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Category:AFFIDAVITS
MONTHYEARML20151W5941998-09-11011 September 1998 Affidavit of Cd Payne.* Affidavit Re NRC Staff Proposed Denial of Rl Herring Application for Senior Reactor Operator License for Use at Catawba Nuclear Station,Units 1 & 2 ML20151Y0601998-09-11011 September 1998 Affidavit of DC Payne.* Supports Denial of Application of Rl Herring for SRO License ML20151W6131998-09-0808 September 1998 Affidavit of Mn Leach in Support of NRC Staff Response to Rl Herring Written Presentation.* ML20151W6311998-09-0808 September 1998 Affidavit of ET Beadle.* Affidavit Relates to Denial of Senior Reactor Operator License Application for Rl Herring. with Certificate of Svc ML20101J9871984-12-21021 December 1984 Affidavit of Cj Czajkowski & Jr Weeks in Response to DA Schlissel Affidavit Addressing ASLB Finding in OL Proceeding That IGSCC Not Expected to Occur as Result of Sensitization of Certain Critical Welds in Cooling Sys ML20101E9211984-12-20020 December 1984 Affidavit of L Lewis Re Assertions of Palmetto Alliance & Carolina Environ Study Group That Operation Will Significantly Increase Costs & Exposures in Performing Maint & Repair Work & Releases to Environ ML20101E8651984-12-20020 December 1984 Affidavit of Wf Reinke Re Delay in Commercial Operation of Facility ML20101E8921984-12-20020 December 1984 Affidavit of WR Stimart Re Explanation of How Delay in Commercial Operation Translates Into Increased Project Costs ML20101E8981984-12-20020 December 1984 Affidavit of PM Abraham Re Safety Implications of Operation of Facility ML20101E9131984-12-20020 December 1984 Affidavit of Wh Rasin Re Assertion Made by Palmetto Alliance & Carolina Environ Study Group That Containment Vulnerable to Breach Because of Hydrogren Explosion in Event of Accidents ML20101E8791984-12-19019 December 1984 Affidavit of SE Ferdon Re Assertions Made in Affidavits of Kaku & Schlissel ML20101E8421984-12-18018 December 1984 Affidavit of Wh Owen Re Testing Sequence Required to Bring Facility Into Operation ML20097J3941984-09-15015 September 1984 Affidavit of Hs Nunn Re Foreman Override Practices. Certificate of Svc Encl ML20098A1711984-09-12012 September 1984 Affidavit of Wh Owen Updating Schedule for Fuel Load & Precritical 0-5% & 5-100% Power Testing.Related Correspondence ML20092B6831984-06-18018 June 1984 Affidavit of Wh Owen Re Change in Fuel Load Date.Date Currently Scheduled for 840629 ML20084K9091984-05-0808 May 1984 Affidavit of Wh Owens Re Current Schedule for Fuel Loading, Testing & Power Ascension Phases ML20083K6221984-04-11011 April 1984 Affidavit of PM Abraham & WR Mccollum Supporting Motion for License to Load Fuel & to Conduct Certain Precritical Tests ML20083K6261984-04-11011 April 1984 Affidavit of Cj Wylie Describing All Normal & Addl Sources of Power Available to Support Facility W/O Reliance on Emergency Diesel Generators.Certificate of Svc Encl ML20088A7931984-04-10010 April 1984 Affidavit of Wh Owen Reflecting Revised Schedule for Fuel Loading,Testing & Power Ascension Phases ML20086L0461984-02-0303 February 1984 Affidavit of Mf Lowe in Response to W Owen 840118 Affidavit Re Delay of Fuel Load & Testing Activities.Certificate of Svc Encl ML20087N5851984-01-26026 January 1984 Affidavit of H Langley Re QC Concerns at Site ML20079N3701984-01-24024 January 1984 Affidavit of Hs Nunn in Response to Applicant Suggestion of Contrived Testimony.Certificate of Svc Encl ML20079G5081984-01-18018 January 1984 Affidavit of Wh Owen Re Current Schedule for Unit 1 Fuel