ML20197H809
| ML20197H809 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/22/1983 |
| From: | Parks R BECHTEL GROUP, INC. |
| To: | |
| Shared Package | |
| ML20197G961 | List: |
| References | |
| FOIA-85-700 NUDOCS 8605190293 | |
| Download: ML20197H809 (3) | |
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,e P REP ARED STATEMENT of RICHARD D.
PARKS Harrisburg, Pennsylvania April 22, 1983 My name is Richard D.
Parks.
Thirty days ago I filed a complaint charging illegal retaliation by my employer, the Bechtel North Ameri-can Power Corporation, because I raised safety concerns about,the cleanup program at Three Mile Is lan d-Unit 2 and spoke with the Nuclear Regulatory Commission.
On March 23 the retaliation that I challenged was the stripping of certain key responsibilities I had in the cleanup program.
At a press conference that afternoon, General Public Utilities-Nuclear president Robert Arnold and TMI-2 director Bahman Kanga indicated that my future with the company had not been determined.
The next day I was placed on an indefinite leave of absence with pay and told that I would be informed of my status within 30 days.
I have been informed that Messrs. Arnold and Kanga were not completely forthright to the public in their press conference.
That same morning they led a meeting at TMI about my whistleblowing disclosure.
According to an affidav$t from a witness who attended the meeting, Mr. Kanga announced that management would have to act carefully due to my legal rights.
Instead of firing me,ime.ediately, management would just transfer me or place me on a leave of absence 8605190293 860501 PDR FOIA PDR p
ZURAS B5-700
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t (7 for a month and then get rid of me quietly.
At the meeting, s
Mr. Arnold also said that the controversy was just a flash in the pan that would die down quickly.
He added that the Udall committee in Congress would not follow through and that I would not be invited to testify.
They were both wrong.
I will not leave quietly, because I am determined to make a constructive contribution to completing the TMI' cleanup economically without gambling with phblic safety.
There is a lot of-work left before we can reach that goal.
1 Since I have not been permitted to return to the Island, I have
.had time to study my notes and do some hard thinking.
As a result, I now believe even more strongly that the polar crane is only an example of a fundamental breakdown in controls on modifications to
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equipment and components in the TME cleanup.
For example, I recall that from the accident until De cember i
1980 there V:r:
ver 1700 modifications significant enough to be formally processed through Engineering Change Modification (ECM) forms.
Less than a dozen of these ECM's had the required test d a t a, cns quality assurance records. ;
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Those fundamental safeguards had been skipped.
Some of the changes l
were petty.
Some, however, involved significant systems in the plant, suak ** : fifications to the decay heat removal system, low-level waste processing' system, ventilation system, radiation detection equipment, and waste storage facilities.
I am familiar with this problem, because during late 1980 and 1981 I was part of a team that researched it.
In almost every case
[L there was no test data.
We wanted to immediately set up a full testing program, but were informed of a management decision with i
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NRC approval to forego Sr.ality assurance for modifications.
I deeply hope that this is not true.
We invited the NRC to
- check the test records, but they did not respond to the invitation.
I will provide further details of these and other concerns in my congressional testimony next week.
I must emphasize, however, that I would prefer to act on my conscience at the Island, instead of at press conf erences and he a:-ings.
My goal is to return to my job and TMI~ and help finish the cleanup properly.
I hope that management wilA Ist me.
i
HOBERG, FINGER, DROWN, COX & MOLLIGAN
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A PROFE S$10NAL CORPORATION CENTRAL TOWER 703 M ARKET STREET INGEM AR E. HOB ERG (1903-1971)
SAN FRANCISCO 94103 JOHN H FINGER LAW OFFICES FHILLIP E. B ROWN (415) 543-9464 PETER N. MOLLIG AN EAsf mAY (NTERPRISE 10095 STEPHENT.COM Caett AcoRrss'INGMAR' CICH ARD C. RAINES October 8, 1985 s^ac50t^o^"
OAVID W. MOY ER 00 8 ROY M AC K E Y MICH AEL R. REYNOLOS CARBAR A A. ZURAS PREEDOM OF litFORMAT80N ACT REQDEST Director Office of Administration h M "[j 7dd Freedom of Information Act United States Nuclear Regulatory Commission h /M-/[U Vashington, DC 20555
Dear Sir or Madam:
We are the attorneys for Richard D. Parks.
Pursuant to the Freedom of Information Act, I am requesting copies of any and all documents concerning the investigation performed by the NRC Office of Investigation (OI) into charges of discrimination and/or harassment made by Richard D. Parks.
I am also requesting copies of any and all documents concerning the " notice of violation and proposed imposition of civil penalty" which was issued by the NRC on August 12, 1985.
The docket number for the investigation and imposition of civil penalty was 50-320.
The respondents in that investigation were GPU Nuclear Corporation and Bechtel North American Power Corporation, license No. DPR-73.
I would appreciate being notified as to how I might assist you in your effort to provide copies of the requested documents.
I would also appreciate being notified in advance as to the estimated cost involved in making copies of the requested documents.
Thank you for your attention and anticipated cooperation.
Sincerely e
BARBAR N. ZURAS BAZ:ad
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GOVERNMENT ACCOUNTADlLITY PROJECT institute for Pokcy Studies 9 90' Que Street. N.W., Woshincton. D.C. 20009 (202)234 0362 March 23, 1983 The Honorable Nunzio J. Palladino Chairman U.S. Nuclear Regulatory Commission Washington, D.C.
20555 De'r Chairman Palladino:
a The Government Accountability Project (GAP).i:s representing Mr. Richard Parks, a senior startup engineer at Three Mile Island (TMI) - Unit II.
Our decision to represent Mr. Parks in based on a 56-page affidavit he provided over the weekend, as well as veri-fication interviews with additional witnesses who supported both his charges and personal credibility.
In his affidavit Mr. Parks discloses, inter alia, 1) safety-related modifications to equipment and components without full prior engineering and approval; 2) quality assurance violations through issuance of test and administrative procedures without prior re-view and approval; 3) plans to use the polar crane without con-ducting all necessary safety tests and conclusions; 4) severe harass-ment and retaliation against those who internally challenged these violations, including investigation and dismissal for utterly pre-textual, previously-unrefined offenses; and 5) NRC collusion with the misconduct.
! J-Based on his experience, Mr. Parks believes that these practices were intentional.
He also believes that they compromise the system of organizational checks and balances at TMI.
The dispute resulted from a management attempt to conduct additional radiation monitoring without falling behind schedule after it was discovered and reported on January 6, 1983 that radiation levels under the reactor vessel are 30 times higher than previously estimated.
' We are alarmed that Mr. Parks' experience mirrors that of so many other nuclear workers who have contacted us.
He reports that your agency has failed to aggressively pursue his concerns.
- Instead, NRC representatives violated his confidentiality, flatly refused to investigate his charges of reprisals, and rejected his allegations on flatly inaccurate grounds contradicted both by NRC notes and cor-porate QA records issued at the same time.
Perhaps most disturbing, j
he reoorted a practice at TMI for NRC representatives"to pr' ovide the licensee with advance drafts of Commission documents, and vice versa.
After a consensus was reached, the "of ficial" version would be released.
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aMnd irii 199 1(
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s Chairman Palladino March 23,'
1983
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U.S. Nuclear Regulatory Commission The continuing allegations of NRC-utility collusion are shate tering public confidence in the Commission.
Mr. Parks, and GAP,
want to cooperate with the NRC.
As a result, we are submitting his affidavit for your review.
Unfortunately, to date Commission rep-resentatives have not responded to Mr. Parks in good faith.
As a result, we have advised Mr. Parks not to communicate further with the NRC until we can negotiate with the Commission to ensure that objective, independent technical and investigative staff will be assigned to his case.
I look forward to your prompt response.
Sincerely 8
D Thomas Devine TD/e1 Legal. Director 4
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s AFFIDAVIT My name is Richard D. Parks.
I am submitting this affidavit freely and voluntarily, without any threats or coercion, to Mr. Thomas Devine, who has identified himself to me as the Legal Director of the Government Accountability Project of the Institute for Policy Studies.
I am' submitting this statement to express my personal knowledge and c'oncerns that the management of Three Mile' Island-U, nit II (TMI) har sacrificed its own system of safety-related checks and balances for TMI cleanup activities in order to meet unrealistic time schedules.
i In the process, equipment has been modified and snap judgments made without proper engineering analysis, quality assurance (QA) steps have intentionally been skipped and totally circumvented, rules and
' documents have been changed after the fact to just'ify QA violations, and those who have defended the normal system of nuclear industry checks and balances have faced pressure, intimidation and retaliation which stripped them of the authority to function as viable members
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of the management team.
I am among those who have suffered this-
' fate.
The quality. assurance violations include many other issues l
of which I am aware but do not have personal knowledge.
1
.TMI is not a plant under construction.
It is a licensed nuclear plant in a recovery mode from the worst near-disaster in O
the' history of nuclear power.
The management of TMI-Unit II from General Public Utilities (Gp0) has said that for them the public health und safety comes first.
They have assembled one of the
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t best-qualified teams of nuclear power personnel in the world to assure tha.t the recovery program is above reproach.
At a minimum, the program must comply with all applicable laws and QA' rules.
We cannot engage in any shortcuts at this plant; they are not an acceptable engineering practice.
The consequences to the public health and safety and to the nuclear industry could be too severe.
I am currently employed by the Bechtel North American Power l
Corporation (Bechtel) as a senior startup engineer at TMI-Unit II.,
Ny present duties include work as an operations engineer reporting to the director of site operations and the manager of plant operatio's. n
. Amongst my other responsibilities before recent reprisals, I served l
as startdp and test supervisor's altern' ate for Unit II, acting startup and test manager from July 31, 1982 - August 9, 1982, alternate Test Work Group (TWG) chairman,, and was certified to perform all Level III activities.
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I have been working in the nuclear industry for 12 years, j
beginning in 1971.
From 1971-1977, I was in the U.S. Navy nuclear power program as a Navy instructor for nuclear power plant operations and. maintenance, and qualified as engineering watch supervisor with
- full responsibility for the plant outside of the control room.
I have worked as a member of the nuclear projects staff as a control room operator in the construction phase at the Clinton nuclear plant. -
From 1978-1979 I was a shift supervisor at the Midland nuclear plant during the construction phase and there completed 26 weeks of cold license traindng in preparation for cold licensing as a senior re-actor operator.
From 1980-1982 I was a senior startup,and test engineer providing consulting services to nuclear power plants under i
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6 construction or operation, includin'g Beaver Valley power station, TMI-Unit II, and Shoreham nuclear power station.
During my first time at TMI-Unit;II, from June 1980 to December 1981, I was personally involved with the construction, testing and placing in operation of the submerged demineralizer system (SDS) as both a senior shift test engineer and as acting startup and test manager for the project.
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Among other duties, I helped to develop and implement the startup and test program f or the TMI-Unit II. recovery.
The first time I was at TMI-Unit II I worked for NUS Corpora-tion.
I was working at Shoreham in January 1982, shen I was invited to apply for a job at TMI-Unit II with the Bechtel Corporation, which was taking,over an integrated management program.
I was told that the Bechtel Corporation needed someone with my experience on the Island to assist in developing procedures to accomplish the " quick i'
look" program, which surveyed with video equipment the rubble pile in
.the core of Unit. II and acquire the data necessary to remove the re-actor vessel head.
In May 1982, I went back to work at TMI..
Until late October 1982, I felt good about my work at TMI.
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was-satisfied with implementation of the. " quick look" program, which i
' ended late last summer.
In September 1982 there was a management 1
reorganization to put Bechtel in charge of an integrated program with GPU for cleanup activities.
I was assigned as an operations engineer in the site operations staff, reporting directly to the site operations director and m1 nager of plant operations.
My re-sponsibilities included liaison functions with the Nuclear Regulatory Com=ission (NRC), engineering groups, and plant staff; ov.arsight and review of numerous modifications to the plant and erection of new I
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cystems to datormine compliance with applicable standards and opera-tional capabilities; and to interface with various task groups and provide operations input into.their activities and ensure compliance with NRC and internal rules.
