ML20140D830

Supplemental Affidavit of DM Crutchfield in Response to Questions Raised in Aslab 841002 Memorandum & Order ALAB-786 Re Basemat Issues.Related Correspondence

ML20140D830
Person / Time
Site:	Waterford
Issue date:	12/17/1984
From:	Crutchfield D Office of Nuclear Reactor Regulation
To:
Shared Package
ML20140D809	List: ML20140D803 ML20140D830 ML20140D845 ML20140D881 ML20140D912 ML20140D944 ML20140D962
References
ALAB-786, OL, NUDOCS 8412190219
Download: ML20140D830 (7)

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' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of LOUISIANA POWER AND LIGHT COMPANY ) Docket No. 50-382 (Waterford Steam Electric Station, Unit 3) )

SUPPLEMENTAL AFFIDAVIT OF DENNIS M. CRUTCHFIELD Q.1. Please state your name, title and by whom you are employed?

A.1. My name is Dennis M. Crutchfield. I am employed as Assistant Director for Safety Assessment Division of Licensing, Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Commission. A statement of my professional qualifications is attached to my affidavit filed on

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August 7, 1984.

Q.2. What is the purpose of this affidavit?

A.2. The purpose of this affidavit is to respond to the questions raised by the Atomic Safety and Licensing Appeal Board, in its Memorandum and Order of October 2, 1984 (ALAB-786), concerning the Staff's communi-cations with "the two primary sources for the Gambit article" published on December 10,1984 (Id. , at 12-13). In addition, I wish to provide certain additional information related to Waterford base mat issues, for consideration by the Appeal Board.

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Q.3. Please respond to the Appeal Board's inquiry as to whether "the Staff interviewed the two primary sources for the Gambit article" (ALAB-786, at 13).

A.3. In my previous affidavit, filed on August 7, 1984, I stated as follows (p.3):

Following publication of the Gambit article, the Staff initiated an inquiry and review of the allegations referred to therein, under the lead of NRC Region IV in conjunction with the Office of Investigations. As part of this review, interviews were conducted with various allegers and a review of documents was initiated by Region IV personnel at the Waterford site.

At the time my prior affidavit was filed, I did not identify the names of the various individuals who had been interviewed by the Staff, due to sensitivity on the part of both OI and the Staff with respect to the disclosure of investigation procedures and techniques, as well as because certain individuhls had requested that their names remain con-fidential. In light of the Appeal Board's interest in this matter, however, and because he has not requested confidentiality, I wish to confirm that comencing in January 1984, the Staff held a number of meetings with George Hill, the individual who served as the primary source i

for the Gambit article.

While the Appeal Board's Order indicates its belief that there were "tho primary sources" for that article, I do not understand that article to l

have had a second " primary source" of information. As far as I have been l

( able to ascertain, the Appeal Board probably had in mind Mr. J. M. " Joe" Davis, the individual whom Mr. Hill replaced as coordinator of the QAIRG l

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document review group. The Staff has met with Mr. Davis and discussed various Waterford-related matters with him.

Q.4. Did the Staff hold additional meetings with Mr. Hill and other allegers subsequent to the meetings with Mr. Hill held in January 1984?

A.4. Yes. In my previous affidavit (at pp. 3-5), I recited some of the facts which led to the formation of the Waterford Task Force.

Initially, interviews with Mr. Hill and other allegers were conducted by OI personnel with the assistance of Region IV. However, as the Staff's review of the allegations progressed further, it became apparent that additional resources and coordination among several Offices within the Comission would be required. Accordingly, on March 12, 1984, the Executive Director for Operations issued a memorandum establishing a program for treating outstanding issues which required resolution before the Staff's licensing decisions for the Waterford facility could be made.

This program led to the formation, in March 1984, of a task force comprised of some 40 technical individuals, which assembled at the Waterford site to gather and review all outstanding allegations concerning the Waterford facility.

Among the first actions taken by the Task Force was to meet with Mr.

Hill and certain other allegers who had come to the Staff's attention (some of whom have requested confidentiality), as a means of gaining a proper understanding of their concerns. As the work of the Task Force

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progre'ssed, further meetings were held with these and other individuals for the purpose of gathering additional information related to the con-struction at the facility, as well as to determine whether the Task I

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Force's interim.and final findings adequately addressed the individual's concerns.

! This process is addressed, in part, in Supplement 7 to the Staff's

- Safety Evaluation Report, dated September 1984 and issued on October 1, 1984. Thus, SSER 7 noted (at p. 2) that "[d]uring January, February, ,

a r i and March 1984, the Office of Investigations debriefed individuals who

alleged matters of wrongdoing and raised technical issues." During the I

j Staff's subsequent review, "in a number of . . . cases, the issue was

discussed with and clarified by the alleger" (Jd.). Further, the Staff ,

I developed a Waterford 3 Open Items Management Program, which required.

