ML20052F257
| ML20052F257 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/07/1982 |
| From: | Rothschild M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Citizens Association for Sound Energy |
| Shared Package | |
| ML20052F258 | List: |
| References | |
| NUDOCS 8205120290 | |
| Download: ML20052F257 (34) | |
Text
i s.
l 5/07/82 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
TEXAS UTILITIES GENERATING COMPANY,)
)
50-446
)
(Comanche Peak Steam Electric
)
Station, Units 1 and 2)
)
NRC STAFF ADDITIONAL ANSWERS TO CASE'S THIRD SET OF INTERR0GATORIES ON CONTENTION 5 On April 20, 1982, CASE filed " CASE'S Third Set of Interrogatories and Requests to Produce to NRC Staff."
(" CASE's Third Set"). According to CASE, these interrogatories relate to Contention 5.1I CASE states
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Contention 5, as admitted by the Licensing Board in its June 16, 1980, Order, alleges:
Contention 5.
The Applicants' failure to adhere to the quality assurance / quality control provisions required by the construction permits for Comanche Peak, Units 1 and 2, and the requirements of Appendix B of 10 C.F.R. Part 50, and the con-struction practices employed, specifically in regard to concrete work, mortar blocks, steel, fracture toughness testing, expansion joints, placement of the reactor vessel for Unit 2, welding, inspection and testing, materials used, craft labor qualifications and working conditions (as they may affect QA/QC) and training and organization of QA/QC personnel, have raised substafitial questions as to the adequacy of the construction of the facility. As a result, the Commission cannot make the findings required by 10 C.F.R. 50.57(a) necessary for issuance of an operating license for Comanche Peak.
(CFUR 4A-ACORN 14-CASE 19 Joint Contention) h$C1 h t 8205120290 920507 DRADOCKOS000g g
that the interrogatories are filed " pursuant to 10 C.F.R. 5 2.720(h)(2)(ii),"
but that CASE did not request a finding by the Board pursuant to those provisions, in accordanca with the Board's instructions to work ou' answers t
informally.
(CASE's Third Set, at 1).
Pursuant to 10 C.F.R. 5 2.740b(a) and 5 2.720(h)(2)(ii),2/ the Staff is not required to respond to CASE's Interrogatories unless the Licensing Board finds that the answers are "necessary to a proper decision in the proceeding," and that the answers are "not reasonably obtainable from any other source" and, on that basis, the Licensing Board directs the Staff to respond. Although objections to these interrogatories in their entirety may properly lie on grounds of 10 C.F.R. 5 2.720(h)(2)(ii), the Staff, in keeping with the Licensing 2_/
The Commission's Rules of Practice specifically exempt the Staff from responding to interrogatories except as provided by 10 C.F.R. 5 2.720(h)(2)(ii).
See 10 C.F.R. b 2.740b(a). The provisions of 10 C.F.R. 5 2.720(h)T2T(ii) are as follows:
[A] party may file with the presiding officer written interrogatories to be answered by NRC personnel with knowledge of the facts designated by the Executive Director far Operations.
Upon a finding by the presiding officer that answers to interrogatories are necessary to a proper decision in the proceeding and that answers to the inter-rogatories are not reasonably obtainable from any other source, the presiding officer may require that the staff answer the interrogatories.
This rule, as well as other regulations relating to discovery against the Staff, was explained by the Appeal Board in Pennsylvania Power and Light Co., et al. (Susquehanna Steam Electric Station, Units 1 and 2), ALAB-613, 12 NRC 317, 323 (1980).
i s
i Board's direction,1/ contacted CASE by telephone to discuss these interrogatories. As a result of the agreement reached during those telephone conversations, by letter dated May 4, 1982, the Staff provided information and documents to CASE in response to certain of the interrogatories.
4 Attached hereto are the Staff's answers to the interrogatories not answered by letter dated May 4,1987, together with the affidavits of Mr. Robert G. Taylor, Mr. William A. Crossman and Mr. Robert C. Stewart.
The responses to all of these interrogatories are based on information provided by those individuals.
Respectfully submitted, IL IbLclAilml Marjorie U. Rothschild Counsel for NRC Staff Dated at Bethesda, Maryland this 7th day of May, 1982.
i
-3/
See Texas Utilities Generating Company (Comanche Peak Steam Electric Station, Units 1 and 2), 14 NRC 150, at 154-157 (1981), wherein the Licensing Board directed the parties to, inter alia:
... confer directly with each other regarding alleged deficiencies in discovery before resorting to motions involving the Board." Order, supra, at 9.
