ML20083C560
| ML20083C560 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/19/1983 |
| From: | Riley E CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | |
| Shared Package | |
| ML20083C535 | List: |
| References | |
| NUDOCS 8312230183 | |
| Download: ML20083C560 (21) | |
Text
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. AFFIDAVIT OF EMANUEL RILEY 9
8312230183 831219 PDR ADOCK 05000440 PDR 0
December 19, 1983
- UNITED STATES OF AMERICA 4
-NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board I
In the Matter of )
)
THE CLEVELAND' ELECTRIC ) Docket Nos. 50-440 ILLUMINATING COMPANY, ET AL. ) 50-441
)
(Perry Nuclear Power Plant, )
Units 1 and 2) )
d-. AFFIDAVIT OF EMANUEL RILEY -
4 County of Lake )
- ss:
State of Ohio )
Emanuel Riley, being duly sworn, deposes and says as foi ows:
! 1. I, Emanuel Riley, am General Supervisor, Construction Quality.Section (CQS), Nuclear Quality Assurance Department (NQAD), of The Cleveland Electric Illuminating Company (CEI).
My business address is 10 Center Road, Perry, Ohio 44081. A
- statement of my professional qualifications and experience is attached. I have personal knowledge of the matters set forth herein and believe them to be true and correct.
- 2. I have reviewed the Motion to Reopen the Record on Comstock Isaues, dated November 25, 1983, filed by Ohio u
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Citizens For Responsible Energy (OCRE), including the two newspaper stories attached to OCRE's Motion. The stories discuss allegations by two former Comstock quality control inspectors, Mr. Phillip G. Hendrickson and Mr. Gene F. Mathis.
I have also reviewed OCRE's November 30, 1983 letter to the Li-censing Board, which attaches a newspaper story discussing al-legations by a former Comstock inspector, Mr. Steve E. Balazs.
The purpose of this Affidavit is to address the health and safety allegations discussed in the three newspaper articles cited by OCRE.
- 3. As the General Supervisor of CQS, I have responsibil-ity for CEI's daily oversight of Comstock's QA/QC program im-plementation. There are numerous contractors at Perry, employing in excess of 300 QA/QC personnel. CQS personnel review and approve all contractor inspector certifications prior to the commencement of work by the inspectors. The Project Organization does not, as a standard practice, review terminations (resignations or discharges) of contractors' QA/QC personnel. However, when health and safety questions are I
raised by contractors' employees, such as with Mr. Hendrickson, Mr. Mathis and Mr. Balazs, CEI does review the facts to assure that applicable health and safety requirements have been met.
Following the media revelations of the inspectors' concerns, CEI officials initiated meetings with each of the three inspectors to review their concerns in detail. CQS personnel then undertook investigations of all of the issues raised by
the inspectors. CQS has taken additional steps to follow up on the published concerns of the three inspectors. The steps include interviews conducted by the CQS Electrical Unit Super-visor with each of Comstock's current inspectors (to date, seven of Comstock's 41 inspectors have been interviewed), and interviews by CQS of all terminating Comstock QA/QC employees.
Based on CEI's interviews-and investigations to date regarding the allegations of the three inspectors, CEI does not believe that the inspectors have identified any issues calling into question the adequacy of CEI's or~Comstock's QA/QC program at Perry or the safety of the plant.
Meeting With Mr. Hendrickson
- 4. On November 23, 1983, Mr. Cyril M. Shuster, the Manager of NQAD, and Mr. Ronald L. Farrell, the Manager of Perry Project Services Department, met with Phillip Hendrickson. The only specific " hardware" issue raised by Mr.
Hendrick. son during the meeting was his concern that Comstock's steel should be individually marked, and physically segregated by safety class in the yard prior to installation. This was stated as a general concern, and was not the result of any in-spections performed by Mr. Hendrickson. (Mr. Hendrickson was terminated prior to completing his training and certification, and thus, performed no inspections.) After Mr. Shuster and Mr.
Farrell explained to Mr. Hendrickson that individual marking, and physical separation, of Comstock's steel was not required
under the American Welding Society (AWS) Code and applicable project procedures, Mr. Hendrickson stated that he had no further. safety concern.
