ML20215D878

First Set of Interrogatories for Documents Re Identification of Util Employees Providing or Receiving Info Leading to Interrogation of Rd Parks Re Quiltech Co.Related Correspondence

ML20215D878
Person / Time
Site:	Three Mile Island
Issue date:	10/09/1986
From:	Woodhead C NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	GENERAL PUBLIC UTILITIES CORP.
Shared Package
ML20215D872	List: ML20215D868 ML20215D878 ML20215D882
References
CIV-PEN, EA-84-137, NUDOCS 8610140341
Download: ML20215D878 (6)

Text

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. wa nyrn ennnre -..nen,w October 9, 1986 DOCKETED USNRC -

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1k5 TJ 10 P3 :19 -

BEFORE THE ADMINISTRATIVE LAW JUDGE 0FFILE Or m ;a y u0CXLim3 & u : ml DU NCH In the Matter of )

) Docket No. 50-320 GPU NUCLEAR CORPORATION ) (Civil Penalty)

) License No. DPR-73 (Three Mile Island Nuclear Station. ) EA 84-137 Unit No. 2) )

NRC STAFF'S FIRST SET OF INTERROGATORIES TO GPU NUCLEAR CORPORATION The NRC staff, pursuant to 10 C.F.R. I 2.740b, serves the follow-ing interrogatories to GPU Nuclear Corporation (Licensee or GPUN) to be answered in writing under oath or affirmation within 14 days.

If additional information comes to light after the Licensee has an-swored these interrogatories, the responses should be supplemented or amended, as necessary, regarding the identity of persons having knowl-edge of discoverable matters, expert witnesses and their testimony and to keep the answers currently accurate as provided in 10 C.F.R.

I 2.740(e).

For each response to the interrogatories hereinsfter propounded, identify the person or persons who prepared, or substantially contributed to the preparation of, the response.

INSTRUCTIONS AND DEFINITIONS

" Document" includes any written, recorded or graphic matter, how-ever produced or reproduced, of every kind and regardless of where located, including but not limited to any summary, schedule, 8610140341 861009

{DR ADOCK 05000320 PDR

memorandum, note, statement, letter, telegram, interoffice communication, report , diary, desk or pocket calendar or notebook, daybook, appoint-ment book, pamphlet, periodical, work sheet, cost sheet, list , graph ,

chart, index, tape, record, partial or complete report of telephone or oral conversation , compilation, tabulation, study, analysis, transcript, minutes, and all other memorials of any conversations, meetings and con-ferences, by telephone or otherwise, and any other writing or recording which is in the possession, custody or control of the General Public Utili-ties Corporation, or the Bechtel Corporation, or any of its officials, em-ployees, representatives, attorneys, investigators or others acting on its behalf.

When identification of an oral communication is requested, identify each participant.in the communication, thcSe present, the date and place of the communication, whether it was by telephone, personal meeting or otherwise, the substance of the communication, and any document that  ::

record, reports, summarizes or confirms the oral communication.

When asked to identify any document:

1. Identify its title and general subject matter;

2. State its date;

3. Identify its author (s);

4. Identify the person (s) for whom it was prepared or to whom it was sent;

5. Identify all persons who received copies.

When asked to identify a person, identify, in addition to the name of the person, and any required information, the last known business and residence address and phone numbers.

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INTERROGATORIES

1. Name the members and the afnliation with GPU divisions of the members of the following TMI-2 review groups during 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)

c. Plant Operations Review Group (PORC)

d. General Office Review Board (GORB)

e. Safety Advisory Board (SAB)

f. Technical Advisory and Assistance Group (TAAG)

g. Readiness Review Committee (RRC)

h. Generation Review Committee (GRC)

2. a. Identify the person or persons employed by GPUN or Dechtel who provided or received information which led to the interrogation of Richard D. Parks concerning the Quiltech company on March 14,1983 by Messrs. Wheeler and Hoffman,

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b. Identify all oral or written communications relating 'to the decision to interrogate Mr. Parks concerning his alleged involvement with Quiltech.

l 3. a. State the names and positions of all GPUN or Bechtel em-i ployees interrogated by Messrs. Wheeler and Hoffman concerning the i Quiltech Company, and the date of each interrogation,

b. Identify any persons net named in answer to interrogatory 3 (a), .above who from June 1, 1982 to the present , were interviewed deposed, or otherwise requested by any employee of, or attorney or agent for GPUN or Bechtel to provide information concerning Quiltech f Company.

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c. Identify all oral communications or documents concerning interrogation of TMI-2 employees concerning the Quiltech Company,

d. State the length of time Richard Parks was interrogated.

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.

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 complaints.

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.

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?

b. State each and every fact , and identify all documents which support or otherwise portain to such contention.

c. Identify each and every person you contend would have been adversely affected by Parks' presence at TMI-2 on or after March 23,1983, and explain the basis for such contention and why.

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.

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9. Was Richard Parks questioned by GPUN-Bechtel after his suspension on March 24, 1983 in order to explore his safety concerns?

Please identify any such communications.

10. 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

e. Edwin M. Gischel o. L. Hoffman

f. Joseph J. Chwastyk p. C. W. Sandford

g. Edward T. Kitler q. K. Pastor

h. James Larson

1. Mark Robi J. Carl Hrbac

10. For those GPUN employees listed in interrogatory No. 10 who are not now employed at TMI-2, please explain the reason they are no longer employed at TMI-2,

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 550.7 during February-March,1983:

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

l (b) Interrogation of Richard D. Parks concerning the Quiltech

, Company.

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

j (d) Suspension of Richard Parks from active employment at l TMI-2 and prohibition of his presence at the site. -

i 12. Identify those individuals, including name, current employer, j business and hours, address and telephone numbers and professional i

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qualifications, you intend to present at hearings in this proceeding along with the subject of their testimony.

13. Identify all oral or written communications, as other documents which relate or refer to the transfer of Richard D. Parks to Bechtel offices in Daggett, California.

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.

v Colleen P. Woodhead Counsel for NRC Staff Dated at Bethesda, Maryland this 9th day of October 1986

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