ML20214T688
| ML20214T688 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/26/1986 |
| From: | Gad R, Tyler T TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | Citizens Association for Sound Energy |
| References | |
| CON-#386-898 OL, NUDOCS 8609300377 | |
| Download: ML20214T688 (26) | |
Text
Filed:
S ptember 26, 1986.
v QRQ sne wm enocwoNDENCQ UNITED STATES OF AMERICA COLKETED USNRC NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD OFFic De 6 is, y 00CKEip:L '., via chi. hut
)
In the Matter of
)
)
Docket Nos. 5 0 -4 4 5 -d
TEXAS UTILITIES ELECTRIC
)
5 0-4 4 6 -d 4~
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. 1)
Pursuant to 10 C.F.R. sec. 2.740 11, the Applicants hereby submit their responses to CASE's "CPRT Discovery -
1," served by ordinary mail on September 11, 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," inasmuch as the same are contrary to the Rules of Practice.
Interrocatories First Unnumbered Interrocatorv "For each of the following questions [,] identify name, job description and employer of each person who has the authority to decide what each of these terms and phrases 03b 3
0
()
mean in practice and answer the question in light of the meaning given to the phrase or term in practice.
Where there are different meanings or interpretations given by different persons [,] provide each separate. meaning or interpretation."
Obiection (Partial):
To the extent, if any, that this interrogatory calls for information regarding the implementation of the CPRT Program Plan, the Applicants object to it on the ground that it is beyond the scope of the CPRT discovery authorized by the Board in its rulings on August 10 and 19, 1986.
i Answer:
The CPRT Senior Review Team ("SRT") has the authority
. to interpret, in the event that interpretation is required, the terms contained in the CPRT Program Plan.
The identity and employers of the members of the SRT are well known to CASE, and are contained in the Program Plan at 19 (section VIII.B.1).
The job description of each, insofar as it is relevant to CPRT, is to discharge the functions of the SRT.
Second Unnumbered Interroaatorv "For each answer [,] provide at least two examples from the actual work of the CPRT with references to documents, procedures and results report which illustrates the application of the definition in practice.
If the term or j
phrase has a different meaning in different contexts, provide at least one example for each different context of the application of the term or phrase."
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'4 1
Obiection:
The Applicants object to this interrogatory on the ground that it calls for information regarding the implementation of the CPRT Program Plan, which is beyond the scope of the CPRT discovery authorized by the Board in its rulings on August 18 and 19, 1986.
Interroaatory No. 1:
" Explain the difference between the phrases ' quality of construction concerns' and ' construction QA/QC concern.'
(Pg. 1).
"a.
Identify the person or persons who answered this question, include the name, position, or title, and organization.
"b.
If the person who answered this question did not rely on first-hand, personal knowledge [,)
provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date, and location which were used or examined to answer the question."
-Answer:
As set forth in Appendix B to the Program Plan, the terms refer, respectively, to "the adequacy of the constructed safety-related hardware" and "the adequacy of the CPSES construction QA/QC program."
The former refers 4
to the extent to which the hardware, as constructed, inspected and tested (if tested) conforms to the drawings,
-3
i specifications and other instructions.
The latter refers to the programs in place for the inspection of the constructed hardware.
This answer is provided by the SRT, acting collectively and collegially.
The answer, not calling for a matter of fact, is not based upon the personal knowledge of anyone.
No document was used other than the Program Plan.
Interroaatory No. 2:
" Explain the term ' third-party expert' as used in the CPRT [ Program Plan)."
(Pg. 2).
"a.
Identify the person or persons who answered this question, include the name, position, or title, and organization.
"b.
If the person who answered this question did not rely on first-hand, personal knowledge [,]
provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date, and location which were used or examined to answer the question."
Answer:
In the historical statement, the phrase " third-party experts" on line 2 of page 2 referred to persons retained by TUGCO, to advise TUGCO on certain matters.
The specific individuals referred to were Messrs.
John Guibert and Frank Dougherty of TERA.
.This answer is provided by the SRT, acting collectively and collegially.
The answer, insofar as it
{
refers to the intention of the drafters of the Program
'l
(
Plan, is based upon the personal knowledge of members of the SRT.
No document was used other than the Program Plan.
1 Interroaatory No. 3:
l l
" Explain the phrase ' safety-significant deficiency' in l
reference to those components or processes which were classified as ' safety-significant' at the time the work was done (1 3.[,) fuel-pool liners, paint 'oatings), (pg. 2) c "a.
Identify the person or persons who answered this question, include the name, position, or title, and organization.
"b.
