ML20238C563
| ML20238C563 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 04/08/1987 |
| From: | Thiesing J BECHTEL GROUP, INC. |
| To: | |
| Shared Package | |
| ML20238C505 | List:
|
| References | |
| CIV-PEN, EA-84-137, NUDOCS 8712310083 | |
| Download: ML20238C563 (129) | |
Text
{{#Wiki_filter:- - - - - - - - - - - ORlGW Al O UNI 1ED STATES l NUCLEAR REGULATORY COMMISSION , 1 IN THE MATTER OF: DOCKET NO: 50-320 (Civil Penalty) GPU NUCLEAR CORPORATION cense No. D E 4- 7 (Three Mile Island Nuclear Station, Unit No. 2) DEPOSITION OF JAMES W. THIESING, JR. LOCATION: GAITHERSBURG, MARYLAND PAGES: 1 - 123 OATE: WEDNESDAY, APRIL 8, 1987
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l I ACE-FEDERAL REPORTERS, INC. (-) OfficialReporters 444 North Capitol Street Washington, D.C. 20001 (202) 347-3700 NATIONWIDE COVERACE hDR ADO K 50 20 T PDR
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'CR30476.0 1COX/sjg 1 1 UNITED STATES OF AMERICA k 2 NUCLEAR REGULATORY COMMISSION i
BEFORE THE ADMINISTRATIVE LAW JUDGE !
- - - - - - - - - - -x 4 : l i
In the Matter of: : Docket No. 50-320 5 : (Civil Penalty) GPU NUCLEAR CORPORATION : l 6
- . License No. DPR-73 (Three Mile Island Nuclear : EA84-137 :
Station, Unit No. 2) : 7 . ! _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x 8 9 DEPOSITION OF JAMES W. THIESING, JR. 10 Gaithersburg, Maryland 11 Wednesday, April 8, 1987 12
, Deposition of JAMES W. THIESING, JR., called for
% 13 examination pursuant to notice of deposition, at the offices of 14 the Bechtel Corporation, 15740 Shady Grove Road, at 9:45 a.m.
15 before WENDY S. COX, a Notary Public within and for the 16 District of Columbia, when were present on behalf of the 17 respective parties; 18 GEORGE E. JOHNSON, ESQ. Office of the Executive 19 Legal Director United States Nuclear 20 Regulatory Commission Washington, D. C. 20555 21 On behalf of the Nuclear Regulatory Commission. 22 J. PATRICK HICKEY, ESQ. 23 Shaw, Pittman, Potts 1 & Trowbridge () 24 2300 N Street, N.W. washington, D. C. 20037 25 On behalf of GPU Nuclear Corporation.
-- continued --
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2 1 APPEARANCES (Continued): KENNEDY P. RICHARDSON, ESQ. Thelen, Marrin, Johnson 3 & Bridges One Kaiser Plaza 4 Suite 1950 Oakland, California 94612 5 On behalf of GPU Nuclear Corporation. 6 7 8 9 10 11 12 (9v 13 14 15 16 17 18 19 20 21 22 23 O 24 25 ACE FEDERAL REPORTERS, INC. 202 347 37(X) Nationwide Coverage 8(Kb3E6646
3 , ,. - 1 CONTENTS 2 WITNESS EXAMINATION 3 James W. Thiesing, Jr. by Mr. Johnson 4 4 by Mr. Richardson 120 by Mr. Johnson 121 5 6 7 8 9 10 11 12 O $ 14 15 16 17 18 19 20 21 22 23 24
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( 25 ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
30476.0
- COX 4 O
1 P_ E p,p-E E J2 1 N E E 2 Whereupon,
-3 JAMES W. THIESING-4 was called as a witness and, having first been duly sworn, 5 was examined and testified.as follows:
6 EXAMINATION 7 DY HR. JOHNSON: 8 Q Would you please state your full name.for.the 9 record, 10 A ' James William Thiesing, Jr. 11 Q Would you please give your-current business 12 address. 13 A 800 Oak Ridge Turnpike, P.O. Box 350, Oak Ridge, 14 Tennessee 37831-0350. 15 0 May I ask who is representing you in this 16 deposition today? 17 A Mr. Richardson and Mr. Hickey. 18 MR. JOHNSON: Mr. Richardson, are you going to 19 make the objections? j 20 MR. RICHARDSON: Oh, I hope there will be no 21 occasion to make objections, but should there be, I will
.22 probably make some. But if Mr. Hickey has a concern, if he l 23 is not unduly disruptive, perhaps you will allow him to make 24 them on.his own, or he can whicper in my ear and 3 wi31 make l
l -' 25 them for him, whatever you wish to do. I 1 I ace FEDERAL REPORTERS, INC. ; 202-347-3X0 Nationwide Coverage 800-336-6646 l
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- 30476.0 l COX 5
\ O: 1 MR. JOHNSON: So long as it-doesn't get 2 disruptive, I will leave it up to you, but I would appreciate 3 it if you would consolidate. 4 MR. RICIIARDSON: Okay. 5 BY MR. JOHNSON: 6 0 Mr. Thiesing,'you h' ave been deposed before. You 7 understand the purpose of depositions is to do facts.related 8 to a proceeding in order to find out relevant evidence for 9 the case? 10 A Yes, I do. 11 MR. JOHNSON: Off the record for a second. 12 (Discussion off the record.) 13 MR. JOHNSON: Let's go back on the record. 14 Mr. Richardson, do you have a statement to make about 15 procedures? 16 MR. RICHARDSON: Yes. With regard to making 17 whatever corrections the witness deems appropriate, our 18 practice wil] be that the witness, through my office, will 19 deliver a letter to the court reporter itemizing whatever 20 corrections t he witness wishes to make to the transcript. 21 Af ter the time period for making corrections expires, with 22 our stipulation, you may use that transcript as a final, 23 complete, deposition transcript, without the necessity of the 24 witness physically signing the transcript. I 25 MR. JOHNSON: Okay. I would appreciate it if you j ACE. FEDERAL REPORTERS, INC. l 202-347 3700 Nationwide Coverage 800-334 6646
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.- COX 6 O
1 would. send me, as well as the reporter, a copy of the 2 changes, since I am going to need'to file those.with the 3 transcript. 4 MR. RICilARDSON: Certainly. I believe-what we 5 have done, and our invariable practice, is to send a' copy, 6 show carbon copy to the opposing counsel, which', of course, l' 7 in this case, would be you. l 8 MR. HICKEY: Since we are clearing up 9 preliminaries, I assume tha t the transcript of . this i-10 deposition will reflect also that I am here on behalf of ; 11 GPUN. 12 MR. JOHNSON: Okay. j
.p 13 BY MR. JOHNSON: l 14 O As Mr. Richardson stated, at the conclusion of the 15 deposition, you will be provided a. copy sometime af ter i
16 tomorrow, which you will be'able to review and change any. j 17 ~ mistakes that are made or inaccuracies in the transcript. 18 MR. RICHARDSON: By prior agreement, we have 40 ] 19 days from receipt of the transcript, or you have 40 days from 20 the receipt of your transcript, to review and correct and i 21 then mail the letter to the court reporter, which we will do 22 on your behalf. 23 MR. JOHNSON: I was wondering, maybe we coulo at j 24 this point try to keep it to the 40 days, if possible. I i 25 haven't been terribly concerned up till now in terms of the l O. ! x ACE. FEDERAL REPORTERS, INC. l 202-34 1 3700 Nationwide Coverage 800-336 6646 I
304'76.O COX 7 1 timing. But as we get toward the end of the trial, it's more 2 'i mporta nt . 3 .MR. RICHARDSON: I think'we tried to meet that. 4 .In one case,.Kitler, it was difficult. There have been a 5 couIile.of cases, for example, I never received the transcript - 6 until quite some time after the witness receives'it. I don't 7 'know what is going.on, but I would like'to get a copy of the 8 transcript at the same time a copy is sent to the witness. 9 So~I am not sure how it's been working, but I think, for 10 example, Mr. Bruner didn't get his transcript until rather. 11 3 ate. 12 MR. JOHNSON: That was my problem.
'13 MR.. RICHARDSON: I never received a copy until 14 sometime after he received his. I guess for the court 15 reporter's benefit, if you could send a copy to me 16 concurrent 3y, when you send a copy to me.
17 (Discussion off the record.) 18 MR. JOHNSON: Let's go back on the record. Do you 19 want me to send Dr. Thiesing's transcript to you? 20 MR. RICHARDSON: George. I fear that may burden i 21 things. If I could burden your Xerox machine to make two 22 copies for you to send a copy to me at the same time you send 23 one to Dr. Thiesing, that would make things go faster. 24 BY MR. JOHNSON: L I 25 Q Okay, back to the deposition. Dr. Thiesing, you O ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-33MM6 b _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
30476.0 1 COX' 8' 1 have.been an employee with the Hechtel Corporation or some 2 corporate entity connected with Bechte) for how long? 3 A Since January 8, 1983, a little over 14 years. 4 Q '737 5 A '73. 6 Q Just' generally, what positions'have you held over. 7 that period? 8 A Nuclear engineering analysis, supervisor. ' I' wa s ,
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9 an engineering. specialist in the energy planning department. ! 10 .I was project manager on the TMI-2 recovery project from 1979 11 until 1983 for a little over four years. I was manager of 12 nuclear plant support services projects in our Oak Ridge 13 office from 1983'through 1985, and I am currently manager of 34 technical functions for Bechtel's Oak Ridge office. 15 Q So you.were at Three Mile Island starting in 1979? i 16 'A Yes. I initially was a participant in the 17 industry advisory group beginning about three days after the 18 accident for a period of about. four weeks, then headed up 19 Bechtel's initial planning offorts at GPU's request, laying 20 out how the plant would be reentered and decontaminated and I 21 cleaned up, and then became the project manager-for Bechtel's ! j 22 role as prime contractor for the cleanup in the late summer 23 of 1979, and held that position or related positions through 1 1 24 May of 1983. : 1 25 Q There was a corporate -- 3 guess it would be a 0 ace-FEDERAL REPORTERS, INC. { 202-347-3700 Nationwide Coverage 800-336-6646
'30476.0
.COX 9 1 corporate reorganization at Three Mile Island, Unit 2, 2 approximately September or October of '82, I believe. How 3 did that affeet your role? ;
.i 4 A Up to.the reorganization, I had functioned as S Bechtel's project manager. That is, as a manager of a 6 contractor organization providing the' prime services for the.
7- cleanup of TMI-2. In September of 1982, we integrated al1' 8 the contractors and utility management and; technical people - 9 into a single monolithic organization, dedicated-to the 10 operation and cleanup of TMI-2. 11 In that organization, people were placed in 12 positions without regard to their corporate affiliation, and 13 we had representatives of as many as five or six different l 14 companies in a single group. _ 15 Q Prior to the reorganization, what.was your 16 relationship with Larry King, professionally? What was his 17 position and what was your position, and did you relate to. .l i 18 each other? ; 19 A We related somewhat. He was the director of site 20 operations responsible for the day-to-day operation of the i 21 plant, and I was Bechtel's project manager. We interfaced 22 moderately, as is natural and required by GPU's procedures 23 for accomplishing work on the recovery. 24 Q Who did you primarily -- who did you report to ( 25 prior to the reorganization? ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 8(XF3364M6
L l l l 1: 30476.O COX. 10 t 1 A Prior to the. reorganization within GPU; is.that . 1 1
- 2. the question?
3 Q Yes. 4 A Within GPU I reported to Ken Pastor. 5 Q I take it your administrator of Bechtel was hero 1, 6 in Gaithersburg? 7 A That's' correct. 8 Q Mr. Bruner? 9 A That's correct, and before him Mr. J3attin. 10 Q Then after the reorganization, you became director 11 of the recovery' programs? 12 A Manager of recovery programs. 13 Q Mr. King stayed as director of site operations? 14 A Yes. 15 0 Did you -- were you aware of the assignment of I
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1 1. 16 Richard Parks as startup and test engineer to Three Mile
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17 Island by Bechtel when he first arrived? l f 10 A Yes, I was aware of it. 19 Q Did you have any role in his being hired or i 20 brought to the Island? j i 21 A No. 22 Q Cou.1d you describe what your work relationship 23 with Mr. Parks was from the time he arrived at the site? _ 24 A For the first two or three months of his tenure ) ; l 25 there, he was working as a procedure writer technical support l O 1 ACE. FEDERAL REPORTERS, INC. 202 4 47-3700 Nationwide Coserage 8(XE336-6646
30476.0 COX. 11 LO 1 individual on a task ~ called " Quick Look," which was the. 2 initial investigation into the . damaged reactor at TMI-2. He 3 was part of a task group that reported to me, although I did 4 not know Mr. Parks, I do not believe I wou.ld have even _] i 5 4 recognized him at that point in time. 6 Q So you saw his work, his name on papers? 7 A I knew he was working in that organization. That .] 8 was the extent of my interface with him. 9 Q Did you form any kind of an opinion about his work 10 during that period? l 11 A Generaily favorable opinion, but nothing very _12 specific.
~ 13 Q Did there come a time when you had become more 14 acquainted with him personally or professionally?
15 A I became more acquainted with him af ter he moved 16 to the site operations organization in the fall of 1982. We ; 17 were in some meeti ngs together, . and I got to the point where 18 I could recognize him, I knew who he was. 19 Q These meetings were.about what subjects? 20 A I don't recall. i 21 Q Were you aware that Mr. Parks had a Dechtel ,
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22 supervisor? 23 A Yes. 24 Q Who was that? q 25 A Andy Wheeler, the manager of startup here in j ACE-FEDERAL REroRTERS, INC. l 202 347-3700 Nationwide Coverage 800-336 4 16
30476.0 l' .. COX' 12 1 Gaithersburg. 2 Q Did Mr. Parks, to your knowledge, have an on-site 3 Bechtel supervisor? 4 A During the period of time that he was working in 5 the Quick Look program during the summer of 1982, yes, he 6 'did.
.7 It was somebody in the Quick Look organizat. ion.
0 . Ultimately he was reporting to Bob Seider. After that. time,- 9 af ter those operations, he did not have a Bechtel 10 supervisor. Ile reported to the on-site operations group 11 through Ron Warren, Ed Gishel, to Larry. King, and'in 12 Bechtel's matrix organization, he reported functionally to 13 Andy Wheeler here in Gaithersburg. 14 Q Correct me if I am wrong'then, it's my 15 understanding that -- maybe I am getting aaead of you though 16 -- in December of '82, approximately, Mr. Parks was appointed. 17 to be an alternate to the startup and test manager or 1 18 supervisor, Ed Kitler, and in that function reported to him. 39 Therefore -- we)), let me stop there. Is that true? 20 A 'The s tatemen c you jus t made, I understand to be h 1 21 true, yes. 22 Q Wou.1d you then consider, as a Bechtel supervisor 1 I
.23 yourself, and reporting to other supervisors above you, was i 24 Mr. Ki t3 er not Mr. Parks' supervisor in that situation?
25 A No. I did not view him as being Mr. Parks'
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p u L 30476.0 COX 13 O As alternate startup and test manager, he would-I supervisor. !
. i 2 only f unction in tnat role in the absence of Mr. Kitler, and !
l 3 would continuo.to report through~the site. operations chain of* 1; i l 4 command when he was performing that function. That sounds l 4 i 5 like an organizational anomaly, and it is one. l l l 6 Q I am having a hard time understanding; my l- 1
- j. 7 understanding from the deposition we have had with i 8 Mr..Kitler was that.Mr. Kitler did have certain l^ responsibilities that he, in turn, delegated to Mr. Parks; is 9
1 10 that true, to your knowledge? l l 11 A Yes. l l 12 MR. RICHARDSON: In what capacity? l 13 MR. JOHNSON: The capacity as startup and test 14 supervisor, he had certain functions that on occasion he l 15 -asked Mr. Parks to perform for him. l l ( l 16 MR. RICHARDSON: 'I think that misstates the
- 17. record. There is testimony that in his absence, Parks, as 18 the alternate, wouJd be expected to do some things.
19 BY MR. JOHNSON: .. 20 0 Let me ask Dr. Thiesing, what is your view of that 21 relationship? 22 A I never viewed that Kitler could assign work to 23 Parks. The startup and Lest group was in the aite 24 engineering organization. And the manager of startup and 25 test had certain procedurally required functions that he had i ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 8(K)-336-6646
l 1' l' 30476.0 COX 14 ; l 1 to perform. In Kitler's absence, Parks was the authorized- . 2 person procedurally to perform those functions. I believed-l !. 3 that'to be the extent of that. appointment as alternate, not-4 that Parks worked for Kitler. 5 Q I see. Could'you, move on.from the' time that 6 Mr. Parks was appointed to the alternate startup and test 7 supervisor position that,'in terms of.your contacts with him, 8 could you'tell me how you related to him in. December and-
- j. 9 January'of 1982-83?
10 MR. RICHARDSON: Is the time frame clear.'to the 11 witness? I am not sure -- 12 MR. JOHNSON: 3 just said. 13 MR. RICHARDSON: I think we can both acknowledge 14 in December, Parks was appointed. Ear 3y September he was 15 appointed as the alternate startup supervisor. 36 MR. HICKEY: You said September. 17 MR. RICHARDSON: No, early December, 10 MR. JOHNSON: I asked him straightforward 1y, in 19 December or January time frame is what I asked him. 20 MR. RICHARDSON: All right. 21 THE WITNESS: I have no specific memory of any 22 interfaces that I can describe in detail . I was in some, not 23 several, but some meetings that dealt with review and 24 approva3 of procedures and other interfaces between recovery 25 programs and site operations. But it was not a detailed O l ACE. FEDERAL REPORTERS, INC. l 202-347 3700 Nationwide Coverage 800-336-6646 l
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entrk prt'.edures, woul'ef tha t ring /a bell?' 11 ' 12 d ,. I attended one o) twc meetings on L'id' t( s ub-iegt , O 13 and he rAgh well have been there, but I c.id t sua f or T A rr - r c, . \ y 14 0 How about the h ad laft 31sr. f. orc; rd.eti ng s . Diit ' < , i
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22 had raised some cicuacerns abou the pobtr crait: . ter,L c i 23 procedure, specifically the polc < rant fund tes t' til oc$1ure
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( 1 'A 'I have no specille memory of.Mr. Parks ha ving c )f i 2 raised those concerns unti59theY-- ,,ometime af ter the i 1,z 1 * '
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l 3[ , , issuance of site.operationn'coraments m, s on the load tiedt fi _s l .. L 7j 4 procedure, lwhich were authored by .1Wks. Tt was some period < s -
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!. S 7 -Q By the way, you received the notice of. deposition - n , t 8 j. . dated March 20, did.you paf? ; V 4, - u ,, 3
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A Da ted Mart:h 20. In all honesty, no. J 10 3_ Q Were you informed by your counsel that he had i t : 1 Q , n.(.g e I 1150, received it? , 12 MR. RICHARDSON: Welli without revealing , N i O 13 privi]eged cotnunications, I didoredeive
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36 , NN JOHNSON: It was sent tt$" Dr., 'Thi esing i n care 17 4 of Mr.' Hickey. s I
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k [ 19 Q Were you informed of the substance of the notice s 20 of deposition? I s- 21 A I think so. 22 O Were yvo informed that it requested you to bring ,' j 23 with you rQ ords in your possessica that were relevant to the"
+< 24 issues in tr.e case?
25 A I am aware that it asked that qdstion. l l , h An FEDERAL REPORTERS, INC. , I 202 347 3701 Nationwide Coverage Abns R,46 __ 1_____._._n__ _ _ _ _ _ _ _ l
l l [i,2 . 1 30476.0-l COX 17 , O Did'you bring any such' documents'with-you?
