ML20209B079
| ML20209B079 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/29/1987 |
| From: | Selleck K ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| Shared Package | |
| ML20209B035 | List: |
| References | |
| OL, NUDOCS 8702030515 | |
| Download: ML20209B079 (52) | |
Text
WELATED COR8EW#
4 Filed: January 29, 1987 Upf D '
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 87 FE8 -2 All :02 before the 6Fi ATOMIC SAFETY AND LICENSING BOARD 0%
)
In the Matter of
)
Docket Nos. 50-445-OL,gy
)
50-446-OL TEXAS UTILITIES GENERATING
)
COMPANY et al.
)
)
(Application for an (Comanche Peak Steam Electric
)
Operating License)
Station, Units 1 and 2)
)
)
)
APPLICANTS' INTERROGATORIES TO INTERVENOR (Set No. 1987-3)
Pursuant to 10 C.F.R.
$ 2.740 ff the Applicants hereby propound the following interrogatories to Intervenor CASE.
Definitions As used in these Interrogatories, the following terms have the following meanings:
" Litigate" with regard to a topic or contention means to offer direct testimony relating to, to cross-examine on, to offer proposed findings or rulings regarding, or to urge the denial (or allowance subject to conditions) of the pending application on the basis of, the topic or contention in question.
0702030515 070129 PDR ADOCK G5000445 0
I O
?Id ntify with rc pact to en cxpart witnoca manna to
.e, state:
(a)
The name, mailing address, age and present professional or employment affiliation of the person; (b)
The profession or occupation and field of claimed expertise of the person; (c)
The history of formal education or training of the person, including, but not limited to, (i) the name and address of each school where the person received special education or training, (ii) the date those schools were attended, and (iii) a description of each degree earned, including the date and granting institution; (d)
The history of specialized training in the area of claimed expertise, including, but not limited to, (1) the type of training received, (ii) the name and address of the institution providing this training, and (iii) the dates of such training; (e)
The history of membership of the person in any professional or trade association in the area in the claimed expertise, including, but not limited to, (i) the name of each professional or trade association, (ii) the dates of membership, and 6
o (iii) o daccription of occh offico hold in each association; (f)
A list of publications of any kind by the person in the area of claimed expertise, including, but not limited to, (i) the title and subject matter, (ii) the name and address of the publisher, and (iii) the date of publication; (g)
A list of any and all licenses in the area of claimed expertise, including, but not limited to, (i) the designation of the authority by which the license was issued, (ii) the date(s) of the licensing, (iii) the requirements for obtaining each license, and (iv) the manner by which these requirements were met; (h)
The amount of time the person has worked in the field of claimed expertise, stating periods where work was other than on a full-time basis; (1)
The name and address of every person, or every i
corporation or other institution, that has employed the person within the last ten years of employment; i
i (j)
All periods of claimed self-employment, including a description of all duties and responsibilities 1
thereof; i
l (k)
All previous experience in the field of claimed l 1
o cxp;rtico which involved prrbicm3, cnnlycoc or studies similar to those concerning which the person is expected to testify in this proceeding; (1)
All other litigation in which the person has been consulted, specifying those matters in which the person has testified, including the name of the case or matter and the court or other forum in which testimony was given; and (m)
Any other experience in the field of claimed expertise.
" Identify" with respect to a document, means to state its date, its author, the type of document, its title (if any) and its present location.
Wherever appearing in these Interrogatories, the masculine form is defined to include the feminine and/or the neuter and the singular form is defined to include the plural wherever necessary to apply the context to any factual situation that may exist or to render the Interrogatory more inclusive in scope.
I-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If the answer to this Interrogatory is an unqualified negative, you may proceed to II-1).
The conclusion is that the above documents [as referred to in $5.1 of Issue Specific Action Plan I.b.3]
pr vida cd:quato justificction of tha cxisting conduit-to-cable tray separation; therefore, no plant modifications are required. (Result Report ISAP I.b.3, Revision 1, page 6).
I-2.
Please state each and every respect in which CASE disagrees with the above statement.
(a)
On what specific facts does CASE base its disagreement?
(b)
Identify the documents upon which CASE will rely to sustain its position of disagreement. or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion of the above statement?
