ML20138G424

Applicant Response to Case 851115 Interrogatories Re Comanche Peak Review Team Program Plan.Certificate of Svc Encl.Related Correspondence

ML20138G424
Person / Time
Site:	Comanche Peak
Issue date:	12/09/1985
From:	Gad R, Tyler T ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	Citizens Association for Sound Energy
References
CON-#485-482 OL-2, NUDOCS 8512160322
Download: ML20138G424 (24)

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. UNITED STATES OF AMERICA sh[,lfjf eg y 3'

NUCLEAR REGULATORY COMMISSION .

h before the ATOMIC SAFETY AND LICENSING BOARD 4

)

In the Matter of )

) Docket Nos. 50-445-2 r.

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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Introduction In each case where an answer or partial answer is 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" or " deficiency") at CPSES could have been identified.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

_ _ _ _ _ _ _ _ _ - - - _ - - u

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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):

e 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:

f '

. SYSTEM .PROCEDURFS DEVIATION RECORD TTPE.

CPRT' CPRT Program Plan and:

l '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-l Deficiencies Design Deficiency Report and Errors (TDDR)*

(Includes Input from CPRT-DAP-DIRs and from SAFETEAM) i Test Deficiency CP-SAP-16 Test. Deficiency Report (TDR)

Non-conformance (Includes Input from

Reporting CPRT Testing TRT ISAPs and from SAFETEAM)

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 Non-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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, SYSTEM PROCEDURES. DEVfATXON RECORD' TYPE STA-405 Non-conformance Report (NCR)

Non-conforming Conditions, any System Transferred te 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

• 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 y" non-conforming conditions produced by these contractors' programs is used to. prepare a.TUGCO NCR or TDDR.

c 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."

Y .,.

The procedures regarding CPRT are or will be contained in th'e CPRT Working Files for the ISAPs and DSAPs, which will be produced.for inspection in accordance~ with the Applicants' answer to Interrogatory / Request No. A-14 of'the set propounded by

. CASE on 8/27/85. Other procedures are available for inspection and copying upon request.

Interrogatory No. 2 Question:

2. Identify all classes of persons other than' full-time employees of TUGCO or. Brown and Root who have used any of-these mechanisms'since June 30, 1984. " Classes of persons" is intended to allow

_(but not require) this answer to disregard the

.name of the particular person but is intended to disclose the name of.the organization'for which the person worked and the person's or organization's status,.i.e., independe'nt contractor, consultant, sub-contractor, etc.

_nswer:

A Mr. Jim _ Wells of Duke Power Company, serving as Director, TUGCO QA.

Mr.-Phillip Halstead and Mr. Dave McAfee, of Daniel Construction Company, serving as Site QC Manager and QA Manager,.respectively.

Mr. R.E.' Camp, IMPELL Corp., serving as Assistant Project General Manager, Unit 1.

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i

C, Ebasco Services, Incorporated: (1) cable tray and conduit supports requalification program; *

-(2) certain engineering support for TUGCO Nuclear

. Engineering; (3).certain quality control inspectors.

I-IMPELL Corp.: (1) start-up services;.(2) cable tray and conduit support requalification; (3) other support services.

Westinghouse Corp.: (1) start-up services; (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. I Interrogatory No. 3 Question:

3. Describe the procedure (s) that should have been followed during the period June 30, 1984,-to the -

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present if a person,. other than a full-time employee of TUGCO or Brown and-Root, saw a condition at CPSES which they_ believed may have be'en a deficiency.

Answer:

The Applicants are unable to answer this interrogatory, with respect to any person other than CPRT and the persons and organizations identified in the answer to Interrogatory No 2, in the absence of --

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some specification of who the supposed person might be.

With respect to CPRT and such persons, see the respon~se 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.

-j' Interrogatory 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 y

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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.

