ML053560119
| ML053560119 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 01/04/2006 |
| From: | Virgilio M J NRC/EDO |
| To: | Goyal J P - No Known Affiliation |
| Starkey D | |
| Shared Package | |
| ML053560084 | List: |
| References | |
| 3-2002-006, BL-01-001, IA-05-055, IR-02-008 IA-05-055 | |
| Download: ML053560119 (17) | |
See also: IR 05000346/2002008
Text
January 4, 2006IA-05-055Prasoon Goyal[Home Address Deleted
Under 10 CFR 2.390(a)]SUBJECT:ORDER (EFFECTIVE IMMEDIATELY) PROHIBITING INVOLVEMENT IN NRC-LICENSED ACTIVITIES (NRC SPECIAL INSPECTION REPORT NO. 50-346/2002-08(DRS)) (NRC INVESTIGATION REPORT NO. 3-2002-006)Dear Mr. Goyal:The enclosed Order Prohibiting Involvement in U.S. Nuclear Regulatory Commission (NRC)Licensed Activities (Order) is being issued because you engaged in deliberate misconduct as
defined in 10 CFR 50.5, "Deliberate Misconduct," by deliberately providing incomplete and
inaccurate information. The incomplete and inaccurate information concerned the licensee's
October 17, 2001, supplemental response to NRC Bulletin 2001-001, "Circumferential Crackingof Reactor Pressure Vessel Head Penetration Nozzles." The matter was investigated by the NRC's Office of Investigations (OI) and the results weredocumented in OI Report No. 3-2002-006. The OI investigation results were provided to the
U.S. Department of Justice (DOJ) for its review.The OI investigation report documented that you concurred in the licensee's September 4,2001, and October 17, 2001, responses to the Bulletin. Prior to the licensee's issuance of itsSeptember 4, 2001, response to Bulletin 2001-001, you expressed concerns to FENOC
management and staff regarding the completeness and accuracy of licensee's response with
regard to the licensee's past and future ability to conduct a complete inspection of the reactorpressure vessel head due to equipment limitations and physical impediments. However, the OI
investigation did not find that you expressed concerns regarding the incomplete and inaccurate
characterization in the October 17, 2001, supplemental response to the Bulletin with regard to
the 1996 reactor pressure vessel head inspection and cleaning, an effort that you conducted. Your actions caused the licensee to be in violation of 10 CFR 50.9, "Completeness and
Accuracy of Information," and caused you to be in violation of 10 CFR 50.5. Therefore, we
determined an Order prohibiting your involvement in NRC-licensed activities for a period of oneyear was appropriate.The enclosed Order prohibits your involvement in all NRC-licensed activities for a period of oneyear effective immediately. In accordance with 10 CFR 2.202 you must submit an answer to
this Order within twenty (20) days of the date of this Order. Your answer may request a
P. Goyal-2-hearing. However, since this enforcement action is being proposed prior to the DOJ completingits review of the OI investigation results, consideration may be given to extending your time to
answer the Order, when good cause is shown. The Order also requires you to immediately
cease your involvement in NRC-licensed activities, if you are involved with an NRC licensee onthe date of the Order, to provide a copy of the Order to the NRC licensee, and to inform theNRC of the name, address, and telephone number of that licensee at that time. Additionally, fora period of one year, after the one-year period of prohibition has expired, you are required,
within 20 days of your acceptance of your first employment offer involving NRC-licensed
activities or becoming involved in NRC-licensed activities, to provide notice to the Director,
Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555, of the
name, address, and telephone number of the employer or the entity where you are, or will be,involved in the NRC-licensed activities.Pursuant to Section 223 of the Atomic Energy Act of 1954, as amended, any person whowillfully violates, attempts to violate, or conspires to violate, any provision of this Order shall be
subject to criminal prosecution as set forth in that section. Violation of this Order may also
subject the person to civil monetary penalty. A copy of this letter and its enclosure is being sent to FENOC, the operator of Davis-Besse.
