ML20213F409
| ML20213F409 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/07/1986 |
| From: | Gad R ROPES & GRAY, TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| CON-#486-1467 OL, NUDOCS 8611140192 | |
| Download: ML20213F409 (27) | |
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UNITED STATES OF AMERICA Dggf NUCLEAR REGULATORY COMMISSION before the 86 mp 12 R2:26 ATOMIC SAFETY AND LICENSING BOARD 6F F 'b ' ' '
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In the Matter of
)
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Docket Nos. 50-445-dh TEXAS UTILITIES ELECTRIC
)
50-446.ek-COMPANY et al.
)
)
(Application for an (Comanche Peak Steam Electric
)
Operating License)
Station, Units 1 and 2)
)
)
APPLICANTS' ANSWERS TO CASE CPRT PROGRAM PLAN INTERROGATORIES (Set No. 5)
Pursuant to 10 C.F.R.
sec. 2.740 ff.,
the Applicants hereby submit their responses to CASE's "CPRT Discovery -
5," served by ordinary mail on September 16, 1986.
Instructions The Applicants have ignored the instructions contained in the paragraphs labelled "A" through "F,"
inclusive, as contained in the document entitled "CPRT Discovery Instructions" under the heading " Instructions" (pages 7-l 10), insofar as the same are contrary to the Rules of Practice.
[
Design By agreement of the parties, and with the concurrence of the Board, matters regarding the adequacy of design aspects of the CPRT Program Plan have been excluded from i
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the matters in respect of which the Board authorized discovery on August 18 and 19, 1986.
Consequently, the Applicants have limited their answers to these interrogatories to matters other than the design adequacy aspects of the CPRT Program Plan.
Interrogatories Interrogatory No. 1:
Identify by name, position and employer the person or persons for each ISAP or DSAP who is responsible for determining whether an " unsatisfactory iten" noted on a CPRT checklist is a deviation, discrepancy, or deficiency.
Indicate what, if any, connection this person has to the Applicants such as employee, consultant, employee of consultant, contractor, etc.
Include any former connection to Comanche Peak and describe the control which Applicants have over this persons.
Objection:
The Applicants object to this interrogatory, on the ground that the requested information is not relevant to the adequacy of the CPRT Program Plan, and therefore is I
beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather l
expressly relying upon the same, the RTL for each Action Plan is responsible for the accomplishment of all of the tasks required to be performed under that Action Plan.
The RTL has the authority to delegate the performance of tasks
. l
O' in his discretion, but remains responsible for the performance thereof.
The identity of the specific individual (s) involved in the performance of each Action Plan will be contained in the Results Report or in the Working File for that Action Plan once it has been completed.
The qualifications and vitae of each RTL and each IC are contained in the Action Plan or will be contained in the Working Files associated with specific Actions Plans, and the " Objectivity criteria" applicable to the CPRT third-party personnel are set forth in the Program Plan at 17 (section VII).
Interrogatory No. 2:
Identify the procedure or procedures used to classify or determine whether or not an " unsatisfactory item" noted on a CPRT inspection checklist is a deviation, discrepancy, or deficiency.
Answer:
The " procedure" is to compare each "unsat" with the acceptance criteria contained in the Action Plan or Quality Instruction and, to the extent applicable, with the definitions contained in Program Plan, Appendix E.
Anything (whether the subject of an "unsat" or not) that fails to meet the acceptance criteria is a deviation; deviations that are determined to be " safety significant" (as defined in the Program Plan at 7 & n.
(section III.B) l and Appendix E) are then further classified as a l
deficiency.
Please note that the term " discrepancy," as employed in this question as if referring to a possible categorization by CPRT of matters identified, is not apt and has been ignored.
Please also see CPP-010 and -016.
Interrogatory No. 3:
Does the safety-significance evaluation group (SSEG) review all of the complete checklists from all ISAPs and DSAPs to identify unsatisfactory items for evaluation?
a.
If the answer to the above question is yes, explain in precise detail what the process is by which the review is accomplished.
b.
If the answer to the above question is no, explain in precise detail the process by which the SSEG receives any inputs from the CPRT programs.
l Answer:
This question is founded upon an erroneous premise, namely that the SSEG evaluates "unsats," and therefore it i
i cannot be answered as framed.