In addition, in its " Order Subsequent to Prehearing Conference of December 1, 1981," dated December 18, 1981, the Board directed the parties to:,
... provide each other with basic information to aid in discovery... Order, at 4.
=-.
NRC Staff Answers to CASE Third Set 1.
This question asks the identity of the persons who prepared the Trend Analyses.
They are as follows:
1976 - R. C. Stewart 1977 - R. C. Stewart 1978 - R. G. Taylor 1979 - R. G. Taylor s
2.
This question asks whether the persons identified in question 1 will testify in the upcoming hearings.
The answer is Yes.
3.
This question asks if the person will be made available, if the answer to question 2 is negative.
No answer is required.
4.a. Yes.
4.b. N/A
2 4.c. NRC Inspection Report 50-445/75-13 identifies a citation relative to the lack of initiating prompt corrective action with regard to deficiency and disposition requests.
The applicant's response to this item is contained in a letter of reply dated January 15, 1976 (TXX 1331).
The NRC acknowledgement letter; G. L. Madsen to Perry G. Brittain, dated February 12, 1976, also alludes to the need for additional information regarding the quality of concrete.
The mutter was resolved during an NRC inspection ccnducted March 10-12, 1976, and as noted in IE Inspection Report 50-445/76-03.
Additional related documents are identified in IE Inspection Report 50-445/76-03 which makes reference to applicant's documents reviewed on site.
NRC Inspection Report 50-445/76-08 identifies a citation which states "the TUSI site surveillance inspector observed that the F&N QA Manager's duties i
and responsibilities encompassed engineering functions beyond that which is described in the CPSES QA Program Manual.
This item of nonconformance l
was not documented as prescribed in the TUSI QA Plan."
l The applicant's response to this matter is contained in a letter of reply dated September 21, 1976, (TXX 1913).
Additional information regarding the infraction (76-08/I.A.2.b.) was requested by a Region IV letter:
W. C. Seidle to R. J. Gary, dated October 8, 1976.
3 The additional information requested is contained in the applicant's letter to W. C. Seidle from R. J. Gary, dated October 26, 1976, (TXX 1998).
The item was resolved during an NRC inspection conducted November 2-5, 1976, and as noted in IE Inspection Report 50-445/76-11.
Other NRC documents involved included an internal Memorandum; R. E. Hall to W. C. Seidle, dated August 25, 1976; and the NRC Manual Chapter 0850.
Any other documents involved, such as Corrective Action Requests, etc., I have not been able to identyfy.
This information should be reauested of the appli-cant.
4.d. With regard tc IE Inspection Report 75-13, related documents that are available from the Public Document Room are as follows:
IE Inspection Report 50-445/75-13, dated December 16, 1975.
Texas Utility Generating Company Reply; Letter, TXX 1331, J. L. Forbis to G. L. Madsen, dated January 15, 1976.
IE Acknowledgement Letter, G. L. Madsen to Perry Brittain, dated February 12, 1976.
IE Inspection Report 50-445/76-03, dated April 1, 1976.
Applicant's documents referenced in IE Inspection Report 50-445/76-03 should be requested from the applicants.
4 With regard to IE Inspection Report 50-445/76-08, documents concerning this matter that are available from the Public Document Room are as follows:
IE Inspection Report 50-445/76-08; dated August 20, 1976.
IE Inspection Report 50-445/76-11; dated October 14, 1976.
IE Letter; W. C. Seidle to R. J. Gary, dated October 8, 1976.
Texas Utility Generating Company Letter (TXX 1913), R. J. Gary to W. C. Seidle, dated September 21, 1976.
Texas Utility Generating Company Letter (TXX 1998), R. J. Gary to W. C. Seidle, dated October 26, 1976.
Other NRC documents concerning this matter and available to CASE for review at the Region IV office, Arlington, Texas, are:
Copies of internal memorandum, R. J. Hall to W. C. Seidle, dated August 25, 1976, and IE Manual Chapter 0850.
Any other documents relating to the item, such as Corrective Action Requests, Deficiency and Disposition Requests should be requested from the applicant's.
4.e. Yes, to both parts.
5 An adequate level of confidence was reached in early 1977.
The applicant's change in senior management is considered the contributing factor.
Also refer to Item C of 1977, 1978, and 1979 Trend Analysis.
4.f. N/A 4.g.(1)
It was the inspector's observation that the Brown & Root construction management, from the foremen up through the site manager, were demonstrating oppressing / domineering, and intimadat-ing attitudes toward, both the Tugco QA and B&R QA/QC staff personnel.
At the time, there appeared to be no response, or attempt to correct this unpleasant atmosphere by either Tugco or B&R corporate management; thus, the inspector's comment that "The licensee's QA/QC program was in a state of degradation."