Questions concerning this Order should be addressed to Michael R. Johnson, Director, Officeof Enforcement, who can be reached at (301) 415-2741.This letter will be maintained by the Office of Enforcement in an NRC Privacy Act system ofrecords, NRC-3, "Enforcement Actions Against Individuals." The NRC-3 system notice, whichprovides detailed information about this system of records, can be accessed from our Web site
at http://www.nrc.gov/reading-rm/foia/privacy-systems.html.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response will be made available electronically for public inspection in theNRC Public Document Room or from the NRC's document system (ADAMS), accessible from
the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, yourresponse should not include any personal privacy, proprietary, or safeguards information so
that it can be made available to the public without redaction. If personal privacy or proprietary
information is necessary to provide an acceptable response, then please provide a bracketed
copy of your response that identifies the information that should be protected and a redactedcopy of your response that deletes such information. If you request withholding of such
material, you must specifically identify the portions of your response that you seek to havewithheld and provide in detail the bases for your claim of withholding (e.g., explain why the
disclosure of information will create an unwarranted invasion of personal privacy or provide theinformation required by 10 CFR 2.390(b) to support a request for withholding confidential
commercial or financial information). If safeguard's information is necessary to provide an
acceptable response, please provide the level of protection described in 10 CFR 73.21.
P. Goyal-3-The NRC also includes significant enforcement actions on its Web site at www.nrc.gov; selectWhat We Do , Enforcement , then Significant Enforcement Actions
.Sincerely, /RA/Martin J. VirgilioDeputy Executive Director for Materials,
Research, State, and Compliance Programs
Office of the Executive Director for OperationsEnclosure: As Stated
cc w/encl:Gary Leidich, President, FENOC
P. Goyal-3-The NRC also includes significant enforcement actions on its Web site at www.nrc.gov; selectWhat We Do , Enforcement , then Significant Enforcement Actions
.Sincerely, /RA/Martin J. VirgilioDeputy Executive Director for Materials, Research, State, and Compliance ProgramsOffice of the Executive Director for OperationsEnclosure: As Stated
cc w/encl:Gary Leidich, President, FENOCML053560119
OFCOERIII:DRAOGC NAMEDStarkeyGGrantLChandler (SBrock for) DATE12/21/0512/15/0512/20/05
OFCOE:DDOE:DDEDMRS NAMEJLuehmanMJohnsonMVirg
ilio DATE12/21/0512/23/0512/29/05
P. Goyal-4-DISTRIBUTION: ADAMS (PARS)SECY OCA L. Reyes, EDOW. Kane, DEDR
M. Johnson, OE
J. Luehman, OE
C. Nolan, OE
D. Starkey, OE
J. Caldwell, RIII
G. Grant, RIII
M. Satorius, RIII
S. West, RIII
L. Chandler, OGC
B. Jones, OGC
S. Brock, OGC
J. Dyer, NRR
D. Holody, Enforcement Coordinator, RI
C. Evans, Enforcement Coordinator, RII
K. O'Brien, Enforcement Coordinator, RIII
K. Fuller, Enforcement Coordinator, RIV
F. Bonnett, Enforcement Coordinator, NRR
Resident Inspector
H. Bell, OIG
G. Caputo, OI
E. Brenner, OPA
J. Schlueter, OSTP
R. Paul, RIII:OI
J. Ulie, RIII:OIM. Janicki, RIII:OI
J. Gavula, RIII
N. Hane, RIII:OIC. Lipa, RIII
C. Weil, RIII
K. Lambert, RIII
M. Phillips, RIII
J. Strasma, RIII:PA
R. Lickus, RIII
J. Lynch, RIII
OEWEB
OEMAIL
OAC3E:\Filenet\ML053560119.wpd
[7590-01-P]UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSIONIn the Matter of))IA-05-055Prasoon Goyal)
)ORDER PROHIBITING INVOLVEMENT INNRC-LICENSED ACTIVITIES(EFFECTIVE IMMEDIATELY)
IMr. Prasoon Goyal was previously employed, at times relevant to this Order, as a SeniorEngineer at the Davis-Besse Nuclear Power Station (Davis-Besse) operated by FirstEnergy
Nuclear Operating Company (FENOC or licensee). The licensee holds License No. NPF-3
which was issued by the Nuclear Regulatory Commission (NRC or Commission) purs
uant to 10 CFR Part 50 on April 22, 1977. The license authorizes the operation of Davis-Besse in
accordance with the conditions specified therein. The facility is located on the licensee's sitenear Oak Harbor, Ohio.