I also worked to research, develop and implement procedures and other sof tware activities for the above pre
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jacts.
To illustrate the scope of my duties, since my return to TMI I have developed dozens of procedures, including test procedures, operating procedures, surveillance procedures, and special operating procedures, among others.
Examples would be development of procedur '
required for the SDS outgassing system, the reactor coolant system (RCS) high point vent szmpling, and Once Thrcugh Steam Generator (OTSG) draining.
Around November 1982, site operations became involved in the head lift task' force (HLTF).
There were weekly meetings.
Within a few meetings, it was clear to the site operations attendees that '
there were significant deficiencies with the program to remove the reactor vesscl head and subsequent activities to remove the fuel.
l The ELTF is a consortium of representatives from the reactor disas-i l
sembly and defueling (RD&D) group, the lead group in the task, force;
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site operations (SO), responsible for interfacing with all matters pertaining to operations of the plant and compliance with technical specifications, regulatory quides and the applicable standards; recovery operations (RO), which serves as constructor; design engi-neering (DE), responsible for engineering input into issues such as methodology; site engineering (SE), responsibleforon-siteengineer:l 4
and interf acing with design engineering; project controls (PC), whic!
handles funding and scheduling; technical planning (TP), responsible" to develop the technical plans behind the methodology and to obtain E
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input from special experts as ndcassary; radiological engineering 4RE), responsible for input on all matters concerning radiation ex-posure to personnel; recovery programs (RP), responsible for manage ment representation and decisionmaking at the meetings; and NRC, 4
responsible for regulatory oversight.
To illustrate the initial SO concerns, we were alarmed that i
the polar crane schedule did not jive with the reactor vessel head lift schedule.
The polar crane's major jobs are to remove the re-I actor vessel head, move other heavy equipment inside the containmen and to stage any support equipment required to remove the damaged core from the reactor vessel.
The polar crane is located at the tc of the reactor immediately under the dome.
I The reactor vessel head has to be removed to take the fuel ot j
The core and other internal components had been extensively damagec during the 1979 accident.
For example, the top 'five feet of the et have a rubble pile where there used to be nuclear fuel.
The origi:
fuel must be removed and replaced, if the plant is to go back into operation, or removed for decommissioning.
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On July 19, 1982, GPU had ' assigned Bechtel to " refurbish the,
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reactor building polar crane in accordance with the P,echtel contai:
ment entry program" pursuant to a July 14, 1982 Work Pequest, CA25 In other words, Bechtel's job was to restore the crane to its un-damaged condition.
This work request was deficient in itself.
Th
" containment entry program" covers issues such as personnel protec from radiatiod.
It,has nothing to do with engineering functions c design OA engineering documentation.
j As L. King of site operations repeatedly reportal (10M 4200-83-068 and 0 there was no integrated scheddle to coordinate between refurbishme ;
of the polar crane, the sequence of events to remove the 1
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reactor head, and subsequent activities to remove the fuel from the reactor core.. As a result, different groups did not understand what the others were doing or what support they needed.
Our second initial concern was that the plant, plant systems
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and components had been modified without proper review of the engi-neering paperwork.
One.of the basic groundrules for items important to safety is that work be reviewed and approved by relevant engineers plant operations review committee (PORC), QA/QC, licensing, the SO director and the NRC.
In most cases, the only review stages that are omitted from items not important to safety are PORC and the NRC.
Administrative Procedure (AP) 1043 governs modifications to Unit "II plant systems.
As I understand the intent, it covers the process for an Engineering Change Modification (ECM), a procedure and form which must be completed for any modifications or replacements of "unlike kind" or important to safety.
At the headlift meetings we learned that ECM's were not con-sistently being issued to accomplish plant modifications.
- Instead,
" work packages" -- internal Bechtel construction procedures developed on-site -- were being utilized for the modifications.
An example included refurbishment of the reacte building polar crane.
The guidelines to prepare a work package do not include the necessary-requirement to ensure licensee compliance with applicable NRC regu-latory guides.
Using work packages to refurbish the polar crane couli s
totally circumvent the site modifications control procedure (AP 1043)
It was immediately apparent to 50 that plant management made
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this decision intentionally.
At various meetings, top level manage-ment representatives repeatedly took the position that the ECM pro
- cedure was cumbersome and would force unnecessary schedule delays l
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due to the time for the detailed review cycle.
Top management sdch as John Barton, deputy site director, James Theising, manager of recovery programs, C. W. Ho'ltman and R. Freemerman of program controls, R. Jackson and R. Rider of Bechtel Engineering, and others stated that as a result work packages would be used.
Our third initial concern was that various representatives at the ELTF meetings were not familiar enough with the relevant Unit Work' Instruction (UWI) procedure, technical specifications, site QA requirements, etc., to adequately develop and submit the procedures into the proper review cycle necessary to maka these procedures
" legal."
PORC files contain the documentation to corroborate this claim.
An example includes UWI 4374-3891-83-PC-2, the Polar Crane No-load Operational Test, which violates AP-1047, the Unit II test manual.
Another example is. UWI 4380-3 054-83-R-02 and 4 38 0-3 054-83-R-03, both procedures for Reactor Vessel Internal Radiation Measurements.
Both the latter procedures address degrading the reactor coolant system boundary, and have a slight potential for altering core con-figuration, its physical shape.
During their initial review, these
'latter two procedures were signed off by individuals not qualified for the task.
Fortunately, these procedures were caught before they were used, and sent to PORC for approval.
The steps in these pro-
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cedures invoke Tech Spec 6.8.2, an NRC-required s'afety specification for level of review and approval on various systems procedures that I
address "important to safety" and " nuclear safety-related" systems.
The PORC chairman should have specified that the NRC, QA/QC, Rad Engineering, the Manager of PO, and Plant Engineering review and O
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approve this procedure.
Unfortunately, he didn't.
On February 16, he reviewed and approved the piecedure without co. ment.
On
- 1983, February 19, 1983, I identified this deficiency to 'the site operatio director, ' corrected the situation a6d on February 24, 1983 submitted Site Operations Problan Report to B. K. Kanga, Director of Unit II, by my of 50 director, yith a M. Mation that ::.11 per-nal involved in the gwho ard
. plementation process receive indoctrination on the requirements and controls for various procedures.
'the Polar Crane No-load Operations
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Test had the scme type of deficiencies.
l SO raised the above and other concerns at the HLTF meetings, but our input was not welcomed.
In fact, the meeting minutes only included a small portion of the concerns raised by S0.-
There was no l
QA/QC representation in the RLTF, and 50 was taking that role.
The i
I other representatives didn't like it.
To illustrate, at an early January 1983 HLTF me' ting, Tom Morris, acting chairman of the HLTF, e
responded sharply when I pointed out that 50 couldn't comply with various requests until procedural' steps were honored.
He said that j
instead of " telling what we can't do," I should "tell what we can de I responded by describing the constraints on me before I could ap-prove the requested actions, and that SO was maintaining the schedul better than other departmants.
After the meeting, however, Morris told Richard Seiglitz, manager of plant maintenance, that I should be counseled for my negative attitude.
I know, because Seiglitz s
described the conversation to a group of SO members including myself He added thatihe responded that he shared my " attitude" and told Morris that I was right.
I have since learned that the concerns rais~ed at the HLTF meetings are representative of"a general TMI track record to f
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continually violate QA requirements; as illustrated by repeated Quality Deficiency Reports (QDR) and the f ailure to take adequate correction actions.
To illustrate, B. K. Kanga recently issued memorandum 4000-83-152, which in part addresses two still-outstanding 1981 QDR's on lack of design verification.
It included an attachment, a memorandum from the director of plant engineering, who stated that upper management had made a conscious decision to set aside design reviews of modifications performed after the accident.
The director of plant engineering was reintroducing design reviews for any modi-fication performed by his organization.
In short, I have learned that non-compliance with QA requirements in Unit II cleanup activities is,a longstanding problem.
During the same timeframe at the and of 1982, SO was working on preparation for and commencement of draining the Once Through Steam Generators (OTSG).
This kept me extremely busy.
It was also because we did not receive engineering direction on a difficult job, how to physically drain the. steam generators.
They had been. working on the problem for over a year.
We eventually devised a method with hoses and temporary fittings, received'NRC approval,'and began
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' draining.
Additionally, ELTF assigned the other operations engineer, Walter J.
(Bubba) Marshall and I to develop and oversee between eight'and ten procedures on head lift activities.
Toward the end of the year, there was a meeting between Dave Lake, manager.of recovery operations, and Larry King, director of site operations, to finalize the comparative responsibilities of construction and site operations to provide personnel fer the head lift.
As a result, SO was responsible for safety-related work that e
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invoked technical specifications, regulatory guides, or professional stand'ards.
OnJanuary3,1983,GPUCorporation,ofwhichGPU-huclearat TMI II is a subsidiary, implemented the UWI procedure to govern all work done at all sites in the GPU system.
This step was necessary i
to eliminate an old problem of different departments working under different systems by standardizing procedure development, review, approval and implementa' tion.
The UWI did not have any provision for work packages, which generically are construction procedures and are not always consistant with operational QA requirements.
The new UWI meant that work packages were obsolete in Unit II.
This was a major policy change and immediately resulted in a major disagre'ement about procedural requirements and compliance between 50 staff members and those of other organizations.
SO took the position that the.UWI system was now the exclusive authority.
Construction (RO) and upper site management (RP) initially continued to insist that all work performed inside the reactor building would be performed with a work package,. instead of a UWI.
In mid-late January the issue was resolved when RO agreed to attach a UWI cover sheet to its work packages.
Unfortunately, this system requires duplicative reviews which contribute significantly to delays in software approval.
RO has further attempted to formalize the work package under the UWI.
The conflict originally arose in the first week of January when SO was refused entry into the reactor building to perform valve.
lineups and set up equipment for draining the A OTSG.
RO refused j
entry because we were not on the two week "look ahead" schedule addressed in their containment entry procedure, a pre-existing 1
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Thio was th2 first entry that cite oparatiene had cver had to make to accomplish a-task totally under its control.
It was due to the 50 responsibilities. on the head lift schedule.
The con-frontation delayed our draining of the OTSG for over a. week, when RO agreed to allow SO entry.
The dispute over two-weeks advance notice eventually went up to B. K. Kanga.
SO informed him that we did not always have the i
luxury of two-weeks advance notice.
In fact, we told him we seldom have more than a day's notice.
I rewrote RO's containment access
. procedure into a UWI that would permit around-the-clock entry for operational personnel, and sent it to Management Services on January 19.
The manager of Management Services called me the week of January 24 and said the. rewrite of the procedure was excellent and clearly
' defined for the first time.
The UWI has not yet received final ap-preval, however, and the basic conflict is unresolved as of a 9
March 4, 1983 meeting.
On January 6, 1983 there was a major development which began the disintegration of the HLTF program, in my opinion.
Memo 4500-83-0125 from Jack DeVine, GPU's, site technical planning director, to' B. K. Kanga disclosed that there was 30 times more radiation-
. under the Unit II reactor vessel than had been previously estimated.
Additionally, the memo revealed that the previous Quick Scan Data was inadequate for this higher radiation source, and did not provide
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any information about the radiological effect of contaminated support tubes and leadscrews underneath the vess'el head.
A recent decon-tamination analysis of leadscrews had suggested they could repre-sent a very significant problem in head removal.
I have since been~
told that the mistake was due to insufficient time to verify pre-liminary assumptions about the strength of the radiation source.
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The memo included a recommendation to alter the head removal plan in order to take into account the higher radiation., At the next SLTF meeting, around ' January 11, there was a decision to advanc I
the schedule sufficiently to remove selected controlled drive mecha-nisms (CRDM) and insert more equipment to reverify the new test re-sults.
Previously we had planned to remove some CRDM's and acquire more data for activities such as flushing.
