ML20238C587
| ML20238C587 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/09/1987 |
| From: | Sandford C BECHTEL GROUP, INC. |
| To: | |
| Shared Package | |
| ML20238C505 | List:
|
| References | |
| CIV-PEN, EA-84-137, NUDOCS 8712310103 | |
| Download: ML20238C587 (129) | |
Text
- - - - - - - -
ORGEAL UNITED STATES g
NUCLEAR REGULATORY COMMISSION l
IN THE MATTER OF:
DOCKET NO: 50-320 g
(Civil Penalty) i GPU NUCLEAR CORPORATION License No. DPR-73, EA84-137 (Three Mile Island Nuclear Station, Unit No. 2)
I' DEPOSITION OF CHARLES W.
SANDFORD LOCATION:
GAITHERSBURG, MARYLAND PAGES:
1 - 126 DATE:
THURSDAY, APRIL 9, 1987 ACE-FEDERAL REPORTERS, INC.
OfficialReporters 444 North Capitol Street Washington, D.C. 20001 (202)347-3700 DR AD K
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UNITED STATES OF AMERICA s
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k"l NUCLEAR REGULATORY COMMISSION 2
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BEFORE THE ADMINISTRATIVE' LAW JUDGE' At fb
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i In the Matter of:
Docket No. 50-320 0
4 (Civil Penalty) 5 GPU NUCLEAR CORPORATION Licensd No. DPR-73 6
(Three Mile Island Nuclear EA84-137, Station, Unit No. 2) o
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9
- - - - - - - - - - - - - - - - - -x 8
9 DEPOSITION OF" CHARLES W.
SANDFORD 10 u.
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Gaithersburg, Maryland
/
11
)t Thursday, April 9, 1987 A
l 12 1
N Deposition of CHARLES N.
SANDFORD, called for examina-f'J _
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13 tion pursuant to notice of deposition, at the offices of the 14 Bechtel Corporation, 15740 Shady Grove Road, at 9:53 a.m.
15 before WENDY S.
COX, a Notary Public within and for the 1
-16 District of Columbia,'when were present on behalf of the 17 respective parties:
18 GEORGE E. JOHNSON, ESQ.
Office of the Executive K
19 Legal Directot United Stateg Nuclear 20 Regulatory Commission Washington, D.
C.
20555 21 On behalf of the Nuclear Regulatory Commission.
22 J.
PATRICK HI(MEY, ESQ.
Shaw, Pittman, Potts 23
& Trowbridge
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e 2300 N Street, A. W.,
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24 Washington, D.
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20037 On behalf of GFU Nuclear g
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1 APPEARANCES'(Continued):
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KENNEDY P. RICHARDSON, ESO.
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Thelen, Marrin, Johnson.
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& Bridges One Kaiser Plaza 4
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Oakland, California' 94612
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On behalf of GPU 14uclear
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CONTENTS
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,2 KITNESS EXAMINATION L'harles W.
Sandford 3
- by Mr. Johnson 4
g by Mr. Richardson 122 4]l by Mr. Johnson 124 4 t. 7,1 5 fp,'
6 EXHIBITS
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'y NUMBER IDENTIFIED 4
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,Sanford-Exhibit 1 84 N
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Respondent's Exhibit A 122 l
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ACE. FEDERAL REPORTERS, INC.
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30477.0 COX 4
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- f. E 2 E E E E.I. H E E
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2 Whereupon, l
3 CHARLES W.
SANDFORD l
i 4
was called as a witness and, having first been duly sworn, 5
was examined and testified as follows:
6 EXAMINATION 7
BY MR. JOHNSON:
8
-Q Mr. Sandford, would you.please state your full 9
name?
f 10 A
Charles W.
Sandford, 11202 Farmland Drive, 11 Rockville, Maryland 20852.
12 Q
Mr. Sandford, have you been deposed before?-
l 0
13 A
Have I ever been deposed before?
14 Q
Yes.
15 A
Yes.
l 16
-Q So you are familiar with the deposition process?
17 A
Yes.
18 Q
Who is representing you today?
19 A
Pardon me?
20 0
Who is your attorney representing you today?
21 A
Ken Richardson.
22 Q
Did you receive a copy of the notice of deposition 23 of Charles W.
Sandford?
24 MR. RICHARDSON:
George, if I may, to speed things 25 along, I can tell you Mr. Sandford, we received the notice of ACE FEDERAL REPORTERS, INC.
202 347-3WK)
Nationwide Coverage MK)-33M646
!30477.0' COX' 5
1
' deposition without waiving any privileges.
I think,.if I can 2
just tell you, Mr. Sandford does-not have any documents'in-3 his, personal possession which are responsive to the notice of L
L
'4 deposition.
r-5 MR.. JOHNSON:
Okay.
l-6 THE WITNESS:
You gentlemen are going to'have to 7
speak up just a=little bit.
My right ear is better than my 8
-left, but my right.is not as good as it should be.
9 MR.. JOHNSON: 'We are just getting. started.
l 10 Usually we have no trouble with that.
I will try to.
11 THE WITNESS:
Shouting makes me nervous, so don't' 12 shout.
13 MR. RICHARDSON:
I just told Mr. Johnson that you 14 have no documents in your personal possession relating to 15 Mr. Parks.
16 THE WITNESS:
That's correct.
17 BY MR.' JOHNSON:
18 Q
Mr. Sandford, when did you join Bechtel 19 Corporation?
20 A
I joined Bechtel in November 3, 1975.
21 Q
In what capacity did you work with Bechtel at that 22 time?
23 A
At that time I was deputy operations manager for 24 the Gaithersburg power division.
25 Q
How long did you hold that position?
ACE FEDERAL REPORTERS, INC.
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A Approximately a year and one half.
2 Q
What was the next position you held?
3 A
I was then appointed project manager for the Grand 4
Gulf Nuclear Station.
5 Q
That was in 1977?
6 A
I would say so.
'76 or '77.
7 Q
What was the work that was involved, just 8
generally, in these two positions, deputy operations manager, 9
Gaithersburg power division, and this next one at Grand Gulf?.
10 A
Well, as deputy operations manager I was assistant 11 to the division operations manager, who was in charge of all 12 projects, the operation of all projects.
O 13 Q
Would that include startup and test operations?
14 A
Well, the assignment of the responsibilities 15 varied from department to department.
But the operation 16 manager was in effect, overall conduct of the projects to 17 start up.
18 Q
At Grand Gulf, what was your responsibility?
19 A
I was responsible for the conduct of that specific j
20 project.
21 Q
Of all Bechtel operations or all operations?
22 A
It was a Bechtel Engineering APC contract.
j J
23 Q
To construct Grand Gulf?
24 A
Yes.
25 Q
What did you do next after Grand Gulf and when?
ACE FEDERAL REPORTERS, INC.
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COX 7
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A I was project manager of Grand Gulf approximately l
2 14 to 15 months, and I reverted back to my original title, l
l 3
which was the assistant operations manager.
As a matter of 4
fact, I held that title in Grand Gulf, it would be considered 5
a special temporary assignment.
6 Q
So you came back to Gaithersburg?
7 A
That's correct.
I never lef t Gaithersburg.
I ran 8
Grand Gulf from Gaithersburg.
9 Q
So the project manager position -- the deputy 10 operations manager position, you came back to, but it was 11 then called assistant operations mane.ger?
12 A
No, the same title, just correct the record.
13 Q
It was a deputy?
Which was correct?
14 A
Deputy.
15 Q
Deputy was correct?
16 A
Yes.
17 Q
I am sorry.
That was in 1977 until what time?
18 A
I think in the interim I was assigned other 19 departments to supplement that.
20 Q
Just so that I can be clear.
21 A
Yes.
22 Q
Did you continue in the deputy operations manager 23 position until your retirement?
24 A
Oh, no, no, no.
25 Q
Would you bring me forward --
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Ace FEDERAL REPORTERS, INC.
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A Well, let me, if you will, please, just to kind of 2
give you a chronology, without it being exactly precise.
3 Q
okay, fine.
4 A
1978, I became a vice president of Bechtel Power 1
5 Corporation.
f 6
Q For any particular area?
I 7
A Well, I had -- again, I had project operations.
1 l
8 At that time I was assigned several other divisions of
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procurement.
These all came in varying degrees with l
10 considerable rapidity, so they may not be precise.
I think I 11 had the technical services group at that time.
At some point 12 in there, I picked up the personnel department.
13 The next major change in my career would have been l
14 probably around 1980 -- early '80s,
'82 or
'3, and I became 15 deputy general manager of the Gaithersburg power division.
16 Those duties entailed those described before.
I believe I 17 added the engineering and construction departments at that 18 time, and served in the position of the general manager in i
19 his absence.
20 Q
Is the general manager the --
21 A
General manager is in charge of -- is the manager l
22 for the Gaithersburg office.
23 Q
Is that the last position?
24 A
That takes us up to August 31, 1986, retired.
25 Q
Congratulations.
Have you worked in the ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-336-6646 L
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1 consultant role in connection with Bechtel since your 2
retirement?
I 3
A No.
I have a consulting agreement with Bechtel.
4 I have not accepted any assignments under that.
5 Q.
.When did Bechtel become involved at Three Mile 6
Island in connection with'the cleanup of Unit 2?
7 A
-Your initial question answered -- we became
~
8 involved in the.first movement of technical experts to TMI at-l 9
the' time of.the accident.
It was some months later.
I don't a
l 10 remember the exact date that we began to' negotiate-with GPU 1
11 to fulfill the role as general contractor for the recovery of q
12 the containment.
I i
O 13 Q
That contract was finalized sometime within a few.
l 14 months after the accident?
l 15 A
Certainly within a year.
16 Q
So sometime in the 1979-1980 time frame the 17 contract was --
18 A-To the best of my recollection, those are the 19 approximate dates.
20 Q
What was your role in implementing that contract?
21 A
I was designated as Bechtel's executive sponsor 22 for TMI work.
23 Q
Did that -- did your involvement with the contract 24 of recovery work change in any significant way over the 25 course of those years between 1979 and '80 and 1983?
ace-FEDERAL REPORTERS, INC.
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1 A
No.
2 Q
How would you describe your involvement, if you 3
could.
4 A
Well, I would describe'my personal' involvement as 5
having the responsibility for an overview of Bechtel 6
activities with regard to TMI work.
7 Q
Who were your principal-subordinates in this 8
effort?
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9 A
Our first project. manager, and you must understand' j
d 10 there were several phases, there was an early planning' stage-
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12 earlier contract, to plan and estimate the cost-of recovery
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13 of the plant.
That was done under the leadership of Chris 14 Judd, J-u-d-d.
15 Q
Okay.
16 A
Included in that team was Jim Thiesing, as a-17 prominent member, and several other technical people to help 18 them with the assessments.
19 Q
All right.
20 A
Later, with the-advent of a formal contract with 21 GPU, Jim Thiesing became the principal Bechtel 22 representative, and his title was project manager.
23 Q
So what time did -- that continued from 24 approximately 1980 until when?
25 A
Thiesing?
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ACE-FEDERAL REvonTEns, INC.
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1 Q
Yes.
He was your project manager until when?
2 A
Thiesing remained our -- not in that exact title 3
role, because of organizational changes, but he was the 4
predominant Bechtel representative on the site until such j
I 5
time as Bahman, B-a-h-m-a-n, Kanga.
It's Kanga, I guess, but 6
I call him Kanga, K-a-n-g-a, also a Bechtel vice president, 7
was transferred to the TMI site to act as director.
8 Q
And that occurred in the middle of 1982, 9
approximately?
10 A
Well, somebody will have to help me with that 11 date.
I don't know just what date that was.
It was there 12 approximately two years -- it was when we set up the 13 integrated operation, the time that we combined the GPU and 14 the Bechtel forces into one team.
15 Q
Okay.
That sets it for me, thank you.
So until 16 that reorganization, Mr. Thiesing was your principal contact 17 at the Island?
18 A
No, Mr. Kanga then became my principal contact at 19 the Island, and Mr. Thiesing would have reported through 20 Mr. Bruner, who was by then, I believe, manager of plant 21 operations or operations manager, one or the other.
22 Q
Mr. Thiesing, after the reorganization, did not 23 report to you through Mr. Kanga, I take it?
Through 24 Mr. Bruner?
25 A
His principal contact was through Mr. Bruner.
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ACE FEDERAL REPORTERS, INC.
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Q Prior to the reintegration into this organization,.
2 did Mr. Thiesing report directly to you?
3
-A I am not clear whether there was somebody else in.
4 Mr. Bruner's role or not, but certainly he and I had a close I
5 and continuing relationship.
6 Q
After the reorganization, did you maintain that l
7 close and continuing relationship with Mr. Thiesing?
8 A
I think that things worked more within the 9
channels at that time than I basically dealt with.
10 Mr. Kanga, there would be an occasion that Mr. Thiesing would l
11 be in the meetings or might stop by my office.
12 Q
So from the time of the reorganization, i
13 approximately, if I may, just state that it's in the record,
(
14 approximately September 30, October 1, 1982, is the official 15 date --
l l
16 MR. RICHARDSON:
Actually, I believe it's l
I 17 September 1.
i 1
18 MR. JOHNSON:
September 1, I am sorry.
l 19 MR. RICHARDSON:
That's right.
'l 20 BY MR. JOHNSON:
I 21 Q
From that time, Mr. -- your contact with the site 22 was indirect, primarily through Mr. Bruner and Mr. Kanga?
23 A
That's correct.
24 Q
Did you visit the site during the period after the
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25 reorganization?
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skCEJFEDERAL REPORTERS, INC.
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202-347-3700 Nationwide Coverage 800-3364M6 l
30477.0 13 7_ COX -
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A There were occasions that I visited the site.
I 2
was not a regular site visitor.
I wasn't on the site 3
inspecting.
But if we would have a meeting with regard to i
4 things we needed to do to strengthen this integrated 5
operation or to make it more efficient, I would go 6
participate in those programs with the employees.
'I sat 7
through one session of sensitivity meetings that we held I
8 between top management and top employees as we were trying to 9
merge the group into a cohesive unit.
From time to time I 10 visited the site.
i 11 Q
What level of reporting -- what kinds of matters l
12 were reported to you on a regular basis after the 13 reorganization on events?
What kind of documentation did you 14 get?
What kinds of briefings did you get from Mr. Bruner or 15 other people?
16 A
Well, I got various periodic reports from 17 Mr. Kanga.
We were in --
18 Q
Could you describe the types of reports that you 19 got?
20 A
I don't think I can in any specific detail.
I 21 recall that I would get reports.
We had an oversight 22 committee made up of national experts that were watching the 23 site.
They met, I believe, quarterly, and I was either 24 invited to those meetings, some of which I attended, the f'T 25 others which I didn't.
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/\\CE FEDERAL REPORTERS, INC.
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1 Q'
What was it?
2
'A The overview advisory committee,.I believe.
It
)
3 was headed by'the'now head of the' NASA organization..
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.1 4
.Q Okay, fine.
- 1 5
A I also would receive reports from Mr. Kanga about 6
progress on how the organization ~was progressing.
The-7 day-to-day and site operations were with Mr. Kanga's status 1
8 and his direct relationship.of reporting to Mr. Arnold.
9 Q
Could you explain that, Mr. Sandford.
10 A
Yes.
The integrated operation concept, which was 11
' conceived by General Public Utilities and conceived ~for the 12 purpose of strengthening the efficiency of the whole group
'O 13 and merging them into a more cohesive cooperative group, was 14 to take the best qualified people from Bechtel and GPU, set 15 up a new organization chart.
And, without regard to which 16 organization they were in, to put the best qualified peoplo 17 in the most critical. jobs.
Those roles might fall to Bechtel 18 people, or they might fall to GPU people.
a 19 Q
I was actually not asking for that type of 20 explanation.
What I really was looking for was the 21 relationship between Mr. Kanga and Mr. Arnold.
22 A
Okay.
To narrow it down, the director, who 23 Bechtel was requested to furnish, was to report to Mr Arnold 24 on a day-to-day basis and to take directions as to how that
- ()
25 project was to be conducted.
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ACE FEDERAL REPORTERS, INC.
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l 30477.0 COX 15 i
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1 Q
Did you have any. regular contact directly with 2
.Mr.
Arnold?
3 A
Yes, we talked from time.to time.
4 We talked, usually, if we would have something 5
unusual.
6 Q
Did you have any regular kind of system for 7
communication with Mr. Arnold?
8 A
No, we didn't have a weekly meeting or a quarterly 9
meeting or anything of that matter.
He basically worked with-10 me most of the time through Mr. Kanga, if he wanted me to-11 know something he told Mr. Kanga.
We used Mr. Kanga pretty 12 much as a conduit.
.13 Q
When Mr. Arnold had something to say to you, he 14 would go through Mr. Kanga, and who would Mr. Kanga speak to?
'15 A
Mr. Kanga would speak to me.
16 Q
The-reason I asked you that --
17 A
If the message was directly for me.
If it.was 18 something Mr. Bruner could handle and it was within his 19 province, why, he would handle it with Mr. Bruner.
I don't 20 mean to imply that by being an executive sponsor at TMI, that 21 those were all the duties I had.
I also had the duties of 22 running this division.
23 Q
Right.
24 A
Particularly in the absence of the division 25 manager.
So usually I got involved in things of some ACE FEDERAL REPORTERS, INC.
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considerable' magnitude after Mr. Kanga was'put at'the~ site --
2
-assigned to'the site would be'better.
3 Q
Now, would you consider -- was the polar. crane 4
recovery project -- I am n'ot'sure I used the right' 5
terminology.
But'the refurbishment-of the polar crane. -Was 6
that a matter that had your attention; was that what you 7
would. call a major undertaking for Bechtel at the site?
8 A
Not early on.
During the technical planning for.
9 the recovery, I.really was not involved in the planning for 10 the. polar crane.
11
'O The polar crane had a key role, didn't it, in-the 12 recovery?
13 A
But it had a technical role.
I didn't deal in 14 technical roles or technical solutions to problems.
15 Q
Who did that?
16 A
That would be Mr. Kanga and the integrated team 17 operations.
18 Q
Did there come a time when you became more 19 involved in the refurbishment program or polar crane project 20 during the '82-83 period?
21 A
There came a time I became more aware.
22 Q
More aware?
23 A.
Of the polar crane, and that jumped several cons 24 down the road to what we are talking about now.
But as you 25 know and I know, it became an issue, both technical and i
ACE. FEDERAL REronTens, INC.
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1 political,:at one time.-
2 Q
Sure.
3 A
I certainly was aware of that, but I am not sure 4
that you want to jump that far along.
5 Q
When your level of awareness of the level of the 6
polar crane became more sensitized?
7 MR. RICHARDSON:
What do you mean more 8
sensitized?
In what respect? 'He has already indicated he 9
was aware of a polar crane.
10 MR. JOHNSON:
All right.
11 BY MR. JOHNSON:
12 Q
When did the information of the polar crane O
13 concerning the refurbishment of the polar crane become 14 greater than it had been?
1 15 A
I think my interest level increased after the 16 Parks incident.
17 Q
Could you put that in time?
When you say the 18 Parks incident, do you mean -- what do you mean?
19 A
Well, what I mean is maybe for the first time that 20 I heard anything of concern about the polar crane was during i
1 21 my meeting with Mr. Parks sometime in March.
l 22 Q
Okay.