- 5. Mr. Hendrickson also complained to Mr. Shuster and Mr. Farrell about.being " intimidated" by a class instructor, and then being discharged after complaining about the alleged intimidation incident to Mr. Richard Bower, Comstock's Quality 3 Control Manager, and asking to talk to the NRC. CQS has thor-oughly investigated these charges, and'is convinced that Mr.
Hendrickson was not'" intimidated," and that he was not termi-nated for asking questions of his management or for asking to talk to the NRC. According to Comstock, Mr. Hendrickson was discharged during his ninety-day evaluation period, and prior to being certified to perform inspections, because of his su-pervisors' determination that he was unable, or unwilling, to learn Comstock's program. We have reviewed with Mr.
Hendrickson and his supervisors the facts surrounding the ter-mination', and have reviewed the applicable termination records.
In addition, we have discussed the matter with Jim Kerr, who was the CQS Electrical Unit Supervisor at the time of Mr.
Hendrickson's termination. Mr. Kerr spoke with Mr. Hendrickson
'and Mr. Hendrickson's supervisors during the meeting in Mr.
Bower's office in which Mr. Hendrickson was informed of his termination. All of our investigations and interviews have confirmed that there was no " intimidation," that the decision to terminate Mr. Hendrickson sas based solely on the merits of
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I his work, and that Comstock acted within its proper rights and obligations as an employer.
- 6. Mr. Hendrickson claimed to Mr. Shuster and Mr.
'Farrell that Mr. Robert Marino, a senior Comstock QA/QC official,-verbally intimidated Mr. Hendrickson during a training session. CQS has investigated the incident. The comment actually made by Mr. Marino was in a brief meeting in Mr. Bower's office, in which Mr. Marino was greeting Mr.
Hendrickson and several other new Comstock inspectors. Mr.
Marino, in a friendly tone, asked the inspectors why they had decided to leave their previous jobs. One of the inspectors, not Mr. Hendrickson, remarked that he had been terminated be-cause of a disagreement with his management. Mr. Marino point-ed to a black and white bottle of " white out," and said that if the inspector saw the bottle as orange, and Mr. Marino saw it as black and white, it was black and white. Mr. Marino's comment does not appear to us to have been intended to discourage the identification of quality problems. It was a .
spontaneous response to the remark of another inspector regarding his termination from a previous job. QA managers such as Mr. Marino are responsible for overseeing the work of large inspection staffs, and bear the ultimate responsibility to CEI for the adequacy of their program. In cases where inspectors and their supervisors disagree (particularly where an inspector is plainly wrong, i.e., where he or she labels a black and white object as orange, to use Mr. Marino's example),
the supervisor bears the responsibility for assuring that the correct QA/QC disposition is made. This, based on CEI's inves-tigation, was the context of Mr. Marino's off-hand remark. The remark hardly appears to us to have been " intimidation."
- 7. CEI's overview and investigations do not support the suggestion that Mr. Marino or other Comstock corporate officials discourage the identification of quality problems.
To the contrary, in response to requests by CEI, Mr. Marino and others from Comstock's corporate offices have spent a great deal of time at the site assuring that Comstock's QA program is receiving senior management attention and support.
- 8. Finally, CQS has examined the claim, stated by Mr.
Hendrickson and the other two inspectors in the newspaper arti-cles, that turnover and morale problems among Comstock inspectors have been excessive. There was significant turnover between September 1983, and November 1983, but this was largely due to intense recruiting of nuclear electrical inspectors from several other nuclear plants. A number of inspectors left vol-untarily for personal reasons unrelated to the Perry job.
There were three discharges during the period, two of which (the discharges of Mr. Hendrickson and Mr. Mathis) are discussed in this Affidavit. We find no basis to conclude that Comstock's turnover is the result of any disregard for quality problems on the part of Comstock's management. There is no doubt that Comstock's inspection program at Perry has been under especially close scrutiny by CEI, the NRC, and the media, particularly after the NRC's investigation in 1981 and 1982, the release of the 81-19 Report, and the highlighting of Comstock's problems in the NRC licensing hearings. CEI and Comstock both believo that this attention, some of it critical in nature, has put a special stress on inspectors and supervi-sors that has, from time to time, adversely affected morale.
