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Category:AFFIDAVITS
MONTHYEARML20151W5941998-09-11011 September 1998 Affidavit of Cd Payne.* Affidavit Re NRC Staff Proposed Denial of Rl Herring Application for Senior Reactor Operator License for Use at Catawba Nuclear Station,Units 1 & 2 ML20151Y0601998-09-11011 September 1998 Affidavit of DC Payne.* Supports Denial of Application of Rl Herring for SRO License ML20151W6131998-09-0808 September 1998 Affidavit of Mn Leach in Support of NRC Staff Response to Rl Herring Written Presentation.* ML20151W6311998-09-0808 September 1998 Affidavit of ET Beadle.* Affidavit Relates to Denial of Senior Reactor Operator License Application for Rl Herring. with Certificate of Svc ML20101J9871984-12-21021 December 1984 Affidavit of Cj Czajkowski & Jr Weeks in Response to DA Schlissel Affidavit Addressing ASLB Finding in OL Proceeding That IGSCC Not Expected to Occur as Result of Sensitization of Certain Critical Welds in Cooling Sys ML20101E9211984-12-20020 December 1984 Affidavit of L Lewis Re Assertions of Palmetto Alliance & Carolina Environ Study Group That Operation Will Significantly Increase Costs & Exposures in Performing Maint & Repair Work & Releases to Environ ML20101E8651984-12-20020 December 1984 Affidavit of Wf Reinke Re Delay in Commercial Operation of Facility ML20101E8921984-12-20020 December 1984 Affidavit of WR Stimart Re Explanation of How Delay in Commercial Operation Translates Into Increased Project Costs ML20101E8981984-12-20020 December 1984 Affidavit of PM Abraham Re Safety Implications of Operation of Facility ML20101E9131984-12-20020 December 1984 Affidavit of Wh Rasin Re Assertion Made by Palmetto Alliance & Carolina Environ Study Group That Containment Vulnerable to Breach Because of Hydrogren Explosion in Event of Accidents ML20101E8791984-12-19019 December 1984 Affidavit of SE Ferdon Re Assertions Made in Affidavits of Kaku & Schlissel ML20101E8421984-12-18018 December 1984 Affidavit of Wh Owen Re Testing Sequence Required to Bring Facility Into Operation ML20097J3941984-09-15015 September 1984 Affidavit of Hs Nunn Re Foreman Override Practices. Certificate of Svc Encl ML20098A1711984-09-12012 September 1984 Affidavit of Wh Owen Updating Schedule for Fuel Load & Precritical 0-5% & 5-100% Power Testing.Related Correspondence ML20092B6831984-06-18018 June 1984 Affidavit of Wh Owen Re Change in Fuel Load Date.Date Currently Scheduled for 840629 ML20084K9091984-05-0808 May 1984 Affidavit of Wh Owens Re Current Schedule for Fuel Loading, Testing & Power Ascension Phases ML20083K6221984-04-11011 April 1984 Affidavit of PM Abraham & WR Mccollum Supporting Motion for License to Load Fuel & to Conduct Certain Precritical Tests ML20083K6261984-04-11011 April 1984 Affidavit of Cj Wylie Describing All Normal & Addl Sources of Power Available to Support Facility W/O Reliance on Emergency Diesel Generators.Certificate of Svc Encl ML20088A7931984-04-10010 April 1984 Affidavit of Wh Owen Reflecting Revised Schedule for Fuel Loading,Testing & Power Ascension Phases ML20086L0461984-02-0303 February 1984 Affidavit of Mf Lowe in Response to W Owen 840118 Affidavit Re Delay of Fuel Load & Testing Activities.Certificate of Svc Encl ML20087N5851984-01-26026 January 1984 Affidavit of H Langley Re QC Concerns at Site ML20079N3701984-01-24024 January 1984 Affidavit of Hs Nunn in Response to Applicant Suggestion of Contrived Testimony.Certificate of Svc Encl ML20079G5081984-01-18018 January 1984 Affidavit of Wh Owen Re Current Schedule for Unit 1 Fuel Loading & Testing & Power Ascension Phases.Certificate of Svc Encl ML20129A5091983-12-14014 December 1983 Affidavit of Rd Bentley Re Lack of Qa/Qc Independence & Harassment/Intimidation of QC Welding Inspectors at Facilities.Related Info Encl ML20082E5501983-11-23023 November 1983 Affidavit of Bp Garde Re 831103 Telcon W/Welding Inspector on Testimony of Util Employees ML20082E5601983-11-23023 November 1983 Affidavit of L Clark Re 831103 Telcon W/Welding Inspector on Testimony of Util