ML20238C579
| ML20238C579 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 02/10/1987 |
| From: | Morris T BECHTEL NATIONAL, INC. |
| To: | |
| Shared Package | |
| ML20238C505 | List:
|
| References | |
| CIV-PEN, EA-84-137, NUDOCS 8712310096 | |
| Download: ML20238C579 (86) | |
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;- UDITED STATES OF NIERICA
\ UUCLEN! REGULATORY COMllISSIOD l
-------__----_-__---------___x j In.thc' Matter.of : Docket No. 50-320 GPU Nuclear Corporation : (Civil Penalty)
(Three Mile Island Nuclear : License Do. DPR-73 j
, Station, Unit Mo. 2) : EA-84-137 i R' :
1 1 1 ), Testimony of THOMAS E. MORRIS TAKEM: 100 Brown Street February 10, 1907 b !!iddletown, Pennsylvania 2:30 p.m. 1 IT IS HEREBY STIPULATED by and between the attorneys for the respective parties that. all objections, except as I (' to the form of the question, shall be reserved to the time
. of trial.
l i i 1.[ I ') ( I!ONICK STENOGRAPHIC SERVICE, INC. 1413 Old Mill Road Hyomissing, Pennsylvania 19610 I' (215) 375-3931 ) g;_, k Gwen A. Leary, Reporter f 87120/10096 871209
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-THELEN, MARRIll, JOHNSON & DRIDGES Attorney for GPUN-One-Eaiser. Plaza, Suite 1950
-Oakland, California: 94612 y BY: JEUMIFER A. KUEUSTER, ESO.
I SHAW, PITTMAli, POTTS & TROh' BRIDGE Attorney.for GPUN 'j 2300 N Street, N.W. Uashington, D.C. 20037 1
'.BY: J. . PATRICK !!ICKEY, P.C.
I Office of General Counsel for-the Attorney for NRC MRC Staff M.S. 9604 MNBD U.S. IIRC a Washington, D.C. 20555 l BY: GEORGE E. JOHNSOM, ESO. I BY: . CHARLES A. BARTH, ESQ. ,j
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'3- duly sworn by Gwen A. Leary, Notary Public, was 4 . examined and testified as follows:
5 6 EXAMINATION BY.MR.. JOHNSON: 7 Q I am^ George Johnson, counsel for_the , 8' NRC staff in the civil penalty enforcement 9 proceeding involving GPU Nuclear Corporation 10 arising out.of allegations made by Richard Parks 11 of discrimination'under 10 CFR Section 50.7. 12 WithEme is Charles Barth, also from the NRC 13 ' staff. 14 And, of course, you know the' counsel 1 15 on;your side of the table; -but for the record, I 16 ask that you identify _ yourselves.
.17 MR. HICKEY: Patrick Hickey for GPU 18 Nuclear.
19 MS. KUENSTER: And Jennifer Kuenster,
- 20. for GPU Nuclear as w e.1 1 ,
21 BY MR. JOHNSON: 22 Q State your full name. 23 A Thomas E. Morris. 24- 0 And your current business address? 25 A P. O. Box 92, Sanatoga, Pennsylvania,
4 r 1 19464. C) 2 0 W h o :. i s your current employer? i 3 A Bechtel National Incorporated. 4 0 What is the site of y o u'r. c u r r e n t work? 'I 5 A The Limerick generating station.run by-6 Phi'ladelphia Electric. 7 0 Land-that is located in.what city? j 8 A Pottstown. 9 0 Pottstown, ' Pennsylvania? q 10 A Yes, l'1 0 What is your work there? ! i 12' A 'I am the project manager for the Rad () 13 Waste -Operation Support Group for Limerick and i 14 the Pea ch Bottom generating station for-15 Philadelphia Clectric. 16 0 In those positions, do you interface ! 17 with the NRC regulatory process? 18 A No, I do not. 19 0 Could you describe just very briefly 20 what you do? 21 A We have a contract at each site to 22 cleanup the, what they call the power block, the 23 inside of the plant, dispose of their low 24 specific activity trash and to maintain their 25 respiratory protective equipnent in a state of
.(
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1. 1 readiness for use.
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'2' And in that context I would guess t
z3 .that, y e s ,- I do' interface,with the NRC i'n ' t h a t 4 theyLaudit.those' functions. 5 0' ;GoingRback in time, how long have you , . 6 '- been employed.by Bechtel' National?' 7= A With Bechtel I have been employed 8 since November cf 1973 November 5, I believe. 9 Q Could you just -- I don't.have a copy 10 of~your. resume. I don't think it was provided. 11 I don't think I asked for it. 12 But could you just briefly summarize l
) 13 your resume?
14 'A Graduated from the' Naval Academy in 15 1965. I spent eight.and a half years'of 16 commission servico in' nuclear submarines. I 17 resigned in October of '
-73 and took an 18 engineering position with Bechtel.
l
-19 I was licensing engineer for the SNUPS I 20 Project, which is a five-unit Westinghouse 21 standardized design. I was a license engineer 1
22 for South Dade, which would have been another ! 23 large multi-unit power plant for Florida Power ' f-l 24 and Light, which was subsequently cancelled. 25 I have been staff engineering and l
E 6 L , j
.f 1 ' licensing for' nuclear safety for the L
L: c) 2 Gaithersburg:--.all of.these Bechtel positions 1
)
13 so,far have been in.the Gaithersburg office in - 4~ Maryland. ) l
^
5 I.was a staff nuclear " safety engineer l 6 .for about a year. I.was assigned to the manager
- 7. of Thermal Power Management in San' Francisco'for ,
1 8 a year as his assistant. I came back to-the l 9 east. coast the day of the TMI accident. 10 0 March 28, 1979? , 11 1 'A Yes. In September of '79,-I was i j 12- assigned.as.the supervisor for Licensing and 1 O 13 uucteer safety et the home off ce 9tosece for ! 14 TMI. I 15 Q Home office' project? ! 3 L 16 A In Gaithersburg, the Design 17 Engineering Group. 18 0 You were with Design Engineering in 19 Ga,ithersburg? : 20 A Yes. And in June of '80 I took a ! 21 position of containment entry supervisor and i 22 supervised all of the entries into the reactor 23 building for the next two years. 24 0 From Gaithersburg? ' l
}
25 A No. I was assigned up here and moved '
w ' 13' - l 1~ communications, internal communications between -! 2 Larry ' King and I-don't know'if it was Mr. 3 Metzger, but it may have been, would it be ~ fair 4 to characterize that there w e r e. d i f f~e r e n t . p o i n t s'- 5- of view about the procedures to be f ollowed with: 6 respect to-the head lift program?- p 7 How would you characterize the" head 8 lift something? I think it was program. But-9 were there differences of opinion concerning -- 10 I was trying to characterize it. ., l 11 The re would appear to have been 12 differences of opinion about how to do that J() '13 work? ; i 14 A Yes, j 15 0 Between Mr. King and the RD&D people? L 16 A And others. There.was always a- 1 17 difference of opinion. 18 Q Could you characterize what that was 19 about? 20 MS. KUENSTER: Between who? 21 THE WITNESS: Detween Metzger and j 1
'22 King? )
l 23 .BY HR. JOHNSON: ,- 24- 0 Yes. 1. 25 A Can I take time out for a second and l 1
14 L, l' . ask them a question? because we didn't discuss .j O 2 a ny th i n g about,this and I am not sure about it. 3- I have an ' answ er , but I don't know ! 4, whether I should-be giv'ing_it. 1 5 (Mr.-Morris.and counsel for GPU leave i 1 6- the' room'to confer.)
~
7 (Pending question'is. read back by.the q i 8 reporter.) ) 9 BY MR. JOHUSON: 10 0 Your answer? 1 1
=11 A I don't remember the-specific 1 12 differences'that Metzgec and King had; and I.
() 13 d o n t , to my recollection, remember reading any l 14 of e:th at correspondence, i
'15 But there were always differences of )
'16 opinion. It was just the nature of the project.
17 MR. HICKEY: You mean 'not just between . l 18 Metzger and King? l I 19 THE WITNESS: I mean between 20 everybody. Everybody had their own little way 21 of thinking how we ought to do it. 22 0 In what context did they surface, j 1 23 these differences? l' 24 MS. KUENSTER: Any difference on the 25 project?. Ask a little more specific question, l l I l j t )
15 1~ please. l; ' !2 BY MR' . JOHNSON: l' 3 0 Are we talking about Head Lift Task
-- 4 Force' meetings?
5- When we are. talking..about' differences
'6 of'. opinion,- are we talking about differences 7 between Site Operations and Recovery Operations 8 in general, when we are talking about 9 differences of opinion, or both?
10 A The differences of opinion were 11 b a s i ca 11y'. ind ivi d u al differences and were.not, 12 to'my way of thinking, differences based on'
.h 13 organization.-
14 It was based on an individual's
.15 background and his experience.
16 MR. HICKEY: Let-me see if I 17 understand. 18 I thought you asked him about the head 19 lift and procedures for performing the head l i f't'. 20 And your last question to him made it i
- 21. confusing in my mind, at least, i
22 Do you want to know about what was 23 expressed in the Head Lift Task Force meetings? 24 Is that your question? 25 MR. JOHNSON: I do, but let me try
W., 16 = 1 !another approach to this thing. 2 .BY MR.. JOHNSON:
'3 'O You were not aware of the memoranda 4 that. Larry King was writing.at'-the time?
5 You were'not circulated copies of 6 those memoranda that Larry King ~was writing 7 -concerning the head lift punch list, for ') 8' example? . 9 A No. If he wrote a piece of 4 l i 10 correspondence that addressed the punch list, I l 11' in all likelihood saw that in the fact that I' ; c l 12 .probably had to go do something about it.
-() 13 But I don't remember.anything that j
[ 14 could be characterized of a difference of i 15 opinion in the context you are talking. : l' 16 0 Do you recall a memorandum-in which 17 Mr. King characterized a long list of items, _! 18 which I think he characterized as the punch list , 19 for the head lift, and said this is -- Site 20 Operations has this function and this function 21 with regard to each of those items and other -- 2 2. I believe other items were considered somebody l 23 else's responsibility? 24 Do you remember seeing any documents 25 like that? l N .. .
4f . 17;
'1_ A' I could very well have, but I don't 2 remember that.
- 3. O Do you remember whether Larry King 4 expressed the. position that.there'was a lack of-5 .an integrated schedule?
- 6. A- .Yes.
