ML20214L691
| ML20214L691 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/18/1986 |
| From: | Tyler T TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20214L684 | List: |
| References | |
| OL, NUDOCS 8609100329 | |
| Download: ML20214L691 (45) | |
Text
.-
Filod: August 18, 1986.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 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)
)
__________________________________)
AFFIDAVIT OF TERRY G.
TYLER I,
Terry G.
Tyler, being first duly sworn, do depose and say as follows:
Qualifications 1.
I hold the degrees of Bachelor of Science in Nuclear Engineering (1975 University of Tennessee) and Masters in Business Administration (1983, University of Tennessee).
I as a Professional Engineer in the State of Tennessee (No.
016333).
Since 1973, I have been engaged in the profession of engineering and engineering management with respect to the design, construction, testing and operation of nuclear power plants.
2.
I as the Comanche Peak Response Team ("CPRT")
Program Director.
I have served in that capacity since 8609100329 E60908' PDR ADOCK 05000445 0
the office was created in March of 1985, and I an intimately
{
familiar with the functioning of the CPRT and, in particular, with the organizational requirements of the CPRT Program Plan and the manner in which the CPRT files are maintained.
I make i
this affidavit on the basis of my personal knowledge.
Purpose of the Affidavit 3.
I make this affidavit at the request of the Applicants in response to the affidavit of Mr. Adam Palmer filed by CASE as an attachment to " CASE Response to Applicants' Motion for Protective Order of July 16, 1986, and Motion to Compel" served under date of July 31, 1986.
Based on the statements contained in Mr. Palmer's affidavit, plus my observation of the manner in which discovery relating to what Mr. Palmer calls " deficiency paper" has been conducted, it is clear to me that Mr.
Palmer does not understand the subjects addressed in his affidavit.
In particular, Mr. Palmer appears to be 1
confused about the difference between the CPRT Working Files and the documents described in Interrogatory No. 1 of
)
" CASE's Interrogatories to Applicants" dated November 15, 1985.
The basis for my conclusion is as follows.
Interrogatory No. 1 4.
In Interrogatory No.
1, CASE asked the Applicants to
"{i]dentify all the mechanisas by which a possible failure to
- 4
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fully comply with an NRC rule, regulation, or procedure (hereinafter collectively identified as ' deficiencies' or
' d e f i c i e r.c y ' ) at CPSES could have been identified since June 30, 1984, whether part of the CPRT or not."
(Emphasis added.)
As the Applicants stated in their answer, that request was not susceptible of a response as framed.
Nonetheless, the answer provided a list of " established systems for such identification."
(The list was supplemented on January 3, 1986.
A copy of the supplemented list is attached to this affidavit for the cor.venience of the Board.)
The Relationship Between CPRT and Project 5.
As has previously been explained to CASE, the detection and identification by CPRT of failures to comply with applicable standards, which are called " deviations,"
functions outside of and wholly in addition to the CPSES QA/QC programs.
As a consequence, the detection of a deviation by CPRT will yield (1) the initiation of a document er series of documents within the CPRT program as well as (2) the initiation of a document (usually an NCR) or documents under the CPSES QA/QC program.
See CPRT Program Plan Appendix H, Section B (4th bullet).
See also Tr. 24249-50, 24257, 24259-60 (Pre-Hearing Conference Transcript of November 22, 1985).
The first item on the list supplied in response to Interrogatory No.
I referred to the CPRT program, while.
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everything else is a part of the CPSES QA/QC program and is independent of CPRT.
This I believed and believe to have been consistent with CASE's request framed in terms of "whether part of the CPRT or not."
The Non-CPRT (i.e..
Project) Documents 6.
As was stated in the answer to Interrogatory No.
1, the non-CPRT documents, that is the CPSES QA/QC documents, are located in various locations depending on the nature of the activity for which the procedure applies and/or the completion status of the hardware.
There is no regulation that calls for these documents to be stored in one central location.
The regulations require only that the documents be stored in a secure area and be retrievable, and the records adverted to by Mr. Palmer meet both of these requirements.
7.
Mr. Palmer's last two visits to the CPSES site were for the stated purpose of inspecting the documents described in the answer to Interrogatory No. I and Mr.
Palmer has in fact been provided access to the documents as he has asked for them.
As these are original permanent CPSES documents, they are stored in a secure vault.
As Mr. Palmer identified documents to review, clerks assigned exclusively to attend upon Mr. Palmer have pulled the requested documents from the vault, taken them to a private office, and permitted -
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him to review them under escort.
The private office was provided at my direction as an accommodation to Mr. Palmer for two reasons: first, there is not sufficient physical space in the vault itself for his activities, and second, because of the magnitude of the documents he had indicated a desire to inspect, I judged it more expeditious to provide such accommodations.
Because documents were taken outside of the immediate vault control area, it is required that they been retained in the custody of one of the vault personnel or their designee.
8.
The magnitude of the documents that Mr. Palner has indicated a desire to inspect is very large.
I have previously offered to try te assist Mr. Palmer in culling out documents if he would tell me what his purpose or goal was or in some other fashion indicate what it was that he is looking for.
Mr. Palmer has declined (or been unable) to articulate any such criteria.
As long as he insists on a " brute force" review of the entirety of the QA/QC documents described in the list attached to this affidavit (i.e.,
the non-CPRT documents), I know of no further way to expedite the process.
9.
I wish to point out, however, that if the purpose of reviewing these documents is to assess the performance of CPRT, there is no need for the inspection that Mr..
e Palmer is performing.
Following the Pre-Hearing Conference of November 22, 1985, CASE requested to be provided with copies of the Project-written NCRs generated as a result of CPRT-identified deviations, together with the CPRT
" deviation paper" that generated them, and for the post July, 1985 period, such documents are being mailed to CASE.
(July, 1985, was the point at which a separate list of NCRs generated as a results of CPRT efforts was maintained.)
The CPRT Documents 10.
With respect to CPRT documents, there is a file maintained in Dallas (for the convenience of CASE) that contains all of the documentation called for by section III.J of the CPRT Program Plan, as implemented by the CPRT " Policy and Guideline on Assembly of CPRT Program Central and Working Files" (PAG-02, copy attached).