23 A
My concern about the polar crane developed 24 following Mr. Parks' public allegations of safety t
25 deficiencies within the crane.
l l
ACE FEDERAL REPORTERS, INC.
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, COX
,b 1
Q One of the documents that was prepared on-site, 2
let me represent to you, was a weekly report about the TMI-2 3
polar crane recovery, and I didn't bring most of them with 4
me, but I have one attached to another deposition.
I was.
5 wondering whether you ever saw this particular report or any 6
report like it that was generated by the recovery people at 7
the site.
8 A
I can't speak with certainty.
9 Q
With respect to -- what can't you speak with 10 certainty, that you didn't see this report or didn't see any 11 reports like it, or could you clarify that?
12 A
No, I am not going to say that I didn't see any 13 report like it.
I am simply saying that I don't recall.
I 14 saw a lot of reports that came through my desk, and whether I 15 saw that specific report or not, I don't know.
16 Q
Were you aware of the -- of an interface within 17 the funding of the polar crane or the containment recovery, 18 let's see, the head lift project, and the polar crane and the 19 flow of funds to Bechtel.
Was that within the purview of 20 your responsibilities, to integrate the funding of Bechtel's 21 project at the site, and the operations that were taking 22 place to lift the head?
23 A
No.
That was a project function.
They had their 24 own cost people and estimators at the site.
But all budgeted
~
25 activities were the responsibilities of the integrated team ACE FEDERAL REPORTERS, INC.
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30477.0 COX.
19 r
1 and the project team.
2 Q.
Did you have ---so you didn't have any oversight 3
-- did you have oversight. functions in that. regard?
4 A
Nothing specific.
5 Q
Were you' aware of any schedule lags or time 6
-crunches.that were developing during the winter.and spring of1 7
1983 with respect to the head lift. project?
8 MR. RICHARDSON:
I think you need to be more l
9 specific'as to what you mean by a time crunch.
10 BY MR. JOHNSON:
11 Q
The schedule for lifting the-head.was falling 12 behind?
O.
13 A-I was generally aware of the continuous review and 14 reconstruction of the schedules.
I was aware that there was 15 a lot of rescheduling being done and there were slippages 16 inherent in almost all of that work done up.there.
17 Q
Did you have meetings with anyone to discuss +. hose 18 slippages?
Did you discuss it with Mr. Bruner?
19 A
I would have discussed them with Mr. Kanga.
20 Q
You say you would have.
Did you?
21 A
Pardon me?
22 Q
Did you?.
23 A
I am sure from time to time I discussed with 24 Mr. Kanga the status of the schedule in the TMI recovery that 25 would have been part of the oversight.
But, again, I
(}
l ACE FEDERAL REPORTERS, INC.
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qualified that to the extent'that thoso things were handled-2 almost exclusively on-site.
That'was a self-contained-
'3 integrated operation with'.the directors of it up.to 4
Mr. Arnold and Mr.-Kanga'in charge of the modifications to i
5 those.
I did not participate in'the modifications of 6
schedules, nor did'I participate _in the preparation of 7
schedules.
I was generally aware of what the status of those 8
efforts were.
9 Q
Did you have -.you said you had, from time to-10
. time, conversations with Mr. Arnold.
11 A
Yes, sir.
12 Q
Do you recall conversations during the 0
13 winter-spring '83 period with Mr. Arnold concerning the 14 schedule for the head lift?
15 A
I can't recall a specific conversation for you.
~
16 Mr. Arnold and I were in contact with problems that regarded 17 TMI and that were matters of concern to me.
So I would be-18 satisfied that he and I would, from time to time, did discuss 19 the schedules with regard to the head lift.
20 Q
Did there come a time when you became familiar 21 with something called the readiness review committee at the 22 Island?
23 A
Yes.
24 Q
Could you tell me when that was and what the 25 circumstances were?
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A I can't tell you when it was.
It seems to me that 2
it was a preface to the -- and during the planning process 3
for the head lift.
I don't know how that ties in with just 4
the whole operation of gaining access to the containment.
5 Q
Did Mr. Arnold contact you concerning the work of 6
the readiness review committee?
7 A
I don't recall any specific conversations that had 8
to do with just that committee.
9 Q
How did the information concerning the readiness 10 review committee come to you?
11 A
I received most of my reports directly from 12 Mr. Kanga.
To a lesser degree, it could have been from O
13 Mr. Bruner.
14 Q
These would have been primarily written or 15 primarily oral?
16 A
I think oral.
17 Q
With respect to the readiness review committee,
)
18 did you -- were you consulted with respect to any issues that 19 were raised in connection with that committee being 20 convened?
21 A
No.
I was not asked to solve or participate in 22 the solutions to the readiness committee findings.
l 23 0
Were the findings --
24 A
I did attend one or two to get the flavor of the
)
25 readiness committee activities.
I l
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Q When did you do that?
What was the time. frame?
q 2
A I can't help you on that.
i 3
Q Did it have to do with the head litt?
4 A
Either that or containment ingress.
5 Q
Does -that mean that: you went down to the site for.
6 those meetings?
7 A
Yes.
8 MR. RICHARDSON:
I believe he. testified that he 9
recalls attending one meeting.
10 THE WITNESS:
-Yes, well, I was going to qualify 1
11 that you made that more pluralistic than I meant it to 12 sound.
I recall at least one meeting, possibly two.
- Again, O
13 as I indicated to you, it was more to get a flavor of how 14 that committee was working and what kind of work they were 15 doing.
16 BY MR. JOHNSON:
17 Q
Okay.
What kind of flavor did you get?
What was 18 your impression?
19 A
I got the flavor of a group of highly technical 20 and opinionated engineers, all very skilled, many with 21 national reputations, and with many ideas of how each item 22 should be conducted.
I was impressed with the freedom of l
23 expression of thought, and I was glad I wasn't chairing the l
24 meeting.
I recall Mr. Arnold and Mr. Kanga conducted that 25 particular meeting.
Perhaps just Mr. Kanga, Mr. Arnold may
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30477.0 23 COX 1
not have been there, but it seems to me that he was.
2 Q
Do you recall any of the subjects discussed at 3
that meeting?
4 A
Not specifically.
5 Q
Generally?
6 A
Not generally.
I really don't know at this point 7
in time whether they were talking about containment ingress 8
or whether they were talking about the head lift, early on in l
I 9
this committee.
10 MR. RICHARDSON:
Can I interpose just a quick 11 question of clarification.
12 MR. JOHNSON:
Wait a second.
I would prefer if O
13 you would wait on your clarification questions.
14 MR. RICHARDSON:
All right.
15 BY MR. JOHNSON:
16 Q
Did you ever become aware of a review body that 17 operated under the TMI-2 procedures, GPUN procedures, called 18 the test working group?
19 A
I don't know if I recall these overview groups by 20 name.
I was aware probably -- I don't want to use the word 21 "probably."
I am sure I was aware, you know, of the various l
l 22 overview groups that were set up.
There were layers and 23 layers of them.
What their specific names were after this 24 period of time, I don't know.
But I would have known of the 25 overview groups.
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Q When you'say overview groups, what do you intend 2
to mean by overview?
3 A
Well, I mean to-imply that the actions, the 4
actions of planning, the conduct of the work by the people 5
actually doing the work, was continually. overseen by two or 6
'three groups, not the least of which was even an NRC group.
7 on-site.
So they are a very closely. scrutinized operation 8
from my point of view.
9 Q
In your conversations with Mr. Kanga, did he ever 10 have any occasion to bring up the question of compliance with 11 administrative procedures with respect to the polar crane 12 load. test procedure?
O 13 A
Do that one again, please.
14 Q
In your-conversations with Mr. Kanga, did he ever 15 have occasion to raise with you compliance with GPUN 16 administrative procedures of a particular procedure, a load i
17 test, polar crane load test procedure?
18 A
Well, you have qualified this now to be GPU
]
19 administrative procedures.
20 Q
Yes.
21 A
I am trying to understand; had you asked me a 22 general question and not been so specific, I probably could 1
23 have given you an affirmative.
24 If you asked me if he discussed with me GPU -- if 25 you would get that narrow with it, I am not sure that I can
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I i
1
'be responsive to that.
]
2 Q
Okay.
So, would it be fair to say that he did l
3 discuss compliance with administrative procedures with you?
4 A
Well, I am somewhat concerned by this l
5 interrogation in this sense, that this happened here, and 6
this happened here, and we seem to be moving from I am trying 7
to answer a question in this time frame, which has one 8
answer; and another question that now seems to lead me to 9
another time frame, which has another answer and another 10 connotation.
While I am trying to be responsive, I am having 11 some trouble jumping around.
Maybe you don't mean to do 12 that.
13 Before you assured me that you were trying to 14 proceed in just a very slow, easy, orderly manner, in kind of 15 a chronological order.
I think that question is out of 16 chronological order for me to answer.
I will be happy to be 17 responsive to it when it falls into the sequence of events 18 sometime later down the road.
19 0
Well, my -- I am afraid I am not sure why it is 20 that you feel you have it out of sequence.
In the way I am 21 thinking, it's in sequence.
But let's back up a second.
If 22 you would just tell me where you think we are in the l
23 sequence, and then maybe I will pick up there.
24 MR. RICHARDSON:
The problem with that question is 25 that you are asking him as to what you think you are doing p) u ACE FEDERAL REPORTERS, INC.
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with your examination.
With all due respect, why don't you 2
restate a question and give it a time frame.
3 THE WITNESS:
Let me -- can we go off the record a 4
minute?
5 MR. JOHNSON:
I prefer we stay on the record.
6 THE WITNESS:
All right.
We will stay on the 7
record.
The thing that is -- what I would like to see evoJve 8
from this, and for this reason, it's very difficult for an 9
outsider to understand the complexity of the TMI project.
10 Now, I am not including you as an outsider.
I expect you now 11 remember'and know more in detail than I can recall in three i
12 years -- but there is a great personal interplay between this 13 time that Bechtel was the prime contractor to the time that 14 we went into an integrated operation, the personality 15 conflicts that resulted from that activity, and then on into 16 the era of where we had the Parks incident and on ad 17 infinitum to the conclusion.
My mind works, and my 18 recollection works best in those successive snapshots, if you 19 will.
20 BY MR. JOHNSON:
21 Q
I see.
22 A
So that was the gist of my question is all.
23 Q
I see.
24 A
It's a very complex subject and a very complex job 25 and tremendous pressure, although I am not now on a soapbox.
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30477.0 COX 27 1
I am not really trying to make a record of it.
I am just 2
saying those are the things that I seem to be working 3
aga i'ns t, although I want to be responsive to your question.
4 Q
I appreciate it.
Let's back up to the point where 5
you say there came a time when there became personality 6
pressures or conflicts.
I don't recall exactly the words you 7
used.
What were you referring to and in what time frame?
8 A
I am talking -- it was particularly troublesome to 9
both organizations at the time we created an integrated 10 operation.
11 Q
Yes.
12 A
I don't mean to say that they were malicious O
13 troubles, I don't mean to say that the people acted less than I
14 professionally.
I simply mean to say that it is a very 15 complex organizational matter to take the technical people of I
l 16 a Bechtel and combine them with the technical people of the 17 GPU and immediately start off with a smooth-running efficient 18 operation.
Since we were interested in a -- our overriding 19 concern was always the public health and safety of the 20 public.
Therefore, it was imperative in our thoughts that in 21 a safe manner that we proceed to recover that plant as 22 quickly as we could.
23 We went through a period of time.
These were the 24 sensitivity hearings, I mentioned the fact that I would go up 25 and meet with Mr. Dieckamp and Mr. Arnold about the group,
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l 30477.0 i _ COX 28 1 1 1 that both of our corporations were committed to having this 2 work and that we were all to pull together, and that even 3 though cometimes they were under us and sometimes we were 4 under them, that's the way we felt that we would best get the 5 job done. So that's what I had reference to. 6 Q You were referring to the sensitivity meetings 7 that you went to and to the time in which the integration 8 started. This was a process, I take it, that didn't happen 9 overnight; is that fair? 10 A It didn't happen overnight. 11 Q Did it ever happen -- well, let me take that 12 back. What I would really like to know is, in your view, did 13' you identify particular events or benchmarks during this 14 period after the integration which stand out in your mind as 15 indicative of the developments in terms of the personalities 16 meshing togather or not meshing together? 17 A Well, my impression was that we made slow but 18 steady improvement, and that the organization did become 19 effective and efficient, and it still has a freedom of 20 expression of diverse technical opinions. I think Mr. Kanga 21 provided strong leadership after he had heard all of the 22 sides of the discussion. He is a very technically competent 23 person himself, that he was in the best position to make a 24 decision as to what course of action he wanted the 25 organization to follow. (} ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-33(r6646
i/ .] m. s N t v 30477.O g OCOX '29J 1 Q-As part of the personality or personnel.pioblems A i .l 2 that had to be worked out, is one of them-that yo4were .l referringtoclashesbetwebnMr. King'andtir)Thiesing, 3 . i 4 between the site operations on the one hand and the recovery 1 t 5 programs on the other?, 6 MR. RICHARDSON: Excuse me,.that's a compound' 'I \\l 7 question. Are'you asking whether the witness recalls tension ~ 8 .or conflicts.between the two departments,:or are you asking 9 him whether he recalls conflictE between Mr. King, 10 personally,-'and Mr. Thiesing, personally? 11 THE WITNESS: Well, I was goin/p t Inswer them .s 12 both. So with your indulgence. O' 13 MR. RICHARDSON: All right. 14 BY MR. JOHNSON: 15 Q Go ahead. 1 16 A I quote from 27 years of experience in the utility. 17 business, and I had primary responsibilities for what we l
- w 18 called the production department, which by your frame of 19 reference, would be an operations department.
I also had the 20 primary responsibility for the engineering procnt'ement and so f 21 forth. I was an executive vice president of (.owa Electric 22 Light & Power. I had the primary responsibilities and was 't. 23 project manager at that time for the construction,of'the 24 Duane Arnold Energy Center in Iowa. I can tell you from that / 25 experience that it is an everyday occurrence that there will s ACE FEDERAL REPORTERS, INC. 202-347-37(K) Nationwide Coverage 8(Kk3364446
i 30477.0 COX 30 I) s. I be a conflict between the men responsible for actually i 2 operating the plants and the men that are trying to engineer 3 and construct them. That is inherent in the industry. 4 And so if we ask, did that carry over to Three 5 Mile Ieland, it carries over to every plant that you would go 6 make an analysis. So, certainly, that primary " leave me 7 alone, this is my plant, I will operate the plant," a:,d the 8 engineers and the people saying that "we are planning this 9 for you, we have these strategic plans, we have these 10 technical plans, and this is the way you must do it" sort of 11 thing, that conflict exists. Good management can control it 12 so that it's healthy. All of these things I speak of are 13 bad. 14 I will now speak with respect to Mr. Thiesing and 15 Mr. King. I think it was common knowledge that they had some 16 personality conflicts. They weren't alone. We just have 17 singled them out. There were other personality conflicts. 18 0 How were those conflicts communicated to you? How 19 did you become aware of them? 20 A Well, they were adjudicated in these meetings that 21 we have discussed by Mr. Kanga. He would listen to the 22 operations point of view. He would listen to Mr. Thiesing ? 23 and other points of view, and then he would decide. And in 24 the course of analyzing his actions, often he would discuss 25 them with me. ~} 1 ACE FEDERAL REPORTERS, INC. j I 202-347-3700 Nationwide Coserage 8(K)-336-6646 _o
30477.0 COX 31 !O .V 1 Q Did he discuss -- okay. You said he discussed 2 them with you. One of the conflicts that is central to this 3 litigation that we are involved-with here had to do with 4 conflicts over procedures to be followed in refurbishing the 5 polar crane, and specifically whether the polar crane load 6 test was to follow certain GPUN administrative procedures. 7 .Did Mr. Kanga apprise you of disputes on that subject? 8 A Repeat the question, please. I didn't hear the 9 last portion. 10 Q Did Mr. Kanga apprise you of disputes between the 11 operations point of view and the recovery point of view j 12 concerning the application of GPUN administrative procedures O 13 to the polar crane load test procedure, or polar crane 4 14 procedures in general? r 15 MR. RICHARDSON: Excuse me. I take it when you 16 say from the recovery point of view, you are referring to the l 17 point of view of recovery programs? l 18 MR. JOHNSON: Yes. This is Mr. Thiesing's 19 department. 1 20 THE WITNESS: Most of these internal struggles 21 stayed on the site. I am certain that I discussed with I 22 Mr. Kanga that there were questions about -- and this was 23 quite late. There were questions about the administrative 24 procedures, and that he was making determinations in those If my memory serves me right -- and please correct ("T 25 arenas. %-) \\ ) l ACE. FEDERAL REPORTERS, INC. l 202-317 3700 PL icnaide Coverage 800-336 4 46
L ' 30477.0 COX _3 2 ' LO 1 me if I am wrong on this -- that when that was first. 2 assigned, it was assigned entirely to Bechtel. I think 3 Bechtel had the primary responsibility at-one time for doing 4 that head lift. And then when the integrated operation came 5 in, I think that changed. Can anybody help;me with that? Is 6 that correct? 7 MR. RICHARDSON: Well, it's somewhat against the 8 clubhouse rules for me to test 5fy. l 9 THE WITNESS: Okay. I am just trying to get the 10 chronology right. 11 MR. RICHARDSON: I don't mind volunteering that I 12 think.it's correct. 13 BY MR. JOHNSON: 14 Q You said it was quite late, as a descriptive 15 ~ term. What did you mean by that? 16 A What I am saying is that the crane issues, while I 17 they went on, those discussions, I am sure went on.in those 18 oversight committees and those kinds of things. There were 19 discussions among the individuals at the site, and there were 20 different interpretations as to just what each of them 21 meant. Those did not become an off -site problem till quite 22 late. I 1 23 Q You were not consulted for your interpretation of l 24 these procedures, I assume? I 25 A No. ACE FEDERAL REPORTERS, INC. I 202-347-3700 Nationwide Coverage 8(433MM6 l
1 l 0 l I 1 30477.0 COX 33 1 Q You say that Mr. Kanga had occasion to make 2 determinations about these matters? 3 A Yes. 4 Q I take it you learned of his determinations 5 through oral discussions with him? j 6 A Yes. 7 Q Do you recall learning of his determination with 8 respect to the particular question that Mr. Parks raised, 9 that is whether administrative procedure 1047, which has a 10 test procedure, and 1043, which is a modification. procedure, 11 were applicable to the polar crane load test procedure? 12 A Well, my qualification of that answer would be, 7 13 again, the timing. I certainly became aware of it after the 14 issue became as major as it did. I don't think I was aware 15 of it before that time, that that was a central issue. 16 There seems to be some connotation in that 17 question that if they were done under Bechtel's quality 18 program, that they were somehow less safe than if they were 19 done under the GPU program. I would suggest to you that 20 nothing could be further from the truth, that Bechtel has a 21 very we31 qualified quality program, and one can argue the 22 technical merits of whether they should have ever been put 23 under 'he Bechtel quality program or not. I think that could 24 be sustained. 25 Q Okay. ace FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 8( 4 336 6646
I L l 1 30477.0' l COX: 34 tO 1 A But to get any implication because of the ' fact 2 that,we were-done.under a Bechtel quality program inherently 3 made them unsafe, I think, would be'a totally wrong 4 assumption. 5 Q In your discussions with Mr. Kanga, did this type 6 of question come up? 7 A It would have been.very late. You know, it would 8 have been probably after the Parks incident and after some 9 investigation of the polar crane incident. There was also a 10 contention, as you know, that I believe it was Mr. Thiesing's 11 group, ' felt that he had formal approval from whatever 12 approval source was required to conduct that work in the 13 manner it was being conducted. .There's still a contention 14 whether one party says no, one party says yes. But I think 15 there's an honest difference of' opinion. 16 Q There was a question that was raised, let me 17 represent, by Mr. Parks. It.was raised in different forms, 18 but one form was a comment, one resolution form, in which 19 Mr. Parks wrote out on February 17, 1983, which he submitted 20 to the leader, I think, of the polar crane task group. I 21 think it was submitted to Mr. Radbill. ?? A Yes. 11 23 Q Were you acquainted with the name of Mr. Radbill? 24 A No. 25 Q I want to focus on the dates here, because it was ( ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage p.3364M6
30477.0 COX 35 ^(s 1 written out on the 17th of February, and it was resolved, 2 according to this form, this is an exhibit in a deposition, 3 the Chwastyk Deposition Exhibit 1, I believe -- no. Chwastyk 4 Exhibit Number 7. It contains Mr. Parks' comments about the 5 procedure that he was reviewing, which, as I indicated here, 6 polar crane load test. Then it contains the comments, 7 " reasons for rejection of Mr. Radbill." 8 It goes on -- initially, it would have been just 9 this document. And then when it came back, it was sent back 10 to site operations by this -- I believe, yes, to Mr. King 11 from Mr. Lake, from recovery operations, with their comments, 12 in type form. If you would look at this, you would see that O 13 there was a difference of opinion about the application of 14 the test procedure. Could you just look at that, please, for 15 me. Take your time. 16 A Okay. Do you have a question? i 17 Q Yes. Were you -- do you recollect a time when you 18 first became aware of a dispute of the nature that is 19 represented by this document? 20 A My best estimate would be when I met with Parks. 21 See, I didn't see these types of documents. I didn't delve 22 into this type of detail. This was that integrated operation 23 operating as I described. You have Parks on one side with an 24 opinion. You have a technical -- another man on the other 25 side of the ledger saying I agree with this, I disagree with (} l l /\\CEJFEDERAL REPORTERS, INC. I 202-347-3700 Nationwide Coserage H(XL33MM6 i
1 30477.0 36 L o. COX-o I i that. That's the way the process worked. If it got serious 2 enough, it got.up to Mr. Kanga, got up to the oversight 1 (' 3 committee, and they. ruled. L L 4 Q Now, these comments generated a number of 5 meetings. One of the meetings it led to was a meeting.of the 6 -- it's hard to read these pages upside down -- was a meeting 7 of the test work group. This is another' document in the 8 Chwastyk deposition, number 12, dated the 7th of March, '83, 9 with the minutes of March 4 meeting of the TWG, test working 10 group, signed by the members or alternates of the group. It 11 contains a discussion.of a number of matters, including those 12 Mr. Parks was raising. One of the conclusions was, as it O 13 says on the third page, it was agreed that performance of the 14 load test would be in compliance with AP 1047. 15 I take it you never saw this document. Have you 16 ever seen this document before? 17 A I don't recall seeing that document, no. 18 Q Do you think you may have seen it? 19 A There's no reason to think that I have seen it. 20 Q Bear in mind the comment date was February 17 and 21 the first resolution was February 25. This meeting is March 22 4. I also would like to show you, these appear to be notes. 23 This appears to be part of Chwastyk Exhibit 9, handwritten 24 notes that were identified yesterday, I believe, by ( 25 Mr. Thiesing. Let me represent to you they are notes from a ACE FEDERAL REPORTERS, INC. 202-347-37(X) Nationwide Coverage SM)-33MM6
l l L L 30477'.0 COX 37' 1 meeting dated 2/28/83, and I believe they were notes taken by 2 Mr.. Pastor, who was a member of recovery-operations at the '3 site at'the' time.- It was in connection ~with preparation for 4 meetings or a meeting.of the readiness review committee. 5 Do.you recall, if you look at this document,-and '6 tell me whether you recall whether your familiarity with the 7 readiness review committee extended to that time frame, this 8 date here and a subsequent meeting of the readiness review 9 committee, 10 MR. RICHARDSON: Could you read that question 11 back, please. 12 (The. reporter read the record as requested.) O 13 BY MR. JOHNSON: 14 -0 I think that's a different document. l 15 A Okay, what was the question? 16 MR. RICHARDSON: I was going to ask Mr. Johnnon if 17 he would kindly restate the question. It wasn't very clear, j 18 MR. JOHNSON: Okay. 19 BY MR. JOHNSON: i 20 0 Do you recall being aware of the issues that are ) 21 discussed here in connection with your recollection of 22 knowledge of readiness review committee meeting? 23 MR. RICHARDSON: Technically, that's a compound 24 question. I guess what you mean to ask is whether he recalls l -25 being aware of any of the issues described.in those notes? I l. ACE-FEDERAL REPORTERS, INC. L: - 202-347 3700 Nationwide Coverage 800-33MM6 ~ l_________..
