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Category:AFFIDAVITS
MONTHYEARML20031H3401981-08-28028 August 1981 Supplemental Affidavit of Jd Heidt,Responding to ASLB Questions Re Environ Qualification Testing & Reliability & Operational Test Info Required ML20003F8051981-04-0707 April 1981 Affidavit Re Consolidated Contention on Low Level Radiation Risk.Theory That Low Level Radiation Is Harmless Is Myth. Id Bross to Lll Encl ML20126H2871981-03-24024 March 1981 Affidavit in Response to Ld Hamilton 810309 Affidavit Re Low Level Radiation Risk.Ld Hamilton Work Is Fraudulent. Affidavit & Ltrs Encl ML19341D7371981-03-24024 March 1981 Affidavit That Statements in Affidavit Answering L Hamilton 810309 Affidavit Are True & Correct.Certificate of Svc Encl ML20126H1341981-03-22022 March 1981 Affidavit That Substantial & Unreasonable Hardship Will Be Imposed on Intervenor Unless Jm Scott Remains Both Expert Witness & Atty ML19350B5341981-03-0909 March 1981 Affidavit in Response to Idj Bross Affidavit Re 1981 Reassessment of Health Hazards of Low Level Ionizing Radiation. Review of Rept Added No Facts to Modify Earlier Conclusions.Certificate of Svc Encl.Related Correspondence ML19340D1101980-12-17017 December 1980 Affidavit Re Health Effects of Low Level Radiation.Supports NRC Statement of Matl Facts Re Consolidated Contention on NEPA Impacts of Low Level Radiation.Prof Qualifications & Certificate of Svc Encl ML19345C5111980-11-26026 November 1980 Affidavit Re NEPA Impacts of Low Level Radiation.Health Risks Associated W/Lwrs Are Insignificant.Prof Qualifications & Certificate of Svc Encl ML19338E9631980-10-0202 October 1980 Affidavit Affirming NRC Position That Impacts of Transmission Pines on Waterfowl Will Be Minimized by Applicant Proposed Routing Which Has No Superior Alternative Available.Prof Qualifications Encl ML19338F0941980-10-0101 October 1980 Affidavit Attesting to Uncertainty of Future Price & Availability of Natural Gas Generation.Prof Qualifications Encl ML19347B3981980-10-0101 October 1980 Affidavit Re Impact of Plant on Waterfowl & Other Environ Effects.Line No Longer Extends Over Lake & Thus Does Not Need to Be Moved.Prof Qualifications Encl ML19347B3861980-09-30030 September 1980 Affidavit Re Allens Creek Vs South Tx Project Sites.Cost Comparison Tabulation Encl ML19347B3871980-09-30030 September 1980 Affidavit Re Site Evaluation.Util Analysis Looks Only to Cost,Not to Benefit.Curriculum Vitae Encl ML19347B3921980-09-30030 September 1980 Affidavit Re Economic Comparison Between Competing Generation Alternatives.Util Does Not Qualify for Any Exemptions to Fuel Use Act Which Would Allow Unlimited Use of Gas for Unlimited Time.W/Certificate of Svc ML19347B3881980-09-29029 September 1980 Affidavit Re Sources of Groundwater for Facility.Lakes Conroe,Houston & Livingston Can Supply Surface Water to Meet City Demands Through Yr 2000.Curriculum Vitae,Excerpts of C Johnson & Saxion Depositions & Certificate of Svc Encl ML19347B3901980-09-29029 September 1980 Affidavit Re Natural Gas Plant Alternative.Util Not Automatically Entitled to Fua Exemption Because No Nonattainment Areas Exist in Houston.No Environ Exemptions Available to Util ML19338E6931980-09-25025 September 1980 Affidavit in Support of Applicant Motion for Summary Disposition of Potthoff Contention 6.Marine Biomass Production Is Not Viable Alternative at Present Time.Prof Qualifications Encl ML19347B3941980-09-11011 September 1980 Affidavit Re Latching.In Order for Radioactive Emissions to Effect Electronics on Aircraft,Aircraft Would Have to Park at Site Boundary for Extended Period.Certificate of Svc Encl ML19343A3301980-09-0909 September 1980 Affidavit Comparing Natural Gas Generation to Nuclear Fission Generation of Electricity as Superior Alternative to Facility ML19331B8881980-08-0808 August 1980 Affidavit in Support of Motion for Summary Disposition of Doherty Contention 45.Flashing Loads Do Not Apply to BWR Loca.Util Complied W/Requirements Re Ability to Withstand Lateral Seismic Forces.Resume & Transcript Excerpts Encl ML19331B8941980-08-0707 August 1980 Affidavit in Support of Motion for Summary