ML20206H020
| ML20206H020 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/13/1987 |
| From: | ROPES & GRAY |
| To: | GREGORY, M. |
| References | |
| CON-#287-3076 CPA, NUDOCS 8704150229 | |
| Download: ML20206H020 (21) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 17 AR? 13 P4:21 before the FFICE G i ,ia ,;,, -
ATOMIC SAFETY AND LICENSING BOARD hSfIC .
)
In the Matter of )
)
TEXAS UTILITIES GENERATING ) Docket No. 50-445-CPA COMPANY et al. )
)
(Comanche Peak Steam Electric )
Station, Units 1 and 2) )
)
)
PERMITTEES' FURTHER1 RESPONSES TO "MEDDIE GREGORY'S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS (SET 5)"
Pursuant to 10 CFR 55 2.740, 2.740b and 2.741, the Permittees respond herein to "Meddie Gregory's Interrogatories and Request for Production of Documents (Set 5)."
The Permittees have ignored the definitions and guidelines in the paragraphs labelled "a" through "e,"
inclusive, as contained in the document entitled "Meddie Gregory's Interrogatories and Request for Production of 1 .
By agreement of the parties, the Permittees are continuing to respond to these Interrogatories as their investigation with regard to each issue is completed.
8704150229 870413
{DR ADOCK 05000445 PDR bll$0
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Documents (Set 5)," insofar as the same are contrary to the !
l Rules of Practice.
Interrogatory 1:
When did Applicants first receive notice of the issues identified by the NRC's TRT Reports and SSERs, and in what .
form did that notice come (i.e., NCR, IR, audit report, memorandum, consultant's report, etc.)?
Interrogatory 2:
I For each item identified in Interrogatory 1, identify what response was taken to the problem and by whom.
Interrogatory 3:
If the answer to Interrogatory 2 is that no action was taken, explain the reason that no action was taken. If that reason is because Applicants relied on a "second opinion,"
identify the individuals or organizations who provided that opinion.
Interrogatory 4:
Identify how each " finding" identified in Interrogatory 1 was integrated into consideration of the subsequent findings by others. (For example, how were the findings by the NRC in 1978 and 1979 integrated into Applicants' response to the findings by the Management Analysis Corporation (MAC)?)
PERMITTEES' RESPONSES (TRT ISSUE: HOUSEKEEPING AND SYSTEM CLEANLINESS) !
At page 0-156 of SSER 11, dated May, 1985, the TRT stated:
The TRT reviewed a draft of flush procedure l FP-55-08, dated August 6, 1984, that was in the l l
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. initial stages of preparation. The purpose of this procedure was to verify cleanliness of the Unit 1 reactor coolant loops, including the reactor vessel
' (RV), by means of handwiping, visual inspection, and swipe testing. Those tests used to determine surface chloride contamination were performed by i _. TUEC systems test engineers and Westinghouse l
representatives. The TRT noted, however, that'
! FP-55-08 required only two swipe tests of the RV (one on the side and one on the bottom). Although ~
the procedure was still a draft, the TRT expressed l
its concern in regard to the adequacy of performing
! only two swipe tests to verify the cleanliness of an item the size of the reactor vessel.
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Permittees believe that the TRT letter of 01/08/85 was their first notice of this supposed issue. Reviewing the background related to Reactor Coolant System (RCS) flush and l
l cleanliness verification reveals that a series of cleanliness confirmation activities occurred. Prior to Startup accepting custody on February 18, 1982, a visual 1
i inspection of all four (4) loops, steam generators, reactor l
coolant pumps, and reactor vessel and internals was conducted. Reactor Coolant System loops were handwiped on several occasions between January 1982 and July 1982 following Emergency Core Cooling System (ECCS) flushes. The RCS was also cleaned, visually inspected and tested for chloride residue in preparation for cold hydrostatic test.
During cold hydro test (July 5, 1982 - August 7, 1982),
water samples were analyzed to assure water chemistry specifications were maintained.
l In preparation for Hot Functional Test (HFT) (October 1982- January, 1983), the RCS was cleaned and visually -.
inspected with water samples again being taken and analyzed J'
to assure maintenance of water chemistry specifications.
During the testing of other fluid systems, the RCS was periodically filled and drained.
