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Category:AFFIDAVITS
MONTHYEARML20058B6891993-05-0707 May 1993 Affidavit of RP Barkhurst to File W/Nrc Encl TS Change Request NPF-38-135 ML20137J2941985-08-21021 August 1985 Affidavit of Kw Cook Re Recent Equipment Failures Discussed in Joint Intervenors 850809 Petition for Review.Certificate of Svc Encl ML20112A9381985-03-14014 March 1985 Affidavit of RP Barkhurst Re Power Ascension Testing Program Performed at Levels Above 5% Rated Power & Delay in Issuance of Full Power Operating Authority.Related Correspondence ML20111C7021985-03-14014 March 1985 Affidavit of RP Barkhurst Re Power Ascension Testing Program to Be Performed at Levels Above 5% of Rated Power.Facility & Operating Staff in Excellent State of Readiness to Proceed W/Power Ascension ML20195F5871985-02-25025 February 1985 Affidavit of Rk Kerr Re 841120 Meeting W/Cain,Dd Driskill, R Barkhurst,Admiral Williams & Rs Leddick to Discuss Licensee 1983 Drug Investigation 05-001-83(966) & 841206 Meeting Between Licensee & NRC in Arlington,Tx ML20112B3291985-01-0707 January 1985 Affidavit of Jl Ehasz Supporting Conclusion That Cracks Do Not Significantly Affect Structural Adequacy of Facility Basemat.Related Correspondence ML20112B3411985-01-0404 January 1985 Affidavit of Mj Holley Supporting Conclusion That Cracks Do Not Significantly Affect Structural Adequacy of Facility Basemat.Related Correspondence ML20112B3581985-01-0303 January 1985 Affidavit of Rf Burski Supporting Conclusion That Cracks Do Not Significantly Affect Structural Adequacy of Facility Basemat.Certificate of Svc Encl.Related Correspondence ML20112B3471985-01-0303 January 1985 Affidavit of Kw Cook Supporting Conclusion That Cracks Do Not Significantly Affect Structural Adequacy of Facility Basemat.Related Correspondence ML20140D8301984-12-17017 December 1984 Supplemental Affidavit of DM Crutchfield in Response to Questions Raised in Aslab 841002 Memorandum & Order ALAB-786 Re Basemat Issues.Related Correspondence ML20140D8451984-12-17017 December 1984 Supplemental Affidavit of Re Shewmaker in Response to Questions Raised in Aslab 841002 Memorandum & Order ALAB-786 Re Conclusions Reached by Civil/Structural Allegation Review Team Concerning Basemat Issues.Related Correspondence ML20140D8811984-12-17017 December 1984 Supplemental Affidavit of R Pichumani Re Basemat Issues. Related Correspondence ML20140D9441984-12-17017 December 1984 Supplemental Affidavit of Jp Knight Re Basemat Issues. Related Correspondence ML20140D9621984-12-17017 December 1984 Affidavit of M Reich,Ca Miller & Cj Constantino Re Safety Significance of Concrete Cracking Observed in Foundation Basemat.Supporting Documentation Encl.Related Correspondence ML20140D9121984-12-12012 December 1984 Affidavit of Js Ma in Response to Request in Aslab 841002 Memorandum & Order ALAB-786 for Update on Affiant Views Re Cracking of Basemat.Supporting Documentation Encl.Related Correspondence ML20195F5231984-12-0707 December 1984 Affidavit of Rd Martin Re Meeting Between Region IV & Licensee at Region Ofc on 841206 to Discuss Licensee Corrective Actions on Investigation of Drug Use by Facility Reactor Operators That Licensee Initiated in May 1983 ML20195F5611984-12-0606 December 1984 Affidavit of Rs Leddick Re Licensee Investigation of Alleged Marijuana Use by Facility Reactor Operators.Ack Knowledge of Licensee Investigative Rept 5-001-83(966) in Nov 1984.W/ Initialed Handwritten Changes ML20195F4551984-12-0505 December 1984 Affidavit of W Cavanaugh Re Investigation of Alleged Drug Use by Reactor Operators at Facility.States That Continuation of Investigation Delayed Until After Operator Licensing Exam ML20195F4201984-11-20020 November 1984 Affidavit of Jm Cain Re Facility Policy About Drug Use by Employees & Licensee Investigation Rept 5-001-83(966) on Drug Usage by Reactor Operators ML20195F4021984-11-20020 November 1984 Affidavit of Wc Nelson Re Licensee Investigation of Drug Use by Facility Reactor Operators.Affirms Suspension of Subj Investigation Until After 830712 Because Investigation Adding Stress to Preparation for NRC Licensing Exam ML20107K6781984-11-0505 November 1984 Affidavit of Tm Devine Re Desire of Three Witnesses Who Signed Affidavits to Keep Identities Confidential