Disposition of Doherty Contention 46.Control Rod Drop Accident Is Not Posed as Issue Due to Fact That Major Reductions in Margins Are Unlikely.W/Prof Qualifications & Transcript Excerpts ML19331B8751980-08-0606 August 1980 Affidavit in Support of Motion for Summary Disposition of Framson Contention 1 & Doherty Contention 11.Design Characteristics & Operating Safeguards to Protect Stored Spent Fuel Adequate.W/Resume & Transcript Excerpts ML19331B8841980-08-0606 August 1980 Affidavit in Support of Motion for Summary Disposition of Doherty Contention 35.Conduct of Safe Welding Operations Will Be Assured by Regulations,Testing,Examination & Audit Requirements.W/Prof Qualifications & Transcript Excerpt ML19331B9171980-08-0606 August 1980 Affidavit in Support of Motion for Summary Disposition of Tx Pirg Contention A-34.No Basis for Requiring Design to Withstand Hydrogen Expolsions Due to Presence of Criteria That Limit Hydrogen Concentrations Below Flammable Limit ML19337A0481980-08-0404 August 1980 Affidavit Re Tx Pirg Contention 50.Concern Re Effects of Ionization on Aircraft Guidance Sys Unfounded Per Elementary Physical Laws.Prof Qualifications,Affidavit,Supporting Documentation & Certificate of Svc Encl ML19330C5601980-08-0404 August 1980 Affidavit in Support of Applicant 800804 Motion for Summary Disposition of Fh Potthoff Contention 6.Marine Biomass Farm Is Remote & Speculative Alternative Energy Source Whose Feasibility & Economics Not Assured.W/Certificate of Svc ML20062H5041980-07-29029 July 1980 Affidavit in Support of Summary Disposition of Jf Doherty Contention 12 Alleging Unreliability of Rod Pattern Control Sys.Specific Concerns,Including Redundacy of Signals, Incorporated in Design.W/Prof Qualifications.Pp 82-93 ML20062H5721980-07-29029 July 1980 Affidavit in Support of Summary Disposition of Jf Doherty Contention 33 Re Doppler Effect.Ge Mathematical Model Used to Calculate Doppler Effect Does Not Rely on Spert Test Data.Prof Qualifications Encl.Pp 235-241 ML20062H5931980-07-29029 July 1980 Affidavit in Support of Summary Disposition of Jf Doherty Contention 43 Re Use of Certain Coating & Cleaning Compounds.Ge & Applicant Committed to Follow Reg Guide 1.37 Re Stainless Steel Cleaning Requirements.Pp 276-279 ML20062H5611980-07-29029 July 1980 Affidavit in Support of Summary Disposition of Jf Doherty Contention 28 Re Control Rod Ejection Accidents.Consequences of Design Basis Rod Drop Event Are Bounding.Prof Qualifications Encl.Pp 201-215 ML20062H4731980-07-29029 July 1980 Affidavit in Support of Summary Disposition of Jf Doherty Contention 5 Re Supression Pool Swell.Sys Protected from Loads by Cantilever Structures Designed to Absorb Loading. Prof Qualifications Encl.Pp 38-51 ML20062H6381980-07-29029 July 1980 Affidavit in Support of Summary Disposition of Tx Pirg Contention 10 Re Intergranular Corrosion Cracking.Facility Will Be Provided W/Positive Leak Detectionn Sys Which Will Prevent Safety Hazards.W/Prof Qualifications.Pp 459-467 ML20062H5431980-07-29029 July 1980 Affidavit in Support of Summary Disposition of Jf Doherty Contention 15 Re Use of Wigle Computer Code.Criteria of Spert Rept (IN-1370) Irrelevant to Scram Reactivity Calculations.Prof Qualifications Encl.Pp 150-155 ML20062H6091980-07-29029 July 1980 Affidavits in Support of Summary Disposition of Jf Doherty Contention 44 Re Intergranular Stress Corrosion Cracking. Use of Carbon Steel Demonstrating High Resistance Renders Allegations Groundless.W/Prof Qualifications.Pp 350-353 ML20062H4791980-07-29029 July 1980 Affidavit in Support of Summary Disposition of Jf Doherty Contention 5 Re Supression Pool Swell.Platform Will Only Experience LOCA Bubble Pressure W/Drag Forces. Prof Qualifications Encl.Pp 52-60 ML20062H6201980-07-29029 July 1980 Affidavit in Support of Summary Disposition of Jf Doherty Contention 31 & Tx Pirg Contention 11 Re flow-induced Vibration on Reactor Components.Necessary Mods Implemented in BWR-6 Design.Certificate of Svc Encl.Pp 404-415 ML19249E7551979-08-0303 August 1979 Affidavit Attesting That Author,As Supervising Engineer for Util,Answered Util Responses to Jf Doherty Fourth Set of Interrogatories.Certificate of Svc Encl ML20150E0781978-11-22022 November 1978 Affidavit Submitted by Petitioner K Hooker to Intervene as Attachment to Her Request for Waiver of NRC Standards for Low Gaseous Radioactive Emissions from Nuc Pwr Plants;Waiver Request Made Per 10CFR2.758.Cert of Svc Encl 1981-08-28
