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Category:AFFIDAVITS
MONTHYEARML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc ML18016A8191999-02-12012 February 1999 Affidavit of G Thompson Re Application by CP&L for Amend to FOL NPF-63 & NRC Review of Application & Proposes to Determine That Amend Request Involves No Significant Hazards Consideration ML20209A9071987-01-28028 January 1987 Affidavit of JW Mckay.* Provides Minor Corrections to 861017 Affidavit.Corrections Should Be Made to Allegation on Undercut Tolerances for Holes Drilled to Receive maxi-bolt Anchors.Certificate of Svc Encl ML20214S1271986-09-25025 September 1986 Affidavit of Tw Brombach Re Allegations Raised in Ps Miriello 860728 Affidavit Concerning QA Filed in Support of 860915 Motion to Reopen Record.Allegations W/O Factual Basis.Util s to Jn Grace Re Insp Encl ML20214S1051986-09-25025 September 1986 Affidavit of SA Brown Re 860728 Affidavit of Ps Miriello Concerning Radiation Exposure,Filed in Support of Motion to Reopen Record.Allegations Re Exposure to High Levels of Radiation Unsupported ML20210B6471986-09-13013 September 1986 Affidavit of Ps Miriello Re safety-related Welds That Never Received Preservice Insp ML20205F3771986-08-0606 August 1986 Affidavit of Tw Brombach Re Issues Raised in 860702 Request for Institution of Proceeding Per 10CFR2.206,specifically Allegations on Inservice Insp of Piping Welds.Insp Rept 50-400/85-48 Encl ML20210E0171986-07-28028 July 1986 Affidavit of Ps Miriello Re False Dose & Const Records Constituting Threat to Public Health & Safety ML20210B6961986-07-28028 July 1986 Affidavit of Ps Miriello Stating That QA Quality Check Program Not Used as Intended at Facility ML20210U7691986-05-16016 May 1986 Affidavit of Ps Miriello Re Failure to Act on Issues of False Dose Records,Intimidation & Unsafe Radiation Practices Until After Contention W-4 Produced ML20210U7751986-05-15015 May 1986 Affidavit of Ps Miriello Re Health Physics Supervisors Ordering Author to Agree W/False Radiation Rept & to File NRC Form 4 in Agreement W/False Radiation Rept ML20204A4921986-05-0606 May 1986 Affidavit of SA Browne Re Results of Review of Ps Miriello 860403 Affidavit in Support of Conservation Council of North Carolina & W Eddleman Request for Admission of New Contention WB-4 ML20210K7041986-04-0303 April 1986 Affidavit of Ps Miriello Re Falsification of Exposure Records.Related Info Encl.W/Certificate of Svc ML20154N2091986-03-10010 March 1986 Suppl to HR Goodwin Affidavit on Timing of Weather Alerts, Per ASLB Request.Info on Precise Times That Weather Alerts Transmitted Unavailable.Certificate of Svc Encl ML20205K6031986-02-24024 February 1986 Affidavit of RW Fell,Supporting NRC Response to Aslab Question Re Conservation Council of North Carolina Contentions 16,17 & 18.Certificate of Svc Encl ML20137P5991986-01-30030 January 1986 Affidavit of Ti Hawkins,Supporting Nrc/Fema Response to Applicant Motions for Disposition of Eddleman Contentions EPX-2 & EPX-8.Certificate of Svc Encl ML20137F4171986-01-13013 January 1986 Affidavit of W Ethridge Re Contention EPX-2.Minor Highway Patrol Radio & Telephone Communications Delays During 850517-18 Exercise Were Due to Priority Assigned to Messages & Emergency Operations Ctr.Difficulties Being Resolved ML20137J0731986-01-13013 January 1986 Affidavit of Ah Joyner in Response to Eddleman Contention EPX-8 Re Emergency Broadcast Sys.Certificate of Svc Encl ML20137F4101986-01-13013 January 1986 Affidavit of Dh Brown Re Contention EPX-2.Relay Procedure Is Normal Operating Procedure for Radiation Protection Section Communications & Causes No Significant Delays or Addl Inaccuracies ML20137F6491986-01-13013 January 1986 Affidavit of M Scott Re Contention EPX-2.Chatham County Responded Appropriately & Effectively to Experience Gained During 850517-18 Exercise.Addl Dispatchers Will Assure Response to Radio Traffic Levels.W/Certificate of Svc ML20137F6161986-01-13013 January 1986 Affidavit of Ah Joyner Re Contention EPX-2.Corrective Actions Being Taken to Resolve Communications Problems Experienced During 850517-18 Exercise.Resolutions Expected Prior to Full Power Licensing of Plant ML20137J0591986-01-10010 January 1986 Affidavit of R Capps in Response to Eddleman Contention EPX-8 Re Emergency Broadcast Sys ML20136F6401985-12-31031 December 1985 Affidavit of Dn Keast Re