7 0' And what do you remember about-that? .; 8 A There were various_ efforts ongoing- at l 9 the time of head lift. Head lift was not the-10 only function occurring at the site; 'and'there 11 was not a-schedule which showed each of these 12 functions and how they interfaced with each I) - 13 ' :other. Larry King was not the only person to 14 raise this concern.
~15 The result of- not having that is the 16 fact that' Larry King and Site operations or some
.17 other group could be asked.to do two totall'y 18 separate and different things at the same time 19 because there were two groups trying to do 20 two --
trying to do their work without 21 necessarily being coordinated with each other. g 22 0 Was the problem that Site Operations l L 23 believed that they should be doing certain items 24 or reviewing certain items and Recovery 25 Operations believed they shouldn't be doing
18 1- lcertain1 operations? 1'0.. -2 ' MR . HICKEY: What. is.the problem you
'3 are. referring'to?
'4 .MR.- JOHNSON: If=you understand'the j 5 question, answer it.
~
'l 6- .MR.-HICKEY: Well,"I don't-anderstand' I l
7 it'. I 'th[ught you had asked him about1 Mr. King' 8- expressing the v'i e w , and he answered he was
.9 aware that there was a lack of an integrate'd 10 schedule. l l
11 'Is-that the problem that you have.just 12 addressed? It doesn't. sound like it. l o (). 13 BY MR. JOHNSON: l 14 0 Let's assume that-that is my question, ! L 15 that Larry King was expressing concerns that 1 16 there was a problem for the lack of an 17 integrated schedule.
'18 Would you characterize what you knew 19 of Larry King's concerns to be of that sort?
20 A Well, now all three of you have 21 confused me. 22 MR. HICKEY: The witness has already 23 , testified that, when you asked him whether he q 24 recalled that Larry King had expressed a view 25 that there was a lack of an integrated schedule,
i
.19 ' l
-1 he s a i d ,. Y e s', he redalled that.. That' is on the 2 record. 1 3 What is t h, ' ext question?'
4 MR. JOHNSON: Let's go on'from there.
'S BY MR. JOHNSON:
!. 6 'Q Did y. o u .h a v e conversations with Mr.
)
7 King concerning that subject? j l 8 A No. ) l
'9 0 Did you have conversations with Mr. .!
l 10 Metzger concerning Larry King's. comments about 11 the lack of an integrated schedule? 12 A 'I had conversations with Mr. Metzger l lh l .- 13
'14 concerning an integrated schedule but not necessarily as a result of Mr. King's comments.
~
15 0 Do you recall being interviewed'by. Mr. 16 Melitta? l
'I J
17- A Yes. l 1 l 18 0 On July 25, 1983, do you recall that? i 19 A Yes, I do. 20 0 And do you understand that that was 11- ! 21 part of an investigation that was being headed 22 up by Mr. Edwin Stier in connection with 1 23 management and safety allegations at TMI-27 24 A Yes. I 25 0 Were you interviewed on any other
20 1 'o c c.a s i on c o n'c e r n i n g -- by either Mr.'Melitta or D 2 Mr. Stier or-people working for Mr.-Stier 3- concerning the subjects in the Richard Parks' j 4 affidavit? 5 A Yes,. I was. .i Can you tell me when thatswas? -l 6 0 j D i 7 A I mean other than this -- no, the only -{ 8 time was the July 25 time. 9 0 on page 6 of your deposition of-Mr. 10 Melitta you are asked a question about the 11 . impact of finding that there was 30 times more 1 12 radiation than -- it must be 30 times more 1 ()- 13 radiation than initially assumed. And this 14 discussion starts actually at the bottom of page 1 15 4 and on page 5. 16 There was apparently discovery.that 17 there was 30 times more radiation than i 18 anticipated under the reactor head, and that 19 this put pressure on the schedule. { l J 20 And the question is on line 10, page 1 I 21~ 6, "Aside from the impact on the CRDM removal, i 22 did the 30 times more radiation memorandum have ] l 23 any other impact on the Il e a d Lift Task Force?" ( 24 And your answer is, "Yes. They tried to upgrade
)
25 the schedule on the polar crane to accelerate i u
l
-21 l
1- completion such that. it,would be available to' )
^[ 2: _s u p p o r t' the removal' of the CRDM's."
]
l 3 .There was, I take it, a' management --- 1 4 management was, your management was giving i j 5 instructions'through Mr. Metzger to.you to try . l 6 'and accelerate your review process with regard
~7' to the h e'a d lift? -l 1
8 A No, I I 1 9 0 What were they telling you to do? ) l 10 A What they'were telling us to do -- if j 11 I can go back, this was somebody's calculation i 12- that projected the increased radiation. And
.i L () 13 there had been a schedule laid out for doing l l
! -14 certain. things. ; l-15 The impact of f.inding an increased 16 radiation level would be that some of the ! 17 schedule assumptions wouldn't be correct,. and 18 that the best way to remove the CRDM's would'be 19 with the polar crane because of the distances l 20 for the individuals doing this. ! i L 21 Uhat that meant was, in order to do 22 that, they needed the polar cranes. So, , i 23 therefore, they were attempting to get the polar 24 crane expedited. 25 And there were some other things. I
'I ,-
' l- 'would have'to go back-in and take a'look, but we
- O' 2 .were going to go b'ack and do.another quick' scan 1
- 3. ' in a n =.a t t empt to confirm this calculation. But 4' no-one.was-telling me to accelerate any- review I
.5 process..
6 They wanted the end date. They wantedi h 7- to meet ti h e end'date. But nobody was telling me h 1
-8 to bypass any of the safety rules or anything, l l
9 like-that. 10 0 In other wo r ds,, they wanted to 11- maintain t h e' same end date?- 1 l'2 A Yes. l 1. h 13 0 Do you recall what that was? 14' A 110 - well -- 15 0 What do you mean by "the end date," 16 first? 17 The head lift. A I get my years q 18 confused, but I think it was July of '84 or 19 , . whenever they actually took it. 20 They were targeted in that time -- no, 21 I think this was July of '83 and it ended up 22 being delayed a whole full year as a result of . 23 all this. 24 0 On page 8 of that deposition, there i s 25 a reference to fi r . Parks' affidavit on page 14
23 I 1 in-which-'it is stated.that " Site operations.was .
. .2- , demanding calculations-to demonstrate'there was. -
3' afthreat to'the criticality in the steam 1 4 generator tubes, and Design Engineering'had. 5 failed-for' months to' supply calculations." j 6 I am reading fromfthe. question o .f Mr.
-7 Melitta. He. asked you whether you. recalled Site .j 8 Operations raising that issue at a meeting.in 9- January, and you said that you didn't.
10 As you recall, to the best of your 11 recollection, what kinds of concerns.was Mr. 12 Parks raising.at the H e a~d Lift Task Force
)_ 13 meetings'at this time?
14 A To be quite honest with you, I cannot
.15 remember the-specific concerns of Mr. Parks. I 16 can relate issues. I don't know who raised 17 them. I don't know if they were instigated by 18 Rich Parks or anybody else. It was a long time i .
19 ago. l 1 i
, .20 0 Could you read over starting at line l 1
21 24 on page 11 through the third line on page 13 j 22 for me and tell me whether your answers there . 23 are essentially accurate and correct?
.p 24 (Witness reading.) 1
'%)
25 A I have read that and are you asking me }
I 24 I l' 'whether I agree with my -- J L2 0 .Are yourfanswers'there, is-it your . 3 belief that they are accurate?
.)
4 .A Yes. 5 Q At the time that you made these 6 statements, not the statements.to Mr..Melitta 7 but the ones that you say that you'made 8 approximately in the' January 1983 framework, was 9 it your belief that Mr. Parks'was raiGing 1 10 legitimato questions with regard to the head 11 lift schedule? 12 A .I never had any problems with the 1() 13 technical questions'that Mr.- Parks asked. I 14 0 Any th i ng else? 15 A I just'had a problem with the:way he 16 asked them, his general demeanor in.the 17 meetings. 18 0 And how would you characterize that? 19 A Totally negative. He could not get L 20 anything done. He could not support anything. 21 It was a can't, can't, can't. 22 The purpose of the task force was to 23 find ways to get it done acceptable to all 12 24 groups, and he was not very supportive. q} 2 5- 0 Can you give me an example of an item
25-
- 1. he said.couldn't be done?
. fhi- ,2 A.- . N o ', I really cant-remember. My
. . i
'3 memory is not that good.
-4 MR. HICKEY: You want.to look at'pages. )
5 14 and 15 of.your transcript, Mr. Morris? I 6- At.the bottom of page 14 there is. l 7 'another meeting talked about there that has an 8 example of Mr. Parks. Maybe it will refresh ] ) 9 your recollection starting on line 21. 10 11R . JOHMSON: This.is in February. l
.1 I
-11 IIR.. H I CK E Y : I take it what you were l 12 looking for was examples of Mr. Parks' E( ) 13 negative --
what !! r . Morris has characterize'd as i l 14 Mr. Parks' negative behavior. ] 15 I am suggesting that it might refresh
- 16. the witness's recollection if he looked at the 17 bottom of page 14 and top of page 15. I think 18 perhaps he can respond. ]
19 MR. JOHNSON: Okay. Fine.' 20 THE WITNESS: No, I have nothing to I i 21 add other than what is in here. I cannot 22 remember a specific incident. I 23- MR. HICKEY: Do you remember the item l 24 that is related in here?
.O ' 1 25 THE WITNESS: Yes, I do.
l 26 1 MR.-HICKEY: .Ua s that an example of 2 'what you-are talking about when you say Mr. d k Parks had a negative' attitude? 4 THE WITMESS: Yes. 1 5 BY MR. JOHNSON: i , ( 6 0 What was the occasion which Mr. Parks 7 refers to in his affidavit-in which he mentions 8 that you told someone coming'out of one of these 'f 9 Il e a d L i f t Task Force meetings.that Mr. Parks 10 ought to be counseled for his negative attitude? 11 A I don't remember which date. 12 MS. KUENSTER: What section of the. () .' 13 cffidavit is i t' that you are looking at it?
'14 THE WITNESS: Is it the. January 14 15' meeting?
16 MR. JOHNSON: I think so. 17 MR. II I C K E Y : Page 8 of Mr. Parks' 18 affidavit, according to Mr. Parks, it is at an 19 carly January 1983 Head Lift Task Force meeting, j 20 He relates some discussion, and then i 21 he says "After the meeting Morris told Mr. ; 22 Sieglitz, manager of plant maintenance, that I I, l 23 should be counseled for my negative attitude." 24 THE UITNESS: That in true. After the 25 meeting I talked to Dick Sieglitz. He may or i
27'
'l mayJnot.have_been at the meeting. I- think he Ej 'k-2 was.- I rel'atedoto him --
l
.I.