4.g.(2)
Yes 4.g.(3) 1.
The appointment of Mr. R. J. Gary, Executive Vice President and General Manager on August 11, 1976.
2.
A September 10, 1976, TUSI and TUGO management change.
6 3.
The establishment of a TUSI Onsite Senior Staff Management Team in late 1976 and early 1977.
4.h.
To the inspector's knowledge, there are no such documents, other than those previously provided.
4.i.
N/A
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5.a.(1)
The contractor's QA/QC Program Procedure Development resulted in the generation of too many procedures ant' instructions applicable to a particular construction activity which made it difficult for craftmen and inspectors to clearly understand and implement.
5.a.(2)
I can only recall that a concerted effort by B&R was initiated to reduce the number of procedures by consolidation of procedures /instruc-tions that improved the procedure in both quality and adequacy.
I N
believe this was contributory to only three citations issued to the applicant in 1977.
l 5.b. To my knowledge there are no other documents relating to the trend analysis for 1977 other than the specific references to Inspection Reports 50-445/76-08 and 50-445/76-09. The trend analysis and supporting documents are available in the Region IV Office for inspection and 1
copying.
l 5.c. Not applicable 1
c a
a
7 6.
Did Mr. Crossman write a memorandum (such as those for 1976, 1977, and 1979, CASE Attachment A pages 2, 3, 7, 8, 19, and 20) to the facilities inspectors for 1978?
Yes, a memorandum was written, dated February 2, 1979, to the facilities inspectors for 1978.
A copy of the memorandum is available in the NRC Region IV office.
7.
The question relates to various statements appearing in the Trend Analysis - 1978.
7.a. The six potential construction deficiencies mentioned in the Trend Analysis were initially discussed in the inspection report noted in the first column below.
The final discussion of each item appears in the inspection j
report noted in the second column.
All inspection reports are in the Public Document Room.
Initial Report Final Report 50-445/78-05 50-445/78-11 50-445/78-09 50-445/78-11 50-445/78-10 50-445/78-10 50-445/78-16 (3.a.)
50-445/78-17 50-445/78-16 (3.b.)
50-445/78-20 l
c, 8
50-445/78-16 (3.c.)
50-445/78-22 Information relative to nonconformance reports (NRCs) should be directed to the applicant since there is no record of these in the NRC reports.
7.b. Additional information was requested relative to the applicant's response l
to NRC Inspection Report 50-445/78-05.
The Region IV letter to the applicant was dated May 12, 1978; the applicant's response was dated July 12, 1978; and the Region IV acceptance of the response was documented in a letter dated July 24, 1978.
The second time that a request for additional information was made occurred in relation to NRC Inspection Report 50-445/78-18.
The applicant's initial response to the inspection finding was dated November 16, 1978.
The Region IV request for more information was dated December 8, 1978.
The applicant's second response was dated December 20, 1978, and the Region IV letter closing the matter was dated November 2, 1979.
All referenced correspondence is on file at the Public Document Room in accordance with NRC policy.
Information relative to Corrective Action Requests, Deficiency and Disposition Requests, Nonconformance Reports, etc., should be directed to the applicant since there is no record of these in the NRC files.
7.c.(1)
CDN is en acronym for Construction Deficiency Notice which in turn is a term used within the NRC to denote a report made to the NRC in accordance with 10 CFR 50.55(e).
9 7.c.(2)
The comment about the time span for unresolved items was made in
~
general terms without extensive information being developed.
The records provide two such instances.
NRC Inspection Report 50-445/78-05 for April of 1978 discusses the non-availability of vendor documenta-tion related to several tanks.
The item was not resolved until NRC Inspection Report 50-445/78-20 for November 1978.
Another example was NRC Inspection Report 50-445/78-13 for September 1978 which was also resolved as documented in NRC Inspection Report 50-445/78-20 for November 1978.
The latter illustration may appear to be a short time span, but was essentially 2 months based on the recollection of the inspector.
7.c.(3)
During the time period to which the Trend Analyses applies, it was an unwritten Region IV practice to initially discuss Applicant Construc-tion Deficiency Notices in the next inspection report and to subsequently carry them in our records as unresolved items.
7.c.(4)
W does mean Westinghouse.
- 7. d. It is stated in each inspection report where unresolved items are identified that " Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompli-ance, or devi,ations." Hence, an unresolved item may become an item of noncompliance, an enforcement item, when the necessary information is received.
The determination on the conversion of an unresolved item to an acceptable item or to an enforcement item is generally made by the inspector and/or his supervisor who reviews the additional information.
