ML20235Y898
| ML20235Y898 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 07/21/1987 |
| From: | Baxter T DETROIT EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20235Y902 | List: |
| References | |
| CON-#387-4046 2.206, NUDOCS 8707270099 | |
| Download: ML20235Y898 (22) | |
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, , a g p' UNITED STATES OF AMERICA " O . ,; i NUCLEAR REGULATORY COMMISSION
'87 at 23 A10:47 BEFORE THE DIRECTOR, OFFICE OF NUCLEAR REACTOR REGULATION OFi In the Matter of ) :u.
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THE DETROIT EDISON COMPANY ) Docket No. 50-341
) (10 C.F.R. 5 2.206)
(Fermi-2) )
LICENSEE'S RESPONSE TO THE PETITION OF THE SAFE ENERGY COALITION OF MICHIGAN AND THE SISTERS, SERVANTS OF THE IMMACULATE HEART OF MARY CONGREGATION -
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4 Thomas A. Baxter, P.C.
SHAW, PITTMAN, POTTS & TROWBRIDGE Counsel for The Detroit Edison Company Dated: July 21, 1987 8707270099 870721 PDR ADOCK 05000341 0 PDR
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TABLE OF CONTENTS l l
i Pace 1 I. Introduction.............................................. 1 II. Standards for Deciding Whether a show Cause l Proceeding Should Be Initiated............................ 3 III. The Allegations in the Petition Do Not
. Raise Significant Health and Safety Issues................ 9 A. Discrimination Against. Individuals................... 9 B. Implementation Effectiveness........................ 11 C. Quality Assurance Requirements...................:.. 14' D. Accountability...................................... 15 ,
E. Relief Requested.................................... 16 IV. Conclusion............................................... 18 Certificate of Service Attachment A: Affidavit of Robert G. Kunkle Attachment B: Letter dated March 30, 1987, A. Bert Davis (NRC) to Jennifer E. Puntenney (SECOM) 4 1
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July _21,_1987 UNITED STATES.0F AMERICA' NUCLEAR REGULATORY COMMISSION BEFORE THE DIRECTOR, OFFICE OF NUCLEAR REACTOR REGULATION In'the Matter of )
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THE DETROIT EDISON COMPANY ) Docket No. 50-341
) (10 C.F.R. S 2.206)-
(Fermi-2) )
LICENSEE'S RESPONSE TO THE PETITION OF THE SAFE ENERGY COALITION OF MICHIGAN AND THE SISTERS, SERVANTS OF THE IMMACULATE-HEART OF MARY CONGREGATION I. Introduction The Detroit Edison Company-(" DECO" or " Licensee") is the holder of Facility Operating License No. NPF-43 for Fermi-2. On May 7, 1987, the Government Accountability Project (" GAP")' filed
-with the Nuclear Regulatory Commission a petition on behalf of the Safe Energy Coalition of Michigan ("SECOM") and the Sisters, Servants of the Immaculate Heart of Mary Congregation (collet-tively " Petitioners"). The petition, filed pursuant to 10 C.F.R.
S 2.206, requests that the NRC institute a show cause enforcement proceeding to modify, suspend or revoke the Fermi-2 license, or to take other-action appropriate and consistent with the relief requested.1 The petition has been referred to the Director, 1/ Previous section 2.206 petitions by SECOM have been denied by the Director, Office of Inspection and Enforcement, and by the '
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Office of Nuclear Reactor Regulation, who acknowledged receipt of the petition on June 29, 1987. See 52 Fed. Reg. 25330 (July 6, 1987).
The petition challenges Licensee's Fermi-2 individual con-cerns program, which is called "SAFETEAM."S!
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The specific relief requested by Petitioners is that the NRC:
- 1. Take possession of all SAFETEAM files and review the allegations for all potential safety related deficiencies, and make these concerns public.
- 2. Require that all SAFETEAM allegations are processed by DECO in accordance with Appendix B to 10 C.F.R. Part 50.
- 3. Require that all utility employees are fully informed about the SAFETEAM program before they make a choice between submitting information to SAFETEAM or the NRC.
Petition at 21-22.