But the original infor-
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mation on which CRDM's to remove would not be available until Janu-ary 21, according to a December 28 HLTF meeting.
(Memo 4380-82-0072 l
The January 6 memorandum and January 11 ELTF meeting added a new sense of urgency.
After the January 6 memo there was massive confusion, due to hasty changes in program direction and procedures.
The project seem to be in disarray, with no one individual in control.
I will try to reconstruct the events that followed to the best of my recollection.
one problem involved the Safety Evaluation Report (SER) for i
the head lift.
SER's are the documents that inform the NRC of the intentions, methodology, engineering approach and supposed " defense in-depth" to protect against pot'ential accidents.
The head lift SER
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initially had been issued in December.
The comments received in the 1
review cycle were e,xtremely critical.
In late January a new SER appeared which was substantially different from the original.
The revised SER still has not been approved.
Additionally, from the middle of January until early February So was intensively involved in trying to develop a method to drain the B steam generator.
After an in-depth study, the only viable option was to drain the steam generator to the re* actor building sump through plastic tubing, incand of design engineer's preference to cut l
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the steam generator sample line.
We took this position, because cutting the sample line would degrade an "important to safety" system and could degrade containment isolation abilities.
However, this decision revived two longstanding hypothetical problems that had to be overcome-- (1) uncontrolled criticality in the reactor building sump due to the suspected presence of fuel in I
the sump; and (2) uncontrolled criticality in the B OTSG upper tube sheet if the reactor coolant system water level were to be lowered below the. upper tube sheet -- a certainty in order to remove the
' reactor vessel head.
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These two problems, although hypothetical, had long been assumed to be credible by the PORC chairman and others, despite the absence of support calculations or other credible analyses.
These two assumptions have directly resulted in unnecessary work, expense and radiation exposure to personnel which could have been avoided if 1
the necessary calculations or other analysis had been performed to disprove this hypothetical situation.
The management action to assure that suberiticality would never occur had been to add an administrative requirement that all 4
. water added to the reactor building sump would contain greater than
~1700 parts per million (ppm) concentration of boron.
This concen-tration of boron was chosen,because at one point after the accident there temporarily had been 1700 ppm's of boron in the sump water without attaining subcriticality.
So management assumed that level
~
was safe, without calculations.
Although management claims this estimate is conservative, there should be calculations or other requirements.
An administrative requirement is insuffipient to f
l satisfy criticality protection under a " defense in-depth" approach l
against criticality.
There is no method or instrumentation to detect l
1
f
~
l s
- _ 14,.
if the sump is critical or not.
Similarly, in a January 14 meeting on concerns about dra'ining
- the steam generator (Memorandum 4302-83-0021), 50 demanded calcu-lations to demonstrate if there were a threat to criticality in the steam generator tubes.
Design engineering had failed for months to supply the calculations.
Several weeks after this meeting, however, they returned calculations demonstrating that there would not be a problem.
At the same meeting, SO requested design engineering to evaluate storing the missile shields -- which protect against flying parts resulting from an uncontrolled steam excursion -- only on the q
A steam generator so that it would not be necessary to drain the B steam generator.
The suggestion was rejected, because it could delay the polar crane schedule.
At the January 14 meeting, 50 further requested that design engineering evaluate double rigging the crane for missile shield lifts in order to increase the safety margin and minimize the chances
.of load drop.
This request was also rejected because it could signi-ficantly' delay the polar crane load test.
At the meeting it was generally agreed that there was no way to assure that the surge line connecting the pressurizer to the reactor coolant system would not be broken if the pressurizer missile shield were dropped inside the concrete and steel reinforced structure around the generator.
If this accident ~oc' curred, it would cause the reactor coolant system to drain to the point where there would be
~
only three feet of water above the damaged reactor core, instead of.
the normal 16 feet of water from the reactor vessel head to the core, j
e t
tys
- To the best of my knowledge, design engineering told us at the 1
meeting that load drop calculations had not been performed.
The January 14 meeting was part of a concerted effort to advance the removal date for. selected CRDM's from the originally scheduled date in March.
Once the CRDM's were removed, the additional sur-veillance 'of radiation levels could begin.
This effort was at the 4
heart of the confusion which developed, because each new idea affected numerous existing procedures.
To remove the CRDM's required use of the polar crane.
At one J
of the January ELTF meetings, in an effort to see if the confusion 1
was premature, So inquired whether the polar crane would even be ready for CRDM removal in February.
The,ELTF chairman responded that he had been assured by the Polar Crane Task Force (PCTF) that it would be ready.
4 At a mid-January upper-level management Critical Action Item
]
Status Report (CAISR) me'eting, Deputy Unit II Director John Barton j
asked Site Operations Director Larry King why SO was asking questions i
on the polar crane.
Barton said the polar crane belonged to Becht'e1.
Kin'g responded, "That's not written down anywhere." "Barton's position
~
, was that the polar crane would be turned over to 50 when it was re-furbished.
King stated that 50 would then get involved because 50 had to sign for acceptance 'of the turnover, including any modifica-tions to the crane.
This prompted a January 20, 1983 memorandum
)
(4200-83-034) stating that the polar crane in f act belonged to Bechtel, and that SO would not be involved in the refurbishment.
4 In early February 'in connection with the SER rewrite, manage- -
~
ment issued for review and approval a new SER on "underhead charac-i
- e n.
m.we,,
_-,,,,-v e---
l
/j i
16 -
terization," a process to reverify the amount of radiation under the reactor vessel h'ead.
The plan was to do the characterization i
at the and of February.
Around February 9, 50 issued' comments.
The
.l comments stated that this new SER assumed the use of the polar crane..
i If use of the polar crane were a requirement, an alternate method would need to be devised.
In our opinion, the polar crane would I
not be available until Ma,rch 2 at the earliest.
Further, SO questioned the methodology for assumptions about varying water levels in the reactor W-of the potential for releases of air-
~'
barne contanination and radiation.
The SER did not reference the lost capa-bility during draindown to perform surveillances required by tech 1
j specs, such as heat removal concerns; issues important to maintain suberiticality by keeping the reactor core covered, such as re-4 flooding the reactor vessel.
Additionally, to $ny knowledge none of the SER's provided calculations showing protections from the consequences of a load drop under worst case conditions, either for the load' test rig, reactor vessel head or other heavy load that could strike the reactor vessel head area.
It could be pestulated that with suf-4
..ficient force, core configuration could be altered and the chances of criticality increased.
Similarly, such a drop could cause one or more of the in-core instrument guide tubes located on the bottom of the reactor vessel to break due to mechanical shock Such a break would cause the total draining of all the boratud water in the reactor vessel which surrounds the core and this could possibly allow criticality.
Theseguidetubeshavebeensubme}gedina 6
e t
-f!
17 -
highly-radioactive environment due to the vast quantities of contaminated water that flooded the reactor building.in 1979 and was not substantially removed until late 1981 or early
^
1982.
An accident of this nature, hypothetical though it may be, would require use of the decay heat removal pumps (low head safety injection) to reflood the reactor vessel and hopefully keep the core covered. -Unfortunately, to my knowledge, these same pumps have not been run or otherwise tested since the accident, because they are in such a high radiation area.
We
' don't know anymore if they would work'or not.
Management has not even attempted to decontaminate the area so that the pumps i,
could be tested and available for use in a possible emergency.
1 I
Between January 20 and February 10, 1983, the Safety Evaluation Report for use of the polar crane was reviewed by 50.
I believe that in all there have.been at least three revisions to this SER.
On February, 10, 1983, the, manager of
]
plant. engineering sent a memorandum to the 50 director (4240
- 83-111), to. whom plant engineering reported.
The memorandum stated that the polar crane safety evaluation is technically unacceptable.
It added that the crane must be tested prior to any lifts, to preclude reducing the safety margin for the public, damaging safety-related or "important to safety" i
i equipment or resulting in significant delays in the recovery a
e e
O 4
g 3
4
~f
. program.
.The memorandum went on to reccmmend that the. test
~
load be lowered to the lowest elevation in the containment.
This would assure that the full use of the crane were tested.
Plant engineering also stated that there should be controls to prevent the crane from operating in untested areas or un-certified or undesirable modes, since particular backup equipment could prove ineffective.
To my knowledge, none 1
of these recommendations have been included in the load test.
I must emphasize that this decision is within manage-
' ment 's discretion, even in the absence of engineering justi-fication.
J On Friday, February 11, 1983, Larry King informed SO l
staff of a meeting between himself, B. K. Kanga and Ed Gischel, director of plant engineering, to obtain his and Gischel's signatures evaluating and approving the polar crane SER.
Messrs. King and Gischel stated that they still had signi-
' ~~
ficant problens with the whole program.
They were those des-cribed above, which.they repeated.
Mr. Kanga then stated that he would take King and Gischel to Bob Arnold, GPU-Nuclear President, to discuss their refusal.
On Monday morning, February 14, 1983, Mr. King informed the so staff that he had received a phone call from John Barton asking "what the hell" Ed Gischel was 8
d
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. doing writing.the polar crane memorandum.
Larry Kinij reported Barton's threat-
"I don't need people like that working for me..I'll fire their ass."
Gischel and King were told',to attend a meeting that afternoon in Rooms 201' and 203 to discuss the polar At that meeting, John Barton held the polar crane load test crane.
SER in his hand and asked why they wouldn't sign it.
4 Upon a review of the SER shown to them, King discovered that it already had been submitted to the NRC for approval without SO review, in violation of Tech Spec 6.8.2.
Barton blamed the SER problems on the lifting and handling program.
This was somewhat confusing sirice there was 3
no approved lifting and handling program on site.
Barton wanted to
}
know why 50 was raising problems at the last minute.
King' stated that Barton should sign it off himself if there were no problems.
According to King, Barton responded, You think I'm going to sign this damn thing with this letter out?
Suppose the NRC sees it?"
~
Later that same day, King and Gischel sent a memorandum to upper management expressing fundamental disagreement with the polar crane program, but recognizing management's authority to proceed'as they wish.
i On Tuesday, February 15, a meeting was held between B. Xanga,
{
- J. Barton, R.. Jackson, D. Lake, J. Theising, E. Gischel, L. King, and R. Freemerman of recovery programs.
The discussion topic was the functional description of the polar crane, a Bechtel internal document at the time not reviewed or approved by GPU or the NRC, to my' knowledge.
The functional description stated what equipment on the polar crane had to be refurbished in order to remove the reactor head.
9 1
e
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s On February 17, SO received'the polar crane load test procedure Larry King assigned me to review it.
The same day, with.Mr. King's prior concurrence,,I issued my comments to Mike Radhill, Polar Crane Task Force (PCTF) leader.
My central comment concerned lack of com-pliance with the modifications control procedure, AP-1043, and the test manual, AP-1047, which meant that procedures performed to date were not technically legal.
Upper management refused to accept these co=ments and returned them to Larry King to verify his concurrence.
On February, February 18, Ed Kitler, supervisor of startup and test, caught up with me.
I was walking to the office from-the parking lot.
His mannerisms made it apparent that he was worried and upset.
He asked me, What the hell are you doing?"
I asked him what he meant.
He replied, "You have upper management pissed off at you, to the point where I've been asked what has to be done to get you transferred off the site."
I responded that I was pro-tected against reprisals under 10 C.F.R. 19 and would go to the NRC if any reprisals occurred.
We had reached my office space and had entered Larry King's office to continue our conversation.
Soon l'
after, Larry King and Joe Chwastyk, manager of plant operations, walked in.
In front of Kitler, I repeated to Larry and Joe that I had been threatened with transfer.
Larry replied, "It does not surprise me."
Ed repeated the original threat and attributed it to Rich Gallagher, an assistant director of site engineering who also j
performs various other functions for top management.
I was vihibly upset.
Kitler added that I shouldn't take it so seriously.
I felt personally threatened and that same morning asked Phil Grant of the NRC's Office of Nuclear Reactor Regulation (NRR) how to report a reprisal threat.
