ML20238C553
| ML20238C553 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/11/1987 |
| From: | Warren R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20238C505 | List:
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| References | |
| CIV-PEN, EA-84-137, NUDOCS 8712310078 | |
| Download: ML20238C553 (144) | |
Text
_
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TRAN~ SCRIPT g
0 OF PROGEDINGS l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE 'IHE ATOMIC SAFETY AND L3 CENSING BOARD
_7 In the Matter of:
Docket No. 50-320 GPU NUCLEAR CORPORATION (Civil Penalty)
(Three Mile Island Nuclear Station, License No. DPR-73 Unit No. 2)
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x V
DEPOSITION OF RONALD P.
WARREN, SR.
Middletown, Pennsylvania Wednesday, February 11, 1987 ACE-FEDERAL REPORTERS, INC.
Stenotype Rqvriers 444 North Capitol Street C
i Washington. D.C. 20001 Yd' (202) 347-3700 Nationwide Coverage 800-336-6646
$ f g 2 3 g f) g g g j f o T
HRMYd j
1p/128 UNITED STATES OF AMERICA wal NUCLEAR REGULATORY COMMISSION In the Matter of GPU Nuclear Corporation Docket No. 50-320 (Three Mile Island Nuclear :
(Civil Penalty)
Station, Unit No. 2)
License No. DPR-73 l
-,,.i
(,
Oral Deposition of RONALD P.
WARREN, SR.
I OFFICES OF:
Nuclear Regulatory Commission 9
a.m.,
Wednesday 100 Brown Street February ll, 1987 Middletown, Pennsylvania I
Stipulation:
It is stipulated by counsel that they waive the reading, signing and sealing of the transcribed testimony by the witness, the filing of the original with the court, and all objections, except as to form, until the time of trial.
APPEARANCES:
/
SHAW, PITTMAN, POTTS & TROWBRIDGE Attorney for GPUid 2300 N.
- Street, N.W.
Washington, D.C.
20037 By:
J.
Patrick Hickey, P.C.
Office of General Counsel for Attorney for NRC the NRC Staff M.S.
9604 MNBB U.S.
NRC Washington, D.C.
20555 By:
George E.
Johnson, Esquire By:
Charles A.
Barth, Esquire
,m
%,r Monick Stenographic Service, Inc.
f'-
1413 Old Mill Road h~7 Wyomissing, PA 19610 Phone 215/375 3931
2 l
1 INDEX 1
1 I)
EXAMINED BY:
PAGE
(>
2 WITNESS:
3 i
3 Ronald P. Warren, Sr.
Mr. Johnson 86 Mr. Hickey 116 4
Mr. Johnson 5
6 EXHIBITS 7
Warren Page 8
Deposition 39 No. 1 QDR CHK-011-83 9
69 No. 2 Summary of Warren Interview by Mr. Barton 0
86 11 No. 3 TWG Meeting Minutes.
12 14 i
i 15 16 18 19
'l 20 1
21 22
. 23 l
25 l
1
1 PROCEEDINGS 2
RONALD P. WARREN, SR.
3 was called as a witness and, having been first duly sworn by 4
the Reporter-Notary Public, was examined and testified as 5
follows:
6 BY MR. JOHNSON:
7 Q
Good morning, Mr. Warren.
I am George Johnsonifrom 8
the NRC staff.
I am counsel for the staff in this proceeding, 9
which as you may know, involves a civil penalty hearing on 10 an allegation of violations of 10 CFR Section 50.7 arising 11 out of matters relating to Richard Parks in 1983.
12 With me is Charles Barth, also counsel for the NRC
[')T 13
\\_
staff and I will just ask your counsel to introduce himself 14 for the record.
15 MR. HICKEY:
Patrick Hickey, counsel for GPU Nuclear.
16 BY MR. JOHNSON:
17 0
Will you state your full name, please?
18 A
Ronald Phillip Warren, Sr.
19 0
Your current business address?
20 A
P. O.' Box 480, Middletown, Pennsylvania, 17057.
21 O
What is your current employer?
22 A
GPU Nuclear.
23 O
Are you employed at the Three Mile Island II site?
24
()
A Yes, I am.
25 Q
What is your current position?
4 1
A Manager project engineering.
2 O
When did you first come to work for General Public 3
Utilitiess Nuclear?
4 A
In September of 1977.
5 Q
What positions have you held since then?
6 A
In 1977, I was engineer.three.
I worked myself to 7
' systems engineering supervisor in 1981, I believe.
8 Q
Systems engineering supervisor?
A Right.
IC' O
Could you explain what that entails?
11 A
I had the mechanical, electrical, instrument 12 engineering disciplines in the plant engineering department.
O What kind of work does that involve?
14 A
We provided technical support to operations and 15 maintenance for Unit II.
16 Q
How long were you in that position?
17 A
I believe approximately two years.
18 0
Until about 1983?
19 A
I believe it was in late 1983.
20 Q
Then what happened?
21 A
I became manager plant engineering.
22 O
You succeeded to Edward Gischel's position?
23 A
That's correct.
24 Q
How long were you there in that position?
25 A
Approximately two years.
Maybe it was 1984, I
5 1
succeeded to Gischel.
I'm not sure.
It was either.'83, or
'8 4, and approximately two years in'that position and then I was'--
2 1
3 I'm in the recovery engineering section right now in my 4
present position.
5 Q
You came into that department sometime in '85, or 6
was it '86?
7 A
'86.
i l
l 8
0 Early '86?
9 A
September.
10 0
That brings us up to the present?
II A
That's correct.
12 O
In your work on the island as a systems engineering
(')\\
supervisor, did you become familiar with system of NRC 13 s.
14 regulation, the regulatory framework within which the licensed 15 operations were conducted, technical specifications,, the 16 Quality Assurance program, those regulatory guides?
17 A
I became familiar with them back in
'77, and on.
18 My position as a technical support engineer required me to 19 be familiar with the technical specifications.
Also back in 20 1978, 1979 time frame, I was vice-chairman of the PORC.
21 0
Can you give me a time frame again?
22 l
A 1978, 1979.
j l
23 Q
Inclusive, after 1979, you were not connected with 24 PORC?
25 A
I believe -- I was connected with them until around
6 1
1980, I believe.
(
)
2 0
.You were also a member of the test working group; 3
were you not?
4 A
That's correct.
5 Q
Do you recall when you were first appointed to that 6
group?
7 A
I believe it was somewhere around 1982.
8 0
I'm going to try to refresh your recollection by 9
showing you a document and see if that helps you.
This looks 10 like a Met-Ed inter-office memorandum.
The subject is 11 Procedure AP 1047 Start-up and Test Manual, TWG, caps, Member-12 ship.
13 Could you read the date for me if you can?
I4 A
November 18, 1980, I believe.
5 Q
If you look at it, it appears to be an appointment 16 by a Mr. --
MR. HICKEY:
It's not clear whether it's 1980, or 18
'82.
I can't tell anyhow.
l 19 MR. JOHNSON:
Let's have the testimony of the witness.
20 BY MR. JOHNSON:
21 Q
Anyway, maybe you can tell me what this is.
This 22 appears to be a signature of Mr.
E.
D.
Elam?
23 A
Branch Elam.
["
Q What is that?
25 A
He appointed me as alternate TWG member in this memo
7 1
0 Based on your recollection, can you verify whether 2
that is November 18, 1980, or otherwise?
3 A
It could have been 1980, because I believe that 4
Branch left in 1981, so he wob1dn'.t have signed out any other 5
memos after that time frame.
O This was your appointment as alternate to TWG on behalf of the plant engineering group or department which you 8
continued to be a member of the test working group until you 9
left -- why don't you tell me?
How long were yo" an alternate 10 to Mr. Bensel there?
11 A
Dick left our group in 1981, so from the time that 12 this letter was put out until probably, I believe, late '81, f '/
\\
13
\\,,
I would have been his alternate.
14 0
Were you later appointed to be primary representativee 15 on the TWG II for plant engineering?
16 A
That's when I believe it was 1982 time frame.
17 Q
For how long did you serve as representative, primary 18 representative, of plant engineering on the TWG?
19 A
I don't ever remember being taken off.
20 Q
Are you still on it?
21 A
There aren't any TWG meetings.
If there are, I am 22 not aware of them, so maybe I was taken off.
23 Q
But, as far as you know, you were never taken off?
24 A
No, sir.
25 I
O Was Mr. Bensel at the time of this memorandum a memb 3r i
l-8 1l' 1
of the plant engineering department?
l bq,/.
2 A
That's correct.
i 3
0 Are you familiar with AP 1047, the administrative 4
procedure that has within it the designation of make-up of 5
the test working group?
6 A
Vaguely, it's been a long time since I reviewed 7
that document, but, yes, I am familiar with it.
8 0
I happen to have one page of it, the pertinent page, 9
which I believe is attached to one of the other depositic 10 in this case.
It appears to be Revision 0, 1047,.Page 4.0 i
11 and it has Section 2.0, which designates who the~ members 12 of the TWG will be.
(
13 Would you just review that and verify that for me?
14 A
That's the make-up the way I recalled it, yes.
15 0
As indicated here, there are designations of five 16 different departments which will have membership on the TWG, 17 start-up and test, plant operations, plant engineering, 18 recovery engineering, site Quality Assurance and Mod /Op's, 19 and that I think is a qualification for that on certain items 20 only, important to safety, 21 Do you recall in general who the members of the test working group were representing each of these departments 23 i
during the time you were a member?
24 A
The start-up and test person -- the only TWG member
(
25 or the only TWG meetings that I remember attending were in 198 2, l
9 1
1983 time frame regarding the polar crane and so consequently,
()
2 the members that I remember sitting with are during that time 3
frame.
But, as I recall, there was Mike Herlihy.
4 Q
Mike Herlihy during this early period in 1980, 5
when you were first appointed?
6 A
I believe he was earlier and then Ed Kitler after he 7
left the company.
From the start-up group --
8 Q
Let me just break in, because I am interested in 9
the designations of each of these people.
10 Mr. Herlihy was at this time that you were appointed 11 the chairman of the TWG?
12 A
I believe he was, yes.
/~N 13
()
Q What department was he in at the time?
I4 A
He was in the plant engineering department, I balieve.
15 Q
Do you know who his alternate was?
A No, I don't.
It may have been Ricx Parks, but I am 17 not really sure.
18 MR. HICKEY:
Did you say Mr. Herlihy was in the plan ;
19 engineering department?
l 20 THE WITNESS:
He started out in the plant engineering 21 department and then was subsequently transferred to the site 22 I
engineering department.
That's my recollection.
23 MR. HICKEY:
I think he was asking about when he was 24 chairman of the TWG, do you know what department he was in.
l f
25 Was that your question, Mr. Johnson?
l l
l
10 1
BY MR. JOHNSON:
/~T
(_/
2 O
Initially, yes.
3 A
I believe at that time period he was in the plant 4
engineering department.
5 Q
Plant engineering, you mean Item C on this 3047 6
format?
7 A
He would have been Item A, start-up and test.
8 Q
So he was in plant engineering, but he was designate d 9
as start-up and test representative on the TWG?
10 A
Yes, sir.
11 MR.. HICKEY:
I don't understand what you just said, is Mr. Warren.
O 13 BY MR. JOHNSON:
14 Q
Let me just continue.
15 MR. HICKEY:
You don't want to clarify it?
16 BY MR. JOHNSON:
17 Q
I am going to try to clarify it.
18 Was it your understanding that during the period, 19 I guess, from November of 1980, while Mr. Hell 1hy was chairper son:
20 of the TWG, that he was in the organization at TMI II, he 21 was assigned to the plant engineering department?
22 A
?.t some tima franc, he 'nc in the plant engineering 23 department, per my recollection, okay.
Whether or not he was 24 in it in 1980, that I am not sure, but I think that even at 25 l
that time frame, he was still in the plant engineering D
11 1
department.
Somewhere around that time frame, he was 2
transferred to the site engineering department.
3 Q
But, you don't recall when?
4 A
I don't recall when.
5 You asked me the question of what department I 6
thought he was in.
It's my belief at this time that he was in the plant engineering department.
I might be wrong.
8 MR. HICKEY:
Then why do you say he's the start-up 9
and test person on this 1047 form, rather than the plant 10 engineering person?
11 THE WITNESS:
Because the plant engineering departme nt 12 when it was first formed had the start-up and test function O
13 in it.
14 MR. HICKEY:
Okay, thank you.
15 BY MR. JOHNSON:
16 Q
I see.
That clarifies that.
17 To jump ahead a bit, when Mr. Parks was -- you are 18 familiar with Mr. Parks?
19 A
Yes, I am.
20 0
When he was assigned -- he was assigned, as I recall,
21 and correct me if I am wrong, to be the alternate member of 22 TWG for start-up and test on December 6, 1982.
Do you recall 23 whether he was or not?
24 A
At some point in time, I believe he was the alternate i
25 for start-up and test, but I don't know when that was.
12 I
Q As I understand, Mr. Parks was assigned to site 1
2 operations at that time?
3 A
He was in the site operations department before he 4
left.
5 MR. HICKEY:
Wait a minute.
That's not his question.
6 His question was as of December 6,
'82.
)
7 BY MR. JOHNSON:
8 O
Let me represent to you that he was appointed by 9
Mr. Kitler on December 6 and he served in that function until 10 February 18, 1983, as alternate member of TWG for this start-up 11 i
and test department.
12 During that time frame, is it your best recollection
N 13 J
that Mr. Parks was a member assigned to site operations?
14 A
It is my recollection that he was assigned to site 15 operations.
16 Q
I think that's established elsewhere, too.
17 The question came up when he was removed, replaced 18 as alternate for the start-up and test function on this group, 19 that he was not part of the start-up and test department or i
M not part of the site engineering department, but part of the 21 site operations department, therefore, he should be replaced, 22 because Mr. Kitler should have somebody from his department --
23 MR. HICKEY:
Wait a minute.
I am going to object.
24 I don't know if there is a question coming at the end.
You 25 are making an awful lot of factual statements that I think 1
13 ll.
1 I
include different views of different witnesses.
You are giving 2
your views of which ones you choose to state from'them.
What 3
is the question to this witness?
You don't even know that he 4
knows about any of that.
BY MR. JOHNSON:
6 I
Q Are you familiar with the reasoning that underlay i
7 Mr. Parks' removal from the TWG on February 18, 19837 8
A No.
9 MR. HICKEY:
Whose reasoning?
10 BY MR. JOHNSON:
11 Q
The reason why Mr. Kitler removed him?
12 A
No, I am not.
O%
13 0
Were you aware of members of the TWG being assigned 14 either as alternate or primary representatives of departments, 15 these five designated functions, who were not at the time they 16 were members of the TWG actually assigned to the departments 17 which they were representing?
18 A
I believe that they were all assigned -- all the 19 i
members were assigned to the TWG from the department for which 20 they represented.
21 Q
To the best of your knowledge?
22 A
To the best of my knowledge, except the clarification n 23 of Rick Parks.
I know he was in the site operations department 24 during that time period and that start-up was in the site 25 engineering department during that time period.
14 i
1 Q
Do you know of any other cases,csimilar cases, in 2
which for some period of time a member of the TWG was from a 3
department not which he was representing on the TWG7 4
A No, sir, I do not.
5 Q
I got ahead of myself considerably there.
I didn't 6
really intend to.
7 Let's go back and would you tell me when you first 8
l met Richard Parks?
t 9
A This goes back aways, but I believe it was somewhere 10 in 1975, or 1976.
I was a test engineer for Newport News Ship 11 Building and Dry Dock Company and he was a Navy person 12 stationed on the Baton Rouge and I met him during that time h
13 s_/
period.
14 Q
How would you describe your relationship with him?
15 A
Casual.
16 Q
There wasn't a professional relationship or was there?
17 A
In my position as a test engineer, we did valve line 18 ups and certain manipulations to the plant systems and he may 19 have been the operator who actually operated the various 20 components for me, but I don't remember any specific incidents.
21 Q
It was work related?
22 A
Yes.
23 Q
So you saw him fairly regularly when you were workin g 24 7-)s
(,
on the same item, I assume?
25 A
On the same shift.
We both rotated shifts and if we
15' i
I happened to be on the boats at the same time, we probably saw f
f 2
each other.
It's a very small boat.
(
3 Q
This was just for approximately a year that you had 4
this relationship with him?
5 A
I believe it was about a year.
6 Q
When did you next have occasion to have contact with 7
Mr. Parks?
8 A
That would have been at Three Mile Island.
9 Q
That was when?
10 A
1979, 1980, somewhere in that time frame, whenever 11 he first came to TMI, I believe he worked for NUS.
12 0
What was Mr. Parks doing as far as you know?
Do-you know?
14 A
I am not exactly sure that I know now what he was 15 doing.
He might have been in the test department, but I can't 16 remember.
17 Q
What kind of contact did you have once he came to 18 the island in the 1980 time frame?
19 A
It was again casual.
We recognized each other from 20 Virginia.
21 Q
Did you work with him at all when he was an NUS 22 employee?
23 A
I may have worked with him involved in writing some 24
()
procedures or maybe in my position with PORC, which I believe 25 I still was on the PORC at that time.
I might have reviewed
16 I
some of his procedures that he was writing at the time.
'2
-Q I understand the PORC stands for Plant Operations 3
Review Committee?
4 A
That's correct.
5 O
It's function was what?
I 6
A We reviewed documentation procedures, LER's, and 7
looked for safety implications, that sort of thing.
8 Q
The review of the PORC was essential to certain 9
types of procedures and operations?
10 MR. HICKEY:
Essential?
BY MR. JOHNSON:
12 O
Was required by plant procedures?
j A
Our review was required of procedures, that's 14 correct.
15 Q
All procedures or just certain procedures?
16 A
As I recall, all the operating procedures -- I'm 17 sure it wasn't all procedures, but most of the procedures we 18 reviewed.
19 Q
The key thing was that if it was an operating
\\
)
20 procedure, it was generally reviewed by PORC?
l 21 A
Yes.
22 i
Q Could you relate to me the circumstances of your 23 leaving that position as vice-chairperson, chairman, of PORC?
24 A
I am not exactly sure when this happened, but I 25 believe that the reason I left was because the PORC was I
17 1
essentially disbanded and a new group which served to form
(
2 the same function or perform the same function as PORC, the 3
safety review group, took over.
4 Q
Is it possible that you have the date wrong that 5
you served on the PORC as vice-chairman, somewhat later than 6
19807 7
A I could have served on it afterwards.
8 Q
Hold on a minute.
I think I may be able to help.
9 When you were deposed on March 31, 1983, by Mr. Stie c 10 I believe it was, who was a lawyer doing investigation for 11 GPU on management and safety allegations at the TMI II, do you 12 recall being interviewed by him?
13 A
Yes, I do.
14 0
On Page 9 of that deposition, there are some questio ns 15 and answers.
I will just show it to you, starting on Line 11.
16 See if that refreshes your recollection as to the time period 17 you were serving on PORC.
18 A
In this I said approximately five years, so that 19 would have taken me up to 1982, and I believe the reason that 20 I left the PORC was because of the reorganization and the 21 formation of the safety review group and I think that would 22 probably be more coincide with the time frame.
23 Q
That could be established independently, I assume.
24
(
If I were to say that it's my recollection that it 25 was sometime in
'82,
'83 period when there was a transition as
18-1 part of the reorganization, general reorganization that was l((>)
g going on, starting approximately September,
'82, that the 3
process of changing from PORC to SRG --
A Safety Review Group.
5~
Q
-- was on-going, was a kind of a gradual process, 6
they were finalizing procedures, and the two were functioning 7
sort of at the same time for a period of it might have been 8
up until the
'82,
'83 period that you were officially still 9
i a member of PORC?
10 A
I believe that's correct.
11 Q
Getting back to your contacts with Mr. Parks, could 12 you describe your contacts with Mr. Parks following the time
~N 13 he was -- is there anything more you wanted to add during the 14 time he was an NUS employee about your contacts with him that 15 you didn't mention?
16 A
I don't remember anything that stands out in my mind,
17 other than the fact that he was here and then during a certain 18 time frame, I don't remember exactly when, he left.
The next 19 thing I remember is he came back as a Bechtel employee.
20 0
Could you say when that was?
21 A
No, I don't remember the time frame.
22 O
That's good enough.
23 i
I believe the record would show that it was sometime 24
)
around May or June of 1982, but nevertheless, what was the 25 nature of your contact when he did return?
