ML20211G510

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Response to Interrogatories Re Bechtel Oct 1984 Rept, Rept of Bechtel North American Power Corp Re Allegations of Rd Parks & Eh Stier 831116 Rept, TMI-2 Rept-Mgt & Safety Allegations. Related Correspondence
ML20211G510
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 10/28/1986
From: Jim Hickey
GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
NRC OFFICE OF THE GENERAL COUNSEL (OGC)
References
CON-#486-1329 CIV-PEN, EA-84-137, NUDOCS 8611040054
Download: ML20211G510 (41)
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UiNHC 16 0CT 31 P3 :01 UNITED STATES 07 AMERICA NUCLEAR REGULATORY COMMISQ9N;:g g ,.

00CKEi!HG & MfVib BRANCH BEFORE THE ADMINISTRATIVE LAW JUDGE In the Matter of )

) Docket No. 50-320 GPU NUCLEAR LORPORATION . ) License No. DPR-73 (Three Mile Island Nuclear Station, ) EA 84-137 l Unit No. 2) ) (Civil Penalty) i RESPONSES OF GPU NUCLEAR CORPORATION TO NRC STAFF'S FIRST SET OF INTERROGATORIES DEFINITIONS As used herein the following terms have the following meanings:

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1. "Bechtel Report" refers to Bechtel's report dated October 1984 and entitled " Report of Bechtel North American' Power Corporation Regarding the Allegations of Richard D. Parks."
2. "Stier Report" refers to the multi-volume report of Edwin H. Stier dated November 16, 1983 and entitled
"TMI-2 Report - Management and Safety Allegations."
3. " September 1983 OI Report" refers to the report prepared by the NRC Office of Investigations entitled "Three i

Mile Island Nuclear Generating Station, Unit 2 Allegations i

8611040054 861028 0 DR ADOCK 05000

s O

Regarding Safety Related Modifications, Quality Assurance Procedures and Use of Polar Crane," dated September 1, 1983.

4. " January 1984 Staff Report" refers to the report prepared by the NRC Staff which reviews the September 1983 OI Report.
5. "May 1984 OI Report" refers to the report prepared by the NRC Office of Investigations entitled "Three Mile Island NGS, Unit 2, Allegations Regarding Discrimination for Raising Safety Related Concerns," dated May 18, 1984.
6. "NUREG 0680 Report" refers to the report prepared by the NRC Staff entitled "TMI-I Restart An Evaluation of the Licensee's Management Integrity as Affects Restart of Three Mile Island Nuclear Station Unit 1 Docket 50-289" and published in July 1984.
7. " Exhibit" in reference to a report refers to a statement, deposition transcript, affidavit, or any other document which is attached to or which accompanied the narrative text of the report.
8. "Mr. Parks' California lawsuit" refers to the legal action entitled " Richard D. Parks v. Bechtel Power Corooration, et al." which is pending in the Superior Court for the City and County of San Francisco, State of California (Civil Action No. 831846).

The person or persons who prepared or substantially contributed to the preparation of each of the following responses is indicated in the response.

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e 1

INTERROGATORY NO. 1 Name the members and the affiliation of GPU divisions of the members of the following TMI-2 review groups during I 1982-83 in addition to the number of meetings held by each group during this time:

a. Test Work Group (TWG)
b. Safety Review Group (SRG) j c. Plant Operations Review Group (PORC) f d. General Office Review Board (GORB) i e. Safety Advisory Board (SAB)
f. Technical Advisory and Assistance Group (TAAG)
g. Readiness Review Committee (RRC)

, h. Generation Review Committee (GRC)

RESPONSE TO INTERROGATORY NO. 1

a. TEST WORKING GROUP (TWG) i

)

1982/1983 Membershio Affiliation D. D. Walker TMI-2 Division j E. J. Kitler TMI-2 Division R. D. Parks TMI-2 Division R. P. Warren TMI-2 Division R. E. Gallagher TMI-2 Division J. C. Fornicola Nuclear Assurance Division W. J. Marshall TMI-2 Division i W. C. Ream TMI-2 Division 4

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R. Poulos TMI-2 Division R. F. Fenti Nuclear Assurance Division M. W. Herlihy TMI-2 Division 1982/1983 Meetinos

+

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b. SAFETY REVIEW GROUP (SRG) 1983 Membership Affiliation G. A. Kunder TMI-2 Division E. D. Showalter TMI-2 Division R. P. Brownwell TMI-2 Division M. L. Benson TMI-2 Division G. W. Clements TMI-2 Division _

S. B. Presgrove TMI-2 Division J. J. Bevelaqua TMI-2 Division I. E. Fergus TMI-2 Division

~J. D. Bigbee TMI-2 Division D. C. Carl TMI-2 Division J. C. Auger TMI-2 Division M. P. Murphy TMI-2 Division J. S. Schork TMI-2 Division 4

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1982/1983 Meetinas No formal meetings (established September 19, 1983)

c. PLANT OPERATIONS REVIEW COMMITTEE (PORC) i 1982/1983 Membership and Alternates G. A. Kunder TMI-2 Division W. J. Marshall TMI-2 Division 2

