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Category:AFFIDAVITS
MONTHYEARML20064D1961994-03-0404 March 1994 Affidavit of Mj Angus Re Motion to Reopen Record ML20057B0261993-08-0909 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from INPO Rept Re Maint & Surveillance Activities at Plant ML20057B0271993-08-0505 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from INPO Re Maint & Surveillance Activities at Plant ML20057B0301993-08-0505 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from INPO Rept Re Maint & Surveillance of Activities at Plant ML20057B0221993-08-0404 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from INPO Rept Re Maint & Surveillance Activities at Plant ML20057B0181993-08-0404 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from Rept Prepared by INPO Re Maint & Surveillance Activities at Plant ML20045G9811993-06-30030 June 1993 Affidavit.* INPO Rept Should Not Be Disclosed Because San Luis Obispo Mothers for Peace Need for Document Do Not Outweigh Interests of Pg&E,Inpo & NRC & Public in Disclosure.W/Certificate of Svc ML20045G9821993-06-25025 June 1993 Affidavit.* Affidavit of Bw Giffin Re Info Contained in Util Response to Third Set of Supplemental Interrogatories & Requests for Production of Documents (Aging) Filed by San Luis Obispo Mothers for Peace ML20045G9901993-06-25025 June 1993 Affidavit.* Affidavit of Bw Giffin Re Info Contained in Util Supplemental Response to Second Set of Interrogatories & Requests for Production of Documents Filed by San Luis Obispo Mothers for Peace ML20045A7031993-05-26026 May 1993 Affidavit of Je Molden Re Util Response to Supplemental Interrogatories Re First Set of Interrogatories & Requests for Production of Documents (Cable Failures) ML20045A7041993-05-26026 May 1993 Affidavit of Je Molden Re Util Response to Miscellaneous Requests for Production of Documents ML20045G9931993-04-13013 April 1993 Affidavit.* Affidavit of Bw Giffin Re Info Contained in Util Response to Second Set of Interragotories & Request for Production of Documents Filed by San Luis Obispo Mothers for Peace ML20128B8341992-11-30030 November 1992 Affidavit of as Masciantonio in Support of NRC Staff Response to Mothers for Peace Suppl to Petition to Intervene.* W/Certificate of Svc ML20116F0631992-10-0707 October 1992 Affidavit of R Becker.* Concerns Re Safety of Plant Operation During Period of CP Recapture Expressed ML20116F0701992-10-0606 October 1992 Affidavit of Biesek.* Concerns Re Safety of Plant Operation During Period of CP Recapture Expressed. Encl ML20116F0361992-10-0606 October 1992 Affidavit of N Culver.* Affidavit Re Safety Concerns of Plant Operation During CP Recapture ML20116F0551992-10-0606 October 1992 Affidavit of E Holder.* Concerns Re Safety of Plant Operation During Period of CP Recapture Expressed ML20235S0091987-10-0202 October 1987 Affidavit of Jd Shiffer.* Explains Util Planned Expansion of Facility Spent Fuel Storage Capacity & Why Delay in Reracking Schedule,Such as Would Be Occassioned by Stay,Will Cause Substantial Harm to Util.Certificate of Svc List Encl ML20216J8641987-06-29029 June 1987 Declaration of Ef Lowry.* Tm Novak Board Notification 87-05 Re Draft BNL Rept Beyond Design-Basis Accidents in Spent Fuel Pools (Generic Issue 82) Received in Late Mar or Early Apr 1987.Proof of Svc Encl ML20216J8471987-06-26026 June 1987 Affidavit of SA Silver Informing That Draft BNL Rept, Beyond Design-Basis Accidents in Spent Fuel Pools (Generic Issue 82) Not Received ML20216J8371987-06-25025 June 1987 Affidavit of N Culver Informing That Board Notification 87-05 Re Draft BNL Rept on Spent Fuel Pool Accidents Never Received ML20216J8191987-06-25025 June 1987 Affidavit of RB Ferguson Re Notification of Generic Issue 82.