If the person who answered this question did l
not rely on first-hand, personal knowledge [,]
provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date, and location which were used or examined to answer the question."
Answer:
The term " safety significant" has the meaning established in the Program Plan at 7 & n.
Only systems, structures or components that.are safety-related are capable of containing safety significant deficiencies.
A system, structure or component is determined by SRT to be safety related if it is relied upon by the CPSES design to prevent or. mitigate the consequences of a postulated -
4 l
accident that could cause undue risk to the health of safety of the public.
The definition is applied to the function and safety-related nature of the system, structure or component, if any, at the time of the assessments by CPRT.
Neither the fuel pool liner nor coatings are safety-related at CPSES.
Therefore, no deviation (as defined in the Program Plan) with respect to either could constitute a hardware deficiency (as defined in the Program Plan).
This answer is provided by the SRT, acting j
collectively and collegially.
The answer, not calling for a matter of fact, is not based upon the personal knowledge of anyone.
No document was used other than the Program Plan and the FSAR.
Interrocatorv No. 4:
" Explain what is meant when the phrase ' determine the nature of' is used.
(page 2)
"a.
Identify the person or persons who answered this question, include the name, position, or title, 2nd organization.
"b.
If the person who answered this question did not rely on first-hand, personal knowledge [,]
provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date, and location which were used or examined to answer the question."
i --
4 Answer:
This phrase was not used by the SRT with any specialized meaning.
This answer is provided by the SRT,. acting collectively and collegially.
The answer, not calling for a matter of fact, is not based upon the personal knowledge of anyone.
No document was used other than the Program Plan.
Interrocatorv No. 5:
" Explain the CPRT's definition of ' root cause'. (pg.
2)
"a.
Identify the person or persons who answered this question, include the name, position, or title, and organization.
"b.
If the person who answered this question did not rely on first-hand, personal knowledge [,]
provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date, and location which were used or examined to answer the question."
Answer:
" Root caus?.3 is explained in the footnote on page 2.
In the absence of a more directed question, we cannot determine what additional information is being sought.
This answer is provided by the SRT, acting collectively and collegially.
The answer, not callir., for :
a matter of fact, is not based upon the personal knowledge of anyone.
No document was used other than the Program Plan.
Interroaatorv No. 6:
" Explain the term ' adverse trend of non-safety significant deviations or design observations.' (pg. 2)
"a.
Identify the person or persons who answered this question, include the name, position, or title, and organization.
"b.
If the person who answered this question did not rely on first-hand, personal knowledge [,].
provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date, and location which were used or examined to answer the question."
Answer:
A trend is a set of related observations and/or deviations having attributes that reflect a discernible commonality.
Examples of possible commonalities include the individual, group of individuals or organizations performing the safety-related activities and the program requirements, procedures or controls governing the performance of the safety-related activity.
A trend is considered by the SRT to be adverse if it is determined that the identified pattern or commonality is likely to have resulted in the occurrence of an undetected deficiency !
in the affected area, population or stratum.
This answer is provided by the SRT, acting collectively and collegially.
The answer, not calling for a matter of fact, is not based upon the personal knowledge of anyone.
No document was used other than the Program Plan.
Interroaatory No. 7:
" Explain, in detail with examples, the process of analyzing the generic implications of each root cause.
(pg.
2)
"a.
Identify the person or persons who answered this question, include the name, position, or title, and organization.
"b.
If the person who answered this question did not rely on first-hand, personal knowledge [,]
provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date, and location which were used or examined to answer the question."
Answer:
Once a root cause has been established, the nature of the root cause itself suggests the potential generic implications.
" Analysis" of potential generic implications means investigation, by some appropriate means, of the existence of the generic implication, or by expanded re-inspections such that, if existent, potential generic implications will be captured.
Appropriate means of _.
4 investigation for-the existence of potential generic implications include expanded sampling under Appendix D, the Action Plan VII.c re-inspections and the Design Adequacy Program self-initiated reviews.
This answer is provided by the SRT, acting i
collectively and collegially.
The answer, not calling for j
a matter of fact, is not based upon the personal knowledge l
of anyone.
No document was used other than the Program i
Plan.
l Interroaatorv No. 8:
i
" Explain the term ' single definitive root cause.' (pg.
2)
"a.
Identify the person or persons who answered this question, include the name. position, or title, and organization.
i "b.
If the person who answered this question did not rely on first-hand, personal knowledge [,]
provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date, and location which were used or examined to answer the question."
i Answer:
The quoted phrase was not employed by the SRT with any specialized meaning.
g This answer is provided by the SRT, acting collectively and collegially.
The answer, not calling for I
a matter of fact, is not based upon the personal-knowledge of anyone.