At,Phil's advice, I spoke with and met Joel Weibe of NRC Inspection and Enforcement (I&E) later r
.y
,__,,._-__.__,..,___,,_.--.-,___,.-_-_.m__y 7
Y.
i-l that day.
I' requested confidentiality, which Weibe said would be granted unless it was " absolutely necessary" to release my identity.
l j
I r'epeated the previous. events of the day and asked what could be done to prevent a transfer.
He replied that the NRC "would take a dim view" if I were suddenly transferred, and there probably would i
be an I&E investigation.
Otherwise, he did not offer advice or j
ass 3. stance.
i i
February 21 was a holiday.
On. February 22 I received a phone
' call'from charlie Hansen, who reports directly to Jim Theising.
Hansen asked me to attend an 11:30 a.m. meeting with B. Kanga to discuss my comments on the polar crane.
Han n's main item of interest was my first comment on the test procedure, that it was an unreviewed safety question and therefore reportable under 10 C.F.R. 50.59.
I stated that this issue was better handled by licensing than i
j' at the departmental level.
l i
After this conversation, I asked Larry King if he had been l
invited to the. same meeting.
He said no, but he would attend des-pite having to cut short a previously-scheduled meeting.
Around
.11: 00 a.m. Hansen called again and moved it up to 11:15.
When I arrived around 11:15-11:20, the meeting was in progress.
- Kanga, Theising, Freemerman, Lake, Hansen, King, Chwastyk and Jim Larson f
of licensing were in attendance.
If I hadn't asked Larry King about the meeting, I would have been the sole So representative.
Mr. Larson had already come and gone after reporting that he didn't know about the 50.59 issue and the lawyers were looking into it.
i Mr. Kanga stated early that he had to catch a plane,- The meeting I
accomplished nothing.
50 explained how the load te'st and polar 1
i crane refurbishment program violated site administrative procedures t
=
s.
,7 due to the violations summarized above of AP-1043, AP-1047 and an unreviewed safety question.
Kanga and the others disagreed.
Ron Freemermanstatedthlattherehadbeennoreplacementofunlikekind in the refurbishment process.
Theising stated that no one had the i
time to read all the administrative procedures for daily business at i
Unit II.
I replied, "I know four people here that have found the time not only to read them but to learn them."
Larry King added it was clear.that those disputing the procedures had not read them, i
There was no denial.
I stated that if management were not familiar with the procedures, they should get QA involved to see if they applied.
I pointed out that I had extensive experience in the
\\
startup and tcat department, and had gone through at least two OA f
+
audits and one I&E as-built audit.
As a result, I knew what the J
a'uditors looked for and that the load test program as presently con-stituted could result in substantial violations and a possible citation.
I also stated that I was still the alternate startup and i
test supervisor for Unit II and did no.t want to have to' resolve audit 1
l _-
~ findings.
Kanga ordered Larry King to appoint a test director for the a
' polar crane.
Larry took exception.
He said that 50 would then be That would be legally responsible for all consequences of the test.
4 inappropriate since 50 had not been involved with the refurbishment process and prior tests of the polar crane.
l The meeting was adjourned with no resolution.
Kanga did issue s
two directives.
First, Larry King should appoint a test director.
Second, Jim Theising should arrange another meeting, this time with QA also in attendance, to discuss th$ applicability of AP-1043 and I
i AP-1047 for the entire polar crane refurbishment and test program.
4 l
2
23 -
I have since learned that Larry King, c'her members of his t
i f amily and' Benjamin J. Slone, a personal friend of mine employed the Shoreham Nuclear Power Station in New York,'. that evening rec unsolicited phone calls from a "Mr. Blizzard," who identified hi self as a Bechtel employee out of Gaithersburg, Maryland.
Larry i
'was out and did not receive the call.
The others did. (This was the first time Mr. Blizzard had called.
Around a week earlier ?
had called for Larry King at work and lef t a message that he was old friend.)
The substance of the calls was that Bechtel wanted reach either Ben or Larry to offer a con'sulting job at TMI-II.
should be explained that Ben Slone and Larry King had formed the I
osni company, known as Quiltec,, sometime in 1981.
On the morning of Wednesday, February 23, Ben Slone telep!
for Larry King.
Larry was unavailable and I took the call.
Re:
asked if I knew a Mr. Blizzard and explained the previous day's He asked what I thought of Bechtel offering him a contract at T.
I said that in my opinion the whole deal stank and sounded like 4
s i
trick.
If I were him I wouldn't have anything to do with it.
1 :-
I have since learned that Blizzard tried several more tim to get through over the next few days.
I know that Larry's wif 1
bawled Blizzard out for asking prying questions.
She told me.
Later that ' day I attended a meeting in B. Kanga's office, along with John Barton, Jim Theising, Ron Freemerman, Ed Kitler Mike Radbill, Larry King, Dave Lake, Joe Chwastyk, Blaine Balla j
QA manager, and Joe Marsden, QA/QC.
This was the meeting with j
that Mr. Kanga had ordered the previous day.
Ron Freemerman op the meeting by stating that he had read AP-l'047 the night befor and it didn't apply to what we were doing on the polar crane.
I 8
O e
p 4
s
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y 24 -
j Freemerman handed'everyone a copy of the Construction Department j
, Project Instruction CDPI-20, " Control and Documentation of Work After Release from GPU to Construction," issued September 1, 1982.
J He said that everyone, including SO and QA, had agreed to this docu-ment last year to govern all work performed by all Bechtel construc-i tion crews, including those on the polar crane.
Ballard asked who in QA reviewed and agreed to it.
Freemerman didn't know.
The CDPI is an internal Bechtel procedure for work i
packages.
It had never been reviewed and approved by GPU.
I had
.never seen it before; Larry King later told me the same thing.
Fur-ther, there were no signatures on the procedure cover sheet for GPU review and approval.
That in itself was a violation of both AP-1043 and AP-1047.
Ballard added that no one in QA would have approved CDPI-20, because of 54.1.3'of the procedure:
This procedure replaces the GPU controlled TMI Unit #2 procedures for control and documentation of work performed by construction after release by GPU to construction.
i
-The provision overrode the entire GPU system of QA controls on work l
and documentation.
It was a direct violation of the QA recovery program, as well as AP-1043 and AP-1047.
Additionally, CDPI-20 l
circumvented the entire review and approval cycle.
Freemerman then I
asked everyone in the room to review and approve CDPI-20 on the spot.
i Ballard and 50 both deferred and agreed to review it further.
To the i
l best of my knowledge, it is not yet approved.
1 I took exception to Freemerman's position about AP-1043 and AP-1047.
I explained that the modifications and refurbishment pro
- grams both had to comply with the site QA Manual.
I reminded him of my experience in the test program at the Island, and that in.my
. -... -., -, _ _ _. _ _ _ _.. _._ ___ ____..,--- __,, _ ~_
_,o
._m.__-__,,._.,_____,._..
.__-._,-__.____,_._m
i.
current role as alternate startup, and test supervisor I was still responsible to identify potential QA audit deficiancias.
Jim Theising interjected to inform me that I no longer had 'to worry about that.
He had issued a memorandum that day or the day before appointing a new alternate, thereby relieving me.
The new man, Dwight Walker, had been on the Island less than six months and
,had little or no knowledge either of the testing manual or the modi-I fications control program.
He later admitted this to me at a Test k
- f i
Work Group (TWG) meeting.
Further, Ed Kitler had only been startup supervisor since September 'and did not have a good 4
working knowledge of the test manual.
Returning to the February 23 meeting, I suggested that the issue was whether the polar crane load test procedure was a func-1 tional test procedure or not.
A functional test procedure demon-strates the total, integrated capacity of a system or component to j
operationally perform as designed, before releasing it for unlimited 1
use.
Under AP-1043 and AP-1047, if it were a functional test, it would have to go through the turnover process and through site ope-rations prior to the test.
~
Management was visibly upset.
I suggested that the polar crane load test could be classified as a construction test, which i
could be performed prior to turnover.
Freemerman asked if we would still have to perform another test after turnover to satisfy the j
functional test requirement.
I said either we'd have to perform another functional test, or else have the Test Work Group review and approve the procedure prior to turnover.
TWG.could evaluate i
the load test procedure as the equivalent to a fdhetional test.
The TWG officially is a review group utilized as a management
~
t
p i
tool te see that there is testing, operational and program review L
4 for all test and modification procedures to ensure compliance.with i
. all legal requirements.
The members must satisfy ANSI N45.2.6, the i
professional standard for qualifications of test personnel.
TWG's i
are an established practice in the industry to see that reviewers l
knowledgeable of legal and professional codes evaluate all test and modifications procedures.
To the best of'my knowledge, the TWG had not been used to review testing since September 1982.
I j
Before'the February 22-23 meetings, Ed Kitler was chair and I was alternate chair of the TWG, due to our same respective posi-i I
tions as startup and test supervisor, and alternate.
Others included Bill Conaway, manager of radwaste shipping.and disposal, Larry King, John Fornicola of QA, Rich Brownwell of site engineering, and Ron Warren of plant engineering.
Prior to that time the TWG had been effactive and independent.
Its worth had been proven in the SDS f
project' in 1980-81, a full blown test program conducted under intense I
j scrutiny.
I do not recall any commitment at the February 23 meeting i
1 to reconstitute the TWG.
The original reason for the February 23 meeting was to seek l
,QA input.
Blaine Ballard asked Mr. Freememan if there were any replacements of unlike kind.
Freemerman then admitted there had j
been dissimilar replacements.
This contradicted his position from the day before.
Ballard then concluded that the program was in 2
i violation of the QA Manual and a Quality Deficiency Report (QDR)
I probably would be issued.
QDR's are quality records, but they are 3
issued and resolve by the same people responsible for the original 1
violation.
As a result, I was not confident that the loophole had i
~
been plugged, despite Ballard's support.
It was doubtful that those i
i 1
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_,___.-.,_,...,_,y,,__,-y._,w.-,-,._-
,[
1i.*
-who circumvented AP-1043.and AP-1047 would chango th31r mindo and i
i overrule themselves, as has since been confirmed.
i j
At the and of the meeting, it was agreed that QA would perform I
[
an engineering and administrative compliance review of all work pack-ages for polar crane modification and testing.
The PCTF would get j
the work packages to QA by Friday, February 25 or Monday, February 28 at the. latest.
Mike Radbill promised to work throughout the weekend if necessary.
J i
On Thursday, February 24, Kanga, Theising, King and possibly
,Chwastyk had a meeting to resolve the serious programmatic differences about the containment entry procedures, which I had written in January.
(Supra, atli.)
The meeting lasted from 1:00-3:30 p.m.
f when the participants lef t to attend a fire safety meeting 'in Room i
l I
209 that began at 2:30.
i
],
Larry King discussed the first meeting with 50 staff.
He said I
i l
they had not gotten past page one.
Theising had stated that the document I reviewed and modified was the wrong version of the proca-dure, which had been revised already.
This was empirically wrong, as I was later informed.
I had worked on the latest version.
The l
main substantive dispute centered on SO's contention that work in
. containment was under the direction of the shift foreman in overall charge of the containment.
RP's p6sition was that the individual j
i entry or task supervisor at the relevant section of the containment i
would control entry.
These individuals were not always licensed j
1 operators.
The dispute was not resolved.
J Also that afternoon, Larry appointed me as the 50 primary TWG member.
f At approximately 5: 00 p.m. that af ternoon, John Barton ap-proached. Larry King and asked him if he was the president of Quiltec.
i e
ty.
I.
- 28 i
Larry said he was.
At that point', Earton lif ted Larry King'o badg3,'
informed Larry that he was suspended without pay for conflict of interest, and escor,ted him off-site.
I.believe that King told me i
Barton identified GPU-Nuclear (GPU-N) President Bob Arnold as the source of the suspension order.
1 It is significant that Larry King had not made any secret that two weeks before he had requested a meeting with a Mr. Clark, vice president of GPU-N, to discuss with Clark his safety concerns about the way work was being conducted on the Island.