* Board Notification 87-05 Re Generic Issue 82 Concerning Beyond design-basis Accidents in Spent Fuel Pools False & Misleading ML20213A0331987-01-13013 January 1987 Affidavit of Kp Singh Re Mothers for Peace & Sierra Club 861215 Motion for Summary Disposition Concerning Design of high-density Spent Fuel Racks.Racks Designed in Compliance W/Applicable NRC & SRP Requirements.Certificate of Svc Encl ML20205F6271986-08-15015 August 1986 Affidavit of Pw Niles Reporting Results of Calculations Performed on Postulated Hosgri Event Data ML20206J4201986-06-24024 June 1986 Affidavit of Rc Herrick on 860624 Re Intervenors 860616 Application for Stay & RB Ferguson Affidavit Re Proposed Reracking of Spent Fuel Storage Sys ML20206J4751986-06-24024 June 1986 Affidavit of Wl Brooks Re Intervenors 860616 Application for Stay & RB Ferguson 860616 Affidavit Re Expansion of Spent Fuel Pools.Certificate of Svc Encl ML20206D7501986-06-18018 June 1986 Affidavit of Jd Shiffer Re Proposal to Increase Spent Fuel Storage Capacity,Approved by NRC on 860530.Intervenor Risk Allegations Refuted.W/Certificate of Svc ML20199D1271986-06-15015 June 1986 Affidavit of RB Ferguson Concluding That Spent Fuel Reracking at Facilities Presents Significant Safety Hazard to Surrounding Environ & Population & Poses Risk of Irreversible Contamination ML20099H6491985-03-0505 March 1985 Affidavit of a Jackson Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Technical & Safety Significance of Issues Raised in 841115 Affidavit Re Flud Computer Program.Errors in Program May Lead to 100% Inaccurate Predictions ML20099H6261985-03-0404 March 1985 Affidavit of L Kinney Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Charges of Matl False Statements by Util in Response to Allegations Jir 75-78 & 80 ML20099H6061985-02-24024 February 1985 Anonymous Affidavit Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Concern Over NRC Response to 841127 Disclosure of Significant Engineering Errors & QA Violations in Design of Pipe Supports ML20099H7281985-02-22022 February 1985 Affidavit of Tj O'Neill Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Matl Licensing Issues Resolved by NRC on Basis of False Statements & Omissions.Failure of Diablo Canyon Allegation Mgt Program Described.New Info Encl ML20099H5021985-02-0606 February 1985 Anonymous Affidavit Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Deficiencies W/Engineering Practices on Large Bore Piping & Pipe Supports ML20099H5591985-02-0404 February 1985 Anonymous Affidavit Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re QA Problems in Drafting Dept,Hardware Deficiencies,Mgt Opposition to Reporting Deficiencies to QA & Failure to Follow Engineering Specs ML20099H7751985-01-23023 January 1985 Affidavit of Mc Thompson Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Addl Concerns on Issues Examined in 850108 Interview.Supporting Documentation Encl ML20099H5741985-01-23023 January 1985 Affidavit of Ho Hudson Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Deficiencies in Cardinal Industrial Products Qa.Corrective Actions Did Not Address Matls Previously Installed.Supporting Documents Encl ML20099H5271985-01-22022 January 1985 Affidavit of P Haffey Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Allegations of Misconducting by Region V & of Util Matl False Statements Concerning Previous Allegations ML20099H6631985-01-21021 January 1985 Affidavit of Jl Mcdermott Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re NRC Mishandling of Previous Allegations.Fifteen New Allegations Listed ML20099H7541985-01-18018 January 1985 Affidavit of CC Stokes Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Failure of NRC to Honor Rules of Allegation Mgt Program & Matl False Statements by Util in Response to Previous Allegations ML20107C4871984-11-0101 November 1984 Affidavit of Tm Devine Re Employee Concerns That Reactor Vessel Level Instrumentation Sys May Not Provide Reliable Readings ML20107C5011984-10-29029 October 1984 Affidavit of Lockert Re Const Qa,Licensee Character & Competence ML20107C4751984-10-22022 October 1984 Marked-up Affidavit of Mc Thompson