Affidavit of Wc Gerstner Re Quality Rept Sys Functions. Confidentiality of Quality Repts Is Key to Effectiveness of Sys.Disclosure of Previously Submitted Repts Would Destroy Sys.Certificate of Svc EnclML20054E650 |
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Site: |
Clinton |
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Issue date: |
06/04/1982 |
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From: |
Gerstner W ILLINOIS POWER CO. |
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To: |
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Shared Package |
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ML20054E649 |
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References |
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ISSUANCES-OL, NUDOCS 8206140030 |
Download: ML20054E650 (10) |
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Category:AFFIDAVITS
MONTHYEARML20125B3021985-06-0606 June 1985 Affidavit of G Laroche Re Environ Conditions of Site,Berm Const & Site Stabilization.Prof Qualifications,Se Turk Notice of Appearance & Certificate of Svc Encl ML20071D5431983-03-0303 March 1983 Affidavit of J Foy Opposing Applicant Motion for Summary Disposition or for Continuance Pending Discovery.No Documents Produced Re Prairie Alliance 830128 Request. Certificate of Svc Encl.Related Correspondence ML20028E3861982-12-13013 December 1982 Affidavit of Wh Bruggeman.Ge Does Not Expect to Abandon Nuclear Business & Will Continue to Furnish Support & Expertise to BWR Owners.Fuel Svc Needs Will Be Served & Hardware Design Mods Will Be Made.Certificate of Svc Encl 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 ML20054E6501982-06-0404 June 1982 Affidavit of Wc Gerstner Re Quality Rept Sys Functions. Confidentiality of Quality Repts Is Key to Effectiveness of Sys.Disclosure of Previously Submitted Repts Would Destroy Sys.Certificate of Svc Encl 1985-06-06
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARU-602875, Comment Supporting Proposed Rule 10CFR50 Re Proposed Rule for Financial Assurance Requirements for Decommissioning Nuclear Power Reactors1997-11-21021 November 1997 Comment Supporting Proposed Rule 10CFR50 Re Proposed Rule for Financial Assurance Requirements for Decommissioning Nuclear Power Reactors U-602719, Comment Supporting Proposed Communication;Gl 97-XX, Assurance of Sufficient Net Positive Suction Head for ECCS & Containment Heat Removal Pumps1997-03-20020 March 1997 Comment Supporting Proposed Communication;Gl 97-XX, Assurance of Sufficient Net Positive Suction Head for ECCS & Containment Heat Removal Pumps ML20136F2841997-03-11011 March 1997 Memorandum & Order (Terminating Proceeding).* Grants Southwestern Electric Cooperative 970311 Motion to Terminate Proceeding & Dismisses 970228 Petition for Leave to Intervene.W/Certificate of Svc.Served on 970311 ML20136F3281997-03-0707 March 1997 Establishment of Atomic Safety & Licensing Board.* Board Being Established in Following Proceeding to Rule on Petitions for Leave to Intervene And/Or Requests for Hearings.Certificate of Svc Encl.Served on 970307 ML20136F3561997-02-28028 February 1997 Petition for Leave to Intervene of Southwestern Electric Cooperative,Inc.* Requests That Commission Grant Petition for Leave to Intervene & Grant Other Relief as Commission Deems Appropriate.W/Certificate of Svc U-602603, Comments on Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors1996-06-21021 June 1996 Comments on Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors U-602559, Comments on Proposed Rule 10CFR20 Re Unauthorized Use of Licensed Radioactive Matl.Proposes Changes to Wording of Pr1996-02-27027 February 1996 Comments on Proposed Rule 10CFR20 Re Unauthorized Use of Licensed Radioactive Matl.Proposes Changes to Wording of Pr U-602408, Comment Supporting