IIOn August 3, 2001, the
NRC issued Bulletin 2001-001, "Circumferential Cracking of ReactorPressure Vessel Head Penetration Nozzles," (Bulletin). In the Bulletin, the
NRC requested thatall holders of operating licenses for pressurized water nuclear power reactors (PWR), including
FENOC for the Davis-Besse facility, provide information to the NRC relating to the structural
integrity of the reactor pressure vessel (RPV) head penetration nozzles at their respective
facilities. The information requested from the licensees included the extent of RPV head
-2-penetration nozzle leakage and cracking that had been found to date, a description of theinspections and repairs undertaken to satisfy applicable regulatory requirements, and the basis
for concluding that a licensee's plans for future inspections would ensure compliance with
applicable regulatory requirements. The NRC also required that all Bulletin addressees,including FENOC, submit a written response to the NRC in accordance with the provisions of10 CFR 50.54(f). That regulation provides, in part, that upon request of the NRC, an NRC-licensee must submit written statements, signed under oath or affirmation, to enable the NRC todetermine whether the license should be modified, suspended, or revoked.On September 4, October 17, and October 30, 2001, the licensee provided written responses tothe Bulletin. Additionally, the licensee met with the NRC staff on numerous occasions during
October and November of 2001 to provide clarifying information. Based, in part, on the
information provided by FENOC in its written responses to the Bulletin and during meetings with
the NRC staff, the NRC staff allowed the licensee to continue operation of the Davis-Bessefacility until February 2002, rather than requiring FENOC to shut the unit down to performinspections by December 31, 2001, as provided in the Bulletin.On February 16, 2002, FENOC shut down Davis-Besse for refueling and inspection of controlrod drive mechanism (CRDM) RPV head penetration nozzles. Using ultrasonic testing, thelicensee found cracks in three CRDM RPV head penetration nozzles and on March 6, 2002, thelicensee discovered a cavity in the RPV head in the vicinity of CRDM Penetration Nozzle No. 3. The cavity measured approximately 5 to 7 inches long, 4 to 5 inches wide, and penetrated
through the 6.63 inch-thick low-alloy steel portion of the RPV head, leaving the stainless steel
cladding material (measuring 0.202 to 0.314 inches-thick) as the sole reactor coolant system
-3-(RCS) pressure boundary. A smaller cavity was also found near CRDM Penetration NozzleNo. 2. The licensee conducted a root cause evaluation and determined, contrary to the earlierinformation provided to the NRC, that the cavities were caused by boric acid from the RCSreleased through cracks in the CRDM RPV head penetration nozzles. The root causeevaluation found that the licensee conducted limited cleaning and inspections of the RPV headduring the Twelfth Refueling Outage (12RFO) that ended on May 18, 2000. However, neitherthe limited RPV head cleaning nor the resultant inspections during 12RFO were sufficient to
ensure that the significant boric acid deposits on the RPV head were only a result of
CRDMflange leakage, as supposed, and were not a result of RCS pressure boundary leakage.On March 6 and March 10, 2002, the licensee provided information to the NRC concerning theidentification of a large cavity in the RPV head adjacent to CRDM Penetration Nozzle No. 3. The NRC conducted an Augmented Inspection Team (AIT) inspection at Davis-Besse fromMarch 12 to April 5, 2002, to determine the facts and circumstances related to the significant
degradation of the RPV head. The results of the AIT inspection were documented in NRC
Inspection Report No. 50-346/2002-03, issued on May 3, 2002. A follow-up Special Inspection
was conducted from May 15 to August 9, 2002, and on October 2, 2002, the
NRC iss ued theAIT Follow-up Special Inspection Report No. 50-346/2002-08 documenting ten apparent
violations associated with the RPV head degradation. On April 22, 2002, the NRC Office of Investigations (OI) initiated an investigation at Davis-Besse to determine, among other matters, whether FENOC and individual employees at the
Davis-Besse facility failed to provide complete and accurate information to the NRC in its
-4-September 4, October 17, and October 30, 2001, responses to the Bulletin and duringnumerous conference calls and meetings in violation of 10 CFR 50.9 and 10 CFR 50.5(a)(2).
