ML20211J414

Affidavit of DC Garlington Re Irregularities in Plant Const or Operations Noticed During Site Visits.Emergency Lights Not Aimed & Locked & Trash in Diesel Room Noted in Monitoring Repts.W/Certificate of Svc

ML20211J414
Person / Time
Site:	Comanche Peak
Issue date:	10/28/1986
From:	Garlington D GDS ASSOCIATES, TEX-LA ELECTRIC COOPERATIVE OF TEXAS, INC. (FORMERLY
To:
Shared Package
ML20211J313	List: ML20211J307 ML20211J355 ML20211J414
References
OL, NUDOCS 8611110130
Download: ML20211J414 (4)

Text

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.. Appandix C AFFADIVIT I David C.'Garlington, being duly sworn, dipose and state the following:

1. I am an employee of GDS Associates of Atlanta, Georgia and have been_ employed by GDS since February, 1986. Prior to this employment I was employed by Southern Engineering.

Company of Atlanta, Georgia, where I had been employed since April 1985.

2.- I have a Masters of Engineering degree in Nuclear-Engineering from Rensselaer Polytechnic Institute. My work experience-includes Reactor Protective System design and accident transient analysis with Combustion Engineering, Power Systems, in Windsor Connecticut, plant engineering in an operating nuclear generating station (Connecticut Yankee), and technical consulting with the Generation Services groups of Southern Engineering and GDS Associates.

in Atlanta.

3. Both Southern Engineering and GDS Associates were hired by Tex-La Electric Cooperative of Texas, Inc. to conduct a. monitoring program of the Comanche Peak steam electric station, under construction near Glenrose, Texas.

As part of my duties at both Southern Engineering and GDS Associates I was involved in all aspects of the monitoring program, including the conducting of site visits, interviews with employees of Texas Utilities Generating Company (TUGCO), the construction. managers of the plant, attending NRC meetings and hearings related to the licensing of the plant, and the preparation of the periodic ,

monitoring reports for Tex-La.

4. The information gathering activities that were done in preparation of the monitoring reports focused entirely upon information provided by TUGCO or independent contractors associated with the project or information publically available through the NRC licensing proceedings news media, etc. The site visits were essentially for.the purpose of surveillance and inspection of construction activity at the plant. No attempts were made to independently ascertain causes of problems of which we were apprised by plant personnel nor were any attempts to inspect nonproblem areas of the plant for possible deficiencies. Such activities were not within the scope of.the monitoring program.

8611110130 DR 861104 ADOCK 05000445 PDR

5. At times in the course of site visits certain irregularities in plant construction or operations would be noticed. Such irregularities were usually superficial problems related to general construction practices and not specifically to nuclear construction or engineering practices. For example, on one occassion, it was noticed that emergency lights were not' aimed and locked, rather they were allowed to swivel. On another occasion it was noticed that trash had collected in one of the diesel rooms. In each of these cases, the problems were brought to the attention of TUGCO and action was taken to correct them. This information was noted in'the monitoring reports.

6. The final product of the monitoring program, the

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monitoring reports, were intended to give Tex-La an independent assessment of the probability of TUEC's. meeting its construction and licensing schedules and its projected deadlines for turnovers of equipment and systems. This information was intended to aid Tex-La'in its own business

.and financial planning, and later in its legal efforts with regard to its law suit against'TUEC.

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r 1 David C. ppflington Subscribed and sworn before me this 8 day of OGM# ,

1986. ,

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l My Commission Expires: h!T Commission Ewires Septembu 14.1990 l

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O?fMIJC

"'We CERTIFICATE OF SERVICE

. I, Peter J. Plocki, one of the attorneys for app icinE72ll6 Tex-La Electric Cooperative of Texas, y that Inc.,herebydkfki{il?Y?nct

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y, on November 4, 1986, I made service of the within Response of Applicant Tex-La Electric Cooperative of Texas, Inc. to

" Supplemental CASE _ Response to Applicants' Motion for Protective Order Re 6/27/86 Discovery and Motion to_ Compel" by mailing copies thereof, postage prepaid, to:

Peter B. Bloch, Esquire Mr. Thomas F. Westermen Chairman Comanche Peak S.E.S.

Administrative Judge .c/o U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board P.O. Box 38 U.S. Nuclear Regulatory Glen Rose, Texas 76043 Commission Washington, D.C. 20555 Dr. Walter H. Jordan Secretary-Administrative Judge U.S. Nuclear Regulatory 881 W. Outer Dr'ive Commission Oak Ridge, TN 37830 Washington, D.C. 20555 Attention: Chief, Docketing

& Services Section Stuart A. Treby, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE Legal Director 1426 S. Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C. 20555 Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney General Atomic Safety and Licensing Environmental Protection Board Panel Division U.S. Nuclear Regulatory P.O. Box 12548, Capitol Station Commission Austin, Texas 78711 Washington, D.C. 20555 Chairman Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Anthony Roisman, Esquire Mr. Lanny A. Sinkin Executive Director Christic Institute Trial Lawyers for Public Justice 1324 North Capitol Street 2000 P Street, N.W., Suite 611 Washington, D.C. 20002 Washington, D.C. 20036 Dr. Kenneth A. McCollom Mr. Robert D. Martin Adninistrative Judge Regional Administrator 1107 West Knapp Region IV Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission, Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Ms. Billie Pirner Garde Geary S. Mizuno,.Esq.

Midwest Office Office of the Executive 3424 N'. Marcos Lane Legal Director Appleton, WI 54911 U.S. Nuclear Regulatory Commission Maryland National Bank Bldg.

Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 Elizabeth B._ Johnson Nancy Williams Administrative Judge Cygna Energy Services, Inc.

Oak Ridge National Laboratory 101 California Street P.O. Box X, Building 3500 Suite 1000 Oak Ridge, Tennessee 37830 San Francisco, CA 94111 Robert A. Wooldridge, Esquire Nicholas Reynolds, Esquire Worsham, Forsythe, Sampels Bishop, Liberman, Cook,

& Wooldridge Purcell & Reynolds 2001 Bryan Tower, Suite 3200 1200 17th Street, N.W.

Dallas, Texas 75201 Washington, D.C. 20036 Mr. W.G. Counsil Mr. Roy P. Lessy, 't.

Executive Vice President Morgan, Lewis & Bockius Texas Utilities Generating Co. 1800 M Street, N.W.

Skyway Tower, 25th Floor Washington, D.C. 20036 l

400 N. Olive Street Dallas, Texas 75201 l Mr. Thomas G. Dignan, Jr.

Ropes & Gray 225 Franklin St.

! Boston, MA 02110 1

! Peter J.' Plocki l

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