ML20211K222
| ML20211K222 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/10/1986 |
| From: | Amoruso P, Hansel J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#486-1509 OL, NUDOCS 8611170101 | |
| Download: ML20211K222 (25) | |
Text
e Filed:
November 10, 1986 150f DOCKETED U5tlRC 16 NOV 14 P2:06 UNITED STATES OF AMERICA CFFf Ct i.?
NUCLEAR REGULATORY COMMISSION CC3E il' m.
before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
Docket Nos. 50-445-OL TEXAS UTILITIES ELECTRIC
)
50-446-OL COMPANY et al.
)
)
(Application for an (Comanche Peak Steam Electric
)
Operating License)
Station, Units 1 and 2)
)
)
ANSWERS TO BOARD'S 14 QUESTIONS (Memo; Proposed Memo of April 14, 1986)
Regarding Action Plan Results Report I.d.3 In accordance with the Board's Memorandum; Proposed Memorandum and Order of April 14, 1986, the Applicants submit the answers of the Comanche Peak Response Team ("CPRT") to the 14 questions posed by the Board, with respect to the Results Report published by the CPRT in respect of CPRT Action Plan I.d.3.
8611170101 861110 PDR ADOCK 05000445 G
PDR D o3 J
O,$ening Recuest:
Produce copies of any CPRT-generated checklists that were used during the conduct of the action plan.
Response
The checklist for reviewing Brown & Root procedure CP-CPM-2.2, " Training of Personnel in Procedural Requirements," is attached.
Question:
1.
Describe the problem areas addressed in the report.
Prior to undertaking to address those areas through sampling, what did Applicants do to define the problem areas further?
How did it believe the problems arose?
What did it discover about the QA/QC documentation for those areas?
How extensive did it believe the problemc were?
Answer:
This Action Plan was prepared to respond to NRC concerns about the adequacy of training of personnel installing conduit supports and the adequacy of instructions provided to personnel on rigging and handling heavy loads.
The concern about the training of personnel installing conduit supports was based on interviews from which the NRC Comanche Peak Technical Review Team (TRT) concluded that craft personnel were not cognizant of Manual 2323-S-0910, " Conduit and Junction Box Supports."
The concern about instructions provided on rigging and handling heavy loads was based on the statement of a craft person to a Region IV Resident Inspector that he had not received instructions on how to rig and handle a large motor-operated valve.
This Action Plan was developed to address the specific concerns of the TRT and Region IV staff as well as to check other areas for shortcomings in the training of craft personnel.
The Action Plan not only provides for the resolution of the TRT concern about the unfamiliarity of craft personnel with Manual 2323-S-0910 but also checks for other shortcomings in training related to the installation of conduit supports.
Even thoagh the TRT found that the corrective action taken by TUGCO to resolve the concern of the Region IV staff on rigging and handling heavy loads required no further action, the Action Plan assessed the adequacy of training conducted for changes made to procedures as a result of corrective action and for identifying any shortcomings in other training provided on rigging and handling activities.
To check for training problems in areas not specified as NRC concerns, the Action Plan assessed the overall adequacy of the craft training programs of major construction contractors involved with safety-related work at CPSES. r l
This assessment covered procedural, classroom, mockup and on-the-job training.
The conclusion of the Action Plan is that past and current craft training practices for major construction contractors were/are adequate.
Although craft personnel could not readily recall the title of Manual 2323-S-091Q, they were cognizant of the S-910/S2-910 drawings in the manual.
These drawings were used to install conduit supports.
Craft personnel were knowledgeable of handling and rigging requirements.
This knowledge was demonstrated in interviews and reflected in field ac tivities.
QA/QC documentation for the training programs (i.e.,
training records) were adequate and in accordance with contractor training procedures.
The craft training programs of the major construction contractors were capable of correcting craft problems that are inherent when a large work force is assembled to construct a complex plant.
Based on interviews, training conducted and Corrective Action Requests (CARS), the training programs were adequate to that task.
Question:
2.
Provide any procedures or other internal documents that are necessary to understand how the checklists should be interpreted or applied.
Answer:
One checklist was used in implementing this Action Plan.