19 1
A I believe when he came back, he was in the start-up and test group.
3 0
Did you know what work he was doing, were you aware 4
of what work he was doing?
6
-~
A No, I don't.
I can't remember.
I think that was 6
after SDS and he may have worked on SDS, but I don't remember 7
exactly what he was doing, and then sometime after the 8
reorganization, he joined site operations. group working as an 9
operations engineer, I believe.
10 Q
Did you have more contact with him once he was 11 in the site operations group?
12 A
I don't believe that we had more contact or less
(~') -
13
~N-contact.
He worked -- he worked with several of the engineers 14 in the plant engineering department, including myself, on 15 tasks that we were -- that we were working on.
For the most 16 part, he helped us out writing procedures for work that we 17 needed to have accomplished.
18 O
Could you give me an example or two?
19 A
He -- the one example that sticks out in my mind was 20 we had a requirement or request to come up with an alternate 21 t.
way of measuring steam generator level and he worked with one 22 of my mechanical engineers on writing the procedure for 23 monitoring that level and I also believe that he assisted with 24
\\
(m/
figuring out the routing of the level two line.
i i
l 25 Q
Any other specific examples of work that you remembe c l
20 1
him doing with your department?
.f 2
A I don't remember any other specific examples.
There 3
3 was one other incident where I worked with him a little bit 4
on a weekend and it involved an instrument, but I can't 5
remember exactly what job that was.
6 Q
Did it have anything to do with containment entry?
j 7
A I don't believe itidid.
8 Q
Did it have anything to do with the drain down of 9
the steam generator?
10 A
I can't remember.
II Q
During this period,we.are talking about, we are 12 talking about a period that is toward the end of 1982, f'h 13
(,j beginning of 1983?
14 A
I believe that was the time period, yes.
15 Q
Did you have regular contact with him?
16 A
I think I saw Rick pretty much every day, whether i
17 or not it was just to say hi or it was to discuss some work.
18 I can't give you specific details, but he sat for awhile right 19 outside of Larry King's office and as part of my dealings or 20 the work that I had in my department, I had a lot of interface 1
21 e
I with Larry King, so consequently I was down in his office quit 22 a bit.
I would have seen Rick, if he was there.
23 j
Q What was your opinion of Mr. Parks as an engineer?
24 A
I thought he was enthusiastic.
I thought he was 25 very helpful to our department.
~ 21 ~
f 1
Q Did you have any assessment of your dealings with I
l f'\\
T,/
2 him on a personal level or what would you say about that?
3 A
I didn't really -- you mean work related on a 4
personal level?
l 5
Q
- Yes, 6
A When we asked Rick to help us out with problems that i
1 7
we were having, I always found that he was more than willing 8
to give us.a hand, okay.
I didn't run into much negative 9
feedback from him.
l 10 0
Did he finish the work that he undertook with you 11 or for you on time?
MR. HICKEY:
That's a pretty general question.
BY MR. JOHNSON:
Q To the best that you recollect, on any particular 15 procedure that you can remember, you mentioned this alternate 16 way of measuring the steam generator level, did he complete 17 that in a timely way?
18 A
As I recall, he did.
19 Q
Did you consider him a reliable counterpart, so to 20 l
speak?
21 A
Yes.
4 22 Q
Did you have any kind of a personal, social type of 23 relationship with Mr. Parks?
24 A
No.
25 I
Q Were you aware of Mr. Parks' role in the head lift
22 L
1 task force meetings that were occurring in -- first of all, (Js) were you aware of the head lift task force in approximately,
2 x
s3 s
3 January, 1983, and its workings?
4 A
Vaguely.
I believe I attended a couple of 4Seir j
5 meetings.
]
6 Q
Do you recollect whether you attended meetings in 7
January of 1983?
8 A
Not specifically, but generally, I believe I did 9
attend some meetings.
I 10 Q
Do you recall attending a meeting on January 20, or 6
l 11 January 14, at any specificity?
12 A
No, sir.
I attend a lot of meetings.
This is a lonc
}
13 time after the fact.
14 0
Were you perhaps at a meeting at which Mr. Parks was 15 asked about the status of a procedure that he had written, 16 let's see, it had to do with the site operations commitment 17 for the issue for use date of the procedure for RCS chemistry 18 control and sampling and a request he contact PORC and get fron 19 PORC the projected date when the procedure would be available?
20 A
I am not specifically familiar with that request.
21 Q
You don't recall being at a meeting in which this 22 request was made of Mr. Parks?
23 i
A No, I do not.
j 24 (s}
Q Were you at a meeting in'which Mr. Parks was raising 25 some concerns about the availability of calculations that he
/
//
23,
,p
.t perceived t,o be required before he cobAt write a pr'ocedure, 1
r' f
.t I (
2 I am not suLe what the prociqure was, and that Mr. Morris, who s
u 3
was) I believe, the acting' head lif,t task force cheirman at i
4 the-timet-s& d something to the effect, tell me what we can i>
c
\\
5 do, don't tell me what we can't do?
Do you recollect that t
)
a conver$adionorencounter?
I 6
4
,J
+
1 7
A I do not.
8 0
lb you recollect any' conversation that Mr. Morris 8
-may have had concerning Mr. yarks' attitude at the head lift 10 task. force meeting?
A No, sir.
12 0
You say you were often in the area adjacent to 4
Mr. Parks' ofsice when you came to visit Mr. King.
How far 14 from Mr. King's and Mr. Parks' office were you generally?
'/
\\
15 How far were your offices from his?
16 A
My office was down the hall, probably about 50 feet, 17 75 feet.
18 0
Did you have any familiarity with the -- I think I 19
)
maydaveaskedyouthisalready,butdidyouhaveany/j' 20 y/
familiarity.with the circumstances surrounding the replacement 21 of Mr. Parks as an alternate member of the test group on 22 February 18, 19p?
23 A
No.
24 t,
Q I am going $o show you an IOM of GPU Nuclear,
'~
25 February 18, 1983, in which.Mr. Kitler designates Mr. Wellker' s
24 1
to act on his behalf as alternate start-up and test 2
representative on the -- I'm sorry, that's not this.
This 3
was to be alternate to him ac start-up and test supervisor.
4 Did you receive that?
5 A
Yes, I did.
6 0
When you got this, did you also get another 7
memorandum which designated him as -- I mean, Mr. Walker, as 8
Mr. Kitler's alternate on the test working group?
9 i
I A
I may have.
I don't recall.
10 MR. HICKEY:
Let me just interrupt one minute for i
11 clarity purposes.
When you say you got this memorandum that 12 he's showing you, do you have a recollection of receiving it I
13
,\\-
or are you referring to the fact that it shows you as an 14 addressee?
15 i
THE WITNESS:
I am referring to the fact that it 16 shows me as an addressee.
I 17 BY MR. JOHNSON:
18 Q
Do you have any recollection of seeing this?
19 A
No, it's been too long.
20 Q
Do you have any recollection of making an inquiry 21 or being informed of the circumstances which warranted this 22 action?
23 A
No, I do not.
24
(_)
Q Did you have any contact with Mr. Kitler during this time frame of February, 19837
25 l
l
)
l i
1 A
I don't remember any specific contacts with him.
2 O
So yca don't remember any contacts in which Mr.
3 Parks was discussed?
4 A
No, sir.
5 0
Do you recall receiving this document which is 6
dated February 23, 19837 It's an IOM again, subject Polar 7
Crane Safety Evaluation.
It's from Mr. Ballard to Mr. Kanga.
I said what the subject is.
Do you recall receiving that?
9 A
I don't recall receiving the memo, but my name is 10 listed on the memo and I am sure I received it.
There were 11 many documents referring to the polar crane that I saw on a 12 day-to-day basis.
I don't remember each and every document
+
13 specifically.
14 Q'
Do you recollect the concerns that Mr. Parks was 15 raising with regard to the adequacy of the polar crane load 16 test procedure at this time?
17 A
I remember the concerns regarding whether or not 18 AP11047 and AP 1043 applied to the polar crane refurbishment.
19 Q
What was your position on Mr. Parks' position, that 20 AP 1047 and 1043 applied to that?
21 A
Yes, that was my position.
22 O
Ycur position was that it did apply, thcse procedure s 4
23 did apply?
24
()
A They should have been used, ves.
25 Q
Do you recall attending a meeting of the test working
26 1
group on -- let me back up just a second.
, (
2 Do you recol. lect a time shortly after Mr. Parks 3
raised his concerns in which representatives or a representative 4
of the recovery engineering department formally rejected Mr.
i 5
Parks' positions concerning the applicability of AP 1047 and 6
AP 1043 to the polar crane load test procedure?
7 A
Could you rephrase the question or restate it?
8 0
I'm'sorry.
l 9
Do you recall that in response to Mr. Parks' comments, 10 that Mr. Radbill or someone else from recovery operations 11 rejected his comments?
12 A
Not specifically, no.
1
()
I3 0
Did you ever see this document, which is a comment I4 resolution form, which is filled out by Mr. Parks, dated 15 the 17th of February and filled out by Mr. Radbill on the 25th 16 I
of February,
'83, do you recall seeing that?
17 A
I don't recall.
I may have seen it, but I don't 18 recall seeing that.
19 0
Do you have any recollection of Mr. Parks' comments 20 being rejected by recovery operations?
21 A
Not specifically.
I veguely recall that during the 22 meeting there were -- there was much discussion regarding 23 whether or not AP 1043 and AP 1047 were appropriate procedures 24
(
to use with polar crane refurbishment program and also that 25 Mike Radbill was -- attended those meetings to explain to the
_________ ____________ _ _ _ D
27 I
l test working group to give some confidence that what his group L /(
2 i
was doing in the way of refurbishment was technically 3
acceptable and in compliance with the TMI II administrative 4
program.
But, as far as specific rejections or specific issues, 5
it's just been too long.
I don't remember the context of the 6
specific issues.
7 Q
But, you did receive this document with its attach-8 ments according to this.,
Let me ask you:
This is your name 9
on this March 1st IOM from Mr. Chwastyk to Mr. Lake, 10 No. 4200-83-102, you are recipient of a copy with attachments; 11 is that correct?
12 A
That's correct.
MR. HICKEY:
The document shows you being listed as 14 a person to whom a copy was sent, right?
15 THE WITNESS:
Yes.
Just-with regard to these types I
16 of transmittals, I have received over the nine years that I 17 have worked at TMI hundreds of transmittals with document 18 resolutions on them.
So in the context of one specific j
1 19 document resolution form, as compared with all that I have 20 seen, it's just a blur.
21 BY MR. JOHNSON:
22 Q
This one doesn't stand out in your memory?
23 l
A No, it does not.
24 Maybe it would help if I described to you some of 25 the work that we did in p2 ant engineering, okay, because
28 I
with regards to the polar crane, I didn't view myself or our 2
department as heavily involved.
3 0
Okay, go ahead.
4 A
We got -- in'.:the plant engineering department, we've 5
been using a site operations tracking list for the various 6
tasks that come through and it's been my experience that we 7
probably carry anywhere between 100 to 150 tasks at any one 8
particular time and the polar crane refurbishment was the 9
project of another group outside of plant engineering.
I 10 viewed it as my primary responsibility to perform or to oversea 11 those tasks for which I was directly responsible, and my work 12 with the polar crane in reviewing their procedures and as a member of TWG was a collateral duty.
So it's not that I am no b 14 trying to answer your questions, it's just that I really don't 15 remember a lot of the specific specifics regarding what you 16 are asking me.
17 Q
You are saying your membership in the TWG was a 18 collateral duty?
19 A
It was a duty to which I was designated and which I 20 had to perform with the rest of my duties.
O But, you didn't take it any less seriously than any of your other duties?
A No, I did not.
24 MR. HICKEY:
Were you suggesting it was in the natur a
25 of a review-type duty, rather than other engineering tasks tha t
'29 I
you were directly performing?
/'T
.THE WITNESS:
I think that would be appropriate to s-3 say.
4 BY MR. JOHNSON:
5 0
Were some of the functions that you were directly 6
responsible for reviewed by the TWG?
7 A
I don't believe that we had any projects at that 8
time that were reviewed by the TWG; 9
O Either informally or formally?
10 A
No, sir.
11 Q
Were you ever asked by Mr. Kitler to perform a 12 signoff function that you had, a review function that you had
(
13 N-as a member of the TWG on an informal basis; in other words, 14 without a meeting, he gave you a procedure and said would you 15 please sign.off or review this in your function as a member of 16 the TWG?
17 A
He may have, but I don't recall specifically.
18 There were some -- there were some cases, I believe, where the::e 19 were documents that came through that they were given out to 20 the TWG members and then Ed Kitler or maybe someone else would 21 come around and say have you reviewed that, did you have any 22 problem, and as long as all the signatures were obtained, 23 it was valid as having bcen reviewed, my understanding.
24
()
Q Let me back up for a second.
I was asking about the 25 l
head lift task force meetings and you said you attended severa l.
30 1
Do you. remember Mr. Parks being in-attendance at
/"
(_
2 any of these meetings?
3 A
I vaguely remember his being in attendance.
4 Q
Do you remember anything unusual about his 5
participation in those meetings?
6 A
The only thing that I remember,and I can't give you 7
real specifics on this, is that I recall that he did have 8
verbal disagreements with other people in.that meeting and 8
they were quite verbal.
10 0
Do you remember anything in particular?
II A
No.
12 Q
Some of the words maybe?
(
)
A I don't remember -- the reason it stands out in my 14 mind is because I don't think that myself, personally, would 15 have been as vocal or as much -- or expressed my disagreements 16 in quite the same way-as Rick did.
17 Q
By the same way, do you mean loudness or profanity 18 or something else?
19 A
I think that it was the general way he expressed his 20 feelings was offensive.
21 Q
He used offensive language or just --
22 A
I don't remember if he used offensive language, but 23 I feel that the way he told people the way they were doing
' 24 their jobs, if he had told me I was doing my job in the came 25 way, I would have been offended.
_-_________-__________m
31 1
/.
Q In other words, would you say he was blunt?
2
\\-
A He was blunt.
3 Q
Not tactful?
4 A
Not tactful, they are good terms.
5 MR. HICKEY:
How about whether it was professional 6
or not professional?
7 MR. JOHNSON:
I woulduappreciate it if.you would 8
save your questions for cross.
9
. MR. HICKEY:
I thought you wanted to have a descript Lon 10 of what Mr. Parks' comments were.
11 MR. JOHNSON:
I do.
12 BY MR. JOHNSON:
Q Did you feel that Mr. Parks was adequately 14 representing his organization at those meetings?
15 MR. HICKEY:
I object to the form of the question.
16 I think it's extremely vague.
What does that mean?
17 BY MR. JOHNSON:
18 l
Q Do you feel that -- I withdraw the question.
19 Do you have any other descriptions you would like l
to characterize Mr. Parks' participation in those meetings as?
21 A
No, I believe that blunt and not tactful is a pretty good description. To use a cliche, I kind of felt he was g
burning his bridges while he was standing on them.
g
(
Is that because this was a collegial group, a N'
Q 25 coordinated group, that there was a need for these people to t-t
32 1
work together or what do you --
2 A
Yes, I would think that if you didn't have everybody 3
working together, the task wasn't going to get performed or 4
that there were going to be difficulties in getting it 5
performed.
9 Q
Were you aware of any difficulties that Mr. Parks 7
had in getting his jobs done?
8 A
No, I was not.
On the other hand, I wasn't aware of 9
any personal dealings that he had with some of the people 10 that he had disagreements with either.
11 O
How many meetings of the head lift task force would 12 you say you attended?
(
13 A
Maybe two or three.
14 0
It was in the January, February, 1983 time frame?
15 A
I believe it was during that time frame, yes.
16 Q
Was Mr. Parks' participation in those meetings 17 a subject of discussion in your department?
18 A
Not in my department, no, or I wasn't aware that it 19 was.
20 0
Were you aware of discussions elsewhere?
21 A
No, I was not.
22 0
As far as you can recollect at the head lift task 23 force meetings, despite Mr. Parks' bluntness and lack of tact, 24 73(,)
would you say his positions were technically correct?
25 A
I would say that he was trying to do his job.
I am
33 1
not aware of any specific instances where he tried to shirk
'(O 2
his responsibilities.
/
i 3
MR. JOHNSON:
Five-minute break.
j 4
(Whereupon a brief break was taken at this time. )
t 5
BY MR. JOHNSON:
6 Q
Mr. Warren, do you remember attending a meeting of 7
the test working group on March 4, 1983?
8 A
I vaguely remember attending some test working 9
group meetings, but the specific dates I don't remember.
0 Q
I have two pieces of paper that appear to be notes taken at this March 4th, 1983 TWG meeting.
Are those your 12 notes, by any chance?
)
A This is not my writing.
O What do you remember about the TWG meeting that you 15 were referring to, whether it was March 4th or not?
l 16 A
I remember discussing the applicability of AP 1043, 17 AP 1047.
I remember Mike Radbill giving us a discussion of 18 where he stood in his polar crane refurbishment program and 19 the work that he had left to do.
I remember some questioning
(
I 20 of the QA representative of whether or not they had reviewed 21 all the documentation and it's my recollection that they said 22 they had not, that they were still reviewing documentation, 23 and that's basically what I remember.
(
)
Q Was it decided by the members of TWG at that meeting,
25 to the best of your recollection, that the administrative
34 1
procedures, AP 1043 and 1047, applied to the polar crane G
/.
2 load test procedure and several other tests?
3 A
Yes, that was my understanding.
O Is it also your recollection that there were other 5
steps to be taken still by various people in resolution of 6
that matter?
7
{
A Yes.
8 MR. HICKEY:
What is the matter we are talking about?
9 BY MR. JOHNSON:
10 Q
The matter was the bringing the polar crane load 11 test procedure and other procedures into compliance with 12 AP 1043 and AP 1047.
A That's.my understanding.
Specifically, I remember 14 that the QA department was reviewing the documentation to 15 insure in their minds that the work on important safety 16 components had been properly performed and documented.
17 O
Do you recall a discussion in which QA's representa-18 tive, I believe it was Joseph Marsden, said that all the 19 deficiencies that were being discussed at that meeting would 20 be covered by one quality deficiency report?
21 A
Yes, that's my understanding.
22 O
It covered several deficiencies?
23 A
Yes.
24
(
Q It would.
25 Do :you recall that the QDR was going to be submitted
____-_________________--_____-_A
35 1
to Mr. Thiesing for his review?
fx 2
A I don't specifically recall that, but that would 3
make sense,ain the fact that the work was being done in his 4-department.
5 l
Q These are meetings that are attached to a memo 6
that --
7 MR. HICKEY:
Those are Minutes.
8 BY MR. JOHNSON:
9 Q
Minutes, pardon me, that are dated March 7, 1983.
10 It's an IOM, which is numbered 4345-83-0005, dated March 7, 11 1983, and the subject, TWG Minutes -- Meeting Minutes of 12 March 4, 1983.
Is that your signature on the first page?
O 13
\\/
A Yes, it is.
14 Q
On Page 2, it indicates short way down, it says 15 the QDR will be submitted to Jim Thiesing.
Does that refresh f
16 your recollection at all?
17 A
Like I said, that just made sense.
18 Q
But, you don't independently recollect it now?
19 A
No.
20 0
How would these matters -- what were the steps that 21 normally would be taken in such a situation or if you remember specifically what steps were taken with respect to the resolu-tion of these deficiencies, what were the steps that were 24 taken to resolve the deficiencies that Mr. Marsden was alluding i
25 to with respect to the two procedures I mentioned?
Could you
36 I
outline what steps were to resolve those?
2 A
I really don't know if I understand your question.
3 Q
Were you familiar with the QDR, what a QDR was?
4 A
Yes.
5 Q
Could you describe what a QDR was and what the 6
process for its review was?
7 A
Yes, I can.
8 Q
'Please.
9 A
QDR stands for Quality Deficiency Report.
In simple 10 terms, a QDR dealt with problems dealing with paperwork, as 11 opposed to problems dealing with material or equipment, which 12 was handled by an MNCR.
O Would you specify what that means?
14 A
Material Non-Compliance Report.
15 The department that became aware of the deficiency 16 would normally write it up and I'm guessing in this case, 17 it would have been the Quality Assurance department would have 18 written up the QDR that was submitted to Jim Thiesing.