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In opposition to the petition, Licensee herein provides this response, which is supported by, among other things, the att6ched Affidavit of Robert G. Kunkle, Director of SAFETEAM at Fermi-2
.(Attachment A hereto). As discussed below, under applicable legal standards Petitioners have utterly failed to establish a (Continued)
Director, Office of Nuclear Reactor Regulation. The Detroit Edison Co. (Enrico Fermi Atomic Power Plant, Unit 2), DD-86-10,
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24 N.R.C. 174 (1986); DD-85-4, 21 N.R.C. 546 (1985).
2/ On May 15, 1985, GAP filed with the Commission, on behalf of the Nuclear Awareness Network, a similar section 2.206 petition in Docket No. STN 50-482, challenging the Quality First Program at the Wolf Creek Generating Station.
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basis for the issuance of a show cause order or any other relief pursuant to 10 C.F.R. S 2.206.
l II. Standards for Deciding Whether a Show Cause Proceeding Should be Initiated Section 2.206 of the Commission's regulations p'rovides a mechanism whereby members of the public may request initiation of an enforcement action to modify, suspend, or revoke a license, or for such other action as may be proper. It also vests authority in the director of the appropriate NRC office to decide whether to institute an enforcement action by the issuance of a show cause order. The only criterion set forth in the rule itself for judging the sufficiency of a petition is the requirement that
"[t]he requests shall specify the action requested and set forth -
the facts that constitute the basis for the request." 10 C.F.R. 5 2.206(a).
The apparent reason for the absence of a more specific stan-dard in the regulation is that the decision to institute an en-forcement action is not an adjudicative one, but rather is a mat- ,
j ter of " prosecutorial" discretion. See Consolidated Edison Co.
of New York, Inc. (Indian Point Units 1, 2, and 3), CLI-75-8, 2 N.R.C. 173, 175 (1975). Nevertheless, the Commission has in pre-vious decisions provided guidance delimiting the exercise of this discretion. j
e In Indian Point, supra, the Commission affirmed a Director's decision denying a 2.206 petition. In so doing, the Commission stated that "[t]he Director correctly understood that a show cause order would have been required had he reached the conclu-sion that substantial health or safety issues had been raised.
. . . [A] mere dispute over factual issues does not suffice" as a basis for issuance of such an order. Indian Point, supra, 2 N.R.C. at 176 & n.2.E! This standard has been acknowledged in dicta by the D.C. and Seventh Circuits. Lorion v. NRC, 712 F.2d 1472, 1475 (D.C. Cir. 1983), rev'd on other arounds sub nom.,
Florida Power & Licht Co. v. Lorion, 105 S. Ct. 1598, 1601 (1985), on remand sub nom., Lorion v. NRC, 785 F.2d 1038, 1,041 (D.C. Cir. 1986); Rockford Leaoue of Women Voters v. NRC, 679 F.2d 1218, 1222 (7th Cir. 1982). -
The Commission has reiterated the " substantial health and safety issues" standard in Northern Indiana Public Service Co.
(Bailly Generating Station, Nuclear-1), CLI-78-7, 7 N.R.C. 429, 433 (1978), aff'd sub nom., Porter County Chapter v. NRC, 606 F.2d 1363 (D.C. Cir. 1979). In that case, the Commission also rejected a claim that the Director erred in failing to permit 3/ The directors have adhered to the " substantial health and safety issues" test. See, e.g., Philadelphia Electric Co. (Lim-erick Genere. ting Station, Units 1 and 2), DD-85-ll, 22 N.R.C.
149, 152 (1985); Washington Public Power Supply System (WPPSS Nuclear Project No. 2), DD-84-7, 19 N.R.C. 899, 923 (1984).
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k petitioner to comment on, respond to, or cross-examine the views of the NRC Staff:
(The Director] is not required to accord presumptive validity to every assertion of fact, irrespective of its degree of sub-stantiation, or to convene an adjudicatory proceeding in order to determine whether an adjudicatory proceeding is warranted.
Rather, his role at this preliminary stage is to obtain and assess the information he believes necessary to make that determina-tion. Provided he does not abuse his dis-cretion, he is free to rely on a variety of sources of information, including staff analyses of generic issues, documents issued by other agencies, and the comments of the licensee on the factual allegations.
Id. at 432-33.