10 4
7.e.(1)
The term "not having enough real talent to do the job correctly" was the writer's way of expressing a concern that some personnel who prepared procedures were somewhat inept in writing procedures.
7.e.(2)
Specific " instances" cannot be provided since there are no records bearing on the matter.
As a more general response, broad guidance type procedures are appropriate when the using personnel are very highly qualified while more specific procedures are required when the using personnel are lesser qualified.
QC personnel have been generally found to meet the requirements of the industry standard, N45.2.6 but would not necessarily be considered a highly qualified individual.
7.e(3)
NRC records do not reflect the names of such personnel nor is the inspector able to recall the names.
7.e.(4)
The term quoted must be taken within the context of the entire paragraph.
The inspector's intent was to express an attitude relative to the need for an adequate balance between very specific procedures and the qualificiations of the people using these procedures.
Thus, a slight imbalance can result together with a small amount.of ineffec-tiveness.
Had the imbalance been more severe, the procedures would have been judged inadequate relative to Criterion V of Appendix B to 10 CFR 50.
The action level for being " forced to attack the situation head-on" would have been based upon the inspector's professional judgment and upon the professional judgment of other NRC inspection personnel inspecting at the site.
11 7.f.
To the best of the inspector's knowledge, there are no additional documents.
7.g. N/A 8.
This question relates to various statements appearing in the Trend Analysis-1979.
8.a. The two items officially categorized by the licensee as 50.55(e) items were:
8.a.(1)
Piping Minimum Wall:
Initial discussion of this matter appeared in NRC Inspection Report 50-445/79-13.
The final discussion of the matter appeared in NRC Inspection Report 50-445/81-09 which also provides a ready reference to several applicant documents on the subject; all of which are in the Public Document Room.
8.a.(2)
Electrical Cable Tray Hangers:
Initial discussion of this matter appeared in NRC Inspection Report 50-445/79-16.
The final discussion of the matter appeared in NRC Inspection Report 50-445/79-27 which also referenced the applicant's correspondence on the matter.
l 8.b.(1)
By way of explanation of the statement "but also not neessarily our fault either in terms of the way the noncompliance is written" was meant by the inspector to indicate that the specificity required by I
1 l
u
12 10 CFR 2, paragraph 2.201, sometimes lends itself to obtaining a less than completely satisfactory response from the applicant.
8.b.(2)
By way of explanation of the statement "wanting something a bit stronger for the record" was meant to express the fact that occasionally an applicant's response was not auditable and, therefore, not strong enough.
A need for auditability is not discussed in 10 CFR 2, paragraph 2.201.
8.c.(1)
The person recommended by the inspector and selected by Region IV management was R. H. Brickley of the Reactor Systems Section of the Vendor Program Branch of Region IV.
8.c.(2)
The audit or, more specifically, an inspection was made in early February 1980, and was documented in NRC Inspection Report 50-445/80-04.
8.c.(3)
The inspection was conducted in accordance with the NRC Inspection Procedure 37996B which is on file in the Public Document Room. 1 The results of the inspection were documented in NRC Inspection Report 50-445/80-04.
8.c.(4)
N/A 8.c.(5)
There ar,e no other documents than NRC Inspection Report 50-445/80-04 and inspection procedure 37996B.
13 8.d.(1)
All official NRC actions are with the licensee (applicant) and may include their agents, of which 8rown & Root is one.
In the specific instance, both were involved.
8.d.(2)
Both line inspectors and first tier supervision were involved.
8.d.(3)
The name of the persons were not a matter of record. The inspector can not recall the names of the individuals involved.
8.d.(4)
The applicant interviewed, at length, the personnel involved and reviewed the respective backgrounds for a better insight into the training needs.
Additional training was developed and provided by the applicant's quality engineering group.
The inspection procedures used by the QC personnel were substantially revised to provide more specificity.
First tier supervision was enhanced by the selection of personnel with the background to appropriately guide the line personnel.
8.d.(5)
Since, as indicated by 8.d.(3), the names are not a matter of record or of recollection, nor can the inspector cecall the names of the individuals.
8.d.(6)
N/A 8.d.(7)
N/A
14 8.d.(8)
The specific observation was documented as a Notice of Violation in NRC Inspection Report 50-445/79-18.
8.d.(9)
All information on the matter is included with NRC Inspection Report 50-445/79-18.
8.e.(1)
The statement " turn the situation around" was in reference to the imbalance between the levels of instructional detail in the inspection procedures within the inspection force.
Refer to question 8.d.(4),
above.
8.e.(2)
No.
The particular wording was chosen since the persons utilizing the Trend Analysis were aware that piping and electrical installations were in 1979 just getting underway although some piping work had been done in 1978.