If so, please (1) identify each expert witness whom Intervenor intends to present with respect to this conclusion; (ii) state the substance of the facts to which each expert witness is expected to testify; (iii) state the substance of the opinion or opinions to which each expert witness is expected to testify; (iv) provide a summary of the grounds for each
-S-
=
cpinien to which occh expart witnsoo 10 expected to testify; (d)
Does the Intervenor disagree with the above statement due to the methodology through which the statement's conclusions were reached?
If so, please state the reasons why the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the precise manner in which the implementation was flawed.
I-3.
Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the Results Report in question?
I-4.
Has the Intervenor propounded any Interrogatories regarding the Results Report in question in order to obtain any information it believes to be necessary so as to make its review of the Working File complete?
II-1.
Does the Intervanor intend to litigate the validity of the conclusions expressed in the following statement?
(If the answer to this Interrogatory is an unqualified negative, you may proceed to III-1.)
[Blased on hammer indication data obtained, in association with the 28-day cylinder data for the..
centrol cencrcto, it io conclud:d that tho tcnth percentile value of concrete-at-issue testable Concrete a
is well above the design strength of 4,000 p.s.i.
(Results Report, ISAP II.b, page 13).
3 II-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
(a)
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(i)
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through whi:h the statement's conclusions were reached?
If so. state the reasons why the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the reasons why the implementation was flawed. I
II-3.
Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the Results Report in question?
II-4.
Has the Intervenor propounded any Interrogatories regarding the Results Report in question in order to obtain any information it believes to be necessary so as to make its review of the Working File complete?
III-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the statement below?
(If your answer is en unqualified no you may proceed to IV-1.)
There is no evidence that systematic falsification of cylinder data or the non-performance of required tests occurred.
(Results Report, ISAP II.b, page 13).
III-2.
Please state each and every respect in which CASE disagrees with the above statement.
(a)
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement with the statement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion of the above statement?
If so, please cntw0r cli Intorregntorios I-2(c)(i) - I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which the statement's conclusions were reached?
If so, state the precise manner in which the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the precise manner in which the implementation was flawed.
IV-1.
Does the Intervenor intend to litigate the conclusions expressed in the following statement?
(If the answer to this Interrogatory is an unqualified negative, you may proceed to V-1).
[T]he Startup and [ Document Control Center) organizations have established sufficient measures to assure that [ System Test Engineers] and other responsible personnel are provided access to, controlled design documents.
This conclusion is baced upon reviewing the startup administrative procedures; the Startup and [ Document Control Center) organizations' previous experience with [ System Test Engineers) having controlled-distribution drawings for their assigned systems; the establishing of libraries within the Startup facilities; and the results of the random sampling and evaluation program. (Results Report, ISAP III.d, page 16).
IV-2.
Please state each and every respect in which the Intervenor disaJrees with the above statement.
.g.
(c) on wh:t tp cific fccto donc tho Intorvanor bcco ito disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the validity of the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(i) - I-2(c)(iv) with regard to their proposed tescimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the precise manner in which the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the precise manner in which the implementation was flawed.
IV-3.
Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the Results Report in question?
IV-4.
Has the Intervenor propounded any Interrogatories
-=
rCgnrding tha Roculto R: port in question in ordar to obtcin l
any information it believes to be necessary so as to make its review of the Working File complete?
V-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If your answer is an unqualified negative, you may proceed to VI-1).
[T]he Startup organization was using effective methods for the use of design documents and was not adversely affected by document control problems.
Consequently,
- root cause and generic implication evaluations were not necessary.
(Results Report, ISAP III.d, page 16).
V-2.
Please state each and overy respect in which the Intervenor disagrees with the above statement.
(a)
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the above statement?
If so, please answer all Interrogatories I-2(c)(1) - I-2(c)(iv) with respect to their proposed testimony.
(d)
Does the Intervenor disagree with the above.
ctatcntnt dua to tho m2thodology thrcugh which ito
~
conclusions were reached?
If so, state the precise manner in which the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were rea:hed?
If so, state the precise manner in which the imphymentation was flawed.
V-3.
Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the results report in question?
V-4.
Has the Intervenor propounded any Interrogatories regarding the Results Report in question in order to obtain any information it believes to be necessary so as to make its review of the Working File complete?
VI-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the statement below?
(If your answer is an unqualified negative, you may proceed to VII-1).