That checklist, which is attached, was developed by the two-man QA/QC Review Team assigned to the Action Plan to verify the implementation of Brown &
Root procedure CP-CPM-2.2, " Training of Personnel in Procedural Requirements."
Checklist items are self-explanatory and are essentially word-for-word extractions from procedure CP-CPM-2.2.
No supporting documentation was needed by the two-man team to understand and use the checklist.
Question:
3.
Explain any deviation of checklists from the inspection report documents initially used in inspecting the same attributes.
(This question is applicable only to construction Results Reports.)
Answer:
The checklist used in this Action Plan to verify the implementation of Brown & Root procedure CP-CPM-2.2 has more items than a checklist used by the TUCCO QA Audit group.
The additional items in the checklist for i
this Action Plan resulted from a more detatled breakdown of requirements from procedure CP-CEM-2.2 i __
than the breakdown of those requirements on the checklist used by the TUCCO QA Audit group.
Question:
4.
Explain the extent to which the checklists contain fewer attributes than are required for conformance to codes to which Applicants are committed to conform.
Answer:
The checklist used in this Action Plan verifies conformance to a procedure rather than conformance to a code.
The checklist that was used contained eleven items.
These items covered the implementation requirements of Brown & Rcot precedure CP-CPM-2.2.
Question:
5.
(Answer question 5 only if the answer to question 4 is that the checklists do contain fewer attributes.)
Explain the engineering basis, if any, for believing that the safety margin for components (and the plant) has not been degraded by using checklists that contain fewer attributes than are required for conformance to codes.
Answer:
This question is not applicable because of the answer to Question 4.
Question:
6.
Set forth any changes in checklists while they were in use, including the dates of the changes.
Answer:
e.
The checklist used in this Action Plan was not 1
changed while in use.
Question:
7.
Set forth the duration of training in the use of checklists and a summary of the content of that training, including field training or other practical training.
If the training has changed or retraining occurred, explain the reason for the changes or retraining and set forth changes i
in duration or content.
Answer:
The checklist that was used to verify the implementation of Brown & Root procedure CP-CPM-2.2 was prepared by one man of the two-man review team and ij i.,
reviewed by the other man.
Approximately three hours 1
were spent in preparing the procedure and one-half hour 4
was spent in the review process.
In addition,
{
approximately one-half hour was spent by each man of i
the two-man review team refamiliarizing themselves with CP-CPM-2.2 and items on the checklist immediately i
before using the checklist.
^
j Question:
8.
Provide any information in Applicants' possession j
concerning the accuracy of use of the checklists (or the inter-observer reliability in using the s
{
checklists).
Were there any time periods in j
which checklists were used with questionable j
training or QA/QC supervision?
If applicable, j
are problems of inter-observer reliability j
addressed statistically?
s !
I i
i l
i
,_mm..__-.._m.._
l l
j Answer:
At no time was the checklist for this Action Plan 1
l used with questionaole training or QA/QC supervision.
1 The Issue Coordinator reviewed the work performed to assure reasonable accuracy.
i
{
Question:
i I
9.
Summarize all audits or supervisory reviews (including reviews by employees or consultants) of training or of use of the checklists.
Provide the factual basis for believing that the audit i
and review activity was adequate and that each concern of the audit and review teams has been resolved in a way that is consistent with the 4
]
validity of conclusions.
4 L
Ancuer:
1 An ERC Corporate QA Audit, ERC-86-03, of this t
]
Action Plan was conducted during the week of June 16, j
1986.
The audit was comprehensive and covered the use t
of the checklist developed for the Action Plan to verify the implementation of Brown & Root procedure CP-i l
CPM-2,2, " Training of Personnel in Procedural l
Requirements."
The auditors were certified in l
accordance with ANSI N45.2.23.
No concerns were identified.
Question:
I i
10.
Report any instances in which draft reports were modified in an important substantive way as the result of management action.
Be sure to explain any change that was objected'to (including by an l
1
' i i
i
0 employee, supervisor or consultant) in writing or in a meeting in which at least one supervisory or management official or NRC employee was present.
Explain what the earlier drafts said and why they wera modified.
Explain how dissenting views were resolved.