Loading & Testing & Power Ascension Phases.Certificate of Svc Encl ML20129A5091983-12-14014 December 1983 Affidavit of Rd Bentley Re Lack of Qa/Qc Independence & Harassment/Intimidation of QC Welding Inspectors at Facilities.Related Info Encl ML20082E5501983-11-23023 November 1983 Affidavit of Bp Garde Re 831103 Telcon W/Welding Inspector on Testimony of Util Employees ML20082E5601983-11-23023 November 1983 Affidavit of L Clark Re 831103 Telcon W/Welding Inspector on Testimony of Util Employees.Certificate of Svc Encl ML20133C6451983-11-16016 November 1983 Affidavit of Hs Nunn Re Quality of Const at Plant ML20133C6411983-11-16016 November 1983 Affidavit of WR Mcafee Re Concerns Over Quality of Const at Plant ML20133C6321983-11-0909 November 1983 Affidavit of JB Stearns Re Concerns Over Shoddy Workmanship & Retaliation Against Persons Challenging Poor Workmanship at Plant ML20081K7301983-11-0202 November 1983 Affidavit of RM Glover Re Proposed Extension of Plume Exposure Pathway Emergency Planning Plume Zone (Contention 11).Certificate of Svc Encl ML20080L9911983-09-27027 September 1983 Affidavit of PA Evans in Response to Palmetto Alliance Allegations That self-initiated Evaluation Identified Problems Which Are Symptomatic of Systematic Deficiencies in Plant Const ML20024E3471983-08-0505 August 1983 Affidavit of R Guild Re Summary Disposition of Contentions 16,DES-19 & 14.Affidavit of Counsel & Certificate of Svc Encl ML20024C9931983-07-15015 July 1983 Affidavit of Lr Davidson Re Palmetto Alliance Contention 6. Concrete Pours on Wall Above Interior Doghouse of Unit 1 Containment Found Acceptable.Rain Leakage Did Not Damage Control Room Boards.Prof Qualifications Encl ML20024C9941983-07-15015 July 1983 Affidavit of Jc Rogers Re Palmetto Alliance Contention 6. Green Water in Uhi Bldg Is Not Unsafe.Contact of Carbon Steel & Stainless Steel Will Not Compromise Matl Integrity. Prof Qualifications & Certificate of Svc Encl ML20024C7491983-07-0808 July 1983 Affidavit of Mc Green Re Palmetto Alliance Contention 16. Spent Fuel Liner Would Not Rupture If Temp Exceeds 150 F. Spent Fuel Cask Cannot Be Dropped Into Spent Fuel Pool.Rails Will Be Relocated So Cask Will Not Be Over Fuel Pool Area ML20024C7551983-07-0808 July 1983 Affidavit of AL Snow Re Palmetto Alliance/Carolina Environ Study Group Alliance Contention 19.Environ Impact of McGuire & Oconee Spent Fuel at Catawba Insignificant.Prof Qualifications & Certificate of Svc Encl ML20024C7441983-07-0808 July 1983 Affidavit of AL Snow Re Palmetto Alliance Contention 16 on Spent Fuel Storage Facility Cooling & Criticality Control Capability.Plant Sys Comply W/Gdc 44.Prof Qualifications Encl ML20070C7281982-12-0202 December 1982 Affidavit of RA Wiesemann Re Westinghouse Proprietary Info in Util Submittal on Improved Thermal Design Procedures 1998-09-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20197J2871998-12-11011 December 1998 Initial Decision (Application for Senior Reactor Operator License).* Appeal of R Herring of NRC Denial of Application for SRO License Denied.With Certificate of Svc.Served on 981211 ML20151W5721998-09-11011 September 1998 NRC Staff Presentation in Support of Denial of Senior Reactor Operator License for Dl Herring.* Staff Decision to Fail Dl Herring on Category a of SRO Exam,Clearly Justified. Staff Denial of Herring SRO License Should Be Sustained ML20151W5941998-09-11011 September 1998 Affidavit of Cd Payne.* Affidavit Re NRC Staff Proposed Denial of Rl Herring Application for Senior Reactor Operator License for Use at Catawba Nuclear Station,Units 1 & 2 ML20151Y0601998-09-11011 September 1998 Affidavit of DC Payne.