Correction to 851104 & 05 Oral Testimony on Eddleman Contention 57-C-3.Certification of Svc & Notice of Withdrawal Encl ML20137L7951985-11-26026 November 1985 Affidavit of Wj Hindman Re Info on Age Distribution & Gender of Daniel Intl Corp Employees & First Line QA Inspectors at Facility.Certificate of Svc Encl ML20135H8321985-09-23023 September 1985 Affidavit of SL Burch Re Undercover Drug Operation at Facility.Related Correspondence ML20135H8371985-09-19019 September 1985 Second Affidavit of SL Burch Re Drug Investigation at Facility.Related Correspondence ML20137L6741985-09-0606 September 1985 Affidavit of P Miriello Re Drug Abuse Observed at Facility Const Site.Certificate of Svc Encl ML20134H4261985-08-23023 August 1985 Affidavit of Wp Haass Re ASLB Questions Concerning Whether Public Disclosure of Info Voluntarily Submitted to NRC Would Impair NRC Future Ability to Obtain Similar Info.Notice of Appearance of Ga Berry & Certificate of Svc Encl ML20135C0421985-08-23023 August 1985 Affidavit of Wp Haass Addressing Series of Questions Propounded by ASLB Re Whether Public Disclosure of Info Contained in Certain Applicant Documents in ASLB Possession Would Impair Staff Ability to Obtain Info ML20134E7891985-08-14014 August 1985 Affidavit of Wj Hindman Responding to SL Burch 850731 Affidavit Re Undercover Drug Investigation During Fall 1984 ML20134E7761985-08-14014 August 1985 Affidavit of MW King Responding to SL Burch 850731 Affidavit Re Late 1984 Undercover Narcotics Investigation at Site ML20134E7661985-08-14014 August 1985 Affidavit of DG Joyner Responding to SL Burch 850731 Affidavit Re Late 1984 Undercover Narcotics Investigation at Site ML20134E7831985-08-0909 August 1985 Affidavit of ML Plueddemann Re Fall 1984 Undercover Drug Investigation at Site ML20133A1111985-07-31031 July 1985 Affidavit of SL Burch Re Assertions in King Affidavit & Undercover Operation of Facility Concerning Drug Abuse. Intelligence Indicated Drug Dealings & Abuse Widespread. Certificate of Svc Encl ML20129H1061985-07-11011 July 1985 Affidavit of Nj Chiangi Re Allegation in Conservation Council of North Carolina Contention WB-3.QA Program Provides Necessary Steps to Ensure Safe & Reliable Power Plant.Certificate of Svc Encl ML20129H0941985-07-10010 July 1985 Affidavit of Wj Hindman Re Allegations in Conservation Council of North Carolina Contention WB-3 That Drug Abuse Widespread & That Mgt Failed to Control Drug Use During Const ML20129H0821985-07-10010 July 1985 Affidavit of Pb Bensinger Re Allegations in Conservation Council of North Carolina Contention WB-3 That Drug Abuse Widespread & That Mgt Failed to Control Drug Use During Const.Biography Encl ML20129H0911985-07-0909 July 1985 Affidavit of Jd Ferguson Re Allegation in Conservation Council of North Carolina Contention WB-3 That Mgt Failed to Control Drug Use During Const.Cp&L Adopted Drug & Alcohol Interdepartmental Procedure.Resume & Procedure Encl ML20129H0991985-07-0909 July 1985 Affidavit of AR Pannill & Gw Flowers Re Allegation in Conservation Council of North Carolina Contention WB-3 That Mgt Failed to Control Drug Use During Const.Employees Subjected to Preemployment Background Verification ML20129H0871985-07-0909 July 1985 Affidavit of MW King Re Allegations in Conservation Council of North Carolina Contention WB-3 That Drug Use Widespread & That Mgt Failed to Control Drug Use During Const.Resume Encl ML20128M0401985-07-0808 July 1985 Affidavit of TS Elleman Supporting Util 850709 Application for Withholding Final Rept Shnp QA/QC-Const Inspector Review Panel, Per 10CFR2.790.Certificate of Svc Encl. Related Correspondence ML20128M0331985-07-0808 July 1985 Affidavit of HR Banks Supporting Util 850709 Application for Withholding Documents,Including Quality Check Rept,Concern/ Allegation Followup & Quality Check Procedure Investigation Rept,Per 10CFR2.790.Related Correspondence ML20116N7771985-05-0202 May 1985 Affidavit of Ti Hawkins in Support of Applicant Suppl to Motion for Summary Disposition of Eddleman Contention 213 Re Emergency Planning.Certificate of Svc Encl ML20116D0091985-04-25025 April 1985 Affidavit of Jf Myers Describing Recent Change to Provisions for Official Transportation Assistance for Persons in Emergency Planning Zone Needing Assistance in Event of Plant Emergency.Related Correspondence ML20112K0061985-04-0505 April 1985 Supplemental