ML20238C670
| ML20238C670 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 01/14/1987 |
| From: | Gallagher R BECHTEL GROUP, INC. |
| To: | |
| Shared Package | |
| ML20238C505 | List:
|
| References | |
| CIV-PEN, EA-84-137, NUDOCS 8712310140 | |
| Download: ML20238C670 (72) | |
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{{#Wiki_filter:-- - - - 0$GD UN11ED STATES g . NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO: 50-320 (Civil Penalty) GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION (Three Mile Island, Unit 2) ll 2 4 h 9 LOCATION: MIDDLETOWN, PENNSYLVANIA PAGES: 1-69 l' DATE: WEDNESDAY, JANUARY 14, 1987 s ACE-FEDERAL REPORTERS, INC. OfficialReporters 444 North Capitol Street Washington, D.C. 20001 (202)347-3700 8712310140 871209 0 PDR ADOCK 0500 NATIONWIDE COVERACE
1 j56 UNI E STANS OF AMERICA _ l
- ~. NUCLEAR REGULATORY COMMISSION j
(/ . l ___ _ ____ __ _ _ ______x In the Matter of: :
- Docket No. 50-320 GPU NUCLEAR CORPORATION : (Civil Pennity)
(Three Mile Island Nuclear Station, : License No. DOR-73 Unit No. 2) : PA S4-137 ___________x Pages 1 through 69 Nuclear Regulatory Commission 100 Brown Street 7 Middletown, Pennsylvania Wednesday, January 14, 1997 Pursuant to notice, the deposition of RICIIARD EDWIN GALLAGHER was taken before.me, Judith A. Toberman, Notary Reporter, commencing at 11:15 a.m. APPEARANCES: GEORGE E. JOIINSON , Esquire COLLEEN P. WOODHPAD, Esquire United States Nuclear Regulatory Commission Office of General Counsel Washington, D.C. 20555 (For the Nuclear Regulatory Commission) KENNEDY P. RICl!ARDSON, Esquire Thelen, Marrin, Johnson & Bridges One Kaiser Plaza, Suite 1950 Oakland, California 94612 (For GPU Nuclear Corporation) Commonwealth Reporting Company, Inc. 700 Lisburn Road Camp IIllt. Pennsylvania 17011 S Camp Hill (717) 761-7150 Philadelphia (215) 732 1687
l-A j57 APPEARAIJCES (Continued): v' J. PATRICK IIICKEY , Esquire Shaw, P it trran , Potts & Trowbridge 2300 "N" Street, N.N. Washington, D.C. 20037 (For the GPU IJuclear Corporation)
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I i Commonwealth Reporting Company, In c. l 700 Lisburn Road Camp Hill, Pennsylvania 17011 f S Camp Hill (717) 761 7150 Philadelphia (115) 731 1687 l 1
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1 Richard Edwin Gallagher 3 By Mr. Johnson 3 -- -- -- 1 5 6 7 8 9 10 11
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Whereupon, l 3 RICHARD EDWIN GALLAGHER 4 having been duly sworn, testified as follows: 5 DIRECT EXAMINATION 6 BY MR. JOHNSON: 7 G Good morning, Mr. Gallagher. g A. Good morning. 9 G Mr. Gallagher, would you please state your full to name? 11 A. Richard Edwin Gallagher. 12 G And your present business address? O 13 A Route 441 South, Middletown, Pennsylvania, at the 14 TMI-2 Nuclear Station. 15 G And you are currently employed by GPU Nuclear? 16 A. No. I am employed by Bechtel North America Power 17 Corporation. 18 MR. JOHNSON: Mould the people around the table please 19 identify themselves? 20 MR. RICHARDSON: Kennedy P. Richardson, representing 21 GPU Nuclear Corporation. 22 MR. HICKEY: J. Patrick Hickey, representing GPU 23 Nuclear Corporation. 24 MR. JOHNSON: I am George Johnson, counsel for the NRC 25 Staff. 1 COMMONWE ALTH REPORTING COMPANY (717;761-7150
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1 MS. WOODHEAD: Colleen Woodhead, counsel for 1:RC Staff. 2 BY MR. JOHNSON: 3 G Mr. Gallagher, will you tell me, what is your 4 current position? 5 A. My present title is manager, defueling engineering. 6 G Are you a licensed professional engineer? 7 A. Yes, sir, I am. 8 G How long have you been employed by Bechtel? 9 A. Since 1971. to G In what capacity were you employed by Bechtel in 11 1982?
-, 12 A. At what time in 1982?
13 When did you come to Three Mile Island? G 14 A. I came in February of 1982. 15 In what capacity did you come to the island? G 16 A. Well, to respond to that I have to do that in two 17 parts. First, my Bechtel title was mechanical supervisor, but 18 my job position at TMI-2 was called lead site liaison engineer. 19 Who did you work for at the island when you came G 20 there? 21 A. I was directly reporting to Bob Rider, who was the 22 project engineer in Gaithersburg, Maryland. 23 Did you have an on-site supervisor at the time? G 24 A. No, sir. 25 Did that change from February '82 forward in terms G 1 i COMMONWEALTH REPORTING COMPANY (717)761-7150
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l s' j3 l ,; 1 of your supervision? v l 2 A. No. I was reporting directly to Mr. Rider until 3 September of 1982 when there was an organizational change at 4 TMI-2. 5 G And then who did you report to? 6 A. Mr. David Buchanan. 7 G Mr. Buchanan was director of site engineering? 8 A. Manager of site engineering. 9 0 Manager. And you were deputy to him? a 10 A. Yes; that's correct. 11 G And Mr. Buchanan is a GPU employee, or was then? 12 A. That's correct; then and still is. O I3 Q. Who was your Bechtel supervisor? I4 A. The way the organization was structured, I did not 15 have a Bechtel supervisor. My direct reporting supervisor was 16 Mr. Buchanan, and he also did my performance evaluation. 17 0 You didn't report to somebody in Gaithersburg? I8 A. No, sir, not in a direct, day-to-day reporting ! 19 relationship. 20 0 What about in an administrative relationship? 21 A. Well, with all the organizational matrices, I took 22 salary administration and final performance review from the ; i 23 chief mechanical engineer in Gaithersburg, Maryland. ; 4 24 Q. Who was that? i i 2I' Who at that time would have been, I believe, A. l l l COMMONWEALTH REPOR~ilNG COMPANY (7 t 7) 761 -7150 - - - ~ _ - _ _ _
I 6 (~~'; i Mr. Tom Habermas. But I did not have any other day-to-day q ,1 2 reporting relationship to Gaithersburg, 3 0 What type of work were you doing after the 4 reorganization in September '82? 5 A. I Personally was serving as lieutenant to Dave 0 Buchanan, assisting any way that I could in the managerial . 1 7 operations of the site engineering department. 8 G But what kind of work were you doing? What was 9 the nature of the work? 10 A. I personally, or site engineering? 11 G You. 12 7 s A. Trying to -- well, preparing memos, delegating l 13 work, and making sure things were done per schedules, trying 14 to develop schedules. 15 G Were you working on any particular projects? M A. Not one, not one in particular; no. 17 0 Were you working on the polar crane refurbishment? 18 A. Not specifically, no. B Were you working on defueling? G 20 A. That was one of many of the tasks that we were 21 I might have worked on it on one day and not working on. 22 worked on it on another day. 23 In your capacity as deputy -- what was it, deputy G 24 manager of site engineering? o-
" A. Yes; that's correct. I 1
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l i 7 3 1 0 -- were you designated as primary site engineering V 2 representative on the Tast Working Group? 3 A. In what time frame? 4 G After the reorganization in September of 1982. 5 A. In what time frame? In September? 6 MR. RICHARDSON: I think he is asking you whether at 7 any time after September 1982 up until today, you were desig-g nated as a representative to the Test Working Group. 9 THE WITNESS: The answer to that was yes. 10 BY MR. JOHNSON: 11 O When were you designated? 12 f- A. I believe that was in February of 1983.
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13 0 And before then you werc not? I4 A. That's correct, because I was not in site 15 engineering. 16 G There was not a site engineering department before 17 February 1983? 18 A. I thought your question was September 1982; you 19 asked me -- you said at any time after site engineering was 20 organized, was I a member of TWG. 21 G Well, I have a document I could show you that 22 shows that as of September 1 there was a site engineering 23 department, and you were designated as Buchanan's deputy in 24 the organizational chart effective August 31, 1982. 25 Is there any reason for you to dispute that? COMMONWEALTH REPORTING COMPANY (717)761-7150
1 1 8 i j6 ,' - I - 1 A. No. I agree with that.
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2 MR. RICHARDSON: Let me clarify that point. Are you 3 saying that you were not designated as site engineering's 4 TWG representative before February of '83 because there was 5 no site engineering department before February 1983? 6 THE WITNESS: No. I thought that --
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a G That's why I asked you the question that I did. 9 That's what I understood you to say. 10 A. We should go back ind try that again. 11 MR. RICHARDSON: I got that your point was that there 12 was no site engineering department before the reorganization. 13 THE WITNESS: That's right; and, therefore, I was not 14 a member of TWG. 15 MR. JOHNSON: There was a misunderstanding. Okay. 16 MR. RICHARDSON: That is why you were not a member of 17 TWG before the reorganization on behalf of site engineering. 18 THE WITNESS: That's correct. 19 MR. JOHNSON: Okay; there was some misunderstanding. 20 BY MR. JOHNSON: 21 0 Prior to your designation in February 1983 to be 22 a representative of site engineering on the TWG, did you have 23 any contact with Richard Parks on a working basis? 24 A. Yes, sir. 25 g When did you first have occasion to work with him? COMMONWE ALTH REPORTING COMPANY (717)761-7150
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1 A. I don't remember the specific date, but it would V 2 have been in the spring of 1982 time frame when he came to 3 Three Mile Island. 4 G Do you recall on what project he may have worked? 5 Was it the Quick-Look? 6 A. Yes. I believe he was preparing procedures for 7 the Quick-Look. 8 G And you were reviewing them or preparing them, or 9 what was your role? Using them? 10 A. No, I was not an implemented of those procedures. 11 I was more in a supervisory role, trying to get some of the 12 rS different engineering completed for that task.
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13 0 What was your interface with Richard Parks? I4 MR. RICHARDSON: Excuse me. " Interface," frankly, is 15 It is probably because a word that has always bothered me. 16 I am not a member of your profession, Mr. Gallagher. 17 Are you referring to " interface" in the sense of some-18 body through whom Mr. Gallagher may have communicated with 19 Mr. Parks, a medium, a liaison, so to speak, or are you 20 simply using that as a word to convey the concept of a working 21 relationship? 22 MR. JOHNSON: The latter. 23 BY MR. JOHNSON: 24 G Did you have a working relationship with Mr. Parks? 20 Well, we were working on tasks that were all needed A. l 1 I COMMONWE ALTH REPORTING COMPANY (717)761-7150
i I l 10 1 (~] L_,) i to perform the Quick-170k evolution. I don't remember any l 2 specific detailed working relationships that we had. 1 3 0 What I guess I am driving at is: did you" have personal contact with him in the work? l 4 4 5 A. Yes. c G Was it more or less on a day-to-day basis? 7 A. (No response.) I a G We were talking about the Quick-Look program. 9 A. I would say, in terms of the Quick-Look evolution, l 1 10 yes. 11 G Did you continue--after you finished the Quick-Look f- 12 project, did you continue to have a working relationship with
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14 A. Yes, I think so, but it would not have been on as 15 frequent a basis; particularly after reorganization when he 16 went to site operations, it would have been less frequent 17 than during the hectic days of the Quick-Look. 18 Q. Did there come a time in either January or February 19 of '83 when you had more contact with him due to the nature of 20 the work? ! 21 I would say that probably after the TWG group A. ) 22 started to meet on a regular basis, that I was dealing with I 1 23 Rick much more than I was previously. l 24 I was actually trying to focus on the time before G i 25 TWG was convened, I think, for the first time in '83; I think 1 COMMONWE ALTH REPORTING COMPANY (717)761 7150 l J
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~^ it was February 25. But I was thinking before that date. , ) I .J .
2 Before you were formally designated to be on TWG,in the first 3 part of the year, did you have occasion to work more fre-4 quently with Mr. Parks than you had in the fall of '82, say? 5 A. I don't recall any particular increase in our 6 working together. 7 0 How frequently did you come into contact with him 8 in the January / February time frame prior to your designation 9 on TWG? 10 MR. RICHARDSON: He has already compared the general , i 11 frequency with, let's say, the fall '82 time period. Are you 12 q trying to ascertain a more specific description in terms of L/ l
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13 how many times per month, or week? 14 MR. JOHNSON: General, yes; just general, kind of how 15 I had during much contact he was having during this period. M the Quick-Look program it was on a day-to-day basis; then it i 17 was infrequent, more infrequent,during the latter period of l i 18
'82. And we compared the two, but I didn't have an idea of
"' what it actually was for --
l 20 MR. RICHARDSON: I gather you're speaking about work- l 21 related contact -- 22 MR. JOHNSON: Yes. 23 -- as opposed to crossing each other MR. RICHARDSON: 24 in the hallway? 25 MR. JOHNSON: That's right. COMMONWE ALTH REPORTING COMPANY (717)761-7150
) l 1 l l 12 I"'; 1 THE WITNESS: I really don't recall a specific measure. 2 MR. HICKEY: Just so I am clear. You're talking about 3 sitting down, Mr. Gallagher sitting down with Mr. Parks to 4 discuss a particular project, and did that happen once a week j 5 in the fall or once a week in January, -- f ! 6 MR. JOHNSON: Something of that nature. l 1 7 MR. HICKEY: -- or once a month? If you know. ) { 8 Is that the question that we're trying to get at? ' 9 MR. JOHNSON: That's the kind of thing that I'm looking 10 for. 11 BY MR. JOHNSON: rm , 12 Did you have some kind of regular personal contact Q. i i J I3 with Mr. Parks during the January /early February period? 14 A. As I say, I really don't recall any specifics. I 15 don't have any reason to believe that it was more than 16 infrequent. I7 Did you have contact on a daily basis in your Q. 18 department with individuals who did have more frequent con- ! 19 tact with Mr. Parks? 20 Could you read that question back? MR. RICHARDSON: 21 (Whereupon, the reporter read from the record, as 22 requested.) t 23 MR. RICHARDSON: I guess I am a little bit confused. 24 Are you asking whether he had frequent contact with people for 20 the purpose of assisting their work contacts with Parks, or COMMONWE ALTH REPORTING COMPANY (717)761 7150
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2 professional way with people who may have been having their i i l a own, separate work relationships with Parks? 1 I I 4 MR. JOHNSON: Either way. Either way. j 5 THE WITNESS: I think -- ' 6 MR. RICHARDSON: Mr. Johnson doesn't want you to guess 7 or speculate, Mr. Gallagher. 8 BY MR. JCHNSON: 9 0 I am rot asking for your speculation. I am asking l to you a specific question, whether you in fact had day-to-day 11 contact with people who had day-to-day contact with Mr. Parks. 12 f q It's very simple. t i
.J 13 A. I had day-to-day contact with people who, I would 14 assume, had day-to-day contact with Mr. Parks.
15 g Who might they be? 16 Well, I believe Ed Kitler would be one. Mike A. 17 Radbill, who was not in my department, but who I dealt with a 18 great deal, would have been another, 19 0 Anybody else that you can think of? 20 Not specifically in that time frame. A. 21 Q How about Tom Morris? 22 In the January to February time frame? A. 23 0 Yes. Did you know Tom Morris? 24 A. Oh, yes. I know Tom Morris. 25 0 What was his position, to your knowledge? COMMONWE ALTH REPORTING COMPANY (717)761 7150
14 12 f A. In that time frame I believe he was the supervisor [ I 2 of decon and rad waste. 3 0 Was he a Bechtel employee? l 4 A. Yes. 5 0 You say he was supervisor of decon and rad waste? l 1 6 A. Yes. 7 G Did you know whether Mr. Morris had personal g contact in his work with Mr. Parks? 9 MR. HICKEY: In January and February, right? 10 MR. JOHNSON: I'm sorry. Yes, in January and February. 11 THE WITNESS: I don't know. I don't remember.
~,,s, 12 MR. RICHARDSON: With regard to the others, Kitler and
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13 Radbill, you said that you assumed that they had day-to-day i 14 contact with Parks. Is that based on your own personal 15 observations, or is that just some kind of a guess? 16 THE WITNESS: I would say that is purely speculation. 17 As I said, I do not know for a fact that they did. 18 BY MR. JOHNSON: 19 G But given their responsibilities with respect to 20 writing procedures and startup and test functions -- 21 Mr. Kitler had the startup and test function, and Mr. Parks 22 was his alternate supervisor, and Mr. Radbill was working on 23 the procedures for the polar crane, and Mr. Parks had a func-24 tion to review those procedures -- that was a reasonable 25 assumption on your part that they had contact? COMMONWEALTH REPORTING COMPANY (717)761-7150 _ -__ m
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'-', jl3 1 MR. RICHARDSON: I have to object. There is a lot x -l l
2 lumped into that question. I think you've got to be specific 3 about what procedures you're talking about, what work tasks 4 you're talking about. 5 MR. JOlf NSON : I note what you said. 6 BY MR. JOHNSON: 7 G Did you understand the question well enough to 8 answer whether that was the basis? 9 A I guess I have to agree with Mr. Richardson. I've 10 forgotten what the question was already. 11 O Based on your knowledge of what Mr. Kitler and 12 3 Mr. Radbill's functions were, you feel that it would be
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(_. 13 reasonable to assume that they had regular contact with 14 Mr. Parks; is that a correct statement? 15 A. I think that would be a fair assumption. M G Good; that's all I was asking. 17 A. If I may add something.
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19 A. I am not sure that in the January 1982 time frame, 20 that Tom Morris was the supervisor of decon and rad waste. I 21 would have to go back and check that. 22 G Do you have an idea what he might have been? 23 A. I don't remember specifically. Organizationally, 1 24 it is too long ago. He was the supervisor of decon and 2I' rad waste, but that might have been at a later date. COMMONWE ALTH REPORTING COMPANY (717)761 7150 i
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'_j G And you don't know;what his position.was before a L.;'
3 j j' 2 that, before he had that posit'on? < 3 A. I don't Memember;the sped fic title. 4 G He.was in $ho' site engine /ering department, or was
/ i s that a separate department that he wqvi in? p 6 A. I would have to go karlo and look at that.g-I don't
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8 G Did you hhve conversations with' rir. Morris in that t
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9 time frame, lanuary/h bruary of '83? l 10 A. I don't specif0 ally remember. ' 11 G I'm not askine you right a+;. this pofnt to recollect J q 12 specific c y'v armtican, but did you' 'iome into contaht with y
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14 MR. RI CH,f.RDSON : Are you sp,aking about prof' lona'
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l 't t , 16 Mlt , JOHNSON: Personal contact of any sort.'
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17 MR. RICdARDSON: Then, Mr. Gallagber, t.at can be i 18 crossing in the hal'.way, me.rting in t!ne .< en's room. ' s i 19 BY MR. NHUSON: .i l' 20 I nm trying to fini something ot.c. You m anster 0 ,
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21 l it 's you see fit. l 22 A. I would tay Miat I'acca;.g nally sar"ir. Morris in l
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l 23 January at d February 4 l' 83. l l ( l l 24 Passing ie th.; hall, or workiag with" nim? l G I i I (No response.) 25 h' A
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17 s jl5 : (_')' 1 0 1 Dic?-you ot;casionnly work with him during that ' u-2,, period? n, . s i i 3'
' A. I'm sure I did., I don't recall the specifics.
t 4 G And then, specifically, you don't remember any par- { I 5 ticular conversation you may have had with him concerning l l i 6 Mr. Parks? {
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7 A. No, I don't recall any ipecific conversations with l 8 him concerning Mr. Parks. , j 9 G Were you aware in the January /early February time 10 frame of nite operations' reservations or concerns about the 11 head lift program, the procedures that were being followed in 12 the head lift program? i' ,3 9 (~ ,/ : 13 A. Cou?Jd I ask you to repeat that, please? . I 14 I Nr.fe you aware, in the January / G I will restate it. l .4 15 early February time frame, of any reservations or concerns the f 4 16 site operations department was raising with respect to,the 17 procedures for the head lift prograr? 18 k ' l MR. RICHARDSON: If I may, I'm going to have to object. B The question potentially partakes of the s7<ne vice which news-20 paper articles ao when they say " Washington, D.C. did this," 21 or " Moscow did '. hat." 22 { When you say "the site operations department,".are you 23 speaking of objections which were formally communicated on 24 behalf of the entire organizational entity known as site , 25 operations, or are you asking whether particular people who 1 1 I l COMMONWE ALTH REPORTING COMPANY (717)761 7150 j l
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l 2 objections or expressed certain concerns? i I s : hs 3 MR. JOHNSON: Yes; that's what I mean. 4 BY MR. JOHNSON. j J 5 G Were you aware of any concerns of that nature l c during that time frame raised by memorandum from Mr. King or 7 Mr. Chwastyk, Mr. Gischel, or other key managers in the site- ] 7 s operations department concerning the head lift program? 9 A. I believe the first written communications that I 10 saw concerning potential problems with the load test procedure
'ly 11 were later in February.
12 MR. HICKEY: He asked you about the head lift program. ! O 13 THE WITNESS: Oh, the head lift program. 14 MR. HICKEY: Isn't that what your question was? 15 MR. JOHNSON: Yes. 16 MR. HICKEY: You said load test procedure. 17 He wasn't responding to your head lift -- 18 THE WITNESS: In terms of head lift, specifically for 19 head lift, no, I do not think I am aware of any specific 20 written correspondence on concerns about the head lift 21 program. ; 22 BY MR. JOHNSON: 1 23 Let me just ask you a technical question for back-i 0 !h W 24 ground. Isn't the polar crane test procedure an element of 25 the head lift program, or is it the other way around, or are , t CoMMoNWE ALTH REPORTING COMPANY (717)761-7150 L_____.___________.- _ _ . _
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n) 1 2 A. I consider the polar crane load test procedure to 3 be part of the polar crane requalification program, which is 4 a separate program. 5 G From the head lift? 6 A. As a step for head lift, but a separate program. 7 G I see; sort of a prerequisite for head lift. 8 A. Yes. 9 0 Did you hear from Mr. Morris or Mr. Radbill, 10 Mr. Kitler, during early February or mid-February, any nega-11 tive comments concerning the way in which site operations, 12 and particularly Mr. Parks, was reviewing procedures that g- ) (_1 I3 were being proposed by Mr. Radbill and others in site I4 engineering for use of the polar crane? 15 MR. RICHARDSON: That is a pretty lengthy question. , M I would ask the court reporter to read that back slowly. a l ,' (Whereupon, the reporter read from the record, as j
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D MR. RICHARDSON: I don't want to impede the inquiry, 90 but there is a compound aspect when you say site operations 21 Are you asking and then you turn the focus to Mr. Parks. 22 The question presupposes that Mr. Radbill about Mr. Parks? i 23 l is part of site engineering, where the witness has not
'l affirmed that that is the case. You indicate "and others in l
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site engineering," suggesting that there was some kind of a i' COMMONWEALTH REPORTING COMPANY (7171761 7150 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . . _ _ _ _ _ 3
20 jl8 (-v ) 1 joint enterprise between Mr. Radbill and site engineering. 2 I think you have got to lay a foundation for these 3 elements, and then ask a specific question and take it ele-4 ment by element. 5 MR. JOHNSON: Okay. 6 BY MR. JOHNSON: 7 G Let me first ask you whether you understood the i i i g question well enough to answer it. 9 A. I would prefer not to answer it. It was a little i 10 too global. To answer it, I think I would have to try to 11 break it down into elements. 12 I accept your counsel's comments, but I would just O 8 13 as soon hear it from you that you don't understand the ques- , l 14
, tion or would like it to be rephrased.
15 Did you hear any negative comments from Mr. Kitler in 16 February concerning Mr. Parks? 1 i 17 A. No, sir, I don't ever recall hearing any negative i 18 comments from Mr. Kitler concerning Mr. Parks. I l 19 Did Mr. Radbill have occasion to talk to you about O l 1 20 Mr. Parks' objections to the polar crane test procedure? I I 21 MR. RICHARDSON: Excuse me. I think so everybody knows
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22 what you're talking about, I gather you're referring to l l 23 Mr. Parks' comments of February 17 concerning the load test l 24 procedure? l 25 MR. JOHNSON: That is one of the things I am thinking l COMMONWE ALTH REPORTING COMPANY (717)761 7150 E _ _____ _ _ _ _ _ _ l
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LJ 2 MR. RICHARDSON: If there is somathing beyond that, 3 then maybe that has got to be pointed out. 4 BY MR. JOHNSON: 5 0 Would you like to see his comments, Mr. Parks' 6 comments, of February 17 before answering this question, or 7 do you think you can answer it without seeing those? I will I 8 be glad to show it to you. 1 9 A. I'm familiar with the comments. I have seen them. 10 Now, if you would rephrase your question again, then I will 11 answer it, or I will attempt to answer it. 12
.3 G Did Mr. Radbill speak to you concerning the NY' I3 ,
comment resolution tnat Mr. Parks filled out on February 17 1 14 and submitted to Mr. Radbill? And just so you can see what 15 we're talking about, I'll take it out here. IU (Document shown to witness.) 17 O Did Mr. Radbill have occasion to talk to you about i 18 that submittal, that comment resolution? 19 You are showing the witness Exhibit 7 to MR. HICKEY: 20 i the Chwastyk deposition, right? { 21 MR. JOHNSON: Right. l , 22 BY MR. JOHNSON: 23 0 When it was submitted, these reasons for rejection 4 24 wouldn't have been there. 25 A. Pight. i < l 1
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I i 22 i i 0 (Rj~') 1 (Witness perusing document.) MR. RICHARDSON: Let me clarify the one aspect. You're I 2 3 asking the witness whether he talked to Radbill concerning 4 Mr. Parks' February 17 comments before -- j i 5 MR. JOHNSON: I didn't say before anything. I just f 6 said did he talk to him. 7 MR. RICHARDSON: Well, no, because you added that the 8 typewritten portion to the right would not have been there, 9 which leads me to wonder whether your question -- 10 MR. JOHNSON: That is the document I was referring to, 11 yes, the document as it would have existed without those 12 comnents, those reasons for rejection, on it. y3
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13 MR. RICHARDSON: So you're asking about whether there 14 was a conversation with Mr. Radbill concerning that document 10 before the typewritten portion on the right was on it? 16 MR. JOHNSON: That's right. 17 TI!E WITNESS : I do not remember any specific conversa- l 18 tions with Mr. Radbill concerning the comments before they M' were resolved. 20 BY MR. JOHNSON: 21 0 Did you have conversations with anybody else in 22 your department concerning Parks' comments? 23 MR. RICHARDSON: Again, before recovery operations 24 stated its response to the comments. 25 THE WITNESS: I, again, do not recall any si cific ; COMMONWE ALTH REPORTING COMPANY (717)761-7150
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(-) ! 2 BY MR. JOHNSON: i a G When was the first time you saw that -- I can show 4 you the form of the document that was submitted. This is l 5 what it looked like when he submitted it. This was supplied o in our first discovery response of September 23, 1986, and it 7 is the 2/17 version of that documerJ.. 8 (Document handed to witness.) , 9 (Witness perusing document.) 10 A. I don't know if I -- 11 MR. RICHARDSON: Mr. Gallagher, there is no pending 12 question.
,-_s i s i/ 13 MR. JOHNSON: Yes. I asked him when he first saw it.
14 THE WITNESS: I was about to ask you to repeat your 15 question. 16 I do not know the specific date when I first saw this i 17l document. 18 BY MR. JOHNSON: 19 0 Did you ever see it in that form? 20 A. I don't know that I have ever seen it in the un-21 resolved form other than as part of testimonies in deposition. 22 G Did you have a role in resolving those comments? j m l
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MR. RICHARDSON: Can I ask you to be more specific? 6 og Are you referring to the witness having a role with regard to l l l 20 recovery operations' response to the comments, or a role with l l
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COMMONWEALTH REPORTING COMPANY (717)761 7150 j
i i 24 l (l I regard to the ultimate pursuit and resolution of the comments? V
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2 BY MR. JOHNSON: ! 3 G Did you have a role in responding to those 1 l 4 comments as they were responded to on February 28? l 5 MR. RICHARDSON: Excuse me. I think the recovery 6 Operations comments are dated February 25. 7 MR. JOHNSON: It seems to me that you are being a I g little bit obstructionist, Mr. Richardson. I think this is a 9 fair question. It was submitted to site operations on 10 February 28; it so says on the very document that you have 11 before you. , 12 I appreciate your concern about being specific and o, l
l 13 being sure that your witness understands the questions, but I 14 also would appreciate not being interrupted unnecessarily.
15 MR. RICHARDSON: I beg to differ with you, Mr. Johnson. IG It is unclear from your gcestion whether you are -- if you 17 use the date February 28, then the witness may understand the 18 question as to whether he had a role with regard to the cover 19 memorandum, but the response of recovery operations is dated 20 February 25. 21 MR. JOHNSON: The document has a February 25 date on 22 it. The cover letter was dated the 28th. 23 I just think it is unnecessary. 24 BY MR. JOHNSON: 25 G Did you have a role in preparing those responses COMMONWE ALTH REPORTING COMPANY (717)761 7150
l l 25 1 on this document, which is the Chwastyk exhibit that we were 2 referring to, 7, which has a date of resolution attached to 3 it of 2/25/83? 4- (Document shown to witness.) 5 A. I do not remember a specific input to these o resolutions. 7 G Did you form an opinion about Mr. Parks' comment s resolution? 9 A. I believe the comment resolutions were by 10 Mr. Radbill. 11 G I believe the title of the document is called
,,,s 12 " Comment Resolution." I really intended the left side of the 13 document.
Ad A. Your question was, again, did I form an opinion 15 on Mr. Parks' comments? 16 Yes. 0 17 A. At the tine they were formulated, I would say it 18 was fair to say that they were a legitimate set of comments, 19 a fair set of comments, that they deserved a fair resolution. 20 Did you just have occasion to look at the resolu-0 21 tions themselves that were submitted by Mr. Radbill when you 22 were locking at the document? 23 A. I did not read them all in detail; no, sir. W 24 G Are you aware, generally, of the position that ' 25 Mr. Radbill took? l l COMMONWEALTH REPORTING COMPANY (717)761 7150
26 j24
, 'T 3 A. I remember that a number of the comments were d
2 rejected. 3 Q. Did you have an opinion at that time that the 4 rejections were justified? 5 MR. RICHARDSON: Excuse me. Are you referring to an 6 opinion that they were correct, or an opinion as to whether 7 they were -- g MR. JOHNSON: Did he agree? I think the question -- 9 MR. RICHARDSON: -- the type of response which could 30 legitimately be made, whether it ends up being correct or I 11 false? 7 12 MR. JOHNSON: Well, you're really splitting it, but
!) '- 13 that's okay.
14 BY MR. JOHNSON: 15 0 I just really wanted to know whether you agreed I 16 with those rejections of Mr. Parks -- to the extent that they j 17 iwere rejected, those comments werre rejected, did you at that i 13 time agree with those rejections by Mr. Radbill? j l 19 MR. RICHARDSON: It presupposes that the witness saw j 20 the recovery operations response when it was issued. You l i l 21 haven't asked that question. l 22 MR. JOHNSON: I know I didn't ask that question.
]
23 BY MR. JOHNSON: 24 0 Maybe if you look at the document. l 25 (Document shown to witness.) l l l COMMONWEALTH REPORTING COMPANY (717)761 7150 l L___________ __
27 j25 f-} v t (Witness perusing document.) 2 A. Okay. Now, if I could just ask you to repeat the a question again, I'll try to give you an answer. 4 0 During the time period, say the 25th of February 5 to March 1, in that time frame, did you agree with the resolu-G tions that were made by Mr. Radbill there? 7 MR. RICHARDSON: So I understand it, the question, I 8 take it, is: did the witness, between February 25 and March 9 1 of 1983, form an opinion -- or did he agree with those 10 comments? 11 MR. JOHNSON: That's right. Exactly right. 12 MR. RICHARDSON: I am going to have to object because rw
)
13 there is no foundation laid as to whether the witness reviewed 14 the recovery operations response between those dates. 15 BY MR. JOHNSON: 16 Did you see those responses when they were {1 17 prepared? 18 I do not have any knowledge as to when I saw A. 19 these for the first time. 20 0 When did you become aware of them? 21 Certainly, A. I could not give you a specific date. 22 4 before I went to the first TWG meetina that these were dis- q 23 l cussed, but I could not pick a specific date that I saw ) 24 those. 1 25 You attended a TWG meetirg on 2/25/83? G COMMONWEALTH REPORTING COMPANY (717)761-7150
28 j26 Yes, sir, I believe I did. ('S i A. L) 2 G Was the subject of Mr. Parks' comments a subject 3 of that meeting? Were his comments a subject of that TUG 4 meeting? 5 A. I don't recall if that was the only subject or if 6 all the comments were part of the subject that may have been , 7 discussed. I believe parts of the comments were. g G That's all I asked: was it a subject? 9 A. I believe it was. 10 G Did you express an opinion -- first of all, who u was at this meeting as far as you can remember?
-s 12 A. For the meeting on the 25th, I do not recall the
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13 specific attendees. 14 G But you were there? 15 A. I believe I was; yes, sir. 16 O Did you state any opinions there concerning the 17 applicability of Administrative Procec'urc 1047 to t.he polar , 13 crane load test procedure? 19 A. I don't know that I did state any. 20 G Did you form an opinion concerning the applicability 21 of Administrative Procedure 1047 to the polar crane load test 22 procedure at that meeting? 23 A. What I would like to do is, I need to -- I would , 24 like to sort out which TWG meeting we are discussing here. 4 25 There were several of them .in a close time frame. i COMMONWE ALTH REPORTING COMPANY (717)761-7150 _ - - - - __- ----_ n
29
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3 MR. RICHARDSON: May the witness see the minutes of 2 those meetings? 3 THE WITNESS: The notes or the minutes. There were two 4 TWG meetings within three days, I think, and I don't remember 5 the dates of each one. 6 MR. JOHNSON: This is kind of brief. 7 (Documents handed to witness.) g (Witness perusing documents.) 9 BY MR. JOHNSON: 10 G Now you have copies. 11 A. I'll use these; fine. 12 Now, if you would like to rephrase your question. ;
)
13 G I have a pending question, and I will repeat it. 14 That is, at the meeting did you express an opinion about the 15 applicability of Administrative Procedure 1047 to the polar 16 crane load test procedure? 17 , A. In terms of the F'ebruary 25 meeting, I do not 18 remember expressing a definite opinion about the applicability 19 of AP 1047, i 20 G That is your signature on these minutes, these TWG 1 21 minutes of 2/25/83? { k 22 A. That's correct. 1 23 G When did you sign that; do you recall? ! 24 A. No, sir; it is not dated. j 25 0 Would you have signed it on the date of its i 1 1 COMMONWEALTH REPORTING COMPANY (717)761-7150 I 1
30 i ( ') I preparation, or do you think it would have been prepared V 2 later? 3 MR. HICKEY: Would you say that again? I 4 BY MR. JOHNSON: 5 0 When would you guess that it was prepared? 6 MR. RICHARDSON: Don't guess, Mr. Gallagher. If you 7 have a basis for saying when, you may respond. 8 BY MR. JOHNSON: 9 0 To the best of your recollection, when did you 10 sign this? 11 A. I don't know. Clearly, after the TWG meeting, but 12 I do not know the date. 73
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) 13 MR. JOHNSON: We're just going to have to slow this 14 thing down.
15 (Counsel Johnson perusing documents.) 16 BY MR. JOHNSON: 17 Q In Mr. Kitler's -- you are familiar with
# Mr. Kitler, Edward Kitler?
19 A. Yes, I know Mr. Kitler. 20 0 In his statement given to Mr. .Stier on July 27, 21 1983, in a deposition, he stated that, "On February 25, I held 22 a TWG meeting. In that meeting everybody agreed that we would 23 do the load test as a construction test." , 24 Is that a correct statement? 20 I believe that is a correct statement, as reflected A. i l l l COMMoNWE ALTH REPORTING COMPANY (7171761-7150
i 31 j29
'i 1 by the minutes.
s/ , 2 0 So you formed an opinion of that sort, that the l 3 load test should be done as a construction test? l 4 A. I concurred in that opinion. . 1 5 0 What is the import of that in terms of Administra- ! G tive Procedure 1047? 7 A. I believe it limits the applicability of AP 1047. 8 G How? 9 A. There are a number of ways, but I think, for pur-10 poses of this discussion, it does not have as much adminis-11 trative -- as many administrative requirements. It is a more
,x 12 streamlined, perhaps, or a little different way to perform the Iv) 13 test.
14 Some people have phrased it as not requiring that 4 15 the format of AP 1047 be followed. Is that one way to express 16 that idea? 17 A. That would be one of the administrative differences 18 between the two; yes, sir. 19 G In Mr. Parks' March 21, 1983 affidavit, on page 20, 20 -- your counsel has a copy of it; maybe you could look at it 21 -- he states that he had conversation with Mr. Kitler coming l 22 in from the parking lot in which Mr. Kitler is quoted -- l 23 MR. RICHARDSON: Excuse me. The problem when you read l W 24 from transcripts and documents and you don't show them to the l 25 witness, then the witness is at a disadvantage. l COMMONWE ALTH REPORTING COMPANY (717) 701-7150
32 0 i MR. JOHNSON: I don't want him to be at a disadvantage. ('_} O 2 MR. RICHARDSON: I appreciate that, but he still needs 3 time to see the document before you start reading it. 4 BY MR. JOHNSON: 5 0 Please read that middle paragraph there on page 20. g A. The one starting, "On February 18"? 7 0 Yes; please. 3 (Witness perusing document.) 9 A. Okay. 10 G Thank you. 11 I direct your attention particularly to the sentence j 12 which says, "Ed repeated the original threat and attributed it () 1 13 to Rich Gallagher, an assistant director of site engineering, f 14 who also performs various other functions for top management." 15 Did you ever talk to Ed Kitler concerning a threat that 16 -- not a threat, but let me phrase it this way: did you ever 17 have a conversation with Mr. Xitler in which the subject of 18 Mr. Parks being transferred off site was the subject? 19 A. No, sir, not before the affidavit was issued. l 20 G Okay; fair enough. I i 21 When did you first become aware of this statement in I 22 Mr. Parks' affidavit?
-l 23 A. I believe it was when I read the affidavit. j 24 And that was approximately when?
