing TRT ISAPs and from SAFETEAM) t Non-conforming CP-QAP-16.1 Non-conformance Report Conditions (NCR)
(ASME-related Construction
]
Non-conforming Conditions)
(includes input from SAFETEAM)*
CP-QP-16.0 en-conformance Report (NCR)
(non-ASME related Construction Non-conforming Conditions) (includes input from SAFETEAM)*
CP-QP-19.10 Construction Startup/ Turnover Surveillance Deficiency Report (DR)
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A SYSTEM PROCEDURES DEVIATION RECORD TYPE STA-405 Non-conformance Report (NCR)
Non-conforming Conditions, any System Transferred to Operations, except ASME-Program Systems)
(includes input from SAFETEAM)
N-61.1 Deviation Notice (DN)
Non-conforming Conditions, ASME-Program Systems Transferred to Operations)
(includes input from SAFETEAM)
Non-conforming QI-QP-[all)
Inspection Report (IR)**
Construction QI-QAP-[all]
Conditions a
1 Certain contractors are performing services for Texas Utilities and operate under their own approved QA/QC programs.
These contractors are:
Bahnson (HVAC), Westinghouse (design), Grinnell Fire Protection (design), BISCO (Environmental Seals), IMPELL (design), Gibbs & Hill (Design), EBASCO (Design), Chicago Bridge & Iron (design and construction) and Stone & Webster!(Design).
Information regarding non-conforming conditions produced by these contractors' programs is used to prepare a TUGC0 NCR or TDDR.
Any unsatisfactory attribute identified during a QC inspection is noted on the IR.
In some cases, the Quality Control Instructions provide the option of proceeding directly to rework the item in question or of submitting an NCR for engineering evaluation. NCR's may be dispositioned " scrap," " rework," " repair" or "use as is."
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l The procedures regarding CPRT are or will be l
contained in the CPRT Working Files for the ISAPs and DSAPs, which will be produced for inspection in accordance with the Applicants' answer to l
Interrogatory / Request No. A-14 of the set propounded by CASE on 8/27/85.
Other procedures are available for j
inspection and copying upon request.
Interrogatory No. 2 Question:
j.
2.
Identify.all. classes of persons other than full-i time employees of TUGCO or Brown and Root who I
have used any of these mechanisms since June 30, 1984.
" Classes of persons" is intended to allow 3
(but not require) this answer to disregard the name of the particular person but is intended to i
disclose the name of the organization for which the person worked and the person's or organization's status, i.e.,
independent contractor, consultant, sub-contractor, etc.
Answer:
.Mr.
Jim Wells of Duke Power Company, serving as Director, TUGCO QA.
1 Mr. Phillip Halstead.and Mr. Dave McAfee, of 4
Daniel Construction Company, serving as Site QC Manager and QA Manager, respectively.
3 1
Mr.lR.E. Camp, IMPELL Corp., serving as Assistant 4
1 Project General Manager, Unit 1.
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Ebasco Services, Incorporated:
(1) cable tray and conduit supports requalification program; (2) certain engineering support for TUGCO Nuclear
' Engineering; (3) certain quality control inspectors.
IMPELL Corp.:
(1) start-up services; (2) cable tray and conduit support requalification; (3) other support services.
Westinghouse Corp.:
(1) start-up services; l
(2) construction and engineering support.
United Engineers and Constructors:
(1) start-up services; (2) construction and engineering support.
Sub-contract organizations performing work for the above.
Interrogatory No. 3 Question:
3.
Describe the procedure (s) that should have been followed during the period June 30, 1984, to the i
present if a person, other than a full-time employee of TUGCO or Brown and Root, saw a 4
condition at CPSES which they believed may have been a deficiency.
Answer:
The Applicants are unable to answer this i
interrogatory, with respect to any person other than CPRT and the persons and organizations identified in
.i the answer to Interrogatory No 2, in the absence of i
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some specification of who the supposed person might be.
With respect to CPRT and such persons, see the response to Interrogatory No.
1.
Interrogatory No. 4 Question:
4.
Describe any deviation from the procedure described in question 3.
For instance, if a written report was required and some persons made an oral report this should be disclosed.