3 BY MR. JOHNSON: I
- 4. Q To Mr. Parks or Sieglitz?-
5 A. Sieglitz. -- that I had no problems- ! 6 'with Rich's' technical comments; b u t- that I felt l 7 that his negative attitude and responses to. ] I 8 questions and just general lack of support i 9 influenced the. task force-in a very negative 10' fashion. 11 We were trying to ~do come. work, trying I 12 to meet a date which management had asked un to I() 13 do. And it took everybody's cooperation and 14 everybody's expectations that weicould do it. 15 And with somebody as -- I don't want to say 16 overbearing, but he influenced the atmosphere.in 17 the meeting such that.everybody was negative.
'1 8 In fact, as a result of that outburst, f 19 I was approached by several of the members of l
20 the task force who said, It is about time 21 somebody told him that. It was not just my 22 opinion that his behavior was detracting from 23 the group's-efforts. r 24 0 You said that everybody, as a result 25 of his negative attitude, everybody's attitude
. 28
- 1 was negative?:
. :ry
'2 A. Right. W e l l ,:. w e w e r e ' - - the recovery-
.3 ~ project'was greatly influenced by-the'outside:
'4 public'.s perspective of what we were'.doing..
~5 .Our mo' rale went upland d'own as the l 6 newspapers did their thing and as we went about l
- 7. our-business. And having an individual like 8 Rich.there doing his thing every single meeting I
9 never let you get the' momentum going that you 10 were ever going to get something done. L ll Q With specific reference to this l 12' statement on Lpage 8, "To illustrate a t. a n , e a r 'l y. i , h() l' 3 January;1983 Head Lift Task Force meeting,. Tom 14: Morris, . acting chairman of the Head Lift Task l ! l'5 ' Force, responded sharply-when he pounded'out' 16 that Site Operations couldn't reply with various l'
- 17 requests until procedural steps were honored.
18 He said that instead of telling what we can't 19 do, I should tell what we can do." 20 Do you recall what those procedural ! 21 steps were.that he was raising? 22' A No.
- 23. 0 You have said that he had a negative 24 attitude. But you also said that he raised 25 technically valid concerns.
_ _ _ _ _ _ _ _ _ _ i
.29
; 1" Are you saying that-the procedural.
2' steps that he was-talking about were either
. '3 valid considerations or invalid-considerations?
L 4 M R ~. HICKEY: He said he didn't recall l l 5 what the procedural steps were. 6 MR. JOHNSON: That isJa different' 1 7 question. 8 MR. HICKEY: If he doesn't know what 9 they are, how does he know whether they are 10 valid? ' 11- MR. JOHNSON: Let me ask the witness.- 12 BY MR. JOHNSON: 13 Q Do you remember? 14 A No. That is j ust a general statement. 15 What you have to understand is that 16 while Rich Parks is pointing out these specific 1 17 procedural steps, in the context of the meeting-18 he was continually putting out negative "I can't 19 do this" and "We can't do thats," and never. ' l l 20 offering what he could, you know, how to -- not 21 necessarily get around it, but how to meet all 1 22 these commitments. I 23 The purpose of the task force was i 24 because we did not have a good set of 25 regulations. It wasn't like we were working the
30 1 10' CFR~50 in the context of building a power O )- 2 plant. . There were no rules on ~ how to recover 1
.] .
'3 from one.
- 13L 4- E a~c h of us brought to the party'some 5 -interpretation of the rules. -And thelother part j j
R 6- was'that 'not everybody, knew what<the rules were, 7 and they' changed all the time. 8 The idea from the task force was to 9- bring everybody together so that-anybody who
.1 0 . knew or had knowledge of a rule-or something 11 that.we had'to abide by, he was supposed to i
12 offer it at that point so that we made sure that' h - 13 ' we at some point in time weren't sited for 14 failure to follow procedure, an agreement we'had 15 made with the Commission in a meeting which may 16 not necessarily have been published to everybody 17 or may not have been published soon enough. 18 And so the task force was using the 19 collective intelligence of everybody to make 1 20 sure that the rules were being followed. l 21 And that is not the one -- I had that l 22 little outburst and it was not directed 23 necessarily to that last instance of whatever r 24 Rich had brought out, but his whole history 25 during that meeting and all the other ones.
31-1 He'just'wouldn't offer a= procedurally th' 2 correct.way tofdo it. He wouldn't offer some L i 3 alternative method which may-not be procedurally ' l
.{
.4 covered.. He just was not'supporti.ve at all.
5 0 So his raising problems but never ! 6 solutions?
-7 A Never providing a solution. .
I
~1 8 Q Did you ever have a conversation
' j 9 directly with Mr. Parks concerning what you .;
.10 perceived as his attitude?
- f. 11 A I don't believe'so.
1 12 Other than in the MR. HICKEY: i 1 13 meetings, you mean'? 14' MR. JOHNSON: Right. 15 BY MR. JOHNSON: ) i 16 0 I mean, after the meetings did you i 1 17 ever' consider taking him aside and saying, -C a n ' t' !
)
18 we work this out, or can't you change your 19 attitude? 20 A I came from the Navy, and there was a ' 21 specific way about going about doing things. 22 One did not.go talk to somebody else's 23 subordinate and tell him to -- well, you talk to 24 his supervisor. And I did that with Sieglitz. l 1 25 Q Why was Sieglitz the person you raised
32 i 1 it with?- fy
\ 2 A I believe Sieglitz at that time was
<3 involved in the supervisory chain.with Parks. i 4 He was inside operations. ,
I
, 5 0 He1was.inside operations andiyou felt j 4
6 'that somebody to whom~ Parks was responsible
-l 7 should get the report rather than Parks'himself?
8 A. Yes. ; 9 Q That was th e - pr o pe r. -ch a n n e l ?- 10- A- Yes. ) 11 0 It.was like a lateral channel?' ! 12 -A- Yes.
.( ) 13 Q. Do you remember what Sieglitz' 14 positi'on was?-
15 A' We are going back to the original
'16 . question that you' asked me about what.I did 17 after that one particular. meeting.
.18 I talked to Dick and I told him that I 19 thought Parks --
again, his technical 20 suggestions were never a problem. It was'just 21 that he was so negative about it, and that he 22= ought to be talked to about it. There are 23 several ways to skin a cat to get your ideas 24 across. 25 And he agreed with me that that recent f l .
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, fa us 1 p e r f o r np% c e M f . . P a'r are s ' .uabin.Upropriate and that -
n 1 s 1 5s
't,] - 2 l 94 is he woulditalk.-to him.
3 0 Did he ever get back .o you? Did j
- a. . \ i L ~
.S i e'g l i t z ever'get back to y o u ? '.?
4-
'w'ty o X . i i j
1' V :, f 5- \A I think in the, context of af t sn th a t, j ', z
\
6 affidavit came out, I talked to D'i'c k ,2 g a n; e s'
, ' jy , l\i 7- because a s' part of that affidavit, Parky thyrs
, . n . ,
\
8 that .S ie g1d tm ag r e e d with Parks, and did!he ~not. 9 Sieglitz'and I had an agreement -- nog 10 an agreement, we had a conversation And,we , o 6 ( 11 agreed 69ain that' Parks' behavior was ' 12 i n a p p r,cp r i a t e . And'that statement in Parks O 13. effidevie wee untrue. 14 '", , O But contemporaneous 1[ did he get pack i i 15 to you before the affidav,st? ' 6 v ., 16 A I~have no recollection pf that., , k '~ 17 , Q Did Sieg1itz ever t a l '6 f a b o u t steps he x l 18 may h)ve taken with regard t t of Parks' a t t i t,r i d e ? 1
\
19 , A Only in the context that he latedhatf 20 a conversation with him. So in that regard, I ,
. 1 f guess he did get back t o 'r;i e .
21-22 0 When did he tell you that? I am
~
, ,\.
23 sorry, I didn't make it clear. ,', 24 A I really don't know. l 25 0 nss it after the affidavit c rete out or
, r 8 '6 e
l l ,, r
~
, .f e ; ' ,
, iy A
x, , 34-u
., ~
.-l' somewhat contemporaneous?
~2 A They were so close together.'I real:1y-3 can't=tell you. .
l, 4 0 When Richard Parks. started ,
-- 'well, 3 Mr. Parks raised some-concerns t h ay '!:e had in.a
-l 6 commentfresolution form on February 17, :1983. q!
L s i I l 7 Ile raised questions co'ncerning whethdr p L 8 there was an.unrevijewed safety. question in the o. l l 9 polar crane test pfocedure and whether the L I 4 L l' 0 ' procedure -pplied with Administrative ' l 11 Procedures 1047 and 1043. , 12- When die you become aware o f Si r . () 13- P a r k's ' problems expressed in that comment ., 14 resolution form? 15' A Never. 16 0 You never became aware of that? J 17 A Decause I was not invo]ved in the . la polar crane. , 19 Q How did you i n t e'r f a c e w i. q h the polar 20 crane work then? You said that there was a 21 decision made because of th o' ne e d to remove the 22 control room rod drive mechanisms -- i 23 A' Yes. l < 24 0 -- to use the polar crane, or was itl ! 25 the head lift? 'I'm carry, was it the CRDM's?
- -- - - - - ___ m[_ .m__wm m._. .1
.- .. _r g-- ,
hk 1 :. QW *
, b{' % '"
H von NR cg 4 35 Wr $'A ' . , - 1 - A . C R D !4 ' s , y e s . .- - f 2_ Q' And the polar crane was going to be 3 ' v id e d f o r that. And so there'was.' great interest s cl74 , 4- in'tpe' review of the procedure'and getting it-
' 3 9'
5 approved and so on.so that the crane could be l 6 used? a.
, e
'7: D' ,
- A. That is right.
- /,L : 4 i 8 ?Q You had no involvement in the. actual l i' 9 proposal' of the procedures for the.use of ~he.
t 14. 10 polhr' crane?
- s. !.
i
?
11 A. The ones to which Parks had comments
)
12 on? .,.
'13 -Q Yes.
