ML19209A319
| ML19209A319 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/27/1979 |
| From: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML19209A316 | List: |
| References | |
| NUDOCS 7910030591 | |
| Download: ML19209A319 (6) | |
Text
UNITED STATES OF AMERICA 6
NUCLEAR REGULATORY COMMISSION BuluRE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
PORTLAND GENERAL ELECTRIC COMPANY,)
Docke t No. 50-344 et al.
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(Control Building
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Proceeding)
(Trojan Nuclear Plant)
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AFFIDAVIT OF BART D.
WITHERS
_ COALITION FOR SAFE POWER'S CONTENTION NO. 3 1.
My name is Bart D. Withers.
I am employed by Portland General Electric Company (PGE) as General Manager of the Trojan Plant.
I have been employed in this position since January 1, 1977.
My professional qualifications are contained in an attachment to this affidavit.
This affidavit was pre-pared by me or under my supervision.
2.
I was assigned as Trojan Nuclear Plant General Manager at the time the deficiency with the Control Building walls was identified.
I participated in many of the meetings between PGE and Bechtel Power Corporation (Bechtel) concerning the capabilities of the building in its as-built condition and the effects of any proposed building modifications on the plant operational capabilities.
As a member of the Plant Re-view Board and Nuclear Operations Board, I pa' bicipated in the review of the plant modifications, procedure changes, and per-sonnel training required for interim operation.
I attended and participated in the ASLB hearings concerning interim oper-ation as a PGE witntss and have been responsible for the BN-17 N
1910080 r) 1086 02-3
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D.
Withers operation of the Trojan Nuclear Plant since it returned to operation pending modification of the Control Building.
3.
The purpose of this affidavit is to address, in part, Contention No. 3 of the Coalition for Safe Power, which reads as follows:
Plant Staff review of proposed modifications is inadequate to assure no violations of Technical Specifications will occur.
4.
The affidavit ou Mr.
E.
W.
Edwards of Bechtel on this contention describes the purpose of work plans which will be prepared by Bechtel for each portion of the modification work.
In this affidavit I will describe the PGE Plant Staf f and explain the review of the Becthel work plans that will be conducted by members of the Plant Staff to assure that none of the work tasks will violste any of the Technical Specifications of the Operating License.
5.
The Plant Staff consist of the Plant operators and the support staffs, which include engireers, technicians, main-tenance craftsmen, warehouse and dministrative personnel and quality assurance incpectors.
The general function of the Plant Staff is t0 operate and maintain the Plant in a safe manner consistent with the Operating License and Technical Specifications.
As described below, within the Plant Staff the responsibility for review of work plans for consistency with Technical Specifications and the Plant's administrative BN-17 1086 026
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D.
Withers procedures is entrusted to the Plant Quality Assurance Staf f headed by the Quality Assurance Supervisor.
6.
The limited purpose of the Plant Staff's review of work plans is to assure that the work itself, as specified in the work plans, will comply with Technical Specifications and the Plant's administrative controls.
This type of.eview is not unique to the modification work; it is routinely conducted for any work plan which governs quality related work activities onsite.
The Plant Staff's review of work plans for the modifi-cation work is not a review of either the adequacy or the effectiveness of the modification design.
It does not involve preparation of the safety evaluation of the modification work, and it is not a review of compliance with quality assurance requirements.
Those additional separate reviews are described in PGE-1020, Sections 4.3.1, 4.3.2, and 6, respectively.
7.
After Bechtel prepares the work plans, they will be submitted to PGE's Resident Engineer, whose approval is re-quired before any work can be performed.
As explained in the affidavit of Mr. Edwards on this contention, these work plans are detailed written instructions and procedures for the performance of specific construction tasks.
The work plans can include design drawings and specifications, as well as supplier documents and applicable codes and standards or references thereto.
8.
Under the PGE's administrative procedures, prior to any approval of work plans by the Resident Engineer he must BN-17 1086 027
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D.
Withers first obtain the written concurrence of the Plant's Quality Assurance Staff.
The Plant Quality Assurance Supervisor, and/or members of his Staff, will review each construction task for performance of the modification work, as set out in the work plans, against the Technical Specifications and Plant administrative procedures taking into account the oper-ating status of the Plant.
The members cf the Plant's Quality Assurance Staff who will review the work plans have back-grounds in Plant operation, and performance of their duties routinel-, requires identification of Technical Specifications applicable to activities in and around the Plant.
Their experience encompasses related disciplines such as radiation protection and welding.
If their review identifies questions concerning the work to be done that requires consultation with additional disciplines, they have ready access to other personnel within the Plant Staff and within PGE's engineering, design and construction staffs.
Should the Plant Staff's review reveal any aspect of the wcrk which would conflict with a Technical Specification or Plant administrctive procedures, that aspect will be changed.
9.
The review by the Plant Staff of Bechtel's work plans will assure that the planned work will not violate Technical Specifications of the Plant's administrative procedures.
If any conflicts are identified, Bechtel's work plans will be changed so tha t.
the work will be dcne in compliance with the Technical Specifications and Plant administrative procedures.
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D.
Withers I,
Bart D. Withers, of lawful age, being first duly sworn, state that I have reviewed the foregoing affidavit, and that the statements contained therein are true and correct to the best of my knowledge arid belief.
13 ALT D. W ITilERS STATE OF OREGO!1
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Co un ty o f,'/EdCc,_ d ))
ss.
SUBSCRIBED AIID SWOR!! TO before me this j7bI day of
/7t c a o,F 1979.
$at 4 k Yds. k NOTARY PUBLIC FOR ORECON My Commission Expires f/9/ff B!1-17 1086 029
PROFESSIONAL QUALIFICATIONS OF BART D. WITRERS PRESENT POSITION General Manager, Trojan Nuclear Plant.
EDUCATION Idaho State University - BS in Chemistry (1956);
Naval Reactor Prototype Training, Idaho Falls, Idaho, AlW (1963), S5G (1972); Westinghouse PWR Simulator Training (1974).
PROFESSIONAL DATA Registered Professional Engineer, California; Member, American Nuclear Society.
SUMMARY
1956-1962 Chemist 1962-1967 Watch Officer and Shif t Supervisor 1967-1969 Operations Manager 1969-1971 Operations Evaluation Manager 1971-1972 Staff Management 1972-1973 Plant Manager 1974-1976 Assistant Plant Superintendent 1977-1979 Plant Superintendent / General Manager EXPERIENCE Mr. Withers has been employed by Portland General Electric Company since 1974. His first 3 years were spent as Assistant Superintendent for the Trojan Nuclear Plant and since January 1, 1977 he has been the Plant Superintendent / General Manager for the Trojan Nuclear Plant.
Mr. Withers was employed by Westinghouse Electric Corporation for 16 years in various positions related to operation and management of nuclear reactors.
He entered Westinghouse's training program and quali-fied as an Engineering Of ficer of the Watch supervising control room operation of a Naval Reactor Prototype.
Mr. Withers served as a Shif t Supervisor and then Operations Manager for a naval reactor prototype.
He was trsnsferred to the Bettis Atomic Power Labora-tory as Manager of Operations Evaluation.
Mr. Withers worked in Staff Management of Naval Core Manufacturing before being assigned as the Plant Manager for the S5G Naval Reactor Prototype.
Before joining Westinghouse, Mr. Withers worked 2 years for Phillips Petroleum as a chemist at a plant which processed spent reactor fuel.
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