ML20205M810

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Partially Deleted Response to NRC Re Violations Noted in Insp Repts 50-528/86-07 & 50-529/86-06 on 860211-0313.Procedure Re Security Alarms Revised to Clarify Requirements in Security Plan
ML20205M810
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 04/22/1986
From: Van Brunt E
ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To: Martin J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20205M477 List:
References
FOIA-86-329, FOIA-86-363, FOIA-86-A-175 ANPP-36364-EEVB, NUDOCS 8704020500
Download: ML20205M810 (19)
v • d • e


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Arizona Nuclear Power Project P.O. BOX $2034 o PHOENIX, ARIZONA 85072-2034

, April 22, 1986 ANPP-36364-EEVB/DAL/98.05 1 Mr. John B. Martin, Regional Administrator U.S. Nuclear Regulatory Commission i

Region V 1450 Maria Lane, Suite 210 ,

Walnut Creek, CA 94596-5368-,

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1 and 2.

Docket Nos. STN 50-528 (License NPF-41) 1

,, STN 50-529 (License NPF-46)

Notice of Apparent Violations: 50-528/86-07-10, 50-528/86-07-03, (50-528/86-07-05, 86-07-06),

(50-528/86-07-04, 50-529/86-06-02), 50-528/86-07-09, 50-529/86-06-01, 50-529/86-06-03.

File: 86-001-493

Reference:

NRC Inspection Reports 50-528/86-07 and 50-529/86-06 (IE-V-737), letter from Ross A. Scarano to E. E. Van Brunt, Jr. , dated April 2,1986.

DearMr.-Mdrtin:

his letter is provided in response to the inspection conducted by Messrs. D. W.

Schaefer and L. R. Norderhaug of the NRC Staff on February 11, through March 13, 1986. ,,Ba s ed on the results of the inspection, 7 apparent violations of NRC j

requirements were identified. De apparent violations are discussed in items 6, 7, 8, 9 and 11 of the referenced letter. He apparent violations and their respective ANPP responses'are attached. -

His report contains Safeguards Information which must be protected against unauthorized disclosure in accordance with the provisions of 10 CFR .2.790(d).

Please ensure appropriate steps are taken to Safeguard its contents. l Very truly yours, W

E E. Van Brun , Jr.

WHEN SEPARATED FROM ENCLOSURES HANOLE ecutive Vice President THIS DOCUMENT AS DECONTROLLED. Project Director EEVB/DAL/dk At tachments cc: M. D. Schuster (w/a ttachments)

D. W. Schaefer (w/ attachments)

L. R. Norderhaug (w/a ttachments)

R. P. Zimmerman (w/ attachments)

A. C. Gehr (w/o attachments)

B704020500 B70327

! PDR FOIA

! THOMP86-A-175 PDR

ATTACHMENT i

NRC APPARENT VIOLATION

  • 50-529/86-06-01 The licensee's approved Security Plan dated October 1979, in Section 11.0 states in part that, Contrary to this requirement, on February 25, 1986, the licensee forwarded a 73.71 (c) report describing an event which occurred at Unit 2. Additionally, on March 13, 1986, Messrs. C. Kelley, ANPP and D. Schaeffer of this office discussed this event in detail. The licensee reported that on February 20, 1986, on three separate occasions, a contract employee from Combustion Engineering, not authorized to enter the jThe employee, however, on these three occasions,

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caushd additional alarms in the security alarm stations - a total of six ~

alarms. The UER alarms caused by this contract employee were as follows.

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Time In-Vital Area Time Out-Vital Area 9:53 a.m. 10:04 a.m.

i 11:47 a.m. 12:15 p.m.

3:38 p.m. 3:42 p.m.

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ATTACHMENT (00NT'D) j i

i NRC APPARENT VIOLATION 1

50-529/86-06-01 Upon questioning, this contract employee advised the licensee that he had apparently l

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,, ;1he failure by the licensee to respond to the security alarms at 9 :53 a.m. , 10 :04 a.m. , 11:47 a.m. , 12:15 P.m. , gnd 3:38 p.m. , represents an apparent Violation (50-529/86-06-01).