0 25 A. I believe within several days after it was issued l COMMONWEALTH REPORTING COMPANY (717)761-7150 l
33 j31 T' 1 it was circulated among people at the island, and that's when L)s 2 I saw it. 3 0 What was your reaction when you saw this statenent , i 4 -- by the way, was that the first time you learned of the 5 statement, when you read it, or did you hear about it before 6 you read it? 7 A No, sir. To my knowledge, the first time I knew g that this was a statement was when I read it in the affidavit. 9 g What was your reaction? m A. I was rather surprised; shocked, I guess. 11 g Did you think about whether it had a basis? Did zs 12 you probe your mind to think: how could Mr. Kitler have said
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14 A. Yes. 15 MR. RICHARDSON: The question presupposes a premise 16 in the witness' mind that he thought Kitler would have said 17 something like that, which is the vice of a compound question. 18 I think it ought to be more specific. 19 BY MR. JOHNSON: 20 0 There is no hidden ball trick here. This is 21 Mr. Parks' statement. He attributes to Ed Kitler a statement, 22 but it seems to me it is a natural reaction for somebody who 23 has a statement attributed to him to think not only why did ) 24 the person who made the statement say that, but how could 2T' have he thought that person -- in this case, Ed Kitler -- could COMMONWEALTH REPORTING COMPANY (717)761 7150 !
i 34 (^}
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1 have formed that -- why would he have said such a thing, if 2 he had, if what Mr. Parks said was true. 3 Having said that -- I didn't pose a question yet -- 4 did you speak to Mr. Kitler concerning that statement after 5 you read this? 6 A. Yes, I believe we discussed it after the affidavit 7 was issued. 8 G What did you ask him? 9 A. I believe our conversation generally was I stated 10 -- I asked Ed -- told him that I never said such a thing, never 11 believed I said such a thing, and I believe I never inferred 12
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such a thing; and Ed responded that to his knowledge, I never i
%.j' 13 did either.
14 G Did he also say that he never used your name in 15 that conversation? 16 A. (No response.) l 17 G Let me put it this way: did he tell you that your 18 name came up in that conversation that he was referring to, , 19 that Mr. Parks was referring to? 20 A. (No response.) l 21 Q Is that clear? l 22 A. Yes, the question is clear. As I recall it, I l l 23 l believe that Ed basically said he didn't know how my name got ) 24 in here, and that he didn't attribute things like that to me, i 1 ! 25 and we let it go at that. COMMONWEALTH REPORTING COMPANY (7171761 7150 j
f i l 35 j33 [ I-,)
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1 0 That was the end of the conversation? 2 A. Yes. G Did you ever speak to Mr. Parks about this? 3 f 4 A. No, sir. l i 5 G Have you spoken to Mr. Parks since he left the 6 site? ! 7 A No, sir, I don't think so. f 8 G Did you have an occasion to talk to Mr. Buchanan 9 or any other supervisors of yours concerning this allegation i 10 once you had read this statement? { 11 A. In terms of a supervisory chain, I believe n 12 Mr. Buchanan and I discussed it, but purely from an historical I
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13 perspective, if you would. But no, I didn't, to my knowledge, ' 14 have any other conversations with any other management about .. 1 15 this allegation. 16 And when you say "other," you include Mr. Buchanan? G 17 A. No; above Mr. Buchanan. 18 Above Mr. Buchanan. G 19 What was the nature of your conversation about this 20 with Mr. Buchanan? l 21 A. I think essentially it was similar to the one with l l 22 Mr. Kitler, in that I told Mr. Buchanan that I never said such ! f 23 things, didn't know how it got in the affidavit, don't know 9 24 how it was inferred. 25 I l COMMONWEALTH REPORTING COMPANY (717)761-7150 L_----
36 l 1 t3 i BY MS. WOODHEAD: L) 2 G May I ask you to clarify? I believe you earlier J 3 said that you did not make the statement reported in the 4 affidavit to Mr. Kitler. 5 Do I understand you correctly to mean that you never 6 stated to anyone on site that Parks should be transferred? 7 A. To my knowledge, I would never have made a state-8 ment threatening Mr. Parks with transfer, because I guess, 9 quite frankly, I didn't think that such a statement was I 10 warranted; therefore, I would not have made one. 11 0 Do you recall ever saying anything of the nature 12 that Mr. Parks should be reprimanded in any way?
- '~) 13 A. No, ma'am, I don't believe I would have ever said 14 that.
15 BY MR. JOHNSON: 16 G When you were interviewed by Mr. Stier as part of 17 a GPU investigation, you were interviewed on the record by 18 Mr. Stier on July 26, 1983 in Middletown. l l 19 Do you recall that interview with Mr. Stier? l 20 Yes; with his associates. A. 21 MR. HICKEY: Was it Mr. Stier? i 22 MR. JOHNSON: It says here it was by Mr. Stier, at l l 23 Mr. Richardson was there. least it started with Mr. Stier. l 24 MR. RICHARDSON: I believe part way through -- l \ 2 MR. JOHNSON: A Mr. Frech was also involved. l COMMONWE ALTH REPORTING COMPANY (717)761 7150
l 37 BY MR. JOHNSON: [Jl 1 2 0 Mr. Stier asked you questions about Quiltec, and 3 Mr. Frech asked you questions about safety classifications 4 and those kinds of things. You do recollect that? A. Yes. . 5 G You also were interviewed by Mr. Aulick, Dean D. 6 Aulick, on May 23, 1983, concerning Quiltec, your knowledge 7 about Quiltec. Do you recall that interview? 8 A. I believe that was the Department of Labor 9 interview? )i 10 G I don't know what the purpose of it is. It says, 11 " Interview with Rich Gallagher in the Bechtel Trailer by Dean
- 12 D. Aulick, May 23, 1983."
73 ( '/
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13 I really don't know what the purpose would have been. 14 Let me show you the document. 15 (Document handed to witness by Counsel Johnson.) 16 MR. HICKEY: Mr. Aulick was an attorney working with II Mr. Stier, Mr. Gallagher, if that brings it to your mind. { 18 BY MR. JOHNSON: 19 0 My impression is that it was related to your 20 examination before Mr. Stier, and, therefore, Mr. Stier's 21 investigation. 22 A. I believe that was a follow-up interview; yes. 23 MR. RICHARDSON: I might help out. Do you recall a 24 blond-haired lawyer sitting down with you, asking you questions ? 25 (No response.) COMMONWEALTH REPORTING COMPANY (717)761-7150
38 6 (' (],/ i BY MR. JOHNSON: 2 0 Did you have any other interviews concerning the f 3 allegations of Mr. Parks or concerning Quiltec in 1983 with 4 any GPU or Bechtel lawyers in addition to these two that I 5 just referred to? 6I MR. RICHARDSON: Are you including or putting aside 7 discussions which Mr. Gallagher may have had with myself and 8 other Thelen, Marrin lawyers with regard to the Department of 9 Labor proceeding? 10 BY MR. JOHNSON: 11 G Let's just treat that separately. Did you have 12 7_. conversations with Mr. Richardson or other Thelen, Marrin (k ') 13 lawyers with regard to the King DOL proceeding? 14 MR. HICKEY: Parks. 15 BY MR. JOHNSON: 16 0 The Parks DOL proceeding? 17 MR. RICHARDSON: Could you read the auestion back, or 18 could you restate it? 19 MR. HICKEY: Excuse me for interjecting. I assumed 20 that you meant to say Parks. 21 MR. JOHNSON: Yes. 22 MR. HICKEY: I'm sorry, f 23 BY MR. JOHNSON: 24 G Did you have any conversations with Mr. Richardson l 25 during 1983 concerning, first, the Parks DOL proceeding? CoMMONWE ALTH REPORTING COMPANY (717)761-7150
i 39 l j37 Yes, I had conversations with _-') 1 A. Yes, sir.
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l 2 Mr. Richardson. 3 0 Did you also have conversations with him concerning 4 the King DOL proceeding? 5 A. No. I don't recall whether that was in 1983, but, l 0 yes, I would have had conversations with Mr. Richardson con-7 cerning my deposition for the Department of Labor. 8 MR. RICIIARDSON : I think one problem we have is that 9 Quiltec, in a way, is an issue in Mr. Parks' Department of to Labor complaint, and I think we all know that it is an issue 11 in Mr. King's subsequent Department of Labor case and his n 12 federal lawsuit, so I think that can cause some difficulty. ( ) 13 MR. HICKEY: But you were asking about 1983, right? 14 MR. JOHNSON: Yes, I was asking about 1983. 15 TIIE WITNESS: I thought I answered the question. 16 MR. JOHNSON: I'm sorry; I didn't hear you. 17 MR. RICHARDSON: I think the question is: did you i 18 have discussions with me concerning Mr. King's Department of i 19 Labor lawsuit during 1983? 20 i THE WITNESS: I am going to ask a question in return. 21 If you will tell me exactly what suit that is, and what { 22 affidavit that generated, I will give you a yes or no. I'm 23 getting a little confused here; we've got too many lawsuits. 9 24 I'm not trying to be obstructionist. I'm just getting 25 confused. COMMONWE ALTH REPORTING COMPANY (717)761-7150 l _------__---J
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~~ j38 MR. RICHARDSON: We have the problem of the overlapping v) ; 1 2 of issues.
3 MR. JOHNSON: I'm afraid I did not bring all the docu- f 4 ments that were produced to me by Mr. Hickey. l 5 Let me just ask Mr. Hickey: did you produce a state- ' 6 ment by Mr. Gallagher as part of the documents that you sub-I 7 mitted to me on December 22? There were various depositions, 8 King, Slone --
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9 MR. HICKEY: I don't think there was a Gallagher 10 deposition. 11 MR. JOHNSON: So can I presume from that that there was 12 rs no deposition --
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13 Well, no. MR. RICHARDSON: I believe Mr. Gallagher was 14 deposed during the course of either a Department of Labor I6 complaint by Mr. King or a federal lawsuit instituted by 16 Mr. King, or in conjunction with both, during 1984. II THE WITNESS: Yes. 18 MR. JOHNSON: I see. l9 Again, Mr. Hickey, can I ask you: can you explain to 20 me why that wasn't included as part of that discovery? 21 MR. HICKEY: I don't think it was requested. The 22 request was for interviews by GPU attorneys, if I remember 23 correctly, or Bechtel attorneys. 24 You rcy I didn't ask for interviews MR. JOHNSON: Yes. l 25 by Bechtel attorneys? COMMONWEALTH REPORTING COMPANY (717)761 7150 _______._d
41 (~') i MR. HICKEY: I said GPU and Bechtel attorneys is what
<J 2 you asked for.
3 MR. JOHNSON: Yes, I believe so. 4 BY MR. JOHNSON: 5 0 So, Mr. Gallagher, you were deposed in the DOL o proceeding concerning Mr. King in 1984? 7 A. I believe it was in the King case, yes. I was 3 deposed by the Department of Labor. 9 G By the Department of Labor? Who is the lawyer 10 that took the deposition, or the person that took it? 11 A. I don't recall. 12 MR. HICKEY: It was one of Mr. King's lawyers. i p~!
~~ I don't remember the specific 13 THE WITNESS: Yes.
14 individual, 15 MR. RICHARDSON: I think what you're saying, it was a 16 deposition given in some type of lawsuit instituted by , 17 Mr. King; is that right? { 18 THE WITNESS: Yes. 19 MR. JOHNSON: Again, Mr. Hickey, may I ask who was 20 representing -- 21 BY MR. JOHNSON: i 22 g Let me ask you: who represented you in that 4 l 23 proceeding? I 24 MR. RICHARDSON: To speed us along, I certainly know 1 25 it was an associate in my law firm. l l COMMONWEALTH REPORTf NG COMPANY (717)761-7150 i
l ) 42 1 THE WITNESS: I don't remember the individual. l 2 BY MR. JOHNSON: l 3 G It was someone in Mr. Richardson's law firm? 4 A. Yes, I believe so. 5 MR. RICHARDSON: I don't recall the name. 6 MR. JOHNSON: I would request that that deposition be i 7 produced as part of the discovery response to Staff's discovery 1 8 requests. 9 MR. HICKEY: I will look at the deposition. It is not to covered by the discovery request. If you would like to have 11 it produced, I will be glad to respond to you on that. 12 MR. JOHNSON: Okay. I would appreciate that. O 13 BY MR. JOHNSON: 14 G What was the subject of that deposition in 1984 by 15 Mr. King's lawyer? 16 A. I believe it centered predominantly about the issue 17 of Quiltec and the discovery of Quiltec. 18 Did you give any other statements to Mr. Aulick or G 19 Mr. Stier, other than the two I referred to before? 20 MR. RICHARDSON: I don't believe that's a statement. 21 BY MR. JOHNSON: 22 G I'm sorry. Did you give an interview to Mr. Aulick 23 in addition to the one on May 23, 1983? 24 A. I don't recall one at this time; no, sir. 25 G Did you give an interview to Mr. Stier or anybody COMMONWEALTH REPORTING COMPANY (717)761-7150
43 1 j41 (s 3 working for Mr. Stier in addition to the interview that I w) 2 referred to of July 26, 1983? 3 A. No, sir. I don't believe there were any additional 4 ones. 5 G By any other lawyer? i 6 MR. RICHARDSON: I think I should help out a bit. It 7 has been a while. I believe you may have been interviewed by 3 a gentleman named Travis Brown, who is kind of a tall guy with 9 darkish hair. 39 THE WITNESS: Um-huh. 11 BY MR. JOHNSON:
,_s 12 G What was the subject of that interview with
[ ) 13 Mr. Brown? 14 FR. RICHARDSON: I think we're drawing a blank with 15 Mr. Gallagher. 16 THE WITNESS: I remember Travis Brown, but I -- 17 BY MR. JOHNSON: 18 G Do you remember being interviewed by him? 19 A. I think we've established that I do. 20 G I want to hear it from you. 21 A. I remember a discussion with Mr. Brown. I don't 22 remember the particulars. If you have a document to refresh 23 my memory -- 24 G No, I'm not aware of -- this is the first time I 25 have been made aware of such an interview. COMMONWE ALTH REPORTING COMPANY (717)761-7150
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j42 (] 1 MR. RICHARDSON: Aulick was shorter with blcpqiFn V , t , 2 hair. - .e
,h 3 THE WITNESS: Ye .. I remember the depo.: .t ion.
4 BY MR. JOHNSON: 1 5 0 Thece wes a disposition? 6 A. No. no. I said I rehember"odg items like deposi-
! I' 5
7 tions. 1 'm af raid with somei of f.hese s 'imall interviews - ^ ' y . , l 8 9 In addition, ' etween , Apr il 16 avd ' June 21, 1983, L 9 Mr. Richardson has s.2bmi :ted Jin affidavit in wnich he has I l 10 said that you were among Lbe pt b ple that he 'conducte'c initinL , 11 or further interviews with[ .II that'c>rrect, l to the bast'ch. l 12 your knowledgei
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U; : j' y ,i MR. RICHARDSON: 02n we'show him the aftfdad c? ? 14 (Document ' landed to witne.ss.' . , 1 16 THE WITNESS. I've already sos.hd earlier,that I know 1
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\ 16 i I discussed these subjects with Mr. Richa;dson in-1985. I i l l' MR. JOHNSON: I had specifically .rvjuest'$d thr:' these 1 a 18 interview -- any interv sw records be produced, and am I 19 correct in undex stendig of:e t you a :e claiming irivilege for 1 I o
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j these documents? i oi I MR. RICHARDSON: '?:2at is correct. l I .-), y l MR. HICKEY: Mr. t.;chardson's intervie@d i t 03 ME. JOHNSON: Yes.. ' ! i W 04 MR. RIrilARUSON : Tnat is correct. 2I' MR. HICKEY: If there was a Travis Brown latervics -- COMMOP VEALTH Ft!.>OfflNG COMPANY (717)761 7/.20 I
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.j i and I fretnkly don't remember.. I obviously wasn't there. But 2 if there was a Travis Brown interview of Mr. Gallagher.that 3 was covered by; the discovery request, it would have baan 4 produced. I don't think'there was one, a written memorandun.
A 5 MR. JOHNSON: _I wasn't produced.. l 6 MR. HICKEi: Then I am confident that there wa'n't s one, 7 because you wilt recall that we gave you about 3Us interviews a by Mr. Aulick and Mr. Brown. ( 9 Mki. JOHNSON: Yes. That's'right, That's why I am to surprised that there was apparently an interview with 11 Mr. Brown. 12 MR. HICKEY: If 'there 'was an :.nWerviev, it apparently i /
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13 wasn't reduced t1 writing. 14 BY MR. JOHNSON: l 15 Do you have any knowledge of whether the interview 0 l t 16 you had with Mr. Brown was reduced to writing? I 17 A. No, air, I do not have any knowledge. 18 G Have you had occasion recently to review the l 19 statement that you gave to Mr. Stier concerning Quiltec on j l 20 July 26, 1983? ! l 21 A .Yes, sir. I read it as a casual refresher. I l 22 (Document nanded to witness by Councel Richardson.) l 23 0 You made a number of statements in there in 1983 l 9 24 concerning when you first learned about the association of l 25 Slone with Quilt <?c and Mr. King with Quiltec, and so on and so COMMONWEALTH REPORTING COMPANY (717) 761 71 t50
l . 4 l 46 l i 1 j44 I forth. 5
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$2 I can go over each statement that I am interested in l l
3y addressing. Would you prefer me to do that, or are you pre-f li 4 pared to say that the statements there, to the best of your ! 5 knowledge, from page 1 to the middle of page 18, are true and 6 correct to the best of your knowledge and belief? 1 7 MR. RICHARDSON: I've got no problem with that approach, 8 but I think we ought to allow the witness to sit down now and 9 carefully review those pages. 10
- MR. JOHNSON: Okay; that's fine. I just thought we 11 might be able to speed it up.
12
-s MR. RICHARDSON: So beginning on page --
I!
I3 MR. JOHNSON: It really starts on page 4, the last line
" on page 3 and following.
Ib MR. RICHARDSON: Until page --
- MR. JOHNSON: 18, I believe.
. MR. RICHARDSON: The end of page 18?
- MR. JOHNSON: No. Up to the point where Mr. Frech D
starts his examination. 2U THE WITNESS: And your question again was? 21 BY MR. JOHNSON: 22 Q Would you review that, and can you tell me whether f i I "") i that is true and correct, the statements you have made there l l W are true and correct to the best of your knowledge and belief ? l 25 A. Certainly. 1 l COMMONWE ALTH REPORTING COMPANY G 17) 761-7150
47 j45 (.-)
\ /
1 (Witness perusing document.) 2 A. Okay. 3 0 You have reviewed the transcript pages? 4 A. Yes. 5 g Are your statements there true and correct to the 6 best of your knowledge and belief? 7 A. Yes, sir. 8 MR. RICHARDSON: If I may make one prefatory comment. 9 I believe the witness did have some changes and corrections to to the original transcript of that -- I think we're calling 11 it the Stier interview.
,<s 12 MR. JOHNSON: Yes.
!<j
)
13 MR. RICHARDSON: And I don't know whether in fact all 14 of those changes were in fact incorporated in this transcript.
]
15 So I think that ought to be pointed out. 16 I'm sorry, Mr. Gallagher. I think the question was I 17 whether the statements contained beginning on the last line of 18 page 3, up until the point where Mr. Frech began examining )
)
19 you on page 18, are correct to the best of your recollection. I 20 MR. JOHNSON: To the best of his knowledge and belief. l l 21 THE WITNESS: And the answer, I believe, is yes, they l l 22 are. They are essentially correct. l 23 BY MR. JOHNSON: 1 l i 1 I I i 24 g I just would like to ask a few follow-up questions l 20 on those statements. Hopefully, we won't be too much longer. COMMONWE ALTH HEPORTING COMPANY (717)761-7150
48 1 On page 11 you describe a discussion with Dave Buchanan l 2 and perhaps Bill Austin, and it concerns information that you a learned -- not that you learned, but information -- well, it 4 isn't clear from the statement on line 3. In answer to the 5 question, "Did you discuss that information with anybody 6 else?" and you say, "I think at that point in time Dave and 7 myself discussed it. Possibly Bill Austin, but no farther than 8 him." 9 It wasn't clear to me what was the "it" that you were 10 referring to. What was the information that was discussed? 11 MR. HICKEY: Just from the transcript, if you look back 12
,s on page 10 at line 14, it looks like there has been a series
/ \
V 13 of questions: "What was the next information?" "What was the 1 1 I4 next information?" "What was the next information?" And the l 10 last one I see before tne point that you're interested in, 16 Mr. Johnson, is on page 10, line 13: "What was the next bit i II of information you required?" Then he talks about it. I8 It just seems to me that the witness ought to at least I 19 look at that, and then he can say whether that is what he was 20 talking about or not. But just from the text of the transcript , i' 21 that's what it looks like, i 22 l THE WITNESS: I believe that I meant that response to l 23 l go back to the question that was asked, and the information j l :
,,4 l about Mr. Reckart, I believe, is what we were specifically '
1 l l 3 discussing. And my response indicated at that point that 1 COMMONWE ALTH REPORTING COMPANY (717)761-7150
----- __ E
I 49
' j47
'T 1 Mr. Buchanan and I had discussed that amongst each other, but j O
2 I apparently could not recall discussing it with anyone else, 3 I personally. 4 BY MR. JOHNSON: 5 Q Mr. Buchanan is going to be coming in later. I o believe his record, his prior statement or interview was that 7 he had a discussion with Mr. Reckart at the New Years Eve g party, and he tried to confirm whether Mr. King was connected 9 with Quiltec, and the record confirmed that. 10 I was wondering whether that is among the things that 11 you discussed with Mr. Buchanan. 12 MR. HICKEY: What is the reference to Buchanan that you 7_ .
; } !
s
'~j 13 are reading?
14 MR. JOHNSON: On page 34 of the Stier statement, 15 " Buchanan was told that King was involved in Guiltec." 16 MR. RICHARDSON: Could we have that transcript before 17 the witness? 18 MR. JOHMSON: Yes. 19 MR. RICHARDSON: Dated September 7? 20 MR. JOHNSON: Yes. 21 MR. RICHARDSON: Okay; I think I've got a cop.7 of it. 22 (Document handed to witness.) 23 MR. RICHARDSON: Mr. Johnson, if you would indicate 24 which portion you are interested in. 25 MR. J011NSON : It is lines 8, 9 and 10. COMMONWEALTH REPORTING COMPANY (717)761 7150
50 j48 l
'] 1 MR. RICHARDSON: On what page? <j 2 MR. JOHNSON: Page 34. "So I was over at Ted Reckart's i
a house on New Year's Eve for a short period of time and I asked 4 Ted if Larry King was involved in Quiltec, and he told me he 5 was." 6 BY MR. JOHNSON: 7 0 My question to you is: was that a subject of the 8 conversation that you had with Mr. Buchanan after the 1st of 9 the year? 10 A. I don't specifically recall that we discussed Larry 11 King's involvement. I do specifically recall that we discussed 12 Ted Reckart working for Quiltec at Shoreham.
J 13 0 That was the big surprise as far as you're concerned?
14 A. Yes, sir. , 15 MR. RICHARDSON: Mr. Johnson, your question was whether 16 that was a subject which came up during that particular II conversation at that time with Mr. Buchanan? 18 MR. JOHNSON: That's right. IU BY MR. JOHNSON: 20 G Also on page 11 you discuss the fact that Rose ol Rittle, who was your secretary in the summer of 1982, -- you 22 noticed that she had been working before regular hours and : 23 after regular working hours, and you saw a piece of Quiltec l 24 stationery, apparently blank stationery, on her desk, but you 2' say you never law her typing on the stationery, the typed i COMMONWEALTH REPORTING COMPANY (717)761-7150
51 [^3 1 product. And I believe that you say that you asked around 0 2 -- either in this statement here, or it is attributed to you 3 in this Aulick statement that you asked around and you 4 learned that it was Richard Parks who had given Rose Rittle 5 the resumes to be typed, but that you couldn't remember for 6 sure how you had found out. 7 MR. RICHARDSON: Where does it say he asked around? 8 MR. JOHNSON: It's in this statement here. 9 BY MR. JOHNSON: 10 G Do you have that before you, the Aulick -- 4 11 MR. HICKEY: May 23? c3 12 MR. JOHNSON: Yes. It's the fourth sentence in para-i
~
)
13 graph 9. "Gallagher asked around and was told she was doing 14 something for Parks." 15 MR. .3ICKEY: Your question had something about Quiltec 16 resumes in it, so maybe if you would rephrase your question. I 17 MR. JOHNSON: Well, I actually hadn't phrased the M question. I was just trying to paraphrase what was in the W record, i I J 20 MR. RICHARDSON: I'm not sure what your purpose is. 21 MR. JOHNSON: Well, let me ask the question. 22 MR. RICHARDSON: If the witness needs his recollection 23 refreshed, then you're certainly uithin your rights to show l l 24 him this interview memorandum, which I think he's indicated 1 20 he has never seen. ! l 0 1 COMMONWEALTH REPORTINC, COMPANY (717)761-7150 l i
l l 52 l
-j 50 rm, 1 BY MR. JOHNSON:
l k.) l 2 g Why don't you read the whole paragraph 9 there on i 1 3 Page 3 of the Aulick interview notes? l l 4 (Witness perusing document.) 3 A. Okay, i l 6 0 To the best of your recollection, did you form an L 1 7 opinion, based on talking to Rose Rittle and others about the l 8 time that you saw the Quiltec stationery on Rose's desk, that l 1 1 9 Richard Parks was the person who had asked Rose Rittle to do l l l 10 typing of resumes on Quiltec stationery? l 11 MR. RICHARDSON: Excuse me. Did he form an opinion at 12 the time he saw the Quiltec stationery on her desk? i.
)
13 MR. JOHNSON: Well, I wasn't that precise. I said, -- 14 MR. RICHARDSON: I think this is an area where we need 15 some precision. 16 THE WT'PESS: There are too many things lumped into 17 that ques i m. In fact, some of your statements I have to 18 differ with. So if you want to work them through one at a 19 time -- 20 BY MR. JOHNSON: 21 O I made a number of statements. Which ones would 22 you disagree with? 23 MR. RICHARDSON: let's have the statements read back 24 or take them one at a time. 25 Okay. MR. JOHNSON: COMMONWEALTH REPORTING COMPANY (717)761-7150 E_________._____
i 53 j51 _3 i BY MR. JOHNSON:
,x.)
2 G Did you in fact ask around to try to find out ; 3 who was responsible for giving Rose some work that she did 4 after hours? 5 A. I believe what I said was that I saw her coming 6 in early before hours. And, yes, I did ask around to see 7 why she was coming in early. i s G And what did you learn? 9 A. I believe what I have stated was that I gaiaed the 10 knowledge that Rick Parks was having her do some extra work. 11 G Did you know what that extra work was? Did you
.s 12 learn from the knowledge that you had received at that time / )
13 what that work was? 14 A. My memory is all I learned was that she was doing 15 some typing for Rick Parks, and it was unspecified as to 16 what it was -- 17 That's what you were told. G 18 A. -- what it was she was typing. 19 But you also saw the olank Quiltec stationery on G 20 her desk? 21 A. Yes, I saw it. 22 Did you put those two pieces of information G 23 together? 24 A. Yes, in inverse order, if you wou'd, but yes, that's 25 essentially what I did. I saw the stationery first, and I COMMONWEALTH REPORTING COMPANY (717)761-7150 j
54 4 1 j52 s 1 asked around and said, " Gee, why is Rose coming in early" and J L) 2 the response I got was, "She's doing some extra work for a Rick Parks." 1 ( 4 Q Did you ever mention to anyone -- let me put it 5 this way: when was the first time you mentioned to anyone ; r> that you had reason to believe that Parks had given Rittle 7 some typing to do? (g 8 A. The question was: when was the first time? 9 G Yes, I t i 10 A. I don't recall the specific date. 11 g Approximately? 12
._ A. My recollection would be that it would have been in s --
13 the fall of 1982, in all probability. I 14
- c. That would have been the first time you mentioned 15 '
this to somebody? 16 A. Yes. I II G Who did you mention it to?
)
18 A. That would have probably been the discussion with l l9 Dave Buchanan. ! 20 0 What did you tell him? l l 21 A. I told him essentially the same story we've just 22 gone through here, about the observations I made of Rose and l 23 a piece of Quiltec stationery, and possibly linking that to 1 24 Rick Parks. 2I' O And you cannot fix a more specific time than you i l l COMMONWEALTH REPORTING COMPANY (717)761-7150 j - l
4 1 i 55 4 4 j53 l I just gave me? 2 A. No, sir, i I MR. RICHARDSON: We've gone for quite a while without 3 f 4 a break. We've got a 2:00 appointment with Mr. Buchanan. i 5 MR. JOHNSON: I will try to finish up by 1:00. l 6 Off the record. 7 (Discussion off the record.) i 1 8 9 10 11 12
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15 l 16 17 18 19 l 20 l l 21 1
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l 22 l l 93 1 24 25 l l COMMONWEALTH REPORTING COMPANY (717)761-7150
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~s80 LT-3.. 56 Gallagher .
1
.c MR., JOHNSON: - Back on the record, b)
- 1 E BY MR' JOIIN' SON :
.2 G Mr.-Gallagher, with respect to the interview-
- L 3- with,Mr.-Aulick on May 23, 1983, could you~look at that 4 statement on the first page and the first paragraph,-please? j 5 A; -Number one on the first page?f 6 G Yes,.please. There is"a-statement. ItLsays,
. 7 "Gallagher confirms that Thiesing spoke with him in 8- -February 1983'and confirms that.he told Thiesing and Slone 9 told Gallagher last summer that Larry King was. president of 10 Quiltec."
l 11 Is that a true statement? 12 gg MR. RICHARDSON: 'There are several elements:to that' (_) 13 s tatement. - I4 MR. JOHNSON: If you'd like me to' break it up, I will 15 break it up. 16 THE WITNESS: Will you break it up? 17 BY MR. JOHNSON: 18
.O 'You did speak to Mr. Thiesing in February 1983?
3 A Yes. j 20 g Did you tell Mr. Thiesing -- did Ben Slone tell 21 you in the summer of 1982 that Larry King was president of 22 Quiltec? 23 A. I do not believe he did. I do not believe that , 24 Ben told me that Larry was president of Quiltec in the summer 20 of '82. COMMONWEALTH REPORTING COMPANY (717)761 7150 I
s01 57 7s (; 1 G Did you tell Mr. Thiesing that, though? 2 A. To-the best of my recollection, what I told 3 Mr. Thiesing was that in the summer of 1982, Ben Slone had 4 told me that Larry King was involved with Quiltec, but I do 5 not think he defined Mr. King as president. O G And that's what you told Mr. Thiesing? That's _ 7 what you just said.
?
8 A. Yes. I told Mr. Thiesing that King was involved. 9 I do not believe I told him that King was president. 10 0 Did you elaborate as to the type of involvement 11 that you believed he had? 12 I may have speculated, but I did not know what the
,-,)
t A. V 13 involvement was. I4 But the source of the information that you had G 15 about King was Slone? i 1 16 A. Yes. 17 G In the notes of Mr. Aulich of May 23, you state ; 18 in paragraph 9, page 3 -- Mr. Aulich attributes to you the 19 "Gallagher did not accost Rose, as it was not statement: 20 on company time." 2l " Accost" seems like an interesting word. Is that the 22 word that you would use to describe what you told him? l 23 A. I would differ a little bit with that description.
"4 G Would you please describe what your best recollec-2r' tion of that would be?
COMMONWE ALTH RE PORTING COMPAN Y (717)761-7150 l _ _ _ _ _ _ _ _ _ _ . _ _ _ I
s82 58 MR. RICHARDSON: Are you referring to the event back in
}) 1 2 1982?
3 BY MR. JOHNSON: 4 G The event with Rose Rittle. 5
,1 I believe what my actions were at that time was G I observed Ms. Rittle coming ir earlier than normal. I had
. 7 observed a piece of Quiltec stationery on her desk, and I 8
s had some rumors, office rumors, if you will, that perhaps 9 she was doing some extra work for Mr. Parks. 10 I, therefore, tried to monitor Ms. Rittle for the 11 next few days, perhaps a week or two. I did not notice 12 anything that I could detect was an abnormality, none of 7-s, 6 / L./ 13 the symptoms that I had seen previously, and therefore 14 dismissed it. In I did not discuss it with her because I did not have 16 any factual basis to do so. 17 Given that you put the fact that she had the G 18 stationery together with the comments that you had heard that 19 Parks had had Rose doing some typing for him, did you feel 20 that if it were true at the time that you learned that, did 21 you feel that what Rose Rittle was doing was improper, assuming 22 it was true? 23 MR. . RICHARDSON: Did he form that opinion at the time? 24 MR. JOIINSON: Yes. 25 MR. HICKEY: There is one ambiguity that may be important l COM MONWE ALTH REPORTING COM PANY (717)761-7150
s82 58 i [) MR. RICHARDSON:
~
1 Are you referring to the event back in w/ l 2 1982? 3 BY MR. JOHNSON: 4 G The event with Rose Rittle. 5 A. I believe what my actions were at that time was ! 6 I observed Ms. Rittle coming in earlier than normal. I had [ _ 7 observed a piece of Quiltec stationery on her desk, and I
?
2 8 had some rumors, office rumors, if you will, that perhaps 9 she was doing some extra work for Mr. Parks. ! 10 I, therefore, tried to monitor Ms. Rittle for the l 11 next few days, perhaps a week or two. I did not notice l 1
- 12 anything that I could detect was an abnormality, none of v
13 the symptoms that I had seen previously, and therefore 14 dismissed it. 15 I did not discuss it with her because I did not have 16 any factual basis to do so. I 17 Given that you put the fact that she had the G l l 18 stationery together with the comments that you had heard that 19 Parks had had Rose doing some typing for him, did you feel l 20 that if it were true at the time that you learned that, did i l 21 you feel that what Rose Rittle was doing was improper, assuming 22 it was true? 23 MR. RICHARDSON: Did he form that opinion at the time? l 0 24 1 MR. JOHNSON: Yes. 25 MR. HICKEY: There is one ambiguity that may be important COMMONWEALTH REPORTING COMPANY (7171761-7150 _-_-..--_a
s83 59 ( ) 1 in the question, if I may suggest it. 2 MR. JOHNSON: Sure. 3 MR. HICKEY: Are you talking about her typing for ! 4 Mr. Parks outside of normal business hours or are you talking i 5 about the substance of what she was typing being improper? 6 MR. JOHNSON: That's good to be clear on that.
- 7 BY MR. JOHNSON:
!O 8 G Did you think there was anything improper in 9 Rose Rittle doing typing for Rick Parks of resumes of Quiltec?
10 MR. RICHARDSON: That is a different question now. 11 First you were asking him whether there was something improper I2 being done by Rose Rittle. (~-]' Lj I3 MR. JOHNSON: I'm sorry. Maybe I misstated it. I I4 really want to focus on Rose Rittle. 15 MR. RICHARDSON: There may be a big difference between N Mr. Parks and Ms. Rittle. II MR. HICKEY: You're talking about her typing? 4
# BY MR. JOHNSON: I 19 0 I want to know whether you thought she had done 20 anything wrong in typing Quiltec resumes after hours.
21 MR. HICKEY: Or typing anything. 22 First of all, I hadn't determined that THE WITNESS: 23 she had done anything yet. l 24 BY MR. JOHNSON: i 1 O My original question tried to suppose that you l ' COM MONWE ALTH REPORTING COM PAN Y (717)761-7150 L_
l s84 L 60 [) I had reached that conclusion. 2 A. Okay. 3 G Assuming that you had reached the conclusion that 4 she had done it, did you believe then that that was improper? 5 MR. RICHARDSON: Well -- 6 MR. JOHNSOM: I'm sorry if there is still ambiguity.
- 7 I'm trying to define it as Rose Rittle typing.
!O 8 MR. RICHARDSON: But if you ask for a contemporaneous 9 opinion whichis predicated on an assumption which he hasn't 10 affirmed, how can he have the opinion?
11 MR. JOHNSON. He did confirm that he drew a conclusion, IS
/~T but he had no facts.
(./ I3 MR. RICHARDSON: Then as I understand your question, 14 the question is: after he drew the inference that Ms. nittle 15 was typing Quiltec resumes after hours or before the workday 16 began, did he then form the opinion that Ms. Rittle was doing II something improper. I8 That is the question. MR. JOHNSON: I9 THE WITNESS: Could I ask you to please read that back? 20 I am confused now. Bear with me. 2I MR. JOHNSON: I think I can repeat it. 22 BY MR. JOHNSON: o.; O Assuming that you did reach the conclusion that l 94
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drew the information, the two pieces of information together -- that is that you knew that Parks had asked Rose Rittle to do i l COMM ONWE ALTH RE PORTING COMPANY (717)761-7150 I
]
l le85 61
) 1 some typing and that you saw Rose Rittle typing--coming in .
i 2 before hours and you saw the stationery and you linked all ) 3 of these together into a conclusion that she, in fact, was 4 typing Quiltec resumes for Parks before hours -- assuming 5 you reached that conclusion, did you -- i 6 MR. RICHARDSON: Excuse me. When you start with
- 7 " assuming" --
8 MR. JOHNSON: Not assuming. 9 BY MR. JOHNSON: 10 0 Did you consider that possibility? Did you believe 11 at that time that that was the case? 19 ('}
~ ~
A. We're going to have to try a different approach 13 on this one. 14 MR. RICHARDSON: 1 think what he's asking you: from 15 what you heard and what you saw, did you infer that Rose Rittle was possibly typing Quiltec resumes during non-working 17 hours? THE WITNESS: Take that as one element. I think we're 19 getting hung up a little bit on the word " resume." I usn't "O
~
think that I've said as a fact that I knew she was typing 21 resumes. 22 I heard that she was doing typing for Rick Parks, 93
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unspecified. I do not know what that was. Now, I did not observe her doing any typing. os
~'
Now, if I had had a little more factual information, COMMONWEALTH REPORTING COMPANY (717)761 7150
l s86 I 62 [jss 1 if I had seen her do something, something more other than an 2 office rumor innuendo, my action would have been, I would 3 have counselled her, because I do not think it would have 4 been proper to have been using -- it is my own personal 5 opinion -- I do not think it would be proper to be doing 6 outside-the-workplace work potentially for another firm in _ 7 the workplace. But I never saw evidence of that. I never
!O s took that action, because I could never reach that logical 9 conclusion.
10 BY MR. JOHNSON: 11 G But having formed that -- I'm sorry. Let me try 12 it another way. 7 x You never took any further action on this i ty
) '
13 ' with Rose Rittle? 14 A That's correct. I watched her. I monitored her 15 for some period of time. I never saw any further indication 16 that there was anything except normal work practices, and I 17 lleftthematterdrop. )! 18 G Did you -- perhaps I asked this question already. 19 I cannot recollect now. The first time that you mentioned 2" what you knew about Parks' involvement with this was when 21 you mentioned it to Buchanan? 22 A With the typing? 23 G Yes. 24 A. Yes, I would believe that was the first person 25 I discussed it with. COMMON WE ALTH RE PORTING COMPANY (717)761 7150
sB7 63 y .-) 1 MR. JOHNSON: Do you have anything?
~/
2 MS. WOODHEAD: Yes. 3 BY MS. WOODHEAD: i 4 0 Would you consider it improper for a secretary 5 to do any sort of typing that was personal or any other sort 6 of typing that was not company business, personal typing
- 7 for employees that was done outside of working hours?
