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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
[Table view] 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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. Attechment 6 AFFIDAVIT My name is Thomas Devine. I am the Legal Director of the I'
Government Accountability Project of the Institute for Policy Studies. I am preparing this affidavit for the Nuclear Regulatory Commission (NRC) Commissioners to summarize my September 19, 1983 discussion with Mr. Chuck Weaver about the summary of his inter- {
view in the Torrey Pines Report on the Zimmer Nuclear Power Station. On September 19, 1983 I spoke with Mr. Weaver for approximately one half hour to discuss whether his interview
'with Torrey Pines was reported fully and accurately in the report. Mr. Weaver had serious challenges to the completeness of his interview su= mary on page 8-5 of the Torrey Pines Report.
He agreed to provide an affidavit, but his phone has since been disconnected. On September 23 I sent him a draft affidavit pre-pared as a result of our discussion and will forward it to the Commission upon receipt.
Mr. Weaver informed me of the following issues which were not included in the summary of his interview: 1) Serious organi-zational weaknesses existed in the Quality Confirmation Program.
- 2) Ther.e was widespread use of In-Process Deficiency Inspection Reports (IIDR) as a substitute for Nonconformance Reports at Zimmer. He described the weaknesses in the IIDR system. 3) Level I quality assurance (QA)/ quality control (QC) personnel handled tk.e more difficult Level II assignments, without adequate super-vision. . 4) In many cases unqualified Level I personnel were ordered by supervisors to sign off on work or they would be __
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"sent down the road." 5) Structural steel was purchased on th basis of design sketches instead of approved Design Document Changes (DDC), because the DDC program was too far behind to be l utilized for the purchases. Inspectors were not ordered to challenge this improper practice. 6) Inspectors were restricted to limited work areas and ordered not to inspect or report de- i.
L ficiencies uncovered in any other location, even for a general surveillance. 7) There was a severe shortage of qualified managers and experienced inspectors. They , jokingly referred to the unqualified substitutes as " hamburger flippers." 8) Con-struction frequently overruled quality control inspectors' de-cisions. 9) There was no formal program, such as an open door policy, to engage in constructive dissent. 10) The function I of Cincinnati Gas and Electric (CG&E) inspectors in the dual inspection program appeared to be generation of statistics, rather than thorough verification of quality. Sometimes the CG&E inspectors literally were asleep and signed off on items without looking at them. On other occasions they wrote up irrelevant i
Nonconformance Reports to make it appear that problems had been identified, while ignoring serious safety violations. He informed l Torrey Pines of specific examples where this practice occurred, such as with hangers and in the primary containment. All of the l above practices occurred during the summer and early fall of 1982, when he was on-site as a QC inspector.
With respect to retaliation against himself, the holes in f
the Torrey. Pines report made it inaccurate. The version in the report is that " Weaver alleged reprisals only regarding reassignment l
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f of duties...." In reality, he informed me that he told Torrey P nes that Kaiser attempted to fire him on pretextual charges after learning that he had made disclosures of QA violations to in- ,
vestigators from the Federal Bureau of Investigation, the NRC and the Government Accountability Project. Until he received intensive support from those and other organizations, it' appeared that he was going to be dismissed. Even with all of these resources, he was put on " furlough" and prevented from working or even going on-site, although he continued to draw his salary.
When the NRC suspended construction, Mr. Weaver informed me l that he was laid off along with many other experienced inspectors who had challenged program violations and were aware of the most serious problems at Zimmer. Although the excuse was the shutdown order, the NRC had not stopped QA work. The fact that the excuse was not accurate was obvious, because simultaneous with the " layoffs" Kaiser was rehiring inexperienced personnel.
Mr. Weaver told me that he had discussed the above issues with Torrey Pines. There was no question in his mind that the Torrey Pines investigators understood what he was talking about.
I have read the above three page affidavit, and it is true, accurats and complete to the best of my knowledge and belief.
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Thomas Devine PHYLUS J. BODE Notary Public, State of ohio My Commissen Dgtres Oct.19.19M a
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