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MR.' JOHNSON: In connection with the readiness -2 review committee. 3 THE WITNESS: I don't think so. 4 BY MR. JOHNSON: 5 Q Do you recall Mr. Kanga apprising you of meetings 6 Din connection with the convening of the readiness review '7 committee at that time, that is the late February or'early 8 March 1983? 9 A I think.I would give the same answer, that I was 10 in contact with Mr. Kanga quite often,.and if there was 11 anything particularly troubling about'that, it is most likely 12 he would have discussed it with me. O 'L/ 13 Q Now, as indicated by these notes, it says that 14 there will be top GPUN management involved in it. You 15 indicated from your knowledge that you had top flight 16 engineers involved in these readiness review committee 17 meetings. I 18 MR. RICHARDSON: Mr. Johnson, a quick observation, 19 'really, to assist you, and this is the point which I wanted 1 20 to raise earlier. You think Mr. Sandford mentioned engineers ) 21 with national reputations. You may wish to pursue this, but 22 there was another committee, I believe, called TAG, which I 23 think was ultimately headed up by the head of NASA. There is 24 a question in my mind whether Mr. Sandford might be confusing l' what you are calling the readiness review committee with this 25 ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-33MM6
i 430477.0 3 COX ~ 39 1 other committee. 2 THE WITNESS: Well, to set the record straight, I-3 am aware there was an overview committee at the site.. I 'am ) 4 also aware there was a committee that you referred to. 5 BY MR. JOHNSON: 6 Q You mean that Mr. Richardson referred to?- 7 A Yes. In addition there was TAG. We have three 8 committees here I think we are talking about. Maybe it was 9 called an oversight committee, the one that had the present 10 head of NASA. I can't recall his name at the moment. Then. 11 there was a TAG group that did an overview. But this was a-12 group, as.I recall, of the people'at the site, conducting the 20 13 work, that had an oversight, overview committee, that they 14 sat down and thrashed out their processes, rules and i 15 procedures and regulations that they were operating the plant 16 by. I assume that's what this discussion is about. 17 MR. RICHARDSON: That's my admonition. If you are-18 not sure a particular meeting had the label, readiness review 19 committee, then I think we should proceed with caution. 20 MR. JOHNSON: Fine. Let's proceed with all 21 caution. 22 THE WITNESS: Can you clarify for me which 23 document that is from, which of those? 24 BY MR. JOHNSON: 25 Q I would like to -- these meetings, this is from a l l. ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage WKU6 6646
30477.0 COX 40 0 -1 . meeting, I would represent, of the date that is. indicated, 2 these notes..But I don't think I have the minutes of the 3 meeting that took place. We did -- I did show you thir -l 4 Chwastyk Exhibit 16,.which was that weekly. report dated March 5 ,4, 1983, of the TMI-2' polar crane recovery. It's a weekly .6 summary page. It does refer to the. readiness review. That 7 the' director of TMI-2, which would have been Mr. Kanga, is i 8 that correct, at that time?. l 9 A Yes. 10 0 "Has placed a hold on implementation of the load. '4 11 test procedure pending the outcome of the formal readiness 12 review. GPU' upper management has convened the review to ~ 13 insure that polar crane refurbishment has proceeded in a safe 14 and technically correct manner and that the load test 15 . procedure is safe. Upon completion of the review on March j 16 12, it is expected that the review board will conclude that 17 the refurbishment work was well done, is sufficient, and that .l 18 the procedure is safe. i 19 "This favorable conclusion will, in turn, trigger 20 release of the hold on implementing the Acad test." 21 My question is, were you aware at that time of j I 22 that process? l 23 A Well, as I have indicated to you before, that 1 l 24 1sese were internal site matters. There's no reason, other l 25 San to think some conversations I might have had with 1 l Ace FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coverage 800-336 6646 l 1 j
1 l 30477.0 COX 41 i 1 Mr. Kanga over the phone, that he was particularly concerned i 2 about an issue. I'would not have been involved in this kind 3 of detail. I think I described my duties as an overview of -j 4 what was going on. 5 Q So you may have, but you don't recall specifically 6 a conversation with Mr. Kanga on the subject? You may have 7 had a conversation? I 1 8 A I don't recall Mr. Kanga spent a lot of time 9 trying to get me to help him make up his mind about which 10 procedure was applicable at the site. 11 Q Yes. I am sorry, I didn't mean to cut you off. 12 A That's fine. 13 MR. JOHNSON: Would you like to take a.five-minute 14 break. 15 (Reces s. ) l 16 MR. JOHNSON: Back on the record. 17 BY MR. JOHNSON: i 18 Q What was the first time that you became acquainted 1 19 with the name of Richard Parks? 20 A It must have been around the first of March, early ) 21 in March of '83 is the year we are talking about, I think,. 22 right? 23 Q Yes. Can you tell me the circumstances? j l l 24 A I think Mr. Bruner contacted me. 1 (~T 25 Q What do you recall about that contact. Mr. Bruner (_/ l ACE FEDERAL REPORTERS, INC. ] 202-347-3700 Nationwide Coverage 80(k3364M6 L______________________
-30477.0 COX .42 1 was here in Gaithersburg, I-take it? 2 A' That's correct. Well,.the gist of the '3 conversation was that there was a problem at the site 4 involving a GPU employee, and I may have known that before 5 .this conversation, and that there was a -- it was believed 6 that he owned a private firm by the name of Guiltech. It was 7 also believed that he was recruiting aeU employees from the 8 site to staff work, and Mr. Parks' name surface'd that we 9 might have'a problem of-our own, and that Mr. Parks had 10 apparently been involved, to some degree, in Mr. King's 3 J 11 ' activities in recruiting employees of GPU's for Quiltech. 12 Q This information=you got from Mr. Bruner? k a J 13 A That's my source,.as I recall. l 14 Q Did you get any information on the subject from j ) 15 Mr. Thiesing? j 16 A I don't think so. 17 Q What about from Mr. Kanga? Did he speak to you 18 about Mr. Parks? 19 A We would have talked about Mr. Parks. My memory 20 is that Mr. Bruner came in and brought up the subject. I am 21 sure I would have brought it up with Mr. Kanga, and we would i 22 have discussed it. I think that would be the order of 23
- sequence, j
l i 24 Q Okay. Do you recall the first time you spoke to l 25 Mr. Kanga about the Parks / King connection here? ACE-FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coverage W)-336 6646 I'
'30477.'0 H COX 43 1
- q 1
A I would think in the following day from the Parks 2 . revelation, or even the same day. 3 'O The same day you learned from Mr. Bruner that? l. 4 A What I learned from'Mr.'Bruner. Now, whether I .5 knew about Parks.a few! days before that and.I. talked.to Kanga 6 about that, I can't be specific. '7 Q Well, Mr. Thiesing drafted a handwritten' note,. 8 memorandum, which we discussed' yesterday in this deposition, 9 which was addressed to Mr. Bruner, I believe -- no, to '10 Mr. Kanga, a' copy to Mr. Bruner. We discussed this 11 yesterday, and it's dated 2/26/83'. I am-sorry,-your. counsel 12 has a copy of it, I_believe. I want to turn it-to another O 13 page. It's just a little simpler. If Mr. Richardson-has a 14 copy he.can show you. 15 MR. RICHARDSON: All right. Do you want to take- '16 this back?- l 17 MR. JOHNSON: Yes, I will. l 18 MR. RICHARDSON: Mine have some etchings on it, 'I k 19 but if Mr. Johnson promises not to peek, we can do that. j l 20 MR. JOHNSON: Okay. 21 MR. RICHARDSON: Okay. l 22 MR. JOHNSON: Is that the same document? 23 MR. RICHARDSON: Yes. 24 BY MR. JOHNSON: 25 Q In the course of writing this document, j i l l l ace-FEDERAL REPORTERS, INC. { 202-347-3700 Nationwide Coverage Mn336Wi46
30477.0 COX 44 1 Mr. Thiesing makes a reference to Mr. Parks on page 8. 2 A I was going.to kind of get the gist of this memo. 3 Is there any hurry? 4 Q Please take your time. 5 A or if you are going to ask about a specific 6 section, I will go directly to it. 1 7 Q I am not going to ask you about the whole 8 memorandum. I am just going to ask you about the Parks 9 connection. Familiarize yourself with it, because I am going 10 to ask you when you first saw it or if you saw it. 11 MR. RICHARDSON: In that case, Mr. Sandford, 12 perhaps you ought to familiarize yourself with the entire j C) f 13 memo. i 14 BY MR. JOHNSON: 15 Q I am not going to ask you in detail about the 16 memo, I am just going to ask you if you recall seeing it f 17 before. 1 18 A Well, I was looking for some help, because I was 19 looking for a date on my memo. f 20 Q Yes. 1 21 A It's undated, and the memo is not written to me. ) 22 The memo is written to Mr. Kanga and with a copy of ] 23 Mr. Druner. And exactly when it fell into my hands, I think l 24 it still supports my contention that Mr. Bruner came in and l 25 told me about the situation. I gave you my best estimate of {} Ace FEDERAL REPORTERS, INC. f f l 202 347-3700 Nationwide Coverage 800-336-6646 l )
30477.0 . 'COX 45 IV 1 the date as being around March 1. Even if Mr. Bruner brought i 2 it in the first time he saw it, even to allow any time for it 3 to be moved around and absorbed, March 1 is probably a pretty 4 good date. 5 Q That's fine. At that time you -- what did you do 6 when you learned of -- let me back up a second. Did Mr. i 7 Thiesing speak directly to you about the subject? j i 8 A . think I handled Mr. Thiesing through Mr. Bruner l 9 and Mr. Kanga. 10 Q So the information you had in your hands was the 1 11 -- you had this particular document that we just were ( ) 12 referring to in your hands at some point? O 13 A Yes. 14 Q Mr. Bruner showed it to you? 15 A I would think Mr. Bruner did that, yes. 16 Q Did you tell Mr. Bruner to follow up on it? What 17 did you tell Mr. Bruner? 18 A Well, I am sure that I told Mr. Bruner to follow f 19 up on it and see what he could find out about it. This 20 obviously is a big fo13owup to action that Mr. Thiesing took, i 21 and it's a request for Mr. Thiesing to explain what those 22 actions were and to make some record of what had gone on. 23 Q So Mr. Thiesing -- I 24 A Who originated that request, whether it was me or l { 25 Mr. Bruner, I am not certain. ) (} ACE FEDERAL REPORTERS, INC. l j 202-347 3700 Nationwide Coverage W L336-6646
l 30477.0 _ COX 46 L.) 1 Q All right. j 2 A It would have been within Mr. Bruner's province to 3 do it. Had it not been done, it certainly would have been j f 4 within my province to tell Mr. Bruner to see that it was 5 done. What_the order of sequence'of it was, I don't recall. 6 Q In discovery in this case, GPU provided us with 7 interrogatory responses. There was an interrogatory number 8 2, an answer provided to it by GPUN, attributed to Thiesing, 9 Gallagher, Santee, Sandford and Hoffman. 10 MR. HICKEY: Which one? 11 MR. JOHNSON: First one on October 1 '86. Starts 12 on page 11 and goes to page 12. It refers to the King O' 13 association with Quiltech, Quiltech investigation by 14 Mr. Thiesing, involvement of Mr. Parks and Ms. Rose Riddle. 15 BY MR. JOHNSON: 16 Q I wonder if you participated in response here. It i 17 starts down here on the second part of page 11, goes to page j l 18 12, i l 19 A How far do you want to go. Just to the end of -- I 20 Q 12. I don't have it any longer in front of me. I 21 think it was mainly the middle paragraph I wanted to focus 22 on. 23 A Okay. 1 24 Q My question is, did you participate in provid2ng j 25 this information? } l ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 4 46
E 1 30477.0 COX 47- ~1 MR. RICHARDSON: Can you'be more clear what you-2 mean by participate? 3 BY MR. JOHNSON:. 4 Q This starts on'11, which is attributed in part to 5 you. I' guess'I should'have let you; read the entire answer, 6 because it goes on, on the top of page-13..Just tell me .7 which part of that answer is attributable to you. 8 MR. RICHARDSON: Are you asking him what portions 9 of the answer he has personal knowledge of? 10 MR. JOHNSON: The answer is it is attributed to 11 him. I think it indicates that some'of.that information was 12 provided by Mr. Sandford, and I just wanted to know what it 13 was. 14 MR. RICHARDSON: Mr. Sandford, you are not at 15 liberty to' divulge what may have'been communicated between-i 1 16 you and myself_or other attorneys in this matter. 17 MR. JOHNSON: That's a pretty broad' statement, 18 Mr. Richardson. I think I am entitled to that portion of the 19 statement that is attributed under oath, I presume, to 20 Mr. Sandford. l 21 MR. RICHARDSON: It's unclear as to what you mean 22 by " attributed" to Mr. Sandford. 23 MR. JOHNSON:- Let me try to find out. Did you-24 contribute information to this response? 25 MR. RICHARDSON: Do you mean did he draft part of f} l 1 /\\CE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6
d i'
- 30477.0-L COX 48 Oj 1
the response? 2 MR. JOHNSON: I am not interested ~1n discovering 3 the: Interstices of your attorney-client relationship. .I am 4 only interested in knowing.the facts and-the facts that 5 Mr.'Sandford provided in this. answer. 'It,seems to me it's 6 represented by having his name there that.he did provide 7 facts. 8 BY MR. JOHNSON: 9 Q If you could tell me, what facts did you provide 10 that are stated here? 11 MR. RICHARDSON: You are. invading the privilege by 12 doing that. I will state my-position very briefly. O. 13 Undoubtedly-Mr. Sandford, over the period of several. years, 14 has~had communications.with attorneys about'the subject 15 matter of this case. It may very well be that information 16 conveyed, during the course of those discussions, is set 17 forth in part in this interrogatory and response. 18 But if you ask him what information he provided to 19 the attorneys, that is invading the privilege. I will let 20 you ask him whether he has any personal knowledge over any of 21 the matters set forth in this response, and you can certainly 22 inquire as to what he knows and for the basis of that 23 knowledge. But he is not at liberty to waive attorney-client 24 privilege and to divulge factual matters that he shared with 25 the attorneys. ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage MK)-336#46 _ _ _ _ _ _ _ _ 1.1___ ]
1 30477.0 ) ,_, C O X 49 l %Y 1 MR. JOHNSON: I disagree with part of that. Let l l 2 me ask you a question. Did Mr. Sandford execute an affidavit ) 3 in connection with this response? 4 MR. HICKEY: May I look at the response? 5 MR. RICHARDSON: I don't believe he did, but we 6 can doublecheck that. It appears to be verified by Philip R. 7 Clark. Is this the only verification? I guess this is your 8 office copy, but looking at your office copy I see a 9 verification signed by Philip R. Clark, which is made on the 10 basis of information and belief. 11 MR. JOHNSON: Let me ask Mr. Hickey. Is that the 12 only affidavit that was appended to this document? /~N \\- 13 MR. HICKEY: That's my recollection. 14 If I may, Mr. Johnson, I understood from your 15 comment that you want to know from Mr. Sandford what 16 knowledge he has about the matters that are stated in that I 17 response. It doesn't seem to me that in order -- you are 18 perfectly entitled to probe and ask him about that -- but it 19 doesn't seem to me that to obtain that information it's 20 necessary or appropriate to inquire about what information he 21 gave to the attorneys. 22 BY MR. JOHNSON: 23 Q In your conversations with Mr. Bruner concerning 24 the subject of the Quiltech connection with Mr. King, did you 25 discuss with him the typing of resumes by Miss Rose Riddle at (} ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage p 33MM6
-30477.0-COX 50 1 the request of Mr. Parks sometime during the summer of 1982?- ~ '2 A During the summer of '82? 3 Q Yes. That-was the time that I am attaching to the '4 timing of the typing, but did he raise that with you when he 5 spoke.to you on approximately March 1? 6 A I.didn't discuss anything with Mr. Bruner about 7 this situation'. The middle-of82 -- 8 Q' No,.that's'not my question. My' question is,.on 9 March 1, 1983, when you became aware. 10 A Oh, March of '83?. 11 Q Yes, March l', 1983,.is the date you became 12 familiar with this memorandum. 13 MR. RICHARDSON: He said March 1 or thereabouts. 14 BY MR. JOHNSON:. 15 Q Yes. We were also talking about you.had a. 16 conversation with.Mr. Bruner, and you think you would have 17 followed up on that. My question was, when you had these 18 conversations, did.you discuss the-typing of resumes by 3 \\ J 19 Ms. Rose Riddle for Mr. Parks? 20 A
- Yes, i
21 Q Did Mr. Bruner raise with you the propriety of 22 what Ms. Riddle had done? 23 A Yes. 24 Q What did he say? 25 A Pardon me? ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-33MM6 =_----_-_:_--_
30477.0 COX 51 1 Q What did he say to you? 2 A Well, he said that there might well be a Bechtel l 3 secretary involved in the Parks cctivities. That our 4 information was she had typed up some resumes at Mr. Parks 5 request. 6 Q Did Mr. Bruner state to you that Mr. Parks 7 appeared to be involved in Quiltech? 8 A Yes. 9 Q Did he tell you that he had information, other 10 than that Mr. Parks was believed to have asked Rose Riddle to 11 type resumes for Quiltech? l 12 A When there was a subsequent conversation with i 13 Mr. Bruner during one of the conversations, he gave me the l 14 information that basically is outlined in the paragraph. 15 Q Do you mean this paragraph here? 16 A Yes. 17 Q Paragraph 12, starting with the substance? I am 18 sorry. I am not sure which paragraph you are referring to. 19 A Well, I don't know how this paragraph ties to the 20 date I am referring to. My information is, as I testified, 21 it would be around March 1. 22 Q Well, the first paragraph describes the typing of 23 the resumes by Rose Riddle and an interview with Mr. Santee 24 and Mr. Troebliger on March 3. Were you aware of that 25 interview at the time it was conducted, March 3, 1983? ggg Ace-FEDERAL R.EPORTERS, INC. 202 347-3700 Nationwide Coveage 8(K)-336-6646
l l l l l 30477.0 COX 52 /^% (/ 1 A Repeat the question, please. l 2 Q Ms. Riddle was the typist, and she was interviewed 3 on March 3, 1983, by Larry Santee and James Troebliger. When 4 did you first become aware of that fact? 5 A I would say immediately or shortly thereafter. 6 Q Could you describe to me the sequence of events in 7 terms of how you first learned of the typing incident and the 8 involvement of Miss Riddle and Mr. Parks, and what actions 9 you took once you learned of that fact? 10 A Well, I believe I testified that Mr. Bruner 11 informed me of the situation. I think there was a period of 12 several days when we confirmed or explored the information we ("/ 5 \\- 13 had in hand at that time. 14 0 When you say "we," who was involved? l 15 A I would say it was probably under Mr. Bruner's 16 direction. 17 0 Do you know what he did? 18 A Pardon me? i 19 Q Do you know what he did? 20 A obviously he had Mr. Santee interview the 21 secretary. l 22 Q Is Mr. Santee a Bechtel employee? 23 A Pardon me? 24 Q Is Mr. Santee a Bechtel employee? ("} 25 A Yes, he is. V ACE FEDERAL REPORTERS, INC. l 202-347 3700 Nationwide Covenige 800-33(>.(,(>4(,