Employees.Certificate of Svc Encl ML20133C6451983-11-16016 November 1983 Affidavit of Hs Nunn Re Quality of Const at Plant ML20133C6411983-11-16016 November 1983 Affidavit of WR Mcafee Re Concerns Over Quality of Const at Plant ML20133C6321983-11-0909 November 1983 Affidavit of JB Stearns Re Concerns Over Shoddy Workmanship & Retaliation Against Persons Challenging Poor Workmanship at Plant ML20081K7301983-11-0202 November 1983 Affidavit of RM Glover Re Proposed Extension of Plume Exposure Pathway Emergency Planning Plume Zone (Contention 11).Certificate of Svc Encl ML20080L9911983-09-27027 September 1983 Affidavit of PA Evans in Response to Palmetto Alliance Allegations That self-initiated Evaluation Identified Problems Which Are Symptomatic of Systematic Deficiencies in Plant Const ML20024E3471983-08-0505 August 1983 Affidavit of R Guild Re Summary Disposition of Contentions 16,DES-19 & 14.Affidavit of Counsel & Certificate of Svc Encl ML20024C9931983-07-15015 July 1983 Affidavit of Lr Davidson Re Palmetto Alliance Contention 6. Concrete Pours on Wall Above Interior Doghouse of Unit 1 Containment Found Acceptable.Rain Leakage Did Not Damage Control Room Boards.Prof Qualifications Encl ML20024C9941983-07-15015 July 1983 Affidavit of Jc Rogers Re Palmetto Alliance Contention 6. Green Water in Uhi Bldg Is Not Unsafe.Contact of Carbon Steel & Stainless Steel Will Not Compromise Matl Integrity. Prof Qualifications & Certificate of Svc Encl ML20024C7491983-07-0808 July 1983 Affidavit of Mc Green Re Palmetto Alliance Contention 16. Spent Fuel Liner Would Not Rupture If Temp Exceeds 150 F. Spent Fuel Cask Cannot Be Dropped Into Spent Fuel Pool.Rails Will Be Relocated So Cask Will Not Be Over Fuel Pool Area ML20024C7551983-07-0808 July 1983 Affidavit of AL Snow Re Palmetto Alliance/Carolina Environ Study Group Alliance Contention 19.Environ Impact of McGuire & Oconee Spent Fuel at Catawba Insignificant.Prof Qualifications & Certificate of Svc Encl ML20024C7441983-07-0808 July 1983 Affidavit of AL Snow Re Palmetto Alliance Contention 16 on Spent Fuel Storage Facility Cooling & Criticality Control Capability.Plant Sys Comply W/Gdc 44.Prof Qualifications Encl ML20070C7281982-12-0202 December 1982 Affidavit of RA Wiesemann Re Westinghouse Proprietary Info in Util Submittal on Improved Thermal Design Procedures 1998-09-08
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20197J2871998-12-11011 December 1998 Initial Decision (Application for Senior Reactor Operator License).* Appeal of R Herring of NRC Denial of Application for SRO License Denied.With Certificate of Svc.Served on 981211 ML20151W5721998-09-11011 September 1998 NRC Staff Presentation in Support of Denial of Senior Reactor Operator License for Dl Herring.* Staff Decision to Fail Dl Herring on Category a of SRO Exam,Clearly Justified. Staff Denial of Herring SRO License Should Be Sustained ML20151W5941998-09-11011 September 1998 Affidavit of Cd Payne.* Affidavit Re NRC Staff Proposed Denial of Rl Herring Application for Senior Reactor Operator License for Use at Catawba Nuclear Station,Units 1 & 2 ML20151Y0601998-09-11011 September 1998 Affidavit of DC Payne.* Supports Denial of Application of Rl Herring for SRO License ML20151W6131998-09-0808 September 1998 Affidavit of Mn Leach in Support of NRC Staff Response to Rl Herring Written Presentation.* ML20151W6311998-09-0808 September 1998 Affidavit of ET Beadle.* Affidavit Relates to Denial of Senior Reactor Operator License Application for Rl Herring. with Certificate of Svc ML20237B6931998-08-13013 August 1998 Rl Herring (Denial of Operator License for Plant).* Rl Herring Submitted Written Presentation Arguments,Data, Info Matl & Other Supporting Evidence,Per Presiding Officer 980630 Order & 10CFR2.1233.W/one Oversize Drawing ML20237A3831998-08-12012 August 1998 NRC Staff Request for Extension of Time to File Response to Rl Herring Written Presentation.* Staff Respectfully Requests Motion for Extension of Time of 2 Wks to Respond to Herring Presentation Be Granted.W/Certificate of Svc ML20237B5571998-08-12012 August 1998 NRC Staff Request for Extension of Time to File Response to Rl Herring Written Presentation.