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Category:AFFIDAVITS
MONTHYEARML20063H0191982-08-26026 August 1982 Affidavit of B Bursey Supporting Motion to Reopen Record & Request for Stay Re Unresolved QC & safety-related Matters. Hl Jennings Allegations Proven by Applicant QC Records Substantiate Inadequate Applicant QC Program ML20052C1701982-04-29029 April 1982 Affidavit of MD Quinton Re B Bursey 820414 Proposed New Contention 1.Steam Generator Tube Matter Referred to Does Not Present Significant Risk to Public Health & Safety ML20052C1641982-04-28028 April 1982 Affidavit of Wd Fletcher Re B Bursey 820414 Proposed New Contention 1.Interim Operation Program Will Preclude Significant Steam Generator Tube Wear Until Mods to Steam Generators Implemented ML20052C1721982-04-23023 April 1982 Affidavit of MD Quinton Re Fairfield United Action Proposed Contentions.Issues Raised Re Steam Generator Tubes Do Not Present Significant Risk to Public Health & Safety ML20052C1681982-04-22022 April 1982 Affidavit of Wd Fletcher Re Fairfield United Action Contention B1.Interim Operation Program Will Preclude Significant Steam Generator Tube Wear Until Mods to Steam Generators Implemented.Prof Qualifications Encl ML20049J6671982-03-11011 March 1982 Affidavit of Lf Storz Re Ms Medeiros Trip Rept on Operating Procedures.Majority of Medeiros Comments Not Substantiated ML20049J6691982-03-10010 March 1982 Affidavit of Kw Woodward Re Ms Medeiros Trip Rept on Operating Procedures.Storz Account of Substance of Conversations W/Medeiros on 811217-18 Correct ML20039B1541981-12-18018 December 1981 Affidavit Re Intervenor Motion to Reopen Record on Emergency Contention A8.Sirens Will Be Tested on 820130. Certificate of Svc Encl ML20010A7161981-08-0606 August 1981 Affidavit Re M Kaku Testimony on Evacuation & Accident Hazards.Prof Qualifications Encl ML20004C4451981-05-27027 May 1981 Affidavit Supporting Ba Bursey Contention A2.Applicants Have Failed to Provide for Reasonably Expected Facility Operating Costs & Underestimated Decommissioning Costs.Ability to Raise Capital Has Been Undermined.Prof Qualifications Encl ML20005B2011981-05-0707 May 1981 Affidavit Re Projections of Population Doses.Prof Qualifications,Notice of Appearance & Certificate of Svc Encl ML20005B1971981-05-0606 May 1981 Affidavit Re Health Effects of Low Level Radiation.Prof Qualifications Encl ML20005B0011981-05-0606 May 1981 Affidavit Re Atws.Concludes That Existing Operator Training Sessions,Including ATWS Sessions,Satisfactorily Address SER Recommended Steps.Prof Qualifications Encl ML20005B1741981-05-0606 May 1981 Affidavit Re Atws.Existing Operator Training Sessions Satisfactorily Address Steps Recommended & Accepted in NRC Safety Evaluation for Reducing Risk from Atws.Prof Qualifications Encl ML20005B0001981-05-0606 May 1981 Affidavit Re Atws.Concludes That Risk of Adverse Consequences from Event Is Acceptably Low & Facility Has Met All NRC Criteria.Prof Qualifications Encl ML20005B1681981-05-0606 May 1981 Affidavit Re Atws.Risk of Adverse Consequences Is Acceptably Low for Full Power Operation.Util Has Met All Current NRC Criteria.Prof Qualifications Encl ML19344F4751980-09-0303 September 1980 Affidavit Re Sc Electric & Gas Co Filing for Protective Order of Documents Sought by Nc Electric Membership Corp Concerning Antitrust Proceeding.Plaintiff Argues Protective Order Would Unduly Burden Litigation Proceedings ML19321B0721980-07-23023 July 1980 Affidavit Stating That Brand & Hall Has Received 100,000 Documents from Sc Electric & Gas Co.Many Documents Relate to Nc & Sc Cases & May Include Inconsistent Info.Certificate of Svc Enc. 15 ML19281C3991979-03-14014 March 1979 Affidavit Re Util Actions in 1973 Conditioning Sante Cooper Participation Upon Enactment of Territorial Allocation Law ML20147C9231978-10-0303 October 1978 Affidavit of Pg Stoddart Re Testimony on Appl for Lic to Operate Subj Facil.Concluded That Applicant'S Design Provisions Re Inadvertent Releases of Radioactive Liquids Are Acceptable Per 10CFR20 1982-08-26