The other principal discipline area, i.e., civil type construction had been underway since 1975 and was much more refined.
8.e.(3)
To the inspector's knowledge, there are no such documents (other than those already provided).
8.f.(1)
The NRC does not specifically approve or disapprove the procedure.
It is allowed by the last paragraph of Criterion III of Appendix B to 10 CFR 50, subject to a requirement that the design changes be reviewed and approved in the same manner as was the original design.
15 8.f.(2)
N/A 8.f.(3)
There is no authority, then or now, provided the design change review methods are implemented properly.
8.f.(4)
There are no specific instances identified in NRC inspection reports.
8.f.(5)
N/A 8.g.(1)
The basis for the first sentence is an opinion by the inspector and has no legal basis.
8.g.(2)
Bechtel is a reference ce the Bechtel Corporation.
ANO-2 is an acronym for a nuclear power facility near Russelville, Arkansas, with an owner assigned name of Arkansas Nuclear One-Unit 2.
8.g.(3)
To my knowledge, there are no other documents dealing with this matter.
8.h.(1)
The inspector's concern was that the applicant would become reluctant to follow the NRC guidance relative to reporting " potential" construc-tion deficiencies as described by 10 CFR 50.55(e).
As discussed in the answer to question 7.c(3), such "potentially" reportable items were recorded in the inspection reports.
There were instances, which the inspector can no longer specifically recall when the newspapers in the Dallas / Fort Worth area carried articles discussing these incidents.
l 16 The phraseology used was and is not considered either mild or inflamatory by the inspector.
8.h.(2)
Yes 8.h.(3)
Why the inspector continued to observe the applicant's actions with regard to 10 CFR 50.55(e).
8.h.(4)
The predicted situation did develop.
8.h.(5)
N/A 8.h.(6)
Two instances of " failure to report" were the subject of Notices of Violation included within NRC Inspection Reports 50-445/80-08 and 50-445/80-18, respectively.
8.h.(7)
The guidance referred to is material published in the NRC Inspection and Enforcment Manual under 10 CFR to assist the inspectors in understanding all of the requirements of 10 CFR 50.55(e).
The Manual is on file in the Public Document Room. 1 8.h.(8)
The only additional document relative to this matter not discussed above is NRC Inspection Report 50-445/80-12, also in the Public Document Room.
This report discusses a meeting between the applicant and the NRC staff in regard to reporting significant construction deficiencies.
17 8.i. There are no additional documents.
8.j. N/A 9.
The meanings of the columns appearing on the referenced pages is as follows:
V or Viol. are abbreviations for " Violation." The term violation was used as a classification tool to denote the relative seriousness of an item of noncompliance included in a Notice of Violation.
Violation was considered the most serious level of noncompliance with a connotation of having an immediate potential impact on the health and safety of the public.
1 I or Infr. are abbreviations for an " Infraction." The term was used in the same context as above to denote a less serious classification Faving only a potential for affecting the health and safety of the public.
D or Def. or DF are abbreviations for " Deficiency." The term was used in the same context as above to denote the lowest level of noncompliance where l
there was little or no potential impact on the health and safety of the public.
D (the second time used) or DV or Dev. are abbreviations for a " Deviation."
This term is applied to inspection findings where the applicant has not violated the NRC Rules or Regulations but has not fulfilled a commitment contained or referenced in his Safety Analysis Report.
18 M/D or Man Days denotes the total NRC inspection time den ted to an inspection.
U or Unres. items denotes the number of unresolved items discussed in the applicable inspection report.
RRI denotes that the resident reactor inspector was the inspector of record.
RGL denotes that the inspection was performed by one or more Region IV office based personnel.
RUT denotes that the inspection was performed within the NRC routine inspection program.
INV denotes that the inspection was of the nature of being an investiga-tion, usually of allegations received.
(
10.
The information provided to CASE was obtained from the personal files of l
Mr. W. C. Seidle.
Mr. Seidle was the Chief of the Reactor Construction l
and Engineering Support Branch of Region IV at the time the information was generated.
The inspectors who generated the mat'erial did so in rough draft which was subsequently finalized (typed) by other personnel.
In the case of the 1978 and 1979 Trend Analysis, the draft material was probably transmitted from the Resident Inspectorb office at Comanche Peak to Region
19 IV by electronic means.
The draft material, having no further use to the inspectors, was destroyed.
The final materials remain in Mr. Seidle's possession and are available to CASE for inspection and copying in the Region IV offices.
11.
To the best of our knowledge, no.
I 12.
N/A 13.
Mr. Taylor was the person who identified the existence of Trend Analyses to Ms. Rothchild.