I note that the PAGs have been available ther.selves in the CPRT Central Files in Dallas and available for inspection since at least as early as May, 1986, yet to date CASE has never inspected them.
It is also relevant to point out that, for each completed Action Plan for which a Results Report has been published, the Working File for that Action Plan has been reviewed and verified to be complete and in accordance with the Program Plan requirements by the CPRT Results Report and Working Files Review Committee prior to submittal of a results report to the
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SRT for approval.
This procedure is spelled out in Attachment 4
(" Verification of Issue-Specific Action Plan Working Files")
to Appendix G ("CPRT Third-Party Quality Assurance Program")
of the CPRT Program Plan.
11.
In his affidavit, Mr. Palmer asserts that all necessary materials for analysis of the TRT concerns were not included in the materials presented to him when he inspected the Action Plan I.a.3 and VII.a.4 Working Files.
Mr. Palmer further asserts in his affidavit that these Working Files did not contain any " deficiency paper" of any type and in some instances lacked documents necessary for a proper and complete analysis of the problems identified by the TRT.
These assertions by Mr. Palmer, whether regarded as claims of fact or matters of expert opinion, are false.
Further, to the extent that these are matters of expert i
opinion, Mr. Palmer appears not to possess the qualifications required for such opinions.
I have reviewed the Working Files for these two Action Plans prior to j
making this affidavit, and my findings, and the reason for my opinions, are as follows:
12.
Action Plan I.a.3 deals with a very limited issue, namely the adequacy of the vendor's environmental qualification file regarding a particular type of hardware.
The Working File contains both the Action Plan and the i
_7_
Results Report (all revisions of both), which describe the issue being investigated, how it was investigated, the evaluation of the findings of the investigators (including any CPRT-identified deviations), the conclusions reached by CPRT regarding the issue under investigation, and the bases for the conclusions.
For this Action Plan, there were no CPRT-identified deviations and, therefore, there were (and could be) no " deficiencies."
In the expert judgment of the Issue Coordinator, the Review Team Leader and the SRT, the issue with which Action Plan I.a.3 deals has been thoroughly reviewed and resolved.
My own opinion is the same.
Perhaps more to the point, there are no other documents upon which the IC, the RTL and the SRT relied in reaching their conclusions.
13.
The situation with respect to Action Plan VII.a.4, which dealt with a " programmatic" as opposed to a hardware issue, is precisely the same except that in this l
case the CPRT identified fourteen program deviations.
Each of these deviations was evaluated in the Results Report and each is reflected in appropriate documents in the Working File.
14.
Some insight into Mr. Palmer's lack of comprehension comes from his statement that Action Plan i
I.a.3 " deals with butt splicing."
(Palmer Affidavit at 1.) l
This is true insofar as the hardware item for which the vendor's qualification files were reviewed was a butt splice, but it is quite wrong if it means (as Mr. Palmer appears to think it means) that Action Plan I.a.3 dealt with any and all issues relating to butt splices.
Mr.
Palmer then notes in the same sentence that the Action Plan I.a.3 Working File "had no supporting documentation in the Procedure, Testing, and Inspection working file index."
Given the nature of the issue with which this Action Plan dealt, one would expect no such documentation because no procedures, no testing and no inspections were employed in the action plan, as both the Action Plan itself and the Results Report point out.
I also note that Mr. Palmer advances no contention that the Working File for Action Plan I.a.4, which did employ procedures and inspection, is deficient.
Conclusions 15.
Based on the foregoing, on my investigation of the specific matters asserted by Mr. Palmer, and on my personal knowledge of the facts:
1)
The assertion that the CPRT iforking Files lack any and all " deficiency paper" is false.
l 2)
The assertion that the CPRT Working Files lack,any " deficiency paper" that, given the issues involved and the findings of the CPRT, one would expect.
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t to be ir. those files, is false; 3)
The assertion that the Working Files are incomplete or that they are spread among different locations is false and is based upon Mr. Palmer's manifest lack of understanding of:
i)
What an Appendix B QA/QC Program is or how it works; ii)
What the CPRT program is or how it works; iii)
What the CPRT Working Files are, what they do in fact contain, and what they are supposed to contain; iv)
What the issues are that are involved in the Action Plans the Working Files of which he was reviewing; and v)
What the Applicants' answer to Interrogatory No. 1 (of the CASE 11/15/85 Set) is and the limited relationship between the CPRT and the other programs and procedures for which CASE i.
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sought information in that interrogatory.
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_ _ _ _v_ _./_A_
W Terry Tyl r State of Texas
)
County of
)
Then personally appeared Terry G.
Tyler, before and personally known to me, who, being first duly sworn d
_/_M um a eday oath that the foregoing statements are true this a
of August, 1986.
_M
__ M ______
Notary ublic My commission expires: 3 #
[ Seal) 5
Filed:
Januar-1, 1986 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
)
Docket Nos. 50-445 TEXAS UTILITIES GENERATING
)
50-446 COMPANY et al.
)
)
(Application for an (Comanche Peak Steam Electric
)
Operating License)
Station, Units 1 and 2)
)
)
APPLICANTS' SUPPLEMENTATION TO THEIR ANSWERS TO CASE'S INTERROGATORIES TO APPLICANTS (November 15, 1985)
Without waiving their objections heretofore interposed, the Applicants hereby supplement pursuant to 10 C.F.R. 2.740(e)~their response to Interrogatory No. 1 of " CASE's Interrogatories to Applicants (November 15, 1985)" by substituting the attached table for the table that originally appears at pages 4 and 5 of the answers filed by the Applicants on December 9, 1985.
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ce e:ar trrs o cn nv p%e,eg SIGNATURES As to Answerst I, Terry G. "yler, being first duly sworn, do depose and say that I j
as 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 senisted 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 auch information, believe them to be true.
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Terry G. Tyler l
rn tio before me this
. 3, 2 E i Swp/Af-C day of De aber, 1985:
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' Notary Public
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As to Objectionet
- = TOTAL PAGE.02 *-
s As to Objections:
Thomas G. D/gnan, Jr.