The results of this evaluation [Results Report, ISAP III.d] provide reasonable assurance that the document control problems which existed prior to 1984 did not adversely affect the testing program. (page 23).
VI-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
~
(a)
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(1)
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the precise manner in which the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the precise manner in which the implementation was flawed.
VII-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the statement below?
(If your answar to this Interrogatory is an unqualified negative, you may proceed to VIII-1.) -
[T]he failure to formally document the responsibility for the audit program in the PSAR/ESAR resulted in no adverse effect on the audit program because sub-tier program documents were written and management acted as if the responsibility had been formally documented.
(Results Report, ISAP VII.a.4, page 17).
VII-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
(a)
On what specific facts does the Intervenor base its r
disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(1) -
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the precise manner in which the methodology flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were. _ _ _._
d ranchnd?
If co, stata tha preciso mnnnar in which the implementation was flawed.
VII-3.
Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the results report in question?
VII-4.
Has the Intervenor propounded any Interrogatories regarding the Results Report in question in order to obtain any information it believes to be necessary so as to make its review of the Working File complete?
VIII-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to IX-1.)
[T] hat the failure to formally describe the position and responsibilities of the Supervisor, QA Audits, in organization descriptions resulted in no adverse effect on the audit program because audit program documents were written and QA management acted as if the position had been formally documented.
(Results Report, ISAP VII.a.4, page 17).
VIII-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
(a)
On what specific facts does the Intervenor base its l
l disagreement?
i (b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof. !
(c)
Does the Intervenor intend to offer the testimony of any expert witness with. respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(i)
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, please state the manner in which the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the manner in which the implementation was flawed.
(f)
What does the Intervenor contend is the nature of the adverse effects, if any, of the failure to formally describe the position and responsibilities i
of the Supervisor, QA audits?
(g)
In what precise manner are the findings that audit program documents were written and that QA management acted as if the Supervisor, QA Audits position, had been formally described and documented, insufficient to mitigate any possible adverse effects of the failure to formally describe 16 -
i
a the pocition and racponsibilition of tha Supervisor, QA Audits?
l IX-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to X-1.)
[T] hat the failure to include the responsibilities of the audited organization in appropriate program documents resulted in no adverse effect on the audit program because review of the audit files revealed that the requirements had been met by the audited organization.
(Results Report, ISAP VII.a.4, page 17).
IX-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
(a)
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(1)
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its -
d conclusions waro raschnd?
If so, stata tha preciso manner in which the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the precise manner in which the implementation was flawed.
(f)
What does the Intervenor contend is the precise nature of the adverse effects, if any, on the audit program due to failure of the program documents to include the responsibilities of the audited organizations?
IX-3.
Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the results report in question?
IX-4.
Has the Intervenor propounded any Interrogatories regarding the Results Report in question in order to obtain any information it believes to be necessary so as to make its review of the Working File complete?
X-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to XI-1.)
[T] hat audit staffing was adequate to implement the sudit progrcm cnd cch;dulon during the periods of interest.
(Results Report, ISAP VII.a.4., Page 19).
X-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
(a)
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the precise manner in which the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the precise manner in which the implementation was flawed.
XI-1.
Does the Intervenor intend to litigate the n.
validity of tha conclusions expranosd in the following statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to XII-1.)
[T] hat the failure to perform vendor audits on an annual frequency resulted in no adverse effect on the audit program because of the additional activities implemented by the QA organization to supplement the audit acitvity.
(Results Report, ISAP VII.a.4, Page 28).
XI-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
(a)
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the precise manner in which the methodology was flawed.
4 (e)
Does the Intervenor disagree with the abovE ststcmant duo to tha actual implcmantation of tha
~
action plan through which the statement's conclusions were reached?
If so, state the precise manner in which the implementation was flawed.
(f)
What does the Intervenor contend is the precise nature of the adverse effects, if any, on the audit program due to the failure to perform vendor audits on an annual frequency?
(g)
In what precise manner were the additional activities implemented by the QA organization, as referred to in "Results Report, ISAP VII.a.4,"
insufficient to counter any possible adverse effects caused by the failure to perform vendor audits on an annual frequency?
e Inte:'henor intend to litigate the XII-1.
Does the validity of the conclusihns expressed in the following statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to XIII-1.)