Clark had agreed to meet Larry on-site on February 25, 1983, the same day of the suspension.
That evening Larry King asked me to go with his secretary Joyce Wenger to collect Larry's personal effects from his office.
1 Joyce had to come because I wasn't sure what belonged to Larry.
i When we arrived, we saw Carl Erbac of plant engineering, who was working late.
We all started packing Larry's personal effects in boxes.
As I started to leave the office with a box, a guard and a'nother individual in street clothes approached and asked what we were doing.
We told the guard that we had to pick up Larry's per-t sonal effects, because he wasn't allowed on the Island.
The guard 1
' replied that on John Barton's orders no one was allowed in Larry King's office, nor was anything allowed out.
His hand was in the i
t f
vicinity of his gun, but the guard was very polite.
I said, "Well, f
you don't argue with a man who has a gun."
We returned the boxes.
.l We also asked if we could call John Barton and he agreed.
Joyce called and asked permission to remove Larry's personal things.
Joyce l
later said Barton refused and explained he couldn't knciw that we 1
wouldn't steal GPU property.
Joyce broke down in tears and asked
\\.
f
. ~.
i
)
i
- again.
Barton again refused,
- and we lef t.
The next morning, Larry 's office was locked shut.
The gu'ard hid told another worker, John Perry, that he had been making rounds every 15 minutes and no one could enter the office except Barton l
and Chwastyk.
l At approximately 8:00 a.m.,
Chwastyk arrived at work.
John Barton came and motioned him to Larry King's office, where they held a closed door meeting for a half hour.
Barton left without a word.
. Chwastyk then assembled the 80 staff and announced that Larry King had been fired for conflict of interest.
Chwastyk added that he was j
1
~
i now the acting director of SO and no one could remove anything withot j
j; his prior permission from Larry's office.
Later on that same Friday, February 25, Joe Weibe of NRC asked i
me to meet him at the NRC office on-site, where he took me to see th< l I
senior NRC representative, Lake Barrett.
Mr. Barrett informed me that NRC I&E had inspected the polar crane over the last week and
~
1 j
could find no problems,.
He said that an I&E investigator had gone 1
unannounced to Bechtel in Gaithersburg where he demanded and.receivec i'
calculations for the load drop test.
If I wish6d, I could request a special investigation by the NRC's Office of Investigations.
I re-plied that I would wait until the results were in from the new QA/
a QC review.
I also asked about a statement I had heard the previous week from 50 staff that the NRC was investigating Bubba Marshall and me j
for our attitudes at the head lift. meetings.
I added that there e
l seemed to be widespread knowledge that I had come to the NRC.
I l
Barrett did not respond to either issue.
t j
Barrett and I also discussed at length the firing of Larry i
j
=.
King.
I expressed my belief that Larry King had been fired for
~
raising safety concerns.
I added that I felt similarly vulnerable, because I had raised the same type of issues as Larry and Ed Gischel.
Gischel had received similarly intimidating treatment'.
Shortly after his February 10 memorandum disapproving the polar crane procedures, I
GPU sent him a certified letter directing him to go to the company's Stress control Center to be evaluated by a company-paid psychiatris.t.
I I believe that he has not yet had the examination.
With respect to
}
my fears, Barrett said that NRC could not do anything until the.
I l
action occurred.
~i At 8: 00 a.m. on Monday, February 28, Mike Radbill of PCTF told j
me of a meeting to be held at 9:00 in Mr. Theising's office.
I called,
Theising and offered to attend.
Ron Warren of plant engineering and
)
I both went to the meeting.
Others in attendance included Theising, i
I' Lake, Radbill, Hansen and. Ken Pastor of GPU.
The meeting was to inform the attendees that on Saturday, February 26, Bob Arnold, GPU-N President,had ordered a blue ribbon readiness, review committee (RRC) assembled to review the polar crane.
The RRC would include I
i Kanga, Arnold, Barton, a Mr..Long, Mr. Heward, and others.
These men were all top-level GPU corporate management, except for Kanga.
The February 28 meeting was to identify items for the RRC.
4 l
j We identified engineering; the polar crane SER, which I contended i
j only covered the head lif.ts and needed to include miscellaneous i
crane use, and, light load special shape load drop analysis; inter-nal review of. action statements and related issues; reasons for limiting QA/QC involvement; NRC review and investigation of the j
~
j polar crane; and why there was an engin,eering decis, ion not to load l
1
.y,
)
test the rigging.
This list come's fr,om Ron Warren's and my notes
\\
j of the meeting.
4 j'
'The minutes prepared by Ken Pastor, however, do not include y
all these. items.
Pastor's version said there were only a few maall plant maintenance comments that still need to be resolved.
His
.i 1
minutes concluded that "[o)nly NRC approval should be necessary f
and this should go quickly since NRC comments are already available I
1 i
and should be resolved by the time it's [the polar crane operating i
i procedure]. submitted to the NRC."
Pastor's minutes accurately re-
- flected these statements, which represented the management position at the meeting.
(In my mind, they also demonstrated some collusion -
with the NRC, which was reviewing procedures before they had all"
1 l
dnternalreviewcommentsresolved.)
But Pastor's minutes ignored
{
the points raised by so.
I believe that the minutes do not accu-I*
rately reflect the entire scope of the meeting.
The omissions dis,
guise the serious nature of the problems that RRC should consider.
l After the meeting had adjourned, Jim Theising asked Ron
' Warren and me to stay behind.
He asked, in a fatherly manner, i
what management could do tci smooth over the growing' split between i
So and the other organizations.
During our conversation we told
' him that Larry King was well respected and loved by his employees, because he always backed them up.
We told Theising that there was a general opinion on-site that 50 was a bunch of malcontents, and an unnecessary evil.
Theising said that. until the Larry King 1{
j incident, he had decided to fire one person per month in order i
to curtail interdepartmental squabbling over ancillary issues.
I Now he didn't know how he would handle interdepartmental disputes.
l 4
l
-/f
- 32,-
~
Theising also stated that it was a second or third level 50 super-l, visor who.had gone to the NRC, and he could see why certain people l
, ould be afraid of *a transfer.
This made me believe the NRC had w
i j
violated my confidentiality.
i After the meeting, I received a memorandum with formal res-4 I
penses to my polar crane comments (10M 4370-83-1019).
In the cover l
}
letter, Dave Lake stated that Mr. Kitler had reviewed and concurred i
with Lake's eva.nents.
The essence of the response was that AP-1043 and AP-104i do not apply to the polar crane load test procedure.
The response also rejected my comment that the performance of the 1
test could create an unreviewed safety question under 10 C.F.R. 50:59 due to an increased possibility of a Loss of Coolant Accident (LOCA).
t LOCA's are covered under the FSAR, although the polar crane isn't.
j 5
To date, the polar crane has not been load tested.
(
on March 1st, Joe Chwastyk and I responded to Lake and Kit-1er's c' mment resolution (10M 4 200-83-102).
In the cover letter, o
i l
Chwastyk stated that 50 did not agree with the resolutions and had verified our position with Mr. Ballard.
The cover letter concluded i
! ~~
that 50 "cannot approve the Polar Crane Load Test Procedure until l
these differences are resolved."
The attached rebuttal to the i
comments resolution deferred to Licensing on the issue of an un-t reviewed safety question.
Otherwise, the 50 rebuttal cited the l
4 r
specific requirements of AP-1047 to show they applied.
I l
Also on March 1, Chwastyk and I issued a memorandum (IoM e
4200-83-105) referencing the continued confusion over applicability of AP-1043 and AP-1047.
We summarized Ballard's February 23 posi-l tion that compliance is mandatory.
We offered four suggestions to l
help resolve the issue:
i l
i
.-Y 4 -
1.
Test Work Group review and. concur that all
- testing performed to date was adequate for satisfying intant of required testing.
j I
j 2.
Test Working Group review modifications per-formed on Polar Crane to determine if neces-
'sary testing had been identified / performed.
3.
Implement turnover process for the Polar l
Crane less the performance of any remaining testing.
This testing should be identified as an incomplete work list item from the cog-nizant department. 'Any deficiencies in the refurbishment program would be identified by this process and adequate resolutions could be addressed.
4.
Test Work Group issue memorandum.to TWG Files identifying inconsistencies / deficiencies, to dat's, and necessary steps implemented to pre-i vent recurrence of program violations.
We. added that AP-1043 and AP-1047 had not been incorporated primarily due to lack of familiarity with the procedures and sug-gested that TWG personnel be made available to PCTF personnel for l
indoctrination.
i To date, there has been no formal response to the March 1 memoranda.
B. Kanaa was on the distribution list for both menoranda.
Late on March 1, 50 staff attended meetings on head lift acti-
~~
vities.and the RCS draindown.
When we, returned, our secretary, Joyce 4
l Wanger was visibly upset.
She said Barton had called her to his i
f office and accused her of xeroxing'and taking to Larry King a j
memorandum that had been missing the day before but reappeared on the morning of March 1.
Barton also accused her of making derogatory i
epmments about himself and Bob Arnold.
She later told me that Barton called her that night around 6:00,p.m.unt home and told her to stay i
there until the investigation was over.
Since that time she has told me of enduring many interviews'and interrogations by GPU personnel department representatives, who have always had one or i
O
- 34.-
The9neetings more individuals with them that Joyce did not know.
have been' held off the Island and covered humiliating personal il-subjects which are irrelevant to Ms. Wenger.
i j
addressing On March 1 I also issued an SO " Problem Report" des-PORC's approval of the polar crane no-load operational test, pite failure to comply with AP-1043 and AP-1047.
,I explained that i
this represented a serious problem with one of the installed checks l
It is significant that i
and balances of the TMI recovery program.
i I have not B. Xanga receives a copy of all 50 Problem Reports.
j i
I yet received a response.
On March 3, there was a meeting in Room 209 with the following members -- Theising, Ryder, Jackson, Siglitz, Lake, Larson, Marsden, l
Nick Kazanas of QA/QC, Freemerman, Radbill, Hansen, Gordon Clements
'of Safety Review Group /PORC, and myself.
The meeting was to discuss f.
The presentation a polar crane presentation dry run for the RRC.
Theising asked was scheduled for 8:30 a.m. on Saturday, March 12.
why Gordon Clements and I were at the meeting, since we were not Dick Siglits replied that I was his backup for the pre-i invited.
sentation on operator training, and Dick did'not know if he would i
Mr. Clements be back in time on Saturday for the presentation.
i explained that he was a member of the safety Review Group and was interested in the polar crane.
The meeting continued'in an effort to establish an agenda Items included the technical approach to for the presentation.
the crane, and why the original $5-10 million projected refurbish-4
)
Jacksdn
)
ment program had been scaled down to a $2.5 million program.
stated that the program had been cut at' the personal ' direction of i
I 1
j
l B. Ranga,.and not always with technical justification for the deviations.
There was no response.
Based on my notes, when the issue of the SER arose, Theising said the items discussed should' primarily include load drops, trave paths and accident consequences.
He continued that the presentatio i
l should say that we think it's a good crane, the probability of a
)
ioad drop is low, the consequences are acceptable and the most like i
problem would be an industrial safety accident.
He added that ther should be a presentation of why the structural nature of the crane and the hook are covered by QA/QC, but the cable that lifts it is i
l not.
He did not of fer any justification, but the reason to exclude 1
the cable was clear to me:
it was too late to fully, inspect the
}j cable without removing it completely from the drum.
1 I raised a question about the safety classification of the polar crane cable, explaining why the whole apparatus was important i
to safety.
Mr. Theising replied that only the structure of the era i
l was important to saf,ety, and that only a person of limited intelli-f gance would think otherwise.
I took exception, explaining that the situation changes once the crane is attached to the head -- its j
7-l design function.
At that point, the entire apparatus including the cable which holds the head is performing a safety / nuclear safety-related function.
In retrospect, I feel even stronger about this position in light of the damage already done to the core.