30477.0 COX 53 1 Q What else? 2 A I think what followed then was a series of 3 meetings between my staff and the home office with regard to 4 Parks and his actions. This would have included Mr. Bruner. 5 We would have brought'in Mr. Wheeler, who was Mr. Parks' 6 immediate supervisor. And we would have brought in the 7 personnel director to represent the interests of the 8 employees. 9 -Q Who was that? 10 A-That was Mr. Ron Nestor. 11 .Q As part of a response that was given by GPU to 12 some -- a writeup of this whole sequence of events by the NRC 13 Staff in 1984, I believe a-report was done for GPUN; in that 14 it states that Arnold questioned King about the preparation 15 of the resumes, and came away with the feeling that King was 16 giving him a very noncommittal, nonspecific response. He had 17 requested that Bechtel look into the' conduct of that 18 company's employees with respect to Quiltech. .19 Do you recall Mr. Arnold contacting you, either 20 directly or indirectly, concerning this matter? 21 A Concerning Parks? 22 Q Yes, the Quiltech typing of resumes. That's not 23 very well stated, but the typing of resumes by Ms. Riddle at i 1 24 the request of Mr. Parks? 25 A I am sure that Mr. Arnold and I would have { I ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage MG336-6646
l L 30477.0 ,_ COX 54 'k s) 1 discussed in detail the aspects of this case. It was a very 2 cJient-sensitive issue. 3 0 What did Mr. Arnold indicate to you? How did he 4 portray that sensitivity? l 5 A As I recall, he went into it with a relatively 6 open mind. He set up an interview. I believe that he had 7 conducted by Phil Clark with Mr. King to ascertain the facts 8 with regard to Quiltech. 9 Q Was Mr. King a sensitive item -- Mr. King was not 10 a Bechtel employee, was he? 11 A That's correct. He was a GPU employee. 12 Q What was sensitive -- what was the sensitive O 13 matter, as far as you were concerned? 14 A Well, the sensitive matter, as far as I was 15 concerned, was that Mr. Thiesing had been the source of the 16 information that Mr. Arnold was acting on. 17 Q Why was that sensitive? 18 A Well, it was sensitive that if Mr. Thiesing 19 happened to be wrong, then we had had an action initiated by 20 Bechtel that could not be substantiated and could have 21 created some very severe client relationships between Bechtel 22 and GPU, and could possibly have had some effects on the 23 conduct of the work. 24 Q Did Mr. Arnold say that kind of -- well, was this 25 the subject of your conversation with Mr. Arnold, the aspect [} ACE-FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Cmcrape 800-3364M6 l
F 304.s.0 COXL 55 p=,m y V E 1 that Mr. Thiesing1had been the source of'the information? 2 A-I think one aspect of the conversation, that i 3 Mr. Arnold would have probably appreciated having received. 4 the information in another format. 5 0-He told you.this? r 6 A Pardon me? 7 Q He told you this? 8 A That's my recollection. l 9 Q Another format being what? 10 A Pardon me? 31 Q What was the other format that he would like to 12 see? \\ ') L 13 A Well, there was an alternative to tho way this was 14 handled, which would have been simply for the information 15 that Mr. Thiesing had derived, or come into possession of, to 16 have been given directly to.GPU, and they could have acted on 17 it on their own volition and judgment. 18 Q I think I know what you are referring to, but just 19 to make it absolutely clear, are you referring to the 20 alternative being that once Mr. Thiesing had been told by his 21 subordinates that they believed Mr. King to be involved in 22 Quiltech and be recruiting GPU employees into Quiltech, that 23 at that point, instead of conducting a Bechtel vendor 24 procurement audit, referring the matter to GPUN; is that what (')) 25 you are saying? ACE-FEDERAL REPORTERS, INC. 202-347-37(K) Nationwide Coverage 8(K)-336-6646 j
ll L ~ 30477.0 L 56 77)COX' L !%/ 1 A I am suggesting it might have been an alternative 2 .that might have cet better with the client. 3 Q I just wanted it clear what you were referring 4 to. Did Mr.. Arnold suggest actions that you might take? 5 A Pardon me? 6 Q. dig Mr. Arnold suggest actions that you might take 7 with respect to either Miss Riddle, Mr. Thiesing, Mr. Parks 8 or Bechtel employees? 9 A No. I think it was a clear cut policy that with 10 respect to Bechtel employees working for either GPU or any 11 client, if they are unhappy with their conduct, that they 12 .will let us know. It.goes to the point of removal from site, 7 13 if that's always their option, but when it comes to the point 14 of what should Bechtel do with respect to its own employees 15 internally, they are not arrogant enough to suggest that they 16 should tell us how to conduct ourselves with our employees. 17 0 Did Mr. Arnold say that he expected to take any l 18 action with respect to any of these three employees as far as 19 GPUN was concerned? 20 A I couldn't hear all of the question. 21 Q I am sorry. With respect to Mr. Thiesing, 22 Miss Riddle and Mr. Parks, did Mr. Arnold say to you that he 23 intended to take any particular action with respect to these 24 three people? 25 A No. ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationv.ide Coverage 800-33MM6 I
30477.0 COX 57 1 Q Did he indicate to you that he believed 2 Mr. Thiesing's conduct ought to be looked into by Bechtel? 3 A Well, as I have indicated, I think he indicated 4 4 that he thought there were other ways that it could have been 5 h a n d '. a d, but by that time Mr. Thiesing's actions had been 6 vindicated by the fact that what he had turned up were 7 factual. I think from that point on GPU was caught up with 8 how to deal with the King issue and not the Thiesing issue. 9 Had Thiesing been wrong, we would have had a totally 10 different situation on our hands, and that's where my area of 11 concern was. 12 0 What about Ms. Riddle? Did he discuss his views 13 as to the seriousness of what Ms. Riddle did? 14 A Mr. Arnold never discussed anybody below the level 15 of Mr. Thiesing with me or with regard to tnis matter. 16 Q He never raised Parks? 17 A Pardon me? 18 Q You said below -- 19 A We talked with Parks from time to time, and I am 20 certain we probably talked about Parks at this time. 21 Q You have just said below the level of 22 Mr. Thiesing, and Mr. Parks was. 23 A Yes. Well, Parks is at another level. 24 0 Yes. 25 A I am talking about the people down in the l (} l ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Cmcrage M&336-6646
{ l-l l L 30477.0 e 58 l ,_ COX l N 1 procurement departments and their procedure for acquiring 2 information and so forth. 3 Q What kinds of instructions did you give Mr. Bruner 4 with regard to proceeding in the manner, once you had had 5 these conversations with respect to either -- well, either of 6 these three individuals, Riddle, Thiesing or Parks? 7 A Nothing with respect to Mr. Riddle. 8 Q Miss Riddle, Rose Riddle. You didn't give them 9 any instructions as to how to handle Miss Riddle? 10 A No, that is fully within his job purview. 11 Q So you just didn't concern yourself with her? 12 A (Witness nodded head.) O 13 0 Mr. Thiesing. Did you direct him to do anything 14 with respect to Mr. Thiesing? 15 A Well, I wanted him to find out from Mr. Thiesing 16 what the facts were with regard to his actions, with regard 17 to Quiltech. I don't know if I asked that through Kanga or 18 through Bruner or whether they had already initiated it and 19 we just discussed it. I certainly had a level of interest in 20 knowing just how this came about. 21 Q In addition to the handwritten memorandum that we 22 talked about, we established yesterday at the deposition of 23 Mr. Thiesing that he was asked to edit and to have typed up 24 that information, and it was then communicated to Mr. Bruner 25 instead of Mr. Kanga. Do you recall seeing that? {} ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverare 800-33MM6
I [ ( -30477.0 59 ,,COX 1 A Yes. 2 Q Was that shown to you about the same time that we 3 are talking about, the beginning of March? i 4 A I am sure I reviewed this, yes. 5 Q There is another document behind it here. I don't 6 know if it was attached to it or not, but it was provided to 7 me. Did you see this document? This is a March 4 8 confidential letter to Mr. Arnold from Mr. Santee concerning 9 the interview with Miss Riddle. Did you see that 10 communication during that time? 11 A I don't know if I saw the document. I am aware of 12 the contents of the document. O 13 Q But as you said, you didn't do the followup. Did 14 you tell Mr. Bruner to handle the Rose Riddle matter 15 himself? Did you give him any kind of instructions? 16 MR. RICHARDSON: He has already testified he did 17 not give Mr. Bruner any instructions concerning Ms. Riddle. 18 MR. JOHNSON: I recognize that. j 19 BY MR. JOHNSON: 1 20 Q Did you discuss the contents of this communication 21 that we just referred to with Mr. Bruner? 22 A Rose Riddle? i 23 Q Yes, concerning Rose Riddle. 24 A As I said, I was thoroughly familiar with the 25 information in that must have come from Mr. Bruner or {} ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage MKb33M616
l l l l 30477.0 ) COX 60 \\ l l 1 Mr. Kanga as a report to me. ( 2 0 Okay, fine. 3 A Again, you can appreciate we weren't firing memos 4 back and forth. We were talking on the phone or doing it 5 through a series of meetings. 6 Q Yes, sir, I do. Okay. Now, you then gave 7 instructions, I believe, to Mr. Bruner with regard to 8 followup on the Parks connection here to the typing, or what 9 was that? You nodded, you did give him instructions? l 10 A Yes. l 11 Q What were they? 12 A We are talking now about the internal audit? O 13 0 Yes, beginning of March. You said -- well, let's 14 back up to your previous statement. You said that you had a 15 series of meetings or discussions. 16 A With staff? 17 Q With staff. 18 A Yes. 19 0 I wanted to proceed from that point. 20 A Yes. 21 Q What happened then? What did you instruct? 22 A Again, I don't know the time interval, but over a 23 period of several days we reviewed Mr. Parks' action. You 24 need to understand that there was considerable activity going 25 on the site with Mr. King, that GPU obviously considered this l ACE FEDERAL REronTnns, INC. 202 347-3700 Nationwide Coserage 8(Kb336 6646
i 30477.0 COX 61 ] (J 1 1 a major breach and a conflict of interest within their own J 2 company. We are governed by Bechtel Directive, I believe j 3 it's 2.1, which sets out our conduct of employees ethic 4 policies, and that covers a gamut of things, basically good 1 5 business ethics, conflicts of interest. 6 Q Yes. 7 A Goes so far as to say that serious action that 8 could be of a serious embarrassment to a client or interfere 9 with the efficient conduct of Bechtel's work for that 10 client. 11 0 Yes. 12 A We were trying to determine if Mr. Parks fell ( 13 under that to the extent that would warrant an internal 14 audit. Bechtel's internal audit is entirely separate from 15 the division of operations. It is a corporate function, can 16 only be initiated at the genera 3 manager's request, or deputy 17 general manager in the general manager's absence. 18 After consultation over a period of several days, 19 and a decision -- a very difficult decision, and not taken 20 lightly, we decided that -- I decided that -- I think I had 21 general concurrence from the staff, but in any event it was 22 my decision that we should bring an internal audit, and we 23 should investigate whether we had all of the facts with 24 regard to the Parks activities. And on the basis of that, if 25 my memory serves me correct, I suggested or requested that (} ACE FEDERAL REPORTERS, }NC. 202 347-37(K) Nationwide Coserage 8(k) 336-6646
L j l I i 30477.0 I COX 62 O 1 Mr. Bruner call Mr. Lee Hoffman, whom I worked with before 1 l 2 and have the highest respect as probably the most competent l 3 internal auditor that Bechtel has, and as soon as he could 4 free his schedule, that he come out and interview Parks and 5 then report back to us. l 6 Q Did you talk to Mr. Hoffman directly? 7 A Well, I did after he came into the offive, when he 8 came in on the assignment, I would have talked to him 9 directly. 10 Q What was it, your determination to bring in the 11 internal audit department, based on? What information led 12 you to determine that it was necessary to do that? 13 A Well, obviously there was a potential for a 14 conflict of interest, to the client's best interest, 15 depending on how deeply involved he turned out to be involved 16 in the Quiltech situation. That was probably the primary 17 one. 18 Secondly, there was a potential that with both 19 Parks and King involved, King being a key player at the site, 20 that this could turn out to be an embarrassing situation for 21 the client. We are all very familiar with how newsworthy TMI 22 and all of its activities is. 23 Q Yes. 24 A We had some concern that Parks was more deeply 25 involved than we might even suspect at that point, that it {} ace-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Cmcrape 800-3364M6
l 1 l 30477.0 COX 63 O 1 could be a serious confrontation with the client. Not only 2 that, but it wouldn't do his job any good if it became a big l 3 public issue. 4 So those were the underlying reasons. l 5 Q But the facts that you based your decision on were 6 limited to the fact that you were told and informed that 7 Mr. Parks had requested Rose Riddle to do rome typing of 8 resumes for Quiltech. Those were the facts? 9 A Those were the facts we had in hand, 10 Q At the time you made that decision, were you aware 11 of the controversy concerning the applicability of the polar 12 -- administrative procedures referred to before, the polar O 13 crane load test procedure? 14 A I was not familiar with Mr. Parks' involvement in 15 the polar crane controversy. To the extent that -- I don't 16 even want to say to the extent. My best mernory is I was not 17 aware at that time that Mr. Parks was involved in an on-site, 18 ongoing controversy about the polar crane. At a matter of 19 fact, the matter of this testimony, I want to explicitly 20 state that there are two separate iusues here, and they were 21 dealt with accordingly, from my office. 22 0 The two separate issues being - - 23 A The two separate issues being subsequent actions i 24 of Mr. Parks and his accusation of safetv, safety concerns 25 and harassment. i l I I ACE-FEDERAL REPORTERS, }NC. l 202 347-3T:0 Nationwide Coverage 800-336-6646 l l j
30477.0 COX 64 L/ 1 Q The other? 2 A The other, of course, just being Quiltech. 3 Quiltech, in my mind, stands alone, and I think the record 4 will substantiate that. 5 0 Was it your understanding that you made that 6 decision that Mr. Kanga was dealing with the controversy 7 concerning the applicability of the administrative procedures 8 to the polar crane? 9 A It wasn't an overriding issue in my life. 10 Q But were you aware of it? 11 A I may or may not have been aware. You know that 12 there was an ongoing discussion. As I said, I was aware of O 13 schedules, as pertains to the crane, whether they would meet 14 their schedules and budgets or not. I was not intimately 15 aware of the technical issues that were involved with the 16 crane. 17 Q So if Mr. Kanga had apprised you of the .18 controversy of that polar crane, he would not have mentioned 19 Mr. Parks' name to you. That's your recollection? 20 MR. RICHAR950N: That's what he testified. He has 21 no recollection of that at this particular point in time. 22 On another subject, and that of eating. 23 MR. JOHNSON: It's time for lunch. l 24 MR. RICHARDSON: Perhaps you can finish right now 1 25 or maybe in five minutes, in which case we would proceed. l ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coserage 800 3364M6 L______________ j
l 30477.0 COX 65 b) 1 1 'MR. JOHNSON: No. I have quite a bit more. Why 2 don't we break for lunch here, if it's agreeable, and j 3 reconvene at 1:00. 4 THE WITNESS: Fine. Or if you want to go straight 1 5 through, that's fine with me. Uh oh, we have somebody 6 disagreeing. She is shaking her head no. 7 MR. JOHNSON: It's about 20 after 12:00. I,et me 8 see if this is a good breaking point. 9 MR. HICKEY: Relatively good, George. 10 MR. JOHNSON: With that admonishment, let's go off 11 the record. 12 (Whereupon, at 12 : 20 p.m., the deposition was 13 recessed, to be reconvened at 1:00 p.m. this same day.) 14 15 16 17 18 19 20 21 22 23 24 l l l l l ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage fuXK33MM6 m
I i 30477.0 l COX 66 l 1 AFTERNOON SESSION (1:05 p.m. ) 2 Whereupon, 3 CHARLES W. SANDFORD 1 l 4 resumed the stand and, having been previously duly sworn, was 5 examined and testified further as fo]Iows: 6 EXAMINATION (Continued) 7 BY MR. JOHNSON: 8 Q Mr. Sandford, we vere talking about circumstances 9 in the beginning of March, 1983, in connection w'th the 10 information that came to your attention with regard to l 11 Mr. King and Mr. Parks and Quiltech. In the conversations 12 that you had with Mr. Arnold, did he apprise you of the fact O 13 that Mr. Parks had raised safety concerns with respect -- or 14 not necessarily safety concerns, but how to raise concerns 15 about the polar crane? 16 A I don't recall that. 17 Q Are you saying that he did not or you just don't 18 remember? 19 A Well, I think I have to say I don't remember. 20 Again, we get into the chronology of, you know, which day -- 21 days follow days here, and which day this conversation 22 occurred and that conversation occurred. He well may have. 23 But my recollection is that my information came from Hechtel 24 and Mr. Bruner. 25 Q You mentioned that you had reviewed, around March (} ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80133M646
1 L I 30477.0 COX 67 i (J-\\ 1 1, this handwritten memorandum from Mr. Thiesing to 2 Mr. Kanga, that you had occasion earlier to look at it. Do l l 3 you recall that one of the matters that Mr. Thiesing 4 mentioned as leading to his taking the action that he did, 5 that is not bringing it to -- directly to the attention of 6 GPUN or to Bechtel management, was the fact that Mr. King had 7 raised safety concerns? 8 MR. RICHARDSON: Which portion are you referring 9 to, Mr. Johnson? 10 BY MR. JOHNSON: 11 Q I am sorry, let's see. My copy is so blurred, I 12 think 4. It says, "In addition, Hank Gishel wrote a memo on 0 13 February 11 stating technical safety concerns regarding the 14 polar crane load test. The SER for the load test was 15 therefore being held up by site operations, and I did not i 16 wish to imply or give the appearance of implying that either 17 Bechtel or GPUN or its corporate entities or Larry's 18 supervisors were attempting to bring pressure on Larry or 19 alter his position or that of Hank Gishel regarding polar 20 crane safety or proper resolution of their comments 21 thereto." I 22 You read that on approximately March 1; is that 23 correct? 24 A I believe that's what I testified to, yes. 25 Q I would like to explore, if I might, this (} l ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-3E6646
30477.0 COX 68 memorandtim that you had a copy of that is from your memo pad 1 l 2 and signed C.W.S., and ask you about it. It says, "Here is 3 the Thiesing/ Blizzard account of what went on." Does that 4 refer to the document that I was just reading from or to some 5 other document? 6 A No. This would refer to the memo that is attached 7 to it. 8 Q That is the handwritten note that we were talking 9 about? 10 A Yes. 11 Q Why does it say Blizzard? Is there something 12 about Blizzard in that account, or from Blizzard? O 13 A Yes. Well, it indicates that Blizzard's 14 documentation was attached to this memo, I think is the 15 genesis of your question. 16 Q Thank you. 17 A I don't recall reading Blizzard's account at that 18 time. What I remember dealing with is what I transmitted 19 here. 20 Q Going back to this short memorandum, which says, 21 "to Buzz," it says " talked to Bahman -- Arnold and King to 22 meet this afternoon. What will come of that remains 23 uncertain. Bahman to let us know. Have not heard from 24 Loomis yet. Depending on what comes of the Arnold-King 25 meeting and Loomis's views, one of the options we may have to [} ACE. FEDERAL REPORTERS, INC. N - - _ -_____-_
