ML20140D881

Supplemental Affidavit of R Pichumani Re Basemat Issues. Related Correspondence

ML20140D881
Person / Time
Site:	Waterford
Issue date:	12/17/1984
From:	Pichumani R Office of Nuclear Reactor Regulation
To:
Shared Package
ML20140D809	List: ML20140D803 ML20140D830 ML20140D845 ML20140D881 ML20140D912 ML20140D944 ML20140D962
References
ALAB-786, OL, NUDOCS 8412190237
Download: ML20140D881 (3)

Text

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t' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION

'BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of L001SIANA POWER AND LIGHT COMPANY Docket No. 50-382 (WaterfordSteamElectricStation,)

Unit 3) )

[ SUPPLEMENTAL AFFIDAVIT OF RAMAN PICHUMANI Q.1. Please state your name, title and by whom you are employed?

A.I. My name is Raman Pichumani. Since March 1984, I have been employed as a Systems Engineer (Mechanical) in the Mechanical Engineering Branch of the Division of Engineering, Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Comission. Prior to March 1984, I was employed as a Geotechnical Engineer in the Structural and Geotechnical Engineering Branch, Division of Engineering. A statement of my professional qualifications is attached to my previous affidavit filed in this proceeding on November 28, 1983.

Q.2. Please describe the nature of your involvement, if any, in the Staff's further evaluation of issues related to the Waterford base mat since November 1983. -

- A.2. On March 19, 1984, I transferred from the Structural and Geotechnical Engineering Branch (SGEB) to the Mechanical Engineering Branch (HEB) of the Division of Engineering. At that time, my review responsibilities for the Waterford plant were transferred to another 8412190237 841217 PDR ADOCK 05000382 0 PDR

9 geotechnical engineering reviewer, Dr. John Chen.

Between th' e time my previous affidavit was filed on November 28, 1983 and the time I transferred to MEB on March 19, 1984, I was mainly engaged with other assignments not related to the Waterford facility.

However, during that brief period, I read the December 10, 1983 Gambit article, and participated in an internal NRC staff meeting on February 7, 1984 and in a telecon with Region IV staff on February 16, 1984. I was also present as an observer for part of a meeting held with the Applicant in Bethesda on March 21, 1984 (a few days after my transfer to MEB). I was not, however, in any way involved with the extensive investigations, discussions, site visits, and detailed evaluations which were performed by the NRC staff and its consultant, BNL, commencing with meetings held with the applicant on March 26 and 27, 1984. Similarly, I was not involved with the work of the civil / structural allegation review team, which commenced its activities in March 1984 after my transfer from SGEB to MEB.

Q.3. Have you reviewed any of the documents reflecting the further evaluation that has been performed by the Staff and its consultants since your previous affidavit was filed on November 28, 1983?

A.3. Yes. After the Atomic Safety and Licensing Appeal Board issued its Order of October 2,1984, I was asked to read the July 18,

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1984 report issued by the Staff's consultants from Brookhaven National Laboratory, as well as the affidavits and addendum to the BNL report

I filed by the Staff on August 7, 1984. I have read those documents, but have not read any other documents prepared by the Staff cr the Applicant, or by their consultants, after hovember 1983.

My review of these documents was undertaken in order to comply with the Appeal Board's request that I provide a statement as to what effect, if any, the Staff's further evaluation has on the position I espoused in my previous affidavit. Accordingly, I have read these documents paying attention only to the geotechnical (soils) area, since my earlier involvement was only with geotechnical aspects of the problem.

Q.4. Please state what effect, if any, the Staff's further f evaluation has on the position you espoused in your affidavit of November 28, 1983.

A.4. After reading these documents, I find that I lack a basis to -

evaluate the conclusions arrived at by the Staff and its consultant, BNL, because of my total unfamiliarity with the large number of .

documents and data to which they refer in support of their conclusions, and because I was not privy to the many investigations, analyses, meetings, and discussions that were carried on after my involvement with the case ended in March 1984. Accordingly, I am unable to state what eff,ect,the Staff's further evaluation has on my previous position.

% h_ed

.Raman Pichumani Subscribed and sworn to this /7+ day of December,1984 84b//jVI-&slh Notary Public My commission expires: 7//,/ffo

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