Affidavit of RG Black on Eddleman Contention 213.Provisions for Alert & Notification of Persons on Harris Lake Obviate Measures Suggested by Contention ML20112K0131985-04-0505 April 1985 Supplemental Affidavit of MR Bassiouni on Eddleman Contention 213.Rept of Proposed Siren Configuration & One Oversize Map Encl.Aperture Card Available in PDR ML20100B1011985-03-22022 March 1985 Supplemental Affidavit of Eh Harris Re Rev of School Evaluation Procedure Which Would Reduce Number of Students Riding Buses & Use of Buses Kept on Property During School Hours.Certificate of Svc Encl.Related Correspondence ML20107M5111985-02-27027 February 1985 Affidavit of Ti Hawkins in Support of Motion for Summary Disposition of Eddleman Contention 30.Emergency Response Plan Provisions Fully Comply w/NUREG-0654 ML20107K0411985-02-26026 February 1985 Affidavit of Ti Hawkins in Support of Applicant Motion for Summary Disposition of Contention EPJ-4(c).Prof Qualifications Encl.Certificate of Svc Encl 1999-04-05
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217L8481999-10-25025 October 1999 NRC Staff First Supplemental Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Objects to Document Request as Being Overly Broad & Unduly Burdensome. with Certification of Svc ML20217H9661999-10-20020 October 1999 NRC Staff Second Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Listed Documents Requested to Be Produced.With Certificate of Svc. Related Correspondence ML20217E0881999-10-18018 October 1999 Order (Granting Discovery Extension Request).* Board of Commission of Orange County 991013 Motion for Extension of 991031 Discovery Deadline,Granted,In That Parties Shall Have Up to 991104.With Certificate of Svc.Served on 991018 ML20217F7711999-10-17017 October 1999 Corrected Notice of Deposition of SE Turner.* Orange County Gives Notice That on 991104 Deposition Upon Oral Exam of Turner Will Be Deposed with Respect to Contention TC-2. Related Correspondence ML20217F7681999-10-17017 October 1999 Orange County Third Set of Discovery Requests to NRC Staff.* Submits Third Set of Discovery Requests & Requests Order by Presiding Officer That Discovery Be Answered within 14 Days. with Certificate of Svc.Related Correspondence ML20217D6181999-10-14014 October 1999 Request for Entry Upon Harris Site.* Staff Hereby Requests That Applicant,Cp&L Permit Entry Into Shearon Harris Nuclear Plant,For Viewing & Insp of Plant Spent Fuel Pool Bldg. with Certificate of Svc.Related Correspondence ML20217E2611999-10-13013 October 1999 Orange County Second Suppl Response to Applicant First Set of Discovery Requests & First Suppl Response to NRC Staff First Set of Discovery Requests.* Clarifies That G Thompson Sole Witness.With Certificate of Svc.Related Correspondence ML20217E2581999-10-13013 October 1999 Orange County Motion for Extension of Discovery Deadline.* Orange County Requests Extension of 991031 Deadline for Concluding Discovery Proceeding.Extension Needed to Permit Dispositions of Two CP&L Witnesses.With Certificate of Svc ML20217E1461999-10-13013 October 1999 Request for Entry Upon Harris Site.* Entry Requested for Purpose of Inspecting SFP Bldg & Associated Piping.With Certificate of Svc.Related Correspondence ML20217D5561999-10-13013 October 1999 Applicant Second Set of Discovery Requests Directed to Board of Commissioners of Orange County.* Applicant Requests Answers to Listed Interrogatories & Requests for Admission. with Certificate of Svc.Related Correspondence ML20217D5761999-10-13013 October 1999 Applicant Third Supplement Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Provides Addl Responses to General Interrogatory 3.With Certificate of Svc.Related Correspondence ML20217D6201999-10-12012 October 1999 NRC Staff Response to Applicant First Set of Discovery Requests to NRC Staff.* Staff Will Respond to Applicant Specific Requests within 30 Days of Receipt of Applicant Requests.With Certificate of Svc.Related Correspondence ML20217D5661999-10-12012 October 1999 NRC Staff First Supplemental Response to Orange County First Set of Discovery Requests to NRC Staff.* Supplements Response by Naming C Gratton as Person Likely to Provide Affidavit.With Certificate of Svc.Related Correspondence ML20212M0271999-10-0707 October 1999 Notice (Opportunity to Make Oral or Written Limited Appearance Statements).