I L /14 A .No. l l aIl s j Q 'And you didn't review them? l 16 A nc. I pa, h.: s - !j. . 17 Q What kind of interface did you have n 1 10 with the polar crane work? lh;
.c f'iI '19
-A I knew the-task leader, who was Mike L) _
'20 Radbili. He invited them to attend the head ]i
'I21- 11'f ti me eti n g since, obviously, their success
, 4 t. (' 'g. 1 22 predetermined ours. , 23 , I would periodically stop by and talk
- l. - >
y i24 , to Mike about certain things, just to keep up to
. 25 speed on what they were doing. We never in the L \
3
'c 'h.
ik -. . _ _ _ - _ - - _ - - . _ - - - _ . _ - - - _ . - _ _ _ . - - _ - - - - - _ _ _ - - - - - _ _ - _ _ _ - - - - _ _ - - - - - - - - - - - - _ - - - _ - - - . -- - - - - . .
,t 36 1 Head Lift Task Force meetings weren't given any.
C) 2 status,-per se, on what the= polar crane was up 3 to these days. 4 But we did publish our meeting
.5 .mi n u t e s . . And I believe we made sure that they 6- got a copy of them or somebody responsible for I
7 the polar crane did, j 8 But any direction to the polar crane, 9 whatever. they were called whether a working ] L l'0; group, task force, I' don't know if they were a 11 task force also; but whatever direction was 12 given--to them, came from management.- We never 4f 13 gave them any direction. We just indicated our 14- needs. 1 I 15 0 Were you on circulation of, like memos j 16 that Radbill would write concerning his work 17 with the polar crane test procedures? I 18 A Not as a matter of procedure. If I 19' wrote a memo and I thought he ought to get it, I 20- would put him on distribution. But'that doesn't 21 necessarily mean that every letter I wrote would 22 go to him or every letter he wrote would go to 23 me. 1
- 9. 4 Q Dut this comment resolution that I was 25 referring to was submitted to !!i k e Radbill, and ;
N J; 37 L
- 1 he~ signs- the new . resolution of Parks' comments.
I l 2 I think it wan'either the 23rd or 25th of l 3 . February. j l 4 Did he speak to you'or inform you, of ' S Mr. Parks' comments?
'6 . A Not.to my recollection.
7 Q Did he discuss with you the resolution
'8 of those comments? ;
i I n H 9' A N ot -'t o my recollection. ; i 10 0 Were you aware of the meeting of.the ; 1 11 test working group first on February 25, 1983, ) 12 and then on-March 4, 1983? ] O- 13 ^ no- i 14 0 Were you' aware that the test working 15- group had been convened? 16 A No. 17 Q Uere you aware that a quality 18 deficiency report, QDR, had been written by the ! i i 19 Quality Assurance Department concerning the 20' question of whether the polar, crane test 21 procedure complied with Administrative 22 Procedures AP 1047 and AP 1043? I 23 A I was aware there was some concern 24- raised by QC; but whether it was specifically 25 that, I can't tell you that.
30
, l' Q 'Did at any time during the period L
2- between February 18 and, say,. March 20 or 2 1',. 3 'did Mr. Radb'ill and you.have..any conversation 4- with respect to Mr. Parks! concerns?
- 4. -
5 A No. 6 Q~ Did you have any conversations with' 7 anyone with respe'ct to Mr. Parks' concerns 8 between February 17 and March 21, 1983?L 9 M S .. KUENSTER: Polar crane concerns on
- 10 the comment resolution ~ form?
1 1- MR. JOHNSON: Yes. 12 THE WITNESS: No, I had nothing to do '
')
( 13. with those procedures or those comments or 14 resolutions. 15 BY MR. JOHNSON: 16 Q Do you know Ed Kitler? 17 A Yes. 18 Q What was your relationship with hin in 19 January-February 1983? 20 A A talking, working relationship. 21 Q What was that? 22 A I knew he was the -- he was on that 23 TWIG. 24 Q Test working group? l 25 A Yes. And that he was the lead nechtel
* ' \
i i t39 1 1 startup engineer'on-site. 2 0 And what were the subjects of your l 1
. .I
.3 . conversations with him? !
1 I 4 A' W e 1.1, I had one t h a' t -- I don't know j 5 whether it.is in'here or not (referring to< j 6: deposition) in which I relayed the 's'a m e
- 7- information to him as I did to Dick.'Sieglit:
l 8 concerning Parks' negative approach to offering I 9 his comments =, and felt that Ed-ought to have a i 10 counsel-ing~ session with him. l 11 The exact time frame I am not'really -j 1 i,
-12 sure. It was not a predetermined type of thing.- l j[). l' 3 0 You j ust saw him?
l ( 14 A' The next time I saw him in-the V ! 15 hallway. L l 16 0 After this meeting in which you I 17' mentioned the thing to Sieglitz? 18 A Yes. And, again, because Parks was a 19 startup, engineer on loan-to GPU by Bechtel; so 20 Kitler had some supervisory role for Parks also.
.21 Q I see. So the logic was to go to ;
22 Sieglitz for the GPU side of it and Kitler for ' 23 the Bechtel side of it? , 24 A Yes.
.O 25 Q To try and deal with that issue that '
40
. l' -you had scen? !
Jr 2- A Yes. 3 Q So.the timing of.that -- did wei - H 4- . establish the time of that meeting? - Ha s Li t. J H 5 .Janu.ary 20? Did we establish the date of that :j 6 meeting? .i a 7 'A' It'just says mid-January in this 8 affidavit. 9 Q' This affidavit says early January j t
.)
10 1983, l
-11 'A Right.
12 0 I am wondering ~if there is t e s t 'i m o n y .
.h 13 -There is discussion of.a January 14. meeting on 14 page 10 of your deposition statement.
'15 MR. II I C K E Y : I'think it was the )
16 January 20-meeting. -] i i 17 THE W I T!1 ES S : I think it was the 15' 18 January 20 meeting, if you take a look at page 19 12. 20 DY MR. JOHNSO!I
)
21 Q At the bottom? j 1 22 A' Yes. 23 0 That refers to a document, I believe? j l 24 A Yes, and that was that meeting. So it l 25 was the' January 20
41-1 Q Okay. 2 So if you had spoken to Mr. Kitler, it' 3 would have been shortly after' January'20? l 4 A A couple or three days, something like
'S that.
- 6. 0 Do you remember with any ---well, what
- 7. else do you remember about this conversation? l 8 A Nothing. Nothing in'the context'of 9 words. It was one Bechte1' supervisor to !
i 10 another. 11' Hey, everybody knew Parks was a 12 Bechtel engineer. His performance was bordering
) 13 on being unprofessional in the way he was
)
14 conducting himself in those meetings. And, Hey, j i 15 talk to him. l I 16 I don't believe, even'if I had chosen 17 to talkLto Parks, that he would have listened to 18 anything I would have said. I think he just . l 19 would have chosen not to. I 20 So I offered to Ed and to Sieglitz 21- that they take a third-party point of view, plus 1 22 they both had some supervisory function with 23 respect to Parks. You know, give him the 4.m 24 message that his negative attitude isn't , V l 25 appreciated, nor-was it wanted; but nothing ____j
42 1- indicatingJthat he.should stop offering his
~h .
t 2 technical comments. 31 0 Was-there something specific that you-4 'can-articulate about his attitude other'than the 5: fact.that he;was negative, that.he was r a i s'i n g 1 l 6 negative problems and not raising s o l 'i t i o n s ? l I 7 Was he belligerent a t- these meetings?~ j l 8 A Rich Parks had a tone of voice which o 9 .was negative. I mean sarcastic. He.never-1 l: .,. 10 . smiled in those meetings. !
'l l' 1, And'in a lot of cases, he> projected a l 12 sort.of an angry demeanor, if you want to call l l
J() 13 it that. There wasn't a positive anything in 14' his actions that we could go on. l 15 0 -Did you have any understanding of ; 16- where his-demeanor was coming from? I 17 A No. 18 0 Did anyone else who was attending l 19 these meetings come to you and-say, What is with 20 . Parks? Why does he have this negative attitude? l 21 A I don't know that anybody offered that 22 comment to me. I know that I asked that. 23 Q That was the kind of question you were 24 asking? 25 A Yes. And I don't believe I got an I l
L 43 i.. . . . .
'^
1 , answer.. 1[ 2' You referred earlier to MR. HICKEY: 3 the comments after you had'your what you call
'4 the outburst?
5 THE WITNESS: Yes. . People did come 6 back and1say, Hell, it was about time. And 7 nobody offered to me any reason why Parks was 8 acting-the way he was.- ']
)
9 BY MR. JOHNSON: -) l 10 ,0 There were more meetings after the. J 11 January 20 meeting of.the head 1ift group? 12 A I assume they went on every week
'() 13 thereafter until --
for another year and a half. J 14 0 And Parks continued to go-to those. !
)
15 meetings?
]
16 MS. KUENSTER: If you know. 17 THE WITNESS: Yes. 18 BY MR. JOHNSON: i 19 0 Did his attitude change?- l l 20 A 'Well, the affidavit speaks for itself 21 in the fact that Parks had a run-in with Potts i 22 within weeks after that. l 23 I don't remember the exact time that I l
, 24 got transferred out of that, but it was shortly
- j. 25 thereafter within March or the end of February.
i
44 1 I got transferred for other reasons. i f- ] i if l 2 'O What I am asking you is, you made the . 3 ' comment to Parks at the meeting? 4 A Yes, ;
-1 5 -Q Di'd' y o u see any difference at the next 6 meeting?
7 A- No. 8 0 Or subsequent meetings that you were 9 at? 10 A No. 11 O What was happening to the problems 12 that he was raising? How were they getting i h 13 dealt with? 14 MS. K U El;S T ER : At the meetings? 15 Q Yes, the problems that you say were i 16 creating this negative environment, i 17 !! R . 'd I C K E Y : Wait. I. don't think that I 18 is his tectimony at all.. I think it was to the 19 contrary. 20 BY MR. JOHNSON: 21 0 He raised procedural problems. What 22 was happening with the problems that he had i 23 raised? l 24 How were they getting resolved in this 25 meeting process? i I i _ _ - _ - _ _ _ _ _ _ -___- i
'45 ;
1 .A. Specifically I don't know how they O 1 2 were being resolved, but I know they.were be'ing 3 handled. There was an attempt to address-
- 4. whatever-procedural deficiencies were raised.
5 -If.they were the fault of someHother j group,.that group was trying to correct that.
~
6 .; 7 Q What.was the procedure, that somebody 8 took meeting minutes in these meetings? 9 A There was no procedure. 10 MR. HICKEY: I think he means
'l l -practice. 1 12 THE WITNESS: 'There was a practice. .)