[T] hat the lack of a formalized methodology for internal audit planning and scheduling resulted in no adverse effect on the audit program because it was established that audit planning was accomplished and audit schedules were prepared to implement the audit program.
(Results Report, ISAP VII.a.4, Page 29).
XII-$2.
Plerhsestateeachandeveryrespectinwhichthe Intervetor disatrees with the above statement.
t t
9 e
e l :
?
1 (a)
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the precise manner in which the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the precise manner in which i
the implementation was flawed.
l l
(f)
What does the Intervenor contend is the precise nature of the adverse effects, if any, on the audit program due to the lack of a formalized methodology for internal audit planning and scheduling?
l t L. _
~
~
(g)
In what precise manner was the audit planning not accomplished and audit schedules not prepared so as to prevent proper implementation of the auditing program?
XIII-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to XIV-1.)
[T] hat the practice of designating a lead auditor candidate as an acting team leader resulted in no adverse effect on the audit program because the acting team leader performed the activities under the direct supervision of a qualified lead auditor who was a member of the audit team. (Results Report ISAP VII.a.4, page 31).
XIII-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
(a)
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
l (c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, 23 -
p
plecca cnawar cll Interrogatories I-2(c)(i)
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the manner in which such methodology is flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the manner in which the implementation was flawed.
(f)
What does the Intervenor contend is the precise nature of the adverse offects, if any, on the audit program due to the practice of designating a lead auditor candidate as an acting team leader?
(g)
In what manner was the finding that the acting team leader performed the activities under the direct supervision of a qualified lead auditor who was a member of the audit team insufficient to mitigate any possible adverse effects mentioned in your response to Interrogatory XII-2(f).
XIV-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following l t l
(
l
ctnt;m2nt?
(If your cnswar to this Intarrogatory is cn unqualified negative, you may proceed to XV-1.)
[T] hat the practice of utilizing site surveillance personnel as audit team members had no adverse effect on the audit program because these personnel did not perform audits of activities which they were responsible for performing.
(Results Report, ISAP VII.a.4, page 31).
XIV-2.
Please state each and every respect in which the Intervenor disagrees with the above statemert.
(a)
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(1) -
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which the statement's conclusions were reached?
If so, state the manner in which such methodology is flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plcn through which tho ototcment'a conclusiona wara reached?
If so, state the manner in which the implementation is flawed.
(f)
What does the Intervenor contend is the precise nature of the adverse effects, if any, on the audit program due to the practice of utilizing site surveillance personnel as audit team members?
(g)
In what manner was the finding that site surveillance personnel did not perform audits of activities for which they were responsible, fail to mitigate any adverse effects on the audit program as discussed in Interrogatory XIV-2(f)?
XV-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If your answer to this Interrogatory is unqualified agreement with the statement, you may proceed to XVI-1.)
[T] hat the failure of the auditor to recommend effective corrective action for audit deficiencies resulted in no adverse effect on the audit program because the organization responsible for the activity has the ultimate responsibility for determinaton of corrective action.
(Results Report ISAP VII.a.4, page 35).
XV-2.
Please state each and every respect in which the Intervenor disagrees with the above statement. _
( a ).
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their prcposed testimony.
t (d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, the precise manner in which the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the actual implementation of the action plan through which the statement's conclusions were reached?
If so, state the reasons why the implementation was flawed.
t (f)
What does the Intervenor contend is the precise nature of the adverse effects, if any, on the audit program due to the failure of the auditor to.
rccommInd offsetiva corractivo cetion for cudit deficiencies?
(g)
In what manner was the finding that the organization responsible for the activity has the ultimate responsbility for determination of corrective action for that activity insufficient to mitigate any possible adverse effects mentioned in your response to Interrogatory XV-2(f)?
XVI-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to XVII-2.)
[T]he audit personal qualification program adequately reflected the requirements of appropriate governing standards and regulatory guidance and therefore resulted in no adverse effect on the audit program.
(Results Report, ISAP VII.a.4, page 38).
XVI-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
(a)
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Irtervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the._.
cenclucien rocchsd in tho cbova stctcmsnt?
If co, please answer all Interrogatories I-2(c)(1) -
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the reasons why the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the reasons why the implementation was flawed.
XVII-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If your answer is unqualified agreement with the statement, you may proceed to XVIII-1.)