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20063N7591982-10-0606 October 1982 Withdrawal of Application for CP ML20063N7471982-10-0606 October 1982 Motion for Termination of Proceedings.Util Decided to Cancel Plant.Certificate of Svc Encl ML20055A7221982-07-15015 July 1982 Memorandum & Order Denying Jf Doherty 820615 Submittals, Treated as Motion to Reconsider ASLB 820602 Order.Motion Untimely Filed & Failed to Show Significance or Gravity of Issues ML20055A3551982-07-12012 July 1982 Amended Contention 59.Certificate of Svc Encl ML20054L5531982-07-0202 July 1982 Response Opposing Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Should Be Considered Motion for Reconsideration of ASLB 820602 Order.Timeliness & Significance of Issues Not Established.W/Certificate of Svc ML20054L4521982-07-0202 July 1982 Response Opposing J Doherty 820615 Motion to Reopen Record to Add Contention 59.Motion Fails to Establish Timeliness &/Or Significance of Issues Sought to Be Raised.Certificate of Svc Encl ML20054J9371982-06-28028 June 1982 Response Opposing J Doherty 820615 Request to Reopen Record. Request Improper & Insufficient to Support Relief.Commission Rules Cannot Be Circumvented by Refiling Same Argument After ASLB Ruling Issued.Certificate of Svc Encl ML20054F9861982-06-15015 June 1982 Motion to Reopen Record to Take Evidence on Contention 59. Gravity of Issues Warrants Reopening ML20054G0171982-06-15015 June 1982 Contention 50 Re Brown & Root Deficiencies in Quadrex Rept. Certificate of Svc Encl ML20053D6371982-06-0202 June 1982 Memorandum & Order Denying J Doherty 820422 Motion Re Contention 58 on Applicant Conduct on Reporting Violations. Applicant 820519 Motion to Strike Doherty 820514 Reply Granted ML20053A3961982-05-24024 May 1982 Order Extending Commission Time to Review ALAB-671 Until 820601 ML20053D0861982-05-24024 May 1982 Response in Opposition to Util 820519 Motion to Strike Doherty Contention 58 Re Applicant Conduct on Reporting Violations.Contention Should Be Treated as Such,Not as Motion.Certificate of Svc Encl.Related Correspondence ML20052H8621982-05-19019 May 1982 Motion to Strike J Doherty Reply to Applicant 820507 Response to Doherty 820422 Motion to Add Contention 58. Commission Rules Do Not Allow Reply.Certificate of Svc Encl ML20052H4441982-05-14014 May 1982 Reply Opposing Applicant 820507 Response to J Doherty 820422 Motion to Add Contention 58.Contention Should Be Admitted W/Amends.Aslb Should Judge Conduct of Applicants. Certificate of Svc Encl ML20052F9941982-05-12012 May 1982 Response Opposing J Doherty 820422 Motion to Add Contention 58.Intervenor Fails to Meet Required Stds to Reopen Record & for Untimely Filings.Certificate of Svc Encl ML20052F2971982-05-10010 May 1982 Order Extending Time Until 820524 for Commission to Determine Whether to Review ALAB-671 ML20052F3121982-05-0707 May 1982 Response Opposing J Doherty 820422 Motion to Add Contention Re Alleged Failure to Rept Design Defects.Substantively, Motion Is Motion to Reopen Record & Stds Have Not Been Met. Certificate of Svc Encl ML20052D1221982-04-29029 April 1982 Findings of Fact on Supplemental Issues to Tx Pirg Addl Contention 31 Re Technical Qualifications.Certificate of Svc Encl ML20052A4541982-04-22022 April 1982 Submittal of Contention 58 Re Applicant Conduct on Reporting Violations at Plant.Certificate of Svc Encl ML20054E0561982-04-21021 April 1982 Supplemental Findings of Fact on Tx Pirg Addl Contention 31 Re Technical Qualifications.Certificate of Svc Encl ML20054D5251982-04-20020 April 1982 Order Incorporating ASLB Rulings at 820412 Hearing Re Tx Pirg 820405 Motion to Enter Counsel for cross-examination & to Reconsider 820128 Order.Motion Denied But Tx Pirg Permitted to Submit Written cross-examination Questions ML20054B6981982-04-14014 April 1982 Transcript of 820414 