ML20235F440
| ML20235F440 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/18/1987 |
| From: | Jim Hickey GENERAL PUBLIC UTILITIES CORP. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#387-4480 CIV-PEN, EA-84-137, NUDOCS 8709290122 | |
| Download: ML20235F440 (8) | |
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%?iiTF September 18i 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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Before the Administrative Law Judge F
In the Matter of
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GPU Nuclear Corporation Docket No. 50-320 - UV EEN
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(Three Mile Island Nuclear
)
j Station, Unit No. 2)
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GPUN'S SUPPLEMENTAL RESPONSE TO THE NRC I
STAFF FIRST REQUEST FOR ADMISSIONS l
l On April 28, 1987, the NRC Staff sent to GPUN requests for l
admissions.
GPUN provided a partial response on June 8, but was 1
unable at that time to respond to ten of the NRC Staff's 107 re-quests.
GPUN now provides the response to these 10 requests.
1 Request No. 13:
"That from December 6, 1982 until February 18, 1983, Richard Parks, alternate Startup and Test Supervisor, was a member of the Test Working Group (TWG), serving as alter-nate to the Chairman of the TWG, Edward Kitler, who represented the Startup and Test group described in AP 1047, Section 2.4."
GPUN admits that on December 6, 1982, Edward J.
Kitler (Supervisor, Startup & Test) authorized Parks to act in Kitler's absence as Startup and Test Supervisor of Unit 2; that on February 18, 1983, Mr. Kitler authorized Dwight Walker to act as Startup and Test Supervisor of Unit 2 in Kitler's absence; and that by separate memorandum on February 18, 1983, Mr. Kitler ap-pointed Mr. Walker the Startup and Test alternate to the Test Working Group.
However, Mr. Kitler's memorandum of December 6, 8709290122 870918 PDR ADOCK 05000320 G
PDR h
4' GPUN denies that Parks 1982,'did not address TWG membership.
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" served" as a TWG member from December 6, 1982 to February he There were no Test Working Group meetings during t 1983, and Parks did 1983.
period from December 6, 1982 to February 18, as Startup & Test alternate to TWG dur-not act or purport to act as alternate Whether or not Parks' appointment ing this period.
as SU&T alter-Startup and Test Supervisor authorizec him to act 7, which was nate to TWG is a question of interpretation of AP-104 during the time in d
not addressed to the best of GPUN's knowle ge question.
the alternate Startup & Test Supervi-TWS."
Request No. 36:
"That is, by virtue of his position, a member of the the oper-
- sor, asks for an admission that Insofar as this Request expressly designated the alternate ative procedure, AP-1047, denies this Startup & Test Supervisor as a member of TWG, GPUN state that the alternate Startup &
AP-1047 does not request.
ember of TWG.
Test Supervisor is, by virtue of his position, a m k'
the request asks for an admission that Par s To the extent that implicitly appointment as alternate Startup & Test Supervisor as Startup & Test alternate carried with it the authority to act See re-GPUN is unable to admit or deny the request.
to TWG, sponse to Request 13.
"That Mr. Kitler's appointment of Dwight nec-f the TWG was not 38:
Walker as alternate Startup & Test member oa violation of AP 1047 o Request No.
essary to correct procedural requirement."
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GPUN cannot admit or deny the request since it implicitly i
assumes that Parks was Startup and Test alternate to TWG.
See response to Request 13.
However, Mr. Walker's appointment was part of an effort to provide appropriate representation on the TWG in a manner furthering the intent of the TMI-2 organization plan.
Request No. 40:
"That no quality deficiency report (QDR) or other report was ever generated documenting a violation of AP i
1047 resulting from Mr. Parks' designation as alternate Startup &
Test representative to the TWG."
This request assumes that Parks was alternate Startup & Test representative to TWG, which assumption GPUN cannot admit or deny.
See response to Request 13.
GPUN admits that no QDR was issued relating to TWG membership and Parks.
Request No. 41:
"That no internal office memorandum or other TMI-2 document was generated prior to March 23, 1983, which re-quired or justified Mr. Parks' replacement as alternate Startup &
Test representative to the TWG to remedy the effects of a viola-tion of AP 1047."
This request assumes that Parks was alternate Startup & Test representative to TWG, which assumption GPUN cannot admit or deny.
See response to Request 13.
GPUN states that AP-1047 and the TMI-2 Organization Plan justified the assignment of Dwight Walker as Start-Up and Test alternate to TWC.
Request No. 42:
"That Mr. Parks was never informed in writing that he was removed as an alternative startup and test represen-tative to the TWG." i 1
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This request assumes that Parks was alternate Startup & Test representative to TWG, which assumption GPUN is unable to admit l
or deny.
See Response to Request 13.
GPUN admits, however, that Mr. Kitler issued a memorandum appointing Dwight Walker as the Start-Up and Test alternate to TWG, and that Parks was not in-formed of this appointment prior to issuance of the memorandum.