[T] hat independent backup information not being in the files for auditors in the past resulted in no adverse effect on the audit program in that the files did contain evidence that QA management had performed an evaluation of the personnel and found them to be qualified. (Results Report, ISAP VII.a.4, page 39).
XVII-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
(a)
On what specific facts does the Intervenor base its disagreement?. _ _ _ _.
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(1) -
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the reasons why the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the reasons why the implementation was flawed.
.i
)'
(f)
In what manner was the finding that files for auditors did contain evidence that QA management had performed an evaluation of the personnel and
{
found them to be qualified insufficier t to mitigate I
any adverse effects on the audit program?
i l
XVIII-1.
Does the Intervenor intend to litigate the 1
l
\\
validity of tha conclusions expracasd in tha following statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to XIX-1.)
[T] hat the failure of TUGCO to administer lead auditor examinations to particular individuals resulted in no adverse effect on the audit program in that the personnel are otherwise qualifed and are believed capable of satisfactorily performing as lead auditors.
(Results Report, ISAP VII.a.4 page 39).
XVIII-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
(a) on what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion -thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(1)
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the reasons why the methodology was flawed.
I (e)
Does the Intervenor disagree with the above. _.
otstcm2nt dua to th3 impic:m:ntction of tha cction
~
plan through which the statement's conclusions were reached?
If so, state why.the implementation was flawed.
(f)
What does the Intervenor contend is the precise nature of the adverse effects, if any, on the audit program due to the failure of TUGC0 to administer lead auditor examinations to particular individuals?
(g)
In what manner was the finding that the personnel are otherwise qualified and believed capable of satisfactorily performing as lead auditors insufficient to mitigate any possible adverse effects mentioned in your response to Interrogatory XVIII-2(f)?
XIX-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to XX-1.)
There is a 95 percent confidence that at least 95 percent of the general population of valves that were disassembled were reassembled in a functionally correct manner and have no code class deviations. (Results Report, ISAP VII.b.2., revision 1, page 19).
XIX-2.
Please state each and every respect in which the Intervenor disagrees with the above statement. - -
(a)
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(1) -
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the reasons why the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the reasons why the implementa on was flawed.
XIX-3.
Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the Results Report in question?
XIX-4.
Has the Intervenor propounded any Interrogatories i t
.~_
rcgtrding tho Raculto Rsport in qusation in ordar to obtain
~
any information it believes to be necessary so as to make its review of the Working File complete?
XX-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to XXI-1.)
There is a 95 percent confidence that at least 95 percent of the TRT issue valves (i.e.,
ITT-Grinnel valves in the spent fuel cooling and cleaning system, the boron recycle system and chemical and volume control system) that were disassembled were reassembled in a functionally correct manner and have no code class deviations.
(Results Report, ISAP VII.b.2., revision 1, pages 19-20).
XX-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
(a) on what specific facts does the Intervenor base its 1
1 disagreement?
l (b)
Identify the documents Intervenor will rely upon to l
l sustain its position of disagreement, or any l
portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(i)
I-2(c)(iv) with regard to their proposed testimony. _
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the reasons why the methodology is flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, st**o the reasons why the implementation is flawed.
XXI-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to XXII-1.)
It is concluded that continued implementation of the Periodic Review of the QA Program as recently demonstrated, and in accordance with the program as presently defined, will result in an adequate and effective Periodic Review of the QA Program.
(Results Report, ISAP VII.a.5., page 10).
XXI-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
(a)
Ca what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof. -
~
(c)
Does the Intervenor intend to offer the testimony of any expert witness with. respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the reasons why the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement'n conclusions were reached?
If so, state the reason why the implementation was flawed.
XXI-3.
Prior to abswering this set of Interrogatories, has the Intervenor reriewed the Working File for the results report in question?
XXI-4.
Has the Intervenor propounded any Interrogatories regarding the Results Report in question in order to obtain any information it believes to be necessary so as to make its review of the Working File complete?
XXII-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following --.
Otct m2nt?
(If your entwar to thio Intorrogatory is an
~
unqualified negative, you may proceed to XXIII-1.)
The actions performed by CPRT, augmented by AMP's testing and analysis of bent and twisted terminal lugs, showed that the original dispositioning of the NCRs at issue was technically acceptable.
