ML19341C891
| ML19341C891 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/02/1981 |
| From: | Gutierrez J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8103040416 | |
| Download: ML19341C891 (5) | |
Text
M March 2, 1981 lh!N'.,.
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UNITED STATES OF AMERICA s
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BEFORE THE ATOMIC SAFETY AND LICENS'.NG BOARE(
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In the Matter of
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N HOUSTON LIGHTING AND POWER COMPANY.
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50-499 (South Texas Project, Units 1 and 2)
IDENTIFICATION OF STAFF WITNESSES AND SUBSTANCE OF TESTIMONY By Board Order dated December 2,1980, the parties were directed to identify witnesses, including the substance of testimony, on or before March 2,1981.
Pursuant to that Order, the ".aff
- lby submits the following list of witnesses and the subject matter each will address.
A)
Panel 1 William C. Seidle, Chief, Reactor Construction and Engineering Support Branch (RC&ESB), Region IV.
William A. Crossman, Chief, Projects Section, RC&ESB, Region IV.
William G. Hubacek, Reactor Inspector, Region IV.
Robert G. Taylor, Reactor Inspector, Region IV.
H. Shannon Phillips, Resident Reactor Inspector, South Texas Project.
Panel I will offer testimony relevant to the inspection and enforcement iiistory of construction activity at the South Texas Project up to I&E Report 79-19 and the Staff Show Cause Order issued April 30, 1980.
Investigative findings which led to the fonnation of the special inspection team which drafted I&E Report 79-19 will be stressed.
In addition, allegations set forth in CCANP/CEU Contentions 1 and 2 will be addressed in part by this Panel's testimony.
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B)
Panel 2 William C. Seidle, Chief, RC&ESB, Region IV.
Robert E. Shewmaker, Senior Construction Specialf st.
H. Shannon Phillips, Resident Reactor Inspector, South Texas Project.
D. W. Hayes, Chief, Engineering Support Section, Region III.
Panel 2 will offer testimony relevant to the formation of the special inspection team which prepared I&E Report 79-19, the manner in which the investigation was conducted, the findings of that investigation and the enforcement actions chosen as a result of those findings.
Testimony will stress the items set forth in the Staff Show Cause Order of April 30, 1980, and the Notice of Violation accompanying the Order.
C)
Panel 3 William C. Seidle, Chief, RC&ESB, Region IV.
William A. Crossman, Chief, Projects Section, RC&ESB, Region IV.
H. Shannon Phillips, Resident Reactor Inspector, South Texas Project.
William G. Hubacek, Reactor Inspector, Region IV.
Ramon E. Hall, Chief Engineering Support Section, RC&ESB, Region IV.
Panel 3 will offer testimony relevant to the corrective actions proposed by the Applicant as a result of the Show Cause Order and the Notice of Violation.
In addition, Staff follow-up inspection activity will be addressed for each item cited in the Show Cause Order and the Notice of Violation to ensure proposed corrective actions have been implemented and steps have been taken to prevent recurrence of similar problems.
The Applicant's inspection and enforcement history relative to the construction activity at the South Texas Project subsequent to the Show Cause Order will also be the subject of testimony.
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D)
John W. Gilray, Quh - cy Assurance Engineer Mr. Gilray will *,.fer testimony relevant to whether the Applicant's current QA/QC organization, which has been implemented for the balance of the construction activity at the South Texas Project, meets the requirements of 10 C.F.R. Part 50, Appendix B.
E)
Lawrence P. Crocker, Senior. Nuclear Engineer (Management Systems)
Frederick R. Allenspach, Nuclear Engineer (Management Systems)
Panel 4 will offer testimony relevant to the proposed management organization for the operations phase of the South Texas Pro,iect. This Panel will also testify to the issue of managerial competence based on current organizational plans of the Applicant for operations.
The Applicant's current plan for transition from construction activity to start-up and operations will also be addressed.
In addition, managerial attitude, as evidenced by interviews with Applicant's management, will be covered by this Panel.
F)
John G. Spraul, Senior Quality Assurance Engineer The testimony of Mr. Spraul will be relevant to whether the Applicant's proposed Quality Assurance Program for Operation of the South Texas Project meets the requirements of 10 C.F.R. Part 50, Appendix B.
Lastly, it is envisioned that all Staff testimony, to the extent it evidences a course of conduct by the Applicant from which corporate
4 character and competence can be inferred, will be relevant to those issues.
i Respectfully submitted,
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'#ayM.Gutiehez J
Counsel for NRC Staff t
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Dated at Bethesda, Maryland, 1
this 2nd day of March,1981.
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' 'e UNITED STALES OF A"!;lCA I;UCLEAR REGULA10RY CO.'";15SION BlIOR.: THE ATO:11C SAFLTY Af;D LICEf;SII;G C0ARD In the italter of
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idVSTON LIGilTIt!G AllD POWER C0:1 patly,
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Docket Nos. 50-498
.E_T_ A L.
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50-499 (South Texas Project, Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of " IDENTIFICATION OF STAFF WITNESSES AND SUBSTANCE i
OF TESTIl-10t4Y" in the above-captioned proceeding have been served on the followin'g by deposit in the United States mail, first class or as indicated by an asterisk by. deposit in the Nuclear Regulatory Comission internal mail system, this 2nd day of March, 1981:
Charles Bechhoofer, Esq., Chairaan*
Brian Berwick, Esq.
Atomic Safety and Licensing Board Assistant Attorney General Penel Ern ironmental Protecticn Division U.S. Nuclear Regulatory Cornission P.O. Box 12548, Capitol Station
!!ashington, D.C.
20555 Austin, TX 78711 Dr. James C. Lanb, III Jack R. Newman, Esq.
i 313 !!oodhaven Road Lowenstein, Newman, Reis, Chapel liill, NC 27514 Axelrad & Toll 1025 Connecticut Avenue, N.W.
Dr. Emmoth A. Luebke*
Washingto.. D.C.
20036 j
Atomic Safety and Licensing Board Panel Atonic Safety and Licensing board U.S. Nuclear Regulatory Commission Panel
- Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Melbert Schwarz, Jr., Esq.
Baker and Botts Atonic Safety and Licensing Appeal One Shell Plaza Panel
- llouston, TX 77002 U.S. Nuclear Regulatory Co..'icsion Washington, D.C.
20555
!!rs. Pegay Buchorn Executive Director Docketing and Service Section*
Citizens for Equitable Utilities, Inc.
Office of the Secretary i
Route 1, Box 1684 U.S. Nuclear Regulatory Comission Brazoria, TX 77422 Washington, D.C.
20555 Kim Eastman, Co-coordina tor Betty Wheeler, Esq.
Barbara A. ililler Tim Hoffman, Esq.
Pat Coy Hoffman, Steeg & Uheeler Citizens Concerned About Nuclear i003 S. fiadison Power Amarillo, TX 79101 5106 Casa Oro San Antonio, TX 78233 4
tounde;.Gutierrez Jay M l for NRC Staff
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