M. R. Hamby TMI-2 Division M. L. Benson TMI-2 Division G. W. Clements TMI-2 Division i

P. E. Ruhter Radiological Controls Division M. D. Pavelek TMI-2 Division E. D. Showwalter TMI-2 Division T. E. Rekart TMI-2 Division H. K. Peterson Radiological Controls Division B. J. Slone. TMI-2 Division i

P. J. Arthur TMI-2 Division J. D..Lawton TMI-2 Division B'. A. DellaLoggia Radiological Controls Division i

R. P. Warren TMI-2 Division A. W. Miller TMI-2 Division 2104R -

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K. J. Hofstetter TMI-2 Division B. S. Pressgrove TMI-2 Division K. L. Harner TMI-2 Division i

J. A. Flanigan Radiological Controls Division C. G. Hitz TMI-2 Division W. F. Kelly TMI-2 Division J. J. Byrne TMI-2 Division S. B. Presgrove TMI-2 Division J. .R. Floyd TMI-2 Division R. P. Brownwell TMI-2 Division j G. M. Lodde TMI-2 Division-I. E. Fergus TMI-2 Division

,- M. P. Murphy TMI-2 Division J. D. Bigbee TMI-2 Division l

i i 1982/1983 Meetinos 166 I
d. GENERAL OFFICE REVIEW BOARD (GORB) 1982/1983 Membership Affiliation i

J. J. Barton GPUN - TMI-2 Division R. E. Brooksbank Consulting Contract To GORB D. K. Cronberger GPUN - Technical. Functions Division I

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I. R. Finfrock, Jr. GPUN-GORB Chairman T. L. Gerber Consulting. Contract To GORB C. H. Ice Consulting Contract To GORB D. T. Leighton Consulting Contract To GORB W. W. Lowe Consulting Contract To GORB M. E. Miles Consulting Contract To GORB L. H. Roddis Consulting Contract To GORB R. N. Whitesel GPUN - Nuclear Assurance Division 1982/1983 Meetinas 22 i

e. SAFETY ADVISORY BOARD (SAB) 1982/1983 Membershio Affiliation Dr. James C. Fletcher Consulting Contract to GPUN President Dr. John A. Auxier Consulting Contract to GPUN President Dr. Jacob I. Fabrikant Consulting Contract to GPUN President Dr. Robert S. Friedman Consulting Contract to GPUN President Dr. Clark-Goodman Consulting Contract to GPUN President Dr. Bruce T. Lundin Consulting Contract to GPUN Presideat Prof. Howard Raiffa Consulting Contract to GPUN President Prof. Norman Rasmussen Consulting Contract to GPUN President Dr. William R. Stratton Consulting Contract to GPUN President i

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Dr. Merril Eisenbud Consulting Contract to GPUN President Mr. Lombard Squires Consulting Contract to GPUN President 1982/1983 Meetinos 8

f. TECHNICAL ADVISORY AND ASSISTANCE GROUP (TAAG) t 1182/1983 Membershio Affiliation R. Brodsky Consulting Contract to EG&G Idaho, Inc.

N. M. Cole Consulting Contract to EG&G Idaho, Inc.

E. A. Evans Consulting Contract to EG&G Idaho, Inc.

W. H. Hamilton Consulting Contract to EG&G Idaho, Inc.

T. A. Peterson Consulting Contract to EG&G Idaho, Inc.

E. F. Sise Jr. Consulting Contract to EG&G Idaho, Inc.

A. P. Malinauskas Consulting Contract to EG&G Idaho, Inc.

T. A. Hendrickson Consulting Contract to EG&G Idaho, Inc.

C. W. Hess Consulting Contract to EG&G Idaho, Inc.

D. O. Campbell Consulting Contract to SG&G Idaho, Inc.

T. S. Cramer Consulting Contract to EG&G Idaho, Inc.

R. H. Earl Consulting Contract to EG&G Idaho, Inc.

E. J. Wagner Consulting Contract to EG&G Idaho, Inc.

Dr. A. Roberts Consulting Contract to EG&G Idaho, Inc.

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1982/1983 Meetinos 24

g. READINESS REVIEW COMMITTEE MEMBERS (RRC) 1982/1983 Membershio Affiliation R. C. Arnold GPUN - President P. R. Clark GPUN - Executive Vice President I. R. Finfrock GPUN - GORB T. L. Gerber Consulting Contract to GORB R. W. Heward GPUN - Radiological Controls Division R. L. Long GPUN - Nuclear Assurance Division D. T. Leighton Consulting Contract to GORB J. J. Barton GPUN - TMI-2 Division B. K. Kanga Director /TMI-2 (Bechtel employee on loan to GPUN) 1982/1983 Meetinas 2
h. GENERATION REVIEW COMMITTEE (GRC) 1982/1983 Membershio Affiliation W. F. Schmauss GPUN Technical Functions Division E. F. O'Connor GPUN Technical Functions Division 2104R '

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l R. C. Cutler GPUN Technical Functions Division G. A. Kunder GPUN TMI-2 Division J. D. McCarthy GPUN Technical Functions Division R. L. Miller GPU Service Corps. - System Laboratory M. A. Nelson GPUN TMI-l Division D. H. Reppert GPUN Radiological Controls _ Division M. J. Stromberg GPUN Nuclear Assurance Division P. R. Walton -

GPU Service Corps. - System Laboratory J. D. Abramovici GPUN Technical Functions Division L. C. Lanese GPUN Technical Functions Division J. D. Luoma GPUN Technical Functions Division 1982/1983 Meetinos 10 (F.R. Standerfer)

INTERROGATORY NO. 2

a. Identify the person or persons employed by GPUN or Bechtel who provided or received information which led to the interrogation of Richard D. Parks concerning the Quiltec company on March 14, 1983 by Messrs. Wheeler and Hoffman.
b. Identify all oral or written communications relating to the decision to interrogate Mr. Parks concerning his alleged involvement with Quiltec.