At this point we can ill afford to take any gambles that might diminish our protection against criticality.
1 The meeting adjourned with a final agenda estahlished in the manner originally pres'nted by.Theising, without any significant e
changes.
After the meeting Gordon Clements told me that the comme: ;
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about limited intelligence was aimed at me.
I agreed.
Gordon also. stated his view on the polar crane, which was consistent with so's position.
We also discussed why PORC chair Geo'rge Kunder was notstop[ingtheviolations.
Gordon responded that on several oc-casions Kunder had refused to get involved with the dispute.
In a subsequent conversation, SRG member Jim Floyd confirmed that Kunder did not want to get involved.
George Kunder's unwillingness to get involved did not sur-prise me..It was not-the first time Kunder had refused to challenge questionable management condpct, regardless of the issue.
His key position as chair of the PoF.C/ Safety Review Group is inexplicable.
It is.a common belief among various members of the 50 staff that os l
Mr. Kunder war the " mystery man".who ordered the safety injection
' pumps turned off d$2 ring the March 1979 accident.
This mistake was responsible for a great portion of the damage.
By stopping the flow of coolant, this mistake had prevented cooling of the core.
On several occasions Joe Chwastyk and shift supervisor Bernie Smith identified Kunder as the mystery man, one or the other have identified Kunder to Larry King, Joe Smith of So staff, John Perry of 50 staff', John Auger of tech spec compliance, Joyce Wenger and myself.
I also believe the following people have knowledge that Chwastyk or Smith had identified Kunder as the man who shut down.
safet3i injection pumps, because they,were told about the same story s
in discussions that I-also attended-- Bob Gummo, a procedure coor-l dinator for T[ nit II; _ Bob Ryan of site engineering; Bubba Marshall; Ron Warren fof plant engineering; Lee Rogers of Babcock & Wilcox; and'possibly Ed Kitler, whom 'I believe was once involved in a con -
veisation about the to'pic with Bubba and.myself.
. "1 37
~
On at least two occasions since Christmas that I can recall, I have become frustrated in.my dealings with Kunder and stated t
that I was thinking about' writing a l'tter to the local newspapers a
identifying him as the man who shut down the safety injection pumps.
i on each occasion, I was upset that Kunder was only making biased and cursory reviews of the RO and RP management proposals.
I be-1 lieved that he was ineffective as the PORC chairman.
On each occasion,. Joe Chwastyk was in attendance when I spoke about re-vealing Kunder's role.
Each time, Chwastyk talked me out of it.
He made statements to the effect that "it would not be good for any o' us. "
Others in attendance when I made these statements included Larry King and Joyce Wenger.
All three of us have suffered systema-tic reprisals during this timeframe, while Chwastyk has not.
Before the March 3 " dry run" meeting, there had been a meeting between NRC and Bechtel management to discuss the use of a five-ton hoist attached to the-main hook on the~ polar crane.
The existence of the NRC meeting had been revealed earlier in the day at the " dry run" meeting.
Theising had rejected my suggestion of more TWG input i
~ by explaining that he could fill out a Procedure Safety Evaluation and use the crane.
He said that the NRC had concurred with use of the five-ton hoist at a meeting earlier in the day.
That evening Larry King called me at home.
He was concerned that the NRC may have compromised my confidentiality.
Larry said he had spoken recently with a Mr. Christopher of the NRC Of fice of Investigations (OI).
King recounted. to me that Christopher said he was not fully aware of the problems on the Island, had not been'in O
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sy contact with I&E on the Island, and wanted to know Larry's safety l,
concerns.
When King started, Mr. Christopher asked if th.ese were
.the same concerns being voiced by Rick Parks.
Larry recalled that Mr. Christopher dwelt on this question.
This reinforced my opinion that the NRC had compromised my confidentiality and was continuing to compromise it.
I believe this is a violation of 10 C.F.R.19.16.
Larry also recalled that previously Mr. Christopher had called him and desperately wanted to meet.
Christopher said if he didn't meet with larry by Friday, March 4, he would be fired.
Larry said he couldn't meet, because he had to go out of town.
Christopher asked King if he were going to the Shoreham plant.
King asked why he wanted to know.
Christopher replied that they were going. to have an inspector at Shoreham to investigate the GAP concerns and said he (King) knew of GAP, didn't he?
King' said no, and they'd have to meet when he returned to town.
On March 4, I attended another meeting en the containment entry procedure dispute.
Bill Kelly, manager of management ser-vices, and Charlie Hansen of RP also attended.
We were unable to resolve the major portions of the dispute, because Hansen stated
~
.he did not have authority to override the personal preferences of his boss, Mr. Theis'ing.
Also on March 4, the first Test Work Group meeting was held (10M 4345-83-0005, March 7, 1983).
The meeting was held to discuss the following polar crane procedures -- load test procedure; review of all data given to QA/QC; and the results of the early February no-load test.
QA stated that all deficiencies found by_their review would result in one QDR.
They listed five modifications that were i
_...,...___...m__.__m..
AJ 1,
not made in accordance with AP'104,3--
1) trolley power and control bypass system; 2) installation of 200 amp fuses in the main disconnect in the cab of the polar crane, instead of 300 amp fuses; 3) new festoon cable and pendent station, from which the crane is operated; 4) installation of two mounting brackets for the jib crane on the trolley, which allows the load to be moved in a parallel dirac. tion;. and 5) installation-of a temporary air supply on the crane.
I I believe that these items were not addressed in the polar crane safety evaluation.
John Fornicola of QA also stated that his manager was con-l templating a stop-work order on Unit II, because Recovery Operations had established a trend of noncompliance with site QA procedures
~
based on repeated previous violations of this nature.
Fornicola added that the QA manag.er would not make a decision until he could make his presentation to GPU-N President Bob Arnold at the RRC-meeting.
It is significant that nothing in this* paragraph is in-cluded in the meeting minutes, which were prepared by my replace-ment as alternate startup and test, supervisor, Dwight Walker.
Also at the meeting, I identified various open items of the i
no-load test procedure which were ambiguous.
It was not clear whether the limit switches had functioned properly -- or at all --
during the test.
Limit switches are automatic self-protection devices that prevent the crane from self-inflicted damage.
Along with others, I raised. numerous additional concerns.
For instance, I asked whether the_ crane had been used yet to lift e
e e
e s
.., 3 50 -
any loads.
Mike Radbill assured me that it had not.
In fact, however,' it was scheduled to be used in a few days, on March 7, to lift and move structural steel despite the absence of any load tests.
The crane in f act was used on March 7.
I also asked whether any further modifications were expected Mike Radbill noted that design engineering had directed on the crane.
RO to install " dummy fuses" instead of the 200 amps fuses which al-ready represented an improper modification.
It is very significant
.that dummy fuses cannot interrupt or shut off power to the polar It was agreed that an ECM would be necessary for the modi-
~
crane.
,fication.
For the sake of expediency, however, Rich Gallagher of site engineering agreed to provide paperwork under AP-1013, the electrical jumper and lifted lead procedure, in order to legally perform the modification prior to ECM approval.
Also as a followup issue, TWG agreed to review the load test procedure for technical content only.
Noncompliance with QA issues would be def erred to upper management for resolution.
On March 7 and 8 I was out on sick leave.
When I returned I learned that the NRC had issued a letter to management addressing
~
nine concerns and inconsistencies between the procedures in the l
- approval cycle and the various safety evaluations also in the cycle.
NRC said these concerns could result in a citation.
The issues involved draindown of the reactor coolant system in order to work on and under the reactor vessel head.
This situation occurred because of-- (1) the numerous SER changes and issuance of new SER's to expedite work and avoid delays,
due to problems identified in previous SER's; (2) management's decision to scrap the troubled SER for underhead characterization e
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of the reactor. vessel head and replace it with the " Quick Look" SEF
'used almost a year before'.
The problem is that the conditions in the Quick.Look SER were no longer compatible with'the new conditiori in the plant, such as water levels.
Also the previous SER did not cover certain prerequisites for underhead characterization, a much more intensive program than Quick Look.
The whole reason for under head characterization was that Quick Look stopped several steps she and therefore underestimated the radiation levels.
Yet management j wanted to use an identical SER for both programs.
The NRC was alsc partially at fault, since it was reviewing draft procedures which had not completed the review and approval cycle.
OnFebruah'25, Lake Barrett of the NRC had told ' e the draft review process was at '
m Barrett's own initiative, volunteered to B. Kanga.
It was an atten j
to help GPU shorten the review cycle and meet their schedule.
But the shortcut backfired.
j When I returned March 9, I also contacted John Fornicola of l
TWG and QA.
I expressed my concern that TWG should reconsider our position on use of the polar crane prior to the load test.
Our position had been that TWG would not have to approve use of the
~
polar crane to move loads when there was an auxiliary five-ton-hoist attached to the main hook.
I now thought that any procedure j which used the polar crane for any load should be written, per-formed and evaluated as a test procedure.
I asked Fornicola to consider my opinion from a QA standpoint to assure compliance with AP-1047.
Fornicola said he would consider the idea, and his initi:
reaction was that I was right.,
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N The iacus of tha' polar crano continued to bother me,. and I did more research for my decision as a TWG member on whether to approve the load test procedure.
I reviewed the following--
(1) 10M 4 37 0-83-2 014 from Dave Lake to design engineering requesting the evaluation and acceptability of using the Unit I load cell rigging to move components in preparation for the polar crane load test; and (2) DERO-0064-file 0290/8420, the response to the above item which said the rigging was compatibl'e except for one camponent.
This i
memoranda suggested management realized that it could create prob-lems to us'e lift rigs equipment which had not been load tested.
As a result, alternative equipment was finally being considered.
A third memorandum I studied was 10M-6110-83-039 from Blaine Ballard to B. Kanga (February 23, 1982) on the polar crane safety evaluation.
Mr. Ballard made two particularly significant comments:
"l)
The load test should qualify the same length of cable that will be required for head lift; and 2)
Load testing of the fabricated load test frame prior to Polar Crane load test'has not been addressed, although all other rigging compo,
nents have."
A fourth memorandum, DERO-0063-file 0290/8190, was from design engineering to Recovery Operations. 'This memo called for the in-stallation of dummy fusss in the polar crane disconnect.
Design
~ engineering said that fuses are not required for cable short cir-cuits or ov9rloads, since a 225 amp breaker that powers the crane would provide this protection.
A fifth document that I reviewed, 2'M72-MH02 (September 20, 1982), was the polar crane functional description.
To the best of my knowledge, this document had never been reviewed and-approved for use, except by Bechtel.
It was a key document.
It spicified which O
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-l items would have to be refurbished or replaced in order to recer-tify the polar crane and remove the reactor vessel head.'
A sixth memorandum that I studied, 10M 4370-83-2016 (Febru-f ary 18, 1983), was the crane maintenance and inspection checklist.
I found that the data in the checklist was ambiguous and could not l
demonstrate that inspection results were satisfactory.
I also showed this document to Bubba Marshall and Jim Floyd of the SRG to see if they could make any more sense of it than I could.
They couldn't.
Another document that I reviewed was ECM S-1017, on installa-tion of temporary power for the polar crane.
This ECM installed 2/0 welding cable instead of 2/0 power cable to the reactor building polar crane.
I had discussions about this substitution with Jack Lawton of plant engineering; Lou Snyder of RO; Gordon Clements of
'PORC/SRG; and Pete Grandi of Catalytic Construction, a Bechtel sub-contractor on the job.
We all agreed that we didn't like it, be-cause it was unsafe and poor engineering practice.
Pete Grandi also i
told me the: 225. amp breaker described above would be. replaced with
~
a 250 amp breaker.
I do not.believe that the modifications and concerns described above were listed even generically in the February 18, 1983 polar crane load test SER (10M 4410-83-L-0037).
Based on my previous conversations, it is generally agreed that each single modification is not significant in itself.
But they each weaken the electrical
~
circuitry protection.
As a result, we also agreed that taken in combination they could significantly increase the chance's of an electrical malfunction or failure.