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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED As a result of the identified deficiencies, procedure 20SP-0ZZ0 7, "CAS/SAS Operations Procedure," was revised and is now in the review and approval cycle. Interim measures have been established to require that security personnel . An evaluation was conducted to determine the root cause of this deficiency. It has been determined thats the root cause was a misinterpretation of the . Security Plan requirements for responding to alarms. As a result, Procedure 20SP-0ZZ07 was revised to have security personnel i The criteria used for the revision was based .on the g

assumption that the t

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, . as ' required by the revised procedure, members of the security force were dispatched to investigate and implement compensatory measures as appropriate. It should be noted that the security alarm l system is designed to detect unauthorized entry attempts and is not i  !

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II.

THE CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF i NONCOMPLIANCE To prevent recurrence, procedure 20SP-0ZZ07 is being revised to require that security personnel As stated above, as an interim measure Security personnel have been directed to as of March 17, 1986. Additionally, a review of security's

-implem'enting procedures will be conducted to ensure that there are no other instances of potential misinterpretation.

In order to emphasize ANPP Management's concern, . and #

potential consequences of an employee .the Plant Manager issued a memo to all ANPP/PVNGS personnel on Fe bruary 26, 1986. This memo reminds all personnel to remain continually vigilant for potential violations and clearly points out the potential consequences of i

willfully violating the requirements.

III. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on March 17. 1986 when the Security force was directed to The procedure revision is currently 1986.

in the review cycle and is expected to be issued by May 9, The procedure review process will be a coordinated effort between -

ANPP and Security Compliance Departments and is expected to be complete by April 30, 1986.

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ATTACHMENT sc .

. APPARENT VIOLATION No. 50-528/86-07-10 '

. 1 Contrary - to the above requirements, a review of licensee Security Incident Reports determined tNat on January 17 and 24, 1986, ,

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!When discovered, the licensee i from the Protecte[ Area.

The licensee 171entified but did not report this violation to the NRC. (Note:

Paragraph 7 of this inspection report identifies these events as not being reported to the NRC.)

1 The failure to account for these -

srepresents an apparent violation. (50-528/86-07-10)

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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED As a result of the identified discrepancies, an evaluation of each

] incident was conducted. This consisted of a review of the

, A review of the identified Incident Reports was also conducted to ensure that the information presented was accurate and consistent with-- tha t '

Based on these reviews it was determined that the information presented in both Incident Reports could be misconstrued to mean that the ACAD's were missing for the period of time listed in the Inspection Report. However, as documented in --

it was verified that 3 by members of the Security Force.

The apparent. discontinuity between the Incident Reports and

', was caused by insufficient detail in the incident reports. These reports' are used as an internal documenting tool and are not designed to provide detailed information on each incident. The particular issue cited in the inspection report does not describe l

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Therefore, based upon the documented accountability checks conducted by the security force it appears

, regulations was committed. that no violation of our current l

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l II. THE CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FUhTHER ITEMS OF ~

NONCONFORNANCE Based upon a review of the potential deficiencies identified above and *

no violation existed. However, to enhance the overall identification and evaluation process, incidents are now being reported .

on Potentially Reportable Occurance (PRO) forms. This provides an independent review by ANPP Compliance of the documentation and evaluation conducted for each incident.

l Although not specifically related to this issue, ANPP Management has expressed concern over individual employee's control of This resulted in the Plant Manager issuing a memo February 25, 1986, to all ANPP/PVNGS personnel identifying the potential i

problems and establishing specific administrative and personnel actions to be taken if an ' '

III. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED N/A i

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ATTACHMENT APPARENT VIOLATION NO. 50-528/86-07-09 l

The licensee's approved Security Plan dated October 1979, in Section 5.2.2

, states in part that, 1

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Further, Section 1.6.6 of the approved Security Plan states in part that, Contrary to the above requirements, between September 30, and October 29, 1985,' Yital Area

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, Additionally, on November 1, 1985, for approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, this vital ,

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Further, on October 30, 1985, for a period ot '

approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, Vital Area

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3 The licensee identified these violations, but did not report the October 30, 1985, incident to the NRC. (No te: Paragraph 7 of this inspection report identified this event as not being reported to the NRC).