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARRC-99-0172, Comment Opposing Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Ep.Stockpile of Ki Not Effective as Immediate & Suppl Measure of Protection1999-08-24024 August 1999 Comment Opposing Proposed Rule 10CFR50 Re Consideration of Potassium Iodide in Ep.Stockpile of Ki Not Effective as Immediate & Suppl Measure of Protection ML20207E4181999-05-17017 May 1999 Comment Supporting Recommended Improvements to Oversight Processes for Nuclear Power Reactors Noted in SECY-99-007A ML20206G3351999-05-0303 May 1999 Comment on Proposed Rules 10CFR170 & 171 Re Proposed Revs to Fee schedules;100% Fee recovery,FY99.Util Fully Endorses Comments Prepared & Submitted on Behalf of Commercial Nuclear Power Industry by NEI & Submits Addl Comments RC-99-0088, Comment on Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e).Believes That Inclusion of Statement in DG, Unnecessary1999-04-28028 April 1999 Comment on Draft RG DG-1083 Re Content of UFSAR IAW 10CFR50.71(e).Believes That Inclusion of Statement in DG, Unnecessary RC-99-0060, Comment on Proposed Rule PRM 50-64 Re Joint & Several Liability of non-operating co-owners of Nuclear Plants.Sce&G Endorses Comments Submitted by Winston & Strawn & NEI1999-03-22022 March 1999 Comment on Proposed Rule PRM 50-64 Re Joint & Several Liability of non-operating co-owners of Nuclear Plants.Sce&G Endorses Comments Submitted by Winston & Strawn & NEI RC-98-0230, Comment Opposing Proposed Rule 10CFR50,52 & 72 Re Changes, Tests & Experiments1998-12-21021 December 1998 Comment Opposing Proposed Rule 10CFR50,52 & 72 Re Changes, Tests & Experiments RC-98-0224, Comment on Proposed Rule 10CFR50.65 Re Requirements for Monitoring Effectiveness of Maint at Npps.Encourages NRC to Continue Cooperative Effort with NEI & Nuclear Industry to Focus on Risk Significant Issues1998-12-14014 December 1998 Comment on Proposed Rule 10CFR50.65 Re Requirements for Monitoring Effectiveness of Maint at Npps.Encourages NRC to Continue Cooperative Effort with NEI & Nuclear Industry to Focus on Risk Significant Issues RC-98-0181, Comment Supporting Comments Submitted by NEI Re NRC Proposed Integrated Review of Assessment Process for Commercial NPPs (Irap)1998-10-0606 October 1998 Comment Supporting Comments Submitted by NEI Re NRC Proposed Integrated Review of Assessment Process for Commercial NPPs (Irap) RC-98-0176, Comment on Draft Reg Guide DG-8022, Acceptable Programs for Respiratory Protection1998-09-28028 September 1998 Comment on Draft Reg Guide DG-8022, Acceptable Programs for Respiratory Protection RC-98-0169, Comment on Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Proposed Improvements to Current Reporting Requirements Would Have Significant & Positive Impact on Regulatory Burden to VC Summer Nuclear Station1998-09-18018 September 1998 Comment on Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Proposed Improvements to Current Reporting Requirements Would Have Significant & Positive Impact on Regulatory Burden to VC Summer Nuclear Station RC-98-0165, Comment on Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Where Evacuations Are Performed,Ki Would Not Add Any Measures of Safety to Approach & Could Complicate Er1998-09-14014 September 1998 Comment on Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Where Evacuations Are Performed,Ki Would Not Add Any Measures of Safety to Approach & Could Complicate Er RC-98-0022, Comment Opposing Proposed GL 98-XX, Yr 2000 Readiness of Computer Sys at Npps1998-02-0202 February 1998 Comment Opposing Proposed GL 98-XX, Yr 2000 Readiness of Computer Sys at Npps RC-97-0279, Comment Opposing Draft RG DG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Npps1997-12-0808 December 1997 Comment Opposing Draft RG DG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Npps RC-97-0243, Comment on Proposed Rule 10CFR50 Re Rule Change to Incorporate IEEE 603 Standard1997-11-26026 November 1997 Comment on Proposed Rule 10CFR50 Re Rule Change to Incorporate IEEE 603 Standard RC-97-0219, Comment Opposing Proposed Rule 10CFR55 Re Initial Operator Exam