No document was used other than the Program Plan.
Interroaatorv No. 9:
" Explain the difference in the two phrase. in questions 5 and 8 supra.
"a.
Identify the person or persons who answered this question, include the name, position, or title, and organization.
i "b.
If the person who answered this question did not rely on first-hand, personal knowledge [,)
provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date, 1
and location which were used or examined to answer the question."
Answer:
None.
This answer is provided by the SRT, acting collectively and collegially.
The answer, not calling for a matter of fact, is not based upon the personal knowledge of anyone.
No document was used other than the Program Plan.
.Interrocatorv No. 10:
" Explain the difference between the ' root cause' and
' probable cause'. (page 2).
4 "a.
Identify'the person or persons who answered this question, include the name, position, or
{
title, and organization. i l
.... - - - - - -. - - - - - - - - - -. - - - - - - - - - ~ -
- - - - - - - ~ ~
"b.
If the person who answered this question did not rely on first-hand, personal knowledge [,]
provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date, and location which were used or examined to answer the question."
Answer:
" Probable cause" is used in the sense of that which might, upon further analysis or investigation, be determined to be (or not to be) the root cause of a deficiency or adverse trend of deviations or observations.
This answer is provided by the SRT, acting collectively and collegially.
The answer, not calling for a matter of fact, is not based upon the personal knowledge of anyone.
No document was used other than the Program plan.
Interrocatory No. 11:
" Explain the phrase '(t]o investigate on a proactive basis...".
(page 3).
"a.
Identify the person or persons who answered this question, include the name, position, or i
title, and organization.
"b.
If the person who answered this question did not rely on first-hand, personal knowledge [,]
provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date,._
and location which were used or examined to answer the question."
Answer:
This phrase is not used by the SRT with any specialized meaning.
This answer is provided by the SRT, acting collectively and collegially.
The answer, not calling for a matter of fact, is not based upon the personal knowledge of anyone.
No document was used other than the Program Plan.
Interroaatorv No. 12:
" Explain the phrase ' static document'. (page 4)
"a.
Identify the person or persons who answered this question, include the name, position, or title, and organization.
"b.
If the person who answered this question did not rely on first-hand, personal knowledgc[,]
provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date, and location which were used or examined to answer the question."
Answer:
A static document is a document that will not (or is not expected to) change; it is the opposite of a dynamic document.
It was used to convey the messsage that "(a]s situations arise, the conduct and scope of CPRT activities
- 13
will be revised as appropriate."
Idz This answer is provided by the SRT, acting collectively and collegially.
The answer, not calling for a matter of fact, is not based upon the personal knowledge of anyone.
No document was used other than the Program Plan.
Interroaatorv No. 13:
' Explain the phrase ' preliminary assessment'.
(pg. 7)
"a.
Identify the person or persons who answered this question, include the name, position, or title, and organization.
"b.
If the person who answered this question did not rely on first-hand, personal knowledge [,]
provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date, and location which were used or examined to answer the question."
Answer:
The quoted phrase was not employed by the SRT with any specialized meaning.
The meaning of the paragraph from which the phrase is taken is that CPRT will investigate (such as by re-inspection) an issue even if an analysis or assessment of the TRT findings leads to the conclusion that the issue is not valid.
An example is the re-inspections performed under Action Plan I.a.4.
This answer is provided by the SRT, acting _.. _ _ _ _ _ _ _ _ - _. _ _ _ _ _ _
1 l
collectively and collegially.
The answer, not calling for a matter of fact, is not based upon the personal knowledge 1
of anyone.
No document was used other than the Program Plan.
Interroaatory No. 14:
I
]-
Explain, in precise terms, what is meant by the commitment that 'each issue will be thoroughly evaluated.'
3 (pg. 7) d i
"a.
Identify the person or persons who answered this question, include the name, position, or title, and organization.
"b.
If the person who answered this question did not rely on first-hand, personal knowledge [,)
provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date, and location which were used or examined to answer the question."
i l
Answer:
Please see our answer to the prior interrogatory.
I This answer is provided by the SRT, acting i
collectively and collegially.
The answer, not calling for a matter of fact, is not based upon the personal knowledge I
of anyone.
No document was used other than the Program Plan.
4 l
Interrocatory No. 15:
"What criteria are used to decide whether an issue has i
been thoroughly evaluated and which person apply those criteria.
l
._m____-,
"a.
Identify the person or persons who-answered this question, include the name, position, or title, and organization.
"b.
If the person who answered this question did not rely on first-hand, personal knowledge (,)
provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date, and location which were used or examined to answer the question."
