ML20213F466
| ML20213F466 | |
| 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-#486-1466 OL, NUDOCS 8611140218 | |
| Download: ML20213F466 (26) | |
Text
h1986, g
Filed:
Novecber l'/64 q
UNITED STATES OF AMERICA i
HELATED CoaRESPONDtNGE NUCLEAR REGULATORY COMMISSION 00LKETED 3
before the ATOMIC SAFETY AND LICENSING BOARD 16 NOV 12 R2:23 0FF !;
00CKiiRL '
9y y a In the Matter of
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Docket Nos. 5 0-4 4 5- # A-TEXAS UTILITIES GENERATING
)
50-446-ou COMPANY et al.
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)
(Application for an (Comanche Peak Steam Electric
)
Operating License)
Station, Units 1 and 2)
)
--______-________________-_-______)
APPLICANTS' ANSWERS TO CASE CPRT PROGRAM PLAN INTERROGATORIES (Set No. 4)
Pursuant to 10 C.F.R.
sec. 2.740 ff.,
the Applicants hereby submit their responses to CASE's "CPRT Discovery -
4," 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 I
contained in the document entitled "CPRT Discovery Instructions" under the heading " Instructions" (pages 7-10), insofar as the same are contrary to the Rules of Practice.
j l
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
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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:
Explain, in precise detail, how the completion of the first and second component of the CPRT (described in Appendix B, summarized in the last two paragraphs on pg. 2) will fully resolve and/or fully bound the safety-significant implications of deficiencies in the CPSES construction QA/QC program?
Answer:
The assertion referred to was (and is) based upon the assumption that the range of the externally raised issues was broad enough to capture at least one manifestation of all of the systematic causes of potential deficiencies that might exist.
Assuming this to be true, then the rigorous pursuit of those issues, including the pursuit of root cause and generic implications of such of them as were determined to be valid, would in fact bound the set of extant deficiencies.
The statement referred to has, o f course, no operative significance given the scope of the self-initiated aspects of the program.
Its remaining purpose is to reflect the historical development of the program plan. {
I i
{
e Interrogatory No. 2:
Appendix B (page 3) states that the self-initiated component of the CPRT will permit the CPRT to make a firm statement about the ".
adequacy of the QA/QC program employed during its construction".
Explain, in precise detail, with reference to the elements of the program plan, what ISAPS/DSAPS explore the failures of the QA/QC program to meet original commitments without regard to the adequacy of the resultant hardware.
(Throughout these discovery requests, the failure of QA/QC to mect an original commitment, such as failing to report an unsat condition, if it is not deemed a deficiency or a discrepancy by the CPRT, will be referred to here as a " boo-boo."
Answer:
I.d.1 I.d.2 VII.a.2 -.8 QA/QC Collective Evaluation We would add that the definition of " boo-boo" is not comprehensible, since failure to record an "unsat" might or might not be a failure of original QA/QC, and since, for the most part, the CPRT is searching for non-conformances of hardware to design documents, which if found are deviations, such that "an unsat condition [] which is not classified as a deviation" is not something captured by CPRT.
Given the foregoing, interrogatories referring to t
" boo-boos" have been ignored hereinafter.
l Interrogatory No. 3:
Appendix B provides for the DAP to report " areas of concern" involving design control processes required by 10 C.F.R. 50, Appendix B, Criterion III to the QA/QC Review Team Leader for evaluation.
In regards to this element of l
the program:
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a.
Identify all procedures or documents which are used in the identification of the area of concerns.
b.
Explain, in precise detail, the term " areas of concern" as used on page 3 of Appendix B, including but not limited to how design observation becomes on area of concern, who is responsible for making the decision whether a boo-boo is an area of concern, and what source documents are reviewed to determine if a boo-boo is an area of concern.
c.
Identify all forms or procedures used to provide the concern to the QA/QC RTL for evaluation.
d.
Identify, by name and form number, the procedures used to perform the evaluation referred to on page 3.
e.
