ML20053A826

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Forwards Testimony on Contention 5 & Response to ASLB Question 1
ML20053A826
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 05/24/1982
From: Reynolds N
DEBEVOISE & LIBERMAN
To: Cole R, Mccollom K, Mark Miller
Atomic Safety and Licensing Board Panel
Shared Package
ML20053A827 List:
References
NUDOCS 8205270325
Download: ML20053A826 (2)


Text

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LAW OFrtCES Or DEBEVOISE & LIBERMAN 1200 SEVENTEENTH STREET,N.W

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WASHINGTON. D. C. 2OO36 T ELEPHON E QO2) S 57-9800 5

May 24, 1982 Marshall E. Miller, Esq.

Dr. Kenneth A. McCollom Chairman, Atomic Safety and Dean, Division of Engineering, Licensing Board Architecture and Technology U.S. Nuclear Regulatory Oklahoma State University Commission Stillwater, Oklahoma 74074 Washington, D.C.

20555 Dr. Richard Cole Member, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Re:

Texas Utilities Generating Company, et al.

(Comanche Peak Steam Electric Station, Units 1 and 2), Docket Nos. 50-445 and 50-446

'/

Gentlemen:

Transmitted herewith pursuant to the Board's Revised Schedule of March 25, 1982, is Applicants' written direct testimony on Contention 5 and Applicants' response to Board Question 1, all of which Applicants intend to present at the hearings scheduled to commence on June 7, 1982.

With regard to Contention 5 (QA/QC Program for Comanche Peak Construction),

Applicants transmit herewith the prepared testimony of (1)

David N.

Chapman, Manager of Quality Assurance for TUGCO; (2)

Antonio Vega, Quality Assurance Services Supervisor for TUGCO; (3) Susan L.

Spencer, TUGCO Quality Assurance Auditor; (4)

Ray J. Vurpillat, Brown & Root Power Group Quality Assurance Manager, and, (5) Roger F.

Reedy, of Reedy, Herbert, Gibbons &

Associates.

Attached to this testimony are documents which Applicants intend to present as evidence at the hearings, and statements of educational and professional qualifications of Ms. Spencer and Messrs. Vurpillat and Reedy.

Statements of qualifications of Messrs. Chapman and Vega were received into evidence at Transcript pp. 509, 511.

3 950 3hg 8205270

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.. Applicants intend to call as witnesses Mr. Chapman, Mr.

Vega, Ms. Spencer, and Mr. Bob C. Scott, Principal Quality Assurance Specialist, Ebasco Services, Inc., assigned to Comanche Peak, as a panel to address the overall QA pro-gram for construction at Comanche Peak, the OA/QC program for all non-ASME Code work at Comanche Peak, and the reso-lution of matters addressed in NRC Inspection & Enforcement Reports.

A statement of qualifications of Mr. Scott also is transmitted herewith.

Applicants also intend to call Messrs. Chapman, Vega, Vurpillat, Reedy and Scott as a panel to address the QA pro-gram for ASME Code work at Comanche Peak and the ASME Sur-vey and Resurvey of the Brown & Root QA program for ASME Code work.

With regard to Board Question 1 (hydrogen control),

Applicants transmit herewith the prepared testimony and state-ment of qualifications of Mr. Fred W.

Madden, Lead Nuclear Engineer, TUSI.

Applicants intend to call Mr. Madden and Kenneth Rubin of Westin'ghouse Electric ' Corporation to respond to Board Question 1.

A statement of qualifications for Mr.

Rubin is transmitted. herewith.'

In addition, with regard to Board Question 3 (ATWS),

Applicants have reviewed the Affidavits presented by the NRC Staff on this matter and believe those Affidavits adequately j

respond to the Board Question.

Nonetheless, Applicants will present Mr. David H. Wade, Senior Licensing Engineer, TUSI, and Mr. MichaelaJ. Hitchler of Westinghouse Electric Corporation i

to respond to Board questioning on ATWS at the hearing.

l Statements of qualifications of Messrs. Wade and Hitchler also are transmitted herewith. '

1 Applicants will not present these individuals should the Board determine that evidence on these Board Questions need not be taken in view of the written information already submitted by the Applicants and Staff.

If the Board is satis-i fied with those written submittals, Applicants urge the Board i

to advise the parties as soon as possible so that further preparation for hearing on Board Questio s 1 and 3 will not be expended unnecessarily.

Respec y s bmitted,

)i l

Nichole S

Reynolds Counsel fr Applicants Enclosures cc:

Service List

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