TNE's decisions pertaining to the appropriateness of the April 1984 AMP criteria appear validated.
The NCRs have all been redispositioned to provide a clear documented basis for acceptance of the existing equipment condition. (Results Report, ISAP I.a.5, Page 9)
XXII-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
(a)
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to i
sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(1)
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the reasons why the methodology was flawed. --
_ ~
i (e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the reasons why the implementation was flawed.
XXII-3.
Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the results report in question?
XXII-4.
Has the Intervenor propounded any Interrogatories regarding the Results Report in question in order to obtain any information it believes to be necessary so as to make its review of the Working File complete?
XXIII-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to XXIV-1.)
Since the activities carried out during the implementation of [ Issue Specific Action Plan I.a.4.]
did not reveal any deficiencies, neither a root cause nor a generic implications evaluation is necessary.
(Results Report, ISAP I.a.4, page 13).
XXIII-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
(a)
On what specific facts does the Intervenor base its disagreement? -e.
~., -
r
.-y
,----4--
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(1)
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the precise manner in which the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the the precise manner in which the implementation was flawed.
(f)
What deficiencies does the Intervenor contend were revealed by ISAP I.a.4.7 XXIV-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to XXV-1.) ;
i t
The rigorous sample inspection program performed under this Action Plan [I.a.4.], together with the added screens provided by the related inspections and tests discussed [in Results Report I.a.4.], provide reasonable assurance that there are no undetected safety-significant or programmatic deficiencies that involve correctness of safety-related electrical terminations.
(Results Report ISAP I.a.4, page 15).
XXIV-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
(a)
On what specific facts doeu the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(i)
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the reasons why the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were _ _ -
racchtd?
If so, state tha rencona why tha implementation was flawed.
XXV-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in t..:
following statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to XXVI-1.)
Since no nonconforming hardware conditions wers identified by the activities performed for this action plan, no NCRs were generated. (Results Report, ISAP I.a.3, page 9).
XXV-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
(a)
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony' of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(1) -
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its I -.
? ~ - - -
conclusions ware roachtd?
If co, stata ths rezcons why the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were redched?
If so, state the reasons why the implementation was flawed.
(f)
In what precise hardware does the Intervenor contend nonconforming conditions exist?
XXV-3.
Prior to answering this set of Interrogatories,
[ has the Intervenor reviewed the Working File for the results
' report in question?
N
?
XXV-4.
Has the Intervenor propounden any Interrogatories regarding the Resultd~ Report in question in order to obtain any information it believes to be necessary so as to make its review of the' Working File complete?
XXVI-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to XXVII-1.)
The AMP, PIES splices are qualified for the expected service conditions at CPSES.
Craft and QC procedures s
have been revised to specify both staggering / separation requirements and continuity checks at the time of installation of the splices in control panels.
Craft and QC personnel have been trained in these revised procedures.
(Results Report, ISAP I.a.3, page 10).
- l l
l c
XXVI-2.
Plscas ctsta cEch and evary rs= pact in which tha Intervenor disagrees with the above statement.
(a)
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the reasons why the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the reasons why the implementation was flawed.
XXVII-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following _
atatcmsnt?
(If your augwar to thio Interrogstory is an unqualified negative, you may proceed to XXVIII-1.)
Craft personnel were cognizant of detailed drawings for conduit and junction box supports contained in Manual 2323-S-0910.
Craft personnel could not readily recall the name of the manual from which the drawings were extracted but that information does not affect workmanship because Craft personnel used the drawings, and not the manual, to accomplish their work.
(Results Report, ISAP I.d.3, page 19).
XXVII-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
(a)
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustsin its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the reasons why the methodology was flawed.
(e)
Does the Intervenor disagree with the above
stattmsnt dua to tha impismantation of tha cetion plan through which the statement's conclusions were reached?
If so, state the reasons why the implementation was flawed.
(f)
In what precise manner does the Intervenor contend that Craft personnel cannot adequately perform their work through use of the drawings but must rely on the manual?
XXVII-3.
Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the results report in question?
XXVII-4.
Has the Intervenor propounded any Interrogatories regarding the Results Report in question in order to obtain any information it believes to be necessary so as to make its review of the Working File complete?
XXVIII-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to XXIX-1.)
Past and current practices for Craft selection and training were found to be in compliance with ANSI N45.2-1971 and, therefore, were determined to be adequate.