Mr. Seidle offered the documents to Ms. Rothchild since neither Mr. Taylor nor Mr. Stewart had retained any copies, notes, drafts, etc.
14.
Yes 15.
Yes 16.
A copy of this information will be available in the NRC Region IV office.
17.
There is no specific procedure in the NRC inspection program for construc-tion that requires an inspector to determine if the construction permit 1
i holder reports every appropriate item to the NRC.
Some of the inspection procedures however, do require that the inspectors examine nonconform-ance reports for completeness, clarity, and appropriateness of corrective
20 actions.
The inspectors would normally consider whether an item had the significance to be reportable.
The nature of 10 CFR 50.55(e) recuires sound, technical judgments on the part of the permit holder in regard to what should be and what should not be reported to NRC.
Within the body of the " guidance" 1 it is stated "The licensee has to make a judgment based on his (or others) evaluation / analysis.
If the licensee decides, on the basis of the above, that a matter is not reportable, he has satisfied the intent of this part of t*ie Regulation."
18.
N/A 19.
Please see the answer to question 8.h.(7).
20.
No 21.
N/A 22.
N/A 23.
N/A 24.
The NRC staff, primarily the assigned project inspector, generally maintains an open items list.
The lists that have been maintained for CPSES do not provide the level of informational detail depicted by the question.
The lists provide information as to the original inspection report discussing
21 an item, a brief descriptive title, the classification assigned, and the inspection report number where the item is finally discussed.
25.
The lists are available for inspection and copying in the Senior Resident Inspector's (Construction) office at CPSES.
26.
The present enforcement policy is stated in 10 CFR 2 and was also noticed in the Federal Register 47 FR 9987 published March 9, 1982.
Part 2, Statements of Consideration also published in the above noted Federal Register explain the history of the evoluation of NRC enforcement policy.
1/
- 29. With respect to the first statement, my answer is yes.
Withrespecttothesecondstatement,therearefourserhicewaterpumpsat Comanche Peak for which final assembly and testing was probably done by Hayward-Tyler. However, the foundry and machine work was done under the auspices of the original contract agent, Babcock & Wilcox (Canada).
1/ The Public Document Room referred to is the main room at 1717 H Street, Washington, D.C.
Provision can be made for CASE to examine and copy these documents in the Region IV office rather than visiting the main NRC Public Document Room.
__m-,-
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I
BEFORE THE AT0 HIC SAFETY AND LICENSING BOARD In the Matter of
)
)
J TEXAS UTILITIES GENERATING COMPANY
)
Docket Nos. 50-445 i
)
50-446 i
)
I (Comanche Peak Steam Electric Station,
)
Units 1 and 2)
)
AFFIDAVIT OF ROBERT G. TAYLOR I, Robert G. Taylor, t, ding duly sworn, do depose and state:
1.
I am the NRC Senior Resident Inspector (Construction) at the Comanche Peak Steam Electric Station.
2.
I was responsible for providing the information in the Staff's answer to CASES's Third Set of Interrogatories (4/20/82) numbers 1, 2, 3, 7, 8, 9, 10, 11, 12, 13, 14, 15, 17, 18, 19, 20, 21, 22, 23, 24, 25,26 and 29.I certify that the answers given are true and accurate to the best of my knowledge.
1 I
Jh?f Yfus
_./
Robert G. Taylor Stbs.ribed and sworn to before me this
- I day of
, 1982 M
A nie t I
<< o>.a.-
Notary Public My Commission expires: /-6-/d
PROFESSIONAL QUALIFICATIONS 7
OF ROBERT G. TAYLOR OFFICE OF INSPECTION AND ENFORCDiENT, REGION IV UNITED STATES NUCLEAR REGULATORY COMMISSION
~
Mr. Taylor is currently the Resident Reactor Inspector at the Comanche Peak Steam Electric Power Station.
In this position, he serves to coordinate all safety related inspection efforts relative to the NRC region and the site.
In addition, he maintains a field office, develops and reconnends enforce-ment action, and acts as a liaison with regional, state and local agencies.
Prior to being the Resident Reactor Inspector at Comanche Peak, Mr. Taylor was the construction project reactor inspector at the South Texas Project from 1976 to 1978.
Mr. Taylor is a registered Professional Engineer in the State of California, spe:ializing in quality control engineering.
Prior Work History 1978 - PRESENT Resident Reactor Ins'pector, Comanche Peak Huclear Power Station.
Duties include coordinating all safety related inspection efforts relative to the NRC region and the site, as well as, maintaining a field office and being a liaison with regional, state and local agencies.