R. K. Gad III Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 Counsel for the Applicants I l I
e
vs. g ergr U$TVr cWY-4LYW WJ bec4 tie. @2 Pcge 1 of 4 SYSTEM PROCEDURES DEVIATION RECORD TYPE CPRT CPRT Program Plan and:
CPP-010 Deviation Report (DR)
(QOC)
CPP-020 Out of Scope Obearvation (QOC)
DAP-2 Deficiency /
Issue Resolution (DIR)
(DAP and C/S/M TRT Issues)
Appendix E (Fed to Project NCR by
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(TRT Issues)
Design TNE-AD-5 TUGC0 Nuclear Engineering Deficiencies Design Deficiency and Errors Report (TDDR)*
(Includes Input from CPRT-DAP-DIRs and from SAFETEAM)
Engineering /
CP-EP-16.3 Deficiency Review Report Construction /
(DRR)
Procurement (Input to QC from Documentation of Engineering, any kind of incident Construction, and/or (reportable, Procurement for non-reportable or consideration for potentially reportable) potential reportability.)
(Superceded by NEO CS-1]
Significant CP-QP-16.1 Significant Deficiency Construction Analysis Report Deficiencies (SDAR)
Identified by QC or in response to DRR.
(Documented preliminary determination of potential reportability.)
f'D47 117/r9e?%
DEC 32 '55 14
'S CPET-GLEN RO PGE.23 SYSTEM PROCEDURES DEVIATION RECORD TYPE Evaluation and NEO CS-l' Potentially Reportable Reporting of
. Item / Event Items / Events under (Form Finure 7.2)
Part 21 and section (Evaluation and 50.55 (e) reporting of itene and events under Part 21 and Section 50,55 (e).
(Supercedes CP-EP-16.3, DQP-CQ-4, and CP-QP-16.1.]
Test Deficiency CP-5AP-16 Test Deficiency Report Non-conformance (TDR)
Reporting (Includes Input from CPRT Testing TRT ISARs and from SAFETEAM)
Non-conforming CP-QAP-16.1 Non-conformance Report Conditions (NCR)
(ASME-related Construction Non-conforming Conditions)
(includes input from SAFETEAM)*
CP-QP-16.0 Non-ccaformance Report (NCR)
(non-ASME related Construction Non-conforming conditione) (includes input from SAFETEAM)*
CP-QP-19.10 Construction Startup/ Turnover Surveillance Deficiency Report (DK)
STA-405 Non-conformance Report (NCR) Form No.STA-405-1 Non-conforming Conditions, any System transferred to Operations, except ASME-Program Systems)
(includes input from SAFETEAM)
DEC 30 95
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58 CPRT-GLEN PC PAGE.04 t
SYSTEM PROCEDURES DEVIATION RECORD TYPE N-61.1 Deviation Notica (DN)
Non-conforming Conditions, ASME-Program Systems transferred to operations)
(includes input ftoa SAFETEAM)
Control of STA-404 Deficiency Report (DR)
Deficiencies Form No. STA-404-1 Problem reporting STA-504 Problem Report (PR)
Form No. STAT-504-1 QA Audit DQP-AC-2 Audit report deficiency Deficiencies (Form Attachment B Deficiencies to audit report)
Significant DQP-CQ-4 Design / Construction Deficiencies Significant Deficiency Analysis Report (SDAR) (Attachment A)
Significant Deficiency identified by TUCCO QA.
Superseded by NE0 CS-1.
Non-conforming CP-QP-[all)
Inspection Report (IR)**
Construction QI-QP-(all)
Conditions CP-QAP-[all)
QI-QAP-(all)
DCP-VC-[all)
Certain contractors are performing services for Texas Utilities and operate under their own approved QA/QC programs.
These contractors aret Bahnson (HVAC), Westinghouse (Design), Grinnell Fire Protection (Design), BISCO (Environmental Seals) IMPELL (Design).
Gibbs & Hill (Design). EBASCO (Design), Chicago Bridge & Iron (Design and Construction) and Scone & Webster (Design).
Information regarding non-conforming conditions produced by these 6
contractors' programs is used to prepare a TUCCO NCR or IDDR or in some cases an SDAR directly (see nota ** below).
cost 147/rPRT5 a
DEC 30 '95 1-19 CPRr-GLEN RC pcGE.25 A
Any unsatisfactory attribute identified during a QC inspection is noted on the IR.
In some cases, the Quality Control Instructions provide the option of proceeding directly to rework the item in question or of submitting an NCR (or other second tier document) for engineering evaluation. NCR's may be dispositioned " scrap",
" rework", " repair" or "use as is".
Other second tier documents include: Component Modification Cards (CMC) Design Change Authorisation (DCA), Potentially Reportable HCW/ EVENT form.
Significant Documentation Analysis Report (SDAR), Piping Deviation Report Form (FDRF). Such second tier documents are not intended to be the initial document by which a deviation is recorded.
(In some cases, an SDAR may be generated directly to follow up a notice from a vendor of potentially reportable deficiency.)
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CERTIFICATE OF SERVICE I, Robert K. Gad III, one of the attorneys for the Applicants herein, hereby certify that on January 3, 1986, I made service of the within " Applicants' Supplementation to Their Answers to CASE's 4
Interrogatories to Applicants (November 15, 1985)," by mailing copies thereof, postage prepaid, to:
Peter B.
Bloch, Esquire Herbert Grossman Chairman Alternate Chairman Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Walter H. Jordan Mr. William L. Clements Administrative Judge Docketing & Services Branch 881 W.
Outer Drive U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C.
20555 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 i
7735 Old Georgetown Road Room 10117 Bethesda, Maryland 20814 I
l i
i 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 Dean, Division of Engineering, 1324 North Capitol Street Architecture and Technology Washington, D.C.
20002 Oklahoma State University Stillwater, Oklahoma 74078 Ms. Billie Pirner Garde Mr. Robert D. Martin Citizens Clinic Director Regional Administrator, Government Accountability Project Region IV 1901 Que Street, N.W.