Then 19 the department that received the quality deficiency would 20 review the deficiency, determine themselves that they felt a 21 deficiency existed and then have to come up with a course of 22 action to correct the deficiency, which could include things 23 like procedural changes, persor.nel being counseled, those 24 types of things.
Normally the department tried to get --
25 would try to get their corrective action written up within 30 i
l 37 l
1 days and then submit it to the Quality Assurance department
(],
2 for acceptance of the resolution and close out and then the 3
rest of the work was just mechanical in closing out the paper-4 work.
5 Q
I'm going to show you what I believe to be the QDR 6
that was referred to by Mr. Marsden.
It's dated 3-8-83.
It's 7
from looks like OQA.
8 A
That's Operations Quality Assurance manager.
9 0
To J.
W. Thiesing, manager of recovery operations, 10 and it's QDR No. CHK-Oll-83; is that correct?
11 A
Yes.
12 O
It is severa] pages long.
Page 2 has a description of the applicable requirements, discusses the QA plan, 14 modifications, which modifications were accomplished, and I 15 believe it continues onto a continuation page and then there's 16 a deficiency section, which also continues onto the continuati on 17 page; is that correct?
18 A
Yes.
19 0
In this particular case, the deficiency notes that 20 a number of items were not in compliance with the administrate-
/e 21 controls of AP 1047; is that correct?
22 A
Right.
23 Q
Then there is a page that says, QA proposed correcti ve 24 O(j action QDR CHK-Oll-83, three items.
It says in the future all l
25 modifications and modifications relating to testing will be 1
l
'38 l'
performed under the controls established by AP 1047 and AP e
k 2
1043 respectively, et cetera, and it also mentions training, 3
like you say, would ordinarily have been one of the corrective 4
actions, talks about the future use of constructions and that 5-all recovery program procedures will be appropr.iately 6
implemented.
7 There's some kind of a note attached here, which I 8
can't read.
It seems to be Chuck.
I see the name Jim Thiesing.
9 I see a date, looks like 3-9-3, maybc it's 3-9-63.
Dc you knaN l
10 what that is?
11 A
No, I do not.
i l
12 O
You don't recognize that?
13 s\\ -
A No.
l 14 Q
The next page has the cause section and it discusses j
15 how a job ticket, CA-258 was issued and addresses the question 16 l
of proper documentation regarding inspection and refurbishment I
17 modification and testing for the polar crane and that section 18 continues onto a continuation pa c.
That appears to be an 19 explanation of why the procedures, AP-1047 and 1043,swere not 20 employed by recovery operations.
21 You are nodding yes?
22 A
It appears to be that, yes.
23 0
Finally, it says -- well, among what it says, it l
I 24 j
[~T
(,)
says it was treated by recovery operations.
It's being turned 25 back to construction and that was one of the factors that was
___a
39 1
involved in the' deficiency.
2 A
Yes.
3 MR. HICKEY:
Would you mark that document as an 4
exhibit, since you are reading from it?
5 MR. JOHNSON:
I will mark this as Warren Deposition 6
Exhibit 1.
7 (QDR CHK-Oll-83 was marked Warren Deposition i
f Exhibit No. 1.)
9 BY MR. JOHNSON:
10 Q
On the next to the last page, underneath where it 11 says corrective actions, it says corrective action will be 12 completed by 4-30-63, training something, I'm not sure, maybe
('N 33
\\
that was to be done at a later date, but you see that, don't 14 you?
i 15 A
Yes.
16 Q
Then it is signed by Mr. Thiesing?
17 A
Yes.
18 Q
On 3-21-83?
19 A
Yes.
20 Q
Did you see this document when it was prepared?
l 21 A
I don't believe I ever saw that document.
22 Q
Does that document -- if you want to look at it some l
23 more, please do -- indicate to you that on the 3-21-83, Mr.
24 f
Thiesing had reviewed and approved the statements that were 25 attributed to the cause, the deficiency, the requirements and
40 1
corrective action?
1 ')
'/
A That's my understanding, yes, based on his signature 3
there'.
4 Q
Would you consider this to constitute a resolution j
5 of the concerns of the deficiencies that are described herein?
6 MR. HICKEY:
I object to the form of the question.
7 I think it's vague and conclusory.
8 BY MR. JOHNSON:
9 Q
If you can answer the question, please do.
10 A
If I understand your question correct, I would say 11 that the remaining part of the page being filled out and having 12 been reviewed would make that document complete.
(:)
O You mean the part underneath Mr. Thiesing's signatur a?
14 A
Well, like I said, once the department -- Jim 15 Thiesing's department was the department responding to the 16 quality deficiency, once that department responded to that 17 quality deficiency, then they sent their resolution back to th e
18 QA department and it was QA's responsibility to review the 19 deficiency, concur in it and close it out.
O Did they do that in this case?
A They had started the close out process.
E 23 A
Yes.
24 Q
It's got a signature of somebody from QA, I believe, 25 Fornicola?
l
1 41' I
A Doug Hosking signed for John'Fornicola.
/~T
(_f.
2 Q
Then it says C over A, party notified 4-20-1983, 3
G. Ebur?
4 A
I believe that's Gale Ebur.
O What does that indicate?
A I would just be guessing.
7 Q
It's a concurrence or something from the QA departme nt?
8 A
I guess the C over A maans corrective action.
I 9
don't know.
10 Q
Would you consider the creation, the initiation i
11 of the QDR on March 8, 1983, to be the same thing as resolution 12 of it?
f' ~\\
13 MR. HICKEY:
I object to the form of the question.
14 I think that's just playing with words.
15 BY MR. JOHNSON:
16 0
When this document was created, it didn't in itself 17 resolve the issues raised in it, did it?
18 A
My personal feeling is that it -- the paperwork --
19 until the paperwork is closed out, the issue is still there.
20 But, once this Paragraph 4 is signed off and both the action 21 party and the QA department have concurred in a resolution, 22 then I believe that that is general acceptance that this is 23 the plan of action to resolve this deficiency and that that 24
-(
should be sufficient.
That's the way we treated quality 25 deficiency reports in the plant engineering department and we dealt with them and sometimes it took the Quality Assurance
42 i
il I
department months to close out one of our responses to a 2
deficiency, but it was my intent that as long as we got the --
a response back to the QA department in a timely manner, which 4
we had set up as 30 days, and they agreed with our response 5-preliminarily, that we had showed intent that this is what 6
we wanted to do to resolve it and everything was okay.
7 Q
And, certain steps might in the future be taken 8
to implement the resolution?
9 A
That's correct.
.10 MR. HICKEY:
May I see the exhibit, please?
11 BY MR. JOHNSON:
12 0
I am going to show you another document.
It's 13 actually just one page.
It appears to be a signoff page of 14 the document.
It has a document number, UWI 4370-3891-83-PC-0 301 15 Underneath it says Revision 3.
It's entitled Three Mile Island 16 Unit II Load Test for Polar Crane Recovery.
17 Have you seen this document before?
18 A
My signature is on it, so I'm sure I saw it.
19 0
What is this document?
20 A
That's the unit work construction for the load 21 test of the polar crane.
22 Q
This is the approval page; what would you consider 23 this page?
'\\_)
A I believe that's the approval page.
O Your signature is listed here, is it not?
A Yes.
I 43 e
I Q
The date is 3-16-837
\\~-)'
'2 i
A That's correct.
Q Just above it, it appears to be Mr. Parks' signature,
4 dated 3-17-837 5
A Yes.
6 O
Can you read what it says there, next to Mr. Parks' j
7 signature?
8 A
I believe it says technical content of procedure 9
only.
10 Q
Do you recall signing off on this document on the 11 16th of March, 1983?
12 A
Not specifically, but I believe that based on what (T
13 N/
Rick Parks had written there, I vaguely remember him discussing 14 the load test procedure and whether or not it should be 15 approved and it was my feeling that there was nothing wrong j
16 with the procedure and as I recall, he asked me why I wouldn't 17 object to the procedure, and I told him that I felt that it wa s 18 my responsibility to review it for technical content and 19 technically it was acceptable, and I believe that's why he put 20 that comment down there.
21 O
When did this conversation take place, to the best 22 of your recollection?
23 A
Probably somewhere around 3-16.
24 O
NJ Q
Did he tell you his feelings about the procedure's 25 acceptability?
44 1
A I'm sure he did.
I don't remember now what grounds
(' _j 2
he was objecting to the procedure being approved.
3 Q
Specifically you don't remember?
4 A
No, not specifically.
5 O
Do you remember whether it had to do with 6
administrative implementation of the format requirements of 7
AP 1047?
8 A
It may have had something to do with that.
8 0
Was he, to the best of your recollection, still not 10 satisfied that the procedures had been followed for this II particular item, this procedure?
12 A
To the best of my knowledge, I think maybe he still
(~T 13
(_)
felt that.
14 Q
Did you physically transmit, pass on, the procedure 15 to him after you signed off on it?
16 A
That I don't remember.
I may have.
Somebody out i
17 of the Mike Radbill section or maybe Mike himself or maybe 18 somebody out of the start-up group might have been walking it 19 around to each individual and then picking it up, so that they 20 didn't lose the procedure.
I don't remember what circumstance s
21 it was transmitted.
22 Q
There's no connotation that was suggested that you 23 might have lost it?
24 l ()
A I wouldn't have lost it.
25 Q
There's a statement at the end of the Minutes that
i 45 I
we referred to of the TWG March 4th meeting.
At the very end 2
it says,"It was agreed that this position of the QDR discussed 3
in Section 2 should not affect the acceptance of no load 4
test results or TWG acceptance of the load test procedure 5
based on technical content."
6 How would you interpret that statement?
7 A
It's my interpretation that the QDR was the basis 8
for us accepting the no load test results and also the basis 9
of providing an approval to the load test procedure if it was 10 acceptable technically.
11 Q
In other words, were there two tracks, two lines 12 of reasoning inherent in the statement; one that the QDR would 9
13 take care of the format problems and that otherwise the 14 technical content was acceptable?
15 A
That's correct.
16 Q
Would you say that Mr. Parks, in your opinion, do 17 you think it's possible that Mr. Parks' comment attached next 18 to his signature on the signoff page, Revision 3, of the load 19 test procedure is consonant with the statement in the TWG 20 Minutes that you would go forward based on the technical 21 correctness of the procedure?
22 MR. HICKEY:
I object to the question.
I think it 23 asks the witness to speculate.
You don't have any foundation 24 for him having discussed it.
25 BY MR. JOHNSON:
46 l
1 Q
I think the question could have been put a'little c.,
2
-more clearly.
I don't think I asked that.
_j 3
What I-am asking you is:
Is there anything 4
inconsistent between -- in your opinion, -- between Mr. Parks 5
having written this, this language, technical content of i
6 procedure only, and the statement that I referred to in the 7
Minutes of the TWG on March 4th?
{
8 A
In my opinion, no.
9 Q
Well, go back in time to February 23rd, I believe --
10 I'm sorry,-February 28th.
Do you recall having a meeting 11 attended by several people from various groups on the site, 12 including people from recovery operations and site operations, 13
\\
on February 28th, discussing -- excuse me.
I believe the i
14 meeting was in connection with the preparation for a meeting l
15 of the readiness review committee that had been designated to 16 be convened by Mr. Arnold.
Do you recall a meeting on 17 February 28th, in Mr. Thiesing's office?
18 A
I don't remember the date, but I vaguely recall i
19 attending a meeting like that.
20 Q
Do you remember Mr. Parks being there?
1 21 l
A Yes, I believe he was.
22 I
Q I am not trying to hide the peanut.
I am just 23 trying to figure out what you remember without prompting you 24
()
and then I'll show you what I have.
25 l
Do you remember that at the meeting certain items I
i
47 1-were identified as -- the subject -- the purpose of the meetin g 2
was for members there to identify matters that should be 1
3 addressed or considered by the RRC?
4 A
Yes, the extent of my recollection was that there 5
was -- the discussion centered around what topics were going 6
to be discussed at the readiness review committee and an 7
assignment of action items to individuals to prepare to discus s 8
those topics.
9 Q
Do you recall that after the meeting that Mr. Thiesi ng 10 asked you and Rick Parks to stay behind to talk to him?
11 A
After one meeting, he did ask us to stay behind and 12 it may have been that meeting.
O 13 Q
Do you recall what was said in that meeting?
14 A
He was concerned and he stated that he felt it was 15 management's concern that since Larry King had been suspended, 16 I believe that that had happened just previous, how the people 17 in site operations were coping and whether the site operations 18 personnel had concerns. that their jobs were in jeopardy or 19 anything like that, any anxieties that would be experienced 20 by site operations personnel, and he asked us to stay behind 21 to discuss with him what our feelings were so that he could kind 22 of get a sense of where people in site operations or how peopl e in site operations felt and whether or not there should be any 24
)
reassurances by management that just because Larry was 25 l
suspended, that didn't mean that management was looking at l
48 1
suspending other individuals.
2 Q
Do you remember anything else?
3 A
No, that's basically.it.
4 Q
Did you respond to him?
5 A
Yes.
6 0
What did you say to him?
7 A
My recollection is basically that I told him that 8
we were concerned, but that was -- it's my feeling that we 9
didn't have any indication from management that the circum-10 stances surrounding Larry King applied to anybody else.
11 0
That was your feeling at the time?
12 A
I believe that was my feeling at the time.
It O-13 would have been in my case, I know, that the circumstances 14 surrounding Larry King didn't apply to me.
15 Q
And, you said that?
16 A
I believe I stated that, yes.
17 Q
What about Mr. Parks, do you recall what he said?
18 A
No, I don't recall what he said specifically.
I am 19 having trouble recalling what I said specifically.
20 Q
You are doing very well.
21 Let me show you Mr. Parks' affidavit.
This is his 22 March 21, 1983, affidavit in which he describes this meeting 23 and also the circumstances of the discussion that I have been 24 talking to you about after the meeting, and I will ask you jus b 25 to read a paragraph.
It's on Page 31 and it goes over to the
}
49 0
~ next.page, starting approximately at.the middle of the page.
y i
~
2 ths/7
-A How far over do'you want me to;go?
3 Ql Just that one paragraph, please..
i 4 -
I'd like to just go through some of these sentences 5
with you - It's about four ' sentences down on Page 31 in that-
'6 "We told'Thiesing there was general opinio.1 second paragraph:-
~
7-on site that 50 was a, bunch of malcontents and an unnecessary 8
evil."
9 Do you remember either you or Mr. Parks saying some-10 thing like that?
11 A
LI don't remember that statement being made, no.
12 Q'
Then the next sentence:
"Thiesing said that until fT 13
\\2 the Larry King incident,-he had decided to fire one person 14 per month in order to curtail inter-departmental squabbling 15 -
.over ancillary issues."
16 What is that, do you recall anything on that order?
17 A
I don't remember that statement being made either.
18 I can remember one statement that Jim Thiesing made that was 19 outside of this meeting.
20 MR. HICKEY:
I think he's trying to find out what 21 you remember about this meeting.
22 THE WITNESS:
I don't remember anything about this 23 meeting.
24
\\ );
BY MR. JOHNSON:
O What was the statement that you do remember outside It-
. ~. -
50 I
of this meeting?
2 A
He once stated that if a schedule had not been 3
issued, that that day, that particular day, that he would fire 4
the individual, and the schedule wasn't issued and he didn't 5
carry out his threat.
So I would not attribute much weight 6
to that statement, if he made it at all.
7 Q
You don't think that statement was made in that 8
conversation you had after this February 28th meeting?
9 A
No, sir I don't believe it was.
10 0
The next sentence, he says, "Now he didn't know how 11 he would handle inter-departmental disputes."
12 Did he say something like that to you?
13 i
)
A I don't remember that statement being made.
I4 O
Then it says on the top of Page 32:
"Thiesing also 15 stated that it was a second or third level 50 supervisor who 16 had gone to the NRC."
17 Do you recall the subject of second or third level 18 supervisor of SO going to the NRC being discussed in that 19 meeting?
20 A
I vaguely remember some reference to somebody from 21 site operations had gone to the NRC.
22 Q
What do you remember, if anything?
23 A
Essentially that Jim Thiesing made such a statement 24
~s and it caused me to wonder if people suspected that I was that 25 individual.
a___
51 I
Q Did you respond to the statement?
l [)
\\>
A I assured him that I didn't believe.that anybody 3
had gone to the NRC and I knew for a fact that I hadn't.
4 Q
Did he probe you on that response at all?
5 A
Not that I recall.
6 Q
Do you recall Mr. Parks responding to his statement?
7 A
As I recall, Rick made the same disclaimer.
8 Q
Did Mr. Thiesing say why he raised that point?
9 A
I believe he phrased it in the context that manageme:1t 10 was hoping that internal disputes and -- internal disputes 11 were handled or could be handled internally, without having to 12 go to outside agencies, that would be disruptive to the-work 13 force.
14 Q
So it was in the context of, these statements, of 15 trying to find out what site operation's reaction was to' Larry 16 King's leaving and so on that he raised this or was it separat a?
17 A
No, it was in the same context.
18 0
There's also a statement there on the second line, 19 "And he could see why certain people would be afraid of 20 transfer."
21 Do you recall that subject being raised by Mr.
22 Thiesing?
23 A
No, I do not.
24 Q
Did Mr. Parks make any statement along that line, 25 that addressed the question of fear of transfer or fear of
52 1
terminated or something like that?
O 2
A I can't ever recall Rick making a statement about being afraid of being transferred or being terminated.
l 4
l 0
Is it possible that or do you recall whether Mr.
5 Thiesing made some kind of a statement about transfers or 6
terminations in connection with the inter-departmental 7
squabbling between site operations and recovery operations?
8 A
I don't remember that.
9 Q
With respect to the question of someone going to 10 the NRC, did Mr. Parks or you ask him how he knew of such an 11 event?
12 A
I don't remember us asking him.
I don't recall him
)
volunteering how he knew either.
It's my understanding that 14 I left the room pretty unsettled, that somebody had done it 15 and that maybe they thought that I was that person.
16 Q
So you were unsettled by the thought that they may 17 have thought that you had gone to the NRC?
18 A
Yes.
19 Q
After that, did you speak to anybody else about that 20 conversation, Mr. Gischel?
21 A
Not that I recall.
22 Q
Anybody else7 23 A
No.
g O
Q Did you have any other conversations with Mr. Thiesi:ag 25 on that subject?
53 I
A Never.
T'.
2 Q
Did you have conversations with Mr. Parks after you 3
left together -- did you leave together at that point?
4 A
I believe we did and we probably walked back to the 5
back to our office, which was separate from where this meeting 6
was held.
l 7
Q Do you remember anything about that walk; did you 8
have a conversation with him?
9 l
A I believe we did.
1 i
10 Q
Do you remember the conversation?
11 A
only that we discussed who in site ops. had gone to 12 the NRC and both of us assured each other that it wasn't us.
O' 13 I was unaware at that time that Rick Parks had had discussions 14 with the NRC.
i 15 Q
Did Mr. Parks express to you concern?
16 A
I don't think any more concern than was already 17 expressed.
I believe as I said earlier, it was kind of an 18 unsettled period in the site operations organization.
19 Q
Did he appear to be unsettled as you were by the 20 statements concerning the NRC?
21 A
He may have.
22 MR. HICKEY:
No, the question is did he appear to be 23 unsettled by the statements.
24 THE WITNESS:
Oh, just those statements?
25 MR. HICKEY:
I thought that is what you were asking.
i
--__._m____-_-___-_m_._.__.__
_.2m_
54 1
MR. JOHNSON:
Yes.
(q -
s) 2 MR. HICKEY:
The statement that someone had gone 3
to the NRC, did Rick Parks appear to be unsettled?
4 THE WITNESS:
I don't remember.
5 BY MR. JOHNSON:
6 Q
What was he unsettled about?
7 A
Well, I think all of us --
8 MR. HICKEY:
Wait a minute.
That's kind of ambiguous 9
in light of the comment that you made before that.
You are 10 talking about this discussion when he's walking back from the 11 office?
He didn't testify he was unsettled.
12 MR. JOHNSON:
He just said he was.
O1 13 MR. HICKEY:
I don't think he did.
14 MR. JOHNSON:
I believe he did.
Would you read back 15 the answer?
16 (Whereupon the Reporter read back the referred to I
17 question and answer as follows:
"Q:
Did he appear to be 18 unsettled as you were by the statements concerning the NRC?
19 A:
He may have.")
20 BY MR. JOHNSON:
21 Q
Did you want to change that?
22 A
No.
23 MR. HICKEY:
Wait a minute.