* Board Will Entertain Oral Limited Appearance Statements Re CP&L 981223 Amend Request. with Certificate of Svc.Served on 991007 ML20212L1441999-10-0505 October 1999 NRC Staff Response to Orange County First Set of Discovery Requests to NRC Staff.* Staff Is Now Voluntarily Providing Responses to Orange County'S Request for Production of Documents.With Certificate of Svc.Related Correspondence ML20212J0801999-09-29029 September 1999 Orange County Second Set of Document Requests to NRC Staff.* Submits Second Set of Document Requests to NRC Pursuant to 10CFR2.744 & Board Memorandum & Order,Dtd 990729.With Certificate of Svc.Related Correspondence ML20212G0001999-09-24024 September 1999 Applicant First Set of Discovery Requests Directed to NRC Staff.* Requests Access to Documents Given to Board of Commissioners by Staff Pursuant to 990920 Discovery Request. with Certificate of Svc.Related Correspondence ML20212G0081999-09-24024 September 1999 Applicant First Suppl Response to Board of Commissioners of Orange County First Set of Discovery Requests.* Suppl Provides Addl Responses to General Interrogatories 2 & 3. with Certificate of Svc.Related Correspondence ML20212D7151999-09-20020 September 1999 Applicant Response to General Interrogatories & General Document Requests in NRC Staff First Set of Discovery Requests.* CP&L Filing Responses Per Staff Request within 14 Days....With Certificate of Svc.Related Correspondence ML20212D8521999-09-20020 September 1999 Orange County First Set of Discovery Requests to NRC Staff Including Request for Order Directing NRC Staff to Answer Certain Discovery Requests.* with Certificate of Svc. Related Correspondence ML20212C1231999-09-17017 September 1999 Orange County Responses to Applicant First Set of Document Production Request.* Orange County Has No Documents Responsive to Request.With Certificate of Svc.Related Correspondence ML20211N7481999-09-10010 September 1999 NRC Staff First Set of Discovery Requests Directed to Applicant Cp&L.* Staff Requests Applicant Produce All Documents Requested by & Provided to Bcoc. with Certificate of Svc.Related Correspondence ML20211N5021999-09-0808 September 1999 Orange County Objections & Responses to NRC Staff First Set of Discovery Requests.* County Objects to Questions to Extent That Staff Seek Discovery Beyond Scope of County Two Contentions.With Certificate of Svc.Related Correspondence ML20211M4201999-09-0707 September 1999 Applicant Response to Specific Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc.Related Correspondence ML20211M5001999-09-0303 September 1999 Orange County Supplemental Response to Applicant First Set of Interrogatories.* with Certificate of Svc.Related Correspondence ML20211H4931999-08-30030 August 1999 Orange County Objections to Applicant First Set of Discovery Requests & Response to Applicant First Set of Interrogatories.* Objects to First Set of Discovery Requests.With Certificate of Svc.Related Correspondence ML20211B7951999-08-23023 August 1999 NRC Staff First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* Staff Requests That Bcoc Produce All Documents Requested by Applicant. with Certificate of Svc.Related Correspondence ML20211B8361999-08-23023 August 1999 Applicant Response to General Interrogatories & General Document Requests in Board of Commissioners of Orange County First Set of Discovery Requests.* with Certificate of Svc. Related Correspondence ML20210T3531999-08-16016 August 1999 Applicant First Set of Discovery Requests Directed to Board of Commissioners of Orange County (Bcoc).* CP&L Requests That Bcoc Answer Listed General Interrogatories by 990830. with Certificate of Svc.Related Correspondence ML20210L9571999-08-0606 August 1999 Orange County First Set of Discovery Requests Directed to Applicant.* Interrogatories & Document Production Requests Cover All Info in Possession,Custody & Control of Cp&L.With Certificate of Svc.Related Correspondence ML20216E2041999-07-29029 July 1999 Memorandum & Order (Granting Request to Invoke 10CFR Part 2, Subpart K Procedures & Establishing Schedule).* Board Grants Carolina Power & Light Co 990721 Request to Proceed Under Subpart K.With Certificate of Svc.Served on 990730 ML20210B2271999-07-21021 July 1999 Applicant Request for Oral Argument to Invoke Subpart K Hybrid Hearing Procedures & Proposed Schedule.