U.S.
Nuclear Regulatory Commission Washington, D.C.
20009 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 Nancy Williams Mr. James E. Cummins I
Cygna Energy Services, Inc.
Resident Inspector 101 California Street Comanche Peak S.E.S.
Suite 1000 c/o U.S. Nuclear Regulatory San Francisco, California 94111 Commission P.O.
Box 38 Glen Rose, Texas 76043 l
k Robert K. Gap'III
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AUG 18 '86 13: 47 CPRT-GLEN RO PAGE,02 e
D-FAG-02 REVISION 1 POLICY ON ASSDGLY OF CPRT PROGRAN CENTRAL AND WORKING FILES
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Revision:
1 PAG-02 Pcg3 1 of 22 1
O POLICY ON ASSEMBLY OF CPRT PROGRAM CENTRAL a_d WORKING FILES n
1.0 FUltPOSE This Policy describes the basic requirements for the establishment, maintenance and disposition of the CPRT Program Central File and working files.
2.0 CENTRAL FILE The CPRT Program Director is responsible for establishment and maintenance of the CPRT Program Central File. This File shall contain the following:
I The original, approved copy of each revision of the CPRT Program Plan and appendices as submitted to the NRC.
A copy of each SRT-spproved revision of Issue-Specific Action Plans (ISAPs) and Discipline-Specific Action Plans (DSAPs) as submitted to the NRC.
The Action Plan Change Request Log and a copy of each p.
approved Action Plan Change Request.
A copy of all approved revisions of CPRT Progras Policies, Guides, and other SRT originated documents that address the conduct of CPRT activities.
A ecpy of the revision (Revision 0) of each Results Raport originally cubmitted by the Review Team Leader (RTL).
A copy of the revision (Revision 1) of each Results Report that is approved by the $1T and of any subsequent revisions.
The Action Plan working files that have been transferred to the Program Central File as outlined in Section 4.0 of this Guide.
A copy of each report from the overview Quality Team on CPRT activities.
A copy of all SRT meeting minutes.
3.0 WRKING FILES O
Each Review Team shall asintain a working file for each Action Plan for which it is responsible. As documents are collected during the execution of an Action Plan, they should be placed in the working
6-LNv FWGLGTs e R: vision:
1 PAG-02 Page 2 of 22 O
POLICT ON ASSEMBLY OF CPRT PROGRAM CENTRAL and WORKINC FILES
~
(Cont'd) 3.0 WORKING TILES (Cont'd) file. The werking file will be maintained at the site where the work is being performed. If the work is being done concurrently at more then one location, esparate files may be maintained. The separate files need not be complete in themselves; however, upon completion of all Action Flan activities, they shall be combined to form one complete file.
It is recognized that each working file is assembled and organized in stages as the Action Flan activities are coupleted and relevant documentation is collected. Accordingly, during the in-process stages of the Action Flan, the requirements delineated below shall be treated as guidelines to facilitate organisation and development of the working file, recognizing that full compliance will not be possible until all of the Action Plan activities have been completed. After all Action ytan activities have been completed, and before the Results Report is submitted to the SRT for review, the Action Flan Issus Coordinator shall assure that the working fils seats the criteria herein and call for a file review.
C The following paragraphe provide criteria for the format and contents of working files that shall be met before the Results Report is submitted to the SRT for review.
3.1 Each working file shall have a file index.
(See Section 5.0) 3.2 Each file or sub-file shall have a file content los listing all documents or document packages therein. Each listed doctusent or document package shall be contained within the file, except that bulky documents may be maintained in a separate location if appropriate reference thereto is made within the working file. See section 5.0 for further discu sion of file content logs.
3.3 Each document or document package shall display the file number and content log sequential number. When a document or document package containe more than one page, each page shall contain an indication of its sequential location within the document or document package. This indication may already be evident, by the page numbering of the document for example.
If not, the pages may be numbered by hand (e.g.,1 of 10, 2 of 10,etc.).
A cover sheet or package "index" may also be used to indicate contents and sequential order. In any case, the arrangement shall allow for proper reordering of pages should they become mixed during reproduction, file transeittal. or O
other use.
3.4 A copy of each approved revision of the Action Plan shall be included in the working file.
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1 I
PAG-02 Page 3 of 22 O
POLICY ON ASSEMBLY OF CPRT PROGRAM CENTRAL and WORKING PILES (Cont'd) 3.0 WORKING FILES (Cont'd)
The working file shall contain a list of all third-party 3.5 personnel implementing the Action Plan, i U uding inspectors, engineers, document reviewers, safety-eigttificance evaluators, helpers, etc., and excluding only clerical help. Participants from other Review Teams (for example, safety-eignificance evaluators of a civil / structural issue) are to be included.
Also included shall be any C?gES Project inspectors.
~
Third-party personnel records for each Action Plan participant shall be maintained, either by retention of copies in each applicable working file, or by reference to their location within the applicable Review Team's files. If the latter option is chosen, all such personnel records for the Review Team shall be transferred to the Central file upon completion of the Review Team's activities. Third-party personnel records shall contain the following, as a minimust Resume of qualifications f
r Completed objectivity questionnaire (Attachment 6.1)
For the Design Adequacy, Civil, Structural, and Mechanical Review Team personnel, a personnel meno or
" initial roster", as described by DAP-15, signed by the Review Team Leader. For other personnel, a completed objectivity evaluation (Attachment 6.2), signed by the responsible Review Team Leader.
Record of training in the provisions of the Program Plan, as determined by the responsible RTL.
Where applicable, records of additional training to any Action Plan procedures and/or CPSES QA program procedures used by inspectors, testers, or records reviewers.
3.6 The working file shall contain copies of any CPRT procedures, instructions or checklists used for engineering analysis, inspection, testing, records review, or other investigations.
(It is not necessary to include procedural documents with general applicability to an entire Review Team, or to CPRT activities as a whole, such as instructions for writing Deviation Reports (DRs), procedures regarding third-party training, etc.).