Answer:
The criteria defining whether particular issues have-been thoroughly evaluated are defined in the Action Plan by which the issue was investigated.
The criteria are applied, in the first instance, by the Review Team Leader for that Action Plan and, ultimately, by the SRT.
This answer is provided by the SRT, acting collectively and collegially.
The answer, not calling for a matter of fact, is not based upon the personal knowledge of anyone.
No document was used other than the Program Plan.
Interroaatory No. 16:
" Explain, in precise terms, what is meant by the descriptive phrase ' multiple, apparently isolated and relatively minor discrepancies'. (pg. 9)
"a.
Identify the person or persons who answered this question, include the name, position, or title, and organization. 1 I
"b.
If the person who answered this question did not rely on first-hand, personal knowledge [,]
provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date, and location which were used or examined to answer the question."
Answer:
The quoted phrase, on page 9 of the Program Plan, was not employed by the SRT with any specialized meaning.
It refers to the potential that there would be encountered
" multiple" -- that is, more than one -
"apparently isolated" -- that is, having no apparent commonality of cause or occurence rate - "and relatively minor" -- that is, of no safety significance -- might nevertheless upon further examination be reflective of "a common shortcoming in the programs and procidures applicable to the CPSES Project."
This answer is provided by the SRT, acting collectively and collegially.
The answer, not calling for a matter of fact, is not based upon the personal knowledge of anyone.
No document was used other than the Program Plan.
Interrocatorv No. 17:
" Explain, in precise terms, the term ' population' (Appendix B, page 7-13). - _ _ _ _ _ _
"a.
Identify the person or persons who answered this question, include the name, position, or title, and organization.
"b..
If the person who answered this question did not rely on first-hand, personal knowledge [,]
provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date, and location which were used or examined to answer the question."
Answer:
" Population" was used in the cited location to refer to a set of items concerning which collective characteristics can be expected to be revealed by examination of selected members.
This answer is provided by the SRT, acting collectively and collegia 11y.
The answer, not calling for a matter of fact, is not based upon the personal knowledge of anyone.
No document was used other than the Program Plan.
Interroaatory No. 18:
" Explain, in precise terms, what is meant by a
' reasonably homogenous work activity.'
(Appendix B, pg. 8)
"a.
Identify the person or persons who answered this question, include the name, position, or title, and crganization.
"b.
If the person who answered this question did not rely on first-hand, personal knowledge [,]
provide the name, position or title, and organization of the person whose knowledge the
- 18
[
J answer was based on.
"c.
Identify the documents by description, date, and location which were used or examined to answer the question."
Answer:
The explanation can be found in the paragraph on Page 8 of Appendix B to the Program Plan wherein the phrase is used.
In the absence of a more directed question, it is not clear to us what further " explanation" is requested.
Please note t_ sat a part of the output of Action Plan VII.c will include the verification of the population process.
See CPP-005.
This answer is provided by the SRT, acting collectively and collegially.
The answer, not calling for a matter of fact, is not based upon the personal knowledge of anyone.
No document was used other than the Program Plan and CPP-005, of which we understand CASE has already been provided a copy.
Interroaatory No. 19:
i
" Explain, in precise terms, what is meant by the descriptive phrase ' quality characteristic.'
(Appendix B, pg. 8) a.
Identify the person or persons who answered a
this question, include the name, position, or title, and organization.
"b.
If the person who answered this question did -
i not rely on first-hand, personal knowledge [,]
provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date, and location which were used or examined to answer the question."
Answer:
The quoted phrase refers to those attributes (characteristics) of the component or process in question which, if not in accordance with applicable design documents, codes and standards, could impair the ability of the component to perform its intended safety-related function under design loading conditions.
See CPP-007.
This answer is provided by the SRT, acting collectively and collegially.
The answer, not calling for a matter of fact, is not based upon the personal knowledge of anyone.
No document was used other than the Program Plan and CPP-007.
Interroaatory No. 20:
"In reference to the explanation of safety significance as provided on page 2 of Appendix E, identify all systems which have the potential for including safety significant discrepancies.
"a.
Identify the person or persons who answered this question, include the name, position, or title, and organization.
i f !
"b.
If the person who answered this question did not rely on first-hand, personal knowledge [,)
l provide the name, position or title, and organization of the person whose knowledge the answer was based on.
"c.
Identify the documents by description, date, and location which were used or examined to answer the question."
4 Answer:
Such a list may be found in the FSAR at Appendix 17A i
and Table 17A-1, pp. 1-50.
f This answer is provided by the SRT, acting
]
collectively and collegially.
The answer, not calling for a matter of fact, is not based upon the personal knowledge of anyone.