Answer:
See response to Interrogatory No.
3.
Ipterrogatory No. 5 Question:
5.
Describe in detail how possible deficiencies identified by any mechanism were handled.
In particular describe the step by step process from the original indentification to final disposition including all steps where discretion or judgment could be used, the' criteria for such discretion or judgment, the method by which the exercise of discretion or judgment was documented, the person (s) (or their levels) at which the discretion or judgment was exercised, and any and all written record made from original identification to final disposition.
Answer:
If this interrogatory seeks the procedures by which suspected deviations should be handled, see the response to Interrogatory No.
1.
If this interrogatory seeks information about how each and every one of the...
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4' identified suspected deviations has been handled over the course of the construction-project, such 4
information is contained in, or could be extracted from an examination, audit or inspection of, the records associated with the procedures identified in response t
to Interrogatory No. 1 or prior versions thereof, and j
the burden of deriving or ascertaining such information j
would,be substantially the same for the party serving the interrogatory as for the party served.
The Applicants will, upon request, produce such records for the period subsequent to June 30, 1984, at either the i
7 offices of Texas Utilities Generating Company, Dallas, Texas, or at Comanche Peak-Steam Electric Station, Glen Rose, Texas (depending upon where the records in question are located) at a time mutually convenient to counsel.
As to documents from prior to June 30, 1984, the Applicants believe that discovery as to events prior to June 30, 1984 is untimely and therefore object.
See objection to Interrogatory No.
1, supra.
Interrogatory No. 6 Question:
6.
Since June.30, 1984, with.whom have Applicants discussed (exclude employees of TUGCO and. Brown and Root as of June 30, 1984; contractors, subcontractors, or consultants of Brown and Root
,s or TUGCO as of June 30, 1984; lawyers, legislators, government officials, members of the press, investors, investment advisors (including bankers), and CASE or any of its representatives) any of the following:
a.
the extent of previously undetected deficiencies at CPSES; i
b.
programs for identifying the extent of such deficiencies; c.
programs for identifying the root cause of such deficiencies; d.
programs for dispositioning any such deficiencies?
In this answer, if more than one person from a single organization was involved in discussions, just list the organization.
Answer:
Contractors retained subsequent to June'30, 1984 and engaged in the CPRT effort; Messrs. Wells, McAfee and Halstead.
Interrogatory No. 7 Question:
7.
Of the persons or organizations identified in the answer to question 6, which ones are currently performing any work on one or more of the four identified categories with respect to CPSES?
Answer:
With the exception of Martin Jones, formerly the CPRT Review Team Leader for Electrical, who has ;
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Interrogatory No. 8 I
Question:
8.
Of the persons or organizations identified in the answer to question 6 other than those listed in the answer to question 7, which ones are currently doing any work with respect to CPSES?
Briefly describe the work they are doing.
Exclude any individual who is now an employee of Brown.and Root or TUGCO but identify approximately how many persons are in this category.
Answer:
See answer to Interrogatory No. 6 Interrogatory No. 9 Question:
9.
Please describe the current job responsibilities of any of the following persons if they are still doing any work with respect to CPSES, list the organization by whom they are employed, the immediate supervisor of the work they are doing and that supervisor's employer:
a.
C. Thomas Brandt b.
Gordon Purdy c.
Greg Begnetzen d.
Chuck Welch e.
J. D. Hicks f.
Mark Welch g.
M.
G.
Kri.shner h.
Bill Cromeans i.
J.
B.
Leutwyler j.
Doug Snow k.
K.
London 1.
Ken Luken m.
Frank Powers n.
J. T. Merritt, Jr.
o.
James Wells p.
I.
Vogelsang q.
H. Hutchison r.
Bob Siever s.
Ted Blixt t.
Dwight Woodward Answer:
Please see the attachment to these answers.
j Interrogatory No. 10 Question:
10.
What, if any, steps have been taken by TUGCO or Brown and Rnot to rehire persons whc nave left the plant since January, 1982, and who have-subsequently been witnesses in the licensing proceeding and/or made allegations to the NRC about CPSES?
Describe in detail the rehiring efforts made, if any, with respect to each such person.