AOG 18 8 6' 13 ': d 9
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PAG-02 R2 vision:
1 Page 4 of 22 O
POLICY ON ASSEMBLY OF CPRT PROGRAM CENTRAL and WORKING FILES (Cont' d) 3.0 WORKING FILES (Cont'd) 3.7 The working file must contain documentation detailing the selection of samples, if a sampling process was used for the Action Plan. Sufficient information shall be provided regarding population definition, random or biased sampling, I
derivation of samples etc., as applicable, to allow for independent verification of.these activities.
3.8 A copy of records or documents resulting from the specific engineering analyses, inspections, testing, records reviews, or other investigations shall be provided.
Summaries of the results of these investigations shall also be provided to j'
support any statistical or quantitative statements made.
3.9 All other associated records required by the Program Plan, the Action Plan, CPRT procedures, etc., to implement the Action Plan shall be included. As applicable, these associated recorde shall include:
I I
Any deviations, deficiencies, and adverse trends and l
p applicable safety significance evaluations.
All calculations.
All evaluations, including those for root cause and generfe implications.
Any issues, observations, or findings being transferred or communicated to another Action Plan.
3.10 Controlled CPSES Project documents used in the course of performing calculations, analyses, evaluations and other activities related to Action Plan completion and Results Report preparation shall be clearly referenced in the working file.
It is the responsibility of the cognisant Review Team Leader to assure that the ravision of each controlled document used was appropriate. Normally, this would mean the revision current at the time of use. Occasionally, however, specific Action Plan objectives may dictate the use of a historic revision.
To discourage unnecessary bulk in the working files, retention of documents available through the Project document control C
systen should be minimized. For example, specifications, procedures, drawings, etc., would ordinarily be referenced, rather than included in the file. Occasionally, however, the l
l
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1 PAG-02 Page 5 of 22 POLICT ON ASSEMBLY OF CPRT PROGRAM CENTRAL and WORKING FILES (Cont'd) 3.0 WORKING FILES (Cont'd)
RTL may elect to include copies of project documents in the working file when he feels that the benefits for doing so outweigh considerations for bulk, reproduction effort, etc..
" Marked-up" project documents shall be retained if they contain annotations which are necessary to reconstruct a Results Report activity.
For any document incluJed in the file Attachment 6.3 may be used to provide name, identification, and revision status if this is not evident from the document itself.
f 3.11 All documents included in the working file shall have a Furthermore, specific applicability to the Results Report.
each action required by the Action Plan and each conclusion j
stated in the Results Report must be substantiated by backup documentation. The following requirements address these general principles.
O Each document in the working file sust have a specific a.
bearing upon one or more section of the Results Report.
i If this connection cannot be established, the document chould not be included in the working file. The relationship between the. document and the RasultsThis Report must be evident to an outside observer.
relationship might be apparent, for example, from the docussot's title or general content. If the applicability of the document to the Results Report would be unclear to an outside observer, then a cover i
j sheet similar to Attachment 6.4 sust be completed and filed with the document. This cover sheet may be used for an individual document, or for a group of documents which has a common applicability to the Results Report, b.
The completion of each action required by the current revision of the Action Plan mist be substancia:ed by documentation within the working files. For example, if testing was required, the working files suet contain reports relevant to the testing. If an evaluation of In the reports is required, it must also be present.
some cases (as, for example, the evaluation of test reports) the required action say appear in the Rasults Report itself, without further documentation in the files. To the extent that the Results Report solely O
and sufficiently substantiates performance of the required action, this say be considered acceptable, since the.Results Report itself is a part of the file.
suw u-r w e s erest4 wmrewaw-wo rans ;we Revisien:
1 PAG-02 Pcg3 6 of 22
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POLICY ON AS$ENELY OF CPRT PROGRAM CENTRAL and WORKING FILES (Cont'd) 3.0 WORKING TILES (Cont'd)
Substantiating documentation need only be kept if it is necessary to establish completion of an action. For example, a CPSES traveller may have been issued te gain access for inspection. Since the corresponding inspection report indicates successful completion of the inspection, the traveller need not be kept merely to establish that access was gained. Likavise, some welding inspections require preparation of the welds (e.g., paint removal). This preparation may be documented on a CPSES traveller. If this is the only evidence that such preparation was indeed performed, then the traveller should be kept in the working file. '
If, however, the inspection reports document this preparation, or if the preparation was a precedural then the prerequisite to signing the inspection report, CPSES traveller should not be kept. A document should only be maintained in the working file if it is necessary to substantiate an action or conclusion in the Results Report.
ps Statements of fact unde in the Results Report must be l
c.
amenable to verification. To this end, a statement may i
be attributed to materisi contained in controlled Project documents. Alternatively, the statement may be backed up by substantiating material contained in the working file. In the latter case, the portion of the file containing substantiating material should be l
evident to an outside reviewer. If it is not, the Resulte Report should provide a reference to the specific working file location of the substantiating material.
Further direction regarding statements contained in the Results Report is provided below.
t l
l Quantification Statements - Numerical or statistical statements regarding results of engineering analyses, inspections, tests, recorde reviews or other investigative actions must be verifiable by working file documentation.
Preferably, quantification of results would be documented on susmary sheets, which in turn would be supported by the records of individual inspectione, tests, etc..
In any case, file documentation must provide a clear basis for
/
numerical results reported in the Results Report.
.-,,,------,------_.--,-,,-,,-w_-
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PAG-02 Rsvisien:
1 Pag 3 7 of 22 O
POLICY ON ASSEMBLY OF CPRT PROGRAM CENTRAL and WORKINC FILES (Cont' d) 3.0 WORKING FILES (Cont'd)
Results of Analyses of Evaluations - Results Reports may contain summaries of analvees or evaluations performed. These summaries must be substantiated by hard-copy analyses or evaluations contained in the working files. In turn, these analyses or evaluations must be based upon other data in the working file and/or by reference to data contained in controlled project documents.
Personnel Interviews - Assertions in the Results Report resulting from interviews of personnel must be backed up by a documented record of interviews, telephone conversations, letters, etc..