Prior to October 1984, when cleaning functions were -
turned over to Operations, cleaning was performed in .
accordance with Flush Plan FP-55-08. The procedures within this Plan satisfy Westinghouse Specifications PS 292722
" Cleaning and Packaging Requirmements of Equipment for use in the Nuclear Steam Supply System." The two (2) chloride residue swipes required by FP-55-08 were intended to be a minimum number, with one swipe (minimum) on a vertical j surface and one swipe (minimum) on a horizontal surface.
l The actual number and specific location of swipe tests was left to the discretion of the chemist performing the swipes.
Accordingly, although the Flush Plan only required swipes at two (2) locations, test lab technicians actually took swipe tests at eight (8) locations in the reactor vessel.
(Project Letter CPPA-45355).
The results of the August 1984 swipe tests for the j
reactor vessel were sent to Westinghouse for confirmation of their acceptability on 7/25/85 (CPPA-45355). Westinghouse confirmed the acceptability of the swipe tests on 7/31/85.
I (TBX-M-1234). Accordingly, the RCS was turned over to operations in October 1984, following final QA acceptance of system cleanliness.
On 01/08/85, the NRC letter to TUGCO notified TUGCO of
the TRT finding. Following formation of the CPRT, ISAP i
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VII.a.7 (Housekeeping and System Cleanliness) was issued to address the TRT finding with regard to the adequacy of the number of swipe tests performed on the reactor vessel.
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(TRT ISSUE: INSTALLATION OF MAIN STEAM PIPES) i At page N-109 of SSER-10 dated April, 1985, the TRT i found that:
. . . the partially installed [ Unit 1, Loop 1] main steam line had been used in flushing operations and sagged due to settlement of temporary supports during flushing and/or construction. TUEC's analysis to assess stresses in the main steam line due to the repositioning 3
operations was inadequate because stresses due to the full sequence of events involved in the incident were not evaluated.
i The TRT also determined that similar repositioning
} operations had been performed on the Unit 1, Loop 4 main
] steam line. No assessment of this second incident has
] been performed by TUEC . . .
TRT reviews also found that the B&R construction practice of using temporary supports during piping erection was not in compliance with the G&H Specification 2323-MS-100 requirements.
Allegation AP-13 as identified on page N-99 of SSER 10 states that "a 32-inch Main Steam line was forced into position by the polar crane and 3-ton come-alongs." In addition, the TRT review of the Gibbs & Hill Specification No. 2323-MS-100 indicated that there were inadequate requirements and construction practices for the support of l
the main steam line during flushing, and for temporary supports for piping and equipment in general. In particular, evaluations to assure the adequacy of temporary
supports during flushing and installation were not required by 2323-MS-100.
Permittees believe that their first notice of this
- precise issue came in February 1983 during the course of, ASLB hearings. On February 3, 1983, Citizens Association ,
for Sound Energy introduced testimony and affidavits regarding allegations of incorrect and inadequate construction practices at Comanche Feak Steam Electric Station (CPSES). In the affidavit of Robert L. Messerly, a former Brown & Root employee, an allegation was made concerning the repositioning of the main steam line, Unit 1, Loop 1. The allegation stated that the alleger had witnessed the repositioning of the main steam line with the polar crane and that the line had been forced into position because it would not fit. The alleger also testified that he had to remove and then reestablish temporary supports for the line.
In light of the allegation, the Field Mechanical Engineer sent a memo on February 4, 1983, to the Pipe Support Engineer explaining the sequence of events associated with the allegation and reasons for the repositioning. (Commons TUSI Memo, 2/4/83). In further response to the allegation, on February 15, 1983, a stress analysis was performed of the as-installed condition of the repositioned main steam line. The results recorded were within acceptable parameters. (Analysis of 2/15/83, as recreated on 8/24/84). .
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. On September 29, 1983, the NRC concluded that based on its investigation that "no violations or deviations were identified in this area (main steam line allegations), hence
_. the allegations cannot be substantiated." (NRC Inspecti,,on Report: 50-445/83-27, 9/29/83).
During its on-site investigation in August 1984, the TRT explored extensively the allegations related to repositioning main steam line and the fabrication of temporary supports. The TRT established that temporary supports were fabricated and used in repositioning the main steam line and more generally were employed during construction of CPSES to maintain the required positions and alignment of components during installation until designed supports were permanently installed.
