ML19339B540
| ML19339B540 | |
| Person / Time | |
|---|---|
| Site: | Bailly |
| Issue date: | 11/06/1980 |
| From: | Lynch M Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19339B541 | List: |
| References | |
| NUDOCS 8011070169 | |
| Download: ML19339B540 (7) | |
Text
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UNITED STATES OF AMERICA 11/6/80 NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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)
NORTHERN INDIANA PUBLIC
)
Docket No. 50-367 SERVICE COMPANY
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(Construction Permit Extension)
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(Bailly Generating Station,
)
Nuclear-1)
)
AFFIDAVIT OF M. DAVID LYNCH I, M. David Lynch, being duly sworn, state as follows:
1.
I am employed by the U. S. Nuclear Regulatory Commission as a Project Manager in the Division of Licensing, Office of Nuclear Reactor Regu-lation.
2.
I have been -the project manager assigned to the Bailly Generating Station since 1973. The NRC Staff evaluation of the Bailly construc-tion permit extension application is being performed under my direc-tion and supervision.
4.
I have no plans to be in'the Chicago area in the foreseeable future.
My required deposition in Chicago on one or more occasions, including travel time, could significantly limit my ability to adeauately meet my responsibilities to the agency and my family in the respects ex-plained below.
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5.
I am the Staff's Project Manager on two active projects, Bailly and WNP-2,- I am required to support both projects equally in general, and each project fully as'the need dictates. Construction of the WNP-2 project, which is in the operating license stage of review, has been halted pending staff approval of the proposed resolution of problems affecting a major plant structure, the biological shield wall.
It is my responsibility to direct the Staff's review leading to a deci-sion on the proposed resolution and, thereafter, write the official response to the licensee.
6.
This particular review effort, which is extremely critical in the con-struction schedule of the WNP-2 project, may be completed before the matter of the specific location for my deposition is resolved. How-ever, it is typical of many other outstanding items concerning this project for which I am' personally responsible. These include:
(a) Guiding the review of the recently discovered capable fault in Gable Mountain, a geologic structure within 12 miles of the WNP-2 site; (b)
Initiating and completing the start of the second round of our review questions for the WNP-2 project; (c) Evaluating the completeness and thoroughness of input for the Staff's Draft Environmental Statement and, thereafter, preparing this document; and (d) Evaluating the canpleteness and thoroughness of the input for the Staff's _ Safety Evaluation Report for WNP-2 and, thereafter, preparing this document.
7..
I am charged with similar dutics on the Bailly project. Giving my deposition (s) in Chicago could also lead to a significant delay in perfonning and executing my functions on the Bailly project. These review functions include:
(a) Guiding the ~ continuing Staff review of the Bailly pile pro-posal, including the revisions to the QA/QC manual and com-pletion of the structural review leading to the ace.eptance of the licensee's pile loads; (b) Evaluating the effectivness of the placement of the produc-tion piles, if this function is authorized; (c) Responding to frequent Congressional, Commission and public inquiries regarding the Bailly project; (d) Guiding the preparation of the staff's evaluation of the construction permit extension request, including the Environ-mental Impact Assessnient; and (e) Assist in the staff's production of documents pursuant to the Intervenors' discovery request.
8.
While.it is possible to have other project managers w1 hin the Division of Licensing fulfill some of my duties while I am on travel, the amount 4
of such assistance that.can be provided is severely limited by two main considerations. First, many of my responsibilities require detailed knowledge of project-specific information which cannot be communicated in the short period of time available for reassigning a given task.
Secondly, each of the other project managers is extremely overloaded with responsibilities for their own projects.
o-d 9.
My branch chief could assume a limited amount of my duties while I am on travel but the amount of this assistance is limited since he is responsible for the management of 11 people under him as well as assuring the proper management of the 25 cases within his branch. Such assistance would also be limited since the branch chiefs depend on the project managers for the detailed knowledge of any single project.
10.
In recognition of the intense pressures placed on my time by the steadily escaiating demands of the Bailly project, my management has assigned an intern, Kenneth Kiper, to assist me. While he can assume some of m3 responsibilities during my absence, this assistance is limited by his relative inexperience. He has been a member of the NRC Staff for eight months and joined us immediately upon graduation from school. Accordingly, my absence from Bethesda would reduce the effectiveness of Mr. Kiper's contribution since part of his effective-ness is dependent on my guidance.