L O 13 8Y an. aounSon: 14 0 Yes, that is what I mean. 15- A There was a practice to, 'first of all, 16 have this punch list which was a list of 17- specific things to.do with dates.and people who 18 were assigned to do them. 19 And so we went over that punch list i 20 every meeting. So as part of the meeting ]
.I 21' minutes, the. status of those things was updated. I 1
22 And then it was also the practice to 23 highlight in the text of the memo forwarding the 24 punch list those issues which were deemed to be I 25 significant such that others on the island
46 1 needed t o -k n o'w about it so they could take. l I 2- action lor be aware of it, j i 3 And the distribution, there was a 1 L 4- standard distribution that everybody.got; plus-l L 5' if'aome1 person showed up that was not normally. L "6- there and he signed the' attendance, he would. (16 L 7 normally get a copy.of those particular-meetingL
- 8. ' minutes.
9 0 So-one of the principal vehicles'for 10 the agendas of these meetings, was that you had-11 the punch list and you succeeded from week to 12 week to take care of.the' items that were on that h 13 list? 14 A And to add to and subtract from. 15 0 And on or about the end of February, 16 beginning of March 1983, you ceased to have the 17 role of chairperson of this? 18 A I probably ceased before that as far 19 as chairman. I attended. In the end of 20 February and March, I was transferred to another i 21 group. 22 Q And Mr. Potts took over? 23 A no, Mr. Metzger. Mr. Metzger was the l 24 manager RD&D, and I guess by default was the 25 chairman since head lift was a function of RD&D.
e
'i s i
, '47 K - I' 'And when he was not there, either l 2_ myself or Potts chaired the-meeting.
3 0 .According to what you said earlier, in-l- L 4 approximately; March of '83 you went to work l 5 under1 the supervision of; Dave Buchanan, Site
'6' Engineeri'ng?
7 'IE Right. 8 '
-Q And were doing recovery-tanks and' 9 shieldILremovals or something for the spent-fuel 10 ' pool?
11- A' 'Yes. 12 Q' So you~really were not really' dealing
.()
13 with the questions that Parks had raised or 1' 14 thote concerns at all? 15 A No. 16 Q I-want-to~ draw your attention to a q 17 deposition that was taken here a couple of weeks I 18 ago'of Mr. Ed Kitler. 19 I am going to show you some statements 20 that he made concerning you. It involves ~as 21 background some conversations between Mr. Kitler 1 22 , and Mr. Parks on the date-of February 18, 1983. 23 And this is page 65 There is a reference again i p 24 on page 69. ; V J 25 Do you have a current recollection of I I i _ -______=______-___-
40 1 a conversation you had with Mr. Kitler in which
'O -2 you said --
well, Kitler caught up with you or
'3 caught you coming,back from a meeting and you
'4 made a statement, "Can't we get rid of that >'
5 guy?" meaning Parks or something. Then t h e'r e is 3 I 6 this other characterization made on page 69, j
- )
7 "Can we get. rid of that guy?" or "What are'we l 8 going to do, transfer that guy?" or something j i 9 :li k e that? 10 :A I don't have a specific recollection 11 that I said those words, but that isEnot 1 12 unlikely either. I don't have a specific , 1 () 13 recollection. 14 0 Do you remember what Mr. Kitler said 15- in that conversation? 16 A No, other than I think he said that he 17 would talk-to Parks. 18 0 was that the same conversation you 19 were ' referring to before? 20 A Yes. ! 21 0 With Kitler?
?
22' A Yes. And well there was one other 23 part of that conversation where Kitler told me j 24- he was responsible for having Parks hired. O ; 25 I did not know it prior to that i
49 1: .particular occasion; but he made the-
.(} 2 recommendation to Bechtel to hire Parks, so he
'3 felt some' obligation to go back and counsel 4 Rich.-
5 0 ~Didayou have any further convers'ation
- 6. with Mr. K i't l e r about Mr. Parks after that?
7 A. No, I think he had left shortly , 8 thereafter that.
'9 0 In other words, it is unlikely that !
-10 you-had other conversations with him because'he-11 left, or you didn't have conversations? 'j 12 A I could have. I d o n '.t think that the f() 13 specific reason for having it wasfParks.
14 MR.-HICKEY: I think that is what he l 15 is asking. 16 THE WITNESS: No. Parks was, if you 17- will excuse me, a minor burble in the life of c 18 TMI. I just went on about business. , 19 MR. HICKEY: You didn't concern i 1 20 yourself with Parks' fate or anything like that? ' i 21 THE WITNESS: No. 22 BY MR. JOHUSON: 23 0 I guess similarly you were not aware 1 24 that he was removed from certain positions on () 2 5' the test working group representation or not? 1 l l
50 1 A Only after the. fact' . 2 Q After the affidavit? 3 -A All that stuff, yes. 4 0 -And were you aware of the 5' investigation of Mr. King and Mr. Parks 6 concerning Quiltec by Bechtel?- 7 A I became aware of it when I'found out 8 that'the s e c r ). t a r y , Rose Riddle, was asked what. 9 she was doing typing. resumes for the people who j 10 were trying.to be hired by Quiltec. 11' O Was this part of.the investigation,
.12 M r .. Troblinger's investigation of-Mrs. Riddle? ,
U(). 13 A Whoever investigated her. 14 0 I understand it was Mr. Troblinger who 15 interviewed her.
'16 A It was my interpretation that there --
17 my understanding that there was only one 18 inquiry. 19 Whenever it was, we heard about it 20 sort of office gossip kind of thing. You all of 21 a sudden find out that she is being asked all
'22 these questions.
23 Q Did you know anything about it l 24 contemporaneous with the actual typing of the 25 resumes that were referred to?
51 1 A No.
~
2 O' Did you.have any knowledge of Quiltec j 3 or-Mr. King's-involvement ~with the job. shop 1 4 ope r a t i on' prior to that time =that there.was the 5 investigation?. A ~No. , 1 L7 0 Were you an attendee at a meeting l . chaired by Mr. Arnold and, I believe, Mr. King 8-l 9 and Martin on. March 23, 1983, at which the Parks 10 affi' davit and Parks' going public was discussed?-~ ! 11 A I don't think so. 12 O There was a meeting on that date'in () 13 the morning about eight-thirty. There were 14 approximately 25 to 30 people in attendance in a 15 room, rather large room with a conference table. '17. 16 Do'you remember attending any meeting I 17 :in the morning of March 23? 18 A If I did, I don't remember. I really 19 don't. 20 Q Do you remember any discussion about i 1 21 what to do with Parks once it became known on , 22 the site that he was going to go public, before 23 he went public? 24 A No. You mean was I directed by my 25 management to do one thing or another? No. ; 1.
4 52 1 Q No. Did you become aware of.the "
]h 2 situation-before he went public?
1
. . . l 3 MS. KUENSTER: That he'was ' going t o. go
]
'4 public?L I 5 MR. ' JOHNSON: Yes.
1
.6- THE WITNESS: Let me offer it this j 7 way. I do not remember knowing _'about it before 8 he did. ,
9 But if it was rumor a day beforehand, 10 I probably knew .that. But I was not-advised or' 11 told by anyone that he was going to have -- go 12 down,to wherever he went to and give his ; () 13 statement. 14 BY MR. JOHNSON: 15 Q. Were you consulted about what to do 16 with Mr. Parks?
. 17 A No.
18 Q During mid-March, I think it was the 19 14th of March, Mr. Wheeler, Andy Wheeler or. 20 Richard Wheeler from the Gaithersburg office, 21 came to the site to interview Mr. Parks along 22 with Lee'Hoffman. 23 Do you know either of those? I 24 A I know Andy Wheeler. 25 Q Did you know him at the time?
a
, 53
- 1. A Yes. !
I) 2_ Were.you. aware that he came to,the , 3 site. March 1983? f 4 A No. 5 Q Were you aware around the time that 3 6 you had'the. conversation with Mr. Kitler or up 7 to or aboutithe time of February 18, 1983,_do 8 you remember! hearing any rumor-concerning Mr. 9 Parks and the= possibility _that'he would be 10 transferred to another location? 11 A 'No, no talk of transfer. 12 0 And other than the discussion that we l () '13 referred to before, which was about the attitude 14 at the task force meetings, was there any other 15 discussion _that you were aware of with Mr. 16- Parks? 17 A That I had?
'18 Q That you became aware of discussions ,
19- about what to do with Mr. Parks between the 20 time, say, January 20 and the time that Mr. 21 Parks left? t 1 22 A No. I was not a party to any l l l 23 conversation, nor was I aware of any. It was l 24 just business as usual. 25 Q But you were keeping informed about
i 54 1 the slippage of the schedule on the polar crane, I assume?.
?2 3 A .Yes. We'were paying attention toLhow j 4' it-affected work, the technical aspects o f :w h a t. j
'S was. going on; but not'necessarily being either j 6 advised or consulted about any other issue.
7 Q There_were weekly reports that were l 8 distributed by the polar crane group. Did,you l 9 get copies of'those? 10 A I may have. 'They may have come.into. 11 our group; whether I actually saw them or not, I 12 don't know. () '13 Q You don't remember whether you read 14 them or not? 15 A No.
'16 Q Do you remember the convening of a 17 committee called the Readiness Review Committee?
18 A That was somewhat after all of this 19 went down. I guess Arnold was still-there. 20 Somebody convened it and they decided 21 to go through the polar crane preparations in a 22- nut-by-nut, inch-by-inch, step-by-step review to 23 make sure that everything had been done [ 24 properly. 25 MR. HICKEY: Were you at a meeting,
l t 55' 1 Mr. Morris, or.are you telling him what you c Q- 2 heard'about the meeting? l l 3 THE W ITN ESS :- No, I was not at any j 4 ' meeting; this is just what I was told'what the > 5 committee was going to do, l.- 6 .BY MR. JOHNSON:
- 7. - Q So you were not a part of the 8 committee?
i 9 'A N o .~ 10 Q Did you participate in any of the. 11 p r e p a r a t o r y ' w'o r k for the c o m m i t t.e e ? 12 A No, I had aething to do with it. O 13 o Did you have eny essienmenee ee ebe 14 result of the work of the committee? l i 15 A No. 16 0 Toward the beginning of the discussion 17 we had today, I think, is it true that you 4
)
18 mentioned -- maybe I am a little confused,.'but 19 did we discuss the role Mr. Parks had in writing 20 procedures and reviewing procedures along with 21 Bubba Marshall? . 22 A I indicated to you earlier that both ]i 23 of them par _ticipa'ed in either writing 24 procedures or reviewing procedures, depending 25 on -- the RD&D may have written a procedure; and
L 56 l 1 therefore, Bubba and Rich Parks were asked to C) 2 review them,. or they were asked to' write ,
'l 3 procedure.