Answer:
No substantive modifications were made to the drafts of the Results Report for this Actios: Plan as a result of management action.
Various editorial changes were made to clarify the text and ensure consistency with source material.
Question.
11.
Set forth may unaxpected difficulties that were encountered in completing the work of each task force and that would be helpful to the Board in understanding the process by which conclusions were reached.
How were each of these unexpected difficulties resolved?
Answer:
No unexpected difficulties were encountered in completing this Action Plan.
Question:
12.
Explain any ambiguities or open items left in the Results Report.
Answer:
The conclusion of the Action Plan is that past training by Brown & Root and Bahnson was adequate.
This conclusion was based on interviews, past training
.g.
and Corrective Action Requests (CARS) but does not include the results of hardware reinspections and documentation reviews conducted by the Comanche Peak Response Team.
These reinspections are covered by othiar Action Plans.
Therefore, the adequacy of past training will be reassessed by the QA/QC Collective Evaluation Group if results of other Action Plans identify shortcomings in the training of craft personnel as the root cause of any construction deficiencies or adverse trends [
Question:
13.
Explain the extent to which there are actual or apparent conflicts of interest, including whether a worker or supervisor was reviewing or evaluating his own work or supervising any aspect of the review or evaluation of his own work or the work of those he previously supervised.
Answer:
No conflicts of interest exist.
Question:
e 14.
Examine the report to see that it adequately discloses the thinking and analysis used.
If the language is ambigucus or the discussion gives rise to obvious questions, resolve the ambiguities and anticipate and resolve the questions.
Answer:
The Results Report for this Action Plan was reviewed for clarity, ambiguities, and obvicus,
1
~ -.
questions.
Any such situations that existed were
- reaolved, i
Respectfully submitted,
[
W Paul Amoruso Action Plan I.d.3 Issue Coordinator 4
(.
tu/
hn Hansel
(
RT QA/QC Review Team Imader The foregoing responses have been reviewed and are concurred in by the CPRT Senior Review Team.
4
'I _
Respectfully submitted, Ei.
b Thomas G.
Dignan, Jr.
R.
K.
Gad III William S.
Eggeling Kathryn A.
Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 _ __
Page 1 of 6 ATTACHMENT I ASLB QUESTIONS Opening Recuest Produce copies of any CPRT-generated checklists that were used during the conduct of the action plan.
a
Response
The checklist for reviewing Brown & Root procedure CP-CPM-2.2, " Training of Personnel in Procedural Requirements", is attached.
i
{
l l
CFRT-662/CPRT6
Question 1:
Describe the problem areas addressed in the report.
Prior to undertaking to address those areas through sampling, what did Applicants do to define the problem areas further? How did it believe the problems arose?
What did it disccver about the QA/QC documentation for those areas? Hew extensive did it believe the problems were?
Answer:
This Action Plan was preparad to respond to FRC concerns about the adequacy of training of personnel installing conduit supports and the adequacf of instructions provided to personnel on rigging and handling heavy loads. The concern about the training of personnel installing conduit supports was based on interviews from which the NRC Comanche Peak Technical Review Team (TRT) concluded that craft personnel were not cognizant of Manual 2323-S-0910. " Conduit and Junction Box Supports". The concern about instructions provided on rigging and handling heavy loads was based on the statement of a craft person to a Region IV Resident Inspector that he had not received instructions on how to rig and handle a large motor-operated valve.
This Action Plan was developed to address the specific concerns of the TRT and Region IV staff as well as to check other areas for shortcomings in the trafr.ing of craft personnel. The Action Plan not only provides for the resolution of the TRT concern about the unfamiliarity of craft personnel with Manual 2323-S-0910 but also checks for other shortcomings in training related to the installation of conduit supports. Even though the TRT found that the corrective action taken by TUGC0 to tesolve the concern of the Region IV staff on rigging and handling heavy ads required no further action, the Action Plan assess' he adequacy of training conducted for changes made to procedures as a result of corrective action and for identifying any shortcomings in other training provided on rigging and handling activities. To check for training problems in areas not specified as NRC concerns, the Action Plan assess the overall adequacy of the craft training programs of major construction contracters involved with safety-related work at CPSES. This assessment covered procedural, classroom, mockup and on-the-job training.