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3 MR. RICHARDSON: To speed this'along, Mr. Thiesing ( 1 a' 4 brought with.him docurents which he wasn't sure whether you lii (f: ,' ,5 h'ad. He has other documents,'NRC investigative reports and 6 the like, which he is.quite confident the NRC already has. 7 Now, this I kn'ow you already have. This is the O handwritten memo dated February 26, 1983, from Dr. Thiesing 9 to Mr. Kanga, document entitled Comments 'on advisory panel 10 head lift meeting," handwritten by L.P. King. 9/13/84. 1 l isg [3 11 Thiesing to Bruner dated March 2, 1983, which I l 12 believe you already have. A letter from R.L. Reiter to C.E. 1p lV 1 13 Corley, dated April 22, 1983. Mu.ltipage typewritten document 14 enti tied " Design Engineering 's Comments on R.D. Parks' [U ll 15 Affidavit." Memo from C.W. Sanford to department managers l 16 dated March 25, 1983. l -y '17 Memo from J.W. Buell to J.W. Thiesing dated March p' 18 24, 1983. Attached to it is a copy of a memo from D.M. 19 Blizzard to J.W. Huell dated February 23, 1983. l 20 Memo from T.G. Flynn to C.W. Sanford dated l l 21 November 30, 1984. 22 A memo from Susan Fitzgerald of the Philadelphia 23 Inquirer staf f - I am sorry, Susan Fitzgerald, whose title 24 apparently is Philadelphia Inquirer staff writer, dated l l 25 November 5, 1984, to Mr. James Thiesing. l j'.(; ace. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Cmerage MKk336-6646
30476.0 COX 18 9 This one I know you have, it's the memo from J.J. 1 2 Chwastyk to D.M. Lake, dated March 1, 1983. Attached to 3 which is a memo from D.M. Lake to L.P. King dated February 4 28, 1983. Which, in turn, has an attachment which is a copy 5 of Mr. Parks' February 17, 1983, comments on the polar crane 6 Joad test procedure, which ref3ects the February 25, 1983, 7 responses of recovery operations. 8 MR. JOHNSON: Okay. 9 MR. RICHARDSON: Here is a three-page document 10 which bears handwriting. The first page at the top says 11 "page 31, paragraph 2." The second page in the upper 12 left-hand corner has the names Thiesing, Pastor, Lake, 13 Hanson, Radbill, Warren, Parks. Upper right-hand corner it 14 says " File, polar crane," dated 2-20-83. The second page, 15 first line of which says " Items to be potentially addressed 16 by readiness review committee." This appears to be a portion 17 of Mr. Stier's November 1983 report. At the top it says 18 " Management and Safety Allegations." 19 Here is a copy of Dr. Thiesing's statement which 20 he gave to Mr. Stier dated Ju]y 25, it says 1981, but I think 21 that was one of the rare mistakes made by a court reporter. 22 I am sure it was 1983. 1 23 Last)y, there is a copy of a typewr3tten set of I l 24 interview notes, the first page bears the title " Interview 25 with Bill Austin, May 8, 1983, 10:00 a.m. by 1)can D. ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Cmerage NKb336-6646
30476.0 COX 19'
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2 MR. JOHNSON: I' notice that some of these appear 3 to be originals. I would like.to have copies. I assume you 4 don'.t want to give up the originals. 5 MR RICHARDSON: Sure. 6 THE WITNESS: Yes, all of this information I would 7 like back. Either a copy of it or the original, whatever you 8 want. We will make copies for you. 9 MR. JOHNSON: Let's leave it on the table. .I am 10 going to refer to these documents during the-deposition. 11 MR. RICHARDSON: To keep'it segregated, could we 12 pile it on top of this accordion folder? 13 MR. JOHNSON: Sure. At the conclusion, I can take 14 it back and make a copy and send it to you, or any way you 15 like. Some of'these documents I have not seen before. 16 BY MR. JOHNSON: 17 Q Actually, I was asking you a question right at the 18 point that we interrupted f or this purpose, concerning, 1 19 believe, this resolution that is appended to the March memo, 20 March 1, 1983, memorandum. So I will just refer you to 21 that. 2? Was that the document that you were referring to 23 before we started discussing the documents that you brought [. 2d with you? l' l 25 A Yes. This set of comments would represent the l O ACE FEDERAL REPORTERS, }NC. 202-347-37(X) Nationwide Coverage 8(xb336446 1
30476.0. COX. 20-1 first time that I can remember having had knowledge that 2 -Parks' personally:had any comments on the polar crane. 3 Q- - When did you f'irst see'this document; do you 4 recall? 5 A I do not recall. I. do not recall seeing it prior 6 to the 25th of February or thereafter, when the resolution, 7 the typed resolutions, had been entered by Mike Radbill of 8 ' Dave Lake's organization. I have since seen copies of the 9 document that were made before the resolutions were typed 10 onto the document by Dave Lake's group. 11 O You attended a meeting, I believe, on February.22 12 at which Mr. Parks was an attendee. I was' wondering if you.' 13 recall attending that meeting, a' meeting in which the polar 14 crane matters raised in this document were under discussion? 15 A Well, the general - .I do remember attending a l 16 meeting at about that point in time. The only thing I i 17 clearly remember about that meeting, as far~as the issues j i 18 that were discussed, was whether the format requirements of l 19 AP 1047 would or would not be met with respect to the polar 20 crane load test procedure. I have a fairly clear memory of 21 that discussion. , i 22 Q Okay, j 23 A It is possible that other issues were discussed, 24 but I don't have a clear memory of that. i l 25 0 Do you recall the posi tion that Mr. Parks took at l 1
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30476.'0-COX. 21 s 1 the' meeting? 2 A Not precisely, other than there was a meeti ng, and 3 1.' don't know whether it was that'one orla subsequent. meeting, 4 he became a rather, I guess vulgar in the right word, 5 regarding the possibility ot getting something approved, and. 6 I don't remember exactly what it was. 7 Q Did you take a position at this. February 22 8 meeting about the app 3icability of those procedures, AP 1047 9 and 1043, with respect to the format for the test procedure,. 10 polar crane Joad test procedure? 11 .MR. IIICKEY : Does your question suggest that both. 12 of those . procedures deal with the format of the load test 131 - procedure? 14 MR. JOHNSON: Yes. 15 MR. HICKEY: Did you mean it to? 16 MR. JOHNSON: Yes. 17 BY MR. JOHNSON: 18 0 You may refer to the document. I represent to you 19 that it does speak to both AP 1043 and AP 1047, and that 20 being the concerns of Mr. Parks, I was wondering if you took 21 a position with respect to the applicability of those two 22 procedures at that meeting? 23 MR. RICHARDSON: This is the meeting on February 2d 22?
.g 25 NR. JOHNSON: Yes.
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30476.0 COX 22 1 THE WITNESS: I:do not recall'tak'ing a firm 2 . position on the-applicability. I recall the result of.the 3 meeting was an agreement that'the load test procedure, as it.. 4 was currently then formatted, would be submitted ~toLthe 5 organizations for review and approval'that are called out in 6 AP 1047. The result of' the meeting was that we would try'to 7 sa tisfy the intent ' of AP 1047 if . -- and I am n'ot clear 8 . whether we.had decided to satisfy the format requirements.of 9 AP 1047, butI do recall that we had decided to satisfy the 10 review intent of'AP 1047 with respect to the po3ar crane.' load 11 test procedure.
-32 MR. RICHARDSON: Perhaps;there may.be some-13 confusion on the part of the witness. I think, Mr. Johnson,.
34 I know there were two meet 5ngs back to,back, one on February 15 22 and one on February 23. 16 -THE WITNESS: I can't remember which was which. 17' MR. RICHARDSON: Okay. 38 HY MR. JOHNSON: o 19 Q Okay. Is it fair to say that have you and
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20 Mr. Parks had differing opinions about the applicability of ] 21 those procedures to the polar crane load test procedure at 22 that time? l i i MR. RICHARDSON: My difficu)ty with the question 23 .J l 24 now is since the witness has indicated he is unable to 25 d"stinguish between two meetings on the 22nd and 23rd, then j O ! J l i ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage tun 336446
30476.0 COX- 23 1 it's not clear what you mean by "at.that time." 2 MR. JOHNSON: Well, we.were talking about the 3 February 22 meeting in the question, and there didn't seem to-4 be any confusion. 5 THE WITNESS: Excuse me for not being able.to 6 differentiate between those two. Can you describe for me 7- what your understanding of the nature of.those two meetings 8 was, and then maybe I can put.the pieces back'together. 9 BY MR. JOHNSON: 10 Q. Sure. I think it's referred to in a number of Il places. 12 My recollection in'that the first meeting was a
. 13 meeting in which you and a number. of people in recovery
~14 operations met with Mr. Parks in -the presence of Mr. Kanga.
15 I am not sure if it was in his office, and the questions 16 raised in Mr. Parks' comment and resolution were discussed, 17 and Mr. Kanga suggested that the QA be brought in to look at 18 it, and there was a subsequentEmceting on February 23 in 19 which QA attended. It was in Mr. Kanga's office. 20 The 23rd meeting was in Mr. Kanga's office, and 21 you attended that with Mr. Barton, Radbill, Freemerman, 22 Kit]er, King, 1.a k e , Chwastyk, Ballard from QA and Joe Marsden 23 from QA/QC. 24 MR. RICHARDSON: Mr. Johnson is Jooking at a page 25 in Mr. Parks' March 21, 1983, affidavit, I believe; is that O I l i ACE FEDERAL REPORTERS, INC. L 202-347-3700 Nationwide Coverare HCKk336 4 16
30476.0 COX 24 O 1 -correct? 2 MR. JOHNSON: That's correct. I 3 MR. RICHARDSON: What page are you referring to?. l l. 4 MR. JOHNSON: This-is page 23. 5 MR. RICHARDSON: Would it help if I showed the l 6 witness that page? 7 MR. JOHNSON: Sure. If you.go back to page 21, 8 you will see a discussion of the February 22 meeting. 9 BY MR. JOHNSON: 10 Q It says, in the first full paragraph on'21 it says 11 "Hanson's main item of interest was my first comment. on the 12 test procedure," et cetera. Toward the bottom of the page it 13 indicates that Mr. Kanga said he had to 3 eave. 14 MR. RICHARDSON: He is trying to read the 15 affidavit, yes. 16 THE WITNESS: Okay. I am to the point where I can 17 tell the meetings apart. 18 BY MR. JOHNSON: 19 Q I,et me just skip ahead to the resolution that 20 Mr. Radbil.1 wrote on 2/25/83. Did you see that at the time . 21 it was finished by Mr. Radbill on 2/25/837 1 22 A I saw it sometime after 2/25/83. I was not party 23 to its issuance. It came in the mail and I read it at some ] 24 point in time after the 25th. 25 Q Were you consulted in its resolution? I j ACE FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 8(n33M486
30476'.O COX 25 O 1 A No, I was not. 2 O I direct your attention to the bottom of page 24 3 where Mr. Parks is saying', "I took exception," et cetera. 4 A Yes. 5 0 It says "I reminded him of my experience," this is-6 Freemerman, "in the tes t program at the Island. In my 7 current role as alternate and test supervisor, I was still 8 responsible to identify potential QA audit deficientins." 9 Then he says at that point that you, Jim Thiesing, 10 interjected to " inform me that.I no longer had to worry about 11 that. He had issued a memorandum that day," et cetera. 12 Do you recall that portion of the February 23 P) V 13 meeting in which Mr. Parks was responding to Mr. Freemerman's 14 position and you spoke up and indicated that Mr. Parks was no 15 Jonger responsible as n'3 ternate startup and test supervisor 16 for this function? 17 A I remember -- 18 MR. RICHARDSON: Are you now paraphrasing the 19 af fi davi t? 20 MR. JOHNSON: Yes. Responsi ble f or identi fying -- 21 essentially review of the procedure as part of the AP 1047 22 process. l 23 MR. RICHARDSON: The way you just added, we now 1 24 have a rather compound ques tion. I thought what you were 25 asking was whether what Parks said conce ning Mr. Thiesing L 1 1 ACE-FEDERAL REPORTERS, INC.
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1 having i.ssued a memorandum appointing a new alternate was ! 2 true. That's what the affidavit says, but then in 3 paraphrasing it you said something else. 4 THE WITNESS: Let me go back and perhaps I can l 5 clarify all of this.by stating the fact'aituation and what I 6 said. 7 1 did not remove Mr. Parks as alternate startup 8 and test supervisor. I did not instigate his removal, I had 9 no prior knowledge that he was going to be removed before 10 Mr. Kitler, with Mr. auchanan's approval, issued a 11 memorandum, some days before this meeting on the 23rd, that 4 12 .had-removed him. 33 The first knowledge I had that he had been' removed 14 was when I received a copy of the memo in the mail upon its 15 distribution. At the meeting, I commented that Mr. Park s. ' 16 statement about being alternate startup and test supervisor 37 was out of context and a little bit misconstrued, since I war 18 in possession of a memo that said that that was no longer the 19 case. 20 DY MR. JOHNSON: 21 Q Okay. We got around to the point a different way l. l' 22 than I intended, but that's fine. l l 23 A It needs to be emphasized. I did not remove him, 24 1 did not instigate his removal, and I did not even know i I 25 about it. Earlier in this deposition, I explained an O ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage Mn3364M6
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. COX 27 O
1 organizational situation to you which you had a little 2 trouble digesting. -You.are not the only person that had a 3 problem with the context that we had a responsibility that 4 was assigned to site engineering within - covery programs, S that is the strrtup f unction. The alternate startup and test 6 supervisor resided in p] ant operations. It was the wrong 7 organizational construct. 8 What I later found out had happened was that 9 Kitler and Buchanan had struggled with that organizational 10 . problem and determined that the only way to solve it was to Al make the alternate startup and-test supervisor a member of 12 the same organization that was responsible'for startup and 13 test. They had recently acquired Mr. Walker, whose first 14 name I do not recall, who was a qua)ified startup and test 15 engineer, and to' solve that organizational anomaly that you 16 were struggling with earlier, they appointed him as the 17 alternate startup and test supervisor. 18 Hecause when I received the memo, 1 went back and 19 asked the question, why had that been done. 20 0 When did you receive it; do you recall? 21 A It was probably one day or maybe two days - well, 22 the answer is I do not reca.1.1. It was before this meeting. 23 Whether it was an hour a day or a week, I don't know. 24 0 Did you have -- so your testimony is that you did p 25 not have any personal conversations with Mr. Kitler d ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-33MfA6
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1 concerning Mr. Parks' removal? 2 A Not prior to the issuance of the memo. I did not 3 .know.it was going to occur. 4 Q. How about prior to the meeting on February 23 that 5 we were just referring to?- 6 A- I do not reca)) having had any' conversations about
~7 it prior to the meeting with anybody.
8 Q With anybody? 9 A 1.may have, but I certainly do not recall having 10 any. 11 Q Were you aware that Mr. Parks was unaware of the 12 memorandum being issued? 13 A No, I was not aware that he was. unaware that the 14 memorandum had been issued. 16 Q Did you subsequently - let me just ask you, you 16 did mak*e a comment to the effect that Mr. Park's was no longer 17 an alte :. ate startup and test supervisor at this meeting; 18 that's correct? 19 A That's fact. Referred the audience to the { 20 memorandum. 1 21 0 Do you remember Mr. Parks' reaction? 22 A No. No, I do not. I 23 Q Did you come to understand that he did not know 24 about that memorandum removing him from that position until i 25 you mentioned it? I O ! { ace-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide CoveraFe Mn336 6646
30476.0 COX 29 O: The question may call for 1 MR. RICHARDSON: 2 speculation tinJ ess you -- 3 BY MR. JOHNSON: 4 Q No. Did you become aware, after making the 5 statement, that he -- 6 A During the meeting? 7 Q -- that he did not know? 8 MR. RICHARDSON: Facially, the question calls for. 9 speculation. Are you asking him whether Mr. Parks had at 10 some point expressed to him that Mr. Parks was nod aware-of 11 that decision? 12 BY MR. JOHNSON: 13 Q Did Mr. Parks state at the meeting that this was a l- 14 surpri se to - him? 15 A Not that I recall. He may have, but I do not 16 recall him having made that statement. The first time I can 17 remember being aware that he alleges that he was surprised 18 was in reading his affidavit. 19 0 How do you recall that meeting playing out after l 20 this conversation in which you responded to Mr. Parks that he l 1. 21 was no longer an alternate startup and test supervisor? What [ 1 22 happened, to the best of your recollection, at this meeting? l l' 23 MR. RICHARDSON: The question being what was said l: after Mr. Thiesing made the observation that Mr. Parks had 24 25 been replaced as the a3 ternate startup supervisor? l g Ace-FEDERAL REPORTERS, INC. !' 202-347 3700 Nationwide Coverage 8(Kb336-6646 I':
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COX 30 n. V. 1 BY MR. JOHNSON: 2 ~Q Correct. 3 A 1 don't recall that question or, th'at statement' 4 having had any effect on the progress of the meeting. .Most 5 of the people in there were aware that that change had been 6 made, and the meeting proceeded. I don't have the specific l 7 memory of how that speci fic meeting -- 8 Q How did you know most of the people were aware? 9 A There was no evidence of any surpr3se on the part l l 10 of anybody. l-l- 31 O Including Mr. Parks? l f 12 A Not that I can recall. But that was four years 'i l 13 ago, over four years ago. I don't have a detaiJed memory of-14 that meeting. 35 O Did you have any discussions with.Mr. Kitler after , 16 that meeting concerning Mr. Parks' removal from that position l l ~ 17 to alternate startup and test supervisor? 18 A Well - l l l 19 MR. RICHARDSON: Could you read that question l l 20 back, please. 21 (The reporter read the record as requested.) 22 MR. JOHNSON: Should have been "from." 23 MR. RICHARDSON: He has already described one 24 discussion -- 25 HY MR. JOHNSON: O 4 I i l Ace FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coveraye 800 336-6646
l L l l > <. '30476.0-l COX 31 1 Q Wait a:second. Do you understand the question? 1 l 2 MR. JOHNSON: If you have an objection, I would 3 prefer that you don't keep trying to interpret my' questions, j 4 If the witness doesn't understand the question, p. lease so l l- 5 state, and I will try to rephrase. 6 MR, RICHARDSON: My, point is that he has already' ; I 7 described a discussion with Kitler and Buchanan. Are you ) 8 asking him to repeat that discussion or are you asking for 9 discussions beyond that? The question is confusing, j l 10 HY MR. JOHNSON: 11 Q Is the question confusing, Dr. Thiesing? 12 A The only way I know how to answer it-is to repeat 13 the answer I gave before. I recall having had a discussion-14 at some point in time with either Kitler or Buchanan or both 15 of them, where I asked the question, why did.you do that. .j 16 Why did you remove him, what is the logic for doing that? .I 1 17 And they explained to me the organizational anomaly that you 10 and I stumb]cd over earlier in this deposition regarding the l 1 19 fact that Parks was not part of the site engineering 20 organization, and that the startup function was a site 21 engineering function, and the alternate should reside inside i 22 engineering. l 23 We had just acquired Dwight Walker, is the man's i 24 name, who was a qualified level 3 and is a startup engineer, l 25 for the express purpose of having a backup for Mr. Kitler. ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-M46 i- .
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-1 Mr. Walker had appeared on the Island, come up to speed to 2 some' extent. They felt it was. time to appoint him to the 3 position that he ha'd been brought to the Island to perform.