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ATTACHMENT (CONT'D) ',

APPARENT VIOLATION NO. 50-528/86-07-09 -

Each time the licensee discovered that a Vital Area door had been I

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, Following each of these events, the ficensee for these vital areas and with one exception, determined that no unauthorized person (s) had entered these vitial areas without having a proper level of vital area access authorization.

This one exception occurred on October 29, 1985, when one of seven NRC inspectors entered this vital area door. This newly assigned regional inspeitor had only been authorized unescorted access to plant protected ' areas and his should not have allowed him entry into this vital area.

Subsequent vital area entries were provided to this NRC inspector through an assigned escort.

The failure to limit Vital Area access to only those individuals authorized '

access to Vital Areas represents an apparent .

(50-528/86-07-09)

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CORRECTIVE STEPS MIICH HAVE BEEN TAKEN AND RESULTS ACHIEVED As stated in the Inspection Report, immediate corrective actions were taken to i

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iAlthough sia11ar in nature and root cause, each' instance is addressed separately.

b As st'ated in the inspection report, these items were identified by ANPP personnel and the proper compensatory measures were implemented when #

each occurrence was identified. In addition, an investigation was conducted each time to ensure that no unauthorized entries occurred.

'Ihe only unauthorized entry made was by an NRC inspector as described in the inspection report.

II.

THE CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NONCOMPLIANCE To prevent recurrence of these events, the following actions are being taken:

Changes are being implemented on the command structure and 7that will simplify the make it easier 'for the operator to differentiate between the units. Until completion of all door access level assignments / reassignments will be independently k

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Central Alarm Station (CAS) operators have been counseled on the necessity of ensuring the on Vital Area doors

, during inputs.

The testing method for Vital Area doors has been revised to include i

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III. THE DATE MIEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved in each case when the door s tatus was updated and the proper access levels assigned. The implementation of DCP No. A0-J-SK-051 is expected to be completed by February 1987.

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ATTACHMENT APPARENT VIDIATION No. 50-529/86-06-03 One apparent violation was identified.

The licensee's approved Security Plan dated October 1979, in Sectiod 3.1.4 states in part that,

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At approximately 9
30 p.m. on February 11, 1986, 4

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, The failure to provide adequate illumination at these two areas represents an apparent violation. (50-529/86-06-03) i

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_ CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED i

As a result of the identified discrepancies temporary lighting has been

installed i k 1

This is being -

' done to minimize shadows and dark areas particularly 4

"'  ! It should be noted that the lighting discrepancy '

discovered in 'this area had been recognized by ANPP Management. As a result, temporary lighting was installed, however, it was inoperable at j

the _ time of inspection. A lighting survey has been conducted and currently all required areas are illuminated to

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Based upon evaluations conducted in response to this issue, it has been 1

) determined that the root cause is permanent lighting that does not '

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! provide sa suff.*cient margin of 11*umination and area coverage to compensate for

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i II. THE CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF i

'. NONCOMPLIANCE I

."(PCR's Based upon the results of the lighting survey, Plant Change Requests 4

"coverag)e are being initiated provided by permanent to increase the illumination and area

, plant lighting where necessary. As an

! interim measure additional security force members have been assigned to monitor plant lighting. In order to address the more generic issue of j

j 1 security force members have been briefed on o.

the need to report all lighting

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! (to ensure adequate illumination.

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The installation of additional lighting, a greater sensitivity by security force members and 'the assignment of additional personnel to "

monitor this area should prevent recurrence. '

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} III. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED i 1

Full compliance was achieved with the installation of the required

! temporary lighting and additional Security postings on February 11, 1986.

j The survey, security force briefings, and the assignment of i

additional monitoring personnel have been completed. It is expected l

that the necessary Pm's will be submitted by April 30, 1986.