O 8 MR. RICHARDSON: I think when eliciting an opinion 9 with regard to a hypothetical question, you have to be more 10 specific with the hypothetical. There are any number of 11 different types of personal business. 12 BY MS. WOODHEAD:
- T, Y
I3 0 Any typing that was not company business outside 14 of working hours. 15 MR. HICKEY: What was that? Did you say "outside"? M MS. WOODHEAD: Yes. II MR. RICHARDSON: Do you include in that typing which
- could be for the benefit of another company, which could be I9 competing with the employer?
20 Any typing. MS. WOODHEAD: 21 THE WITNESS: Could you repeat your question again? 22 BY MS. WOODHEAD: 23 G Do you consider it improper for a GPU/Bechtel
')4 secretary to do any typing that is not company business out-20 side of working hours?
l COMMONWEALTH REPORTING COMPANY (717)761-7150
l s88 l 64 j i'
/^T
(,,) 1 MR. RICHARDSON: Objection. The question is hopelessly l 2 vague. I don't see how the witness can get a handle on it. 3 THE WITNESS: I think I understood your question. 4 Your question, I believe, was: do I think it's improper 5 for a secretary of one company to do typing off hours outside 6 the workplace for another company.
- 7 MS, WOODHEAD: No, no.
8 THE WITNESS: I misinterpreted your question. 9 BY MS. WOODHEAD: 10 Would you consider it improper for Rose Rittle G 11 to do any sort of typing at the TMI site outside of working
~12
(~)
/
hours if it was not bona fide GPU business or Bechtel business, I3 in other words, some sort of personal typing? It could be l4 personal letters of yours or Rick Parks or have absolutely Ib nothing to do with the business. 16 It could be college applications. It could be personal f II business typed by a company secretary outside of working 18 hours. 19 A. In the workplace?
"O
~
0 At the workplace, right.
"1 MR. RICHARDSON: Given the examples that you just gave, 2
as I understand the question, it is: would you consider it O'] to be improper to do typing during non-working hours which is "4
^
not for the employer, the company, and which would not have or
~',
an adverse effect on the employer or any of the employer's l l COMMONWEALTH REPORTING COMPANY (717)761-7150
s89 65 clients,
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- v. e y
2 BY MS WOODHEAD: 3 0 I'll let you answer my question or Mr. Richardson's 4 question be cause they are two dif ferent questions. 5 MR. RICHARDSON: That's the implication. If she's 6 typing a college application for her son or daughter -- _ 7 the point is, when you say non-company business, depending g on how you define it, that can include a host of things which 9 can be adverse to the employer. 10 THE WITNESS: I think in an attempt to answer all of 11 this, there are several levels at which I can respond. The
.-- 12 first is I think doing work after hours either for pay or
/ ,;
13 not for pay which is a conflict of interest is improper, and 14 I think most companies or many companies now have conflict 15 of interest statements which they forrnalized in the last 16 few years to give that guidance. 17 I think typing that you're doing for someone else -- 18 and let's not get into the issue of pay or not for pay -- 19 is somewhat of a grey area. I don't think it's very prudent. 20 I would counsel against that. That "You should not do that. 21 is not very prudent." 22 I think typing for your own personal use on a company 23 machine after hours is perfectly acceptable as long as you 24 have permission from someone to do that. 25 So I think there is a graded answer, at least in my COMMONWE ALTH REPORTING COMPANY (717)761 7150 E_ _ ___ _ _
s90 66 i n
) 1 own feeling, as you look at the different -- I'm sure there 2 are even more classifications.
3 BY MS. WOODHEAD: 4 Q So, as I understand it, on a general basis, typing r, that is not company business would have different levels of } 6 disapproval from you depending on the subject matter; okay. !
- 7 Thank you.
8 BY MR. JOHNSON: 9 Q One last thing. In the report of your statement l 10 to Mr. Aulick, there were counts -- ! 11 MR. HICKEY: Mr. Buchanan just walked in, if that 1 I2 I just wanted you to know he was here in
,/~] matters to you.
v I3 ' case you were going to ask a question that related to him. 14 MR. JOHNSON: Well, actually I would prefer that he II' not hear the question, if that's okay with you.
- BY MR. JOHNSON:
O Paragraph 3 on the first page, slone apparently
- asked you if you ever were interested in leaving, to let him I"
know, and you, it sounds like, respectfully declined. 00
~
Is that accurate, what is recounted there? og (Document shown to witness.)
- 0. >
~~
A. Yes. That is a fairly accurate statement of our 5 03
~'
conversation, yes, j 8 04
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O You never submitted a resume to Quiltec? ! 1 A. No, sir, i COMMONWEALTH REPORTING COMPANY (717)761-7150 j
-_-- b
1 s91 67 t 1 0 And what I said was accurate? 2 A. Yes. 3 MR. JOllNSON: Thank you very much. 4 (Witness excused.) 5 (Whereupon, at 1:10 p.m., the deposition was G concluded.)
- 7
?
O 8 9 10 11 l'") O 13 l 14 15 16 1*/ 18 l { 19 20 21 22 23 24 2e COM MONWE ALTH RE PORTING COM PANY (717)761-7150
l 1 l 68
- j54 ! ') 1 CERTIFICATE OF DEPONENT 2 I, Richard Edwin Gallagher, have read this transcript 3 of my deposition taken on Wednesday, January 14, 1987, and w.th 4 the exception of the corrections noted, if any, find it to be 5 a true and accurate record of my testimony. 3 6
7 8 Date Richard Edwin Gallagher 9 10 11 12
/ ja I4 Signed, this day of , 19 t
?
15 16 II Notary Public 18 Municipality: I9 My commission expires: 20 21 22 , 23 24 25 COMMONWEALTH REPORTING COMPANY (717)761 7150 l
69 es j55 lv ) 1 CERTIFICATE OF NOTARY REPORTER 2 I hereby certify, as the Notary Reporter, that 3 the foregoing proceedings were taken stenographically by me, 4 and thereafter reduced to typewriting by me or under my 5 direction; that this transcript is a true and accurate 6 record to the best of my ability; that the witness whose 7 testimo.:y appears in the foregoing pages was duly sworn by 8 lue ; that I am neither counsel for, related to, nor employed 9 by any of the parties to the action in which this deposition 1 10 was taken; and further, that I am not a relative or employee 11 of any attorney or counsel employed by the parties hereto, I2 l fm, nor financially or otherwise interested in the outcome of C/ i3 l the action.
" COMMONWEALTH REPORTINC COMPANY, INC.
15 m - p --g
'" By: ( YlNi a . ( .
/7'!,JN yl fin
Judith A. Toberman Notary Public in and for the 18 Commonwealth of Pennsylvania Cumberland County, Pennsylvania My commission expires on: April 27, 1987 21 22 23 24 25 l COMMONWE ALTH REPORTING COMPANY 8717)761-7150
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March 2, 1987 Ms. Judith Toberman commonwealth Reporting Company, Inc. l 700 Lisburn Road Camp Hill, Pennsylvania 17011 Re: In the Matter of: GPU Nuclear Corporation (Three Mile Island Nuclear Station, Unit No. 2) Deposition of Richard Edwin Gallagher S~4 - 3'.74 %
Dear Ms. Toberman:
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j ! s") Please make the following changes and/or corrections to the transcript of Richard Gallagher, whose deposition testin.ony was taken on January 14, 1987: Page Line(s) Changes / Corrections j 5 15 "a Dechtel" should read "a direct Dechtel" 6 12 delete "Trying to -- well," 10 21 delete " group" 33 14 delete "Yes." , 39 5 delete "No." 58 12 change "was" to "as" s-
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i i" Ms. Judith Tobermari < U, J- ' / '
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L s f(, 58 13 ( , N'cherefore dismissed" shoul$ seaci ( k '*therefore I dismissed" l 66 1 ' j' insert " cases" ~ a Eter \ lif ferent. " \ i t very'c;rly yours, , i [I ' i THELdH. MARRIN, JOHIISON & BIlfDCIS (,
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Jenn v fer K r/. ster < JK:ws / cc: VUeorge E. Johnson, Esq. J. Pat ric'.i Hickey, Esq. I Richard E. Gallagher { l
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'UNnED STATES O
NUCL' EAR, REGULATORY COMMISSION
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IN THE MATTER OF: DOCKET NO: 50-320
? e' DPR-73 GPU NUCLEAR, INC' .
ASLBP No. EA84-Three Mile Island Sta'. ion, 137 __ ! Unit 2 I (CIVIL PENALTC D:?POcITION OF JOSEPH J. CHWASTYK O l LOCATION: WASHIW! TON, D. C. PAGES: 1 - 145 k DATE: MONDAY, DECEMBER 1, 1986 e ACE-FEDERAL REPORTERS, INC. O Official Reporters l 444 North Capitol Street m ; , , o p Washington, D.C. 20001 cAg $ ) ( CO2) 347-3700
* ^ ' ' ""' "'"^ '
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L 3 i - J l CR29049.0-TAYLOE/dnw 1 UNITED STATES AMERICA 2 NUCLEAR REGULATORY CCMMISSION ,
.3 BEFORE THE ADMINISTRATIVE LAW JUDGE 4 : # A.
l O _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x
.5, ,
v . 9., f }l;' In the Matter of: .: l 3 ' GPU NUCLEAR, INC. : Docket No. 50-320 7 8 Three Mile Island Station, : DPR-7.3 Unit 2 : I 9
- ASLBP No. EA84-137 s- ,- - - - - - - - - - - - -x (CIVIL PENALTY) 10
-11 DEPOSITION OF JOSEPH J. CHWASTYK s
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12 Washington,:D. C. 1 [- .
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l [ 13 Monday, December 1, 1986 f l
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14, 3 Deposition of JOSEPH J. CHWASTYK, called for examination, i- h. o b, pursuant to notice, at the law offices of Shaw, Pittman,-Potts ' .q t i6 & Trowbridge, 2300 N Street, N.W., at 10:00 a.m. before FPANK I lV l 17 i l U*f < 'TAYLOE, a Notary Public within and for the Commonwealth of I ,9s 18 l Virginia (by stipulation of counsel), when were present on \ 3i '\ s-19 Tc behalf of the respective parties: s, 1 GEORGE JOHNSON, ESO.
"i 20
,J COLLEEN P. WOODHEAD, ESQ.
21 ,U.S. Nuclear Regulatory Commission Office of the Executive Legal Director 22 Washington, D. C. 20555 On behalf-of Nuclear Regulatory Commission. p 'p . 23 j.1 J. PATRICK HICKEY, ESO. V 24 Shaw, Pittman, Potts & Trowbridge I. 23'JO N Street, N.W. kg 25 Washington, D. C. 20037 On behalf of GPU Nuclear, Inc.
- q -- continued --
A ACE-FEDERAL REPORTERS, INC. UL_- = ~ = " --* c- 8-"-
2 1 APPEARANCES: (CONTINUED) O 2 KENNEDY P. RICHARDSON, ESQ. 3 Thelen, Marrin, Johnson & Bridges One Kaiser Plaza 4 Suite 1950 Oakland, California 94612 5 On behalf Bechtel North American Power Corporation. MICHAEL F. McBRIDE , ESQ. HARRY H. VOIGT, ESQ. 8 LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W. 9 Washington, D. C. 20036 On behalf of the Former Metropolitan 10 Edison Employees. 11 12
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0 13 - 14 15 16 17 18 19 20 21 22 23 24 O 25 l l ACE-FEDERAL REPORTERS, INC. ; Nationwide Coverage 800 336-+;M6 i w_-____----_-_--_-__ ___ -.-___ _202 347 3700
3 1 _C _O N_ _T E_ _N T _S 2 WITNESS EXAMINATION 3 Joseph J. Chwastyk by Mr. Johnson 4 ElElEllE CHWASTYK EXHIBITS IDENTIFIED 7 Exhibit 1 17 8 { Exhibit 2 10 9 Exhibits 3 and 4 36 , 10 l Exhibit 5 39 , 11 l Exhibit 6 40 l 12 Exhibit 7 46 13 Exhibit 8 48 14 Exhibit 9 51 < 15 i i Exhibit 10 53 - 16 Exhibit 11 66 Exhibits 12 thru 14 68 18 Exhibit 15 69 19 Exhibit 16 77 20 21 Exhibit 17 128 22 Exhibit 18 142 23 24 l 25 e ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Covemge 800 33MM6 ( _ - _ _ _ _ _ _ _ _ _ _
29049'.0' 4 LTayloe l' P R O C E E D_ I_ N G_ S_ 2 Whereupon, 3 JOSEPH J. CHWASTYK
-4' was called.as'a witness and, having'been first duly sworn, y 5 was examined and testified as follows:
6 EXAMINATION i 7 BY MR. JOHNSON: 8 Q. ' Good morning, Mr. Chwastyk. My name is George 9 Johnson. I'm a lawyer, counsel for the NRC staff, and in 10 an enforcement proceeding which has been brought by the 11 Commission against GPU Nuclear Corporation concerning 12 violations of Section 50.7 of the code of -- 10 CFR, Code 13 of Federal Regulations, which deals with discrimination 14 against employees for engaging in protective activities, i 15 which are defined by the Energy Reorganization Act and-the j 16 regulations, and you have been requested to come here to be. l 17 deposed concerning the facts dealing with whether I 18 Mr. Richard Parks was discriminated against for raising 5 19 safety concerns to management at Three Mile Island Unit 2 20 during the period of February and March, 1983, and for
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21 raising those concerns to the NRC and to the Department of
] . 22 Labor during that time.
23 Mr. Chwastyk, when did you first -- 24 MR. MC BRIDE: Before we go ahead, why don't we 25 identify for the record who else is present today. My name J n v ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 6646
29049.0 5 Tayloe (^)
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1 is Michael F. McBride, with the law firm of LeBoeuf, Lamb, 2 Leiby & MacRae. The address has been provided the reporter. 3 With me today is Mr. Harry H. Voight, my partner
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4 in the same firm. We appear as counsel for the witness, 5 Mr. Chwastyk. 6 MR. HICKEY: I'm Patrick Hickey, Shaw, Pittman,
, 7 Potts & Trowbridge, counsel for GPUN.
8 MR. RICHARDSON: Kennedy P. Richardson, with the 9 firm of Thelen, Merrin, Johnson & Bridges in Oakland, 10 California, and I'm here today representing Bechtel North 11 American Power Corporation. 12 MS. WOODHEAD: My name is Colleen Woodhead -- 13 MR. RICHARDSON: Excuse me, and GPU Nuclear (~)l 14 Corporation. 15 MS. WOODHEAD: I'm Colleen Woodhead, from the 16 Office of General Counsel, NRC. 17 BY MR. JOHNSON: 18 0 Mr. Chwastyk, when did you first come to work at 19 Three Mile Island? 20 A It was 1968, I believe it was. I would have to 21 look at records to be absolutely certain, but it was in 22 that time frame. 23 O And you were working for Metropolitan Edison 24 Company at that time? 25 A Yes, I came to work initially at Metropolitan ACE-FEDERAL REPORTERF, INC. CM-3WO Nanonwide Coserage 6(6 336 W e
29049.0 6-Tayloe 1 Edison. 2 0' And.you continued to work for Metropolitan 3 Edison Company and then General Public Utilities-Nuclear 4 until'when?
,5 A .Sometime in 1983.- I'm not.sure exactly.
-6 0 When did you become manager of plant operations 7 at Three Mile Island Unit 2?
8 A Specifically I can't say definitely. After the 9 accident in 1979 I was promoted to supervisor-operations 10 and that position eventually became manager of operations. 11 I'm not sure exactly when that was, although I was at that 12 time. I'm no longer aware of this' time frame. 13 0 This is a document that'is dated September 1, {]) 14 1982. The subject is TMI 2 reorganization implementation 15 announcement, 400-82-K-296, it looks like. It contains a 16 reorganization and some organizational charts and I would 17 just like you to confirm your placement on this chart for
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18 the record. Page 5 of 13, attachment 1 to that document, 19 dated August 31, 1982, indicates J.J. Chwastyk as manager 20 of plant operations for the GPU TMI 2 division. 21 MR. HICKEY: Are we going to mark one of these
- 22 as an exhibit, Mr. Johnson?
23 I guess, I think we should if we are going to 24 ask the witness about it. 25 MR. JOHNSON: Okay. Sure. ACE-FEDERAL REPORTERS, INC. 002 347 3700 Nationwide Coserage 80lk336-St6
29049.0 7 Tayloe ( N- 1 MR. HICKEY: Can I see that, please? 2 THE WITNESS: Sure. 3 I don't recognize the document, but I recognize
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4 my name and the position. 5 BY MR. JOHNSON: 6 0 So on or about September 1, 1982, you were 7 manager of plant operations? 8 A If that question means is that when I became 9 manager of operations, I can't answer that. I would have 10 to look in the personnel records. But, you know, it 11 indicates at that time I was definitely the manager of 12 operations. (} 13 0 Okay. I've identified the document. 14 MR. JOHNSON: Why don't we mark it for purposes 15 of identification as Staff Exhibit 1. 16 MR. MC BRIDE: May I suggest that it might be 17 l better down the line if you were to identify these 18 documents as Chwastyk Deposition Exhibit Number 1. 19 Otherwise, if you get into the hearing, you are going to l 20 have some confusion between at least two documents that are f 21 going to be known as Staff Exhibit Number 1. 22 MR. JOHNSON: Okay. Why don't we mark it, then, 23 Chwastyk Deposition Exhibit Number 1 for identification. 24 (Chwastyk Deposition Exhibit 1 identified.) t 25 I, MR. HICKEY: Off the record. (1) l l ACE-FEDERAL REPORTERS, INC. , n x.w.n- sa-- -
r 29049.0. 8
- Tayloe .
1 .(Discussion off the record.) 2 ^BY MR. JOHNSON: 3' O There came a. time, didn't there, when you 4 replaced, at least in'an acting capacity, Larry King, as 5 site operations director, I believe it was on or about 6 February 24th or February.25th, 19837 7 A Yes. 8 0 And how long did you serve as acting site 9 operatlons director, if you can' remember that, please? 10 A- 'I think it was.in the order of a month or two, 11 but I'm not absolutely certain. Again, understand this. 12 happened to.me -- I'm not trying to be uncooperative. 13 Again, the details are somewhat a little cloudy in my mind. {g 14 0 During that time did you continue to serve as 15 manager of plant operations as well?
'16 A Yes, I did.
17 0 When you ceased being acting site operations 18 director, you went back to being manager of plant 19- operations? 20 A Yes. 21 0 And can you give a date for that?
. 22 A No, I can't, not without, again, looking at some 23 records of some kind. Not strictly from memory, I can't.
24 0 Was there a time when a man named John Barton 25 took over the position as site operations director when you ACE-FEDERAL REPORTERS, INC. 2C3474M Nationside Coverage 8@ 336646
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29049.0 ; 9 , tayloe j ;] l IJ 1 ceased. acting for Mr. King? l 7- ; i (_ s 3 Yes, there was. I-2 y A i i 3 O You just don't recall. -
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4 k Was that in the late spring, spring sometime of [ O 5 !! 1983? li g 6 i A Spring sometime of 1983 would be somewhat near 7 l accurate. I'm not exactly sure. I 8 O Did you hold any other positions at TMI 2 after l 9 that time other than manager of plant operations? 10 h A I don't believe so. Not that I can recall, I 11 l anyway. i 12 ! O I have a document here. It's a memorandum from O 13 l Anthony N. Fasano, chief, TMI 2 project section, with the
) 14 NRC at the time, for Lake H. Barrett, deputy program 15 l director, TMI program office, dated July 28, 1983, and the l
I 16 subject is phone call to Joe Chwastyk, and it is very brief. 17 It says "I spoke to Joe at 7:45 a.m., July 28, 1983. This 18 was a friendly call, to ask him about his status and to ask l i 1 i 19 , him if he had any safety concerns at this time. He said he l 20 had resigned and is currently preparing his resume. He li 21 i indicated that he had no safety concerns." 22 i I'll show you the document. We will mark that. i
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i 23 ' I don't expect that you have seen that before. 24 j Would it be true, then, that by July 28, 1983, i i 25 you had resigned from your position as plant operations O
; ACE-FEDERAL REPORTERS, INC. !
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i l 29049.0 : 10 Tayloe i i ! c 1 i manager at TMI 2? f} (e ! 2 l A Based on that memo there. I just don't recall 3 l the exact time, or date. I 4 ; O Was that -- you had resigned from the staff of
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i 5 l GPU Nuclear Corporation? 6 A Yes. That's correct. 7 ! MR. JOHNSON: I'm going to mark this as Chwastyk 8 Deposition Exhibit 2 for identification. 9 [ (Chwastyk Deposition Exhibit 2 identified.) 10 BY MR. JOHNSON: 11 0 Could you please tell me what were the 12 , circumstances of your resignation? t 13 l A The circumstances were primarily I was tired of ( 14 Three Mile Island. I was like living in a glass house and 15 llpeoplewere throwing stones at you all the time and it had L 16 been like that since the accident. 17 0 Were you asked to submit your resignation? 18 :1 A No, I was not. ll 19 O So your leaving was completely voluntary? 20 l A Yes, it was. l* i 21 l May I ask you why you asked that question? l' i 22 j Again, this is part of the record as far as I know.
. s 23 ] Q Well, as far as I know I have no information on
- 24 the circumstances of your leaving, and I was curious to ask i :
25 ' you the following question, if I may? 1 (1) i !! j ACE-FEDERAL REPORTERS, INC.
; 2C t47-3700 Nananw Kie Cmerage 8%33M4 l
s' 0 E-l 29049.0 j 11' sTayloe '! 1 AL All right. O 2 , 0 .W as your departure in any way related to
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3 management.-- GPU management's views with. respect to your 4 p connections with Quiltec? 5- I assume you understand the name.Quiltec? 6 A Yes, I do. . I 7 0. Let me repeat the question. Was your' departure 8 in any way related to management's views with respect to 9 your' connection to Ouiltec? 10 A' I don't'know how to-answer-that except to say 11 that it was a-matter of my just being fed up with the.whole 12 Three Mile Island scenario, and I guess you could say 13 Quiltec was part of that. I () 14 0 Could you explain what you mean by "was part of 15 ) that"? 16 ; A That was one of the problems of living in a . I 17 glass house-type atmosphere and everything I did was viewed 18 by not only the company but by everyone else, including the 19_ f media, et cetera. i It was a very high pressure job and it 20 (justbecamenolongerworthwhiletometocontinue it. I 21 l 0 But based on your earlier answer, that your. l 22 ! resignation was completely voluntary, no one connected with !
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!I 23 l GPU Nuclear or lawyers for them made any statements to you 24 l in connection with your connection with Ouiltec that you 25 <
should leave? () l iI i I l a ACE-FEDERAL REPORTERS, INC. l 1 m.m .1,e _ e. ce .,.,. so>,e.e~e !
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.29049.0 .I' 12 LTayloe l
1- ; A No . '
! I 2 l 0 .Did you ever come to work again for GPU Nuclear l
3 1 either at Three Mile Island-Unit 2 or-elsewhere? 4 A No, I have not'. 5 0 Where have you been employed -- let me just back l 6 I.up'a.second. -1 ll 7 l When you left GPU Nuclear in approximately July, 8 1983, did you go directly to another position? I 9 l A No, I did not. I went to real estate school and i 10 got-my real estate. license and joined Coldwell. Banker in, I 11 'thi'nk, January of 1984. I believe that is.right. 12 Somewhere in that time frame. 13 O Du ri ng '.. th a t time, from July 1983 until January O. 14 1984 -- Jenuery 1984 wee the dete you went to worx er 15 Coldwell Banker? I 16 l A Coldwell Banker Real Estate. l 17 l 0- During the perfod of approximately that six 18 l months, were you employed at any time? l 19 l A No, sir. 20 0 How long did you work for Coldwell Banker?- 21 . A I left them -- I believe it was early September i 22 i of last year or this-year. Wait a minute.
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23 , No, this year. This year.
'24 , 0 1986?
t ! 25 g A It was either late October or early September i o i 3 ! O 1 ! l 1 .
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1 ACE-FEDERAL REPORTERS, INC. M Nationwide Courage E63M-446 . _ _ _ - - _ - _ _ _ _ _ . _ - _ _ . _ . _ -- __ _ . -_-347 '3700_ _ _ _ _ _ _ _ - _ _ _ - . _ - _ - _ _ - _ _ _ - _ _ _ _ _ _ - - _ _ . _ _ _
1 !j 29049.0 $. 13 l Tayloe ] I I, 1 this year. ID
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2 MR. MC BRIDE: Do you mean late August or early 4 1 3 ) September? i 4 k> THE WITNESS: You are right. I'm sorry. Late 5 , August or early September.
. 6 BY MR. JOHNSON: il
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7 0 And you were employed during that time, January [ 8 i of 1984 through September of 1986 in the Harrisburg area? i i 9 j A Yes, I was. 10 0 And with Coldwell -- l 11 A Coldwell Banker, yes. l! 12 l 0 Coldwell Banker. I 13 And following late August, early September of () 14 1986, with whom were you employed? ! 15 ; A I took a position as a consultant for General i 16 ' Physics at Rancho Seco nuclear station. i 17 j 0 And what kind of work have you been doing for 18 . General Physics Corporation at Rancho Seco? d 19 4 A I was assigned to operations training department, l i il ' 20 restart implementation, effective last week I took over a 21 ) position of training supervisor in charge of operations . l J 22 i training. d B 23 J 0 If I may just go a little bit out of sequence l 24 i and go back to the time when you were manager of plant 1 1 25 a
. operations at TMI 2: Would you generally describe your !
CE) i d i 4 ' l I ACE-FEDERAL REPORTERS, INC. i l i .m x_m- seu- g;
t 29049.0 i 14 Tayloe I responsibilities in that position? () 1 0 2 q A Yeah. Very generally. It's been a number of a 3 j years. But basically I had three areas of responsibility: I 4 j One was the operation of the unit post-accident; two was 5 rad waste operations which involved the new systems, et i 6 d cetera, that we had installed to process radioactivity e 7 faftertheaccident; and the third area was radioactive 8 waste shipping disposal. 9 l 0 In your responsibilities for operation of unit 10 post-accident, did you get involved in the questions of 11 l compliance with technical specifications, with federal 4 12 1 regulations, with compliance with quality assurance 13 , programs applicable to TMI Unit 2? () 14 l A All those areas were, in fact, part and parcel 15 of all three areas, operations, rad waste and shipping l i 16 l disposal.
;i 17 j 0 And in connection with those responsibilities, l I
1 18 h did you have responsibilities related to the refurbishment i N I 19 j of the Polar Crane, particularly with the way in which the L j 20 )workonthePolarCranewasbeingperformed? l l 21 . A I think to properly answer that I have to 22 ! explain the interreaction of the different groups we had at 23 the Island at that time. 24 The Polar Crane was an item that was turned over 25 back to what we call " construction," which I think they had l (:) :
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l 29049.0 15 l Tayloe 1 1 a different name for it, but for a very generic term we can O 2 3 just describe it as " construction." They were to make the l i 3 ;l changes necessary in accordance with, you know, procedures
- l 4 in terms of ECMs, that type of thing, and they would then, 5 in turn, turn that -- after the modifications were made, 6 j they would turn that over to a startup and test group, and 1
7 j the startup and test group would do whatever testing was 8 l required, again in accordance with procedures and proper i 9 , regulations at that time, and then that crane would be 10 ; turned over to site operations. By " site operations," as 11 the manager of operations I really had not much to do with 12 the crane. That was a maintenance function. t 13 j! O I'll get back to the question of the turnover of 14 site operations. (]) j 15 . Just to complete the cycle with respect to your l 15 l employment in connection with GPU Nuclear: Are you in any d 17 q way connected with either GPU Nuclear or Bechtel at the i 1 18 . present time? 19 A I don't know how to answer that because Bechtel 20 i is, in fact, at Rancho Seco and they are doing some work ; 21 for Rancho Seco, but I'm not connected with them in any way. i 22 j< Q In an employment relationship? 23 j A In an employment relationship, no, I'm not.
-l i 24 j May I add, also, here: I also have a real l
l 25 estate company that I'm in partners with a number of other 4 i (:) ! 1 ACE-FEDERAL REPORTERS, INC. o :c:.m.~ x_ m c- 8- m ;
E l 29049.0 16 Tayloe 1 fw 1 i people, and I also am involved -- I'm in the process of (_ l developing 83acresofgroundinto160-someunitsof 2 :i ,
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3 l single-family units. So I'm not just relying on Rancho i 4 i Seco or General Physics. l 5 j 0 Is that in the Harrisburg area? 6 A That is in the Harrisburg area. 7 O That grows out of your connections with Col' dwell l 8 ji Banker? 9 : A Well, out of my connections with real estate, I , t 10 ! yes, i 11 O Could you give me a little bit of background b 12 about why you decided to go into real estate given your 13 L expertise in the engineering area?
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14 ! A Well, yes. I think real estate had always 15 ! fascinated me, even throughout my career in the nuclear I 16 [ power industry, and I had always thought about getting ! l! 17 g involved in real estate, not so much as an agent, you know, a 18 l working for commissions and selling homes and that type of l
'i i 19 ] thing, but primarily maybe as an investor and develop my !
20 ; own real estate company. l H : 21 ; O What kind of income did you live off of when you l 3 22 You said you were
] left GPU Nuclear in the summer of 1983?
' l 23 y not employed.
1 l1 24 MR. MC BRIDE: I'm going to have to object to l 25 ; this as irrelevant unless you can explain what this has to I CE) , Acn-FEDERAL REPORTERS, INC. 3 mm.m ~~ _ . ___________a
29049.0 . 17 Tayloe- ) ( 1 do with the case.in which Mr. Chwast'fk has been asked to 2 testify about.
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MR. JOHNSON: The circumstances of Mr. Chwastyk's t l 4 i leaving Three Mile Island is certainly relevant to the case, 5 and I'm just trying to probe - ,this is just a follow-up to
. 6 .
a previous question, which was what were the circumstances 7 of his leaving, and to ask him to give , little bit more 8 background as to what his motivation and reasons were. He 9 gave some very general answers, and I'm just trying to 10- probe, that's all. 11 MR. MC BRIDE: I have no objection to your 12 asking him about circumstances of his departure, and I' 13 wouldn't object to further questions along that same line, () 14 but I think what income he lived off after he left is not I 15 germane. 16 MR. JOHNSON: Okay. I'll accept that. 17 i BY MR. JOHNSON: t 18 0 Did you consider staying in engineering? 19 I A I considered it after I left Three Mile Island, 20 not in terms of going to work at another utility or lbut 3 21 ; going to work as a consultant. 22 As I mentioned earlier, my interest in real 23 estate was only a manifestation of my thoughts, which was 24 to establish myself into some kind of a business that would 25 bring in an income and give me some flexibility. So after l l C) J l 4 e
+ l ACE-FEDERAL REPORTERS, INC.
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29049.0 1 18 q Tayloe ;
/ 3 1 i I'left GPU I'tried for a few' months to work:with Larry King 1 \
l-' in developing a consulting business as a partnership. . We 2 .l 1 I 3: - never entered'into any kind of a partnership agreement,~but 4 L my hopes.were that if I cou1d.get some business for Quiltec 5 'that I would have a -- that I would'be;in.a position to 6 request a partnership. 7 0 And this was in the period right after'you left-8 GPU? 9 A Yes. 10 O. Did you work with Larry King on soliciting 11 business for Quiltec?- 12 A I talked to Larry King. We didn't work too much l 13 f 'together. I talked'to him in terms of what he thought we O 14 l cou1d de to generete eome busineee, end then 1 did e 1ot ce 15 work on my own at home in terms of trying to contact 16 . different utilities, et cetera, and basically to try to I 17 fsellthemsomekindofconsultingservices'. 18 0 Did you have any success? 19 A No, we didn't. That's why I went back to my 20 fall-back position, which is real estate. l i ' 21 ,] O Your counsel today is being paid for by the
!i 22 utility, by GPU Nuclear?
23 . A Yes. 24 3 MR. MC BRIDE: I might add for the benefit of il 25 $ the record that provision of counsel is pursuant to section 1 O 1 i : j a l Ac7-FEDERAL REPORTERS, INC. !! 202-347.2700 Nauar. wide Coserage KO-73MM6
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29049'.0 [ , 19 Tayloe
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{ l~ l 1410 of the Pennsylvania Business Corporation's Code. O- 2 MR. JOHNSON: I'm not familiar with that section.- 3 Could you explain'what it says? 4 MR. MC BRIDE: The statute authorizes a 5 corporation in Pennsylvania to provide. legal counsel to
. 6 . officers, directors or employees of the corporation 7 . pursuant to the provisions of the Code.
8 MR. HICKEY: .I might also add, I don't think you 9 are under any misapprehension'about this, but that 10 situation of counsel being provided to Mr. Chwastyk has
'll existed for some time before the notice of violation was 12 issued in this matter.
13 Your. question referred to providing counsel to O 14 aim coaev- . 1 aiea t thiex it a a e#v i 911cetio" caet it 15 had just started today, but I wanted to clear it up. 16 MR. MC BRIDE: In fact, we have been counsel for
- 17. ! Mr. Chwastyk since April of 1980 pursuant to the same l
18 f provisions of the Pennsylvania Code. 19 MR. JOHNSON: Okay. Thank you for providing 20 that information. I 21' BY MR. JOHNSON: I: 22 I O Have you had occasion, Mr. Chwastyk, to review 23 j your deposition dated August 4, 1983, which was sworn j 24 testimony given to a Mr. Stier and a Mr. Mileta. 25 MR. MC BRIDE: S-t-i-e-r, and Mileta is i ! O , I 4 i i ACE-FEDERAL REPORTERS, INC. i mm.m s_ ~ m,~. ; l
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[' 20 i
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2 BY MR. JOHNSON: I 3 - 0- To repeat the question, have you had occasion 4 recently to review that deposition? 5 A- I had this available to me here recently and I
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6 , reviewed parts of it. .I don't think I ~ can say I reviewed i 7 it all. 8 , O Could you just give me a ballpark figure of how 9 , long you' spent reviewing it? 10 A On-that specific document I probably can't. I 11 received a-number of documents from my counsel and I spent l 12 i approximately three hours reviewing all those documents. 13 .O Based-'on your review of, as.you say,' parts-of O 14 the deposition, are you currently satisfied that the 15 ! testimony you gave there was, as a general matter, true'and' l 16 g correct to the best of your knowledge? 17 MR. MC BRIDE: I object to that question on the 18 f ground that the witness has not reviewed the entirety of i 19 the transcript and he cannot answer that question. i I 20 : In fact, I will note for the record that there i
! i 21 ;
are some places in here in which the transcript appears to 22 be curious at best about whether it is an accurate f
! t 23 q recordation about what the witness said.
i
. 24 For example, the bottom of page 77 has typing in l ,
i 25 a different typeface and a different spacing and would l a i O 1 i ! l
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i. 1 appear to me to'be what'is recorded-as the answer at the ! 77~)-
-(- I 2- bottom of that page is unlikely to have been the witness' 3 answer given the phraseology of the wording. But I cannot 4 Lsay.that for a fact. But I don't believe the witness can 5 answer that question as broadly as you put it.
6 BY MR. JOHNSON: 7 0 Let me put it another way, taking another side 8 of it: In reviewing the statement that you gave,-did you 9 find anything that was not accurate?- 10 A No, I did not. 11 MR. MC BRIDE: I think we are going to be able 12 to. proceed more expeditiously here if you ask him specifics 13 about this rather than the statement in general given that () 14 he hasn't reviewed the entirety of the statement. 15 BY MR. JOHNSON: 16 0 On page 6 -- excuse me. 17 Are you ready? 18 'A Yes. 19' MR. MC BRIDE: Yes. 20 , BY MR. JOHNSON: 1 21 l 0 On page 66 there is a reference on line 6 and 22 l following of your being interviewed several times I 23 concerning Quiltec and King, and you were asked at line 8 l i 24 whether you remembered being interviewed by John Barton on i 1 25 ll March 10th, and you said yes. !
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1 That is correct, as far as you know? i 2 i A I said yes -- it says here, yes, I remembered it ; l l 3 a vaguely at that time. 1 4 il 0 Do you remember being interviewed by Mr. Barton? 5 iI h A I remember again very vaguely being interviewed 4 6 ] by Mr. Barton. 4 7 l 0 And one of the subjects of that discussion with d 8 l Mr. Barton was involvement of GPU employees with Quiltec 9 ! including Mr. King and others? 10 A I can say that the meeting was, in fact, about 11 [ Mr. King and Ouiltec. I'm not sure about others. J 12 ? O Do you recall being interviewed by Mr. Barton on 13 ; another occasion concerning Quiltec? () 14 ll 9 A Right now I don't, no. I recollect a meeting 15 Whether that is this
]withMr.BartonaboutQuiltec.
16 'l meeting or some other meeting you are talking about, I 17 9 don't know. 18 j 0 But based on your statement in the deposition it 19 is likely that that was the date, March 10th? 20 ; A I can't answer in terms of the date. I just l 21 J don't know if it was March 10th or some other date. j i l 22 0 Were you also interviewed by Mr. Robert Arnold l 23 ] concerning Ouiltec? 24 I A Yes, I was. l 25 0 Appended to your deposition is a memorandum to ; (:) ! ACE-FEDERAL REPORTERS, INC. !
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1 the file by R.C. Arnold, re: termination of employment of k ; 2 l Larry P. King, and the first line -- f I I 3 i MR. MC BRIDE: Just one moment, counselor, if !l 1 1 4 l you would. I think that has been separated from the copy 5 that the witness has before him. I believe I have the
- 6 ! document you are referring to and I'll put it before the 7 witness.
8 Excuse me. Is this the document headed 9 " Excerpt from March 21, 1983, R.C. Arnold Memorandum to 10 File"? 11 MR. JOHNSON: Yes. That's right. 12 MR. MC BRIDE: I put that before the witness. 13 MR. JOHNSON: Okay. lll 14 l l BY MR. JOHNSON: 15 Q Do you have any independent recollection of that ll i 16 l meeting with Mr. Arnold? 17 4ld A Except that I met with him, no, not the 18 specifics of it, not without maybe reading this. n 19 L Q Well, take a second to look at it. I
- I 4
20 !; (Pause.) l
! I 21 l BY MR. JOHNSON:
N 22 ; O Having reviewed that, do you have any further 23 l recollection of that meeting? i 24 A. No. My recollection is no better now. It is 25 j probably even worse than it was then.