ML20096B5691984-08-0606 August 1984 Affidavit of M Reich,Ca Miller & Cj Constantino Re Safety Significance of Concrete Cracking in Foundation Base Mat. Prof Qualifications & Addendum to BNL Review of Facility Base Mat Analysis Encl.Related Correspondence ML20079F3401984-01-12012 January 1984 Affidavit of Tf Gerrets Re Allegations of Missing & Phony QA Documentation & Forged Signatures on Safety Insps ML20080M6761983-09-27027 September 1983 Affidavit of Jl Ehasz Supporting Util Opposition to Joint Intervenors Motion to Reopen on safety-related Concrete. Cracks Expected to Form in Concrete Mat,Enabling Transfer of Tensile Load from Concrete to Embedded Steel ML20080M6941983-09-27027 September 1983 Affidavit of Wf Gundaker Supporting Util Opposition to Joint Intervenors Motion to Reopen Record on safety-related Concrete.Corrosion of Reinforcing Steel in Concrete Mat Will Not Occur to Significant Degree.Certificate of Svc Encl ML20028F1721983-01-26026 January 1983 Affidavit of s Duplessis on Brochure, Plans to Help You During Emergencies. Individuals W/Sixth Grade Reading Skills Can Read Brochure,But Brochure Is Poorly Organized ML20028G2201983-01-26026 January 1983 Affidavit of El Duncan Re Emergency Info Brochure.Brochure Violates Keep It Simple Stupid Principle. Method of Brochure Distribution Faulty.Certificate of Svc Encl.Related Correspondence ML20083N0831983-01-24024 January 1983 Affidavit of El Duncan Re Emergency Info Brochure.Brochure Violates Keep It Simple Stupid Principle.Both Maps Deficient as Presented.Brochure Fails to Speak Directly to Educ Level of Affected Persons ML20063N2691982-09-14014 September 1982 Affidavit of Deplessis.Only Small Segment of Population in Parishes Will Be Able to Read Info Brochure w/75% Comprehension.Prof Qualifications & Certificate of Svc Encl ML20063N2581982-09-11011 September 1982 Affidavit of El Duncan Re Emergency Info Brochure.Brochure Shows No Understanding of Target Population or Subgroups within Target Population.Method of Distributing Brochure Is Faulty ML20063N2641982-09-11011 September 1982 Affidavit of P Winograd Re Document on Plans to Aid Area Residents During Emergencies.Readability of Document Works Out to Be First Yr College Matl.Format Makes Vital Info Hard to Locate.Prof Qualifications Encl ML20063D1971982-06-30030 June 1982 Affidavit Requesting Certain Info Contained in Encl CEN-207(C)-P,CEN-208(C)-P & CEN-249(C)-P Be Withheld Per 10CFR2.790 ML20052G9481982-05-13013 May 1982 Affidavit of Rg Azzarello Answering ASLB Questions.Upon Initiation of Total Loss of Feedwater,Remaining Steam Generator Water Inventory Would Allow Approx 10-15 Minutes Before Dryout Condition Would Occur 1993-05-07
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20116G9431996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re, Mods to Fitness-For-Duty Program Requirements 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 ML20086D8841995-06-29029 June 1995 Comments on Proposed Rule Re, Review of NRC Insp Rept Content,Format & Style ML20085E5891995-06-0909 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control ML20080A1331994-10-21021 October 1994 Comment Supporting Proposed Rule 10CFR2 Re Reexamination of NRC Enforcement Policy.Advises That Util of Belief That NRC Focus on Safety Significance in Insps & Enforcement Policy Can Be Achieved by Utilization of Risk Based Techniques ML20073M3261994-10-0303 October 1994 Comment on Pilot Program for NRC Recognition of Good Performance by Nuclear Power Plants ML20072B8521994-08-0505 August 1994 Comment Opposing Proposed Rule 10CFR26 Re Consideration of Changes to FFD Requirements.Licensee Believes Reduction in Amount of FFD Testing Warranted & Can Best Be Achieved in Manner Already Adopted by Commission ML20065P4121994-04-25025 April 1994 Comment on Proposed Rule 10CFR50 Rule Re Code & Stds Re Subsections IWE & Iwl.Expresses Deep Concern About Ramifications of Implementing Proposed Rule ML20058G6211993-12-0606 December 1993 Comment on Draft NUREG/BR-0058, Regulatory Analysis Guidelines,Rev 2. Concurs W/Numarc & Nubarg Comments ML20056F3481993-08-23023 August 1993 Comment Opposing NRC Draft GL 89-10,suppl 6 ML20058B6891993-05-0707 May 1993 Affidavit of RP Barkhurst to File W/Nrc Encl TS Change Request NPF-38-135 