4 In'a lot of cases when we were asked. 5 to do something, there was a p r o c e d u r e ' ..t h a t <
..j 6 covered.the entire days' events. It may;say,.Go I 7: into the reactor. building'and follow this 1 8 . procedure, but:there was a general governing i
9 procedure. And a lot of times Bubba and Rich , i
' 10. would write those. !
l 11 0' But you used those procedures? )
'I 12 A Yes. >
l)' 13 Q And what time frame? 14 A For. Quick Look. That was in the , 1 1 15 summer of '82. 16 0 What about later in time when you were 17 working in the RD&D area? 18 A Well, there was only one other thing 19 that we did, and that was trying to unlatch the 20 CRDM -- I'can't remember the name of the bottom j 21 attachment that was still there; but anyway, i L 22' that procedure may or may not have been written i 23 by Parks and Marshall. 24 It was obviously written by somebody 25' in Site Operations because we didn't write it. ; 1
V 57 1 Q And it was what.you followed when you l 2 did it? 3 A Yes. l i18-4 0 And when did'you implement that l 5 procedure? 6 A That was in October or November. 7 0 1982? 8' A. Yes, ' 8 2'. 9 0 Were there any other procedures that-10 you.can r e c a l'1 that were written by Site 11 -Operations that you proceeded to use during the 12 l a t'e r period prior to your transfer to the spent fh' ( 13 fuel pool operations?
)
l' 14 A ue did Quick Scan, which was sticking ) J 15 .an instrument into the reactor vessel. So there 16 was, or there should have been, some involvement 17 by Site Operations in that. . i 18 How, whether we wrote it and they 19 reviewed it or whether they wrote it and we l 20 reviewed it, I don't know. 21 But again, since it was an operation 22 specifically interfacing with the reactor 23 vessel, Site Operations had a very important 24 role to play in that. 25 0 Can we place that in a time frame?
58
~
1' A Well, Quick Scan was in November or
. 0. 2 ' December, I believe.- .And'it was right after 3 that where that calculation 1came.out. Based L on 4 t h'a t information, they projected that there was 5- 30-times t h' e amount of radiation level.
6 0. I seem to recall-that the memo that' 7 relates to that is January 6, so it would be 8 sometime just before then, I assume? R 9 A- I do not- remember the specific dates, 10 but November and December was the time . frame 11 that.we did Quick Scan. The Devine memo that 12' talked about it was January 14 () 13- 0 And it was the procedure for Quick 14 . Scan that you were just referring to that Site
.15 Operations had a role in writing or reviewing l 16 that was used?
17- A Yes. 18 Q Were any other procedures written or 19 reviewed by Site Operations during the 20 subsequent period until you left, January or 21 February? 22 A I don't remember when we went back in 23 and did the lowering of the water level, which L 24 was the. result of that memo.
}
25 But whenever that was, that procedure
- - - ~ - - ~ , - , - - , - - - - - - - - - - - - - - , - - . - . , -
s. l L 59 l
'l 1 would aiso have been done'by. Site Operations, or 2 a ~ significant role in it since they actually .had. i 3 to change the water level. {
4 0 And that was:done prior to your 5 ' changing job's?' 6 A -I don't k n o w .- It was right in that l
.7 time frame, j 8 Q But it was approximately around.'the 9 time you left for the spent. fuel work?
10 A I believe.so, yes. I 11 0 During the period between February, 12 mid February and the end.of March, did you ever-() 13 become aware -- I'm sorry, until Mr. Parks went
]
14 public, did you ever become aware of Mr. Parks 15 having gone to the NRC? 16 A No. i 17 MR. J O H N S Oll : I don't have any other I 18 questions. l } 19 MR. HICKEY: I have a few, i l 20 ' L L 21 EXAMINATION BY MR. HICKEY: l 22 Q I am trying to get a little better 23 understanding when you had the task force 24 meetings and what the purpose of that group was. 25 Let me pursue that briefly. j
60 1 Why don't you tell us what you can 2 about the organizations that served on the Head 3 Lift Task Force. Who made up the Head Lift Task 4 Force? Who were the representative groups? l 5 A Well, first there was Reactor 1 6 Disassembling and Defueling, because they had l 7 the major responsibility for the activity. There 8 would be somebody from Radiological Engineering 9 because the w or k was being done in the reactor ( 10 building, which was a severe radiological l 11 hazard. l 12 There were people there from GPU's () 13 licensing department to ensure that the activity 14 was described in a safety evaluation report; and 15 once approved, were there to make sure that 16 procedures and things that we were doing fell 17 within the bounds of what we told the URC we 18 were going to do. 19 0 Once approved by the NRC? 20 A Right. And they would also review the 21 procedures beforehand while we were in the draft 22 stage to make sure that we weren't describing 23 something procedurely which was not bounded by 24 the safety evaluation. 25 There were people from EG&G who were E. .
/
.i Jj g
m =>
-n y .
I 61 1 funding -- and I guess that issnot fair. EG&G
'\ ,y s,
2 was the consultant -- DOE, the team that did all I i
'3 the information. 1 h )
4 I am not sure what the name of the 5 people were, but t)ey were responsible for F l 6 making sure that 'all of tbe , inf orma tion ); hay was ,
.4 7 collected, because the G o v e. r n m e n t was paying for li g 8 some of this, that it gotjo everbody thatlit 9 was s u p p o s e d ' t. o . So they wen 5, to all the l s .,
{' 4 10 meetings. i 11 Site Engineering would attend because 12 they had responsibility, Design En insering O 13 wou1d eteend, necovery Overetioa2 w'% as :#ek'ed s to i 14 a t t e n,d . I don't know that they made it on a 15 regular basis. <
- f. i. l 16 Q Recovedy Programs? f 3
17 A Well, Recovery Programs included
! 4 18 Recovery Operations, Site Engineering, Design j 19 Engineering. -
20 The task leader, who I think it was { 21 Haltman, would have been there. Maybe not every 22 one, but it was the intent that they lxt sthere t., . 23 also. r ,(
\
9 ' g'= 24 0 was the 11R C invited? ' (] V 25 A They were invited. All of tho%u
/ ,.;
} h,..
l' E ,
-M
1
+
. :. . _. ,.u 62; I meetings were open. They were announced. I 2 know George Coleman and Phil Grant- used to come 3 by.
4 Q Those were NRC bnployees? ( 5 A Yes. How whether Cir not they were in i 6 specific attendance on any of the onec today, ~ I 7 don't know; but they did attend the meetings. 8 0 All these organizations attended 9 because they had some role in the ultinato.: goal, 10 which was to remove the heaa from the :reaccor 11 vessel? 1 12 A Yes. ) 13 0 And Site operations was another group 14 that atte,nded? 15 A Yes. That was Parks and Marshall. 16 0 li n d Mr. S i e g l i t :: and Mr. A cohall? b 17 A Yes. 10 0 Who would have been the senior m e rib e r 19 of that group? 20 A Of th o s e three, Sieglitz. 21 0 And the issues that prompted bringing 22 all these people together were to try to 23 coordinate the many activities that u re r e going 24 to lead up to the head lift? 25 A Mot only to coordinate but a]so to
-- ~ --
g . --. ;.
,~ h l' \
! 63 L gyl'f-f !
s 1 aseign the appropriate group the functions that l f^( , 2 were: required. l l
', i 3 If a structural calculation was I
! i l / 4 required, then Design Engineering would do it. s's 1' f 5 If a ' calculation estimating the amount of 6 m a n - r e ra .was required, then either RD&D or f' ) 7 R a d i o l o <j i c a l Engineering would do it. I B Obviously if a procedure had.to be ] 9 written which we thought interfaced with the I ' 10 r e a .: t o r vessel, then we would assign that 11 particular procedure to Site Operations, since ; I. s i l 12 they ware the keeper of the procedures. i I 1 () 13 Q Sounds like there were numerous l 14 subtasks that had to be accomplished in order to , i 15 get . ready to remove the head from the reactor 16 vessel? 17 A That's right. 18 0 They included things that Radiological l 19 Engineering was responsible for, like measuring j i radiological levels so they could determine 20 21 u r. d e r what working conditions the work would be 22 done? TJ A Yec. And Data Acquisition was another 24 g r o u'p'. I think that was their name. They were
)
25-the ones that -- I don't know who was in charge L. w .
64
-1 of it at th'e time, but-they the hard data.: .They
- Q~ 2 were responsible for' calculating that 30 . times j 3, 'g r e a t e r than expected number.
4 So there was some analytical , a 5 extrapolations that_had to be done. And that 1 6 was the -- so many organizations and so-many' ; 7 names. They. worked for Jack Devine and it 8 was -- there are so many organizations and j i 9 names. It was --~I don't remember ~the specific 10 -title. You would have to go back to the history 11 of the organization. 12 O But in the meetings that you had, am I () 13 correct that you would not be resolving specific. , . 14 ' substantive issues; for .e x a m pl e , the polar crane 15 and whether it should be fired in one fashion or 16 another fashion? 17 A No. 18 0 That would not be addressed in the 19 Head Lift Task Force. That would be addressed 20 by the people working specifically on the polar l l 21 crane? 22 A Right. Our interest was only when 23 would the crane be ready, and when would the 24 missile chields be removed. 25 Q And you needed to know that because
l 65 1 there were.other steps and other tasks that;were. 2 going to be going on'that would depend.on that - 3 and other things?
~
l 4 A .That is right.
-5' 'O So.is it accurate 't o describe the Head 6 Lift Task Force role as one of coordination'or 7 one of~trying to bring.together a bunch of ,
I S. separate. individual tasks for schedule purposes?- l 1 i 9 LA Yes. ; l l' 0 'O Mr. Potts was interviewed by.Mr. 1 1- Stier. He described this incident that~you . 12- ' r e f'e r r e d 't o briefly in your testimony, too. ! h 13 Let'me read his descr.iption of it. j l , 14 .This:in from Mr. Potts' Stier interview.. I'am l L - 15 reading from.page 6-of that interview.- He is ; 16 asked on line 6, "Mr. Potts, do you recall such ; 1 . 17 an instance with Mr. Parks, Richard Parks?" l 18 "Yes, I do." "Could you describe for us the 19 incident?" 20 And Mr. Potts speaks, "The incident is l l 21 much as described by Item 9. What I can recall , 1 22 in addition to what is there in the minutes is I l 23 had asked Parks, I believe three times, if he 24 would contact PORC and get from PORC a projected 25 date when the procedure would be available. l _____________m___ . _
e 66 1= .Th a t: procedure was a. critical' item to completing
.2 the schedule.