In addition, some of Comstock's inspectors have complained to CQS that higher salaries being offered to new inspectors are creating inequities within'the Comstock salary structure, and have also raised other items unrelated to any health and safety concerns. We are following up with Comstock on these items.
Based on our interviews with inspectors, and our close field surveillance of inspector performance, CQS has found no evi-dence that morale or turnover problems have adversely impacted the quality of inspections being performed.
Meeting with Mr. Mathis
- 9. On November 27, 1983, Mr. Shuster and I met with . Gene Mathis to discuss his concerns. Mr. Max Gildner, the NRC Re-sident Inspector at Perry, also attended the meeting. Ini-tially, we reviewed with Mr. Mathis each of the concerns attributed to him in the November 23, 1983 newspaper article.
We were particularly concerned about the statements in the newspaper article regarding " daily harassment from production."
Mr. Mathis did not provide us with any specifics to substanti-ate the charge, and our interviews and investigations in
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response to the complaint do not indicate that production pressure has compromised in any way the independence and ade-quacy.of Comstock's QA/QC program. In addition, prior to our 4
investigation of Mr. Mathis' concerns, CQS personnel under my direction were closely monitoring Comstock's field installation and inspection to assure that the independence of Comstock's inspection program.was not compromised. I am confident, based 7
~ on CQS' prior surveillance, that Mr. Mathis' allega'-ions regarding " daily harassment from production" are not accurate.
- 10. There is an implicit suggestion in the November 23, 1983 newspaper article that Mr. Mathis may have been fired be-cause he was " worried about work at Perry." We have thoroughly
' investigated the circumstances of Mr. Mathis' termination, and
- are satisfied that this was not the case. Mr. Mathis, although a technically proficient inspector, had a serious temper problem that is documented throughout his personnel records.
He~was. discharged because of a series of incidents of un-justifiably flying off the handle at co-workers and supervi-sors. Based on our review of the incidents, they were not the result of poor treatment or disregard by his management in the area of quality control. In fact, Mr. Mathis received excel-lent ratings from his supervisors for documenting quality problems.
- 11. We asked Mr. Mathis about his statements, as
-published in the November 23, 1983 newspaper article, that there were cable tray drawings and installation problems. Mr.
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- . Mathis showed us the photographs mentioned in the newspaper article. However, the photographs were part of a t
nonconfermance report which, based on our review, properly doc-t umented the problem. In our meeting, Mr. Mathis also provided us with a list.of specific concerns not covered in the newspaper article. Some of these are labor-management issues outside the scope of any health and safety concerns. Others involve various inspection and nonconformance reports which Mr.
Mathis asked us.to review. Other items involve engineering or design questions, not directly related to QC inspection issues.
We are thoroughly. reviewing all of the items raised by Mr.
Mathis to assure that no safety issues have been overlooked, and will attempt to report back to Mr. Mathis with our find-i ings.
- 12. .Mr. Mathis expressed to us a concern about turnover and poor morale. This matter is addressed in 1 8 of my Affida-vit.
- 13. While we are continuing to investigate some of the 1
details provided in our meeting with Mr. Mathis, our investiga-tions performed to date do not reveal any areas of quality breakdowns or unsafe plant conditions in Mr. Mathis' area.
Meetings with Mr. Balazs
- 14. 'I' participated-in three meetings with Mr. Balazs to discuss, and give feedback on, Mr. Salazs' concerns. The 3-meetings were held November 30, 1983, December 5, 1983, and ,
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December 8, 1983. Portions of the meetings were attended by Mr. Shuster; Mr. Vernon Higaki, the CQS Electrical Unit Super-visor; and Mr. Pete Hunter, a Unit Supervisor in the Project Organization's Operational Quality Control.Section. I have also had several follow-up phone conversations with Mr. Balazs.
