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Category:AFFIDAVITS
MONTHYEARML20087K9231984-03-21021 March 1984 Executed Signature Page of Affidavit of M Kaku in Support of 840320 Renewal of Application for Stay ML20023D0351982-07-26026 July 1982 Affidavit of at Howard Re QC Breakdown & Criminal Falsification at Zack Co,Hvac Contractor at Facilities ML20023D0341982-07-26026 July 1982 Affidavit of SL Marello Re QC Breakdown & Criminal Falsification at Zack Co,Hvac Contractor at Facilities ML20063E9141982-06-24024 June 1982 Affidavit Re Results of Sloppy Concrete Pours,Holes & Honeycombs in Concrete.Accumulated Debris Not Disposed of Prior to Pour & Too Much Concrete Poured at One Time.Worker Health Not Main Concern of Supervisors ML20063E9191982-04-22022 April 1982 Affidavit Re safety-related Const Flaws in Installation of Pipes & Supports.Pipes & Hanger Supports Not Placed as Specified ML20063E9241982-04-21021 April 1982 Affidavit Re Sloppy Workmanship Leading to Const Damage. Const Crews Core Drilled Through Reinforcement Bars, Containment Wall & Reactor Vessel Pedestal Around 694 Foot Elevation of Unit 1 ML20063E9231982-04-21021 April 1982 Affidavit Re Damage to Fire Protection Equipment Such as Sprinklers Throughout Plant During Const.Concerns Raised Over Core Drillings of Concrete Reinforcement Bars in Containment Walls & Pedestal.Hangers Not as Specified ML20027A8161982-03-17017 March 1982 Affidavit of D Bridenbaugh Re Adequacy & Quality of Const of Certain Structures at Facilities in Response to Previous Testimony That Steel Reinforcements in Concrete Walls Were Severed During Mod to Safety Sys ML19208B0171979-09-13013 September 1979 Affidavit of Distribution of Fsar,Amend 46 1984-03-21
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20207E0051999-03-0202 March 1999 Transcript of 990302 Public Meeting with Commonwealth Edison in Rockville,Md.Pp 1-104.Supporting Documentation Encl ML20236H9381998-06-30030 June 1998 Transcript of 980630 Meeting W/Commonwealth Edison in Rockville,Md.Pp 1-123.Supporting Documentation Encl ML20198P3001997-11-0404 November 1997 Transcript of 971104 Public Meeting W/Ceco in Rockville,Md Re Measures Established by Ceco to Track Plant Performance & to Gain Understanding of CAs Put Into Place to Improve Safety.Pp 1-105.W/Certificate & Viewgraphs ML20059C2351993-12-17017 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication ML20247R4811989-09-22022 September 1989 Petition for Rulemaking PRM-50-53 Providing Comments on Ocre Petition Requesting NRC to Reopen ATWS Rulemaking Proceeding.No Basis Found for Ocre Petition Since Stability Considered During ATWS Rulemaking ML20247F1141989-09-0606 September 1989 Petition for Rulemaking 50-53 Reopening ATWS Rulemaking Proceeding in Light of Power Oscillations Occurring at Facility Following Dual Recirculation Pump Trip on 880309. Listed Encl Repts Should Be Made Part of Record ML20245J0191989-04-14014 April 1989 Comment Re Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants ML20247N7531988-07-28028 July 1988 Petition for Rulemaking PRM-50-53 Requesting NRC Action to Review Undue Risk Posed by BWR Thermal Hydraulic Instability.Nrr Should Issue Order Requiring All GE BWRs to Be Placed in Cold Shutdown for Stated Reasons ML20151A9091987-03-0505 March 1987 Comment Opposing Proposed Rule 10CFR50 Re Licensing of Nuclear Power Plants Where State &/Or Local Govts Decline to Cooperate in Offsite Emergency Planning ML20151C4881987-02-26026 February 1987 Comment Opposing Proposed Rule 10CFR50 Re Licensing of Nuclear Power Plants Where State &/Or Local Govts Decline to Cooperate in Offsite Emergency Planning ML20087K9231984-03-21021 March 1984 Executed Signature Page of Affidavit of M Kaku in Support of 840320 Renewal of Application for Stay ML20083G0531984-01-0606 January 1984 Addendum to Petition for