ML20058E0251990-10-12012 October 1990 Comment Supporting Proposed Rule 10CFR51 Re Renewal of Nuclear Plant OLs & NRC Intent to Prepare Generic EIS ML20055E9871990-06-29029 June 1990 Comment Opposing Proposed Rule 10CFR55 Re Mod for fitness-for-duty Programs & Licensed Operators.Util Believes That High Stds of Conduct Will Continue to Be Best Achieved & Maintained by Program That Addresses Integrity ML19353B2241989-12-0101 December 1989 Comments on Draft Reg Guide,Task DG-1001, Maint Programs for Nuclear Power Plants. Util Endorses NUMARC Comments W3P89-0196, Comment Opposing Proposed Rule 10CFR50 Re Maint Programs at Nuclear Plants.Proposed Rule Would Require Establishment of Maint Programs Based on Reg Guides That Have Not Been Developed,Proposed or Approved1989-02-28028 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Maint Programs at Nuclear Plants.Proposed Rule Would Require Establishment of Maint Programs Based on Reg Guides That Have Not Been Developed,Proposed or Approved ML20235V4571989-02-27027 February 1989 Comment Supporting Proposed Chapter 1 Re Policy Statement on Exemption from Regulatory Control.Agrees W/Recommendations & Limits Proposed by Health Physics Society in L Taylor Ltr to Commission ML20205P9691988-10-26026 October 1988 Comment Supporting Proposed Rule 10CFR50 Re NUREG-1317, Regulatory Options for Nuclear License Renewal. Supports Contents of NUREG-1317 & Endorses NUMARC Comments on Rulemaking & Position Paper by NUMARC Nuplex Working Group W3P88-1366, Comment Supporting Proposed Rule 10CFR50 Conserning Policy Statement Re Cooperation W/States at Commercial Nuclear Power Plants or Utilization Facilities1988-07-13013 July 1988 Comment Supporting Proposed Rule 10CFR50 Conserning Policy Statement Re Cooperation W/States at Commercial Nuclear Power Plants or Utilization Facilities ML20135F0931987-04-0909 April 1987 Testimony of Bb Hayes Before Senate Government Governmental Affairs Committee on 870326 Re Discovery of Sensitive NRC Document in Files of Senior Official of Louisiana Power & Light Co ML20212N5781986-08-27027 August 1986 Order Imposing Civil Monetary Penalty in Amount of $50,000 Based on Violations Noted in Insp Conducted on 860101-31. Violation Noted:Plant Entered Mode 3 While Relying on Action Requirements of Tech Spec 3.6.2.1 ML20202G3811986-04-10010 April 1986 Order Imposing Civil Penalties in Amount of $130,000,based on Safety Insps of Licensee Activities Under CPPR-103 Conducted from June 1983 - Sept 1985.Supporting Documentation Encl ML20210B9141986-02-0505 February 1986 Notice of Publication of Encl 841219 Order.Served on 860206 ML20198H4461986-01-30030 January 1986 Memorandum & Order CLI-86-01 Denying Remaining Portion of Joint Intervenors 841108 Fifth & Final Motion to Reopen Record Re Character & Competence of Util Per 850711 Decision ALAB-812.Dissenting View of Palladino Encl.Served on 860130 ML20137J3531986-01-17017 January 1986 Order Extending Time Until 860214 for Commission to Act to Review ALAB-812.Served on 860117 ML20138P5301985-12-20020 December 1985 Order Extending Time Until 860117 for Commission to Review ALAB-812.Served on 851220 ML20137U4821985-12-0505 December 1985 Order Extending Time Until 851220 for Commission to Act to Review ALAB-812.Served on 851205 ML20138S0051985-11-15015 November 1985 Order Extending Time Until 851206 for Commission to Review ALAB-812.Served on 851115 ML20138H2451985-10-24024 October 1985 Order Extending Time Until 851115 for Commission to Act to Review ALAB-812.Served on 851024 ML20133F2711985-10-0404 October 1985 Order Extending Time Until 851025 for Commission to Act to Review ALAB-812 .Served on 851007 ML20134L5981985-08-28028 August 1985 Notice of Appearance of R Guild & Withdrawal of Appearance by L Bernabei & G Shohet for Joint Intervenors.Certificate of Svc Encl ML20137J2801985-08-26026 August 1985 Answer in Opposition to Joint Intervenors 850809 Petition for Commission Review of Aslab 850711 Decision ALAB-812, Which Denied Joint Intervenors 841108 Motion to Reopen Record.Kw Cook 850821 Affidavit Encl ML20137J2941985-08-21021 August 1985 Affidavit of Kw Cook Re Recent Equipment Failures Discussed in Joint Intervenors 850809 Petition for Review.Certificate of Svc Encl ML20136J1961985-08-19019 August 1985 Answer