ML20039C044

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Affidavit of Cw Moon Re 790926 Meeting.Mm Cherry Motivation Appeared to Be to Identify Issues to Be Used in Context Against NRC Licensing Practices.Prof Qualifications Encl
ML20039C044
Person / Time
Site: Byron  Constellation icon.png
Issue date: 12/21/1981
From: Moon C
NRC
To:
Shared Package
ML20039C034 List:
References
NUDOCS 8112280350
Download: ML20039C044 (4)


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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COMMONWEALTH EDIS0N COMPANY Docket Nos. 50-454

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50-455 (Byron Station, Units 1 and 2)

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AFFIDAVIT 0F CALVIN W. MOON REGARDING SEPTEMBER 26, 1979 MEETING 1.

My name is Calvin W. Moon.

I was the NRC Staff project manager for

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the Byron operating license application in 1979.

A copy of my professional qualifications is attached.

2.

The Licensing Board's December 8,1981 Order requested the attendees to a September 26, 1979 meeting among the _ parties to give

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their bes. recollection of pertinent discussions which took place during that meeting.

I have prepared this affidavit in response to that Licensing Board request. Myron Cherry, Esq. telephoned me on i

December 18, 1981 concerning this matter.

3.

.I cannot recall whether I took notes of the meeting in question and have been unable to locate in my files any notes of the meeting.

The statements which follow are based on my recollection of the meeting.

4.

I accompanied Richard Goddard, NRC Staff Counsel, to the meeting with the understanding that the purpose of the meeting was to a

negotiate a final statement of contentions proposed by the Rockford League of Women Voters (League).

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PDR ADOCK 05000454 C

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Myron Cherry, Esq. advised that he was considering becoming Counsel for the League, but at the time of the meeting was participating only in the formulation of the wordings of the League's contentions.

6.

The attendees failed to accomplisn the objective of the meeting because Mr. Cherry was not prepared to address the specific intent of each of the League's contentions.

7.

League representatives said little and allowed Mr. Cherry to speak for them.

8.

Throughout the meeting Mr. Cherry's motivation appeared to be one of identifying issues that he could use in his contest against NRC licensing practices.

He did not appear to have any desire to pursue the specific contentions of the League and to aid the attendees in achieving the objectives of the meeting.

9.

During the meeting Mr. Cherry identified generic issues as an item of high interest to him.

10.

Mr. Cherry identified steam generator tube problems to illustrate his position on generic issues.

Specifically, he argued that if the Byron steam generators were acceptable, there was no basis for the staff to pursue the matter as a generic issue. Conversely, he argued that if there was a generic issue, no basis existed for licensing Byron.

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I cannot recall whether the subject of delay as a motivation for intervention was ever raised.

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12. The foregoing constitutes-my best recollection of-the substance of

'the meeting.

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-Calvin-W. Moon Subscribed and sworn.to before me j

this e/sf day of December,1981.

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CALVIN W. MOON PROFESSIONAL QUALIFICATIONS LICENSING BRANCH NO. 1 DIVISION OF LICENSING I am a Senior Project Manager in Licensing Branch No.1, Division of Licensing, U. S. Nuclear Regulatory Commission.

In my present position, I have overall responsibility for conducting the safety and environmental reviews of power reactor license applications assigned to me. This includes the responsibility for planning and coordinating the efforts of other tech-nical personnel involved in the review.

I hold a Bachelor of Science degree in Mechanical Engineering from Iowa State University and a Master of Science degree from Stanford University.

I am a registered professional engineer in the State of Iowa.

I have a total of 29 years of professional experience.

For three years I was employed by the University of California at the Los Alamos Scientific Laboratory with responsibilities for the design and development of mechanical sys te.ms.

For fourteen years I was employed by private industry in various staff and supervisory enginee. ring positions working on the design and

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development of gas cooled reactors for application to military propulsion,

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marine prop,ulsion, space propulsion and space auxiliary power systems.

In 1968 I accepted a position as Reactor Engineer with the Regulatory I

Staff of the Atomic Energy Commission.

In this capacity, I participated in 3

'the development.of reactor safety criteria.

In my present position I have -

participated in the safety reviews of several power reactors by the Atomic Energy Commission and the Nuclear Regulatory Commission.

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