Identify the person or persons responsible for conducting the assessment of the concerns.
f.
Identify the procedures used to perform the assessment and if required, the analysis described on page 3, para.4.
Answer:
a.
DAP-2, DAP-7 and DAP-19.
b.
The " areas of concern" refer to potential programmatic weaknesses (e.g.,
control of inputs, design verification, design change control and other essential elements of 10 CFR, Part 50, Appendix B, Criterion III and ANSI N45.2.ll) inferred from the results of the DAP reviews of design basis documents described in the Program Plan, Appendix A and DSAPs VII, IX, X and XI.
The procedures above describe the process and define who does what.
c.
DAP-2 and -19...--
d.
DAP-2 and
-7.
e.
Same answer to sub-part (b), supra.
f.
CPP-014.
Insofar as this interrogatory employs the term " boo-boo," please see our answer to Interrogatory No.
2, supra.
Interrogatory No. 4:
Provide the matrix referred to on page 4, para.
7.
Objection:
The Applicants object to this request, on the ground that the matrix referred to is a specific CPRT Program output.
Until such time as this aspect of the program is completed, this request calls for the production of uncompleted and in process materials.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, the matrix referred to will be contained in the Collective Evaluation Report for i
the Quality of Construction and Construction QA/QC Program.
i Please also see " Applicants' Response to Board Memorandum of 8/8/86 (Assistance to the Board)" filed 10/6/86.
l l
Interrogatory No. 5:
l Explain, in precise terms, how a concern is determined j
to be " valid" in order to be tracked on the matrix.
Answer:
This question is founded upon an incorrect premise, l !
l i
9 namely that only issues that are " valid" are contained in the matrix.
Therefore, the question cannot be answered as framed.
Interrogatory No. 6:
Identify the person or persons from the QA/QC review team assigned to develop the matrix.
Objection:
The Applicants object to this interrogatory, on the ground that the requested information is not relevant to the ndequacy of the CPRT Program Plan, and therefore is 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 Quality of Construction and QA/QC Adequacy Program Plan RTL is responsible for the accomplishment of all of the tasks required to be performed under Program Plan Appendix B.
l The RTL has the authority to delegate the performance of i
tasks at 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. !
I I
Interrogatory No. 7:
Explain, in precise detail, the circumstances under which external source issues would not be adequately addressed by existing ISAPs such that revisions of ISAPs or new ISAPs would be necessary.
(Page 4)
Answer:
This question cannot be answered as framed.
Were it known in advance where an external source issue was not captured by an existing Action Plan, either an additional Action Plan or a revised Action Plan would have been published.
The purpose of the language referred to by this question is to demonstrate the SRT's commitment to the flexibility requisite to accomplishment of the CPRT program goal.
It should be noted that certain ISAPs were written and approved prior to the time that the matrix system was first implemented.
As a result, it may be determined (when the matrix has been completed and the Collective Evaluations are performed) that there are External Source issues not directly addressed in an ISAP or Results Report.
These issues will be identified and addressed in connection with the Collective Evaluations and will be documented either in the Collective Evaluation Report or in separate documentation contained in the Working File for the Collective Evaluation.
Insuring such coverage is one of the purposes for which the Collective Evaluations were )
added to the Program Plan.
Interrogatory No. 8:
Explain in precise detail how a review and verification of an already implemented TUGCO Corrective Action program would be used to provide additional data to the collective evaluation process.
Identify each TUGCO program which falls into a.
the description provided in response to question 8.
b.
For each program identified provide the following information:
1.
When the program was instituted.
2.
If concluded, when the program was concluded.
3.
What was the original impetus of the program.
4.
Name the organization and the principle individuals responsible for conducting the program.
Objection:
The Applicants object to sub parts (a) and (b) of this interrogatory on the ground that, to the extent referring to implementation of the Program Plan, this interrogatory is beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986, and on the ground that they call for the production of uncompleted, in process efforts, which is improper discovery.