* Granted by C Bechhoefer on 980818.W/Certificate of Svc.Served on 980818 ML20236T8511998-07-21021 July 1998 Specification of Claims.* Rl Herring Claims That Answer Given on Exam Was Correct When TSs Are Considered & When Design Basis Document Considered in Conjunction W/Duke Power Nuclear Sys Div.W/Certificate of Svc.Served on 980727 ML20236F5391998-06-30030 June 1998 Memorandum & Order (Hearing File & Spec of Claim).* Orders That Brief Spec of Claims Should Be Filed by Herring,Telling Why He Believes Staff Erred in Grading Exam.Staff Must Furnish Hearing File.W/Certificate of Svc.Served on 980630 ML20236F5631998-06-30030 June 1998 Notice of Hearing.* Presiding Officer Has Granted Request of Rl Herring for Hearing on NRC Denial of Application for Operator License for Plant.W/Certificate of Svc.Served on 980630 ML20149K8221997-07-29029 July 1997 Exemption from Requirements of 10CFR70.24, Criticality Accident Requirements. Exemption Granted TXX-9522, Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources1995-08-26026 August 1995 Comment Opposing Proposed GL on Testing of safety-related Logic Circuits.Believes That Complete Technical Review of All Surveillance Procedures Would Be Expensive & Unnecessary Expenditure of Licensee Resources ML20065P4491994-04-21021 April 1994 Comment Opposing Proposed Rule 10CFR50.55 Recommendation to Incorporate Proposed Rule to Adopt ASME Code Subsections IWE & Iwl ML20044G7371993-05-25025 May 1993 Comment on Proposed Rules 10CFR170 & 171, FY91 & 92 Proposed Rule Implementing Us Court of Appeals Decision & Rev of Fee Schedules;100% Fee Recovery,FY93. Opposes Rule ML20101R5931992-07-0606 July 1992 Comment on Proposed Rule 10CFR50 Re Loss of All Alternating Current Power & Draft Reg Guide 1.9,task DG-1021.Opposes Rule ML20091Q8661992-01-31031 January 1992 Comment Opposing Draft NUREG-1022,Rev 1, Event Reporting Sys,10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting ML20087F7471992-01-15015 January 1992 Comment Opposing Rev 1 of NUREG-1022, Event Reporting Sys ML20246J6571989-08-31031 August 1989 Order Imposing Civil Monetary Penalty on Licensee in Amount of $75,000 for Violations Noted in Insp on 881127-890204. Payment of Civil Penalty Requested within 30 Days of Order Date.Evaluations & Conclusions Encl ML20247J8921989-08-31031 August 1989 Order Imposing Civil Monetary Penalty in Amount of $75,000, Based on Violations Noted in Insp on 881127-890204,including Operation in Modes 1-4 W/One Independent Containment Air Return & Hydrogen Skimmer Sys Inoperable for 42 Days ML20205N1471988-10-20020 October 1988 Comment on Petition for Rulemaking PRM-50-50 Re Provision That Authorizes Nuclear Power Plant Operators to Deviate from Tech Specs During Emergency.Request by C Young Should Be Denied ML20234D2821987-09-15015 September 1987 Joint Intervenors Emergency Motion to Continue Hearing for 2 Wks & for Immediate Prehearing Conference.* Urges That Hearing Re Offsite Emergency Planning at Plant,Scheduled for 870928,be Continued Until 871013.Certificate of Svc Encl ML20198C5771986-05-14014 May 1986 Transcript of 860514 Discussion/Possible Vote on Full Power OL for Catawba 2 in Washington,Dc.Pp 1-86.Viewgraphs Encl ML20203N4561986-02-20020 February 1986 Unexecuted Amend 6 to Indemnity Agreement B-100,replacing Item 3 of Attachment to Agreement W/Listed Info ML20151P2231985-12-31031 December 1985 Order Extending Time Until 860110 for Commissioners to Review ALAB-825.Served on 851231 ML20136H7231985-11-21021 November 1985 Decision ALAB-825,affirming Remaining Part of ASLB OL Authorization,Permitting Applicant to Receive & Store Spent Fuel Generated at Duke Power Co Oconee & McGuire Nuclear Power Facilities.Served on 851121 ML20138B3611985-10-11011 October 1985 Order Extending Time Until 851025 for Commission to Act to Review ALAB-813.Served on 851011 ML20137W4311985-10-0202 October 1985 Order Extending Time Until 851011 for