Mr. Balazs' primary concerns were with the status of certain wiring in panels within the diesel generator rooms and with wiring within the motor control centers. Although he did not raise it as an issue during'our meetings, I also asked Mr.
Balazs about the reference in the November 28, 1983 newspaper article to "a maze of unidentified wiring from the reactor to the control room." Mr. Balazs told me that the newspaper arti-cle confused this issue, which he said relates to the adequacy of wiring connectiona contained in boxes found at the ends of electrical penetrations. Mr. Balazs said he was concerned that some of the wires were bent beyond allowable. limits, but had i,
been unable to find anything in the existing procedures on which to base a nonconformance report. We are investigating l this item, and will attempt to contact Mr. Balazs when we have an answer to his question. After discussing Mr. Balazs' other i
j~ two concerns, described in more detail below, Mr. Ealazs indi-l l cated that we had satisfactorily answered his concerns and that he would sign a statement to this effect. A copy of Mr.
Balazs' statement is attached. Mr. Balazs understands that I am' furnishing the statement to the Licensing Board, and has told me that he has no objection to my doing so.
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- 15. The motor control wiring issue, about which Mr.
Balazs was concerned, was fully documented.on inspection reports issued by another Comstock inspector in October 1982.
The inspection reports have all been closed out. Also, in re-sponse to our meet,ing with Mr. Balazs, 100% re-inspections of the items of concern to Mr. Balazs have been performed by the Project Organization Operational Quality Section. ,
CEI is confident that nonconformances in the wiring of the motor contrcl cabinets ~have been properly identified. As noted in the attached statement, Mr. Balazs no longer has a concern with this item.
- 16. Similarly, fr. Balazs' concerns regarding electrical deficiencies in diesel generator control panels have also been answered to Mr. Balazs' satisfaction. Mr. Balazs was assigned the task of inspecting certain repair work performed by Comstock under sub-contract to General Electric. General Electric, not Comstock, provided the diesel generator panels in question. GE had identifie'd deficiencies with the lugs in the panels, and properly documented the deficiencies in engineering change documents. While performing inspections of the lug repair work, Mr. Balazs identified what he believed were deficiencies outside the scope of the repair work on the lugs.
Since GE had the design and QA/QC responsibility for these other items, and consistent with a prior agreement between GE f
and Comstock, Mr. Balazs was instructed to document his concerns on inspection reports, and not to draft nonconformance L
. a reports until the items were reviewed by GE. . Inspection reports were written by Mr. Balass on February 24, 1983, docu-menting.his findings. After considerable discussion with GE over the proper criteria to be applied to the items which Mr.
Balazs identified, Comstock and-the Project Organization joint-
..ly decided to write nonconformance reports on the items, which l was done by Mr. Balass on April 5, 1983. Based on subsequent
-engineering review by GE and the Project Organization of both the lug deficiencies, and the items identified by Mr. Balans,
-CEI verbally reported all the items to the NRC under 10 C.F.R.
$ 50.55(e) on June 15, 1983. A copy of CEI's written notifica-tion to the NRC (letter, dated July 15, 1983, M. Edelman to J.
-Keppler) is attached. The corrective action, discussed in the letter, is not expected to be completed for some time, and will be sequenced with ongoing construction work in the area.
At no time did Comstock, GE, or the Project Organization fail to ade-quately identify or track these items. As stated, Mr. Balazs l
is now satisfied that there are no outstanding safety concerns.
- 17. The areas just discussed were the primary areas of safety concern to;Mr. Balazs.
We also discussed a number of
.other items, all of which will be reviewed to assure that the items do not constitute safety problems or QA/QC procedural deficiencies.
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- 18. While CEI is continuing to investigate some of the specific items raised during our meetings with the three
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inspectors, we have not found in our investigations to date any 1
evidence of either undocumented safety problems; serious QA/QC procedural errors; " harassment" or " intimidation" of inspec cra; or improper decisions in connection with the dis-charge of inspectors. Many of the complaints are explained by communication problems between the inspectors and their co-workers and supervisers. Communication problems and dia-agreements among workers and disciplines in an organization of the size and complexity of the Perry organisation are not unex.
pected'. We do not believe that the communication problems which gave rise to the complaints of these three inspectors were the result of serious management deficiencies, or a 'ack .
of concern regarding the importance of a strong, independent electrical QA/QC program. In any case, CEI will continue to monitor the electrical area, and other areas, to assure that the QA/QC program at Perry remains strong and effective,
( Emanuel Riley Subscribed and sworn to before me this bf44 day of December, 1983.
