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Category:AFFIDAVITS
MONTHYEARML20080P0481983-09-26026 September 1983 Affidavit of T Devine Summarizing 830919 Discussion W/ C Weaver Re Summary of Interview in Torrey Pines Rept. Weaver Seriously Challenges Completeness of Interview Summary ML20080P0291983-09-26026 September 1983 Affidavit of D Jones for Govt Accountability Project Protesting Torrey Pines Rept Chapter on Cases Studies.Ref to Author Interviews Incomplete & Thus Inaccurate.Analysis of Whistleblower Missed Real Problem of Lack of Freedom ML20080P0671983-09-24024 September 1983 Affidavit of R Reiter for Govt Accountability Project Expressing Dissatisfaction of W/Summarized Interview in Torrey Pines Rept ML20058E4831982-07-26026 July 1982 Affidavit of Anonymous Individual Re Warnings to Mgt of Severe Problems in Welding Program.Certificate of Svc Encl ML20058E4801982-05-13013 May 1982 Affidavit of Rl Reiter Re Direct Knowledge of Widespread Inaccurate Blueprints,Drawings & Records for Traceability of Matls in Plant Design ML20039G2111982-01-0808 January 1982 Affidavit by ZAC-ZACK Counsel on Absence of Written Direct Testimony Statement for Witnesses C Mcintosh,J Fite & D Seiger.Witnesses Will Require Subpoenas & Oral Direct Exam. W/Certificate of Svc.Related Correspondence ML20039D2381981-08-0707 August 1981 Affidavit Re Browns Ferry Fire.Similar Fire Could Occur to All Control Cables,When Stacked One on Top of Another ML19254E5851979-09-28028 September 1979 Affidavit Re Veracity of Portland Cement Association Const Technology Labs Fire Protective Cable Tray Fire Test Rept, June 1979 ML19254E5841979-09-28028 September 1979 Affidavit Re Veracity of Portland Cement Association Const Technology Labs Fire Protective Cable Tray Fire Test Rept, June 1979 ML19256E2641979-09-21021 September 1979 Affidavit Attesting That June 1979 Fire Protective Cable Tray Fire Test Rept Prepared by Ms Abrams.Cable Circuit Continuity & Continuous Svc Temp Maintained Adequately ML19256E2601979-09-21021 September 1979 Affidavit Attesting That Contention 17 Lacks Merit. Development of Fire Protection Criteria Re Electrical Cables & Cable Trays Described in Fire Protection Evaluation Rept Which Proves Adequacy of Safety Measures.Resume Encl ML19210E1321979-05-21021 May 1979 Affidavit Re Metal Shavings in Control Rod Blades.Cites Incomplete Cleaning of Blades & Unwarranted Passing Insp ML19254F9681979-05-21021 May 1979 Affidavit Attesting That After Working as Millwright General Foreman at Facility During Oct 1978-Feb 1979,acquired Knowledge of Facts Re Clean Metal Shavings in Control Rods. Chips Still Remain in Blades ML19254E4541979-05-21021 May 1979 Affidavit of GL Reynolds on 790521 1983-09-26
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20056E5101993-08-11011 August 1993 Comment Opposing Proposed Rule 10CFR20 Re Radiological Criteria for Decommissioning ML20059P0531990-10-15015 October 1990 Comment Opposing Proposed Rules 10CFR2,50 & 54 Re Nuclear Power Plant License Renewal IR 05000358/19820101986-06-24024 June 1986 Applicant Exhibit A-49,consisting of Forwarding Partially Withheld Safety Insp Rept 50-358/82-10 on 820607- 0818 (Ref 10CFR2.790) & Notice of Violation ML20129A3751985-05-16016 May 1985 Order Revoking CPPR-88,based on Util 840127 Plan to Convert Facility to Coal Fuel ML20133N3621985-03-14014 March 1985 Unexecuted Amend 3 Terminating Indemnity Agreement B-85 ML20094C3571984-08-0202 August 1984 Transmittal of Info Re Util 840320 Motion for Withdrawal of OL Application.Fuel Removed from Site,Steam Supply Sys Modified & CRD Mechanisms Removed.Certificate of Svc Encl ML20087H7881984-03-20020 March 1984 Motion Requesting Issuance of Order Authorizing Withdrawal of Application.Plant Will Be Used as Part of New Fossil fuel-fired Electric Generating Plant.Certificate of Svc Encl