ML20126G014
| ML20126G014 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/13/1985 |
| From: | Sinkin L Citizens Concerned About Nuclear Power, INC. |
| To: | |
| Shared Package | |
| ML20126G006 | List: |
| References | |
| OL, NUDOCS 8506180038 | |
| Download: ML20126G014 (7) | |
Text
--
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD DOLMETED ushPC In the Matter of
(
'85 JUN 17 M1:21 HOUSTON LIGHTING AND
(
Docket Nos. 50-498 OL POWER COMPANY, ET AL.
)
'50-499 OL (South Texas Project,
(
GFFICE ': 3EC' -
Units 1 and 2)
(
00ChW ^ 5:4' EDNCH QQANE idggt[((cq([og of W[tgggggg Citizens Concerned About Nuclear Power hereby identifies the following individuals as the witnesses CCANP intends to
- call, either by agreement or through subpoena in this proceeding:
1.
Mr.
Don D.
Jordan, Chairman of the Board and Chief Executive 0+ficer of Houston Lighting and Power, to testify regarding his failure to mention the Quadrex Report, or the pendency of a far-reaching review of BLR's design engineering services during his Phase I testimony.
2.
Mr.
George W.
- Oprea, Jr.,
former Executive Vice President -
Nuclear of HL&P, to testify regarding communications with the NRC Staff about the Quadrex Report which occurred between August 19, 1981 and September 9, 1981:
the HL&P requests for permission to the NRC to carry out safety-related construction during the period May 7,
1981 through December 31, 1981; and his failure to mentinn the Duadrex Report, or the pendency of a
far-reaching revtew of D&R's design engineering services during his Phase I
1 t es t i n.on y.
3.
f1r.
Jer ome H.
- Goldberg, Group Vice President - Nuclear of
- HLLP, to testify regarding the HL&P requests for permission to the NRC to carry nut safety-related construction during the 8506180038 850613 PDR ADOCK 05000498 G
PM i
period May 7, 1981 through December 31, 1981 and his failure to mention the Quadrex Report, or the pendency of a far-reaching review of BLR's design engineering services during his Phase I
testimony.
4.
Mr. Richard A.
Fra:ar, Manager - Litigation Technical Support for HL&P, to testify regarding his failure to mention the Quadrex
- Report, or the pendency of a far-reaching review of BLR's design engineering services during his Phase I testimony.
5.
Mr.
Cloin Robertson, Houston Lighting and Power, to testify regarding his role in the decision making process regarding which items in the Quadre:: Report would be notified to the Nuclear Regulatory Commission Staff and whether the Quadrex Report as a
whole would be turned over to the ASLB.
6.
Mr.
M.
E.
- Powell, Houston Lighting and Power, to testify regarding his role and the role of the HLLP Incident Review Cornmittee in the notification to the NRC of 50. 55 (e) potentially reportable items and in the reporting of significant develcpments at the project to the ASLB during the:. period April - June, 1981.
7.
, lack R.
- Newman, Newman Holt:inger, P.C.,
to testify reoarding his role in the decision not to deliver the Quadrex Report to the NRC Staff and the ASLB prior to September 1981, his role in the ultimate release of the Ouadrex, Report, his representations to the Bnard and parties r enarding the Quadrex Report, and his role in HLbP's tallure to inform the Board of its decision to remove Brown and Root as architect-engineer for STNP.
8.
Alvin Gutterman, Newman Holt:inger.
P.C.,
to testify l
regarding his knowledge of and recponses to the Quadre:: Report in t.he period from January 1,
1981 thenugh September 24, 1981.
i t
i i
9.
Maurice
- Axelrad, Newman Holt:inger, P.C.,
to testify j
regarding his knowledge of and responses to the Quadrex Report in the period from January 1,
1981 through September 24, 1981..
10.
Attorneys for Baker and Botts (identitles currently unknown) who prepared the prefiled testimony of Mssrs.