$wc 7&bbW NOTARY PUBLIC My commission Expires l
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. ATTACHMENT 1'"'~
Dece.ber 8, 1983 This note is to confir'm the meeting held on Monday. Dece.mber 5, 1983 at 2:00 PM between myself and representatives of the Nuclear Quality Assurance Department of the Cleveland Electric Illuminating Company (CEI). Persons in attendance were: Mr. Emanuel Riley, General Supervisor, Construction Quality Section; Mr. Vernon Higaki, Unit Supervisor, CCS Electrical Unit; and Mr. C. W. (Pete) Hunter, Unit Supervisor, Operational Quality Control. This meeting was a follow-up to a meeting held on Wedneaday, November 30, 1983 with Mr. Cyril Shuster, Nuclear Quality Assurance Department Manager and Mr. Emanuel Riley, Construction Quality Section Supervisor.
The first meeting was called by Mr. Shuster who indicated that CEI was interested in discussing any safety concerns that I had. At our first meeting I had expressed a concern regarding the construction /
quality, status of certain panels within the diesel generator rooms and wiring within the motor control centers. After reviewing my concerns, I was offered the opportunity to review 'the status of these items. -
The purpose of the meeting held on December 5, 1983 was to allow CEI -
the opportunity to present the facts regarding the status of the concerns I had raised in the earlier meeting-Based on the information presented to me, I have no safety concerns about the items that I have discussed the L. X. Cemstock and CEI to date. - -
Signature I Date 4
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ATTACHMENT 2 o P.O. Sox 5000 . CLEVELAND. oMIO A4101 -
TELEPMoNE (216) 622 5600 .
ILLUMINATING OLDG- -
55 PUBLIC SOUAR h Serving The Best Location in the Natio<
M'JRRAY R. EDELMAN VICE Mit$loENT nU:uAn July 15, 1983 Mr. Ja=es G. Keppler Regional Ad=inistrator, Region III Office of Inspection and Enforcement U.S. Nuclear Regulatory Co==dssion 799 Roosevelt Road .
Glen Ellyn, Illinois 60137 RE: Perry Nuclear Power Plant Docket Nos. 50 '440; 50-441 HPCS Local Panels E22-S001
[RDC 75(83)] -
Dear Mr. Keppler:
This letter serves as an interi= r,eport pursuant to 10CFR50.55(e) on the potential /significant deficiency concerning the Eigh Pressure Core Spray 1 (EPCS) Diesel Generator Electrical Panels supplied to Ferry Nuclear Power (jE?
Plant by the General Electric Co=pany (GE). Mr. F. Jablonski of your office was notified on June 15, 1983, by Mr. M. Kritzer for The Cleveland Electric Illu=inating Co=pany (CEI) that this potential deficiency was being evaluated by CEI.
l This letter contains a description of the deficiency, planned corrective action, and the scheduled date for sub=1ttal of our final report.
-Description of Deficiency I
A nu=ber of nonconfor=ing conditions attributed to poor work =anship were identified. in the EPCS Diesel Electrical Panels. So=e exa=ples of nonconfor=ing ite=s identified in the two panels (1 per unit) are i= properly cri= ped ring lug ter=inations , te=porary wire labels still present, =issing inspection covers, no I.D. on ter=inal strips, paint overspray, broken wire strands and/or no insulation of the barrel to connection point, use of unapproved cable cleats, and the use of unapproved tape. A co=plete description,of the nonconfor=ing conditions is available on Project Nonconfor=ance Report (NR)
P033-1650 and GE Field Deviation Disposition Request (FDDR) KL1-735 for the Unit 1 panel and Project NR P033-1651 and GE FDDR KL2-591 for the Unit 2 panel, i
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, ..Cerrectiva Action The ring lug terminations will be replaced in the Unit 1 and 2 panels in h~)~b accordance with GE FDDR's KL1-735 and KL2-591, respectively. The recaining ite=s identified on the Project NRs will be reworked or repaired in accordance with the engineering dispositions for NR's P033-1650 and P033-1651.