4 Q Did this discussion with Mr. Huchanan and 5 'Mr. Kitler take place before or after this February 23 6 meeting? 7 A Probably after. 8 MR. HICKEY: Just for the record, the. witness'said 9 he had a discussion with either Kitler or Buchanan or both. 10 MR. JOHNSON: Okay. 11 BY MR. JOHNSON: 12 O In this conversation that_you are referring to,_ 13 can you pin it down to the period of time, was it within a 14 week after this February 23 meeting? 15 A I-can't objectively pin it down to any particular 16 time. But I believe it probably was within a week of this 17 meeting. 18 Q. Do you recall whether Mr. Kitler mentioned 19 anything to you about problems he had been having with 20 Mr. Parks in that discussion? 21 A The only discussion I had with Kitler and Buchanan 22 regarding " problems with Mr. Parks," and I don't recall which i 23 one of them it was. But as I said before, Parks had become 24 rather vulgar and emotional in one of these two meetings, and 25 I can't remember whether it was the one on the 22nd or the , ACE FEDERAL REPORTERS, INC. j 202-347-3700 Nationwide Coverage Mn336-6646
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30476.0 COX 33 O 1 one on the 23rd, but I suspect other records will define that 2 for you. He had indicated that if you can get that approved, 3 I will give all you gays a blowjob. That even exceeded my 4 level of propriety in a business meeting. I remember l 5 discussing that it seems tha t he has gotten a little bit out l 6 of hand with respect to how he deports himself in meetings. l l 7 It seemed that the issue was becoming very emotional. But I 6 can't pin down the date that I had that discussion, and I 9 can't pin down whether it was Kitler, Buchanan or both. 10 0 Did Mr. Kitler discuss with you a conversation 11 tha t he had had with Mr. Parks on February 18 regarding 12 either a threat to transfer or rumor to transfer Mr. Parks 13 off-site? 14 A The on]y discussion that I ever had with Kitler 15 about transferring Parks was somewhat prior to this time, at 16 a point where Kitler had indicated his intent to resign from 17 the company and go somewhere else. I had suggested that 18 Parks might we)) be a good rep)acement for Kit]er as startup 19 and tes t manager, if we could acquire his services from site 20 operations, if we could obtain his re] ease f rom site 21 operations. 22 I cannot pinpoint the timing of that - 23 Q That was my next question. 24 A Dut it was sometime before this, maybe in the 25 December-January time frame. ACE-FEDERAL REPORTERS, INC. 202-347-37(0 Nationwide Cmerage 8(G33MM6
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1 Q Did Mr. Kitler indicate to you.that he was 2 thinking.of. leaving? 3 A -Yes, in the earlier time frame. He had stated an 4 intent to renign and had set a date. ! 5 Q Did he say at that time what he intended to do?
,1 6 A No. It was unrelated to ---it~was'mostly related !
7 to the fact that he was approaching one year on a temporary 8 assignment, and his temporary assignment per diem benefits 9 would not'be paid; it was an economic issue. l 10 Q My question was specific and it went to whether 11 you had had a conversation with Mr. Kit.ler in which 12 Mr. Kitler mentioned a conversation he had with Mr. Parks 13 concerning Mr. Parks being transferred off-site. That's what 14 I was focusing on. 15 A I did not discuss that with Kitler. 16 Q Did-you discuss such a move of transferring 17 Mr. Parks of f-site with anyone or prior to this meeting of 18 February 23? 19 A No, I did not. lie didn't work for me, though 1 20 really didn 't have any -- I wasn' t in an organiza tional j 21 position to have that discussion, really. 22 Q How about with Mr. Morris? Did you have i i 23 conversations with Mr. Morris on any kind of frequency during l 24 this Tanuary-February 1983 period? l 25 A Not on any frequency. I 1 1 1 ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6 1
30476.0 1 Q Did you have any conversations with him concerning, l 2 Mr. Parks? 3 A. Not that ] recall. 4 Q Do you remember being interviewed'by'Mr. Joel-5 Wiebe, the seni(>r resident inspector'at the Three Mile Island I. 6 Unit 2, in approximately February, late. February, 1983? L 7 MR. RICHARDSON: Do we have Mr.'Wiebe's memo of 1 8 that interview? l 9 MR. JOHNSON: I would like to ask him whether he
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1 10 recollec ts it before I show it to him. 1 . Il THE WITNESS: Not -- I remember being in a meeting l~ 12 with Wiebe about that period of time, but I don't' remember it l l
'13 as being an interview. But if you say I did -- I don't have .l 14 any detailed recollection of that meeting at this point in l
'15 time.
16 BY MR. JOHNSON: j l> l l 17 Q Okay. Do you remember what the general subject 1 18 was? l 19 A No, I don't. I am sorry, I am drawing a blank. ! 20 Q This is the memo I was referring to. It's March 1 21 10, 1983, memorandum on the subject of allegations from Rick j l' 22 Parks, dated February 18, 1983; and the second page, the i L 23 first full paragraph, there is a reference to a discussion 1 24 with you. Does that refresh your recollection? I 25 MR. RICHARDSON: Mr. Thiesing, take your time to l-l l ACE FEDERAL REPORTERS, INC.
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b t l ', 30476.0 L COX 36 L. . 1 . review the entire memo. [ .. '2 THE WITNESS: That meeting with Wiebe that you l l 3 referred to was.most'likely a telephone call, notea meeting. l l 4 Very short, and I do have a memory of.it. It was just a-5 singular question, did I know of anybody who had been 6 threatencd with a transfer or whether their job had been 7 threatened because of comments they had made. .IIe'didn't put 8 any names to that, and I answered no, as is indicated in 9 Mr. Wiebe's memorandum to Mr. Christopher. The reason I
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I 10 couldn't recall it is it really wasn't a meeting. It was 11 pretty much one question, one answer, end of discussion. I 12 believe it was on the telephone. 13 BY MR. JOHNSON: 14 Q Do you recall whether Mr. Wiche referred to the 15 person as either a Bechtel or a GPU employee? 16 A .No, I do not remember him referring to either 17 one. I believe he was anonymous. He didn't talk about what 18 particular type of employee. 19 Q Did Mr.. Wiebe's question lead you to think that 20 someone had gone to the NRC with such an allegation? 21 A That rumor was already afoot and broadly known to 1 22 many peop.le on the Island when I talked to him. That 23 someone, unidentified a.s to name or organization, but rumored 24 to be from the site operations organization, had approached 25 the NRC with concerns of unidentified origin. ACE FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coverage 8M336-6646
i: L- .30476.0-COX '37' O With concerns.of unidentified; origin. Could you 1 Q 2 explain that, _. please.
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3 A' Concerns about some safety matter,. undefined. l- 4 Q: Do you remember any of the nources of this-rumor, 5 to whom, from whom you.may have heard that? l 6 A No, I do not. But it seemed to b'e rather common-1
- l. 7 knowledge'as early as 26th, 27th of February. 'Dut:at that.
l 8 time, and at the time that I' talked:to Wiebe', I'had no idea 9 who that was. I really didn't care' that much, to tell'you j. 10 the truth ~. L 1.3 Q Did there come a time,when you-got more-12 information about'who the rumo'r may have been about? j ll 13 A I certainly became aware that it had been' Parks-l 14 when he issued his affidavit in'-- what is the date of thias , 15 affidavit? 16 MR. RICHARDSON: March 21, 17 BY MR. JOHNSON: 18 Q March 21. s 19 A March 21. 1 e 20 0 Okay. 21 A I don't recall being aware who had gone to'the NRC l 1 1 22 before the issuance of that affidavit, although I may have. 23 It was certain.1y we.13 after March 10. l 24 Q So you are saying that there was a rumor on the q 1 L 25 site at approximately the time you were interviewed by- l l-l l' l .: I 1' ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 8(43364M6 l
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1 .Mr. . Wiebe, that someone from the site had_been to the NRC, 2 .but about a safety concern, but'you don't recall from whom
'3 you heard.the rumor? 3 s
4 A It was one of my subordinates, but I don't know 5 which one, and it was certainly February -- it was.'before the. l 6 end of February. : 7 0 Were you aware of the rumor when you spoke to 8 Mr. Wiebe? , 9 .A Yes, I was. - 10 Q Hut you did not mention the rumor to him? J 11 A I did not. He didn' t ask . about i t' either. He
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12 asked a very specific question, and :I gave him a very short,
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O 13 specific answer, and that was all the f:urther the discussion ; i 14 went. ; l 15 0 And that was the end of the discussion? ) 16 A That is correcL. 17 O Did he ever get back to you? 18 A No, he did not. 1 19 Q Do you recall attending a meeting on February 28 20 or thereabouts in which the readiness review committee agenda 21 was being discussed among various members ofsiteopehations 22 and recovery operations? 23 A Yes, I do. 24 Q Do you remember, after the meeting being 25 adjourned, having a discussion with either Ron Warren or Rick O l l AcF-FEDERAL REPORTERS, INC. . 202-347-3700 Nationwide Coverage 800-3364M6 t______-.__-__--_-____ . _ _ _ _ _ _ -
- 30476.0 COX 39 1 0 1 Parks'or both of them?
2 A At the conclusion of the meeting, I. asked Ron 3 Warren to stay in the room for a short discussion. Rick 4 Parks, either on his own initiative,'or at Ron Warren's' 5 . request, stayed with him. And the focus of that discussion 6 was to try to mend a rift that seemed to be developing 7 between the site' operations' organization and the recovery 8 programs group. 9 It's necessary that.those two organizations have-j' .10 an open communication chain, that they work together to solve 11 problems, to get differences of opinion on procedures 12 resolved. They provide support services to each other. I 13 sensed that the nature of that interface was becoming very' l 14 strained and people were beginning to deal on.almost a purely 15 emotional level. I viewed Ron Warren as a senior uninvo3ved, i 16 if you will, _ person within the site operations organization i 17 who might contribute to lowering this level of tension. i la I indicated that'we have had some issues that have l
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I 19 come up, Larry King's suspension is one. I indicated that it 20 was rumored on the site that someone, not identified, but i l 21 thought to be inside operations, had approached the NRC with :l 22 safety concerns. I indicated that I was aware that certain l (' 23 individuals within uite operations were very upset about j I 24 Mr. King's suspension, and I indicated that we needed to put 25 those issues aside, Jet them run their natural course. There LO 4 ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage Mh336 6646
t i l 30476.0 ! COX 40 0 1 is no' question in my mind that the NRC was going to I
'2 investigate very carefully whatever allegations had been made l 3 by whoever had gone to the NRC and that that issue would run 4 its'natura) course.
There was no question in my mind that. 5 the Larry King suspension was going to get a-clear hearing )i 6 and a clear hearing within GPU, and I was asking my people in 7 recovery programs to put those issues aside, lower their 8 Jevel of emotional involvement in this issue and open up the 9 channels with communications and interface in site 10 operations. 11 I euphemistically suggested I could, if I wanted- I 12 to, fire one person a month until these people quit this 13 internecine bi ekcri ng. I en]isted Ron Warren's support and 14 said I can help you with your side of the problem, can you 15 help me lower the intensity of this discussion so we can get 16 a businesslike dialogue going again. I 17 My sense of it is that that he3 ped some. Shortly la after that, we were able to come to agreement and set an 19 agreed-to course of action on how we were going to resolve j 20 the issues related to the polar crane load test procedure, 1 21 minutes of the test working group were ultimately written and -l 22 approved by all parties concerned, and things seemed to 23 improve a .little bit,. But that was the focus of the meeting, ) 1 24 and that's what I was trying to get al. At that point in l 25 time, i t had never even occurred to me that Rick Parks was O i I I, ACE-FEDERAL REPORTERS, INC. I~ 202-347-3XX) Nationwide Coverage 8(n3364646 ! J l l _ _ _ _ _ _ _ _ _ _ _ _ _ _ J
l' L 30476.0. COX 41 LO 1 l 1 the pt..r nn that had gone to the NRC, absolutely had never 2 occurred to me. l' . . l 3 0 That is February 28 we are talking about?. 4 A .That's right. I didn't know who it was, and I
- S didn't much care.
l 6 Q When you caid -- you said euphemistically, I am l l 7 not sure what.you meant by euphemistically you were going to. 8 fire a person. You-mean from recovery operations, somtbody l 9 within your -- 10 A Somebody within my shop.- I have'no authority over l 1 11 .the people in plant operations or in site operations. Maybe l l 12 I am misusing the word. 13 Q I just wanted you to clarify. 14 A I didn't mean I was. going to fire somebody, but 15 certainly I can take measures to get.my people'in recovery 16 programs to understand that'they needed to lower the level of 17 emotional content in their relationship with site operations 18 and return that re3 ationship to an open dialogue and 19 businesslike relationship. I was enlisting his support to do 2C likewise within site operations if he could help me. I 21 Q Could you identify individuals within recovery 22 operations who you felt were reacting emotionally t o the 23 issues? 24 A Oh, I think it was rather universal within ! I 25 recovery programs. Personnel were extremely upset about (q/ l ACE. FEDERAL REPORTERS, INC. 202-347-37(X) Nationwide Coverage 8(Kk33M646 1
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30476.0
. COX 42 O-1 Larry King's alleged involvement with Quiltech and what that .
L 2 imp] sed. I had that feedback from any number of people who I ] 3 can't identify, but I have a memory that that war, kind of an G universa.1 feeling. S Q You had been doing an inquiry around that same 6 time in which you had spoken to people like Buchanan, 7 Ga33agher and Austin about that matter. In that who you are 8 referring to? 9 A I am referring to the response after Mr. King was 10 suspended by Mr. Arnold and Mr. Harton. That it became known 11 what the cause of his suspension was. Many people in 12 recovery programs were upset about that. They didn't think i O. 13 that that was appropriate behavior on his part, in having set 14 up this company to body shop people to other power plants. 15 On the other side of the issue was the issue of 16 Mr. King's suspension, and I think it's normal for people in 17 an organization to react strongly when their 3eader, who they 18 have some respect for or like, is suspended, and they don't 19 totally understand the fact situation. I was in the meeting 20 on the 28th with Mr. Warren and Mr. Parks, suggesting we 21 ought to set those issues aside, they wil] take care of l 22 themselves. The NRC is involved, GPU management is l 23 invo3ved. Our job is to get on with the r ecovery, and we 24 have to have an open dialogue and interface t.o make l I l 25 progress. Without that interface, you can go nowhere. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage M&33MM6 l _ .__- _ ____-- ___.-____ _ -- _ - _ _ _ _ ___ _ - - _ _ _ n
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l 73cause procedural arid, admir[g s tra ti ve system that i; s r:e' ' ap q t t, r 2 at TMI is a check and balarne prga ni v'ti on . O? e cannbt mako 3 progress without the otherL e y >- , 4 ' O Gett2ng back to the s ta-t e. ie n t a bc ut. fou were swarc < 5 enat .R w oody het gor n, to tiu tre, how sid you - in wha t 6 context did you fa.,, .tb t point? - Was , in the c o r t > +.: t of r 7 this discusaion -- T. t a.:e . i L it was in the contex of a 8)i? ( di scusrC on about how do, we deal w i t '- t.his prolem, a what 9" you are discussing. 10 ; Hut do you remember i, peci f i ca l ) y hoa the ma t te.r o f. . i ( , 11 someone going to the NRC 'can!r 'ip? 12 i F I ra.ised it as an exampic of thingo or an example 9 13 ot . issues that are causing the ,i n t s r f;' c . the Communi. cations
, N 34 interi' ace, between the two organiza' ions to breax down, i
15 because peopl e ar e react i.ng tr;- it. There were other b, i y - p I 13 ink I h.i /e giv'en you a ecppl e . i s 16 y,' examples. 17 Q People were rtacting to someone'goin, 'o
. the the 18 NRC?
i l 19 A \*r. 20 0 How? ,, , ! 21 i A. Oh, I think they d.I'e a s k i ng wio; >..a s that done, I 22 l wd; it ah appropriate ihing to do. People in recovery l 23 proJrams did not be]ieve they he<f tone anything :Sai l l 24 warranted comebody to take safety rLacerns to the HRC. But I 4 i and e ,
's ! for my purposen. :f mm f u))y aware of the r u l e r, l
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You.have no rigntjtg ' approach;' I regulations of these matters.
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2 the itRC4 with safety concerns,: and I was trying to get~my' 3 peop1d. in recovery programs to put that aside, it's an issue ' ( 4 thahwib1';takecareofitself, it has its own momentum, it
- <; t m 5- will be den t with by the NRC. Don't let that cloud your u, 6 irterface wit.II. site operations. I was requesting Warred <to' seq .. .
r
% 7 see if he.could help us do likewise with some of the: issues J
<. ,8 ;y of concerrato the site operations people.
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,,s 0 ;What was his reaction?;
1: 10 t A He didn't say very muchg_lat it'was generally 3
' ll positive. He expressed an understanding, as I reca'11, that.
L2 ,
!!we needed to set these 1 issues aside if-we were going to make' b) 13 to repair this interface and continue doing busined p;rogress -
14 in n ousinesslibbi manner.
)
15 Q , What role d!d Mr. Parks play in this t , sa i 16 conversation? Did he enter into it? 't 17 A No'n that I remember. 'I i. t 18 0 But you were adtYressing -- they were standing .. 4- .19 together with you? ;, [f 20 A Yes. I had asked Ron Warre,n,to stay and Parks had J 21 slayed either on his own initiativa or 'at Won's initiative.
'?2 I was talking to both of them, but most{y Ron Warren. _
2Ron 23 Warren was in a' leadership, manag'ement, supervisory 1 1 ;; I 7.4 poci tion . It was he I was trying to deal with.
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n JS Q Mr. Parks, at the top of page 32 of his affidavit, I. . f i, 1 ACE FEDERAL REPORTERS, INC. , f
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1 says.that -- attributes to you a statement saying he could j s 2 see.why.certain people would be afraid of a transfer. -j I 3 A I.did not make that. statement. j 4 Q Okay. Is there anything that you said concerning 5 the transfer'of someone? 6 A No, absolutely not. I would like to. reiterate, it i 7 never occurred to me that Parks was the individual that.had i y 8 .gone to the NRC. 9 Q Moving on to the resolution ihat you'-- you were i 10 aware tha t the test work group was to meet and did meet on.- 11 approximately, wel.1,'I believe it was March 4. Were you 12 aware of that meeting? O v- 13 A
.There were a couple of meetings of.the test work l
14 group in that time frame. I am now aware that those meetings 15 occurred. I doubt.that I was aware that they were going to 1 16 occur a t some specific- time, though I knew the tes t work 17 group was dealing with this issue in a general sense'at'that 10 poin t in time. Ilow many meetings, are you referring to one 19 meeting or a series of meetings? 20 Q Well, I believe, as your counsel mentioned, there 21 was a meeting.on February 25. But the one I was referring to 22 mainly was the March 4 meeting. 23 A Yes. 24 0 In which, as I recollect, the decision to have the i i 25 issue of the format requirements of AP 1043 and 1047' resolved ACE-FEDERAL. REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 4646
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'30476.0 COX 46 LO 1 .in a quality deficiency report, and put most of those issues
.2 in this report what was-decided upon. And-it was generally 3 . decided that those format procedures did apply to the polar 4- crane. load test procedure.
5 A Do you have a copy of the minutes of that 6 meeting? 7 0 One moment, please. 8 MR. RICHARDSON: Do you want the minutes of the 9 February 25 meeting too? 10 MR. JOHNSON: No. 11 MR. RICHARDSON: Just March 4? 12 MR. JOHNSON: Yes. 13 THE WITNESS: I am familiar with this meeting. I 14 'am familiar with the minutes. I read the report. 15 BY'MR. JOHNSON: 16 Q They were circulated to you. I take it you were 17 not at the meeting? 18 A I was not at the meeting. 19 Q As it indicates, the memo was circulated to you? 20 A Yes. 21 MR. HICKEY: I am not sure that the. record 22 reflects what the witness is looking at. 23 MR. JOHNSON: I am sorry. We are .looking at the 24 memorandum of March 7- 1983. Subject is TWG meeting minutes 25 of March 4, 1983. It's to a distribution of Buchanan, et i ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 336-6646
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cetera, including Mr. Thiesing. It's signed by the members j 1 l 2 of1the test work group, and it covers several pages of TWG: l 3 meeting minutes. 4 BY MR. JOHNSON: 5 Q Do you recall the resolution'of the quality 6 deficiency report that was to be written in conjunction with 7- this TWG meeting? 8 A You are referring to its ultimate resolution? 9 Q Yes. ! 10 A Yes, I do. 11 Q Yes, go ahead. 12 A We indicated that in the future actis'fies on the 13 polar crane would be carried out in accordance with AP 1043 14 and AP 1047, and the direction would be given to my people 15 that that is the way we were going to do it. 16 0 Okay. The document was attached as Deposition 17 Exhibit 1 to the Warren, Ron Warren deposition. This QDR was-18 a document that was addressed to you and resolved by you; is 19 that correct? 20 A Yes, it was. 21 0 The date of your resolution was March 21, 1983? 22 A Correct. 23 Q Did you ever communicate wi th Mr . Parks concerning i 24 the resolution of the concerns about format under AP 1047, 25 1043, with regard to polar crane load test procedure, before
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i 1 .that date? 2 'A .No, but it had been decided in the test working .