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among other elements, the following: i

NRC staff conferences, when possible, with allegers to l

assure an accurate initial understanding of allegations, i

. Continuing staff contact with all allegers, when possible, i to further assure that the staff's evaluations and resolu- '

) tions accurately addressed the concerns of the allegers; i

as well as give the staff the assurance that all issues ,

of safety significance were covered in their review.

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(Jd. In addition, SSER 7 notes that the Task Force met often with the [

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l The Management staff was assisted by the NRC Office of 1 Investigations (01). . . 0! and the Management staff

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worked closely to resolve the issues for investigation.

. During their evaluation of technical allegations, the l' staff often met with allegers to clarify an allegation '

! or discuss its status. In many cases, the alleger was I satisfied with the staff's evaluation. ,.

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(Id., at 2-3). SSER 7 contains further descriptions of this process, in many of the individual allegation sumaries.

Q.5. Please respond to the Appeal Board's inquiry as to whether the Staff, after completing its review of a particular allegation, "made con-tact with at least one of the individuals . identified in the article for the purpose of determining if the information uncovered by the staff fully addresses the individual's expressed concern" (ALAB-786, at 13).

A.S. As indicated above, an integral element of the management pro-gram adopted by the Staff for the purpose of identifying and resolving allegations required continuing staff contact with all of the allegers, when possible, in order to assure that their concerns were being addressed and resolved properly. In this regard, in the Staff's initial meetings with Mr. George Hill, and on numerous occasions with other illegers, the Staff obtained documents and references to other documents beyond those discussed in the Gambit article. Follow-up meetings were held when possible, to determine whether the allegers' concerns were being properly addressed.

For example, the allegation reported in the Gambit article, involving a 60-page non-conformance report written by Mr. Hill's QAIRG team on Cadweld records -- specifically referred to by the Appeal Board (ALAB-786,at13)--areembracedwithinanumberofallegations,suchas A-115, A-146, and A-156. The issue of Cadweld splicing was identified ,

as Item 11 in Mr. Eisenhut's letter of June 13, 1984, as an unresolved item having potential safety significance. Following the issuance of Mr. Eisenhut's letter, the Staff again met with Mr. Hill, who indicated

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that he was satisfied with the Staff's approach to resolution of this matter. The Staff's subsequent evaluation of this matter is addressed in the affidavits of Robert E. Shewmaker, filed August 7 and December 17, 1984. Further details concerning the final resolution of this issue, as well as the other items listed in Mr. Eisenhut's letter, will be addressed in SSER No. 9, scheduled to be issued shortly.

It should be noted that during the course of its investigation, the Staff met with those individuals identified in the Gambit article es well as more than 50 other individuals, many of whom have requested confiden-tiality. The Staff has attempted, during the course of this investigation, to meet with the allegers whenever possible, although it has not been possible to do so in each and every instance upon which the Staff completed its review of each of the more than 350 allegations that were identified.

However, on numerous occasions, the Staff discussed with the allegers many of the conclusions it had reached concerning the allegations and, as noted in SSER 7 (at p. 3), obtained the alleger's agreement that the item had been satisfactorily resolved. Based upon these meetings and the work performed by the Task Force, the Staff is satisfied that the Task Force has adequately addressed the individuals' concerns and, in some cases, addressed concerns which were not identified in the original allegations or subsequent meetings with allegers.

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Q.6. Has the Staff received any new information related to Water-ford base mat issues, which are not addressed by the Task Force findings?

A 6. Yes. The Staff has received information that the Applicant discovered cracks in the concrete base mat outside the reactor building

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ringwall (in the Fuel Handling Building and Auxiliary Building) as early as October 1977; that other such cracks were discovered prior to May 1983 (when cracking outside the ringwall was reported by the Applicant); and that the Applicant has had a program in place for the repair of such cracks since 1977. This information is to be contrasted with other statements made by the Applicant orally and in documents submitted to the Staff and Appeal Board conce,rning the discovery of cracking in the base mat. The Staff has referred this matter to the Office of Investigations.

( Q.7. Does this additional information affect any of the Staff's conclusions as to the safety significance of base mat issues?

,r A.7. No. This new information has been discussed with Dr. John

! , Ma, Mr. James Knight, and the Staff's BNL consultants (Drs. Morris Reich,

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Charles Miller, and Carl Costantino). These individuals have all stated that this new information does not affect their respective views concerning Waterford base mat safety issues.

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aDenn s M. Crutchfield

! Subscribed and sworn to before me this 17th day of December, 1984 g -

. Notary Fublic My. commission expires: 7//,/86 9

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