In its review the TRT determined that with respect to the welding of temporary supports, the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code, 1974 Edition (including Addenda through Summer 1974) and the American Welding Society (AWS) D1.1-75 Structural Welding Code do not address the suhject of temporary supports except for temporary welds attaching to, and their removal from Code installations.
The TRT did establish that Permittees had appropriate requirements and procedures for welding of temporary attachments to permanent components. (Brown & Root Procedure CP-CPM-6.9E, Revision 7, paragraph 3.17 and -
Revision 6 of Gibbs and Hill Piping Erection Specification l
2323-MS.-100). The TRT also found that the practices employed in the fabrication and installation procedures were adequate. However, since many of the temporary support
-- practices used were identified as " unwritten principles,,"
the TRT concluded that they should be controlled by written ,
procedures. In essence, the TRT concluded that Permittees unwritten temporary support requirements and procedures were adequate, going beyond even the G&H Specification 2323-MS-100, but being deficient, however, only in their unwritten form.
Permittees were informed that the installation of main steam pipes and fabrication of temporary supports were TRT concerns in the TRT letter of 11/29/84. Subsequently, the CPRT issued ISAP V.e (installation of Main Steam Pipes) to address and resolve the TRT concerns. Included in the- CPRT effort are a number of temporary support procedure and specification revisions addressing concerns identified by TRT.
(TRT ISSUE: ONSITE FABRICATION)
At page 0-302 of SSER 11 dated May, 1985, the TRT stated that:
The TRT findings regarding onsite fabrication shop activities indicate that:
A. The scrap and salvage pile in the fabrication _(fab) shop laydown yard was not identified and did not have restricted access.
- B. Material requisitions prepared in the fab shop did not comply with the applicable procedures.
.l C. The fab shop foremen were not familiar with
. procedures-that controlled the work under their responsibility.
D. Fabrication and installation procedures did not include information to ensure that B&R-fabricated threads conformed to design specifications or to an applicable standard.
__ E. Indeterminate bulk materials that accumulated as a result of site cleanup operations were mingled'with controlled safety and nonsafety material in the fab, shop laydown yard.
F. Site surveillance of material storage was not
- documented.
I G. Work in the fab shop was performed in response to 1 memos and sketches instead of hangar packages,
[ travelers, and controlled drawings.
J Permittees believe that their first notice of any concern relating to the fabrication shop was on July 16, 1976, during an exit interview for NRC Inspection No. 76-07.
This inspection identified a lack of adequate procedural process control of welding for both QC and craft.
On July 22, 1976, Site Surveillance Report No. C-10-76 was issued which identified Brown & Root procedure QCP-2.13, for fabrication shop welding activities, as not being satisfactory. (This was the same condition as identified in NCR Inspection No. 76-07.) On that same day and in response to Surveillance Report No. C-110-76, the TUSI Site QA l
- Supervisor issued Memo TUQ-185 to Brown & Root ordering that work stop on site fabrication of safety related miscellaneous steel components.
I on July 27, 1976, Memo TUQ-188 was issued to lift the l
stop-work order of TUQ-185 following a revision of Brown & l Root procedure CP-QCP-2.13. However, after further review l
9 of the requirements related to fabrication operations, "
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sufficient concern existed to reinstate the stop-work order and this was accomplished via Memo TUQ-190 (07/28/76).
On 08/05/76, Brown & Root furnished a memo to TUSI Site
, QA Supervisor for proper handling of miscellaneous metals fabrication. This description was deemed sufficient to satisfy CPSES PSAR, Section 17.1.1.5 commitment.
Accordingly, the stop-work order was lifted based on this information via Memo TUQ-196.
On 08/26/76, Brown & Root responded to NRC Inspection No. 76-07 and fully described the revisions and procedure corrections that were to be taken. (BRT-595). Likewise, TUGCO responded to the NRC regarding Inspection No. 76-07 and identified the same corrective action as described by Brown & Root's transmittal. On 09/21/76, the NRC issued Inspection Report No. 76-10 which closed out the open item on Report. No. 76-07. With the issuance of the Report, Permittees believed the fabrication shop was being operated correctly.
