AFFIDAVIT OF RICHARD A. WURY

City of Glen Rose ) as:

State of Texas )

RICHARD A. BERRY, being duly sworn, deposes and says:

1. My name is Richard A. Berry. I an an employee of

Stone and V'ebster Engineering Corporation (SWEC). I

presently hAve approximately 17 years of nuclear industry

experience. Axtached to this affidavit as Exhibit A is my

resume.

2. The purpose of this affidavit is to describe the

review of the NSRS perceptions in which I, and others in my

group, participated at TVA's Watts Bar site in early 1986.

was not interviewed by the NRC on this subject.

3. In January, 1986, I spent several working days at

the Watts Bar site, along with six other experienced SWEC

employees, conducting a review to evaluate the validity of

eleven so-called "perceptions" that had been formed by TVA's

Nuclear Safety Review Staff (NSRS). The members of our

group, under the direction of Mr. Craig Lundin, had

extensive experience in the particular areas of nuclear plant

activity that were covered by the NSRS perceptions. My own

experience is in the engineering area, where I have worked on

8811230375 m 'if:

the design and layout of piping systems, including management

of the pip* support and pipe stress analysis efforts at other

projects.

4. Our group spent a short, but intensive, period of

time at the Watts Bar site conducting an investigation to

determine whether the back-up information provided by the

NSRS supported its perceptions.

5. Our group worked both collectively and

individually. I reviewed documentation, I interviewed TVA

engineers and quality control staff, and I observed

activities at the plant. At daily exit meetings with Mr.

Lundin and throughout the day, the members of the group

discussed the facts that we were finding. There was some

overlap in our activities, as well, which was a useful source

of information and resulted in substantial discussion of the

issues. Throughout our review, we worked in close

communication with each other. Although our effort was not

formalized, this lack of formality in no way affected our

attitude, our approach, or the results of our effort.

6. We were given a free hand to investigate whatever

we felt was necessary, and there wav absolutely no effort by

Mr. Lundin or anyone else to influence the outcome of our

effort.

7. Our group did not produce a report. Instead, each

day we shared the information we had gathered with Craig

-2-

Lundin, and at the end of the review process, we participated

in a final matinq with Mr. Lundin to discuss our work.

Richard A. Berrt

Subscri bd and sworn to before so this/= day of November, 1988.

Notary Public

My Commission Expires: -- L-.

-3-

44L4.'t J,~y v =18'7

December 1986

BERRY, RICHARD A. ASSISTANT PROJECT ENGINEER ENGINEERING GENERAL

DIVISION

EDUCATION

Lowell Technological Institute - Bachelor of Science, Nuclear Engineering - 1968

Northeastern University - Master of Science, Mechanical Engineering - 1975

LICENSES AND REGISTRATIONS

Professional Engineer - Massachusetts Professional Engineer - New Jersey

EXPERIENCE SUM MARY

Mr. Berry joined Stone & Webster Engineering Corporation in October 1971 and was assigned to work on the Beaver Valley Power Station - Unit 1 for Duquesne Light Company where he participated in developing responses to questions on the Unit 1 Safety Analysis Report and assisted in system design. In January 1972, he was assigned to work on Beaver Valley Power Station - Unit 2 where he was responsible for engineeting various systems and participated in the preparation of the PSAR as well as in licensing hearings. In October 1974, he was assigned as Principal Nuclear Engineer for the project; and in December 1977, he las appointed Lead'Power Engineer. In July 1979, he was transferred to the Power Division's Systems Standards Group where he served as Lead Engineer for the development of fluid system descriptions, P&IDs, and technical staadards in the nuclear discipline. In December 1979, he was transferred to Stone & Webster's Cherry Hill Operations Center and assigned as Assistant Project Engineer on River Bead Station - Unit I for Gulf States Utilities Company, where he is currently assigned.

Prior to joining Stone & Webster Engineering Corporation, he had operational experience in the U.S. Navy on a shipboard conventional power plant. He was assigned as Main Propulsion Assistant for 2 years in charge of the ship's 600 psi steam propulsion plant. Also during his tour in the Navy, he served I year as navigptor.