The conclusion of the Action Plan is that past and current craft training practices for major construction contractors were/are adequate. Although craft personnel could not readily recall the title of Manual 2323-S-0910, they were cognizant of the S-910/S2-910 drawings in the manual. These drawings were used to install conduit supports. Craft personnel were knowledgeable of handling and rigging requirements. This knowledge was demonstrated in interviews and reflected in field activities.
2 CPRT-662/CPRT6
Question 1 QA/QC documentation for the training programs (i.e.,
(Cont'd) training records) were adequate and in accordance with contractor training procedures.
The craft training programs of the major construction contractore were capable of correcting craft problems that are inherent when a large work force is assembled to construct a complex plant. Based on interviews, training conducted and Corrective Action Requests (CARS), the training programs Vere adequate to that task.
Question 2:
Provide any procedures or other internal documents that are necessary to understand how the checklists should be interpreted or applied.
Answer:
One checklist was used in implementing this Action Plan.
That checklist, which is attached, was developed by the two-man QA/QC Review Team assigned to the Action Plan to verify the implementation of Brown & Koot procedur+
CP-CPM-2.2 " Training of Personnel in Procedural Requirements". Checklist itees are self-explanatory and are essentially word-for-word extractions from procedure CP-CPM-2.2.
No supporting documentation was needed by the two-man team to understand and use the checklist.
Question 3:
Explain any deviation of checklists from the inspection report documents initially used in inspecting the same attributes.
(This question is applicable only to construction Results Reports.)
Answer:
The checklist used in this Action Plan to verify the implementation of Brown & Root procedure CP-CPM-2.2 has more items than a checklist used by the TUGC0 QA Audit group.
The additional items in the checklist for this Action Plan resulted from a more detailed breakdown of requireeeats from procedure CP-CFM-2.2 than the breakdown of those requirements on the checklist used by the TUGC0 QA Audit group.
3 CPRT-662/CPRT6
Question 4:
Explain the extent to which the checklists contain fewer attributes than are required for conformance to codes to which Applicants are co=nitted to conform.
Answer:
The checklist used in this Action Plan verifies conformance to a procedure rather than conformance to a code. The checklist that was used contained eleven items. These items
)
covered the implementation requirements of Brown & Root procedura CP-CPM-2.2.
Question 5:
(Answer Question 5 only if the answer to Question 4 is that the checklists do contain fewer attributes.) Explain the engineering basis, if any, for believing that the safety margin for components (and the plant) has not been degraded by using checklists that contain fewer attributes than are required for conformance to codes.
Answer:
This questien 19 not applicable because of the answer to Question 4.
Question 6:
See forth any changes in checklists while they were in use including the dates of the changes.
Answer:
The checklist used in this Action Plan was not changed while in use.
Question 7:
Set forth the duration of training in the use of checklists and a summary of the content of that training, including field training or other practical training.
If the training has changed or retraining occurred, explain the reason for the changes or retraining and set forth changes in duration or content.
Answer:
The checklist that was used to verify the implementation of Brown & Root procedure CP-CPM-2,2 was prepared by one man of the two man review team and reviewed by the other man.
Approximately three hours were spent in preparing the l
procedure and one-half hour was spent in the review process.
I In addition, approximately one-half hour was spent by each man of the two man review team refamiliarizing themselves with CP-CPM-2.2 and items on the checklist immediately before using the checklist.
4 CPRT-662/CPRT6
Provide any information in Applicants' possession concerning
~ Question 8:
the accuracy of use of the checklists (er the inter-etserver reliability in using the checklists). 'Jere there any time periods in which checklists were used with questionable training or QA/QC supervision? If applicable, are probier.s of inter-observer reliability addressed statistically?
At no time was the checklist for this Action Plan used with The issue Answer:
questionable training or QA/QC supervision.
Coordinator reviewed the work performed to asmure reasonable accuracy.