30477.0 COX 69 1 consider, if this confrontation continues to escalate, is how 2 to separate Bechtel from Thiesing's actions. This might mean 3 temporary suspension, et cetera. We will see. C.W.S." 4 Could you explain to me what was the reference 5 when you mentioned "we may have to consider if this 6 confrontation continues to escalate," as to how to separate 7 Bechtel from Thiesing's actions, what was the confrontation 8 that you saw that you thought might continue to escalate? 9 A I think the confrontation that I saw was between i 10 King and Thiesing, and the fact that GPU had not taken -- 11 they had taken one position with King and the safety issues 12 were up, then there was a discussion. As I recall, it was t 13 initially suspended out of hand, and then he came forth with 14 a series of safety issues; and on the basis of that, there 15 was the interview I referred to earlier where he had the 16 meeting with -- 17 Q You have lost me. Who is the "he" you are talking 18 about? 19 A Yes, I told you this morning. 20 MR. HICKEY: Clark? 21 MR. RICHARDSON: Phil Clark? i 22 THE WITNESS: Phil Clark, had a meeting with Phil 23 Clark on those issues. Then, as I remember, he was either i 24 reinstated or they were reconsidering their case with King, 25 and there was stil] an issue we had in hand, Thiesing's ( } 4 1 ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Cmcrape 800-336-6646 j
l I 1 l l 30477.0 70 []COX v 1 account of what had transpired. There was still this concern 2 on my part that if it turned out that Thiesing, even through 3 his check, was wrong, that we had a situation with Thiesing 4 where he wouldn't be viewed very favorably by GPU management 5 for bringing up a problem that might not have been accurate. 6 As I said earlier, I think subsequent events 7 proved that he was, and that's what I was talking about, a 8 temporary suspension would obviously indicate that I felt we 9 might get some direction, like we ought to get him off the 10 site, or we ought to suspend him or something like that. I 11 don't think they would have said we ought to suspend him, 12 they would have limited their things -- that's my language. 13 They would have limited their comments to, I don't think it's 14 appropriate that Mr. Thiesing be on the site any further. 15 That's a hypothesis. That's a reaction, immediate reaction 16 to reading this bulletin or memo that Mr. Thiesing had 17 written. 18 I want to reemphasize that subsequent events 19 proved Mr. Thiesing's information, regardless of how he 20 arrived at it, turned out to be true. As far as I was 21 concerned, that vindicated his actions. 22 BY MR. JOHNSON: 23 Q You paraphrased for me earlier today the text of 24 Bechtel Directive 2-1. So I know that you are familiar with (} 25 it. ACE FEDERAL REPORTERS, INC. 202-347-37(X) Nationwide Cmerage 8(Kh3364M6 f
30477.0 COX 71'- 1 'Did you consider whether Mr. Thiesing,-onceLyou 2 learned of Mr. Thiesings role in investigating the-i 3 Quiltech-King connection, whether-Mr. Thiesing had violated-l 4 Directive 2-1? l s. 5 'A No,.I don't think I ever. considered Mr. Thiesing's. ] 6 actions in that light. I think it would be hard to find him 7 within a. conflict of interest, and that he was, in his.own 8 judgment, trying to conduct the work as he best saw fit under 9 their responsibilities assigned to him. l 10 0 I draw your attention to page 2 specifically, 11 where it tells -- which I think is addressing an issue that 12 you have identified regarding Mr. Thiesing,-Mr. King and this O. 13 note that we were just discussing,'where.it gives the I .14 directions as to -- 15 MR. RICHARDSON: That's too far away. It's too 16 hard for me to read.. Why_ don't you let me get out'my copy. 17 MR. JOHNSON: Okay. ^ i 18 Thank you, Mr. Richardson. 19 BY MR. JOHNSON: 20 Q It says in the second paragraph, "in situations in 21 which Bechtel knows or is informed by a reliable source, that 22 a client," et cetera, "Is acting illegally or unethically, a 23 report of inquiry must be made of any impropriety to the 24 responsible Bechtel supervisor." And so on. I think you 25 summarized this fairly well earlier. (} l l l l l 14CELFEDERAL REPORTERS, INC. l. 202 347-3700 Nationwide Coverage 80(b336446 l l l i
I i l l l l 30477.0 COX 72 7_V 1 Why didn't you consider the fact that Mr. Thiesing 2 had been conducting an investigation through the procurement 3 to be in violation of this paragraph? 4 MR. RICHARDSON: This is a minor objection. He 5 has already testified that he did not consider it at the 6 time. I gather what you really mean to ask is why, now that 7 you are raising the issue, does he think that that 18 not a 8 violation of 2-1. Is that what you are asking? 9 BY MR. JOHNSON: 10 Q Let me back up for a second. I take it you did 11 not read this paragraph or consider this paragraph 12 contemporaneous 1y as suggesting that Mr. Thiesing had done 13 anything improper? 14 A Well, I think if you read it in its full context, 15 it says "the division, special operations or service manager, 16 will, in turn, notify the counsel of the appropriate 17 operating company, which was Mr. Loomis, who was our in-house 18 attorney. And at his or her option, the manager of internal 19 auditing." So that doesn't state that we have to notify the 20 manager of internal audit, it's a management decision. As I 21 indicated to you earlier today -- 22 Q Let me just focus on Mr. Thiesing's actions. I 23 Mr. Thiesing, as you recall, determined, as is outlined in I 24 that handwritten memo of 2/26/83, determined to have a 25 procurement on it done on Quiltech rather than to report the (} ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage MX)-336W46
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L O COX 1 information he had received from his' subordinates.concerning N i 2 King and Quiltech, to his supervision. a 3 MR. RICHARDSON: Excuse me, that's a j 4 mischaracterization of a memo. -When you say information, 5 that suggests. factual information. The memo refers to l l J 6 rumors. 7 MR. JOHNSON: I_would appreciate -- 8 MR.-RICHARDSON: If you are going to characterize l 9 the exhibit or the document, I think you'ought to do so 10 ace' Ira tely. i 11 MR. JOHNSON: It seems to me you are trying to i 1 12 testify for your witness. I think you ought to let him ( -) 13 testify. 14 BY MR. JOHNSON: 15 Q Well, my question to you is, you were aware of the 16 information stated in that memorandum, you have just said, 17 around March 1. It says, I believe, that Mr. Thiesing.had i 18 received information from several of his subordinates; is ] i 19 that correct? 20 A Yes. 21 Q Why was it not appropriate for Mr. Thiesing at 22 that point to contact either Bechtel or GPUN supervision, 23 rather than to conduct the procurement audit? 24 A You are asking in retrospect would it have been 25 wiser for Mr. Thiesing to do that. In my judgment, it (} ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coveraye MK)-336-6646 _.A.
l I i l l 30477.0 COX 74 1 would. The fact that Mr. Thiesing, as he explained in his 2 memo, which was persuasive to me, his reason of why he didn't 3 do that, obviously that question had been asked of him, and 4 that's what was the genesis of this memo; and knowing 5 Mr. Thiesing, his reputation, his presentation of the job, is 6 a fair characterization of what he had done and why he had 7 done it. 8 Q So your possibilities of considering to suspend 9 Mr. Thiesing temporarily didn't have anything to do with the 10 fact that you feel he may have violated any Bechtel policy, i 11 but was a consideration growing out of your client-Bechtel 12 relationship? l '\\ 13 A I think you have to be very imaginative to think i 14 that there is anything in Thiesing's action that literally, ) i 15 you know, violated Bechtel policy. It is not unusual, when l 16 you want information about small companies, or to find 17 companies, to go to procurement. They are the ones that have 18 that information. That's precisely what he did. 1 l 19 MR. RICHARDSON: Have you completed your answer, 20 Mr. Sandford? You were going to interrupt the witness. 21 THE WITNESS: Yes, that's enough. It's really 22 mixing apples and oranges. In my judgment, to ask the same 23 question with regard to the seriousness of what Thiesing had 24 done with what we thought we knew about Parks at that time, 25 are two separate and distinct and different items. ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Cmerage MG336-6646
l304'77.0 ! COX 75 1 BY MR. JOHNSON: 2 Q Wasn't it one of your concerns, as is stated in 3 this' memorandum, that Mr. Thiesing's behavior might have put 4 Bechtel in a bad light? 5 A It-was a concern that'Mr. Thiesing's actions would 6 be perceived by Mr. Arnold. I think that, again,'is a 7 genesis of the note on my memo. But, again, I didn't think-8 that merited-more than a concern with a client. It certainly 9 didn't merit an internal'. investigation of Mr.-Thiesing's 10 conduct-of his work. 11 Q Was the distinction between the way you considered 12 Mr. Thiesing's conduct and Mr. Park's conduct a reaction of f I \\ 13 Mr. Arnold? 14 A No, it was because of the relative seriousness of 15 the information we had in mind.at the time. Mr. Parks had 16 apparently participated in helping supply an off-site ) 17 company, the president of which was'Mr. King, by at least 18 acquiring resumes of current GPU employees and making those 19 resumes available for other job sites. 20 0 But if the only information -- you testified the 21 only information you had was that Mr. Parks asked Ms. Riddle 22 to type some resumes. Do you have any other information? 23 A No, but we didn't know that we had all the 24 information. We didn't have a memo from Parks at that time 25 that limited his actions. We did have from Mr. Thiesing. l l ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 l i I .__2.________._..___.._._.__
l l i 30477.0 l COX 76 fs \\sh 1 Q When Mr. Hoffman came to Gaithersburg to~ initiate 1 l 2 his investigations, his internal audit, did you give him 3 instructions? l 4 A Yes. 5 Q What were they? 6 A The instructions were a brief summary of the facts 7 as we knew them, that he was to do, within his own area of 8 responsibilities, an interview with Mr. Parks, to ascertain 9 if the facts or the information we had were, in fact, facts. 10 This was as much for Parks' protection as to find something 11 to prove that Parks had done something wrong. 12 Secondly, we wanted him to talk to other people G 13 that were involved in that situation and to bring back as 14 complete a story as he could, which would either implicate 15 Mr. Parks and implicate him further, or to bring back 16 information that would indicate this is an overblown 17 situation. In any event, he runs those -- when you ask it, I 18 give him directions. What I did is give them an outline of 19 the case, and they conduct their work according to the 20 internal audit policies of the company. 21 Q Was part of Mr. Hoffman's mission to further 22 explore the propriety of Mr. Thiesing's actions? 23 A No, we didn't ask him to -- I think he talked to l l I 24 Mr. Thiesing, but we certainly didn't call for any official 25 internal audit of Mr. Thiesing. () ACE FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage m)-336-6646 l l
I 30477.0 77 ,,COX (._) l L 1 Q The same with Ms. Riddle? L 2 A She was interviewed. We thought she was a much I 3 lesser player in -- so she was interviewed. She gave a very 4 straightforward, frank answer, as I understand it. She 5 agreed as to what her participation had been. She admitted 6 that she had been paid for her services, and in her favor, we 7 found she had done this work on her own time after hours. o 8 0 Were your findings -- was any action taken with 9 respect to Ms. Riddle, any personnel action? 10 A Nothing formally that I recall, other than she was 1 11 counseled that Bechtel frowned upon this type of activity and 12 she shouldn't participate in it any more. 13 Q When you say " frowned on this activity," what was 14 the activity frowned on? 15 A Pardon me? 16 Q What was the activity frowned on? 17 A Well, she had done what had been alleged. She had 18 typed a number of resumes of GPU employees at Mr. Parks' 19 request and given them back to him. 20 Q What was the -- the part I was trying to focus on 21 -- what particular aspect of what she did was the part that ] 22 was frowned upon, if you can focus on that, was that she had 23 used company property? l l 24 A No, she worked, as I indicated, on her own time. () 25 Q Yes. (/ i Act FEDERAL REPORTERS, INC. 202 347 37(X) Nationwide Coseraec 8(KL3364M6 L-_-_-____-________
30477.0 COX 78 1 A The issue was that she shouldn't participate in 2 any activity, regardless of how innocent it might appear, 3 that would lead her to again help solicit employees from one 4 of our present employees, for some off-site job. 5 Q You just stated in a previous answer that you got 6 feedback that Ms. Riddle was full and frank and open in her 7 statement. Did you have a different kind of feedback with 8 respect to Mr. Parks' interview? 9 A No. 10 Q For Mr. Hoffman, Mr. Wheeler? 11 A No. Our feedback from Mr. Parks' interview was 12 that he was very suspicious at the request of the interview, O 13 when Mr. Hoffman approached him, that he said that he would 14 not be interviewed without a neutral party in the room, a 15 request which was granted, and either before as a condition 16 of the interview, or following the interview, he requested a 17 meeting with me. And when I say me, I am not sure that it 18 was specifically me, but he wanted to talk to somebody in 19 authority of higher management. My understanding from j 20 Mr. Hoffman is that during the conversation with Mr. Parks, 21 he generally verified the facts as had been spelled out to us 22 before as assumption to our supposed facts. i I 23 Q Was t.he information that you received from - 24 well, let me back up. 25 You got reports about the interview with Mr. Parks ace FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 8G)-33MM6 ~
) l 30477.0 O~ 1 or Mr. Hoffman and Mr. Wheeler when they returned? 2 A Yes. I was verbally apprised probably the next l 3 day. 4 Q Prior to the meeting with Mr. Parks? 5 A Yes. 6 Q Your meeting? 7 A Yes. 8 Q Did they tell you that the information that they 9 were able to establish through Mr. Parks was limited to the e 10 information perhaps in a little bit more elaborate form that 11 Mr. Thiesing had alleged? 12 A Yes. O 13 Q Did they tell you that they had information that 14 Mr. Parks was involved in guiltech in any other way aside l 15 from the type arranging for the resumes to be typed? j 16 A No. I think his activities, as I recall, were 17 that he did-have numerous resumes typed. He characterized 18 that both in my meeting with him and in the internal review, 19 internal audit that was an act of friendship, that he had 20 been requested to do this, and so he had accommodated 21 Mr. King. 22 1 think the only thing, perhaps, new, that came l 23 out of it of any significance, was that he had accepted money ( 1 24 from Mr. King, not for himself, but to pay the secretary for 25 her time and work in typing up the resumes. (} ACE FEDERAL REPORTERS, INC. ) 202-347-3700 Nationwide Coserare H(K)-336-6646 l j
30477.0 COX 80 1 Q Was there anything different in kind between the 2 role of Mr. King, of Mr. Parks, and Ms. Riddle, based in your 3 judgment on what you knew after hearing this information? l 4 MR. RICHARDSON: I am sorry, could you read that 5 question back, please. 6 (The reporter read the record as requested.) 7 THE WITNESS: Yes. I think they are two totally 8 different situations. 9 BY MR. JOHNSON: 10 Q How so? 11 A I think she, from my relatively minor matter, 12 under the request of her supervisor, on her own time, did O 13 some work for him, which she may or may not have realized 14 even the significance of what she did. I don't think there 15 was any question in Mr. Parks mind at all as to what he was 16 participating in, even if you accept the fact that he was 17 doing it to accommodate a friend, it should have raised some 18 warning sign in his mind, this is not quite the way we do 19 business. 20 0 Isn't it one of your later observations, in 21 exonerating Mr. Parks, that he may have interpreted the 22 request as coming from a supervisor, Mr. King as his 23 supervisor? 24 A You are calling for some speculation on my part. ( 25 Q No, I am asking you, didn't you later reach a ACE-FEDERAL REPORTERS, INC. 202-347-3M Nationwide Coverage 800-336 4 46
u30477.0 COX B1 1 determination as to what to do with Mr. Parks based, in part, 2 on the fact that Mr. Parks was a subordinate of Mr. King? 3 h May I just address, maybe even in a more general 4 sense, my perception of what led to these things to lead to 5 an answer to your question? 6 Q Please answer my question and then elaborate. 7 MR. RICHARDGON: Mr. Sandford, if you feel a yes 8 or no does not adequate 3y respond to the question, you may 9 give whatever answer you believe is complete or appropriate. 10 MR. JOHNSON: Perfect 3y okay. I would just like 11 an answer to my question, please. 12 THE WITNESS: Okay. Repeat your question, O 13 please. 14 BY MR. JOHNSON: 15 Q Didn't you later reach a determination about the 16 disposition of Mr. Parks in this matter, based, in part, on 17 the fact that Mr. Parks was a subordinate of Mr. King? 18 A I think I would characterize it as predominant 3y 19 because he was a friend of Mr. King, and Mr. King was a 20 mentor to Mr. Parks, and that they had a very close personal 21 relationship, more than a supervisor giving him an order to 22 go do it. I think he did it on his own free will. l 23 Q Was Mr. Parks Ms. Riddle's supervisor? 24 A I am not sure of that. I don't know. 25 Q So you received the information back that {} l l ACE FEDERAL REPORTERS, INC. j 202-347 37(R) Nanonwide Coverage MKT-33MM6 )L-____-----__
30477.0 COX 82 1 Mr. Parks would like to speak to someone, or perhaps you 2 specifically, and that that was arranged for the next day 3 after the interview with the internal auditor? 4 A I would like to take credit for clearing my 5 calendar the next morning and seeing Mr. Parks, if there's 6 room in this dialogue for credit. 7 Q okay. I am afraid there is room for it, but I B don't know how much value it is going to have. 9 A Doesn't buy you much. Well, I think it shows 10 intent, for what that is worth. 11 Q When Mr. Parks came in, how did you begin the 12 meeting? to 13 A I think generally like all meetings, where we have 14 a request like that, you call the meeting, and why don't you 15 tell me what is on your mind. 16 Q Did the subject of the information about the 17 resumes being typed at Mr. Parks' request by Ms. Riddle come 18 up? k 19 A Absolute 3y. It certainly was one of my agendas. 20 Q When did it come up? 21 A Later in the meeting. 1 I 22 Q It didn't come up in the beginning? 23 A I don't believe so. \\ \\ l 24 Q Do you remember for a fact that it didn't come up l 25 in the beginning, or you just don't remember? ACE. FEDERAL ' REPORTERS, INC. ( 202-347-37(K) Nationwide Coveraye MXb336W,46 l
L l l l l 1 30477.0 l COX 83 1 A No, I don't think it came up early in the meeting, 2 other than maybe there might have been some' preliminary 3 remarks either he or I made about the day before.