The SSEG evaluates l
" deviations" (as defined above), as identified and confirmed by the cognizant population engineer, to determine whether a deviation is a deficiency.
(Note that l
the SSEG function referred to applies to Action Plan l
VII.c. and to certain other safety significance evaluations l
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l under other hardware action plans.)
Interrogatory No. 4:
[No interrogatory 4 was included in the set.] -
Interrogatory No. 5:
Explain the process in precise detail, using examples from released results reports where helpful, how discrepancies are " classified into categories of relative significance."
a.
Identify all categories used for classification b.
Identify the types of bases used to establish the classification, and identify on what forms the bases will be documented.
Answer:
The classifications referred to are those identified in the balance of the section of Program Plan, Appendix E, from which this quotation is taken.
Please see our response to Interrogatory No.
2, supra.
Interrogatory No. 6:
Explain, in precisc detail, what a discrepancy is.
(Use examples from completed checklists available to CASE or other checklists attached to your answer.)
Answer:
" Discrepancy" is not employed in the Program Plan with any specialized meaning or to denote a classification of findings.
Where employed, it is used to denote the l
aggregate of the classifications defined in Program Plan, Appendix I at 1 ff.,
Section B.
Interrogatory No. 7:
l To what extent, if any, do the inspection checklists record differences between the as-built as installed l
hardware and information recorded on the original inspection checklists.
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Example:
The CPRT identifies an unsatisfactory item for attribute X.
Attribute X was also an attribute on the original quality control inspection report, where it is marked " sat".
On what form or in what place does the CPRT identify the failure of the original QA/QC inspection to identify the unsatisfactory item.
Answer:
Hardware is inspected to attributes and accept / reject criteria determined by CPRT to be relevant to safety significance, which are not necessarily the same as the attributes and accept / reject criteria employed in making original acceptance inspections.
Whenever a deviation is detected, the deviation is assessed for safety significance.
If found to be " safety significant" (as that term is defined in Appendix E), the deviation is classified as a deficiency.
Those deviations not classified as deficiencies are assessed as possible adverse trends.
A root cause assessment is made in the case of deficiencies and adverse trends.
Reference to the origine.1 inspection documentation would normally be expected to be made only in the course of performing a root cause assessment.*
Recording of findings made in the course of root cause
'In addition, original documentation is also reviewed, under Action Plan VII.c, for certain inaccessible or non-recreatable attributes, and for inspector certification, and in certain TRT-responsive Action Plans (e.g.,
I.a.1, I.a.2). _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
investigations are not required by the SRT to be made on any particular prescribed forms; they will be discussed in the Results Report and would ordinarily be retained in the Working Files for the Action Plan in question.
It is perhaps worth noting that this question suggests that its author does not understand the fundamental concept of the CPRT, and does not understand the difference between a program that tests the adequacy and acceptability of a facility and a program that singles out and tests only one aspect of the process by which the facility was created.
CPRT is the former.
It is designed to lead to a conclusion that the CPSES facility is (after taking into account any l
corrective actions) adequately designed and constructed and tested (and is therefore eligible to be licensed).
It will establish reasonable assurance as to the absence of l
undetected, encorrected safety significant deficiencies, either by determining that they never existed or that they have been found.
In the process, much may be learned about the adequacy vel non of the original acceptance inspection program, but the purpose of the exercise will be accomplished whatever the ultimate verdict about that program might be.
A program that singled out and tested the adequacy of l
the original inspection program, on the other hand, would 1 1 l
l
be certain to test the original program in all respects.
However, it would not test the hardware directly, nor could it assure global coverage of any indirect assessment of hardware.
In addition, auch a program would not (and could not) test the hypothesis of falsification of records, includinc any extent to which record reliability might be impaired by the hypothesized existence of harassment and intimidation of inspection personnel.
Finally, should such a program lead to a negative verdict on the adequacy of the original acceptance inspection program, nothing of utility would have been accomplished, because a program like CPRT would then have to be engaged in order to provide the requisite reasonable assurance that CPRT provides directly.