1976 - 1978 Construction Project Reactor Inspector,' Arkansas Nuclear Power Unit No. 2 and South Texas Project. Duties included inspection of the South Texas Project while under construc-tion to ascertain whether this facility conformed to the provisions of the construction pennit and relevant j
specifications.
1974 - 1976 Reactor Inspector, Vendor Inspection Branch, Project l
Inspector for Stone and Webster Corp. and Combustion i
Engineering, Inc.
l 1968 - 1974 Senior Quality Assurance Engineer, Fort Calhoun Nuclear i
Power Station. Mr. Taylor was the Senior Quality Assur-i ance Engineer for Gibbs and Hill, Inc.
1962 - 1968 Senior Quality Assurance Engineer, AMF Inc. Duties in-cluded various quality assurance positions'in regani to ballistic missile construction projects.
l
k
(
1960 - 1962 Construction Section Supervisor, Quality Control Titan 1.
Denver, Colorado, United States Air Force.
1953 - 1960 Electronic Section Sapervisor, Quality Control, Chicago Air Procureraent District, United States Air Force.
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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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TEXAS UTILITIES GENERATING COMPANY
)
Dockets:
)
50-446
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(Comanche Peak Steam Electric Station, )
Units 1 and 2
)
AFFIDAVIT OF ROBERT C. STEWART I, Robert C. Stewart, being duly sworn do depose and state:
1.
I was the principal inspector for the Comanche Peak Steam Electric Station from June 1974 to January 1978.
2.
I was responsible for providing information in the staff's answer to CASES'S Third Set of Interrogatories (4/20/82) numbers 1, 2, 3, 4, 5, 9,10, 11, 12, 17, 18, 19, 24, 25, and 26.
I certify that the answers given are true and accurate to the best of my knowledge.
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- 4 Robert C. Ste' watt
Su,bscribed and sworn to before me dh tisbv(dayof 1 82.
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1L Not,ary Public My Commission expires:
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Statement of Professional Qualifications Name:
Robert C. Stewart
Title:
Reactor Inspector Employer:
Division of Resident, Projects, and Engineering Programs, Region IV, United States Nuclear Regulatory Comission.
I am a Reactor Inspector in the Projects Branch #1, Project Section A in the Division of Resident, Projects, and Engineering Programs, Region IV, located in Arlington, Texas.
In this position, I am responsible for inspections and coordination of all safety-related inspections for facilities assigned to me within Region IV jurisdiction.
I held this assignment for the Comanche Peak Steam Elec-tric Station during the period July 1974 to January 1978.
Education:
Farragut College, Farragut, Idaho (Univ. Idaho)1946-48 Mechanical Engineering / Nuclear Engineering Heald Engineering School, San Francisco, Calif. (night 1953)
G.E. School of Nuclear Engineering, Richland, Wn. (night 1943))
G.E. School of Nuclear Engineering, Richland, Wn. (night 1954 Pierce College, Woodland Hills, Calif.
(night 1967-68)
Engineering Management i
NRC Training Courses i
NRC Training Center Courses:
Concrete Technology & Codes Refresher Courses September 1981 Nondestructive Examination Refresher Course June 1980 Electrical Technology & Codes July 1979 BWR 4 Reactor Systems and operations May 1973 BWR 6 Feb. 1973 PWR W.
April 1975 NRC Teactor inspection techniques Dec. 1977 Ohio State University Columbus, Ohio Welding technology and Codes Oct. 1977 l
l Portland Cement Association Skokie, Ill.
Concrete Technology and Codes Feb. 1977 Convair School for Nondestructive Testing General Dynamics Convair Aerospace Div.
- San Diego, California Jan. 1976 t
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2 University of Texas at Arlington Graduate course: Nuclear Power Engineering Fall 1977 Advanced Problems in ME Solar Energy Spring 1978 Experience:
1971-Present:
Reactor inspector, Region IV, U.5. Nuclear Regulatory Connission In this position I am responsible for project inspection of nuclear facilities under Region IV jurisidiction.
1955-1971 Rockwell International (fonnerly Atomics International, Inc.) Canoga Park, California.
Senior Facilities Proje.ct Engineer:
Assigned to the Program Office of the Fast Flux Test Facility (FFTF) Reactor fuel handling systems design and manufacturing. Responsible at project level to coordinate, plan, and program the conceptual designs, and testing of the FFTF. Duties also involved an assignment as Construction Manager, Sodium Component TestInstallation(SCTI).