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2 at the memo now you can recollect anything more now than 3 p you could without having looked at it? l 4 , A Well, I recollect that part about the conflict l l l 5 ! of interest. I remember relating that to Mr. Arnold. I i 6 i remember somewhat some discussion about a meeting, but , 7 again I don't remember it any better than what I did there. It appears from this excerpt, or from this I 8 [ 0 11 9 I memorandum to the file, that you did meet with Dave 10 l Buchanan and Bill Austin on the afternoon of March 11, 1983? I 11 h A No, I don't believe that is correct. I met with 12 Mr. Arnold. I don't think Buchanan and Austin were there. 13 0 So you met separately with Mr. Arnold? fs (,) 14 k A Yes. I would.think that's the way it was, yes. 15 0 Did you meet with Mr. Arnold on this subject on l1 16 i more than one occasion? O 17 j A I don't recall. F 18 0 0 Is your best recollection that it was just this 1 9 19 a one time? 1 20 ) A I don't recall any other meetings. I S ! 21 lI O With Mr. Arnold? i 22 A With Mr. Arnold.
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4 23 ] O At all, or on this subject? i
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24 A On this subject.
] I 25 0 Okay. Also appended to your sworn testimony ;
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1-]o before Mr. Stiercis something called " Excerpts-from D.
.O. ' 2 Aulick Interview of J. Chwastyk."
3~ Do you recall a person' named -- is it Dean-4 Aulick? 5 A Yes, I believe it was Dean Aulick. Yes, I do. l 6 0 And-Aulick is.an attorney, as best'you know? 7 A- As best I know, yes. 8 f 0 Do you remember who he worked for? 9 A I believe he worked for Mr. Stier. I'm not 10 certain. 11 0 Do you recall meeting with him a number of times 1
- 12. on the. subject of Ouiltec?
13 A I remember meeting with Mr. Aulick. Again, I f 14 don't know if it was a number.of times, once, twice, three 15 times or what. But I'm sure it is all part of the record 16 l so it must be there somewhere. l. 17 0 Did you meet with any other attorneys connected l 1 18 l with Mr. Stier or GPU Nuclear or Bechtel during this same 19- , time frame of March, April of 1983? 20 MR. MC BRIDE: Excuse me. May I have that 21 question reread, please. 22 I (The reporter read the record as requested.) i
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23 MR. MC BRIDE: I assume by the phraseology of 24 i your question that you're excluding Mr. Chwastyk's counsel? I 25 MR. JOHNSON: Yes. His own personal counsel. I (:) l 1 i e i ACE-FEDERAL REPORTERS, INC. I 202 3 3 3700 Nationwide Coserage MAL 336-p l
l 0 l l 29049.0 26 j Tayloe l L i ! 1 ( MR. MC BRIDE: Yes. Thank you. O j 2 THE WITNESS: I don't think I can answer that.
.l 3 I met with an awful lot of attorneys over the years, and I j 4 f can't take two months out of three or four years ago and t
5 say I did or did not meet with any one of them, [ i 6 j BY MR. JOHNSON: l-7 ; O When you met with Mr. Arnold, were you ! 8 represented by counsel when you spoke to him? 9 A No, I was not.
/
10 0 When you spoke to Mr. -- 11 MR. HICKEY: Can I ask if you can clarify that: 12 l Are you asking whether someone was with him when he met 13 with Mr. Arnold? () 14 J MR. JOHNSON: Well, I'm given to understand that 15 i he was provided with counsel. L 16 MR. HICKEY: Your question was was he 17 represented by counsel when he met with Mr. Arnold. I'm i 18 [;askingifyoucanclarifywhetheryoumeansomeonewas , s 19 j! physically present with him. . 20 ) 2 MR. JOHNSON: Yes. I think that is the way it l i a 21 was understood, too. 22 % THE WITNESS: That is how I understood it, yes, i!
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23 > whether my counsel was with me at the meeting, and I 24 l answered, no, they were not. 1 25 p BY MR. JOHNSON: j l C) ; ! t f i 1 ACE-FEDERAL REPORTERS, INC. 2 m.m , _m c_. mum .j
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1 29049.0 27 I Tayloe i - J c , 3 I
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1 0 But you did have an attox;iey at b:c t time? 2 A May I speak tp my;'epunsel a minute?, !
.i 3 j i
(Pause.) r 4 > The reason I couldn't answo/ taat,.is because at
, i l \
5 j the +.ime I was[be~0Ng represented by c ansyg, but it ws:.1 :> h y .,
- 6 a other matters, and I can't say that I was aware that, if I J
7 needed counsel on this specific subject, that theylnere . ! r. 8 l available. ,o i i
'f' 9 0 Were you. accompanied by counsel when'cyou'were >
10 interviewed by Mr. Aulick? i. 11 A No, I was not. ' i 12 1 0 Did you have any meetings wir.h any other people- , c 13 in GPU nanagdnent othetathan Mr. Arno13,and Mr. Barton or '
; 14 ; legal representatives -- strike thet --)'gry.er than '
\
f j 15 ', Mr. Arnold and Mr. Barton? I I 16 li MTi; MC BRIDE: I'm sorry. >
.i ii 17 j ffL MR. JOHNSON:
R t ;; n 18 1 0 Did" you, meet conentning Ouiltec during this same ' ! 19 0 q time frame with anyone in GPU management other than a i I ,' 20 1 Mr. Arnold or Mr. Barton? 1 21 , A Not that I can recall, no. i 22 1 0 In terms of your sworn testinony or deposition 23 j testimony to Mr. Stier and people working I'or him, are the y s o 24 :! only transcripts the transcripts that are in this so-called
] s 1 25 j "Stier report" --
I have a version of it cor.p ined Q the H l
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9 j. 29049.0 / ., 28 Tayloe i 1 \l I 1 ! Bechtel: report, but I believe it was something -- a l h 0 l 2 !! document dated November 16, 1983, of two sworn -- two 1 ' 3 j pieces of sworn testimony. One was August 4, 1983 and the 1 4 > other was March 1, 1983.
- l<
5 l Are you aware of any other statements,' sworn I 6 h statements, that you gave? 11 ! 7 f A I'm not even aware of those two. So, no, I'm l 1 8 h :.at aware of any sworn stanaments' I gave, other than what 9 J is available he,re for us on the record. 10 MR. MC BRIDE: I assume you meant your question l 11 l to be confined to thc3 subject of Ouiltec? i 12 l MR. JOHNSON: Right. On Quiltec. 13 BY MR. JOHNSON: .). l ? h 14 0 Do you recall any other interviews with.any l 15 l lawyers other than your own counsel in connection with the l , 16 Quiltec matter other than Mr. Aulick or the depositions i 17 I; with Mr. Stier and Mr. Mileta? j i 18 )l A In that same time frame?- ; 19 , 0 Yes. ! 20 ij MR. RICHARDSON: Excuse me. Could you read that. } i 21 1 question back, please. i 22 (The reporter cead the record as requested.)
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23 MR. MC BRIDE: What time frame are we refer.cing i 24 1 to here? 25 1 MR. JOHNSON: The time frame would be March to ; i l ll> ; I j ACE-FEDERAL REPORTERS, INC. l
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~ August of'1983, and with regard to Quiltec.
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2 - THE WITNESS: Not that I can recall. 3 , Let me ask this question: You are asking if I , l ! 4 i gave my' depositions, is that correct? i 5 BY MR. JOHNSON: 6 ! O i phrased it as " sworn statements." f l 7 A Sworn statements. 8 I guess I don't understand, of all the records 9 of all the testimony I gave, there is no way I can remember 10 all of them. I don't know why I'm being asked this 11 question. 12 0 Well, your recollection is that you can't recall 13 any other statements?
. ('_
/ s) '14 A Yeah, that is my recollection.
15 0 After you left GPU in the summer of 1983, were 16 you Lver offered employment again with either GPU or [ d, 17 y Bechtel? h 18 ] A No, I was not. N l, 19 1 0 I would like to go back to your work as manager 20 j of plant operations during the '82-83 time period. l! 21 ' In your role as manager of plant operations you 22 said you did have certain responsibilities in connection 23 l with compliance with technical specifications, OA 24 procedures, and other procedures in connection with the 25 work being done on the Polar Crane and the turnover of the I I:t_; en i
! i 1 i
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I 29049.0 30 Tayloe i 1 i crane. ! h ! 2 MR. HICKEY: Excuse me. I think you put two
]
I l; 3 i questions together there, and I think it is not an accurate j il 4 l summary of what the witness said. I would ask you to ! l 5 rephrase it. I 6 ii BY MR. JOHNSON: 1 7 0 Maybe I can ask you: In connection with the 8 l Polar Crane refurbishment program, and during that period, 9 1982-83, what were your responsibilities or roles? i 10 MR. RICHARDSON: Did you say "as manager of the 11 Polar Crane"? i 12 THE WITNESS: Manager of plant operations. 13 'i MR. HICKEY: You said "as manager of the Polar h 14 Crane refurbishment program." You mean " manager of plant 15 operations." l 16 q BY MR. JOHNSON: j 4 4 17 j 0 What was your role in relation to the Polar j ii i 18 4 Crane work? l l I 19 A Specifically I don't know that I can say I i ! 20 j anything. My role as manager of operations, though, l ll 21 ,, required compliance with various requirements, including ! 22 ] procedural, technical specifications, regulatory l 1 23 j requirements, et cetera. l l !
. 24 : We did have a member of our staff on the test l l
25 U working group that was involved with the Polar Crane ; l i (B> 1 i i : I a 1 ACE-FEDEML REPORTERS, INC. d 3 C .14*-3'00 Nanonwide Cos eraae Co 3%f646
! l l l 29049.0 ] 31 l [ Tayloe : i 1 ! l ! l process and i. hat was our function in that area. we 2 3 0 on page 113 and 114 of your August 4th 1 i l 3 [ deposition, I would refer you to your testimony there, l l l 4 which generally you say that you and Mr. King decided to 5 raise certain problems at an early stage in order to avoid l surprise to those responsible for the Polar Crane work, and 6 i 7 j so that it could be corrected. 8 Is that a fair summary of what you say there? 9 i MR. RICHARDSON: Excuse me. You are reading 10 i from which line, what line? I 11 MR. JOHNSON: Well, it's the bottom of page 113, 12 top of page 114, and you say "As a matter of fact, one of 13 the things that I had discussed with Mr. King somewhere 14 around the end of the year was the fact that we have that 15 as a final hammer, if you will, to ensure that that Polar 16 ll Crane, the work is properly done and documented. We Il 17 ll decided , though, that rather than sit back and say we will i 18 r just wait until they are ready and won't sign it off and 19 they can't put it in service until they do it right, we i 20 i decided to bring up those concerns beforehand so they can l1 21 be corrected." j 22 ll During that time frame, which was around the end
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23 of 1982, the beginning of 1983, site operations was in a d
. 24 ; position of, in a sense, looking over the shoulder of i
25 recovery operations, which was responsible for the ll O ; i i e, i j ACE-FEDERAL REPORTERS, INC. l,
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29049.0'-' l 32 M- Tayloe ~l l' l refurbishment'of the Polar Crane, is.that a'. fair. statement? 2~ MR. HICKEY: I would like to suggest that it is 13 . a pretty vague statement, but if the witness;can answer it,- l 4 that's okay. 5 THE WITNESS: I.think I can answer it, and that 6 is our function was'not to look over recovery operation's 7 shoulders. We had specific functions and responsibilities 8 that we had to comply with. There was a time during this'
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9- time frame where we felt that most of the expertise in the 10 things I mentioned area.-- the areas of responsibility, j 11 that is compliance, procedures, tech specs, regulatory 12 requirements, was in site operations, not to say that there 13 was no expertise anywhere else, but the majority of 14 . expertise was-in site operations. ] 15 BY MR. JOHNSON: 16 O You make reference on page 137 and 138 of your 17 ! deposition to one particular type-of matter, and that was 18 that you and Mr. King were concerned about failure to use ! l 19 [ ECMs. Is that engineering change memoranda? Is that what l I l 20 l you are referring to? l i 1 21 ! MR. RICHARDSON: Excuse me. Could we find the ( 22 l testimony that you are referring to? 23 l Could you give us a page and line number, please, i
- 24 j MR. JOHNSON: Page 137 and 138, bottom of 137 l
25 and the top of 138.
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1 MR. RICHARDSON: The question beginning on line Of-2 i 177 3 MR. JOHNSON: Yes. 4 MR. RICHARDSON: What is the number on 44-C? 6 5 j! That refers to the question, I think. 6 MR. JOHNSON: I would appreciate your just 7 l letting me ask the question. i 8 On the top of page 138 did you say that you were 9 ; concerned that the work being done on the Polar Crane 1 10 should be covered by ECM that was not being covered by ECM. 11 Now, ECM stands for engineering change l i . I 12 l memorandum? I 13 - THE WITNESS: Yes. In terms of the answer to I () 14 l that question, and I think I stated it there, it was 15 l possible that they should have been doing work under ECMs, 4 0 16 'l but we weren't sure of that. il 17 f BY MR. JOHNSON: 18 l This is an example of the kind of procedural i 0 19 q compliance that would be part of your responsibilities, to c 20 !l make sure that if the matter required an engineering change
'l 21 ) memorandum that that procedure be followed? ,
n 22 A I think you are putting this in a context that I
]
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23 ; really can't answer, because what you are saying, or the s 24 ] way I'm reading it anyway, is that it was our ;
! i 25 g responsibility to ensure that everybody at all times did j l !
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l 29049.0 ! 34 Tayloe i 1 things in accordance with proper procedures, regulations, 2 h tech specs, et cetera, and I can't answer that because we J 3 P only had certain areas of responsibility which we had -- 4 you know, we had the ability to do that. What I'm saying 5 here is, we had an organization that was a pretty diverse 6 !l and expanded organization and we could not, you know, , l 7 oversee what everybody was doing in that organization to 8 ensure the compliance with these things. 9 0 But you did have concerns apparently at that 10 time with regard to the work on the Polar Crane that to the 11 that it should be covered by ECMs that there were fextent 12 4 ECMs covering them? 13 A We had concerns that possibly it was possible f (3_) 14 that perhaps the people that were working on this project 15 l were not, in fact, complying with some of our in-house i 16 l procedures and therefore it is possible, because of not 17 j complying with in-house procedures, that we were not i 18 hcomplyingwiththepurpose that we write those procedures, l i 9 19 you know, compliance with regulations, et cetera. l 20 h 0 I'm going to show you a few memoranda, GPU i
] !
21 internal memoranda. i I 22 MR. JOHNSON: I don't have extra copies of them.
. 1 l 23 I believe that your counsel has access to them.
. 24 ) I'm going to show them to you and I will mark j i
25 : them for identification. 1 O i i i il 1 i ACE-FEDERAL REPORTERS, INC. ,
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d i 29049.0 j 35 i d Tayloe ! I i 1 4 BY MR. JOHNSON: I~T 'l
\# 2 f Q The first one is a February 7th, 1983, 3 ; interoffice memorandum of GPU Nuclear, 4200-83-068 Subject, l 4 Head Punch List as a Management Tool, and it is from L.P.
I 5 King, site operations director, to R. Metzger.
. 6
] It starts off with the following Icnguage:
a 7 ! "The purpose of this memorandum is to once again express my 4 8 concerns on the use of a punch list as the means of 9 managing the head lift tasks. This is an inadequate tool 10 l for monitoring the progress of the project because it does j 11 not identify the relationships of ties between sequence 12 ; tasks." i 13 l I'll show it to you and then I'll mark it. I i () 14 MR. MC BRIDE: Where were you reading from, 15 ]please? 16 MR. JOHNSON: The very beginning. 17 l (Discussion off the record.)
'i 18 4 MR. MC BRIDE: Do you want him to read the 19 .
entirety of the document, counsel? 20 MR. JOHNSON: If he wants to. 21 MR. MC BRIDE: I think that he does, and might
]
1 22 j I suggest that it would be an appropriate time to take a 23 break. 24 MR. JOHNSON: Okay. 25 (Recess.) 1 t . N i l 0 : I ACE-FEDERAL REPORTERS, INC. ! j 2'C-30 mn Nationwide Cos erage 800-33MM6 !
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I MR. JOHNSON: On the record.
;f- ' l' ;
r 2 ; This F.ebruary 7, 1983 interoffice' memorandum ; l . 3 .l ..that you.were just looking'at, I'm going to identify as l l 4 j Chwastyk Deposition-Exhibit'3 for' identification. 5 -(Chwastyk Deposition Exhibit 3 identified.) l
'i .!
l 6 l (Discussion off the record.) l 7- l BY MR. JOHNSON: 8 0 Mr. Chwastyk, while we were off the record, I l 9 showed you a document dated. February 7, 1983, an ; 10 . interoffice memorandum of GPU Nuclear, and it's number is 11 4200-83-069, and it's subject is Concerns Over Head. Lift 12 Schedule, and it is from L.P. King, site operations 1
.13 director, to B.K. Kanga, K-a-n-g-a, and J.J. Barton, and I !
14 would like to mark this as Chwastyk Deposition Exhibit 15 Number 4 for identification. >
! -l 16 i (Chwastyk Deposition Exhibit 4 identified.)
17 BY MR. JOHNSON: l 18 ! O Mr. Chwastyk, did you get an opportunity to look 19 at both of these memoranda? , t i 20 A Yes, I did. 21 [ O Had you ever seen these before? 22 1 A I can't say definitely that I did. 23 i 0 Do the subjects of the memoranda appear familiar
, 24 to you?
25 , A Yes, they do. l i; a O l! i l a :l j. ACE-FEDERAL REPORTERS, INC. 20:-347-3700 Nanotiwide Coverage Sin N ta
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! , i 0 'Could you describe what'they were about, 1 l
.a. 2 i. generally?
3 A Well, very generally what they were about is the 4 fact that we did not have a detailed schedule on a number 5 of items, including some of the things'they talked about,
; 6 which, you know, I had kind of' forgotten about, but we'did-7 not have a detailed schedule showing start to finish and 8 expected completion dates and responsibility.
l 9 j 0 And can these be characterized as concerns that
'i 10 site operations was raising with recovery operations, 11 concerning coordination and enabling site operations to 12 ' perform its designated function?
l 13 MR. MC BRIDE: I object on the ground that it
.O 14 eex tae witaeee to enece1ete edoue the vie or the 15 department.vis-a-vis,another department. I'think it would 16 be better to focus the questions on the authors of the 17 memoranda and the persons to whom they were addressed.
18 i BY MR. JOHNSON: i 19 ! O Was Mr. King for site operations expressing to I 20 l management in recovery operations.its views as to the way 21 in which failure to have an integrated schedule was 22 impacting on the ability of site operations to perform its l' 23 functions? l 24 . NR. HICKEY: Is that a quote from one of the l i 1 I 25 , documents? l O. 6 o e ACE-FEDERAL REPORTERS, INC. li x w .37oo sationwide coserage soo-33swa
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l l MR.. JOHNSON: No. (~) 2 j THE WITNESS: I just wanted to look.at this- , l 3 because I don't remember what Metzger's position was. The
.4 first memo you marked as Chwastyk Deposition Exhibit Number S 3I think was to the person in charge of scheduling or i
6 someone that should have been in charge of scheduling. 7 Now, you keep referring to' recovery operations. 8 I don't think I can define right now who and what was in i 9 recovery operations specifically, but it was. basically -- 10 my Deposition Exhibit Number 3 was a letter to R. Metzger 11 who, I believe, was the person responsible in some way to 12 ensure that the. work we had planned'to do was done properly, 13 and-this' memo was site operations' input in trying to () 14 ! orovide our-experience'into the whole process. 15 BY MR. JOHNSON: 16' O In terms of Mr. Metzger in particular, I will 17 lshowyoupage7of13from.ChwastykDepositionExhibit 18 l ' Number 1, and I believe it shows him as serving under the 19 l manager of recovery operations as manager, reactor 20 l disassembly and operations. 21 1 I'll show that to you to confirm that. 22 i Do you see Metzger's name handwritten? 23 A Is that over here on the right? 24 l 0 Yes. 25 A I'll take your word for it. I'm not sure I can
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i _1 j distinguish'that.that is:Metzger there. I'm sure there
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2
) must be better copies around that are distinguishable as
~3 .; being Metzger.
I 4 ! . O Does that appear to say Metzger?
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5 A, I'see an R and an M, definitely, and'possibly a-
. 6 -T. It's possibl e it could be Metzger. . You know, I, concede .{
l ! 7 that it is Metzger if it means anything. I 8 0 I have in front of me, and I'm going to show you 9 another interoffice memorandum from GPU Nuclear, number 10 4240-83-111, dated February 10, 1983, subject, Review of
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11 Polar Crane Load Test Safety Evaluation,.to L.P. King, site 12 operations director, TMI 2,.and it is from E.G. Gischel, 13 , G-i-s-c-h-e-1, plant engineering director, TMI 2, and I'm 14 going to mark it_for identification as Chwastyk Deposition 15 Exhibit Number 5 for identification. 16 (Chwastyk Deposition Exhibit 5 identified.) 17 MR. MC BRIDE: May I ask counsel: The document 18 j that you have marked as Deposition Exhibit Number 5 has some handwriting in the right margin in blue. 19 20 l Is this handwriting that was added by someone on i 21 i the NRC staff or is it your representation that that I 22 ! handwriting was on the document in GPUN's files? 23 MR. JOHNSON: I don't know what the source of q
; -3 24 this handwriting is. I would assume it is not part of the 1
.l 3 25 original document, and you can choose to ignore it.
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t 29049.0 ' 40 l{l Tayloe ! I 1 MR. HICKEY: May I see the document? li 2 ; BY MR. JOHNSON: i ii i i 3 1 O Mr. Chwastyk, I'm going to show you another 4 interoffice memorandum, number 4240-83-138, February 17, 5 , 1983, subject, Polar Crane Load Test Safety Evaluation, and 6 it is to J.W. Thiesing, T-h-i-e-s-i-n-g, recovery programs, j 7 and it is signed by E.G. Gischel, plant engineering 8 j director, TMI 2, and L.P. King, site operations director, 4 9 TMI 2, and it refers to two other memoranda, including the l i 10 ; one I just showed you as Chwastyk Deposition Exhibit Number 11 5. 12 Before I give it to you I'll mark it for i 13 !l identification, if I may. 61 14 A All right. llh n 15 O I'm going to mark this exhibit as Chwastyk
]
1 16 i Deposition Exhibit Number 6 for identification. il 17 ), (Chwastyk Deposition Exhibit 6 identified.) 18 ; MR. HICKEY: Do you want to look at Exhibit 57 ! 4 19 d THE WITNESS: Can I see the top of this? 3 f 20 y MR. HICKEY: While the witness is reviewing 6, I j j ! 21 was going to ask counsel if Exhibit 5, which has this ; 4 I l 22 ] handwriting on it -- it looks to me like it is original 23 i handwriting. It is not Xeroxed on this paper -- if he
!i 24 i knows the source of the document, because maybe that would 25 ;
indicate where the handwriting came from? i (Il 1 l I i l
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i l .. I Do you know where you got-this document?'
,o 2 l MR. JOHNSON:. It'is from NRC files. It's not
.3 I something that~I got from the Stier report.
.4 MR. HICKEY: Perhaps when we break for. lunch, if
- 4 5 you wouldn't mind we'can'have copies made'of these
,- 6 documents that you are making as exhibits, since we only 7 have one set of them.
8 MR. JOHNSON: Sure. Can I have the copies back? 9 f BY MR. JOHNSON: 10 .0 Have you, Mr. Chwastyk, seen these memoranda 11 before? 12 A Again I think I have but I can't recall.them 13 , specifically, other than just reading them right now. O 14 o wita ree9ect to caweetvx oevoeitica exaiatt 15 j Number 5, the memorandum from Mr. Gischel to Mr. King, 16 Mr. Gischel is telling Mr. King that.he found the Polar 17 Crane load test safety evaluation presented for review and 18 comment technically unacceptable to plant engineering; and 19 the second memorandum, which is from King and Gischel to 20 , Thiesing of recovery programs referencing this memorandum, l 21 ! says that the purpose of the memorandum is to summarize the 22 I status of site operations review of the Polar Crane load
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23 l test safety evaluation and document close out of plant i 24 j engineering's comments which were the subject of the 25 ( references 1 and 2 that are indicated therein. O l 0 a t, a J ACE-FEDERAL REPORTERS, INC. I o m:.w.~ ~~n7y yyy
29049.0 3 42 Tayloe j il 1 1 j Then the second memorandum, Exhibit 6, says in O 2 4 part, "As a result of discussions at these meetings," which ; a ! 3 ]areenumerated, several meetings between Mr. -- involving { tl l 4 l Mr. King and Mr. Barton, Mr. Thiesing, and others, Plant I
. i 5 ! engineering agreed" -- I'm quoting now -- "to close out the ? 6 d comments of reference 1," which is Chwastyk exhibit 5, on j
7 j the basis of overriding programmatic concerns which in the i 8 l opinion of program management overshadowed the technical s 9 concerns of plant engineering." t 10 d The last paragraph states, "Although site F 11 operations has voiced a fundamental disagreement with the il 12 f Polar Crane retest program, we do not challenge the 13 authority of the office of the director to proceed with the 14 program as written." , 0 ! 15 Did you have any role in the preparation or
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4 i 16 review of these two documents? l 17 d A Not that I can remember, no.
- i 18 j 0 Were you aware of "A fundamental disagreement" 1
19 j that site operations voiced with respect to the Polar Crane 20 j retest program? t i 21 3 A I don't -- l 1 ! 22 j Q let me show you the memorandum. 1 23 q A Yes. ,
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1
- 24 i I guess I really don't know how to answer that j i
25 , question, because I don't know what a fundamental , I l
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I i 1 1 I disagreement of the Polar Crane retest program -- what that h I 2 l means. l l 3 0 Given that you don't understand what 1l 4 " Fundamental disagreement" means, were you aware, 5 contemporaneously, in February of 1983 that there were
; 6 j expressions of disagreement in general with the safety 7 evaluation for the Polar Crane load test?
8 ; A Yes, I was, i 9 0 And these concerns that are reflected here 10 didn't reflect your concerns? They just reflected 11 Mr. Gischel and Mr. King's concerns? i 12 l A Not specifically, okay, but generically they did, i 13 simply because again I go back to what I said earlier, and llh 14 , that was site operations and plant operations had the l . 15 l responsibility for compliance with regulations, procedures, ll 16 l et cetera, and in this instance I think this is the same i. 17 category except that the Polar Crane and the Polar Crane a 18 refurbishment and test was more of an engineering evolution 19 )than it was an operations evolution. 1 20 k Maybe just to expand on that a little bit, let
;l 21 0 me just briefly say that compliance was the responsibility II 22 into
[A of site operations and site operations is broken down
] three categories: Operations, maintenance and engineering.
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23 1 24 1 0 Yes. 25 ] A There were things done in engineering that had c l TID ) ! i i 1 I i ACE-FEDERAL RIEeORTERS, INC. 202-34'-3700 Nnonwide Coserage sn 3hM6 l
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1 i 1 i 1 I no relation:to maintenance; there were things done in 2 maintenance that had'no relation to operations, andLvice
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3' l versa.- And what I'm1saying here is this Polar Crane at i 4 this' time was more of an engineering function and 5 requirement'than it was operations. l
,' 6 1 0 However, site operations was concerned'about the s
7 process by which engineering changes being made on the 8 . Polar Crane were being turned over for operations, for 9 i testing and operations; is.that not true? 10 MR.~ MC BRIDE: Again I object to the question as I 11' asking for the' witness to testify about the attitude of the 12 department as opposed to others, specifically that he may 13 be'able to address himself. () 14 Could you please make the question more specific? 15 MR. JOHNSON: Mr. Chwastyk was a member of the i ,
- 16. j site operations department.
17 ) That is true, isn't it? 18 J THE-WITNESS: Yes. i 19 i BY MR. JOHNSON: 1 20 I O You were aware of positions that were being 21 ' taken by Mr. King and Mr. Gischel; is that true? l 22 A Yes, to a degree, yes. 23 i MR. JOHNSON: So I think it is a fair question l
. 24 ,
to probe Mr. Chwastyk's knowledge about the site operations 25 department. He was a top level manager in that department. 1 (2) ! !, 1 ! 9 ! ti I ACE-FEDERAL REPORTERS, INC. hl
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45 LTayloe. l 1 l I think it is a fair. question. Could I have the I 2 question 1 read. s 3 b (The reporter read the record as requested.) f 4 BY MR. JOHNSON: 5 0 Let me rephrase the' question for you, maybe. As
; 6 a member of site operations you were. concerned that the 7 system, which was the Polar Crane that was being turned 8 over to operations after.the rework that was being done, be 4
9 done in conformance with site procedures, administrative 10- procedures; is that not true? 11 A That is true, but keep in mind that'this is 12 ' pre-turnover, you-know, and you made a reference earlier to
.13 my statement in one of these documents where we had a
() '14 choice to make and that was do we just sit back and let j 15 things happen and then when it is time for turnover to our 16 site operations just refuse to accept it because it did.not i 17 meet some of these requirements, and we chose not to do 18 that. We chose to bring up these problems so that they 19 ; could be resolved so that they wouldn't adversely affect 20 the schedule. I 21 , I guess I lost what the question was. I don't 22 know if that answered it or not. 23 O Your statement is fine. l 24 I'm going to show you a document; it is actually l 25 W a composit. Incidentally, this is Stier Exhibit 118, for (21 1 f,
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!i The date is February 28, 1983, interoffice
&' F 3 memorandum of GPU Nuclear, number 43-70-83-1019, subject, 4
l resolution of comments, Polar Crane load test procedure.
! It is from D.M. Lake, manager, recovery operations, to L.P.
5 l
,- 6 l King, director, site operations.
7 Attached to it is a document entitled " Comment i 8 Resolution," and it has a designation handwritten next to 9 the printed word " Document," "UWI-4370-3891-83-PC01, P/C 10 load test," and under that it says -- under reviewer, R. 11 Parks, and then next to that is printed "Date of Comments" 12 and over that is written "2/17/83." This comment 13 resolution is four pages. This version of it has () 14 handwritten comments in the third column and it has in the 15 sixth column typewritten under the column reason for 16 [rejectionwhatappearedtobetheresolutionsofthe ! ti I 17 ) comments of R. Parks by a Mr. M.E. Radbill, R-a-d-b-i-1-1, 1 18 j! dated 2/25/83. l,, 19 l I'll mark that as Chwastyk Deposition Exhibit j U l 20 Number 7 for identification. 21 (Chwastyk Deposition Exhibit 7 identified.) 4 22 j BY MR. JOHNSON:
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4 i 23 d 0 I'll show it to you. I would like you, if l 24 j possible, to focus on the handwritten comments starting on s i 1 25 j the second page by Mr. Parks. A (1) ) ! I l u 1 i ACE-FEDERAL REPORTERS, INC. u nn ~_ n , -- ;
29049 02 .I 47 Tayloe l l 1 f With respect to Mr. Parks' comments, I believe Q'.. ~2 -it is his statement that he wrote this and before it was 3' accepted by Mr. Radbill -- now, Mr. Radbill was -- do you 4 recall what department he was with? 5 A No, I don't.
-6 .For help, I know that Mike Radbill was 7 associated somehow with the Polar Crane. I don't know 8 exactly what his title was or what department he worked for.
l 9 O He was contact person listed by Mr. Lake, who 10 was the manager of recovery operations. So I would take.it 11- that he was with recovery operations, and his position
- 12. escapes me right at the moment. I think we can probably 13 ' find'it as we go along.
h 14 In any case, were you consulted -- I was in the 15 . middle of characterizing it as being submitted to Mr.
-16 Radbill but turned back before it was accepted for checking 17 9 with Mr. King.
18 I assume, then, that you never saw this before 19 it was submitted to Mr. Radbill; is that correct? Do you i 1 20 [ recall that? i 21 ' A I don't recall it specifically. I recall 22 discussing some of the topics that are indicated as 23 I comments. I don't recall the document per se. 24 0 I'm going to show you another memorandum, 25 ; another document. It is an IOM interoffice memorandum of i O i i
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1 .! 'GPU Nuclear, 4200-83-102, dated March 1, 1983, the subject O': L 2 l j is IOM number 4370-83-1019, resolution to comments on P/C
=3 load test, 'to' D.M . Lake, manager, recovery operations,'and .
4 it.is signed by J.J.~Chwastyk, site operations director, 5 acting. l 6 i Attached to this one-page memorandum are two 7 pages of comm'ent resolution are responses numbers 1 to 14. 8 I'm going to mark.it as Chwastyk Deposition Exhibit Number 9 8 for identification. 10 l (Chwastyk Deposition Exhibit 8 identified.) 11 l BY MR. JOHNSON: 1 0 I'll show it to you. 12~ l 13 .This memorandum which is signed by you states, O. 14 l rhie memoreaaum treae ite site overeetone review of the 15 -l Polar Crane Task Group's resolutions to comments made on 16 the subject procedure, dated February 17, 1983. We do not 17 agree with the resolutions and have verified this position I J
-18 ,
with B.E. Ballard, QA manager, and, therefore, cannot F i 19 ! approve the Polar Crane load test procedure until these Il 20 !!differencesareresolved,"andthenitlistsasacontact 21 l person Rick Parks. I 22 l Who wrote these two pages of comments stating
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23 i your disagreement with resolution by Mr. Lake concerning 24 the application of procedures in AP 1047 to the Polar Crane 25 load test? ! I 1 I l l v i ACE +EDERAL REPORTERS, INC. l
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- v' 1 O I'm referring you to the language -- thatfentire 2 ! paragraph. Would-you look'at.it, please.
- 3. l A Yes.
4- I've read it.
. 5 O Now, this is signed by Mr. Radbill, Polar Crane-6 task group leader, and D.M. Lake, manager of recovery 7 . operations, and I assume it reflects their views.
8 Does it say that the repeated. rounds of comments 9 by various site' review groups was causing a delay -- a week 10 for each round of comments. -Each round of comments was 11 resulting in approximately one week delay in the 12 finalization of the Polar Crane test procedure? 13 MR. MC BRIDE: I object on the grounds that.the (} 14 / document speaks for itself. I 15 k THE WITNESS: That's basically what it says. s I! 16 q May I comment on that, though? 17 BY MR. JOHNSON: ) i 18 d O Yes. Go ahead. 0 19 ji A You know, this is not unusual. We just had gone d I 20 j through a big shakeup in terms of how we were complying j r 21 llwiththeprocedures, and it is very typical of any problem, li 22 f once a problem is identified, there is always the swing of j i i 23 q the pendulum in the opposite direction, and in fact it j
!! l j
24 y became another management problem to resolve that. 25 s! Other than that, I don't see -- you know, we are ! (:) I l a i e i d ACE-FEDERAL REPORTERS, INC. x., xs_ __. s . 33 - . A
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h O 1 I talking about someone that was responsible to get this work , 2 3 done and he was being frustrated by all these changes. f l J 3 J 0 During this period, from approximately February 4 ] 25th, 1983, through much of March, at least, 1983, you were
. 5 ; Rick Parks' supervisor as acting director, weren't you?
] l 6 K A I believe that is correct. l Y
7 h Q- And he was the author of the comment resolution
!i 8 ll which was the subject of several of the exhibits, the one il 9 i that you responded to -- I forget who it was -- the i
10 rejection of Mr. Parks' comments of March 1st. At that 11 l time, approximately March 1st, when you say that your other i 12 March 1st memorandum -- I think it was document number 10, ggg 13 he -- to your mind was that a satisfactory -- was that the 14 ! point at which you felt that Mr. Parks' comments were
- i 15 ]properlyresolved?
16 I A You mean all of his comments in the previous l 17 ; memo? J 18 j Q That's right. The comment resolution that was i 1 19 i initiated on February 17th, in which you commented on the i i l 20 ;i recovery operations resolutions of them on March 1st. Did i l 21 you feel that the resolution as of March 1st of his j 22 complaints was more or less satisfactory for your purposes? s 23 MR. RICHARDSON: Is the question that by the end l
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24 ; of March 1, did the witness feel that Mr. Parks' February ! 25 17th comments had been more or less satisfied? ACE-FEDERAL REPORTERS, INC. i mm x- c_ ~~ i
29049.0 , 80 tayloe l ( l MR. JOHNSON: Resolved, yes. Resolved to your i 2 i satisfaction. ; I I 3 l THE WITNESS: All of them? I don't know that I t
- 4 I looked at all of them. I know the one concerning the admin l
I
. 5 procedures went a long way to resolving a lot of those 6 comments. I didn't look at all of the specific comments to 7 see what was specifically still outstanding and what was 8 ,
not. 9 On the other hand, though, the resolution of -- 10 getting the APs agreed to I thought went a long way to 11 , resolving a lot of the discrepancies we had with the Polar i 12 Crane, because it put us back into a mode where we were 13 operating under our procedures. [} 14 i BY MR. JOHNSON: l 15 g 0 So it was your belief that the most significant il 16 elements of that comment resolution had been taken care of 17 at that point? 18 I A In terms of the admin procedures, that's correct. 19 O Did you communicate to Mr. Parks this belief on i 20 0 March 1st when you wrote this memorandum; that is, 1 21 i memorandum number 10. i 22 J A Well, I don't know that I gave him a copy of the 1' 23 memo. l 24 , O Did you inform him that you believed at that 1 25 j point his concerns with respect to AP 1043 and AP 1047 () ! 1 : l j ACE-FEDERAL REPORTERS, INC. ! 3 - s_ m c- ~~ i g _ _ _ _ _ - _ - _ _ _ _ _ _ _ - _ _ - _ -
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) 1 being applicable had been satisfactorily resolved in your l 2 i mind? ,
3 A I don't recall. I'm sure I did. I know I felt
. 4 l that way.
. 5 ; O Did he feel that way at that time?
. J 6 l A I don't have any indication that he did not.
1 7 O Did Mr. Parks on that day inform you that he
]
1 8 ' agreed with your memorandum? d 9 MR. HICKEY: Number 10? 10 h THE WITNESS: Wait a minute. Mr. Parks is ( i 11 h working for me. Mr. Parks doesn't agree with my
?
12 ! memorandums. (')
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13 MR. JOHNSON: I see. OKay. 14 l MR. HICKEY: Can I interrupt long enough to 15 :', direct the witness' attention to the initials on Exhibit 10, 16 0 1 which would suggest to me that Mr. Parks had some role in , il 17 )preparingthedocument, if you will look at the second page. 18 d "JJC/RP." >
.1 i 19 j THE WITNESS: Yes, definitely. That indicates l 4 i 20 that Mr. Parks had some input into this memo. I can't say 21 how much, but it does indicate he had input into that memo. j
. 22 BY MR. JOHNSON:
23 ! O Were you familiar with the fact that the l 9 : 24 i readiness review committee was convened to deal with the 'i 1 25 safety of the Polar Crane refurbishment program? (1) .. 1 d l l ACE-FEDERAL REPORTERS, INC. x-n ~ _ - - 8nn- y!
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29049.0 > 82 I l tayloe ( ) k- 1 A I was familiar, yes, with the fact that there
" 1 2 ! was a readiness review committee established in their i
r J 3 l charter. Mr. Arnold, I believe it was. 4 0 And was that something that had been part of the i 1
. 5 schedule prior to, say, the initiation of the comment 6 resolution by Mr. Parks on February 17th?