Interrogatory No. 8:
Identify the person, persons, or groups who are responsible for the classification of design discrepancies as observations, deviations, or deficiencies discussed in Appendix E, on page.
1.
Objection:
l For the reasons set forth above under " Design," the Applicants object to this question in its entirety.
Interrogatory No. 9:
For each design review or inspection describe which documents of the original package are included in the review process.
Answer:
For construction, please see our response to
-g_
Interrogatory No.
7, supra.
Interrogatory No. 10:
For each design review of inspection [ sic] identify each attribute for which the originai inspection reports are included in the inspection process.
Response
We do not understand the term " design review of inspection" and therefore cannot respond to the question.
If the intention was to seek a list of all attributes for which inspections are being performed under Action Plan VII.c. these are contained in the Quality Instructions prepared for the implementation of that Action Plan, copies of which have already been provided to CASE.
To the extent that the intention was to seek a list of all attributes for which design reviews are being performed, the Applicants object to the question for the reasons set forth above under " Design."
r Interrogatory No. 11:
i Explain, in precise detail, what an " identified error" is as it is used on page 1 of Appendix E.
Answer:
The quoted phrase was not employed with any specialised or defined meaning.
It refers, conceptually, i
i to the identification of an error in the activity being reviewed.
Such errors could include (but are not necessarily limited to) typographical errors, errors in
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bringing forward data or the results of calculations, errors in referring to incorrect reference material, failure to translate adequately from one mode of statement (such as a design commitment) to another (such as the implementation of the commitment in a specific context),
mathematical errors.
As stated in Appendix E at 1 (section B.1), the term refers to the aggregate of all findings made during design review prior to classification of the finding into one of the classes defined thereafter in that Appendix.
Interrogatory No. 12:
Describe in detail the process which is used to decide what is a safety-related structure, system, or component that could have an adverse impact on the adequacy of the desiclide [ sic].
Answer:
We do not understand the term "desiclide."
Nonetheless, please see our response to Interrogatory No. 20 of "CPRT Discovery - Set No.
1."
Interrogatory No. 13:
Explain in precise detail, the process by which an identified design discrepancy "is determined" to not constitute a design deviation and therefore becomes a design observation.
Objection:
For the reasons set forth above under " Design," the Applicants object to this question in its entirety. _ _ _ _ _ _ _ _ _
l Interrogatory No. 14:
Explain, in precise detail, what is a " verified failure to meet a design commitment or specification."
Include in the definition which of the original commitments and specifications are included and which are excluded.
Objection:
For the reasons set forth above under " Design," the Applicants object to this question in its entirety.
Interrogatory No. 15:
Explain in precise detail, the process by which an identified design discrepancy is determined to be a " verified failure to meet a design commitment or specification."
Objection:
For the reasons set forth above under " Design," the Applicants object to this question in its entirety.
Interrogatory No. 16:
Identify the person or persons (see instructions) who make the determination on whether a set of related design discrepancies constitute an adverse trend.
Objection:
For the reasons set forth above under " Design," the Applicants object to this question in its entirety.
Interrogatory No. 17:
Identify all person or persons (see instructions) who are responsible for classifying construction discrepancies as deviations or deficiencies.
Answer:
Please see our responses
- o Interrogatories Nos. I and 3,
supra.
Interrogatory No. 18:
Explain in precise detail (see instructions) the process through which an unsatisfactory item on a checklist becomes a discrepancy or deficiency.
Answer:
Please see our responses to Interrogatories Nos.
1, 3 and 7, supra.
Interrogatory No. 19:
In regards to the classifications made of boo-boos (see CPRT Discovery - 4, Q.
- 2) in the construction adequacy program, what definition is used to describe a failure of the original inspection to identify the boo-boo?
Answer:
Insofar as this interrogatory employs the term " boo-boo," please see our answer to Interrogatory No. 2 of "CPRT Discovery - Set No.
4."
Please also see our response to Interrogatory No.
7, supra.
Interrogatory No. 20:
Identify the person or persons (see instructions) who make the determination that a set of related construction deviations constitutes an adverse trend.
I Objection:
The Applicants object to this interrogatory, on the ground that the requested information is not relevant to the adequacy of the CPRT Program Plan, and therefore is l
beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:..