Answer:
Without waiving the foregoing objection, but rather 1
O expressly relying upon the same, the language referred to was designed to anticipate the potential that a specific external source issue had already been addressed and resolved by a previously undertaken and completed CPSES project corrective action.
In such a case, the extent to which the issue either remained viable or had been closed would depend upon the validity of the completed corrective action, which CPRT would assess.
In the absence of a more focussed question, it is not apparent to us what further
" e x p l a nit t i o n " is requested.
Interrogatory No. 9:
List all the procedures used in developing and/or implementing the CPRT activities described in Appendix B.
Ob.jection:
The Applicants object to this interrogatory on the ground that, to the extent referring to implementation of the Program Plan, this interrogatory is beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986, and on the ground that they call for the production j
of r, completed, in process efforts, which is improper l
discovery.
l Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, see PAG-01 through PAG-12; CPP-001 through CPP-026.. _ _
Interrogatory No. 10:
Identify all evaluations which will be conducted by another Review Team instead of the Safety Significance Evaluation group.
Objection:
The Applicants object to this interrogatory on the ground that, to the extent referring to implementation of the Program Plan, this interrogatory is beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986, and on the ground that they call for the production of uncompleted, in process efforts, which is improper discovery.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, assuming the reference to be to the provision in Program Plan, Appendix B at 11 for the performance of safety significant evaluations by someone other that SSEG in connection with the evaluation of deviations identified during the implementation of i
Action Plan VII.c, no such instances have been identified to date.
Interrogatory No. 11:
Identify the form or procedure used by the safety-significant evaluation group to identify design-related deviations in order to turn them over to the Design Adequacy Review Team.
Answer:.
See CPP-018.
Interrogatory No.
12:
Explain in precise detail the actual methodology by which the CPRT will determine, a.
the root cause o f any safety-signi ficant deficiencies, b.
the generic implications of the root cause in order to determine if other areas of hardware might contain safety-significant deficiencies attributable to the same root cause, and c.
how it will be determined if additional hardware evaluations would be required to establish root cause or to bound the root cause or determine generic implications.
Answer:
Please see our answer to Interrogatory No. 7 of CPRT Discovery - Set 1.
Please also see CPRT Policies and Guidelines " Guide on Root Cause and Generic Implications" (PAG-04); CPP-011.
Interrogatory No. 13:
Explain how the SIE will "sase time" in the resolution of areas which the category I ISAPs indicated had generic implications as a result of the root cause determination.
Answer:
By proceeding directly to investigations that might ultimately be required, thereby achieving economies of anticipation.
Interrogatories Nos. 14. 15 & 31:
Explain how the SIE resolves the concerns that might - - -
exist about the QA/QC program breakdown which results from evidence of inadequate qualification of QC inspectors in the past.
Explain how the SIE resolves concerns that might exist about the QA/QC programs implementation over the history of the project as a result of potential occurrence of harassment, intimidation, or pressure of QC inspectors.
Explain how the SIE resolves concerns that might exist about the QA/QC program's implementation over the hiscory of the project as a result of the potential failure of management to possess or exhibit the proper character or competence to properly implement the QA/QC program.
Answer:
The function of the self-initiated programs is to detect deficiencies regardless of cause.
In addition, the document reviews conducted under Action Plan VII.c look at inspector qualification directly.
See CPP-025.
It should be understood that there is a fundamental difference between a program that tests the adequacy and acceptability of a facility and a program that singles out and tests only one aspect (such as QA/QC) 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 adequately designed and constructed and tested (and is therefore eligible to be licensed).
It will establish reasonable assurance as to the absence of undetected, uncorrected safety significant deficiencies, either by determining that they never existed or that they have been found and are being fixed (i.e.,
appropriate corrective S
actions have been defined).
In the process, much is expected to be learned about the adequacy of the original acceptance inspection program (including the competence of inspectors), but the purpose of the exercise will be accomplished whatever the ultimate verdict about that program might be.