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ATTACHMENT APPARENT VIOLATION No. 50-528/86-07-03 i

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One apparent violation was identified.

During this inspection, the inspectors reviewed the licensee's S)curity ,

Incident Reports, Pbtentially Reportable Occurrence (PRO) Reports and (10 CFR

73.71c) Security Event Re ports. The inspectors' review of these reports 4

revealed situations at thits 1 and 2 which were not reported to NRC in accordance with the requirements of 10 CFR 73.71(c).

i i 10 CFR 73.71(c) requires in part, that each licensee notify the NRC Operations Center via the Energency Notification System, within a specified time, of any

{ event which threatens or lessens the effectiveness of a required physical

! security system.

The time period begins upon discovery of the event by any member ^of the security organization or any other licensee employee.

Additionally, the licensee is required to submit a written report to NRC i

1 describing the event in detail within five days of the time of discovery.

Specifically, the Table in this paragraph requires that an uncompensated Major i

! Ioss of Physical Security Effectiveness be telephonically raported to NRC

,, within one hour. Additionally, thi:, fable requires that a compedsated Major

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or an uncompensated Moderate Ioss of Physical Security Effectiveness be telephonically reported to NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Footnote 2 to this paragraph indicates in part, that a Major loss occurs when security features breakdown without proper compensation allowing unauthorized or undetected access to

Vital Areas.

Further, footnote 4 to this paragraph indicates in part, tha t the term properly compensated, means measures as specified in the security or contingency plans, or if the event is not specified in either of these plans, it means measures implemented within 10 minutes of an event's occurrence that provides a level of security equivalent to that existing before the event.

) Footnote 5 to Paragraph 73.71(c) indicates that moderate loss of physical security effectiveness occurs when a major loss of effectiveness is properly ompe:

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ATTACHMENT (CONT'D) 1 APPARENT VIOLATION NO. 50-528/86-07-03 A review of the licensee's Security Incident Reports determined that on i several occasions listed in the following table, security component failures, i

which provided an avenue for unauthorized access, were properly compensated for when discovered by the licensee but were not reported to the NRC.

DATE NATURE 09/24/85 09/30/85 10/30/85 11/26/85 o

i 12/21/85

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01/04/86 '

01/23/86 '

01/24/86 i

The failure to report these events represents a repeat violation.

(50-528/86-07-03)

NOTE:

On September 23, 1985, the licensee failed to notify the NRC of a specific deficiency in the perimeter (See NRC Inspection Report 50-528/85-30.)

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CORRECTIVE STEPS WICH HAVE BEEN TAKEN AND RESULTS. ACHIEVED _

As a ' result of the apparent deficiencies described above an evaluation was conducted to determine the root cause. It was determined that two factors have contributed to the overall confusion and subsequently, to not submitting the required reporta. -

Ihe current written guidance provided by the NRC is not concise and can lead to misinterpretations. However, the primary cause for not reporting- the incidents described above was misinterpretation by ANPP personnel of the regulatory requirements addressing this area.N As a result of this evaluation an Event Reporting Manual has been developed by ANPP which clarifies the reporting requirements of 10 CFR 73.71(c).

Kay security department personnel have been trained on the requirements and copies of the manual have been issued to the Central Alarm Station (CAS) for reference.

II.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF NONCOMLIANCE In addition to the development of the Event Reporting Manual, identified potentially repartable incidents are now being reviewed by both ANPP and Security Compliance personnel. These independent evaluations will provide a second level review and should ensure compliance with 10 CFR

,, 73. 71(c) .

III. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

' . Based upon conversations with NRC Region V personnel the specific events

  • " identified above will not be reported. 1herefore, full compliance was achieved on March 7, 1986 with the issuance of the revised Event

,, Reporting Manual and the completion of personnel training.