The OI report (No. 3-2002-006) was issued on August 22, 2003. A copy of the OI report was
provided to the U. S. Department of Justice (DOJ), Office of the United States Attorney,
Northern District of Ohio for review. The matter remains under continued Federal investigation. Mr. Goyal, through the performance of his engineering duties, through his direct involvement inthe licensee's 1996 RPV head inspection and cleaning activities, and through oral and written
communications with other FENOC employees was aware of the results of previous RPV head
inspections.*Mr. Goyal was the engineer responsible for performing the 1996 reactor head inspectionduring the Tenth Refueling Outage (10RFO). During a sworn, transcribed interview with
OI, Mr. Goyal stated that he could not see the top of the RPV head during 10RFO dueto the limited access through the mouseholes and the accumulation of boric acid on the
RPV head. *Mr. Goyal wrote Potential Condition Adverse to Quality Report (PCAQR) 96-0551documenting that the accumulation of boric acid on the head and the size of the
mouseholes limited the extent of the inspection. Mr. Goyal documented in PCAQR96-0551, in part:"Since the boric acid deposits are not cleaned it is difficult to distinguishwhether the deposits occurred because of the leaking flanges or the
leaking CRDM."
-5-"This PCAQR is the quality document which recorded the boric acid depositon the RV head. The deposits were discovered during the visual inspection
of the RV head performed through the mouseholes utilizing a video camera. The extent of the inspection was limited to approximately 50 to 60% of the
head areas because of the restrictions imposed by the location and sized of
mouseholes. The inspection showed varying sizes of boric acid mounds
scattered in various areas of head. It is extremely difficult to develop an
estimate of the amount of boric acid deposit because of the deposit scatter
and limited inspection."*Mr. Goyal authored a "White" paper, distributed to other Davis-Besse staff onMay 8, 1996, that discussed control rod drive nozzle cracking within the nuclear powerindustry. Mr. Goyal documented in the "White" paper, in part: "All plants, except Davis-Besse and Arkansas Nuclear 1, have large accessholes in the skirt area of the service structure to view/clean the entire head.
Davis-Besse's access is limited to about 50 percent of the head area."Several FENOC employees, including Mr. Prasoon Goyal, were responsible for the informationprovided to the NRC by FENOC in response to the Bulletin.
IIIPrasoon Goyal was employed by FENOC as a senior engineer in the Design Basis Engineeringorganization at Davis-Besse at the time the responses to the Bulletin were developed and
transmitted to the NRC. Mr. Goyal was a design engineer and the individual who reviewed thelicensee's 1996 inspection of the CRDM flanges, and conducted the licensee's inspection of theRPV head and CRDM nozzles during 10RFO. Mr. Goyal reviewed the October 17, 2001 supplemental response to the bulletin. On
-6-October 17, 2001, Mr. Goyal concurred as "Design Basis Engrg - Mech" [Design BasisEngineering - Mechanical] in the issuance of the licensee's October 17, 2001 supplemental
response to the Bulletin.Item 1.d of the Bulletin requested each pressurized water reactor (PWR) licensee, includingFENOC for Davis-Besse, to provide a description of the RPV head penetration nozzles and
RPV head inspection (including type, scope, qualification requirements, and acceptance
criteria) that were performed at PWRs in the 4 years preceding the date of the Bulletin, and thefindings resulting from the inspections. The licensees were requested to include a description
of any limitations (insulation or other impediments) to accessibility of the bare metal of the RPVhead for visual examinations.On September 4, 2001, FENOC submitted its written response to the Bulletin for Davis-Besse. On October 17, 2001, FENOC submitted a supplemental response to the Bulletin for
Davis-Besse and included information not provided in the September 4, 2001, response with
regard to RPV inspections and cleaning conducted during 10RFO. Attachment 1 to the
licensee's October 17, 2001, supplemental response to the Bulletin stated under the sectionentitled, "Summary," in part:"In May 1996, during a refueling outage, the RPV head was inspected. Noleakage was identified, and these results have been recently verified by a