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RESPONSE TO INTERROGATORY NO. 2 (a) The following employees provided or received the information in question:

David Buchanan 4

Richard Gallagher James Thiesing Larry Santee James Troeblinger Rose (Rittle) Pavalonis l Charles Sandford Herbert Bruner t

i Lee Hofmann Bahman Kanga William Austin (Thiesing, Gallagher, Troeblinger, Santee, Sandford, Bruner, Hofmann)

(b) On February 22; 1983, after James Thiesing received

! confirmation of Larry King's association with Quiltec, Mr. Thiesing was told by David Buchanan that Rich Gallagher had knowledge about Quiltec. Later that_ day, Mr. Thiesing met with Mr. Gallagher in the presence of Mr. Buchanan. During this meeting, Mr. Gallagher informed Mr. Thiesing that in mid-1982 his secretary, Rose Rittle,

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typed Quiltec resumes after hours. Mr. Gallagher said that I Ms. Rittle did this work at the request of Mr. Parks. Similar information was later received from William Austin.

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e In response to the foregoing information, Larry Santee and James Troebliger interviewed Ms. Rittle on March 3, 1983.

Ms. Rittle informed them that in the summer of 1982, Mr. Parks had asked her to type the resumes of a number of TMI personnel on Quiltec stationary. She stated that she recalled some of the resumes as being those of Ben Slone, Mike Herlihy, Larry King, William Austin, William Henry III, Ted Rekart, and Ken Lionarons.

Mr. Parks asked her to keep this typing job confidential. She also stated that Mr. Parks paid her $75 cash after she completed the work.

The substance of the foregoing was conveyed to Charles Sandford by Herbert Bruner, Bahman Kanga and~possibly others.

Mr. Sandford then directed that the matter be referred to Bechtel's internal audit department. Following this referral, Lee Hofmann, Bechtel's chief internal auditor, decided to interview Mr. Parks as part of the internal audit investigation. Mr. Sandford informed i Mr. Arnold between March 3 and March 14, 1983 of the decision to interview Parks regarding a potential violation of Bechtel's policy on avoiding conflicts of interest with clients. Mr. Arnold did not object to that decision by Bechtel.

In further response to interrogatory no. 3(b), GPUN refers to James Thiesing's memorandum to Bahman Kanga, dated February 26, 1983, Darrel Blizzard's meidorandum to Joe Buell dated February 23, 1983, and James Thiesing's memorandum to Herbert Bruner dated March 2, 1983 and to the communications and documents relating to 2104R -

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4 other interviews conducted by Mr. Hofmann, which communications and

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interviews are described in GPUN's response to interrogatory 3 below, and to the notes prepared by Larry Santee and 1

i James Troebliger and file memorandum of James Troebliger dated f

I March 3, 1983 with respect to their interview of Rose Rittle on~

1 l March 3, 1983.

(Thiesing, Gallagher, Santee, Sandford, Bruner, Hofmann)

INTERROGATORY NO. 3

a. State the names and positions of all GPUN or Bechtel d

employees interrogated by Messrs. Wheeler and Hofmann concerning the l

l Quiltec Company, and the date of each interrogation.

l b. Identify any persons not named in answer to l

interrogatory 3(a) above, who from June 1, 1982 to the present, were l

or interviewed, deposed, or otherwise requested by any employee of, attorney or agent for GPUN or Bechtel to provide information concerning Quiltec Company.

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c. Identify all oral communications or documents a

concerning interrogation of TMI-2 employees concerning the Quiltec I

Company.

d. State the length of time Richard Parks was i

interrogated.

RESPONSE TO INTERROGATORY NO. 3 1

j (a) GPUN states that Mr. Hofmann.or Mr. Wheeler or 4

both interviewed the following persons with respect to Bechtel l

internal audit's investigation concerning Mr. Park's l

I involvement in the Quiltec matter:

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1. Mr. Parks on March 14, 1983.
2. Edward Kitler on March 10, 1983.
3. Darrel Blizzard on March 10, 1983.
4. Joseph Buell on March 10, 1983.
5. Bahman Kanga on March 11, 1983.
6. Rose Rittle on March 11, 1983.
7. James Thiesing on March 11, 1983.