On 11/23/81, however, the results of an ASME survey was issued to Brown & Root. Deficiency Item F in the ASME report addressed " Identification and Control of Materials and Items" in which Brown & Root uses salvaged components from Section III supports to fabricate other Section III supports without having the Certificate of Compliance for the material. On 01/15/82, Brown & Root issued NCR M-3131 which identified this condition. Subsequently, Brown & Root also transmitted to ASME for resurvey, its " Response to 10 -
1 Implementation Portion of Report of ASME Nuclear Survey conducted October 12-14, 1981, at CPSES." The corrective action referenced NCR M-3131 stated that Brown & Root will obtain Certificate'of Compliance for salvaged material from vendor.
Following a resurvey and exit interview, ASME considered ^
Deficiency Item F to be addressed by Brown & Root, but not closed. Additional time was needed for complete resolution.
Accordingly, ASME requested a completion date for corrective action. In response to this request, on 03/25/82, Brown &
Root furnished a schedule for completion and stated that closure would be concurrent with the closing of NCR M-3131.
NCR M-3131 was closed on 01/11/83. With this closure, the Permittees believed all identified problems regarding onsite fabrication had been solved.
On 01/08/85, however, the NRC letter to TUGCO identified the TRT concerns regarding onsite fabrication shop activities. Following formation of the CPRT, ISAP VII.b.1 (Onsite Fabrication) was issued to address the TRT findings.
This Action Plan provided for an assessment of onsite fabrication activities, in general, whether performed in the fabrication shop or other plant areas.
(TRT ISSUE: PLUG WELDS)
At page N-64 of SSER 10 dated April, 1985 the TRT found:
An NRC RIV [ Region IV) inspection identified
indications of unauthorized ' plug welds.' TUEC concurred with the RIV findings and issued NCRs, whose disposition action confirmed the presence of unauthorized ' plug welds.' The TRT concludes that the existence of these welds and the difficulty in detecting them raises a generic concern regarding
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the potential existence of an unknown number of such unauthorized ' plug weld' repairs of- -
questionable quality in the hundreds of base plates, pipe supports, and cable tray supports throughout Units 1 and 2. Potentially defective welds located in highly stressed areas could have safety significance. This concern of the TRT shall be addressed by TUEC.
Further in SSER 10 the TRT stated at pages N-329 and N-330:
The TRT investigated alleged generic problems regarding uncontrolled repairs to holes existing in pipe supports, cable tray supports and base plates in Units 1 and 2. These holes, which had been.
misdrilled during fabrication, were repaired by plug welds. Since these supports are Seismic Category I supports and the effects of the welds have not been evaluated, this constitutes a violation of Criteria IX and XVI of Appendix B to 10 CFR 50. Region IV inspections have confirmed the existence of such welds in cable tray supports located in the Unit 2 Cable Spreading Room.
Although the effects of unauthorized, undocumented and uninspected plug welds in some locations (e.g.,
the webs of I-beam or in structural members in compression) will be inconsequential, their effects in critical locations, (e.g., flanges of I-beams in flexure or in structural members in tension) in critically loaded supports or base plates could affect their structural integrity and intended function.
Permittees believe that the issue of uncontrolled plug welds as identified by TRT was first raised during the September, 1982 ASLB Hearings. In testimony filed on September 1, 1982, Darlene K. Stiner and Henry A. Stiner alleged that mislocated holes in cable tray and pipe supports were welded closed without engineering .
authorization. The allegers also stated that they were ,
L directed by their supervisor to make unauthorized walds, and L
that welds were made without adequate cleaning such that J these welds may have contained slag. It has also been
- j. determined, however, that Permittees might be said to have
~ notice of plug weld related concerns in mid-1979. During ASLB testimony in February, 1984 Darlene K. Stiner related -
an instance of-unauthorized plug welding on pipe supports 1
which occurred during 1979 (Page 10,286, Transcript).
< i Investigation revealed that the unauthorized welding was addressed at the time it occurred. The pipe supports in j question were scrapped and the responsible foreman was demoted on September 16, 1979 to a nonsupervisory position.
Shortly before the Stiner incident in 1979, the repair j of mislocated holes in cable tray supports was generically authorized in Design Change Authorization, DCA-5347. No i
similar generic authorization for repair of mislocated holes 4
in pipe supports was issued.