NUMARC Comments on Proposed Rule 10CFR50 Re Plant Shutdown & Low Power Operations.Requests Addl Period for Public Comment Be Made Available1995-02-0101 February 1995 Comment Supporting NUMARC Comments on Proposed Rule 10CFR50 Re Plant Shutdown & Low Power Operations.Requests Addl Period for Public Comment Be Made Available ML20071N4861994-07-21021 July 1994 Comment Supporting Petition for Rulemaking PRM-50-59 Re Changing 10CFR50 & 73 for Frequency W/Which Licensee Conduct Independent Reviews & Audits of Safeguards Contingency Plan & Security Program from Every 12 Months to Every 24 Months ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process U-601930, Comment Opposing Draft Rev 1 to NUREG-1022, Event Reporting Sys - 10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting1992-01-30030 January 1992 Comment Opposing Draft Rev 1 to NUREG-1022, Event Reporting Sys - 10CFR50.72 & 50.73,Clarification of NRC Sys & Guidelines for Reporting JSP-860-90, Comment Opposing Proposed Rule 10CFR26 Re fitness-for-duty1990-10-30030 October 1990 Comment Opposing Proposed Rule 10CFR26 Re fitness-for-duty ML20043F9941990-06-0606 June 1990 Comment Supporting Petition for Rulemaking PRM-50-55, Coordinating Revs of FSAR W/Refueling Cycles.Approval of Rulemaking Change Would Provide for More Logical & Timely Basis for Incorporating Plant Procedure Changes in Future U-601249, Comment Supporting Proposed Rule 10CFR50 Re Nuclear Plant License Renewal (NUREG-1317)1988-10-21021 October 1988 Comment Supporting Proposed Rule 10CFR50 Re Nuclear Plant License Renewal (NUREG-1317) ML20204J3461988-10-20020 October 1988 Order Imposing Civil Monetory Penalty in Amount of $75,000. Violation a Occurred as Stated.For Violation C,Violation Most Appropriately Classified at Severity Level IV & Should Be Removed as Violation Supporting Civil Penalty ML20205Q9141988-10-20020 October 1988 Comment Opposing Proposed Rule 10CFR26 Re Commission Statement on Fitness for Duty of Nuclear Power Personnel. Commission Requested to Reconsider Efforts Prior to Issuing Final Rule 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 ML20196C5481988-06-0707 June 1988 Comment Supporting Proposed Rule 10CFR50 Re leak-before-break (LBB) Technology.Believes That Extension of LBB Technology to Performance Requirements for Emergency Core Cooling Sys Appropriate U-601050, Advises That Util Endorses BWR Owners Group 870820 Comments on Draft NUREG-1150, Reactor Risk Ref Document1987-09-30030 September 1987 Advises That Util Endorses BWR Owners Group 870820 Comments on Draft NUREG-1150, Reactor Risk Ref Document ML20206J2131987-04-10010 April 1987 Transcript of 870410 Public Meeting,Discussion/Possible Vote in Washington,Dc Re Full Power OL for Plant.Pp 1-73. Supporting Documentation Encl ML20135H3381985-09-11011 September 1985 Order Revoking CPPR-138 ML20133N7801985-08-0707 August 1985 Unexecuted Indemnity Agreement B-91 ML20129A8351985-07-11011 July 1985 Memorandum & Order Terminating Proceeding Per 850517 Motion on Grounds of Mootness.Requests ASLB Authorize NRR to Rescind CPPR-138.Served on 850712 ML20126F1611985-06-13013 June 1985 Memorandum & Order Directing Any Party Wishing to Examine Photographs to File Request W/Aslb by 850701.Photographs Deal w/850611 Memorandum & Order Requesting Addl Info on Unit 2 Excavation.Served on 850614 ML20126A0141985-06-11011 June 1985 Memorandum & Order Requiring NRC to Provide ASLB & Parties W/Photographs,Maps & Accompanying Explanations Referred to in G Laroche 850606 Affidavit Re Evacuation.Served on 850612 ML20126C3271985-06-11011 June 1985 Order Directing NRC Provide ASLB W/Photographs,Maps & Accompanying Explanations Referred to in 850606 Affidavit of Germain Laroche Addressing Environ Conditions of Excavation Site.Served on 850612 ML20125B3021985-06-0606 June 1985 Affidavit of G