(Hofmann, Wheeler)

(b) GPUN objects to subparts (b) and (c) of interrogatory no. 3 on the grounds that they are not relevant to the subject matter of this proceeding and are not calculated to lead to admissible evidence insofar as they seek information concerning inquiries made after Mr. Parks' press conference on March 23, 1983. Without waiving the foregoing objections, GPUN responds as follows:

John Barton William E. Austin Milton Pollack David Buchanan Joseph Chwastyk Philip Clark Richard Gallagher Larry King Larry Santee (Stier, Thiesing, Arnold, Buell, Blizzard, Clark, Gallagher, Santee) 2104R '

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(c) In addition to other oral communications which are described elsewhere in these responses, the following oral communications took place concerning inquiries made of TMI-2 employees with regard to the Quiltec matter, prior to March 24, 1983:

1. The oral communications described in Mr. Thiesing's memorandum of March 2, 1983 to H. D. Bruner and in Darrel Blizzard's memorandum to Mr. Thiesing of February 23, 1983, and in Larry Santee's letter to Robert Arnold of March 4, 1983.
2. When Mr. Parks first met with Mr. Hofmann and Mr. Wheeler on March 14, 1983, Mr. Parks was advised of the purpose of the requested interview, Mr. parks requested permission to invite a co-employee to sit in during the interview, which request was granted. The substance of the interview is described in the notes of the interview made by Mr. Hofmann, Mr. Wheeler and Mark Kobi. These notes have been or will be produced to the NRC staff in response to the NRC Staff's first request for production of documents.
3. As described in his written interview notes, which notes will be produced to the NRC Staff, Mr. Hofmann participated in oral communications with additional individuals as stated.in GPUN's response to interrogatory no. 2 above.

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4. On February 24, 1983 Mr. Arnold and Mr. Clark talked to Mr. Barton by telephone and directed that he and James Troebliger meet with Mr. King and question him with I

regard to Quiltec. Mr. Arnold subsequently met with and interviewed Mr. King. See Exhibit 8 of Stier Report.

5. Mr. Barton interviewed Mr. Chwastyk on March 10.
6. Mr. Barton also may have interviewed Massrs. Buchanan and Austin.
7. Mr. Arnold interviewed Messrs. Chwastyk, Buchanan and Austin. See Stier Report Exhibit 8.
8. Also see Stier Report Exhibits 265 and 273.

(Stier, Thiesing, Arnold, Buell, Blizzard, Clark, Gallagher, Santee)

(d) Mr. Parks' interview by Messrs. Hofmann and Wheeler on March 14, 1983 lasted approximately 3-4 hours.

(Hofmann, Wheeler)

INTERROGATORY NO. 4 Identify each GPUN or Bechtel North American Corporation employee to whom Richard Parks expressed concerns, either orally or in writing, about the safety of and/or procedures for, the testing of the polar crane at TMI-2.

RESPONSE TO INTERROGATORY NO. 4 GPUN objects to interrogatory no. 4 on the grounds that it is not relevant to the subject matter of this proceeding and is not calculated to lead to the discovery of admissible evidence in that it seeks information regarding 2104R -

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concerns conveyed after Mr. Parks' press conference on  !

March 23, 1983. Without waiving the foregoing objections, GPUN responds that Mr. Parks expressed concerns of varying degrees of substantive specificity concerning the polar crane to the following GPUN and BecbS.el employees or representatives prior to March 23, 1983: Larry King, Joseph Chwastyk, Mike Radbill, Edward Kitler, Charles Hanson, James Thiesing, Ronald Freemerman, Bahman Kanga, John Barton, Edward Gishel, Blaine Ballard, Joseph Marsden, Gordon Clements, John Fornicola, Peter Grandi, David Lake, Dwight Walker, Richard Sieglitz, David Buchanan, Ronald Warren, Richard Gallagher, Walter Marshall, Andrew Wheeler, Lee Hofmann, Richard Jackson, Mark Kobi, Nicholas Kazanas, Charles Sandford, and Vernon Leopard.

(Stier)

INTERROGATORY NO. 5

a. Identify each GPUN or Bechtel North American Corporation employee who, after February 18, 1983,-became aware of complaints concerning activities at TMI-2 made by Richard Parks to NRC personnel.
b. Identify all oral or written communications, through which any such employees became aware of such

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complaints.

RESPONSE TO INTERROGATORY NO. 5 GPUN objscts to interrogatory no. 5 on the grounds that it is not relevant to the subject matter of this

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proceeding and is not reasonably calculated to lead to the discovery of admissible evidence to the extent that it seeks information regarding employees who became aware of the complaints in question after Mr. Parks' March 23, 1983 press conference. Without waiving the foregoing objections, GPUN states:

(a) During the time period between February 18, 1983 and the aforementioned press conference, the following GPUN or Bechtel employees or representatives were informed that Mr. Parks had made complaints to NRC personnel concerning activities at TMI-2:

Carl Hrbac Lee Hofmann Andrew Wheeler Charles Sandford Bahman Kanga Joe Chwastyk Mark Kobi (Hoffman, Wheeler, Sandford, Kanga, Chwastyk, Kobi, Stier)

(b) On March 10, 1983, Mr. Parks told Mark Kobi that he had been to the NRC concerning the alleged harassment he had received after raising issues concerning the polar crane and that the NRC had conducted an investigation into his technical concerns but concluded that they were not valid.