In order to meet the " substantial health and safety -
issues" standard, a petitioner must do more than merely state its disapproval of NRC policy or its belief that the accused utility may be found to have been in violation of the Commis-sion's regulations. In order to satisfy the substantial health and safety issues standard, a petitioner must set forth evi-dence of violations of sufficient significance that the public l health and safety may be affected thereby. Thus, for example, in Limerick, supra, 22 N.R.C. at 166, the Director determined that the petit'oners' showing that the plant suffered from a j trend of operator errors did not amount to a significant safety i
I problem warranting a show cause order. The Director noted that errors may occur at a nuclear plant, but that most violations discovered through NRC inspections are of minor significance.
Id. at 161. If more significant violations are discovered, escalated enforcement action may be considered by the Commis-sion, including the imposition of civil penalties, short of instituting a show cause proceeding. See id. If, however, a truly major deficiency is identified through the inspection process, or otherwise, then the NRC could issue a variety of orders, including a show cause order, to assure appropriate re-medial action. See id. But, as the Director stated:
Isolated deficiencies in the licensee's program, however, do not necessarily under-mine the program to such an extent as to give rise to a significant safety concern.
What is required, when a violation is iden- .
tified, is a careful assessment as to the significance of the violation, its cause, and the corrective action taken to preclude recurrence. '
id. at 161-62 (footnote omitted).
Where, as in this case, the allegations in a section 2.206 petition are drawn primar.ily from the reported results of NRC inspection activities, show cause proceedings generally have been viewed as unnecessary. See, e.Q., Washincton Public Power Supply System (WPPSS Nuclear Project No. 2), DD-84-7, 19 N.R.C.
899, 022-23 (1984). This is because in such cases the peti- >
tioner does not seriously challenge the NRC Staff statement of l 1
the facts, but only disagrees as to the significance of those 1
facts and the nature or extent of enforcement action to be l
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taken. But, "[t]he choice of a remedy for a violation is
'within the sound judgment of the Commission, and not foreor-dained.'" . Consumers Power Co. (Midland Plant, Units 1 and 2),
DD-84-17, 10 N.R.C. 226, 231 (1984), quoting Petition for Emergency and Remedial Action, CLI-78-6, 7 N.R.C. 400, 406 (1978); see alsq, Duke Power Co. (Catawba Nuclear Station, Units 1 and 2), DD-85-9, 21 N.R.C. 1759, 1771 (1985). Thus, show cause proceedings or other formal adjudicatory proceedings are inappropriate forums for resolving wholly discretionary matters like the extent of enforcement action to be taken.
Consequently, even before reviewing Petitioners' allega-tions in' detail, it is clear that the Petition must fail. Pe-titioners have failed to present cogent evidence of any viola-tion of the Commission's regulations, let alone one which would '
warrant the~ institution of an enforcement proceeding. Indeed,
' Petitioners have ignored the NRC's explicit warning that spe-cific factual information must support the petition. In ac-knowledging receipt of GAP's preliminary investigation report on SAFETEAM, and SECOM's letter stating an intent to file a 2.206 petition, the Regional Administrator stated:
. . . you should be aware that specific factual information is required for pro-cessing a 2.206 petition. The GAP investi-gation report referred to additional in-formation concerning the allegations.
Whether or not you desire to pursue this matter under the 10 CFR 2.206 process you should provide all information obtained by l GAP related to safety issues so that they may be appropriately evaluated.
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4 Letter dated March 30, 1987, A. Bert Davis to Jennifer E.
Puntenney (Attachment B hereto). Where no specific factual basis is provided by petitioners to support a claim, further inquiry need not be made. Seoucyah Fuels Corp. (Gore, Oklahoma Facility), DD-86-13, 24 N.R.C. 587, 598 n.10 (1986), citino Limerick, supra, DD-85-11, 22 N.R.C. 149 (1985).
Not only have Petitioners ignored the Regional Administra-tor's request to provide more specific factual information, the 22-page petition contains considerably less than the 36 page GAP report filed in February. The only " facts" set forth as the basis for the petition are drawn from the NRC Staff's own documents on inspection activities in 1985, and have been ren-dered obsolete by subsequent improvements to the SAFETEAM pro-gram. The bulk of the petition is a legal and policy argument, generic in nature, on the role and administration of individual concerns programs at nuclear power plants.A The rulemaking forum is available to resolve such generic issues. See, e.o.,
Quality Technology Company Petition for Rulemaking, 52 Fed.