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- 11. Apart from my job requirements, I am presently faced with an intensely personal problem which dictates that I minimize, to the maximum extent possible, my absence from the Washington metropolitan area. My mother is afflicted with cancer and has less than eight months to live. She has undergone intensive radiation therapy during the first half of 1979 which injured her health but was unsuccessful. She is presently re-ceiving chemotherapy using an experimental combination of chemicals, including the use of-platinum, which has further damaged her health but has not had, nor will it have, any therapeutic value. The main
purpose of the present treatment is palliative Q.e_., to minimize the otherwise intense pain) recognizing that death may be hastened as a e nsequence. Accordingly, it is my intention to maintain close com-munication with my mother and to be with her during her last few days.
This goal will be best achieved by limiting my absence from the Washing-ton area during the next few months.
- 12. When professional travel, such as site visits, are required in the future, I intend to schedule them at the end of the week, thereby minimizing the impact. Where possible, site visits will be made by other staff members as was recently done on the WNP-2 project.
- 13. A copy of my professional qualifications is already on record in this proceeding.
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7 avid Lync n.
Subscribed and sworn to before me this 6th day of November,1980 T
Notar /ublic
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My Commission expires: July 1, 1982
- UNITED STATES OF. AMERICA-NUCLEAR REGULATORY C0:0'ISSION BEFORE THE ATOMIC' SAFETY N!D' LICET: SING BOARD, In the Matter of ~
Doc' et "e. 50-367 NORTHERN INDIANA PUBLIC
)
k SERVICE COMPANY-(Constraction Permit Extension)
(Bailly Generating Station,
)
Nuclear-1)
)
CERTIFICATE,0F SERVI _C,E I hereby certify that copies of "NRC STAFF RESPONSE T0 PORTER COUNTY CHAPTER INTERVENORS' MOTION TO COMPEL DISCOVERY AND MOTION FOR PROTECTIVE ORDER" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Comission's internal mail system this 6th day of November,1980.
- Herbert Grossman, Esq., Chairman Edward W. Osann, Jr., Esq.
Atoaic Safety and Licensing Board Panel Suite 4600 U.S. Nuclear Regulatory Commission One IBM Plaza Washington, D.C..
20555 Chicago, Illinois 60611
- 0r. Richard F. Cole Robert L. Graham, Esq.
Atomic Safety and Licensing Board Panel One IBM Plaza U.S. Nuclear Regulatory Commission 44th Floor Washington, D.C..
20555 Chicago, Illinois 60611
- Mr. Glenn 0. Bright George and Anna Graboeski Atomic Safety and Licensing Board-Panel 7413 W.136th Lane U.S. Nuclear Regulatory Commission-Cedar Lake, Indiana 46303 Washington, D.C.
20555 Dr. George Schultz Kathleen H. Shea, Esq.
867 East Cool Spring Street Lowenstein, Newman, Reis, Axelrad Michigan City, Indiana 46360 and Toll 1025 Connecticut Avenue, N.W.
Diane B. Cohn, Esq.
Washington, D.C.
20036 Suite 700 2000 P Street, N. W.
Robert J. Vollen, Esq.
Washington, D. C.
20036 c/o BPI' i
109 North Dearborn Street Chicago, Illinois' 60602-
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i 2-John Van Vranken, Esq.,. Chief l
- Atomic Safety and Licensing
-North.ern Region Board Panel Environmental Control Division U.S. Nuclear Regulatory Commission 188 West Randolph Street.
Washington, D.C.
20555 Chicago,_ Illinois 60601
- Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington,.D.C. -20555 Clifford Mezo, Acting President.
- Docketing and Service Section Local 1010 Office of the-Secretary United Steelworkers of America U.S. Nuclear Regulatory Cennission 3703 Euclid Avenue Washington, D.C.
20555 East Chicago, Indiana 46312 William H. Eichhorn, Esq.
Eichhorn, Morrow & Eichhorn 5243 Hohman Avenue Haanond, Indiana 46320'
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i Steven C. Goldberg O Counsel for NRC Staff i
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