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2. On March 10, 1983, Mr. Parks may have indicated to Joseph Chwastyk that he had visited the NRC.
3. Lee Hofmann, Andrew Wheeler, and Mark Kobi were told by Mr. Parks on March 14, 1983 that he had gone to the NRC to complain about threats which he had allegedly received as a result of the comments he made concerning the Polar Crane.
4. On March 15, 1983, Mr. Parks told Charles Sandford, Andrew Wheeler, and Lee Hofmann that he had gone to the NRC concerning vaguely described concerns with respect to the Polar Crane.
5. Mr. Kanga and possibly others reviewed or were otherwise aware of Mr. Parks' letter to Charles Sandford of March 16, 1983, makes reference to " raising concerns with the Nuclear Regulatory Commission."
6. Mr. Kanga and possibly others reviewed or were otherwise aware of Mr. Parks' letter to Mr. Kanga of March 21, 1983 which refers to Mr. Parks' " reports to the NRC."
7. With regard to Mr. Hrbac, see his statement in Appendix C of the Stier Report.

(Stier, Hofmann, Wheeler, Sandford, Kobi, Chwastyk, Kanga).

INTERROGATORY NO. 6 Identify all other documents (not identified in previous responses) which contain information relating / referring or pertaining to Richard Parks making complaints to NRC personnel.

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RESPONSE TO INTERROGATORY NO. 6 GPUN objects to interrogatory no. 6 on the grounds that it is not relevant to the subject matter of this proceeding and

, is not reasonably calculated to lead to the discovery of admissi-ble evidence insofar as it seeks information concerning com-plaints made by Mr. Parks after his press conference on March 23, 1983. Without waiving the foregoing objections, GPUN states that, apart from the documents identified elsewhere in these re-sponses, it knows of no other documents authored before March 24, 1983 except the memoranda written by NRC personnel, which memoranda were produced by the NRC staff in response to GPUN's first request for production of documents, and Mr. Park's affida-vit of March 21, 1983.

(Stier)

INTERROGATORY NO. 7

a. On what basis do you contend that it was necessary to suspend Richard Parks' employment and bar him from the site to avoid disruption?

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b. State each and every fact, and identify all docu-ments which support or otherwise pertain to such contention.
c. Identify each and every person who contend would have been adversely affected by Parks' presence at TMI-2 on or after March 22, 1983, and explain the basis for such contention and why.

RESPONSE TO INTERROGATORY NO. 7 A response to Interrogatory No. 7 will be filed in the near future.

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INTERROGATORY NO. 8

a. Identify each investigation conducted by GPUN or Bechtel concerning the allegations of improper activities at TMI-2 contained in the affidavit of Richard D. Parks dated March 21, 1983.
b. Identify all reports, documents, or communications containing the findings of such investigations, or which relate, or refer to such investigations.

RESPONSE TO INTERROGATORY NO. 8 GPUN objects to Interrogatory No. 8 on the grounds that it is vague and ambigious in that it is uncertain what the Staff means by " investigation." Insofar as Mr. Parks expressed con-i cerns about the polar crane before the March 23 press conference, those concerns were pursued during.the course of the review pro-cess at TMI-2. Construing this Interrogatory as not seeking

' facts concerning the addressing of these concerns in the review process, GPUN responds that the following investigations were conducted after the March 23 press conference with respect to the issues raised in his affidavit of March 21,-1983:

(a) 1. Between March 23 and March 24, 1986, John Barton obtained statements from individuals identified in the Parks' affidavit as having knowledge of the

" mystery man."

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2. In April, 1983, GPUN established a TMI-2 Special Review Task Force, under the supervision of Robert Whitesel, to investigate the technical issues raised 1

in the Parks affidavit. l l

3. On March 25, 1983, GPUN retained Edwin H.

Stier to conduct a complete, independent i

investigation of Parks' allegations, except for the allegations that Parks had been harassed by Bechtel.

4. On March 29, 1983, attorneys for Bechtel began an investigation of Parks' allegations in preparation for litigation before the U.S. Department of Labor, concerning Parks' allegations of harassment by Bechtel.

(b) GPUN has presently identified the following documents which may be responsive to this Interrogatory. GPUN will supplement its answers as additional documents are identified.

1. Stier Report
2. Bechtel Report
3. Preliminary Report TMI-2 Special Review Task Force, July, 1983
4. Edwin H. Stier Preliminary Report on

" Mystery Man" Allegations, April 21, 1983

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5. Memorandum to Thiesing from TMI-2 Special Review Task Force Polar Crane Refurbishment and Testing Procedural Compliance, May 23, 1983, 6363-83-0007
6. Memorandum to Thiesing from TMI-2 Special Review Task Force Polar Crane Refurbishment and Testing Review, May 6, 1983,.6361-83-00005
7. Responsep from Thiesing to Whitesel, May 17 and June 2, 1983
8. Letter from Edwin H. Stier to Robert Arnold, June 22, 1983
9. Memorandum from Whitesel to Long, July 30, 1984, 6300-84-624
10. Various documents in the files of the Special Review Task Force that were gathered during its investigation
11. Letter from Edwin~H. Stier to Robert Arnold, September 6, 1983
12. Letter from Edwin H. Stier to Robert Arnold,

Subject:

Allegation by TMI-2 Employees, September 23, 1983

13. Report: TMI-2 Staff Meeting of March 23, 1983, te Philip R. Clark, from Edwin H. Stier, dated November 1, 1984

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14. Comments on NRC Staff Responses to Questions frcm Udall Committee Concerning TMI-2 Cleanup, prepared for Philip R. Clark by Edwin H. Stier, dated February 27, 1985
15. Letter to NRC Commissioners from Robert C. Arnold,

Subject:

Three Mile Island NGS, Unit 2 Allegations Regarding Discrimination for Raising Safety - Related Concerns, dated June 8, 1984

16. Statements of Individuals Obtained in Response to Request Described in Item 1 of Response to Part a. (Exhibit 37 of Stier Report) l

INTERROGATORY NO. 9 Was Richard Parks questioned by GPUN-Bechtel after the suspension on March 24, 1983 in order to explore his safety concerns? Please identify any such communications.