* Applicant Recommends Listed Schedule for Discovery & Subsequent Oral Argument.With Certificate of Svc ML20209G7371999-07-16016 July 1999 Notice of Hearing (License Amend Application to Expand Sf Pool Capacity).* Provides Notice of Hearing in Response to Commissioners of Orange County Request for Hearing Re CP&L Amend Application.With Certificate of Svc.Served on 990716 ML20209D1791999-07-12012 July 1999 Memorandum & Order (Ruling on Standing & Contentions).* Grants Petitioner 990212 Hearing Request Re Intervention Petition Challenging CP&L 981223 Request for Increase in Sf Storage Capacity.With Certificate of Svc.Served on 990712 ML20212J5831999-07-0101 July 1999 Notice of Appearance.* Informs That SL Uttal Will Enter Appearance in Proceeding Re Carolina Power & Light Co.Also Encl,Notice of Withdrawal for ML Zobler,Dtd 990701. with Certificate of Svc ML20196A8751999-06-22022 June 1999 Order (Corrections to 990513 Prehearing Conference Transcript).* Proposed Corrections to Transcript of Board 990513 Initial Prehearing Conference Submitted by Petitioner & Application.With Certificate of Svc.Served on 990622 ML20207D6991999-05-27027 May 1999 Orange County Proposed Corrections to Transcript of 990113 Prehearing Conference.* Orange County Submits Proposed Corrections to Transcript of Prehearing Conference of 990513.With Certificate of Svc ML20207D6651999-05-27027 May 1999 Applicant Proposed Corrections to Prehearing Conference Transcript.* ASLB Ordered That Any Participant Wishing to Propose Corrections to Transcript of 990513 Prehearing Conference Do So by 990527.With Certificate of Svc ML20207D6891999-05-27027 May 1999 Orange County Response to Applicant Proposed Rewording of Contention 3,regarding Quality Assurance.* County Intends to Renew Request for Admission of Aspect of Contention.With Certificate of Svc ML20206R8731999-05-20020 May 1999 Memorandum & Order (Transcript Corrections & Proposed Restatement of Contention 3).* Any Participant Wishing to Propose Corrections to Transcript of 990513,should Do So on or Before 990527.With Certificate of Svc.Served on 990520 ML20206R2411999-05-13013 May 1999 Transcript of 990513 Prehearing Conference in Chapel Hill,Nc Re Carolina Power & Light Co.Pp 1-176.Supporting Documentation Encl ML20206H9331999-05-11011 May 1999 Notice (Changing Location & Starting Time for Initial Prehearing Conference).* New Location for Conference, Southern Human Resources Ctr,Main Meeting Room,Chapel Hill, Nc.With Certificate of Svc.Served on 990511 ML20206G4051999-05-0505 May 1999 Applicant Answer to Petitioner Board of Commissioners of Orange County Contentions.* Requests That Technical Contentions in Section III & Environ Contentions in Section IV Not Be Admitted.With Certificate of Svc ML20206F9491999-05-0505 May 1999 NRC Staff Response to Orange County Supplemental Petition to Intervene.* None of Petitioner Proposed Contentions Meet Commission Requirements for Admissible Contention.Petitioner 990212 Request Should Be Denied.With Certificate of Svc ML20206A0851999-04-22022 April 1999 Erratum to Orange County Supplemental Petition to Intervene.* Citation to Vermont Yankee LBP-87-17,should Be Amended to Read Vermont Yankee Nuclear Power Co (Vermont Yankee Nuclear Power Station).With Certificate of Svc ML20205Q8121999-04-21021 April 1999 Order (Granting Motion to Relocate Prehearing Conference).* Initial Prehearing Conference Will Be Held in District Court of Orange County Courtroom,Chapel Hill,Nc on 990513 as Requested.With Certificate of Svc.Served on 990421 ML20196K8771999-04-0505 April 1999 Orange County Supplemental Petition to Intervene.* Informs That Orange County Contentions Should Be Admitted for Litigation in Proceeding ML20196K8861999-04-0505 April 1999 Declaration of Gordon Thompson.* Informs of Participation in Preparation of Orange County Contentions Re Proposed License Amend ML20205E3101999-04-0101 April 1999 Memorandum & Order (Protective Order).* Grants 990326 Motion of Petitioner for Approval of Proposed Protective Order to Govern Use & Dissemination of Proprietary or Other Protected Matls.With Certificate of Svc.Served on 990203 ML20196K9041999-03-31031 March 1999 Declaration of DA Lochbaum,Nuclear Safety Engineer Union of Concerned Scientists,Re Technical Issues & Safety Matters Involved in Harris Nuclear Plant License Amend for Sfs.* with Certificate of Svc 1999-09-08
[Table view] |
Text
\ ENCLOSURE 4 l 4 .