Emergency Relief Per 10CFR2.206 Re Integrated Leak Rate Testing.All Documentation Re Integrated Leak Rate Tests Must Be Made Public ML20083C2741983-11-29029 November 1983 Petition for Emergency Relief Concerning Unsafe Conditions Re Integrated Leak Rate Testing for Us Nuclear Power Reactor Containments.Severe Errors,Defects & Loopholes Exist in Current Methodology ML20083C2771983-11-29029 November 1983 Petition for Emergency Relief Re Primary Containment Leak Rate at Facilities.Unsafe Condition Exists Re Ability of Primary Containment to Fulfill Design Function ML20082M6711983-11-29029 November 1983 Petition for Emergency Relief Concerning Unsafe Conditions Re Integrated Leak Rate Testing of Us Nuclear Power Reactor Containments.Severe Errors,Defects & Loopholes Exist in Current Methodology ML20023D2141983-03-11011 March 1983 P Donahue Show Transcript 08302 Re Nuclear Power Safety. Info Re Facilities & Zack Co Encl ML20062H4111982-08-13013 August 1982 Order Extending Until 820820 Time for Commission to Decide Whether to Review NRR Director Partial Denial of State of Il & B Rorem 820324 Request for Action Under 10CFR2.206 ML20027E1461982-07-28028 July 1982 Requests Show Cause Proceeding to Suspend & Revoke Any License Allowing Unit 1 Reactor Operation at or Above Criticality,To Halt All OL Proceedings & Hold Open Public Hearings Re QC Problems & Const Flaws ML20062B8701982-07-27027 July 1982 Transcript of Commission 820727 Public Meeting in Washington,Dc Re Discussion & Possible Vote on Full Power OL for Plant.Pp 1-89 ML20023D0341982-07-26026 July 1982 Affidavit of SL Marello Re QC Breakdown & Criminal Falsification at Zack Co,Hvac Contractor at Facilities ML20023D0351982-07-26026 July 1982 Affidavit of at Howard Re QC Breakdown & Criminal Falsification at Zack Co,Hvac Contractor at Facilities ML20062B5301982-07-19019 July 1982 Decision DD-82-9 Denying Petition for Show Cause Proceeding Against Util for Operation of Unit 1.Decision Re Unit 2 Will Be Made Upon Completion of Evaluation ML20063E9141982-06-24024 June 1982 Affidavit Re Results of Sloppy Concrete Pours,Holes & Honeycombs in Concrete.Accumulated Debris Not Disposed of Prior to Pour & Too Much Concrete Poured at One Time.Worker Health Not Main Concern of Supervisors ML20054J0331982-06-22022 June 1982 Transcript of 820622 Discussion in Washington,Dc Re Full Power Ol.Pp 1-97.Viewgraphs Encl ML20054F5471982-06-14014 June 1982 Order Extending Time Until 820623 for Commission to Decide Whether to Review Director of NRR Partial Denial of Il Friends of the Earth & B Rorem 820428 10CFR2.206 Request for Action ML20027A7901982-05-0303 May 1982 Amend to 820324 Request for Show Cause Proceeding.Nrc Should Expand Investigation of Alleged Potentially Hazardous Condition at Facilities ML20027A8171982-04-28028 April 1982 Request to Institute Show Cause Proceeding to Suspend License Granted on 820417,allowing Fuel Load.Request Due to Holes Bored in Reactor Pedestal,Core Drilling of Concrete Containing Rebar & Voids in Concrete Structures ML20063E9191982-04-22022 April 1982 Affidavit Re safety-related Const Flaws in Installation of Pipes & Supports.Pipes & Hanger Supports Not Placed as Specified ML20063E9231982-04-21021 April 1982 Affidavit Re Damage to Fire Protection Equipment Such as Sprinklers Throughout Plant During Const.Concerns Raised Over Core Drillings of Concrete Reinforcement Bars in Containment Walls & Pedestal.Hangers Not as Specified ML20063E9241982-04-21021 April 1982 Affidavit Re Sloppy Workmanship Leading to Const Damage. Const Crews Core Drilled Through Reinforcement Bars, Containment Wall & Reactor Vessel Pedestal Around 694 Foot Elevation of Unit 1 ML20027E1091982-04-13013 April 1982 Comments of State of Il on Util 820331 Presentation to Nrc. Detailed Analysis of All Existing Rebar Damage Repts Incomplete.Extent of Damage Cannot