ML20087N2281984-03-0101 March 1984 Endorsement 25 to Nelia Policy NF-249 ML20079F8181984-01-16016 January 1984 Response Opposing Miami Valley Power Project 831231 Proposed Issues & Support for Contentions Re Qa.Issues Not Specific or Litigable.Certificate of Svc Encl ML20083J5321983-12-31031 December 1983 Proposed Issues & Prospective Witnesses Supporting Miami Valley Power Project Proposed Contentions Re Qa,Character & Competence.Certificate of Svc Encl ML20079H6901983-12-14014 December 1983 Petition Per 10CFR2.206 to Defer Judgment or Decision on Proposed Course of Action for Completion of Facility Until Suppl Created for Record of J Keppler 831215 Briefing.W/O Encls ML20082P8501983-12-0606 December 1983 Response Opposing City of Mentor 831115 Memorandum in Support of NRC 831031 Motion to Defer Rulings on Miami Valley Power Project Motion to Reopen Record.Motion W/O Merit.Certificate of Svc Encl.Related Correspondence ML20082M5791983-12-0202 December 1983 Response Opposing Applicant 831115 Answer to NRC 831031 Motion to Defer Ruling on Petition for Reconsideration & Motion for Leave to File Addl Evidence Prior to 831215 Conference of Counsel.Certificate of Svc Encl ML20082L0991983-11-30030 November 1983 Memorandum in Support of City of Mentor Motion to Further Defer Rulings Until Completion of Investigation Into Matl False Statements by NRC & Applicants.Certificate of Svc Encl ML20082D6991983-11-15015 November 1983 Memorandum in Support of NRC Motion to Defer Rulings on Miami Valley Power Project Motion to Reopen & City of Mentor Motion to Further Defer Rulings Until Completion of Investigation.Certificate of Svc Encl ML20081M7951983-11-15015 November 1983 Answer Opposing NRC Motion to Defer Rulings on Miami Valley Power Project (MVPP) 831003 Motion to Reopen Record.Decision Should Not Be Deferred to Await Completion of Investigation. Certificate of Svc Encl ML20085K7841983-10-18018 October 1983 Answer Opposing Miami Valley Power Project 831003 Petition for Reconsideration of ASLB 830915 Memorandum & Order Denying Project Motion to Reopen Record to Admit Eight Late Filed Contentions on Qa.Certificate of Svc Encl ML20078K5621983-10-13013 October 1983 Memorandum in Support of Miami Valley Power Project (MVPP) Petition for Reconsideration of ASLB 830915 Order.Mvpp Urges ASLB to Address Stds for Reopening Record.Issues Should Be Included to Ensure Complete Record.Certificate of Svc Encl ML20078F9641983-10-0606 October 1983 Notification to Commission of Miami Valley Power Project Misrepresentation in 831003 Motion for Reconsideration of ASLB 830915 Order.No Util Counsel Communicated W/Govt Accountability Project.Certificate of Svc Encl ML20078F8891983-10-0606 October 1983 Notice of Jh Laverty Employment W/Conner & Wetterhahn,Pc. Laverty Will Not Participate in Matters Leading to OL Issuance Due to Previous Employment W/Commissioner Roberts. Certificate of Svc Encl ML20078F8751983-10-0606 October 1983 Notice of Jh Laverty Employment W/Conner & Wetterhahn,Pc. Previous Employment W/Commissioner Roberts Eliminates Any Contribution to Zimmer Case ML20080P0771983-10-0303 October 1983 Motion for Extension to File Appeal Until 10 Days After Svc of ASLB Decision on Miami Valley Power Project Petition for Reconsideration.Certificate of Svc Encl ML20080P0141983-10-0303 October 1983 Petition for Reconsideration of ASLB 830915 Order Denying Miami Valley Power Project Motion to Reopen Record for Admission of Eight Proposed Contentions.Addl Info Provided Since Original Decision.Certificate of Svc Encl ML20080P0481983-09-26026 September 1983 Affidavit of T Devine Summarizing 830919 Discussion W/ C Weaver Re Summary of Interview in Torrey Pines Rept. Weaver Seriously Challenges Completeness of Interview Summary ML20080P0291983-09-26026 September 1983 Affidavit of D Jones for Govt Accountability Project