Re Possible Fake Welds on Stanchions Holding Up Safety Injection Sys Lines in Unit 1 ML20098F9381984-10-0101 October 1984 Affidavit of Mj Jacobson & Tg De Uriarte,Signed Only by Tg De Uriarte,Re QA Program.Certificate of Svc Encl ML20093N2341984-07-30030 July 1984 Affidavit of Jl Mcdermott Re Need for Reinsps & Systematic Retraining of All Personnel at Facility ML20093K0621984-07-27027 July 1984 Affidavit of Dh Hamilton Re Location & Subsurface Geometry of Hosgri Fault & Tectonic Deformation in Region of Fault ML20093K0811984-07-27027 July 1984 Affidavit of Wh White Re Hosgri Fault Design Bases. Certificate of Svc Encl ML20093K0691984-07-26026 July 1984 Affidavit of SW Smith Re Regional Seismicity & Morgan Hill Earthquake ML20093J3481984-07-24024 July 1984 Affidavit of DG Bridenbaugh,Restating 810811 Affidavit Re Potential Hazards of built-up Fission Products Release. Certificate of Svc Encl ML20090A8501984-07-11011 July 1984 Affidavit of T Devine Notifying of Resignation of I Yin from Review Team Overseeing Plant Readiness for Commercial Operation ML20092B6621984-06-19019 June 1984 Affidavit of DA Rockwell Re Allegations of Mgt Harassment. Related Correspondence 1994-03-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARDCL-99-123, Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations1999-09-20020 September 1999 Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations ML20205N4081999-04-14014 April 1999 Comments Opposing Proposed Rules 10CFR2,19 & 20 Re Proposed Repository at Yucca Mountain.Requests Information on How Much Radiation Being Released Now at Diablo & Hanford NPPs ML20205N4601999-03-21021 March 1999 Introduces K Schumann as Representative of Nuclear Waste Committee (Nuwic) of San Lius Obispo County.Informs That Nuwic & Nuclear Waste Management Committee Concerned with Transportation of Spent Nuclear Fuel Rods from Dcnpp ML20195E8841998-11-24024 November 1998 Petition for Mod to OLs to Require Plant Owner to Have Independent Contractor Evaluate Plant Safety Culture ML20236T3011998-07-24024 July 1998 Order Prohibiting Involvement in NRC Licensed Avtivities (Effective Immediately).Lh Brooks Prohibited for 5 Yrs from Date of Order from Engaging in NRC Licensed Activities ML20248C2261998-05-22022 May 1998 Comment Opposing Revised Proposed Rule 10CFR50 Re Protection & Safety Sys ML20129J4191996-10-18018 October 1996 Order Approving Application Re Corporate Restructuring of Pacific Gas & Electric Company by Establishment of Holding Company DCL-95-206, Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations1995-10-0606 October 1995 Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations ML20091P8721995-08-23023 August 1995 Comment Opposing Petition for Rulemaking PRM-50-61 Re Nuclear Energy Institute Proposed Amends on Fire Safety for All NPPs DCL-95-001, Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments1995-01-0303 January 1995 Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments ML20077M7521994-12-30030 December 1994 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operation for Nuclear Power Reactors DCL-94-270, Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal1994-12-0808 December 1994 Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal ML20149H0851994-11-0404 November 1994 Initial Decision (Construction Period Recovery/Recapture).* Renewed Motion to Reopen Record 940808,denied.Served on 941104.W/Certificate of Svc ML20072L2651994-08-23023 August 1994 PG&E Opposition to San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record.* Util Opposes San Luis Obispo for Peace Motion Based on Affidavit Stating No Evidence Found in Motion Re Flaw in Program.W/Certificate of Svc ML20072F0291994-08-12012 August 1994 Erratum to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Intervenors Corrects Error in Renewed Motion to Reopen Record Re Application for License Amend to Extend Term of Operating License for Plant.W/Certificate of Svc ML20072B2651994-08-0909 August 1994 Comment Supporting Proposed Rule 10CFR26 Re FFD Requirements Concerning Random Drug Testing ML20072A5821994-08-0808 August 1994 San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record Re PG&E Application for Amend to Extend Term of OL for Plant.