Preferably, the interviewer should indicate concurrence with this record by signature or initials. When possible, recorded statements should be verified by reference to objective evidence.
p ~s Conclusion - Conclusions within the Results Report 4
must be supported by material in the working file and/or by other sections of the Resulta Report.
l Recossendations regarding action to prevent l
occurrence in the future need not necessarily be I
substantiated by working file documentation.
3.12 Occasionally an issue will be raised in one Results Report and referred for resolution to another Rasults Report. These issues are noted during Results Report l
l review and tracked by the Results Report and Working File Review Committee. Any such issue must be resolved i
by the Results Report and working file to which it has been transferred.
3.13 External Source issues ars tracked by two systems: onc for ISAPs and one for DSAPs. These systems relate each external source issue to Action Plens. The Action Plan Results Report and working file sust address the external source issues assigned to it.
1 I
AUG ' I E ~' '~8 6 13:51 CPRT-GLEN R O'
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1 FAG-02 Page 8 of 22 l
O POLICT ON ASSEMBLY OF CPRT PROGRAM CENTRAL and WORKING FILES (Cont'd) 4.0 TRANSFER OF A WORKING FILE TO THE CENTRAL FILE Prior to submittal of an Action Plan Results Report to the SRT, at a time determined by the responsible Issus Coordinator, the Results Report and Working File Review Cosaittee will initiate an independent review of the file to ensure that it complies with the requirements of this Guide and the Program Plan. Attachment 6.5 of this Guide provides a checklist which may be used for this review.
General policy for this review is provided in Attachment 4 of l
Appendix G of the Program Plan. The review shall be completed and any discrepancies corrected or tabled for SRT discussion prior to distribution of the respective Results Report to the SRT.
After an Action Plan Results Report has been approved by the SRT, a copy of the revision of the Results Report initially submitted by the RTL and a copy of the SRT-approved revision of the Results l
Report shall be placed in the working file. The respective working i
l file shall then be turned over to the CPRT Program Director for transfer to the Central File and subsequent retention, maintenance, and distribution as appropriate.
p 5.0 FILE NUMBERS. FILE INDEX, AND FILE CONTENT LOG l
Each fils (both the CPRT Central file and working file) should have For a primary file nuakar and an optional subfile identifier.
working files a file prefix identical to the Action Flan number, should be used. The Central File and the working files shall have
[
file indexes. Examples of Central File primary and subfile numbers organiend into a file index are shown in Attachasat 6.6.
Examples of working file primary and subfile numbers organized into a file index are shown in Attachment 6.7.
Other breakdowns say be used as long as they provide logical separations of the documents for the given Action Plans. Each primary or subfile shown on the file indez must contain a file content log. Attachment 6.8 is an example of such a file content 103 The file content los sheet must contain a sequential number for each document or group of documents and a brief description of the ites. Where applicable, dravias numbers, inspection report numbers, etc. should be used in the file content los to adequately identify the ites. The file number and content los sequential number are to be placed on the first page of each doeunent or group of documents contained in the files. Attachment 6.9 provides example formats for these numbers.
e
,-y-n,---
e---
n
,,e-,---m---------en,--.,n,,,--mven--- - - - - - - - -. - - - - - -
- - - - - ~
PAG-02 Revision [
1 Pcge 9 of 22
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C' POLICY ON ASSEMBLY OF CPRT PROCKAM CENTRAL and WORKING FILES (Cont'd) 6.0 ATTAC10ENTS 6.1 CPRT Objectivity Questionnaire 6.2 CPRT Objectivity Ivaluation 6.3 Example Document Excerpt Policy Sheet 6.4 Example Document Use coding Sheet 6.5 Working yile Review Checklist 6.6 Ezasple File Policy for Central file 6.7 Example File Policy for Working File 6.8 Example File Content Los 6.9 Format for Document Identification D
l l
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f I
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1 PAG-02 Page 10 of 22 POLICY ON ASSEMBLY OF p.
CPRT PROG 8 TAM CENTRAL and WORKI_ G FILES N
(Cont' d).1 CPRT Objectivity Questionnaire 1.
Name _
2.
Position on CPRT 3.
Name of current employer 4.
Data this questionnaire is completed Do you hold any stock or other securities of Texas Utilities Company?
l 5.
Have you ever been a director, officer, or employee of Texas Utilities Company 6.
or any of its subsidiaries *?
Have you ever entered into a contract, whether oral or written, with Texas I
7.
Utilities Company or any of its subsidiaries or with another person, firm, or corporation who has acted as a contractor for the Comanche Peak project other l
than a contract releting to your involvea6nt in the current CPRT program?
Would the answer to any of the above questions be "yes" if answered by any 8.
member of your immediate family (father, mother, spouse, son, or daughter)?
Have you been promised any additional compensation or reward or anything of 9.
value by anyone, contingent upon the position you take on any issue being i
considered by you in the CPRT program? __
i Do you know of any reason, whether inquired about in this questionnaire or not, 10.
which would affeet your ability to be completely objective in performing any of the tasks assigned to you under the Comanche Peak CPRT program? _
Would the answer to any of the above questions be "yes" if answered by your 11.
current employert If the answer to any one or nors of the above questions was "yes" then please 12.
fully explain each such "yes" answer, by number, on the reverse side of this Attach additional sheets to provide further information, if questionnaire.
necessary.
Signature Subsidiaries of Texas Utilities Company are Texas Utilities Electric Company, p
Texas Power & Light Company. Texas Eleqtric Service which has four divisions:
i Company, Dallas Power & Light Company, and Texas Utilities Generating Company;
)
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PAG-02 Pese 11 of 22 POLICY ON ASSEMBLY OF CPRT PROGRAM CENTRAL and WORKING FILES (Cont'd)
Attachbant 6.2 CPRT Objectivity Evaluation NAME Questions with YES answere Does the YES respones(s) constitute a violation of CFRT Objectivity Criteria?