Thus structured, CPRT can, in fact, accomplish what a program that singled out and tested the adequacy of only i
the original inspection program cannot accomplish.
A QA-Program-grounded assessment, for instance, would not test the hardware directly, nor could it assure global coverage of any indirect assessment of hardware.
In addition, such a program would not (and could not) test the hypotheses of falsification of records or records unreliability, including any extent to which record reliability might be impaired by the hypothesized existence of harassment and intimidation of inspection personnel.
A QA-Program-based assessment is critically dependent upon the accuracy of its determinations (or assumptions) about root cause, while CRPT's global approach is tolerant both of any imprecisions in the root cause assessment process as well as of any situations in which no determination of root cause is possible.
Finally, should a QA-Program-based assessment lead to a negative verdict on the adequacy of the original. - --
acceptance inspection program, nothing of utility would have been accomplished, because a hardware based program like CPRT would then have to be engaged in order to provide the requisite reasonable assurance that CPRT provides directly.
Interrogatory No.
16:
To the extent that the presentation of Mr. Hansel and others at the October 2 or 3, 1985 public meeting, does not adequately describe or explain or differs from how the installed safety-related hardware was categorized into populations, and then into homogenous work activities, provide a correct explanation.
Answer:
If the question is nbout the methodology and purpose of the population derivation process, the process is adequately described in Program Plan, Appendix B.
If the question is intended to elicit data on the implementation of that process, such data will be contained in the Results Report and Working File for Action Plan VII.c.
See also l
CPP-005, i
Interrogatory No.
17:
Identify each population into which safety-related hardware was/is categorized (App.
B, pg. 8-9).
Answer:
Please see our response to Interrogatory No. 16, supra.
Please also note that a preliminary population list is attached to Program Plan, Appendix C, Action Plan VII.c,.
Attachment A.
Interrogatory No. 18:
Identify the person or persons whose " experience" was relied upon to categorize each of the populations identified above.
(App.
B, pg. 8-9).
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 at 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. 19:
Identify for each population the " reasonable homogenous work activities" identified.
(App.
B, pg.8-9).
Answer:
Please see our response to Interrogatory No. 16, supra.
Interrogatory No. 20:
Describe, in detail, the process used to determine which " quality characteristic" for each HWA to use.
Answer:
Please see CPP-007...
4 Interrogatory No. 21 Identify each quality characteristic for each HWA which will be verified, and which characteristics will be verified by sampling methods and which characteristics will be verified by actual inspection of the installed work (pg.
8, et seq.)
Objection:
The Applicants object to this interrogatory on the ground that, to the extent referring to implementation of the Program Plan, this interrogatory is beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986, and on the ground that they call for the production of uncompleted, in process efforts, which is improper discovery.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, the quality characteristics (attributes) that will be verified are set focth in the Quality Instructions, copies of which have already been provided to CASE.
We do not understand the distinction apparently intended by the draftsman of the second clause of the question.
Interrogatory No. 22 Identify, for each attribute o f each HWA, which attributes will be reinspected and which attributes will be reviewed for samples of the hardware. (pg. 9)
Objection: - - -.
The Applicants object to this interrogatory on the ground that, to the extent referring to implementation of the Program Plan, this interrogatory is beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986, and on the ground that they call for the production of uncompleted, in process efforts, which is improper discovery.
Answer:
Without waiving the foregoing objection, but rather expressly relying upon the same, the attributes which were reinspected are shown on the reinspection checklists.
Those which had a review are shown on the Documentation Review Checklists.
Both sets of checklists have previously been provided to CASE.
Please also see CPP-007.
We do not understand the distinction intended between " sampling" and
" inspection."
Interrogatory No. 23 Explain the process in detail, including identiffing the procedures used to accomplish the tasks described in the above questions.
Answer:
Please see our responses to the above questions.
Interrogatory No. 24 Identify (by name, job title, entity employed by, supervisor) the person or persons responsible for selection of the samples described on page 9, paragraph 2 of Appendix B.