}
7 A I don't know when that readiness review 8 8 [ committee came into being. 9 0 But it was done on an ad hoc basis -- it was 10 called into -- it was convened for the specific purpose at 11 some point in that period of dealing with the safety of the 12 j' Polar Crane refurbishment? {} 13 l I A Yes. 14 0 Was the readiness review committee convened at 15 bleast in part because of the comments raised by site l 16 ; operations? 4 17 !! MR. HICKEY: Are you referring specifically to l l 18 l Mr. Parks' February 17th comments? 19 E MR. JOHNSON: Particularly Mr. Parks comments 0 20 1 and in the weekly report referred to before, number 16, 1 21 0 that there had been comments causing delay in the schedule. l' 22 l MR. RICHARDSON: Objection. There is no 23 foundation as to whether their witness was part of the
]3 24 decision-making process which led to the readiness review 25 3 meeting. J (1) l
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;v- '1-d committee. I vaguely. remember that.
'2 ! O You mean when it was actually convened on March 3 12th? You mean when it actually had its review session and:
- '4 the. presentation was made? Is that what you mean?
. 5 A' No.
6 0 I'm sorry. 1 7 :A I was at a meeting where'Mr. Arnold explained to 8 whoever all was at that meeting that he would -- he was 9 directing that a readiness review committee be established 10 to investigate this. I don't know exactly when that was. 11 0 Do you recall what he said the reason was for-12 convening the readiness review committee? 13 A No, not really. 14 0- To the best of your recollection what do you 15 believe it to have been? 16 l A I think it was based on the fact that there were l P l 17 l i so many problems in the whole -- the whole Polar Crane 18 [ refurbishment was such a problem area that he felt to be l 19 labsolutelycertainthatallconcernsandallsafety
- l. 20 problems, issues, et cetera, were in fact resolved before ,
j. 21 jj we did anything with that Polar Crane, that he had a q 22 j, responsibility to ensure that happened, and he felt the
- 23 best method to do that was to devise and come up with a l
24 committee tasked with that specific function.
)
25 i MR. HICKEY: I would like to ask whether the , O 1 l f , I i n ACE-FEDERAL REPORTERS, INC. 1l .m, s _ m c- m,_
s y , t ' c. !j 85 ;l 29049.0 l ' tayloe ; , i tm i k-) I b witness' tectimony reflects his recollection of what he 2 ll heard Mr. Arnold say or his opinion about what he thinks 3 lMr.Arnoldwas thinking. Because his answer wasn't clear. i 4 THE WITNESS: 'No. It was my impression of what j ,
. 5 .! Mr. Arnold had explained at that taeeting. Py W
6 1 MR. JOHNSON: Thank ybu. 1 0 7 THE WITNESS: It is def-f.nitely not verbatim. 8 ll BY MR. JOHNSON: 1 9 0 And once the readiness review committee found 1 10 l the Polar Crane program to be acceptable, then the testing 11 could go forward, assuming other reviews, NRC approval, et ' r 12 li cetera -- p (} 13 ! A Yes, right. > 14 0 Do you recall when the readin6rs revtew f 15 committee met? , ll 16 A No, i don't. ,
] '
i 17 0 Does March 12th sound right to you? l [l 1 l 18 , A I have no idea. ,, , s
; ,t 19 , 0 Once it"did meet and reach,the conclusion that "1 l !
20 j the Polar Crane refurbishment 3rogram was acceptable, was > l' j 21 k satisfactory, manLgament was quite anxious to mera ehead 22 )) with it, with the test; is that not correct? ( 23 :j MR. RICliARDSON: Objection.' , 24 MR. HICKEY: I object to the form of the f 25 question. My goodness, your question says r#at managemeat (Z) , f
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(M l l (J l } -- undefined -- was quite anxious -- undefined -- to move l I 2 ] ahead; and you haven't asked the witness whether he had any j 1 3 discussions about it.or had anv information or any
~ . 4 f memorandum. I really don't think that is a fair question. . 5 MR. JOHUSON: LOkgy.' . 9 6 l BY MR. JOHNSON:
l 7 0 You had a meeting with Mr. Barton on March 10th. lO You said'one of the subjects 8
] We talked about it before.
y 9 ll was your involvement with Quiltec. I 10 In your deposition with Mr. Stier back in August i 11 of 1983 you referred to that discussion, and I'll direct , l
!j t'
12 4 you to the page in that document. Just a second. Let tre. . i . 33 find my notes. t , 'I' 14 : MR. HICKEY: Are you looking for a page a 15 h reference? h) I was looking for my notes. 16 MR. JOHNSON: No. it 17 BY MR. JOHNSON: 18 j Q On page 66. i i 19 And then on page 71, on line 5.,you were giving-l 20 an answer to a question, and the question was, "That is l i 21
)that Barton asked what Parks was doing going to the NRC?
I
- 22 ] "Yes, that is totally incorrect. Let me just l
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. 23 explain that." j i
24 , Do you have that portion of the deposit..'on? ; i ! 25 l A Yes, I do, I i i ACE-FEDERAL REPORTERS, INC. 3 - -, ,_-- sm_ i
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49 l f
,k 1 A If I recall properly I wrote the cover letter 2 l and Rick Parks did the necessary digging to get the ,
'l 3 . information on the attachments. !
i ! 4 MR. HICKEY: The witness doesn't have the !
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5 document in front of'him. You might want to point his 6 $, attention to the~ initials at the bottom of the cover memo, { p 7 { which say JJC/RP/, and then I guess the secretary's 8 initials.
? I don't know whether that throws any light on 10 ) who wrote the cover memo or not, l }. THE WITNESS: Let me just briefly explain this: j
- . >4 12 l We .go back to the previous document where we talk about 13 f1047andsom'ecitharproceduresapplicability.
It was my I ; 0 1< lcotentionfcomthestartofthisthing that those things 15 in ' f a c t. apply, {ldid 16 l BY MR. JOHNSON: 17 : O Excuse me. Did? 18 A Did in fact apply. As a matter of fact, I had l 19 l been working with Parks on trying to resolve this problem. I l 20 Neither Larry King nor Rick Parks had enough experience at 21 ll the Island to even know what the 1047 was and some of these 1
!i l 22 0 other procedures, but I had been on the Island for quite N
23 awhile and I knew our procedural control system and 24 , there.fbre I was very instrumental in providing the
,I 25 j background for this type of thing. Rick Parks was our site ;
q i
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29049.0 $] 50 tayloe gm 1 a] operations representative and Rick did a lot of the digging k-] i 2 l out of material. That's what I say: I told Rick where to l 3 ! go and he got the information to compile the attachments. i 4 d Q This memorandum purports to be a site operations
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5 hpositiononthePolarCraneloadtestprocedurebyyou
' !l , 6 [ acting as director of site operations; that is correct, 7
(3 isn't it? 8 A Yes. p 9 q Q And as it states here, and as you just stated, 10 it is your position that AP 1047 applied to the procedure? 1 11 [ A Yes. I remember talking to Blain Ballard about l 12 li i that specific subject, and that is included in the cover 13 I memo. (~ (_) 14 0 I'm going to show you another document entitled a 15 " Site Operations Problem Report," dated 2/28/83, and it
.I 16 y contains statements related to -- well, I'll read the n
17 3 problem section. , I I 18 d It says, "On 2/28/83 a meetir.g was held to j il 19 ) determine required presentations for the readiness review j 20 'i committee. This meeting resulted in site ops receiving two 4 21 U action items (see attached) It should be noted that site 3 . ! 22 hOPsattendancewasnot requested. The meeting was found d i out about through a casual conversation with one of the f) I 23 l 1 3 i
. 24 1 required attendees." i a l1 25 I believe that this part of the -- the top part ; J O 1 4
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29049.0 51 tayloe d j (} l , of this report is written by Mr. Parks, and in the section 2 that follows it says "Further action required:" It says, 3 ; " Request site operations attendance at all meetings
. 4 involving site operations personnel and/or equipment inside 5 ; the protected area that is a part of the permanent plant,"
6 signed by you on 2/28/83, and then it says in the section (; 7 ]belowthat, " Additional action taken: Copy of PR," and I i 8 j assume that means problem report, "Sent to J. Thiesing, 9 > requesting recovery programs notify the site operations t I 10 i director of all meetings described above," and that is also l 11 j signed by you and the same date. i 12 I'm going to mark this as Chwastyk Deposition 13 Exhibit Number 9 for identification. /'T i
# (Chwastyk Deposition Exhibit 9 identified.)
14 ! I 15 ! BY MR. JOHNSON: i 16 ; O I'll show it to you. 4 17 l A Do you want me to read this? J I 18 ; O I don't think it is necessary. I just want you N 19 to verify that you in fact -- as far as you can tell, or as 20 J far as you can recall, the first part was s.#.tten -- the 21 top half was written by Mr. Parks and the bottom half was 22 written by yourself?
\\ l 23 i MR. MC BRIDE: The top half and bottom half we
't 24 I, are referring to of page l?
'l 25 MR. JOHNSON: Of the first page, right, of the l l
() ,l l l 4 5
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29049.0 9 52 tayloe j 1 r 1 site operations problem report. 2 j THE WITNESS: I can't verify that, no. You know, i 1 3 ]I'mnot that familiar with Parks' handwriting to say that s 4 q is Parks' handwriting. 5 p! MR. JOHNSON: But that is your signature at the d
. 1
- 6 fbottom?
e 7 h THE WITNESS: Yes, that is mine, p 8 i MR. JOHNSON: Okay. 9 ll BY MR. JOHNSON: I s 10 i 0 Now, this is another document that appears to be L 11 [ prepared by yourself or at least signed by you, and this 3 12 f one is another interoffice memorandum, 4200-83-105, dated 13 l March 1, 1983, subject applicability of AP 1047/1043 to ( 14 ! Polar Crane test program, and it is to E. Kitler, l l 15 K-i-t-1-e-r, startup and test supervisor, and it is signed 16 by yourself, Mr. Chwastyk, and it appears to -- it relates, d 17 l as the subject indicates, to the position of site i 18 j operations, that the Polar Crane refurbishment program had l V I 19 , to comply with AP 1043 and AP 1047 and suggests four points i I 20 i for resolving the concerns that you were expressing i i 21 j concerning the application of those procedures, and j i i 22 , Mr. Parks had raised in his comment resolution of February l I l 23 ;i 17th, and as to which you disagreed with the resolution by 24 i your March 1st memorandum that we went over just a second ! 25 , ago. ; i () I ACE-FEDERAL REPORTERS, INC.
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l 29049.0 53 l tayloe l l i I 1 l And I'll mark this as Chwastyk Deposition ('",)e 2 h Exhibit Number 10 for identification. 3 (Chwastyk Deposition Exhibit 10 identified.) 4 I BY MR. JOHNSON: 5 O I'll show it to you. l 6 ! A I'm not sure that the characterization you just 7 gave this memo is correct. 8 l 0 Would you care to characterize it? 9 l A Basically this memo was written after everyone 10 f agreed that they in fact did apply to the Polar Crane, and 11 l this memo was -- the purpose of this memo was to identify i 12 i to Mr. Kitler, who was the startup and test supervisor, and 13 j also the chairman of the test working group, some possible (" i 14 ! resolutions as a result of perhaps previously not following i 15 l these procedures. 16 O I see.
]1 17 j Mr. Chwastyk, toward the end of the first 18 Y j paragraph it does say subsequent to this meeting, which is I
ll 19 1 a reference back to the February 23rd, 1983 meeting, which l' I
- l 20 ] was held in Mr. Kanga's office, and which site operations j' I
i 21 il expressed its belief that these procedures applied, and ll l 22 ; back to the memo, it says, " Test working group was convened 23 on February 25, 1983, to review and discuss the necessary 24 methods for ensuring the testing performed to date and any 25 ] future testing complies with AP 1047 requirements. It ! j ! (:) ' i t
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- 1. 1 would be to the best interest of all-involved if the 1
j 2 i i
' following suggestions were implemented to resolve the j 1
3 existing concerns." ; 4 At the time that'you wrote this'memorand'um -- l . 5 youcare the author of this meiuorandum that I'm referring to? 6 A I'm the signatory, whatever that is... 7 0 Are you the author of it? 8 A Yeah, to some degree. I' notice there is an RP i
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9 there for Rick Parks,.so apparently he had some input. j 10 0 Okay. At that time did.you have the agreement. 11' of Mr. Kitler'as startup and test supervisor and other l 12 management in recovery operations that' procedure'AP 1043 and AP 1047 applied to the Polar Crane refurbishment h 13 14 l program? 15 l A Yes,.I believe I did, and that was the purpose, 16 you know, was to provide or suggest a means to backtrack i 17 l previous work done. Il 18 - 0 I would like you, then, to explain to me, if it 19 had already been agreed'to by everyone that AP 1047 and AP 20 f 1043 applied, then why did you write this memorandum on the d 21 !! same date, which we identified as Chwastyk Deposition f 22 ! Exhibit 8, March 1, 1983, the same date, to Mr. Lake, L 23 [ manager of recovery operations, in which you indicated that 24 > site operations disagreed with the comment resolution -- 1 25 j now, that refers back to the February 28th resolution of O 1 . 1
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(:) 1 Mr. Radbill, saying that AP 1047 does not apply since this 2 is a construction test, and other similar comments saying i 3 that AP 1047 did not apply -- why did you write this other 4 ] memorandum expressing your disagreement with the resolution 4
,- 5 y if in fact recovery operations agreed with your position on 1
6 : that date? I 7 ! A Apparently because that memo was written at the I 8 ) time they didn't agree with it and the second memo was 9 4] written after they agreed with it. E 10 0 So are you saying that the expression of k 11 1; disagreement was written on March 1st at a time which they
!I 12 ' disagreed, and at some time on March 1st they came to agree
() 13 , and then you wrote this other memorandum expressing that to 14 k Mr. Kitler? 15 ) A Yes. 3 16 l MR. HICKEY: I don't understand what you just 17 1 said. 18 ' MR. RICHARDSON: Maybe it would be helpful to l 19 have the two memoranda in front of the witness. , i 20 . MR. JOHNSON: He seems to understand it. ; 21 d THE WITNESS: I understand it, yeah. 22 j MR. JOHNSON: This is the comment resolution 23 i itself. I ! 24 ' MR. HICKEY: I expressed some confusion on the 1 25 basis of Mr. Johnson's question, and the part of it that (:) ,
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il L29049.0- !i 56 tsyloe E 1 i was confusing to me was that I understood him to be saying 2 that the disagreements that were expressed were expressed 3 on March 1, but I. thought he.was referring to the recovery 4 program's' disagreements, f
'5 ' j THE' WITNESS: No. I think I un6erstood that --
6 MR. HICKEY: .Is there.a question that'you are
'7 looking for an answer to now? Are we just looking at the 8 document?
9 MR. JOHNSON: No. It is just your comments. 10 MR. HICKEY: Okay. 11 MR. MC BRIDE: I want to make sure that the 12 witness understood the question that he was asked.
.(} 13 Did you answer the question as you still 14 understand it, Mr. Chwastyk, or not?
l 15 THE WITNESS: Let me just reiterate so that I'm 16 on board with what everybody else is thinking. I believe 17 l your question was how did this memo come about where I 18 l expressed disagreement with their resolution and then on 19 the same date come out with a memo that says, okay, we have 20 resolved the problem, now, here are some suggestions on how 21 l to correct the problem now, how they came out on the same 22 date; and my response was between the time that this memo 23 was written and the time this memo was written the group of l 24 3 people had agreed that 1047 and 10,'whatever the other 9 25 procedure is, is applicable. () i q !, c
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1 MR. MC BRIDE: By the two memos that are l 2 ( referred to in the prior answer, the record should reflect i 3 ) that the witness was referring to Deposition Exhibits 8 and
. 4 4 l 10.
I
. 5
}
BY MR. JOHNSON: il 6 d O So what you are saying is that at the time you
?
7 h wrote the memorandum which is indicated as Exhibit 10, that 8 I Mr. Kitler and Mr. Lake had agreed that procedures AP 1043 t
) and 1047 applied to the Polar Crane refurb#shment program?
10 j fl A .I can't say what Mr. Kitler and Mr. Lake agreed 11 ! to. I'know that manaaement decided that those procedures 12 'i didn't in fact apply and Mr. Lake and Mr. Kitler would be (} 13 responsible to comply with those procedures. 14 s Q When you say " management," who made that 15 ; decision? 16 A Specifically I know Blain Ballard was involved. ! 17 )I think Mr. Kanga was involved and a few other people were i 18 ' there. n 19 ' O Mr. Ballard was with QA? 20 A Yes. a 21 i O And Mr. Kanga was the director of TMI 2? J J 22 < A Yes. 23 j The reason I remember the second memo that you l 1 i 24 i refer to, the one to Kitler and myself, that was written in i i 25 the framework of appeasement, if you will, and by that I 1 C:) 4 1 ACE-FEDERAL REPORTERS, INC. .
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i 29049.0 58 i i tayloe O 1 mean their contention up until this point was that their 2 . procedure did not apply, and our contention was that they ! 3 in fact did apply, and we basically won the battle. 4 0 The "they" is who now? Who is the "they" that
. 5 you just referred to? "They" said? You mean recovery 6 l operations?
I 7 l A Yeah. Whoever some of these people are that Il 8 i those memos are addressed to. l 9 O okay. 10 A One of the things that I wanted to get out was 11 the fact that we are working with these people, and that 12 { was the reason behind that second memo that same date. It 13 did not only show that we could identify problems but we ({} 14 could also help them in their resolutions. 15 I would like to just state for the record the li 16 ll fact that they are on the same date is no real big thing. 11 17 ]I can rap those things out pretty quick.
?
18 q 0 obviously you could. But up until March 1st 19 j they had -- at some point on March 1st those individuals -- 20 ] the key individuals had not agreed that AP 1047 and 1043 l 21 applied to the Polar Crane refurbishment? 22 MR. HICKEY: You are talking about the key 23 ( people? 24 MR. JOHNSON: The individuals he referred to. 1 25 j Mr. Kanga and Mr. Radbill, Mr. Lake, Mr. Kitler. l (2) .
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29049.0 59 l tayloe () 1 THE WITNESS: I don't know that I could say 2 Mr. Kanga. This is more of an interdepartmental 3 i disagreement. So I don't know if Mr. Kanga and Mr. Barton l 4 -- how much they were aware of this disagreement, except 5 that I'm sure they were cc'd on quite a few of these memos. 6 [j BY MR. JOHNSON: 7 I O So you would say it was more likely to be at the 8 level of Mr. Kitler and Mr. Buchanan? 9 l A Mr. Lake, yeah, people like that, definitely. 10 I'm sure that Kanga and Barton were aware that there was i 11 some disagreement here. I just don't know how much l 12 awareness they had of the actual specific problem. 13 0 I was just interested in establishing that there 14 ! was some kind of agreement or change of position reached on
!)
15 (March 1st? 16 A Yes, that's correct. 17 0 Okay. That's what I wac trying to establish. l 18 a MR. HICKEY: Let me just interrupt one minute.
]
19 l I'm sure you don't mean to do this. None of us have the 20 documents in front of us except you, and I have a 21 d recollection that the document that you showed the witness 22 i referred to a meeting on February 25, which according to 23 the memoranda it says that agreement was reached. Now, you 24 i have just characterized it as being agreement that was j 25 1 reached on March 1. Perhaps you might want to direct the r~ i
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l k 1 witness to that language, if my memory is right. !
'l l1 2 ,i MR. JOHNSON: I don't think your recollection is 3 correct, although I can't recall anything on February 25th 4 ; that we referred to.
! I 5 P MR. RICHARDSON: You read from Exhibit 10, the l 1
6 sentence beginning " Subsequent to this meeting." It refers 7 l to a meeting on February 25th. ll I will read this portion 8 " MR. JOHNSON: Okay. i i 9 l again. I 10 h MR. HICKEY: May I see the document just a 11 moment, please? 12 MR. JOHNSON: Sure. I I') V 13 I MR. HICKEY: Could I see 8 and 9, also? 14 MR. JOHNSON: That is 8 and this is 9. 15 l MR. HICKEY: I may have given you the wrong y 16 y exhibit number when I was talking about my recollection, V 17 ] but I see on Exhibit 8, now that you have made it available, j 18 that on page 2 it says, "A meeting was held with B. Ballard, s 19 K. Thiesing, R. Freemerman, E. Kitler, K. Barton, R. Parks, 20 ) L. King, on 2/23/83 whereby it was determined that AP 1047 l i 21 , did apply to the Polar Crane test program." 22 I understood your questions to be incorporating 23 ) the assumption that the only decision that was made was l 24 ]madeonMarch1,and I'm suggesting that that may not be an 25 l accurate characterization based on just what these exhibits i C:) i ! h l ACE-FEDERAL REPORTERS, INC.
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l 1 z' l 29049.0 61 tayloe t') kJ I 1 i say, and that maybe the witness can throw some light on it t i 2 ]1 and maybe he can't. But I'm not agreeing with your 1 3 j characterization of the documents.
. i 4 BY MR. JOHNSON:
5
] Q Did this comment resolution which refers to the
?
meeting of 2/23/83, where it says "whereby it was 6 7 determined that AP 1047 did apply to the Polar Crane test ll i 8 program," did that represent the opinions of the people 9 l represented in that list, Mr. Thiesing, Mr. Freemerman, I 10 i Mr. Kitler, Mr. Barton, as well as Mr. Parks and Mr. King f 11 l at that time? i 12 I MR. HICKEY: You don't want to ask him if he was I . () 13 l at the meeting, do you? 14 il Perhaps we would have some better basis for g 1 15 > asking the question. I 16 MR. RICHARDSON: While the witness is studying 17 )thedocument, would you read the question back, please. 18 (The reporter read the record as requested.) ! l 19 THE WITNESS: May I see that other memo dated 9 20 l, March 1st? ll 21 ) MR. JOHNSON: Here is one. I think you have the 1 22 other one in front of you. 23 MR. RICHARDSON: Do we also have Exhibit 7? 24 i I'm a little bit confused with the dates we are i 25 throwing around. We have this reference to a meeting on i i 4
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tayloe ] P 1 i February 23, 1983; we have recovery operations' response to 1 2 Mr. Parks' comments dated February 25, 1983. 3 , BY MR. JOHNSON: I
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4 i O Mr. Chwastyk, did you attend the meeting that is l
. 5 l referred to on 2/23/837 l l .
6 : A I recall a meeting. Whether that was the date 7 or not, I'm not certain. 8 0 And what was the purpose of that meeting? l 9 l A The purpose of that meeting was to discuss the l 10 ! applicability of 1043 and 1047. 11 O And did site operations go into that meeting 12 I with -- strike that. i 13 At that meeting did in fact Mr. Thiesing, i 14 Mr. Freemerman, Mr. Kitler and Mr. Barton agree, as it says l, 15 l here, that AP 1047 applied to the Polar Crane? 16 j MR. RICHARDSON: The question is a bit ambiguous. H 17 ; Are you asking whether each of those gentlemen expressed 18 h agreement or whether in their minds they were agreeing with !
;i i 19 y a conclusion? In which case it calls for speculation. l
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l 20 MR. JOHNSON: Mr. Chwastyk sent this memorandum j l ll 1 : If he's not the author of these words, then he
] himself.
i 21 22 certainly reviewed them before they were transmitted, and i 23 ] I'm asking him whether there is a question about whether I
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24 i that is what that means. 1 25 1 MR. RICHARDSON: I'm partly the culprit. When c 1 ACE-FEDERAL REPORTERS, INC.
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0 1 l ' .([) 1 j you say "that," what does that refer to? e
'2 I MR. JOHNSON: The statement that we are talking i'
3 about on page.-- on the second page of Exhibit 8, which L4 .happens to be comment number 2, resolution. AP 1047 does
- 5 j apply to the circumstances of this memorandum. PerhapsLthe 6 l confusion'is the fact that March 1st Mr. Chwastyk has sent 7 a memorandum expressing continuation of the site operation's-8 q position on the applicability of AP 1047 to the Polar Crane 9 i load test and the disagreement with the resolution which-l 10 ! was dated'-- transmitted to them on the 28th of February, l
11 l and one of the points that is being made in Mr. Chwastyk's i 12 response was we disagree with your resolution which states 13 that AP 1047 does not apply because we think it does apply, (]) ; 14 and in fact at a meeting -- a meeting was held on the 23rd 15 , of February whereby it was determined he -- and I'm asking W' 16 j Mr. Chwastyk a simple question, but I've had only comments 17 from lawyers, and I would like to be able to get an answer i ' 18 - from him -- whether this statement in fact says or means J 19 Y that these individuals, Thiesing, Freemerman, Kitler and 20 ) Barton, in fact agreed. 21 I would submit to you it doesn't say they agreed. 22 What it says is a meeting was held with them whereby it was 23 determined that AP 1047 does not apply. Did that term 24 ) refer to Mr. Ballard's determination, for example, or QA ! 3 25 R determination, or site operations determination, or did it (2) I l! s 1 9
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( l j in fact refer to a determination by these individuals? i 2 l THE WITNESS: I don't know whether I can answer f 3 ) that.
.' 4 BY MR. JOHNSON:
5 O Isn't it reasonable to draw a conclusion from 6 i that memorandum in conjunction with your March 1st l 7 I memorandum that in fact Mr. Thiesing, Mr. Barton, I I 8 i Mr. Freemerman and Mr. Kitler from recovery operations -- l 9 I well, Mr. Barton was not with recovery operations, but the 10 ; people who were -- didn't necessarily express agreement and i 11 l in fact they did not agree at that meeting that AP 1047 12 j applied? I 13 MR. MC BRIDE: I object to the form of the 14 question as unreasonable to draw a conclusion. 15 ll M R ., JOHNSON: I'll rephrase it. v 16 ;I BY MR. JOHNSON: 3 17 0 0 Did in fact Mr. Barton, Mr. Freemerman, ll 18 1 Mr. Kitler or Mr. King say at that meeting that they agreed ; 19 j that AP 1047 applied? That is a simple question. You were i 20 g there. 21 A Not that I can recall, no. l
- 22 ] O And based on this document do you draw that
{ . 23 y conclusion, that that is what this is saying?
- 1 24 ) A No, t
25 l O I'm referring to your March 1st memorandum. l C) l l fI 1 i ACE-FEDERAL REPORTERS, INC. , l W347-3700 Naaonwide Coserage S$3.1644 l
i 29049.0 ' 65 tayloe O' -1 l Your answer is no? L 2 . A Can you ask that question again? l 3 i O All I'm saying is,' you'are'not saying there in i 4 that statement, comment resolution on page 2.of that March
,- 5 1st document, that those individuals were agreeing that AP-t 6 l 1047 applied;.you are just saying.that it was' determined at 7 that meeting' by some' person or somebody'that it applied; 8 isn't.that correct? i 9 A That's correct. ;
10 0 That's all I wanted to verify. I think if we 11 could keep the comments.to as few as' reasonable it would'be 12 helpful. h 13 So in fact on February 23rd Mr. Ballard did send 14 a memorandum to Mr. Kanga concerning this same matter, in 15 which he says for quality assurance, because he's manager 16 of TMI quality assurance, modifications / operations, that 17 ! he's going to look into this question, and whether AP 1047 i 18 {hasbeencompliedwith, and report to Mr. Kanga, and I will i 19 l' show you this interoffice memorandum. It is number ' 1 20 ; 61-10-83-039, dated February 23rd, 1983, subject, Polar
. 21 ! Crane safety evaluation, to B.K. Kanga, director, Unit 2, 22 from Blain E. Ballard.
, 23 l MR. MC BRIDE: Mr. Johnson, if you have a 24 ]problemwithkeepingcommentstotheminimum, then I'm j 25 .
going to make the same observation about your questions. j O. . 1 : 1 i n i i k l' [ ACE-FEDERAL REPORTERS, INC. [
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l 1 l 29049.0 . 66 ! tayloe j l !I r' I! (%/ 1 l I've been listening to a lot of characterizations about 2 memoranda here this morning. I think things would move 3 faster if we showed the witness the memoranda and ask him 4 the questions rather than prefacing the questions with your
. 5 characterization of the memoranda.
6 l MR. JOHNSON: I'm going to mark this number 11. 7 l1 I'm not interested in lawyer's characterization 8 here. I would agree with that. I'm interested in your g! 9 r) testimony. 10 I wholeheartedly subscribe to your comment. l 11 ! (Chwastyk Deposition Exhibit 11 identified.) l 12 l MR. JOHNSON: I'm marking for identification l 13 Chwastyk Deposition Exhibit Number 11. This is IOM
}
14 l 611083039. It is covered actually by another memorandum of j 15 [ March 4th from Larson to Barrett in this particular version.
)
16 3 MR. MC BRIDE: May I ask, Mr. Johnson, whether il 17 !! this memorandum is part of the Stier report? s i 18 MR. JOHNSON: If you will give it back to me a 19 !! I'll look. ll 20 MR. MC BRIDE: Let's let the witness review it. ; 21 h BY MR. JOHNSON: 22 d 0 would you characterize this memorandum as 23 n expressing a decision by OA as to whether AP 1043 and AP
- l 24 jl 1047 applied to the Polar Crane load test procedure? I n :
25 l A Yes, I would. f i ! (E) 1 i I a i l ACE-FEDERAL REPORTERS, INC. l n .nn ~ ~- r- 8u- ,
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0 And that being what? i I 2 ; A They say that they are going to verify that the 3 provisions of those two procedures are complied with. 4 0 And does it indicate that recovery operations
. 5 agreed with that position?
i ! 6 ! A Not that I can recall. I would have to look at I I 7 l it again. I l 8 i Without studying it, I don't see anything in
! l 9
l here about recovery operations agreeing or disagreeing. i 10 1 0 Thank you. I' 11 MR. MC BRIDE: Were you able to determine f 12 l whether that was part of the Stier report?
/~ 13 l MR. JOHNSON: I'm sorry.
(T/ i 14 The cover memorandum is a document received by I > 15 l the US NRC on March 7, 1983, at 1:00 p.m. It has a date b 16 y stamp on it. So I assume that its source is an NRC source. I don't know. 17
]/ It may be in the Stier report.
18 h (Discussion off the record.) 19 BY MR. JOHNSON: 20 j 0 I'm going to show you a document dated March 7, i j i 21 1983. It is an IOM again, 4345-83-0005, " Subject, TWG l b 22 ! meeting minutes of March 4, 1983," and it says, " Attached 23 are minutes of the TWG meeting of March 4, 1983, to discuss _ 3 a 4 24 3 Polar Crane issues." It is to a series of people. ! I f 25 0 Buchanan, Clements, Fornicola, Gallagher, Marsden, Parks, ! i C) i
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1 29049.0 68 tayloe . l /G ! !! V' 1 l Radbill, Thiesing, Walker, Warren. [' q 2
] I'm going to mark this as Chwastyk Deposition
;l 3 q Exhibit 12 for identification.
i 4 l (Chwastyk Deposition Exhibit 12 identified.) . I I'
- 5 h MR. JOHNSON: I draw your attention to the d
6 [ comments dealing with AP 1047 on page -- on the second page 7 under -- it actually starts on the first page of the i 8 [ minutes themselves, under the heading: "Results of 0A-0C 9 l audit of Polar Crane task group's documentation of work on l l 10 crane," and also on the last page. 11 , I'm going to show you two other documents, which 12 l is towards the end of this series of documents. The next (] 13 one is " Quality Deficiency Report," and the first page is Its initiator is J.F. Marsden. j 14 l dated 3/8/83. It f.s a i 15 document of three pages with two attachments, each of one l. 1 16 j page. I'm going to mark it Chwastyk Deposition Exhibit 13. 1 17 4 (Chwastyk Deposition Exhibit 13 identified. ) 18 MR. JOHNSON: And another memorandum, IOM, l 19 f 6110-83-046, March 10, 1983, "
Subject:
Polar Crane ! t i 20 ll: refurbishment review to J.W. Thiesing, manager, recovery ; 21 programs, from B.E. Ballard." I'm going to mark that l l ' 22 Chwastyk Deposition Exhibit Number 14. ll 23 (Chwastyk Deposition Exhibit 14 identified.)
, ) j 1 i 24 1 MR. JOHNSON: I'm going to show you one more i1
; i j
25 document, and this is an undated memorandum without a :1 ( .i l v , i
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Subject:
TWG minutes of 2/25/83," and it ! 4 2 j is signed by E.J. Kitler and R.D. Gallagher. It is Stier
! l 3 Document 89. 1 l
. 4
{ THE WITNESS: Is it important I read all these? l
! i 5 '
MR. JOHNSON: Yes. j< 6 Well, I'm going to refer you to specific parts l I l 7 , of them. It's up to you if you want to read them. l 8 This will be Number 15, the next one? ; f I 9 j MR. RICHARDSON: The February 25th meeting? j 10 !! MR. JOHNSON: Yeah. b' 11 0 MR. RICHARDSON: Yes. ,
! i 12 l (Chwastyk Deposition Exhibit 15 identified.)
rw 13 ! THE WITNESS: I wonder if we can hold off until (_) I've just lost all interest in them. 14 i after lunch on these? I 0 l 15 I can't force myself to read all this. j 16 MR. JOHNSON: Why don't we just give them to you [i l 3 17 over lunch to look at. 18 ; THE WITNESS: Okay.
- l 19 i MR. JOHNSON: And then we will start questions l 1
20 3 on them when we come back. l l 21 lI THE WITNESS: That will be fine.
. l 22 ,
MR. JOHNSONe Off the record.
. 23 ] (Discussion off the record.) ,
k l 24 l (Whereupon, at 12:55 p.m., the deposition was ; 1 f 25 ) recessed, to reconvene at 1:45 p.m., this same day.) (1) ! i i 3 ACE-FEDERAL REPORTERS, INC.
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I 29049.0 70 tayloe : i () 1 i AFTERNOON SESSION (1:45 p.m.) 2 i Whereupon, i 3 ! JOSEPH J. CHWASTYK f 4 resumed the stand, and having been previously duly sworn, b 5 0 was examined and testified further as follows: t 6 EXAMINATION (Continued) i 7 MR. RICHARDSON: I want to correct what I said 8 at the outset of the deposition. I am not authorized to 9 j appear in this deposition on behalf of Bechtel North 10 American Power Corporation. I am appearing solely in 11 , association with Mr. Hickey as cocounsel for GPU Nuclear 12 Corporation. l l 13 Bechtel North American Power Corporation is not l 14 a party to this proceeding. 15 i MR. HICKEY: Off the record. l 4 l 16 g (Discussion off the record.) l 4 l 17 ll BY MR. JOHNSON: l >l 18 !I O Mr. Chwastyk, have you had a chance to look at A 19 y the last three documents that I gave to you? il 20 ) A No, I haven't. I glanced at them, but I didn't l I ! l 21 ] get a chance to read them in detail. 1 4
. 22 'l 0 I'll try to expedite our questioning so that we . 23 can complete the deposition in order that you can make your 24 l plane back to the West Coast. '
il l 25 4 A Okay. l (:) l ! t a 1 I
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i > \ 29049.0 -] 71 tayloe l 1 0; Would you turn to the - -I think'it's the third 2 > page of Chwastyk Deposition Exhibit 13, which is the ODR of 3 E March 8th. 4 l A' Uh-huh.
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. 5 ! O And would you note that the corrective action is I
6' j ' signed by, looks like J.H., or J something, Thiesing, on l 7 3/21/83; is that not correct? f 8 ! A That's correct. 9 0 And it makes three points there. The first'two 10 i deal with AP 1043 and 1047 expressly. It says that "For 11 h future tasks,-all modifications and modifications related E 12 ! testing will be performed under the controls established by
- l 13' AP 1043 and AP 1047 respectively. In addition, all 14 l recovery programs personnel responsible to authorize work l
15 activities will be trained in the administrative controls ,
, i 16 delineated in AP 1043 and AP 1047."
17 < And item 2 says "All recovery program 18 procedures" -- 19 L MR. MC BRIDE: Excuse me. I think we could move 20 this along faster if you just refer him to the language, 21 ! which you have done. You don't have to read it into the 22 : record. 23 MR. JOHNSON: Okay. 24 1 BY MR. JOHNSON: l
!l 25 ;! O Are you aware of any formal response that [
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a i 29049.0 ! 72 l' tayloe , l () 1 9 recovery operations agreed with yours and Mr. Parks' 2 !! position about the applicability of AP 1043 and AP 1047 1 3 ;; with respect to the Polar Crane modifications before that h
- 4 fdate, 3/21/83?
II
, 5 ) MR. RICHARDSON: Could you read that.
6 1 (The reporter read the record as requested.) 7 ; MR. RICHARDSON: By " formal response," are you F 8 referring to just any memorandum, or a formal response to a I 9 ! OA action? l 10 l BY MR. JOHNSON: 0 11 p O Mr. Chwastyk, do you understand the question? 12 ! A No, I don't, because I have the same problem, 13 formal response. I could look at my memo dated Chwastyk
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14 b Number 10 there as being an indication that there was some 15 [ kind of response that 1043 and 1047 were accepted as 1 16 t controlling documents, and the date on that is March 1, 17 q 1983. 18 O That is a document written by yourself, however, i l 19 is it not? l 20 j A Yes. 21 ,j 0 Are you aware of any memorandum to yourself or i 22 j to Mr. Parks or any other document that was sent from 23 recovery operations to you as the acting director of site l
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i l 24 j operations? l f 25 l MR. RICHARDSON: Excuse me. I think it is still i l (:) l
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l 29049.0 73 tayloe l n 't) 1 ambiguous. If some representatives of recovery operations -- 2 do you include that in the question? For example, TWG 3 q meetings, are they within the scope of your question? Or 4 ; .are you only referring to a memorandum -- l 5 l MR. JOHNSON: I'm asking a simple question. I 1 6 / asked him whether he received any documents, and I would 7 like to get an answer from him rather than a question from k 8 j you. 9 MR. HICKEY: You can ask him whether he was i 10 h aware of any memoranda, and if that is what the question is I 11 !! limited to, then that is fine. d 12 l MR. JOHNSON: I think I should be able to get an {} 13 14 answer from him without getting questions from you. We are trying to move this thing along. L il 15 , THE WITNESS: Can you rephrase the question, or 4 16 J restate the question? 17 BY MR. JOHNSON:
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1 18 j 0 I showed you this response that Mr. Thiesing 1 19 I wrote on this ODR, dated 3/21/83. l 20 j A Yes.
- ! t 21 '! O I wanted to know whether you received, as acting i
22 I director of site operations, any memorandum or other 1 23 .j response from recovery operations which Mr. Thiesing was ,
! l 24 director of -- manager of, before that date, between March jl 25 i ist, particularly, or at any time prior to March 21st, 1983, l 3
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l l 1 i 29049.0 1 74 ! tayloe ; (:) 1 I stating in essence what Mr. Thiesing says there, which is I a 2 1 that AP 1043 and AP 1047 apply to the Polar Crane d 3 q modifications. 4 ! i 4 Y I asked that question 10 minutes ago. We are '
' l 5 trying to move this thing along. I appreciate if you keep l 6 your comments to a minimum, d
7 MR. RICHARDSON: I disagree. The question is f n 8 ll vague and ambiguous. If you are talking about just a u 9 memorandum from one person or organization to another, that 10 is one thing. But we have other documents in which you 11 have several signatories, for example, who represent 12 j several organizations, including recovery operation. e () 13 MR. JOHNSON: If I don't finish today, I will 14 ., try to get Mr. Chwastyk back here, if that is what you i 15 I would like to see. 1 16 1 THE WITNESS: I appreciate everybody's concern s 17 about my getting back, but I think it is just as important j l 1 i 18 that I get done here and we get this thing straightened out. I i 19 You know, if I can't get back, I can't get back. I can j 20 ; take care of that from a personal basis. i 21 i I would like to categorize your question because l 22 ' there was no reason for me to get a memo from Thiesing.