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Answer:
If the question means, do the Applicants have any program for the recruitment of witnesses and "allegers" as a special class, the answer is "No."
If the question means, do the Applicants have any policy of extending preferential treatment to witnesses or "allegers" who might apply for employment, the answer is "No."
The Applicants believe that those witnesses and "allegers" who have applied for and obtained employment at CPSES have done so on their own merits and qualifications.
i Interrogatory No. 11 Question:
11.
To what extent, if at all, has the fact that some of the allegations of some of the persons referred to in Que'stion 10 have been found to be valid by either the NRC or applicants affected steps taken to rehire these persons?
Answer:
Please see the response to Interrogatory No. 10.
Interrogatory No. 12 Question:
12.
How many persons hired by Applicants since January 1, 1984, are experts hired by Applicants for the purpose of preparation for, or in anticipation of this licensing hearing?
This question dcas not seek a legal conclusion but a corporate answer using the corporation's opinion of the meaning of the question.
Answer and Objection:
The Applicants have not yet made any determination as to which of the experts retained by it since January 1, 1t84, it intends to call to testify at trial.
The Applicants object to the balance of this
. interrogatory on the ground that the information called for is not discoverable information about retained experts, under Fed.
R. Civ.
P.
26(b)(4) as applicable to these proceedings, and on the ground that CASE has not yet propounded the interrogatories called for by Fed.
R. Civ.
P.
26(b)(4)(A)(i), which is a predicate to any request for additional discovery with respect to expert witnesses whom the Applicants do intend to call to the stand.
Interrogatory No. 13 Question:
13.
How many persons working for consultants, contractors, and subcontractors since January 1, 1984, do Applicants claim are included in the answer to question 12?
Answer and Objection:
The Applicants have not yet made any determination as to which of the experts retained by it
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since January 1, 1984, it intends to call to testify at trial.
The Applicants object to the balance of this interrogatory on the ground that the information called i
for is not discoverable information about retained experts, under Fed. R. Civ. P.
26(b)(4) as applicable to these proceedings, and on the ground that CASE has not yet propounded the interrogatories. called for by Fed.
R. Civ.
P.
26(b)(4)(A)(i), which is a predicate to any request for additional discovery with respect to expert witnesses whom the Applicants do intend to call 1
to the stand.
Without waiving its objection, the Applicants contend that all of the technical personnel engaged in the CPRT effort are experts retained by them in preparation for and in anticipation of litigation.
Interrogatory No. 14 Ouestion:
14.
How many of the persons identified in the answer to Question 12 and 13 would have been hired irrespective of the existence of this licensing hearing?
List those persons, or if more than one person is employed by the same organization, list the organization and the number of persons employed by it.
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Answer:
No answer required.
Interrogatory No. 15 Question:
15.
At what time, for how long, and under what circumstances may representatives of CASE conduct inspections of construction at CPSES and documents (QA/QC, engineering and design) at CPSES?
Answer:
The Applicants will respond to any request for discovery propounded by CASE.
In addition, the Applicants will consider any informal request by CASE for inspections of the type referred to in this interrogatory, provided that such requests are submitted in writing to counsel for the Applicants and are sufficiently specific (i.e.,
names, addresses and social security numbers of proposed visitors, areas of the plant of which inspection is requested, and proposed dates and alternative dates) to permit a response.
__4
ATTACHMENT T0 " APPLICANTS' ANSWERS TO CASE INTERROGATORIES TO APPLICANTS" (November 15, 1985) a.
C. Thomas Brandt Job
Title:
QE Supervisor Employer:
Ebasco Supervisor:
P. Halstead Supv. Employer:
Daniel Responsible for the training, corrective actior, NRC interface, and programmatic and technical direction for'the QC inspection force.
b.
Gordon Purdy Job
Title:
Site QA Manager Employer:
Self Supervisor:
Raymond J. Vurpillat Supv. Employer:
Brown & Root Responsible for the QA/QC Inspection Program for ASME systems and components. Administratively responsible for all Brown & Root QA department employees.
c.
Greg Bennetzen Job
Title:
ASME Quality Engineer Employer:
Brown & Root Supervisor:
Satish Ranadine Supv. Employer:
Brown & Root Charged with assisting in the technical development and implementation in the ASME QA inspection program.
d.