Is it your understanding 24 that the witness means that Mr. Parks was unsettled?
His 25 answer he may have, is that what you are referring to?
l i
55 r-l l
1 MR. JOHNSON:
It's my understanding that he has
?s-( )-
2 testified that when I asked him was Mr. Parks unsettled as Mr.
3 Warren was by the comments about the NRC, he said I may have; 4
is that correct, that's what you said?
5 THE WITNESS:
Yes.
6 BY MR. JOHNSON:
7 Q
That's what I take it as, he may have.
l 8
You are not certain?
9 A
I'm not certain, that's correct.
10 Q
You are not certain today?
11 A
Today.
12 O
During this period of time, did there ever come a
()
time during the period February, March, until Parks left the 13 I4 '
site where you had trouble working with Mr. Parks?
15 A
No.
16 0
Were you aware of the circumstances involving Mr.
17 Parks being removed as primary site operations representative 18 on the TWG?
19 A
I don't believe I was.
I don't recall at this date 20 that I was.
21 Q
Did you attend a meeting on March 23, 1983, in the 22 morning, that was chaired by Mr. Arnold in a large room with a 23 conference table?
24 A
I don't remember attending -- I remember attending I
(}
25 one meeting.
I am not sure what the date was.
l l
l l
56 I
Q What was the subject of that meeting?-
2 v
A The subject, as I. recall, was -- this was I believe 3
after the -- after Rick Parks had submitted his affidavit and 4
the subject was what we were going to do with polar crane 5
program to get it back on track,where it had to go, where it 6
had to proceed to, that sort of thing.
7 Q
Do you remember someone, either Mr. Arnold or Mr.
8 Kanga or Mr. Barton, standing or being in front of the meeting 9
having a piece of paper that was either a statement of Mr.
10 Parks, his affidavit, or some kind of press release in his 11 hand?
12 A
No, sir, I don't.
f 13 Q
-You don't remember that'.
14 Did you attend that meeting with Mr. Gischel?
15 A
Is this before the affidavit?
16 O
This one that you said you did remember.
17 MR. HICKEY:
After the affidavit.
18 BY MR. JOHNSON:
1 19 Q
You said the affidavit --
20 A
I believe that Ed would have probably been there, ye:3.
21 Q
Do you recall whether Mr. Parks had had his press 22 conference at the time of this meeting?
23 A
As I recall, the meeting that I attended was after 24
(
his press conference.
25 Q
It dealt with how to proceed with the polar crane?
L L
57 l
l' A
And, the recovery program, right.
L(
2 O
Do you recall being at a meeting in which what to 3
do with Mr. Parks was discussed?
4 I'm sorry, that wasn't phrased very well.
5 How to relate to Mr. Parks was discussed, once Mr.
6 Parks came back to the site, what kind of treatment Mr. Parks 7
should have, for example, whether he should be given documents f
8 if he requested documents?
9 A
No, I don't recall a meeting such as that.
10 When Rick Parks came back to the site, I believe he 11 was escorted off the island.
I saw him as he was leaving.
12 That was -- I only saw him one time after he submitted his
(}
affidavit and that was -- he was walking out the office area.
13 14 He had come back and he immediately left.
15 O
The meeting that you are referring to was after that?
16 A
The meeting that I attended would have been after 17 that,,yes.
18 Q
Were you at a meeting at.which_Mr. Barton made. the 19 statement that Mr. Parks should be fired for making his concerr s?
20 A
I don't. remember hearing John Barton saying that.
21 I assume I wasn't at the meeting.
22 Q
Going back to the readiness review committee meeting 23 that you discussed in your February 28th meeting with Mr.
24
(
Thiesing's office, was one of the purposes of the readiness 25 review committee being convened to address the concerns on
58 1
AP 1043 and AP 1047 that Mr. Parks had raised?
I) 2 MR. HICKEY:
I object to the form of the question.
l 3
There is no foundation about whether the witness is aware of 4
the circumstances surrounding the convening of the readiness 5
review committee.
6 MR. JOHNSON:
He just discussed that he attended 7
a meeting at which the issues were discussed; is that correct?
8
-THE WITNESS:
Yes.
9 MR. HICKEY:
You asked him what he knows about the 10 circumstances or the reason for convening the readiness review 11 committee.
There's no foundation for that question.
BY MR. JOHNSON:
(}
13 Q
Did you learn from attending that meeting what the 14 purpose of the readiness review committee being convened was?
15 A
I believe that the purpose was to address all the 16 issues that were open on the -- regarding the polar crane 17 and to present the -- this committee that was formed, the 18 readiness review committee, with a presentation that all those 19 issues were adequately addressed and that the polar crane was 20 indeed safe to utilize for the load test and subsequent 21 operations.
22 O
Were Mr. Parks' concerns about the applicability 23 and compliance with AP 1043 and AP 1047 with regard to the i
24
(
polar crane load test procedure one of those matters?
25 A
They may have been, but I don't remember it now.
59 1
As I recall, there were probably 15, 20 issues that were discussed and I don't remember the specifics of any of those 3
issues.
4 Q
Did you learn from Mr. Gischel of a meeting at which the affidavit of Mr. Parks and what to do about the affidavit 6
was discussed?
7 A
It seems to me that I learned about the affidavit 8
before it was issued, maybe a day before, but I don't remember 9
who told me about it or specifically what they said, other 10 than Rick Parks was going to be on T.V., because I remember 11 going home that night and turning on the T.V.
to see if he was 12 on.
)
Q I see.
14 So you don't specifically recollect having been 15 informed by Mr. Gischel?
16 A
No, I don't remember.
17 Q
Do you remember having a meeting with other super-visors under Mr. Gischel, Mr. Hoffstetter, Mr. Mummert and I 19 think there's one other individual, Mr. Carl Harney?
20 A
Carl Harbac?
21 Q
Was it Harbac, was he on that level with you?
A No, he wasn't on that level.
Q Do you remember a small meeting in which Mr. Gischel 24 nvened with just the supervisors at your level on 25 approximately March 23, just before Parks went public?
60 1
A No, I don't remember that meeting.
.A k.j Q
Would you turn to Page 36 of the Parksiaffidavit,.
2 l
please?
3 4
During the period of winter '82,
'83, until Mr.
5 Parks went public, do you recall having any discussions with 6
Mr. Parks concerning his relations with Mr. Kunder, George 7
Kunder?
8 A
Not specifically.
9 O
During this period you say you were vice-chairman 10 of the PORC, so I assume you had some kind of regular ontact 11 with Mr. Kunder?
12 He nodded.
Would you audibly respond?
A
'82,
'83?
14 0
Yes.
15 A
That was after the reorganization.
I wasn't vice-16 chairman of PORC then.
I think that was after I was vice-17 chairman of PORC, because that's after the SRG formed.
18 0
Is it your understanding that when there was the 19 major reorganization in September of 1982, that the SRG was 20 formed?
21 A
I think it was formed somewhat before that, but I 22 know after that, that reorganization, it was in existence and 23 the PORC, as I recall, was no longer functional.
24 Q
I just direct your attention to some statements made 25 on Page 36 of Mr. Parks' affidavit, among them is a sentence
i 61 I
in the first complete paragraph where it says, "We also
.,q l (j 2
discussed why PORC chair, George Kunder, was not stopping 3
violations.
Gordon,- " I believe that's Gordon Clements.
His 4
name is used on the previous page.
This is a discussion, if 5
you go back to Page 34, that apparently followed on after 6
either during or after a meeting of March 3rd, according to 7
Mr. Parks, and he had a conversation after the meeting with 8
Mr. Clements.
It's recounted at the bottom of Page 35, top 9
of 36. According to Mr. Parks, Gordon responded on several 10 occasions Kunder had refused to get involved with the dispute.
11 Mr. Kunder was head of the SRG when it was formed; 12 is that correct?
j O
13 A
I believe he was or maybe there was somebody that 14 was for a couple days was head of the SRG and then George took 15 over.
I'm not sure.
But, essentially, he was head of the SRG 16 from its inception.
17 Q
Were you aware of any frustrations that Mr. Parks had 18 with respect to Mr. Kunder?
19 A
Not specific frustrations.
I would assume that he 20 might have had some frustrations if certain procedures were 21 returned with comments or rejected.
22 O
I don't understand your answer.
You understand, but 23 MR. HICKEY:
He said, I assume.
24 BY MR. JOHNSON:
25 0
Why do you assume that?
62 I
A Because George was or the SRG's responsibility as th a
/0 k/
2 g
PORC's had been previous was to review documents for adequacy 3
l and that adequacy spanned an entire realm.
Sometimes document s 4
were rejected for administrative inconsistency.
Sometimestthe 1
5 l
person that was conducting the review didn't agree technically 6
with the way a procedure was written and would return it or 7
would refuse to sign it.
My favorite example is the first six 8
procedures that I wrote were all rejected by the PORC on the 9
same day and in my own opinion I was frustrated that day.
10 0
What was the day, can you recall when that was?
11
{
I A
Back in '78,
'77.
I was brand new here.
12 George was head of this group and as the head of the
(
13
\\~
group, it was George's final responsibility to either agree 14 with the comments and reject the documents or to override his 15 own people.
So he had some difficult decisions to make and 16 I think that people from time to time were frustrated with 17 George, that they didn't -- that he didn't pick their side 18 in an issue.
19 In reading this part of Rick's statement, it seems 20 feasible to me that he may have been frustrated from time to 21 time, because he submitted some documents that George disapproved.
O This is your deposition to Mr. Stier, I believe, 24 O
N_/
from 3-31-83.
You are asked starting on Page 6, Line 12, 25 do you know anything about the relationship between Richard
63 I
I Parks and George Kunder and the discussion goes on for awhile, n
k_
2 I think, up to Line 12 on.the next page, Page 7.
Would you 3'
just look over that for a second?
4 A
I don't think that this -- what I said here is reall y 5
inconsistent with what I have already told you, except that I 6
can't remember the specific details.
I don't remember specifi :
7 times when Rick was upset.
8 Q
You would adopt those statements as true today?
9 l
A Yes, I believe I would.
10 Q
Do you know of any basis -- let me ask you in a 11 different way:
At the time that Mr. Parks expressed his or 12 you learned of Mr. Parks being upset with Mr. Kunder, do you
' t/.
13
\\-
recall whether you believed that Mr. Parks had a basis for 14 being upset?
15 A
I don't recall.
16 Q
You don't recall today whether you felt he had a 17 basis then?
18 A
Yes, I do not recall that I thought he had a basis.
19 0
On Page 9, you said, "There were instances of 20 disagreements I had with George, but as far as I was concerned 21 that was a working relationship."
22 Could you describe what you were referring to, there 23 were instances of disagreements I had with George?
24 A
Regarding procedures.
I had written a procedure; 25 George disagreed with how I wrote the procedure or what I had
64 1-in the procedure and he refused to sign my procedure until r~(,)
2 I made clarifications or corrections.
That's what I meant by 3
working relationship.
It was just in dealing with day-to-day 4
work.
George had some difficult positions to take and sometimes l 5
they didn't go always the way a person would like them to go.
6 Q
Once you learned Mr. Parks had gone public or was 7
about to go public, what was your reaction?
8 A
I don't specifically recall.
It must have been 9
curiosity, because I remember watching the T.V.
10 Q
Do you remember having any discussions with anyone II on the site about how you would react following Mr. Parks 12 suspension if he were to come back to the site to work?
()
I3 A
No, I don't.
I --
14 0
What was your -- go ahead.
15 A
I saw -- like I stated previously, I saw Rick Parks 16 in the hall as they were escorting him out and I talked to him 17 so --
I 18 O
Was it a pleasant conversation?
What kind of 19 conversation was it?
20 A
It was brief.
The only thing I remember out of the 21 conversation was something to the effect that I'll be hearing 22 l
from him again and that's basically it, but it wasn't an 23 unpleasant conversation, I know that.
24
(
0 If he had returned following his suspension, would 25 you have been able to continue to work with him if he had come back?
1 A
On a working relationship, I think I would have.
D
(/
2 Q
In the Parks' affidavit and in your previous state-1 3
ment, you mentioned that you had notes of the February 28th, 4
1983 meeting, the readiness review committee matters were 5
discussed.
Do you have those with you today?
6 A
I read your Notice of Deposition and that you wanted 7
notes and files.
I did search my files to see if I had anythi ng 8
left.
I am not a very good notetaker and I don't keep much.
9 I usually write notes to myself to remind me to do something, 10 not for historical purposes and I couldn't find anything and II I assume I must have thrown everything out or maybe I gave the i
12 things I had to Mr. Stier, because his investigation was
)
pretty soon after these events.
14 Q
Okay.
15 I think you may have, as it's indicated in the j
16 deposition that you did.
17 MR. JOHNSON:
Mr. Hickey, do you have those?
l 18 MR. HICKEY:
No.
19 BY MR. JOHNSON:
20 Q
On Page 35 of the deposition I believe of September. 3, 21 1983, you make a statement, "I believe I did attend that 22 meeting.
I took some notes in my notebook and Rick borrowed 23 my notebook and he jotted down some notes in the notebook and 24
(
those notes I provided to you."
25 So you gave them to Mr. Stier or Mr. Malita, whoever
l 66 I
conducted this investigation; is that correct?
!)
2 Nj A
I am sure I must have if I said it there.
1 3
Q Do you recall getting them back?
1 4
A No.
5 MR. JOHNSON:
Mr. Hickey, do you know whether they 6
were identified in your search?
7 MR. HICKEY:
I beg your pardon?
I don't understand 8
what you are asking me.
9 MR. JOHNSON:
The question was:
Were these notes l
10 searched for in your response to the staff's discovery request?
11 MR. HICKEY:
I don't remember specifically looking 12 for those notes.
I don't remember -- I am not sure where in
/~5 13 kl the discovery request they would be covered.
But,the Stier 14 materials are all available and have been since the Stier 15 investigation.
16 MR. JOHNSON:
I looked and I didn't see the notes.
I 17 identified in the document index that follows Mr. Warren's 18 deposition.
I presume they were not part of the bound 19 materials.
20 MR. HICKEY:
Did you take notes in your discussion 21 after that meeting, the one you and Mr. Parks had with Mr.
22 Thiesing?
23 THE WITNESS:
I probably didn't.
Like I said, I 24
()
don't take very detailed notes.
25 MR. H1CKEY:
You didn't happen to ask Mr. Parks if
67 1
he has a copy of the notes?
/(,j.
2 MR. JOHNSON:
You are asking me?
3 MR. HICKEY:
Yes.
MR. JOHNSON:
I don't recall asking him for'those notes.
6 Let me see if I can get them from Mr. Parks.
If I 7
can't, I may ask Mr. Hickey for them.
8 (Whereupon a brief break was taken at this time.)
9 BY MR. JOHNSON:
10 Q
Mr. Warren, in addition to the two statements that 11 you gave, one to Mr. Stier and one to Mr. Malita on the 31st 12 of March, 1983, and the second one, I think, was September 8, 13
\\
1983, did you give any other statements to lawyers or other 14 investigators employed by Mr. Stier or anyone else concerning 15
'these matters?
16 A
I gave a statement to John Barton.
17 0
Okay.
18 On March 23, 1983, is that what you are referring 19 to?
Does that document represent that interview?
20 A
Yes.
21 0
Did you want to say something?
l 22 A
Nothing regarding that.
You asked about other 23 statements.
I've given so many.
I spoke to the NRC one time 24
()
about Larry King and I think I spoke to the NRC another time regarding Ed Gischel, maybe Rick Parks.
I am not sure.
I l
1
68 I
think I had two interviews by the NRC.
[)
2
(, /
0 In any of those interviews did you discuss anything-3 concerning Richard Parks?
4 A
The interview with John Barton discussed Rick Parks 5
and the two interviews with the NRC, the one was regarding 6
a background investigation on Larry King, I remember that.
7 I don't think Rick Parks' name came up.
The other one I can't 8
remember exactly what the subject was on that and his name may 9
or may not have come up on that.
10 0
I am going to show you this record of this March 23, 11 1983 interview, which aypears to be an interview between you 12 and Mr. Barton.
It's one page.
Have you seen that before?
A Yes.
14 Q
Did you retain a copy of that?
15 A
I couldn't find it, so I don't know if I have it now 16 or not, although I have a copy that Mr. Hickey provided me.
17 Q
Could you refer to your copy?
18 A
Sure.
19 Q
Do you recall the circumstances of this interview?
20 A
It was immediately after Rick Parks submitted his 21 affidavit and I believe that John Barton called in a number of 22 people regarding this reference to a mystery man.
I think he 23 asked us all the same question.
24
(')
Q When he spoke to you, had you already learned previ ously of Mr. Parks' affidavit?
69 l
l 1
A Yes, I believe I had already read it.
7 L,
2 l \\m/
Q Do you remember the circumstances of your receiving l
l 3
a copy?
4 l
A I don't remember how I got a copy, whether it was 5
distributed by communications or if somebody in management 6
had a copy and they had copies reproduced to other individuals 7
Q But, you'are confident that at the time of this 8
interview you had read it?
9 A
I feel confident that I had read it, yes.
10 MR. HICKEY:
The memorandum refers to it, doesn't it ?
11 Should we mark this as an exhibit?
12 MR. JOHNSON:
Fine.
.f~
13
\\-
(Summary of Warren Interview by Mr. Barton was marked 14 Warren Deposition Exhibit No. 2.)
15 BY MR. JOHNSON:
16 0
Had you read the affidavit on the same day t:iat you 17 were interviewed by Mr. Barton?
18 A
I don't remember, 19 0
Was it fresh in your mind when you had the interview ?
20 A
As I recall, it was.
21 Q
Do you remember other than the fact that you just testified that you don't recall how it was distributed to you, do you remember the circumstances under which you first learne d 24 of the affidavit?
25 A
I don't remember the circumstances.
I know that I
70 1
knew about the affidavit the night that Rick went public,
/'~)
2
\\~/
because I went home and watched it on T.V, and I remember 3
going home and knowing that he was going to be on T.V.
So I 4
knew about it then.
But, how far in advance I knew, or who-5 told me that there was going to be -- that he was going to 6
submit an affidavit, I don't remember.
7 Q
What was your reaction when you did read the 8
affidavit with respect to the discussion in it concerning Mr.
9 Kunder?
10 A
My reaction was that some of the statements that 11 Rick made were inaccurate or taken out of context and that by 12 submitting them in an affidavit to try to lend credibility to C')
his product, he had actually done just the opposite and made 14 you question whether or not anything was true.
15 Q
Specifically what things are you referring to in 16 terms of the accuracy?
17 A
Well, the most specific instance is referring to 18 the safety injection pumps, when it was my understanding that 19 the pumps he should have been referring to were the reactor coolant pumps.
l Q
Why is that, why should he have been doing that?
22 A
They were the pumps that I understood were secured i
I 23 on the day of the accident and the other thing that kind of 24 troubled me about that specific statement was that Rick wasn't at TMI on the day of the accident and I was and I knew that
71 I
there was a lot of information that I was never in my own mind
?
I 2
(,
fully sure about and it bothered me that a person that wasn't 3
even here would bring up issues like that when he didn't i
4 really have;any background or basis to raise those issues.
5 0
At the time you read the affidavit, did you have 6
information that Mr. Kunder had been involved in turning off the reactor coolant pumps during the accident?
8 A
I believe that I was told somewhere during the time 9
of the accident, that George had been the person to tell the 10 operators to secure the reactor coolant pumps because they were 11 experiencing high vibrations.
I wasn't here when those pumps 12 were secured.
When I showed up, or when I arrived at the site i
13
\\
that day', there was a lot of difficulty in getting one of 14 those pumps restarted, and that's why I believe that after the 15 fact, there was some questioning about whether or not they 16 should have been secured in the first place.
To be perfectly 17 honest with you, to this day, I don't know who ordered the 18 reactor coolant pumps to be turned off, nor who secured them.
19 0
When you say secured, you mean who physically 20 turned them off?
21 A
Who physically manipulated the controls.
22 Q
Did you feel that if Mr. Parks had instead of 23 referring to the high pressure injection pumps, had referred t a
24
()
the reactor cool.hnt pumps, that he might have had a basis in 25 referring to Mr. Kunder in that connection?
I
72 1
A It would have put his write-up in a different
,r\\
(
2 perspective, I think.
Like I said, I am not sure even nowa 3
that George did actually secure those pumps.