Reg. 1200 (1987). An enforcement proceeding against Licensee is not necessary to resolve these arguments.
1/ For example, Petitioners argue that by encouraging the in-dustry initiatives with concerns programs, the NRC is abdicating its regulatory responsibilities. Petition at 2, 7. Petitioners also cite the NRC's ". . . continued refusal to require worker allegation programs to be subject to the requirements of federal ,
regulations." Id. at 13.
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III. The Allegations in the Petition Do Not Raise Significant Health and Safety Issues A. Discrimination Acainst Individuals Asserting that workers have been " harassed, pressured, forced to quit, fired, or otherwise discriminated against," for participating in SAFETEAM, Petitioners find it "
. . . clear that SAFETEAM is more of a tool for management to eliminate dissent, than a tool for identifying and resolving allegations in a timely manner." Petition at 2. Petitioners offer not a single example of such an aggrieved worker, and do not cite to any Department of Labor or NRC Staff investigations or insp,ec-tions which have found discrimination because of SAFETEAM par-ticipation. -
Petitioners provide no specific criticism of SAFETEAM's procedure for protecting an individual's name, other than Peti-tioners' mistaken impression that names are turned over to man-agement, and Petitioners' conclusion that the investigative process itself compromises the individual's identity. See Pe-tition at 7, 18. As explained by Mr. Kunkle, the Fermi-2 SAFETEAM recognized from the outset that participating individ-uals' identities must be kept confidential. Kunkle Affidavit, 5 5. The individual's name is known only to the SAFETEAM in-terviewer and the secretary. The investigator, the Review
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Committee, and all others have access only to a concern identi-fication number. Id., 1 11, There undeniably is a tension, which Petitioners recognize only selectively, between protecting the individual's identity and the level of detail of investigative information sought.
As to nuclear safety concerns, it usually is quite feasible to 1
obtain facts adequate to assess the concern, without also sug-gesting the individual's identity.E/ Where it is not feasible to assess the concern and to protect the individual's name while assessing the concern, the original SAFETEAM interviewer of the concernee will contact the concerned individual for per-mission to proceed with the investigation. Kunkle Affidavit, 1 11.
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Petitioners claim they are interested in an honest commit-ment to protecting individuals who need anonymity, and "more than lip service to a principal (sic]." Petition at 19. Yet, Petitioners suggest the need for more detailed investigations and documentation, id. at 3, 6, while at the same time advocating that SAFETEAM files and documents should be in the public record, subject to public review and comment. Id. at
- 16. These internally inconsistent criticisms and proposals 5/ In this program, then, it is neither always appropriate nor always necessary to learn and document "who, what, when, where, how and why." Compare Petition at 3.
confirm-that Petitioners not only do not understand the facts, but also that they do not understand how to run an effective individual concerns program. In contrast, Licensee has struck an appropriate and reasonable balance between the need to pro-tect the individual's name, and the pursuit of a sound investi-gation of the concern.E/
B. Implementation Effectiveness
< Petitioners cite an OI report, three inspection reports, s $
and their own conclusions from unsubstantiated GAP interviews of workers, in support of their argument that SAFETEAM has not properly investigated individuals' concerns. Petition at 2-6.
It is unnecessary to burden the Director of NRR at this
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point with Licensee's assessment of the OI report, since the OI review of SAFETEAM was conducted more than two years ago -- in June, 1985.7/ The OI concerns received immediate attention from Licensee and other NRC Staff organizations. A task force 1
i s/ The NRC Staff has found that at the South Texas Project and l Comanche Peak Steam Electric Station, the confidentiality of the concerned individuals was appropriately protected by SAFETEAM, and did not appear to distract from the investigators' ability to evaluate concerns. NRC Inspection Report 50-498/85-18, - '
50-499/85-16 (Jan. 2, 1986) at 6; NRC Inspection Report 50-445/85-12, 50-446/85-08 (Feb. 6, 1986) at 8. Compare Petition i at 19.
7/ Memorandum for Ben B. Hayes from Harold G. Walker (July 31, 1985), Fermi 2 Nuclear Power Plant SAFETEAM review.