Summarize all audits or supervisory reviews (including Question 9:
revisus by employees or consultants) of training or of use Provide the f actual basis for believing of the checklists.
that the audit and review activity was adequate and that each concern of the audit and review teams has been resolved in a way that is consistent with the validity of ccnclusions, An ERC Corporate QA Audit, ERC-86-03, of this Action Plan was conducted during the week of June 16, 1986. The audit Answer:
was comprehensive and covered the use of the checklist developed for the Action Plan to verify the implementation of Brown & Root procedure CP-CPM-2.2, " Training of Personnel in Procedural Requirements." The auditors were certified in accordance with ANSI N45.2.23. No concerns were identified.
Report any instances in which draft reports were modified in Question 10:
an important substantive way as the result of managems.at Be sure to explain any change that was objected to action.
(including by an employee, supervisor or consultant) in writing or in a meeting in which at least one supervisory or Explain canagement official or NRC employee was present.
what the earlier drafts said and why they were modified.
Explain how dissenting views were resolved.
No substantive modifications were made to the drafts of the Results Report for this Action Plan as a result of Answer:
Various editorial changes were made to canagement action.
clarify the text and ensure consistency with source material.
CFRT-662/CPRT6 5
i l
Question 11:
Set forth any unexpected difficulties that were encountered in completing the work of each task force and that would be helpful to the Board in understanding the process by which conclusions were reached. How were each of these unexpected difficulties resolved?
Answer:
No unexpected difficulties were encountered in completing this Action Plan.
Question 12:
Explain any ambiguities or open items left in the Results Report.
Answer:
The conclusion of the Action Plan is that past training by Brown & Root and Bahnson was adequate. This conclusion was based on interviews, past training and Corrective Action Request (CARS) but does not include the results of hardware and documentation reinspections conducted by the Comanche Peak Response Team. These reinspections are covered by other Action Plans. Therefore, the adequacy of past training will be reassessed by the QA/QC Collective Evaluation Group if results of other Action Plans identify shortcomings in the training of craft personnel as the root cause of any construction deficiencies or adverse trends.
Question 13:
Explain the extent to which there are actual or apparent conflicts of interest, including whether a worker or supervisor was reviewing or evaluation his own work or supervising any aspect of the review or evaluation of his own work or the work of those he previously supervised.
Answer:
No conflict of interest existed.
(Jih6744rfephari~bh.
Question _14:
Examine the report to see that it adequately discloses the thinking and analysis used.
If the language is ambiguous or the discussion gives rise to obvious questions, resolve the ambiguities and anticipate and resolve the questions.
Answer:
The Results Report for this Action Plan was reviewed for clarity, ambiguities, and obvious questions. Any such situations that existed were resolved.
6 CPRT-662/CPRT6
I.d.3 CRAFT PERSONNEL TRAINING DATE: 6-3-86 PAGE:
OF TITLE: TRAINING / PROCEDURE CHECKLIST PREPARED BY:
DATE:
APPROVED BY:
DATE:
The purpose and scope of this checklist is as follows:
PURFOSE: To provids verification of procedure implementation and assistance in the determination of control adequacy.
SCOPE: The checklist will be used during discussion and observation with Field Administration Group personnel involved with the activities described in B & R procedure CP-CPM 2.2, Rev. 4.
REVIEWER:
DATE:
d CPRT-662/CPRT6
-m
CHECKLIST Completion Date:
PROCEDURI: CP-CFM 2.2. Rev. 4 Prepared By:_
TITLE: TRAINING OF PERSONNEL IN Approved By:
PROCEDURAL REQUIREMENTS I.D.
ITEM DESCRIPTION / REQUIREMENTS YES NO REMARKS l.3.2 Training category tables are available for all craft personnel 2.1.3 Category numbers are utilized in the training computer data base for tracking individual training requirements by time sheet nos.
2.1.4 Additional training is administered when employees change depts. or job responsibilities based on category tables.
2.2.1 Training coordinators are designated for each department.
2.2.5 Coordinators receive training in CPM 2.2 (latest revision).
I 2.4.1 Field Admin Group maintains a listing of procedures for which l
each craft worker requires
(
training.
l
(
2.4.2 Training Coordinator (Project) notifies the Field Admin Group of procedure revisions in j,
writing.
l Page 1 of 2 l
CPRT-662/CPRT6 l
t
^
/
I.D.