3 " P a r k s r e p e a t e d l y . ' ~r e f u s e d .- And based 4 on b e i~n g unable to get Parks to contact PORC, I
)
5 then asked Mike Smith to undertake that action, i; 6 and he agreed." l 7 And just to. continue, Item 9 that Mr. 8 Potts'was referring to was from the minutes of ; 9 the head = lift -- notes and' comments.from the 10 meeting of February 22 and it reads, "The
- 11. meeting chairman, .Potts, . attempted 12 unsuccessfully to obtain from Gite. Operations
() 13 Parks a commitment for the issue for. use.date of 14 the procedure for RCS chemistry control 15 sampling. RD&D Smith took the action to contact 16 PORC for a projected release of the procedure 17 from that group." 18 Do you remembet that incident now that i 1 19 I have given you these details? 20 A Yes. l l' 21 MR. J O!! N S O M : What is the document you 22- are referring to? 23 MR. HICKEY: I am referring to the 24 February 23, 1983, memorandum.
Subject:
Head 25 lift' punch list. To: Distribution. And it is
1. 4
-1 : th e list: ?of notes and commitments from-the- i
.2 meeting held February 22.. 1
.3 DY-MR. II IC K E Y : )
[: '
. 4 Q Now, do you recall .that there was a n' 1
l ~5 interest .i n t h e . II e a d Lift Task Force in knowing i l 6' when a particular procedure about RCS' chemistry
~7 control and sampling was going to come out? )
i
'8 A Yes.
9 0 What did RCS-chemistry and: control l 10 deal.with-orLrelate to? 11 A When the reactor vessel's water level 12 w'a's l o w e r e d , and subsequently the pressure in 20 () 13 the reactor vessel, the abil'ity to sample'the i 14 r e a ct o r cooling system by the installed system
' 15: was no longer effective.
16 The system has got to be pressurized 17- to at least 100 pounds; .and if you don't do 18 that, you don't get flow. Therefore, you cannot l l l 19 give a representative sample and results of the 1
\
20 condition of the reactor coolant system, and, 21 therefore, the tech specs. b 22 Therefore, the procedure had to be 1 23' written for us to manually withdraw a sample f l 2'4 from the top of the reactor vessel. ) 25 0 So you needed a procedure for someone 1 'T1 -.
- I
m;
- l 68 l 1
I .
- 1. tongo and take a samp1~e, a. p e r s o n ,. not
~-
2 automatically? 3 A Yes. i 4 Q- P o r. -a person to go into'the' reactor vessel and get a' sample'of the reactor cooling 5
. . i 6' system water, ' contaminated water, from.the-top ;
t 7 of the reactor vessel so that you could see what -! l 8 the chemistry of it was. Is that right? ; J 9 A. So that we could assure the NRC that ' l
'10 we were, actually GPU, was meeting-the tech -l 11- specs.
12 O And who was supposed to: prepare.the () 13 procedure?- Was that a Site Operations' task? 14 A Based on the memo, yes. i 15 Q And as part of the procedure, ; i 16 preparation and approval, did it need to be ,. 17 reviewed by the PORC? ! l 18 A Yes, it did. l [ 19 Q Do you understand that what (1 r . Potts 20 was trying to get Mr. Parks to do was to report i 21 when the PORC approval of that procedure would i 1 22 be completed? 23 A Yes. 24 0 Mr. Parks wasn't raising any concerns 25 about the procedure in that meeting, was he?
69
.1 ~ 'A N o' . PORC is a PlantL Operational 50 J- - 2 Review; Committee.
[ 3 *
'I might add that'it<is normally the 'l L l
[ 4 responsibility of'the individual who wrote the l l 5 procedure'to be up to-date on where it -i s and 6 where-it is going to go and where it'is coming 1 7 from, and not just to write-it and throw it into j l 8 the system and forget about it. a 9- Q Now, were there other instances in the i] 1 h -10 Head Lift Task Force meetings where.there were j l o 11 questions about'when various procedures would be
-12 available?
b) 13 Was that an unusual- or a regular partL 14 of the Head-Lift Task Force discussions? . 15 A I would believe it would be usual 16 because there were a lot of procedures. 17 Q Now, was the. Head Lift Task Force j 18 doing a substantive review of the contents of 19 the procedures? 20 A No. , 21 Q You didn't approve the procedures, did 22 you? 23 A No. <l 24 Q Was the Head Lift Task Force
- 25 interested in finding out when the procedures 1
r EI 4 lI ' ' ' ' ' 1
d 70
.1 - would be approved?.
r< - 2' A .Yes, and to make sure that they 3- addressed all of.the technical issues that were 4- pertinent.
)
Some of .Mr. Parks' complaints 5 and '
-4 6 this.is starting-to come back for me. 'Some of
] l 7, Mr. Parks' complaints.were the lack of i
8 inf o r ma ti'on for him to write.his procedure. One 9 of.the points he talks about was;the criticality- l I l 10 ,ca lculations. H 11 There are a lot of times when-people 1 21 were supposed to provide information in one sort-() -13 or another, either some sort of analytical model I 14' or go'off and get some data or provide a' design ! 1 15 which gives you valve numbers and whatnot, which i 16 would allow you to w'r i t e- a procedure that would 17 operate it. I l I L 18 And so a lot of times when the l 19 complaints were being raised, we were asking him 20 to draft a procedure, maybe not knowing all of 21 the valve numbers, but at least to get moving. 22 And he wouldn't get off the dime 23 because.he didn't have all of the information to 24 begin with to' start his activity. 25 Q Was it your view that he could have
.71
'l' started the activity and completed some of it f(}
~
l2 and then filled in the missing data latercon?
.3 A Yes. That is the way most of the
~
4 Island operated at that time because there wore 5 a lot of unknowns, 6 0 You weren't talking'about using the-7 procedure before it was completed, were you? 8 A No. 9 0 But Mr. Parks was unwilling _to even 10 begin. preparing the procedure until be.had all 11 tho' data? Is that what you are saying? 1
.1 2 A Yes, in some-case.
L~ O 13-o .when "r- verxs made ehese comments 14 that you characterized. as negative comments and 15 so on, did you feel that he was dealing with. the l i 16 ' issues that were being r a.i s e d in the task force i 17 on the merits, or did you find his comments i 18 didn't really address the merits? i 19 A Well -- 20 0 Maybe the question is too vague to be i 21 helpful. Let me be more specific. 22 You talked about Mr. Parks having a a. 23 sarcastic tone when he made comments in these 24 meetings. Is that right? 25 A Yes. i m-m_-_- _ . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
72-1 0 When he responded.to-other p e o pl eL' s 2~ questions'or comments, didLhe uso sarcasm? a
~3- A Antagonistic'tonefof voice, yes.
'4 0 Was that conducive to a helpful 5 discussion of the issues at=the meetings?
6 A No. 7 0 -Would you feel it was a professional 8 manner for.Mr. Parks to adopt. that tone?. 9 A- N o '. - 30 0 Was Mr. Parks engaging in personal 11 criticisms or. personalities of other members of l 12 the task force? ()L. 13 A No. 14 Q Do you. remember him having a crude. I 15 method of expressing himself in-these task force 16 meetings? 17 A I think we all did. I 10 Q His was not unusual? 19 A No. 20 0 Is there anything else that you.can 1-
.21 describe about Mr. Parks attitude beyond what 22 you have already said that you felt was 23 unhelpful in these proceedings, which prompted 24 your' comment to Sieglitz that he ought to be 2 .5 - counseled?
--_-__-_--__-_____-_-__7 L c l
L . 73-t - 1- -A' ILthink I1have really s a i~d - i t all. set = j t") - 2 MR. HICKEY: I don't have~any.other j t 3 -questions.: 4 5 6 EXAMINATIO!) BY~MR. ' JOHNSON: ) 7 0 With respect to the procedures that
.8 Mr. Parks was claiming he needed more 9 information on before he could start writing 10 them --
let me back up. 11 Did he, in fact, state at' these Head 12 Lift. Task Force meetings.that he needed more of ()f 13 the'information before he: could start writing i 14 the procedures? 15 A Yes. l 16 0 Can you remember any ~ of the particular l l 17 procedures that were involved?- 1 18 A one of the procedures at issue, now 19 whether or not this was a specific topic that ] i L 20 Parks brought up, I don't know, was the movement b l 21 of the missile shields. I 22 MR. HICKEY: You are saying that you L 23 are not sure whether Parks --
- 24 THE WITNESS
- I know Parks at some 1
25 point in time raised this issue. I am not sure i i
?
l 74 l' when in'the context of all the. stuff we talked ! 2 about,
]
J
=3 But part of conducting head lift,
.I 4- obviously, was: to move these four 20-ton' missile 5 shields off the reactor vessel and to put them o 1
6 some place, d 7 Mow, the normal place for them:to be 8.. put was two on each-of what they call.the 9 D-rings.on top of the steam generators. And 10' there was a' question as to whether or.not one-L 11 should do;that in the context of this
'12 criticality in the steam generators.
][1 13 There was also an issue as to whether
-14 or'not how far.down the steam' generator should i
15 be drained; such that if we dropped the missile L- 16 shield and it severed the reactor coolant pipe, 17 we would maintain water level in the reactor 18 vessel. I 19 And there were a lot of if's, and's 20 and but's that went along with that -- why you 21 could write a technical procedure which would 22 allow you to do one or the other. You could 23 not, in all honesty, provide one saying this is 24 the way to do it if-no one had'done the analysis 25 which allowed you to say it was okay to do that.
75 1 And in that context,, that is -a lot 2 of times that is the.way Rich would-keep from
~3' ' writing the procedure, by saying, I don't have.