Protesting Torrey Pines Rept Chapter on Cases Studies.Ref to Author Interviews Incomplete & Thus Inaccurate.Analysis of Whistleblower Missed Real Problem of Lack of Freedom ML20080P0671983-09-24024 September 1983 Affidavit of R Reiter for Govt Accountability Project Expressing Dissatisfaction of W/Summarized Interview in Torrey Pines Rept ML20080F2451983-09-13013 September 1983 Memorandum Supporting Miami Valley Power Project 830603 Motion to Reopen Record for Admission of Eight Contentions. Torrey Pines Mgt Review & NRC Repts Confirm Project Substantially Correct on Qa.Certificate of Svc Encl ML20080E6921983-09-12012 September 1983 Answer Opposing Miami Valley Power Project 830826 Motion for Leave to Submit New Documents & for ASLB Review of Pending Investigations.Motion Unjustified Attempt to Bend Rules on Late Contentions.W/Certificate of Svc ML20080D2791983-08-26026 August 1983 Motion for Leave to Submit New Evidence in Support of 830603 Proposed Contentions & for ASLB Review of Significant Pending Investigations.Certificate of Svc Encl ML20080C7171983-08-25025 August 1983 Answer Opposing Miami Valley Power Project 830811 Motion for Leave to File Reply Brief to Util & NRC Answers to Project 830712 Motion to Compel Discovery.Project Had Opportunity to Brief Issue in Original Motion.Certificate of Svc Encl ML20076A6451983-08-15015 August 1983 Notice of Substitution of Counsel for Amicus Curiae Brief & Appearance Before Aslb.Certificate of Svc Encl ML20024E5591983-08-11011 August 1983 Motion for Leave to File Reply Brief to Applicant & NRC 830803 & 01,respectively,answers Opposing Miami Valley Power Project Motion to Compel Discovery.Assertion of Boundary on Discovery Should Be Briefed.Certificate of Svc Encl ML20024E3941983-08-0505 August 1983 Motion for Leave to File Reply Brief & for Clarification of Responsibility to Duplicate Previous Analysis & Evidentiary Submissions.Util Challenge Frivolous,Heavy on Chutzpah & Deficient on Common Sense.Certificate of Svc Encl ML20077L5161983-08-0303 August 1983 Response Opposing Miami Valley Power Project 830707 Reply Brief Supporting Project 830603 Motion to Reopen Record.Aslb Lacks Jurisdiction to Hear Motion to Reopen to Admit Eight late-filed Contentions.Certificate of Svc Encl ML20024D1381983-07-27027 July 1983 Answer Opposing Miami Valley Power Project 830712 Motion for Protective Order to Withhold Identity of Persons Upon Whose Allegations Project Relied in Seeking to Reopen Record.Motion W/O Merit.Certificate of Svc Encl ML20024D1261983-07-27027 July 1983 Answer Opposing Miami Valley Power Project 830712 Motion to Reopen Record for Admission of Eight QA Contentions. Motion Actually Is Untimely Appeal from Earlier ASLB Rulings.Relief Sought Contrary to Commission Orders ML20024D1171983-07-27027 July 1983 Answer Opposing Miami Valley Power Project 830712 Motion to Defer Ruling on Review of ALAB-727 Pending Ruling on Motions to Reopen.No Justification Given to Delay Review for Unrelated Matters ML20080A2721983-07-21021 July 1983 Response to Applicant Motion for Leave to Respond to Miami Valley Power Project Reply Brief.Applicant Should Respond Only to Substance of Proposed Contentions Re QA Program Inadequacy.Certificate of Svc Encl ML20076L4691983-07-15015 July 1983 Motion for Leave to Respond by 830729 to Miami Valley Power Project (MVPP) Reply Brief Re Applicant Opposition to Eight QA Contentions.Mvpp Reply Distorts Record & Applicant Position.Certificate of Svc Encl ML20072N4741983-07-12012 July 1983 Motion to Defer Ruling on Whether to Review ALAB-727 Until ASLB & Aslab Rule on Miami Valley Power Project 830603 & 0712 Motions to Reopen Record to Admit Contentions on QA & Character & Competence,Or Alternatively,To Reopen Record ML20072N4631983-07-12012 July 1983 Motion to Reopen Record for Admission of Eight Contentions on QA & Corporate Character & Competence.Aslab Has Jurisdiction Even If ASLB Lacks Jurisdiction to Reopen Record ML20072N4501983-07-12012 July 1983 Reply Brief Supporting Miami Valley Power Project 830603 Motion to Reopen Record for Admission of Eight Contentions on QA & Corporate Character & Competence & Motion to Compel Discovery on Contentions ML20072N4901983-07-12012 July 1983 Motion for Protective Order to Shield Identity of Affiants Providing Portion of Basis for Miami Valley Power Project Eight Proposed Contentions.Certificate of Svc Encl ML20072K7331983-07-0101 July 1983 Answer Opposing Miami Valley Power Project 830629 Motion for Leave to File Reply Brief to Util & NRC Answers to Project 830603 Motion to Reopen Record.No Purpose Would Be Served by Permitting Redundant Discussion.Certificate of Svc Encl ML20024B0591983-06-29029 June 1983 Motion for Leave to File Reply Brief,By 830706,to NRC & Util 830630 Answers to Miami Valley Power Project 830603 Motion to Reopen Record to Admit Eight Contentions on QA & Util Character & Competence.Certificate of Svc Encl ML20072F4481983-06-22022 June 1983 Memorandum Supporting Miami Valley Power Project 830602 Motion to Reopen Record to Admit Eight Contentions on QA & Lack of Corporate Character & Competence.Reopening Necessary to Foster Public Confidence in Nrc.W/Certificate of Svc ML20024A6661983-06-20020 June 1983 Response Opposing Motions to File Amicus Curiae Brief in Support of Miami Valley Power Project Motion to Reopen Record for Admission of Eight QA Contentions.Certificate of Svc Encl ML20024A6621983-06-20020 June 1983 Response Opposing Miami Valley Power Project 830603 Motion to Reopen Record for Admission of Eight QA Contentions. Motion Untimely ML20076J1361983-06-16016 June 1983 Ohio Sierra Club Amicus Curiae Brief Supporting Miami Valley Power Project Motion to Reopen Record to Admit Eight Contentions.Contentions Provide Evidence That QA Problems Exist.Certificate of Svc Encl ML20076J1201983-06-16016 June 1983 Petition for Leave to File Amicus Curiae Brief Re Miami Valley Power Project Motion to Reopen Record to Admit Eight Contentions on QA & Character & Competence.Requests Extension of Time.Certificate of Svc Encl 1993-08-11
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STATE OF ILLINOIS )
) SS.
COOK COUNTY )
AFFIDAVIT OF ROBERT E. COTTA ROBERT E. COTTA, being first duly sworn according to law, comes forward and states:
- 1. My name is Robert E. Cotta. I am employed by Sargent & Lundy as the Senior Electrical Project Engineer for the Wm. H. Zimmer Nuclear Power Station. In this posi-tion I oversee the electrical design and cable interface between various electrical systems. Specifications for electrical equipment also fall in my area of responsibility.
In addition, I have participated in the development of fire protection criteria for cables and cable trays and in the design and observation of various tests relating to this equipment.
- 2. A statement of my professional qualifications is attached hereto as Exhibit A and is incorporated b.y reference herein.
- 3. With regard to electrical cables and cable trays, I participated in the development of fire protection cri-teria and in the development of the Fire Protection Evaluation Report (" Fire Report") consisting of the Report and 14 revisions which form part of the Application for an operating -
1256 136 0
g3 i 791102
license for the Zi=mer Station. This Report, as revised, is, to the best of my knowledge, information and belief, true and correct and incorporated into this affidavit by
reference.--
- 4. I am fmmiliar with the tests conducted by the Construction Technology Laboratories ("CTL") of the Portland Cement Association (Revision 13 to the Fire Report) . I observed the tests and have studied the resulting report entitled " Fire Protective Cable Tray Fire Test Report."