Requirements1997-10-24024 October 1997 Comment Opposing Proposed Rule 10CFR55 Re Initial Operator Exam Requirements RC-97-0134, Comment Supporting NUREG-1606, Proposed Regulatory Guidance Related to Implementation of 10CFR50.59 (Changes, Tests or Experiments)1997-07-0707 July 1997 Comment Supporting NUREG-1606, Proposed Regulatory Guidance Related to Implementation of 10CFR50.59 (Changes, Tests or Experiments) ML20148N0861997-06-19019 June 1997 Comment Opposing NRC Draft Suppl 1 to Bulletin 96-001 Which Proposes Actions to Be Taken by Licensees of W & B&W Designed Plants to Ensure Continued Operability of CR RC-97-0096, Comment Discussing Proposed Rule 10CFR73 Re Changes to Nuclear Power Plant Security Requirements1997-05-0202 May 1997 Comment Discussing Proposed Rule 10CFR73 Re Changes to Nuclear Power Plant Security Requirements RC-97-0055, Comment Opposing Proposed GL on Loss of Reactor Coolant Inventory & Associated Potential for Loss of Emergency Mitigation Functions While in Shuddown Condition1997-03-12012 March 1997 Comment Opposing Proposed GL on Loss of Reactor Coolant Inventory & Associated Potential for Loss of Emergency Mitigation Functions While in Shuddown Condition ML20136H9531997-03-0505 March 1997 Comment Opposing Draft Regulatory Guide 1068, Medical Evaluation of Licensed Personnel at Nuclear Power Plants RC-97-0024, Comment on Proposed Generic Communication, Effectiveness of Ultrasonic Testing Sys in Inservice Inspection Programs. GL Seems to Approach Mandating Implementation of App Viii Requirements1997-02-25025 February 1997 Comment on Proposed Generic Communication, Effectiveness of Ultrasonic Testing Sys in Inservice Inspection Programs. GL Seems to Approach Mandating Implementation of App Viii Requirements ML20135C4911997-02-17017 February 1997 Comment on NRC Draft NUREG 1560, IPE Program:Perspectives on Reactor Safety & Plant Performance;Vols 1 & 2. Comment Provided to Enhance Accuracy of Nureg,Per Request ML20113C1881996-06-24024 June 1996 Comments on Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors RC-96-0154, Comment on DRG,DG-5007,re Proposed Rev 3 to RG 5.441996-06-17017 June 1996 Comment on DRG,DG-5007,re Proposed Rev 3 to RG 5.44 ML20096F1991996-01-15015 January 1996 Comment Opposing Petition for Rulemaking PRM-50-63 Re Use of Ki as Insurance Against Nuclear Accidents RC-95-0236, Comment Opposing Draft RG DG-1043,Proposed Rev 2 to RG 1.49, NPP Simulation Facilities for Use in Operator Exams1995-09-13013 September 1995 Comment Opposing Draft RG DG-1043,Proposed Rev 2 to RG 1.49, NPP Simulation Facilities for Use in Operator Exams RC-95-0178, Comment on Proposed Review of NRC Insp Rept Content,Format & Style1995-06-28028 June 1995 Comment on Proposed Review of NRC Insp Rept Content,Format & Style ML20086A8611995-06-13013 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control ML20083N4761995-04-26026 April 1995 Comment Re Proposed GL Concerning Pressure Locking & Thermal Binding of SR Power Operated Gate Valves.Believes That Full Backfit Analysis Should Be Performed to Enable Utils to Perform cost-benefit Analysis to Be Utilized RC-95-0009, Comment Supporting Proposed Rule 10CFR21 Re inter-utility Transfer1995-01-0909 January 1995 Comment Supporting Proposed Rule 10CFR21 Re inter-utility Transfer ML20077M7131995-01-0303 January 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operations.Believes That Pr Totally Unnecessary & Represents Addl Regulatory Burden Not Fully Cost Justified RC-94-0292, Comment Supporting Proposed Rule 10CFR20 Re Frequency of Medical Exams for Use of Respiratory Protection Equipment. Util Agrees That Frequency of Medical Exams Should Be Determined by Physician1994-11-11011 November 1994 Comment Supporting Proposed Rule 10CFR20 Re Frequency of Medical Exams for Use of Respiratory Protection Equipment. Util Agrees That Frequency of Medical Exams Should Be Determined by Physician ML20072B1771994-07-29029 July 1994 Comment Opposing Petition for Rulemaking PRM-9-2 to Change Rules Re Public Access to Info,Per 10CFR9 ML20071H4111994-07-0606 July 1994 