So that issue 4
still remains to be addressed, but the fact was that I am not l
5 aware that the safety injection pumps or the high pressure 6
injection pumps were secured and I thought that that rendered 7
that part of his transcript totally inaccurate.
8 O
Did you have any knowledge of the basis on which --
9 I am talking about the time of this interview -.did you have 10 any knowledge as to the basis for Mr. Parks' statement?
11 A
I do not.
12 O
Did not, I am talking about then.
(}
13 A
I did not at the time either.
14 0
In other words, you didn't know what Mr. Parks knew 15 or how he learned it concerning either the reactor coolant 16 pumps or the high pressure injection pumps?
A No, not the specific incident that he became aware 18 or that he had discussions regarding either sets of those 19 pumps.
20 Q
On a different subject, when did you first become 21 aware of the involvement of Larry King with job shop operation ? '.
22 A
Maybe I can answer it in a different way.
I -- when 23 Larry was suspended because of his conflict of interest, my 24
(
own personal belief was one of disbelief, because he had never 25 talked to me about any other company or any involvement with
'73 1
any other company, nor some of the individuals whose names
/N-f( }
2 got brought up, such as Ben Sloane.
I recall conversations 3
where he told me Ben was alive and doing well, but he never 4
referred to them as business associates'or partners or whatever 5
they were.
I first heard the name Quiltec a few days, maybe a 6
week, before Rick Parks' affidavit and I heard it from Rick 7
Parks.
8 Q
Were you aware of any rumors concerning Mr. King 9
and the job shop prior to that time, prior to the suspension 10 of Mr. King?
II A
I was not.
12 O
Just to go back momentarily to the readiness review
/'"N 13
()
committee:
In your prior statement to Mr. Malita on 14 September 8, 1983, you were asked about the readiness review 15 committee on Page 34 and then you answered that you were not 16 involved, "Were you involved in what is known as the readiness 17 review?"
You said,
I don' t believe I was.
I think the task 18 force was formed by Mr. Arnold and I wasn't involved in that."
19 You were asked, "Do you know why the task force was 20 formed?"
You answered, "It was to discuss concerns that had 21 been raised regarding the polar crane by people like Mr. Gisch 31, 22 Mr. Parks and other people such as QA."
23 MR. HICKEY:
QC.
24
(}
BY MR. JOHNSON:
Q I'm sorry, QC.
Is that statement true, is that a true statement of
74 I
what you believe?
k]/
f A
Yes.
m 3
Q During Mr. Gischel's deposition on the 15th of 4
January, Mr. Hickey was asking Mr. Gischel some questions, 5
and this is concerning the polar crane.and Mr. Gischel's 6
position on the procedural violations, and I would just like 7
you to read this colloquy between Mr. Hickey and Mr. Gischel, 8
starting on Line 14 and ending on Line 20.
9 MR. HICKEY:
I think that as I read that at least, 10 I think you need to read somewhat before that to get the 11 context of the pronouns.
12 MR. JOHNSON:
All right.
O~
13 BY MR. JOHNSON:
14 Q
Okay, have you?
My question is regarding Mr. Gische l 15 started talking about retest of the polar crane and he says 16 they were planning to test the polar crane without proper 17 certification of the modifications that were made to it.
Do 18 you have any knowledge of what Mr. Gischel is referring to here?
19 A
No, I do not.
20 MR. HICKEY:
That's Page 108, by the way.
21 MR. JOHNSON:
Sure, Page 108.
22 BY MR. JOHNSON:
23 Q
As L general matter during the period January, April 24
)
May of 1983, you had day-to-day contact with Mr. Gischel; is that correct?
75 1
A Yes.
)
(
2 o
You worked for him?
3 A
I did.
4 0
Would you say that he had any trouble at that time 5
with respect to recording his recollections, to your knowledge?
6 MR. IIICKEY:
What?
7 BY MR2 JOHNSON:
8 0
Did you have any occasion to see things that Mr.
8 Gischel wrote?
10 A
I believe there were a couple letters that he 11 wrote and he showed me the letters before he issued them.
I 12 didn't see any personal notes or things that he wrote other
()
than regular company inter-office memorandum.
14 O
Did you perceive any difficulty he had in writing 15 those notes, those letters?
16 A
I didn't witness him writing them, all I saw was the 17 final drafts.
18 0
Was there anything unusual about the letters in 19 terms of their accuracy or his ability to recollect facts or 20 cogently express himself?
21 MR. HICKEY:
I object to the form of the question.
22 BY MR. JOHNSON:
23 Q
Do you have any recollection of those letters?
24 O
^
a
=ot-Q What was happening with respect to the relationship
l 76 1-between your department and Mr. Barton during the spring of
[
2 1983, which caused you to write this memorandum of June 9, 198 3, l
3 No. 4240-83-3977 4
A John Barton believed or I believe he believed that 5
plant engineering was not working to the level of excellence o r 6
to the level of efficiency for which he would have expected, 7
and he ordered our department to fill out time sheets t.o 8
transmit to him what each engineer spent his individual time 8
He didn't give us any format for these time sheets that on.
10 we were supposed to submit, nor was anybody else in the TMI II 11 division, to my knowledge, required to submit similar type 12 of time sheets.
We were required to submit time sheets, but
)
not to the level of detail which John required us to submit.
14 So to paraphrase it, we were submitting two time sheets, versu s 15 other other groups that only had to submit one and our second 16 time sheet was in much more detail.
17 We undertook submitting those time sheets and my 18 feeling was we didn't question submitting them.
But, the --
19 once John saw what we submitted to him, he didn't like the way 20 we had formatted our time sheet, so he sent them back to us 21 and said that they were insufficient detail, they didn't allow 22 him to fully access what we were doing.
23 MR. HICKEY:
Can I interrupt?
Does this have some 24
()
relevance to one of the issues in this proceeding?
This is a 25 June, '83 memo about a department that Mr. Parks was not a par t
77 1
of and time sheets.
(
2 MR. JOHNSON:
What I was trying to determine was 3
whether there was some kind of on-going aftermath of the 4
earlier difficulties that had prevailed at the time that Mr.
5 Parks was on the site between site operations and management.
6 That was the reason I asked the question.
MR. HICKEY:
It seems to me it's pretty far afield.
8 You can ask if you want.
BY MR. JOHNSON:
10 Q
Do you have anything more to say?
11 A
That was basically it.
We submitted these time shee ts 12 for a period of about three months and then they were
()
discontinued.
But, during those three months, it became prettr 14 frustrating, at least to myself, to be requiring people to 15 spend -- they were spending approximately an hour a day that 16 they could be working filling out time sheets.
17 Q
Did this have in your mind anything to do with 18 concerns that had been raised by Mr. Gischel, Mr. Parks and 19 Mr. King?
20 MR. HICKEY:
I object to the question.
Is there any 21 foundation for that question, asking him to speculate whether 22 in his mind it had anything to do with it?
I object.
23 EY MR. JOHNSON:
24
()
Q You can answer the question if you can.
A I am not aware of any foundation.
h 78 I
Q Any connection?
2 A
Any connection at all.
3 Q
I am going to show you a document that was -- first 4
let me ask you a couple questions preliminary to showing it to 5
you.
6 Do you recall attending a staff meeting with Mr. Kanga 7
on May 4, 1983, Kanga-Barton staff meeting?
8 A
I nay have.
I attended some staff meetings, but the 9
date has no significance.
10 0
Did you attend it for Mr. Gischel, if you did?
11 MR. HICKEY:
Maybe you ought to clarify.
Do you 12 recall attending the staff meeting he's asking you about?
O' 13 THE WITNESS:
No.
14 BY MR. JOHNSON:
15 Q
Let me show you notes that were discussed in Mr.
16 Gischel's deposition, Gischel Deposition Exhibit 5, and Mr.
17 Gischel said he prepared these notes.
18 Have you ever seen those notes before?
19 A
No.
20 Q
Please take your time and read it through.
21 MR. HICKEY:
Why are we asking him to read these?
22 MR. JOHNSON:
I am going to ask him questions about 23 it.
24
'( )
MR. HICKEY:
About something he hasn't seen?
MR. JOHNSON:
You don't have to read it if your counsel:
79 I
doesn't want you to read it.
,0 (m/
MR. HICKEY:
I am trying to understand what the 3
purpose of it is.
4 MR. JOHNSON:
I am going to ask questions and read 5
parts of it.
6 MR. HICKEY:
Are you trying to refresh his 7
recollection about what?
8 MR. JOHNSON:
An event described there, yes.
F THE WITNESS:
Okay.
10 BY MR. JOHNSON:
11 Q
Does reading that memo refresh your recollection 12 of the particular Kanga-Barton staff meeting which you attended?
A No, it doesn't refresh my memory on the staff 14 meeting.
The issues I am well aware of.
15 Q
I am particularly interested in whether you recall 16 a statement by Mr. Kanga where Mr. Gischel writes, "Also Kanga 17 apparently was quite pleased about Parks' reference to the 18 mystery man in his affidavit."
19 Do you recall informing Mr. -- first of all, do you 20 recall reporting the contents of this meeting to Mr. Gischel?
21 A
No, I do not.
22 Q
Do you recall statements like those attributed to 23 i
Mr. Kanga in this document, saying that Kanga apparently was 24
)
quite pleased about Parks' reference to the mystery man in his affidavit?
80 1
A I don't remember saying that Kanga was pleased.
I
{f 2
believe that Kanga did make that statement, that the mystery 3
man allegation was significant in discrediting a lot of the 4
charges in Parks' affidavit.
5 0
That it indicated it was enough to discredit the 6
whole document?
7 A
I don't know if he said that.
8 Q
Did you express to Mr. Gischel any opinion or 0
reaction with respect to that statement that he said?
10 A
No, I don't.
I personally believe that statement, 11 as I indicated earlier, that Rick did a disservice to himself 12 and also to GPU by even raising an issue like that, because he O
13 had no basis or experience to raise that kind of an issue and 14 Ed could have put that down saying that Kanga expressed those 15 i
sentiments, when, in fact, I had expressed them.
16 Q
I don't follow that.
You are saying --
17 A
The fact that the reference to the mystery man could 18 discredit his entire document.
19 0
In other words, you are saying it is possible that 20 you told Mr. Gischel that you believed it discredited the document, not that Mr. Kanga believed it discredited the entire i
document?
23 l
A Yes.
i 24 Do you feel one or the other is more likely to be O
l 25 l
l correct?
l l
A I don't know.
l
81 1
Q But, it's a possibility?
2 A
It's a possibility.
3 Q
Mr. Gischel apparently thinks that based on this 4
memorandum, that it was Mr. Kanga who made those statements 6
and he goes on to say that, "Ron said he was very disappointed 6
at the attitudes exhibited by many, including Kanga and Barton,
7 at the meeting."
8 Could you describe what he's referring to there?
9 MR. HICKEY:
I think the witness testified he didn't 10 remember making those statements.
11 BY MR. JOHNSON:
12 O
If you can.
(:)
8 A
I can't tell you what attitudes I was talking about, 14 if I did, in fact, talk about them.
15 Q
Did you take any notes at this meeting of March --
this Kanga-Barton staff meeting that is referred to here?
A I may have, but they are long gone if I did.
O Did you give them to Mr. Gischel?
I A
I don't think I ever gave any notes to Ed, nor did 0
I ver see any of the notes that he made when people discussed 21 things with him, although I do know that some of his discussio:1s 22 he made notes after they had discussions with him.
23 Q
Does the remaining part of this memorandum, the note 24 of Mr. Gischel's, reflect attitudes that you had at that time, 25 that is that you were disappointed in the tone of the meeting
82 1
concerning dealing with the problems, issues that were raised 2
at that meeting?
3 MR. HICKEY:
Could you rephrase the question?
I 4
am not totally clear what you are asking him.
5 MR. JOHNSON:
I am asking him whether the notes 6
that Mr. Gischel make there accurately portray Mr. Warren's 7
attitudes concerning or his reaction to the attitudes expresse d 8
in the meeting.
MR. HICKEY:
I have to object.
He doesn't remember 10 the staff meeting.
He doesn't remember reporting to Gischel.
11 I think the question is unfair.
12 BY MR. JOHNSON:
O 13
\\_/
Q Actually, I didn't phrase the question initially 14 that way.
I said whether these attitudes were attitudes that 15 you had, irrespective of whether you attended the meeting or 16 not or you recollect the meeting.
17 MR. HICKEY:
And the attitude you are referring to?
18 BY MR. JOHNSON:
19 Q
Disappointment in the attitude of many on the site, 20 including Kanga and Barton, about resolving issues.
21 A
Personally I don't know what attitudes they were 22 exhibiting or what attitudes were talked about here.
The only 23 one issue that I see in this letter in which I was somewhat
()
disappointed was the ITS issue.
25 0
Which was?
83 l
1 A
Important to safety, and the conflict was that some
/O of us believed that we had a document in place which defined i
3 what was important to safety and other people believed that 4
you develop criteria to define what important to safety was.
5 My personal feeling was that the former applied and that was 6
overruled.
7 0
What's the significance of taking the former position 8
versus the latter?
9 A
My feeling was it was cleaner cut.
Getting 10 questioned by review groups like QA and the NRC and various 11 other groups, where they asked you to state specifically why 12 you made such a determination, I preferred having a document
(~'
13 that I could fall back on saying this is how I made that 14 determination versus having people come in and take a separate 15 point of view or a separate approach to a problem and saying, 16 well, we disagree with your determination now and having no 17 basis to really fall back on, other than a technical judgment 18 or subjective opinion.
19 Q
I see.
20 In other words, the second way of doing it, was doin g 21 it on a case-by-case -- determining it on a case-by-case basis whether a matter was important to safety or not?
A That's correct.
24 Q
So that when you started doing a particular project 25 or reviewing a particular matter, you weren't sure until the l
f 84 l
1 1
end of the process whether it was considered important to 2
safety or not?
3 A
That's correct.
4 Q
Do you recall ever saying to Mr. Gischel that you 5
felt that positive things were going to happen as a result of 6
the investigations, I assume you meant Parks, Gischel, King, 7
related investigations, but that you weren't sure that manage-8 ment was responding in appropriate fashion?
9 A
No, I do not and I don't believe I was sure positive 10 things were going to happen.
Q Do you recall being interviewed by somebody from the 12 government accountability project?
rm 13 A
I vaguely recall that interview.
14 Q
Do you remember the name of the person?
15 A
I think it was Thomas Devine.
16 Q
Do you remember where that interview took place?
17 A
It think it was at Killian and Gephart.
1 18 Q
In downtown --
19 A
In downtown Harrisburg.
20 Q
Do you remember anything in particular about that 21 interview?
22 A
No, I do not.
They asked me a bunchnofaquestions.
23 I came and I left.
24
()
Q You were glad to be gone?
25 A
I was glad to be gone.
85 1
0 Did you take any notes during that interview?
2 A
No, sir.
3 Q
Was it taped to your knowledge?
4 A
Not to my knowledge.
I don't believe it was taped.
5 Q
Do you have any record of any sort of that interview?
6 A
No, I do not.
7 Q
After that interview, did you have any other contact s 8
with Mr. Devine?
9 A
No.
To my recollection, he called me up at home 10 and wanted to ask me questions and I told him to -- I wasn't 11 going to talk to him and then Killian and Gephart called me 12 up and they said they recommended that I talk to him just to
(
13 answer his questions and so I went down and talked to him.
14 0
Killian and Gephart acted as your counsel in that 15 matter?
16 A
That's correct.
17 Q
Do you have any recollection of discussing your 18 relationship with George Kunder in that meeting?
19 A
No, I do not.
20 Q
Did Mr. Parks ever have a discussion with you concerning his removal as primary representative of site i
l operations on the test working group?
A No, I don't remember any discussions about that.
24
\\
MR. JOHNSON:
That's all I have.
Thank you very t
25 much.
86 3
MR. HICKEY:
I have a few questions just to clarify 2
a couple of matters.
3 BY MR. HICKEY:
4 Q
You previously were shown.-- if we are going to 5
discuss it, maybe it would be desirable to also mark this.
6 I think it's your copy, Mr. Johnson, the TWG meeting Minutes 7
of March 4, 1983, which you had signed indicating your 8
approval on the front, right, Mr. Warren?
9 A
Yes.
10 MR. HICKEY:
Can we mark this as Exhibit 3 to the l
11 Warren deposition?
12 (TWG Meeting Minutes were marked Warren Deposition 13 Exhibit No. 3.)
14 BY MR. HICKEY:
15 Q
The Minutes that are attached to that meeting talk 16 initially about the load test procedure.
Review those three 17 paragraphs under that first heading, would you, please?
18 A
Okay.
19 Q
That talks about the QA representative, Mr. Fornicol a, 20 advising that test working group that the QA comment on the 21 load test procedure were administrative, quote, administrative close quote, except for one comment.
What does that mean to you, what did it mean to you f~'
in March of 1983, when he describes the comments as administra 25 tive?
t
87 1
MR. JOHNSON:
I don't think it was established that r
i 2
he read this document.
Are you asking him when he heard those 3
comments?
You are asking him whether he heard those comments j
4 and based on that what it meant?
5 MR. HICKEY:
No, I am asking him what the word i
6 administrative as Mr. Fornicola uses it in these Minutes 7
meant to him.
8 THE WITNESS:
The word administrative taken in this 9
context would mean to me that there might have been missing 10 signaturen.
There might have been an exception to the procedu ce II and it wasn't signed off, resolution might not have been 12 written down.
It could have meant that the individual who l
I~h 13
(_/
was doing the test used blue ink versus blhck ink.
14 BY MR. HICKEY:
15 Q
Decause the administrative procedures celled for 16 black ink?
17 A
Called for black ink.
18 Q
How about the failure to initial cross-outs or 19 changes in the procedure, is that administrative?
20 A
That would be an administrative problem.
21 MR. JOHNSON:
I'm sorry, I didn't catch that.
22 BY MR. HICKEY:
23 0
I asked him if another kind of administrative 24
()
problem was the failure to initial cross-outs in the procedure 25 when you change a word or make a correction.
Administrative
88 1
procedure calls for you to initial and date that, does it not?
2 A
That's correct, it does.
3 O
The Minutes. reflect that all of the TWG members 4
were given a copy of the load test procedure for final review 5
and that comments were to be given to Mr. Radbill on Monday, 6
March 7th.
Did you submit any comments on the final load 7
test procedure?
e A
I don.'t remember if we did or not.
9 0
Was the practice at TWG in those days if any of the 10 members have further comments to submit that they would be 11 circulated to all members of the TWG?
12 A
I believe that was the practice, yes.
( >w So that if anyone in response to this direction at t:
13 1e Q
14 meeting had submitted comments, you would have expected to hava 15 received the comments?
16 A
Yes.
17 0
You have no recollection of receiving any comments?
18 A
No, I don't have a recollection, although I was showa 19 that one set of comments I think was to that procedure.
I 20 don't remember seeing that one either.
Q Are you talking about the signature page on the 22 procedure?
What are you referring to?
23 A
Comments by Rick Parks.
MR. JOHNSON:
The comment resolution sheet?
25 THE WITNESS:
That was' distributed to me, but I
1 89 1
don't remember it now.
A.Q 2
BY MR. HICKEY:
i 3
Q The one that was dated February 17th, Mr. Parks' 4
comments?
5 A
Was it?
I don't even remember it'now.
6 MR. JOHESON:
I think the point is he got a lot of 7
things, but he doesn't necessarily remember it.
It's this 8
one,we are talking about.
This is what, this comment 9
resolution 17th of February, '83?
l 1
10 THE WITNESS:
Right.
11 BY MR. HICKEY:
12 Q
That's what you were referring to?
()
13 A
Yes.
14 Q
You don't recall after the TWG meeting of March 4 15 getting further comments from anyone about the load test 16 procedure?
17 A
No, I do not.
Q The Minutes reflect that Mr. Parks, according to the Minutes, considered it inappropriate to provide separate 20 SOP's to cover prerequisite valve line-ups.
What does that 21 mean?
What are separate SOP's?
22 A
I would interpret separate to mean multiple.
23 Q
What is SOP?
24 A
Standard Operating Procedure or Special Operating 25 Procedure.
I
_.____._____________________.___._..__________._____w
i 90 1
Q What is he saying when he says it was inappropriate (3
(_)
2 to provide separate SOP's to cover prerequisite valve line-ups ?