'3 group, I believe, that we were going to set up the polar j 4 crane load test in accordance with AP 1047. It was going to' 5 he reviewed by the test working group as called for by 6 procedure. A .l .1 of those comments were resolved in Mr. Parks
7 favor'in a manner very close to.what was understood to be his 8 desires. So I-didn't feel the necessity to make a direct 9 response to him. 10 MR. RICHARDSON: Mr. Johnson, is your question 1 11 whether the witness had a discussion with Mr. Parks after the 12 March 4 TWG meeting but prior to the resolution of the QDR? 13 'MR. JOHNSON: Yes. , 14 MR. RICHARDSON: Okay. 15 THE WITNESS: After the March 4 TWG meeting but' 16 prior to the resolution of the GDR? 17 MR. RICHARDSON: I thought that's what the IB question was. Or did you include in it discussions with 19 Mr. Parks prior to the March 4 meeting? 20 MR. JOHNSON: You characterized my intent' 21 correctly, i 22 MR. RICHARDSON: A.11 right. 23 MR. HICKEY: What does that mean? I am confused 1 24 now. l l 25 MR. JOHNSON: We.11, I think Dr. Thiesing answered l -O l ACE. FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coverage MO-336-6646
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[ 1 the. question. 2 MR. RICHARDSON: But'both you and Dr. Thiesing.
.3 understood the question to be after March 4'but before" March-q 4 21.
5 BY MR. JOHNSON: 6 Q Did you understand it -- 7 A After March 4, before March 21, I recall no direct 8 discussions with Mr. Parks regarding that QDR. I gave 9 instructions, though it was clear at that point in time, that 10 we had -- once the QDR was written, we.had made a 11 determination that we were going to change the procedural 12 approach to doing the work on'the polar crane. I had given 13 instructions to the people. We were marching down'that. path 14 with respect to the polar crane' load test, and I' finally-15 wrote out and documented those directions'for the file in the- i 1 16 resolution of the QDR. 17 The -- but at the time the QDR was issued, there 18 was never any question about how it was ultimately going to 19 be resolved, and those directions had already'been given. 20 MR. JOHNSON: Would you like to take the break j i 21 now. !
)
22 (Recess.) 23 BY MR. JOHNSON: l 24 O Back on the record. Dr. Thiesing, I would like to 25 ask you a feu- questions about when you -- the circumstances
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- l. COX S0 LO l; 1 of writing this memoranda that was identified to me'this j L
2 morning, the 2/26' events leading up.to my informing l 3 Mr.' Barton of the existence of the Quiltech organization and j L i I 4 who its officers were. In this memorandum, you start off at ] 1 1 . 5 the very top describing' when you first learned about a 6 business relationship between Larry King and Bennie Sloan. 7 Is it true .that 'you learned of such a rela tionship in May .or 8 June of 1982? 9 A Well, at that point in time, I wouldn't say I i
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(' 10 " knew," in quotes, anything. But it was rumored that there
- j. 11 was a business reJ ationship between Sloan 'and Larry King at L 4 l- 12 the time that he left, at the time that Sloan left GPU. I l 1-13 didn't put much credibility to that.
14 Q You knew Ben Sloan at that time? 15 A I knew who he was. I knew him, yes. 1 16 Q Did you know what he was doing? 17 A Jn the recovery? l 18 Q When he left. 19 A I did not know what he was doing after he left 20 GPU. 21 Q Did there come a time when you understood that he 22 was involved in a job shop operation? 23 A It had been rumored that he had left to go into 1 24 some sort of a job shop operation at the time he left. 25 Q That was part of the rumor? l O ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
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l 1 A- Yes. 2 Q. How wou3d you classify it as a; rumor? It'was a 3 widespread rumor? 4 A Moderately. wide -- 5 _MR. RICHARDSON: As your lawyer, I have got to-6 point out that the question does call f or specul'ati on. I. 7 gather you are asking him for.his perception or his opinion 8 as to how many people knew? 9 BY MR. JOHNSON: 10 Q. Yes. You say it was a moderately widespread 11 rumor? 12 A That was my perception of it. .Within the people 13 that'I dealt with day-to-day, several had commented'that Ben
-14 was leaving, he would not say why he was leaving or where he 15 was going to go, and it was rumored tha t he was -in some 16 business relationship with 1,arry King.
17 1,ater on, people speculated that he was in some 18 sort of a job shop operation, but that was a33 idle 19 ' conversation and rumors. I did not consider any of that to 20 be fact or a point that I knew, point of knowledge at that 21 point. 22 O In an interview you gave to, I b e.l i e v e , Mr. Dave 23 Hoffman from the internal audit division of Bechtel in March 24 of '03, you were asked a question, I believe, as it was
. 25 indicated by his notes, along this line, and you suggested to ACE FEDERAL REPORTERS, INC.
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i i t-I' ! 30476.0 l' COX . 52l l f3 l- V.- 1 him, did you not,- tha t the GPU' employee. named Bob Reiter was j l 2 the source of this information? l
- 3 A -Well, Bob Reiter is not a GPU employee.
4 0 Okay. .Who is Hob Reiter?' I 5 A He was the manager of design engineering acchtel 6 : assigned to-me from the Gaithersburg office. 7 Q Did you state to Mr. Hoffman, when you were 8 interviewed.by-.him, that.you believed.at that time that 9 Mr. Reiter was the source of the rumor? 10 A I may-have. I cant confirm whether I did or 11 not. 12 MR. RICHARDSON: Excuse me. Which rumor are we (~ , 13 talking about? 14 MR. JOHNSON: The rumor that we were'just talking 15 about. Okay. 16 BY MR. JOHNSON: 17 Q The original rumor concerning -- when you first 18 heard, that was what we were talking about, May or June '02, 19 that rumor. That's what I was referring to in these notes. 20 MR. RICHARDSON: About some kind of business 21 relationship between Sloan and King? 22 MR. JOHNSON: That's right. 23 BY MR. JOHNSON: 24 Q What did you te33 Mr. Hoffman, to the best of your 25 recollection?
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1 MR. RICHARDSON: With regard to tha t rumor? 2 HY MR. JOHNSON: 3 Q With regard to that specific matter. 4 A A33 I recall te3 31ng ' him was that it had been 5 rumored that Sloan was in some sort of a business 6 relationship with Larry King. I do not recall attributing 7 that rumor to anybody, though I may have suggested it could 8 have been Reiter, it might have been Buchanan, it might have 9 been Austin. I do not recall the details. 10 0 But if.he wrote it down, do you think it's likely q 11 that you said it was Bob Reiter? 12 MR. RICHARDSON: That calls for speculation. 13 BY MR. JOHNSON: 14 Q Do you have any reason to believe that Mr. Hoffman 15 would have written tiown a name that you didn't give him? 16 A No, I have no reason. l 17 Q Why didn't you give this rumor much 18 consideration? You cay it was like3y to have come from the 19 people who worked for you, Bob Reiter or Austin or Buchanan. { 20 What was it about it that led you to think that it was not ; I 21 trustworthy or, wha t have you, credible? , 1 22 A It was not - I had no way of judging whether it I i 23 was or was not credible. It was not backed up by any facts 24 or quotations or statements that I could find a source for. 25 Q Did you pursue it in any way? l l l l l Ace FEDERAL REPORTERS, INC. .' 202 347-3700 Nationwide Coverage 800 336-6646
l J .- 30'76 4 0 -j COX 54 1 A No. 1 l 2 Q Referring you again to-your handwritten note to ! 3 Mr. Kanga, you' note that in September or October of 1982,1 4 Mike Hurley .lef t GPU,- I was told again, probably by Dave j 5 ' Buchanan, that Hurley would not divulge his future 6 intentions, but i t was rumored to' be associated with'
-i 7 Mr. Gloan. l 8 Do you believe the rumor, it was rumored by 1 9 Mr. Buchanan, are you referring to that same information?
10 A I am referring to that I believe it was' Dave 11 Buchanan who told me that. 32 Q Mr. Buchanan told you that it was-rumored that O. 13 .Hurley was associated with Mr. Ben Sloan?
.14 A It was probab.ly Buchanan, as stated here.
15 Q Whoever it was, probably Dave Buchanan, what he 36 . told you, was he reported a rumor to you, or did he report _to 17 you a fact? 18 A He reported a rumor. 19 Q By that time, did you know the nature of the work 20 that Ben Sloan was doing? 21 A No, I did not. 22 Q- On page -- do you have your original to look at? 23 I don't know what page it is. Excuse me. Page 2, I am 24 sorry. 25 There is a discussion that in late 1982 Ken I ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6646
l 30476.0 COX 55 0 hionarons of plant engineering resigned, again surfaced from 1 2 Huchanan and/or Hill Austin, in that he was going to work for 3 some company in which Larry King had an interest. ) 4 Again, did you hear this information from the 5 named individuals? 6 A Either Buchanan or Austin or both. 7 Q What did you hear from them? 8 A That it was being supposed or rumored or that 9 there was some information, the source of which was not given 10 to me, that L5onarons had gone to work for a company that 11 King had an interest in, and I viewed that as a continuation 12 of that same rumor, probab]y source to whatever had started 13 that rumor early in the summer. 14 Q That is what this next statement referred to, "at
'5
. this point I presume that the continuing information flow was 16 routed in a common erroneous statement of unknown origin in 17 the pa s t, and did not pursue the issue."
18 That's what you mean? 19 A Yes, sir. 20 0 If I may just paraphrase the thought then, you 21 believe that this wasn't new information you were receiving, 22 complet.e]y new information, anyway? 23 A That is correct. 24 MR. HICKEY: You said wasn't, did you not? 25 BY MR. JOHNSON: Acn-FEDERAL ReponTens, INC. 202-347-3700 Nationwide Coserage 800-3364M6
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\ - l< 1 Q Wasn't. 2 A Was not completely new information. It was a 3 continuation of the same piece of information that had 4 surfaced in the summer. 5 Q With the new person being involved? 6 A Different person associated with the same rumor. 7 Q Shortly'after the beginning of 1983, after the new l 8 year, did Dave Buchanan come to you with information that he 9 had learned concerning Larry King? 10 A I don't -- 11 MR. RICHARDSON: By shortly after, are you talking 12 about within'a month or a few days? t'~T D 13 BY MR. JOHNSON: , 3 14 Q Within a few days. 35 A So you are speaking of early January? 16 Q Early January. I 17 A Wot to my recolJ ection, no. l 18 Q I am referring to a memorandum written by 19 Mr. Arnold, dated March 21, 1983. It was provided to me in j l 20 discovery. It's a memorandum to the file of several pages. ! 21 On the third page, it contains statements about 22 Mr. Buchanan. I don't know if counsel has it, but I will I i 23 show i t to you. It states that "in ear.ly January, Buchanan 24 was informed that Mr. King was president of Quiltech. He 25 stated that he gave the substance of that information to ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800-336-(M6 l j
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i i Dr. Thiesing in January." 2 You can Jock at that if you like. 'Does that 3 refresh your recollection? 4 A No, it does not. I don't recall having that 5 specific conversa tion with Buchanan. It may well have 6 occurred, but I didn't recall it a c the time I wrote my 7 memorandum of February 26, '83,.and I still' don't. But there 8 were, as you could see from my memo, several indica tions -' of ~ 9 that same piece of information coming forward, or related 10 information. It's possible he did. 3 just never remembered-11 that conversation specifically either in 1983 on that. l . 12 Q Did you have any conversations with Mr. Arnold
- l. \ 13 concerning the chronoloijy thal we are discussing now during 1
1
-14 the period in February or March, 1983?
l 15 A Not that-I can recall, no. l l 16 0 When you'1 earned from Mr. Austin on your business 17 ski trip in early, February 1983 that Mr. Austin was aware 1 18 that Mr. Hur]ey and Mr. Reckart, Sloan and Lionarons had 1 19 departed from GPUN to work for job shop, which Larry King was ll 20 either president or some - or in some other way had a l 21 substantial business interest, did you ask Mr. Austin when he 22 first became aware of this information? 23 A I don't recall asking him that question, though it 24 may have come up in the discussiori.
.- 25 Q Did you ask him the basis for his information?
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L L ( p l' ~30476.0 l COX 58 LO 1 A We, in general, discussed the basis for.that, and l 2 he talked about having been at an American Nuclear-Society 3 meeting in the month of November and running into somebody l 4 who told him that his friends, S30an, Reckart and Lionarons, 5 were working together at the Shoreham plant; and that, l 6 according to Mr. Austin, ran contrary to his understanding of' 1 ! 7 where those people had gone. 8 MR. HICKEY: The witness just said Lionarona. I 9 wonder if he meant to refer to Mr. Hurley, Reckart and 10 Mr. Sloan. I don't think there was ever any indication that 11 Mr. Lionarons worked at the Shoreham' plant. 12 THE WITNESS: Yes, you are right. Hurley, because 13 he is the one that left earlier. Yes, it was Hurley. 14 HY MR. JOHNSON: 15 Q Okay. Did Mr. Austin mention to you on this 16 business trip that he had known this information since 17 November? 18 A Yes, I believe he did. 19 Q Did you ask him why he didn't bring it to your 20 attention ear]ier? 21 A No. 22 Q Had he brought it to your attention earlier? 23 A Not that I can recall. Certainly not in a way 24 that led me to believe that he be.lieved that this i nf ormati on 25 was true. In prior discussions on the subject, the ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 8 5 336 6646
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COX 59 o 1 information was always portrayed as a rumor or.something that-i 2 had been surmised by someone else. And in this conversation,- 3 Austin professed a belief that he was dealing with' facts, 1 4 with something that was really true that was. causing l l- 5 difficulties, in that we were losing some pretty-talented l l 6 people from the recovery organization, and that he felt 7 management was delinquent in not having taken some' action to 8 find out what was~ going on and.stop the process of attrition 9 to this company which he believed was. siphoning off people, 10 resources from GPU. ! 11 0 Did he refer to conversations he had had with 12 Mr. Buchanan growing out of a New Year's Eve party at l 13 Mr. Reckart's? 14 A I don't recal]. I know I have read of that 15 conversation and other documents, and I can't, in my mind, 16 determine whether that's where I learned of that conversation 17 or whether he talked about it. 18 0 So would you characterize the 3;iformation you had 19 gotten from Mr. Austin as different from a rumor? I am 20 taJ king about the inf ormation you were given on approximately 21 October 2, 1983. i 22 A Certainly Austin believed it had moved from the I 23 category of a rumor tha t wasn't substantiated to something 24 that was most likely fact and required management action. 25 The key here was that he had no other organizational O. l l l ACE FEDERAL REPORTERS, lNC. l 202-347-3700 Nationwide Coverage 800-336 4 46
i 30476.0 COX 60 r 1 recourse, if you will, other than up through-the 2 Buchanan-Thiesing chain of command. That's the organization 3 that he was in,Jand I viewed'that'he was saying we have a 4 problem and you, as a member of my management chain,=ought to-l 5 look into yt and solve.it, because it's only going to get 6 worse.
.7 So at that point in time, I told him I would --
8 first of all, I told him that I didn't necessarily believe 9 that that was true, but I wou3d']ook i nto it. I believe that. 10 he felt strongly enough about it that it deserves some 11 attention, and while I didn't tell him this at that' time,.I 12 -decided at that time that the best route was to have Joe 13 Huell, the procurement manager, just run a vendor information 14 survey on that company, which is a rather . routine activity en. 15 their part when they want to procure goods or services from a 16 company that they have not dealt with before;-they look in 17 the utandard procurement register of Dunn & Bradstreet where 18 you can get information about the company, who owns it, what-19 services they provide, et cetera. 20 Go I decided that, while on the trip, probably 21 around the 2nd or 3rd of February, that I would just have Joe l 22 Buell.look into it, without telling Buell what the purpose of l 1 l 23 the request was. l l 2d Q Did you consider Mr. Austin a reliable source? l l 25 A Yes. l' O l 1 1 Ace-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Cmerage 8(Xk336-6646 L____--________. - _ - .
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!COX- 61 1 Q On page -- my version of'this in so obscure _--
2 yes, you are on that page. What page is that? m 3' A Page 3. 4 Q Page 3 of that same memorandum, we are discussing. 5 5. 6 You are discussing five options which you say you 7 considered. You say with respect. Lo the first one, that it 8 would have been irresponsible to ignore Austin's concerns, 9 and then you say the reason is because the: loss of employees 10 were -- concerns regarding'this loss of employees were i 11 widespread within my organization. What were you referring l 12 to when you say " widespread within my organization"?
- l d
13 A Austin's comments, during our conversations around 14 the 1st or 2nd of February, that not only.he but ot.hcrs were 15 -- believed this information to be true, and were concerned i 16 about it. l i l- 17 0 In discussing options 2 and 3 on the same page and- ! 18 the next page, option 2: " communicate the allegations to j l
- i. 19 Bechtel management and seek advice," 3 being " communicate the !
20 allegations to GPU and management for their disposition," you 21 say on the next page, "I didn't feel it ethical to raise 22 suspicion." M y c o p.y i s - i s it suspicions? Suspicion?
'l 23 Next page. I am sorry, you may be missing a page. ;
24 A That's page 4. l 25 0 can I look at it? O l-b ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 6646 i
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L g L i-30476.0 COX 62 1 A Sure.
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I 2 0 -It's hard to see upside down. I am sorry, 3 "auspicions." .It was on the,next page. I 4 A Okay. 5 0 "I didn't feel it ethical'to raise suspicions 6 regarding Larry at this time,-since such suspicions are much 7 easier to raise than dispel." In light of the widespread 8 concern that you just mentioned, how was it that you felt ]
'9 that using either option 1 or 2 would raise suspicion? ,
10 A Do you mean options 2 or 3, which dealt with 11 either turning that information over to Bechtel or GPU 12 directly?
. 13 0 Yes. In light of the fact taatyou knew people 14- within the organization and the GPUN organization were aware 15 of this information?
16 A Well, none of the'-- I was not aware that any l 17 management personnel above mv level, or any management 18 personnel to whom Larry King reported, were at all aware of j 19 these rumors and-possibilities. As far as I was concerned, a 20 it was still a piece of information that was believed to be ] 21 fact by some people in my organization, but which I had no 22 hard evidence or documentation. At that time 3 felt it was I 23 unlikely that these allegations were true. .j l i 24 Hut Austin demonstrated a 3evel of concern that ) 25 was great enough that I felt I had to either determine what l
\ l ACE FEDERAL REPORTERS, INC. i 202-347-3700 Nationwide Coverage 800 336-6646
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l 1 l- 30476.0 ) COX 63 I was going on or in some way dispel his concern by looking up l 2 the identity of this company, which I believed to be called .j
)
3 Quill Engineering at the time, based on what Austin had said, j i 4 and find out who, in fact, did own it, provide that 5 information back to Austin and whoever else in the 6 organization was interested to dispel that. But I really 7 didn't want to bring that information to management's 8 attention, because.I really'didn't think that it wasLJikely 9 that it was'true. j 10 0 You made that decision, you say, during that 11' business trip? 12 A That's correct. 13 Q At the time you made that decision, were you aware 14 of Bechtel Directive 2-1? 15 A Certainly was. i 16 Q Do you know what the directive -- you now 17 recollect what -- s trike tha t. 18 At that' time, did you understand the procedur i es 19 called for in that directive with respect to reporting 20 information concerning unethical behavior of Bechtel 21 employees? 22 A Yes, reporting hard information regarding 23 unethical behavior, yes, sir. 24 Q I am going to refer you to page 2 of 4 of that 25 directive, which is a section called " Relationships with O ace FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6646
l 1' 30476.0 l . COX 64 1 clients, suppliers,.. subcontractors, others." If your counsel l.) '2 has a' copy,.it wou.1d be simpler. 3 HR. RICHARDSON: I think I do. Bear with me. i 4 MR' JOHNSON:
. Okay.