This recort is true and correct to the best of my knowledge, information and belief. The cable trays utilized in the CTL test are the same type as utilized in the Wm. H. Zimmer Nuclear Power Station. In addition, the type of Kaowool used in the tests will be the same as utilized at the Zimmer Station. The method of application utilized in the course of the tests will also be identical to that used at the Wm.
H. Zimmer Station. Moreover, the cables utilized in the CTL tests were the same type which will be cocooned in Kaowool at the Zimmer Station.
- 5. The 90-minute tes;t period for the CTL tesE was determined after concultation with the NRC Staff.
It was
--*/ It should be noted that Revision 12 which reports on tests which were run by Husky Products, Inc. for the Wm. H. Zimmer Station from September 1978 through January 1979 is only being relied upon with regard to the ampacity measurements for a cocooned cable tray. -
In addition, Underwriters Laboratories Test Report R8758 dated September 6, 1978 antitled " Report on Cable Raceway Protection Systems, Fire Test Investigation,"
while valid, has been superseded by the CTL Report con-tained in Revision 13.
)7q 37
determined on the basis that if this test were passed, a sufficient degree of fire protection in needed parts of the Zimmer facility would be provided considering the various locations of cable trays, ignition and fuel sources, and fire detection and fire protection measures at the various locations.
- 6. All cable trays which are to be cocooned will be wrapped with three one-inch layers of Kaowool as utilized in the CTL tests. Cables which pass through cable trays cocooned with Kaowool have been suitably derated in order that their design temperatures are not exceeded either in normal operation or as a result of a postulated fire.
- 7. The design of the Zimmer Station utilizes concrete curbs around penetrations of floors through which cable trays are routed such that any flammable or other liquids spilled on the floor cannot contact a vertical cable tray or penetrate into the Kaowool cocoon. In addition, when Kaowool butts to a floor, ceiling or wall, a qualified fire retardant sealant will be used to further prevent pene-tration of any flanmable liquid. ~ -
s,
~s o' 138
. -4 S. Therefore, I conclude Miami Valley Power Project's Contention 17 is completely lacking in = erit.
EXECUTED COPIES WILL SE PROVIDED LATER Robert E. Cotta Sworn and subscribed to before me this day of , 1979.
Notary Public My Commission expires .
1256 139
STATEMENT OF PROFESSIONAL QUALIFICATIONS ROBERT E. COTTA SENIOR ELECTRICAL PROJECT ENGINEER SARGENT & LUNDY My name is Robert E. Cotta and I mm the Senior Electrical Project Engineer for the Wm. H. Zinner Nuclear Power Station.
My business address is Sargent & Lundy Engineers, 55 E.
Monroe Street, Chicago, Illinois 60603.
As Senior Electrical Project Engineer, my duties are to oversee the electrical design and the cabling interface between various electrical systems. Specifications for electrical equipment also fall in my area of responsibility.
I directed the fire protection aspects of cable tray and cable design and I participated in the preparation of the Fire Protection Evaluation Report for the Zimmer Station.
I have completed two years of college 3svel courses at the University of Michigan and the University of Illinois.
I am a registered professicnal engineer, having passed the examination in the State of Illinois, and I am also registered in the State of Ohio. My work history includes 8 years as a
~
plant engineer with several companies, and several years working in maintenance and operating groups for utility companies. I have been with Sargent & Lundy for the past 13 years.
In 1966 and 1967, I was assigned to the coordination of electrical drawings for the Nuclear Steam Supply Systems on boiling water reactor plants. From that time through 1972, I was assigned as the Electrical Project Engineer and subsequently Senior Electrical Project Engineer on a two unit boiling water reactor. For the past 9 1/2 years, I have been Senior Electrical Project Engineer assigned to the Zimmer Station project.
My professional activities include membership on the Ad Hoc Work Group which developed IEEE 384, " Criteria for Independence of Class lE Equipment & Circuits," membership on the Steering Committee of the IEEE for the Task Force to develop fire stop standards, past Chairman of the IEEE Wire & Cable Systems Work Group which developed IEEE 422,
" Guide for the Design & Installation of Cable Systems in Power Generating Stations," and presently Chairman of the Station Design Subccmmittee of IEEE.
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