Chuck Welch Job
Title:
QC Service Supervisor Employer:
TUGC0 Supervisor:
P. Halstead Supv. Employer:
Daniel Primary responsibility is interface with Resident NRC Inspector, e.
J. D. Hicks Job
Title:
Site QC Supervisor Employer:
TUGC0 Supervisor:
P. Halstead Supv. Employer:
Daniel This position is responsible for implementing the QC. Program for Non-ASME related activities at CPSES as specified in QA/QC procedures and instructions.
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Mark Welch Job
Title:
QC Supervisor Employer:
TUGC0 Supervisor:
Bob Siever Supv. Employer:
Brown & Root Building QC Supervisor implementing non-ASME QC Program (Unit 1).
g.
M. G. Krishner Job
Title:
Unit 2 QC Supervisor Employer:
Ebasco Supervisor:
J. D. Hicks Supv. Employer:
TUGC0 Functional supervision of all inspectors for the Unit 2 construction inspection activities, n.
' Bill Cromeans Job
Title:
Civil Supervisor / Laboratory Supervisor
~
Employer:
Brown & Root Supervisor:
J. B. Leutwyler Supv. Employer:
Brown & Root i
Responsible for inspection and testing of construction materials in soils, water and concrete.
i.
J. 8. Leutwyler Job
Title:
QC Supervisor for Safeguard 2 1
Employer:
Brown & Root Supervisor:
M. G. Krishner Supv. Employer:
Ebasco i
Responsible for supervision of QC non-ASME personnel for inspection of all non-ASME activities and Safeguard 2.
i j.
Doug Snow Job
Title:
QC Coordinator Employer:
Brown & Root Supervisor:
P. Halstead Supv. Employce:
Daniel Help coordinate ERC (reinspection effort) assisting with documentation procedures; specification, addressing deviation reports.
k.
K. London - no record of such a person at CPSES.*
1.
Ken Luken Job
Title:
Lead Startup Engineer Employer:
Westinghouse Supervisor:
C. E. Scott Supv. Employer: TUGC0 Responsible for scheduling and directing all start-up testing activities.
m.
Frank Powers - no record of such a person at CPSES.
- n.
J. T. Merritt Job
Title:
Assistant Project General Manager Employer:
TUGC0 Supervisor:
J. B. George / Construction A. B. Scott / Start-Up Supv. Employer:
TUGC0 Responsible for engineering and construction activities and for start-up testing.
o.
James Wells Job
Title:
Director, QA Employer:
Duke Supervisor:
John Beck Supv. Employer:
TUGC0 Responsible for management and direction of the TUGC0 QA organization.
p.
Ivan Vogelsang Job
Title:
Project Support Engineer Employer:
TUGC0 Supervisor:
R. E. Camp Supv. Employer:
Impe11 Project interface in Electrical and I&C areas.
q.
H. Hutchinson Job
Title:
Paper Flow Group Supervisor Employer:
Brown & Root Supervisor:
Bill Baker Supv. Employer:
Brown & Root Responsible for the day-to-day activities of the Unit 2 paperflow groups which prepare, distribute, control and store work packages for Craft and QC.
Also responsible for the field administrative group which maintains timekeeping, training and personnel records for the B&R construction force, r.
Bob Siever Joo
Title:
Field Inspection Supervisor Employer:
Brown & Root Supervisor:
J. O. Hicks Supv. Employer:
TUGC0 Responsible for implementing the CPSES QC inspection program.
s.
Ted Blixt Job
Title:
QE Group Supervisor Employer:
Brown & Root i
Supervisor:
Gordon Purdy Supv. Employer:
Self Responsible for implementing portions of the CPSES QA program including issuance of QA procedures / instruction manual, io.
t.
Dwight Woodyard
+
Job
Title:
QE Employer:
Brown & Root Supervisor:
Ted Blixt Supv. Employer:
Brown & Root Responsible for assuring that the input for QA procedures / instructions is approved by the third party organizations.
4
- Notes:
(A)
"K.