* Supports Denial of Application of Rl Herring for SRO License ML20151W6131998-09-0808 September 1998 Affidavit of Mn Leach in Support of NRC Staff Response to Rl Herring Written Presentation.* ML20151W6311998-09-0808 September 1998 Affidavit of ET Beadle.* Affidavit Relates to Denial of Senior Reactor Operator License Application for Rl Herring. with Certificate of Svc ML20237B6931998-08-13013 August 1998 Rl Herring (Denial of Operator License for Plant).* Rl Herring Submitted Written Presentation Arguments,Data, Info Matl & Other Supporting Evidence,Per Presiding Officer 980630 Order & 10CFR2.1233.W/one Oversize Drawing ML20237A3831998-08-12012 August 1998 NRC Staff Request for Extension of Time to File Response to Rl Herring Written Presentation.* Staff Respectfully Requests Motion for Extension of Time of 2 Wks to Respond to Herring Presentation Be Granted.W/Certificate of Svc ML20237B5571998-08-12012 August 1998 NRC Staff Request for Extension of Time to File Response to Rl Herring Written Presentation.* Granted by C Bechhoefer on 980818.W/Certificate of Svc.Served on 980818 ML20236T8511998-07-21021 July 1998 Specification of Claims.* Rl Herring Claims That Answer Given on Exam Was Correct When TSs Are Considered & When Design Basis Document Considered in Conjunction W/Duke Power Nuclear Sys Div.W/Certificate of Svc.Served on 980727 ML20236F5391998-06-30030 June 1998 Memorandum & Order (Hearing File & Spec of Claim).* Orders That Brief Spec of Claims Should Be Filed by Herring,Telling Why He Believes Staff Erred in Grading Exam.Staff Must Furnish Hearing File.W/Certificate of Svc.Served on 980630 ML20236F5631998-06-30030 June 1998 Notice of Hearing.* Presiding Officer Has Granted Request of Rl Herring for Hearing on NRC Denial of Application for Operator License for Plant.W/Certificate of Svc.Served on 980630 ML20149K8221997-07-29029 July 1997 Exemption from Requirements of 10CFR70.24, Criticality Accident Requirements. Exemption Granted TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20065P4491994-04-21021 April 1994 Comment Opposing Proposed Rule 10CFR50.55 Recommendation to Incorporate Proposed Rule to Adopt ASME Code Subsections IWE & Iwl ML20044G7371993-05-25025 May 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. Opposes Rule ML20101R5931992-07-0606 July 1992 Comment on Proposed Rule 10CFR50 Re Loss of All Alternating Current Power & Draft Reg Guide 1.9,task DG-1021.Opposes Rule ML20091Q8661992-01-31031 January 1992 Comment Opposing Draft NUREG-1022,Rev 1, Event Reporting Sys,10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting ML20087F7471992-01-15015 January 1992 Comment Opposing Rev 1 of NUREG-1022, Event Reporting Sys ML20246J6571989-08-31031 August 1989 Order Imposing Civil Monetary Penalty on Licensee in Amount of $75,000 for Violations Noted in Insp on 881127-890204. Payment of Civil Penalty Requested within 30 Days of Order Date.Evaluations & Conclusions Encl ML20247J8921989-08-31031 August 1989 Order Imposing Civil Monetary Penalty in Amount of $75,000, Based on Violations Noted in Insp on 881127-890204,including Operation in Modes 1-4 W/One Independent Containment Air Return & Hydrogen Skimmer Sys Inoperable for 42 Days ML20205N1471988-10-20020 October 1988 Comment on Petition for Rulemaking PRM-50-50 Re Provision That Authorizes Nuclear Power Plant Operators to Deviate from Tech Specs During Emergency.Request by C Young Should Be Denied ML20234D2821987-09-15015 September 1987 Joint Intervenors Emergency Motion to Continue Hearing for 2 Wks & for Immediate Prehearing Conference.