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ATTACHMENT C

APPARENT VIOLATION NOS. (50-529/86-06-02, 50-528/86-07-04, (50-528/86-07-05, and 50-528/86-07-06) .

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8. MC-81054 - Physical Barriers - Vital Areas

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Two apparent violations were identified.

A. The licensee's approved Security Plan dated October 1979, in Section 5.2.1 s'iates in part that,

1. Contrary to the above requirements, a review of licensee security

'I incident reports determined that on September 30, 1985, the vital area barrier installed s \

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Additionally, on November 26, 1985, the vital area barrie,r b '

. 'Ihe licensee identified, but did not report these violations to the NRC. (Note: Paragraph 7 of this inspection report identifies these two events as not being reported to the NRC).

(50-528/86-07-04)

2. Contrary to the above requirement, on February 13, 1986, the inspectors identified an opening in a vital area barrier in the vicinity (50-529/86-06-02) ,

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ATTACHMZNT (CONT'D)

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APPARENT VIOLATION 1;03. '(50-529/86-06-02, 50-528/86-07-04, (50-520/86-07-05, and 53-528/86-07-06) ,

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, , i The failure to , provide an, tadequate barrieE ,

f . I' represents three examples of an appar(,ent violation.

B. The . licensee's approved . l. . ,

Security Plan dat, ed occ,cber '1979, Section 5.2.1 ~statec in part that:

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Contrary ' t 4 the above requirement, air February 13, 1986, the inspectors identified a , ,

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Contrary to the above requirements, a review ofilicensee Security Incident Reports determined that on Septembe r 2 4,' 1985, an ,

inadequate Vital Area b.dr$er existe! adjacent to The.iteensee identified but did not report this violation to the EC. (Note: Paragraph 7 of this inspection report identifies this event as not being reported to the NRC). (50-52d/86-07-05)

The failure to provide an adequato barrier represents an apparent violation.. (50-528/86-07-06) i e

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. CORRECTIVE STEPS WICH HAVE BEEN TAKEN AND RESULTS ACHIEVED Due to the similarity of Items 8A and 8B they are being addressed as one concern.

As an . immediate response to the concerns identified by the NRC each barrier was properly compensated for by the stationing of security force members. The barriers identified by ANPP were properly compensated for at the time of their discovery. Since the identification of the barrier.

deficiencies, they have either been physically usaraded or administratively downgraded through the implementation of ~

The root cause of this issue is attributed to two tacrohs. Revisions to the Security Plan on October 1984 (Amendment 7) 3 and on August 1985 (Amendment 8) which revised the commitments for the installation of barriers, and a potential misinterpretation of these revised.. commitments which were used -during "walkdowns" and subsequent evaluations. Although deficiencies have been identified, ANPP Management's concern in this area is evident. ANPP conducted internal walkdowns which identified and initiated corrective actions for three (3) of the five (5) barriers described in the inspection report.

Additionally, an independent firm was contracted to evaluate the security barriers on two separate occasions.

II.

THE CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER ITEMS OF

' NONCOMPLIANCE In response to the identified concerns ANPP has initiated engineering walkdowns to evaluate existing barriers. The criteria being used during this evaluation has been verified to comply with the current commitments

' as defined in the Security Plan , Amendment 10 issued February 1986.

-Ba rriers identified as potentially deficient will be documented, properly compensated for and reworked as necessary. 1 1

III. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The valkdowns will be completed for Units 1 and 2 by April 30, 1986.

Evaluations and necessary rework is expected to be completed by May 30, 1986. Unit 3 barriers will be evaluated prior to full implementation of the Security Plan.

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o May 16, 1986 FREEDOdl GF iMFCEtMATM M REQUEST Nuclear Regulatory Commission 1717 H. Street, N.W. [I{)- -

~M 3 Washington, D.C. 20555 l To Whom It May Concern:

s- a i-p s Pursuant to the Freedom of Information Act (FOIA, 5 U.S.C.

522) and the Federal Privacy Act (5 U.S.C. 522a), I, Blaine P.