. 23 BY MR. JOHNSON: j i
24 , O Let me just ask you to answer the question first. 25 Then you can give this comment. Did you receive such a ACE-FEDERAL REPORTERS, INC. rm.- m_ c_ x. u-
1 ! n , I I ' 29049.0 ? s 75 l tayloe . ) 1 g i O 1 memorendum2 < l 2 A I reedived no memorandum (o that effect, no; but s j
$ i' 3 q then again, there would be no reason 1 would.
i d i I 4 ll 0 Okay. Now, give me your explanation j 5 A Well, in the chain of conitzand / if$ou dll, that 6 we talked about, the organizational structure, recovery 7 ) operations war or should be shown as parallelN to site i I 0 5; 8 0 operations, and it does, as a matter of feet, on Chwastyk 4 t , i 9 Number 1, third page, it shows Jim Thiesing, m2 nager of 10 recotery programs and site operations director, Larry King, 11 l in parallel reporting to, John Bahton, deputy director. Pio
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12 j this is a quest. ion' of 'canager, recovery Arograms, did they
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13 agree and will they comply with these things? That would' # l j 14 ]havebeenbetweenmanager, recyrerir prograrta v7c . depaty:' I, 15 !; director, TMI-2, any agrecment or me4.*andum nnceniry] . 16 compliance with AP 1043 or AP 1047, [he direction of s';at i 17 memorandum would be from'Ilamger, recovery programs, to l i 18 deputy director of TMI-2,'vice from manager recc:ery 1 ( s s , 19 programs to site operations director. ; 20 0 In any cas'.. you didn't receive anything fro 21 Mr. Thiesing? i ' I 22 A No, I did not. I 23 0 Did you receive anything from Mr. Barton to that l 24 effect? 25 A In terms of a written memorandum? ' O .
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i 29049.0 ; 76 -' tayloe l _) ((^h. 1 0 Yes. 2 .I A Not that I'm aware of, no. 4 49 1 l t > ,. 3 ! O or from Mr. Kanga? l [ 4 A Again, not that I'm aware of. 5 0 During the period between February -- beginning '[ ; l i i! 6 j I of February and the beginning of March,3 did anybody say l]
;q 7 anything to you as a member of site operations, as manager l ]
8 lofplantoperations, and then subsequently as acting site
? l operations director, that the successive rounds of comments l
10 by site operations was causing delay to the schedule for i 11 testing the Polar Crane? 12 A No, not that I'm aware of. I 13 0 Was in fact the rounds of comments that were -}
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14 being made by site operations, such as the comments that 15 j were submitted in the comment resolution of Rick Parks that 4 16 l you had occasion to respond to, the resolutions thereof on P L 17 j March 1s: - ,:as the effect of those comments to delay the { l 18 $ schedule for testing the Polar Crane? d o 19 1 A Was the effect of the comments --
!i 20 j 0 Did the rounds of comments -- in other words, 21 h there were successive revisions cf the Polar Crane test
- 22 l procedure as a result of the comments; is that correct?
- 23 A I would assume so, but, you know, I don't know 24 j that for a fact. i i t 25 l 0 And I'm asking you, did that rasult in the delay $
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J l in the finalization of the procedure as a consequence of l r> I 2 the. test? o , s 3 g A Well, I guess that would depend on your q 1 4 ,i prospective on, y,ou know, what characterizes a delay. As I
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5 ; mentioned earlier, we could have not made these comments
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and just waited at the end and refused to have accepted l 7 l that crane and which would have just basically wasted a lot l 8 ' of time. So rather than do that we decided to make our i ; 9 comments known and try to get them resolved so that we l t 10 l could in fact go on with the program in accordance with i 11 !l witn our procedures and all the other requirements that we 12 have to operate under. So, you know, how do you i (} 13 characterize that? Is that a delay? I don't feel it was a 14 [ delay. 15 0 I'm going to show you a document that has been 16 distributed to you. It is entitled "TMI-2, Polar Crane l n l 17 li. recovery weekly report, number 30, March 4, 1983, weekly i
;1 18 summary," and it is five pages, and it is signed by I f
19 lMr. Radbill, task group leader, and D.M. Lake, manager, '! 20 i recovery operations, and I will mark it Chwastyk Deposition l 21 l Exhibit 16. t
.I 22 j (Chwastyk Deposition Exhibit 16 identified.)
1 23 J BY MR. JOHNSON:
.i 24 i 0 Do you have it there in front of you? j l ,
25 i A Yes, I do.
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1 4 l J i , 29049.0 [ 87 tayloe j lI I l 1 1 O Okay. On line 7 and line 8, you say, "In ) i < 2 addition to obvious problems with King, we had problems 3 with the NRC and supposedly someone going to the NRC with
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4 their perceived problems."
. 5 What did you mean there by "We had problems with 6
l the NRC"? I 7 l A Well, what I meant was that the NRC had been t 8 !j asking some questions that were basically -- I don't know l 1 9 lhowtorespondtothat--thatwerebasicallyin-house i 10 l items that we were doing. That's what I meant by problems. f 11 It seemed like they were asking questions about things -- l 12 i you know, not to say that it was not a fair concern, but it i {} 13 14 ! just didn't seem appropriate for them to be asking about them. l 15 O How did you know they were asking questions? 4 16 i A Because people had told me. u 17 l O Who?
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18 : A I have no idea. l 19 j O Did someone from the NRC approach you with ; i 20 ] questions? l 21 i A Not that I can recall. They may have. 22 , O Do you recall who was the source of this 1 23 ) statement, " Supposedly someone going to the NRC with their 1 24 f perceived problems. Mr. Parks had been acting very strange l I l l 25 ' in a number of ways. I don't even know if I can get into l l CE) i l 1 ACE-FEDERAL REPORTERS, INC. ! E - ----- 1 "" --*"*"** " " ' " " '
1 0 29049.0 1. 88 tayloe j
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/T !I (_) 1 1 them now or not." 2 Would you explain what you meant by the fact 3 i that "Mr. Parks had been acting very strange in a number of
. 4 ways"?
. 5 ; A Well, I think to even respond to this we have to
!i 6 s go back to what the question is about.
7 If I remember correctly, he talks about -- the 8 discussion here was about a certain page of Mr. Parks' 9 affidavit, and I thinn the questioning was about a certain 10 section of that. I don't have that with me. It was 11 something in Mr. Parks' affidavit that I said was totally 12 < incorrect. I 13 0 Okay. What did you mean by "Mr. Parks had been 14 ; acting very strange in a number of ways"? f 15 ] A Well, by that I mean he was nervous, he was 9 16 h having meetings with people that I didn't think were part 3 17 1 of his duties, you know, at least I didn't see them as { i 18 ; being part of his duties; he was taking time off. That n 19 1 sort of thing. 20 0 And later on on that page, line 20, you say, 21 i "One of the things we discussed, and this is with 1
- 22 q Mr. Barton, was the fact that it seemed as if someone was i . 23 j going to the NRC and making complaints or accusations or 24 . whatever."
1 25 A What page are we on? I'm sorry. g-)s (. , 1 i i I ACE-FEDERAL REPORTERS, INC. l 202-ML t7m Nanonwide Cowrage NYi-336We
3 li 1 29049.0 0 89 j tayloe i] 1 0 Same page, page 71, lines 18 through 22. 1 1 ' 2 A Okay. l 3 0 Was it your belief at the time of this March
, 4 l 10th meeting with Mr. Barton that Mr. Parks was the one who lj
. 5 h was going to the NRC? gi ,
. j 6 !! MR. MC BRIDE: Was it his belief at what time?
I 7 l THE WITNESS: On March 10th, when he had the 8 y meeting with Mr. Barton. d 11 9 f BY MR. JOHNSON: 3 10 0 was it your belief that Mr. Parks was the person 11 fwhowasgoingtotheNRCwiththesecomplaintsor 12 haccusationsorwhatever? h 13 A When I was talking to Mr. Barton? gg 14 lli 0 Yes. 15 j A I think it crossed my mind that it may be il 16 q Mr. Parks. l! 17 !! O Well, on the next page, page 72, line 10, you 18 i say "The reason I said that is because I firmly believe I J 19 j that Mr. Parks was in fact going to the NRC based on all 20 the indications that I had at the time." What were the indications that you were ! 21 1 d
- 22 ] referring to there?
i - 23 A I think it is pretty much what I just mentioned 24 l a little while ago. His nervousness, his lack of -- you I i 25 . know, his nervousness, his not being at work, his meetings ! til i ; i ACE-FEDERAL REPORTERS, INC a :c- x_ m_ m_
l- ! 29049.0- 'I 90-tayloes ! 1 and~ discussions about some things that I thought really i weren't that important. 2 3 0 Could you give me an example'of what you mean? 4 Meetings and discussions about some things that.weren't
. 5 important.
6 A Things like rumors, you know, what I would 7 classify as rumors. He seemed to dwell a lot-on rumors:- 8 what is the basis of the rumor, and where did the rumor 9 come from. It's very hard to, you know, say exactly what 10 they were'right now. It was just a feeling that I.had 11 based on a whole bunch of things that had transpired at 12 that time, and to put my finger on it, to say this was that 13 and that was that, I.just can't do that. 14 MR. HICKEY: I take it that is what you are 15 . asking him to do? You are asking him now about 'what he can i 16 ' remember about what he had in mind three years ago when he 17 made the statement to Mr. Stier, is that correct? 18 MR.' JOHNSON: That's correct. a MR. HICKEY: The witness, I gather, is trying to 19 )
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20 $ do that as best he can. 21 MR. JOHNSON: And I appreciate that. i 22 j THE WITNESS: Yes. . 23 MR. JOHNSON: That's the way I understand it. 24 j BY MR. JOHNSON: f 25 O Again, following on there, at lines 12, 14, 15, 0 1 8 k , i
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y i > H l 1 1 29049.0 9 91 tayloe lJ i lh 1 you say "I also felt that he was basically over his head." d 2 1 What did you'mean by that? l , 1 3 ! A What I really meant by that was Rick to me was a jl
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. 4 [ good employee but he had a difficulty in recognizing end I
5 l dates, or endpoints, and I had worked with him quite a lot 1 6 ) over the few months prior to that in not only identifying 4 7 ] actions but identifying endpoints of those actions. By Il 8 Y that I mean, you know, if a problem was developed, I would l 9 j help him -- try to direct him into going to the right 10 places to get the necessary information and then get the 11 ) information and we would sit down and discuss it, and I i 12 q would point out to him, okay, this is what th,is says and 4 13 this is what this means and this is what it should be. 14 My thought there was that he had let himself get l 15 carried away in terms of, you know, a perceived problem 9 16 j that he saw no endpoint on. H 17 ] O On a particular matter? l 18 A I would say the Polar Crane was one. But again, 19 $ specifics, I can't give you something very specific. I l 20 : just felt that he was possibly in over his head in terms of , i ! 21 q the Polar Crane in that he really didn't have the l j
. 22 experience to determine, you know, that a problem was
. 23 I resolved or not resolved or what had to be done to get it 24 . resolved or the proper thing to do to get it resolved and j i
l 25 ! that sort of thing. That's what I meant by that statement. i ACE-FEDERAL REPORTERS, INC. i :o:mm - mec _ y --
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29049.0 j 92 tayloe ! k 1 0 Did it have something to do with your feeling ( 2 that -- this is on March 10th -- that with respect to his l I l 3 ; comment resolution, with respect to the question of whether l i
- 4 l AP 1047 and 1043 applied to the Polar Crane refurbishment . 5 program, did it refer perhaps to your feeling that the 6 endpoint had been reached on that particular point; that 7 the resolution -- OA had gotten involved, the points had 8 been well taken, and that Mr. Parks failed to recognize a
9 [ that he had made his point and the problems that he raised 10 l were being dealt with? Is that part of what you were l 11 ; referring to here? l 12 [ A It very well may be. I don't recall the AP as 13 being one of those specific points, but it is exactly that ggg 14 type of thing. 15 l 0 It is that kind of thing that you are referring 16 , to? d 17 A Yes. 18 ; O And the same thing with respect to, he didn't 1 19 have a firm grasp on what was happening with well enough to i 20 I have a good picture of what was happening, that is, to the l
-l 21 d NRC?
1 22 A Not only to the NRC, but to anybody. You know,
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23 Rick had an ability, you know, to dig, but his abilities l i 24 sort of waned when it came down to, you know, what do you i i tl 25 ) do with the information that he has dug out and how do you i (Il 1
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' tayloe i 1 .get it resolved, and sometimes even' recognizing that it was h 2 I in fact resolved. I' 3 ; I know at one point -- I happen to just remember 4 it because'I'just read it not'too long ago -- the point
. 5 , with -- I'm very good on names'-- electrical' engineer on f
6 l cables or something. That was in one of the documents that 7 I had to read prior to this thing. If I remember correctly, 8 l he had brought up a problem about using some kind of cable-9 and he. thought it was not proper, or something else, some 10 other problem, and I directed him to our engineering group. 11 The engineering group looked into it and decided that in 12 fact it-was all right. You know, Rick was not satisfied,- 13 so we had to sit down and discuss and explain to him why it {]). 14 .was all right -- whatever that cable was being used, was . 15 i okay. 16 MR. MC BRIDE: Does the name Jack ,,tWton mean P. 17 ] anything to you? 18 THE WITNESS: Right, Jack Lawton. I 19 ' BY MR. JOHNSON: 20 !! O Is this an example of that: On February 23rd, , f ! 21 ; there is a memorandum, 43-80-830104. Subject is " Head lift 1 22 . punch list." It is signed by Metzger. At top it says, i 23 " Attached is the punch list for use in the next meeting, 24 j March 1st, '83." 'I il i
. . 25 il The following is a list of notes and commitments i C)
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29049.0- l 94
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l 1 ftaken'inameetingheldFebruary22nd, 1983. One.of the 2 points, 9, says, "The meeting chairman Potts attempted l 3 unsuccessfully to obtain from site operations' Parks
- 4 commitment for use date of the procedure for RC" -- RC as
. 5 . chemistry control and sampling. "RD&D, Smith took the 6 action to contact PORC for projected release or procedure 7 from that group."
8 Is that the kind of thing-that you are referring [ 9 to with respect to Mr. Parks, or is that something else? 10 A Well, if I interpret this -- and I would ) 11 interpret that Parks was there and he wouldn't give.Potts a 3 12 4 commitment date. I guess that could fall into that 13 classification. The reason would be that, you know,' Parks 7 14 q may not'have known how to come up with a commitment date. 15 0 Okay. Going on with the same page, 72, from 16 your deposition of August 4, 1983, you said "I thought that, 17 well, maybe, as his supervisor, that I could sort of help i 18 i him to prevent those problems from getting out of hand. I 19 really thought that he was doing it. He was in over his i 20 i head, really, he didn't know what was going on, what was , 21 l happening." I i
- 22 j What was getting out of hand, or what might get
- 23 out of hand that you are referring to there?
24 I A What I was referring to there was that the fact 25 that Rick had a problem in actually understanding how to O 4 i c 1 1
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l i 29049.0 ' 95 ; i tayloe ; i 1 1 resolve situations, and some times even a problem in 2 recognizing that situations were in fact resolved. I just ! I 3 j felt that he just didn't have enough experience to be able l 3 4 to do that, and therefore, you know, his perception of what ll!
- 5 ) was happening may not be entirely correct, and I had been 1 I 6 ) able, in the past, by sitting down with him, to explain 0
7 some of this to him, a 8 Y 0 Now, this refers back to a conversation that you 9 9 ll were having with Mr. Barton concerning these matters.
!i 10 !! A Yes.
f 11 j 0 Did you say to Mr. Barton that you believed H 12 Il Mr. Parks was going to the NRC? f 13 A No, I don't think I did. ggg 14 O Did Mr. Barton say to you that he thought that 15 Parks was going to the NRC? 16 3] A No, he didn't. , 17 j 0 So he didn't ask you, why is Parks going to the ! 3 l 18 NRC7 ! i 19 j A No: I think that's what started this 20 conversation. l I 21 O Right. It says here in your deposition that you l 22 j firmly believed Parks was going to the NRC. 23 Did you convey this belief to Mr. Barton? 24 i A No, I did not. 25 0 You said, also, that -- on line 2 and 3 that II> ! ACE-FEDERAL REPORTERS, INC. ; i CW@J Naticr. wide Ccaerage Scr L 336-6<4 !
l 29049.0 !' 96 tayloe r's { (_) 1 4 hr. Barton said that the company was not interested in who 2 ' was going to the NRC. He made that clear to me. i 3 A Yes. l
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- 4 0 So the subject of who was going to the NRC and
. 5 whether it was Parks or not was discussed?
6 A No. The fact that someone was, in fact, going 7 to the NRC was discussed. I 8 O But was Parks at.all mentioned? 9 A As a matter of fact, like I said here, I 10 li remember Mr. Barton making a point that the company wasn't 11 really interested in who it was. 12 O But you didn't tell him you thought it was Parks? . 13 A No, I did not.
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14 0 In the deposition that I'm referring to, we're 15 commenting on page 46 and following, the Parks affidavit i 16 dated 3/21/83. 17 , One of the points that is covered on page 47 at h 18 the top, it says "He also recommended I see a lawyer and , 19 hsuggestedoneofthecompanypaidlawyerswhowas 20 i representing the operators in the grand jury investigation." I 21 Did you, in fact, recommend that Mr. Parks see a
- 22 , lawyer?
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- 23 A Yes, I did.
24 0 What was your reason for doing that? 25 : A Because even though he denied that he was going () j I 0 q i ACE-FEDERAL REPORTERS, INC. i] -m> x _mm_. mm 3- __ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ Q
3 290"49. 0 97 tayloe. ; [ M'ug. 1 to the NRC, I still was not convinced. I knew he was-over 2'.i - his head.. I thought he'd better get some counsel because 3 j he was probably going-to need it eventually if he continued I
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5' Let me go back: My objective here he was to try l 6 to help'him out of the situation like some of the 7 situations I had helped him out of before. When he denied-8' j it, there was nothing I could do about it then. 9 0 He' denied what? 10 A He denied going to-the NRC. There was nothing I. 11 could do to help him because he was denying it. What could 12 l I do then? :
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13 0 In your mind at that time what was the problem 14 l that going to the NRC was going to bring upon him? Why did l' 15 he need a lawyer? i 16 h A First of all, I suggested he have a lawyer after s 17 he denied he was going to the NRC. 18 i 0 okay. 19 A But I knew he was doing something that was not 20 right, and I also knew his propensity for just getting 21 ' himself in trouble. You know, I just suggested, well, if I l
- 22 were you I would get an attorney.
23 j When you say he had a propensity for getting J h 0 j
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!I I 25 ti A By that I mean, what we talked about earlier, he O !
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/~) 9 (mj 1 jjust never let go ci a subject, whether the subject was 2 [ resolved or not.
1 3 would always try to continue with that 3 subject.
.' 4 0 When you had your meeting with Mr. Barton on the ll
. 5 ;; 10th, did that question come up, the question of Mr. Parks
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6 f not being able to let go with his objections on the Polar 7 Crane? 8 A I don't recall Mr. Parks being the subject of 9 that conversation, if at all. i 10 l 0 Did you have any other conversations with
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11 i Mr. Barton in which the subject did come up during the i 12 ! period, say, March 1st to March 17th? 13 j MR. HICKEY: The subject being? (^)) 14 MR. JOHNSON: Mr. Parks' problem in letting go 15 of the Polar Crane issue. 16 THE WITNESS: Not that I can remember. But then f 17 j again, I was working with John quite a bit during that time 18 frame. 19 ri BY MR. JOHNSON: d ! 20 1 0 Did anyone, including Mr. Barton, Mr. Thiesing l 1 ! 21 i or Mr. Kanga, in the period between March 1st and, say --
. 22 not including March 17th, but up until that date -- speak . 23 to you, or did you speak to him about the issue of ,
l l 24 ; Mr. Parks' complaints either to the NRC or not being able 1 I 25 I to let go of the issue at all? rs : ! l (_) a i i i 6 1 ACE-FEDERAL REPORTERS, INC. j M 63M-N4 ! 20 3C3'on Nanonwide Cos erage l
O i y 29049.0 j 99 l tayloe 1 ! i 1 A You know, I can't remember anything specifically. I 2 I mean, that is just 15 days. i ; 3 , O Did you have any conversations with Mr. Parks l l
. 4 [ -- you did have, according to his affidavit, a conversation l4 . 5 with him on the 10th and we were just discussing it.
6 ; Did you give him any more advice, other than 7 going to get a lawyer? 8 A You mean on the 10th? 9 0 Yes, on the 10th. Did you suggest to him that
/ maybe he didn't know how to let go and that maybe this i
10 l 11 l thing was getting over his head? i 12 A No, not that I -- getting over his head, I think l 13 we talked something about that. I think I mentioned that 14 , somewhere. But in terms of his not being able to let go, i 15 I j no. 16 We did not discuss it in terms of what I li 17 perceived his problem to be. It was more in terms of he 18 i apparently had a problem and I was trying to find out if I
.i 19 1 could help him.
20 1 0 I'm not sure if I remember your answer correctly.
- i 21 q During this period did you have any discussions
- 22 Y with any of your superiors, who would have been Mr. Barton 23 l and Mr. Kanga, since you were acting site operations t
j 24 I director, those two people would have been your supervisors. i 25 Did you have any discussions during the period e , i i i ACE-FEDERAL REPORTERS, INC.
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l l I 29049.0 100 !; tayloe I l t 1 l (m) 1 ! March 10th to 16th -- I'm sorry -- let's keep it March 10th j, i 2 to 16th -- concerning Mr. Parks? l i 3 l A I really can't answer that. You are asking for ! [
. 4 a specific date, March 10th through 16th or whatever, and i
. 5 i other than reading the documents and looking at time frames 1
6 ! that is the only method I have of bringing something to 7 mind. 8 ! O Do you recall any meetings, without reference to 9 other than this meeting with Mr. Barton, and then
!)adate, !
10 the meeting on the 17th with Mr. Kanga, in which the 11 ! subject of Parks and the problems that you were identifying i 12 here with respect to not letting go were discussed? O 13 l A I vaguely remember talking to Mr. Barton about O ' 14 b Mr. Parks. I can't remember what the subject -- what the 15 l4l tenancy of discussion was. I seem to believe it was post i 16 his public statement, or whatever. Again, I don't really l 17 d recall anything specific about it. 18 0 0 Now, moving on to -- you don't recall any other 19 advice that you gave Mr. Parks on the 10th, other than what 20 you have already said, in terms of getting a lawyer? Do ! 21 you recall anything else about that conversation?
. 22 A No. I would have to look and see what I said j . 23 ,
about it. I don't recall hardly anything about it except ;
- i i
24 j what I read. j l il 25 1 0 Did you say to Mr. Parks that management knew ! O 1
, i s
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l \-) .1 lI that he had gone to the NRC and would get him? l 2 I A No, I don't recall saying that at all. 1 a 3 ll Q Do you recall saying anything about -- you say 4 he thought he ought to get a lawyer because he was over his
. 5 head. Did you feel that he stood in danger of his job at 6 that time?
7 l A I don't think I did. I think I thought more in 1 8 terms of -- I guess maybe I never thought about 9 I consequences, but I did think about what it is going to l 10 j mean to him and other people in terms of getting into I 11 3 situations where, you know, you have everybody looking over [ 12 j your shoulder on what you are doing or what you did, you ; 4
/"3 13 know, that type of thing. I didn't think in terms of %) ;
14 l outcome. I was thinking more in terms of the problems that i 15 l I could foresee. 16 O But you thought something bad might happen to k 17 h him if he didn't -- d 18 i A Like I say, I don't know that I even thought 19 , about the consequences of it. You know, I was thinking i 20 h more in terms of the headaches that I could foresee -- 21 s O He was getting into trouble? ll 22 A Yeah, he was getting into trouble, and I could 23 only see that as being problems for him, problems for me, 24 : problems for everybody. l 25 j Q Okay. Were you aware that on March 14th that I (1) ! l i !
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- 1. Mr. Parks met with Mr. Hoffman and Mr. Wheeler of Bechtel-2 concerning Quiltec?
3 MR. HICKEY: Do you want to give a time on that?
.~ 4 Where'or when?
. 5 MR.-JOHNSON: I think.I said March 14th..
6 BY MR. JOHNSON: l l 7 0 Were you aware contemporaneously? I'm sorry. l l 8 Thank you. 9 l A I guess I was made aware of it at some time. I 10 -don't know when it was. It wasn't at the time of the 11 meeting.- ] l 12 ; O It seems to me that he mentions in his affidavit 13 that.he got a call at 8:00 in the morning that at 10:45 he [ 14 ; was going to have this interview. : I 15 His affidavit says that Ed'Kitler called him. (
'16 But you were vaguely aware that he had met with ,
17 him around that time, if not before? 18 A I don't know when it was. I was aware that he 19 l eventually met with these people. It may have been -- 20 , MR. HICKEY: You didn't mean he would have been i 21 I aware that he met with him before?
- i
. 22 ! THE WITNESS: No, definitely not before. 3 i - 23 j BY MR. JOHNSON:
24 1 0 Before the affidavit was written, you weren't i 25 ; aware that he met with them?
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n) 1 A Not that I can recall. 2 i 0 You met with Mr. Parks on March 17th, and I will i 3 l now refer you to page 156 of your deposition before
. i
- 4 l Mr. Stier.
l
. 5 In Mr. Parks' deposition I think he 6 characterizes the circumstances here on the 17th, that you 7 called him in -- let me just get this. No. He says, page 8 52, "Around 1:00 p.m. that day I informed Joe Chwastyk that i
9 i I could not approve the Polar Crane load test because of 10 the serious violations that permeated the program." 11 l To the best of your recollection how did that
- l 12 meeting, that meeting at 1:00 p.m. initiate? Did you go
('] 13 l see him or did he come see you?
\_/ l '
14 l A At 1:00 p.m.? lJ 15 ! O Yes. 16 i A Wait a minute. This is where a big discrepancy lI 17 lA is. I 18 J 0 On line 13, it says "Mr. Parks came to me with i 19 h some concerns." That suggests that he came to your office? 20 A Yes. [ l i 21 0 Did you ask him to come, or did he come in --
. 22 ,,
A He came in of his own volition. q 23 ' MR. HICKEY: You created an impression that this ll 24 You never asked the witness that. You !
]l was a 1:00 meeting. i 25 '
Parks' affidavit. You quoted a deposition that - C) lquotedMr. ! I l.
; ACE-FEDERAL REPORTERS, INC.
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.tayloe L 1 never had any time reference. I think you ought to-ask the 2' witness whether.he knows if it was 1:00.
3 BY MR. JOHNSON:
. 4 O Do you recall that it was on the 17th of March?
5 A I' don't recall that, but I know it was because l . 6 of a memo I wrote as a result of this meeting. , 7 0 All right. And to the best of your recollection 8 what was the time? j 9 j . A- I have no idea. I i 10 0 Was it afternoon? [ l l 11 : A I have no idea. I l 12 0 Can you place it in relation to other meetings
)
13 that day? 14 j A No, I can't. i
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15 < 0 You met with Mr. Kanga afterwards? l 16 h A I met with Mr. Kanga afterwards. But again, I d 17 ' don't know what time that was, either. I'm sorry. I just' l 18 I can't. relate it to time. l 19 0 It says here in the deposition, at line 13, 20 "Mr. Parks came to me with some concerns he thought he had 3 21 l 'in relation to the reactor building Polar Crane."
. 1
. 22 Did he tell you, as he says in his affidavit on
. 23 page 52, that because of serious violations he could not 24 , approve the Polar Crane test, that is, sign off on the j j '
i 25 j procedure? O- 1 i ; l ACE-FEDERAL REPORTERS, INC.
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) 1 A I don't recall.that aspect of it. I don't 2 recall that specifically, no.
3 I -0 What do you' recall?. l
. 4 A I recall Rick coming to me and we discussed some -, 5 problems, and this may have been it, but I don't really l
6- recall what the problems were with-the Polar Crane, and 7 then his indicating that he felt he had lost his ability to 8 be. effective with the Polar Crane because of all that had transpired recently on the subject. 9 10 0 Was that your feeling,.too? 1 11 A Not definitely. You know, I. felt it was very 12 j much.a possibility and it was was more important that he i 13 felt that way, not me. l 14 MR. MC BRIDE: You interrupted him earlier when 15 you asked him what did he recall. l 16 l Did you finish your answer to that question? 17 i THE WITNESS: Well, what I recall was, as I said, I 18 , Rick started to relate to me that he felt he lost all i 19 ! effectiveness in his ability to properly contribute, you 20 l know, to the Polar Crane project. 21 ; BY MR. JOHNSON:
. 22 0 Was that because of his own feelings or because . 23 of the circumstances?
24 . A Well, as he related to me it was more -- it was
! i 25 as a result of his ability or inability, if you will, to (E) t a
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.tayloe f .i,,-) - 1 j project-in-a. proper:way problems and resolutions and the i
2 ! fact that, as a result _of things that had transpired in the I 3 i recent past at that time, that he just felt that he
,' 4 couldn't'see the forest for the trees any longer; he 5 couldn't recognize-that what he was looking at as..a problem 1 J
.6 was, in' fact, a problem or just something.that because of :
I 7 .some of the things that had transpired lately.were just-l 8 ' perceived to be problems in his mind. 9 O And did you agree with him? 10 A 'Well, again, I'm not sure that I thought so much. 11 in terms of agreeing with hin as.it was more in: terms of it 12 was, in fact, a problem. I wasn't thinking in terms of 13 what was the reason for the problem, but what is the 14 resolution of the problem. ; 15 We decided that the best way would be to take D 16 Rick off the Polar Crane project. 17 O That was the next thing I was going to ask you 18 l about. 19 l Did he suggest that to you? 20 A I don't recall now, but I read in my affidavit l l 21 ; that he did, in fact, suggest it.
. 22 l 0 Where do you find that?
1 23 l A Okay. I'm sorry. I read it wrong. I was ; 24 , reading line 16. It's actually on line 18. 25 Okay. All right. So it was there that I () v9
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I 29049.0 ! 107 , tayloe ! l h 1 suggested it. Again, I don't recall, you know, the } 2 , specific words or how it came about. But I do remember 1 3 recognizing that possible solution as being in fact a good
. 4 solution to the entire problem, and that was to, you know,
. 5 ,
relieve Rick of his responsibilities as it relates to the 6 ! Polar Crane and give him some time to collect himself and 7 _ get himself back into a mode of -- you know, a better mode I 8 f of being able to operate. 9 0 Okay. So you suggested it. At that time -- l 10 MR. HICKEY: Just a moment. That is not what I 11 ! heard the witness just say. If you want to say that is 12 what he said three years ago, that is fine. But I heard 13 the witness say that he doesn't remember who suggested it. 14 Okay? l 15 ' MR. JOHNSON: Okay. I i 16 [ MR. HICKEY: That makes the record unclear. I 17 ! MR. JOHNSON: Okay. Fine. l 18 BY MR. JOHNSON: 19 , O You have no present recollection of having l' 20 suggested this? l 21 3 A No, I don't. The only recollection I have of it I
- l\
. 22 ;! now is the fact that it was put forth and Rick seemed to l
,1
. 23 heartily agree with it, he thought it was a good idea, you 24 know, and we went from there. l 1 i 25 : 0 How did he convey to you that he thought it was ;
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l. 29049.0 -!- 108. tayloe j l h 1 { a good-idea? 2 A I remember specifically his grinning and sitting 3' up.in the chair. 4 0 Grinning? 5 .A ' Yeah, you know, sort of a happy.look on his face
~
6 type of thing. I do remember that.specifically about that-l 7 section of it. 8 O And saying something or'just grinning? 9 A No. I think he said, yeah, that sounds like the 10 way to do it, or that is a good idea, or something-of that 11 I nature. He indicated very much that he was very responsive l 12 l and he felt it was -- he felt, himself, it was a good way. 13 to get out.of the situation. L ) I 14 1 0 Did he.tell you that he was feeling a lot of 15 pressure at that time? 16 j A Yes, he did. 17 !! 0 And'did he describe why he was feeling the I 18 pressure? 19 l A Well, again I think this gets back to what I i 20 l said just previously, and that was he was feeling this 21 ll pressure as a result of things that had transpired lately lI j 22 and he indicated that he was not sure that he could, in 23 fact, operate as efficiently as he possibly could because 24 he had gotten so involved in this thing. So it was all
'25 ,
part of this conversation. ,
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I 9 l 29049.0 109 i tayloe j N llh 1 a 0 Do you recall him mentioning anything 2 ) specifically with regard to the pressure that he was u 3 [ feeling, telling you something specific? ' 4 A Not that I can recall, nothing specific. You 5 ! know, nothing specific that I can recall. It was just my 1 6 it general remembrance of it now that that was part of the ll 7 conversation. 8 , O Did he tell you that he was feeling isolated in
)
9 ij any way? l I 10 A That is very possible. I think that goes along ll 11 with the fact that he felt like he had -- you know, he had 12 l sort of put himself out there by himself in terms of some 13 of the things he did. So I guess that would be one way of 14 -- again, I don't recall specifics. It is more a general i l 15 i recollection that I have. h l' 16 h 0 You say you then told him you were going to 4 17 9 draft a letter reflecting that he would be taken off the i il 18 h TWG for purposes of the -- ! 19 ll A No. We discussed how best to do this and we i 20 3 agreed that the best way to do it would be to draft up a ! i i 21 i letter and, you know, make it as specific to Rick's : I
. ]
22 ll position as possible. By that I mean try to draft up a d
. 23 : letter that would not reflect negatively on Rick, but at !
! i 24 ' the same time relieve him of that responsibility on that j 25 Polar Crane so that he could go on to other things.
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5 J-29049.0 $ 110 tayloe () 1 I O Did he suggest any other possible solutions, 2 other than removing him? 3 W A. Not that I can recall. 4 0 Did you suggest any other solutions? 5 f A Not that I can recall, no. I can recall us 6 P coming to this conclusion as the best possible way. 7 3 0 You don't recall any alternatives that were 8 discussed? 9 l A No, I don't. I 10 0 Do you remember anything else about that 11 conversation? 12 l A Yeah. I remember that -- this part is vague. I
~
13 remember talking about the memo and how the memo would be Os 14 drafted, and I don't recall, you know, if I sat down and 15 wrote something up while Rick was there or if I wrote 16 something down and then Rick came back later and reviewed I 17 j it, we went over it together, and I got his concurrence 4l 18 0 with the wording of the letter. I think I even said in 4 19 g here that he may have made some comments or some changes to F 20 0 it. But I don't recall that now, i 21 ll 0 According to your deposition as it follows on
. d
, 22 ? here, I believe, that you then, after you finished your d
23 ) conversation, and I would assume you then dictated a memo 24 or wrote out this memorandum or had it typed up, you went i 25 -l over to Mr. Kanga's office or you called Mr. Kanga? C:) 1 I! i 3 ACE-FEDERAL REPORTERS, INC. lI
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29049.0 111 tayloe l [ l l A I called Mr. Kanga. I called him simply because } 2 I knew Rick had been talking to Mr. Kanga and to some other l 3 l Bechtel people, and I thought we've got a resolution of } I 4 this problem and we'd better let Mr. Kanga know. So I l
. 5 ll called Mr. Kanga and, as a matter of fact, he then asked me 6 to com. Mwn to his office and discuss it, and I remember ;
7 that because it bothered me a little bit because I didn't i 8 l want to waste that time. I figured, we've got the problem I 9 y resolved, let's get it done and go on, but Mr. Kanga said n 10 0 come down and talk to him. So when the girl finished I 11 i typing the letter, I went down and talked to Mr. Kanga and I 12 discussed what had transpired. ggg 13 0 I would like to get into that discussion. 14 l Actually, I would like to refer to Mr. Kanga's i 15 ! deposition. 16 l MR. JOHNSON: Counsel, do you have page 73 of ! e 1 17 f Mr. Kanga's deposition in front of you? ' i 18 MR. MC BRIDE: No, sir, I don't. fi 19 j MR. JOHNSON: Okay. I'll show it to you. { l 20 j I don't have another copy of this.
; i 21 Do you mind if I come over there and look over N
22 g your shoulder? 23 j MR. MC BRIDE: No. That's fine. 24 l BY MR. JOHNSON: 25 If you will look at line 13, where this is ! O (Il . 1
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7 2 ,i MR. RICHARDSON: What pago2, , j .
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3 f MR. JOHNSON: Page 73.Y, y I 4 BY MR. JOHNSON: t f -1 I
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5 j O Is that discussion on lines 12 to 16J. ins accurate
. I N 6 l representation of what you told -- 1 i
o
- 7 j A 12 to where? ; _ . ,1 i
i 8 y 0 12 to 16. ,
, (
9 l A Okay. Well, I'm not'sure I understand the "quite
,s 4
10 h nervous that day' part of that. But I may have said 11 ll something about Parks being a little nervous or,,'omething.
!l 12 [ I don't recall it.
i s .t 13 ! O You remember him saying it wouldbh\helpfultc'[' h i /
/
14 ; ( Parks? ' 3 3 ( 15
.' MR. HICKEY: Who said that?
t s i 16 h MR. JOHNSON: Kanga, excuse me. U ~ 17 j THE WITNESS: No. I said that. -
'i 18 MR. JOHNSON: You remember saying to Mr4 hnga
]
a 19 ll that it would be helpful to Mr. Parks if Parks was 20 . replaced -- g i
., o 21 THE WITNESS: Yes, yes, I do.A 22 i MR. JOHNSON: Okay. ,
- l '
23 f1 BY MR. JOHNSON: + s 4
. I 24 ! O I:o you recall in your discuspion with Mr. Kanga
.i l 25 jlsuggestingthatessentiallythiswassomething that would ;
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j 2L ! A'- Yes. - 2 . 3 r , e/ -l 3 .
.O And'if not his'. idea, something he wanted? - 1,
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4 A.- Oh,.yes, definitely. He indicated to me that he - 5' i felt'tliat:that'would'be a perfect: resolution to the7probless ... j . . . . J
'6 ,0- :And you conveyed that te. Mr. Kanga? q'
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7 'A To Mr. Kanga. , 8' O. Then what happened? Mr. Kanga called.Mr. Parks 4
#' O 9 .down to'the office? Y! t l-i l t' .
