ML20138M608

Affidavit of L Stanley Re Encl Notes of 810102 Telcon W/ Jr Sumpter Concerning Util Desire for Review of Brown & Root Engineering.Certificate of Svc Encl

ML20138M608
Person / Time
Site:	South Texas
Issue date:	12/12/1985
From:	Stanely L, Stanley L HOUSTON LIGHTING & POWER CO., ZYTOR, INC.
To:
Shared Package
ML20138M582	List: ML20138M578 ML20138M608
References
OL, NUDOCS 8512230065
Download: ML20138M608 (6)

Text

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k' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DEEIO L'WC BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'85 DEC 19 P2:38 In the Matter of )

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HOUSTON LIGHTING & POWER ) Docket Nos. 50T49&NQL SEiiVifi 8

COMPANY, ET AL. ) 50-496 0d2

)

(South Texas Project, Units 1 )

and 2) )

AFFIDAVIT OF LOREN STANLEY LOREN STANLEY, being duly sworn, deposes and says:

My business address is Zytor Incorporated, Suite 203A, 1213 Lincoln Avenue, San Jose, California, 95125. I testified in this proceeding on July 29 and 30, 1985.

I have reviewed the attaened single page of handwritten notes, a copy of which was provided to the Licensing Board and parties by Applicants' counsel on November 29, 1985. These notes were made by me during a telephone conversation I had with Dr. James R.

Sumpter of Houston Lighting & Power Company (HL&P), with some minor additions I made later. The conversation occurred on January 2, 1981. In the conversation, we discussed the desire of HL&P to have a review conducted of Brown & Root engineering on the South Texas Project, the scope of the proposed review and its schedule.

It is apparent from my notes that Dr. Sumpter gave me some background information about the project, such as the fact that Mr. Goldberg had recently come to HL&P from Stone & Webster.

My attention has been directed to the notation "May 81 Hearing

- NRC." I have no specific recollection of any mention of the 8512230065 851217 PDR ADOCK 05000498 C PDR

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NRC hearing during my conversation with Dr. Sumpter. It is possible that Dr. Sumpter mentioned the hearing as part of the general background discussion, or in the context of discussing the schedule for the review. However, neither at that time nor at any other time was it ever suggested to me that the review was being undertaken in any way for purposes of preparation for the hearing.

I was present at the STP hearing on July 11 and 12, 1985, when Mr. Goldberg testified about the purposes of the Quadrex engineering review. His testimony was consistent with my recollection of the purpose, as I understood it in 1981. 'I knew that Mr. Goldberg had recently assumed responsibility for the design and construction of STP and I understood that he wanted to get an independent review of the status of the engineering effort and B&R's ability to perform the remaining design work. At one point during that time, Dr. Sumpter mentioned to me that the review might assist HL&P in answering any questions about engineering that might arise at the NRC hearing. That comment may have been made during the January 2nd telephone conversation, or at some other point.

In any event, I understood that the added ability to answer such questions was a relatively minor incidental benefit the review might provide, and was not a motivation for conducting the review.

I have been asked whether, during our January 2, 1981, telephonc conversation, Dr. Sumpter said the people performing the study should be " fairly heavy people" because they might be called to testify in the May 1981 hearing. Dr. Sumpter did not make any such statement. Dr. Sumpter never suggested to me, either in-that telephone conversation or at any other time during the

review, that Quadrex personnel might be asked to testify in the NRC hearing. My reference to " fairly heavy people" was simply my own shorthand for noting Dr. Sumpter's request that we employ experienced personnel in the review.

The attached page of notes was copied with an index card stapled to it. It was not unusual for cards to be stapled to papers in my files at Quadrex. I do not recall what is written under the card, however, I am certain that I did not intentionally cover something of potential interest when I sent this copy of my notes to Dr. Sumpter in 1982.

dneus Loren Stanley

&/ #A State of California S S

County of Santa Clara S Subscribed and sworn to before me, a Notary Public in and for Santa Clara County, California, this /A day of December 1985.

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i UNITED STATES OF AMERICA 00; gg ,- .

NUCLEAR REGULATORY COMMISSION U i'i ~ "

BEFORE THE ATOMIC SAFETY AND LICENSING BOAgg OE019 P2:38 In the Matter of ) 0Frict -

} 00CAE$;;fr nt .!,6 HOUSTON LIGHTING & POWER ) Docket Nos. 50-498bbfCh#"'

3 COMPANY, ET AL. ) 50-499 OL

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(South Texas Project, Units 1 )

and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of the letter to the Atomic Safety and Licensing Board from A. H. Gutterman dated December 17, 1985 with attached " Affidavit of Loren Stanley" have been served on the following individuals and entities by deposit in the United States mail, first class, postage prepaid on this 17th day of December, 1985.

Charles Bechhoefer, Esq. Brian Berwick, Esq.

Chairman, Administrative Judge Assistant Attcrney General Atomic Safety and Licensing For the State of Texas Board Panel Environmental Protection U.S. Nuclear Regulatory Division Commission P.O. Box 12548, Capitol Station Washington, D.C. 20555 Austin, TX 78711 Dr. James C. Lamb, III Kim Eastman, Co-coordinator Administrative Judge Barbara A. Miller 313 Woodhaven Road Pat Coy Chapel Hill, NC 27514 Citizens Concerned About Nuclear Power Frederick J. Shon 5106 Casa Oro

• Administrative Judge San Antonio, TX 78233 U.S. Nuclear Regulatory Commission Lanny Alan Sinkin Washington, D.C. 20555 Christic Institute 1324 North Capitol Street Mrs. Peggy Buchorn Washington, D.C. 20002 Executive Director Citizens for Equitable Ray Goldstein, Esq.

Utilities, Inc. Gray, Allison & Becker Route 1, Box 1684 1001 Vaughn Building Brazoria, TX 77422 807 Brazos Austin, TX 78701-2553

Oreste Russ Pirfo, Esq.

Robert G. Perlis, Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission

' Washington,-D.C. 20555 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service-Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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