ML20087N787

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Affidavit of ML Andrews in Response to Hudson 840131 Affidavit as Contained in Joint Intervenors 840222 Motion on Const QA
ML20087N787
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 03/16/1984
From: Andrews M
PULLMAN POWER PRODUCTS CORP. (FORMERLY PULLMAN, INC.)
To:
Shared Package
ML16340E243 List:
References
NUDOCS 8404040396
Download: ML20087N787 (3)


Text

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EXIIIBIT No. 1

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' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD

)

In the Matter of )

) Docket Nos. 50-275 PACIFIC GAS AND ELECTRIC ) 50-323 COMPANY )

) (Construction Quality Assurance)

(Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) )

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AFFIDAVIT OF MILTON L. ANDREWS STATE OF CALIFORNIA )

) ss.

COUNTY OF )

SAN LUIS OBISPO )

I, Milton L. Andrews, being duly sworn, depose and say:

I, Milton Andrews, am currently employed by Pullman Power Products as a superintendent at Diablo Canyon. I am submitting this affidavit to respond to Mr. Hudson's January 31, 1984 affidavit as contained in Joint Intervenors Motion on construction quality assurance dated February 22, 1984.

3404 PDR %ho 0

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1. In regard to the reduction of force (ROF) termination of Mr. H. Hudson
  1. 3383, and Mr. J. McDermott 43326, on 1/13/84, they were picked on a R0F O lay-off which was caused by the reduction of force on the over-all jobsite. They were selected by using the process of who I felt were the best qualified people to keep. I was acting as General Foreman.
2. In the Area 10 Fab Shop there were approximately 20 men, I was told to cut the crew by 2 men.
3. I first picked the people I felt would be more apt to do a better job in the long run, for the benefit of the shop as a whole which, I might add, was being done over the whole jobsite, primarily the same way. I consulted with the foreman and he agreed. So, the consequence was the ROF of the two men mentioned above. 1

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4. I was not instructed by my supervisors or anyone to layoff Mr. Hudson and Mr. McDermott. I was not aware that Mr. Hudson had contacted or made allegations to the NRC when I chose Mr. Hudson and Mr. McDermott for layoff on January 13, 1984.
5. I might add that since the ROF termination of these two men, approximately 300 more men have been R0F (terminated) with no prejudice.
6. The ROF was not based on where they were from, out-of-state or local l union affiliation.

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f DATED: March 16,1984

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Milton L. Andrews I

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l Subscribed and sworn to before me this 16th day of March, 1984

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!% nUTRA r:ouw r: u:- cAurcamA (h Ida Dutra j set r: s ra!:.'s co?.Tt ;I, Notary Public in and for the ],,5 Mr coem. exoires ws 2.13:7 9 County of San Luis Obispo, -- ''''''''''

State of California.

My commission expires January 2, 1987 i

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