Senior Research Engineer:-
II Assigned to SNAP Compact Power Systems, Testing, and Launch Team. As a member of the SNAP 10A launch team, coordinated the transporation handling, launch vehicle interfacing, and pre-launch and post-launch testing of the world's first t uclear reactor to be orbited in space.
l Reactor Construction Engineer / Senior Research Engineer:
Overseas on-site representative in the construction of four, 50 kW, research reactors; Tokai-Mura, Japan; Frankfurt, Germany; Berlin, Gennany; and Milano, Italy.
subsequent to the overseas assignments, I was assigned as a member of the Reactor Testing unit of the SNAP experimental reactor grnup in the successful demonstration of the feasibility of the SNAP II, 50 KW-NAK coolant reactor concept. -
Senior Reactor Construction Engineer:
Senior Site representative (Construction) responsible at project level to coordinate, plan, program and supervise the construction of a 40 MWe Organic Moderated Reactor (OMR) for the city of Piqua, Ohio. The assignment also included the supervision of maintenance, in charge of
Time-and Material contract, in completing repairs and
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design changes and modifications.
Reactor Construction Engineer:
As the on-site representative, supervised reactor installation and associated components of first sodium cooled nuclear power reactor, Santa Susana, California.
Duties involved direct supervision of construction forces in the installation and erection of the reactor containment, reactor vessel and associated components / systems. Duties also included the development of installation and testing procedures.
1947-1955:
Kaiser Engineers and Atkinson & iones, Richland, Washington.
l Assistant Department Engineer - Mechanical Assigned to the on-site construction project manager's staff in the construction and preoperational testing of five plutonium production reactors at Richland, Washington.
My duties involved the coordination of all work programs of the field and field engineering staff; direct field design.
layouts required to simplify various phases of project con-struction; and establishment of testing prograns/ procedures and supervision of final systems / component acceptance testing.
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O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
TEXAS UTILITIES GENERATING COMPANY
)
Dockets:
)
50-446
)
(Comanche Peak Steam Electric Station,
)
Units 1 and 2
)
AFFIDAVIT OF WILLIAM A. CROSSMAN I, William A. Crossman, being duly sworn do depose and state:
1.
I am the Chief, Reactor Project Section B, at the NRC Region IV office.
2.
I was responsible for pec;iding information in the staff's answer to CASES'S Third Set of Interrogatories (4/20/82) numbers 6 and 16.
I certify that the answers given are true and accurate to the best of my knowledge.
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William A. Crossman pubscribed and swo n to before me Ithis 3rd day of 1982.
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'Y Notary Public My Commission expires:
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PROFESSIONAL QUALIFICATIONS OF WILLIAM A. CROSSMAN UNITED STATES NUCLEAR REGULATORY COMMISSION Mr. Crossman is Chief Reactor Project Section B, Reactor Project Branch 1 Region IV, Nuclear Regulator, Commission Arlington, Texas.
Mr. Crossman has held this position in Region IV since May 1974, and in the course of his responsibilities he has reviewed, approved, and performed inspections and investigations of nuclear facilities under Region IV jurisdiction.
In this position, he was responsible, from May 1974 to March 1982, for the supervision of the project inspectors who inspect the Comanche Peak Project.
Mr. Crossman received a Bachelor of Science degree in chenical engineering from the University of Texas in 1950.
He is a registered Professional Engineer in Nuclear Engineering in the State of California.
Prior Work History 1974 - Present Chief, Reactor Project Section, Region IV - Responsible for direction of inspection personnel with review and approval of scope and report of inspections and investigations performed.
Participate in direct evaluation of activities related to reactor construction with occasional contact with ACRS at subcommittee meetings.
(AEC/NRC) 1973 - 1974 Chief, Reactor Project Section, Region II - Responsible for direction of inspection personnel with review and approval of scope and report of inspections and investigations performed.
Participate in direct evaluation of activities related to reactor construction with occasional contact with ACRS at subcommittee meetings.
(AEC) 1968 - 1973 Reactor Inspector - Served as a member of the technical staff oT Region II with responsibility for inspection of assigned power, research, and test reactors during construction, test and startup, and operation.
(AEC)
.1965 - 1968 Reactor Operation - Various supervisory responsibilities for Nuclear Reactor Operation, including refueling activities, health physics, maintenance, planning and scheduling, and design changes.
(Douglas United Nuclear, Inc.)
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1958 - 1965 Re_ actor Operation - Various supervisory titles and respon-sibilities for nuclear reoctors, including operations supervisor, refueling, health physics and maintenance.
(General Electric Co.)
1950 - 1958 Reactor Fuels Pro _ cessing - Various supervisory titles and responsibilities for nuclear related work, including plutonium and uranium recovery, irradiated fuel processing, plutonium production. radioactive waste managenent, and health physics.
(General Electric Co.)
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