RESPONSE TO INTERROGATORY NO. 9 By letter dated April 14, 1983, to Thomas Devine of GAP, William F. Hoefs, one of Bechtel's attorneys, requested an opportunity to interview Mr. Parks concerning his allegations. Mr. Devine denied this request on April 19, 1983, as confirmed by a letter from Phillip R. Placier, another Bechtel attorney, to Mr. Devine dated April 20, 1983.

After considerable negotiation, Mr. Parks finally agreed to be interviewed by Edwin Stier. This interview commenced on May 10, 1983, and was aborted by Mr. Parks' refusal to continue the interview after that date.

Mr. Placier was permitted to attend this interview but was prohibited from asking questions.

(Hoefs, Placier)

INTERROGATORY NO. 10[A]

State the current address, place of employment and telephone number of the following persons:

a. Robert C. Arnold k. Rich Gallagher b~. Bahman K. Kanga 1. Dave Buchanan
c. John J. Barton m. H. D. Bruner
d. James W. Thiesing n. R. Wheeler 2104R 10/27/86 -
e. Edwin M. Gischel o. L. Hofmann
f. Joseph J. Chwastyk p. C. W. Sandford
g. Edward T. Kitler q. K. Pastor
h. James Larson
i. Mark Kobi
j. Carl Hrbac RESPONSE TO INTERROGATORY NO. 10[A]

GPUN objects to Interrogatory No. 10 on the grounds that it is not relevant to the subject matter of this action and is not reasonably calculated to lead to the discovery of admissible evidence insofar as it seeks the r.esidential addresses of the individuals in question. Without waiving the foregoing objections, GPUN states:

am Robert Arnold Address: 100 Interpace Parkway Parsippany, New Jersey 07054.

Place of Employment: GPU Service Corporation Telephone: (201) 263-6290 h1 Bahman K. Kanga Address: 15740 Shady Grove Road Gaithersburg, Maryland 20877-1464 Place of Employment: Bechtel Eastern Power Corporation Telephone: (301) 258-4929 2104R 10/27/86 -

nm John J. Barton Address: Oyster Creek Nuclear Generating Station Route 9 Forked River, New Jersey 00731 Place of Employment: GPU Nuclear Corporation Telephone: (609) 971-4814 di James W. Thiesing l

Address: P. O. Box 350 Oakridge, Tennessee 37830 Place of Employment: Bechtel National Inc.

Telephone: (615) 482-0339 at Edwin M Gischel Address: P. O. Box 542 Reading, Pennsylvania 19440 Place of Employment: Metroplitan Edison Company, Central Division Telephone: (215) 929-6521 f2 Joseph J. Chwastyk Forwarding Address: 610'Wartzville Road Enola, Pennsylvania 17025 Place of Employment: None given to GPUN Telephone: None given to GPUN l

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i

g. Edward J. Kitler.

Forwarding Address: 77 Bouilea Ave.,

Middletown, Maryland 21769 Place of Employment: Unknown Telephone: Unknown hm James Larson Forwarding Address: 606 Crestview Road Hummelstown, Pennsylvania 17036 Place of Employment: None given to GPUN 1

Telephone: Unknown 12 Mark Kobi Address: 15740 Shady Grove Road Gaithersburg, Maryland 20877-1464 Place of Employment: Bechtel Eastern Power Corporation Telephone: (301) 258-3000 12 Carl Hrbac Forwarding Address: 3918 Mar. ion-Bucyrus Road Marion, Ohio 43302 2104R

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hm Richard Gallagher Address: Three Mile Island P. O. Box 480 Middletown, Pennsylvania 17057 Place df Employment: Bechtel Eastern Power Corporation Telephone: (717) 948-8196 It David R. Buchanan Address: Three Mile Island

.P . O. Box 480 4

Middletown, Pennsylvania 17057 Place of Employment: GPU Nuclear Corporation Telephone: (717) 948-8321 at H. D. Bruner Address: 15740 Shady Grove Road i

Gaithersburg, Maryland 20877-1464 Place of Employment: Bechtel Eastern Power Corporation Telephone: (301) 258-4119 l

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n2 R. A. Wheeler Address: 15740 Shady Grove Road Gaithersburg, Maryland 20877-1464 Place of Employment: Bechtel Eastern Power Corporation Telephone: (301) 258-3991 -

22 H. Lee Hofmann Address: P. O. Box 3965 San Francisco, California 94105 Place of Employment: Bechtel Power Corporation Telephone (415) 768-7216 at C. W. Sandford Address: 15740 Shady Grove Road Gaithersburg, Maryland 20877-1464 Place of Employment: c/o Bechtel Eastern Power Corporation (Mr. Sandford is retired) at M. K. Pastor Address: Three Mile Island P. O. Box 480 r

Middletown, Pennsylvania 17057 Place of Employment: GPU Nuclear Corporation Telephone: (717) 948-8043 2104R 10/27/86 -

INTERROGATORY NO. 10[B]

For those GPUN employees listed in interrogatory No. 10[A] who are not now employed at TMI-2, please explain the I

reason why they are no longer employed at TMI-2.

