ML20087N800

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Affidavit of Rt Knowles in Response to Unfounded,Anonymous Allegation 109 as Contained in Joint Intervenors Motion
ML20087N800
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 03/17/1984
From: Knowles R
HOWARD P. FOLEY CO.
To:
Shared Package
ML16340E243 List:
References
NUDOCS 8404040418
Download: ML20087N800 (3)


Text

___ _

. 1 EXHIBIT NO. 2 l

UNITED STATES OF Af1 ERICA

" NUCLEAR REGULATORY C0!1f11SSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL 00ARD

)

In the Matter of ) Docket Hos. 50-275 PACIFIC GAS AND ELECTRIC ) 50-323 CO:1PANY )

) Construction Quality Assurance (Diablo Canyon Nuclear Power )

Plant, Units 1 and 2 )

)

)

AFFIDAVIT OF ROBERT T. KNOWLES STATE OF CALIFORNIA )

) ss COUNTY OF SAN LUIS OBISP0 )

I, Robert T. Knowles, hereby duly sworn, depose, and say:

I, am the Staff Electrical Engineer for the H. P. Foley Company at the Diablo Canyon Nuclear Power Plant.

I am submitting this affidavit in response to the unfounded, anonymous allegation #109 as contained in the Joint Intervenors' Motion.

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8 have read the JI flotion at paragraph 109, Page 31 and the anonymous allegation dated January 16, 1984 at Paragraph 3, pages 5-5. Specifically, I am responding to the statement "One of Foley's managers told his supervisor about the problem. In response, he was lead to believe that he had a choice of keeping quiet or losing his job." This unsupported statement is unfounded.

I was the Howard P. Foley Company's Electrical Engineer responsible for the installation of the Unit ! Incore Thermocouple modifications, per Field Change Order No. 537. At the onset of the job we were advised that the termination boxes on the reactor head (known as the Beta shields) were not safety related. Later in February,1982, I became aware that the Beta shield portion of the work should have been treated as safety-related. I confirmed this by use of an Engineering Disposition Request to PGandE. At this point, I revised the work process traveler so as to include the Beta Shields as a quality item, and informed an H. P. Foley Quality Control inspector, Mr.

Dennis High, and the H. P. Foley Quality llanager, Mr. Virgil Tennyson, that as.

a result of the new requirements it was necessary to initiate an H. P. Foley Company Non Conformance Report (NCR). This NCR was required because some materials had been purchased as Non-Class I. _I worked with Mr. High in the preparation of the NCR (H. P. Foley NCR #8802-683). At no time was there any reason not to involve QA/QC in the documentation or reporting of the NCR. All information that I had was given to Mr. High and all parties involved. PGandE-Enngineering and QA/QC and Howard P. Foley Engineering and QA/QC were aware of the nature of the discrepancy. Every aspect of the system that required quality review and inspection was described, - documented, and corrected in accordance with the approved H. P. Foley Quality Program.. At no tine during V .

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the processing of the flCR did !!r. High express any dissatisfaction with corrective action. He had no reason to believe that his choice was " keeping.

quiet or losing his job." In fact, the I1CR was written by l1r. High at my request and was approved by !!r. Tennyson. There was never any suggestion that fir. High should " keep quiet." In light of the facts, any such allegation is simply ludicrous.

2 DATED: March 17, 1964

. h R. T. KNOWLES Subscribed and sworn to before me this 18th day of !! arch,1984 OFFICIAL SEAL M WENDY SPROUL Wendy seent-$gflot4L, " * ""'e catwoonia Notary Public in and for the "

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,i County of San Luis Obispo, -

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State of California.

My cwnission expires June 30, 1986 t

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