* Motion to Reopen Record to Introduce Insp Rept Identifying Alleged Problems W/Plant.W/Certificate of Svc ML20071L2061994-07-26026 July 1994 Comment Supporting Proposed Rule 10CFR26 Re Changing Current Drug Testing Policies to Exclude All Personnel in nonsafety-related Positions ML20072B8481994-07-26026 July 1994 Comment Opposing Proposed Rule 10CFR26 Re Changes to FFD Requirements Concerning Random Drug Testing ML20071L1901994-07-20020 July 1994 Comments on Proposed Rule 10CFR26 Re Relaxing Rule on Drug Testing of Employees Working at NPP DCL-94-134, Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program DCL-94-135, Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs ML20064D1791994-03-0707 March 1994 Pacific Gas and Electric Co Reply in Opposition to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Motion to Reopen Record Denied.W/Certificate of Svc ML20064D1961994-03-0404 March 1994 Affidavit of Mj Angus Re Motion to Reopen Record ML20063L5721994-02-25025 February 1994 San Luis Obispo Mothers for Peace Re Util Application for License Amend to Extend Term of Operating License for Plant.* Advises That Record of Proceeding Should Be Reopened to Consider Insp 93-36 Re Util Surveillance of Asw Sys DCL-94-021, Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation1994-01-26026 January 1994 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation ML20059D2431994-01-0707 January 1994 Package of Intervenor Exhibits Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20062N0001993-12-30030 December 1993 PG&E Reply Findings of Fact & Conclusions of Law.* Mothers for Peace Proposed Findings & Conclusions Do Not Provide Any Supportable Rationale to Change Findings & Conclusions Previously Proposed by Pg&E.W/Certificate of Svc ML20058P3931993-12-22022 December 1993 NRC Staff Findings of Fact & Conclusions of Law in Form of Initial Decision.* Certificate of Svc ML20058K7491993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Board Has Extended Filing Time for Util Until 931230.W/Certificate of Svc. Served on 931206.Granted for Board on 931203 ML20058K8771993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Requests That Board Extend Date for Staff to File Findings Until 931222. W/Certificate of Svc ML20059M5291993-11-19019 November 1993 Applicant Exhibits A-21,A-22,A-24,A-25,A-26,A-29 & A-F1, Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20058E0741993-11-19019 November 1993 San Luis Obispo Mothers for Peace Proposed Findings of Fact & Conclusions of Law Re Licensee Application for License Amend to Extend Term of Operating License for Plant.* W/ Certificate of Svc ML20059E8931993-10-28028 October 1993 Memorandum & Order (Motion for Extension of Time).* San Luis Obispo Mothers for Peace 931018 Request for two-wk Extension of Time to File Proposed Findings of Fact & Conclusions of Law Granted.W/Certificate of Svc.Served on 931029 ML20059E8531993-10-27027 October 1993 NRC Staff Response to Board Memorandum & Order Re Extension of Time.* Staff Believes That San Luis Obispo Mothers for Peace Has Shown No Good Cause for Requesting Extension to File Proposed Findings of Fact.W/Certificate of Svc ML20059E8631993-10-25025 October 1993 Pacific Gas & Electric Co Response to Motion for Extension of Time.* Util Does Not Agree W/Board Assessment That Mothers for Peace Request Appears to Be Reasonable But Will Not Oppose Request.W/Certificate of Svc ML20059B2191993-10-19019 October 1993 Memorandum & Order (Responses to Motion for Extension of Time).