Requesting That Commission Deny Joint Intervenors 850809 Petition for Review of ALAB-812 Denying Motion to Reopen QA & Character Competence Issues.Certificate of Svc Encl ML20133L8901985-08-0909 August 1985 Petition for Review of ALAB-812,denying Joint Intervenor Motion to Reopen Record of OL Hearing to Litigate Util Lack of Character & Inability to Assure Safe Operation in Light of Const QA Breakdown.Certificate of Svc Encl ML20133L0421985-08-0808 August 1985 Order Extending Time Until 850920 for Commission to Act to Review ALAB-812.Served on 850808 ML20128Q1861985-07-23023 July 1985 Request for Extension of Time Until 850809 to File Appeal to 850711 ALAB-812 Denying Joint Intervenors Motion to Reopen Record.Certificate of Svc Encl ML20209F1921985-07-11011 July 1985 Decision ALAB-812 Denying Joint Intervenors 841108 Motion to Reopen Record on Const QA & Mgt Character & Competence, Except Insofar as Issues Re Matters Under Investigation by Ofc of Investigation Are Raised.Served on 850711 ML20116P1931985-05-0606 May 1985 Response to NRC & Util Responses to Aslab 850322 Memorandum & Order ALAB-801.Motion to Reopen Record of Licensing Proceedings for Litigation of Util Competence Should Be Granted.Supporting Documentation & Svc List Encl ML20116H3341985-04-30030 April 1985 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20100K3221985-04-10010 April 1985 Supplementary Comments Attesting to Validity of Statements of Fact in Sser 9 & Clarifying & Explaining Current Position on Resolution of Allegation A-48.Util Can Safely Operate & Manage Facility.Certificate of Svc Encl ML20111C7021985-03-14014 March 1985 Affidavit of RP Barkhurst Re Power Ascension Testing Program to Be Performed at Levels Above 5% of Rated Power.Facility & Operating Staff in Excellent State of Readiness to Proceed W/Power Ascension ML20112A9381985-03-14014 March 1985 Affidavit of RP Barkhurst Re Power Ascension Testing Program Performed at Levels Above 5% Rated Power & Delay in Issuance of Full Power Operating Authority.Related Correspondence ML20111B6541985-03-12012 March 1985 Motion for Leave to File Reply to Applicant Answer to Joint Intervenors Motion for Leave to File Supplemental Memorandum & Applicant Response to Supplemental Memorandum.Svc List Encl ML20102C1351985-02-28028 February 1985 Response Opposing Joint Intervenors 850225 Motion for Leave to File Supplemental Memorandum & Response to Suppl.Suppl Untimely Filed.Allegations Unsupported.Certificate of Svc Encl ML20195F5871985-02-25025 February 1985 Affidavit of Rk Kerr Re 841120 Meeting W/Cain,Dd Driskill, R Barkhurst,Admiral Williams & Rs Leddick to Discuss Licensee 1983 Drug Investigation 05-001-83(966) & 841206 Meeting Between Licensee & NRC in Arlington,Tx ML20107M7461985-02-25025 February 1985 Supplemental Memorandum in Support of Joint Intervenors Motion to Reopen.Determination by Aslab That Joint Intervenors Met Burden to Reopen Record for Litigation of Contention That Util Mgt Lacks Competence Requested ML20107M7321985-02-25025 February 1985 Motion for Leave to File Supplemental Memorandum in Support of Motions to Reopen.Request Based on Recent Public Repts Re Instability & Lack of Independence of Mgt of Applicant & Lack of Respect for NRC ML20101T3701985-02-0101 February 1985 Answer Opposing Joint Intervenors 850125 Motion for Leave to File Reply to Applicant 841130 & Staff 841221 Answers.Motion Should Be Denied & Reply Brief Rejected.Certificate of Svc Encl ML20101U3411985-01-25025 January 1985 Joint Intervenors Motion for Leave to File Reply to Applicant & NRC 841221 Responses to Joint Intervenors 841108 Motion to Reopen Three QA & Mgt Integrity Contentions for Litigation ML20101U3511985-01-25025 January 1985 Joint Intervenors Reply to Applicant & NRC 841221 Responses to Joint Intervenors 841108 Motion to Reopen Three QA & Mgt Integrity Contentions for Litigation.Certificate of Svc Encl 1996-08-07
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t' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION
'BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of L001SIANA POWER AND LIGHT COMPANY Docket No. 50-382 (WaterfordSteamElectricStation,)
Unit 3) )
[ SUPPLEMENTAL AFFIDAVIT OF RAMAN PICHUMANI Q.1. Please state your name, title and by whom you are employed?