Comment Supporting Petition for Rulemaking PRM-50-59 Re Change to Frequency of Independent Reviews & Audits of Safeguards Contingency Plan & Security Program ML20071H1091994-06-22022 June 1994 Comment Supporting PRM 50-60 Re Proposed Changes to Frequency W/Which Licensee Conducts Independent Reviews of EP Program from Annually to Biennially RC-94-0107, Comment Supporting Proposed Rule Change to 10CFR50.55 That Would Include Containment Requirements in Inservice Insp Programs1994-04-21021 April 1994 Comment Supporting Proposed Rule Change to 10CFR50.55 That Would Include Containment Requirements in Inservice Insp Programs RC-94-0057, Comment Supporting NUREG-1488, Revised Livermore Seismic Hazard Estimates for 69 NPP Sites East of Rocky Mountains1994-02-28028 February 1994 Comment Supporting NUREG-1488, Revised Livermore Seismic Hazard Estimates for 69 NPP Sites East of Rocky Mountains RC-93-0314, Comment Supporting NUMARC Position on Proposed Rule 10CFR73 Re Protection Against Malevolent Use of Vehicles at Nuclear Power Plants1993-12-28028 December 1993 Comment Supporting NUMARC Position on Proposed Rule 10CFR73 Re Protection Against Malevolent Use of Vehicles at Nuclear Power Plants ML20046D5271993-07-30030 July 1993 Comment Supporting Proposed Rule 10CFR55 Re Proposed Amend to 10CFR55 ML20045G8541993-06-22022 June 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. Provides Recommendations RC-93-0127, Comment Concurring W/Numarc Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp1993-05-21021 May 1993 Comment Concurring W/Numarc Comments on Draft NRC Insp Procedure 38703, Commercial Grade Procurement Insp ML20118B8431992-09-29029 September 1992 Comments on Review of Reactor Licensee Reporting Requirements ML20095L2681992-04-27027 April 1992 Comments on NUREG-1449, Shutdown & Low Power Operation at Commercial Nuclear Power Plants in Us. Endorses NUMARC Comments ML20096A4541992-04-27027 April 1992 Comment Endorsing Comments Made by NUMARC Re Proposed Rule Misc (92-1), Conversion to Metric Sys. Concurs W/Nrc Position That Staff Will Not Allow Licensees to Convert Sys of Units Where Conversion Might Be Detrimental to Health ML20096D4661992-04-27027 April 1992 Comments Supporting Proposed Rule Re Conversion to Metric Sys ML20079E0981991-09-20020 September 1991 Submits Comments on NRC Proposed Resolution of Generic Issue 23, Reactor Coolant Pump Seal Failure, & Draft Reg Guide DG-1008 ML20073B2021991-04-15015 April 1991 Comment Supporting Proposed Rule 10CFR50.55a Endorsing Later Addenda & Editions of ASME Code Sections III & XI W/Noted Exceptions.Util Also Endorses Comments Submitted by NUMARC ML20070D9091991-02-21021 February 1991 Comment Opposing Petition for Rulemaking PRM-73-9 Re Rev to 10CFR73.1.Util Disagrees W/Petitioners Contention That Purported Increased Terrorist Threats Necessitate Need to Revise Design Basis Threat for Radiological Sabotage ML20024G0211990-12-0303 December 1990 Comments on Proposed Rule 10CFR50 Re Emergency Response Data Sys (Erds).Nrc Intends to Make ERDS Info Available to State Govts ML20058G5721990-10-24024 October 1990 Comment Opposing Proposed Rule 10CFR26 Re Fitness for Duty Programs 1999-08-24
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',, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of '
)
)
SOUTH CAROLINA ELECTRIC & )
GAS COMPANY ) Docket No. 50-395
)
(Virgil C. Summer Nuclear )
Station, Unit 1) )
AFFIDAVIT OF O. S. BRADHAM ON ANTICIPATED TRANSIENTS WITHOUT SCRAM My name is O. S. Bradham.
I am the Manager, Virgil C. Summer Nuclear Station for South Carolina Electric & Gas Company. My statement of professional qualifications is provided in Attachment A. I am responsible for operating activities and personnel of the Virgil C. Summer Nuclear Station. This affidavit addresses the procedures and training to detect and take required corrective action for ATWS events consistent with the requirements of the NRC Staff as set forth in the Safety Evaluation Report, Chapter 15.3.5, in regard to (1) develop-ment of ATWS emergency pr,ocedures and (2) operator training.