JAnswer:

If this interrogatory seeks the procedures by

~which suspected deviations should be handled, see the .-

-response to Interrogatory No. 1. If this interrogatory

. seeks ~information1 about how each and every ona of the

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identified suspected deviations has been handled over the course of the construction project, such information is containe'd in, or could be extracted from an examination, audit or inspection of,' the records' associated with the procedures identified -in response to Interrogatory No. 1 or prior versions thereof, and the. burden of deriving or ascertaining such information 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 Lthe period subsequent to June 30, 1984, at either the 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 --

f- .

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;

'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 f~T-9.

resigned (see Transcript of Public Meeting in Granbury, Texas, on November 5, 1985, at 62-63), all of them.

Interrogatory No. 8 Question:

8. Of the persons or organizations identified in the answer to question 6 other than those listed in theLanswer 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 Bennetzen

d. Chuck Welch

e. J. D. Hicks

f. . Mark Welch l

p

g. M. G. Krishner

.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.

Interrogatory No. 10 Question:

10. What, if any,. steps have been taken by TUGCO or Brown and Root to, rehire persons who have 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" hs a special cla'ss, 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.

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 Question 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 does not_ seek a legal. conclusion but a

p.

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, 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 "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

notfyet' 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 p p,e--., ., e go

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 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.

Without waiving it's' 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

-Question:

~

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.

F'-

• Answer:

No answer required.

• Interrogatory No. 15 Question:

15. At whatitime,.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

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proposed dates and alternative dates)'to permit a response.

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ATTACHMENT T0 " APPLICANTS' ANSWERS TO

~ CASE INTERR0GATORIES TO APPLICANTS" (November 15, 1985)

a. C. Thomas Brandt Job

Title:

QE Supervisor-JEmployer: Ebasco Supervisor: P. Halstead Supv. Employer: Daniel Responsible for the' training, corrective action, 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. Administrative 1y 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.

r-

f. 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. Hilks Supv. Employer: TUGC0 Functional supervision of all inspectors for the Unit 2 construction inspection activities.

h. Bill Cromeans Job

Title:

Civil Supervisor / Laboratory Supervisor

' Employer: Brown & Root Supervisor: J.-B. Leutwyler Supv. Employer: Brown & Root Responsible for inspection and testing of construction materials in soils, water and concrete.

1. J. B. Leutwyler Job

Title:

QC Supervisor-for Safeguard 2 Employer: Brown & Root Supervisor: M. G. Krishner Supv. Employer:

Ebasco

~

Responsible for supervision of QC non-ASME personnel for inspection of all non-ASME. activities and' Safeguard 2.

J.- Doug Snow Job

Title:

QC Coordinator Employer: Brown & Root

. Supervisor: P. Halstead

-Supv. Employer: 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.

c c x E

l '

m. Frank Powers - no'rycord of such a person at CPSES. s

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n. J. T. Merritt -

Job

Title:

Assistant Project General Manager

'~ ' ~ ' '

Employer: TUGC0 V J.6 i" '

Supervisor: '

J. B. Georhe/Coitstruction mA. B. kott/5tirt-Up -'

Supv. Employer: TUGC0 " .

ResponsibleforengineeringJ.ndconstructionactivitiesandfo'h start-up testing. -

o. James Wells s

Job

Title:

Director, QA

\'

.s Employer: ' Duke  %

Supervisor: John Beck ,.

Supv. Employer: TUGC0 Responsible for management and direction of the TUGCO,0A organization. _

p. Ivan Vogelsang s Job

Title:

Pro]ect Support Engineer s Employer: TUGC0 m Supervisor:

Supv. Employer:

R. E. Camp Impell

• c'

\

.\

Project' interface in Electrical and I&C areas. '

q. H. Hutchinson -

Job

Title:

Paper Flow Group Supervisor '

Employer: Brown & Root Supervisor: 48ill Baker '

Supv. Employer: Brown & Root t

Responsible for the day-to-day activities of the Unit 2 paperflow "

groups which prepare,~di nribute, control and store work packages ,

for Craft and QC. A ho responsible for the field administrative s ' ,

groupwhichmaintai,nftimekeeping,trainingandpersonnel. records \

for the B&R construction force. , s

, M  : \

r. Bob Siever 4,.. 3 JoD

Title:

Field Inspec, tion Supervisor Employer: Brown & Root, pv p yer: hGb .