4' every last bit'of inf orma ti'on -I need i n' order'to 5 write the procedure to do it. 6 The p'oint .was, well,' write a procedure 7 where you' stack-two o'f.- t h e m here and two4 of them 8 there. Write another procedure where you stack 9 'all four of them in one spot. And when we come 10 up with the reasoning as.to which way you ought 11 to go, then pick one. 12 But there is no reason for us to sit h 13 down and wait until that' technical d e'~c i s i o n 14 occurs'before you write a procedure. That: -just 15 extends the schedule that much l o n g e r . .. 16 So write a-procedure,- or write two 17 procedures. Put your thoughts together and get-la it to the point where you have covered all the 19 substantive issues in each one. And when the 20- technical evaluation comes out -- and it all. 21 comes out to the fact that the SER, the safety
- 22. evaluation report, is' approved by the 11 R C . That i
23 is'the key as to which way we go. l-24 But you can't sit and wait until you 25 get 100 percent approval on each one of these l:
76
-i
.1 things before~you go on.- If youfasked him to do l'
L- )I '2 something, he would say, I don't'have this or I l L 3 don't have that, i 1 You" referred to the. safety evaluation. ) 4 0 5- WasRthe safety evaluation for the polar crane .{ i 6 functional' description at all related to?this' '!
.i 7 s ubj e ct ?
8 A No. Because this particular thing was 9 talking about head lift, which.is -- and the 10 technical adequacy of the polar crane would be i 11 addressed separately in that'you could lift
- 12. certain amounts.
()f'
.13 0 so it was a load t e s ti p r o c 'e d u r e that I
- 14. this pertains to, the lifting _ the missile j 15 shields? j 16 A Yes, it did.
17 You are way out of what we are talking i i i 10 about; but the load test had to use those i 19 missile shields as part of it. There was not f
)
20 enough weight of anything.else in the reactor 21 building to effectively conduct a load test i 22 unless you used those. l 23 0 I seem to recall Ed Gishel suggested 24 using these shields or lowering them to the 25 lowest level possible, or some kind of weight, I
.77
~
. 11 and they were'already in.the reactor.
And 2 ~ testing'it in that'way to minimize.the drop 3 consequences?
- 4. . A' Right.
.5 0l But when you talk about this 6 particular, procedure that you wanted Parks to i
7 w r'i t e with. respect to movement' of the missile. ! 8' shields, which procedure.was'it? i 9 A I don't know a number or name. 10 O -It,wasn't the load test procedure for L 11 the polar crane? I
, l '2 A Mo.
l(f :13 Q Can you identify.it.in any way? j 14. A Well, my answer no may be wrong in the l l l2 15 context that they may have combined that 16 function and not only moved' the missile shields 17 to some place so they could do the load test, l 18 but also put them away after it was all said and l 19 done. And it may have been one procedure. l 20 What we were doing was -- we 1 21 physically wanted the missile shields moved, i 22 And obviously the polar crane had to be l oa d l l 23 tested before we could use it to pick up the 1 1 24 head. ] l 25 Now, whether that was one procedure or '
78
- 1. ~20 procedures was reallyono~ concern of ours, s r - '()I 2 -- other: tha n th a t th ey got to that milestone.
31 0 What I don't understand is, 'a s . I- 'l
- 2: 1 l 4 understand _what was going on1withLParks'and his )
l . 5' complaints-.about the load test procedure ~was
.6 that he wasn't the drafter of it. He g o t' - i t. as-7 a review item,'and he wouldn't sign o'ff onlit. _j l
l 1 8 So that is the matter that is 9 ' confusing to me. 10 A He may not have written'it. He'may l 11 have been a reviewer.
-12 MR. HICKEY: Can I see if I'can' !
()' 13 clarify something? a l 14 I never heard Mr. Morris. indicate i I 15' that -- first of all, you talked about 'a n 16 example of Parks being unwi'lling to write 17 procedures without having a l.1 the data. 18 THE WITNESS: Yes. i 19 MR. HICKEY: And then I think you 20 testified that you recalled a particular
' 21- instance; but you didn't remember whether this i 22 involved Rich Parks or not, where there was a l
23 need for a procedure to move the missile shields 24 out of the way and that there was an issue of 25 whether that would be prepared with all the data
79: L 1 or not all the data. [^9
^~#
i 2' Do you remember that'that.was an
- 3. assignment given to Rick Parka specifically?
'4 THE WITNESS: No. )
I S. MR. HICKEY: You don't know?- 6 THE WITNESS: No. i l 7 MR. HICKEY: So I don't'think that the j L i 8 witness has testified that there was a' procedure' l 9 that' Rick Parks was refusing to write that was d i 10 coming to'the attention of the-Head Lift Task-u 11 Force relating to the movement of the missile 12 shields or the polar crane load test, which is t () 13 what'I thought your question assumed.- 14 BY MR. JOHNSON: 15 Q You started out by you saying, Mr. 16 Morris, that something was coming back to you; 17 and it was the procedure that dealt with the 18 movement of the missile shields and this four-19 20-ton shields being moved off the vessel. 20 I was trying to find out what you 21 called that procedure. ; 22 A I don't know what the procedure is. 23 There was also a procedure that related to the I 24 draining of the. reactor coolant system and you 25 had to go to a particular level.
80-1 And'a lot of those -- any time'it was
T 2; specifically involved with.the reactor coolant
- 3 system, Site Operations did write it. Who' wrote.
4 theEpolar crane load tests was probably.the
'5 , polar crane working crew. l 6 0 I was. going'to say I think that- is 7 probably more accurate, because this particular )
8 revision f o r. the' load test is prepared by ; 9 Michael Radbill, on March 9, 1983. l- l' O So with respect to the load test for I think it was not ! 11 the polar crane recovery, i [. 12 prepared by Site Operations. lI[ ) 33 A Did you want me to answer something? l 14 0 No. But it seems to me that by ) 1 15 looking at that cover sheet or sign-off sheet ! 16 for Revision 3 for that procedure, you can see 17 that -- you would agree, wouldn't you, that it 10 was Mr. Radbill who prepared it? i 19 A Yes. 20 Q Do you recall when this procedure 21 about the concerned removal of the missile 22 shields was, in fact, written or who wrote it? ; 23 A In the same time frame because the 24 l oa d test had to use the missile shields. 25 0 And with respect to the draining of
81 ! 1 1- .the steam generators, 'do.you-know when that { ( '1 L)'- 2' was?. l 3 A We were talking about it in-the same l
'4 context. The1 specific date I don't.know, but i n-i i l 5 the same general time frame. ]
I 6 First the missile. shields had to be ) :. I 7 moved -- or several things hadito be done. The a b L '8 missile shields had to be moved, and the reactor L 9 vessel had to'be drained 1to below the flange. 10- And b oth ' tho se procedures had to be in place ,l
)
l
'll before'you'could obviously do those. And they 12 were'in.that- same time frame. J
( 13 Q Do you know whether or not Mr. Parks 14 drafted those procedures? 15 A No, I don't. 16- 0 Do you know who did d r a f t .. t h e 17 procedures? 18 A Well, it was either him or Bubba l 19 Marshall. They were the two. i 20 0 Were you attending the Head Lift
.21 Task Force meetings when the matter came back to 22 you on your punch. list that these had been 23 drafted? l l
l 24' A' I don't know. J 25 Q You just don't recall a meeting in 1 -
l-
-02 j ~
I i
- 1. 'which'the.fprepared one was discussed? ;
J d 2 A ;No.. {
.3 MR .: JOHMSON:- Thank you no,further j i
4 questions. !
.(
5 MR. HICKEY: No further questions. I 6 MS. KUENSTER: No questions. 7
.]
8 (Depocition adj ou r ne d at 4:30 p.m.) 9 10 11 12
- O 13 14 15 i
16 17 1 18 19-l 20 21 22 23
':/ 24
.]
25
83 i (b DD331?1DbID
'l i
! i l 1 I, Gwen A. Lee.r y , the of ficer bef ore whom the within { 1 deposition (s) was taken, do hereby certify that the witness k i a whose testimony appears in the foregoing deposition, was duly sworn by me on said date and that the transcribed _ 1, deposition of said witness is a true record of the testimony given by said witness; ie That the proceeding is herein recorded fully and j i accurately; I 1 That I am neither attorney nor counsel for, nor
]
related to any of the parties to the action in which these
,/ }
depositions were taken, and further that I am not a 1 relative of any attcrney or counsel employed by the parties hereto, or financially interested in this action. 1 _.. _t - A7 _ Gwen A. Lea y,y Re ter
!!otary Public in and for the Commonwealth of Pennsylvania
(~\ G
f
!h. ^
' .\
Jl 1 l I have read my deposition and it is true and ! correct except for any corrections noted on the attached ~ erratta cheet.
?
t-9: ;
~~~~~--- __________________
y i l I f 9
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t.. .. I 1 I' THELEN, M AHHIN, tIOHNSON 8, BRIDGES
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I l Ms. Gwen A. Leary, Reporter i Monick Stenographic Service, Inc. 1413 Old Mill Road Wyomissing, Pennsylvania 19610 Re: Deposition of Thomas E. Morris
Dear Ms. Leary:
Thomas E. Morris has read his deposition and has made the following changes: Pace 61. line 21: Haltman is changed to Hultman. ! i Pace 62, line 2: Coleman is changed to Kalman. f7 Thank you for your cooperation and prompt ( ) attention to this matter.
/% /
i Very truly yours, THELEN, MARRIN, JOHNSON & BRIDGES j
~
e nife A. Kuenster JAK/ dig cc: Patrick Hickey, P.C. George E. Johnson, Esq. Charles A. Barth, Esq. , ss l
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Ms. Gwen A. Leary, Reporter Monick Stenographic Service, Inc. , 1413 Old Mill Road l' Wyomissing, Pennsylvania 19610 Re: Deposition of Thomas'E. Morris
Dear Ms. Leary:
Thomas E. Morris has read his deposition and has made the following changes: Pace 61, line 21: Haltman is changed to Hultman. Pace 62, line 2: Coleman is changed to Kalman. Thank you for your cooperation and prompt attention to this matter. Very truly yours, THELEN, MARRIN, JOHNSON En BRIDGES I
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e nife A. Kuenster JAK/ dig cc: Patrick Hickey, P.C. George.E.oJohnsoni.Esq.OF Charles A. Barth, Esq.
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,,,,,.....77 Ms. Gwen A. Leary, Reporter Monick Stenographic Service, Inc.
1413 Old Mill Road Wyomissing, Pennsylvania 19610 Re: Deposition of Thomas E. Morris _
Dear Ms. Leary:
Thomas E. Morris has read his deposition and has made the following changes: Pace 61, line 21: Haltman is changed to Hultman. Pace 62, line 2: Coleman is changed to Kalman. Thank you for your cooperation and prompt attention to this matter. Very truly yours, THELEN, MARRIN, JOHNSON & BRIDGES
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.e nife A. Kuenster JAK/ dig cc: Patrick Hickey, P.C.
-George E.? Johnson,.Esq.1 Charles A. Barth, Esq.
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