ML20011A221

Page 10 to Applicants' 810930 Brief in Opposition to Citizens for Equitable Utils 810930 Motion to File Addl Contentions,Inadvertently Omitted from Some Copies.Original of RR Hernandez 810930 Affidavit Encl

ML20011A221
Person / Time
Site:	South Texas
Issue date:	09/30/1981
From:	HOUSTON LIGHTING & POWER CO.
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20011A217	List: ML20011A216 ML20011A221
References
ISSUANCES-OL, NUDOCS 8110080313
Download: ML20011A221 (2)

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show that.the NRC Staff 1as been kept informed of this matter

~from the outset.

In the face of this background, CEU's unsupported assertion that this matter reflects adversely on HL&P's character and managerial competence is patently frivolous and a clear mischaracterization of the facts. There is not a single fact alleged in the CEU motion (other than the clearly erroneous assertjon of fai. lure to report to-NEC) which, if assumed to be true, would reflect adversely on HL&P's character or managerial competence.

The American Bridge steel was inspected by American Bridge inspectors who were not subject to whatever factors might have affected on-site B&R QC Inspectors. Over 95 per-cent of the steel was delivered before issuance of the Show Cause Order, all of it before September 1980. The steel is not subject to reinspection at the site absent some indication of a problem (cf. Tr. 3024-26; 3259-66). An investigation of the American Bridge QA Program or the vendor surveillance program for this structural steel would not address the conditions affecting QC Inspectors in past years or the im-prevements that have been made in the QA Program since early 1980 and would involve this hearing in a consideration of matters totally unnecessary to the resolution of the basic issues. Any problems that may have existed in the American Bridge QA Program or the B&R vendor purveillance program in the past are simply unrelated to the issues in this proceeding.

8110000313 811001 PDR ADOCK 05000499 O PDR Ir

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• UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION f

.B_C ORE THE ATOMIC SAFETY AND LICENSING BOARD

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In'the Matter of )

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) Docket Nos. 50-498 OL HOUSTON. LIGHTING AND POWER 50-499 OL COMPANY, ET AL. )

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(Snuth Texas Project, Units )

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1 &-2) 5 AFFIDAVIT OF RALPH k. HERNANDEZ STATE OF TEXAS COUNTY OF HARRIS Ralph R. Hernandez, being first duly sworn, deposes and crys: That he is employed by Houston Lighting and Power Company 23 a Supervising Engineer; that his professional qualifications are described in the record of this proceeding; that he partici-pated in the preparation of the attached " Response to the Board Questions Regarding Steel Supplied by American Bridge" and is familiar with the contents thereof; that_he has personal know-Icdge of or has made suitable inquiry concerning the facts con-tained in said response; and that facts contained in said response cre true and correct to the best of his information, knowledge and belief.

DATED this j day of September, 1981.

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SIGNED: 'W/r/z,N_ q . 6 pt,/2M Ralph R. Hernandez , . -

SUBSCRIBED AND SWORN TO before me this. h day of September, 1981.

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Notary /Public in and~ foMhe County of Harris, State of Texas My Commission expires:,_yjuz% /f /ff,$-

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