ML19209A323

Affidavit of Bd Withers Re Intervenor Coalition for Safe Power Contention 17 & Intervenor Consolidated Intervenors Contention 2d.Prof Qualifications Encl

ML19209A323
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: ML19209A315 ML19209A317 ML19209A318 ML19209A319 ML19209A321 ML19209A322 ML19209A323 ML19209A328 ML19209A336 ML19209A341 ML19209A347 ML19209A349 ML19209A353 ML19209A358 ML19209A363
References
TAC-07551, TAC-11299, TAC-7551, NUDOCS 7910030603
Download: ML19209A323 (7)

Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE 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. 17 AND CONSOLIDATED INTERVENOR'S CONTENTION NO. 2D 1.

My name is Bart D.

Withers.

I am employed by P 7rt-land 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 participated 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 witness and have been responsible for the BN-21 1086 046 78200so({[2/;p

CFSP 417 and CI #2D Page 2 of 6 B.

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 add ess, in part, Coalition for Safe Power's Contention No. 17,. Ich reads as follows:

Performance of modification work will hamper the ability of plant operators to respond to any emergency properly and thus poses an undue risk to the public health and safety.

and Consolidated Intervenors' Contention No. 2d which reads as follows :

Licensee has not shown that there will be adequate fire protection at the Trojan plant during modifications in the following areas:

d)

Sufficient fire brigade access exists and will be maintained.

4.

The plan for the modification program has been devel-oped to be compatible with Plant operations under both normal and emergency conditions.

The affidavit of Mr.

E.

W.

Edwards on Coalition for Safe Power's Contention No. 17 identifies those areas where the modification work will be performed and also identifies potential interferences with access.

This affidavit will explain how PGE has identified all instances in which the modification work might interfere with the ability of Plant operators to respond to an emergency, in-cluding a fire, and will explain why the modification work will not cause such interferences.

BN-21 1086 047

s CFSP #17 and CI #2D Page 3 of 6 B.

D.

Withers 5.

In order to respond properly to an emergency, Plant operators must be able to react to visual and audible signals provided by Control Room instrumentation.

In some cases per-sonnel may have to operate equipment from remote locations outside the Control Room, thus, access to such locations must be assured.

Therefore, proper response to any emergency re-quires that Plant personnel be able to function properly within the Control Room and to reach remote locations in other parts of the Plant.

In addition, fire brigades must have access to a fire, wherever it might be located.

6.

PGE has reviewed Mr. Edwards' affidavit and has deter-minted that it correctly identifies all areas of the Plant where the modification work will be performed and all potential interferences with access by the modification work.

7.

In the event of a fire or other emergency within any of the areas where the modification work will be performed, Plant personnel would need access within such area.

Should such a fire or other emergency arise, modification work would be halted and construction workers would be instructed to leave the area and report to their supervisor outside the Plant buildings to await further instructions.

This will be part of the instruction given to workers on site for the modi-fication program, and the presence of these workers would not hamper the ability of Plant personnel to take effective action with respect to a fire or o':her emergency within such areas.

BN-21 1086 048

CPSP #17 & CI #2D Page 4 of 6 B.

D.

Withers 8.

PGE has also reviewed the modification work to ascer-tain whether there are any remote locations (as discussed in paragraph 5 above) within or adjacent to the work areas ident-ified in Mr. Edwa rds ' affidavit to which Plant personnel may need access during an emergency.

The only such remote loca-tions are:

East Emergency Diesel Generator Room at el. 45' in the Turbine Building West Engineered Safety Feature Switchgear Room at el.

69' in the Turbine Building Load Centers B12 and B06 (non-safety-related) at el.

69' in the Turbine Building East Electrical Auxilia_ ries Rocm and Batteries at el.

61'/65' in the Coatrol Building 9.

For each of the remote locations identified above, PGE has determined that at least one alternate access path is available which would be totally unobstructed by the modifica-tion work.

Accordingly, the modification work will not com-promise the ability of Plant personnel to reach such locations during an emergency.

10.

With respect to each of the specific instances identi-fied in paragraphs 6-8 of Mr. Edwards' affidavit where the modification work could involve potential interference with access paths, we have again determined that the modification work will not compromise the ability of Plant personnel to respond during an emergency, including a fire.

The limitation on access at el. 45' in the Turbine Building (Edwards' affida-vit, paragraph 6) is not in an area where safety-related BN-21 1086 049

CFSP #17 and CI #2D Page 5 of 6 B.

D.

Withers equipment is located and would not limit personnel access.

The stairway to the Visitors' Gallery above the Control Room and the ladder to the Turbine Building roof and crane cab (Edwards' affidavit, paragraph 7) do not provide access to re-mote locations containing safety-related equipment or to any equipment needed for normal operation.

In any event, there is another existing access to the Visitor's Gallery, and as described in the affidavit of Mr. Edwards' (paragraph 7) another access will be provided to the Turbine Building roof and crane cao.

Finally, the potential interferences caused by workers in aisles ( Ed wa rd s ' affidavit, paragraph 7) will be no greater than those one would expect during routine Plant maintenance.

Even so, as described above, should an emergency arise, includ-ing a fire, modification work will be halted and construction workers will be instructed to leave.

11.

Only a small portion of the modification work will take place at el. 93' in the Control Building adjacent to the Control Room.

If noise from work in this area interferes with operations, the Shift Supervisor will halt the work and work methods will be changed to reduce noise to acceptable levels.

Additionally, a few construction workers would be required to be on the Control Room side of the walls during the drilling and bolting operations.

These individuals would be working away from areas requiring immediate operator attention or action.

Furthermore, their presence and actions in this area would be controlled by the Shift Supervisor to preclude their inadvertently interfering with operations in the event of an emergency.

Thus, the modification work will not hamper BN-21 1086 050

CFSP #17 and CI #2D Page 6 of 6 B.

D.

Withers the ability of operators in the Control Room to respond to an emergency.

12.

The foregoing discussion demonstrates that any poten-tial impacts of the modification work on the ability of Plant personnel to respond to an emergency or fire have been identi-fied, and that all necessary precautiens will be ta).en to pre-clude any adverse impacts of the modification work on the ability of such personnel to respond properly.

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 and belief.

JAWL BART D.

WITHERS STATE OF OREGON

)

County of

'alb#o[ )

SCRIBED AND SWORN TO before me this j[E day of SUp/< c., <_,#

/

1979.

a.* d u k n

PUBLIC FOR ORSC,////f 0N NOTARY

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My Commission Expires

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/

BN-21 1086 051

.e PROFESSIONAL QUALIFICATIONS OF BART D. WITHERS PRESENT POSITION General Manager, Trojan Nuclear Plant.

EDUCATION Idaho State University - BS in Chemistry (1956);

Naval Reactor Prototype Traf r.ing, Idaho Falls, Idaho, A1W (1963), S5G (1972); Westinghouse PRR 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 /0eneral 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 r. clear reactors.

He entered Westinghouse's training program and quali-fied as an Engineering Officer 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 transferred 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.

108r6 052