ML20213F801

Forwards First Amended Complaint for Damages Re Transfer of R Parks Offsite Due to Comments Concerning Polar Crane Load Test Procedure.Related Correspondence

ML20213F801
Person / Time
Site:	Three Mile Island
Issue date:	05/06/1986
From:	Zuras B HOBERG, FINGER, BROWN, COX & MOLLIGAN
To:	Johnson G NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20213F753	List: ML20213F751 ML20213F762 ML20213F773 ML20213F789 ML20213F801
References
CIV-PEN, EA-84-187, NUDOCS 8611170183
Download: ML20213F801 (3)

Text

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• IIOBERG, FINGER, BROWN, COX & MOLLIGAN A PROFEsssON AL CORPORATION CENTRAL TOWER 703 M ARMET STREET INGEM AR E. HOS ERG (1903 *l978) SAN FRANCISCO 94103 JOHNH FINGE R PHILLtP E. BROWN LAW OFFICES PETER N MOLLIGAN (415)543 9444 STEPHEN T, COM gast EAT; ENTERPWist 800ss RICHARD C RAINES Caste ADOntss"lNGMAR JAMCs GCAGAN May 6, 1986 QAveD w MOYER ROS ROY M ACREY BARB AR A A. 2UR AS S AR A S. EVANS CHRISTINE M. SCH ENON E George E. Johnson, Esq.

Office of Executive Legal Director U. S. Nuclear Regulatory Commission MS 9604 Washington, D.C. 20555 Re: Parks v. Bechtel Power Corporation

Dear Mr. Johnson:

Pursuant to your request, enclosed is a copy of the First Amended Complaint for Damages.

Very truly yours, (p,

BARBARA ,A'.. URAS l

BAZ:ad Enclosure 8611170183 861106

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advises that there is a constant movement of employees in this industry from one contractor to another. He believes there were other persons besides King who acted at times as job shoppers to accomodate these movements. He stated his belief that the full-scale investigation of Parks for his alleged connection with Quiltech was an act of intimid-atton against Parks.

Lawrence King, in his 4/26/83 statement before the House Interior and Insular Affairs Connittee (Exh. F-1), stated he never made any secret "

of Quiltech's existence during the previous 1.5 years the company was in business while he was at TMI. Like Parks, he states, he received no training or counseling at TMI on conflicts of interest, and that none ,

of his work with Quiltech violated GPUN's written guidelines, which prohibit relationship with companies that do business with GPUN. He relates that the day before his dismissal a Bechtel employee made several calls to offer Quiltech a job at TMI, which he distained to respond to. He also expressed the feeling of intimidation about his safety concerns.

Parks wrote two letters to Bechtel about the Quiltech interrogation -

on 3/16/83 (Exh. I appended to Exh. A-1), and on 3/21/83 (Exh. 1 append $d to Exh. A-2). In the fonner letter he sought reconciliation with Bechtel, stating he appreciated their sensitivity to conflicts-of-interest, declared he has not and will n3t seek gain from this source, and requested a copy of the conflict-of-interest standard. He also offered to reconsider his challenges to procedure, but that until responded to he finds it difficult to do so, or to respond to pressures without explanation of the flaws in his analysis. In the second letter, to Mr. Kanga, he refers to Kanga's open door invitation to report continued acts of harrassment and lists the "pretextual investigation" of his supposed involvement with Quiltech.

Exh. 2, appended to A-2, is an " Agreement and Acknowledgement of Oblig-ation" form that serves as Bechtel's conflict-of-interest document, and that Parks claims had not been presented until after the Quiltech examination.

Mr. Kanga stated it ic Bechtel's policy to look into conflict- i <

of-interest problems via the spectal internal group based in San Francisco,'

and are not originated in the Gaithersburg office he reports to. He said Parks had asked him why such a big deal is being made of this issue.

Kanga states he is not doing this - he seeks understanding and to be ensurgd Bechtel employies do nothing to embarass clients.

Attorney Richardson's connents (Exh. A-3) explain that in the course of investigating King's " flagrant conflict of interest" it was learned that Parks, a close friend, may have had some involvement, and it was determined his role should be investigated to see if any Bechtel policies had been i

violated. Further, in accordance with standard procedures, Bechtel management asked the Internal Audit group for investigation of its employees who may have had involvement. Richardson relates Parks' being advised of his right to decline to cooperate without retaliation or reprisal, and and that Parks was questioned in a non-threatening and professional manner.

The Internal Auditor found Parks may have violated Bechtel's policy, but there were mitigating circumstances and no disciplinary action should be taken. Richardson states Parks cannot support his inference that his participation in prctected conduct was the motivating factor in the decision

' to interview him. He said there is no evidence connecting the inter-rogation of him with any retaliation for having gone to the NRC. Also, that the events after the 3/14 meeting are devoid of any Bechtel harrassment or retaliation against Parks for engaging in protected conduct - he was given prompt access to senior Bechtel management, and responsible personnel were made available to review and explain his concerns.

Parks, claims that the investigation was a form of harrassment. An isolated, innocent incident was seized upon four days after he had complained to NRC about Robert Arnold's persistent questioning about Parks' knowledge of Quiltech's activities.

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