, . l 10 . I don't recall if Mr. Kanga' called him or if'I >
11 called him or who. called'him. ?' l 12 j O' But he was invited to come to Mr. Kanga's officgy { 13 14 l A He was invited to come to the office. And he came,'and you had a discussion about the' O l -
- 15 l. memorandum, and according. to this MrJ. Kanga indicated tdf
.j 16 Parks that he wanted to be,sure that Mr. Parks didn't 1l Mr. '
17 :I interpret.the memorandum that you had written removing 18 Mr. Parks from TWG, for purposes of che, Fo.?ar Crane revieth { 19 to be an act of intimidation? I 20- l A- ~ Mr. Kanga seemed to me to dwell: quite a ' Liit on . y !. j t , 1).i
.21 Verifying that Mr. Parks did not view this as some sort of I
. l i.
l - 22 'II retaliation or intimidation or whatever. h l 23 'O. Do you know why he-did that? l 24 i A No, I didn't. I thought he was just being j; , 25 4 careful. ,' O ] ; ll ii lt ,- l ACE-FEDERAL REPORTERS, INC.. l j . i 2tC 347 3Hx) Natiora u.9Coserage 800 336 6646 i
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4 i . 1 O Did he.tell you either before or.after anything Mn' l'. >2 ! .about his views about this, the question of intimidation? nw p, : M3 ]j A I dont recall really that he~did. t "- 4 J : O Did yodi bring it up? - 3 w I 51 D A No. Mmember,'I. wanted to get it done and.get [ , 6 out of there. 'I had other things.to do. . - l' 7 (Q- Did Parks indicate'toleither of'you that he felt 8 , that. there ' was 'something retaliatory about it? - l I 9 'i < Oh, no, , The' only. thing strange is, his
.li-10 4.losponses to Sr. Ka,nga's queries were I thought a little. j n
11 i ' strange. I don't even recall what-they.were.- I've read
,n,
- 12. l them again somewhere since then,1but I. remember thinking at.
Il3 I the.' time, boy, that is;a queer way to answer. 14 , O He says on page 52 of his. affidavit, he' 15 responded, w'en h asked twice about whether he agreed --
- 16 "Kanga asked me twice," he says, "to agree that my. removal
.( /j
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was not an act of intimidation." -I. responded ' Note the
, 18 intent is well defined.'" Do you recall that?
j ! j,{ 19 h A 1 don't recall those specific words. I do i p;n 20 recall his respon'se being a little strange, and I believe [ fa. : r 21 ! that falls into, that category. But I do have the 4 . >: l p 22 i impression that he was agreeing. I do have that impression.
'b \
23 0 ' Elsewhere in the deposition you mentioned that 24 : on leaving, Mr. Parks indicated that he had signed of f on 3 c i 25 ! the Polar Crane test procedure, is that not correct? O. 4 i a o ACE-FEDERAL REPORTERS, INC. 1 i n.w.~ , n--n -- I;
i - 1 29049.0 < 115 tayloe i
'l :I think it is mentioned a couple-of times in the 0
2 l deposition. 'Let me try to find the first" reference to it. i
- 3 I think it was earlier.
. 4 A I~ don't; remember again.the specific.words he
- a. 5 ! used. Again, I've read Mr. Parks'. affidavit, about his
_i .. 6' approval based on technical content. It was surprising to 7 me because it had nothing to do at all that I could see 8- with what we had been talking about. He said'it as he.was 9 leaving the meeting. 10 0 'After the conclusion? l 11 i A -After the conclusion and I had signed the memo, t - 1 12 as he was walking out the door, he just sort of turned and 13 'made some sort of comment.
.14 0 To the best of your recollection what did he'say?
15 ! A The only thing I can tell you now, he says that 16 it was something about approval based on technical content, l t 17 f and I think that was referring to one of the Polar Crane 18 l tests or something. It's probably written down here. l 19 My only recollection of it was that it was just l 20 strange, because his comment about -- it was about some l l. 21 other document, some other problem or function. It had 22 nothing to do with what we were talking about. It was just
. 23 ! strange that he said it.
24 0 Wasn't the pressure about the Polar Crane one of a i 25 the reasons why, in your opinion, he was having these C:) , !
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() 1 i difficulties? 2 A I don't think when we were talking with him and
]
d 3 l' Mr. Kanga that any specific -- l
.~ 4 1 0 Right. But in your earlier conversations with
. 5 him, in which, according to the deposition -- I neglected
. il 6 l to touch that point, but according to the deposition you 7 went -- I would like to find that specific -- you went over 8
lI his problems point by point and you say, to put them to I 9 1 rest -- 10 A Yeah, I think I know what you are talking about. 11 I don't remember what those problems were. 12 l 0 Page 156. You don't remember what they were 13 specifically? O. 14 i A No, no. 15 l 0 On line 13. "Mr. Parks came to me with some i 16 ] concerns he thought he had in relation to the reactor 17 building Polar Crane. We discussed those concerns and I ll 18 ll was able to put them to rest." i ll 19 ] A Right. By that I mean we discussed some 20 N specific problems and basically, I think, my impression was i 21 j that the resolutions that I saw Parks agreed with and
. 22 'I that's when we went off to the other subject.
l
. 23 '
O Now, were those things that he put to rest 24 ll related to his comment resolution and the question of , 1 ! I 25 whether the acceptance of AP 1047 and 1043 by recovery i l ACE-FEDERAL REPORTERS, INC. ! 2 xmm,> x_m- - i
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1 operations -- was that part of it? 2 i A. Again, I don't know. I think up to thisipoint 3~.h--youknow, he had come into the office and he wanted to 4' . l Ldiscuss some specific things anb1 I wanted to put those I 5: gthingstorest, but I didn't want to spend'a whole bunch of 6 time. going over. problems that had been resolved, et cetera.
- 7. O Was that one of the problems?
8 A I. don't know. I really don't know. 9 I
'O- But in your deposition apparently you -- in'1983,-
10 in August', you did remember'that there was a discussion 11 ; about concerns he had in relation to the reactor building 12 - Polar Crane. That's.what it says there? l 13- A Yes, yes. 14 h 0 okay. And the test procedure that he signed off 15 on was for technical content only, as you later learned, or 16 9i learned as he was going out the door, was a Polar Crane 17 test procedure which then perhaps related to an earlier q l 18 l conversation you had had that day with him? 19 4 A It perhaps could have. I just didn't recognize 20 ; that it had any bearing at all on'what we had been talking I 21 about with Mr. Kanga.
- 22 ; O And did he say something going out the door like, - 23 ! "It's too late, I've already signed the procedure"?
L 24 A. He said something as he was going out the door, 25 and that's what he says there. This is the thing that --
- i i i! ;
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() 1 I it just had no relation'to what we had been discussing, and
' I really didn't 2 he said something, and.it didn't register.
i 3 know what he was talking about when he said it. i
~*
4 0 You said something, I think, in here that he 5 i slipped away-before you could find out what1he meant. 6 A Yeah. He.was half out the door when he said i 7 that. 8 0 What was your reaction to what he said? 9 A My reaction was, ' wait a minute,: what are you-10 talking about, but he was'gone. i 11 I But you didn't take that as indicating in any. O l 12 I way that he didn't agree with'the resolution? 13 A No. It had nothing to do with it. That is why
-{) it sort:of took me by surprise. I didn't really know what 14 15 he was talking about, because it had nothing to do with the 16 l conversation we were having with Mr. Kanga.
4 17 l 0 You interpreted as having nothing to do? i 18 l A Yeah, right. 19 l 0 'He may have thought it had something to do with 20 ! it? I 21 , A He may have, but if he did he never did get that
- I 22 i across.
.23 l 0 There was a meeting on March 23rd,'1983 which 24 I'm trying to remember what the circumstances of it were.
25 fi Do you recall a March 23rd, 1983 meeting in () i s A l [ i ACE-FEDERAL REPORTERS, INC. i 3 .m , _ m c _ ,, s< ~ - -
i l l 29049.0 ;j 119 i i tayloe !! k 1 I which Mr. Arnold presided? - I il 2 j A Perhaps if I knew something about what the ; 3 I meeting was about. I cannot relate it to just March 23rd. l 4 O Let me show you a document. 5 i MR. MC BRIDE: Is this document you that just [ l 6 i! handed us, Mr. Johnson, an exhibit in the Stier report? j a 7 h MR. JOHNSON: No. f 8 ! MR. MC BRIDE: Do you recall that in setting up
- .l 9 i tnis deposition I asked you to provide me things that had 10 reference to Mr. Chwastyk and you said that you would and 11 then you later said that if it was something that was in
'!! the Stier report you assumed I could get that from the 12 company, but otherwise that you would provide such ll) 13 i
14 !i materials to me? Il 15 fl MR. JOHNSON: I said generally I would provide a . 16 , documents that were pertinent to the deposition. ! i k 17 MR. MC BRIDE: I would note for the record that 1 l 18 this document refers to Mr. Chwastyk on page 1 and it was i n i 1 19 j not provided to me prior to the deposition. 1
! l 20 MR. JOHNSON: Duly noted. ;
e i 21 i BY MR. JOHNSON: i i! ! 22 O Would you take time to look at this document,
]
23 ) please? 24 A Okay. I 25 MR. RICHARDSON: Excuse me. Mr. Johnson, have ; III '
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- () 1 you produced this in discovery today?
2 MR. JOHNSON: No, I have not. 3 MR. MC BRIDE: I would like to take a recess at
. ,4 this point since.this is not a document that the witness .. 5 has seen before. i 6 I have no idea what we were just handed.
L '7 MR. JOHNSON: Sure. Okay. l (Recess.) 8 9 MR. JOHNSON: As I indicated to Mr. McBride l outside in the hall and during the break, I just became- i 10 11 aware that this document had Mr..Chwastyk as an attendee at 12 this meeting recently. I'm sorry that you hadn't seen it {) 13 14 before right now. BY MR. JOHNSON: 15 0 Have you had a chance to review it? 16 ! A Yes, I have. 17 Q Do you recall attending a meeting at 8:30 in the 18 morning on 3/23/83 with the people who are listed here on i 19 ! the first page of this document? 20 l A I recall attending a meeting concerning, you 21 l know, Parks going public. The date and the time and the i 22 ! people there, I don't know. l
. 23 l 0 Do you remember anything about this meeting in i
24 ; terms of the discussion of how to deal with Mr. Parks? 25 A I vaguely remember the meeting and discussing i
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l l. 29049.0 121 i tayloe l I 1 Parks, what we should do and that type of thing, I read 2 I through this document. I don't know that I can comment on , You know, I have a I( 3 anything that is in the document. l l l
.- 4 ! little problem here. It seems to indicate Mr. Arnold gave i
. 5 ll us one direction and then a few minutes later changed
.I a
6 / everything, and I've worked with Mr. Arnold and for 7 i Mr. Arnold a long time and I have never seen him do that. 8 0 What you are relating to is his initial 9 i statement that all should cooperate? l 10 A Yeah. That very much is like Mr. Arnold right l 11 l there, that first statement, cooperate fully, candid, and
! I 12 {
all that stuff, because that is the way we have operated on l g 13 ; that island since the day I got there. ' 14 0 Do you recall Mr. Barton then saying " bull shit"? l i 15
]4 A Let me just say that Mr. Barton saying " bull l 1
1 ' 16 shit" would not ba something that was so unusual that I
)k 17 would remember it. ,
i 18 0 Do you remember anything else, don't give him l 19 anything, in fact, don't let him back on the Island, in ! i 20 fact, no one should speak to him? l 21 j A Not definitely. It seems to me that is
. 1
- 22 i something that Barton would say, but I don't remember the 23 specifics.
l i 24 Q All right. ! 25 MR. HICKEY: I don't know that you have ; O i ! t
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Etayloe ! () l- identified these notes for the record. Would you'say what 2 I it is that we are-reading? I 3- l MR. JOHNSON: Yeah. They appear to be
.' 4 ! handwritten notes by Ed Gischel. There is a signature, or l
. 5 l a monogram at.the end on the third page, it looks'like E
. .. j -
6 something S, or E something G. I think they are 7 handwritten notes of Ed Gischel. 8 i MR. HICKEY: Do we have any information about l 9 when the notes were made? 10 MR. JOHNSON: All I have right now is what you 11 have? 12 MR.~ HICKEY: In other words, you are not 13 representing whether they are or'are not contemporaneous O 14 with the meeting? 15 MR.' JOHNSON: I believe they are. 16 ! MR. HICKEY: Will'you tell us the basis for the d 17 f belief? i 18 Is it something beyond the text of the notes? l 19 MR. JOHNSON: No. It is not something beyond 20 i the notes. The text appears to recant verbatim statements. 21 l It appears to be something that would have been recorded at
. 22 I the time. . 23 l BY MR. JOHNSON:
i 24 I O As you recall this meeting, was -- l 25 l MR. RICHARDSON: Excuse me. Can I clarify that O 1> , I I l ACE-FEDERAL REPORTERS, INC. l ll 20: 34-370u Nationude Cmerage 8%336-6M6 !
l 29049.'0' i 123 tayloe ! l 1 , last statement? 2 Mr. Chwastyk, are you saying that you recall
'3' l Mr. Barton saying that or you-simply suspect that is 4' something Mr. Barton might have said?-
5 THE WITNESS: I don't recall him~saying,.but it 0 6 is something that, in my' opinion, it is something he might 7 have said, the bullshit part. 8, MR. RICHARDSON: Okay. , 9 'BY MR. JOHNSON: 10 0 Do you recall that anyone else -- well, let me i- 11 ask.you this question: Did you say anything at this i 12 l meeting? () 13 l A Not that I can recall, but that would be very
~14 unusual because every time I've ever been to a meeting I I
15 ! always had some opinion. i 16 j 0 To the best of your recollection, do you 17 tuuember expressing any views with respect to how to deal 18 with Mr. Parks? 19 A No, I don't. I 20 l 0 Having' read through these notes, they only have l 21 i statements '
- Mr. Arnold and Mr. Barton -- I'm sorry -- and 22- Mr. Kanga recounted.
i 23 To the best of your recollection, did anyone
, l 24 : else besides those three individuals speak at this meeting?
d 25 A Again, to the best of my recollection, I don't I () f !
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'tayloe O 1 know.
2- ! O How were you informed about this' meeting,'that i 3 l you should attend it?
.. 4 A .I don't know. Probably a telephone call.
. 5- 0 -Do you remember from whom?
t. 6 ll A No. I
--7 0 Do you remember anything about what you were 8 told it would be about?
9 A I don't. 10 0 Do you remember any' discussion about what.should 11 :be done, what-kind of action to take with respect to 12 Mr. Parks? l A- All I can say is I just vaguely remember -- and r' 13
- d' there were all kinds of suggestions on how this should be l
14 15 -! handled, but that is about it. I can remember my feeling . 16 was, well, Arnold and Kanga are going to make up their 17 minds and they are going to make the decision. That was my I 18 impression. 19 l 0 Do you recall some of the views? 20 A Not specifically, no. 21 j 0 Generally?
- I
- 22 A Generally I think it was the full spectrum.from
.. 23 what is related here'of Mr. Arnold saying to the other
. i l ,
24 j' spectrum of what Mr. Barton said about not letting hi. back l : l 25 ! on the Island. (:) k O
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1 MR. MC BRIDE: Are you saying that Mr. Barton' 2 i said that? i 3 l THE WITNESS: No. I'm just relating'that this'
.$ 4- is the range of what was discussed'in there, using-this l . 5 document'as an illustration.
l i 6 BY MR. JOHNSON: 7 O But you don't remember a view in connection with 8 a person?
- 9. A No, not specifically, no.
10 0 Do you remember anybody speaking up for l 11 Mr. Parks? 12 A 1 don't remember anybody speaking up for Nim, 13 but again I don't remember anybody speaking against him, 14 either. It was how'to handle the situation. It wasn't our 15 l opinions of what Parks did. l1 16 il 0 Do you recall anybody giving the view that il 17 l Mr. Parks shouldn't work on the Island anymore because of . l l 18 ! making this statement? f 19 l A In this meeting? l 20 k 0 Yes. 21 .j A No.
- 22 ! O Do you recall anybody saying that his going I
, 23 l public would have a deleterious effect on the operations on' ;
24 i the Island? 25 A I really don't recall very much about that. To i O 1 i, , h ! t c li l ACE-FEDERAL REPORTERS, INC. ! mmana smoa cmge mm I ___ _ . _ _ _ _--- _ _. _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ a
a
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29049.0 . 126 tayloe' -'
'l
( )- 1 me11t was more of, people were expressing'all' kinds of 2, things, and it didn't seem very important. 3 . 0 I. don't quite understand that'last comment. i l'
-4 What didn't seemLimportant?
- 5. A Well, you know, I just thought that Arnold and 6; i Kanga'were.the people that were going to come out -- you
- 7. - know, using their legal representatives, et cetera, as to 8 how we would handle the situation.
.9 0 So why do you think he had the meeting with all 10 those people?
11 MR. RICHARDSON: Excuse me. That calls for-12 speculation. Are you going to ask him the preliminary. 13 question, whether he had a discussion with Arnold about why 14 the meeting was convened? 15 MR. JOHNSON: I think he said he didn't know why 16 it was convened, other than he was told that there would-be 17 ; a meeting. 18 BY MR. JOHNSON: 19 0 Did Mr. Arnold or Mr. Kanga or Mr. Barton 20 discuss the meeting with you outside the process of the 21 ! meeting? k 22 ll A No. i 23 0 could you read back to me my original question, l 24 : please. 25 (The reporter read the record as requested.) c:) a 4 i :!
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V 1 a i BY MR. JOHNSON: 2 0 What purpose, in your mind, would there have 3 ! been to have a meeting with 14 attendees? I
. 4 q A In my mind it was one to inform us of what was I
. 5 h transpiring based on what Mr. Arnold and Mr. Kanga knew, C
6 and I think that was the primary purpose of it. I don't il 7 know if -- the secondary purpose may have been just to get 8 inputs. But I'm not certain of that second point. l 9 l 0 Do you remember a discussion about firing 10 Mr. Parks and somebody responding that he was protected by l 11 . certain laws and regulations and that it would be difficult 3 12 !! to fire him? l (~g 13 i A In the context of this meeting? (_/ , 14 j 0 Y e 's , in the meeting. 15 A I can't say whether they did or not. I've heard l 16 that before, but I don't know if it was in this meeting. ] 17 f MR. JOHNSON: Okay. I would like to mark this s 18 ] document as Chwastyk Deposition Exhibit 17 for , 19 identification. 20 ;. There was one copy that was a -- I may have 21 J given away both copies.
- 22 MR. HICKEY: I have one that has the bottom line
. 23 ; on page 2.
24 I MR. JOHNSON: Do you also have the version that
;j l, 25 y says " protect him" on the last line? i (1) I !!
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'Q %/ - 1 i
l Do you have one? 8 2 MR. RICHARDSON: Pat, you take that. i
-3. MR. JOHNSON: I want to give it: to the reporter.
4 MR. HICKEY: When.you are done, before the
.. 'S reporter leaves, I'll make some copies of that.
6 MR. JOHNSON: I would ask that this memorandum 7 that'we have been discussing, 3/23/83, handwritten, 8- i three-page. memorandum, with the initials E something G in
~
9 the circle at the end of it, be marked for identification 10 as Chwastyk Deposition Exhibit 17. 11 (Chwastyk Deposition Exhibit 17 identified.) ; 12 t BY MR. JOHNSON: 13 0 I want to reverse gears a bit and go back to the 14 date of February 18, 1983. Try to gear it back a little 15 bit. i 16 l A Okay. 17 0 I refer you to page 20 of the Parks affidavit. l 18 -l In the second full paragraph, about midway down, I .! 19 it says "We had reached my office space and had entered 20 l Larry King's office to continue our conversation." 1' 21 i Why don't you'just read that second full
. 1
. 22 l paragraph and become familiar with it.
. 23 l -A I've read it. ,
24 0 Do you recall that, as Mr. Parks states in his i l 25 affidavit, that -- as it says going toward the bottom, ! O !.! , t,
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" Larry King, and Joe Chwastyk, manager of plant operations, f/ 1
-l l2 walked in,.this all occurred I believe.early in the morning. ;
3 of February:18th, and.in front-oflKitler, says, 'I repeated' 4, to Larry.and Joe that'I had been-threatened with transfer.' 5 Larry replied, 'It does not. surprise me.' He had repeated j
.. j 6 the original threat, which was, what the hell are you doing, j 7' and I asked him what he meant and he said, 'You have upper 8 management pissed off at you to the point where I've been 9 asked what has to be done to get you transferred off.the 10- site,'"'and back to the bottom part, it says "Ed' repeated 11 the original threat and attributed it to' Rich Gallagher, an .)
12 assistant director-of site engineering, who also performs 13 various other-functions for top management. -I was visibly 14 upset. Kitler added that I shouldn a t'take'it so seriously." 15 Do you recall that conversation? 16 ! A I recall a conversation about Rick being 17 l concerned about his being transferred. 18 0 Did it happen more or less as recounted here in r 19 i the affidavit? 20 l MR. HICKEY: I would ask that you make that 21 question a little clearer. 22 l It could be significant. 23- BY MR. JOHNSON: 24 0 Would you say that the account of those events j 25 ( is accurate as reported in that paragraph that we have just ! i l 1 ;
) I j ACE-FEDERAL REPORTERS, INC. !
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<V n 1 discussed? 2 l MR. MC BRIDE: ~Are you asking him only with I 3 !. respect to the part-of'the paragraph that applies to the- [ 4 i meeting that he. attended, or the'first part of it that i
. 5 ! evidently occurred between Mr. Kitler and Mr. Parks 6 <according to Mr. Parks?
7 MR. RICHARDSON: -There are several other ones-8 there. Maybe you can break it down. 9 BY MR. JOHNSON: 10 0 .What I really wanted to know is the.part that- l
.11 refers to you, and what was said in your presence.. Would i 12 you say that that is accurate as it is stated?
?
13 A You know, this part here, " Larry replied, 'It [ 14 does not surprise me.'" I don't remember that. l 15 ! O Go ahead. i 16 f A He had repeated the original threat. I don't i 17 l remember him talking about specific people, you know. It i 18 1 seems to me like he had somehow got the impression that 19 . Rick was going to be transferred and he was repeating this 20 i to Rick and then Rick, of course, wanted Larry and I 21 involved. c 22 ! Kitler added -- yeah, I would say that. That is i .
. 23 l my attitude. I didn't really see it as anything serious. l 24 Again it just sounded to me like a rumor because Rick Parks 25 was basically working for us and we had no intention of C) ]i i
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. 1 l having him transferred.
2 l 0 But what you heard was Ed Kitler.did'say i 3 something to the effect'that there was. talk of transferring-
. 4 Rick Parks?
. 5 .A' .I don't know whether he had said it or-Rick lsaid 6, t it and asked Ed for his confirmation of it.
7 0 And did he confirm it? 8 j A Ithink it was confirmed.that someone,.somewhere, 9- was-talking about transferring Rick Parks. 10 0 And do you recall a' reason being attached to it? 11 .A No, I don't. I do recall, though, that in my 12 l mind, and I stated this, that to me it was'just a rumor and 13 there was no reason to get all excited about it. simply 14 because Parks was working for King and I, and I know I had 15 l no intention of transferring him. 16 0 And Kitler was not a-GPU. employee, he was a 17 lBechtelemployee, right? 18 , A Right. 19 0- And Parks was, also? I 20 l A Right. ; i 21 0 So if he was going to be transferred it would be
. 22 ; at least partially the decision of Bechtel? - 23 i A Well, yeah. I imagine -- I guess -- I assumed 24 that he was working for us, and whether he was working for i
25 ' Bechtel or not, we are the ones who would determine whether O. i l 1 l 4 1 i j ACE-FEDERAL REPORTERS, INC. il 202-347 3700 Nationuide Coserage 800-336-6M6 _ _ _ _ _ _ __ _ _ _ . _ . _ _ . _ _ _ _ _ . . __.__.___._______..___._._____.______.____.___b
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) 'l or not he would be transferred, and'my_ impression was that 2 if~he was doing a good job for us and if they did, in fact, f
3 l try to transfer him that we would try.to do something about
. 1 i
.- 4 it. As a matter of fact, if nothing else, hire him-as a' !
. 5 ,
_GPU employee. 6 0 It says here that Parks was visibly upset. Did 7 0 you notice his demeanor? 8 l{ l A This goes back to what I.said earlier. Parks -! 9 got visibly upset about a lot of things, and not-1 10 necessarily things that were of seriousness in which you 11' should get upset about, and I looked at this as one of 12 those situations, and it was basically because to me -- it 13 was indicated'to me that it was a rumor. You know, I don't
} If I got all upset' 14- get all upset because of rumors.
l
\
15 because of rumors, I would get a blubbering idiot by now. I l 16 0 I didn't catch that last statement. ! i 17 f Now I understand why. , t l 18 i Did you talk to Parks yourself and say to him- l 19 fthatyoushouldn't take this seriously? , 20 ! . A Yes. I think I expressed exactly what I-just j l' 21 } said to you. As a matter of fact, I even mentioned the !
\
. 22 l fact that he's working for I and Larry and we weren't I
. 23 thinking about transferring him. That thought never :
24 fenteredourmind. 1 25 0 Now, I understand that it is very possible that ., () ) I; c ji 1 i i i i 4 J ACE-FEDERAL REPORTERS, INC. t - - - - - - - - - -
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(- f-). 1 perhaps Bechtel could have transferred him over and above 2 what we wanted. Okay. But again my thought was, even if 1 3 l they wanted to do that, it would be just a matter of us
- 4 hiring him straight into GPU Nuclear.
5 j 0 Did Parks say anything in this connection ti 6 i regarding his conversations about this threat that they i 7 l were related to his raising safety concerns? 8 A No. 9 0 Did anyone in this -- 10 A No. That's why my impression was it was just a i 11 I rumor. I didn't have any basis that I was able to
\
12 ascertain. l (} 13 0 What was Kitler's attitude in this? Did he seem upset or agitated during the course of this conversation? 14 l I 15 p A No. I think Kitler's attitude was, you know, 16 h'!pretty much what he says here. You know, Kitler was. sort 4 17 lloftrying to calm him down, also, you know, it's not that U 18 h serious, you know, don't get all bent out of shape about it. j 0 l 19 i O Was that the last you heard of that incident? j 20 f fDidyouhaveoccasiontodiscussthat incident with anyone l l 21 l else on the site between that date and the date on which ! 1 22 [ Parks was suspended from the site? , l
- 23 i A No, I don't think so. Not that I can recall l j l 24 ] anyway.
4 25 i 0 Do you recall any meetings with either ! () 1 a l i N j ACE-FEDERAL REPORTERS, INC.
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l 29049.0 134 tayloe 4 / ! k_" l Mr. Barton or Mr. Thiesing or Mr. Kanga at any time between 2 ! the 17th of February and the 21st of March, private 3 i meetings you.had with either of those those individuals, in
. 4 which Mr. Parks' employment status was discussed? . 5 i A No.
b 6
- O Did you attend any meetings in which either l
7 j Mr. Barton or Mr. Kanga were in attendance, other than the i i 8 I one that we have discussed on the 23rd of March, between i 9 I February 17th and March 21st, 1983, in which the employment 10 status of Mr. Parks was discussed? j 11 A Not that I can recall. 12 l 0 In your mind, did you have any role in the j i . /~T 13 ! decision, or any input into the decision to suspend \_/ l - 14 i Mr. Parks from the site? 15 i A No, not that I can recall. 16 0 Do you feel that Mr. Parks could have returned l l 17 to work after his press conference and worked with the 18 ' other individuals on the site as a startup and test 19 ( engineer, as he had been? 20 0 MR. RICHARDSON: I think that calls for 21 speculation and --
. 22 MR. JOHNSON: I just asked him his own opinion. . 23 It's not speculation.
24 MR. RICHARDSON: Well, there are any number of k 25 and I think you have to describe the () )lspeculativescenarios, I I
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() 1 scenario more specifically. 2 MR. JOHNSON: I note your objection,
]
BY MR. JOHNSON: 3
]i !
. 4 j O Can you answer the question?
h I was simply going to say I'm sure Parks would
. 5 g A
'1 have no problem with it. I'm not sure what some of the 6
7 , other people on the Island, what their problems would be. 0 8 0 You said you thought Parks might have an 9 objection? 10 l A No. I said Parks probably would not have an 11 ; objection. I 12 ! O Would not have. I see. 13 l Would you have been able to work with him if he 14 had returned?
!I 15 "
A Probably not, not without, you know, some 16 ! assurances that any conversation I had with him was , i 17 l properly documented and witnessed such that it could not be J 18 1 taken, you know, and changed around, from what I had seen 19 ' happen in his affidavit. 20 0 And what was it about what had happened between i 21 6 the 17th and the 23rd of March that made you feel that way? i . 22 A His affidavit. I :i
. 23 i 0 His affidavit?
. 4 ;
24 i A Yeah. . I i I 25 Q Anything in particular about the affidavit? l (:) i ACE-FEDERAL REPORTERS, INC. i 4 m.m x_ m c- 8<- i t____... -
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~29049.0 136 tayloe:
) 1 A There are a number of areas in his affidavit l
2 - that what he put down in his affidavit is not anywhere near i 3 ' what I~ recall transpired. I think we have talked about
.~.. 4 :some of them.
. 5 j 0- Let me move briefly to.another subject. Early 6 on you said Mr. Parks'did not know much about AP 1047 and 7 .1043.
8 Were you aware he had a role in drafting these 9 procedures when he was a NUS employee during the' 1980-1981 10 period? 11 A No. 12 .; MR. JOHNSON: If I could just have a second. I 13 I'm just about done. 14 (Pause.) 15- g BY MR. JOHNSON: 16 0 Mr. Chwastyk, did you attempt, with respect to n 17 [thisquestion.of.r.Parksnotbeingabletoletgoof M 18 ! certain issues, did you attempt to show him documents that l 19 had been generated, like the ODR, or the Marsden memo that l J 20 i we talked about, or the Ballard memo? Not the Marsden memo,
.21 but the Ballard memo of March 10th, the minutes of the TWG
. I
. '22 meeting, the March 4th TWG meeting, any of these documents 1 1
, 23 i that we have discussed and marked for identification, did l 24 : you try to show him with documents that his concerns were 25 taken care of?
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. 1 A You know, if I'ever received a document that was i
2 of of interest to someone else I usually tried to see that i-3 ; -they had a copy of it, yeah.
.- l
. 4 l 0 Do you recall in your_ discussions'with Mr. Parks
. 5 trying to illustrate to'him through these documents that
.. j-6 l his concerns were -- his real concerns were taken care of?
F 7 MR. RICHARDSON: Excuse ~me. Are you asking him 8 whether he tried to do that by physically showing him the 9-documents?. 10 MR. JOHNSON: That's what I mean. By showing 11 him the-documents. j 12 THE WITNESS: I don't know that I can say by 13 ' physically. showing'him, but by giving him copies and maybe:
.14 making a comment. But not going'through the document step 15 fbystepandexplainingeveryaspectofit. No, I did not.
P 16 I BY MR. JOHNSON: 17 Il i 0 Could you explain a conversation that you had, 18 according to Mr. Parks' affidavit, with a Mrs. King on 19 l March 10th, which according to his affidavit you called 20 ; Mrs. King to say something about somebody was trying to get l 21 dirt on his wife, or his wife was trying to get dirt on 1 l
.- 22 .
Parks, in order to get his children away from him?
. 23 l A I have no recollection of anything like that 24 il ever occurring. I had no idea, for instance, that his wife 25 f was dead until I read his affidavit. I don't ever remember O ,
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'having any discussion at all concerning his wife or family 2 with anyone.
3 0 You don't recall calling'Mrs. King? [ 4 A This is one of those things that I just don't 5 know where it came from. I have no idea. 6 It seems to me it's like something out of the - 7 Karen Silkwood movie, or some damned thing. 8 0 Did anyone discuss with you the reasons for 9 -removing Mr. Parks -- I mean, contemporaneously with his
~i 10 removal ~in February as alternate TWG from the site, the 11 startup and test supervisor department?
12 MR. MC BRIDE: Do you mean Mr. Chwastyk's 13 memorandum of March 17th, 1983? 14 i MR. JOHNSON: No. I'm ref6rring to an earlier i 15 memorandum from Mr. Kitler which designated Mr. Walker as 16 Mr. Kitler's alternate on the test group in the startup and 17 test supervisor department. 18 f BY.MR. JOHNSON: 19 h 0 Did anyone discuss contemporaneously, Mr. Kitler, i 20 ; Mr. Gallagher,-Mr. Thiesing, Mr. Parks? 21 i A I remember it being discussed that he was 22 removed as an alternate, so we made him a site operations 1 23- ; representative. 24 MR. RICHARDSON: Excuse me. Are you referring 25 to Mr. Parks' removal as the alternate startup manager? (I) . 1 4 l ACE-FEDERAL REPORTERS, INC.
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6 29049.0 139 tayloe l l d f () 1 MR. JOHNSON: Yes. Alternate representative on 2 the TWG, yes.
;i 3 !! MR. RICHARDSON: I don't know whether or not
. 4 that is a direct consequence, but the decision that I'm
. 5 familiar with is the decision to replace Mr. Parks by il 6 [ Mr. Walker as the alternate startup manager.
4 7 i MR. JOHNSON: Right. That's the one. It was a 8 memorandum dated February 18th, written by Mr. Kitler, ; I 9 ! which removed Mr. Parks as alternate startup and test l 10 ll manager. I guess that's the position it was. Ii 11 ll THE WITNESS: I thought it had something to do 12 with the membership in the TWG or something. 1 13 i MR. JOHNSON: Okay. I have the memorandum here. 14 Just a second. 15 BY MR. JOHNSON: 3 16 !! O On February 18th, by document 4345-83-0002, O : 17 ] subject, startup and test personnel coverage, Mr. Kitler 18 wrote a memorandum to various people, and it says, "During J 19 i periods of my absence, D. Walker will act in my behalf as a 20 flstartupand test supervisor of Unit 2." l i l j 21 MR. JOHNSON: That seems to me to be what you
]
22
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23 . There was also another item, and that is, l 24 : 4345-83-0003, February 18th, 1983 procedure -- subject, l 25 i procedure, AP 1047, start up and test manual, TWG , i (:) ; d l ACE-FEDERAL REPORTERS, INC. n E3G370 Nanon w ice Cm erage RO 3346N6
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b; 140 29049.0 l tayloe j i h 1 c membership, and that is to various people, and it says, . 2 ) "In accordance with paragraph 2.1 of the subject procedure 0 3 j startup and test membership on TWG will to E.J. Kitler,
~, 4 member, and D.D. Walker, al te ra te . " That is signed by 5 l Mr. Kitler. S
I
. I 6 , BY MR. JOHNSON: s i
7 0 Do you remember any ibeussions concerning ( 8 Mr. Parks' replacement in both of these roles ( o 9 ! contemporaneous with that? ; , l , 10 A I remember the fact that he yab'iuken out as an I i 11 l alternate and therefore as an alternate member of the TWG, so we just made him a permanent member of the TWG bv' t a 12 l site 13 operations. G 14 Q Did Mr. Buchanan, Mr. Gallagher, 't r . Thiesing, I g I 15 l mention to you thesreasons for his removal? 16 h A No. I mean, to me it was just a matter of, you 11 17 ) know, Kitler as11gning someone involved with his day-to-day 1 18 d activities as his alternate, and Pa:t n 'really didn ' t meet il i
. i' . -
19 l that requirement, a.id apparently whoo m he aJ.flaned did. i , / ,
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20 1 But then I think there was som condecn that Parks had 21 g about being removed from the TWG, you know, so our response
, 22 to that was you arn only an alternate to TWG, so we will 23 ;
make you an alterrute to TWG. ,
,i 24 "
O You were enrolled in that? e b \ 25 ; A Yes. y ; h . e t, ,
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A Yes. Understand, un unt.iI now he's only; been an?' J ,.
.- 4 alternate, and then wh'en he raised this concern and he feiksi ,
.. -5 you'.know'M that it was something'-- I'iri not"3urs;what hio p ,
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6 concern was, but he just didn't'like -it. It w9med like
'7 somebodhwastryingtodosomethingagainsthimi so "ve 8 said we.will make you a' permanent member.
a 9 0- _ Did you feel that'there'was any relationship
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10 between his comment resolution' ca February '17th and his
,1l I 11 removal by Mr..Nitler?
- l.
12 A I dcE't think I ever thought abbutfit. You know,
; 13 I mean, that was'not an unusual circumstance. for Mr. Kitler.
i 14 We were always changing alternates based on people moviny
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15 from one job to another or responsibilities changing. , py a; j ; 16 1 0 To your knowledgw was Mr. Parks funct;ioning l
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( _j 18 ! A I don't think he was doing anythin;r, as an 30 ; I 19 I alternate to Mr. Kitler. That's why it wasn't any big deal. 20 I don't think there was any functions being achieved by i 21 that group up until we started td 'get ' int 6 the admin ,
. 22 f procedural requirements for TWG, et cetera.
{
. 23 g 0 Did you -- did you believe,at that time, in 24 l February of 1983, that Mr. Parkc' removal by nr. Kitler as 25 his alternate had anything to do with the prospect of O
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k) il 8 reactivation of the TWG and the prospect that it would be 2 -) needed on the Polar Crane?
/ ll If it did, it was the 3
l A Let's put it this way:
~
. 4 ) dumbest thing he could do. He had him as an alternate and
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;. . ;5 all he had to do was attend the meetings and Parks wouldn't i;
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7 h MR. JOHNSON: All right. That concludes my 8 ' questions, and I thank you very much. l h, 9 .. MR. MC BRIDE: I would like-to do something very 10 quickly here. 11 k I would like to have marked as Chwastyk 12
-l." Deposition Exhibit Number 18 a copy of Mr. Chwastyk's March f 13 ') 17th, 1983 memorandum concerning Mr. Parks.
' %] 14 l (Chwastyk Deposition Exhibit 18 identified.) 15 d- EXAMINATION [! 16 [ 'BY MR. MC BRIDE: 17 0 Mr. Chwastyk, I put before you a copy of what ( 18 l has been marked Chwastyk Deposition Exhibit Number 18 and I d 19 j ask you if that is the memorandum to which you earlier 20 (] referred in questions to Mr. Johngon concerning the 21 .ro. placement of Mr. Parks by Mr. Marshall as primary member
. 22 ] only with respect to the reactor building Polar Crane
)
. 23 :) project on the TWG?
'i j 24 .) A Yes, it is.
- i j 25 j O When you submitted this memorandum on the 17th r ,
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k 1 of March, did you do so as any sort of reprisal against ) p 2 I Mr. Parks' raising any safety concerns or for taking any 3 other actions with respect to his employment?
. 4 ;i A No, I did not. As a matter of fact, I thought il
, 5 [ it was actually of benefit to Mr. Parks and he agreed with ll 6 a that at that time.