5 THE WITNESS: I have it.
]
6 BY MR. JOHNSON: -l
'7 Q Okay. I am referring you specificallylLo,the 1
8 second paragraph on page 2 there. It says "in situations'in'. . 9 which Bechtel'knows or is intormed by.a reliable source'that' 10 a c3ient/ supplier / subcontractor or other participant,. 11 including a Bechtel employee, in a Bechtel project, is' acting l 4 12 illegally or unethically, a report of any impropriet y should 13 be made to the responsible Bechtel supervisor." Et cetera, 14 then it goes on and says "who, in turn, will promptly bring 15 it to the attention of the responsible division, special 16 operati onal service manager," then proceeds. 17 A Yes. 18 Q You were aware of this paragraph at the' time you j 19 made this decision? 20 MR. RICHARDSON: Wait. 21 BY MR. JOHNSON: 22 Q The decision to go ahead and do the vendor audit? 23 MR. RICHARDSON: Specific wording of the paragraph 24 as opposed to the existence of policy 2-1? 25 BY MR. JOHNSON: ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage IMG336-6646
30476.0 COx 65 O Were you aware of the procedures called for in 1 Q 2 that paragraph that I just mentioned to you? l 3 MR. RICHARDSON: That's a compound question, since l 4 you are talking about procedures. 5 MR. .TOHNSON: Sure. 6 BY MR. JOHNSON: 7 Q Was there any part of this paragraph which you 8 weren't aware of? i 9 A I was not awrtre of the details of the wording in 10 the paragraph. I was aware of the general philosophical 11 requirements of Directive 2-1. 12 Q Okay. 13 A The -- I be.lieve that it required, if I had hard 14 evidence, documentation, or had been informed by a reliable 15 source that he had hard evidence, documentation, or was a 16 witness too, that I needed'to turn that over according to the 17 directions here. 18 The problem was, I didn't have any hard evidence, 19 I had no documentation, and my source of information, which 20 was basical.ly Austin at that time, did not indicate he had 21 hard evidence or documentation or had directly observed. He 22 was quoting - 1 23 0 People who worked with these people? 24 A Third-hand and fourth-hand that he believed to be I l 25 true. I think his reason for be.lieving that was he was ACE FEDERAL REPORTERS. INC. 202-347-3700 Nationwide Coverage 800-336-6646
30476.O ; 66
. COX ?
O 1 hearing it so often. But, in my mind, saying something many 2 times doesn't'make it true. You have to have some firsthand 3 information. I just wasn'.t in possession of any firsthand 4 information. Given the nature of .the effect that information 5 would have, if it was transmitted to Bechtel and GPU' 6 management, I didn't think it was prudent to pass that 7 information on, since I didn't have any reason to believe 8 that 5t was true, other than a serious concern on'the part of 9 one of'my subordinates. 10 0 But you consadered Mr. Austin to be a-reliable 11 source, you indicated that already to him? 12 A In the context that I didn't think.he was the type 13 that would make things up or lie to me on purpose. But in 14 the context of Directive 2-1, " reliable" would mean able to 15 provide documentation or firsthand evidence. I don't believe 16 that I have ever said he was in a position to do that. 17 Q What was the information that he did give you 18 concerning Mr. Hurley and Mr. Reckart working at Shoreham? 19 A That he had been informed at a dinner at the ANS 20 meeting in November that they were working there together, 21' and that fact conflicted with what they had, "they" meaning 22 Mr. Reckart, Mr. Hurley, had, and Mr. Sloan, had told he or 23 friends of his at the time that Reckart, Sloan and Hurley l i 24 Jeft GPU. l l 25 Q You knew that they had Jeft GPU? i ACE-FEDERAL REPORTERS, INC.
.I 30476.0 COX 67-O That was 1 A -I certainly knew they had left GPU, yes.
2 a fact. 3 Q Sure. 4 'A Where they were going was the point at issue, and. 5 Austin was combining the fact that he believed they had l 6 misinformed him about where they were going:with the fact 7 that they were all working together, with the fact that he 8 had heard, from sources that I can't identify, that these
.9 people had become associated with a company that I,arry King ,
10 either was in charge of or had a business interest in, and 11 that set of-very' circumstantial evidence, I believe, pointed l 12 to a problem related to the drain of personne] resources from' N -13 GPU. He believed it strongly enough that I felt that I.ought 1 1 '4 to at least .look into it and dispel it, if possible, or find 15 out what the basis of it was. 1 16 Hut it wasn't hard information. That was clearly 17 lacking. You will note that even the name of the company I ] 18 didn't get direct. I had believed it was Quill Engineering 19 and, in fact, it was Quiltech, one word. 20 Q You were interviewed by Mr. Hoffman-in March of 21 1983. That's correct, isn't it? )
'22 A Yes. 1 23 Q And from - do you have the notes, a copy of the l'
L 24 notes of his interview with you? ll ' 25 A No, I do not. i i ' l ) l l ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80(F336-6646 L_- - --
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. COX 68 O.
1 Q They were provided'to me in discovery. 2 MR. RICHARDSON: I have got them. 3 BY MR. JOHNSON: 4 Q It's eight pages of notes. Do you recall how long 5 that interview was?' 6 A I estimated it'at one to 1-1/2 hours. 7 Q Where did it take place? 8 A In one of the offices near my off. ice. 9 Q Did you speak to Mr. Hoffman'either before or 10 after this interview concerning the interview? 11 A Not that I recall. 12 O Who set it up?
' f* . I believe it was Buzz Bruner.
13 A 14 Q Did you have a conversation with Mr. Bruner 15 concerning this interview prior to the interview? 16 A Yes. 1/ Q What did he tell you? 18 That I was to meet with Mr. Hoffman at some given f A 19 time at some given place. And thal the nature of the 20 discussion was the recent events related to Quiltech. 21 Q Specifically, did he tell you what he expected 22 Mr. Hoffman to be asking you? 23 A No, he did not. 24 Q Did he give you any instructions? 25 A No. O ACE-FEDERAL REPORTERS, INC. 202-347 37(X) Nationwide Coverage 8(Kk336446
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'COX- 69' LO 'l Q ACter the interview, did you speak to Mr. Bruner
'2 'concerning -- immediate.ly after the interview, within a day ;
3 'or so, about'this interview? j i 4 A I have no reco))ection whether I did or did not. .l S Q When the interview commenced, did Mr. Hoffman j l 6 expl ai n to you the purpose of the interview?' L 7 A In general terms, that he was trying to ascertain. [ .
-l
- 8 the fact situation surrounding the events that had recently !
1 9 occurred related to Quiltech. l l 10 Q. Was it any more specific than that? 11 A Not that I recall. 32 O Do you recal) him mentioning the name of Mr. Parks l 13 at the beginning of the interview? 1 14 A I am sure it was mentioned, I don't reca.11 when. l 15 Q Did he indicate to you at any time during the l 16 interview that the purpose of his investigation was to 17 investigate the conflict of interest allegation concerning 18 Mr. Parks? L 19 A Not specifica))y. Ilis purpose was a general l 20 determination of the f act .situa tion surrounding that whole l l j .. 21 issue, I presume, including Mr. Pa rl:s . But other issues were l l 22 dealt with. 23 0 Did he . lead you to believe that anyone other than l l 24 Mr. Parks and Mr. King were under investigation? l
. 25 A W5th respect -- investigation with respect to 1'
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30476 0 COX , 70
'O I what, sir?
2 Q To Qui 3 tech, conflict of interest. 3 A No, he did not. 4 Q Did you discuss with Mr. Hoff. man thei directsve 5 that we have just referred to, 2-1, during the course of this. 6 interview?
- 7. A I don't reca.13 directly,:but I can --
8 MR. RICHARDSON: 1 am sorry, can you read that 9 question back, please. 10 (The reporter read the record as requested.) 11 THE WITNESS: I do not recall whether that'was 12 discussed or not. l._ 13 BY MR. JOHNSON: 14 0 Did Mr. Hoffman ever get back to you concerning. 15 the interview results,'after he was concluded? 16 A No, he did not- . 17 Q Did Mr..Bruner have any conversations with you 18 between the time this interview took p3 ace and the time that 19 Mr. Parks was suspended from the TMI site concerning the 20 investigation? 21 A That would be'between the 10th or lith of March I. 22 and -- 23 Q The 24th of Marcih. l 24 A The 24th of March.' I couldn't say. He probably 25 did, but I have no direct memory of any conversation that I l I ACE. FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage MXL336 4 16
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16 procurement audit that you instigated with Mr. Buell, come g) n
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\ t At one point int time, .pnd I c'p.r ' t pla ce i t ,. but it.
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( .. .. r 1 Bruner. o 31, i 2 0- Mr. Nruner.was your supervisor? N ' ,. O 3 . n 3 A He wa s with h, Bechtel, the person to whom I 4 reported. 5 [- In the.rerlovery organization, I. reported to John I
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J 7 0 InMaee.Sute.hof--letmejustby%up. .Did he B: . ) tell you' anything elztc,' mther than it was th4 preferred c , y ,n ;a w 9 oi course? 10 A No. a 11 i Q .Did he bring up the subject?- 12 cf MR. RICil ARDSON : When did this take' place? I , f. d s 13 ini s s ed that , - !>
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1 15 1.he-date'it took place. ! 16 - MR. JOHNSON: It was in March, s 17 Tile WITNESS , But I efink it was $n the early 18 portion. March, April, May time f;rame. I'wouJd, place it 19 sometime early in the' month of March, but.I can't: testify to 20 the exact date. ' j t 1
- l>
t . 21 MR. RTCHARDSON: A21 right, i'f ~ i 22 BY MR, JOHNSONt, l 23 Q ') During this conversation, did Mr. Brunei. bring up I .
-24 the subject of the directive of 2-]?
b j I 25 A I can'L recall Vight now. j l (
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.s TOX 73 7
'9 N 1 Q Did he connect.his'" preferred course of action" i } , 2 .for this situation with the Dechte) Directive 2-1? 3 A He may-or may not have, but I don't recall whether i o. 4 he d.id~or not.
'5 0 Did he indicate to you any displeasure with the 6 way in which you had followed up'on the information 7 concerning Mr. King?
8 A only to the extent that he wou3d have preferred 9 that'I provide the information to - that I-had received' from ! 10 Austin and Buchanan to him. 11 Q' .Did he say anything to-you or do anything that 4 , j .7 -12 could be interpreted as a reprimand or warning or catition w 13 concerning your actions?- l 5 ": , 14 A- ~No,,not those three words, 15 Q Any other words?: 16 A I think he directed me that 39 further --~if such 17 a set of circumstances were to arise again, I should just 18 turn the information over to whoever my in-Bechtel supervisor
'19 was. I allowed as to how, if it ever occurred again, I will 20 certainly do so.
l 21 0 Did you become aware of any personnel actions with l 22 respect to yourself by Mr. Bruner, Mr. Sanford or others in l l 23 the-Bechte3 supervision h.ierarchy,'related to your actions in l
- l. 24 the investigation of Mr. King?
l l l 25 A No personnel actions, no l O
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... COX 74 JO 1 Q When you left Three Mile Island, what.was the 2 nature of your reassignment, if you would say that again, j 3 please.
i 4 A I wa tt reassigned as manager of nuclear plant 5 support service projects in Hechtc1's Oak Ridge office, and I 6 was promoted one grade. 7 0 When did you f:irst learn about the connection 8 between Mr. Parks and Quiltech? 9 A Probably on the 22nd or 23rd of February, in a 10 discussion I had with Mr. Buchanan and Mr. Gallagher, 11 Mr. Ga33agher vo3unteered that at some point during the , l 12 summer of 1982, that he had noticed that Rose Riddle, who was ! 13 a secretary i n si te engi neering, had been typing resumes'on 14 Quiltech stationery, and she had told him - that is, Rose 15 Riddle had told Mr. Gallagher that she was doing so at the 16 request of Rick Parks. 17 Q Did you ask him what action Mr. Gallagher took at 18 that time with respect to Ms. Riddle? 19 A I don't recall asking him. 20 Q Did he tell you? 21 A Nor do I reca13 him te333ng me that he did 22 anything in particular. I would like to add to that last l 23 response that prior to the February 22 or February 23 meeting 24 with Buchanan and Gallagher, it had not been even suggested 25 to me that Parks might have been i nvolved with Quiltech or 1 i Ace-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 6646 l- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ . _ . _ _ _ _ _ _ . _ l
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30476.0 , COX 7S ! tO : 1 that .he might have been involved with wha tever organization 2 these engineers.were going to when they..left GPU. 3 MR. RICHARDSON: If it'is' desired to become-4 involved with the cafeteria, the. time is approaching. 5 MR. JOHNSON: All right. 6 (Whereupon, at 12:22 p.m., the deposition was 7 recessed, to be reconvened at 1:05 p.m. .this.same day.) -
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8 I 9 10 , 11 l l 12 l IO 13 a 14 i 15 4 i b - 17 'f I 18 ! i 19 : 1 20 21 22 l 23 24 O l l. L ACE-FEDERAL REPORTERS, INC. l~ 202-347-3700 Nationwide Coverage 800-3364M6 l
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COX 76. I l' ' AFTERNOON SESSION (1:05 p.m. ) 2 Whereupon, .- 3 JAMES W. THIESING. J
'4 resumed the stand and, having been previously duly swo.t'n, was? !
5 examined and testi fied further a's follows: 6 EXAMINATION (Continued) j
.]
7 HY MR. JOHNSON: i 8 Q Dr. Thiesing, I have, over the few minutes we have 9 had since lunch, I was looking over this document that was 1 10 given to me It's confidential 3, design engineering's 11 comments on R.D. Parks' affidavit. IL says " attachment to 12 REOE-0383." 'I 13 A Yes. 14 0- Could you give me some background when this was , 15 prepared and what it was attached to and who prepared it? 16 A I believe you have a copy of the memorandum that 17 it was attached to. It's the one with some pencilled 18 handwriting on it. There i t is. These go together. 19 Q Okay. Let me just identify it for the record. 20 Excuse me. It's an April 22 letter, 1983, to Mr. Lorley from 21 Mr. Reiter. l l 22 A Yes. This was a memorandum with attachment that 23 was either solicited by Mr. Corley from Mr. Reiter or 24 vo]unteered by Mr. Reiter to Mr. Corley. Mr. Cof]ey was , 25 Mr. Reiter's functional reporting point within the O-. l Ace-FEDERAL REPORTERS, INC. 202-347-37(K) Nationwide Coverage 8(X)-336-6646
,30476.0' 7f 1 .Gaithersburg office of Bechtel'at that time. I am not sure. q 1
2 when I came into possession of a copy of it, but it was 3 sometime in 1983, and it discusses some of the issues.in.Mr. l 4 Parks' af fi davit. 5 Q It's got kind of a tabular aspect to it. 'It'says 6 paragraph"'in one column and the next says " design 7 engineering comment." Those are paragraph numbers of-the g 8 ' Parks affidavit of March 23?. 9 MR. RICHARDSON: I think no foundation has been
'10 laid as to whether he prepared the affidavit. Are you.asking.
l l 1 Il for his understanding of.the document? l
- j. 12 BY'MR. JOHNSON:
l - I' L . . l 13- Q That was one of my questions. I take it you did l 14 not prepare this document? l [ 15 A 'I did not prepare th't a document. 16 Q Reading it, though, it looks as if Mr. Reiter, in 17 connection with a few other peop]e, maybe Mr. Jackson, ~j i l 18 prepared this document. Is that your understanding? j 19 A That's my understanding. . l- J 20 Q The reason I say that, certain points it says "I," 21 then Reiter in parentheses, and in certain other places it
.22 was "I and Jackson" in parentheses. Do you know anybody else 23 who participated in the preparation of this document?
24 A No, I do not. There may have been. I am just not i 25 aware of it.
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I 30476.0. 1 COXl 78 -j O Is it' correct, then, to. assume that these 1 Q
'2 paragraph notations are references to.the Parks-affidavit of ;
3 March'21, 1983? i 4 A They are, but I don't know how to - break the code.- l 5 In other words, I don't know how to correlate the numbers 6 with this af fidavit. 7 Q That .was going to be my next . question, because -- ] 8 MR. RICII ARDSON : Is that an assumption on your !
'9 part or did somebody te)) you th'at?
10 THE WITNESS: It's. an assumption on my. part. 11 MR. RICHARDSON: Nobody wants.you to guess or 12 speculate, 13 BY MR. JOHNSON: 14 Q I.was having difficulty correlating the comments 15 with the affidavit, since the af fidavit doesn't have numbered 16 paragraphs. I just was going through it, and perhaps~I may 17 have a few questions, but it's difficult, since 2 can't 18 relate it directly or easily to the affidavit itself without. 19 some study. 20 Have you recent]y read this document? 21 A No, I haven't. 22 O You once read it? l
'23 A I don't think I have ever sat down and read the 24 entire document word for word. I have read par ts of it and l .n 25 looked at it, but I don't th. ink I have ever read the whole i V ACE FEDERAL REPORTERS, INC.
30476.0 COX 79 L 1 thing. 2 Q With regard to this handwritten note. that 'is from 3 Bill Adams to Chuck Sanford on the cover letter, who is Bill 4 Adams? 5 A He was at that time and still is the manager of-6 engineering for what is now called Bechtel Eastern Power 7 Corporation here in Gaithersburg. He was the man to whom 0 Chuck Corley reported. 9 Q What does OR stand for? 10 A Quality engineering. 11 0 That's a designation of Bechte]? l 12 A That's.a Bechtel designation.
.g 13 Q Did you review this document in any way at the 14 time it was prepared, approximately?
15 MR. R3CHARDSON: Wait. Are you referring to the l l 16 handwritten note at the bottom? 17 MR. JOHNSON: Yes. i J 18 BY MR. JOHNSON: 19 Q The handwritten note and the document, it seems, 20 were prepared the same day, April 22, 1983. Did you review l 1 21 - you said, previously, that you don't reca.11 when this 1 l- 22 attachment came into your possession. Does tha t apply also j 23 to the Jetter?
- j. 24 A That's correct.
l 25 Q Did you have any role in the review of the ( ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide CoveraFe 8(Xh336 6646 f L_-___-----_-_---------- l
l 'i i l l i 30476.0 ) y ., COX 80 .j LO 1 1 comments? 2 A .No, I did not. l 3 Q I would speculate that at.some point this was in i 4 the records.of Mr. Sanford, since it's a handwritten. note and- .. q I- 5 this is the original.from Hill Adams toLChuck.Sanford-on:the ! 6 letter. Did you inherit Mr. Sanford's files? ? 1 ( '7 A No, I did not. I really don't know how I came j s 8 into possession of that, especially since it has that 9 ' handwritten note to Chuck Sanford on it. .It was just in my 10 ' file when I went back to' review what I had in light of your l 11 . notice of deposition, and so I pulled it.
.12 Q Thank you. I appreciate.that.
13 MR. IIICKEY : If you are done with that, may: I see-14 it. 1 15 BY MR. JOHNSON: 16 Q Now, this document here appears to.be two: - i 17 different documents appended to each other. This is the l 18 first page, they are all handwritten pages, two pages it 19 seems to me have appeared elsewhere. I rec.ollect discussing 20 it in the Chwastyk deposition. I 21 The second two pages are block printed. It says 22 " File, polar crane." At the top it says "Thiesing, Pastor, l 23 I,a k e , Ila ns on , Ra d bi l .1, Parks, Warren." Jn the right it says 24 2/28/83. It appears to me to be notes that are referred to , i 25 in Mr. Parks' affidavit concerning this premeeting for the O l 1 ACE FEDERAL REronTEns, INC. 202-347-3700 Nationwide Coverage 800-33MM6 L_1_____________---__--___ __
l 1 l 30476.0 COX 81- j 1 readiness review committee. Is that your understanding of , 1 2 what those are? j 3 A That's my assumption, but I.cannot state with
- 4 absolute confidence who wrote these, but it certainly appears 5 to be the notes of the readiness review meeting held on.the.
