ML20083K255

Affidavit of RG Tolson & CT Brandt Re Changes in Safety Classification

ML20083K255
Person / Time
Site:	Comanche Peak
Issue date:	04/12/1984
From:	Brandt C, Tolson R EBASCO SERVICES, INC., TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20083K230	List: ML20083K226 ML20083K255
References
NUDOCS 8404160114
Download: ML20083K255 (2)

Text

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

) Docket Nos. 50-445 and TEXAS UTILITIES ELECTRIC ) 50-446 CCMPANY, et al. )

) (Application for (Comanche Peak Steam Electric ) Operating Licenses)

Station, Units 1 and 2) )

AFFIDAVIT OF RONALD G. TOLSON AND C. THOMAS BRANDT REGARDING CHANGES IN SAFETY CLASSIFICATION We, Ronald G. Tolson and C. Thomas Brandt, being first duly sworn, hereby depose and state as follows:

(Tolson) My name is Ronald G. Tolson. I am employed by Texas Utilities Generating Company. A statement of my edu,cational and professional qualifications was admitted into the record as Applicants' Exhibit 20.

(Brandt) My name is C. Thomas Brandt. I am employed by Ebasco Services, Inc. at Comanche Peak. A statement of my educational and professional qualifications was received into evidence as Applicants' Exhibit 141A.

This-affidavit addresses the question of whether " reverse classification," i.e., classification of safety-related com-ponents, systems or structures as non-safety related, and then reversing that classification, has ever occurred at Comanche Peak. This question was posed by the Board in its March 15, 1984, Memorandum (Clarification of Open Issues) at 11.

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Based on personal knowledge and an inquiry of Site and Home office Engineering personnel as well as members of the Construction Staff, we have been able to identify two instances

.where " reverse classification" has occurred. These instances related to platforms and monorails (including associated embeds).

While we cannot conclusively say these are the only instances of reverse classification (to make such a conclusive statement would require a complete review of literally thousands of design documents), it is clear that there has not been a " practice" of reverse classification of items at CPSES.

In any event, in every instance where a non-safety grade structure or component is classified or reclassified safety-grade, the QA program requires a complete and thorough inspection and analysis of the upgraded component or structure to assure conformance with the design specification requirements. Accordingly, regardless of the reclassification of a structure or component, the QA program provides assurance that the safety o the plant n

is not degraded. 7, d '

f l Ronald G. Tolson C~ Thomas Btandt Subscribed and sworn to before Subscribed and sworn to before me this g^ day of April,1984 me this lith day of April,1984 ha.D0 Public

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