Our next report on this subject will be sub=1tted by April 6,1954.
Sincerely,
/
Murray R. Ecelman Vice President Nuclear Group MRI:pab cc: Mr. M. L. Gildner NRC Site Office Director Office of Inspection and Enforce =ent
- U.S. Nuclear Regulatory Co==ission Washington, D.C. 20555
- .. U.S. Nuclear Regulatory Co=cission f.iE5' c/o Document Manage =ent Branch Washington, D.C. 20555 Records Center, SEE-IN Institute of Nuclear Power Operations 1100 circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 O
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ATTACHMENT 3 December 1983 o on O Statement of Professional Qualifications and Experience EI Emanuel Riley PEPRY PROJECT START DATE: January 1975 CURRENT POSITICN: General Supervisor, Construction Quality Section, The Cleveland Electric Illuminating Company (CEI)
SUMMARY
OF POSITIONS WITH CEI:
General Supervisor, Construction Quality Section 10/81 to Present Responsible fcr development and maintenance of the QA Programs for all construction quality' functions which include quality control inspection, quality engineering and resolving other quality problems with project participants, contractor representatives and the Nuclear Regulatory Commission. This responsibility includes the QA/QC oversight of all safety-related contractors. Reports directly to the Manager of the Nuclear Quality Assurance Depa?tment. Major responsibilities include:
- 1. Directing and controlling all quality assurance agents and consultants hired to support Construction Quality Section.
- 2. Reviewing and approving all construction contracts to verify quality requirements for nuclear safety-related construction.
- 3. Establishing and implementing all construction quality' control inspection requirements, reviewing and approving contractors' programs and procedures, and planning and performing contractor audits.
- 4. Ensuring that contractors identify and correct deficient or incorrect construction.
- 5. Ensuring that nonconformance reports are prepared and acted upon.
- 6. Establishing and implementing programs for indoctrination and training of Section personnel to quality requirements; and assuring that only qualified and certified personnel perform audits, inspections, tests and nondestructive examinations.
- 7. Overseeing the development of all construction quality assurance manuals, procedures and instructions; and providing input for Safety Analysis Report preparation and maintenance.
- 8. Acting as primary liaison with NRC inspection and enforcement personnel.
Resume
" Ehanuel Riley Page 2
SUMMARY
OF POSITIONS WITH CEI: (continued)
Sr. Project Administrator, "uclear Ccnstructicn Section 9/78 Froject Crganization Contracts Manager responsible for supervision of Contract Administration element.
Sr. Project Inspector, Nuclear Construction Section 9/77 Project Organization Contracta Manager responsible for supervision of Contract Administration element.
Project Inspector, Nuclear Construction Section 7/76 Contract Administrator, Mechanical / Piping / Structural disciplines.
Associate Inspector, Contract Construction Section 5/74 Began assignment at Perry Plant in 1975 as Contract Administrator for steel containment structures, Owner furnished cranes and field erected tanks.
Senior Construction Technician, Contract Construction Dept. 3/71 Assignments varied from contracts administration and inspection of general construction projects to the Lakeshore fuel conversion. Other assignments included during this period were the coordination and inspection of mechanical and piping disciplines during construction of Eastlake Unit #5.
In 1974 assigned to Davis-Besse for two months; performe.d surveillance of construction activities and assisted in the inspection of system hydro test. Also spent four months on rotation of assignment to Nuclear Quality Assurance Department.
PREVIOUS WORK EXPERIENCE Cuyahoga Metropolitan Housing Authority 9/68 to 3/71 Maintenance and Modernization Coordinator Duties included supervision of maintenance operations of three large housing projects and also supervision of the Central Heating Plant and Steam Distribution System.