Without waiving the foregoing objection, but rather expressly relying upon the same, the RTL for each Action Plan is responsible for the accomplishment of all of the tasks required to be performed under that Action Plan.
The RTL has the authority to delegate the performance of tasks in his discretion, but remains responsible for the performance thereof.
The identity of the specific individual (s) involved in the performance of each Action Plan will be contained in the Results Report or in the Workin.{ File for that Action Plan once it has been completed.
Interrogatory No. 21:
Describe or identify the CPRT program element that identifies failures of the original QA/QC inspection process to identify a condition which was unsatisfactory at the time of the original inspection.
Answer:
Please see our response to Interrogatory No.
7, supra.
Interrogatory No. 22:
To what extent does the QA/QC program adequacy intend to draw conclusions or make statements about the implementation in compliance with 10 CFR Part (50),
Appendix B of the original QA/QC program?
Answe_r:
Please see our response to Interrogatory No.
7,
- supra, and Program Plan, Appendix B at 12.
Interrogatory No. 23:.
Explain in precise detail, using examples if helpful, what is or would be a " verified failure" of the QA/QC program to meet a regulatory requirement.
Answer:
The terms set forth in Program Plan, Appendix E, at 4 (section B.4(a)) were not used with any specialized meaning.
For examples, please see the Results Report for Action Plan VII.a.4.
The potential for such " verified failure (s)" is directly investigated in Action Plans I.d.1, I.d.1 and VII.a.2 through VII.a.9.
Also, in the assessment of " root cause," it is possible that
' verified failure [s]' of the QA/QC program to meet a regulatory requirement" may be identified.
The identification of such
" failures" will be documented in the Results Report or in the Working Files for the Action Plan in which the identification,is made.
Interrogatory No. 24:
Identify the CPRT procedures or checklist used to determine what is a " verified failure of the QA/QC program."
Answer:
Please see CPP-Oll.
Interrogatory No. 25:
(
Describe in precise detail the process by which a verified failure of the QA/QC program becomes a QA/QC program deficiency.
Answer:
The " process" consists of comparing the deviation to l
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i the definition of " deficiency."
Please see CPP-Oll.
Interrogatory No. 26:
Explain in precise detail (see instructions) what would be a " substantive revision of the program" as used on page 4 of Appendix E in evaluating the inadequacy of a QA/QC program element.
Answer:
The quoted terms were not employed with any specialized meaning.
If a substantive revision would be required to bring the program into compliance, this is a measure of the extent to which it is, without the revision, out of compliance.
Interrogatory No. 27:
Explain in precise detail (see instructions) what the term " extensive evaluation" means as used on page 4 of Appendix E.
Answer:
The quoted term was not used with any specialized meaning.
It is the same as the concept employed in 10 CFR section 50.55(e)(iii) & (iv).
Interrogatory No. 28:
Explain in precise detail (see instructions) what a
" set of related QA/QC deviations" is as used on page 5 Appendix E.
Answer:
The quoted term was not used with any specialized meaning.
Interrogatory No. 29:
Identify the person or persons (see instructions) who make the determination when a set of related QA/QC deviations is determined to constitute an adverse trend that is programmatic in nature.
Answer:
The RTL for each Action Plan is responsible for the accomplishment of all of the tasks required to be performed under that Action Plan.
The RTL has the authority to delegate the performance of tasks in his discretion, but remains responsible for the performance thereof.
The identity of the specific individual (s) involved in the performance of each Action Plan will be contained in the Results Report or in the Working File for that Action Plan once it has been completed.
Interrogatory No. 30:
Explain in precise detail (see instructions) how the CPRT program determines if a trend "is likely to have resulted in the occurrence of an undetected deficiency in the affected area, population or stratum."
Answer:
Please see PAG-04; CPP-Oll.
Interrogatory No. 31:
Explain in precise detail (see instructions) what an
" unclassified trend" is as used on page 5 of Appendix E.
Answer:
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The referenced classification of deviations permits CPRT to proceed directly to the treatment that would be I r
required in the case of classification as an adverse trend without engaging in the effort necessary to determine that it is, in fact, an adverse trend, where in the judgment of the RTL, subject to review and approval by the SRT, so doing is expeditious.