The Craft selection and assignment process is a practicable approach with responsible checks and balances.
Procedural, on the job, classroom and mockup training programs have been effective.
(Results report, ISAP I.d.3, page 20.)
e XXVIII-2.
Please state each and every respect in which the Intervenor disagrees with the above. statement.
(a)
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the reasons why the methodology was flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the reasons why the implementation was flawed.
(f)
In what precise manner does the Intervenor contend thnt pnct end currsnt procticao uccd for Craft selection and training were inadequate?
(g)
In what precise manner does the Intervenor contend that procedural, on the job, classroom and mockup training programs have been ineffec tive?
XXVIII-3.
Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the results report in question?
XXVIII-4.
Has the Intervenor propounded any Interrogatories regarding the Results Report in question in order to obtain any information it believes to be necessary so as to make its review of the Working File complete?
XXIX-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
(If your answer to this Interrogatory is an unqualified negative, you may proceed to XXX-1.)
No testing deviation or deficiency was identified and no generic condition exists which indicates that there are inadequate controls on the M&TE traceability in preoperational testing, initial startup testing, or station procedures at CPSES.
Accordingly, no root cause determination is required.
(Results Report, ISAP III.a.4, page 11).
XXIX-2.
Please stato each and every respect in which the Intervenor disagrees with the above statement.
(a)
On what specific facts does the Intervenor base its disagreement? -..-__
~-
o e
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(i) -
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its conclusions were reached?
If so, state the reasons why the methodology is flawed.
(e)
Does the Intervenor disagree with the above statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the reasons why the implementation was flawed.
XXIX-3.
Prior to answering this set of Interrogatories, has the Intervenor reviewed the Working File for the results report in question?
XXIX-4.
Has the Intervenor propounded any Interrogatories regarding the Results Report in question in order to obtain a
i f
cny information it believes to be necessary so as to make o
its review of the Working File complete?
XXX-1.
Does the Intervenor intend to litigate the validity of the conclusions expressed in the following statement?
Based on the discussion presented in Section 5.0 above,
[in Results Report, ISAP III.a.4]it was concluded that requirements exist in Startup station implementing procedures to insure compliance with TUGCO's M&TE traceability commitments. (Results Report, ISAP III.a.4, page 11).
XXX-2.
Please state each and every respect in which the Intervenor disagrees with the above statement.
(a)
On what specific facts does the Intervenor base its disagreement?
(b)
Identify the documents Intervenor will rely upon to sustain its position of disagreement, or any portion thereof.
(c)
Does the Intervenor intend to offer the testimony of any expert witness with respect to the conclusion reached in the above statement?
If so, please answer all Interrogatories I-2(c)(1) -
I-2(c)(iv) with regard to their proposed testimony.
(d)
Does the Intervenor disagree with the above statement due to the methodology through which its
)
I l
conclusions were reached?
If so, state the reasons o
why the methodology was flawed.
(e)
Does the Intervenor disagree with the above j
\\
statement due to the implementation of the action plan through which the statement's conclusions were reached?
If so, state the reasons why the implementation was flawed.
By their attorneys, Thomho G.
Dignan, Jr.
R. K. Gad III William A. Eggeling Kathryn A.
Selleck Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Telephone:
(617)423-6100 i
i I
C
- D Eil.
CERTIFICATE OF SERVICE V4
'87 FEB -2 A11 :02 I,
Kathryn A.
Selleck, one of the attorneys for the Applicants Ja..
herein, hereby certify that on January 29, 1987, I adde' service of Sf 3 ?
the within three sets of interrogatories (Sets 1987-1, 1987-2 and 1987-3) addressed to Intervenor CASE, by mailing copies thereof, 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 Nancy Williams Administrative Judge Cygna Energy Services, Inc.
c/o Carib Terrace 101 California Street, Suite 1000 552 North Ocean Blvd.
San Francisco, California 94111 Pompano Beach, Florida 33062 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 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 Washington, D.C.
20555
t 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 2000 P Street, N.W.,
Suite 611 Washington, 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 37030 Maryland National Bank Bldg.
l Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 Ms. Billie P. Garde Midwest Office 3424 N. Marcos Lane Appleton, Wisconsin 54911
'/.
%~
Y
/KaVhryn A.
Selleck