Commission to Act to Review ALAB-813.Served on 851003 ML20134N5761985-09-0404 September 1985 Order Extending Time Until 851004 for Commission to Act to Review ALAB-813.Served on 850904 ML20126M2091985-07-30030 July 1985 Order Amending First Paragraph of Footnote 126 Re Need for Power & Financial Qualifications in ALAB-813 . Served on 850731 ML20126K7701985-07-26026 July 1985 Order Extending Time Until 850730 for Commission to Act to Review Director'S Decision DD-85-9.Served on 850729 ML20129C2351985-07-26026 July 1985 Decision ALAB-813 Affirming Aslab Authorization of Issuance of Full Power Ol,Except Insofar as Receipt & Storage Onsite of Spent Fuel Generated at Other Facilities.Served on 850729 ML20129K1651985-07-19019 July 1985 Order Extending Time Until 850726 for Commission to Act to Review Director'S Decision DD-85-9.Served on 850719 ML20129H9361985-07-10010 July 1985 Unexecuted Amend 5 to Indemnity Agreement B-100,changing Items 1 & 3 of Attachment ML20128K2171985-07-0808 July 1985 Order Extending Time Until 850719 for Commission to Act to Review Director'S Decision DD-85-9.Served on 850709 ML20127P0991985-06-28028 June 1985 Transcript of 850628 Supplemental Oral Argument in Bethesda, Md.Pg 99-169 ML20133C5201985-06-26026 June 1985 Undated Testimony of PM Reep Re Welding Inspector Concerns. Rept of Verbal Harassment Encl ML20127K7171985-06-24024 June 1985 Order Extending Time Until 850709 for Commission to Act to Review Director'S Decision DD-85-9 ML20126K6391985-06-17017 June 1985 Order Advising That Counsel Be Familiar W/Content of Commission Request for Public Comment on Decision to Exercise Discretionary Price-Anderson Act Authority to Extend Govt Indemnity to Spent.... Served on 850618 ML20126B8101985-06-13013 June 1985 Order Scheduling Supplemental Oral Argument on Pending Appeals on 850628 in Bethesda,Md Re Public Notice of Hearing Concerning Use of Facility for Receipt & Storage of Spent Fuel from Oconee & Mcguire.Served on 850613 ML20126E4601985-06-13013 June 1985 Notice of Supplemental Oral Argument on Pending Appeals on 850628 in Bethesda,Md.Served on 850613 ML20125B4251985-06-0707 June 1985 Responds to Aslab 850603 Order Requesting Response to NRC 850529 Filing Re Whether Notice of Proposal to Use Catawba to Store Oconee & McGuire Spent Fuel Discretionary or Required.Certificate of Svc Encl ML20126A7631985-06-0404 June 1985 Director'S Decision DD-85-9 Granting & Denying in Part Palmetto Alliance Request for Mod,Suspension or Revocation of CPs for Facilities Due to Harassment & Intimidation of QC Inspectors ML20129A6381985-06-0303 June 1985 Order Allowing Applicant to File & Serve Response to NRC 850529 Assertion Re Storage of Spent Fuel Generated at Another Facility Constituting Use of Commercial Utilization Facility No Later than 850607.Served on 850604 ML20128P0001985-05-29029 May 1985 NRC Views on Whether Notice of Proposal to Use Facility to Store Oconee & McGuire Spent Fuel Required or Discretionary. Certificate of Svc Encl ML20128P1031985-05-29029 May 1985 Memorandum Responding to Palmetto Alliance/Carolina Environ Study Group & Staff 850517 Memoranda Asserting That Fr Notice Not Reasonably Calculated to Inform of Requests Re Spent Fuel.Certificate of Svc Encl ML20127K0231985-05-20020 May 1985 Order Extending Time Until 850529 for Aslab to Act to File & Svc Reply Memoranda.Served on 850521 ML20127G2281985-05-17017 May 1985 Memorandum Responding to 850425 Aslab Order Addressing Four Questions Re Receipt & Storage of Spent Fuel.Certificate of Svc Encl ML20127H0041985-05-17017 May 1985 Response to Aslab Questions on Adequacy of Notice of Proposed Use of Facility to Store Spent Fuel from Oconee & McGuire Facilities.Aslab Has No Jurisdiction Over Proposal. Certificate of Svc Encl 1998-09-08
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AFFIDAVIT 4
- 1. My name is Billie.Pirner Garde. I am the Director of the Citizens Clinic of the Government Accountability Project of the Institute for Policy Studies,1901 Que Street, N.W. , Washington, D.C. 20009. 1 e,
, e' .
