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AFIDAVIT OF SAM W. CIOW

COUUT OF iWELTOK ) us:

STATE OF TOElKSSEK )

SAM[y w. CIO)E, being duly sworn, deposes and says:

I. Mly name is samy W. Crows. I am an employee of the Tennessee

Valley Authority (TVA). Prior to joining TVA in February 1987, I was an

employee of Stone and Webster Engineering Corporation (SUEC). I have

approximately 15 years of nuclear industry experience. Attached to this

affidavit as Exhibit A Is my resume.

2. The purpose of this affidavit is to describe the technical

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

participated at the Watts Bar site in early 1986. 1 was not interviewed

by the MEC on this subject.

3. In January, 1986, 1 spent eight working days at the Watts Bar

site, along with six other experienced SWEC employees, conducting a

review to evaluate the validity of 11 so-called "perceptions" that had

been formed by TVA's Euclear Safety Review Staff (MRS). The members of

our group, under the direction of Craig Lundin, had significant

experience in the particular areas of nuclear plant activity that the

VSRS had challenged.

4. Our group spent a short but intensive period of time at the

Watts Bar sit* conducting a review to determine whether the information

that was provided by the USRS staff for its perceptions was valid. In

conjunction with our effort to assess the accuracy of the perceptions, we

reviewed and assessed the quality of the draft TVA staff responses to the

ISRS perceptions.

5. Our group worked both collectively and individually. I

reviewed documentation, some of which was obtained from the NSES staff; I

interviewed TVA engineers and quality control staff; I observed

activities in the plant. At daily exit meetings with Mr. Lundin and

throuShout the day, the members of the group discussed the facts that we

were finding. In some Instances, I Interfaced directly with the TV& line

engineers. I passed on observations and comments about the responses to

Mr. Lundin. 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 coumanication with

each other. Although our effort was not formalized, the 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 was 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 inforattion we had gathered with Hr. Lundin, and at the end of the

review process, we participated in a final eetins with Mr. Lundin to

discuss our work.

Sammy rows

Subscr g V and sworn to before me

this day of ovember, 1968.

My Cosmission expires: (<

Manager, Quality Control Group

Samy W. Crowe

I STITUTION:

DEGREES

DATE

EXPERIENCE (DATES, POSITION, EMPLOYERS):

February 1987 - present

April 1973 - February 1987

April 1986 - February 1987

January 1981 - April 1986

December 1984 - April 1985

October 1979 - December 1980

October 1977 - October 1979

December 1975 - October 1977

July 1975 - December 1975

April 1975 - July 1975

January 1975 - April 1975

January 1974 - December 1974

April 1973 - December 1973

- TENNESSEE VALLEY AUTHORITY Assistant to the Director, DIQA, Sequoyah

- STOVE & WEBSTER ENGINEERING CORP.

- Restart Task Force Member for TVA at Browns Ferry.

- Assistant Superintendent Field Quality Control, Nine Mile Point 2. Lycoming, New York

- Lead Piping Engineer, Braidwood Construction Assessment Program, Braidwood Power Station, Braidwood, Illinois (temporary assignment)

- QA Engineer, River Bend. St. Francisville, Louisiana

- Senior FQC Engineer, Shoreham Power Station, Wading River, New York

- FQC Engineer, Shoreham Power Station, Wading River, New York

- FQC Engineer, Millstone III, Waterford, Connecticut

- FQC Engineer, Haddan Neck, Haddan Neck, Connecticut

- FQC Engineer, Beaver Valley I, Shippingport, Pennsylvania

- Senior QC Inspector, Beaver Valley 1, Shippingport, Pennsylvania

- FQC Inspector, Beaver Valley I, Shippingport. Pennsylvania

CUMLATIVE WORK EXPERIENCE

Nuclear Quality Assurance - 14 years

Welder - 6 years

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QC Engineer Supervisor in charge of pi.piq erections 1 75 4 7 B v al and all weldirq activities; welder quali

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ENGINEERING REGISTRATION

STATUS "DS LIC918iU RUNO51$ gIg gZAMiNATION liSCIPLi|

MEURms.'p IN PROFESSIONAL SOCIETIES

Amurca Society of Macdanic1 ErqirNW5 - AsWociate ?bre

PUBLICATIONS

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Lycoling, NY

Piping Discipline Lead Eineer

Station Drai&xod, n

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o responsible for activities of receiving, electriCal, civil, Inut zw*aticn and calibratio lab inspectors as related to job ; perzuwr - and att~nanoe.

ksj, mble f= the electrical I pipig and welding and the mdmical (incly pipe suports and ueauipwit) disciplines. .-bilities includW s and tedmical mistant to the Field Qui~ty control Enguvrs and other parsounel assiged to ec discipline.

Paspon ibl to the Project O Mnager for the ASM In progrm oaliazxce and i ~e~atio by site dapr! --- ts and oraization. ResponsAhiliti also incld assuranc that venors and/or sulierso mply and furnish equiptt/mterials in acordare with specifications, e, etc. Coordinat client interfac and activities with site and/or vendor.. esolve proble areas that are identified by the site and/or client. Identify and resolve areas that cld result in probl. for vendors, site and/or client.

Pasponsible to the Superintandwit of Field Quality Control for organizing, planning and directing the activities of Field Quality COtrol p~ersonnel. Ensure that Quality ontrol personl are atly trained, poperly interpret and use seicaosdrwsingu ode and Quality Assurance poures. Provide reP- neo solutions with

u Quality Control and Design qi1ner . Coordinate with ContztI suevision and ~iE rz to dispose of problemw -- mtered in the Yklio ase. Act as the Sr. Site an tative for Quality Control in the absence of the -perin ent of Quality Control. 3YAplaemt omany polcy against discrimination and of affirmative action.

Rosponsible for the deelp ant of inspection and sanpling plans for the piping em evaluation program (included pipin, supports, wlds, a wip restraints, etc.). Perfod review and evaluation of inspection results. Prepared dwmnttin pacages and codted pre-ealuati analysis for AE review of &hginsrin calculatns and conducted poet-evaluation iupawt asseswm t of their revis. Tompory Assigrant.

ConiuWaz e of NNf2 duties upon return fru teoporary sag, w I at &aidiood.

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