This is a special concern due' I
l
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t
~
44 -
to the recent failure of safety-related breakers to function on an open signal,at the Salem nuclear plant.
l At home the evening of March 9, Larry King called again.
Sometime on March 9' Larry had spoken with Bob Arnold.
Larry was concerned that Arnold was attempting to implicate me with Quiltec in order to fire me as well.
King told me that after his suspension he had been ordered to respond formally to the Quiltec charges.
Part of the response was to include every member of GPU and Bechtel management who knew of Quiltec before February 14.
In his response, Larry named Joe Chwastyk and Ed Kitler.
I asked Larry why he had even talked to Arnold after he had been fired.
Larry responded that the day after he was escorted off site, his suspension was upgradad so that he remained on payroll.
On March 16 he eventually.was fired with March 23 his effective 1ast day as an employee.
Returning to the issue of my involvement, King recounted that Arnold had not said anything as he reviewed the written response, until he came to the question about those with prior knowledge of Quiltec.
Then Arnold asked, What about Parks?"
Arnold continued to dwell.on that issue for the remainder of the meeting.
Lar.m.f told me that he was unaware whether I had known about Quiltec, and so told Arnold.
I said that he should have included me on the list, because around a year ago I had helped him to find a typist who would do some job after hours.
Larry did not recall
\\
the incident.
At any rate I have never received any financial gain dramQuiltecnorhadanybusinessinvolvementwiththis[ firm, which' is owned by my two friends.
It bothered me considerably that Arnold had raised this m
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The whole Quiltec issue disgusts me.
Larry King's ethics o
are bey,ond reproach.
His only " conflict" was based on his insis-tence that the TMI job be done correctly.
I was upset that GPU and Bechtel would try to extend such a pretextual, shabby smear to des-troy my career, when I was not even part of Quiltec.
On M' arch 10, a Thursday, I went to the NRC to discuss the Arnold-King conversation.
I stated that it was another management 4
act to intimidate or remove from the' Island anyone who tries to stop them from violating government and industry standards.
Before the meeting, I had discussed this issue with Carl Erbac, Ed Gischel and another member of plant enginecr_ng.
I wanted their advice on whether I 'should seek a special investigation.
I asked Carl Erbac
~
to accompany me to the NRC meeting, and he did.
When we entered Joe Weibe's office, I stated that I wanted
. to request a special investigation.
I then explained Larry King's call'the previous night and my concern.
Weibe responded that they had been expecting this and'were ready for me.
He handed me a slip of paper with the address of the Department of Labor,(DOL) as well
_~
as Mr. Christopher's phone number.
Weibe said the NRC's official
. position was that it would not get involved, because this is an
. employer-employee labor matter.
I'should go to the Department of Labor.
He said he had spoken to Mr. Christopher at OI to confirm
~
this stand, and Christopher agreed.
I should feel free to call Christopher as well.
Both Mr$ Hrbac and I expressed our concerns over how my confidentiality had been compromised.
I asked what the NRC would do if I were suddenly transferred, laid off or fired?
Wouldn' that tend to prove my point about intimidation and reprisals?
Weibe o
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repeateA that this would be a personnel matter for DOL.
Upon leaving the office, Carl stated and I agreed that I had been had..
When I arrived back at the office, I contacted Mark Kobi of Bechtel RD&D and asked him to take a walk with me.
I trusted and
)
valued Mark's opinion, because he had advised me to stay on the job 1
and do it right after I was first advised by Mr. Morris that I should be counseled for my bad attitude.
At the time, Mark had advised that.I was professionally respected and was needed to help establish GPU staff confidence in Bechtel employees.
He had added that Bechtel needed my experience and that I would be evaluated on my work, not on whether I was well liked.
As a result, I trusted him.
On March 10, I went over the whole story of recent events i
with Mr. Kobi -- including the threats and intimidation tactics.
I asked him how to get in touch with senior Bechtel management in-Gaithersburg to discuss these issues.
Mark told me to contact my Gaithersburg boss Andy Wheeler and request a meeting with one of l
the vice presidents.
Mark said that what I described was not the Bechtel way of doing business.
I thanked Mark and went back to j
i the office.
j At around 1:30 that day, Joe Chwastyk called me into his office.
No one else was there.
He began the discussion by stating I
that if I repeated any of it, he would deny it.
He said he had just been to what would probably be one of his last meetings on the Island.
The meeting was with John Barton, who wanted to know--
\\
k (1) What was Chwastyk's involvement in Quiltec?
(2) What was Par,s doing going to the NRC?
Joe asked me straightforhard if I had called the NRC OI people.
I replied that. I hadn't, which was true.
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Chwastyk then stated that management knew I had gon2 to the NRC and would get me.
He also recommended that I see a lawyer and suggested one of the company-paid lawyers who is representing the
' operators,in the grand jury investigation.
I said, "Thanks, but no thanks.
I don't trust company-paid lawyers.
I'll find my own."
I then told Joe that I felt sick and wanted to leave work.
He gave his permission.
Later that evening of March 10, Larry's wife Gloria King spoke with me.
She said Joe Chwastyk had called to tell them he
.was worried 'about me, because my wife was trying to get some dirt on me that could be used to take away custody of my children.
Al-though it is generally thought on-site that I am divorced, in fact I'ma a widower.
My wife died three years ago.
The company crossed the line when a threat was made that affected my sons.
This threat convinced me to contact and seek iegal counsel from the Government
-Accountability Project.
Until this time I had been struggling within the system.
Thi 3 action prompted me to seek outside help.
I knew now that these people had to be stopped.
On Monday, March 14, I returned to work.
At 8 c 00 a.m. Ed Kitler called me.
Ed stated that my boss from Gaithersburg, Andy Wheeler, and another individual were on their way up to discuss Quiltec.
They arrived around 10:45 a.m.,
and Ed Kitler told me to report to Room 204 of the administration building.
At Room 204 I met my boss Andy Wheeler for the second time in'my life, as well as an individual named Lee Hoffman, who iden-tified himself as a member of the Bechtel internal auditing group (internal affairs) out of the home office.
After preliminary, k
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-48, reassuring smalltalk, Mr. Hoffman started quizzing me on area job shops.
Within a few minutes, I realized that this was a witchhunt.
I stopped the, interview and asked if I could read their notes, and have a copy of their notes after the meeting.
They replied "no" to both questions, stating that it was not Bechtel procedure.
I said it was not my procedure to talk one-on-two, especially in light of recent occurrences and threats against me.
I added that I wanted to'and would answer all their questions truthfully and fully if I could have an impartial witness present.
In reply, they said I was free to leave and did not have to answer any questions.
I said I wanted to answer their questions, but needed to protect myself with an observer.
I specified a member of GPU management whom I knew and trusted.
They said no because this was an internal Bechtel affair.
They suggested B. Kanga, an
~
idea I rejected. -
I said then that I wanted to meet with a Bechtel senior vice president, preferably Mr. Komis who runs the Gaithersburg office.
I explained that I was sick of the-threats and intimidation and wanted it to stop.
I had not even known who ran the Gaithersburg office
- until Hoffman told me.
They asked if we should leave the Island.
I s&id no, we should meet now.
Hoffman called a Gaithersburg vice president named Mr. Sanford and we eventually scheduled a meeting for 8: 00 a.m. the next day.
After more argument, Wheeler and Hoffman allowed me to bring Mark Kobi in as a witness.
The interrogation commenced, with all four of us taking notes.
After 5-10 minutes of questions about east coast job shoppers and irrelevant questions a, bout how job e
shoppers do business, I told them basically that we should talk about Quiltec since that is what they came to discuss.
The rest of the questioning pertained to my alleged involvement With Quiltec.
I told them that I was not part of Quiltec but had some peripheral contact because of my friendship with the owners.
In this context, I told them that once I had helped Larry find a typist who did some work for him after hours, but had not received any financial gain.
It should be noted that Messrs. Hoffman and Wheeler were not interested either in hearing about intimidati n or my safety concerns 9
Hoffman told me that this further information was not for his needs.
)
I replied, "Well, you're going to hear them anyway."
They were openly disinterested in these problems, although I made them listen.
On the way out, Mark Kobi told me that what we had seen was not the Bechtel way.
He, too, felt that I was being set up.
As best I can recall,.he said the approach was inexcusable and he was surprised that I had maintained my composure.
On balance, I believe that the interrogation was a further attempt to retaliate, intimi-
)
date me and force me to back off.on my safety c9ncerns about the I _
polar crane.
~
on. Tuesday, March 15, I met with Mr. C. Sanford, Mr. Hoffman and Mr. Wheeler in a closed-door session.
I allowed this meeting to be three-on-one, because I felt at the time that no Bechtel corporate vice president would participate i'n a smear.
In this meeting I repeated to Mr. Sanford as many of my safety concerns and threats against me as I could remember.
He, too, did not appear to be interested except when I identified specific Bechtel employees )
Sanford did state that Bechtel does not tolerate intimidation of i
its employees.
+
, Sanford then accused me of aiding and abetting Larry King's*
efforts to steal GPU employees for personal gain.
He added that he had not set a date to pass judgment on this issue, buti that I could be fired.
I asked on what grounds.
He responded it'would be for making a poor judgment call.
At this point I regretted speaking one-on-three and didn't see what else could be accomplished.
The meeting was adjourned shortly after.
.On Wednesday, March 16, I hand-delivered through Mr. Kanga's office a letter to Mr. Sanford about our discussion.
The letter stated that I shared management's conflict-of-interest concerns, have not sought or received any financial gain from Quiltiec, and pledged that I wouldn't.
I asked for some written description of employee standards on conflicts of interest since I had not received any indoctrination program.
I wanted to know what was expected of I of fered to reconsider my safety challenges if Bechtel would me..
explain in writing why I was mistaken.
Finally, I asked for a written pledge that the intimidation cease.
The letter is attached as Exhibit l'.
Upon returning to my apartment, I discovered that it had been broken into.
Nothing was taken, but my personal papers had been rifled.
When questioned by the local police department, my neighbors stated that the previous night they had heard what sounded like foot-l steps and something being knocked over_ in my apartment.
- Luckily, my boys and I had not been at home the night before.
Although I
}
cannot prove that the break-in was related to the previous intimi-dation, I coul'd not take a chance on any mental or physical harm to my children.
As a result, I have sent them to a safe location.
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l On Thursday, March 17, at 8: 00 a.m., Mr. Ranga had' me in for a two-and-a-half-hour meeting about the letter I had delivered the day before.
I informed him that to date I still had not received a satisfact6ry response to my concerns on the polar crane; that I still had serious problems with it; and that I was being pressured
. to approve'the load test.
Kanga said his door was always open if I felt intimidated or threatened, but that any further reas~surances would be up to Mr. San-ford.
Nevertheless, he warned me not to go public with my concerns.
He said that once before things had gotten much worse for an employee who had tried that and was " humiliated."
He said it could be as long as.two weeks before any decision was reached on me about Quiltec.
He volunteered that it was unfortunate, but other individuals like myself had come to BeclSel without any indoctrination.
He said C
.that was a problem he would have to resolve.
He said that he had to send a report to Bob Arnold describinj how the issue with me had been handled; that I personally had put Bechtel in a bad light with a client; and that as a result I stood a good chance of getting
~
fired.
Kanga did, however, promise that the Licensing and QA depart-ments would sul:rait written responses to satisfy my concerns on the polar crane.
I told him tha't failure to ensure reviews required by the QA Manual and applicable standards, procedures and regulations constituted an unreviewed safety question.
I said this was especi-ally true, since we worked at TMI Unit II and had told the world that public heal'th and safety were our top priority.
Mrs Kanga was becoming openly nervous and agitated.
We finished the meeting, i
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Around 1: 00 p.m. that day, I informed Joe Chwas.tyk that I could not' approve the polar crane load test, because of the serior
~
violationsthat permeated the program.
I added that I did not ' find anything technically wrong with how the procedure was written for what it covered.
But it did not address the major issues raised i the review cycle.