Responsible for implementing I the CPSES QC inspection program. s

.- 1 Uv'

s. Ted Blixt ,

N Job

Title:

QE Group Supervisor Employer: Brown & Roos s Supervisor: Gordon Purdy ,,

Supv. Employer: Self '

g .

Responsible for implementing portions of the CPSES QA progeat including issuancg of QA procedures / instruction manual.

m. .

ws

= -t' k

n_ _.

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.

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L

• Notes:

London" '(item "K.") may have been intended

~

-- ( A) "K.

to refer-to:

Art. London ~

Job

Title:

Startup Electrical Group Leader

' Employer: IMPELL Corp.

' Supervisor: .. Ken Luken L .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) 4 l: J.T. Merritt (Unit 2)

. Supr. . Employer: IMPELL~ Corp. (Camp)

E TUGCO (Merritt)

I ' 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.

(-

f E

D'EC 5 '89 8:33 R0 PES GR/817-350-5051 PAGE.18

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T-t Signatures As to Answers: 'i "tr I, Terry G. Tyler, being first_ duly sworn, do depose i

and say_that I am the Program Director of the Comanche Peak

^

Response Team ("CPRT") (see " Comanche Peak" Response Team Program Plan," 6/28/95), that I am familiar'with the i  !

t information contained in the CPRT fil'es and available to

.CPRT third-party personnel, that I have, assisted in the I

preparation of the foregoing answers, and that the foregoing i answers are true, except inoofar as they are based on

'information that is available to Texas Utilities or the CPRT

'v ) e L (third-party personnel) but not within my personal

. knowledge, as to which I, based on such information, believe 1

them to be true. I W ~

. b)

Terry G[/ Tyler //

corber*

Sworn to bef me this , ,

yo =

=-==r, 1985:

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x -- ROBERT K. C/0,111  ;

Notary Publi NOTA'tY PUBLIO s  !

My.Commisai Expires: th cemdc.:r. trn: M' 5. E,,'

As to chiactions: ,

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, . Thomas G. Dign~an, Jr. T R. K. Gad p1I

~ Ropes & Gray ,

A 225 Franklin Street Boston, MA 02110 r

(617) 423-6100 Counsel for the; Applicants b

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~ CERTIFICATE OF SERVICE A

=I, Robert K. Gad III, one of the attorneys for the Applicants

s. .herein, hereby certify that on December 9, 1985, I made service of the " Applicants Answers to CASE's Interrogatories to Applicants t

'{ November 15, 1985)" by mailing copies thereof, postage prepaid, to:

-Peter B.LBloch[~ Esquire Herbert Grossman Chairman Alternate Chairman

m. Administrative' Judge. Administrative Judge

^"7 rAtomic. 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 JDr. Walter H.-Jordan Mr. William L. Clements SAdministrative Judge Docketing & Services Branch 881 W. Outer Drive U.S. Nuclear Regulatory Commission Oak. Ridge,. Tennessee 37830 Washington, D.C. 20555

~

Chairman Chairman

' Atomic -Safety and -Licensing Atomic Safety and Li~ censing 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 3E S . Nuclear Regulatory. _ Dallas,. Texas 75224-Commission

, 7735 Old Georgetown. Road

. Room-10117

. Bethesda, Maryland 20814 P W

r L[$W.s ocdA X

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Tm? .

.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,ED.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 IV

'1901 Que Street, N.W. U.S. Nuclear Regulatory Commission Washington, D.C. 20009 Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011

-ElizabethTB. Johnson N Mizuno, Esquire Administrative Judge  :#yGearyS.

- Office of the Executive ,

. Oak Ridge National Laboratory Legal Director i '

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 c : Nancy Williams- Mr. James E. Cummins Cygna Energy Services, Inc. Resider.t 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 se, Texas 76043

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Robert'K. Gad III

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