6 28th of February. i 7 Q Flipping over to the-first page, it appears to'be 8 comments directed by someone to the-text of the Parks March 9 21, 1983, affidavit on that meeting. Does that seem to b'e J 10 correct as far as you are concerned? 11 A- That's correct. 12 Q Do you know who prepared those notes? 13 A I believe they were prepared by Ken Pastor. 14 Q Did Mr. Pastor give these notes to.you? 15 A I be33cve he did. My memory is that they were 16 prepared at his initiation, because he had read things in the-17 Parks af fidavit that dealt wi th his handling of meetings and 18 minutes thereto that he, Pastor, disagreed with, and he was 19 volunteering information that he felt would set the record 20 straight. 21 O Was the Parks affidavit circu3ated among the 22 people in your department at Three Mile Island for similar 23 types of comments? 24 A It was circulated. I remember having copics made 25 tor a variety of supervisory and management people in ace FEDERAL REPORTERS, INC. i 202 347-3700 Nationwide Coverage 8(K)-33M646 i- - _ ____ __ _ ____ _ _ ._
4 30476.0 COX 82 L.O 1 recovery programs.. I did not elicit' comments or request 2 comments from Mr. Pastor. I don't personally remember 3 requesting" comments from Mr. Rei!;er's organization, but l 4 several people volunteered, at their own initiation, to 5 provide comments, because they read things in Mr. Parks' l 6 . affidavit that they disagreed with or felt needed
.k 7 clarification,=and I have come into possession of those, l 8 because they-were either given to me or I was copied on a-9 memorandum or something of that nature.
lL 10 0 Referring back to this first document'and - 11 attachment I referred to that had this cover letter of April 12 22, 1983, if you would look through therc,- would it be 13 correct to -- then you could take your time in answering'-- 14 would it be fair to say that these comments, uome of them,. 15 are in. agreement with Mr. Parks' s tatements and others -are l l 16 disagreements? 17 MR. RICHARDSON: I would interpose an objection. i 1 18 There is no foundation laid as to whether he answered that i 19 question. He has testified he didn't prepare the document, i 20 and as to the wording of the document, it speaks for itself. 21 DY MR. JOHNSON: 22 Q You may answer the question if you can. 23 MR. RICH Ah 6'.ON : No, I am going to instruct you 24 not to answer that question. If there is a particular 2S wording in the document, Mr. Johnson, that you have reference
.O l l
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l 30476.0 COX 03 O 1 to, you can point it to us and I will let him read the 2 document and he can give you his understanding of what it 3 means if he teels that, based on the English language, he has 4 a comfortable understanding. But I am not going to let him 5 answer a general question as you just posed. 6 BY MR. JOHNSON: 7 Q I am showing you another document that was 8 presented to me that I have seen before, confidential 9 memorandum on Bechtel North American Power Corporation 10 stationery to Mr. Bruner, from you, March 2, 1983. Would it l-11 be fair to characterize this memorandum as a typed version of 12 the handwri tten memorandum of 2/26/03 that we discussed 1 0 v 13 earlier? 34 A Typed ani shortened a Jittle bit, yes. l 15 Q Thank you. Did someone instruc t you to have a 16 typed -- have the earlier version typed and edited, or 17 something? 10 A Yes. I was requested by Mr. Kanga to direct a 19 memorandum summarizing the contents of this memorandum to 20 Mr. Bruner, because he was my functional reporting point in 21 the Hechtel organization. l 22 Q Okay. Did you have any discussions with 1 23 Mr. Sanford in the period March to June 1983, concerning 24 either Mr. Parks or Quiltech? 25 A Not that I can recall. l l l ACE FEDERAL REPORTERS, INC. 202-347 37(K) Nationwide Coserage 8(Kb336&46
'30476.O COX 84 1 MR. RICHARDSON: I am sorry, Mr. Johnson, during-2 what period of time?
3 MR. JOHNSON: I think I indicated from March to 4 June. 5 MR.' RICHARDSON: A31 right. 6 BY MR. JOHNSON: 7 0' On another document,. which has at i ts head, 8 " interview with Bill Austin," May 18, 1983, 10 : 0 0. 'a . m . , 9 there's this same memorandum attached to it that.I just 10 referred:to, March-2, 1983. But'it.has some handwriting. Is 11 that your handwriting on there?
.12 A No, it is not. ^f' ,
13 Q Do you know whose it is? 14 .A N o ,- I do not. 15 MR. RICHARDSON: George, here is Mr. Thiesing's 16 business card - 17 MR. JOHNSON: I have it. 18 MR. RICHARDSON: Send him the transcript. 19 MR. JOHNSON: Yes, sure,-thanks. 20 BY MR. JOHNSON: 21 Q Do you have a copy of an interview of Dr. James 'l 22 Thiesing by Dean Aulick, May 20, 1983, from Dr. Thiesing's 23 office? Let me back up a second. 24 Do you recall an interview with Mr. Aulick, do you I 25 reca.11 Mr. Aulick? O ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 L_________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
i I-l 30476.0 COX 85 1 A Quite frankly, no. Can you put an organization L 2 with him? 3 Q I believe he was an attorney-working with 4 Mr. Stier in the investigation that Mr. Stier was doing into 5 a))egations in 1983 at Three MiJe Island. 6 A What was the date of the' interview?' 7 Q May 20, 1983. 'It was at 1:30 in the afternoon in 8 your. office, according to this note. 9 MR. RICHARDSON: He was a blond-haired guy, sort i 10 of --'I don't want to say heavyset guy -- stout? Il THE WITNESS: No, I don't have a mental picture.of 12 that. 13 MR. RICHARDSON: A33 right. 14 THE WITNESS: But'if you show'it to me, perhaps I 15 can -- i 16 HY MR. JOHNSON: 17 Q Okay. I would just like to ask you about some 18 information that he appears to have recorded as a result of 19 this meeting with you. In relation to the source of the 20 inf ormation that you had about King and Sloan, and I will 21 show it to you, he indicates that either -- that Bubb>i 22 Marshall, or Walter Marsha.13, was a source of information, 23 and that that information about King and Sloan had come from 24 Tom Morris. Would you look at page 3 and see if that f 25 refreshes your recollection about that subject. 1 ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 8(0-3364M6 i
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, . :COX 86 i f.. 1 1 A I have no memory of the conversation, but.I
'2 certainly won't dispute that it'probably occurred. Thi s' 'was -
3 . well af ter the time f rame tha t we have beenL discussing, and 1
=4 .this occurred on.May 20. 'And since the March 1983 time ]
l' 5 . frame, I have picked up, either through reading transcripts,. 6 or having been told by people, a lot:of additional
.7 -information.regarding what happened then. .I don't' remember .,
8 this conversation. ~ Hut I don't -- but I suspect it probably. ; 9 . occurred. . But I.am quoted as having said that I only.came 10 .into. possession of that information in the April, perhaps 11 April 15 to 20 time frame. A few days before this interview 12 took place. l
- p ;
; 13 MR. HICKEY: Actually, I think.the interview is. j
- I 14 dated'May 20.
i 15 THE WITNESS: May 20, I am sorry. 16 MR.-RICHARDSON: .Within the last couple of days, 17 isn't it? 18 THE WITNESS: Yes, May 17, 18, 20, something like 19 that. 20 MR. RICHARDSON: 1,et the record reflect that we 21 are hearing the sounds of spring. 22 HY MR.' JOHNSON: 23 Q I want to go back to this vendor audit and the way 24 it was done that you asked Mr. Buell to do, t o investigate 25 whether Mr. King was, in fact, a principal in a job shop O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
30476.0 l COX 87 LO 1 called Quill or Quiltech or what have.you. As part of that, 2 was it your understanding as part of thht work that 3 Mr. Buell, or whoever was working with him, would be 4 requesting information directly from individuals invo]ved 5 with Quiltech? 6 A Let me correct that first part of your statement. 7 I didn't ask Buell to find out whether Larry King was-8 involved with Qui] tech or Quill Engineering. I asked him to 9 do a standard vendor survey. I told him this company might 10 be a source of startup engineers, which we were utilizing at 11 TMI and which Bechtel in general was in short supply of in 12 the 1983 time frame. I asked him to find out who.they were, (3 v 13 what they did, what services they provided, where they were 14 headquartered, who owned them. From the standpoint of, in 15 his mind, I hope, just doing a routine survey on a potential 16 vendor's services. 17 Now, the intention at that time was to find out, 18 either confirm that King was not associated with that 19 company, which I really thought was going to be the outcome, 20 or that the company didn't exist, which I also thought was a 21 possible outcome, or -- and I considered it a lower 22 probability outcome -- confirm, as has been alleged, that he 23 was involved with a company that was hiring individuals away 24 from GPU. , 1 25 So I didn't tell him about Larry King or what was
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I i 1 l 30476.0 COX 88: f O I just told him to do a vendor information 1 suspected. 1 l' 2 survey. I-did that because I didn't want to promulgate a l l 3 ' rumor or induce him to do something that would be;outside of I 4 his normal ethical course of-business in checking in the l In fact, he l-5 public record - to find out about a company. 6 finally found Qui.itech by. checking with the Virginia j 7 Corporation Commission through public records. 8 I did not intend ' f or him to deal directly with [ 9 Quiltech to secure information, though, in the routine' course 10 of things, once they locate the company; and I should have 11 known it at the time, but it never occurred to me, they will l 12 contact the company directly and say will you send us a t 13 brochure, fliers, resumes or whatever other information you-14 have to tell us about the services you offer. That was the l 15 nature of the contacts that were made with people associated 16 with Quiltech. I had not anticipated that those contactu l-17 would be made, however. 18 0 But you did start this process by which ; l 19 procurement people would go out and secure information as far 20 as - well, let me start again. 21 You say you did not tell Mr. Buell the true 22 purpose of your request? 23 A That is correct. J 24 Q Therefore, if he went out and tried to confirm the L 25 personnel who was involved in this organization, which you i l ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage MXb336-M46 l
l' l J 1 L 30476.0 l COX 89 Oi 1 did ask him to do, it might have led him into' personal 2 contact with some of these individuals; isn't that correct? 3 MR .- RICII ARDSON : Could you read that question l L l l' '4 back, please. 5 (The reporter read the record as requested.)' 6 MR. RICHARDSON: Are you asking him with regard :to-7 his state of mind at the time, or whether, from an objective, 8 scientific point of view, that is a possible chain of 9 events? 10 MR. JOHNSON: It wasn't a very artfully phrased 11 question. I apologize. 32 BY MR. JOHNSON: 13 Q What I really wanted to ask you was whether or not 14 it would have been a reasonable assumption that given the 15 directions you did to Mr. Buell, that he would have contacted 16 individuals involved with Quiltech, if he could find them. 17 MR. RICHARDSON: Same objection; by reasonable-16 assumption, do you mean reasonable in terms of somebody who 19 was familiar with what procurement, the procurement 20 department does with regard to vendor surveys, or reasonabic 21 in terms of whether Mr. Thiesing knew at the time, or from 22 whose point of reference? 23 BY MR. JOliNSON: 24 0 I am thi nking of Mr. Hue] 3 's poi nt of ref erence, 25 not yours. In your opinion, wouldn't it have been reasonable O ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Cmcrage Mn.336-6646
l-lj 30476.0 l/ . COX 90 1 behavior on Mr. Buell's part to have contacted people in ! .2 - Qui} tech if he could find them? 3 MR. RICHARDSON: I don't mean to be obstreperous, 4 but with that being the. qualification, I think the-question 5 calls for speculation, since there is no. foundation as to 6 this witness' personal knowledge concerning Mr. Buell's frame ! 7 of mind'at the time. 8 THE WITNESS:- At the risk of -- may I just tell 9 you what I thought, notwithstanding the nature of his 10 question? 11 MR. RICHARDSON: Yes. 12 THE WITNESS: I did not, at the time I asked Buell 13 to carry out the vendor survey, anticipate that he would make 14 -- attempt to make direct contact with the company, one can 15 argue, in hindsight, that I should have anticipated that he 16 would. 17 My personal opinion is, in hindsight, that it was ! k 18 quite reasonable for him to. I asked him to find some 19 inf ormation f.or me on the basis that I might be interested in 20 securing services from that company, and in my opinion it's 21 not unreasonab3e that he did on the basis of that direction l I 22 attempt to contact Quiltech directly. Obviously if they are j 1 23 interested in selli ng their services, that would be the most I 24 direct way of acquiring the information. 25 But the facts are, I did not anticipate that he
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-1 would. What I' wanted him to do was operate in his normal .,
2 course of business, not to do anything that was outside'of-3 his normal course of business and dealings which I could 4 presume, since Hechtel's procurement organization is pretty 5 highly disciplined and regulated within the company, that he 6 would operate in a way that was above board, ethical and 7 appropriate. 8 So, in summary, I did not anticipate that he would 9 contact him, but in hindsight it's not unreasonable to think 10 that he would have contacted them. I think it was an 11 appropriate move, given what he knew about the situation. 12 HY MR. JOHNSON:
.fh 13 Q In your opinion, would it have been a conflict of 14 interest for Quiltech to have accepted an of fer for a job at 15 Three Mile Island if offered as a result of this 16 procurement?
17 MR. RICHARDSON: I -- 18 THE WITNESS: Let me ask for the clarification. 19 MR. IIICKEY : You can go first. 20 MR. RICHARDSON: Let me interpose the objection. i 21 THE WITNESS: Go ahead and interpose the 22 objecti on . 23 MR. RICHARDSON: Well, the question is not clear 24 as to what you mean by " conflict of interest," if the term 25 arises out of a policy, whose policy are you talking about; O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 4 46
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. COX 92
.O 1 although-I don't think-this is the case, the way you frame 2 the question,.it suggests that Mr. Hue)) .may have made such 3 an offer, but that.'s-a premise this witness has not 4 affirmed.
5 Now, I wil] leave it'at that. With regard to the. 6 las t series of questions and answers, can we -- I think the-7 two of you have been loosely ref: erring to Mr. Huell as having 8 made these direct contacts. I think we all undersLand them. 9 In fact, a Mr. Blizzard, under Mr. Due31's direction, made
-10 the contact.
11 THE WITNESS: That's true. 12 MR. JOHNSON: Sure. 13 THE WITNESS: To clarify, may I volunteer some 14 factual information? 15 DY MR. JOHNSON: 16 Q You'may. 17 MR. RICHARDSON: Yes, you may. la Tile WITNESS: There was never any intention to 39 offer contracts for goods or services to Quiltech if it 20 turned out that Mr. King or other people who had been 21 associated with GPU or TM3 held a major interest in that 22 company. 23 BY MR. JOHNSON: 24 Q Did you communicate that to Mr. Buell? 25 A No, but I did not. authorize him, and by Bechtel's x ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 8(X)-336-6M6
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.COX' . 93 O
1 procedures, ho is not authorized to make any offers to those.- 1 2 peop3e when he makes a contact. All he is authorized.to say-3 'is that we might'he interested in securing, can you provide 4 information. That's, exact 3y speaking, not an of fer tci j 5 provide or to secure services. l-l 6 Had i t turned out, as I quite frank 3y anticipated, 7 that either the company didn't exist, or more importantly the 8 company existed but King and other GPU people were not l 9 involved with it, it might have provided a source of startup 10 engineers to Bechte), and those. people were in great demand-11 at that point in the history of the nuclear industry. So if 12 they had not been involved, we might we)) have, either at TMI 13 or in some other context, of fered to procure services from 14 them. Hut. there was never any intention to of fer to procure 15 services from them if the outcome of the investigation was-16 that King or somebody was involved. 17 Q As part of the outgrowth of Mr. Buell and 18 Mr. Blizzard 's inqui ri es , you got a report back from 19 Mr. Buell, I guess it was. I have seen that document, I 20 don't know if it's in this pile or not, in which certain 21 informa tion was -- I think it's attached to those things, i 22 that certain information was acquired, and among those things 23 was an account given by Mr. Blizzard of his conversations 24 with, oh, somebody he t.hought might be Mrs-. King. 25 MR. RICHARDSON: We have it right here.
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-1 MR. JOHNSON: I. don't. I was kind of foundering a l l
l 2 ]ittle. bit here. If I could just find it. Thank you.. i 3 BY MR. JOHNGON: j 4 Q Okay. .I was thinking about this document.which is f 5 dated February 23, 1983, and it's to Mr. Buell'from , i 6 Mr. Blizzard. Thank you. This.is part of this?'.Yes,'I- , L ., 7 thought so. ! j 8 It does indicate an item 15, 16, 17 andI18 on 9 pages 2:and 3, that there were attempts and contacts'were l 10 made, one with a woman who advised that -- strike'that. 11 On the last page, several calls were'made, ! 12 received a cal] made from a lady made to Hode, who said she 1'
\. '13 had:been talking.to Hode, et cetera; 18, received call at 14 5:00 p.m. from same lady, I think she saidlher name was King,.
15 but I am not sure. 16 Wou3d you read through 18 there and any.other part 17 of the memorandum that you like before I ask you the next-18 question. 19 A Yes.
?,0 Q This memorandum was transmitted to you by this 21 personal confidential memorandum from Buell to you dated 22 February 24, 1983; isn't that correct?
23 A Yes. 24 Q So you became aware of. this information on 25 February 24, 1983. Did you - ACE FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Coverage 800-336 4 646
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=COX 95 O-Q 1 MR.. RICHARDSON: I don't think he has affirmed 2 that.
3 BY MR. JOHNSON: 4 Q Did you? 5 MR. RICHARDSON: Did you receive it the same day i I 6 it was dated? 7 THE WITNESS: I.did not receive it the day-it was 8 dated. I received it some few days after February 23, and I 9 cannot place the date. 10 BY MR. JOHNSON: 11 0- Okay. The memorandum is dated February'24. 12 Did you make - did you try to contact Mr. King or. ;
.13 Mrs. King, either directly or' indirectly, to indicate'to them 14 that there was- no' intent to draw them into a conflict of 15 interest? ;
16 A I personally? 37 Q Yes. 18 A No. i i 19 Q Did you instruct Mr. Blizzard and Mr. Buell to do , 20 so? 21 A No. May I ask -- i 22 MR. RICHARDSON: Wait. Just answer the question. 23 THE WITNESS: All right. 24 BY MR. JOHNSON: ) l 25 Q Was it your understanding f. rom this item 18 in ! ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage MK)-336-6646 w__ _- _--___-_ _ -_ - _ _____a
a-130476.O COX- 96' 1 this February 23 memorandum, that Mrs. King or the person 2 identified there interpreted. the inquiry by 'Mr. Blizzard.as 3 such an attempt? 4 MR. RICHARDSON: Could you read that question S back.
-6 (The reporter read the record as requested.)
7 MR. RICHARDSON: I am no't sure I understand the 8 qu es ti on . The question is whether Mr. Thiesing interpreted 9 March 18 as indicating that Mrs. King interpreted 10 Mr. Blizzard's inquiry as an attempt to draw Quiltech into a 11 conflict of interest? 12 MR. JOHNSON: That's correct. 13 BY MR. JOHNSON: 1 14 O Do you.. understand the question? 15 A I unders tand the question.
)
16 O Can you answer the question?
- l. 17 A The answer is no, I did not understand item 18 to 18 imply that Mrs. King was objecting to Bechtel or believed 19 Bechtel was attempting to draw them into a conflicts of l 20 interest. Furthermore, there was certainly no intention of j l
21 drawing them into a conflict of interent. 22 O Getting back to your discussions in February with I o 23 various people, I think your February 22 or 26 memorandum and l 24 the March 2 version of it referred to your conversations with 25 Mr. Gallagher, Mr. Ruchanan, and is giving you information i l Ace-FEDERAL REPORTERS, INC.
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.1 concerning what they knew about Quiltech. In conjunction ;
I 2 with your discussions with Mr. Buchanan, did Mr. Duchanan , i i 3 give you any notes? l 4 A. No. Not that I.am aware of. i 5 Q On the second page of the typed version, the March I 6 2 Bruner memo, "I' called Dave Huchanan into my of fice..on . 7 February 22." 8 MR. RICHARDSON: Wait, second page? We can't find 9 it, i 10 MR. JOHNSON: Yes, second page. Sorry. Last 11 paragraph. 12 BY MR. JOHNSON: O)
%. 13 0 so in connection with those statements that he 14 made to you, he did not give you any documentation?