* Urges That Hearing Re Offsite Emergency Planning at Plant,Scheduled for 870928,be Continued Until 871013.Certificate of Svc Encl ML20198C5771986-05-14014 May 1986 Transcript of 860514 Discussion/Possible Vote on Full Power OL for Catawba 2 in Washington,Dc.Pp 1-86.Viewgraphs Encl ML20203N4561986-02-20020 February 1986 Unexecuted Amend 6 to Indemnity Agreement B-100,replacing Item 3 of Attachment to Agreement W/Listed Info ML20151P2231985-12-31031 December 1985 Order Extending Time Until 860110 for Commissioners to Review ALAB-825.Served on 851231 ML20136H7231985-11-21021 November 1985 Decision ALAB-825,affirming Remaining Part of ASLB OL Authorization,Permitting Applicant to Receive & Store Spent Fuel Generated at Duke Power Co Oconee & McGuire Nuclear Power Facilities.Served on 851121 ML20138B3611985-10-11011 October 1985 Order Extending Time Until 851025 for Commission to Act to Review ALAB-813.Served on 851011 ML20137W4311985-10-0202 October 1985 Order Extending Time Until 851011 for Commission to Act to Review ALAB-813.Served on 851003 ML20134N5761985-09-0404 September 1985 Order Extending Time Until 851004 for Commission to Act to Review ALAB-813.Served on 850904 ML20126M2091985-07-30030 July 1985 Order Amending First Paragraph of Footnote 126 Re Need for Power & Financial Qualifications in ALAB-813 . Served on 850731 ML20126K7701985-07-26026 July 1985 Order Extending Time Until 850730 for Commission to Act to Review Director'S Decision DD-85-9.Served on 850729 ML20129C2351985-07-26026 July 1985 Decision ALAB-813 Affirming Aslab Authorization of Issuance of Full Power Ol,Except Insofar as Receipt & Storage Onsite of Spent Fuel Generated at Other Facilities.Served on 850729 ML20129K1651985-07-19019 July 1985 Order Extending Time Until 850726 for Commission to Act to Review Director'S Decision DD-85-9.Served on 850719 ML20129H9361985-07-10010 July 1985 Unexecuted Amend 5 to Indemnity Agreement B-100,changing Items 1 & 3 of Attachment ML20128K2171985-07-0808 July 1985 Order Extending Time Until 850719 for Commission to Act to Review Director'S Decision DD-85-9.Served on 850709 ML20127P0991985-06-28028 June 1985 Transcript of 850628 Supplemental Oral Argument in Bethesda, Md.Pg 99-169 ML20133C5201985-06-26026 June 1985 Undated Testimony of PM Reep Re Welding Inspector Concerns. Rept of Verbal Harassment Encl ML20127K7171985-06-24024 June 1985 Order Extending Time Until 850709 for Commission to Act to Review Director'S Decision DD-85-9 ML20126K6391985-06-17017 June 1985 Order Advising That Counsel Be Familiar W/Content of Commission Request for Public Comment on Decision to Exercise Discretionary Price-Anderson Act Authority to Extend Govt Indemnity to Spent.... Served on 850618 ML20126B8101985-06-13013 June 1985 Order Scheduling Supplemental Oral Argument on Pending Appeals on 850628 in Bethesda,Md Re Public Notice of Hearing Concerning Use of Facility for Receipt & Storage of Spent Fuel from Oconee & Mcguire.Served on 850613 ML20126E4601985-06-13013 June 1985 Notice of Supplemental Oral Argument on Pending Appeals on 850628 in Bethesda,Md.Served on 850613 ML20125B4251985-06-0707 June 1985 Responds to Aslab 850603 Order Requesting Response to NRC 850529 Filing Re Whether Notice of Proposal to Use Catawba to Store Oconee & McGuire Spent Fuel Discretionary or Required.Certificate of Svc Encl ML20126A7631985-06-0404 June 1985 Director'S Decision DD-85-9 Granting & Denying in Part