Laroche Re Environ Conditions of Site,Berm Const & Site Stabilization.Prof Qualifications,Se Turk Notice of Appearance & Certificate of Svc Encl ML20125B2631985-06-0606 June 1985 Response to Applicant 850517 Motion to Terminate Proceeding. No Opposition Offered,Subj to Two Listed Site Redress Conditions.G Laroche Affidavit Encl ML20128P7311985-06-0303 June 1985 Notice of Filing of Answer to Applicant Motion to Terminate Proceeding ML20128P7401985-05-29029 May 1985 Response to Applicant Motion to Terminate Proceeding.No Objections Offered.Method Applicant Proposed for Remediating Unit 2 Excavation Area Questioned.Certificate of Svc Encl ML20127G1901985-05-17017 May 1985 Motion to Terminate Proceeding,Due to 831018 Cancellation of Unit & 850409 Withdrawal of Application for OL & Request for Rescission of CPPR-138.All Stabilization Work Described in FSAR Completed.Certificate of Svc Encl ML20114D0281985-01-28028 January 1985 Notice of Filing of Joint Stipulation.Certificate of Svc Encl ML20114D0441985-01-28028 January 1985 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20099D2701984-11-15015 November 1984 Third Supplemental Response to State of Il First Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20099D2921984-11-15015 November 1984 Third Supplemental Response to State of Il Second Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20099D2561984-11-15015 November 1984 First Supplemental Response to Prairie Alliance First Round of Discovery.Certificate of Svc Encl.Related Correspondence ML20099C6261984-11-15015 November 1984 Supplemental Responses to Applicant Interrogatories Re Contentions 2 & 3.Certificate of Svc Encl.Related Correspondence ML20097G2291984-09-18018 September 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl. Related Correspondence ML20097G2071984-09-18018 September 1984 Notice of Change of Address & Telephone Number.Related Correspondence ML20098A3921984-09-11011 September 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20094P6621984-08-13013 August 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20090E5021984-06-28028 June 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20090E4831984-06-28028 June 1984 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20092J8221984-06-22022 June 1984 Notice of Withdrawal of Appearance in Proceeding.Certificate of Svc Encl ML20091R9621984-05-31031 May 1984 Notice Forwarding NRC Region III Re Independent Design Review.Certificate of Svc Encl.Related Correspondence ML20090L2101984-05-22022 May 1984 Notice of Appearance of SL Johnson.Certificate of Svc Encl ML20087P8451984-04-0404 April 1984 Second Supplemental Response to State of Il First Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20087P8201984-03-23023 March 1984 Second Supplemental Response to State of Il Second Set of Interrogatories.Certificate of Svc Encl.Related Correspondence ML20086T9881984-03-0202 March 1984 Notice of Filing of Joint Stipulation in OL Hearing ML20080Q4241983-10-0606 October 1983 Notice of Appearance in Proceeding.Certificate of Svc Encl 1997-03-07
[Table view] |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0hD!ISSION
'IN THE MATTER OF ILLINOIS )
POWER COMPANY, S0YLAND )
~ POWER COOPERATIVE, INC. and )
WESTERN ILLIN0IS POWER )
t COOPERATIVE, INC. )
- ) Docket No. 50-461 OL (Operating License for )
Clinton Power Station, Unit )
- 1) )
AFFIDAVIT e
STATE OF ILLINOIS )
) SS COUNTY OF MACON )
William C. Gerstner, being first duly sworn, upon oath deposes and says as follows:
- 1. I am an Executive Vice President of Illinois Power Company (" Illinois Power"), 500 South 27th Street, l Decatur, Illinois 62525.
- 2. My responsibilities as Executive Vice President of Illinois Power include the supervision of the construc-l tion and preparation for the future operation of the i
Clinton Power Station.