The construction and inspection procedures applicable to I the repair welding of mislocated holes at CPSES evolved with j time and were different for ASME components (e.g., pipe j supports) and AISC components (e.g., cable tray supports).
i' For ASME components, base metal repairs required the 1
4 issuance of a Repair Process Sheet (RPS) by the Project Welding Engineer. An equivalent document (Resolution of 4
Defects form and later the RPS) was used for base metal repairs of AISC components except for the repair of mislocated holes that were welds using pre-specified l
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techniques. In addition, the construction and incpection procedures applicable to cable tray supports did not require documentation specific to the repair of mislocated holes prior to November, 1980. Instead, the inspection of these
.. welds was temporarily documented using a QC acceptance -'
sticker on the support. Thus, while the repair of -
mislocated holes in cable tray supports was authorized, the inspection records prior to November, 1980 do not provide a basis to confirm or refute the allegation that some mislocated holes were repaired without QC inspection.
In January, 1980 the Brown & Root Senior Project Engineer issued Interoffice Memo No. 18507 providing direction on how to facilitate plug welds for cable tray hangers and instrumentation racks in accordance with applicable codes.
Recognizing the need for improved quality control tracking of weld repair of misdrilled holes, Revision 2 of inspection procedure QI-QP-11.10-2 was issued requiring all QC inspectors to document specifically all inspection of weld repairs to misdrilled holes through the use of the Operational Traveler which contained a step for plug welding. (11/10/80)
Effective August 4, 1981, WES-029, Rev. O, " Welding Specification for Field Fabrication and Erection for Structural Steel," was introduced outlining the requirements l
for making weld or base metal repair. Although not specifically addressing plug welds, the requirements were
interpreted to apply to such and thereforo plug welding was documented through the Repair Process Sheet.
In September, 1981, Henry A. Stiner alleged during an NRC interview that plug welds were illegally used to fill
~ holes found to have been drilled in incorrect locations tn1 various pipe supports, base plates and cable tray supports. .
In response to the allegation, the NRC conducted on investigation on September 15 - 16, 1981, and Inspection Report 81-12 was issued stating the investigation was unable i
to find significant problems to support the allegation.
i' Prefiled ASLB testimony of Darlene K. Stiner and Henry A. Stiner, dated September 1, 1982, as noted previously, further alleged the unauthorized practice of
! plug welding at CPSES.
! On July 16, 1983, Rev. I to DCA-5347 was issued providing further direction and guidance in plug welding procedures for unused holes in cable tray supports.
In response to the September 1, 1982, Stiner testimony, plug welds which may have been made without proper controls i were subjected to physical. tests by the Brown & Root Senior Project Welding Engineer to determine structural integrity.
The results of the tests completed on November 3, 1983, confirmed that the tensile strength of plug welds was still within the limits required even.though defects may have been induced into the plug welded areas.
Again in February, 1984, Darlene K. Stiner and Henry A.
Stiner alleged in testimony' filed in ASLB proceedings that' '
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unauthorized and unacceptable plug welding had occurred at CPSES.
During an exit interview conducted in March, 1984, an employee identified certain programmatic concerns in the
-. QA/QC program related to the traveler system whercby -
craftsmen were allowed to retain control of inspection documentation after QC had accepted work and prior to transfer of the traveler to permanent records.
NCR-M-84-00893 was issued on March 22, 1984, in response to two specific incidents in which craft personnel made changes on a traveler after QC acceptance. The travelers in question documented two plug welds.
NRC's Region IV performed inspections in the south yard tunnel and north cable spreading room in mid April, 1984.
No plug welds were found in supports in the south yard tunnel. Three I-Beams in cable tray supports in the north cable spreading room were found to contain plug welds.
Because no documentation could be found to substantiate these suspected welds, NCR's M-84-01230 R1, M-84-01231 R1, and M-84-01232 R1 were issued. Based upon Region IV's findings, the NRC issued a letter to TUGCO on April 30, 1984, requesting a response to the Region IV inspection results. TUGCO's response, (TXX-4183), issued on May 29, 1984, agreed with the NRC's findings and stated that applicable NCR's had been issued. TUGCO also agreed to perform additional visual inspection. Subsequent correspondence with NRC Region IV in July and August, 1984,
provided details of TUGCO's sampling plan, the proposed completion date of sampling and TUGCO measures taken to prevent recurrence.
