ML20151T611
| ML20151T611 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 01/29/1986 |
| From: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20151T554 | List: |
| References | |
| OL, NUDOCS 8602100318 | |
| Download: ML20151T611 (4) | |
Text
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^ ATTACHMENT A c
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD t
In the Matter of
)
)
HOUSTON LIGHTING & POWER
)
Docket Nos. 50-498 OL COMPANY, ET AL.
)
50-499 OL
)
-(South Texas Project, Units 1
)
and 2)
)
AFFIDAVIT OF JEROME H. GOLDBERG I have reviewed the January 17, 1986 Motion of CCANP to reopen the record of Phase II and the documents attached thereto, including the excerpts of the deposition of Mr. Eugene A.'Saltarelli.
In those deposition pages Mr. Saltarelli mentioned a meeting he had with me in which we discussed the desirability of an independent review of B&R design work on STP.
I recall such a meeting between Mr. Saltarelli and myself in late 1980.
This is the meeting I mentioned in my testimony of December 5, 1985 at Tr. 15534-35 and 15578.
In that meeting Mr. Saltarelli and I discussed the potential value of third party assessments of engineering work on nuclear projects.
-Mr.
Saltarelli mentioned that he had participated in such a review for NUS on an earlier project.
We then discussed the usefulness of such a review at STP and its potential benefit to both.of us in performing our respective responsibilities, 8602100318 860203 PDR ADOCK 05000498 G
PDR ^
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+ particularly since we were both relatively new to the Project.
During the course of the meeting, I very likely mentioned to Mr. Saltarelli, as I had to others in 1980-81, that a benefit of such a design review would be that I would be better able to answer questions concerning STP engineering.if any were raised in future ASLB hearings.
The CCANP Motion asserts that the Quadrex Review and certain design review work. assigned to NUS were "part of an overall litiga-tion strategy agreed upon by HL&P and Brown & Root."
CCANP Motion at 14.
Neither the Quadrex review nor the NUS work was performed in order to prepare for the ASLB hearing; Mr. Saltarelli and I did not discuss these efforts in the context of planning a strategy for licensing litigation.
Rather, our principal focus was on our mutual professional interest in assuring the safe and successful completion of STP engineering and design.
I have read the foregoing portion of this affidavit to Mr.
Saltarelli and he generally confirms my recollection of our conversa-tion in 1980.
TE be7ome H.
Goldberg /
State of Texas S
S County of Matagorda S
Sworntoandsubscribedbeforemethisc(IN_ day of January, 1986.
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FEB -619865s':in UNITED STATES OF AMERICA NUCIEAR REGULATORY COMMISSION h-occrrimG S
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BEFORE THE ATOMIC SAFETY.AND LICENSING BOARD
/
tu In the Matter of
)'
)
HOUSTON LIGHTING & POWER
)
Docket Nos. 50-498 OL COMPANY, ET AL.
)
50-499 OL
)
(South Texas Project, Units 1 )
and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the letter to the Members of the Licensing Board from Maurice Axelrad dated February 5, 1986, the letter to Mr. Lanny A.
Sinkin, Esquire from Jack P. Newman dated February 3, 1986, the letters to Jack R. Fewman from Lanny A. Sinkin, Esquire dated January 17, 1986 and Janeary 24, 1986, respectively, and Applicants' Response to "CCANP Motion to Reopen the Phase II Record:
IV; For Discovery and to Suspend Further Activity in Phase III" dated February 3, 1986 have been served on the following individuals and entities by deposit in the United States
- r. ail, first class, postage prepaid on this 3rd day of February, 1986.
Charles Bechhoefer, Esq.
Brian Berwick, Esq.
Chairman, Administrative Judge Assistant Attorney 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 1324 North Capitol Street Washington, D.C.
20002 Mrs. Peggy Buchorn Executive Director Ray Goldstein, Esq.
Citizens for Equitable Gray, Allison & Becker Utilities, Inc.
1001 Vaughn Building Route 1, Box 1684 807 Brazos Brazoria, TX 77422 Austin, TX 78701-2553
e f.
=l p 1 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 9
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