- 2. In that role I have been directly conducting or supervising the investigation of the Catawba Nuclear Power Plant since late March of 1983. That investigation has included a complete review of all available documentation amassed through both the Operating License Hearings and '
r available in the Public Document Room of the Nuclear Regulatory Commission
("NRC"), as well as obtained by GAP through the Freedom of Information j# ,,
Act (FOIA). It has also included a detailed analysis of information f
and complaints provided by the welding quality control inspectors to <
i Duke Power Company, its contractor. the Maragement Analysis Corporation (MAC), and the NRC Staff. Finally, our investigation has included contacts and interviews with enployees, former employees, and management officials of Duke. Some of these contacts have been initiated by GAP IFvestigators, some of them have been in response to contacts from workers l ( .
and former workers. ,
- 3. Currently GAP is working with the Office of Investigations (01), the Of fice of Inspector and Auditor (OIA), and the Office of Inspection and Enforcement ,
(IE) Region II in their respective investigations / inspections of worker l
concerns about the Catawba facility and NRC oversight.
l ,
- 4. Of particular concern to GAP in recent weeks has been information received l
about excessive pressure on the Catawba site toward welding quality control inspectors scheduled to testify concerning their 1981 complaints regarding L .
831'1280233 831123 l .PDR ADOCK 05000413 g, PDR l -
1:
\.
harassment of QC Inkpectors, lack of support of QC inspectors from QC supervisors, verbal overriding of non-conforming conditions indentified by QC inspectors, specific hardware problems identified by QC inspectors, and other issues identified by inspectors in their complaints to their own management as well as complaints made to the NRC.
- 5. For example, in conversations that I have had with welding quality control inspectors in recent weeks that are scheduled to testify I have been told that "We just want the pressure off of us by Duke.," and "I intend to testify truthfully when they put me on the stand, but I know that I am going to lose my job as soon as this trial is over.," and "I cannot volunteer any information that I know, all I can do is answer questions."
- 6. More importantly, on November 3,1983, a call was received at the GAP office from a welding inspector who identified himself as a welding quality control inspector not scheduled to testify who was calling out of concern for, and at the request of, other welding quality control inspectors who were scheduled to testify in the proceeding. This inspector, who did not reveal his name, disclosed the following information relevant to the matter before the Commission:
(1) His " buddies" were undergoing " training sessions" at Duke's Charlotte offices in which they were being closely questioned about what they were supposed to say.
(2) The " pressure on the job site was so thick that you could cut it with a knife."
(3) His co-workers were having to go "over and over and over" what they said in their written statements and told to practice saying it in many dif ferent words.
\
(4) He stated that they were all afraid that as soon as they were finished with the hearing that they would be laid off because Duke would not have any need to keep them anymore.
(5) He said that they were all aware, through CAP and the newspaper and television reports, that there was supposed to be a new NRC investigation into their claims, but they were afraid it would be too late.
(6) He said that he did not know whether or not what the lawyers were doing to his buddies was illegal or wrong, but they wanted to find out.
- 7. I talked to this gentleman for approximately 45 minutes about his questions on the hearing process, as well as about other issues concerning the plant not relevant to this matter now before the Commission. Mr.
Louis Clark, Exceutive Director of CAP, also discussed his concerns about the pre-hearing witness preparation by Duke's attorneys.
- 8. At the conclusion of the conversation I recommended that he convey all of the information he had told me to Mr. John Sinclair of the Office of Investi-gations of the NRC and provided him with the phone numbers of OI in Washington, and Atlanta.
- 9. It is my understanding that he called OI with his information the next l
l day.
The above information is true and complete to the best of my knowledge under threat of perjury.
LL W ' h*
BILLIE PIRNER GARDE Subscribed and sworn to me this_ d.8/!([ day of November,1983 in the District of Columbia.
.z ( Md My Commission expires kne 14,1995 IN U'inMI l'U Dirl L ,
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