ML20133Q343

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Affidavit of B Garde Re Failure to Provide Affidavits in Response to Affidavits Submitted by Util in Motion for Summary Disposition.W/Svc List
ML20133Q343
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 10/28/1985
From: Garde B
GOVERNMENT ACCOUNTABILITY PROJECT, TRIAL LAWYERS FOR PUBLIC JUSTICE, P.C.
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20133Q340 List:
References
OL, NUDOCS 8511010509
Download: ML20133Q343 (5)


Text

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i AFFIDAVIT My name is Billie Pirner Garde.

I am the Director of the l

Environmental Whistleblower Protection Clinic, which is a joint I

project c* the Government Accountability Project (GAP) and Trial Lawyers for Public Justice (TLPJ), at 1555 Connecticut Avenue, N.W., Washington, D.C.

20036.

I am making this statement freely, of my own volition, without any threats, inducements or promises of rewards to the j

Nuclear Regulatory Commission (NRC) about the Vogtle nuclear power plant, Units 1 and 2 being constructed in Georgia.

This affidavit is being prepared for the Atomic Safety and Licensing Board to state the reasons that I am unable at this time to provide affidavits in response to the affidavits submitted by Georgia Power Company in their Motion for Summary Disposition.

During the months of August and September I have had contact with current and former employees, both craft and QA/QC inspectors of Pullman Company, Williams Company and Georgia Power Company.

Some employees have contacted me by telephone and mail, or at the local office of the Government Accountability Project in Augusta, Georgia.

I have not, at this time, asked any of these employees to put their concerns or experiences into an affidavit for submittal to the licensing board.

Information that I received from these workers was general in nature in response to my questions about procedural issues, the implementation of the quality control program, and the specific deficiencies of which they were aware.

8511010509 851028 PDR ADOCK 05000424 l

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I 2-Some of the workers have filed complaints with the Depart-ment of Labor alleging that they were discharged, demoted, trans-ferred or in other ways discriminated against for raising safty concerns to their management.

Some of these workers have agreed 4

to provide information to this licensing board regarding their knowledge of quality control / quality assurnace problems at the Vogtle Plant.

To date no affidavits have been completed from any of the workers who have contacted the Environmental Whistleblower Protection Project, or the Government Accountability Project.

Such affidavits are normally prepared after GAP has concluded a verification study of the workers allegations.

The affidavits usually are then submitted to the Regional Office of the NRC for inspection, investigation or other enforcement purposes.

If the Board grants the Motion for Reconsideration all I

workers who have contacted GAP or the Environmental Whistleblower i

Protection Project will be apprised of the opportunity to participate in these hearings.

Affidavits from those who agree to participate will be submitted.

These workers have already been informed by GAP representatives of the rights and responsi-blities under 10 C.F.R. 50.7, and Section 210 of the 1974 Energy

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l Reorganization Act, as amended.

Signed and sworn t hu-BILLIE PIRFER GARDE n,

Sworn to before at Shi 8th day of October, 1985.

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.D UNITED STATES OF AMERICA

_I NUCLEAR REGULATORY COMMISSION g

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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GEORGIA POWER COMPANY, et al.

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Docket Nos. 50-424 OL

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50-425 OL (Vogtle Electric Generating

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Plant, Units 1 and 2)

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SERVICE LIST I hereby certify that copies of the foregoing Motion for Reconsideration (Memorandum and Order on Summary Disposition of Contention 8 Re: Vogtle Quality Assurance) were mailed, first class, postage prepaid, this 28th day of October, 1985, to:

Morton B. Margulies, Chairman Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Mr. Gustave A.

Linenberger Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Dr. Oscar H. Paris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Bernard M. Bordenick, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 i

Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.

20555 t

4.

Laurie Fowler Legal Environmental Assistance Foundation 218 Flora Avenue, N.E.

Atlanta, Georgia 30307 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Bradley Jones, Esquire Regional Counsel U.S. Nuclear Regulatory Commission Suite 3100 101 Marietta Street Atlanta, Georgia 30303 Richard P. Wilson, Esquire Assistant Attorney General Office of the Attorney General P.O.

Box 11549

Columbia, S.C.

29211 George F. Trowbridge, Esquire Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C.

20036 Ruble Thomas Vice President - Licensing Georgia Power Company /

Southern Company Service P.O.

Box 2625 Birmingham, AL 35202 Charles Whitney, Esquire Georgia Power Company P.O.

Box 289A, Route 2 Waynesboro, GA 30830 Lee S. Dewey, Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.

20555 James E. Joiner, Esquire Troutman, Sanders, Lockerman & Ashmore 127 Peachtree Street, N.W.

Suite 1400 l

Atlanta, GA 30043 l

. e D.O.

Foster Vice President /

Project General Manager Georgia Power Company P.O. Box 299A, Route 2 Waynesboro, GA 30830 Deppish Kirkland Consumers Utility Counsel 32 Peachtree Street, N.W.

Suite 225 Atlanta, GA 30303 lk J&

u TIM JOHNSON Campaign for a Prosperous Georgia 175 Trinity Avenue, S.W.

Atlanta, Georgia 30303 Georgians Against Nuclear Energy 1253 Lenox Circle Atlanta, Georgia 30306 Representative for Joint Intervenors s