3 What does that mean?
4 A
Evidently, there were a number of valve line-ups 5
that were involved in getting ready for this test and they 6
had separate procedures for different valve line-ups and I 7
guess Rick's point was, and I don't remember it now, but I 8
guess his point at the time was that you could cover that with 9
one document.
10 0
Instead of having multiple documents, you would have II it all on one document?
12 A
That's correct.
(}
13 Q
According to the Minutes, was TWG in agreement with 14 that view that one document could be used?
A Yes, this UWI 4370-3891-83-PC-0001.
O Do you recall any other commentstof'Mr. Parks at the 17 TWG meeting of March 4th regarding the load test procedure 18 beyond what is reflected in the paragraph we have just read?
19 A
No, sir.
l N
Q You were also shown by Mr. Johnson a quality 21 deficiency report No. CHK-011-83 and that's been marked already 22 as Warren Deposition Exhibit 1, and I am showing it to you 23 here.
24
()
If you will look at the text of the report, correct 25 me if I am wrong, but it appears that the first page under
91 1
Item 1B, description of deficiency, refers to the fact that the
/^%
l,)
2 administrative program for controlling work activities in s
3 Unit II was not complied with for the polar crane refurbish-4 ment.
5 Do you understand that administrative program in 6
that expression is used in the same manner in which you 7
described it in the Minutes of the TWG meeting?
8 A
No, I would say that they are slightly different.
9 Q
Can you explain the difference or describe it?
10 A
Well, when you talk about the administrative program,
11 you talk about all the Admin, procedures which governed the 12 operation of the unit and the way that the personnel are supposed to do business and the type of requirements I think 14 that when they say the administrative program was not complied 4
15 l
with are items like they took a procedure and didn't utilize i
4 16 the procedure, the entire procedure, where the administrative 17 deficiencies that they normally talk about when you are doing i
18 detailed review of procedures go down to like one line item 19 in a whole procedure and that -- the whole procedure was 20 followed, but the one line item was not complied with.
So I 21 might be wrong in my interpretation, but that's the way I woul d i
22 interpret it.
23 l
Q The examples that they list on this quality deficiency 24 l ()
report, Exhibit 1, relating to the polar crane refurbishment, 25 take a minute, if you haven't already, and read those three L__-______________________
92 1
examples that they give.
2 A
Okay.
3 0
Reading them, do you have some general recollection 4
that those were issues about ways in which there was 5
non-compliance with the administrative procedures governing 6
the polar crane refurbishment?
7 A
Could you rephrase the question?
8 Q
Sure.
9 Does this quality deficiency report recall to your 10 mind that there were these issues described in this report 11 about non-compliance with administrative procedures in the 12 polar crane refurbishment?
Do you remember these being issues ?
I'
(,)\\
13 Let me break it down:
For example, Item 2 says that 14 there were modifications to the crane that were not documented 15 on an ECM as required by AP 1043.
Do you remember that that f
was one of the issues of non-compliance with administrative 17 procedures?
18 A
I do.
19 Q
Do you recall whether there was some documentation 20 4
of the modifications on some other form besides an ECM?
21 A
I believe that Mike Radbill's group was documenting l
22 everything that they did as an attachment to this maintenance 23 job ticket, CA-258, so that they had some type of record of 24
()
what they had done with the polar crane.
25 Q
But, the deficiency or the non-compliance procedure
93 l
l 1
was that it was not documented on an ECM; is that correct?
2 A
That's correct.
3 Q
What is an ECM?
4 A
Engineering Change Memorandum.
l 5
0 That is a form that is required by AP 1043?
6 A
That's correct.
7 Q
Do you know whether the documentation that Mr.
8 Radbill's group had completed about these modifications 9
contained substantially the same information that was required 10 by AP 1043?
11 A
I don't know that.
12 Q
But, the deficiency that is outlined here is the
(}
13 failure to put it on the ECM form as the administrative 14 procedure required?
A That's correct.
16 Q
Am I right that these three examples on this 17 deficiency Item B about the refurbishment all relate to 18 non-compliance with AP 1043?
19 A
I'd say they do.
20 Q
On the next page, they continue the deficiency 21 section and talk about deficiencies related to the fact that 22 constructi6n and operational tests were performed on the crane 23 to test procedures, however, the administrative controls of 24
(
AP 1047 were not complied with, and then they give seven
'~
25 examples there.
The first one is, quote, the tests were not
94 1
included in the MTX.
Do you know what that means?
.(.
(
2 A
Master Test Index.
3 0
What is the Master Test Index?
4 A
That's the -- I can't remember as related to the 5
start-up program anymore.
I believe it was just an index 6
of the test that they were supposed to perform and it was 7
maintained by the start-up peaple, but I am not sure that that 8
is what they did.
9 i
0 But, as best you are able to recall today, the j
10 i
deficiency that is identified here is a failure to list these l
l 11 tests that were performed in this Master Test Index; is that 12 right, yes?
I"\\
13
(.)
A Yes.
14 Q
Item 2 says, scopes were not prepared.
What do you 15 understand that to mean?
16 A
That would be one section in the procedure which is 17 entitled scope and it lists the scope ofdthe document.
18 Q
What was wrong with the construction and operational 19 tests that were performed on the polar crane was the test 20 i
i procedures that were utilized did not have a scope section at 21 i
the beginning?
22 A
I believe that's what it was.
j 23 Q
Item 3 says that TP formats were not used.
What 4
24
\\)
does that mean?
25
)
A
- Test procedure. formats.
AP 1047 gave you a specified
95 i
l 1
format to utilize.
2 O
Format in the sense of paragraphs and sections and 3
how you set up the test procedure?
4 A
That's correct.
5 Q
Item 4 says, test status was not kept.
Do you know 6
what that means?
A No, I do not.
8 Q
Do you have any recollection today from the TWG 9-meeting whether that issue was discussed?
10 A
No, I do not.
11 Q
Item 5, test briefings were not conducted.
Do you 12 know what that means or refers to?
I'h 13
\\/
A These were briefings prior to start of testing that 14 the test personnel conducted so that everybody knew what they 15 were supposed to do, what their job functions would be during 16 the test.
17 Q
Do you know whether before the construction and 18 operational tests that were performed on the crane, people 19 were informed about what they were supposed to do during the 20 test?
21 A
I don't remember.
22 Q
Item 6 says, start-up and test engineering log was 23 not maintained.
Do you understand, what does that refer to?
24
,n(,)
A That's the lognbook kept by the test engineer.
Q What do you put in that log book?
96 1
A Usually what they put in is.the section of the 2
test procedure that they are following, any significant notes 3
that they might have.
4 Q
Do you know -- and that's a record of what happens 5
during the test, is it, or --
6 A
It's a record of what happens shift by shift on 7
the testing that is being performed.
8 Q
Do you know whether there were records kept of what was happening while these tests were performed in someplace 10 else than the start-up test engineering log?
11 A
No, I don't.
12 O
The deficiency that's identified is it was not logged f')s
-in the start-up and test engineering log and presumably 1047 13
(
14 required that to be done?
15 A
Right.
16 Q
Item 7 says a prerequisite list was not maintained.
17 What does that refer to?
18 A
I assume that there's a list of prerequisites.
19 Somewhere they must have documented what prerequisites they 20 had for doing the test.
21 Q
Prerequisites in what sense are you talking about?
22 A
Things that you have to do before you are ready 23 to do the test.
A valve line-up is typically a prerequisite.
24
)
Q They didn't have a list of what the prerequisites i
25 were for the test?
7_______
97 I-1 A
I assume that's what they mean there.
()
2 Q
Now, you reviewed and signed off on the polar crane 1
3 load test and Mr. Johnson showed you the signature page from 4
that.
5 MR. JOHNSON:
I will get it for you if you like.
6 BY MR. HICKEY:
7 0
I believe it had your signature, dated March 16, 8
Ron Warren, March 16, right?
9 A
Right.
10 0
He asked you about your signing that document and 11 as I understood your testimony, you said that you felt your 12 responsibility was to review it for the technical content
/~\\
13
()
and that you felt it was technically acceptable; is that what I4 you said in substance?
A That's what I said.
16 Q
What do you mean when you said your responsibility 17 was to review it for technical content?
18 A
The steps in the procedure were reviewed to -- were 19 reviewed by us to make sure that the way they were performing 20 the test, the sequence that they used, that they could 21 perform it in that manner.
22 Q
In a safe manner, you mean?
23 A
In a safe manner, that it could be performed.
If 24
(
we felt that it was an unsafe manner, then it was our 25 responsibility to flag that, because we couldn't perform the test then.
98 1
Q Were you also reviewing it to see that the test A
2 would sufficiently test the operation of the equipment, that 3
it would be effective to tell you that the equipment would 4
function properly?
5 A
Yes.
6 0
When you say you were reviewing it for technical 7
content, what are you excluding, what were you not reviewing 8
it for, if anything?
I am just trying to understand whether 9
your statement implies if you were looking at some things as 10 you reviewed it and not considering some other things.
11 A
No, we basically looked at the procedure for --
12 i
1 0
Let me ask you something specific:
Did you --
r 13 f.1,. JOHNSON:
You didn't let him finish.
14 BY MR. HICKEY:
15 Q
I thought you had finished, I'm sorry.
16 A
The way we reviewed procedures, if we were to write 17 a procedure, we would look -- what we considered a complete 18 procedure, we would write or hopefully the way we write 19 procedures is complete, so if we review a procedure, we review j
20 it in the same light and if the procedure -- it there were any 21 i
steps that we were aware of that would be omitted or that 22 precautions that maybe should have been taken that we were 23 aware of that aren't included in the procedure, then we would 24
()
have probably flagged them.
25 Q
But, for example, if the procedure was not formatted,
99 1
one of the examples that was listed in the quality deficiency
!^)
l (-)
2 report, if the procedure was not formatted in accordance with 3
the format spelled out in AP 1047, would you feel that your 4
review required you to disapprove the procedure because of 5
that?
6 A
No, I wouldn't have thought that.
It would now 7
under the present administrative program with the responsible 8
technical reviewer, but back then, I wouldn't have felt it 9
was our responsibility.
10 Q
But, did you have any qualms or compunctions about 11 signing off and approving for performance this test procedure 12 for the load test for the polar crane?
'"(h 13
/
A If I signed it, I didn't have any qualms or 14 compunctions against approving it.
15 0
You may have covered this in your answers to Mr.
16 Johnson.
He asked you a number of times about this occasion 17 when after a meeting, Mr. Thiesing asked you and Mr. Parks 18 to remain and had a brief discussion with you.
I recall you 19 testifying earlier that after that discussion with Mr. Thiesing, 20 you believed that you and Mr. Parks had returned together to 21 your offices, which were in a different building than where th e 22 meeting was held; is that right?
23 A
That's correct.
24
( j\\
Q Was the meeting in the administration building?
25 A
That's where it was.
l
100 1
Q Your offices were in the green building?
,x k,)
2 A
In the green building, which is several hundred feet 3
down the road.
4 Q
When you and Mr. Parks walked back to the green 5
building after having had this discussion with Mr. Thiesing, 6
did Mr. Parks indicate to you in any way that he was fearful 7
about being transferred or in some way treated improperly by 8
any part of management?
9 I
A I don't remember statements to that effect.
10 Q
Do you think that it's likely that you would if he 11 had made such statements?
l 12 MR. JOHNSON:
I object.
Youtare asking him to
('N 13
\\_)
speculate.
He already said he doesn't remember.
14 MR. HICKEY:
I think it's more than a speculation.
15 It reflects on whether that kind of statement would be an 16 unusual statement for him to hear from Mr. Parks.
17 MR. JOHNSON:
I don't know where that's going.
18 BY MR. HICKEY:
19 Q
If you can answer it, I'd like you to answer it, 20 Mr. Warren.
If you can't, just say so.
21 A
I don't think that -- I don't think I would have 22 attributed that to be a significant statement that I would --
23 that would have stayed in my mind over a number of years.
24
)
Q After you had this knowledge that the affidavit was 25 coming out from Mr. Parks and you were asked to have a meeting
101 h Mr. Barton.to discuss the references in the affidavit 1
wit
(
2 to the mystery man, and we have shown you and I am showing you 3
again Page 36 of Mr. Parks' affidavit, Mr. Johson was asking 4
you about two kinds of pumps.
The Parks affidavit refers on 5
Page 36 to the safety injection pumps.
Can you describe o
briefly what those pumps are and where they are located and 7
what their function is?
8 A
They are also referred to as the make-up pumps.
The re 9
are three of them in the auxiliary building on the 282 foot 10 elevation.
They supply make-up water to the reactor coolant 11 system.
12 MR. JOHNSON:
That's what the safety injection; pumps
(
13 are?
I'm sorry.
14 BY MR. HICKEY:
15 g
- yes, The high pressure safety injection pumps are those.
16 A
17 0
You said they supply, I'm sorry?
18 A
Water to the reactor coolant system, make-up water.
19 Q
You also referred to the reactor coolant pumps.
20 What are those and where are they?
A There are four of those pumps.
They are located in 21 22 the reactor building inside the D-ring and they circulate the 23 water through the core.
24 Q
Can you compare them in terms of size or capacity, 25 are they comparable in that regard?
102 1
A The reactor coolant pumps are much larger than the 2
make-up pumps.
3 0
Now, Mr. Parks in his affidavit not only referred 4
to Mr. Kunder as the mystery man who ordered the safety 5
injection pumps turned off, but he also said, quote, on 6
Page 36, "This mistake was responsible for a great portion of 7
the. damage.: fBy stopping the flow of coolant, this mistake 8
had prevented cooling of the core."
9 Did you understand when you read that that Mr. Parks 10 was stating that Mr. Kunder was responsible for a large portion 11 of the damage caused by the accident in 1979?
12 MR. JOHNSON:
Could I have a clarification, when are
/~N 13
(_)
you referring to?
14 BY MR. HICKEY:
15 Q
When you read it in 1983, when you read this 16 affidavit.
17 A
To tell you the truth, I don't know what my 18 subjective feeling was regarding what he wrote here, all I 19 know is thinking was he made a mistake in referring to the 20 wrong set of pumps.
21 Q
Read it today.
Does that paragraph not indicate 22 to you,those two sentences that I just read, that Mr. Parks 23 is stating that Mr. Kunder's mistake was responsible for a gre at 24
)
portion of the damage in the accident?
l 25 l
A Yes, I would say it does.
103 l
l 1
Q Do you have any reason to think you read it any
/"%
i 2
differently in 1983?
3 A
No.
4 Q
Did you believe in 1983, that that accusation was 5
valid that Mr. Parks had made about Mr. Kunder?
6 A
What accusation?
7 Q
That Mr. Kunder's mistake was responsible for a 8
great portion of the damage in the March, 1979 accident.
9 A
I don't believe I did, but I really don't remember 10 what my feelings were.
11 Q
Mr. Johnson asked you about an occasion when you 12 were interviewed by Mr. Parks'
/yer, Mr. Devine, as you said,
13 at the offices of your attorneys, Killian and Gephart, in 14 11arrisburg.
It has previously been produced in discovery 15 in this case a form, I'm showing it to you now, pre-printed 16 form or questionnaire with handwritten statements filled in on 17 it, and it appears to be a record of an interview of Ron 18 Warren, dated June 14, beginning at 4:20 with a series of 19 l
questions and handwritten answers written in.
This is my 20 copy here that I am showing you.
21 My question is whether that is your handwriting on this document?
23 A
No, it is not.
24 O
After you were interviewed by Dr. Devine, did he 25 show you any documentation or record that he had made during
104 l
l l
I the course of that meeting for your review?
2 A
I don't believe he did.
3 0
Before I showed you this document, had you seen it 4
before, this questionnaire?
5 A
Yes, sir.
6 Q
But, before I showed it to you?
7 A
Monday, no.
8 0
Let me see if this refreshes your recollection about 9
that interview in one specific regard.
The document has a 10 question as follows, these pages aren't numbered, but it's 11 about six pages in:
Question 6A, "In your view, why is 12 management really displeased about Rick's challenge to the i
O-13 polar test project?"
14 MR. JOHNSON:
Do you mind if I look over your 15 shoulder?
16 MR. HICKEY:
No, not at all.
17 BY MR. HICKEY:
18 O
That's the question that's on this pre-printed form 19 here:
"In your view, why is management really displeased abou t
20 Rick's challenge to the polar test project?"
The handwritten I
21 note that responds appears to be the response to that is, "Not 22 too happy when J.
B. called me up.
He said he felt it was a 23 shame that George ' dragged in the mud.'
I agreed."
24 j
Do you remember telling Mr. Devine when you were 25 interviewed at Killian and Gephart in substance that Mr. Barto l felt it was a shame that George Kunder had been dragged into
. _ _ _ _ _ =
105 1
the mud-by Mr. Parks' affidavit and that you agreed with that 2
v view?
A I don't remember making that statement.
4 0
Was that your feeling'at the time?
5 A'
.I think that would have been my feeling, yes.
6 Q
Mr. Johnson asked you about whether you would have 7
been able to work with Mr. Parks if he had returned to the 8
job site following hits press conference and the release of his 9
affidavit, and as I gof: yopr answer dc orn, you responded that -
10 you could have on a working relationship.
What do you mean 11 by that expression?
'i 12 5
A Over the yearj,1I have worked with people that I hy/
13 w/
have enjoyed working with and have become friends with and I 14
.I have.. worked with people 'that I don't enjoy working with'and 15
i w6dd 'never be friertts with them and I work with _ people that 16
~
I didn't like at first and then I changed my mind.- But, when t
37 I view my job or any job that I have ever done that the job 18 is most.tmportant'and that that's what the company is paying 4
19 me to do is to do a job, arid I try not to let my personal 20 prejudices oN inner feelings or preferences interfere with me 21 d I
dein9 the job.
Su17 person'i personality or his make-up
't 22 genehally isn't a major factor in my day-to-day work dealings.
Now, whether or not I could ever become friends with Rick 24 nd Parks again, I don't! think I equld.
I don-'t like being here,
\\
25 s..
i for ilstanca, and I attribute a lot of that to Rick Parks, but
'um
! h
=-
106 I
whether or.not that would affect my working with him, if he 2
came up and he was working for the company and I was working 3
for the company and we both had a job to do and it happened 4
that we had to' interface with each other, I don't think that that would be.a7 problem.
6 0
Would you have been confident in your ability to 7
trust Mr. Parks as you had these working relationships with 8
him?
9 A
Probably I wouldn't have a great deal of trust in 10 him, no.
11 O
I think at the beginning, you gave your -- in 12 response to Mr. Johnson's question -- strike that.
6 13
\\
From your contact with Mr. Parks during the time 14 that you worked with him at TMI II, do you believe Mr. Parks f.5 knew the difference between the reactor coolant pumps which 16 were located in the reactor building and the three safety 17 injection pumps that were located in the auxiliary building?
18 A
I believe he did.
He should have.
19 Q
Mr. Parks also said in his affidavit on Page 36, tha t 20 he believed -- I'm looking at the bottom of the page here, 21 that you knew that Mr. Kunder had been identified as the man 22 who shut down the safety injection pumps by Mr. Chwastyk or Mr 23 Smith, because you had been in discussions with Parks on that l
24
,f(
subject.
You see your name appears here three lines up from l
25 J
the bottom.
Is that statement accurate that you in discussions I
i
107 1
with Parks, or Chwastyk, or Smith said Kunder was the man who f~
t 2
shut down the safety injection pumps?
3 MR. JOHNSON:
Before you answer the question, could 4
you point to me where on this page I am supposed to be looking
?
5 MR. HICKEY:
It's about three lines up from the 6
bottom, where I indicated.
7 BY MR. HICKEY:
8 Q
Do'you have the question in mind?
8 A
I don't believe that statement is accurate.
10 MR. JOHNSON:
Which paragraph?
BY MR. HICKEY:
12 O
Were you in discussions like Mr. Parks described
)
in this affidavit?
14 A
I never remember any discussions such as that.
15 Q
Mr. Johnson asked you about when you first learned 16 about Mr. King's involvement with a job shop operation and you 17 said that you first heard the name Quiltec a few weeks before 18 I am not sure that's accurate, but sometime shortly before Mr.
19 Parks' affidavit came out.
Are you able to place the time 20 for us at all?
21 A
Anywhere from a couple days to a couple weeks.
It 22 was several weeks or more than a couple weeks after Larry had 23 been suspended.
24
()
Q Had you spent a good bit of time in your work duties 25 with Mr. King discussing -- let me just leave the question at that.
