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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
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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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- Attachmtnt 7
- AFFIDAVIT ec(L My name is Richard Reiter. I am submitting this affidavit to Thomas Devine who nos identified himself to me as the legal director of the Government Accountability Project of the Institute for Policy Studies. I am submitting this statement to make a record of my dissatisfaction how my interview with investigators from j Torrey Pines was summarized in their report. I have instructed Mr. Devine to share this affidavit with the Nuclear Regulatory Commission (NRC) Commissioners.
The summary of my interview was printed on page'8-5 of the report. It is so severly incomplete that it is innacurate. The two most significant issues that I discussed were the widespread lack of material traceability, and the reasons why I believed that the falsification of documents and markings was intentional.
In each case I discussed the issues in detail and provided specific exaniples. Neither issue was mentioned in the summary.
I also discussed why the personnel actions against Mr. Dave Jones were retaliatory. Again the report does not mention my analysis. I believe the omission is significant, because the relevant c,hapter in the report directly concerns retaliation, and because*Torrey Fines concluded that no reprisals had been taken againct Mr. Jones.
I also was a witness to the Torrey Pines interviews with witnesses identified as messrs. "Q" and "R". I have reviewed Mr. R's evaluation of the summary. To the best of my recollection, gtb 0310060263 831003 PDR ADOCK 05000358 PDR g
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I believe that his criticisms of the summary table are accurate. . l
- l I have read the above 2 page affidavit, and it is true, accurate S' and complete to the best of my knowledge and belief.
T' WC l Richard'L. Reiter I'
.ho n to and signed in my presence this @ </7// _ day of 8hA h Ipp 1983.
4 E RY E. WitLIAMS gopry Pubhc. State of Ohio Ey I;msmissi:D Entras Dec. 18, 1985 G
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