PROCEDURES l
Plant emergency operating procedures at the Virgil C.
(
Summer Nuclear Station address actions to be taken by the operators if an ATWS event should occur. Specifically, manual reactor scram is initiated, emergency feedwater initiation is verified or initiated, if required, turbine trip is verified or initiated, if required, and emergency boration is initiated, if required.
I 8107060406 810 07 PDR ADOCK 050 395 O
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- It chould be recognizcd that cmsrgency procadures related to ATWS events are not fundamentally new information for plant operators. Alternate methods of scramming the reactor have routinely been addressed in procedures for commercial nuclear power plants..
OPERATOR TRAINING The operator training and testing program is described in FSAR Chapter 13.2. This existing process ensures that the Virgil C. Summer Nuclear Station licensed operator is competent to recognize emergency conditions, to take the proper corrective action, and to protect the health and safety of the public. A strong knowledge of plant systems and emergency procedures is required of all licensed opera-tions personnel.
ATWS training of the operators has been conducted in special one day classes. It included the definition of ATWS, types of events and scenarios of potential concern in regard to ATWS, and recognition of and actions to be taken in an ATWS event. Also, actions to be taken by the operator if an ATWS event should occur have been discussed in the training sessions on plant emergency procedures. ATWS will continue to be addressed in future operator training classes.
SUBMISSIONS TO NRC We have addressed ATWS and related procedures and training in FSAR Sections 5.5.13.4, 15.2, 15.2.7, 4.3.1.7 and 15.2.15 in our response to Question 211.122.
SUMMARY
In summary, it is South Carolina Electric & Gas Company's position that the existing operator training sessions including special ATWS sessions and the plant emergency operating procedures which address actions taken if an A*WS event occurs satisfactorily address those steps recommended and accepted in the Safety Evaluation Report by the NRC Staff d
for reducing the risk from ATWS.
I hereby certify that the foregoing information is true and correct to the best of my knowled e and belief.
Asd G. S. BRADHAM Subscribed and sworn to before me this cG day of W c, , _ , 1981.
Li
,5 ([ v % N, c + (L.S.)
Notary Public My Commission expires: / .;- 3 0 - Y F .
ATTACHMENT A
". ~ i O. S. BRADHAM PROFESSIONAL QUALIFICATIONS I am the Manager of the Virgil C. Summer Nuclear Station.
I have overall operating and personnel responsibility for the Summer Plant and am responsible for plant operations in a safe, reliable,'and efficient manner by ensuring compliance with all requirements of the operating license.
i Upon high school graduation in 1947, I entered the United States Army, graduating from Officers Candidate School in 1951, taking communications and engineering courses, leaving the Army in 1953.
From 1953 to 1961 I was employed by the Savannah River Plant as an Instrument Technician on production reactors.
From 1961 to 1967 I was employed at the CVTR Reactor Plant, Parr, South Carolina as I&C Technician and Instrument l
and Electrical Supervisor.
From 1967-1978 I was employed by Duke Power Company in the respective positions of I&C Engineer for Oconee Nuclear Station (1967-1973), Technical Support Group Superintendent i for Oconee Nuclear Station (1973-74), and Superintendent of Maintenance for Oconee Nuclear Station (1974-78) . In the last capacity I reported directly to the Plant Manager.
In 1978 I accepted employment with South Carolina Electric & Gas Company as Plant Manager for the V. C. Summer Nuclear Station.
In my positions with Duke Power Company I was responsible at various times for selection, hiring, and training of l
t 0 Plant staff for the I&C Group; for I&C portion of preopera-tions, start-up, power ascension program and maintenance of all instrumentation for Units 1 and 2; zero power physics and power ascension test program for Unit 3; I&C Section, Chemistry Section, Performance Section, and Health Physics Section activities for Units 1, 2, and 3; all Mechanical Maintenance Section, Instrument & Electrical Section; Planning / Scheduling and Material Section activities for Oconee Station, consisting, among other tunigs, of managing six refueling outages in addition to numerous maintenance outages and normal maintenance outages and normal opera-tional support activities. In my last capacity I frequently and for periods of weeks at a time assumed the job of Acting Plant Manager while the Plant Manager was on vacation or out
- of town.
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