re-review of the video tapes obtained from that inspection."The October 17, 2001, supplemental response to the Bulletin also stated under the sectionentitled, "Previous Inspection Results," in part:
-7-"The inspections performed during the 10
th , 11 th , and 12 th Refueling Outage(10RFO, conducted April 8 to June 2, 1996; 11RFO, conducted April 10, to
May 23, 1998; and, 12RFO, conducted April 1 to May 28, 2000) consisted of
a whole head visual inspection of the RPV head in accordance with the
DBNPS Boric Acid Control Program pursuant to Generic Letter 88-05, 'Boric
Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in
PWR Plants.' The visual inspections were conducted by remote camera
and included below insulation inspections of the RPV bare head such that
the Control Rod Drive Mechanism (CRDM) nozzle penetrations wereviewed. During 10RFO, 65 of 69 nozzles were viewed, during 11RFO, 50 of
69 nozzles were viewed, and during 12RFO, 45 of 69 nozzles were viewed."Information included under Column 6 of Attachment 2 of the licensee's October 17, 2001,supplemental response stated, in part, that 24 nozzles have a "flange leak evident." Note 1 on
the same table stated, in part:"In 1996 during 10 RFO, the entire RPV head was inspected. Since thevideo was void of head orientation narration, each specific nozzle view could
not be correlated."The licensee's October 17, 2001, supplemental response was materially incomplete andinaccurate in that the licensee did not view the stated number of RPV head penetration nozzlesduring the referenced outages, and the licensee believed that only five RPV head control roddrive mechanism flanges were leaking instead of the 24 RPV head control rod
drive mechanism flanges noted in the response. Mr. Goyal was aware that the licensee's
October 17, 2001, supplemental response was materially incomplete and inaccurate and
concurred on the response, thereby allowing it to be submitted to the NRC. Based on the above information, the NRC concludes that Mr. Goyal had sufficient knowledge ofthe condition of the RPV head and the limitations experienced during the RPV head inspections
conducted during 10RFO, and notwithstanding that knowledge, he deliberately provided
-8-materially incomplete and inaccurate information, when on October 17, 2001, he concurred onthe licensee's October 17, 2001, supplemental response to the
NRC.The information provided by the licensee under oath in the Bulletin supplemental response wasmaterial to the NRC because the NRC used the information, in part, to allow FENOC to operateDavis-Besse until February 2002 rather than requiring the plant to shut down by December 31,2001, to conduct inspections of the head as discussed in Item 3.v.1. of the Bulletin.Based on the above information, Mr. Prasoon Goyal, while employed by the licensee, engagedin deliberate misconduct by deliberately providing incomplete or inaccurate information that he
knew was not complete and accurate in all material respects to the NRC, a violation of10 CFR 50.5(a)(2). Mr. Goyal's actions also placed FENOC in violation of 10 CFR 50.9. The
NRC determined that these violations were of very high safety and regulatory significancebecause they involved a pattern of deliberate documentation of inaccurate or incomplete
information that was required to be submitted to the NRC. Had the NRC been aware of thisincomplete and inaccurate information, the NRC would likely have taken immediate regulatoryaction to shut down the plant and require the licensee to implement appropriate corrective
actions.IV
The NRC must be able to rely on the licensee and its employees to comply with NRCrequirements, including the requirement to provide information and maintain records that are
complete and accurate in all material respects. Mr. Goyal's deliberate actions raise serious
-9-doubt as to whether he can be relied upon to comply with
NRC requirements and to providecomplete and accurate information to the NRC. Consequently, I lack the requisite reasonable assurance that licensed activities can beconducted in compliance with the Commission's requirements and that the health and safety ofthe public will be protected if Mr. Goyal is permitted to be involved in NRC-licensed activities.
Therefore, the public health, safety and interest require that Mr. Goyal be prohibited from any
involvement in NRC-licensed activities for a period of one year effective immediately. Additionally, Mr. Goyal is required to notify the NRC of his first employment in NRC-licensedactivities for a period of one year following the prohibition period.