Hearing.Pp 21,787-22,027 ML20050E2181982-04-0808 April 1982 Order Ruling on Doherty Motions.Request for Production of Bechtel Quadrex Rept Review Moot Since Applicant Furnished Rept on 820316.Motion of 820315 for Subpoena of Quadrex Corp Employees Denied W/O Prejudice ML20050J1111982-04-0606 April 1982 Answers to Second & Third Sets of Interrogatories,Questions 29 & 8 Respectively,Re Quadrex Rept.Certificate of Svc Encl. Related Correspondence ML20050E2891982-04-0505 April 1982 Answers & Objections to Doherty Sixth Set of Interrogatories.Related Correspondence ML20050E2961982-04-0505 April 1982 Answers & Objections to Seventh Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20050C4211982-04-0202 April 1982 Objections to Request for Admissions.Requests Untimely, Irrelevant to Issues Before ASLB & Extremely & Unduly Burdensome.Certificate of Svc Encl.Related Correspondence ML20050B1141982-03-31031 March 1982 Decision ALAB-671,affirming ASLB Decision Denying R Alexander Petition to Intervene.Aslb Assessment of Untimeliness of Petition Free of Matl Error.Issue Raised No Longer Cognizable ML20050C4081982-03-31031 March 1982 Answers & Objections to Fifth Set of Interrogatories. Certificate of Svc Encl.Related Correspondence ML20042C5661982-03-30030 March 1982 Reply Opposing Tx PIRG,810315 Proposed Findings of Fact & Conclusions of Law.Proposed Findings Are Collection of Disjointed Thoughts & Facts W/No Rational Assessment of Effect on Problem or Issue Discussed.W/Certificate of Svc ML20042C6431982-03-29029 March 1982 Motion for ASLB to Call DE Sells as Witness for Tx Pirg Addl Contention 31 & Quadrex-related Matters.Testimony Needed to Explain Why NRC Did Not Immediately Obtain Quadrex Rept. Certificate of Svc Encl ML20042C6181982-03-29029 March 1982 Response Opposing J Doherty 820315 Motion for ASLB to Subpoena Quadrex Corp Employee Witnesses as ASLB Witnesses. Request Is Based on Misperception of Scope of Reopened Hearings.Certificate of Svc Encl ML20050C4791982-03-29029 March 1982 Answers & Objections to Jf Doherty Fourth Set of Interrogatories Re Tx Pirg Contention 31 & Quadrex Matters. Certificate of Svc Encl.Related Correspondence ML20050C5011982-03-26026 March 1982 Supplemental Testimony of Jh Goldberg on Technical Qualifications.Brown & Root Terminates Due to Lack of Engineering Productivity,Not Due to Allegations in Quadrex Rept ML20050C5041982-03-26026 March 1982 Testimony of Lj Sas on Tx Pirg Addl Contention 31 Re Quadrex Rept.Rept Raises No Issue as to Whether Ebasco Can Properly Engineer Project.Prof Qualifications Encl ML20050C5091982-03-26026 March 1982 Response to Jf Doherty 20th & 21st Requests for Documents. Certificate of Svc Encl ML20049K0801982-03-25025 March 1982 Answers & Objections to Interrogatories.Certificate of Svc Encl ML20049K0671982-03-25025 March 1982 Reply to Tx Pirg 820315 Addl Proposed Findings of Fact & Conclusions of Law.Certificate of Svc Encl ML20042C5201982-03-25025 March 1982 Motion to Compel Discovery from Applicant & to Postpone Evidentiary Presentations at 820412 Hearings.Applicant Objections to Interrogatories Unsupported & Necessitate Hearings Be Delayed.Certificate of Svc Encl ML20049J9651982-03-24024 March 1982 Testimony of Fr Allenspach & JW Gilray Per ASLB 810128 Order Re Doherty Renewed Motion for Addl Evidence on Tx Pirg Addl Contention 31.Quadrex Rept Does Not Alter Previous Conclusions That Applicant Technically Qualified ML20049J9701982-03-24024 March 1982 Answers to First Set of Interrogatories Re Tx Pirg Contention 31.Certificate of Svc Encl ML20049J9671982-03-24024 March 1982 Response to First Set of Interrogatories & Request for Production of Documents Re Tx Pirg Contention 31 ML20049K0841982-03-23023 March 1982 Answers & Objections to Third Set of Interrogatories. Certificate of Svc Encl ML20049K0941982-03-23023 March 1982 Answers & Objections to Second Set of Interrogatories. Certificate of Svc Encl ML20042C5481982-03-23023 March 1982 Fourth Set of Requests for Admissions Re Quadrex Rept & Tx Pirg Contention 31.Certificate of Svc Encl ML20042A2721982-03-18018 March 1982 Order Scheduling 820412-16 Evidentiary Hearing to