YE5
, NO EVALUATION D
RECOMMIND
, NOT RECOMMEND
, FOR APPROVAL Review Team Leader l
l
., - - _....., -, -.. _ -,. -. - - -. _ ~,, - - - - - _ _ - - -, -,, ~. -. -., - - - - -, -,,,. _ - -
AUG 10 '86 13:52 CPRT-GLEN RO PAGE.11 Revisions 1
PAG-02 Page 12 of 22
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POLICY ON ASSEMBLY OF CPRT PROGRAM CENTRAL and WORKING FILES (Cont'd).3 Example Document Excerpt Policy Sheet The attached is an excerpt from the following documener Titles Document Number:
Revision:
Date of revisica Source of document (DCC, CPAT Library, etc.):
Date obtained from source: __
The above is the latest revision of the controlled document D
The above is not the most recent revision of the controlled docusent. However, it is the appropriate revision for analysing the particular CPSES feature (s) for which it was used.
Pages or sheet numbers contained in the excerpts
,-,-y
-y
,--m m - -,-,- -
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AUG 18 '86 13:53 CPRT-GLEN RO PAGP 12 c.
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1 PAG-02 Page 13 of 22 C-POLICT ON ASSEMBLY OF CPRT PROGRAM CENTRAL and WORKING FILES (Cont' d).4 Example Document Use coding Sheet This sheet or its equivalent can be used to indicate how a document or group of documents pertain to the respective Action Plan, if the relationship is not otherwise obvious.
ACTION PLAN NUMBER:
Applicable Section:
The attached document (s) were used in completing the above Action Plan in the following way:
Provided engineering or construction details used in the implementation of the Action Plan.
Examples: Controlled drawings, specifications, or procedures Served as randomly selected samples used to determine the p
adequacy of the design, construction or conformance to a procedure.
Examples: Construction records, as-built drawings, design documents Provided the basis against which the design er construction was inspected or tested.
Examples: Design criteria (PSAR), design specifications, design drawings, design or construction procedures, codes or standards (ASTM, ACI, IEEE, etc.)
Document the completion of an inspection or test conducted in conformance with the Action Plan.
Examplest CPRT QA/QC inspection reports, independent testing, contractor test records Document calculations perforand as part of the Action Plan to check or verify the adequacy of the design or to check existing CPSES calculations.
F.xamplest Calculations performed by CPRT personnel Used to establish the population from which random samples were selected.
Examplest Lists of documents or CPSES elements (conduits, concrete placements, pipe hangers, etc.) which O
comprise the population.
Document the consunication among the participants in the Action Plan.
k Exampleet Letters Memoranda. Telephone notes, Meeting notes
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PAG-02 Pcg2 14 of 22 O
POLICY ON ASSEMBLT OF CPRT PROGRAM CENTRAL and WORKING FILES _
(Cont'd).4 (Cont'd)
Summarize the results of the inspections and tests conducted in conformance with the Action Plan.
Examples: Lists that correlate data from several sources Provide as-built information analysed for conformance with design documents.
Examples: As-built drawings or sketches developed by the CPSES project team, photographs or video tapes Other:
C' i
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I C
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AdG 18 '85 13:53
'CPRT-GLEN RO ~
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1 PAG-02 Pcg3 15 of 22 POLICY ON ASSIMBLY OF
'/~'
CPRT PROGRAM CENTRAL and WORKING FILES (Cont'd).5 Working File Review Checklist ISAP REVIEWER /DATE R Setisfactory Review completed M further Action Required COMPLETE FURTRER CRITERION ACTION REQUIRED 1.
A file index is present.
2.
Each file or sub-file has a file content log.
Verify by spot-checking that all documente listed in the los are present.
3.
Verify by spot-checking that each document contains a file index number. Where documente are comprised of many pages, only the front page or cover sheet need be marked with the file index number.
4.
Copies of all approved revisions of the Action Plan are included.
8 i
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--.--.-w.,--,--.,-.-..---,-----,,.w.
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PAG-02 Rsvision:
1 Page 16 of 22
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POLICY ON ASSEMBLY OF CPRT PROGRAM CENTRAL and WORKING FILES (Cont'd).5 l
(Cont'd)
COMPLETE FURTHER CRITERION ACTION REQUIRED
)
5.
The file contains a list of all non-clerical third-party Action Plan participants, including inspectors, engineers, document reviewers, -
safety significance evaluators, helpers, etc.,
as applicable. This list includes any CPSES inspector used.
Also, verify the following for each third-party Action Plan participant by review of the personnel records. Note: These records may either be contained in the working files, or f 's that file may reference the file location of e
the records in the Review Tess's files.
I l
Resume showing qualifications.
Completed objectivity questionnaire.
l Personnel meno or " initial roster" per DAP-15, or completed objectivity evaluation, as applicable.
Records of training to the Program Plan.
Additional training to specific procedures, if applicable.
If CPSES personnel were used to perform inspectione, verify the following Qualifications.
Lack of personal involvement in the original inspections.
,.-n-
,,,,,,,,,.,--,------,---.n,.
,.,,-,-,_w
,,.-..--,,--.-.-,-.,.-,-,-----m,-m7
AUG 18 '96 13 54 CPRT-GLEN RO PAGE.15 PAG-02 Revision:
1 Page 17 of 22 POLICT ON ASSEMBLY OF CPRT PROGRAM CENTRAL and WORKING FILES (Cont'd)
<.5 (Cont'd)
COMPLETE FURTHER CRITERION ACTION REQUIRED 6.
Copies of procedures or checklists used for engineering analysis, inspection, testing, records review, or other investigations are included.
7.
Documents are present which detail the sample selection process, if sampling was used. Spot check the semple selection sechanics, r
C 8.
Documentation resulting from engineering l
analysis, inspection, testing, records review or other investigations is included.
1 9.
All applicable deviations, deficiencies and adverse trends and all calculations and evaluations, including evaluations of root cause, generic implications, and safety significance are included.
- 10. Project documents used to support calculations, l.
evaluations, analyses, etc. are clearly referenced, or included in the file, as appropriate.
11a. Each document in the working file has a specific relationship with the activities involved in completing the Action Plan, and this relationship is (or has been made) obvious.