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of )
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CAROLINA POWER & LIGHT COMPANY
)
and NORTH CAROLINA EASTERN ) Docket No. 50-400 OL
- MUNICIPAL POWER AGENCY )
)
(Shearon Harris Nuclear Power )
Plant) )
AFFIDAVIT OF THOMAS W. BROMBACH County of Wake )
) ss.
State of North Carolina )
Thomas W. Brombach, being duly sworn according to law, de-poses and says as follows:
- 1. I am employed by Carolina Power & Light Company
("CP&L") at the Shearon Harris Nuclear Power Plant as a Project Specialist / Inservice Inspection. In this capacity I am respon-sible for non-destructive examination ("NDE") of Class 1, 2 and 3 components, piping and their supports to ensure applicable requirements of ASME Code Section XI and 10 C.F.R. S 50.55(a) are met. I testified before the Licensing Board on November 12,
. 1985. See " Applicants' Testimony of Harold R. Banks, Roland M.
Parsons, George L. Forehand and Thomas W. Brombach on Evaluation and Reinspection of Work Performed by Employees Implicated in 8609290402 860925 PDR ADOCK 05000400 0 PDR
\
6 Possible Drug Activity (CCNC Contention WB-3)," ff. Tr. 10,077.
My professional qualifications and experience are described in that testimony.
- 2. I have been actively engaged in NDE and inservice inspection programs at nuclear power plants since 1976. I have received extensive NDE training, including ultrasonic testing, visual inspection and eddy current testing / examination. While employed by Virginia Electric and Power Company from 1976 until 1982, I was certified as an NDE examiner. From 1978 to the present I have been employed in supervisory positions, overseeing NDE and inservice inspection activities. These du-ties formerly included direct supervision of Ms. Miriello. Be-ginning with my early training and experience in the United States Navy, I have seventeen years of hands-on experience in power plant operations, maintenance and testing.
- 3. The purpose of this affidavit is to address certain allegations raised in the Affidavit of Patty S. Miriello con-cerning quality assurance ("Miriello QA Affidavit"), dated July 28, 1986, which was submitted in support of " Motion to Re-open the Record Pursuant to 10 CFR 2.734 by Coalition for Alter-natives to Shearon Harris, Wells Eddleman and Conservation Coun-cil of North Carolina," dated September 15, 1986. I do not here attempt to address each of Ms. Miriello's allegations because l
l l
i ,
some of them are repetitive of those previously responded to in my affidavit dated August 6, 1986, which was filed in support of
" Applicants' Response to CASH's Show Cause Petition," dated August 15, 1986. I have reviewed the Miriello QA Affidavit and do not believe that it refutes the accuracy of my August 6, 1986 affidavit. In this affidavit, I shall demonstrate that Ms.
Miriello's QA allegations are without any foundation whatsoever.
- 4. Ms. Miriello acknowledges that Phil Temple and I offered her an opportunity to discuss any problems that she might want to discuss in her Quality Check exit interview of February, 1985. See Miriello QA Affidavit, 1 4, p. 2. I typi-cally speak with employees who are changing departments or who are leaving the site in order to ascertain whether they had any problems concerning their work or observations. If they do, I am interested in knowing what the problem was and whether they believe the problem has been resolved adequately. If they do not believe that the problem has been addressed and corrected, I ask them to describe the problem fully so that it may be inves-tigated and resolved. I offered Ms. Miriello this opportunity in advance of her exit interview, yet she declined my offer. By way of explanation, Ms. Miriello states only that: ... I felt that it would have been unwise for me to restate problems which I had already. brought,to their attention in the past." Miriello l
1 I
l l l
~
i h
4 QA Affidavit, 14, p. 2 (emphasis in original). Ms. Miriello further indicated that she did not believe that the Quality Check exit interview was of any value and she therefore did not mention that she had or knew of any problems with the plant at that time. Id. at Y 6, p. 3. Ms. Miriello thus refused two opportunities to express any concerns she may have had.