- Jordan, Oprea,
- Goldberg, and Frazar to testify regarding their knowledge and responses to the Quadrex Report, particularly any discussions with said HL&P witnesses or other persons regarding inclusion of information about the Quadrex Report in the prefiled testimony in Phase I,
amending said prefiled testimony once the Quadrex Report wi.s delivered to HL&P, and/or including the Quadrex Report in the testimony given during the hearings in Phase I.
11.
Mr.
Jesse Poston, City Public Service Board of San Antonio, Texas to testify regarding the discussions held by the Management Committee for STNP regarding the Quadrex Report and communication or lack thereof regarding that report to the NRC and parties to this procbeding.
Reference:
Applicants response to Board ordered discovery, Documents #10, 12, 44 12.
Richard
- Herr, Investigator,
- NRC, Region IV to -testify regarding the investigation in which he received and reviewed the Quadrex Report.
13.
Mr.
Joe I Tapia, Reactor Inspector, Region IV, to testify regardino his involvement in the NRC investigation which led to the revelation of the entire Qiusdren Report to the NRC.
14.
Mr.
H.
Shannon
- Phillips, Senior Resident Inspector / Construction, Regton IV,'
to testify regarding his l
participation in the NRC investigation in which he reviewed the r
Duadrea Report.
- 15. Donald E. Sells, Senior Project Manager, St. Lucie Plant, ORB
- III, Division of Licensing,
- NRR, to testify regarding his discussion about the Quadrex Report with HL&P managers and other members of the NRC Staff from the time he first heard about the Quadrex Report being commissioned through December 1981.
16.
Mr.
Ed
- Reis, OELD,
- NRC, to testify regarding his communications with Mr.
Don Sells and with Houston Lighting and Power or HLt.P 's counsel about turning the Quadrex Report over to the ASLB.
17.
Mr.
John Collins, NRC, regarding his meetings with HL&P to discuss the Quadrex Report after the Report was reviewed by NRC investigators in August 1981, including his discussions regarding potential 50.55(e) reports and his tentative conclusion that the entire report represented an " engineering control breakdown" for which a 50.55(e) report should have been made as a violation of 10 C.F.R. Part 50, Appendix B,
Criterion VII
(
Reference:
Applicants' supplementary response to ASLB ordered discovery, Excerpt of Mimutes of September 1C, 1981 Meeting of STP Participants) and his meeting with HL&P personnel on October 6,
1981 at which time the Quadrex Report and the termination of Brown and Root as architect-engineer were discussed.
Also to testify regarding his supervision of the investigation into the allegation that HLLP conspired to prevent the NRC from seeing the entire Quadrex Report.
- 18. Mr. Karl Seyfrit, NRC, regarding his communications with HL&P in the period from May 7, 1981 through December 31, 1981 about requests from HL&P to proceed with safety related construction at 1
STNP and -his tentattve conclusion that the entire report I
4
represented an
" engineering control breakdown" for which a
50.55(e) report should have been made as a violation of 10 C.F.R. Part 50, Appendix B,
Criterion VII
(
Reference:
Applicants
- supplementary response to ASLB ordered discovery, Excerpt of Mimutes of September 12, 1981 Meeting of STP Participants).
19.
Mr.
Jay Gutierre:,
- OELD, to testify regardir.?
his participation in the investigation into the allegation of a
conspiracy to withhold the Guadrex Report from the NRC.
20.
Mr.
G.
L.
Madsen, Reactor Inspector, Region IV, to testif f regarding his participation in the investigation into the allegation of a conspiracy to withhold the Quadrex Report from the NRC.
21.
Mr.
Don
- Driskill, Reactor Inspector,
- NRC, to testify regarding his participation in the investigation into the allegation of a conspiracy to withhold the Quadrex Report from the NRC.
- 22. William J.
Dircks, Executive Director for Operations, NRC, to testify regarding his role in the NRC's initial inquiry into HLLP's handling of the Quadrex report, his evaluation of CCANP's charges of a conspiracy to withhold the Quadrex Report from the
- NRC, and his subsequent testimony to Congress regarding the significance of the Quadrex Report as demonstrating the magnitude of potential quality assurance problems at STNP.
