ML20137X129

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Affidavit of G Krishnan Re Knowledge of Mgt Analysis Corp Rept & Issues Raised by Rept.Author Admits General Awareness of Discovery Process Re 1980 Licensing Proceedings.Related Correspondence
ML20137X129
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 12/02/1985
From: Krishnan G
GIBBS & HILL, INC. (SUBS. OF DRAVO CORP.)
To:
Shared Package
ML20137W974 List:
References
OL, OL-2, NUDOCS 8512100417
Download: ML20137X129 (2)


Text

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AFFIDAVIT OF GARY KRISBNAN THE STATE OF rex 4 3  :

COUNTY OF Sc-e uecu  :

BEFORE ME, the undersigned authority, a Notary Public in and for:bwensecc County, Texas, on this day personally appeared GARY KRISHNAN, who by me being duly sworn upon his cath deposes and says:

My name is Gary Krishnan. I am employed by Gibbs

& Hill as a Mechanical Engineer in TUGCO Nuclear Engineering at the Comanche Peak Steam Electric Station. I assumed this assignment in August, 1985. In December, 1984 I was in the Site Stress Analysis group in the Gibbs &

Hill Mechanical Engineering Department at the Comanche Peak siIe. I began work on the Comanche Peak Steam Electric Station in October, 1978 with Gibbs & Hill in New York City, New York. I moved to the site in April, 1981.

I was not interviewed by Management Analysis Company

("MAC") in connection with their management quality assurance audit of the Comanche Peak Project in 1978. I was not aware that MAC had issued a report on their work, have not seen or had a copy of the report, and have not read their report.

G

1 I was generally aware of the discovery process pertaining to the Comanche Peak licensing proceedings in 1980, but did not know of any particulars. I did not participate in any discussions as to whether the MAC report should be pro'duced in resp'onse to the discovery reques.t by the Intervenor, CASE, in the Comanche Peak Steam Electric Station licensing proceeding.

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GARY KRISHNAN SUBSCRIBED AND SWORN TO before me by the said GARY KRISHNAN on this, the .2 9 day of Dscameert-- , 1985.

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.motaryLPublic th and for

. 3,e.m County, Texas s

My Commission Expires:

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