15 A No. 16 Q Notes of any sort? 17 A Not that I can recall, no. I am not in possession 18 of any. 19 Q Okay, thank you. A memo was produced from C.W. 20 Sanford to Buzz, I think that was Buzz Bruner, was produced l 21 to me in discovery, and it refers to you. I would like you l 22 to look at it. It says "here is the Thiesing/ Blizzard 23 account of what went on." Talk to Bauman, Arnold and King. l 24 Talked to Bauman, Arnold and King to meet this afternoon -- 25 what wi)) come of that-remains uncertain. Bauman to .let un 0 ACE-FEL)ERAL REPORTERS, INC. 202-347-37fK) Nationwide Cmerage 8(Kk336 6646 O--____----________
I 30476.O. COX 98 O Have not heard'from Loomis as yet. Depending on what 1 'know.
'2 comes of the Arnold / King meeting, and Loomis's views -- one 3 of the opt. ions we may have to consider if this confrontation 4 continues to esca. late, is how to separate Bechte) from 5 Thiesing's actions -- or Thiesing actions. This might mean 6 temporary suspension, et cetera. We'll see."
7 Do you want to look at that for a second. 8 Do you know what Mr. Sanford may have . Wait a 9 second. Do you know who Mr. Loomis is? 10 A Yes, I do. 11 Q Who is he? 12 A He was the division counsel for Eastern Power 13' division of Hechtel. 14 0 Do you know what Arnold / King meeting is being 15 referred to here? 16 MR. RICHARDSON: Objection,. cal]a for speculation, ! i 17 no foundation laid. It doesn't indicate what he was 18 referring to in the note. ] 19 BY MR. JOHNSON: 20 0 Has anybody showed you this note before? 21 A Recently, yes. l 22 Q I don't want to delve into attorney-client ) 1 23 relaLions, but was it your attorney? 24 A Yes. 25 Q Hack in 1903, did anybody discuss this note with O 1 1 ACE FEDERAL REPORTERS. INC.
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l.- 1 you? i 4 - a 1 , 2 'A< No, they did not. 9 '
,rf, n H, g 9 , NQ) 3 ,Q Were. ym aware that I aold and King were meetpng ' d 1, s , ~Y 4 in February, 1983,.jameframe?
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5 A I was.awapt of a meeting tist had been schedule 4,1 . j i <. 3 4 t s., > l 6 yes. h. g/, y
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7 0 What was that meeting,.as far asiyou anow?. ! l- 4 h. l V 8 A Well, I only became aware of that.after the time v.
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j 9 that Larry had been suspended, and at soug po, int in time'I .
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t.' l was told by someone who.I can't identify, ii may have been in 10
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11 an open meeti ng,' or it m,[; havepm on. a one-to-oqc, gtdit a- , 1 12 . meeting between Arnold and-King was scheduled ct,some point
., g. or 13 in time. I don't know much mor(Yabout ! it tp.n that.
Y ( 14 Q ff) youdon'tknowwhhr$c chen aubs{ance of ' the j , , i p}(J1 d 3 15 meeting was? L , j]t ;31 ,
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16 A Not firsthand, no. \ > ..
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7 17 O Second, die you havo other than~firothand s
, t 18 information about the subjb.-A cf the meeting? .
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-19 A I have read vari 7us NRC(rd; rtr, the Stier lI '
l' 20 investigation, summary report, et ceteta; and to the extp' utf si4 21 that it describes what happened in that meeting, and 3 haVe g 22 been exposed to it, but I don't have a memory of what those,. 6 23 things said. ' ji 'k 3 24 Q You had more contact with Mr. Bruner than you did 25 with Mr. Sanf ord ,' I a time; is that colrect? ' O < T
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'l A Tttat is correctsat[this point' in time, sure.
- 2 O' If there is goin@ 1.o be a commisnication between
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v Hk. Sanford and Mr. Bruner ori"the subject of a cond).rontation . 7 3 j 4 that was inherent in the situation that you identifiers;i;t
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- 5 would have been presented to you.by Mr..BrutperQrather,the.n
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' ' l 6 Mr. Sanford?
7 .MR. RICHARDSON: Don't answer that question.
\ '
8 That's calling for sheer speculation.
- 1 i ; ..
'9 BY MR. 40HNSON: 33' ,
10 Q Did Mr. Brun$r bring up the subject of the 11 escalation of a confrontation between site operations or TPU 3 e 12 on the one hand and Becheci ot)the other, with respect, to
.O 13 charges or the information, Jet's say, that Mr. King was 14 involved in hiring away people' t' rom GPU? '
15 t A Nut that I recall, no,
.f ,
16 , Q To the best of your. recollection, during Lne 17 period of February to June, I N3, did Recht.el management'
't 18 above you take any actions that you would consider to be j g.
19 distancing themselves from you with respect to your role in J I 20 this investigation?
'21 A No, they did not.
22 Q Did you attend a meeting on March 23, 1983, well, 23 I guess it was called or chaired by Mr. Arnold and Mr. Kanga 24 with the TMI-2 staff, which Mr. Parks' going public was 25 discussed? O ACE-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage WU- 1 6 16 __ _____.__.i__....__._.________..________._
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0: Yes, I)did. 1 .1 g , A . l l: 2 Q What;do you recall'about-that meeting?' 3 MR. RICHARDSON: I gather you are'asking-if he l l ~ l
~
4 recalls about-what'was'said? There is a physical' setting - -- .I I lF . S BY MR. JOHNSON' nia t 6 Q Sure. I-would,like to know everything. Do.you / 7 remember where it was-held? El A- It was' held'in one-oflthe two big conference rooms 1
,, J i 9 ~l' that were near Mr. Arnold's. office or.near Mr. Kanga's office l
?
l 30 in the TMI-2 adm. ministration building. It included management. 2 d personnel from a broad spectrum of departments within'the
, 11 h 1
1 12 1 TMI-2 organization. Mr. Arnold indicated that Parks had
- 13 released an af fidavit and was about to -- and was going to 34 hold a press conference or was going to hold a press l
l ' 7 ,. 15 conference arid they expected some . written material. I don't g . 16 know exactly what the chronology was.. He indicated that GPU
, '17 would-be making a public statement in response.to that press i
18 conference. l 4 19 0 Were you-seated at this meeting or stand _ng? j 20 A I don't recall. 1,- 21 Q Were you able to hear what went on? 4 27. A I certainly can hear what Bob Arnold said. mn m 1 23 0 lio you recall Mr. -- do you recall some discussion 24 among the various parties, including Mr. Kanga and Mr. Barton f 25 and perhaps Mr. Arnold, concerning what actions to take with - 'O l ,iJ I L .. . . ,
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3'0476.0 ! COX- 102 EO' 'j I resp'ect to Mr. Parks in consideration of his going public? i L 2 A The on.ly thing I can firm 3y remember is Kanga .)
.i P 3 cautioning the group that Mr. Parks was engaged in' protected l l: !
4 behavi or, or protected actions, from the standpoint of i 5 Department of Labor and NRC regulations. I guess it's
- 6 Department of Labor that establishes those regulations,.and.
7 that we should be somewhat circumspect in our dealings within l- and be sure not -to do anything that violated his right to ! 8 9 engage in that protective behavior, which is bringing a 10 safety concern regarding a regulated industry, to the
,i L.. 11 attention of the regulator.
l' 1 12 Q Did you say anything at this- meeting? l l 13 A I don't believe so. 1 14 -Q Did you take any notes at this meeting?~ 15 A I am pretty sure not. 16 Q Did you go to this meeting with anybody in-17 particular? 18 A No. It was only a few steps from my office. I 19 just got up, left my office at the time of the meeting,
'20 walked into the meeting room.
21 Q Do you recall there being a discussion concerning L 22 whether Mr. Parks should have access to the protected area? 23 MR. RICHARDEON: To the what? 24 HY MR. JOHNSON: l- 25 Q First of all, could you define for me what l ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide CoveraFe 800-336-6646
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'COX- -103 o
O l- 1 " protected area" means with regard to the TMI-2 site?' H L 1 l -2 A It's a' regulatory concept which defines a boundary
'3 within which the important but_not critical. systems of the 4 nucJear power plant are enclosed. Access tci that area _ is 5 limited to-people who'have, number one, been properly l- 6 trained; and, number two, have passed some' cort of a l 7. background investigation or other determination of their ] \
l 8 trustworthiness and whether they might be expected to take i l 9 so.ac unreliable action'. The protected area at TMI is-l 10 basically the' fence that runs'alongside of the road'that runs l 11 north and south along the plant. It's a fence that goes all i 12 the way'around the perimeter. 13 Q If someone were denied access to the protected' 14 area, he certainly could not perform any functions with j
.i 15 regard to - well, let's put it this way. T.et's back up a l
I 16 second. ! i I 17 Could Mr. Parks have performed any of his ] l l 18 functions if he were denied access to the protected area? 19 A Oh, yes, he could. 20 Q Where could he have performed them? l 1
'21 A His offices were not inside the protected area.
l l- 22 Q I see. The protected area would have included the l l_ 23 reactor building? l 24 A That's correct. 25 O The auxi)iary building, contro3 room? 1 1; l ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6646 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ]
l.1 30476.0-COX 104 Oi Turbine building, the control' room. 1 A 2 Q But.not the administration building? 3 A Not the administration building. 4 0 Is that where he was or was he in a trailer or
.5 something?
'6 A He was in a trailer adjacent, right across the 7 road from Unit 2 on the' west side of the' plant.
8 0 Would restricting him from the protected area.have 9 interfered with his job, the performance of'his duties? 10 A Probably not greatly, given what he wasldoing at 11 that time. 12 Q And what was your understanding of what.he was
'13 -doing?
14 A . Reviewing procedures, reviewing safety 15 evaluations. 16 0 In other words, not entering the containment 17 building or anything like that on a regular basis? 18 A Would not have overwhelmingly restricted his j 19 abilities to do his job. 20 0 Do you recall a discussion.of that sort concerningl
.21 whether to restrict Mr. Parks from access to'the protected 22 area?
23 A I remember such a discussion having occurred. I 24 can't definitely place it at this particular meeting, but it 25 may have been at this meeting. I ace FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Coverage Mn336-6646 ] 1 ___ y
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- 1COX 105 ll 1 MR. RICHARDSON: The question uses the word ,
.2 " protected area." Do you' recall a discussion concerning a 3 pr<.,tected area as you have just defined it?
4 -THE WITNESS: I remember such a discussion 5 occurring. I can't~ place it at this meeting. It may have - 6 occurred at this meeting.. I just can't say.with surety. - t 7 BY MR. JOHNSON: =l 8 Q With respect to Mr. Parks? 9 A' With respect to Mr. Parks. 10 0 Okay. Do you recall Mr. Barton making any profane: 11 statements at that meeting? 12 A. No, not directly, I dcin ' t . 13 Q Do you remember-him having an opinion about 14 Mr. Parks' behavior? 15 A I can't, no, not specifically at that meeting. I 16 don't have-any direct memory-of him having said anything. He 17 may have, but it wou3d have been an.aside.
.18 Q So you don't remember him saying that Mr. Parks 19 should not be allowed back on the Island?
20 A Not directly at that meeting, no, I don't remember 21 him saying that at that meeting. 22 0 But you recall that he said that at some point? 23 A No, I don't reca.13 him ever having said it. It l- 24 doesn' t mea n he didn' t say it, I just don't recall having 25 heard him say it. ACE-FFDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage MO-3364646 U_ _ _ - - _ _ _ _ _ _ - - _ - _ - _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ - _ - _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ . _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _
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' COX . 106 D
V 1 Q In connection with.Mr. Kanga's statement, that'.you
.2 recall'him saying that Mr.. Parks had been engaged in-3 protected activity, and, therefore, management should proceed 4 cautiously-with respect to what it did, do you recall any S discussion concerning the. disposition of Mr. Parks in terms-6 of -his employment on the site?
7 A .No, I do not recall any specific discussion of 8 that. Perhaps if'you couJd be more specific I?cou]d be. 9 Q- Sure. Do you remember Mr. Kanga.or a13vbody else 10 saying that one couldn't just transfer him off the site or 11 fire him, because he was involved in protected activity?. 12 A WeJ1, I don't know the specifics of it, but Kanga 13 did talk about the fact that he was involved'in= protected 14 activity and that he - I think he kind of brief ed people on 15 what the implications of that were. The person has a right 16 to bring safety concerns to the - to a regulatory body, and 17 the individual's employment is-not to be impaired solely 18 because he brings ~ safety concerns to the attention of a 19 regulatory body. 20 0 Did Mr. Kanga say other things that you don't 21 remember? 22 MH. HICKEY: Pardon me? The question is whether 23 he said other things that he doesn't remember? 24 MH, RICHARDSON: The question more or less answers g 25 itself. ace-FEDERAL REPORTERS, INC. I 202-347-3700 Nationwide Coverage 800-336-6646
30476.0 COX 107-1 BY MR. JOHNSON:
,2 O Let me put'it another way. Was that all'that 3 Mr. Kanga said at this. meeting?
4 A It's all that I remember him saying.
'5 Q Did you have any discussions with any of;the 6 people in~your department concerning Mr. Parks' ' affidavit 7 directly after this meeting of March 23, 1983?
8 A Well, there were lots of discussions about 9 Mr. Parks' affidavit. 'Whether I had one directly after-that 10 meeting, there is no way I could-pinpoint-it that 11 accurately.
- 12 -Q _ Were you interviewed by Mr. Barton on that day in:
I O 13 the afternoon? 14 A Interviewed? 15 Q Wel], did you have a meeting with Mr. Barton? 16 A I have no memory of that. May have. I.-have no J 17 direct memory'of that. His office was one door away from L 18 mine. 19 MR. HICHARDSON: Perhaps if you could describe the 20 subject of the~ meeting you have in mind. 21 BY MR. JOHNSON: l l 22 Q Sure. Do you have any recollection of Mr. Barton l j! 23 conducting a series of interviews on March 23, 1983, in the 24 af t :rnoon? ! l 25 A Not direct 3y, no, not that I can place on March l 1 i j I I ace FEDERAL REPORTERS, INC. I 202-347-3700 Nationwide Coverage 800-336-6646 4
30476.0 COX- 108.
~'( i 1 23,' interviews of whom, perhaps if I knew of whom.
2 0 Well, of Mr.-Chwastyk, Mr. Marshall, Mr. Perry, 3 Smith. 4 A Those'are plant operations-people who were at that
'S period of' time regularly in and out.of Barton's office, 6 particularly since Barton became the acting director of. site 1
7 operaLions at the time Larry was suspended, that group of
)
8 J peop]e that you. mentioned; and others.from plant operations 9 were regularly in and out of his office, and I' don't know the .; l 10 nature of those meetings. J l~ 11 Q Did you have any discussions with any of the-12 people on your staff during the days'immediately following 13 this meeting, March 23, about working with Mr. Parks, it he l 14 should come back to the Island? l l 15 A No, but I can't pinpoint any s.pecific 16 discussions. By this. point in time, and shortly.thereafter, l 17 Mr. Parks made numerous rather vocal allegations, including a 18 stint on a local radio talk show, where he made what I 19 thought were some rather outlandish accusations about myself 20 and others. I have little doubt that 3 said it would 21 certainly be difCicult to work with him, after that. He 22 alleged on this talk show that I had been taking radioactive l 23 sewage and dumping it into the storm sewers in Highspire, f i 24 Pennsylvania, under the cover of darkness. I am here to ] 1 25 testify that that is not true. I don't think anybody of ) ACE. FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6646
'30476.O COX 109 ?
1 reasoned judgment of TMI and what went on at TMI would think' 2 it was true. 3 ' Hut I was being accused of that. Other people 4 were-being accused of nefarious activities which-they did not S believe they had carried out either. So I remember the 6 general tenor of things was going to be it's going 1to be real~ 7 'hard to work with him if he comes back to the Island, because 1 That talk
^
8 .you never quite know what he was going to say. 9 show went on for an hour and a half or two hours and covered 10 a large number of people and a large number of subjects. 11 Q Do you remember the host of the show? 12 A Freddie Williams. e 13 Q You were told by Mr. Gallagher, I think it was 14 approximately February 22, that he told you back in.the 15 cummer of 1982 that Rose Riddle had typed some resumes for 16 Mr. Parks; is that correct? 17 A That's what I understood him to say, yes. 18 Q What did you perceive at that time to be the 19 significance of that information? 20 A Well, I think it was a strong implication that 21 Rick had been working with or for I,arry in the development of-22 the Quiltech organization in some way.
)
23 Q That was based on just the information that 24 Mr. Gallagher told you that was - that he had given some 1 25 resumes to Mrs. Riddle or Ms. Riddle to type, and it was to I ace FEDERAL REPORTERS, INC.
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. COX 110 i
.1 -be typed on Quiltech stationery? l 1
2 A . (Witness nodded head.) ]
.i 3 Q Any other information? You are nodding yes? .]
4 A I am nodding'yes. q
.5 Q- Any'other information?
6 A No. ,; 7 MR. RICHARDSON: Wait a minute. 'It isn't a bit 0 clear. You asked him for what significance he saw'in the ;
)
9 information which you received from Mr. Ga]1agher, are you?
.10 MR. JOHNSON: No. He answered that question. !
11 MR. RICHARDSON: Okay. 12 MR. JOHNSON: Then I was asking him whether he-5 13 based his conclusion or his evaluation of.its. significance on 14 any information other than what I just said. 15 MR. RICHARDSON: Oh, I see. 16 THE WITNESS: No, I didn't. But keep in mind that 17 I- I don't recall having quoted a conclusion or an 18 evaluation to anybody when that information was passed l' 19 along. If you will look at the memorandum, the two Inemoranda 20 I wrote, which really represent the summing up of everything l 21 I knew about the situation, I passed on the information that 22 Gallagher said that he had observed Rose Riddle typing
- l. 23 resumes or had been told by Rose Riddle that she typed 24 resumes on Quiltech stationery at Rick Parks' direction.
l 1 25 That's merely a statement of perceived fact, and I don't l ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-3364M6 l
i l 30476.0
- COX 111 {
1 recall having made any particular conclusions from that that i 2 I passed on to somebody. I made some mental conclusions in. i 3 my own mind. But I passed the information along just as .l l-
. 4 stated.
l l 5 BY MR. JOIINSON : 6 Q Did you.have any other information that indicated 1 l l > 7 to 'you that Rick Parks was . working f or Qui 3 tech or wi th j 8 Quiltech? l 9 A No, I do not. That wan'the first time and the -l 10 only time. It was the only time up to that point that I had 11 had any indication that he was aesociated with Quiltech, and- ) i 12 I did not receive any other firsthand information related.to 13 that after that discussion with Gallagher, although other l 14 information that was developed was developed by other people, 15 and I only became aware of it secondhand or by reading ) i 16 transcripts. 17 0 Was Rose Riddle somebody who worked in your shop? l 18 A She worked as a secretary in a site engineering 19 organization in my shop, yes, j j 20 Q Did you attribute any significance, ethical l 21 significance, to her typing the resumes? 22 A Not ethical with respect to her personal behavior, 23 no, because she was carrying out a direction that was given 24 to her by somebody that she perceived to be her superior in 25 the organization. ACEJEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 8(Kb3364M6 1
30476.0 COX 112 j 1 Q Was Mr. Parks her superior? ! 2 A Not directly, but could have been perceived by her 3 to be. She was a group secretary and they take instructions 4 from a Jot of people. 5 Q But was it your - was the information that you 6 got from Mr. Gallagher that Mr. Parks had directed her to do j s 7 this typi ng ? 8 A Ei ther directed or requested. I have heard from 9 somebody, it may have been Gallagher, that he paid her to do 10 it after work, a litt.le extra work after work. "I will pay 11 you to type some resumee." 12 Q Apart from the Qui 3 tech context, is there anything
/;
C/ 13 unusual about u .3ecretary doing such typing after work, 14 before work? 15 A Not particularly, no. As long as it didn't occupy 16 the company's resources or GPU, the client's, resources, no. 17 0 Did you have any reason to know one way or another 18 whether Rose Riddle was involved with Qui] tech? 19 A No, I had no reason to know one way or the other. 20 Q Did you have any dealings, once Larry King left 21 under his suspension, on February 24, 3983, with 22 Mr. Chwastyk? 23 A Yes, sure. 24 Q What kinds of contacts did you have -- maybe we 25 could bracket this by saying when did Mr. Barton actually l l l l l ACE FEDERAL REPORTERS, INC. I 202-347-3700 Nationwide Coverage 8(6 336 6646
1 30476.0 COX 113
-(3 l
%) l
, 1 take over responsibilities as acting site operations 2 director, if'you can recall?