23.
Mr.
Richard
- DeYoung, NPC, regarding his role in the NRC headquarters inquiry into HLbP's nandling of the Quadrea Report and his findings.
24.
Mr.
James Lieberman,
- NRC, regarding the NRC enforcement policies as they apply to the fact of HL&P's handling of the 5
Duadrex Report and regarding his response to communications from CCANP at the time of the discovery of the Quadrex Report concerning the potential for such enforcement actions.
25.
Commissioner Thomas M.
- Roberts, Nuclear Regulatory Commission, to testify regarding representations made to him on February 21, 1982 by Mr. Jerome Goldberg concerning the nature of the Quadrex Report and the reasons for its commissioning, representations which CCANP contends were false and misleading and represented further evidence of HL&P's intent to deceive the NRC regarding the report.
Res ectfully submitted, AL Lanny inkin Representative for Intervenor Citizens Concerned About Nuclear Power, Inc.
3022 Porter St.,
N.W.
- 304 Washington, D.C.
20008 (202) 966-2141 Dated: June 13, 1985 Washington, D.C.
e 6
L.
o g%
UNITCO STA1ES OF RMERICA NUCLEAR REGULATORY COMMISSIOk BEFORE THE AIOMIC SAFETY AND LICENSINU BOARD OMhEM)
U%RC In the Matter of
(
15 JUN 17 All:21
)
HOUSTON LIGHTING AND
(
Docket Nos. 50-498 OL POWER COMPANY, ET AL.
)
50-499 O L gyp,.
00Cdii,[.fYy^['[
(South Texas Project,
(
Units 1 and 2)
(
E T' M. >i CEBIIEICeIE OE SEBy1CE I
hereby certify that copies of CCANP'S IDENTIFICATION OF WITNESSES and CCANP'S LETTER TO NENBERS OF THE BOARD DATED JUNE 13, 1985 were served by hand delivery (*)
or deposit in the U.S.
- Mail, first class postage paid to the following individuals and entities on the 13th day of June 1985.
- Charles Bechhoefer, Esquire Brian Berwick, Esquire Chairman Asst. Atty. Gen.
Atomic Safety and Licensing Board State of Texas U.S.
Nuclear Regulatory Commission Environmtl. Protection Washington, D.C.
20555 P.
O.
Box 12548, Capitol Sta.
Austin, Texas 78711 Dr. James C.
Lamb, III Administrative Judge
- 0reste Russ Pirfo, Esquire 313 Woodhaven Road Office of the Exec. Leg. Dir.
Chapel Hill, North Carolina 27514 U.S.
Nuclear Regulatory Comm.
Washington, D.C.
20555
- Frederick J.
Shon Administrative Judge
- Jact R.
Newman, Esquire U.
S.
Nuclear Regulatory Commission 1615 L Street, NW, Suite 1000 Washington, D.C.
20555 Washington, D.C.
20036 Melbert Schwarz, Esquire Baker and Botts Mrs. Peggy Buchorn 300 One Shell Pla:a Executive Director, C.E.U.
Houston, Texas 77002 Route 1,
Box 1684 Brazoria, Texas 77422
- Atomic Safety and Licensing Bd.
U.S.
Nuclear Regulatory Comm.
William S.
Jordan, III, Esq.
Washington, D.C.
20555 Harmon, Weiss b Jordan 2001 S Street, N.W.,
Suite 400
- Atomic Safety and Licensing Washington, D.C.
20009 Appeal Board U.S.
Nuclear Regulatory Comm.
Pat Coy Washington, D.C.
20555 5106 Casa Oro San Antonio, Texas 70233 Dockettnq and Service Section Office of the Secretary Ray Goldstein U.S.
Nuclear Regulatory Comm.
1001 Vaughn Bida.
Washington, D.C.
20555 j
807 Brazos Aus in, Texas 78701 l
/s.M.- -. -..
Lanny nkin
-