ML022760126

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Tennessee Valley Authority'S Submission of Exhibits
ML022760126
Person / Time
Site: Browns Ferry, Watts Bar, Sequoyah  Tennessee Valley Authority icon.png
Issue date: 09/30/2002
From: Marquand B
Tennessee Valley Authority, Winston & Strawn
To:
Atomic Safety and Licensing Board Panel
Byrdsong A T
References
+adjud/rulemjr200506, 50-259-CIVP, 50-260-CIVP, 50-296-CIVP, 50-327-CIVP, 50-328-CIVP, 50-390-CIVP, ASLBP 01-791-01-CIVP, EA-99-234, RAS 4891
Download: ML022760126 (4)


Text

I r- s If,4 49W DOCKETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION October 1, 2002 (3:48PM)

ATOMIC SAFETY AND LICENSING BOARD OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF IN THE MATTER OF ) Docket Nos. 50-390-CivP;

) 50-327-CivP; 50-328-CivP; TENNESSEE VALLEY AUTHORITY ) 50-259-CivP; 50-260-CivP;

) 50-296-CivP

)

(Watts Bar Nuclear Plant, Unit 1; ) ASLBP No. 01-791-01-CivP Sequoyah Nuclear Plant, Units 1 & 2; )

Browns Ferry Nuclear Plant, ) EA 99-234 Units 1, 2 & 3) )

TENNESSEE VALLEY AUTHORITY'S SUBMISSION OF EXHIBITS Pursuant to the request of the Atomic Safety and Licensing Board (Board), Tennessee Valley Authority (TVA) has redacted TVA Exhibit Nos. 24, 39, 55, 56, 93, 94, 149, and Joint Exhibit Nos. 22 and 23. TVA is submitting the three official record copies to Judge Bechhoefer. Copies are also being sent to Judge Bechhoefer and Judge Young. The NRC Staff and Judge Cole indicated that they did not want a redacted copy.

In addition, pursuant to the Board's ruling, TVA has prepared summaries of TVA Exhibit Nos. 83-96, 109, and 110. TVA is submitting to Judge Bechhoefer the three official record copies of the summaries for inclusion in the record in the place of the business records which were originally offered into evidence during the hearing. Copies are also being sent to Judge Bechhoefer, Judge Young, Judge Cole, and the NRC Staff.

Finally, TVA tenders herewith into evidence TVA Exhibit 75, an extract from the Institute of Nuclear Power Operation's (INPO) written evaluation of TVA's Sequoyah Nuclear 1

T-empjal-- ;ecy-05'

-t Plant performed during the weeks of September 28 and October 5, 1992. On September 9, 2002, Robert J. Beecken, the former Sequoyah plant manager testified that he became critical of Fiser's management skills, in part, due to findings by INPO (See transcript page 4799, line 14; page 4800, line 3; page 4821, line 11; page 4822, line 2). During Mr. Beecken's cross-examination, counsel for NRC Staff asked questions which implied that INPO had not made any findings regarding the Chemistry program at Sequoyah (See Transcript page 4825, line 9; page 4828, line 20). TVA Exhibit 75 corrects any false impression that counsel's questions may have created since it shows that INPO in fact made the three findings discussed in the December 9, 1992, tape-recorded conversation Fiser had with Mr. Beecken (See Joint Exhibit 27 at 50-58; and TVA Exhibit 148). TVA is submitting herewith to Judge Bechhoefer 2

the three official record copies of TVA Exhibit 75. Copies are also being sent to Judge Bechhoefer, Judge Young, Judge Cole, and the NRC Staff.

Respectfully submitted, September 30, 2002 Maureen H. Dunn General Counsel Office of the General Counsel Tennessee Valley Authority Thomas F. Fine 400 West Summit Hill Drive Assistant General Counsel Knoxville, Tennessee 37902-1401 Facsimile 865-632-6718 John E. Slater Senior Litigation Attorney Brent R. Marquand Senior Litigation Attorn Telephone 865-632-4251 Of Counsel:

David A. Repka, Esq. Attorneys for Tennessee Valley Authority Winston & Strawn 1400 L Street, NW Washington, D.C. 20005 3

II CERTIFICATE OF SERVICE I hereby certify ihat copies of TVA's submission of exhibits has been served on the following persons by Overnight Messenger.

Administrative Judge Administrative Judge Charles Bechhoefer, Chairman Richard F. Cole U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel Two White Flint North Two White Flint North 11545 Rockville Pike 11545 Rockville Pike Rockville, Maryland 20852-2738 Rockville, Maryland 20852-2738 e-mail address: cxb2@nrc.gov e-mail address: rfcl~nrc.gov Administrative Judge Dennis C. Dambly, Esq.

Ann Marshall Young Jennifer M. Euchner, Esq.

U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Office of the General Counsel Two White Flint North One White Flint North 11545 Rockville Pike 11555 Rockville Pike Rockville, Maryland 20852-2738 Rockville, Maryland 20852-2738 e-mail address: amy~nrc.gov e-mail address: dcd~nrc.gov e-mail address: jme~nrc.gov Office of Commission Appellate Adjudication (w/o exhibits) Mr. William D. Travers (w/o exhibits)

U.S. Nuclear Regulatory Commission Executive Director of Operations One White Flint North U.S. Nuclear Regulatory Commission 11555 Rockville Pike One White Flint North Rockville, Maryland 20852-2738 11555 Rockville Pike Rockville, Maryland 20852-2738 This 30th day of September, 2002.

Attorney for Tennessee Val y Authority 4