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4 basically, the thrust of the meeting was to find out what'had 5 led him to come to Gaithersburg. i, 6 0 I understand. Do you recall what were those l 7 preliminary remarks that may have been said the day before? 8 A As I recall, I don't remember them specifically, l 9 but as I remember, he expressed some concern about some 10 harassment-that he felt he was receiving at the site. He 11 mentioned two or three names, none of those which I am going 12 to be able to recall for you specifically. But he mentioned -O 13 two or three people and two or three incidents as examples of 14 where he thought he was being harassed at the site. He 15 brought up some -- later he brought up that he had some 16 safety concerns, and I believe we delved into that in a 17 higher level of. thy don't you be specific and tell me what I i 18 you are talking about, we can't generalize about these sorts 19 of things. i 20 My recollection of it was that he said nonspecific 21 on a safety issue, not to say that he might not have I 22 mentioned one or two. 23 Q At the very beginning of the meeting, did you i 24 express an opinion about his conduct with respect to 25 Quiltech? l ACE FEDERAL REPORTERS, INC. l 202-347 3700 Nationwide Coverage 8(Xh336446
1 l f j 30477.0 1 COX 84 l (f'\\.) 1 l i L 1 A I don't think so. I did before the meeting was 2 over. l 3 Q What was that? 4 A Pardon? 5 Q And what was that? 6 A Well, we discussed Bechtel's policy with regard to 7 conf 31ct of interest and the conduct of the client's work. 8 He made some comments about he thought he had made some 9 mistakes in that arena. He seemed quite open about it. I 10 told him that we considered that a serious breach of 11 conduct. I told him that that type of conduct could lead to 12 dismissal. I told him that the jury was still out, it was O 13 all under consideration, we had just received the auditor's 14 report, and we would study the facts, and we would get back 15 to him with a decision as quickly as we could. 16 Q I would ask you to identify this document, if you 17 can. 18 A That would be my notes that I jotted down at the 19 time I was carrying on the conversation with Mr. Parks. i 20 MR. JOHNSON: I would like to identify this as 21 Sandford Deposition Exhibit 1. It's a one-page handwritten 22 note dated 3/15/83. 23 (Sandford Exhibit 1 identified.) 24 MR. JOHNSON: Along the top it says " Rick 25 Parks / Lee Hoffman." There is a doodle and then "Andy {} ace-FEDERAL REPORTERS, INC. 202-347-3700 NationwiJe Coverage Mo-33M616
30477.0 COX 85 1 Wheeler" and the date. 2 BY MR. JOHNSON: 3 Q Did you make these writings on this page during f 4 the course of this interview? i 5 A Yes, when I was speaking to Parks. That's why so l i 6 many of them are incomplete. I was conducting the meeting 7 and occasionally jotting down some observations at the same 8 time. 9 Q Did anyone else take notes of this meeting, to 10 your knowledge? 11 A I am not sure. I guess it would be Lee Hoffman's 12 nature as an internal auditor. I would not be surprised to O 13 find that he had some notes or whether Mr. Wheeler took any 14 notes or Mr. Hoffman, literally, although I am not sure. I 15 would think Hoffman did. 16 Q The first item that you mentioned here is 17 "Thiesing versus King, bad blood personalitywise." Could you 18 describe what that is referring to? 19 A I think that's Parks' lead-in to the meeting. I 20 think I am just noting that probably the first thing that 21 Parks told me was that his observation was that there was a 22 conflict between Thiesing and King, peranalitywise. 23 Q It says -- I am not sure what that says. 24 A "Only Bechtel employee in the operations group (3 25 caught in the middle." That's -- well, I will let you ask %) l ACE-FEDERAL REPORTERS, INC. l '02-347-3700 Nationuide Coverage 800-33MM6
i 1 30477.0 COX 86 O O .l i i the question. 2 Q Parks was describing his situation there? 3 A Yes. 4 Q Next line says " backbiting on polar crane"? 5 A Yes. 6 Q What did he say about that? I assume this is 7 his -- 8 A I don't know how much I can expand on that bri.ef 9 note. But it indicates to me that he commented to some 10 extent on the polar crane was an issue at the site, and the 11 groups were struggling with it. There were some conflicts 12 going on about procedures and so on and so forth. O 13 Q The next line says " hostility, bad personnel 14 management practices." Do you recall what that indicates 15 what that was about? 16 A I think that -- I don't know that he said that he 17 had hostilities. Perhaps I had merely jotted it, I had 18 detected hostility, or more likely he said, you know, there 19 is hostility on the site which ties into this personality 20 conflict. He indicated that, in his judgment, there was some 21 bad personnel management practices at the site. You have to 22 understand most of these were general statements. I don't 23 have a list, as you notice, of how he flushed all of these 24 out. These are the man expressing -- he said there are hurt 25 feelings on the site. I think he felt that he didn't get as ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 3364446
30477.0 COX 87 1 involved in the decision as he should. 2 0 What he is initially talking about are things that 3 he had on his mind here, his personal feelings about his 4 situation on the site? 5 A I think that's right. He was expressing 6 unhappiness with it. 7 Q Then you have a mark that says " threat," there is 8 a doodle around it and some little items that appear to 9 relate to that? I 10 A There is a lead-in up there that say "I don't take i 11 threats." Some of the guys on the site have been threatening 12 me, "I don't take threats." The connotation of threats 13 here. I have doodles all over this thing. When you get to 14 threats, I see here he mentioned he had Kitler by name, and 15 this would be a paraphrase of supposedly what Kitler told ) 16 him. 17 Later Ed -- and now we have to assume that's q l 18 Kitler, I don't know if that's safe to do -- but at least a 19 person on the site by the name of Ed supposedly said, had f 20 told him, you are going to get yourself transferred off the l 21 site. Neither of those have very much merit if you think l 22 about them, because neither one of them as a Bechtel employee j l 23 have any authority to transfer him off the site. They could 24 go to their management up through GPU and request at the 25 proper 3evel, which would certainly not be less than the (} l l l I ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Cmerage 8(G 336-6646
30477.0 l~ 88 L O.COX-1 'Kanga level. You know, they could have arranged to have him 2 transferred off the site, but they had no authority to -- 3 they'might say those kinds of things to him, but I am not 4 certain that they did. I don't know what kind of conflicting 5 testimony you might have gotten in the so-called threats. I 6 suspect there are two very separate and disparate stories on 7 these issues. ~ 8 0 There are more than two, but go ahead. The next 9 line, is_that your own observation? 10 A Yes. 11 0 That is "something of a troublemaker (personal 12 observation)"? O 13 A Let me tell you.quite candidly what I think I 14 meant. 15 0 sure. 16 A I had listened to this first summary of things 17 that we have enumerated. I had listened about what Ed Kitler 18 was going to do and all of these people that are out to get 19 me. Nothing more, nothing more to go on than just a note for ~ 20 my own future reference that we have got an attitude: problem 21 here in this young man, he was a young man, and he wasn't a l I 22 terribly experienced young man, he had about a year with ] 23 Bechtel. So I just jotted it down just to keep in context i 24 with whatever else I was going to hear up until what I had l 25 heard up till then. l ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 8(0-3364M6
[ 30477.0 COX 89 1 1 Q Did it have any particular reference to any of the 2 things you had written above? 3 A No, I think it's kind of a summation after six, 4 eight lines of notes of what my impressions were beginning to 5 be. 6 Q When you say " troublemaker," what kind of trouble 7 did you see him making? 8 A Well, I think my impression was that we had a 9 pretty big job up there, and most people thought of it as 10 being pretty well run. So far he hadn't been able to find 11 one single thing that was being run to his satisfaction. He 12 just seemed to have an attitude of pretty much down on 13 everybody and everything. That's what I was alluding to. 14 The next line he had volunteered that he is very defensive 15 about his job. 16 Q What did you take that to mean? 17 A Well, I took it to mean that he probably 18 recognized that he had something of a chip on his shoulder, 19 that he was quick to defend his prerogatives and his areas of 20 responsibility, and if he thought anybody was in his domain, 21 why, he was pretty quick to react to it. He said there was 22 an going joke at the plant operations, that "you just keep 23 doing a good job and stepping on Bechtel management toes, and 24 you will lose your job and get transferred." I have no 25 record of anybody in Bechtel, anybody of management status, } ACE FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coverage 800-336 4 46
30477'.O' COX 90 'l ever making such a remark or comment-to him. 2 Q Let me ask you about this, you got an impression 3 from Parks here. You.say you didn't know much about' Parks 4 prior to this time, prior to March 1, anyway. 5 A Yes. 6 Q Was it your feeling that the supervision at the-7 site was, or that this situation that you were identifying 8 here with these notes, reflected on the quality of the 1 I 9 Bechtel supervision under you? In other words, this.is the 10 first time you seem to have focused on-Parks in these 11 matters. Did you feel -- 12 A Now we are going back to something I wanted to O 13 expand on a little earlier. Parks had a unique position. 14 Parks was a relatively new Bechtel employee. I am going to 15 tell you things you already know, but I would like to have 16 them on the record. 17 Parks had been with Bechtel something like a 18 year. He had been a former employee of NUS. He was hired by 19' Bechtel at the site, directly from NUS. As I understand it, 20 he was immediately assigned to Mr. King's operations group, 21 probably at Mr. King's request, and he may have even 22 recommended that we hire him. He had worked for Mr. King, l 23 under Mr. King before, and he was the only Bechtel employee, 24 to my knowledge, that was working in Mr. King's operations 25 group, okay. It made it very complicated for Mr< Parks and 1 ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-3 % 4646 { j
4 30477.0 1 COX .91 1 for Bechtel management, because he basically was under the 2 day-to-day management of Mr. Parks. 3 Q Mr. King, you mean? 4 A I mean under Mr. King. We all know,-from 5 testimony here, that there was an ongoing conflict, if you 6 will, I think that's too strong a word, but there was always 7 issues between a group that happened to be made up by a-8 Bechtel inan,. Thiesing, who headed it up, but was made up also-9 of many GPU employees, and the operations group headed up by 10 Mr. King; and we all recognize that that was one of the major 11 issues of integrating this team and making it work. 12 I think Mr. Parks got his philosophies, his input, .O 13 1 think in this case, he was carrying the banner of Mr. King, 14 and I am not questioning his loyalty, and I think that's 15 where this got mixed up some. I don't think he ever 16 identified himself, nor had an opportunity. So it was hard 17 to say that Bechtel me.nagement failed when they really didn't 18 have -- his contact would have been with Mr. Wheeler on a 19 functional basis. I think the record would show he didn't 20 see Mr. Wheeler that many times. 21 Q Do you mean on an administrative basis? i 22 A Yes, he is administrative. His salary 23 administration, to be sure that he had the performance 24 reviews that he was being treated as a Bechtel employee is to l I 25 be. But he basica.11y was a part of Mr. King's group. I ACE FEDERAL REPORTERS, }NC. 202-347-3700 Nationwide Coverage 800-336-6646 l l t
30477.0 COX 92 1. think that's a complication here that we need to put on the 2 record. And, in some places, I think that comes to 3 Mr. Park's defense. 4 Q Yes. 5 A He admitted during the course of'that meeting, and 6 the last statement I have here, that he had used what he 7 thought probably was bad judgment in the Quiltech: situation. 8 Q Did you accept his statements as credible 9 statements, particularly this last one? 10 A I had no reason to doubt it. 11 MR. HICKEY: The last statement being about the 12 one that he used poor judgement in doing this? 13 BY MR. JOHNSON: 14 Q Yes. 15 A As I said, he was open about Quiltech when I 16 interviewed him. He was open apparently with-Hoffman about 17 Quiltech. He, if not an apology, at least he said that he 18 thought he had used bad judgment with respect to Quiltech. 19 Q Thank you. Did you have discussions with 20 Mr. Wheeler and Mr. Hoffman concerning this March 15 21 interview with Mr. Parks -- did you have conversations with 22 those individuals after Mr. Parks left, about the interview? 23 A We would have reviewed the interview. 24 Q What was your conclusion or observation? That's 25 not a very good question. Let me try to rephrase it. } l l ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage mig-3364M6
l 30477.0 _ COX 93 l 1 Did you and the two other gentlemen who were in 2 attendance from your office with Bechtel reach any kind of l 3 consensus or conclusion regarding that interview? 4 A We did not reach a conclusion with respect to how 5 we should dispose of the Quiltech situation with Mr. Parks. 6 Q So how did you leave it with Mr. Hoffman? 7 A Well, Mr. Hoffman, of course, had to go soon. 8 This was a very short track meeting we had. They talked to 9 him in the afternoon. They were down here early the next 10 morning. -Mr. Hoffman had to go review his notes, and he 11 needed to write up some kind of a form, you know. And he 12 needed to come to some kind of a consensus in his own mind O 13 about what he had heard, and how he evaluated it with respect 14 to Directive 2-1, whether he had, in fact, been abrogated or 15 not. That was done over a period of some time. He 16 interspersed that, as I recall, with a trip to England. He 17 was on other situations. 18 In-house, we again held basically the same staff 19 people I have discussed with you before, and we discussed 20 various aspects of it. We wanted to come to a conclusion as 21 quickly as we could, both for Parks' benefit and for our 22 benefit, and I think the record shows what day we arrived at 23 that decision. I don't recall that date. It took us about a 24 week, I think, to sort through, catch through Hoffman and 25 sort through it all. The decision to what -- of what we {} ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-3364M6
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1 would do ultimately remained with management, internal audit 1 2 will present their findings. 3 Q It was presented back to you? 4 A And it would come back to me. 5 Q We were just talking about events that transpired 6 on the 15th of March. Did Mr. Hoffman depart from your l 7 presence on the 15th and you didn't see him again for some i 8 time? 1 9 A Or the next day. Probably left the next. day. 10 Q Did~Mr. Kanga call you the next day or two, on the 11 16th or 17th of March, to inform you that Mr. Parks had a 12 letter for you that Mr. Kanga had reviewed for Mr. Parks? 13 A Yes. 14 Q Could you tell me the circumstances of calling 15 you, what day it occurred and how it came about? 16 A I can't tell you the date. I know he called me 17 and told me that he was very surprised that Mr. Parks had 18 brought a letter addressed to me to his office, and that he 19 would be forwarding it to me. 20 0 Did he say anything else to you? 21 A Pardon me? 22 Q Did he say anything else to you? l 23 A He probably gave me the context of the letter. 24 0 Did he read it to you over the phone? ( 25 A I would think so, f ACE-FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coserage 800-336-6646 O --__= -_-_- __a._
30477.0 COX 95 v) 1 Q This is the letter, the March 16 letter, Exhibit 1 2 to the Parks affidavit. If you could come up with another 3 copy of that, I would appreciate it. Thank you. 4 Is that the letter? 5 A This is the letter. 6 Q Thank you. Do you recall, in the conversation, of 7 Mr. Kanga placing the situation with Mr. Parks in any 3 i 8 particular context in terms of whether he had just met with-9 Mr. Parks or not? I am just trying to fix the timing of your 10 call with Mr. Kanga on the letter. 11 A Time of day? I can't help you on that. I can't 12 help you if there were meetings before Mr. Kanga and (d h 13 Mr. Parks, if there was ongoing conversation before this 14 letter, but I can tell you my definite thoughts on the matter 15 are that this letter came as a complete surprise to Mr. 16 Kanga, and that he was not prepared to receive a letter. 17 Q My question really is, when you spoke to Mr. Kanga 18 about the letter for the first time, did he indicate that he 19 had just met at a meeting with Mr. Parks? 20 A That's my impression, that Mr. Parks had just 21 brought the letter over to him. There might have been an 22 intervening time while he was trying to get ahold of me if I l 23 was out of the office, but I would say it was reasonably 24 clear. 25 Q Within the same day? ACE FEDERAL REPORTERS, INC. ( 202-347 3700 Nationwide Coverage 8(0-336-6646
i i l 30477.0 I 'COX 96 (~x( 1 A Pardon me? 2 Q Within the same day? 3 A I would assume so. 4 Q If I represent to you that Mr. Parks and Mr. Kanga 5 had their conversations on March 17th, that it would have 1 6 been on that day? 7 MR. RICHARDSON: Well, the difficulty is the facts 8 that have been established are that this letter was in an 9 envelope addressed to Mr. Kanga, left with his secretary on 10 the 16th. We both know that Mr. Kanga'and Mr. Parks met 11 briefly the morning of the 17th concerning this letter. It's 12 unclear what you meant by the same day. I believe you 13 prefaced it by saying it was the day when Mr. Kanga received 14 the letter. 15 MR. JOHNSON: I did say March 17. 16 MR. RICHARDSON: That's why you confused me. 17 MR. HICKEY: That's why it is confusing. 18 MR. RICHARDSON: The 17th was not the day that the 19 letter was deposited with Mr. Kanga's secretary. 20 BY MR. JOHNSON: 21 Q I am not assuming you know all the details of how 22 this letter came into Mr. Kanga's presence or how Mr. Parks 1 23 delivered it. When you spoke to Mr. Kanga, he had already i l 24 spoken to Mr. Parks about the letter. That's correct, ( I q 25 though? I think you just affirmed that. v ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