* Board Believes Intervenor Request for Extension of Time to File Proposed Findings of Fact Appears Reasonable. W/Certificate of Svc.Served on 931019 ML20059B1071993-10-18018 October 1993 San Luis Obispo Mothers for Peace Motion for Extension of Time for Filing Proposing Findings of Fact & Conclusions of Law.* Requests Extension of Two Wks or Until 931119 to File Proposed Findings of Fact.W/Certificate of Svc ML20057D0531993-09-23023 September 1993 Notice of Appearance.* Notice Given That Undersigned Attorney Enters Appearance in Listed Matter & Listed Info Provided.W/Certificate of Svc ML20057B0401993-09-14014 September 1993 NRC Staff Reply to PG&E Response to Staff Motion to Amend Protective Order.* NRC Staff Moves Board to Adopt Language Requested in 930817 Motion as Stated.W/Certificate of Svc ML20056G4891993-08-30030 August 1993 Pacific Gas & Electric Co Response to Motion to Amend Protective Order.* Staff Asks That Protective Order Be Clarified by Adding New Footnote to Paragraph 3 of Order. W/Certificate of Svc ML20059M1381993-08-24024 August 1993 Staff Exhibit S-1,consisting of Re 920519 Enforcement Conference ML20059D2071993-08-24024 August 1993 Intervenor Exhibit I-MFP-193,consisting of Review of LER 1-90-015-00,re Docket 50-275,dtd 910118 ML20059D2241993-08-24024 August 1993 Intervenor Exhibit I-MFP-220,consisting of Protest of Util ML20059M8621993-08-24024 August 1993 Intervenor Exhibit I-MFP-35,consisting of Rept, Self- Evaluation of Diablo Canyon Power Plant, Dtd Jul 1993 IR 05000275/19920261993-08-24024 August 1993 Intervenor Exhibit I-MFP-118,consisting of Notice of Violation & Insp Rept Re Docket 50-275/92-26 & 50-323/93-26,dtd 921113 ML20059D0841993-08-24024 August 1993 Intervenor Exhibit I-MFP-139,consisting of Insp Rept Re Dockets 50-275 & 50-323,dtd 920417 IR 05000275/19920131993-08-24024 August 1993 Intervenor Exhibit I-MFP-140,consisting of 920416,mgt Meeting Repts 50-275/92-13 & 50-323/92-13 IR 05000275/19910061993-08-24024 August 1993 Intervenor Exhibit I-MFP-71,consisting of Rept of EC W/Util Mgt,Re Rept Numbers 50-275/91-06 & 50-323/91-06,dtd 910411 IR 05000275/19930111993-08-24024 August 1993 Intervenor Exhibit I-MFP-26,consisting of Re Insp Repts 50-275/93-11 & 50-323/93-11 1999-09-20
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UNITED STATES OF AERICA NUCLEAR REGULATORY ComISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD i
In the Matter of ) Docket Nos. 50-275 l
) 50-323 PACIFIC GAS AND ELECTRIC C0WANY )
) (Design Quality Assurance)
(Otablo Canyon Nuclear Power )
Psant, Units 1 and 2)
AFFIDAVIT OF HOWARD B. FRIEND STATE OF CALIFORNIA )
i
) ss. '
CITY AND COUNTY OF SAN )
FRA4 ISCO )
I The above being duly sworn, deposes and says:
- 1. I, Howard B. Friend, am P oject Completion Manager for the Diablo Canyon Project. I am thoroughly familiar with the contract between Bechtel Power Corporation and Pacific Gas and Electric Company covering the work to be perfomed by Bechtel to complete the Diablo Canyon Plant.
i
- 2. During the course of his meeting with menbers of the NRC Staff on January 25, 1984, Mr. Charles Stokes clieged that the contract Bechtel has with PGandE is a lump sum contract (Tr. at 22). This is not true.
t The PGAE/8echtel contract is a cost plus contract. That is, direct costs and expenses incurred by Bechtel in the perfomance of services are i reimbursed at cost. The indirect costs incurred by Bechtel are recovered by // !
//
//
0
l adding a percentage to the direct payroll costs. This is known at "an I allowance for indirect costs." There is also provision for a fee. .
Dated: Ma ch 5,1984 HOWARD B. FRIEND /
Subscribed and sworn to /
before me this 5th day of March,1984.
m
. n g
9tancy J. Linnaster v SEAL Notary Public in and for the City and County of San Francisco, State of California.
% comission expires April 14,1986.
h,:xxxxxxxxxxxxxxxwxxxxmxxxx g, NANCY J. LEMASTER -
- 8. J.f'4,\ NOTARY PUBLIC. cat lFORNIA a . i t.- CITY AND COUNTY OF .
O SAN GANCISCO y Cominission Expres Aptd 14.1986 gyyyy y n. ..n... ..yo y y, 1
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