Palmetto Alliance Request for Mod,Suspension or Revocation of CPs for Facilities Due to Harassment & Intimidation of QC Inspectors ML20129A6381985-06-0303 June 1985 Order Allowing Applicant to File & Serve Response to NRC 850529 Assertion Re Storage of Spent Fuel Generated at Another Facility Constituting Use of Commercial Utilization Facility No Later than 850607.Served on 850604 ML20128P0001985-05-29029 May 1985 NRC Views on Whether Notice of Proposal to Use Facility to Store Oconee & McGuire Spent Fuel Required or Discretionary. Certificate of Svc Encl ML20128P1031985-05-29029 May 1985 Memorandum Responding to Palmetto Alliance/Carolina Environ Study Group & Staff 850517 Memoranda Asserting That Fr Notice Not Reasonably Calculated to Inform of Requests Re Spent Fuel.Certificate of Svc Encl ML20127K0231985-05-20020 May 1985 Order Extending Time Until 850529 for Aslab to Act to File & Svc Reply Memoranda.Served on 850521 ML20127G2281985-05-17017 May 1985 Memorandum Responding to 850425 Aslab Order Addressing Four Questions Re Receipt & Storage of Spent Fuel.Certificate of Svc Encl ML20127H0041985-05-17017 May 1985 Response to Aslab Questions on Adequacy of Notice of Proposed Use of Facility to Store Spent Fuel from Oconee & McGuire Facilities.Aslab Has No Jurisdiction Over Proposal. Certificate of Svc Encl 1998-09-08
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1 0 l i,
UNITED STATES OF AMERICA 0 a H!U:
NUCLEAR REGULATORY COMMISSION D'E !
BEFORE THE ATOMIC SAFETY AND LICf.NSING APPEAL BOARD E 04 In the Matter of )
Y bNiY&f[
) ,
DUKE POWER COMPANY, et al. ) Docket Nos. 50-41'4 -
) 50-415 (Catawba Nuclear Station, )
Units 1 and 2) ) ;
AFFIDAVIT OF WARREN H. OWEN My name is Warren H. Owen. I am employed by Duke Power Company as Executive Vice President, Engineering, Construction and Production Group. I have held this position since July 1,1984.
I have a BS in Mechanical Engineering from Clemson University. I am a Registered Professional Engineer in the states of North and South Carolina. I have served in responsible positions in industry-related organizations such as the Electric Power Research Institute, the Edison Electric Institute, the Atomic Industrial Forum and the Institute for Nuclear Power Operations. Currently I am serving as a member, and am the former, Chairman of the AIF Policy Committee on Nuclear Regulation.
I have worked for Duke Power Company since 1948. After assignments at two of the company's coal fired generating stations and the Steam Production Department General Office staff, I moved to the Design Engineering Department in 1961.
e In 1966 I was appointed the Principal Mechanical Engineer in the Design Engineering Department. I served in that capacity until 1971 when I was appointed Vice President of the Department. In 1978 I became the Senior Vice President for 8412260422 841221 PDR ADOCK 05000413 9 PM .
Engineering and Construction and was elected to the Board of Directors of the company. I served as Senior Vice President through April 1982, when I was elected Executive Vice-President, Engineering and Construction. In June 1984 I was appointed Executive Vice President, Engineering, Construction and Production Group, the position I hold today.
In my capacity as Executive Vice President, Engineering Construction, and Production Group, I have overall responsibility for the construction and commercial operation of the Catawba Nuclear Station. Included within this responsibility is assuring that the plant is brought to commercial operation on schedule in May of 1985.