- 5. Before I address Ms. Miriello's concerns individually, it is noteworthy that Ms. Miriello's allegations are bound by a common theme. Each concern focuses on a problem of which Ms.
Miriello was once aware, but the subsequent resolution of which she may not have gained personal knowledge.
- 6. Ms. Miriello states: "In November 1984, [ Thomas Brombach] was told of Conam inspection personnel missing a row of steam generator tubes during the eddy current inspection."
While it is true that Conam initially failed to inspect a row of steam generator tubes, Conam identified and corrected the over-sight pursuant to procedures I imposed which required Conam to ensure that a record existed for every tube. Therefore, Conam did not report the missed row to CP&L, and there was no reason to do so. Had Conam failed to notice that it had missed a row of tubes, this would have been easily discovered and corrected upon CP&L's review of the eddy current tapes. Nonetheless, based on the information presented to me by Ms. Miriello, I
i i
instigated a review or the eddy current tapes of the steam gen-erator inspection to ensure that every tube had been inspected.
Each tube was properly inspected by Conam. In addition, CP&L later contracted with EPRI to conduct a 5% eddy current tape inspection review which verified the quality of Conam's inspec-tion.
- 7. Ms. Miriello alleges that the inspection reports on 10-20 welds are incorrect. See Miriello QA Affidavit, 1 4, p.2.
The basis for Ms. Miriello's allegation is her belief that these welds were inspected prior to being cut out and reworked, and that they were not reinspected subsequent to being so repaired.
See i.d. During the summer of 1984, with the initiation of the pre-service inspection program, it had become apparent that some welds were being reworked after pre-service inspection. I therefore asked Ms. Miriello to investigate that possibility.
It was then that Ms. Miriello discovered, as I had suspected, that a few welds had been reworked post inspection, without being reinspected. These welds were subsequently reinspected.
In order to correct this situation, CP&L and its contractors de-vised a new communications system consisting of daily morning meetings to ensure that all welds were reinspected after they ,
l had been reworked. In addition, all weld changes are docu-mented. These records are routed to Inservice Inspection l
("ISI") by controlled distribution, so that ISI is kept abreast of any welds that may require reinspection. CP&L is therefore 4
confident that its inservice inspection reports are complete, accurate and up-to-date.
5.
In conclusion, Ms. Miriello has identified past con-cerns which have already been identified and corrected, notwith-standing her lack of personal knowledge concerning these correc-tions. As such, Ms. Miriello's allegations are without factual basis.
) .
Thomas W.(Ercunba@
subscribed and sworn to before me this M ay of September, 1986 Notary Public Hy Cossnission Expi$es 8E 3f .
ENCLOSURE 5 Y V Cp&L Catchna Power & Light Company SHEARON HARRIS NUCLEAR PROJECT AU3141$26 P. O. Box 101 New Hill, North Carolina 27562 File Number: SHP/10-13510E Latter Number: Ho-860328 (0)
Dr. J. Nelson Crace NRC-469 United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)
Atlanta, Coorgia 30323 Dear Dr. Crace In reference to your letter of July 15, 1986, referring to RII:
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50-400/85-48-01, the attached is Carolina Power & Light Company's reply to the violation identified in Enclosure 1. -
It is considered that the corrective actions taken are satisfactory for resolution of the ites.
Thank you for your consideration in this matter.
Yours very truly, R. A. Watson Vice President Harris Nuclear Project RAW / css Attachment cci Messrs. C. Maxwell (NRC-SHNPP)
- 8. C. Buckley (NRC) l MEM/HO-8603280/ PACE 1/051
l v
Attachment to CP&L tter of Response to NEC Report RII: 50-400/85-48-01 Regereed Violation 10 CFR 50.554 paragraph (g) subparagraph (2) allows the licensee to use the American Society of Mechanical Engineer (ASME) Code Section XI, 1980 Edition with addenda through the winter 1981. Carolina Power and Light Company's Inservice Inspection Program delineated in Procedure Number ISI-201 Revision I, the ASME Code, 1980 Edition, with addenda through winter 1981.
Contrary to the above, Nuclear Energy Service, Inc. (NES) Inservice Inspection Procedure IST-501 (Rev. 1) and 157-401 (Rev. 1) were written to the ASME Code, 1980 Edition with addenda through winter 1982.
This is a Severity Level V violation (Supplement II).
Denial or Admission and Reason for the Violation:
The violation is correct as stated.