GPUN does not know if or when Parks received a copy of Kitler's memorandum.
Request No. 43:
"That prior to February 24, 1983 Mr. Kitler never informed Mr. Parks that he was being replaced as alternate Startup & Test Supervisor or Startup & Test representative to the TWG."
This request assumes that Parks was alternate Startup & Test representative-to TWG, which assumption GPUN cannot admit or deny.
See Response to Request 13.
GPUN admits that Mr. Kitler did not inform Parks of Mr. Walker's appointments as alternate Start-Up and Test Supervisor and Start-Up and Test alternate to TWG prior to those appointments.
Request No. 62:
"That during a meeting on February 28, 1986 (sic) to discuss the polar crane, Mr. Parks criticized the SER for the polar crane."
GPUN objects to the request as vague in that it does not specify the statements Parks supposedly made.
Without waiving this objection, GPUN admits thc; on February 28, 1983, a meeting was called to develop an agenda for a presentation on the polar crane to the Readiness Review Committee and that Richard Parks i l
i
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's attended the meeting.
However, GPUN is unable to admit or deny whether Mr. Parks commented on the polar crane lo.ad test SER.
while Parks' March 21, 1983' affidavit stated, "We identified (for the Readiness Review Committee meeting agenda]
the polar
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crane SER, which I contended only covered the head lifts and needed to include miscellaneous crane use, and light load specia) shape load drop analysis," Parks' affidavit is ambiguous as to t
whether he expressed such a contention at the meeting.
Neither Parks' notes of the meeting nor Ken Pastor's notes of the meeting reflect Parks making such comments.
Further, Parks testified in a deposition in the Bechtel civil litigation that he could not i
recall any specific comment he made during that meeting.
Request No. 67:
"That on March 3, 1983, Mr. Parks raised a question of the safety of the polar crane cable during a meeting held.to discuss presentation of polar crane matters to the RRC formed on February 27, 1983."
GPUN objects to the request, because the phrase " raised a j
question of the safety of the polar crane cable" is vague..
GPUN admits that during discussion on March 3, 1983, of matters to be presented to the Readiness Review Committee, Parks commented on l
the QA classification of the polar crane cable.
i Request No. 78:
"That neither Mr. Hofmann, Mr. Wheeler, nor l
anyone else affiliated with Bechtel or GPUN substantiated that Mr. Parks held a proprietary, pecuniary, or professional interest in Quiltec or that he had any association with Quiltec other than arranging the typing referred to in the preceding admission."
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GPUN objects to the request as vague in not specifying a time frame or explaining what is meant by " proprietary, pecuniary or professional interest."
Without waiving this objection, GPUN denies this request.
The evidence reflects that Parks had a sub-stantial association with Quiltec, including possessing business cards identifying him as a Quiltec consultant, consulting with i
Quiltec management, participating in Quiltec marketing activi-ties, assisting in obtaining work for Quiltec with Long Island Lighting Company, assisting in the recruiting of GPUN employees to work for.Quiltec, helping conceal the activities of Quiltec and Lawrence P. King from TMI management, etc.
1 Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE A
.c J.
Patrick Hickey, P.C.
David R. Lewis Counsel for GPUN Dated:
September 18, 1987 l
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1 AFFIRMATION I, Philip R. Clark, being duly sworn according to law, state:
That I am president of GPU Wuclear Corporation: that I have read the foregoing Supplemental Response to NRC Staff First Request for Admissions; that on the basis.of knowledge, information.and belief GPUN subscribes to the reasons stated'in the Supplemental Response f or denying dr for not being able to admit or deny particular requests.
Philip R. Clark Subscribed and sworn to before me this / / day of September, 1HY 2 },1i /f As v,~uA
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-UNITED STATES OF AMERICA ed
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NUCLEAR REGULATORY COMMISSION 1
Before the Administrative Law Judoe.
' *87. SEP 23 A10 34 Grn
'In the Matter'of'
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GPU Nuclear Corporation
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Docket No. 50-320
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EA'84-137
-(Three' Mile Island Nuclear
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l Station, Unit No. 2)
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CERTIFICATE-OF SERVICE I hereby certify that copies of'the foregoing "GPUN'S SUP-i PLEMENTAL RESPONSE TO THE NRC STAFF FIRST REQUEST'FOR ADMIS-
.SIONS," dated September 18, 1987, were served by deposit in the
-United States mail, first class,-postage prepaid, this.18th day of September,'1987, to.'the following persons:
Ivan Smith, Esquire i
Administrative Law Judge Atomic Safety and Licensing Board Panel U.S2 Nuclear Regulatory Commission i
Washington, D.C.
205S5 Docketing and Ser'vice Branch Office of the' Secretary j
U.S. Nuclear. Regulatory Commission Washington, D.C.
20555 i
George E. Johnson, Esq.
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Office of the General Counsel
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U.S. Nuclear Regulatory Commission l
Washington, D.C.
20555 l
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David R.
Lewis I
J' Counsel for GPUN l
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