TUGCO took various measures to prevent recurrence during
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the Summer of 1984. Changes were made in the Quality Inspection Program relating to plug weld inspection and -
documentation: QI-QP-11.10-2, Rev. 26; QI-QP-16.0-5,
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Rev. 10; UNSAT IR per CP-QP-18.0 (Inspection Report);
QI-QP-11,21-1 (Requirements of Visual Weld Inspection) were all issued. During the same period office memos TUQ-2183.1, TUQ-2189, TUQ-2194, TUQ-2195, TUQ-2197 and TUQ-2284 were issued defining actions to be taken regarding undocumented plug welds.
On November 29, 1984, the NRC letter to TUGCO notified TUGCO of certain TRT findings. Subsequently, the CPRT was formed and ISAP V.d (Plug Welds) and ISAP VII.a.2 (Non-conformance and Corrective Action System) were issued to address the SSER 10 findings with regard to plug weld inspection and documentation.
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l (TRT ISSUE: CONTAINMENT INTEGRATED LEAK RATE TESTING I (CILRT))
At page J-14 of SSER No. 7 dated January, 1985, the TRT stated as follows:
a generic problem could exist because when the CILRT leakage rate was calculated by a method different from that which was committed to in the FSAR, the FSAR had not been amended to reflect that change. The TRT questioned the TUEC procedure for 1
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- NRC. ,
i Further, at page J-83, the TRT required TUEC to
" identify deviations from FSAR commitments which had not been previously identified to the NRC."
4 Permittees believe that the TRT letter of September 18, "
1984, was their first notice of this issue. The TRT was concerned that a generic' problem might exist regarding procedures for documenting and identifying ESAR deviations to the NRC. The need to address FSAR commitments related to the testing program had been recognized since the inception r of the CPSES Startup Program. The first Unit 1 preoperational test was started in July, 1982, and the I applicable CPSES Startup Administrative Procedures regarding i
FSAR commitment compliance had been in place since 1979.
l Although the CPSES Startup organization did not have a specific written administrative procedure for processing an FSAR change until after the TRT review, their established practice was to complete a standard FSAR Change Request ,
l form. If the proposed change was accepted by CPSES, the information in the change request form was then incorporated into an FSAR Amendment which was forwarded to the NRC.
TUGCO believed this procedure adequately documented and identified FSAR deviations to the NRC.
Following notification by TRT of this issue on September 18, 1984, TUEC formed the CPRT and issued ISAP III.b (Conduct of the CILRT) to address the TRT. finding as
i ctat d in SSER No. 7 end undsrtcka tha ectiona required by the TRT therein.
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- StWC CERTIFICATE OF SERVICE I, Kathryn A. Selleck, hereby certify that on A g g il1g8 g I PRANCW made service of the within document by mailing copies th'ereof, postage prepaid, to:
Peter B. Bloch, Esquire Mr. James E. Cummins Chairman Resident Inspector Administrative Judge Comanche Peak S.E.S.
Atomic Safety and Licensing c/o U.S. Nuclear Regulatory Board Commission U.S. Nuclear Regulatory P.O. Box 38 Commission Glen Rose, Texas 76043 Washington, D.C. 20555 Dr. Walter H. Jordan Ms. Billie Pirner Garde Administrative Judge Midwest Office 881 W. Outer Drive 3424 N. Marcos Lane Oak Ridge, Tennessee 37830 Appleton, WI 54911 Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Lawrence J. Chandler, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S. Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224
, Commission Washington, D.C. 20555 l
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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 Mr. Lanny A. Sinkin ,
Executive Director Christic Institute Trial Lawyers for Public Justice 1324 North Capitol Street l
2000 P Street, N.W., Suite 611 Wr.shington, D.C. 20002 Washington, D.C. 20036 Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge Regional Administrator 1107 West Knapp Region IV Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B. Johnson Geary S. Mizuno, Esq.
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 Washington, D.C. 20555 Nancy Williams Cygna Energy Services, Inc.
101 California Street Suite 1000 San Francisco, California 94111
/ KaWhryn A. Selleck l
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