Thompson, Complainant in the following matter, hereby request copies of any and all NRC records and information, including but not limited to notes, letters, memoranda, draf ts, minutes, diaries, logs, calendars, tapes, transcripts, summaries, inter-view reports, procedures , instructions, drawings, charts, graphs, maps, photographs, files, agreements, handwritten notes, studies, data sheets, printcuts, notebooks, books, tele-phone messages, interim and/or final reports, investigative files, and any and all other records relevant to and/or gener-ated in connection with the following listed items:

Item 1. NRC and/or ANPP investigation and findings of ANPP Security Officer,i ~ allegations of assault

_ with deadly,weapos"and foreiable rape by Officer, p_.....,,, . ..., 3 Item 2. All above copy requirements and specifically, copies of tape recordings made concerning Arizona Republic Reporter, John Staggs' telephone call to-NRC officials on February 25, 1986 regarding Staggs' inquiries as to the NRC Exit Briefing discrepancies and related remarks of February 14, 1986 to ANPP officials. ,

Item 3. NRC inspection report and findings of non-compliance concerning NRC inspection of ANPP Security System and safeguards program on February 11, 1986 through February 14, 1986.

For any documents or portion that you deny due to a specific FOIA exemption, please provide an index itemizing add describing the documents or portions of documents withheld.

The index should provide a detailed justification of your grounds for claiming such exemption, explaining why each exemption is relevant to the document or portion of the document withheld. This index is required under Vaughn v.

Rosen (I), 484 F. 2d 820 (1973).

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I request that fees be waived.

s I hope to hear from you as soon as possible within the maximum 10 days the law stipulates.

Sincerely, NW?Y= g m Blaine P. Thompson 4910 W. Diana Glendale, Arizona 85302 cc: Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 BPT/pk l

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e May 16, 1986 N EDOBfGF.IMR2224,T m Nuclear Regulatory Commission C REQUEST

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1717 H. Street, N.W.

Wa sh i ng ton , D.C. 20555

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Nh3 To Whom It May Concern:

( h gg, fd' s- a i-n Pursuant to the Freedom of Information Act (FOIA, 5 U.S.C.

522) and the Federal Privacy Act (5 U.S.C. 522a), I, Blaine P.

Thompson, Complainant in the following matter, hereby request copies of any and all NRC records and in fo rma t ion , including '

but not limited to notes, letters, memoranda, draf ts, minutes, diaries, logs, calendars, tapes, transcripts, summaries, inter-view reports , procedures , instructions, drawings, charts, graphs, maps, photographs, files, agreements, handwritten notes, studies, data sheets, printouts, notebooks, books, tele-phone messages, interim and/or final reports, investigative files, and any and all other records relevant to and/or gener-ated in connection with the following listed items:

Item 1. NRC and/or ANPP investigation and findings of ANPP Security Officer,I ' allegations of assault

._ with deadly, weapon"and foreiable rape by Of ficer,

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Item 2. All above copy requirements and specifically, copies of tape recordings made concerning Arizona Republic Reporter, John Staggs' telephone call to NRC officials on February 25, 1986 regarding Staggs' inquiries as to the NRC Exit Briefing discrepancies and related remarks of February 14, 1986 to ANPP officials. .

Item 3. NRC inspection report and findings of non-compliance concerning NRC inspection of ANPP Security System and safeguards program on February 11, 1986 through February 14, 1986.

For any documents or portion that you deny due to a specific FOIA exemption, please provide an index itemizing and describing the documents or portions of documents withheld.

The index should provide a detailed justification of your grounds for claiming such exemption, explaining why each exemption is relevant to the document or portion of the document withheld. This index is required under Vaughn v.

Rosen (I), 484 F. 2d 820 (1973).

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eQ I request that fees be waived.

I hope to hear from you as soon as possible within the maximum 10 days the law stipulates.

Sincerely, N i-? h g= m Blaine P. Thompson 4910 W. Diana Glendale, Arizona 85302 cc: Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 BPT/pk

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