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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
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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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Text
"
I UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
SOUTH CAROLINA ELECTRIC & GAS COMPANY, et al.
Docket No. 50-395-0L (Virgil C. Summer Nuclear Station, Unit 1)
COUNTY OF ALLEGHENY ss STATE OF PENNSYLVANIA AFFIDAVIT OF W. D. FLETCHER My name is W. D. Fletcher. I am Manager, Steam Generator Development and Performance Engineering in the Nuclear Technology Division of the Westinghouse Electric Corporation. My business address is P.O. Box 855, Pittsburgh, Pennsylvania 15230. I have previously prepared an Affidavit for use in this proceeding with regard to the " Petition to Intervene and Request for Hearing" filed by Fairfield United Action ("FUA") dated April 9, 1982. I have reviewed the " Motion for Admission of New Contentions" dated April 14, 1982 submitted by Brett A. Bursey in this proceeding. Mr. Bursey's New Contention 1 is very similar to FUA's Contention Bil. The purpose of this Affidavit is to address whether, as Mr. Bursey contends (Motion at 2), his motion raises significant safety questions. I have reviewed the results of the data gathered from 1For this reason, I have made several references to my earlier Affidavit.
I wish to incorporate my April 22, 1982 Affidavit herein. A copy is attached for ready reference.
8205040447 820429 DRADOCK05000g )
o o operating plants, utilizing Model D steam generators. In my opinion, the interim operation program developed by Westinghouse and South Carolina Electric & Gas Company ("SCE&G") for the V. C. Summer plant will preclude any significant steam generator tube wear until modification to the steam generators can be implemented. New Contention 1 does not present, in my opinion, significant safety issues. As explained in greater detail in my Affidavit of April 22, 1982 referenced above, I have concluded that the interim operating program for the Summer plant within the specified parameters will minimize the potential for significant tube wear.
Beyond the interim operation program, Westinghouse currently has an engineering design program to modify Model D steam generators to alleviate tube wear. The anticipated design modification can be implemented in the field. An extensive testing program is in progress to verify that the anticipated modification to the steam generator preheater section addresses and corrects tube wear. The testing program incorporates a variety of testing facilities such as 0.417, 2/3 and full scale model tes ting. These test results, when combined with actual plant performance data, are expected to provide verification that the design .nodification will perform as predicted by engineering design analysis.
Mr. Bursey argues in his New Contention 1 that if the plant is not safe to operate at full power, it should not be allowed to operate at half power. The logic of that argument escapes me, and I certainly disagree both with the premise and the conclusion. As outlined for l
Summer, the interim program for operation is designed to minimize the potential for significant tube wear, based on laboratory findings and other plant operating experiences at reduced power levels. This program 2
includes periodic tube inspections in addition to analysis of tube motion instrumentation data taken while the plant is in operation. This program for interim operation is explained in my April 22, 1982 Affidavit. More-over, subsequent to the modification, which will have been tested prior to installation, it is expected that the plant will be operated at full power without experiencing excessive tube wear.
The other issues raised in New Contention 1 are not concerns during the V. C. Summer interim program as described above and in my April 22, 1982 Affidavit. Operation during this period is designed to minimize the potential for tube wear so that tube rupture, multiple tube rupture and/or LOCA events and actions of the PORV are not relevant.
FURTHER AFFIANT SAYETH NOT.
P 3
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Before me, the undersigned authority, personally appeared W. D. Fletcher, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Corporation (" Westinghouse") and that the averments of fact set forth in this Affidavit are true and correct to the best of his knowledge, infor-mation, and belief:
/
bU t W. D. Fletcher, Manager Steam Generator Development and Performance Engineering Sworn to and subscribed beforemethise1.fday of da'f /
t[ 1982.
_l$$b$0/ / Ydk Notary Public eiutt 5104uA, n0TARY PU211C N04fl0EVILLE 80R0, ALLEGHENT COUNTY MY COMul53 ION EIPitES MARCa 10.1988 Member. Pennsvivania Association of Notades l
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