The voluntary upgrade to the winter 1982 addenda of the ASME Section XI Code, in Procedures IST-401 (Rev. 1) and IST-501 (Rev. 1), was done in the interest of keeping the SENPP ISI program up to date with current ASME code requirements. Notification to the NRC of CP&L's position to utilize the more stringent requirements of the winter 1982 addenda in the referenced NDE procedures, was not considered to be necessary by the personnel involved. -
Corrective Steps Takaa and Results Achieved:
A letter stating CP&L's position to utilise the winter 1982 addenda was submitted to the NRC (NER) on March 13, 1984 (Letter No. NLS-86-069). As of this date, no response has been received back from the NRC. 15I-201 is being revised to invoke 1980 Edition with addenda through winter 1982 for nondestructive testing and acceptance criteria.
coerective Steps Taken to Avoid Further Woncompliancet !
ISI Personnel (Technical Support Unit) have been reinstructed in the requirements of 10CPR50.55a(s), to provide written notification to the NRC (MIR) when changes in ASME code commitments in the SHNPP ISI program are required.
Date When Full Compliance Was Achieved It is projected that a response indicating acceptance of CP&L's position will be received from the NRC (NRR) by September 15, 1986. Revision to ISI-201 is projected to be approved by August 22, 1986.
I Reinstruction of ISI personnel was accomplished on August 8, 1986.
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MEM/HO-8603280/ PACE 2/051
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ENCLOSURE 6
. V V C9&L Carolina Power & Light Compariy SHEARON HARRIS NUCLEAR PROJECT P. O. Box 101 AN 4 G86 New Hill, North Carolina 27562 File Number: SHF/10-13510E Letter Number HO-860331 (0)
Dr. J. Nelson Grace NRC-470 United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)
Atlanta, Georgia 30323 Dese Dr. Grace:
In reference to your letter of July 15, 1986, referring to RII 50-400/85-48-03, the attached is Carolina Power & Light Company's reply to the violation identified in Enclosure 1. _
It is considered that the corrective actions tchan are satisfactory for resolution of the itam.
Thank you for your consideration in this matter.
Yours very truly, i
R. A. Watson Vice President Harris Wuclear Project RAN/iae Attachtent
~
ec: Messrs. G. Maxwell (NRC-SHNPP)
B. C. Buckley (NRC)
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MEM/H0-8603310/ PACE 1/051 l
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Attachment to CP&L Letter of Response to NRC Report RIIS 50-400/85-48-03 Reported Violation 10 CPR 50, Appendix B, Criterion V, requires that activities ,
affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these j instructions procedures or drawings. NES Preservice and Inservice I Data Control Procedure IST-101 Rev. 1, Paragraph 5.2.E. requires that corrections to data reports are to be completed by a single line drawn through the incorrect entry, initialed, and dated by the responsible individual when the correction is made.
Contrary to the above, on December 2-6, 1985, examination data sheets were observed where the NES Wondestructive Examination (NDE) Lead Examiner, had written " rewrite" on initial examination data sheets that had been signed by an NDE examiner and given a i
- ontrol number. In some instances, technical entries of evaluations were changed on the rewritten data sheets.
This is a Severity Level V violation (Supplement II).
Damial or Adel_sion s and Reason for the Violation:
The violation is admitted as stated.
The reason for the violation can be attributed to misinterpretation of procs. dural requirements by the 151 personnel involved. The subject rewrites of data sheets were performed to correct excessive errors as required to create a clear and
' accurate final record. The involved personnel interpreted paragraph 5.2 of IST-101 to allow rewrite of data sheets during the initial review, when in fact paragraph 5.2.C only allowed rewrites prior to entering the review cycle.
Corrective Stsee Taken and Results Aehleved:
The rewritten data which was maintained in a segregate file has been reviewed against the final Weld Inspection Data Packages and incorporated with each file. The differences between these records have been reviewed and the final package reflects the baseline condition of the welds. The corrected data sheets haveIn been reviewed and stand as the final QA document for record.
the future process data sheets will be corrected pursuant to procedure 15T-101, paragraph 5.2.E.
MEM/H0-8603310/PAGE 2/0S1
Corrective Steps Ta E to Avoid Further Ecetempliance:
Applicable personnel have been instructed in the proper use of CP&L Procedure IST-101 and the correct means by which revisions to inspection data can be made pursuant to paragraph 5.2.C 5.2.E, and $.2.0 of IST-101.
Date When Full Compliance Was Achieved I
Full compliance was achieved on February 1, 1986. 1 NEM/H0-8603310/ PACE 3/051