VAccordingly, pursuant to sections 103, 104, 161b, 161i, 161o, 182 and 186 of the AtomicEnergy Act of 1954, as amended, and the Commission's regulations in 10 CFR 2.202,10 CFR 50.5, and 10 CFR 150.20, IT IS HEREBY ORDERED THAT EFFECTIVE
IMMEDIATELY:1.Mr. Prasoon Goyal is prohibited for one year from the date of this Order from engagingin NRC-licensed activities. The NRC considers NRC-licensed activities to be those
activities that are conducted pursuant to a specific or general license issued by the
NRC, including those activities of Agreement State licensees conducted pursuant to theauthority granted by 10 CFR 150.20. 2. If Mr. Goyal is currently involved with another licensee in NRC-licensed activities, hemust immediately cease those activities, and inform the NRC of the name,
-10-address and telephone number of the employer, and provide a copy of this Order to the employer. 3.For a period of one year after the one-year period of prohibition has expired, Mr. Goyalshall, within 20 days of acceptance of his first employment offer involving NRC-licensed
activities or his becoming involved in NRC-licensed activities, as defined in ParagraphIV.1 above, provide notice to the Director, Office of Enforcement, U.S. Nuclear
Regulatory Commission, Washington, DC 20555, of the name, address, and telephonenumber of the employer or the entity where he is, or will be, involved in NRC-licensed
activities. In the notification, Mr. Goyal shall include a statement of his commitment to
compliance with regulatory requirements and the basis why the Commission should
have confidence that he will now comply with applicable NRC requirements.The Director, Office of Enforcement, may, in writing, relax or rescind any of the aboveconditions upon demonstration by Mr. Goyal of good cause.
VIIn accordance with 10 CFR 2.202, Prasoon Goyal must, and any other person adverselyaffected by this Order may, submit an answer to this Order, and may request a hearing on this
Order within 20 days of the date of this Order, consideration may be given to extending the
response time for submitting an answer as well as the time for requesting a hearing, for good
cause shown. A request for extension of time must be made in writing to the Director, Office of
Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555, and include a
statement of good cause for the extension. The answer may consent to this Order. Unless the
-11-answer consents to this Order, the answer shall, in writing and under oath or affirmation,specifically admit or deny each allegation or charge made in this Order and shall set forth the
matters of fact and law on which Mr. Goyal or other person adversely affected relies and the
reasons as to why the Order should not have been issued. Any answer or request for a hearing
shall be submitted to the Secretary, U.S. Nuclear Regulatory Commission, Attn: Rulemakings
and Adjudications Staff, Washington, DC 20555. Copies also shall be sent to the Director,
Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555, to the
Assistant General Counsel for Materials Litigation and Enforcement at the same address, to the
Regional Administrator, NRC Region III, 2443 Warrenville Road, Lisle, IL 60532-4352, and toMr. Goyal if the answer or hearing request is by a person other than Mr. Goyal. Because of
continuing disruptions in delivery of mail to United States Government offices, it is requested
that answers and requests for hearing be transmitted to the Secretary of the Commission eitherby means of facsimile transmission to 301-415-1101 or by e-mail to hearingdocket@nrc.govand also to the Office of the General Counsel either by means of facsimile transmission to
301-415-3725 or by e-mail to OGCMailCenter@nrc.gov. If a person other than the Mr. Goyalrequests a hearing, that person shall set forth with particularity the manner in which his interest
is adversely affected by this Order and shall address the criteria set forth in 10 CFR 2.309.If a hearing is requested by Mr. Goyal or a person whose interest is adversely affected, theCommission will issue an Order designating the time and place of any hearing. If a hearing isheld, the issue to be considered at such hearing shall be whether this Order should be
sustained.Pursuant to 10 CFR 2.202(c)(2)(i), Mr. Goyal, may, in addition to demanding a hearing, at thetime the answer is filed or sooner, move the presiding officer to set aside the immediate
-12-effectiveness of the Order on the ground that the Order, including the need for immediateeffectiveness, is not based on adequate evidence but on mere suspicion, unfounded
allegations, or error.In the absence of any request for hearing, or written approval of an extension of time in whichto request a hearing, the provisions specified in Section V above shall be effective immediately
and final 20 days from the date of this Order without further order or proceedings. If an
extension of time for requesting a hearing has been approved, the provisions specified in
Section V shall be final when the extension expires if a hearing request has not been received. FOR THE NUCLEAR REGULATORY COMMISSION
/RA/Martin J. VirgilioDeputy Executive Director for Materials,
Research, State, and Compliance Programs
Office of the Executive Director for OperationsDated this 4
th day of January 2006