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of' personnel'from NRR,.I&E and Region III was at the site by June 27, 1985, to. perform a more detailed investigation of SAFETEAM concerns.for technical merit. The inspectors reviewed the SAFETEAM findings to determine if the investigative effort adequately addressed the concern and if the corrective action had been completed.. At the same time, Licensee performed an independent inspection of the SAFETEAM findings to verify ade-quacy of the investigation and corrective action. Licensee-agreed to-review 50% of the hardware and software safety-related concerns. The NRC inspectors reviewed a sam-pling of the remaining 50% of the safety-related concerns. NRC Inspection Report 50-341/85029 (DRP) (July 29, 1985) at 7-87 NRC Inspection Report 50-341/85037 (DRP) (Oct. 25, 1985) at 14.
The inspectors reviewed more than 10% of the total hard- '
ware and software safety-related concerns identified to SAFETEAM. During the inspection, Licensee expanded its review to approximately two-thirds of the safety-related concerns and over 50% of the non-safety related hardware concerns. Because of the additional inspections, there was an overlap between the Detroit Edison review and that performed by the NRC -- result-ing in roughly 85% of the concerns inspected by the NRC being l 1
previously reviewed by Detroit Edison. NRC Inspection Report 50-341/85037 at 14-15. The inspection identified some prob-lems, believed to be isolated examples, and these are cited by Petitioners. Petition at 4-5.
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Although some flaws were identified in the SAFETEAM, an overall good effort went into the SAFETEAM project. . With the supple-mented and augmented inspection effort by both DECO and the NRC, we were able to reach the same conclusions, although the inspectors found.it difficult for the SAFETEAM to reach their conclusions on some concerns based upon the originally. avail-able documentation in the packages.
Overall.the inspectors believe the packages were complete and well documented and the concerns were adequately addressed. .The licensee has since committed to improve the weaknesses identified in.the NRC and DECO inspections.
The results of this inspection and DECO inspection.were provided to NRC Region III and were used as the basis for regional input to the Commission briefing on July 9, 1985. -
NRC Inspection Report 50-341/85037 at 15.
Soon thereafter Licensee implemented a more effective pro-gram for screening and training SAFETEAM interviewers and in-vestigators, and provided more detailed procedures for imple-
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mentation of-the SAFETEAM program. Kunkle Affidavit, 1 13.
1 Consequently, the. Petition rests upon outdated criticisms of SAFETEAM program effectiveness. The NRC Staff and Licensee thoroughly inspected the program in 1985 when these criticisms arose, determined that the program fundamentally was sound, and Licensee implemented appropriate improvements to correct the deficiencies found. Clearly an enforcement proceeding is not needed now to rehearse this history.
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C. Quality Assurance Requirements Petitioners see-a " loophole" in the regulatory' process.
They appear to believe that because SAFETEAM is not a part of the formal Quality Assurance organization at Fermi-2, deficiencies ~ identified through the SAFETEAM program may be-ig-nored. Petition-at 8, 11-14. Petitioners claim "[t]his loop-hole allows large numbers of safety-related deficiencies to exist in-the files of the utility without requiring compliance with-federal regulations." Id. at 8. Apparently Petitioners believe there are federal regulations which require reporting of certain types of allegations to the NRC. Id. at 12.
Petitioners' several errors are significant and compound-ing. First, there is no federal regulation requiring a license ,
or permit holder to report mere allegations to the NRC. See, e.a., 10 C.F.R. SS 50.36(c), 50.55(e), 50.72, 50.73. Second, the reporting requirements which do apply do not distinguish among the means by which the information about a deficiency comes to the licensee. The reporting obligations apply whether or not the Quality Assurance organization identifies the defi-ciency. Indeed, those obligations apply if SAFETEAM identifies a reportable deficiency, and procedures are in place to ensure that such a deficiency is reported to the NRC. See Kunkle Af-fidavit, 11 17-18.
4 SAFETEAM is not relied upon to meet the NRC's quality as-surance requirements for Fermi-2, and at the same time does not relieve the QA organization and other Fermi-2 organizations of their own responsibilities. Id., 11 6, 17. In short, the
" loophole" does not exist. Petitioners simply have confused quality assurance and reporting requirements, and their request that Appendix B to 10 C.F.R. Part 50 be applied to SAFETEAM makes no sense.