A.I. My name is Raman Pichumani. Since March 1984, I have been employed as a Systems Engineer (Mechanical) in the Mechanical Engineering Branch of the Division of Engineering, Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Comission. Prior to March 1984, I was employed as a Geotechnical Engineer in the Structural and Geotechnical Engineering Branch, Division of Engineering. A statement of my professional qualifications is attached to my previous affidavit filed in this proceeding on November 28, 1983.
Q.2. Please describe the nature of your involvement, if any, in the Staff's further evaluation of issues related to the Waterford base mat since November 1983. -
- A.2. On March 19, 1984, I transferred from the Structural and Geotechnical Engineering Branch (SGEB) to the Mechanical Engineering Branch (HEB) of the Division of Engineering. At that time, my review responsibilities for the Waterford plant were transferred to another 8412190237 841217 PDR ADOCK 05000382 0 PDR
9 geotechnical engineering reviewer, Dr. John Chen.
Between th' e time my previous affidavit was filed on November 28, 1983 and the time I transferred to MEB on March 19, 1984, I was mainly engaged with other assignments not related to the Waterford facility.
However, during that brief period, I read the December 10, 1983 Gambit article, and participated in an internal NRC staff meeting on February 7, 1984 and in a telecon with Region IV staff on February 16, 1984. I was also present as an observer for part of a meeting held with the Applicant in Bethesda on March 21, 1984 (a few days after my transfer to MEB). I was not, however, in any way involved with the extensive investigations, discussions, site visits, and detailed evaluations which were performed by the NRC staff and its consultant, BNL, commencing with meetings held with the applicant on March 26 and 27, 1984. Similarly, I was not involved with the work of the civil / structural allegation review team, which commenced its activities in March 1984 after my transfer from SGEB to MEB.
Q.3. Have you reviewed any of the documents reflecting the further evaluation that has been performed by the Staff and its consultants since your previous affidavit was filed on November 28, 1983?
A.3. Yes. After the Atomic Safety and Licensing Appeal Board issued its Order of October 2,1984, I was asked to read the July 18,
~ '
1984 report issued by the Staff's consultants from Brookhaven National Laboratory, as well as the affidavits and addendum to the BNL report
I filed by the Staff on August 7, 1984. I have read those documents, but have not read any other documents prepared by the Staff cr the Applicant, or by their consultants, after hovember 1983.
My review of these documents was undertaken in order to comply with the Appeal Board's request that I provide a statement as to what effect, if any, the Staff's further evaluation has on the position I espoused in my previous affidavit. Accordingly, I have read these documents paying attention only to the geotechnical (soils) area, since my earlier involvement was only with geotechnical aspects of the problem.
Q.4. Please state what effect, if any, the Staff's further f evaluation has on the position you espoused in your affidavit of November 28, 1983.
A.4. After reading these documents, I find that I lack a basis to -
evaluate the conclusions arrived at by the Staff and its consultant, BNL, because of my total unfamiliarity with the large number of .
documents and data to which they refer in support of their conclusions, and because I was not privy to the many investigations, analyses, meetings, and discussions that were carried on after my involvement with the case ended in March 1984. Accordingly, I am unable to state what eff,ect,the Staff's further evaluation has on my previous position.
% h_ed
.Raman Pichumani Subscribed and sworn to this /7+ day of December,1984 84b//jVI-&slh Notary Public My commission expires: 7//,/ffo
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