City cf Cicesland Steam Fireman was the beginning position with the City of 12/60 to 9/68 Clevaland, Chio. Advanced through the line of progression to Stationary Engineer, to Shift Engineer responsible for a working cre. of sixteen men, including Boilermakers, Steam Fitters an: - 'itters, etc.
Cuyahoga Metropolitan Housing Authority 9/55 to 12/60 Chief Maintenance Clerk responsible for inventory control, payroll and budget preparr. tion.
, ,o 8.esume Emanuel Riley Page 3 CURRENT CERTIFICATIONS First Class Stationary Engineer's License,1961 Cencrete and Steel Inspector, City of Cleveland, Department of Suilding, 1971 Certificate of Competency - Pressure Piping, State of Ohio,. 1976 EDUCATION East Technical High School Technical Degree, June 1954 Cuyahoga Community College Courses in Architectural and Construction Engineering Technology, 1971-72 CONTINUING EDUCATION Management of Managers Seminar 1983 University of Michigan Career Development Program Track II 1981-82 Case Western Reserve Univeristy Construction Scheduling and Cost Control 1981 Hill International, Inc. -
Quality Assurance Audit Techniques Course 1981 L. Marvin Johnson and Associates, Inc.
Contract Administration Course 1978 George Washington University Construction Management Fundamentals 1977 Center for Professional Advancement (NJ)
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Forty-Hour Quality Assurance /Cuality Control 1977 Course, NNIC Three-Day BWR Design Orientation Course 1975 Ten-Week Nuclear Power Production Course 1972 PROFESSIONAL AFFILIATIONS Business and Professional Association of Churches of God in Christ-International l
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e .. o December 19, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
THE CLEVELAND ELECTRIC )
ILLUMINATING COMPANY, ET AL. ) Docket No. 50-440
) 50-441 (Perry Nuclear Power Plant, )
Units 1 and 2) )
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Applicants' Answer To OCRE Motion To Reopen The Record On Comstock Issues" were served by deposit in the United States Mail, first class, postage prepaid, this 19th day of December, 1983, t'o all those on the. attached Service List.
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/bdkI) L/
Harry H./ Glasspiegel' /
Dated: December 19, 1983 s
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UNITED STATES OF AMERICA l I
NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensine Board
)
In the Matter of ) .
) Docket Nos. 50-440 THE CLEVELAND ELECTRIC 50-441 ILLUMINATING COMPANY )
)
(Perry Nuclear Power Plant, )
Units 1 and 2) )
SERVICE LIST Pater B. Bloch, Chairman Atomic Safety and Licensing Atomic Safety and Licensing Board . Appeal Board Panel U.S. Nuclear Regulatory Constission U.S. Nuclear Regulatory Consission 20555 Washington, D.C. 20555 Washington, D.C.
Dr. Jerry R. Kline Docketing and Servica Section Atomic Safety and Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 20555 Washington, D.C. 20555 Washington, D.C.
Colleen P. Woodhead., Esquire Mr. Glenn O. Bright Office of the Executive Legal Atomic Safety and Licensing Board Director U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Christine N. Kohl, Chairman Atomic Safety and Licensing Ms. Sue Hiatt OCRE Interim Representative Appeal Board 8275 Munson Avenue U.S. Nuclear Regulatory Commission Mentor, Ohio 44060 Washington, D.C. 20555 Terry Lodge, Esquire Dr. W. Reed Johnson 618 N. Michigan Street, Suite 105 l Atomic Safety and Licensing Toledo, Ohio 43624 Appeal Board U.S. Nuclear Regulatory Commission i
Washington, D.C. 20555 Donald T. Ezzone, Esquiro Assistant Prosecuting Attorney t Gary J. Edles, Esquire Lake County .1A= histration Center Atomic Safety and Licensing 105 Center Street Painesville, Ohio 44077 Appeal Board U.S. Nuclear Regulatory Commission John G. Cardinal, Esquire Washington, D.C. 20555 Prosecuting Attorney Ashtabula County Courthouse Atomic Safety and Licensing Jefferson, Ohio 44047 Board Panel i U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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