'30477.0 COX 97 1 MR. RICHARDSON: Well, no. He said his impression 2 was that Mr. Kanga had recently received the letter'from 3 Mr. Parks. That is different than a meeting with Mr. Parks 4 where they discussed the letter. 5 MR. JOHNSON: Fine. 6 THE. WITNESS: I can't'~ answer that with certainty, 7 because I don't know. I have opinions.about all these 8 things, but I don't have certainties about some of them. 9 BY MR. JOHNSON: 10 0 To the best of your knowledge, is it your 11 recollection that -- 12 A To the best of my knowledge, Mr. Kanga would have 13 called Mr. Parks over and discussed the content of this 14 letter before he sent it forward. 15 Q My question to you was when you spoke to Mr. Kanga 16 about the letter, and you said that you recollected that he ) 17 had read the letter to you, that Mr. Kanga had already had a 1 18 conversation with Mr. Parks about the letter? 19 A Again, I can't answer that with certainty. I 20 don't know. 21 Q Again, I am not asking for certain. To the best 22 of your recollection. 23 A I really don't want to speculate -- j 1 24 MR. RICHARDSON: Don't speculate. Mr. Johnson 25 doesn't want you to speculate. I think you are just saying ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 J
i l [ 30477.0' COX 98 1 you don't recall. 2 THE WITNESS: I am saying that I know for certain 3 Mr.. Kanga called me, he had a letter from Mr. Parks. It was 4 a great surprise from him. 'He was going to transmit it to 5 me. From that point on, I guess you will have to get what he 6 did from Mr. Kanga. 7 BY MR. JOHNSON: 8 Q In your conversations with Mr. Kanga -- pardon me 9 for asking about the conversation, but since you did have a q 10 conversation I am going to ask you -- did Mr.~Kanga: mention 11 to you a situation in which Mr. Parks was either removed from 12 a particular function, that is, his startup,. primary' site 13 operations, primarily' representative on the test working 14 group, that he was about to be removed from.that position or 15 had been removed from that position? 16 A. My recollection of that is that Mr. Kanga spoke to 17 me before that had taken place, and explained to me that 18 Mr. Parks and the other gentleman questioned Mr. Kanga,.they 19 had discussed it. That the other gentleman asked Mr. Parks 20 once or twice if he had a basic problem with that. 21 Q Yes. 22 A The answer was in the negative, and I questioned 23 that. You know, are you certain of this, and they assured me j 24 they were. 25 0 Your recollection is that they described -- that { ACE. FEDERAL REPORTERS, INC. ) 202 4 47 3700 Nationwide Coverage 800-336 4 46 i
.I i 30477.0-l COX 99 LO 1 1 Mr..Kanga. described.this, what you have just.said, in the i 2 same call, he -- '3 A No, I didn't say that. I just said before, I 4 ' don't know what the' relationship between the action of when 5 that took place and when'this letter took place. But it's my '6 recollection that.Mr. Kanga discussed that this was going to 7 take place and that'all of the people that were' involved,, 8 including Mr. Parks -- 9 Q Were onboard and in agreement? l 10 A Were' onboard. He said it was not'an issue. We I 11 all know later it became a major issue, but, again, you are 12 going to find very conflicting testimony on that. 13 0 He did not speak to you before he had those 14 conversations about whether Mr. Parks agreed with the 15 proposed action before the action was.taken? He didn't speak 16 to you before that? 17 A I didn't think so. j 18 Q Do you remember whether he spoke to you the same 19 day the actions were proposed to be taken, those discussions 20 that you referred to? 21 A I don't know that for a fact. 22 Q But when you talked to him about it, it was soon 23 after those discussions had taken place? 24 A No. I think that Mr. Kanga and I had a 25 conversation, prior to the time those actions were taken, ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
30477.0 COX 100 1 without any relationship to the date of this letter, because 2 I don't know, and 7 don't know that those two conversations 3 are tied together at all. 4 Q Which two conversations? 5 A Pardon me? 6 Q Which two conversations? 7 A Well, you have alluded to two conversations. One 8 that I and Mr. Kanga had, with regard to this letter. 9 Q Yes. 10 A And another with regard to the timeliness with 11 which I knew about the change in duties for Mr. Parks from 12 that one specific committee. That conversation could have O 13 taken place before this letter, for all I know. I just don't 14 want them tied together, because I don't know. 15 Q But you believe they were two different 16 conversations? 17 A I believe so. As a matter of fact, I don't think 18 they are related at all. 19 Q Why do you think that they are not related at all? 20 A Well, because I think they are two entirely 21 separate issues. 22 Q Meaning -- 23 A one was an organization problem, and it fit 24 certain organizational requirements, as I understood it, at 25 the site. That you had the appropriate representation on ACE FEDERAL REPORTERS, INC, 202-347-3700 Nationwide C overage mL3364646
30477.0 COX 101 1 given committees, and that that committee was overpopulated 2 with operations people. To meet the administrative 3 procedures and so on and so forth, that that was carried out 4 for that purpose and that purpose only, but oecause of the 5 issues that were surrounding Parks at the moment, the 6 Quiltech thing, particularly, that he was given the courtesy 7 of a discussion about it, whether he was concerned about it, 1 \\ 8 and my information was it was negative. 9 This letter was a surprise of Mr. Parks, initiated 10 by Mr. Parks, carried out by handdelivering it to Mr. Kanga, 11 and my impression of that is as big a surprise to Mr. Kanga 12 as it turned out to be to me. O 13 Q In your conversation with Mr. Kanga about the 14 discussions about removing Mr. Parks from that committee, did 15 he mention Mr. Chwastyk? 16 A If he is the gentleman that initiated the 17 recommendation; is he? 18 Q Yes, I believe he is. 19 A If -- he mentioned the man that was primarily 20 responsible for balancing the committee and then initiated 21 it. I don't know him by name. There were three people 22 involved. Parks, the man that set about to initiate, which 23 was not Bahman Kanga, but the man that set out to initiate 24 the change, and then brought to and approved by Mr. Kanga. 25 Q Did Mr. Kanga, in his conversation with you about {) ace FEDERAL REeomrERS, INC. 202-347 3700 Nationwide Coverage M o.33 M,646 3
l 30477.O' COX-102 O-1 that action, indicate to you that Mr. Parks -- that he had 2 asked Mr. Parks that -- to agree or for his verification, that the action did not constitute discrimination or 3 4 harassment or retaliation? 5 A Yes. He specifically asked him that.. 6 Q And that Mr. Kanga reported to you that Mr. Parks 7 had indicated that it was not? 8 A He indicated he had no problem with it. 9 Q Did you counsel Mr. Kanga concerning taking that 10 action? 1 11 A After this report, I did not suggest to them that 12 they not follow their own administrative procedures at-the 13 site, I didn't run the day-to-day operation of the site. I 14 viewed these things with respect to the client's preparation 15 budget, schedules, how it would appear to the world or how we l 16 might all be affected by it. i 17 Q Did Mr. Kanga represent to you that Mr. Parks was j 18 being removed, in part, because of some administrative .j 19 anomaly of too many site operations representatives on this l 20 committee? l 21 A That's my recollection. There was an unbalance on 22 this committee. Operational may be a wrong choice of words. 23 But there was an unbalance on the committee. Each of the 24 groups on the site were not appropriately represented as they 25 should have been. ace FEDERAL REPORTERS, }NC. l 202-347-3700 Nationwide Coverage 80fk336-6646 i
1. 30477.0 COX 103 Qv l 1 Q And that Mr. Parks' removal would accomplish a 2 better representation? 3 h The appropriate representation. 4 0 The appropriate representation. Did Mr. Kanga ask 5 you or tell you that it was of concern to him to take this 6 action because Mr. Parks had raised concerns about the 7 validity of the procedures used in the polar crane load test 8 procedure? 4 9 A I didn't hear all of your question. 10 Q Did Mr. Kanga raise to you his own reservations ) 11 about taking the action because Mr. Parks had raised safety j 12 concerns - V 13 A Not prior to the action. My perception was that i 14 he thought it was a clean cut administrative proceeding. 15 0 And had nothing to do with the fact that Mr. Parks I 16 had raised concerns about the polar crane? 17 A That's correct. 18 Q At the end of that conversation you had with l { 19 Mr. Kanga about this removal business, would it have been 20 reasonable for Mr. Kanga to conclude that you had no 21 reservations or no disagreement with his action that he 1 22 proposed to take? 23 A Mr. Kanga didn't expect me to approve his 24 day-to-day operations to the site organization, because, as I G 25 said, he was under the direct administration of Mr. Arnold. U ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80(b336446
30477.0 104 .,, COX (_ 1 Q Did you indicate that it didn't seem to be a i 2 problem? 3 A I didn't express concern. 4 Q Just to make sure I understand what that answer 5 means, did you say "I don't have a concern," or "that's none 6 of my concern," or did you say "I have no problem with that" 7 or something of that nature? 8 A Let's say by omission, by not commenting on it in 9 a derogatory manner, Mr. Bahman would know me well enough to 10 know that I had no concern. 11 Q Silence would be assent, so to speak -- I am 12 sorry, would silence have been a type of an assent in that /~T \\l 13 type of situation? 14 A I was not known as being reluctant to speak up if 15 I disagreed with an action, even though it wasn't my 16 responsibility. 17 Q I note that the deposition of Mr. Wheeler, he said 18 a textbook could be written about your management style. 19 A Yes. 20 0 I don't know if you were aware of that. 21 A It wouldn't be 101, it would be about 99. Don't 22 put that in. 23 MR. JOHNSON: Let's take a five-minute break. 24 (Recess.) 25 BY MR. JOHNSON: { 1 ACE FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 800-336-6M6 l 1
30477.0 coy 105 1 Q Let's get back to the decision, if we can, on 2 Mr. Parks' Quiltech connection. How did that'come to be 3 made? 4 A The decision to decide that Mr. Parks was not -- 5 was not in a position -- we didn't feel that he had -- 6 0 On the Quiltech matter. 7 A Yes. Okay. Well, on Quiltech, as I said, we 8 analyzed that for several days. We consulted with 9 Mr. Hoffman, we consulted with personnel, we consulted with 10 Mr. Wheeler, Mr. Bruner. I think the consensus, from 11 internal audit, was that he had, in fact, had a conflict of 12 interest in what he had done. But I think, as'we evolved 13 this thing and looked at it from Parks' side also, we got 14 back to where there were some extenuating circumstances for 15 Mr. Parks, and that this wasn't the most serious conflict of 16 interest, that it had not really compromised GPU or Bechtel's 17 relationship with GPU. 18 And quite frankly, we found, when we checked the 19 personnel records on Mr. Parks, that, one, his performance 20 evaluation was that he was certainly an adequate to l 21 reasonably good employee with respect to startup; that two, 22 he had been hired at the site; and three, he had been missed 23 by almost all of the Bechtel policies of employee 24 orientation. Mr. Parks should have been read by Bechtel 25 Directive 2.1, and he should have had other orientation ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 85336-M46
30477.0 COX 106 1 courses that did'not occur basically because he was hired at 2 'the site, transferred almost immediately into another 3 organization, and it just didn't get done. 4 So I felt that we hadn't done all for Mr. Parks we 5 should have done to alert him that such things are considered 6 very seriously by Lechtel. 7 To shorten this dialogue, I decided that we really 8 should give him another chance. 9 Q Was he on probation, in your mind, or exoneration? 10 A No, as a matter of fact, he wasn't on probation. 11 Our people were instructed that Mr. Parks was now just a 12 Bechtel employee, that he.was to be treated as any other .O 13 Bechtel employee. If he did well, he was to be rewarded. If 14 he did poorly, he was to be counseled. I think we had his 15 comments, that he thought he had used some bad judgment, and 16 we had reason to believe that that wasn't going to happen 17 again. So the offshoot of that was we began to be somewhat 18 concerned that perhaps our personnel policies weren't 19 reaching to as many people in the field as they should, and I 20 instructed personnel to make a special effort to get to all 21 of our job sites and to see that all the people that have 22 been hired in the field were getting the same personnel 23 orientation as we had given to engineers hired into the home 24 office. I 25 Q Let me ask you, Mr. Kanga -- I am, in a sense, l l ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800-3364M6
I 1 l 30477.0 i cox 107 (' j 1 backing up here just a bit -- Mr. Kanga was said to have said l 2 to Mr. Parks that his -- that Mr. Parks' action with respect j 3 to having secretaries, a secretary type resumes, had put 4 Bechtel in a bad position. 5 Do you recall Mr. Kanga indicating that he had 6 said that to Mr. Parks? 7 A What is the date and what is the occurrence? 8 Q It would have been in approximately the time frame 9 at which Mr. Parks had come in to talk about the letter that 10 we referred to, the one that is dated March 16, 1983, that is 11 in front of you. 12 A I don't know if Mr. Xanga told him specifically 13 that, but I am quite sure I probably told him specifically 14 that. 15 0 You mean at the March 15 meeting? 16 A Yes. As I have testified earlier, I expressed the 17 seriousness that Bechtel considered these breaches of 2-1. 18 We did get word up to Mr. Parks as quickly as we made a 19 decision that he would not be penalized or punished for this 20
- action, And I would think that we had Mr. Wheeler discuss 21 with him about getting his orientation courses and starting 22 off with a clean slate with both parties.
23 Q Did you communicate your decision with respect to 24 Mr. Parks on the Quiltech matter to Mr. Arnold? 25 A It would have been more logical, I guess, that I } ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 4 46
m.' w 30477.0 COX 108 1 reported it'to Mr. Kanga, because I had no direct 2 responsibility to Mr. Arnold as to how we handled it 3 administrative 1y. I would have presumed that it went to 4 Mr. Kanga, to Mr..Kanga to Mr.. Arnold. I wouldn't preclude 5 that I talked to Mr. Arnold about it, but I.would rather 6 think that it went to Mr. Kanga. 7 Q- .Did Mr. Kanga report to you conversations he.had-8 with Mr. Arnold about the resolution of the Quiltech 9 investigation? 10 A I recall no objections to our solution to the 11 problem. 12 Q Do you recall him relating to you any O 13 conversations he had with Mr. Arnold about the subject? ~14 A Not specifically. 15 Q When did you first become aware that Mr. Parks was 16 going ~to go public with a press conference to make known his .i 17 safety concerns, et cetera, at Three Mile Island? 18 A My best recollection, it was the afternoon before 19 the occurrence. '20 Q How did you learn that? 21 A A call from Mr. Kanga. l 22 Q What did he tell you? j i 23 A Pardon? 1 24 Q I am sorry, I did ask a question, maybe you didn't 25 hear it. What did he tell you? ) l ACE FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coverage 80(1336-6646
30477.0 COX' 109 1 A He just related the fact that Mr. Parks had 2 decided to go public and would be. holding a press conference '3 either the following' day, or, if he called me that morning, 4 later that afternoon. I think it was the following-day, in 5 downtown Washington. He mentioned that he was associated 6 with GAP, and that they would be holding a joint press 7 conference. 8 Q .Did Mr.. Arnold -- you said this was Mr..Kanga that-9 spoke to you? 10 A Yes. 11 0 Did Mr. Kanga relate to you what had transpired in place that morning that Mr. Arnold 12 a meeting that had tat 4 13 had convened to discuss the situation with respect to 14 Mr. Parks? 15 MR. HICKEY: Can I ask, if you will clarify the 16 question, I think it's unintentionally misleading. The 17 witness said he believed he had a phone conversation with 18 Mr. Kanga the day before the press conference. You have 19 asked him about a meeting that was convened that day, and 20 it's not clear whether you are referring to that day being 21 the day of the press conference or that day being the day 22 before the press conference when he had the phone 23 conversation with Mr. Kanga. 24 MR. JOHNSON: That day means the day of the 25 meeting, not the press conference. ACE FEDERAL REPORTERS, INC. 202-347-37(X) Nationwide (merage 8(X)-336-6646 L_--__.____.-_____
'30477.0 COX 110 1 MR. HICKEY: Wait a minute.. That just confused it 2 further.. 3 MR. RICHARDSON:. I think'he is going to restate 4 the question. 5 BY MR. JOHNSON: 6 Q I will state it again. You received a phone call-7 from Mr. Kanga in which he related to you information a'uout 8 Mr. Parks going public; is that correct? 9 A Yes, and my specific answer, the timing of that 10 should be, shortly a.fter Mr. Kanga found out'about it, 11 whether it was the afternoon or before,-or whether he found 12 out the following morning, the day of the press conference, I ,O 13 .am certain that I was notified almost immediately.. 14 .Q Did he relate to you the contents of a meeting 15 that had been called at the site of top management people on 16 Unit 2, convened by Mr.. Arnold, on the subject of Mr.-Parks 17 going public? 18 A At one time or another there was a discussion of 19 countervailing strategy of how to deal with the press 20 conference, whether that was a fallout from a meeting with I l 21 Mr. Arnold, or I suspect it was GPU management and I f 22 Mr. Kanga. 23 Q I am afraid I got a little lost with your answer. .1 l i l 24 You said that there was discussion, but I had asked you, did j l 25 he relate to you what had happened at a meeting. It wasn't l L 1 l l
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,o -30477.0' COX-111 1 directly responsive and you said,_.I think, that"probably came .2 from a me'eting. 3 A. Let me.be as precis'e as I can -- i N 4 MR. RICHARDSON: Are you asking about a? meeting' / 5 where all supervision of TMI-2 were'present or a meeting y 6 limited to' top management? 7 BY MR. JOHNSON: 't 1 8 Q May I represent to you that.thu)ro was such a 9 meeting at~ which a large number of canagement people a U the N 4 10 Unit 2 were present, which was convened by Mr. Arnold'and 11 Mr. Kanga, at whic'O'both speak. I am wondering ifj when you spoketkM.)tKanga,her'slatedtoyou.thesuShlianceofthat 12 ~ a-O o, 13 meUQyi. ,g L 14 MR. RICHARDSON: I think that is not entirely 1: 15s accubate. I t 's a,.3 meeting where a11(levels of" supervision areq i 16 present. The testimony is, people at Mr. Kitler's level and 1 L L 17 above were in attentla,nce at that meeting. When you say w 18 management, that may,be confusing. 1 19 MR. HICKEY: May I make a suggestion. I don't 20 think it's really b dispute in;the record that there was a l-s 21 meeting on the morning of March 13,'that's'the day of the' 1 l~ 22 press conference.y I. think it's also not disputed in the ( ( l. 23) record that Cy0G Jnd Etechtei personnel learned'about the l 4, 24 plans for the press ccnference the day before, March 22. You 25 can ask the w2tn w Q an&smaybe if you put the dates in, it ACE FEDERAL REPORi't!RS, INC.