Had you spent much time with Mr. King in connection
108 1
with your work duties?
l 2
A Subs quent to Ed Gischel having a stroke, 1 spent 3
some time with Larry King.
Probably I communicated with him 4
at least once a day and probably several times a day.
5 Q
Did Larry King make reference in his discussions wita 6
you to his friend,-Ben Sloane?
7 A
He had made references to Ben Sloane.
8 Q
Did Mr. King ever indicate to you in any way that 9
he was connected with Mr. Sloane in a business relationship?
10 A
He did not.
II Q
When you first heard therQuiltec name, you heard it 12 from Mr. Parks, right?
A That's correct.
14 0
What were the circumstances under which you heard 15 the Quiltec name from Mr. Parks a few days before Mr. Parks' 16 affidavit came out?
17 A
To the best of my memory or recollection, he came 18 into my office and he was discussing Larry's termination and/o c 19 suspension and he believed that he had been associated with l
20 l
Quiltec and he used Quiltec by name and that was the first tim a 21 I ever heard that name.
22 Q
Your answer was a little ambiguous, at least as I 23 heard it.
He said he believed he had been associated with 24
()
Quiltec or --
25 A
Rick Parks believed that management thought that he
109 j.
I was associated with Quiltec.
2 MR. JOHNSON:
Who is he?
3 THE WITNESS:
That Rick Parks was associated with 4
Quiltec also.
5 BY MR. HICKEY:
6 Q
And Mr. Parks expressed some concern to you about this?
A Yes, and he stated that Rick Parks was not associated 9
with him.
That's my recollection, that Rick stated that he wa s 10 not associated with Quiltec.
11 Q
Did you know either Mr. Herlihy, Michael Herlihy 12 or Mr. Rekart, who had left TMI in the late 1982 time frame?
(~)
13
\\m/
A Yes, I knew them both.
14 Q
Did you have any understanding about where they went 15 when they left TMI?
16 A
No, I did not.
17 0
You didn't talk to either of them about their plans 18 when they were planning to leave?
19 A
I don't remember if I ever talked to Mike Herlihy 20 when he left.
I didn't know him as well or deal with him that 21 much.
But, I believe that Ted Rekart submitted his resignatio:1 l
22 to me.
He was in our department at the time and he_ told me j
23 where he was going and I know he didn't tell me he was going 24
()
with a firm named Quiltec, because I do know that I didn't 25 hear the name back then, and I believe he told me he was going l
l 1
somewhere in Texas.
. r~
2 Q
Let me put it in this fashion:
Did he tell you l
l 3
specifically that he was going to work at the Shorham Nuclear 4
Plant?
l 5
A No, he did not.
6 Q
I just have a couple more brief matters.
l 7
When Mr. Gischel wanted to communicate information 8
to the plant engineering people, did he have staff meetings 8
or how would he meet with -- I guess with two groups of people,
10 one with his plant engineering staff in general and two, with l
II the supervisory part of his plant engineering staff, which 12 would have included you and a few others?
}
3 A
He had both types of meetings.
Plant engineering 14 -
was a fairly small organization and so it wasn't very difficult 15 to get all the plant engineers in one room to have a staff 16 meeting.
So if he wanted to pass on information to the entire 17 group, it was just as easy to convene the entire group versus 18 have a meeting with two or three key people and then have them j
19 pass the information down.
20 Q
How large would the entire group of plant engineering 21 have been if he had convened it in March of
'83, approximately ?
22 A
In March of '83, probably about 15 people.
23 Q
Do you have any recollection about the time that Mr.
24 fs
(}
Parks went public on March 23rd, of Mr. Gischel telling you 25 that Mr. Kanga had stated that Mr. Parks was going to be
111 I
transferred and then gotten rid of quietly?
2 A
No, I don't remember that statement.
I don't 3
remember a meeting either that put out words to that effect.
4 Q
Mr. Johnson showed you a comment that you made when 5
you were interviewed by Mr. Stier about the readiness review 6
committee and your belief about the reason for its formation.
7 Do you know who set up the readiness review committee, who 8
appointed it or established it?
9 A
I think Bob Arnold did.
10 Q
Do you know when he did that?
11 A
No, I do not.
12 Q
Did you ever discuss with Mr. Arnold the reason for I'\\
13 -
establishing the readiness review committee?
14 A
No, I did not.
15 Q
Did anyone ever report to you Mr. Arnold's reasons 16 for establishing the readiness review committee?
17 A
I don't remember.
My recollection is that that 18 committee was formed to address all the outstanding issues 19 with the polar crane load testing and to provide upper manage-20 ment or senior management with assurances that the TMI II 21 project was ready to perform the load test.
22 O
I am just asking if you can remember what the basis for that understanding was, how you came to that under-24 standing, if you can remember something specifically that led 25 you to that understanding.
112 1
Al I think that was communicated to all of us when they (qj 2
made the announcement that there was going to be a readiness 3
review committee.
4 Q
So the document that appointed the readiness review 5
committee might reflect that?
6 A
I don't remember if it was ever a document.
I think 7
it was just hearsay that was passed on down the line.
8 0
You referred to a -- to two different views about 9
the classification of systems and equipment as important to 10 safety or ITS and I want to ask you just a question or two 11 about that.
12 If I understood you, your statement was that you believed that since there was a document defining or listing 14 which systems were classified as important to safety, that 15 should be determinative and there should not be an evaluation 16 of whether, in fact, a particular system or a particu3ar part 17 of a system was or was not important to safety; is that 18 accurate?
19 A
That's accurate, unless we had a document that 20 further broke down-.the systems into subsystems and addressed 21 each of them as important to safety or not important to 22 safety.
23 0
The benefit that you felt that view of yours offered 24
()
was that it made clear what systems were important to safety, 25 because you could simply look at the list; is that right?
T.
l 113 1
A That's correct.
(Q_/
2 Q
Do you understand that part of the reason for 3
classifying systems as important to safety or not important 4
to safety was to martial resources so that important to safety 5
systems could receive more attention and those that were not 6
important to safety would not be unnecessarily taking up 7
resources?
8 A
I have heard that view discussed and I don't 9
particularly agree with that view.
I think the arguing that 10 goes on after the fact, discussing whether or not a system 11 was important to safety or not important to safety more than 12 makes up to those resources that are saved on the front end.
r's (m)
Q Was the important to safety list that was in 14 existence in March of 1983, a current list or was it in need i
15 of updating, if you know?
16 i
A I believe it was in need of updating, 17 0
Was there a project underway to update the list 18 and obtain --
19 A
I believe there was.
20 Q
Is it the fact that the list did not accurately 21 reflect -- let me see how I am going to phrase this.
22 Do you know whether the list had been significantly 23 updated since the accident had occurred as of March, 1983?
24
()
A After the accident, Tech Functions, which is the 25 technical branch of the home office in Parsipanny, developed
114 1
a list and that was a significant departure to the list that f%
(_,)
2 we had before the accident, which really wasn't a list before l
3 the accident.
But, I don't believe that that list Tech 4
Functions developed was ever significantly updated before 5
1983.
6 Q
Your view, I take it, was not held by everyone on 7
the site about a better way of classifying things as important Eto safety or not important to safety; is that right?
9 A
No, it was not.
10 0
I want to direct you briefly to just one other part 11 of Mr. Parks' affidavit.
The part specifically is on Page 43, 12 but let me put you into context in which he addresses it.
O(,
On Page 41, Mr. Parks reports that on March 9, when he returne d
14 to work, he talked to Mr. Fornicola and studied a number of 15 memoranda or reviewed a number of memoranda and then he starts 16 talking about the memoranda.
I want to direct you specifically /
17 to one which appears on Page 43, an ECM S-1017, installation 18 of temporary power for the polar crane.
Mr. Parks' affidavit 19 reflects that this ECM which installed two/zero w.lding 20 cable instead of two/zero power cable had been the subject of 21 discussions that he, Parks, had with a number of people, 22 including Jack Lauton of plant engineering.
23 j
Did you know Mr. Lauton?
24
()
A Yes, I do.
25 Q
Did he work under you in plant engineering in March i
__ -__ ________ _______________=_ - _ __ _____________
115 1
of 1983?
2 A
Yes, he did.
3 0
What was his background or area of work?
4 A
He's a degreed electrical engineer from Penn State 5
and he was my electrical engineer.
6 Q
The issue that Mr. Parks is referring to here relates 7
to the propriety of using welding cable instead of power cable 8
for a transmission of electrical current to the polar crane; 9
is that right?
A That's the way I understand it.
11 Q
Did you have occasion to discuss with Mr. Parks 12 or with Mr. Lauton the substitution of welding cable for power I'\\
13
's,)
cable?
14 A
I believe I discussed it with both of them.
15 Q
Did you have any particular expertise or knowledge 16 about the propriety of using welding cable instead of power 17 cable for this electrical purpose?
18 A
No.
My background is in mechanical engineering, 19 so I defer to Jack Lauton.
20 Q
Did Mr. Parks, to your knowledge, have any particula c 21 expertise in the propriety of using welding cable instead of 22 power cable?
23 A
Not that I am aware of.
24 4
Q Mr. Parks isn't a degreed engineer, is he?
25 A
I don't believe he is.
r 116 l
I
('.
Q What did Mr. Lauton say about the propriety of using k j) 2 welding cable instead of power cable for the polar crane?
3 A
He said the cable were equivalent.
4 O
Mr. Parks said, "We all agreed," referting to Mr.
5 Lauton and others, "We all agreed that we didn't like it 6
because it was unsafe and poor engineering practice."
7 Is that an accurate statement of Mr. Lauton's views 8
as Mr. Lauton stated them to you?
9 A
As I recall it, Jack didn't say it was unsafe and 10 he said it wasn't standard engineering practice, not poor 11 engineering practice.
12 MR. HICKEY:
I don't have any more questions, Mr.
13
,\\~-
Warren.
Thank you.
14 MR. JOHNSON:
I neglected to bring my copy of the 15 Devine interview.
I was wondering if you had any objection 16 to me looking at your copy?
17 MR. HICKEY:
Off the record.
18 (Discussion held off the record.)
19 MR. HICKEY:
On the record.
You can look at them, 20 Mr. Johnson.
21 MR. JOHNSON:
Thank you.
22 BY MR. JOHNSON:
23 Q
During the interview, were you asked questions 24 concerning your interaction with Mr. Kunder, the PORC chairman 25 l
during the interview with Mr. Devine?
117 1
A I assume I was.
It's indicated here.
2 Q
I was wondering if you could explain to me the 3
writing that's here.
The question indicates here, "Have you 4
personally experienced any frustration in getting on with your 5
job because of delays in respect of PORC7" Then it says, "If 6
yes, in what way?"
This is all printed information on this 7
form.
Then there's handwriting and it's in shorthand.
That' 8
says not equal and I would suggest perhaps that means not 9
because, the not equal sign is not, then B over C is because 10 of delays, I disagreed, but not expect to, and then I can't 11 really make out what this is.
12 In your reading this, would you try to decipher
("\\
13
\\_)
what you were saying here, if you just read this language here 14 including the arrow that continues at the bottom of the page?
15 First of all, read it and tell me whether you remember being l
16 asked the question about the subject of frustrations with PORC 17 and then what your answer was.
18 First, were you indeed asked the questions about 19 your recollection about your experience with dealing with PORC
?
20 A
I'm sure I was.
I have been asked that question a 21 l
number of times.
I believe what this had to do with was that l
22 George wrote a letter to Larry King and -- about -- regarding 23 a procedure that we wrote or something that plant engineering 24
()
was doing that was late.
It might have been a response to 25 one of his action items that we hadn't responded to inuwhat he
118 1
felt was a timely manner.
He went to Larry King first and
)
2 then Larry came down and asked me why we were late and what I
-I 3
objected to war. chat I thought it would have been more 4
appropriate had he asked me first why werwere late before
~
5 going to Larry.
If I couldn't satisfy his concern, then he 6
certainly was within his rights to go to Larry and escalate 7
his concern.
8 Q
I see.
9 A
I think that's --
10 0
That was the subject of all of this?
11 A
Yes.
1 12 Q
Thank you.
(~)\\
13 Under Item 6, having to do with a meeting apparently u
14 the form says with respect to a meeting called by Mr. Arnold 15 on March 28, 1983, regarding the New York Times article.
It 16 appears to me that you were asked a question about that I
meeting.
Were you indeed asked a question about that meeting?
18 A
I don't remember.
I'm sorry.
I can't remember.
I9 Q
It says, I believe, in somewhat of a scrawl here, 20 "I attended one with all of SO staff after work, W.K.
He did 21 comment that L.K.,"' Larry King, I presume, "was dismissed,"
I assume that's because of C.I.
MR. HICKEY:
Conflict of interest.
24
('~\\
BY MR. JOHNSON:
d 25 Q
Round table discussion --
1 l"
l
119 MR. HICKEY:
Felt.
7-BY MR. JOHNSON:
3 0
-- felt distrust equals detrimental, is that what 4
that --
i 5
A Yes.
6 0
Was that your answer to Mr. Devine concerning only 7
Mr. King with respect --
8 MR. HICKEY:
Do you remember making that answer, 9
first of all?
10 BY MR. JOHNSON:
11 Q
Does that bring to mind an answer that you gave to 12 Mr. Devine?
('\\
13 s_)
A That seems to be the meeting I attended after 14 Rick submitted his affidavit and I would think that was probably 15 what was discussed, yes.
16 MR. HICKEY:
I think he's asking you about the 17 meeting with Mr. Devine.
Do you remember making this answer 18 to Mr. Devine?
19 THE WITNESS:
I don't remember making the statement.
j 20 BY MR. JOHNSON:
21 Q
In any event, the statement appears to address Larry 22 King and not Mr. Parks?
23 A
Yes.
24
)
Q This talks about the Stier interview.
In respect 25 to the Stier's interview, it says, "I believe you spoke to him
120 1
with a court reporter present," and then the jotting says,
. f m.
(s 2
1 CTREP,S, and LL or CC later.
Do you know what that means?
3 A
No, I don't.
4 Q
Could it mean court reporter, Stier and CC later?
5 Does looking at this material here that's written 6
down here refresh your recollection with the number of inter-7 views you had with Mr. Stier or Mr. Frech?
I don't believe 8
you mentioned Mr. Frech's name before.
I asked you about two 9
interviews that I have copies of the depositions, one with 10 Mr. Malita, I believe and the other was with Mr. Stier.
Does 11 this indicate to you that maybe there was another time that 12 you were deposed or met with somebody working with Mr. Stier or with Mr. Stier?
14 A
There was one time that I met with one of Mr. Stier' s
15 associates and there was no court reporter present and then 10 two times that I met with him with a court reporter present.
17 Q
I had asked you, I think, whether there was others 18 and perhaps it wasn't clear I was looking for another answer, 19 additional information.
20 What was the subject of that unreported interview?
21 A
They asked a lot of background, questions, like how I
22 long I had worked with Larry King, what was my relationship 23 with Larry King, what was -- how did I feel about him, that 24
()
type of thing.
25 0
Was that before the reported interview?
121 1
A That's right.
In' fact, that one statement in the 2
one transcript where I said I provided you those notes, it 3
might have been at this interview.
4 O
So at the interview before the reported interview, 5
did that occur shortly before the reported interview?
6 A
To the best of my recollection, they were like a 7
month apart or something.
8 Q
So that Rick Parks was a subject of that unreported 9
interview?
10 i
A He may have been, yes.
11 MR. JOHNSON:
I presume, may I just ask Mr. Hickey, 12 I presume that you looked for all the documents, because 1 did I\\
13
)
request you to do so.
Is there any reason, to your knowledge, 14 why this one might not have been produced?
15 MR. HICKEY:
I don't know what request you are 16 l
talking about.
17 MR. JOHNSON:
I asked that the documents pertinent 18 to the investigation of Mr. Parks, and I forget which document 19 request that was, the investigation of Mr. Parks by Bechtel 20 or GPU be produced, and this appears to be -- there appears 21 to have been an interview.
I don't know that a document 22 recorded it, but I presume there was some kind of record kept, 23 since you supplied me with that kind of document for other 24
)
people.
25 MR. HICKEY:
If we had a document that reflected an
1 122 l'
interview done by Mr. Stier's associates about Mr. Parks,
]
/"T l
(_/.
2 it would have been produced.
I don't believe I have ever seen 3
a document that reflects Mr. Frech's notes of an interview 4
of Mr. Warren.
5 I can say it stronger than that.
I have never seen 6
a document by Mr. Frech' reflecting notes of Mr. Warren.
7 BY MR. JOHNSON:
8 0
Did Mr. Frech take notes?
9 A
I believe he did.
10 0
Were any subjects covered in that discussion that 11 weren't covered in your recorded reported interview that 12 followed it?
I\\
13
\\)
A I don't remember.
That's a real long time ago 14 and I really don't remember.
I remember a lot of background 15 information that was covered in there that wasn't covered in 16 the recorded interview.
17 Q
Do you remember there being any substantial differen :e 18 between -- aside from the background information, between the 19 two interviews?
20 A
No, I don't remember.
21 Q
That's fair enough.
It's a long time ago.
22 It appears that the subject -- it says discussed all 23 points where I was. mentioned, plus E. G.
I assume E. G.
is 24 l
Ed Gischel.
So I assume, tell me if I am right, that when it 25 says with Frech I discussed all points where I was mentioned,
123 I
I assume he's referring to points where you were mentioned in
/~h j
kl the Parks affidavit.
Do you think that's correct?
3 A
I think that would be a fair assumption.
4 Q
We have attempted to cover those things today.
5 Do you know what this means? :On the attachment 6
page, it says, "Ron Warren," it's-underlined, and then it 7
says, "RP's prior checking."
Do you know what that's about?
8 A
No, I don't.
l 9
Q What about this one, EGS period, where GK avoided, 10 perhaps that's controversy, avoid maybe difficult dscisions 11 that challenge management?
What does EGS stand for?
12 MR. HICKEY:
Remember, this is not something that
(~h 13
\\/
he wrote.
~
14 BY MR. JOHNSON:
15 Q
Right.
Does that bring to mind some statement that j
16 you made concerning George Kunder in the interview with Mr.
17 Devine?
18 A
They might have asked me that question.
I don't 19 remember them asking snything about that.
20 0
This is the subject that was covered in the Parks 21 affidavit?
l i
22 A
Yes.
23 j
Q You just don't remember what you said?
l 24
)
A No, I don't remember.
25 Q
I think what's happening here, he had perhaps written
124 i
1 down two topics to discuss and then wrote the responses down rO l_j 2
here, because it says Rick's prior checking and then it has 3
something that follows and it appears that you didn't under-4 stand what he was talking about?
5 A
Uh-huh.
6 Q
RCP, that's reactor coolant pump?
7 A
Reactor coolant pump.
8 Q
It appears that you were asked about the reactor 9
pump turnoff perhaps during the accident and it seems as 10 though he attributed to you a statement that George Kunder did 11 it because of something, I can't read it, procedure called 12 for it when vibration reached certain level?
, )
A That's my understanding.
Nm 14 Q
Of what you said?
15 A
Of why the reactor coolant pumps were secured during 16 the accident.
17 Q
Is this st:itement attributable to you?
18 A
It could have been, because that's who I understood 19 ordered them secured.
20 Q
Next point is does not recoliect a meeting, I believe?
21 A
I don't recall what that is.
22 O
When you were being asked about the QDR and the 23 statements in there and also the -- by Mr. Hickey and also the 24
)
discussion of the Minutes of the March 4th TWG meeting, you 25 were asked questions about administrative procedures and i
125 1
non-compliance with administrative procedures.
Were you
/ )
2 N/
implying in your answers that compliance with administrative 3
procedures is never at safety significance?
4 A
No, I was not implying that in my answers.
5 Q
Would it be a fair statement to say that violations 6
of administrative procedures have varying safety significance, 7
depending on the procedure that's not followed and the 8
circumstances?
9 A
That would be safe to assume, yes.
10 MR. HICKEY:
You said varying?
11 BY MR. JOHNSON:
12 Q
VaryiAg circumstances.
13
\\
When you defined or described what the high pressure 14 injection pump as being the make-up pumps, do the high pressur a 15 injection pumps spray water onto the core?
Is that how they 16 work?
17 A
No.
18 Q
How do they work?
What is the mechanism of the 19 cooling that's provided?
20 A
Well, they take cooler water and they inject it into 21 l
I 22 Q
I see, just through a separate --
23 A
Through a separate nozzle.