D. Accountability Just as Petitioners seek inconsistent ends when they urge strict confidentiality coupled with highly detailed inquiries and public records, Petitioners also propose an individual con-
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cerns program which is both accountable to and independent from those responsible for safe plant operation. See Petition at 8,
- 12. "
The SAFETEAM was established, is staffed and managed inde-pendently of the Fermi-2 organization. Of course, Licensee must retain responsibility for the program, just as it is re-sponsible for other activities which could affect safe opera-tion of the plant. Detroit Edison management conducts routine oversight of the program. Kunkle Affidavit, 11 5, 19. The files of SAFETEAM other than those with concernee names are also available for NRC audit and inspection. As the NRC 1 l l
1 inspectionLand i' investigation reports discussed above amply dem-
- onstrate, the NRC hasLalready-conducted substantial oversight.
of SAFETEAM activities.
It is clear, then, that SAFETEAM is accountable to
. Licensee,'and~in turn to the regulator which is accountable to
' the public. -The program is not, need not, and should not be j . accountable to GAP, which is overseen only by"itself.
E. Relief Recuested Petitioners'are correct that the NRC has encouraged the industry initiatives which are embodied by the numerous indi-vidual concern programs established at nuclear power plants.
See, e.a., Houston Lichtino & Power Co. (South Texas Project, Units 1 and 2), LBP-86-15, 23 N.R.C. 595, 638, _746-47 (1986),
aff'd, ALAB-849, 24 N.R.C. 523 (1986); carolina Power & Light Co. .(Shearon Harris Nuclear Power Plant), LBP-86-ll, 231N.R.C.
294,~342 (1986), aff'd, ALAB-852, 24 N.R.C. 532 (1986). If the NRC were now to take over or otherwise to direct these pro-grams, not only would the programs not succeed as they have in their voluntary setting, but utility initiative would be dis-couraged. More importantly, however, neither the law nor the facts support the relief requested in the Petition.
The NRC should not take possession of all SAFETEAM files, conduct its own review, and make them all public. First, the l
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6 l Staff has already reviewed many SAFETEAM files and has agreed with the conclusions reached. Second, Petitioners have not identified even a single safety concern brought to SAFETEAM which Petitioners claim has not been satisfactorily resolved.E!
Third, public review of SAFETEAM files might compromise l
employee confidentiality and discourage participe. ion in the program.
The NRC should not require that SAFETEAM allegations be
" processed" by Licensee in accordance with Appendix B to 10 C.F.R. Pstt 50. This request is meaningless, since deficiency reporting requirements apply to Licensee independent of the quality assurance regulations. .
Finally, the NRC should not dictate SAFETEAM's communica-l tions a employees. The employees are fully informed of the '
available opportunities to report concerns, and are not misled into choosing SAFETEAM. See Kunkle Affidavit, 11 8-9.
i 8/ While it is not a part of the Petition, and therefore is not relied upon by the Petitioners, a GAP report released earlier this year listed 28 allegations which GAP claimed came from 49 individuals formerly asssociated with Fermi. SAFETEAM has inves-tigated these concerns and found that they have been appropri-ately dispositioned. Kunkle Affidavit, 1 21.
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l-l IV. Conclusion For a11 of the foregoing reasons, the Petition t,hould be denied.
Respectfully submitted, Thomas A. Baxter, P.C.
SHAW, PITTMAN, POTTS & TROWBRIDGE 2300 N Street, N.W.
Washington, D.C. 20037 (202) 663-8090 Counsel for The Detroit Edison Company Dated: July 21, 1987
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CERTIFICATE OF SERVICE I
'87 3123 A10:47 I hereby certify that copies of " Licensee's Response to the PetitionoftheSafeEnergyCoalitionofMichidkna.andtheSis- ,
,a ters, Servants of the Immaculate Heart of Mary Congregation" with Attachments were served this 21st day of July, 1987, by deposit in the U.S. mail, first class, postage prepaid, except as other-wise indicated, upon the following:
Mr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. A. Bert Davis (Federal Express) '
Regional Administrator U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 -
Assistant General Counsel for Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. John J. Stefano (Hand Delivery)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Edward G. Greenman (Federal Express)
U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Mr. Walter G. Rogers Senior Resident Inspector U.S. Nuclear Regulatory Commission 6450 N. Dixie Newport, Michigan 48166 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555
'4 Government Accountability Project 1555 Connecticut Avenue, N.W.
Suite 200 Washington, D.C. 20036 Thomas A. Baxter ed 4
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