Interrogatory No. 32:
Identify all procedures, or checklists, used to conduct the evaluations for adverse trends as discussed on page 5 of Appendix E.
Answer:
Please see CPP-Oll.
Interrogatory No. 33:
Describe in precise detail, (see instructions) the process by which an identified trend will be evaluated.
(pgs. 5-7).
Answer:
Please see PAG-04; CPP-Oll.
Interragatory No. 34:
Explain in precise detail (see instructions) the factors considered when deciding whether it is more practical or expeditious to not perform a safety-significance evaluation. (id.)
Answer:
i There is no defined set of such factors, it being the responsibility of the RTL recommending such action to l
justify it.
In general, factors would include (but not be l
limited to) the amount of time necessary to complete a safety significance evaluation, the extent to which i
additional information, not presently available or likely to be acquired for any other purpose, might be required, the ability of the RTL to predict the likelihood that an affirmative conclusion would be reached, the amount of effort required to afford the unclassified deviation the treatment required of deficiencies and adverse trends (and a comparative assessment of that effort to the effort required to make the classification).
In general, these are attributes of a situation in which " performing a safety significance evaluation in respect of the unclassified deviation (s) or an adverse trend analysis in respect of the unclassified trend would serve no purpose Please see Program Plan, Appendix E at 6; CPP-Oll.
Interrogatory No. 35:
Identify the procedures or source documents on which
" unclassified deviations" would be found.
(Id.)
Answer:
It is not clear what is intended by the term
" procedures or source documents," and, given the conjunction of the two, the question is quite unclear.
If the intended question was where in the CPRT program output would " unclassified deviations" be recorded, the answer is wherever a deviation has been classified as an l
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" unclassified deviation," the fact will be recorded in the i
Results Report, or the Working File associated therewith, in l
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which the classification was made.
Interrogatory No. 36:
Describe, or identify, the process by which unclassified deviations or trends will be traced for purposes of root cause and generic implications.
Answer:
Assuming that " traced" means " tracked" (see Program Plan, Appendix E at 6), the process applicable to the treatment of unclassified deviations is the same as the process applicable to deficiencies.
Interrogatory No. 37:
Identify or explain the criteria for identifying "special cases" in which it would be appropriate to take or do actions beyond those listed in the program plan.
Answer:
There are no established a priori criteria.
This is another example of the extent to which the Program Plan anticipates the need for flexibility in order thoroughly to I
deal with any issue that may arise.
Please note that whoever drafted this question appears to be working from a superseded version of Appendix E, since the reference to "special cases" has been deleted as unnecessary.
The current version of Appendix E is Rev. 2 l
(6/6/86).
l Interrogatory No. 38:
Identify the person or persons who decide whether or when it would be appropriate to take or do ect'_nc beyond !
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A those listed in the program plan.
Objection:
Answer:
Assuming that the question refers to action that might be taken by the CPRT beyond those listed at any one time in the Program Plan, the SRT, acting collegially and collectively, which may receive a recommendation from an RTL.
Interrogatory No. 39:
Describe in precise detail (see instructions) how the CPRT insures that "all deviations" are transmitted to the CPSES project for evaluation and disposition.
Answer:
All deviations (as defined) are recorded, the precise form of which varies from Action Plan to Action Plan.
Copies of all such reports are forwarded to the utility for, among other things, processing as potential NCRs.
Please see Program Plan, Appendix F at 14; PAG-01 at 4; CPP-010.
Interrogatory No. 40:
Describe in precise detail (see instructions) the process by which the CPRT determines that appropriate corrective action has been defined for the non-conformance associated with the deviation.
Answer:
The question misstates the category of deviations for which definition of corrective action by CPRT is required.
. l
- - - ~.- - - - -
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See Program Plan, Appendix H.
Interrogatory No. 41:
Describe in precise detail (see instructions) the process by which the CPRT determines that appropriate corrective action has been accomplished for the non-conformance associated with the deviation.
Answer:
Please see Section C of Program Plan, Appendix H.
(Note: please also see our response to the prior interrogatory, which shares with this one a misconception about the scope of the corrective actions as to which CPRT L
I oversight is required.)