No document was used other than the FSAR.
4 j
Interroaatory No. 21:
" Explain in precise detail the phrase ' programmatic in nature' as used throughout Appendix E.
i i
"a.
Identify the person or persons who answered 3
this question, include the name, position, or title, and organization.
i "b.
If the person who answered this question did not rely on first-hand, personal knowledge [,)
j provide the name, position or title, and organization of the person whose knowledge the answer was based on.
j "c.
Identify the documents by description, date, and location which were used or examined to answer the question."
^
Answer:
i The phrase was not intended by the SRT to denote or
, 1
_. ~.. -,.. _ _ _.
.._.m,
. i
l connote anything other than that implied by the ordinary usage associated with the terms in question.
It refers to an adverse trend of deviations that constitutes or manifests a systematic failure of a procedure, instruction or specification to achieve its intended purpose.
This answer is provided by the SRT, acting collectively and collegially.
The answer, not calling for a matter of fact, is not be. sed upon the personal knowledge of anyone.
No document was used other than the Program Plan.
Interrocatorv No. 22:
Produce for copying and inspection all documents examined and/or relied upon in answering these questions and identify for each_ document produced to which answer it is related.
Answer:
No documents of which copies have not already been provided to CASE have been referred to or relied upon in providing the foregoing responses.
l _
CIGNATURES 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 j
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.
Terryy.Tylep Sworn to before me this
- 3-d day of September, 1986
84uG h3m
/ Notary %blicJ.sr4re ek 7aru.s My commission expires ~: mucu 2r /9Fr As to objections:
,, I h,
i 1
R.
K. Gad II'1 l
DOLMETED CERTIFICATE OF SERVICE USNRC I, Robert A. Wooldridge, one of the attorneys for the klEnMhNih,7 hereby certify that on September 26, 1986, I made' service of /pg(cants' Answers 00CliEiN ^ SIWiCL to CASE CPRT Program Plan Interrogatories (Set No.1) by mailing co%sMhereof, postage prepaid, to:
Mr. Peter B. Bloch, Esq., Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Kenneth A. McCollom 1107 West Knapp Stillwater, Oklahoma 74075 Elizabeth B. Johnson Oak Ridge National Laboratory P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Dr. Walter H. Jordan 881 West Outer Drive Oak Ridge, Tennessee 37830 I
Mrs. Juanita Ellis President, C ASE 1426 South Polk Street Dallas, Texas 75224 Renea Hicks, Esq.
Assistant Attorney General Environmental Protection Division P. O. Box 12548, Capitol Station Austin, Texas 78711 i
Nicholas S. Reynolds, Esq.
William A. Horin, Esq.
i Bishop, Liberman, Cook, Purcell & Reynolds 1200 Ses --+eenth Street, N.W.
Suite 700 Washington, D.C. 20036 Mr. W. G. Counsli Executive Vice President Texas Utilities Generating Company Skyway Tower,24th Floor l
400 N. Olive Street Dallas, Texas 75201 1 - - _ -
Mr. ' thomas G. Dignan, Jr.
Mr. R. K. Gad, Ill Mr. William Eggeling Ropes & Gray 225 Franklin Street Boston, Massachusetts 02110 Mr. Roy P. Lessy, Jr.
Wright & Talisman 1050 Seventeenth Street, N.W.
Suite 600 Washington, D.C. 20036 5566 Robert D. Martin Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Lanny A. Sinkin Christic Institute 1324 North Capitol Street Washington, D.C. 20002 Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. William L. Clements Docketing & Service Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Stuart A. Treby, Esq.
Office of the Executive Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Chairman i
Atomic Safety and Licensing Appeal Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Ms. Ellen Ginsberg, Esq.
U.S. Nuclear Regulatory Commission 4350 East / West Highway,4th Floor I
Bethesda, Maryland 20814 Billie Pirner Garde Government Accountability Project Midwest Office 3424 N. Marcos Lane Appleton, Wisconsin 54911 2
Nancy Williams Cygna Energy Services, Inc.
101 California Street Suite 1000 San Francisco, California 94111 David R. Pigot Orrick, Herrington & Sutcliffe 600 Montgomery Street San Francisco, Cailfornia 94111 Mr. Shannon Phillips Resident inspector Comanche Peak SES
' c/o U.S. Nuclear Regulatory Commission P. O. Box 38 Glen Rose, Texas 76043 Anthony Roisman, Esq.
Executive Director Trial Lawyers for Public Justice 2000 P. Street, N.W., Suite 611 Washington, D.C. 20036
'}, )/
f r
T F, W eig Robert A. Wooldridge t l
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