London" (item "K.")
may have been intended to refer to:
Art London Job
Title:
Startup Electrical Group Leader Employer:
IMPELL Corp.
Supervisor:
Ken Luken Supr. Employer:
Westinghouse Responsible for supervising electrical startup activities.
(B)
" Frank Powers" (item "M.")
may have been intended to refer to:
Fred Powers Job
Title:
Unit 1 Bldg. Manager Employer:
TUGCO Supervisor:
R.E. Camp (Unit 1)
J.T. Merritt (Unit 2) l Supr. Employer:
IMPELL Corp. (Camp)
TUGCO (Merritt)
Accountable for the management of the Unit 1 task force personnel that will assume the quality implementation and timely completion of construction work activities necessary to support fuel load of Unit 1.
1
)
DEC 3 '85 S:33 POPES GR/617-350-5051 PAGE.13 i
Signatures l
As to Answers:
I, Terry G.
Tyler, being first duly sworn, do depose and say that I am the Program Director o.
the Comanche Peak Response Team ("CPRT") (see " Comanche Pea.a Response Team Program Plan," 6/28/85), that I am famil c dun the information contained in the CPRT files and available to CPRT third-party personnel, that I have assisted in the preparation of the foregoing answers, and that the foregoing answers are true, except insofar as they are based on information that is available to Texas Utilities or the CPRT (third-party personnel) but not within my personal knowledge, as to which I, based on such information, believe them to be true.
W N
TerryGpTyler Sworn to befoy'e me this y o f/W-
= = r, 1985:
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~' ROCE3T K. C/ D.111 Notary Publi NOTAM FU3' O My Commissi Expires:
??y Cc :" 3 M *: M {...
As to objections:
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Thomas G. Dignan, Jr.
T R. K. Gad pII i
Ropes & Gray 225 Franklin Street Boston, MA 02110
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(617) 423-6100 Counsel for the Applicants 1
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CERTIFICATE OF SERVICE j
I, Robert K.
Gad III, one of the attorneys for the Applicants herein, hereby certify-that on December 9, 1985, I made service of the " Applicants' Answers to CASE's Interrogatories to Applicants j
(November 15, 1985)" by mailing copies thereof, postage prepaid, i
to:
Peter B. Bloch, Esquire Herbert Grossman Chairman Alternate Chairman Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board.
Board U.S. Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 3
i 1
Dr. Walter H. Jordan Mr. William L. Clements Administrative Judge Docketing & Services Branch i
881 W.
Outer Drive U.S.
Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C.
20555 1
Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing j
Appeal Panel Board Panel U.S. Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Stuart A. Treby, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S.
Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission 7735-Old Georgetown Road r
Room 10117 Bethesda, Maryland 20814 i
5 L%WL&
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Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel P.O.
Box 12548, Capitol Station U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C.
20555 Anthony Roisman, Esquire Joseph Gallo, Esquire Executive Director Isham, Lincoln & Beale Trial Lawyers for Public Justice 1120 Connecticut Avenue, N.W.
2000 P Street, N.W.,
Suite 611 Suite 840 Washington, D.C.
20036 Washington, D.C.
20036 Dr. Kenneth A.
McCollom Mr. Lanny A.
Sinkin Administrative Judge 3022 Porter Street, N.W.,
- 304 Dean, Division of Engineering, Washington, D.C.
20008 Architecture and Technology Oklahoma State University Stillwater, Oklahoma 74078 Ms. Billie Pirner Garde Mr. Robert D.
Martin Citizens Clinic Director Regional Administrator, Government Accountability Project Region
1901 Que Street, N.W.
U.S.
Nucle ar Regulatory Commission Washington, D.C.
20009 Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B. Johnson 7 Geary S. Mizuno, Esquire Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director P.O.
Box X, Building 3500 U.S.
Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Maryland National Bank Bldg.
Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 Nancy Williams Mr. James E.
Cummins Cygna Energy Services, Inc.
Resident Inspector 101 California Street Comanche Peak S.E.S.
Suite 1000 c/o U.S.
Nuclear Regulatory San Francisco, California 94111 Commission P.O.
Box 38 Glen Rose, Texas 76043
)p I
/t Robert K.
ad III i
,