Receive Addl Evidence in Houston,Tx ML20042A2771982-03-18018 March 1982 Memorandum & Order Denying J Doherty 820310 Motion for Postponement of 820412 Hearing on Tx Pirg Addl Contention 31 & Quadrex-related Matters.Ample Time to Complete Discovery Given.Personal Obligations Are No Excuse ML20042B2351982-03-17017 March 1982 Seventh Set of Interrogatories Re Tx Pirg Addl Contention 31 & Quadrex Rept Matters.Certificate of Svc Encl ML20042A4791982-03-17017 March 1982 Response Opposing J Doherty 820310 Motion for Postponement of 820412 Hearings.Sufficient Grounds Not Provided to Justify Delay.Certificate of Svc Encl ML20041G1711982-03-17017 March 1982 Response Opposing J Doherty 820310 Motion to Postpone 820412 Hearing on Quadrex Rept.Doherty Cannot Profit from Failure to Comply W/Aslb Order Re Completion of Discovery by Postponing Hearing.Certificate of Svc Encl 1982-07-02
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UNITED STA1 3 0F AMERICA
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NUCLEAR REGULA10RY COMMISSION 9'
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Occket No. 50-466 (Allens Creek Nuclear Generating
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SUPPLEMENTAL AFFIDAVIT OF JAMES 0. HEIDT State of California County of Santa Clara I, James D. Heidt, Program Manager of the Reload Fuel Licensing Unit of the GeneralElectric _ Company,.of lawful age, being f.irst. duly, sworn, -
upon my oath certify that the statements contained in the attached pages are true and correct to the best of my knowledge and belief.
Executed at San Jose, California, August A7, 1981
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NOTARY PUtuC-CAUFoRNir o NOTARY F'JBLIC IN AND F0p SAID SANTA CLARA COUNTY COUNTY aid ST JE g
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of S
S HOUSTON LIGHTING & POWER COMPANY S
Docket No. 50-466 S
(Allens Creek Nuclear Generating S
Station, Unit 1)
S SUPPLEMENTAL AFFIDAVIT OF J. D. HEIDT The purpose of this Supplemental Affidavit is to respond to Board Questions generated in the Board's Second Order Ruling Upon Motions for Summary Disposition which dismissed TexPirg Contention A-38.
In that order, the following two questions were asked.
1.
What environmental qualification testing has been or will be condacted on the proposed solid state differential pressure level transmitter wirh whataesults,tandmon_what~ schedule? _ _..
systeme 2.
Will reliability and operational test informatica be required before final acceptance of this design departure from earlier systems, of what nature, and on what schedule?
The equipment will be qualified in accordance with applicable NRC requirements (presently IEEE 323, 1974 issue and Regulatory Guide 1.89, Noven.ner 1974).
The NRC has recently issued NUREG-0588 as the standard reflecting the NRC position on environmental qualification fer Class IE equipment.
Since the Lransmitters are Class IE, the recommendations of NUREG-0588 will be considered in developing the qualification requirements of the transmitters.
The appropriate environmental qualification requirements for the transmitters will be met by including those requirements in the design specification used to purchase the equipment or by actual qualification testing of the equipment after purchase.
The qualification of these transa.tters for the ACNGS environment will be demonstrated prior to operation of the ACNGS plant.
The use of the solid state transmitters is part of the package of design improvements to the scram discharge volume that were developed during the design evolution of the mor e: modern, solid state safety system'for the GE BWR-6 family of plants.
As part of that package, transmitters
similar to those~to be used at Allens Creek will be installed at BWR/6's that will be operating prior to Allens Creek.
Accordingly, operational experience demonstrating the reliability of these transmitters will be available prior to operation of ACNGS with the new transmitters.
In addition, pre-operational testing will be performed on the actual ACNGS transmitters prior to ACNGS operation.
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