Include in your response the person or persons 9
(identified by name, job title, entity employed by, supervisor) responsible for selecting the subset of the population defined as "having greater importance to safety."
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 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 at 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. 25 Identify the procedures or instructions used by the indiv; duals identified in response to the previous question to accomplish the sample selection process.
~.
Answer:
Please see Program Plan, Appendix D; CPP-006.
Interrogatory No. 26:
Identify all sources of CPRT input to the collective evaluation of CPRT findings,, observations, and conclusions that relate to the adequacy of the CPSES construction QA/QC program.
Answer:
Please see CPRT Program Plan, Appendix B at 10, item B; CPP-014.
Please note that it is intended that no t
potential source of CPRT input be excluded.
Interrogatory No. 27:
Identify all sources of input to the collective evaluation of CPRT findings, observations and conclusions that relate to the quality of the installed hardware at CPSES.
Answer:
Please see CPRT Program Plan, Appendix B at 10, item B; CPP-014.
Please note that it is intended that no potential source of input be excluded.
Interrogatory No. 28:
Identify (by name, job title, entity employed by, supervisor) the person or persons who are responsible for preparing each of the collective evaluation reports identified above.
l 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 -
beyond the scope of the discovery authorized by the Board on August 18 and 19, 1986.
Answer:
Without waiving the foregoing objection, but rather i
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 at 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. 29:
Describe in detail the process by which the two collective evaluations will be merged to form the summary report on the QOC.
Answer:
There is no " process."
The task described is analytical.
Interrogatory No. 30:
1 Identify (by name, job title, entity employed by, supervisor) the person or persons responsible to preparing the 00C Summary Report.
Objection:
I
- 'O -
l i
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 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 Plap.
The RTL has the authority to delegate the performance of tasks at 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. 32:
Produce for inspection and copying all documents identified in the answers to these interrogatories and relied upon or examined in the course of answering these interrogatories.
l Answer:
l It is not believed that any documents of which copies have not already been produced for inspection by CASE are so described (except for CPP-014, which has been modificu,
since last provided to CASE).
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 objections interposed in the foregoing responses.
1 L
I l.
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.
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Terry Tyle l
Swprn to before me this t
- t-day of 0:trSer, 1986:
4/ o v e in b eR.
Notary Publ.F1____
c My commission expires: _ _]_k
_h__k_k_______
As to Objections:
I -- --- -
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- s2---g Thomas G.
Di an, Jr.
R.
K.
Gad I William S.
Eggeling Kathryn S.
Selleck Ropes & Gray 225 Frankling Street Boston, Massachusetts 02110 Telephone: (617) 423-6100 i
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"912MnmorJu pegg;g Mf$@:
CERTIFICATE OF SERVICE
'86 NOV 12 Pl2:23 0
I, Robert K. Gad III, one of the attorneys for0
$Pplicants 7
BPA a herein, hereby certify that on November 1986, I made service of the within " Applicants' Answers to CASE CPRT Program Plan Interrogatories (Set No. 4)" 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 i
Commission Glen Rose, Texas 76043 Washington, D.C.
20555 i
Dr. Walter H.
Jordan Nancy Williares Administrative Judge Cygna Energy Services, Inc.
881 W. Outer Drive 101 California Street, Suite 1000 l
Oak Ridge, Tennessee 37830 San Francisco, California 94111 Chairman Chairman l
Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission l
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 i
U.S. Nuclear Regulatory Dallas, Texas 75224 l
Commission Washington, D.C.
20555 i
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-. - _., - -,, - ~., - -. -. - - -,. -, -
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~ - _ _ _. _ -,. _ _ _ _., - - - _ _ _ _, - - _ _. -
Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Division Board Panel P.O.
Box 12548, Capitol Station U.S.
Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C.
20555 Anthony Roisman, Esquire Mr. Lanny A.
Sinkin Executive Director Christic Institute Trial Lawyers for Public Justice 1324 North Capitol Street 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
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Robert K. Ga /III l
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