RESPONSE TO INTERROGATORY NO. 10[B]

GPUN objects to interrogatory no. 10[B] on the grounds that it is not relevant to the subject matter of this proceeding and is not calculated to lead to discoverable evidence.

INTERROGATORY NO. 11 Identify all documents which support., or are otherwise relevant to, your defense to the following assertions of adverse actions by GPUN-Bechtel prohibited by 10 CFR $50.7 during February-March, 1983:

(a) Removal of Richard D. Parks from the Test Working Group as Alternate Startup and Test Supervisor.

(b) Interrogation of Richard D. Parks concerning the Quiltec Company.

(c) Removal of Richard Parks from the Test Working Group as Site Operations representative for purposes of polar crane review.

(d) Suspension of Richard Parks from active

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employment at TMI-2 and prohibition of his presence at the site.

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RESPONSE TO INTERROGATORY NO. 11 With the reservation that its investigations and review are still continuing, GPUN states that, in addition to the documents identified elsewhere in these responses, the

following documents support or relate to GPUN's defenses to the i assertions in question

, 1. Lake Barrett's memorandum to Bernard J. Snyder of March 24, 1983, concerning TMIPO site actions related to the polar crane / Parks' issues.

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2. Report of Allegation prepared by Joel S. Wiebe and dated February 18, 1983, concerning allegations expressed by Mr. Parks on February 18, 1983.
3. Memorandum from J. S. Wiebe to R. K. Christopher dated March 10, 1983, concerning allegation from Rick Parks, dated February 18, 1983.
4. Memorandum from J. S. Wiebe to R. K. Christopher dated March 11, 1983 concerning additional follow-up on the Rick Parks' allegation dated February 18, 1983.
5. Mr. Parks' affidavits of March 21, 1983 and April 22, 1983.
6. All of Mr. Parks' signed statements given to the NRC.
7. All NRC memoranda or notes of interviews with 1

Mr. Parks.

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8. Affidavits, signed statements, and letters submitted by Mr. Parks to the NRC concerning Diablo Canyon, Zimmer, and other nuclear power projects.
9. The transcript of the deposition of Mr. Parks

- which is currently in progress in Mr. Parks' California lawsuit and the exhibits to such deposition.

10. All of the exhibits to the Bechtel Report.
11. All of the exhibits to the Stier Report.
12. AP 1047 and AP 1043.
13. Memorandum of Kenneth Pastor of January 7, 1982 and memorandum of Mike Herlihy of February 23, 1982 concerning what constitutes a functional test within the meaning of AP 1047.
14. All of the memoranda which identify the members of TWG or announce changes in TWG membership during the-period of 1981 through March 23, 1983, copies of which will be produced to the NRC Staff.
15. All correspondence between Robert Arnold and Larry King during the period of' February 24, 1983 through March 23, 1983 concerning his suspension and allegations.
16. The notes taken by Andrew Wheeler and Vernon Leopard concerning their meeting with Mr. Parks on March 22, 1983, which notes will be produced to the NRC Staff.
17. The notes taken by Charles Sandford concerning his meeting with Mr. Parks and others on March 15, 1983, which notes will be produced to the NRC staff.

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18. Mr. Parks letter to Charles Sandford dated March 16, 1983 and Mr. Parks' handwritten cover note.
19. Mr. Parks' letter to Bahman Kanga of March 21, 1983.
20. Letter from Richard W. Starostecki to Bahman Kanga of March 14, 1983 concerning NRC Inspection 50-320/83-03 and the attached inspection summary and details.
21. Mr. Parks' application for employment with Bechtel dated April 26, 1982.
22. Bechtel Directive No. 2-1 dated June 19, 1979 concerning conflicts of interest.
23. Bechtel " Freedom of Expression and Appeal" policy and procedure and Bechtel Gaithersburg Power Division policy entitled " Professional Excellence", May 20, 1981.
24. Memorandum from Larry King to John Barton dated 1

January 20, 1983 concerning turnover of polar crane to Bechtel.

25. Memorandum from Edward Gishel to Larry King dated February 10, 1983 concerning the polar crane safety evaluation report.
26. Memorandum from Ron Freemerman to Edward Gishel of February 17, 1983 responding to Mr. Gishel's memorandum of February 10, 1983.
27. Memorandum from Bahman Kanga to Robert Arnold of February 18, 1983 and enclosures concerning the polar crane load test safety evaluation report.

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4 28.. Memorandum from Bahman Kanga to Charles Sandford dated March 1, 1983 and enclosed copy of a draft of a memo from Robert Arnold to Larry King concerning the latter's allegations /

Concerns.