Be Estimated ML20027E1021982-04-0808 April 1982 Excerpt of Transcript from 820408 Hearing in Chicago,Il Re Proposed General Increase in Electric Rates.Certificate of Reporters Encl ML20027E0901982-03-31031 March 1982 Responds to Petition by State of Il Re Reinforcement of Steel Damage During Installation of Cored Holes & Concrete Extension Anchors.Exhibits Encl ML20053D7421982-03-24024 March 1982 Request to Institute Show Cause Proceeding & for Other Relief to Immediately Suspend Consideration of Util Request for Fuel Loading & Low Power Testing in Light of Newly Discovered Safety Issues ML20027A8161982-03-17017 March 1982 Affidavit of D Bridenbaugh Re Adequacy & Quality of Const of Certain Structures at Facilities in Response to Previous Testimony That Steel Reinforcements in Concrete Walls Were Severed During Mod to Safety Sys ML19208B0171979-09-13013 September 1979 Affidavit of Distribution of Fsar,Amend 46 ML19260C4331979-08-21021 August 1979 Petition to Institute Proceedings to Suspend or Revoke Cp. Util Did Not Consider Hydrodynamic Loads That Result from Dynamic Effects of Drywell Air & Stream Forced Into Suppression Pool During LOCA ML19276G8871979-08-21021 August 1979 Petition by Citizens Against Nuclear Power,Il Valley Citizens Against Nuclear Power,Citizens United for Responsible Energy & Appleseed to Institute Proceeding to Suspend &/Or Revoke License ML19209A8221979-08-21021 August 1979 Requests That NRC Suspend or Revoke License of Util to Const Nuclear Power Plant Using Mark II Containment Design.Major Design Changes in Essential Safety Sys Are Under Review. Certificate of Svc Encl ML17266A3541979-03-27027 March 1979 Endorsement 99 to Maelu Policy MF-22 ML20062A8931978-09-25025 September 1978 Indemnity Agreement B-84 1999-03-02
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- A A F P' I D A! V I 1 My name is Edwin Greve.
affidavit I am< submitting this freely and voluntarily,;without any threats inducements or promises.of reward ,
, to Mr. Thomas Devine, who has identified himself as the legal dire t Government Accountability Project c or of the Policy Studies. of the Institute for I wish to register my concern over safety-related construction flaws at the LaSalle power plant. c ear nu l I also want to protest construction waste that has raised the cost of thetplanti limits. beyond reasonable '
I have been a pipefitter and' plumber since 1955 I worked as'a pipefitter at LaSalle during M 1981. arch and April crew.
I did inspection and revision work on the h anger In April I tore my rightiarm out of the socket in an injury and have been laid upesince.
i A number of my concerns involve the design of the plant, which was very cluttered -
It was necessary to crawl between.the pipes in order to do my job.
Unfor-tunately, the installation of parts did '
not always match their location on the blueprints. ,
j Sonetimes one part was .
g gay 1146 MY-XE ,
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installed in a location where the. blueprints called for . .
another. On one occasion I warned.a drafting engineer
not to install a certain pipe because another.pgrt needed to go in that space, lie responded. ."I don' t care about anything I can't see."
Another aspect of design controls involves material
- traceability. Even if a pipe or hanger. support fits in a certain location, you have to insure that .the specific quality pipe or support-called for in the design is ac-tun 11y installed. Unfortunately,,that was not always the case. For instance, the metal inihanger supports is iden '
tified by a color co'de. When construction had the right size supports but not enough of the right color, they just repainted the color on the hanger., I uncovered this prac-tice on about 5% of my inspections. Commonwea th Edison ,
responded that the color's were wrong in the first place.