We had just been going through the motions.
Around 3:30 p.m. that afternoon, I was called back to B.
Kanga's office for a meeting with him and Chwastyk.
The subject of the meeting was IOM 4200-83-147, dated that day from J. Chwast3 It stated that effective immediately Mr. Marshall would replace me as the primary So member on the TWG only for the Reactor Building
' Polar Crane Project The memorandum continued, This action is considered ' appropriate for the present situation and is not considered a negative reflection of Mr. Park's. ability, conduct or per-formance.
The designation of Mr. Marshall should not adversely affect the Polar Crane Refurbishment Schedule.
At the meeting Kanga asked me twice to agree that my removal was not an act of intimidation.
I responded, "In my opinion, the intent is well-defined."
They were too late.
As I left the room I told Mr. Kanya th2
~
I had already signed the procedure.
I had reconsidered after spea ing with Chwastyk earlier and signed with the proviso " based on technical content of the procedure only."
I took this step becau:
I did not want to pursue a personal vendetta about the program, a:
the approval in this form was consistent with the substance of my earlier position.
" Approval based on technical content" is a generic term.
It does not imply either that all required topics have been covered, or that OA requirements have been followed.
6 9
ge l
on March 18, in an attempt to, help update Bubba Marshall for his new duties, I reviewed certain memoranda.
One was a March.7, 1983 NRC public letter signed by B. J. Snyder, Program Director, TMI Program Office, NRR, which concurred with the polar crane refurbish-ment program.
The summary portion of the letter states:
The NRC staff concurs with the Functional Description
^as it relates to the Reactor Building Polar Crane Load Test using the main hoist system.
QA/QC has been in-volved at all stages of the refurbishment process in addition to NRC staff.
Safety considerations have
. been addressed under a separate letter.
My review of the fetter also revealed that on February 17, the same day as my comments on the polar crane refurbishment and the crane itself, GPU had sent the entire program to the NRC for
. concurrence.
This, of course, rebutted the NRC's claim of full prior review and approval.
The NRC position was discredited by another memorandum I
. reviewed, IOM 6110-83-046 UHarch 10, 1983).
The topic of this' memorandum, from Blaine Ballard of QA to Jim Theising, concerned the same polar crane refurbishment review.
Mr. Ballard listed eleven comments indicating QA violations.
The misdeeds included
' ~
modifications made without issuing an ECM; lack of engineering evaluation and documented acceptance for substitute lubricants and oils; insufficient engineering review and approval for all work; drawings or data sheets that were missing from work packages; pack-
~
age sign-offs that were incomplete for individual steps, including
. l 1
cases where work was done without any signatures; design engineering
)
evaluations tbat had been. made by the inspector without engineering
~
corroboration; insufficient capability in work packages to link identified discrepancies with their resolution, insufficient information to document activities,"and work packages that had l
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54 -
been modified, del'cted and' cign;d off no m30 ting th3 ".intant' of the document referenced, or that had steps added subsequent to' reviews by outside groups.
QA is not qualified to do engineering evaluations.
But QA said that neither AP-1043 nor AP-1047 had not been followed, and a Quality Deficiency Report would be issued for the violations.
These findings flatly contradicted the conclusions in the NRC letter issued just three days before.
I The third document I reviewed was a March 14, 1983 note from Lake Barrett of the NRC to J. Larson, Unit II director of licensing.
The note disapproved. the "TMI Unit 2 Recovery Operations Polar Crant Operation" Procedure No. 4000-IMP-3891 (Rev.0).
Barrett listed's'ix reasons for rejecting the procedure:
i 1.
It contains several references to the auxi-m.-
liary hoist / hook.
This portion of the polar crane was never submitted to us' for use and never approved by us for use in the Recovery Operations Program.
Therefore we will not ap-prove a procedure that permits its use.
2.
It does not specify that all rigging used with j
~ ~ ~ ~
the polar crane shall be certified / tested as meeting applicable ANSI standards.
3.
It does not require a quality-control-type check of all rigging for loads in excess of ten tons.
4.
It does not specify.the minimum-weight load that requires a brake test.
We recommend ten tons.
5.
The procedur's should reference an engineering drawing for specifics on the limitations of crane travel.
(An alternative would be to specify the no-travel portion of the' crane arc on Exhibit 2.)
1
'It does not reference a governing procedure 6.
(or other document) to specify the individual who shall be in charge of the overa11 operation when lifting particular loads.
This note contradicted Barrett!s statement to me that he could' find e
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no problem with the polar crane.
i also found it curious that the NRC would issue such a significant negative conclusion in a private " note" to the utility, when it had issued such a glowing public endorsement just three days earlier.
This cozy private relationship with the utility may not be new.
Several sources previously had shared with me their under-standing that prior to issuing formal NRC letters, Barrett's practice has been-to first submit his drafts either to Bob Arnold or B. Kanga
'for editing and comments. 'Once a consensus was ac'hieved, Barrett would issue the letter officially.
The note on disapproval of the polar crane operation procedure added credibility in my mind to these reports.
Many of my concerns raised above involve a systematic attempt i
to circumvent administrative and QA requirements for the polar crane.
This represents a significant breakdown in the system of organiza-tional checks and balances.at TMI Unit II.
I am worried that this 1
structural breakdown may apply to other work done in the plant dur-ing the last year.
)
e
~
Approximately a dozen of the issues I raised directly concern
. public health'and safety,in my opinion.
We must be able to rely on the polar crane when we use.it to remove the reactor vessel head and other heavy equipment.
We can't afford to trust untes'ted equip-ment which has been compromised by an unknown amount of radiation damage.
Most significant, I a'm disillusioned that GPU and Bechtel management are taking such a sloppy approach toward restoring TMI o
e 9
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there is no tJnit II.
In light. of the damage already done at T,MI, excuse to gamble on public health and safety in order to Joset cost-d i
hdls
.and pro uct on sc e u e.
I am equally disillusioned that the NRC has knowingly provided informal guidance and formal approval for this misconduct.
At the same time, the NRC has failed to work in good faith with employees like myself who seek to uphold the law.
If the NRC'and the nuclear industry are this careless at TMI, how much can we trust the pro-grams at other plants?
The issues described above are illustrative of my concerns.
1 They cover major saf ety, administrative and QA violations of the last f ew months.
I am prepared to discuss additional violations, and other issues suqh as gross waste.
5 I have read the above 56-page affidavit, and it is true, accurate and complete to the best of my knowledge and belief.
/
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/
~
RICHARD D. PARKS
/
SUBSCRISED AND SWORN TO before me this4/ hay of
, 1983.
Lt//b' s#/. M Nothry Pub 1::.c-910fA H. StJRKE
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MTARf PUBtJC DISTRICT OF COLUMBIA My Commissicn Expires January 2,1986 e
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EXHIBIT 1 March 16, 1983 Mr. Sanford Bechtel North American Power Corporation Gaithersburg, Maryland
Dear Mr. Sanford:
This is to express my appreciation for the time that you, Mr. Wheeler, and Mr. Hoffman took from your busy schedules yesterday to meet with me about my safety. concerns at Three Mile Island Unit II.
Since the meeting, I have thought hard about the conflict-of-interest issue you raised, as well as my own serious concerns about the legality of procedures being used in the Unit II cleanup pro-gr'am.
I greatly desire to remain an effective, productive employee of Bechtel and a well-respected member of our corporate " family." As a result, I am submitting the following comments and requests for your further consideration:
1)
I appreciate your sensitivity to conflicts-of-interest. In fact, I share it.
As a result, I wish to state unequivocally that I have never' sought nor received any financial compensation and/or gain from the Quiltech Corporation.
So that there will not be any questions about my future conduct, I pledge not to seek or receive any financial compensation and/or gain from Quiltech during my Bechtel employment. So that there will not be any confusion, would you please send me all employee standards of conduct in general, and the conflict-of-interest standards in particular? As mentioned yesterday, I have not yet received any formal-j '
indoctrination about what is expected of me from a Bechtel corporate standpoint.
j
- 2) I would like to reconsider the challenges to procedures in question.
It is difficult to reconsider, how'ever, because I have yet to receive a full analysis of why my concerns are mistaken. To illustrate, there has not yet been any written response to a March 1, 1983 memorandum from Mr. J.J. Chwastyki to Mr. D.M. Lake, which expresses my continuing dissatisfaction with procedures for the Polar Crane Icad Test. ' Rather, I have been pressured to eliminate my objections without any
)
~
' explanation of the flaws in my analysis. Could you please see that I receive such
/
an analysis? This is a serious issue with significant potential safety consequences.
l I' vant to study any other viewpoints seriously before I modify or abandon my own i
professional opinion.
i
- 3) It is difficult to serve mechtel well when I am being intimidated i
for attempting to do my, job conscientiously, and for raising concerns with the Nuclear Regulatory Connission. Can I receive your personal reassurance that i
this intimidation will cease?
Thank you again for your attention. I hope that this letter will be the first step toward ' resolving an unnecessary, regrettable conflict.
CJ CC:
R. Wheeler L. Hoffman B. Kanga f
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Goprnment AcconnalbilityProject M">ma M.t2' lOESO y
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. D.C. 20009 1
M F0R IMMEDIATE RELEA5E FOR MORE INFORMATION PRESS CONFERENCE:
CO.U AGT: ica Devine or Louis Clark Friday, April 22,1983 (202) 234-9382 10:30 A.M.
Majority Caucus Roon (Rcom 140)
Barb Snyder(717)944-1847 State ca pitol Harrisburg, Pennsylvania f
SITE OPERATICh$ WHISTLEBLOWERS FIGHT B ACK 3
At a press conference Friday morning at the State Capitol in Harris-burg, Pennsylvania, a former employee and a sus pended employee at the j
Three Mile Island nuclear plant will answer questions about their Departrent I of Labor complaints against the General Public Utilities Nuclear Corporation 2
(GPUN). They will be. joined by Mr. Thomas Devine, Legal Director of the 3
Government Accountability Project, a Washington-ba sed whi stleblower su ppers
}
group that is representing the two witnesses.
~
Ms. Joyce Wenger, former Administrative Clerk at the TM!-Unit 2 Site l
Operations of fice, announced that she is filing a Department of Labor 3
complaint.in which she alleges that her dismissal on March 23,1983, a f ter k
3 years with GPUN, stemmed entirely from her knowledce of the safety concerns raised by her supervisor, Mr. Lawrence King, who was fired the same day.
j j
A few days af ter Mr. King was suspended in late February. GPUN management i
3 initiated an internal investigation and smear campaign against Ms. Wenger i and she was ordered to " stay home."
In her a f fidavit, Ms. Wenger descrites her ordeal:
l The entire investigation was a nightmare for me.
Words were 4
put in my mouth that I never said, and I was interrogated by 9
. no less than six different representatives of site management on several different occasions about subjects of h i gil y ques.
l tionable relevance to any genuine concern. My co-workers were
'i being questioned about my character and personal li fe.
It was i
obvious to me that certain members of GPUN management wanted 4
to fabricate a basis for firing me, because I had worked for Mr. King, knew that he had raised safety concerns to manage-
}i ment, and because I had also openly expressed my belief that t
Mr. King had been " set up" because he tried to do his job i
right.
In other words, contrary to my previous naive view, i
I was being investigated because ! " knew too much" and couldn't be trusted to remain silent, due to my loyalty to Larry King.
3 Ms. Wenger was fired three weeks later based solely on the ground of "in-j consistent statements" which she did not make during this internal investi-i gation. "The investigation ended as a self-fulfilling prophecy that Ms. Wenge-waaid be fired for being secretary to a supervisor who raised sa faty concerns to management," Mr. Devine said.
Mr. Richard Parks, the engineer who originally disciosed issues of
~
safety concerns about the polar crane ed headli f t operations in th-T ". !.
Unit 2 cleanup program and management reprisals for expressing those can.
cerns, announced the filing of his supplemental co. plaint and a'fidavit to the Department of Labor.
I.
.