ML20099H527

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

ML20099H527
Person / Time
Site:	Diablo Canyon
Issue date:	01/22/1985
From:	Haffey P GOVERNMENT ACCOUNTABILITY PROJECT
To:
Shared Package
ML20099H479	List: ML20099H476 ML20099H502 ML20099H527 ML20099H559 ML20099H574 ML20099H606 ML20099H626 ML20099H649 ML20099H663 ML20099H728 ML20099H754 ML20099H775
References
2.206, NUDOCS 8503190399
Download: ML20099H527 (4)

Text

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Exhibit 2 UNITED STATES OF AMET _ ,. m _ - ._. _,.2 NUCLEAR REGULATORY COMMISSION BEFORE THE NUCLEAR REGULATORY COMMISSION In the matter of )

)

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

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(Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) )

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AFFIDAVIT OF PHILLIP HAFFEY g State of California )

U -ccurty (du ATTi' Of MM6 Of Sar Luir Obispo )

ss City Of .u Lwas Obispo )

b _Cr*T Y o h W A-- M W 4 ,

l The above being duly sworn deposes and says:

My name is Phillip Haffey. I am giving this statement ,

freely and voluntarily, without any threats, inducements or coercion,.to Mr. Th'o mas Devine. This affidavit is to file allegations of misconduct by the Nuclear Regulatory Commission (NRC) Region V staff in response to my initiatives to work with 1

i the NRC, and of material false statements by Pacific Gas and l l

Elcctric Company (PGandE) in response to my previous allegations.

1. NRC Region V staff destroyed my confidentiality prior to an l

l April 1984 plant tour by only requesting the Deficient Condition Notice (DCN) logs for myself and another anonymous alleger, which idontified us by our work, in preparation for the event.

2. On the morning of the April 1984 NRC plant tour of Diablo Canyon, imraediately af ter my identity had been effectively 8503190399 850314 PDR ADOCK 05000275

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revoalad, my houco woc the torgot of en unprecedontod cymbolic ottack -- a 12 inch cut-of f saw wheel was stuck in the lawn outside as an apparent warning.

3. After breaking our confidentiality agreement, the NRC made this sacrifice all for nothing by accepting an irrelevant excuse by PGandE to remove me from the plant tour be ore it started; at the time, I had not filed any written allegations.

4. If the NRC had permitted me to attend the plant tour, I could have pointed them to examples of oversized bolt holes on safety-related systems, covered only by washers and not by fishplates as rcquired by code.

5. The deficient bolt holes were the result of a bolting rework program that may have lef t the bolts less secure than before the ropairs, since the wire that orginally packed the holes was rcmoved and not replaced during the rework program.

6. The cause of the lost wirepacking was the uncontrolled nature of the repair program: supervisors informally gave instructions to ignore requirements for inspection prior to bolt and nut torque, and no one kept track of the lost wire stuffing, which wea merely swept up by laborers.

7. PGandE's response to allegation V-28A -- that I was intens on going beyond contractural requirements for bolt holes -- is misleading, beccuse the slotted holes that I challenged rcpresented a problem with design control; they were not reflected on the design drawing in that condition.

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8. I ropactedly cttompted to gcin written documentction from PGandE that would justi y the verbal instructions to deviate from the design through slotted bolt holes, but none was ever provided.

9. PGandE failed to correct the drawings to even accurately roflect the slotted holes , which still are misrepresented on the dosign documents.

10. PGandE's statement in response to allegation V-28B -- that the bolting rework program was covered by QA Instruction #64 --

10 f alse, misleading, a joke or all three, since despite my freguest requests, no one from QA Manager Harold Karner down to cy supervisor ever produced such an instruction during my oxperience working in the program,

11. QC inspectors did not have the organizational freedom to override supervisory commands and comply with code requirements f or fitup inspection during the bolt rework program, since the cpace on the inspection form consistently was marked "N/A" ("Not Applicable").

12. I disagreed with the stated managment attitude underlying the bolting re-torque program - "go as f ast as you can get away with " -- since the repairs were due to poor quality work in the first place and I believed management should make a commitment to control the quality of corrective action.

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13. PGendE'O roponce to cliegation V-29 -- denying discrimina-tien on the 3ob against aggressive inspectiors -- is false, since Gy supervisors personally told me that I was denied overtime because I would Just use it to reject welds.

14. PC:n6E offered a red herring to attack me for not offering ccmplaints when I resigned, since the complaints went to QA Menager Harold Karner -- the target of my allegations and the man who could be called on for references that might cause me to loce my upcoming new job.

I have read the above four page affidavit and it is true, cccurate and complete to be best of my knowledge of belief. .

/ & <

' Philf1p Heffey 7 o

i STATE OF CAllFORNIA iss COUNT 4 oFM7?! . (ShJedM '

on J 16vu way 22, p2_W before me, the undersigned, a Notary Public in and for said State. personally appeared PCiiJoA4IevI personally known to me (or proved to me on the basis of satis-factory evidencei to be the persorust whose namet snstare sub.

scribed to the wethin instrument and acknowledged to me that WDA 1 De LISE 3 NOTARY PUBUC

• he/she/tney esecute the same. 9 CAUFORNIA $

WITNESS h da offacial Santa Barbara County -

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