ITEM DESCRIPTION / REQUIREMENTS YES NO REMARKS 2.4.3 Upon notification of procedure /rev. issuance the Field Admin. Group notifies applicable coordinators of required training via proper form.
2.5.1 Procedure revision training is documented.
Each person 2.5.2 receiving training and instructor who administers signed requirement form.
2.5.6 Training of new hires, promotions, transfers is 2.6.5 documented using a Training Record Form.
2.6.1 The Construction Procedure Index List used by dept, heads and supervisors is maintained current and up-to-date.
Page 2 of 2 l
CFRT-662/CPRT6
/h CHECKLIST Completion Date:
PROCEDURE: CP-C?M 2.2. Rev. 4 Prepared By:
TITLE: TRAINING OF PERSONNEL IN Approved By:
PROCEDUFAL REQUIRDENTS I.D.
ITEM DESCRIPTION / REQUIREMENTS YES NO REMARKS 1.3.2 Training category tables are available for all craft personnel 2.1.3 Category numbers are 'itilized in the training computer data base for tracking individual training requirements by time sheet nos.
2.1.4 Additional training is administered when employees change depts. or job responsibilities based on category tables.
2.2.1 Training coordinators are designated for each department.
2.2.5 Coordinators receive training in CPM 2.2 (latest revisien).
2.4.1 Field Admin Group maintains a listing of procedures for which each craft worker requires training.
2.4.2 Training Coordinator oject) notifies the Field Admin Group of procedura revisions in writing.
Page 1 of 2 1021/ MISC 9
e I.D.
ITEM DISCRIPTION/ REQUIREMENTS YES NO REMARKS I
2.4.3 Upon notification of procedure /rev. issuance the Field Admin. Group notifies applicable coordinators of required training via proper form.
2.5.1 Procedure revision training is documented.
Each person 2.5.2 receiving training and instructor who administers signed requirement form.
2.5.6 Training of new hires.
promotions, transfers is 2.5.5 documented using a Training Record Form.
2.6.1 The Construction Procedure Index List used by dept.
heads and eupervisors is maintained current and up-to-date.
Page 2 of 2 1021/ MISC 9
b DOC b f. ii..
CERTIFICATE OF SERVICE o w" I,
Kathryn A. Selleck, one of the attorneys for pgp ggpjgc9qpgf herein, hereby certify that on November 10, 1986, I made service of 0FFK: ~
' ii. 4 the within " Answers to Board's 14 Questions (Memo; o p0rbrg[p,"d A
1986) Regarding Action Plan Results Report I.d.3",
by mailing a
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.
881 W.
Outer Drive 101 California Street, Suite 1000 t
Oak Ridge, Tennessee 37830 San Francisco, California 94111 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 7735 Old Georgetown Road Room 10117 Bethesda, Maryland 20814
._...-______,._-__,,._,_y,.
,,,,., -.,.,. - _ _. - ~ _, _ _.,,
e
-o.
Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel P.O.
Box 12548, Capitol Station U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C.
20555 Anthony Roisman, Esquire Joseph Gallo, Esquire Executive Director Isham, Lincoln & Beale Trial Lawyers for Public Justice 1120 Connecticut Avenue, N.W.
2000 P Street, N.W.,
Suite 611 Suite 840 Washington, D.C.
20036 Washington, D.C.
20036 Dr. Kenneth A. McCollom Mr. Lanny-A. Sinkin Administrative Judge Christic Institute 1107 West Knapp 1324 North Capitol Street Stillwater, Oklahoma 74075 Washington, D.C.
20002 Ms. Billie Pirner Garde Mr. Robert D.
Martin Midwest Office Regional Administrator, 3424 N. Marcos Lane Region IV Appleton, WI 54911 U.S. Nuclear Regalatory Commissi~on Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B. Johnson Geary S.
Mizuno, Esquire Administrative Judge Office of the Executive Oak Ridge National Laboratory Legal Director P.O. Box X, Building 3500 U.S.
Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Maryland National Bank Bldg.
Room 10105
~
7735 Old Georgetown Road Bethesda, Maryland 20814
/
Kathryn A.
Sel'leck
. -..