PROFESSIONAL AFFILIATIONS

Working Group ANS 56.2, Containment Isolation Provisions for Fluid Systems - Member (former chairman)

U.S. Naval Reserve - Commander

DETAILED EXPERIENCE RECORD

BERRY, RICHARD A. 05388

STONE & WEBSTER ENGINEERING CORPORATION, CHERRY HILL, NEW JERSEY

(Dec 1979 - Present)

Appointments:

Assistant Project Engineer (Plant Services) - June 1985 Assistant Project Engineer - Dec 1979 Lead Engineer - July 1979 Senior Power Engineer - June 1978 Lead Power Engineer - Dec 1977 Power Engineer - April 1975 Principal Nuclear Engineer - Oct 1974 Engineer - Oct 1971

River Btnd Station - Unit 1, Gulf States Utilities Company (June 1985Present)

As ASSISTANT PROJECT ENGINEER in charge of headquarters engineering support, responsible for final licensing support for GSU's operating license, technical support during preoperational and power ascension testing, and engineering and licensing services, during commercial operation.

Salem Nuclear Generating Station, Public Service Electric and Gas Company (June 1986 - Aug 1986, part-time)

At PSE&G's request, performed an independent evaluation of the design drawing update program being used on Salem Units 1 and 2 and led a SWEC team in performing this task, which entailed a detailed assessm 'eat of approximately 90 different drawing types used in PSE&G's configuration control program.

Watts Bar Nuclear Station, Tennessee Valley Authority (Jan 1986)

As SENIOR ENGINEERING REPRESENTATIVE on a SWEC Engineering and Quality Assurance Group, asked to perform an independent review of TVA's responses to quality concerns identified at Watts Bar. Review focused on design control conformance with the requirements ibf IOCFR50, Appendix B.

River Bend Station - Unit 1, Gulf States Utilities Company (Dec 1979 - June 1985)

As ASSISTANT PROJECT ENGINEER, responsible for-engineering management of over 300 personnel in the Structural, Geotechziical, and Engineering Mechanics disciplines on project.

Directly responsible for the procedure development and management of the piping, structural, and duct support verification programs. These programs, which were tailored for Lhe River Bend project, provided detailed inspection attributes and checklists to assure consistent, thorough traceability between the inspected installations and the corresponding

7 RAe 0

drawings, specifications, and analysis. He developed management systems

for tracking progress and guided the day-to-day problem resolution and

group coordination activities necessary to bring about the successful completion of these programs.

Previously, responsibilities included coordination of all power, hydrau

lic, advisory operations, and environmental engineering and design ef

forts. Also responsible for the review of input to estimates, allocation

of manpower, review and approval of specifications, specification adden

da, purchase requisitions, outgoing correspondence, drawings, sketches, and various technical reports.

STONE & WEBSTER ENGINEMRING CORPORATION, BOSTON, MASSACHUSETT~S (Oct 1971

Dec 1979)

As LEAD ENGINEER (July 1979 - Dec 1979), directed the efforts of the Sys

tems Standards Group in the production of standard system descriptions, P&IDs, evaluation and resolution of problem reports, and development of

technical guidelines for SWEC Power Division.

Beaver Valley Power Station - Units 1 and 2, Duquesne Light Company

(Oct 1971 - Dec 1979)

As LEAD POWER ENGINEER (Dec 1977 - Dec 1979), responsibilities included

overall supervision and coordination of the project's power engineering

and design groups, comprising a total of approximately 100 personnel.

-Appointed Senior Power Engineer in June 1978.

As PRINCIPAL NUCLEAR ENGINEER (Oct 1974), responsibilities included re

view, coordination, &ad supervision of work performed by Engineers as

signed to the project's Nuclear Group. Appointed Power Engineer in

April 1975.

Was responsible for various systems, including the fuel pool cooling and

purification, recirculation spray, primary grade water, boron recovery,

sample, chemical and volume control, liquid waste, low-head safety injec

tion, containment vacuum and leakage monitoring, post-DBA hydrogen -con

trol, and steam generator blowoown systems. Also responsible for machine

location drawings for the fuel building, decontamination building, prima

ry auxiliary building, safeguards building, reactor containment, and yard

and tunnel piping.I

Participated in writing the Beaver Valley Power Station - Unit 2 Prelimi

nary Safety Analysis Report and later testified in licensing hearing

which resulted in a construction permit for Unit 2. Also prepared speci

fications for various system components, including pumps, degasifiers,

heat exchangers, and evaporators.

As ENGINEER, worked on the Safety Analysis Report and on system design.

U.S. NAVY (Oct 1968 - Oct 1971)

As LIEUTENANT, Junior Grade (Oct 1970 - Oct 1971),.served as ship's navigator on the U.S.S. BUCK (DD-761). Also served as H and B DIVISION OFFICER and HAIN PROPULSION ASSISTANT (Oct 1968 - Oct 1970).