- I question whether the same metal.was installed as called -
for in the design. ,,
Other times the parts didnit'even fit. Por instance, another warker described to me how on one occasion a pipe jumped out over a foot when it was removed during a re- .
4 vision. It. turned out that construction crews had to use
'I a "portapower" Jack to wedge the pipe in when it was first' '
est installed, because it was too large.. I wonder how many '
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r other pipes of the wrong dimension <are wedged in that taut.
Those pipes will have hot water. running through th'em and
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nove around a lot when the plant is.in operation. '
- 4 In some cases I saw equipment that was damaged during ins'ta11ation. For example, 1 observed damaged gauges and electrical controls with bent arms or broken springs.
When I raised these problems with the foreman he expressed disinterest. -
Although I do not have f:irst-hand knowledge, other er.ployees alerted me to questions [about the quality of the concrete. They described how galoshes and timbers are im-bedded in the concrete, which weakens its strength.
I have been away from LaSalle for a year, so it is possible that repairs have been made.. I doubt, however, that reinspections have been thorough enough. One ex-planation is the nature of the construction and repair crews. All too often management:wouJ' hire Mexican or other foreign' welders off the street bf ebtaining tempo-rary work permits.
These employees Nere not always qual-ified and frequently could not communicate well due to language barriers.
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But.they were very well-paid and were totally,atjhemercyofthecompanytokeeptheirjobs. -
As a result, they could not be counted on for thorough, '
'DI professional work independent of pressures to speed pro-
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Another reason fo'r my doubts is the management atti-
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tude at LaSalle,1 i
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On balance, employee mor~ ale was'very )
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low. Most employees I spoke with hadtbecome apathetic.
They felt that thei* complaints would'not make a difference J
except for themselves - - they raight lose their jobs.
One of the most inmediately distressing problems ig-nored by management involved worker safety. For instance, many of the men do not know how to tie the proper knots for rope pulleys that hold heavy, equipment. Af ter I saw i
whole knots slip and thought ' about. the safety hazard, I i suggested a picture chart that showedihow to tie the knots right. Nothing happened. -
On another occasion the exhaust and ventilation f ans quit during heavy welding. The-room;became hot and hazy. ,
We were getting woozy from the' f umes. created by welding 1
and grinding into n.etal and paint.. I reported the inci-dent,'bu't' welding continued for hours before repairs were made. i O
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i I am not only upset about an unsafe plant and dan -
.i gerous working conditions.
I am.also upset, about .the
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4 gross waste at LaSalle. -
There.is no excuse for some o of l the cost increases that the ratepayers are supposed to
The same systems were revised and reinstalled ~
up to five times.
One time while I was at LaSalle mass-ive structural beans had to be. ripped out and replaced, because the originals were insufficient load. for the stress '
I The utility has blamed the Nuclear Regulatory Co m-I nission ("NRC") for all the rework. In my opinion, how-ever, it of ten is th'e utility's cnen . fault.
While I was '
at LaSalle construction crews installed parts in Unit II that everyone knew were wrong.
We. knew, because the NRC already had required revisions-on the same parts n in U it I I can point out to NRC investigators the specific problems identified in this statement, and agree to accom-pany then on any NRC investigation of these chargesI am .
making these allegations because I am a perfectionist , and that is what is needed to properly build a nuclear pl ant.
As seen above..however,. Commonwealth Edison did not follow this approach at LaSalle. ,
~ !. As. a resul.t, when that plant gets a fired up I am taking my family on a long vacation
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I have read the above .1 page statement and it is true, !
accurate and complete to the best of my knowledge and !
- a . j belief. .- , ,
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n < A4/4 Edwin Grhve j
SUBSCRIBED AND SWORN TO
~ BEF RE }lE TifIS 1.2 DAY C" './1 d _ 1982. -
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