3 A My. memory is at the time of Larry King's .l
)
4 suspension, then at some 3ater date, either right after or 5 sometime after' Larry was ultimately removed from the company, 6 that job was given either permanently or in an acting sense 7 to Joe Chwastyk. In that context,.I had a lot of' interfaces i 8 with Mr. Chwastyk, because'he was. functioning as the. head of ! 9 the site operations group. And,:as I have said before, there 10 is a requirement for a lot of dialogue and interplay between. 11 those'two organizations for work to get.done at TMI. 12 0 I don't know if it's'that important, but I don't 13 think what you said is strictly correct. My understanding of 14 what happened was that temporarily Mr. Chwastyk was acting ~ i 15 site director and then after about a month, Mr. Barton was-16 officially designated to that position, but I don't think 17 it's of great consequence. 18 A I have the order inverted. 19 Q You think what I just said is probably correct? 20 A It certainly could be. I don't have a clear 21 memory of it. At one time Barton was and at another time 22 Chwastyk was. If you have hard information, I am willing to l l 23 accept that. 24 0 Okay. I don't think it's crucial for the l . 25 ques tions . Did you have any discussions with Mr. Chwastyk D l , L ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage MO 336-6646 L________.____.____
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, COX 114 l=
l l 1 between February 24 and May of '83 concerning Mr. Parks? 2 A Nothing that is significant enough that I <* a n 3 recall it, no. l 4 Q Did you become aware, during that time period, 5 that Mr. Chwastyk had some involvement with Quiltech? 6 A Not duri ng that time period, no. I didn.'t become 7 aware of that until after I left TMI. My memory'is it'was in 8 the summer of 1983 or ear]y fall of 1983. 9 Q You left the site in June, and I believe 10 Mr. Chwastyk left shortly after that. Are you aware of any 11 of the circumstances of Mr. Chwastyk 1 caving the site, 12 . leaving the employment of GPU Nuclear?-
- p I have second- or third-hand information is all,
%/ 13 A 14 hearsay.
15 Q What is that? 16 A I was told that someone who had left GPU called 17 somebody in the GPU management chain and indicated that he 18 had been promised employment with Quiltech, such employment 19 had not materialized, he was interested in coming back to 20 work for GPU and, oh, by the way, did you know that Joe 21 Chwastyk had given a presentation on Quiltech's behalf in the 22 fall of 1982. l 23 Q Do you remember when you got this information? 24 A It was afLer I left T.MI. I 25 Q Did you rely on any information from Mr. Chwastyk j ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
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30476.-0 COX' 115 ~ 1 with regard to the King /Quiltech connection in connection. 2 with your gathering information? 3 A 'No, I did not. 4 MR. RICHARDSON: .Could you read that question and 5 answer back, please. 6 (The reporter read the record as requested.-). 7 BY MR. JOlf NGON : 8 0~ Did you have any conversations with Mr. Kanga in 9 March, 1983,.with regard to Mr. Parks? 10 , A' None of any significance. I was notified, 11 probably in meetings, of various actions and considerations: 12 that were being taken with respect to Mr. Parks. Maybe by 13 Mr. Kanga, but I was not a consultant, or.I did not consult 14' wi.th Kanga with respect to what action Becht ei woald or would 15 not take with respect to Parks. I did not consult with him 16 regarding information that he was developing regarding the 17 Parks situation. After the 23rd of March, I was a spectator 18 with respect to the Quiltech/ Parks issue, other than the 19 normal day-to-day interface that we had. 20 0 Were you instructed in that r..ard? 21 A No, no. It was just an issue that had been passed 22 up the chain. Other people were taking care of it, and I had 23 a job to do. I 24 O At any time before the meeting of March 23, 1963, 25 in which Parks' going public with his allegations was made ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 3364M6
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l l- -l 1: .30476.0 116 [ p .. C O X 1 'known, did you have any discussions with either Mr. Kanga or. j l 2 Mr. Chwastyk or Mr. Kitler concerning al. legations by
'3 Mr. Parks of harassment?
l l .4 .A No. I -- 1 5 Q Discrimination? 6 A Dis crimi na ti on, no. I recall being. Informed that 7 Parks had had a meeting with Chuck Sanford wherein he asked 8 for assurances that his employment with Bechtel would not be 9 hazarded by virtue of his going to the NRC with safety i 10 questions. I remember seeing a copy.of a letter which Chuck 11 Sanford sent brick to Parks on that subject. I remember being 12 . informed by people that included Kanga, that was in the
' (.O) 13 meeting, that Parks was going to have a press conference, 14 that he had released an affidavit, and I remember being.
15 informed by somebody that he had been, after his' press 16 conference, and after he had been written up in the New York 17 Times and in television, that he was being placed on leave 18 with pay, and restricted from the TMI site until such time as 19 all these issues were finally resolved. But I was not
-20 consultative, I was being told what was happening.
21 Q Okay Did you have any other discussions, other 22 than the one with Joe] Wiebe on approximately February 24, is 23 my recollec tion, concerning Mr. Parks? 24 A May I ask for a c.l ari f i ca ti on . Did I have any 25 other discussions with Joel Wiebe? O-ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 8(Xb3364M6
p I. ll ~ _130476.0'- COX: 117 1 Q No, I didn't make-it clear, I am sorry. .Did you 2 have any .other discussions or interviews with the NRC other 3 .than -- about Mr. Parks. l 4 or his concerns or allegations other-than the S conversation we discussed earlier, which you,had a. call, a l 6 telephone call with Mr. Wiebe? l .
'> 7 MR. RICHARDSON: Is your question limited.to the 8 period prior to March 23?
9 BY MR. JOHNSON: 10 0 Okay, up until' March 23. 11 A No,--I did not. 12 Q. But you were interviewed on one or more occasions 13 .by the NHC subsequently? 14 A That is correct. 15 Q On page 672 and -73 of your deposition to 16 Mr. Stier, you discuss this incident in which you say that 17 Mr. Parks was reviewing containment entry procedure at the 18 behest of someone not yourself., and that he feels reviewing 1 19 the wrong procedure and some more discussion about what you 20 didn't care for in the procedure that he wrote up. Do you 1 21 recall that testimony? 22 A Yes, in general, I do. 23 Q Do you recall what it was that led to, in'your 24 opinion, that he was looking at the wrong procedure or using 25 the wrong procedure? 1 ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-(M6
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.. 'COX 118 p
L (% J. 2 1 A Well, as I recall,'we were in the process'of 2 creating a revision to that procedure to procedura.lize 3 certain requirements that the NRC program office at TMI had And to make a general 'administra'tive revision l 4 laid upon us. 5 to that procedure. There were'several versions or revisions .l 6 in an attempt to revise that procedure, and the one he was- 1 i 7 using was severa1' versions old and become out.of date in a context of where we were going with that procedure. ] 9 Q- Was it,.in a significant way, out of date? 10 A Yes, but I don't remember in what manner it was 11 out of date. 12 0 Did the problems that you had with what he came'up 13 with ultimately have to do with that matter, that i t was.. the 14 wrong procedure? 15 A Well, no. They really dealt with the fact _that 16 we, in recovery programs, in developing that procedure and 17 the overall protoco.1 of how we were entering the containment, 18 had made certain commitments to the NRC that we would do 19 business in a certain way, that we would use a command 20 center, that the NRC would be informed in writing of the 21 content and the nature of all entries into the containment. 22 That they would have right of review and right of disapproval 23 of proposed actions during the entry, t ha t a.1.1 documents 24 describing those proposed actions would be delivered to the 25 NHC no .less than 24 hours prior to their implementation, and a ace-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 800-336-6646
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m. i 30476.0 COX 319 0 1 that any changes or additions would be telephoned to the NRC 2' and their concurrence sought prior to making any. changes. 3 The procedure that Parks proposed tended to. 4 abrogate'many of those commitments and did not contain 5 requirements to make these notifications'to the NRC. 6 -Q Were they in the procedure that he was working'on? 7 A Those commitments were in the procedure that - 8 some of them were in the procedure that he was working on, 9 and he had proposed-to delete those commitments. Others had 30 been added as this procedure was being revised over a-period l 11 of a few days to make it consistent with the protocol we were 12 following within the NRC. Some were. not in- the early versiori 13 of the procedurs that we were working,with, and others he had 14 deleted. 15 Mr. Parks desired to operate with much more 1 16 freedom of action from the NRC with respect to what was done in the containment and in a much more business-as--usual 17 18 approach. 1 19 0 It didn't have anything particularly to do with j
\
20 site operations access, just access in general? i 21 A We3J, just access in general. 22 Q What was the ultimate resolution of this? It 23 seems to me I remember from your deposition at the time you a 24 left that it still had not been finalized? l 25 A I don't know that it has ever been finalized, but !
- l. ;
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30476.0 COX 120 1 we continued to operate according to the basic set of 2 protocol requirements that had been given to us by the l 3 NRC/TMI program office, and'that they wanted,certain 4 documents'and they wanted certain things in place and they 5 wanted to operate through a command center, et cetera. 6 MR. JOHNSON: I would ask that eitherwe' copy 7 these before I leave, or you arrange to have.them copied, or l
- ' 8 I will take them with'me and send you back the originals.
9 MR. HICKEY: Perhaps if we have them copied 10 overnight you can pick them up in the morning. 11 MR. JOHNSON: That would be fine. 12 MR. RICHARDSON: All right. d 13 MR. JOHNSON: Thank you very much. I have no 14 further questions. 15 MR. RICHARDSON: I just have one question. Ile 16 . mentioned something I didn't remember. 17 EXAMINATION 18 BY MR. RICH ARDSOti: 19 Q Mr. Thiesing, a few minutes ago I believe you 20 indicated that you recall seeing a letter from Mr. Sanford to 21 Mr. Parks in relation to Mr. Parks' allegations of 22 harassment. My question is, are you reasonably certain that i 23 you saw such a letter? 24 A We)), I am not -- I remember a letter going back, ! p 25, and it may have been a letter that Andy Wheeler sent to Parks k (J l ACE FEDERAL REPORTERS, }NC. 202 347-3700 Nationwide Coverage MXb336 6646
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COX '121 D u 1 'a few days after his meeting with Sanford. 2 EXAMINATION 3 BY MR. JOHNSON: 4 Q Was that the letter that .can 3 go ahead? 5 MR. RICHARDSON: Go ahead. 6 BY MR. JOHNSON: 7- Q Was that the let ter tha t informed Mr. Parks that 8 he was suspended with pay? 9 A The one that Andy Wheeler sent was that letter, 10 yes. That may be the.one I am thinking about. I' remember a 11 letter was sent from Parks to somebody in Bechtel and a 12 letter went from Bechtel back to Parks. My guess is.I more f)
% 13 probably should have ascribed that-letter to Andy Wheeler.
~
14 Q Could you get a copy of the Bechtel disposition of 15 the Quiltech charges against Parks? 16 A I don't know. 17 Q There was a document that I think came'in in the-18 deposition of Mr. Bruner, I think it was Pace and Brush were 19 the names I associated with that memo. 20 Do you remember that? e 21 MR. RICHARDSON: I would be happy to show it to d 22 him if you like. l 23 THE WITNESS: Sure, do you want to show it to me? 24 MR. JOHNSON: Sure. . l l 25 THE WITNESS: I didn't see that. j l_(,x ) l U ACE FEDERAL REPORTERS, INC. ) 202-347-3700 Nationwide Coverage 800-336-6646
l 1 30476.0 COX 122
-)
.)
1 MR. RICHARDSON: I will have to'put my hand over a 2 privi.leged feature of this thing, which was a memo from S.M. 3 Pace to H. Brush dated March 24, 1903. 4 Tile WITNESS: No, I have never seen that before. 5 MR. JOHNSON: That's all. Thank you very much. i 6 So you are wasving signature on this? 7 MR. RICHARDSON: Yes. 8 (Whereupon, at 2:45 p.m., the deposition was 9 concluded.) 10 11 12 (O .) 13 , 14 15 16 17 18 19 20 21 22 l 23 24 25 4 1 ACE FEDERAL REPORTERS, }NC. 202-347-3700 Nationwide Coserare MG3364M6
CERTIFICATE OF NOTARY PUBLIC & REPORTER' 123
.'VA' I, WENDY S. COX , the officer before whom the foregoing deposition was taken, do hereby certify .that the witness whose testimony appears in .the foregoing deposition was duly sworn by me; that the testimony of said witness was taken in shorthand and thereafter reduced to typewriting by me.or under my direction; that said deposition is a true record of the testimony given by said witness; that I am neither counsel for, related to, nor employed by any of the parties to the action in which this deposition was taken; and, further,
, that I am not a relative or employee of any attorney or O\ counsel employed by the parties hereto, nor financially. ,
i or otherwise interested in the outcome of the action. Notary Publicxin and for the DISTRICT OF COLUMBIA My Commission Expires November 14, 1987 1 ( l
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May 5, 1987 I Wendy S. Cox Ace-Federal Reporters, Inc. 444 North Capitol Street Washington, D.C. 20001
$9 3JR.* fM Re: In the Matter of: GPU Nuclear Corporation (Three Mile Island Nuclear Station, Unit No. 21'
Dear Ms. Cox:
Enclosed please. find four pages of editorial and substitutive corrections which Mr. James Thiesing has made to the transcript of his deposition which was taken on April 8, 1987. s very truly ours,
.d~4 Kennedy P. Richardson KPR/ law cc: James W. Thiesing J. Patrick Hickey, Esq.
George E. Johnson, Esq. 1
T~ . . J. Paca/Line Currantiv Raads Should Read [~ 8/8 Nuclear engineering. supervisor.
. . For five years, I was Nuclear engineering iL accident analysis supervisor.
*~
11/4 net know Mr. Parks, I not know Mr. Parks. I i 12/8 Ultimately . . . Bob Ultimately . . . Bob Seider. Rider. 13/24 engineering organization. engineering And . . . organization, and 16/2 . . . until the -- . . . until sometime sometime . . . . .. 17/12 believe . . R. L. Reiter believe. . . R. L. Rider . 20/15 Well, the general -- I I do remember . . . do remember. . . 21/4 he became a rather. . . he became rather. . . 27/18 Because when I . . . When I . . . 31/21 reside inside reside in site (,,/ 31/24 level 3 and is a level 3 startup startup 34/6 No. It was unrelated to No. It was mostly
-- related . . .
34/9 would not be paid; it . . Would not be paid after a year; it . . . 34/19-20 No, I did not. He didn't No, I did not. He work for me, though. . . didn't work for me. any -- I wasn't in . . . I wasn't in . . . 35/11 THE WITNESS: Not -- I THE WITNESS: I remember . . . remember. . . 36/22 . many people . . . him. many people . . . him: That. . . that. . . 39/5 request. . . hin. And request . . . him. The 40/9 channels with . . in channels of . . . site with site 40/14 said I can help you with said can you help with
Paco /Line Currently Raads Should Read 4 can't identify, j'~' 42/3 can't identify, . . . was kind of an . . . was kind of a . . . L g 42/14 up this company . . . up this company . . . shop people . . . shop GPU people . . . 43/1 Because procedural . . . Because the procedural { 43/2 at TMI . . . at TMI . . . organization. One . . . organization, one . . . test working . 45/13 . . . test work . . . . . .
. test working. . .
45/16 . . . test work . . . . . 49/17 The -- but at the . . . But at the . . . him, . Bob Reitner . him, . . . Bob Rider. . 52/1 . . . 52/3 Well, Bob Reitner . . . Well, Bob Rider . . . 52/4 Okay. Who is Bob Reiter? Okay. Who is Bob Rider? He was . . engineering He was . . . engineering 52/5-6 .
' Bechtel -assigned to me assigned to me from the from the Gaithersburg Bechtel Gaithersburg . .
Mr. Reitner . Mr. Rider . . . ( 52/9 . . 53/8 Reiter Rider 53/19 Reiter Rider 53/22 It was not -- I I Mike Hurley . . . Mike Horlihy. . . 54/4 Buchanan, that Hurley . Buchanan, that Herlihy 54/5 .
. souce to . of that . sourced 55/12 of that . . . . .
to . . . 57/11 that conversation. . . that conversation . . . either in 1983 on that . . either now or in 1983. that Mr. Hurley . that Mr. Herlihy . . . 57/18 . . wonder . . Mr. Hurley wonder . . . Mr. Herlihy 58/9 . THE WITNESS: . . . right. THE WITNESS . . . right.
/~' 56/12 I Hurley, . . . Herlihy . . .
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58/13 he it! . . . Hurley. heisb.x g Herlihy. / .. 7 _3 (v ) 60/7 no at . . . (Delete entire litte) 60/P first of all . . . First of all . . .
)
60/10 he felt . . . deserves . . he felt . . . deserved
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s' 62/16 Well, . . . -- I was I was . . . i 62/21 fact . . . , but which I fact . . . , but about
. . . which I . , . .
( I belje e . I-65/13 The - . . . I believe .,. >t !, , 65/16 witnestfi too, Witnesssto, s/ s ,
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66/18 Hurley y ,Merli$y
, g 66/22 Hurley Herli$y h' s ,
66/23 Hurley I Herlihy 3
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67/18
'dirtet - rorrect \/ ,r- 68/6 I estimated . . . I estimate . . .
t ( 72/14 THE HITNESS: I can't, I THE WITNESS: I . . . 3 72/18 portion. March, April portion of the March,I'
... April, . . .
. 9 73/9 ' ttn t I provide . that informatica to --
' inf oratinnI provide that5 .; gk. . .
that.'. .) '* s 73/14 No, riot chose Yhree No, not those words.
- l words. ,
73/16 I think . . . that in I think . . . that if / further -- if . . . . . . h, g. i
- T 76/21 Mr. Reiter. Mr. Rider.
was either . !. k 76/23 was either . . . .- i from Mr. Reiter. . . from Mr. Rider q . , ,
, 3 s
volunteered by Mr. / 76/24 volunteerJ3 by Mr. Rider . . . \ ; Reiter . , , . s
~
l (l' '[N-4 76/25 Mr. Reiter's . . . Mr. Rider's . . .
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\ / l 77/16 Reading .7 . .Mr. 7e 1 br'.i . Reading. .
. My Ritter ;
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- 1 i 1 Pace /Line Cuitently Reads Should Read
. ML, l requesting . . Ib: . requesting. .
9 82/3 '
.l Reiter's . . . Rider's . . .
l Bechtel., . conflicts Bechtel . . . conflict f 96/19 . of of
,, i I certainly can hear. . . I certainly could hear 101/22 that we . . dealings that we . . . dealings l 102/7 .
With him . , . ! within . . . 102/9 engage in that protective engage in that protected 108/15 No but, I can't . . . / I can't . . . approximately . . that approximately . . . . 109/14 that back-in . he told you back'in . . . . 109 (NOTE: Answer following question beginning ou line 13 of page 109His correct only in response to the question an edited above.) 111/14 ,information that was information that was , developed was developed by . . . , developed by . . . 9 111/18 She worked . site . . .
. . in a She worked the site .
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somebody, it may . somebody, it may . . . 112/9 . . Gallagher, that he paid Gallagher, that he (Rick Parks) paid . . . laid b;oc as. And . laid upon us, and . .. 118/4 . . '}}