ML20213F751
| ML20213F751 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/06/1986 |
| From: | Johnson G NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Jim Hickey SHAW, PITTMAN, POTTS & TROWBRIDGE |
| Shared Package | |
| ML20213F753 | List: |
| References | |
| CON-#486-1498 CIV-PEN, EA-84-137, NUDOCS 8611170122 | |
| Download: ML20213F751 (3) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION COU Elfi E(
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WASHINGTON, D. C. 20555
?N November 6, 1986 86 NOV 13 All:29 Off u i 00CM i!,.
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J. Patrick Hickey, Esq.
Shaw, Pittman, Potts & Trowbridge 2300 N Street, NW Washington, DC 20037 In the Blatter of GPU NUCLEAR CORPORATION (Three Afile Island Nuclear Station, Unit No. 2)
Docket No. 50-320 (Civil Penalty)
Dear hir. Hickey:
9 In our meeting of October 28, 1986, you identified certain specific information which you were seeking through your first interrogatories and inquired about the existence of additional resportsive documents.
In addition, you requested that certain information and documents which were identified, but not trade available based on privilege, be provided in whole or part.
1.
The first item of discussion was whether all oral and written com-munications between the NRC and Richard Parks had been identified.
I have contacted the pertinent individuals or offices and come up with the following:
l a.
I was unable to find in OI case files relating to this matter any additional notes or record of the April 27,1983, afay 2, or 51ay 3, 1983 interviews described in answer to Interrogatory 41 (apart from the original copy of the June 6, 1983 statement).
There is no indication, other than the rec-ollection of A. Bill Beach, of any August 1983 interview with 51r. Parks.
b.
Parks gave two sworn statements dated July 25,1983 (Exs.
97, 98 to 5/18/84 OI Report).
1) a 10-page statement concerning harassment and retalia-tion; and 2) a 2-page statement concerning missing records and fail-ure to maintain controls for post-accident modifications.
c.
Parks spoke to P. RicKenna of OIA on June 23, 1983.
That statement is included in the 9/7/83 OIA Report.
Although our review of OI documents is not yet completed, no record 8611170122 861106 PDR ADOCK 05000320 q
G PDR 50j
of any statement to OI on or about that date has been found.
d.
On November 22, 1983, Parks met with R. Meeks.
Meek's l
notes of that meeting have been~ supplied by letter dated October 29, 1986.
Also on November 22, 1983.
Parks met with Robert Capra, Drian Sheron, and Norman Lauben, of the Office of Nuclear Reactor Regulation, concerning Parks' analysis of the EDS Nuclear, Inc., as it related to the "mys-tery man" issue.
An affidavit of Robert Capra, has been prepared,
discussing this meeting and identifying the following documents:
1.
Memorandum dated October 28, 1983, from B.B.
Hayes to H.R. Denton, "EDS Nuclear Inc. Analysis of the High Pressure Injection Pumps," with at-tachment:
" Richard D.
Parks' Overview of the EDS Nuclear Inc. analysis of the High Pressure Infectioi. Activity During the TMI-2 Accident,
11.
Handwritten notes, possibly of 11/22/83 meeting between Parks and Capra, Sheron and Lauben.
iii.
Memorandum dated April 24, 1984 to B.D.
Hayes from H.R. Denton, "NRR Evaluation of HPI Actua-tion at TliU-2 About 5:41 a.m. on March 28, 1979,"
with enclosure.
This affidavit and the attachments arc supplied herewith, e.
Richard Parks gave oral testimony to OIA investigators on June 24, 1985.
This testimony was related to OIA's follow-up Parks' complaints about the 9/7/83 OIA report, requested by memorandum of June 28, 1984, by Samuel Chilk.
The transcript of this interview is enclosed herewith.
2.
In the NRC Staff Supplemental Response to GPU Nuclear Corporation's First Set of Interrogatories and NRC Staff Supplemental Response to GPUN's First Request for Production of Documents, dated October 9,1986, the Staff identified several documents as responsive to Interrogatory No. 37.
With respect to item (e)(1) identified at page 6 of said supplemental response, the Staff has determined to release the six-page transcript of a July 7, 1985 interview with Mr. King.
It is also releasing pages 40 and 50 of an Interview of Lawrence Peter King, of the same date, together with the cover page.
This portion of the interview is responsive to Interrogatory 60.
The Staff objects to disclosure of the remaining pages of this interview, first, because i
the remainder of the interview does not refer or relate to the allegations by
' Parks that he was discriminated against for engaging in protected activities at TMI, or that there were engineering, programmatic or other deficiencies at 1
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TMI, and, second, that it is otherwise protected from disclosure, pursuant to 10 C.F.R.
I
- 2. 790(a)(6) as part of the personnel records of an NRC employee.
3.
It has been confirmed that the December 21, 1983 OI Report of In-vestigation is a public document.
It has an accession number of 850220038.
4.
Without walving the work product immunity asserted in responding to Interrogatory No. 49, the Staff hereby provides the November 6,1986 letter from B. Zuras to G. Johnson.
The attachment referenced in the letter is the complaint in the civil action brought by Parks in California (which I believe you have in your possession).
You also requested, by telephone, a better copy of the Report of Allegation, dated 2/18/83 written by Joel Wiebe, and a copy of page 6 of the DOL Compliance Officer's Report, which was to have been provided in the Staff's September 23, 1986 response, but was apparently missing.
These two document pages are provided herewith.
As I indicated to you, a supplemental response concerning responsive materials in OI files will be forthcoming.
Sincerely,
(
tl v Ge ge Jo nson Counsel for NRC Staff
Enclosures:
As stated cc w/o encl:
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