C
=,-.,--~--,,.-,m,
,,ew
,,.,-,,,.,,-a,,,,
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,,,.,,,,,_ne,
--.-_...-._.,,--..-m
--.n-,,,., -
-,4
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FAG-02 Prge 18 of 22 POLICT ON ASSEMBLY OF CPRT PROGRAM CYNTRAL and WORKING FILES (Cont'd).5 (Cont'd)
COMPLETE FURTHER CRITERION ACTION REQUIRED e
i' lib. The working file contains documentation to substantista the performance of investigative actions described in the current revision of the Action Plan.
11c. Documentation relevant to each conciveion reached in the Results Report is included.
Determine by spot-checking that the back-up documents substantiate the conclusions drawn.
12.
Issues transferred from another Results Report I are addressed within the Results Report and/or l working file. Also, verify that issues being l
transferred from the Results Report are l
recorded for tracking by the Results Report and!
Working File Review Committee.
- 13. External Source issues related to the Results report are resolved within the Results Report and working file. 50ft: These issues may be datermined by asking the administrators of the ISAF or DSAF external source issues matrix, as '
applicable.
Remarks:
~'ea
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R:visient L
PAG-02 Pass 19 of 22 f\\
POLICY ON ASSEMBLY OF CPRT PROGRAM CENTRAL and WRKING FILES (Cont'd).6 Example File Policy For Central File CENTRAL FILI File # Subfile #
Content 1
Original, approved copy of the CPRT Program Plan and Action Plans as filed with NRC 2
Correspondence to NRC (re: TRT/CPRT) 3 Correspondence from NRC (re: TRT/CPRT) 4 CPRT Policies and Guides Rasvaes and objectivity questionnaires for l
5 SRT and Review Tess Leaders 6
Meeting Minutes and Transcripts P*g 6A SRT Nestings 6B Meetings with NRC (transcripts) 1 6C Other Meetings 7
Action Plan Results Reports Other Reports and Evaluations 8
9 Miscellaneous Closed Working Piles Transferred to Central l
l 10 File l
i r--,e--
,,,---,.-----n---------,.,,r,--,
---,--,-,,,a--,,na
-.-,,,-w,,,,,,.----,
--,m-
AUG 18 96 14iOS CPRT-GLEN R0 PAGE.03 a
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PAG-02 Page 20 of 22 POLICY ON ASSEMBLY OF CPRT PROGRAM CENTRAL and WORKING TILES (Cont'd).7 Example File Policy For Working File WomtING FILE Primary Prefix File # Subfile #_
Content I.a.1 1
Copies of all SET-spyroved revisions of Action Plan I.a.1 2
Personnel data I.a.1 3
CPRT Procedures 3A CPRT Engineering Procedures 35 CPRT Inspection Procedures 3C CPRT Testing Procedures h
I.a.1 4
Sampling Data 4A Population List 4B Sample Derivation and List i
Raoults Documentation (inspection, records I.a.1 5
review, testing, and engineering results) organized by task or by Action Pisa phase.
I.a.1 6
Discrepancy Docuneatation 6A DRs, DIRs, etc.
6B Safety Significance Evaluations 6C Trend Analyses 6D Root Cause Analysis 6E Generic Implications Evaluation I.a.1 7
Results Report I.a.1 b
Miscellaneous
,e--------,,---,,,r,e-
,mr-,a
,,--,r-,-
w-w
,,--w---.,wene w>w-,,,-,e,-----m-
--w-,n,e.--e-me--we-wwr-
r AUG 16 '66 14: 09 CPRT-GLEN RO PAGE.04 R0 vision:
1 PAG-02 Page 21 of 22 FOLICY ON ASSEMBLY OF CFRT PROGRAM CENTRAL and WOREING FILES i
(Cont'd).8 Example File content Log FILE CONTENT LOG PRETIK:
FILE:
SUBFILE:
c.
,I Description Log Number 1
=
2 3
4 1
I 1
AUG 18 '86 14: 10 CPRT-GLEN RO PAGE.05
?
o Revisions 1
PAG-02 Page 22 of 22 o
POLICY ON ASSEMBLY OF CPRT PROGRAM CENTRAL and WORKING FILES (Cont'd).9 Format For Document Identification Numbers CENTRAL FILE DOCUMENTS N A. nnn sequential number
~~
(from file content log) optional alphabetic character for subfile identification file number (from file index)
Exaanles:
1.003 4.017 h
6A.027 6C.153 WORKING FILE DOCUMENTS f
X.x._n - N A. g n sequential ovaber (from file content log)
~
l optional siphabetic character for subfile identification file number (from file index) file prefix (identical i
to TRT issue number)
Examples:
1.003 I.a.1 1.c
- 4A.017 8.001 II.b III.e.2 - 45.003
,_,,---___,____.___._m.,__.r_.,,,
pggOttCEN "DOCKEILD USNRC CERTIFICATE OF SERVICE 16 gy -8 R2 '41 I, William S.
Eggeling, one of the attorney fRf 0phlugpplicants 198,OCKETING & SE8vlCf.
I s&EEHservice of herein, hereby certify that on September 2, the within document 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 Mr. William L.
Clements Administrative Judge Docketing & Services Branch 881 W.
Outer Drive U.S.
Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C.
20555 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
P 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 Commissi<
Austin, Texas 78711 Washington, D.C.
20555 Anthony Roisman, Esquire Nancy Williams Executive Director Cygna Energy Services, Inc.
Trial Lawyers for Public Justice 101 California Street 2000 P Street, N.W.,
Suite 611 Suite 1000 Washington, D.C.
20036 San Francisco, California 94111 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 Citizens Clinic Director Regional Adminictrator, Government Accountability Project Region IV 1901 Que Street, N.W.
U.S.
Nuclear Regulatory Commissi Washington, D.C.
20009 Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Elizabeth B.
Johnson Geary S.
Mizuno, Esquire Administrative Judge offdce of the Executive Oak Ridge National Laboratory Lepal Director P.O. Box X, Building 3500 U.S. Nuclear Regulatory Commissi Oak Ridge, Tennessee 37830 Maryland National Bank Bldg.
Room 10105 4
7735 Old Georgetown Road Bethesda, Maryland 20814
[
William S.
Ngg ing ?
l l
l i
i