The purpose of this affidavit is to explain the testing sequence which must be followed to bring Catawba Unit 1 into commercial operation, and to demonstrate that any delay which would result from a stay granted by the Appeal Board would translate into an equivalent delay in commercial operation. The schedule of testing activities which regulations require to be performed during the initial ascension to full power operation is a phased progression, with specific required activities performed at various sequential power levels (plateaus). Logic dictates that the activities must be performed in a certain sequence in order to complete the entire sequence of tests in a reasonable amount of time. Once the sequence of power ascension tests is begun, the unit must be escalated in power immediately following completion of testing at a given plateau, in order to allow completion of the entire sequence of such tests on schedule.
2-
30-day delay in achieving criticality The recently-announced in a Westinghouse improperly installed component found because of an i h might have existed reactor in South Korea has removed any margin wh c During that delay, corrective in the schedule as it previously stood. including on plant equipment, will be performed maintenance only during shutdown, which can be performed surveillance of systems l operation.
to lessen the impact of the delay on commercia I i
must be completed prior to
?
schedule and sequence The following commercial operation:
1 The time from entering Mode II to occurrence of initial Mode II_:
criticality is three days.
scheduled sequence of the Following initial criticality I
activities is:
days of testing to measure Thirteen Zero Power Physics Testing:
ters.
reactor core parameters and verify core design parame primarily consisting Three days of testing, 10% Powe'r Testing: verification of plant the main turbine generator and of operation of j
response to a change in unit load.
i including vertftcation Six days of testing, 20% Power Testing: feedwater flow path, in l response to a change
' of steam generator
A.C. power and testing of the response of the station to loss of verification of the ability to operate the station from auxiliary control stations.
of activities, including Twenty-nine days 30% Power Testing:
d level control verification of nuclear steam supply system pressure an control rod systems, testing of the reactor (
operation, operation and and physics parameters reactor core further verification of verification of plant transient response. l -
of testing, including Twenty-seven days 50% Power Testing: onse, further core verification of plant process radiation monitor resp flow testing and transient physics parameter determination, precision response tests.
twenty-four days in This testing plateau is 75% power Testing: (trip) of the a transient induced by shutdown duration, and includes testing planned at from 68% load. Other unit main turbine generator coolant flow test, and a precision reactor this plateau includes testing to verify reactor core physics parameters.
activities, focusing on An eight day set of 90% Power Testing: and response reactor core physics parameters further verification of of the plant to a rapid change in feedwater temperature.
Nineteen days of testing, including tests of 100% Power Testing: response to a parameters, verification of plant reactor core physics full loss of electrical load at the main generator .and transient response testing.
The net effect of the 127-day period of tests and work described above will be to place Catawba Unit 1 in maximum readiness for reliable commercial operation.
This schedule of activities is a challenging schedule with no contingency for idle time due to delays in power ascension. It has been compared in detail with the actual times required to conduct the ,
power ascension testing on Duke's McGuire Units 1 and 2. The comparison shows that the cumulative duration of 127 days (four months and one week) for power ascension testing is very close to that found necessary to perform similar testing on both McGuire units. Minor differences in the duration of such testing are directly attributable to changes in the scope of testing required by regulation.
In conclusion, we are faced with a large amount of work which must be completed in an orderly sequenced fashion, which demands that a
we have the ability to achieve criticality and move unencumbered through the various levels of plant output which I have discussed, in order that we will be able to complete the required testing program and place the unit in commercial operation on schedule. At this point, any delay in achieving initial criticality will result in a commensurate delay in commencement of the testing program, which results in a day-for-day delay in commercial operation.
As the r
_'D.,
e affidavit of Mr. W. R. Stimart shows, any such delay will impose substantial costs on Duke, its co-owners, and its customers.
IA.'blCN . lllit a Warren H. Owen and swo tobeforeme Subscribgdayof th s jfL_, c4AtR L 1984.
N30h' ' hb Asthul%i I
/ Notary Public y/
s
/
My Commission Expires 'Ic28-8d>
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