Interrogatory No. 42:
Describe in precise detail, (see instructions) how it is determined what is the "affected area, population or stratum" of the generic implications of the deficiency.
Answer:
This is defined, at least in the fi rst instance, by the attribute or the specific accept / reject criterion that produced the deficiency.
See PAG-04; CPP-Oll.
Expansion into other attributes or strata cannot be described on a hypothetical basis.
Interrogatory No. 43:
Describe in precise detail, (see instructions) how the CPRT will determine whether appropriate corrective action has been accomplished for the non-conformance associated with each deficiency.
Answer:.
Assuming that " accomplished" is synonymous with r
" implemented," please see Section C of Program Plan, 1
Appendix H.
Interrogatory No. 44:
Describe in precise detail (see instructions) how a trend which is not classified as an " adverse trend" is dealt with under the CPRT.
Answer:
No specific follow-up activities are required for a trend which has not been classified as an adverse trend.
See Program Plan, Appendix E, at 7 (section C.4).
(Note:
if the question was intended to address " unclassified
{
trends," please see our response to Interrogatory No. 36, supra.)
Interrogatory No. 45:
There is no interrogatory numbered 45.
Interrogatory No. 46:
Identify how the results of adverse trends will be documented and reported.
Answer:
The identification of an adverse trend, the determination of root cause and generic implications, and the determination of any corrective action, will be documented and reported in the Results Report or the Working File for the Action Plan in which the adverse trend was identified, or in the appropriate Collective Evaluation _ _ _ _ _ _.
report.
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I Interrogatory No. 47:
Produce for inspection and copying all documents identified in the answers to these interrogatories and all documents examined and/or relied upon in providing answers to these interrogatories.
Answer:
It is not believed that any documents of which copies have not already been produced for inspection by CASE are so described.
Nonetheless, the Applicants will produce for inspection and copying, at the offices of Texas Utilities Generating Company, 400 North Olive Street, Dallas, Texas, at a time to be mutually agreed upon by counsel or other representatives of the parties, any document referred to herein without objection specifically identified by CASE of which it has not already had an opportunity to inspect.
Motion for Protective Order To the extent required by the Rules of Practice, the Applicants move for a protective order on the objectionn interposed in the foregoing responses.
I I
SIGNATURES I,
Terry G.
Tyler, being first duly sworn, do depose and say that I am the Program Director of the Comanche Peak Response Team ("CPRT") (see " Comanche Peak Response Team Program Plan," 6/28/85), that I am familiar with the information contained in the CPRT files and available to CPRT third-party personnel, that I have assisted in the preparation of the foregoing answers, and that the foregoing answers are true, except insofar as they are based on information that is available to Texas Utilities or the CPRT (third-party personnel) but not within my personal knowledge, as to which I, based on such information, believe them to be true.
Y1 w
e hd---
Terry G.
yler Sworn to before me this
_fk__ day of set h-
, 1986:
Nevernbeh a3 o ary Pub ic
/
_f_0_jlf___9_Q_________
My commission expires:
As to Objections: _ _ _ _ _. _ _.. _
E i
I Thomas G.
D pan, Jr.
R.
K.
Gad I I William S.
Eggeling Kathryn S.
Selleck Ropes & Gray 225 Frankling Street Boston, Massachusetts 02110 Telephone: (617) 423-6100 B
l evu w cOHRESPONDENC%
00LKfiU upc CERTIFICATE OF SERVICE
'86 NOV 12 R2:26 I,
Robert K. Gad III, one of the attorneys fotrthe : Applicants 00CKL T tlit 4
herein, hereby certify that on November 1986, I mad 5Eservice of the within " Applicants' Answers to CASE CPRT Program Plan Interrogatories (Set No. 5)" by mailing copies thereof, postage prepaid, to:
Peter B.
Bloch, Esquire Mr. James E. Cummins Chairman Resident Inspector Administrative Judge Comanche Peak G.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 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 Washington, D.C.
20555
9 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 37830 Maryland National Bank Bldg.
Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 Ms. Billie P.
Garde Midwest Office 3424 N. Marcos Lane Appleton, Wisconsin 54911
. /
Robert K./ Gad III l
l 1
._.