29. Weekly reports issued by polar crane task force.
30. All exhibits to Stier Report.
31. All exhibits to Bechtel Report.
32. The September 1983 OI Report and all exhibits thereto.
33. The January 1984 Staff Report and all exhibits thereto.
34. The May 1984 OI Report and all exhibits thereto.
35. The Nureg 0680 Report and all exhibits thereto.
36. Written statement of Mr. Parks dated April 22, 1983.
37. All written memoranda or notes of Department of Labor interviews with Mr. Parks.
38. All written statements given by Mr. Parks, Larry King, Edward Gishel and Joyce Wenger to the N.R.C. and the Udall Committee.
39. All memoranda or notes of NRC interviews of Mr. King, Mr. Gishel, Ms. Wenger and other witnesses.
40. All memoranda or notes of Department of Labor interviews with Mr. King, Mr. Gishe1~, Joyce Wenger and other witnesses.

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41. Transcript of April 26, 1983 Energy and Environment Subcommittee Hearings on Three Mile Island.
42. Transcripts of Mr. Parks' interviews with radio or television news media representations.
43. P. R. Clark's memorandum to file dated February 25, 1983 regarding his meeting with Larry King.
44. Polar Crane Functional Description (Rev. O) and letter from Bahman Kanga to TMI Program Office dated October 8, 1982.
45. Polar Crane Recovery Description dated March 29, 1982 and transmittal to GPUN.
46. Edwin H. Stier's memorandum to' Philip R. Clark dated March 29, 1985 concerning NUREG-0680 Supplement 5.
47. All versions of the Department of Labor report regarding Mr. Parks' allegations.
48. The letter from the Department of Labor reporting the results of the Department of Labor's investigation of Larry King's allegations of unlawful retaliation.
49. The correspondence between Robert Arnold and the House Committee on Insular Affairs, March 17, 1983-May 31, 1983.

INTERROGATORY NO. 12 Identify those individuals, including name, current employer, business and hours, address and telephone numbers and professional qualifications you intend to present at hearings in this proceeding along with the subject of their testimony.

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T RESPONSE TO INTERROGATORY NO. 12 With the reservation that its discovery and review are still continuing, GPUN states that it presently intends to present the following witnesses to testify on subjects relating l to Mr. Parks' harassment allegations:

1. Edward Kitler
2. Lee Hofmann I 3. Richard Gallagher
4. Andrew Wheeler
5. Dwight Walker
6. Charles Sandford
7. Bahman Kanga
8. Joseph Chwastyk
9. David Buchanan
10. Joseph Marsden
11. Robert Arnold INTERROGATORY NO. 13 Identify all oral or written communications, or other documents which relate or refer to the transfer of Richard D. Parks to Bechtel offices in Daggett, California.

RESPONSE TO INTERROGATORY NO. 13 GPUN objects to interrogatory no. 13 on the grounds that it is not relevant to the subject matter of this proceeding and is not reasonably calculated to lead to the

discovery of admissible evidence.

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INTERROGATORY NO. 14 Identify all oral or written communication, or other documents containing information, concerning.the termination of Richard Parks' employment by the Bechtel Corporation in February, 1984.

RESPONSE TO INTERROGATORY NO. 14 In response to interrogatory no. 14, GPUN refers to and incorporates herein its objections to interrogatory no. 13 above.

INFORMATION PROTECTED BY PRIVILEGE In accordance with section 2.740, 10 C.F.R, the foregoing responses are limited to matters which are not protected by the attorney-client privilege or the work product privilege.

Dated: SHAW, PITTMAN, POTTS & TROWBRIDGE By \' O_

ckey J.fP'atrick Att rneys f%or GPU 1N r Cor oration 2104R 10/27/86 .

i VERIFICATION l

I, PHILIP R. CLARK state under penalty of perjury:

That I am the President of GPU Nuclear Corporation; that I have read the foregoing "GPU Nuclear Corporation's Responses to NRC Staff's First Set of Interrogatories": and that the informa-tion contained therein is true and correct to the best of my knowledge and belief.

u PhilifR. Clark Subscribed and sworn to before me this 24th' day of October 1986.

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'b a las / A n d '.

O BRZbZ WSKl '

l NOTARY PUBUC OF NEW JtitSEY

'St CaletSS'ON EXPfRE5 007. 4,1:07 l

t D00t'EIU UNITED STATES OF AMERICA uisisc NUCLEAR REGULATORY COMMISSION Before the Administrative Law Judge 16 0CT 31 P3 :01 In the Matter of )

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) Docket No. 50-320 00CKElihGA E k aCf GPU Nuclear Corporation ) License No. DPR-73 ERANCM

) EA 84-137 (Three Mile Island, Unit 2) )

CERTIFICATE OF SERVICE This is to certify that copies of the foregoing " Responses of GPU Nuclear Corporation to NRC Staff's First Set of Interroga-tories" were served by deposit in the United States Mail, First Class, postage prepaid, this 28th day of October, 1986, to the following persons:

Ivan Smith, Esquire Administrative Law Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Branch Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 George E. Johnson, Esquire Office of the General Counsel 9604 MNBB U.S. Nucler Regulatory Commission Washington, D.C. 20555

\AM.O J.iPatrick H:.ckey

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