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i,- ) 30477.0 cOx -112 . O 1 'will' help him clarify, if'he can remember, which day he had a 2 ' discussion. 3 MR. JOHNSON: 'Okay. 4 'BY-MR. JOHNSON: L \\p 5 Q Do you~ recall having this discussion on March 23 6 with Mr. Kanga? 7 A Well, I am going to continue to give myself the. L 8 range of dates that:I have established originally,=because-I 9 can't' testify to something more definitive than that. 10 .Q Was it your impretsion,.from the phone call, that-la Mr. Parks had not had his. press conference yet? 12 A' Yea. 13 O Did Mr. Kanga say that the options had been 14 discussed at a' meeting about what to do with Mr. Parks? 15 '.A There were discussions of options of how to j v y 16 respond to Mr. Parks, not what to do with Mr. Parks. How to h-17 respond to Mr. Parks'1 press conference. 18 Q Did there come a time when Mr. Arnold called you 19 directly concerning his decision about what to do with 20 Mr. Parks? l 21 A There was a time that Mr. Arnold and I discussed 45 i 4 22 how to handle the situation with Mr. Parks, and at that time 1 P l y.. / 23 Mr. Arnold expressed a preference or a desire that Mr. Parks 24 not be returned to the site. 25 Q Could you put a time on that, when did he have -) ace FEDERAL REPORTERS, INC. .j 1 202-347-3700 Nationwide Coverage 800-336-6646 n
l l 30477.0 i COX 113 (.) 1 that conversation with him? 2 A Not specifically. 3 Q Was it after -- 4 A Prior to the time he was suspended. 5 Q Well, the date of the letter suspending him, by 6 Mr. Wheeler, is March 24. The date of the press conference 7 was March 23. It was between the press conference and the 8 letter? 9 A My thought would be that it would have been 10 following the press conference. 11 Q Did Mr. Arnold give you a reason why he reached 12 that conclusion? That is, that he should not be returned to 13 the Island? 14 A Well, there were probably more than one reason. 15 The predominant reason was that the contents of the 16 information that Mr. Parks had publicly announced were of 17 such a nature that they were offensive to many of the 18 professional team that we had at the site, including both GPU 19 and Bechtel people, and there was a concern expressed that we 20 could effective 3y conduct our work at the site, or if those 21 professionals would even work with Mr. Parks, and one has to 22 only analyze some of the statements that he made in his 23 affidavit to realize that he took some shots personally at 24 other people, 25 0 I don't want to cut you off -- kq _) ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverape 800-336-6646
30477.0 ) COX 114 O 1 A This is important because -- t [ 2 Q I am asking you a question not about what you 1 3 later learned about the affidavit, which you would be free to 4 comment, I asked you a specific comment about what Mr. Arnold l 5 related to you. 6 MR. RICHARDSON: That's what he is doing. You 7 interrupted him. 8 THE WITNESS: I told him we didn't make a 9 decision, we had no basis to make a decision that he should 10 be suspended until we knew what was in the press conference. 11 All we knew was that he was going to have a press 12 conference. Whether he released that information to tk 13 Mr. Kanga earlier than that, I am not really clear. 14 BY MR. JOHNSON: 15 0 I am sorry. I apologize for interrupting you, and 16 now you have gone back one step more than I had intended to 17 ask you to. What I am trying to focus on is what Mr. Arnold 18 told you after the press conference about what his judgment 19 was or the reasons why Mr. Parks should not come back on the 20 site. 21 A I thought I answered that. 22 Q I apologize for interrupting. Go ahead. 23 A Well, I don't know that I have anything to add to 24 that. ,/ ' 25 Q You started giving an explanation about "if you ACE. FEDERAL REPORTERS, }NC. 202-347-3700 Nationwide Cmerage 800-33MM6
l 1 30477.0 115 ,_ COX v 1 look at the affidavit." Had you looked at the affidavit at 2 that time? 3 A Yes. 4 Q How did you get the affidavit? 5 A Again, I would rely on it being from Mr. Kanga or 6 brought to me directly from the press conference. 7 Q What did you do once Mr. Arnold spoke to you, what 8 did you do then? Did you speak to Mr. Kanga? 9 A Well, we had another discussion with the staff 10 group I have described before, including Mr. Kanga. 11 Mr. Kanga confirmed that he didn't think it was possible, as 12 a practical matter, to allow Mr. Parks to return to the site, C, 13 that there was too much emotional reaction to things that he 14 had said at the press conference. I, myself, felt -- made my 15 own management assessment, that there really was no practical 16 or pragmatic way to put Mr. Parks back on that site. 17 So while Mr. Arnold told me what he wanted to do, 18 and we would have -- we certainly would have accommodated i 19 that, because that's our policy. 20 0 In other words, if Arnold had said to you, we 21 don't want him on the site anymore, that would have been l l 22 enough for you? 23 A We do not work clients on any site -- we do not 24 work employees on any site that the client objects to, and 1 25 asks to be removed. But Mr. Arnold, in his defense, was not l l ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverare 8(n 336-6646 i
j 30477.0 COX 116 O l 1 standing alone. I would have made the decision for the same 2 reasons that he made it. I viewed the affidavit very 3 seriously. 4 Q What was it about the affidavit that you viewed so 5 seriously? 6 MR. RICHARDSON: Beyond what he has already 7 testified about? 8 BY MR. JOHNSON: 9 Q I don't think you have told me more than you 10 agreed Mr. Arnold told you his basis, and you looked at the 11 affidavit, took it seriously, and reached the same kind of 12 conclusion independently. Now, I am asking you, what was the 13 basis for your independent judgment. 14 A I think mostly at that time -- because the safety 15 issues had not been thoroughly investigated by that time. I 16 think it was the personality, it was the personality 17 assassination, if I may characterize it as such, in the 18 denigration of the professional team that was employed at the 19 TMI site. I thought much of it was totally imaginative and 20 uncalled for. It served no purpose, even for Mr. Parks' 21 purpose. 22 Q Did you know that the facts in the affidavit were 23 false? 24 A I know the quality of the people that I was 25 dealing with that was telling me that it was false. ACE FEDERAL RneonTEas, INC. l 202-347-37(K) Nationwide Cmcrage 8(K)-336-6646
_ _ _ _ = - l i 30477 0 ' 117' COX 1 Q Who was telling you it was false? 2 A Pardon'me? 3 Q Who was~ telling you that it.was false? 4 A Mr. Kanga would be my basic source of [ 5 information. 6 -Q Did he say everything in the affidavit was false? 7 A No, absolutely not. I don't mean to imply that'. 8 Q What did he say was false? 9 A Pardon me? 10 0 What did he say was false? 11 A Well, I don ' t have a ' memory-to go recall your. 12 -affidavit for you, but I think everybody remembers there was O 13 a so-called mystery man identified as having shut down some 14 safety-related pumps at TMI, based on hearsay and later 15 rejected or refuted, and I am sure a careful review of that 16 document will show other instances. 17 Q Did Mr. Arnold tell you that he had independently 18 investigated, in the interim -- I am talking about his 19 conversation with you the day of the press conference, or 20 shortly thereabouts -- that he had independently investigated 21 whether the persons -- Mr. Parks attributed his knowledge 22 about the mystery man allegation, and that he had those 23 people spoken to and that they had denied the truth of the 24 allegations that Mr. Parks attributed to them? 25 A I don't recall getting that directly from ACE-FEDERAL REPORTERS, INC. 202-347-37(X) Nationwide Coverage N(x)-3364M6
l 30477.0 118 COX l 1 Mr. Arnold. 2 Q Did you have that knowledge when you reached your 3 conclusion to suspend Mr. Parks? 4 A I had the knowledge, the reason given that there i 5 was enough emotional turmoi) over the thing, as Mr. Parkr! l l 6 said, and there was enough quer. tion about the validity of l l 7 what he had said, that if we were to continue our work at 8 that site, that Mr. Parks was very unwelcome and could not 9 return. 10 0 The judgments that you were basing your judgment 11 on were primarily those of Mr. Kanga and Mr. Arnold? 12 A Well, and I would say probably Mr. Thieeing. O 13 Q You spoke to Mr. Thiesing about this? 14 A Mr. Bruner. 15 Q You spoke to Mr. Bruner? 16 A I talk to the staff all the time about these 17 things. 18 Q But specifically you spoke to Mr. Thiesing? 19 A I think I would retract that, because I don't 20 spec.ifically remember. He is one I well might have talked 21 to, but I don't remember. 22 Q So when you talk about your staff group, you are 23 l! really talking about Mr. Wheeler and Mr. Bruner? 24( A Mr. Bruner and Mr. Kanga. 1 25 MR. RICHARDSON: Did you say Wheeler? g ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 80(k33MM6
g 7, h t -30477.0-COX-119 0; 1 THE WITNESS: Oh, Wheeler. Wheeler would'be y. l 2 another. One or two of Wheeler's men were involved. This -3 wasn't something we had-a week to meditate about. The press. ~~ 4 conference happened,-and a decision had to be'made almost. 5 immediately of what our options were and how we were going to-6 deal with them. I.think we also had some concern for Parks i 7 in this matter. We didn't think it was a healthy atmosphere 8 to put'him back into. We did the most compassionate thing, I' 9 think, we could have done, which is to suspend him with pay. 10 BY MR. JOHNSON: .l l 11 Q In testimony before the House Subcommittee on H. Energy and Environment of the U.S. Congress April'26, 1983, 12 13 you were in-a hearing in which you made a statement as 14 follows: "Since I am the author of Mr. Parks' suspension, 15 let me answer ;that question,- please. " It comes at page 47 of 16 the printed version. I will just point it out to you. It's sort of in the middle of that page. 17 18 A Okay. 19 0 What did you mean when you said "I am the author 20 of Mr. Parks' suspension"? ) 21 A Exactly that. ) L 22 Q Is this his suspension? I have pointed you to a 23 letter of March 24, 1983, to Mr. Parks, signed by 24 Mr. Wheeler. 25 A Well, we have had a play on words. Again, you l ace-FEDERAL REPonTens. INC. 202-347-3700 Nationwide Cmerage 800-336-6646 I -l
30477.0 COX 120 /~N -G 1 have said what did you mean by that, and I have rather 2 quickly run over the word " author," you know. What I meant 3 to inform you of was that I made the decision and that I was 4 responsible for the decision to do that. Mr. Wheeler 5 obviously has been delegated to carry out that decision. 6 Q You didn't write that letter? 7 A Pardon? 8 Q Did you write that letter? 9 A No. 10 Q Did you review the letter? 11 A I would say I reviewed the letter. So in the 12 strictest sense, I am not the author of the letter. \\l 13 Q I didn't want to attempt to put words in your 14 mouth. I just wanted you to characterize it for me. 15 To the best of your knowledge, did.Mr. Wheeler 16 write this letter? 17 A I would -- 18 MR. RICHARDSON: Mr. Sandford, here we are getting 19 into a delicate area. Insofar as the company's attorneys may 20 have been involved with regard to consultations concerning 21 the content of the letter and draf ting it, you are not at 22 liberty to divulge what was said or done in consultation with 23 the company's attorneys. But with that admonition, you may l i provide what other information you might have.in response to 24 25 the question. l 1 ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coveraye 8(X)-336-6646
l' 30477.0 COX 123 f'x U l l 1 THE WITNESS: I don't think I can add anything to l 2 that. 3 BY MR. JOHNSON: l 4 .Q That sounds like what Mr. Richardson said, that 5 sounded accurate to you? 6 A Yes. 7 Q There is one key sentence in here. It says, "In 8 order to insulate you from even the appearance of such 9 conduct, and to assure the continued effectiveness of all l 10 personnel at the site, we are placing you on an indefinite l l 11 leave of absence with pay," et cetera. The two phrases here, 12 one, " insulate you from the appearance even of such conduct," l 13 and back to the previous sentence, which is a denial of 14 harassment and intimidation. 15 A I didn't hear you. 16 Q The previous sentence is what is referred to, I I 17 believe that says "we deny any such harassment or 18 intimidation 1.as occurred." l l 19 The insulation, in order to " insulate you from 20 even the appearance of such conduct," was that a factor in 21 your decision? 22 A I think the fact that we couldn't assure ourselves 23 of how Mr. Parks would be received at the site, all previous 1 j 24 actions notwithstanding, following his press conference, was 25 a risk we didn't want to take. ^ ~v l 1 ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coscrape 800-336 6646 I l
f30477.0 COX 122 10 1 Q And then the latter part of it says "to assure the 2 continued' effectiveness of all personnel at the. site." 3 A .Yes, I think I have addressed that.: 4 Q You say you based your decision on'that matter, on. -5 .the advice of Messrs. Bruner, Kanga, Wheeler and' statements 6 of Mr. Arnold? 7 A Yes. 8 MR. RICHARDSON: I would state his testimony-9 stated he also based it on his own managerial judgment. 10 THE WITNESS: Well, I think that's part of the 11 record. I think I have acknowledged that after consultation,. 12 that I made these final decisions with regard.-to to this 13 major event. 14 MR. JOHNSON: I think I am done, just one minute, 15 please. i 16 MR. RICHARDSON: Please make this Respondent's 17 Exhibit A 18 (Respondent's Exhibit A identified. ) 19' MR. JOHNSON: Thank you, that's all I have. 20 EXAMINATION l 21 BY MR. RICHARDSON: 22 Q I just have a couple of questions. Mr. Sandford, l 23 earlier in this deposition Mr. Johnson asked you some j 24 questions concerning a discussion you had with Bahman Kanga 25 with regard to a decision made on or about March 17 to ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800-336 6646
I30477'.0 COX 123 l 1 replace Mr. Parks with somebody else as the primary 2 representative of site operations to the-test working group. '3 'Do you recall that testimony? 4 A -Yes. [ 5 Q Sir, I bel.ieve you stated that you recalled 6 Mr. Kanga telling'you that the reason for replacing Mr. Parks l 7 in that regard was to achieve greater organizational balance 8 on.that committee? 9 A Yes. 10 0 -Now, during the break, following.that session of i 11 this deposition, I showed you a document. Let me now show 12 you a document which has been identified as Respondent's 13 Exhibit.A and ask you.whether this is a copy of the document-14 which I showed you during the break? 15 .A' Yes,-it is. 16 Q As indicated by Exhibit A, Mr. Parks is being 17 replaced by a Mr.. Marshall, who is also a member of the site 18 operations department. 19 I now ask you, having looked at Exhibit A, do you 20 still believe that Mr. Kanga told you that the reason for 21 replacing Mr. Parks with Mr. Marshall was to achieve greater 22 organizational balance on the TWG committee? 23 A No. It's obvious from this memorandum that I was 24 mistaken about that. I think what happened and cause% a f-25 confusion, that there were two such events, one that preceded l I. ACE FEDERAL REPORTERS, INC. f' 202-347-37(K) Nationwide Coverage 8(X)-336-6M6 o_
i 3047.7.0 COX-' 124 IO:
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.this,s. 'd ;uhat I am recalling is organizational balance 2 occurred at an earlier time, and thatlthis was for a-1 3 -different reason. 4 MR. RICHARDSON: I have no more questions. 5 EXAMINATION 1 6 BY MR. JOHNSON: 7 Q On that, when did you first learn about this j 8 organizational balance issue? 9 A I don't really know. It's'just part of the. memory 10 I have of what has transpired, and I transferred it, in my-11 mind, to this event, with Parks. 'I don't know whether that i 12 was in February that that happened, or I would be guessing if 13 I told you the month. 14 Q My question is, did you know about'the -- is the 15 earliest that you knew about anything involving -- let me J 16 start again, it's getting late. 17 Did you contemporaneous 1y know about the removal 18 of Mr. Parks from the TWG for the purpose of establishing 19 balance? 20 A I don't think so, but through subsequent 21 conversations, obviously, at some time, I picked up this 22 thread of operational overpopulation of that committee, and 23 they were doing it to balance it up, and I have transposed it 24 to this issue, which is clearly wrong. 25 MR. JOHNSON: Thank you very much. ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
30477.0 .. COX ' 125- .-0 1 MR. RICHARDSON: 'Mr. Sandford, with your blessing,. 2 although we will give'you a copy of the typewritten 3 transcript of the deposition to review, I. agreed with 4 Mr. Johnson not to burden'you with having to.take'the 5 . transcript to a post office-to~get it notarized. .I will 6 simply receive whatever corrections you may have, send the-7 letter to the court reporter. itemizing:the corrections, a 8 carbon copy to Mr. Johnson, and_that will be it. 9 THE WITNESS: Fine. 10 (Whereupon, at 3:25 p.m., the-deposition was 11 concluded.) 12 13 14 15 16 17 18 19 20 21 22 23 24 l 25 l ACE-FEDERAL REPORTERS, INC. 202-347-3700 Natienwide Coserage 800-336-6646 I ___ j
y i CERTIFICATE OF NOTARY PUBLIC & REPORTER 126 l (wa, _ s,/ I, WENDY S. COX the officer'.before ] l 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, i that I am not a' relative or employee of any attorney-or r counsel employed by the parties hereto, nor financially or otherwise interested in the outcome of the action. 6 A Notary Public in and for the DISTRICT OF COLUMBIA My Commission Expires November 14, 1987
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Gntor.C 100 Momorandum Date: 3/17/83 d" br cor d e k '" E*b nsa cKenf o f 4 l <t t v 7 f
Subject:
TWG Membershi ~ To: E. Kitler, Su e isor of Start Up Location: 2 te Operations Bldg. 222 I Effective immediately, please consider W. Marshall as the Primary Site Operations Department representative to the TWG. Mr. Marshall will replace Mr. R. Parks as the primary member only for the Reactor Building Polar Crane project. l This action is considered appropriate for the present situation 1 and is not considered a negative reflection of Mr. Park's ability, conduct or performance. The designation of Mr. Marshall should not adversely affect h the Polar Crane Refurbishment Schedule. _/ /
- </ M r dI. J. Chwastyk
// Site Operations Director. (Acting) JJC/bjs cc W. Marshall DN6362 R. Parks J. Barton B. Ranga File d &- O 4 g,4j J 3 f y s y _ -;~d. En y y & clay-6/tLy sf,ks __}}