- 3. The management of Illinois Power believes that
.the most important factor in the construction of the 7
ClintonPowerStationistoinsurethataqualityplfnt is built. As part of Illinois Power's commitment to the EXHIBIT 1 8206140030 820600 PDR ADOCK 05000461 0 PDR
quality construction of the Clinton Power Station, I have assumed direct responsibility for Quality Assurance a,d n
~
. Quality Control at the Clinton Power Station. Since; February,1982, for exampic, the Director of Quality Assurance for Illinois Power has reported to me alone.
lie has no intermediate superiors.
- 4. Direct communication between the Quality Control inspectors at the Clinton Power Station and Illinois Power management is a vital method by which 1
Illinois Power insures the quality construction of the Clinton Power Station. I want the Quality Control inspectors, who are the individuals most responsibic for the quality construction of the Clinton Power
- Station since they perform the actual inspections, to feci free to come to me with any problems which they believe have not been adequately addressed.
- 5. To set up such direct communication, I met alone with Quality Control inspectors at the Clinton i
Power Station in February of this year. I told the l
Quality Control inspectors that all forms of direct l communication between themselves and me was to be in addition to,and not to supplant the other methods
,availabic for reporting problems to both management and
" to the Nuc1 car Regulatory Commission. I emphasized -
firmly to the Quality Control inspectors that they .
l
feel free to report cor.cerns to the Nuc1 car Regulatory Commission through the on-site inspector or otherwise.
I gave the Quality Control inspectors both my home an,d
,officephonenumbersandtoldthemtocallatanytihe with any problem. During this meeting, we discussed a system for implementing direct written communications.
In setting up this system, their primary concern was the confidentiality of any communications. To assure confiden-tiality, a Quality Report system was developed with the following features:
- a. Quality Control Report forms are
- available at various locations at the Clinton Power Station.
- b. An employee fills out a Quality Report form (which he or she may sign or submit anonymously) and deposits it in one of two locked boxes which are located in the field office building and in the plant.
- c. One particular Illinois Power employee unlocks the box and transmits the deposited Quality Reports to me. This employee was selected by the Quality
," Control inspectors.
- d. I personally review the submitted Quality Reports, investigate the ,
concerns raised, and implement whatever
I action is called for. I am the only Illinois Power employee who sees the contents of the Quality Reports.
- c. With respect to anonymously-submitted Quality Reports, where appropriate I prepare written responses to the reports which describe the actions taken and the reasons for such actions.
and have them posted at the Clinton Power Sc Ation. I respond in writing directly to the senders of signed reports.
- 6. Confidentiality of the Quality Reports is the key to the effectiveness of this reporting system. Any disclosure of the previously submitted Quality Reports and any required disclosure of future Quality Reports I believe would destroy this vital system. This is because the Quality Control inspectors would no longer feel secure that their comments were confidential.
- 7. One example of the paramount importance which the Qualicy Control inspectors place on confidenti-ality is that soon after the initiation of the Quality Reports, some Quality Control inspectors believed that there had been a leak in the system. This caused the submission of Quality Reports to cease. The submission
.of Quality Reports resumed only after my firm assurances that no leaks had occurred. _'
- 8. Quality Report forms are available to all employees at the Clinton Power Station. The employees arefreetoaddressanyconcerns,whetherrelatedtoI Consequently, many of ?
~
quality or not, on the forms.
'the submitted Quality Reports have not dealt with the quality of the construction of the Clinton Power Station.
Instead, they have dealt with personnel matters such as compensation for overtime. Some of the reports have contained personal allegations, not dealing with quality, against other employees. While Illinois Power is concerned with and investigates all allegations in such reports, to reveal these reports, however-restricted they might be, I believe would have not only a totally chilling effect on the system but potentially a serious adverse effect on individual employees.
- 9. Many of the submitted Quality Reports are almost indecipherable. This is because of the frequent use of acronyms specific to nuclear construction.