24
()
Q Somewhere along the line, I got the impression that 25 it worked by spraying water over the whole thing.
126 1
A No.
/~S
(_)
2 Q
You made a statement in response to Mr. Hickey 3
concerning your approval on this document.
We didn't mark 4
it.
It's the Revision 3 of the load test for the polar crane, 5
that you signed on March 16th, 1983.
6 A
Uh-huh.
7 Q
You said with respect to a question about whether 8
you were excluding other things when you meant -- you said I
9 that it was technically adequate in some former question I 10 guess answered to me, that you weren't necessarily excluding i
anything, you just looked at it and that was the way you 12 characterized the basis of your review,as a technical review.
[~h 13
\\)
I was a little confused by your answer.
I just want 14 to try to clarify.
15 You made a statement about back then, the administra -
16 tive aspects were okayed and something about administrative 17 review not being necessary and then something changed it seeme d 18 like that you implied that there was a change, and I was i
19 wondering what you were referring to?
20 A
I know what you are talking about.
We generally 21 looked at the way systems and components fitted together, i
22 how they were supposed to operate.
We deal a lot with 23 tech manuals for equipment and we didn't probably give as much 24 7,s i,
)
emphasis back then on administrative details as we should have.
25 But, we have also received a number of citations and even in 1
127 1
our own organization, we get written up quite a bit about
[n,I 2
falling down administratively on the job and so our present 3
procedure program has a requirement that every document or 4
procedure be reviewed by a responsible technical reviewer who 5
reviews the document technically, but we also had instruction 6
that it's not sufficient just to review it technically, it's 1
7 also a requirement that we review everything administratively, 8
and so it's much more emphasized now than it was back during 9
that time frame.
10 0
Thank you.
11 Do you recall when that change was implemented or 12 the instructions changed?
<s 13
( )
A I don't recall.
I4 Q
Do you recall the circumstances surrounding it?
15 A
I don't recall those either.
16 Q
You don't recall whether it was in relation to 17 the questions that arose in the context of the TWG review of 18 the administrative procedures on the polar crane?
19 A
No, I don't recall that.
20 MR. JOHNSON:
I thank you very much and I think 21 that conludes the deposition.
22 (Whereupon the deposition was concluded at 1:33 p.m.
)
23 24
^'
25
128 1
CERTIFICATE
,m,
(_)
2 I,
Holly G.
Rhodes, the officer before whom the 3
deposition of RONALD P. WARREN, SR., was taken, do hereby 4
certify that RONALD P.
WARREN,SR.,
the witness whose testimony 5
appears in the foregoing deposition, was duly sworn by me on 6
February 11, 1987, and that the transcribed deposition of said 7
witness is a true record of the testimony given by him; that 8
the proceedings are here recorded fully and accurately to the 9
best of my ability;;that I am neither attorney nor counsel for,
10 nor related to any of the parties to the action in which this 11 deposition was taken, and further that I am not a relative of 12 any attorney or counsel employed by the parties hereto, or I)
13
'N s financially interested in this action.
14 O
{,
15 Holl'y' G.
odes, Reporter-Notary Public
~
16 17 Notary Public in and for the Common-wealth of Pennsylvania.
18 My Commission expires January 14, 1988.
19 20 21 22 23 24 t'~N
'N 25
tv /]rtit< W D 0 % roioe u CW
/
i-TAOM:
OQA Mtntgsr Date:
3/8/83 N.u i5 l
l h TO:
J.W. Thiesing. Manaler Recovery Pro gams l
.w)
Subject:
QDR No.:
CHK-011-83 Tile No.:
TF-011-83
]
The attached QDR has been evaluated by OQA and found potentially reportable.
Please review the QDR and take action you consider necessary to inform Regulatory.
Agencies, Upper Management and GRC/PORC Committee Chairmen.
You are requested to furnish written acknowledgement of the receipt of this notification. Please provide copy of completed evaluation report to OQA Manager for placemnt in QDR file The attached QDR is forwarded for corrective action.
Please arrange for the P'
completion of Section 3 of the QDR, and provide a date by which corrective action will be completed.
Return the QDR, with Section 3 completed, to the OQA Manager.
You are requested to furnish wtitten acknowledgement of the receipt of this transmittal.
ror your information.
The attached QDR and supporting documents are forwarded for your retention as QA Records and are to be retained for the life of Unit I/II. You are requested to i
furnish written acknowledgement of the receipt of this transmittal.
Al gs Examination of our records indicates that this QDR corrective action is overdue.
()
Please provide a revised completion date and interim status report to the OQA Manager for approval.
~
Other/ Additional:
p1...,
r.nnna en ch, mecark.a nnn h, inv41 n son, A blank " Pare 2" in attached for vour re=nnn=a.
Aten n1....
=<en anA return thia tr nemi tral fnre en n. Nov-Tv1 v 9 c; 7
,,nn, 4,,1 c thie renort.
Th nk vnu_
CC:
( ) Chairman PORC
( ) Chairman GRC
( ) QA Design and Procurement Manager (Site Supvr) ( ) Operations QA Manager
( ) QA Manufacturing Assurance Manager
(NI Manager QA Modifications / Operations
(>Q Unit Manager I/II
( ) Dir. Matl. Mgmt. Systems and Purchasing
( ) Supvr. Licensing
( ) Others r--
Receipt Acknowledgement Required Yes.,_.
No 'a If receipt acknowledgement is required, sign the following statement and return this form to the OQA Manager.
The receipt of Trom:
is hereby acknowledged.
g ODR No.
5 Signed:
DN001118
.g.
]-
Quality Deficisney Report (QDR)
<1
. g 1.
Description of Deficiencies v
r*
a.
Completed by laitiator:
t i
Unit -
1 initiator; J.F. Marsden U-2 Proi.0A Ent.0A M/0 3/8/83 0900; owne worsecs.en om m Requirement (s):
l
" Measures shall be establish'ed'to control and coordinate 'the annroval and
~
he hie 2 Weenverv OA Plan. Pnem 40. Parmeranh 1.17 memene in nare_
inanance of instructions. nrocedures and drawinen includine chaneen. which ermeerike all Tonavenn e to safsev meriviriam."
The fini e 2 Weenverv OA Plan. Pnee 79. Parmersnh 6_11_1_1 memeee in l
l nart. "Recoverv. maintenance. or inodification of eenimnant and defueline shall I
be orenlanned and nerformed in meenrdance with vrieeen,rneedurma. instructions or drawinee meernerimee en the e4resmaennema which ennfann en annliemble enden b.
Deficiency:
(continued)
The Administrative Proeram for controlling work activities in* Unit 2 ma no e enenl i ed wi th f ar che Polar Crans Refurhiehamne.
F1mmnlem are na follows:
11 A mainemn nem 4nh ed et m e - r'A 7tA; um. namA en enen over the Pniar crane to enn-cence4nn
%. e.
men an nenw4mfans 4n ehm N4 e 9 nene=Anese Anf4n4ne i
'4eme.
snw meeknA. fne en en 4 mm, ne man 4n-mne en ennmecurrinn anA eka nume nubmeonent eurn haelt to onermeinna.
- 2) Mad 4fiemeinne were nerformeA en the ermes_ where now femma were added I
av neiefnm1 man 4nmane uma venimesA with femma di f feran e than the ne4einal a m. 4 e.,
e m _4.mma., e. ana eh.
.na 4,4 em e 4_.
.m,.m
_e a,,e,,mmn e na,,,,
m,,
Fr*W ma cann4emA kw A9 i nA 't 5
em'ema_ ie'vam noe elene if h aien Ene4 neerine van aware of the
'n In an==
mnA4fiemeinne. in nehave N a4en F_neinmarine kmA minehnrived the chanoe vim
.l
- r.n a,-
(continued) l PRD CARRY 'IO OQA MANAGER (CRETE EITIA'ED), QA EGrx.trIU }WM (0::ms.
i mTIATEM. OR S*rDT SUPERVISOR 03 LMGT/tEEKEND 1
!2.
Quality Evaluation Yes Na i
vos u.
- ~ *.. ". * *
- 1..ce:nnt := Sriety:
/
Potential 10CFR 50
- 8* :
A' *UNA
[
0%
?: s~.dal 1==
~
Potential 10CFR 20 Fc:::. lat
- OCFR 73
_ __/
Potential 10CFM 21 l
I W7 Evaluated By:
A M MMLL 644 Medor8 AL g/fhy g,,c w
n OQA Manager /
[
QA Eng. Mgr. Concurtunce:
L hg g
/
Ol e!%
If evaluated to be potentially reportable notify Unit Director or Duty Supt. and send copy of QDR to Licensing l
}
Date/ Time Unit Director Notified:
w/A Licensing Notified Yes C No [
M D$001119 c.i..
e Parties responsible for correctrve action:
J.W. Thiamine. Manneer Recovery Proer===
l
{g 1
W.
Recuired response Date:
j g
)
C3 Nc.
3 Ii 130 days or less from transmittal datel d
in j
&Tt&CMutNt t
- M U fi O*I " " !
ACCCC3*s L
Rsquirem:nt Section continusd:
'l
'@)
l
'yf-standards, specifications, and criteria.
l The Unit 2 Recovery QA Plan, Page 81, Paragraph 6.11.1.7 states, " Proposed modifications shall be reviewed, approved and controlled in accordance with the applicable requirements of the License and Technical Specifications and procedures governing the design, procurement, construction, testing and insp ection. Modifications to structures, systems and components Important to Safety shall be reviewed and accepted in accordance with the requirements i
of this Plan.
Deficiency Section continued:
j Construction and operational tests were performed on the crane to test
[
procedures, however; the arkinistrative controls of AP 1047,"Startup and Test Manual" were not complied with. N =ples are as follows:
i 1)
The tests were not included in the MII
~
2)
Scopes were not prepared
^
3)
TP formats were not used
~
- 4) Test status was not kept g
- (
5)
Test briefings were not conducted
{
6)
Start Up & Test Engineering log was not maintained
- 7) A prerequisite list was not maintained All refurbishment and testing activities on the Polar Crane were performed to Bechtel Work Packages. This document is defined in a Recovery Ops. internal procedure that has not been approved by any other organization at TMI-2 for performing work.
Specific problems identified in associated work packages will be resolved in the resolution of the individual work packages.
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In the future hti sedifications and modifications related ' testing T
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In mktism, all Recovery Programs person-
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nel responsiW.e to authortze: work activities will be trained in, the Ads:inistrative unntrolzy Minuted in AP 1043 and AP 1047. ',,
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and implomat al. >nts except' for modifications.
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All Recovery Progras procedures vill be typ:topriately imp:lem3ted
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At the initiation of the polar crane inspection and refurbistament */Nktsm, maintenance job ticket CA258 was issued (coff"'IEE"w. hec).
Inis job tic k.e t requedeo maintene.nce modification, and refurbishne.ut ol~ETd7.. alar crane as caenM &cesaT.4 wann turnover to plant operations to be a;ctmpanied,by proper documentation ryarding ir.nection, re-ls
d furbishment, modificationUarft'EE"c"Et utilized to place the crane back ira service tor
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head lift.
This job tiEGil~was unditiitic'3ad by GFUN and Bechtel[ at that time,7.o have CON Q UE ON ang t.jhtn recusred is prevent rt:urmeca) j Sl cns. ve c.ioru
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.y,11. modifications _ and modifications related tating will be perfor:ned t
un$er the controla established in LP 1043 and AP.104I respectively.
In addition, all Recovery ProgramL~)Isrsonnel responsible to authorize work act Dicles will be ts:
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Mhg_Adm1Distratjyt. Controls delineated in AP 1043 qp AP 109,g
,2.,,, f,JMecevery Program procedures required to satisf7 J,h_elequirements of the TMI-2 1Mgge. technical specifications. recovery operatigna raggor the recovery QA Plan td1.'!_be appropriately implemented by the Unit 2 Procedur..
- 3. The Unit Work Instruction vill be utilized chen required.e Pro.gr.am by pr.ocedure for al.L Rec.overy Programs work activities.
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?!CTE: M'TE.R CCMP:.rTION O? TM!S SEC"."1CN nETUEN THE COR TO J'-!! f C i
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ATTACEMENT 1 f[']3.
ACTION (Continued)
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CAUSE:
administratively severed the polar crane from the plant and to have placed it in a "curned back to construction" condition for refurbishment and testing.
This allowed engineering direction and decision making to flow in a more streamlined fashion since many required refurbishment steps could not be defined until after inspections and tests were performed. Later review of the TMI-2 administrative procedural requirements has determined that no i
such "turnback" is provided for. Under these conditions, all modifications i
to the crane would have to have been implemented via S-ECM's, and testing would have to have contemplated not only the substantive requirements of AP-1043 and AP-1047 (which are being met) but also the format and sequence requirements contained therein.
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DN001124
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OneGMATom-SUPERVISOR-SUPERVISOR OF MAINTENANCE-MAINTENANCE FOREMAN-Joe PanFonasER-MAINTENANCE FOREMAN-SUPERYtSOR OF MAINTENANCE
WALIMvV Oepp,rinem y w 1
,r, Warren March 23, 1983
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Re:
Parks' Affidavit Ron remembers one instance where there was a difference of opinion between Marshall, Brill, Warren and Kunder in the presence of Parks.
It involved a Unit Work Instruction that was prepared by one of Warren's engineers.
Discussion was over Kunder's comments on the UWI and the type of paper, i.e.,
procedure that should be used to do the job.
Warren responded to Kunder's comments via memo.
Gischel got involved, over-
. ruled previous agreements and decided that an ECM would be prepared to reflect actual work performed; essentially agreeing with what Kunder desired in his discussions with Warren.
Warren feels that Parks was present during some of these dis-cussions.
Warren doesn't remember any reference to " mystery man"
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until today.
Warren does not remember being party to or in the presence of any discussion re Kunder and Safety Injection pumps as mentioned on Page 36 of the subject affidavit.
Warren remembers another recent involvement w/Kunder.
King was aware of this instance.
Kunder wrote a memo to King on Plant Engineering not meeting commitments to PORC.
Warren and Kunder discussed this issue in presence of King and resolved the issue in that Plant Engineering (Warren) and Kunder agreed to appropriate resolution of the outstanding commitments.
The reason Warren brings up this last instance is that he be-lieves Parks walked in and overheard at least part of the discussion.
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a./o/57 Inter-Office Memorandum k-4345-83-ooos
[r 0 1 Nuclear Mar m. '983 TdG Meeting Minutes of s e jt u March 4,1983 To D. Buchanan Locanon Administration Building G. Clements J. Fornicola R. Gallagher J. Marsden R. Parks
- M. Raabill J. Thiesing D. Wal ker R. Warren Attachea are the minutes of the TWG reetir.g held on March 4,1983 to
' discuss Polar Crane issues.
1 4-23
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E. J, Kitler Startup & Test Manager 4/
Unit II ff W 4
$- Y-P.3 Plarft TWG Representative 3 $63 Iq0O).ht !pu I
Plant Engineering TWG Representative Qf0 3~y-83 Site Engi eeringeTWG Representative 0
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3-7-13 a
G QA Mod / ops TWG Representative DRB/DDW/jaa Attachment O
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TWG HEETING MINUTES A TWG meeting was held on March 4,1983.
The following persons were present:
TWG Dwight Walker (SU&T)
I Rick Parks (Plant Ops)
John Fornicola (0A)
Ron Warren (Plant Engr. )
Rich Gallagher (.SE)
GUESTS Gordon Ciements--@0RC)
Mike Redbill (PLTG)
Dave Buchanan (SE)
Joe Marscen (QA)
The meeting was held to discuss the following polar crane issues:
1.
Load Test Procedure status e.
2.
Review of all data given to QA/QC 3.
Results of No-Load Test 1
Load Test Procedure John Fornicola stated that QA had coments on the load test procedure.
All but one of the coments were administrative.
vided to group members when issued.
Coments will be pro-All TWG members were given a copy of the load test procedure for final review.
Coments are to be given to Mike Radbill on Monday, March 7 Rick Parks considered it was inappropriate to provide separate SOP's to cover prerequisite valve lineups.
It was agreed by WG that lineups could be included on UWI 4370-3891-83-PC-0001 cover sheet.
2.
Results of 0A/0C Audit of Polar Crane Task Groues Documentatier. of Work on Crane Joe Marsden stated that all deficiencies would be covered with one ODP.
He noted that many of the modifications were made without ECM's.
Back-fits could, however, be accornodated with engineered drawings instead of ECM's.
He noted the following specific modifications made; not in accor:-
ante with AP-1043:
1.
Trolley power and control bypass syster 2.
Insta11atior; of 200 amo fuses in main disconne:: i n c a : o f c:'. a r crane (vi:e 300 amps) 3.
New pendent station and fes:00r :a::s
I.
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TWG Meeting Minutes Page 2 4
Installation of two mounting brackets for jib crane on trolley 5
Installation of temporary air supply on crane.
The QDR will be submitted to Jim Thiesing.
had been discussed with Design Engineering. It was noted that these items missing signoffs on UWI's and Work Packages.Other def
, and It was noted by John Fornicola that the no-load test sho.uld_.have been re
- vjewed by TWG-but was not.
1 3.
No-Load Test l
I John Fornicola stated that all QA comments were administra Rick Parks expressed concern that in the no-load test procedure, Steps 8 92, 220, 228, 320, and 328, it is not clear whether the limit switches functioned.
Mike Radbill agreed to provide written clarification.
It was agreed that the following open items of UWI 4374-3891-83-PC-0002 would be resolved piror to the load test:
1.
Upper geared limit switch needs verification of operability.
2.
Trolley limit switches need verification of operability.
3.
1.ubrication of main hoist gears on trolley.
- 4. l Additional Discussion.
Mike Radbill noted that P.C.T.G. performed adjustment and verification of proper operation of the upper rotary type geared limit switch.
This was performed via an approved IT4I.
viewed and signed off by TWG members.It was agreed that it should have been re-Startup Problem Report to address this. Mike Radbill will initiate a Rick Parks questioned whether the pelar crane hook had been used to li'-
any loads.
hook had not been used to lift any icads. Mike Radbill stated that, to t John Fornicola noted that no testin; has beer. listed en the v.T X.
It was agreed that all further testing would be listet.
In response to concerns frc-Rick Fa eks, i wa s a;*eet t.at ~k'G is nc e.
quired to approve lifts uting the #ive :
.;is; atta:ned c the ociar crane main hook.
Mike Radbill noted that Re::very 0:s was : ire::e: :;. Le si gt Enginee-i ;
to insta11 dumy fuses vice 200 a:; 'uses ir ::ie crane r. air c4s:cnpe:.
J' 4l TWG Meeting Minutes Page 3 It was agreed an ECM would be required.
For the sake of expediency, Rich Gallagher agreed to prepare do:umentation utilizing AP-9013 te perform this modification in advance of ECM approval.
It was agreed that performance of the load test would be in compliance with AP-1047.
It was agreed that disposition of the QDP. discussed in Section 2 should N'
not affect acceptance of no load test results or TWG acceptan:e of the load test procedure based on technical content.
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SHAW, PITTMAN, PoTTs & TROWBRIDGE A PARTNERSMfp INCLUDING PROFES$10NAL CORPORATIONS 2300 N STREET, N. W.
1 TELEX / CABLE WASHINGTON, D. C. 20037 VIRGINIA CFFICE 89 2693 (SMAwLAW wSH)
ISol FARM CREDIT ORfvE MCLE AN. VIRGINIA 22102 T E LE PMON E (703)7907900 202) e63.uv4 872491 TE LE COPIE R (202)223 3760 & 223-3761 DAVID R. LEWIS (202)77 338 April 7, 1987 George Johnson, Esquire Office of the General Counsel U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 In the Matter of GPU Nuclear Corporation
(
(Three Mile Island Nuclear Station, Unit 2)
Docket No. 50-320; EA 84-137
Dear George:
Enclosed please find Ronald Warren's deposition corrections i
and certificate.
Sincerely, e__.
David R. Lewis Enclosure
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CERTIFICATE OF DEPONENT I, Ronald P. Warren, Sr., have read this transcript of my deposition taken on Wednesday, February ll, 1987, and with the exception of the corrections noted, if any, find it to be a true and accurate record of my testimony.
(
03-17-87
[ WN Yk4 L 'IIIIb l N'otary(j$ublic Municipality: DAUPHIN COUNTY, LONDONDERRY TOWNSHIP
[^'N My commission expires:
August 21, 1989
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