- 10. On behalf of the management of Illinois Power, I promised the Quality Control inspectors that submitted Quality Reports would be kept in strictest confidence.
This promise was made to assure the effectiveness of this tvital system of communication. I have permitted Sheldon
'LA . Zabel, counsel for Illinois Power, to examine the, Quality Reports in preparation for the Third Special: .
Prchearing Conference held in Champaign, Illinois on-May 4, 1982. Illinois Power will take whatever steps are necessary to insure the continued confidentiality of the s
Quality Reports. This would include discontinuing the
~
Quality Report system instead of compromising the integrity
~
of the system through disclosure of the Quality Reports already submitted.
- 11. The facts stated herein are within the personal knowledge of the affiant, who, if sworn as a witness, can and would testify competently to the facts herein set forth.
, .r. -: :
'_s ,1 y 'A h% ,[,(t ti;r William C. Gerstner Subscribed and Sworn to before me this 4th day of June , 1982.
?dui n me. 7h /dt//
v Notary Public My Commission expires:
January 16, 1983
me e
4
l 1
e CERTIFICATE OF SERVICE s
I hereby certify that an original and two -
- ?
conformed copies of the foregoing document were served upon the following:
Secretary of the C ommission United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Branch and that one copy of the foregoing document was served upon each of the following:
Hugh K. Clark, Esq., Chairman P. O. Box 127A Kennedyville, Maryland 21645 Dr. George A. Ferguson School of Engineering Howard University 2300 Sixth Street, N.W.
Washington, D.C. 20059 Dr. Oscar H. Paris Atomic Safety and Licensing Board U.Ss Nuclear Regulatory Commission Washington, D.C. 20555 Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C. 20555 Philip L. Willman Assistant Attorney General i Environmental Control Division 188 West Randolph Street Suite 2315 Chicag,, Illinois 60610
. Jan Kodner
. Tutt and Kodner _
173 W. Madison Street ,
Suite 1004 -
Chicago, Illinois 60602 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555
~.
4 4 Atomic Safety and Licensing Appeal Boafd Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 in each case by deposit in the United States Mail, pestage
. ~
prepaid on June 8, 1982.
~
nOne of the Atto s for Applicants
! Sheldon A. Zabel i William Van Susteran l Charles D. Fox, IV SCHIFF HARDIN 5 WAITE 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 (312) 876-1000 e
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'n -
, ,53
'IN THE MATTER OF ILLIN0IS )
POWER COMPANY, S0YLAND ) l ;a' POWER COOPERATIVE, INC. ) ;, p" and WESTERN ILLINOIS )
POWER COOPERATIVE, INC. ')
) Docket No. 50-461 OL (Operating License for )
Clinton Power Station )
Unit 1)
NOTICE 1
> TO:
i Hugh K. Clark, Esq., Cha'irman P. O. Box 127A Kennedyville, Maryland 21645 Dr. George A. Ferguson School of Engineering Howard University 2300 Sixth Street, N.W.
Washington, D.C. 20059 Dr. Oscar H, Paris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C. 20555 Philip L. Willman Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60610 f
Jan Kodner Tutt and Kodner hidd)
~
173 W. Madison Street Suite 1004 Chicago, Illinois 60602
Atomic Safety and Licensing Board Panel-U.S. Nuclear Regulatory Commission Washington, D.C. 20555 =_
. Atomic Safety and Licensing 4 Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 PLEASE TAKE NOTICE that I have filed with the Secretary of the United States Nuclear Regulatory Commission Applicants' SUPPLEMENT TO MOTION FOR A PROTECTIVE ORDER in the above-captioned matter. A c opy of this - document is attached hereto and hereby served upon you.
f&
ne of the Att eys for Applicants c;-
Sheldon A. Zabel William Van Susteran Charles D. Fox IV SCHIFF HARDIN 6 WAITE 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 (312) 876-1000 Dated: June 8, 1982
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