U 7 5 O Had you at any prior time with respect to your 1 8 hactivitiesconcerningMr. Parks taken any adverse actions i !j 9 ) against him because of his having raised safety concerns? ll 10 y A No, never. 11 ; MR. MC BRIDE: I have no further questions, i 12 ! MR. HICKEY: Just for the record, I think all
! I 13 counsel are aware that the witness was available only for ggg 14 today and to make his flight connection to the west coast ,
i 15 It is now 4:05. I don't l, he had to complete this by 4:00. 16 intend to ask the witness any questions at this time. 17 l I have to say that, should it be necessary, I L i i 18 j may have to ask that the deposition be reopened to allow me I! 19 y to ask him questions. But that simply remains to be seen. u 20 j I'm assuming the witness will be available for questioning l i 21 il, in the matter. . i
. ]
. 22 j MR. MC BRIDE: I would like to say before we go !
I
. 23 off the record and have the witness confirm that the l 24 witness appeared here today voluntarily at Mr. Johnson's I '
25 , request, is that correct, Mr. Chwastyk? l tlk l 4 ACE-FEDERAL REPORTERS, INC. 202- W 3'30 Nationw ide Ca erage SiO 33MM6
l 29049.0 144 tayloe h 1 fl THE WITNESS: That is correct. 2 MR. JOHNSON: Would Mr. Chwastyk want to see the 3 i original for signature? 1 l 4 ! THE WITNESS: I would like to see a copy of it I 5 eventually. 6 i MR. MC BRIDE: I think I should suggest, then, 7 that what we ought to do in light of the witness' desire to 8 review the transcript and make corrections is ask the j 9 reporter to send the original of the transcript of this 10 deposition to me. I will forward it to Mr. Chwastyk, get 11 his corrections, and return them to the reporter with 12 copies for counsel. 13 MR. JOHNSON: Under our contract it comes to me O 14 and I will send it to you. I 15 MR. MC BRIDE: Fine. 16 i MR. JOHNSON: Thank you very much. I 17 !I (Whereupon, at 4:05 p.m., the deposition was 18 concluded.) 19 [ il i 20 h 21 ; l
, l 22 l JOSEPH J. CHWASTYK 23 !
24 i 25 f 9 , a 0 i ACE-FEDERAL REPORTERS, INC. a m.m3- x.e . . c ,. .,. e .>,s. ems
'145 CERTIFICATE OF NOTARY PUBLIC & REPORTER I -
.I, FRANK TAYLOE , the officer before whom the. foregoing deposition was takens 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 thereaf ter reduced' to typewriting by me or under my direction; that said deposition is a true record of the _ testimony given by said witness; that I am neither counsel. for, related to, nor employed by any of the parties to the action in which this deposition was taken; and, further, that I am not a relative or employee of any attorney or counsel employed by the parties hereto, nor financially 1
or otherwise interested in the outcome of this action.
./ - -: " i
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Notary Public in an'd for the
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. . . . . ____.. . ? O p September 1, 1982 --
,- (f bpct TMI-2 Reorganization Implementata.on Announcement h @ (d4 Locaten Three Mile Island ,f I " President, GPUNC (R. C. Arnold) / L Executive Vice President, GPUNC (P. R. Clark) !
Vice President, Oyster Creek (P. B. Fiedler) Vice President & Chairman GORBS (I. R. Finfrock) Vice President, Communications (W. L. Gifford) Vice President, Administration (F. Glickman) Vice President, Radiological & Environmental Controls (R. W. Heward) Vice President, TMI-l (H. D. Hukill) (R. L. Long) Vice President, Nuclear Assurance Vice President, Maintenance & Construction (F. F. Manganaro) Vice President, Technical Functions (R. F. Wilson) Pursuant to Mr. R. C. Arnold's August 2, 1982 memorandum the future regarding reorganizing our resources to meet an integrat-q challenges of the TMI-2 Recovery Program effort, ion has been assembled.
'qj ed GPUNC/Bechtel organizat This consolidation and streamlining approach is intended to maximize the available resources in meeting the demands ahead of us.
GPUNC will retain responsibility for overallThe radiation re-control, quality assurance and emergency programs.6, 1982. A organization was approved by the NRC on Augustrevision to the Recov tion Plan has been internally issued effective September 1, 1982. Phase-I The reorganization is being accomplished in two phases. will install the reorganization without modifying the Safety Review Process; phase-II will modifytothis process replace theby estab-Plant lishing a Safety Review Group (SRG) (PORC) and Generation Review Operations Review CommitteePhase-I will become effective on September 1, Committee (GRC). 1982.
~
Documentation required to implement phase-II includes the follow-ing: (1) Technical Specification Change l f* % ' (2) Docketed Organization Plan Change m hgn (3) Internal Organization Plan Change T J (4) (5) QA Plan Change Issuance of a Corporate Level Procedure "(9 y} { e' Approval for these items is targeted for October 15. 1982. A0000eJ8 W-____-_______
( Inclosed, for your information, are the Organization Charts 1, pages 1-13) with corresponding responsibilities (Attachment f for each of the six (6)' primary departments that constituteIt is intended j the reorganization.for=ation will provide you sufficient su==ary detail for this ; initial phase of the reorgani=ation. Major evolutions brought about in these changes included:
$ (1) Dissolution of Recovery Engineering and establishment of a Recovery Programs Depart-ment to include Site Engineering and Design Engineering functions.
(2) Establishment of a Licensing and Nuclear PORC, for the interim, Safety Department. will be reporting functionally to this department while remaining advisory to the Site Operations Director. A Risk Assess-ment section has been formed in this depart-ment to continue the function performedasby the Risk Assessment Task Force (RATF) reev ended by GOR 3. (3) A Technical Planning Department has been O- for=ed to provide appropriate e=phasis on that aspect of the project. The Government and Industry Program Depart-(4) directly ment has been realigned to report TMI-2, thus to the Office of the Director c=phasizing the role of external funding for recovery. In conclusion, these changes are intended to improve opera-i tional effectiveness of the TMI-2 organization by integrat ng the 3echtel and GPUNC activities, thus increasing management I attention to all aspects of the TMI-2 recovery effort. have been encouraged by the response of the organizationf tothe the changes and look forward to focusing the attention o j organization to the defueling and decontamination efforts. B. K. Kanga . Director, I-2 ves Attachment 1 (pgs. 1-13) cc: (listed on page 3)
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- o W ASHINGTON. D. C. 20555
(^;kh.s. ([f E July 28, 1983 MEMORANDUM FOR: Lake H. Barrett, Deputy Program Director TMI Program Office , FROM: Anthony N. Fasano, Chief f TMI-2 Project Section ..
SUBJECT:
PHONE CALL TO J0E CHWASTYK I spoke to Joe at 7:4L AM, July 28, 1983. This was a friendly call to ask him about his status'and to ask him if he had any safety concerns at this time.. He said he had resigned and is currently preparing his resume. He indicated that < he had no safety concerns. O
\)
~ m !) Ha Anthony A. asano Chiet, MI-2 Project Section
- l 1
I e 4
, UUuowe v v Dats:
Febru:ry 7, 1983 f .. Headlif t Punch 1.ist as a Management Tool 420083-068 Location: TM1/U-2 Site Operations Bldg. #222 - Room #109 R. Met:ger To: .
.n The' purpose of this memorandum is to once againd express lift tasks.my concerns on the use of a punch list as the means of managing the hea This is an inadequate tool for m,onitoring the progress of the project i because tasks.
it does not identify theksrelationships and rely on timely or tiesl
. implementing or final sequence on many of these tas
~
To date, input from other groups to maintain our schedule commitments. i input is you have not identified any instances where the group provid ngThere delinquent except for line #17. their cot:mitments, as Site Engineering / Design Engineering have not met The shown on the punch list, but were never shown as beingd delinquent. as delin-common practice used by these. groups to avoid beingthe identifieBy usin ified
,n quent is to "reforecast" the due date. impact downstream of t and the schedule changed accordingly. hing the
(*) cause as the i=plementor we are held responsible forfrom accomplis other groups. task on time, regardless of late input or lack of input It is your job This is not a realistic or logical management strategy. d ify as as the controlling group for accomplishing the head lif t to ifully ent unacceptable late input on the front end of these tasks, and to realize the i= pact to subsequently scheduled activities. To use a specific example, it was identified to you i letter 9 and 10. on thethat drain path and level indication for schedule line items ld The responsible parties were identified as Lake and Rider, but you fa to identify the fact that they did not meet slipped, modifying procedures, 24, 1982. Even though this front end input ks were still l h writing UWI's and the physical work associated with t e tas further. expected to be accomplished on time. ' To complica of a new accelerated schedule to support the " quick scan". As a further exa=ple,shown. the punch list item for final receipt of the fact
' head removal SER is still notOperations is 19,still 1983. being shown k' hat is not as de our comments were returned to Bob Rider on January n reflected is the fact allow for an adequate that review the ofSER in light waswith concerns notOTSG received l
1 eve . in su () i ( ;c%w;yq g:
~ y d:
l f,f,
- 4 4200-83-068 R. Met:gsr l .
' Esadlif t Punch List
- as'a Management Tool .
nly
. (}~ .h As I indicated to you and others, in your organization, t e ointerfaces re way to properly status and monitor all of theiled head lift schedule.
- the head lif t is through an integrated, deta lift schedule At this point in time, we have not had a detailed headThis is totally since November - 17, 1982. Mr. Thiesing stated- at least two weeks
~ d, but I be-questioned by management.ago that a revised detailed) head lif t sche
~
lieve his statement was-in error. d. When and if this 1 it does not this revised schedule has still not been theseissueschedule items. is identify the critical path items and the constraints to h n on One of the most critical items, the polar crane, is not even the head'11ft schedule. polar crane l is needed to accomplish many this item to complete on time will literal y pus schedule out to the right. ts , I am As a method of documenting my ability to meet our commitmenI hav preparing a form letter to notify you officiallyi when ing to our tasks. I am not using necessary procedures or engineering f January information ts and they were 17, 1983, pe
- your punch list addition form based on my experien ,
not inputed to the punch -list as shown. d I will be available to discuss any aspects of this memoran um. J w
- /
bd. King ; Site Operations rector j l LPK/JFP/jmv cc: File (s) 9 1 0 ( l
UU U UVU vvvv - Data: February 7, 1983 S ct: Concerns over Head Lift Schedule h v 4200463-069 B. K. Kanga/J. J. Barton Location: TMI/U-2 Site Operations j To: Bldg. #222 - Room #109 ,,
.. n L. F. King memorandum #4200-83-068 to
- FIFERENCE:
R. Metzger -
Subject:
Headlif t Punch List as a Management Tool (Attached) h"#
'L%kdcy,,gg$y ien l
, l Site Operations has expressed repeated concerns over not having an integrated schedule. In order to cope with meeting our end dates we'have developed detailed schedules to identify where information The referenced is needed to meet milestones on the master schedule.
memorandum to R. Metzger identifies my concerns. Verbal requests have not seemed to be effective in getting a response. We have spent several hours in a meeting in Room 209 discussing ',; a schedule that was put together at the last minute, with our input.
" This was only done because of the request by your office to hold the g meeting in your presence. .
The present head lift schedule does not show integration with the polar crane schedule and, if this had been done, it would have identi-fled that the crane was not available to support CRDM removal. I have reviewed the polar crane schedule and talked to the polar crane schedu-1er and the polar crane vill not be available to remove the missile shields until March 2, 1983. This fact has not been identified to you and certainly will impact " Quick Scan" CRDM removal and lowering of the water level. RD&D continues to work off mini schedules without identifying overall i= pact. Untimely delivery of engineering sof tware has caused late input of infor=ation necessary to write procedures and perform work. None of these coacerns have been identified in the RD&D head lift minutes and, consequently, no action taken to correct them. I believe the integrated schedule is needed i=ediately to identify any further impact on the June 30, 1983 date. Dave Lake needs more
- timely input to schedule resources and work in the containment.
The presence of your office is needed at the Head Lift meetings until we are once again on track to meet the June 30th co=1tment. l (U *
/. /
W -,- King . Site Operations Di ctor L?K/jmv
... r45. m
vuussv - - - - l February 10, 1983. o Cate k e J Nuclear suonet Review of Polar Crane Load Test Safety Evaluation 4240-83-111 L. P. King, Site Operations Location TMI-2 Plant Engineering
-To
-Director, TMI-2
~
Ref: Memo 4410-83-M-0141 The polar crane load test safety evaluation presented for review and comment via the referenced memo, is technically unacceptable to Plant Engineering. ' The polar crane must be tested before making any lifts, the failure of which could reduce the present margin of safety to the general public, result in damage to nuclear safety related or important to safety equipment, or that could result in a significant delay in the recovery program. Since this is not feasible in the absolute sense, the polar crane load test must be performed in a manner that achieves the necessary end result in a way that minimizes risk of further damage particularly to important to safety or nuclear safety related equipment. The necessary testing could be accomplished incrementally , (]) in a manner that meets the above stated concern and allows for " progressive requalification of the crane. For example, prior. . J; to lifting the indexing fixture, the crane and associated liftleast 150% o rig should be qualified to lift at the indexing fixture and associated rigging. Prior to lifting m-the missile shields, the cranc should be qualified to lift 150% of those lead's, and so forth. The qualification testing should be performed in an area of containment that is shown by an engineering evaluation to be the safest area in which to perform the testing and, of course, this should be an area in which the test load is at a sufficient 17' low elevation as to permit testing of the maximum amount of cable. It is important that the test load be lowered to the lowest elevation in containment that the crane is to be certified to . service in order to fully qualify the appropriate length of cabic. .
' e With regard to crane interlocks and controls, appropriate l interlocks and control features should be in place to prevent the crane from operating in untested areas or uncertified or l
undesirable modes. This is particularly important in view of the reliance on sound powered phones, hand signals, remotely stationed personnel to act as emergency breaker operators, etc., any of which could prove ineffective in an emergency. [h aem mq iQj f% 4 ^ V-3y fe 3;7
.S
KING - Page 2 . If'you have any questions on this information, please contact me.
- E. H. Gischel - Plant Engineering Director TMI-2 EHG:hh cc: R. P. Warren l
O . e W v
**- uuu vvu vv - -
%L. 'eb.ocry 17, 1983 J ,
gggg, Pohr Cranc Load Test - l (3 Satety Evaluation ~ V 4240-83-138 . J. W. Th$esing, Recovery Programs Location: TMI-2 Plant Engineering To: Bldg. F222 l
REFERENCE:
(1) E. H. Gischel memorandum to L. P. King
* #4240-83-111 dated February 10, 1983 (2) R. L. Freemerman memorandum to E. H.
Gischel #4300-83-F-0002 dated February 17, 1983 The purpose of this memorandum is to sur:carize the status of Site Operations review of the Polar Crane Load Test Safety Evaluation and document closeout of Plant Engineering's cot::nents which were the sub-l ject of References 1 and 2. k Site Operations coments, other than those of Reference 1, have been resolved. We assume that calculations are available te support the load drop analysis mentioned in the SER. The comments of Reference 1 were discussed extensively at the morning meetitig uit 7ein u.ely 11, 1903 with fir . lionsa in ritaahara. during an afternoon meeting on February 11, 1983 with Mr. Ranga, on the af ternoon of February- 15, 1983 with Mr. Barton, and again' on the ' afternoon of February 16, 1983 with Messrs. Barton, Kanga, Thiesing," Freemerman, Rider and Jackson. As a result of discussions at these meetings, Plant Engineering agreed to close out the comments of Reference 1 on the basis.of over-riding programmatic concerns which, in the opinion of program manage-ment, overshadowed the technical concerns of Plant Engineering. It is our understanding that a management position has been taken to turn the polar crane over after the load test. Although Site Operations has voiced a fundamental disagreement with the Polar Crane Retest Program, we do not challenge the authority of the Office of the Director to proceed with the program as written.
- 'QQ}yg
- n-ggg E. H. Gischel !
- %n-:kj9p!3rj Plant Engineering Director /IMI-2 l g,g M" Dy qm.
= . .
p,;: C ( r> s vL. P. King / Site Operations Airector/TM1-2
.., i 4240-83-138 ,
' Polar Crane Load Test February 17, 1983 I Safety Evaluation !
O . EHG/jtnr cc: J. J. Barton R. L. Freemer m l B. K. Kanga '
, P. K. Jackson
. R. L. Rider File (s)
O . e 4 e 4 e O
$-lse < h Y l Inter Office Memorandum ,
( pa e February 28, 1983 3 3 " 4370-83-1019 f {/ j " gg{ Sveiect Resolution of ' Coments: Polar Crane Load Test Procedure
*To L. P. King Location Three Mile Island Unit 2 Director, Site Operations Trailer 105
. File: 0303.1/4785 NR , l
~
l This memorandum transmits the Polar Crane Task Group's resolutions of Mr. Park's coments on UWI-4374-3891-6.$-l'C0001, Polar Crane Load Test Procedure. They have been reviewed by and are concurred upon by the Start-Up and Test Manager, Mr. Ed Kitler. Should you have any questions, please call Mike Radbill at extension 8865.
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/a D. M. Lake .
Manager, Recovery Operations
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Inter office Memoranduro , 1 bh March 1, 1983 IOM #4370-83-1019 Resolution to . ( Subject Comments on P/C Load Test 4200-BS 102- -i D. M. Lake, Manager Recovery Ops Location TMI/U-2' Site Operations To , , Bldg. #222 - Room #1091 , ,
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s This memorandum transmits Site Operations review of the Polar Crane Task Group'.s resolutions to comments made on the subject procedure, 6 dated February 17, 1983. We do not agree with the resolutions and have verified this position with B. E. Ballard, QA Manager and,, therefore, cannot approve the Polar Crane Load Test Procedure until these differences are resolved. Please refer to the attached re- ~ sponses to comments made on Polar Crane Load Test. Should you have any questions, pleace contact Rick Parks at extension 8423.
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'f J. Chwastyk k' [
Site Operations Director (Acting) attach. cc: B. E. Ballard (W/ Attach.) R. J. Barkanic (W/0 Attach.) dffjp$yy ] D. R. Buchanan (W/O Attach.) 9 '
;/4 J. C. Fornicola (W/ Attach.) ,..
R. L. Freemerman (W/ Attach.) '
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s's. C. h ann (W/ Attach.)
. B. K. Kanga (W/0 Attach.) ,
E Kitler.(W/ Attach.)
. R. D. Pcrks (W/ Attach.)
M. K. Pastor (W/At. tach.) ~ R. L. Rider ('3/0 Atcach.) R . P . Warren (W /l.! ta <.h. ) # File (s) (
- -- ~ -- - .-_.-__ -____. _______
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- - ;. Q. y ,, i 77 Canment 61 Resolution - Do not disagree with.your resolution this comment is better addressed by (V Licensing than at the departmental level. Cot =nent #2 Resolution - Disagree. AP 1047 does apply...per Section 3.1.1 of TI-1 " Individual Test Procedure" are the highest
** level procedure utilized by the test
., program and are used for P_0ST CONSTRUCTION
- testing, or integrated system / plant tests. A meeting was held with B. Ballard (Manager, TMI QA), J. Thiesing, R. Freemerman, E. Kitler, J. Barton, R. Parks, L. King on 2/23/83 whereby it was determined that AP 1047
N did apply to the Polar Crane Test Program. 4 Comment #3 Resolution - Disagree.' Format must comply with Section 3.1.1 of TI-1 of AP 1047. Refer to Comment
#2 Resolution.
Comment #4 Resolution - Disagree. Referenced UWI is not programmatically correct. The referenced UWI/ Test Procedure
- is a test procedure and is therefore governed by AP 1047 not the UWI procedure. Approval
' O cvc1e ret the uwt deee not cem>17 ith wo approval cycle specified by AP 1047.
Comment #5 Resolution - Do not concur with your resolution. It is Site Operations understanding that the SER submitted to the NRC specified certain incontainment systems aligned / isolated and/or drained. There should be a prerequisite for each system included in the Load Test Procedure. Coment #6 Resolution - Accept resolution. Co= ment #7 Resolution - Disagree. Again AP 1047 does apply , as does the cot:nent. Comment #8 Resolution - Disagree. AP 1047 does apply, therefore all testing performed is under administrative requiremcets stated in AP 1047. Com=ent #9 Resolution - Disagree. An " operational" tests implys
" functional", which is to be performed after turnover..in any case, it has been l
determined that both :he no load and load i ' test procedures are construction test procedures and therefore must comply with AP 1047 (. l
v-Comment #10 Resolution - Disagree. Again AP 1047 does apply. Refer to response #2. 7 '
\'~ ') Cowaent #11 Resolution - Accept resolution.
Comment #12 Resolution - Disagree. AP 1047 applys. C ent #13 Resolution - Accept resolution. Comment #14 Resolution - Accept resolution.
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, ,l m ate: March 1, 1983 . C.E.p
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Subject:
Applicability of AP 1047/1043 to Polar Crane Test Program f ( ' J Q [ 4200-83-105 To: E. Kitler, Startup & Test Supvr. Location: TMI/U-2 Site Operations Bldg. #222 - Room #109
REFERENCE:
IOM #4200-83-102 - Rejection of Polar Crane Task
. Groups Resolution to Site Operations Comments on Load Test Procedure Recently, much confusion has existed over the applicability of AP 1047 and AP 1043 to the Polar Crane Refurbishment / Test Program. On February 23, 1983 a meeting was held in B. Kanga's office at which time the attendees were informed of Site. Operations belief that the Polar Crane Refurbishment Program has to comply with AP 1043 and AP 1047. This belief was reinforced to the attendees by B. E. Ballard, Sr. - Manager of QA at TMI. Subsequent to this meeting, the Test Ucrking Group was convened on February 25, 1983 to review and discuss the necessary methods for ensuring that testing per-formed to date and any future testing complies with AP 1047 requirements.
It would be to the best interest of all involved if the following suggest-ions were implemented to resolve existing concerns.
- 1. Test Work Group review and concur that all testing performed to date was adequate for satisfying intent of required testing.
- 2. Test Working Group review modifications performed on Polar Crane to determine if necessary testing has been identified / performed.
- 3. Implement turnover process for the Polar Crane less the performance l of any remaining testing. This, testing should be identified as an incomplete work list item from the cognizant department. Any defic-iencies in the refurbishment program would be identified by this l process and adequate resolutions could be addressed.
l l 4. Test Work Group issue memorandum to TWG Files identifying inconsis-I tencies/ deficiencies, to date, and necessary steps implemented to prevent recurrence of program violations. In addition, it has become apparent that all requirements of AP 1043 and AP 1047 are not being incorporated due, primarily, to a lack of familiarity with these procedures. I suggest the Test Working Group members be made
. available to the various organizations involved with the Polar Crane Test Program for the purpose of indoctrination of personnel in the requirements of these procedures.
Should you have any questions pertaining.to the TMI-2 Test Program, R. Parks, W. Marshall, and R. Warren are the Site Operations representatives for the t___________________ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____. .
Applicability of AP.1047/1043 to -
-4200-83-105 Polar Crane Test Program March 1, 1983 L
Test Working Group'and are available for your assistance. v' Mg ~b /C I v . v. s i
, J. J. Chwastyk . ..
Site Operations Di ctor (Acting) cc: B. E. Ballar'd, Sr. t- J. J. Barton D. R. Buchanan.
'J. C. Fornicola R. Freemerman B. K. Kanga G. A. Kunder D. E Lake W. J. Marshall R. D.-Parks -
t R. Rider .. J. W. Thiesing R. P. Warren File (s) 4 e I I O
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Inter-Office Memorandum Da e March 4, 1983 4410-83-M-0198 4400-831064 ff ( 'J QQ $h[ Subiect QUALITY ASSURANCE COMMENTS ON POLAR CRANE LOAD TEST SER
. To " ETH;E Barrett Location TMI-2 Licensing and Nuclear Safety Attached per your request is GPUNC memorandum 6110-83-039 from B. E. Ballard to B. K. Kanga dated February 23, 1983, I l discussing Quality Assurance concerns regarding the Polar l Crane Load Test Safety Evaluation.
If you have any questions, please feel free to call. l
- n V
J. E. Larson l I-2 Licensing and Nuclear Safety Director JEL/JJB/jep Attachment , i CC: J. J. Barton/B. K. Kanga : B. E. Ballard V '/i. E[jjf G. A. Kunder ("Il fQg b E r= a S hF
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e . Inter-Office Momerandum o Date Suojet: February 23, 1983 Polar Crane Safety Evaluation bdNuclear 6110-83-039 To B . Y.. Kanga Location TMI Trailer 175 Director, Unit 2 Quality Assurarce has reviewed the Safety Evaluation for the Polar Crane Load Test and the concerns that have been raised per your request. The calculations to back up the Safety Evaluation were reviewed. Bechtel Quglity Assurance was requested and has reviewed the calculations in Gaithersburg and GPUN QA has reviewed the calculations available on site. The only calculations available at the site were B&W analysis of decay heat removal, whic,h were originally performed to support quick look, but are also applicable to the loss of components due to load drop. In the Safety Evaluation, some events were evaluated in a probabalistic manner and no calculations were made. One example is the drop of a missile shield directly on the Reactor Head. The extent of damage is postulated and not backed up by calculations. Our review also identified two items that were not specifically addressed in the Safety Evaluation:
- 1) The load test should qualify the same length of cable that will be required for head lift.
- 2) Ioad testing of the fabricated load test frame prior to Polar Crane load test has not been addressed, although all other rigging components have.
There have been additional concerns raised that are not directly related to the Safety Evaluation but which could be a potential problem. We plan to investigate the following areas in more detail and will inform you if our current program is inadequate:
- 1) Training for operators and personnel directing the load test.
- 2) Calibration of the load cell.
- 3) Modifications to the Polar Crane--concerns have been raised that all modifications to the Polar Crane were not appropriately documented.
- 4) Test Program - verify that the progra==atic controls for testing were followed (i.e. , AP-1043 and AP-1047 have been complied with) .
I
- 5) Reverify inspection and refurbishment documen ta tion .
A0000d48
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B. K. Kanga Memorandu:n 6110-83-039 [D February 23, 1983 Page 2 I would reccx: mend Engineering assure themselves that they have adequately covered the two items noted concerning the safety Evaluation. Though these
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items may not require any modification to the Safety Evaluation, they may require change or review for applicability to the actual load test implementing procedures. In su= mary, we in QA have found no significant programmatic problems with the Safety Evaluation or the Polar Crane refurbishment process but we will continue to assess this program and keep you appraised of any problems discovered. It should be noted that there appears to be a number of technical concerns being raised and these should be addressed fully by Engineering. An interesting item to note which we did discuss within QA was the approach Bechtel has taken on this specific Safety Evaluation. Though it is accept 2 1e from a programmatic and engineering standpoint to perform the evaluatation based on a worst case scenario, in our recovery mode, there may be some operational considerations that may make this approach not always prudent. An analogy is, in our industry for years we considered the large break LOCA the worst case limiting accident before the TMI accident, where as now we have learned that a small break LOCA deserves equal attention. Senior Engineering management ] I $ should perhaps review this issue. G bB.C. b OOn.t.o E. Ballard, Sr. Mpnager - TMI QA Modifications / Operations
. BEE:JFM: cam cc: N. C. Ka anas R. L. Long CARIRS a
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-tr.,w Inter Office Memorandum .l O 4 er" Nuclear s
4345-83-0005
- m , o . i,82 TWG Meeting Minutes of Suogct March 4,1983 1 Locahon Administration' Building To D.' Buchanan ,
G. Clements J. Fornicola R. Gallagher ;i J. Marsden R. Parks y M. Radbill ? '~ J. Thiesing '
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D. Walker h R. Warren Attached are the minutes of the TWG meeting held on March 4,1983 to discuss Polar Crane issues.
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% 4- z 3 E. J Kitler y Startup & Test Manager - Unit II Plarf ff) d $~YP3 TWG Representative lq0(/J 0.;tJLK 353 Plant Engineering 'ING Representative 00el! 9 31 83 Site Engi eering G G Representative s G 00nu 3-7-15 QA %d/0ps TWG Representative DRB/DDW/jaa Attachment A000 1
TWG MEETING MINUTES o I A TWG meeting was' held on March 4,1983. The following persons were present:
-TWG Dwight Walker (SU&T)
Rick Parks (Plant Ops) John Fornicola (QA) Ron Warren -(Plant Engr.) I Rich Gallagher (.SE) GUESTS Gordon Clements (PORC) Mike Radbill (PLTG) Dave Buchanan.(SE) Joe Marsden (QA) The meeting was held to discuss the following polar crane issues:
- 1. Load Test Procedure status
- 2. Review of all data given to QA/QC
- 3. Result's of No-Load Test O 1. Load Test Procedure John Fornicola stated that QA had coments on the load test procedure.
All but one of the coments were administrative. Coments will be pro-vided to_ group members when issued. All TWG members were given a copy of the load test procedure for final review. Coments are to be given to Mike Radbill on Monday, March 7. Rick Parks considered it was inappropriate to provide separate SOP's to cover prerequisite valve lineups. It was agreed by TWG that lineups could be included on UWI 4370-3891-83-PC-0001 cover sheet.
- 2. Results of QA/QC Audit of Polar Crane Task Groups Documentation of Work l on Crane I Joe Marsden stated that all deficiencies would be covered with one QDR.
He noted that many of the modifications were made without ECM's. Back-
, fits could, however, be accommodated with engineered drawings instead of
}. ECM's. He noted the following specific modifications made; not in accord-L ance with AP-1D43:
- 1. Trolley power and control bypass system
- 2. Installation of 200 amp fuses in main disconnect in cab of polar crane (vice 300 amps)
- 3. New pendent station and festoon cable
q TWG Meeting Minutes V Page Z
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- 4. Installation of two mounting brackets for jib crane on trolley .)q
. 5. Installation of temporary air supply on crane. .
The QDR will be submitted to Jim Thiesing. It was noted that th'ese items had been discussed with Design Engineering. Other deficiencies noted were lack of compliance with AP 1047 and 1043, and p O missing signoffs on UWI's and Work Packages. It was noted by John Fornicola that the no-load test should have been re- w viewed by TWG but was.not. . M
- 3. ~No-Load Test
. John Fornicola stated that all QA coments were administrative in nature. ,
b Rick Parks expressed concern that in the no-load test procedure, Steps 85, 92, 220, 228, 320 - and 328, it is not clear whether the limit switches functioned. Mike Radbill agreed to provide written clarification. ; It was agreed that the following opm; items of UWI 4374-3891-83-PC-0002 h' would be resolved piror to the load test: ,
- 1. Upper geared limit switch needs verification of operability. Y
,e
- 2. Trolley limit-switches need verification of operability.
- 3. Lubrication of main hoist gears on trolley.
- 4. Additional Discussion ;
Mike Radbill noted that P.C.T.G. performed adjustment and verification of proper operation of the upper rotary type geared limit switch. This was performed via an approved UWI. It was agreed that it should have been re-viewed and signed off by TWG members. Mike Radbill will initiate a < Startup Problem Report to address this. Rick Parks questioned whether the polar crane hook had been used to lift any loads. Mike Radbill stated that, to the best of his knowledge, the , i
- hook had net been used to lift any loads.
John Fornicola noted that no testing has been listed on the MTX. It was j i agreed that all further testing would be listed. 1 h In response to concerns from Rick Parks, it was agreed that TWG is not re-quired to approve lifts using the five ton hoist attached to the polar ? crane main hook. Mike Radbill noted that Recovery Ops was directed by Design Engineering ., to install dumy fuses vice 200 amp fuses in polar crane main disconnect. a 1
=
s TWG Meeting Minutes Page 3 O It was agreed an ECM would be required. For the sake of expediency, Rich Gallagher agreed to prepare documentation utilizing AP 1013 to perform this modification in advance of ECM approval. It was agreed that performance of the load test would be in compliance with AP-1047.
~ 1 It 'was' agreed that disposition of the QDR discussed in Section 2 should not affect acceptance of no load test results or TWG acceptance of the
. load test procedure based on technical content, i
O 1 l 4 l e 1 e--_---.__.---_.-.
. 4
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Quality Deficiency Report (GDRI (3u w . m i
.At iction of Deficiencies Com !sted by initiator: %M%.Mggg um. o initiator; J .F. Marsder U-2 Pre 4.OA Ent.OA M/ /8/F7 0000 Tr.csecu- 0 4 2, .- ,
Name , i Recuireme ntish Sm-se-, k 1 1_9 r% , T7a d - 9 **anve.-v OA Dis- Snee 40 e-a .e 4- . , , . _ .
;. " Measures shall be establish'ed to control and coordi .ste the aetroval and iseuance of instruction. rrecedures and dre.-fr-e tac *r!'-e eksaeae_ v' ' e ' ' .ee es, ,11 T-,r--n-+ n cas . ,. . ,. - 4 . . e - d , , ." /
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- 3. D eficio ney: (continued) ,
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.Recuiremet: Section continued: .
s
.' I standards, specifications, and criteria.
" Proposed d nce with The Unit 2 Recovery CA Plan, Page 61, Paragraph 6.11.
the' applicable requirements:of the .I.icanse and Techn caconstruction, testing and procedures governing the design, procurement, d ce=penents Important j inspection. . Modifications to structures, systems and in accordance with the requirements
- to Saf ety shall be reviewed and ,accepte ,
of'this ?lan. A' s Deficienev Section continued: Construction and operational tests were performed on the crane to test 1ve con l procedures, however; the ad=1mistra: Exa=;1es are as follees: Test Manual", vere not conplied with. f 1) The tests were not included in the MTI s
- 2) Scopes were not prepared F
i 3)' TP fo =ats were no: used
- 4) Test status was not kept
- O
- 5) Test briefings were not conducted *
-4 " 6) Start Up t, Test Engineering log was not maintained - a
- 7) A prerequisite list was not maintained e
/11 refurbishment and testing activities on the Polar Crane were to 3echtel k'ork Packages.
g procecure that has not been appreved by a y other organization at TY.!-2 s for perforcing work. 9, -
+
Specific problems identified in associated work packages vill be reselve. f in' the resolution of the individual work packages. M u W # y. b .g. , ar . ., :h n) * . 7 - . - . . J _g
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f itien A:s';;ned te: (ssre:cire ) C:use:
,s d At the initiation of the polar crane inspection and refurbishment progrs=, maintenance joo ticket CA258 was issued (copy attacnec). inis j ob ticket requestec maintenance ,
socification, anc refurbishment or tne polar crane as ceemec necessary witn turacve; to olant operations to be accompanied by proper documentation regarding inspection, re-furbishment, modification, and testing utilized to place the crane back in service tor ' i head lift. Ibis job ticket was unoerstooo oy GPUN and Bechtel, at that time, to nave
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/ CONT
- Cette:pAIED:-QN A'V. AQHMENT 1)..:,ccing a: .::n re::utred i: prevtn tt:Urte .:s)
..v e - .n o n:
- 1. For future tasks, all modifications and modifications related tsting vill be perfo ed
- under the controls established in AP 1043 anc AP 1047 respectively. in accition, a12 Recovery Programs personnel responsible to autnorize work aCCivities w11. De t.rainec in eb Ad-inistrative Controls delineated in AP 1043 and AP 1047.
~2. All Recoverv Procra= orecedures recuired to satisfy the requirements of the nf1-2 license. technical specifications, receverv overstions clan. or the recovery OA Plan will be aceropriately i=clemented by the Unit 2 Procedure Program.
- 3. The Unit Work Instruction will be utilized when required by procedure f or all Recovery Programs work activities.
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3.- ACTION - (Continued) . ...; CAUSE: administrative 1y severed the polar' crane from the plant and to have placed it' in a " turned back to construction'! condition for refurbishment and testing' . .
. This allowed engineering direction!and decision making to' flow'in a more- -
. streamlined ' fashion since many required refurbishment steps could not be defined until after inspections and tests were performed. Later' review. -
of the THI-2 administrative procedural requirements has determined that no such "turnback" is provided for. Under these conditions, all modifications to the crane would liave to have been implemented ;.via S-ECM's, and' testing-would.have to have contemplated not only the_ substantive requirements of AP-1043 ~and AP-1047- (which are being met) but also the format and sequenc~e requirements contained therein. O s
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Intor Offico Mamarandum m . March 10, 1983
]
km INuclear at' 3 09: POLAR CRANE RI7URSISHMENT REVIEW . 6110-83-046 IO J. W. Theising Location TMI Trailer 175 Manager, Recovery Programs
/
~
We had com=itted to reviewing concerns that had been raised on the Polar Crane Refurbishment to assure that there were no open items or potential problems that could impact the acceptability of the crane for load test. The review covered verification of inspection and refurbishment documen-tation, documentation and approval of modifications, test program, training for operators, and calibration of the load cell to be used for the load test. The results of our review are as follows: The " Work Packages" that documented the work performed on the Polar Crane were reviewed and the follocing general comments were noted. (1) Several modifications were made without issuing an ECM. Most items found were "Not Important to Safety" but the requirements for documenting design changes on an ECM still apply to assure appropriate design reviews e and configuration ccntrol. The work packages that implemented =odifica-tions were: M-0024 - Installation of temporary Jib Crane. E-0046 - Inst:llatien of Pendant, Cable and Festoon Cable. E-0055 and E-0059 - Trelley Power / Control Bypass. l l E-0037 - Polar Crane Control Cabinets (letter CIE-737). 1 (2) In a number of packages, it was identified that substitute lubricants / oils were used and the engineering evaluation and documented acceptance l for use were not included in the package. (3) Site Engineering had not reviewed / approved all of the work packages submitted. (4) The " marked up drawings" or " data sheets" required by various inspection plan peints were not always part of the submitted psekages. 4 (3) Even though "qc" did have involvement in some Of the work packages, the ! "QC" block (Item 8 of the work package) was never checked "yes." 1 (6) Package signof f s (signof fs for individus1 steps) were incomplete - in some cases the work was done and the signatures had been erroneously omitted. (7) In many of the packages " design engineering evaluations" had been made by the " inspector" without documented corroboratica from engineering. 1. Accoo648 ~ __
y! ,- %p ~m l Memorandum 6110-83-046 March 10, 1983 gl~ 73
~~
Page 2 m 3:, m: 4+ 1 4 g (8) In many cases, there was no link between packages identifying a discrepant , JJe condition and later packages which either clarified or resolved this conditi
.m 4W . g;#; (9) Many of the packages did not contain sufficient infor=ation to adequately document an activity (package indicated that at item was lubricated but @@pp. does not specify what lubricant was used). j f a s.; r ;
- d. M (10) The Work Package equipment list was generally not completed, providing no means of verifying what equip =ent on the list was utilized. !
5 (11) Work package ite=s were modified, deleted, signed off as meeting the " intent i of the document refetenced, or steps were added subsequent to reviews by dij{q outside groups. s w @ h< l w d5 The specific proble=s with each work package have been discussed with the Polar i Crane Task Group and have been returned for their correction. The majority of l Q"i M che problems found were administrative in nature. The items identified in (1) l Mi above could.be a potential proble= if the appropriate design reviews were not p$; performed. These items have been referred to Design Engineering to determine 15h if the appropriate reviews were completed and documented. Design documents tg; will be required to be updated. The violatien of the Administrative Controls e[ for modifications will be documented on a Quality Deficiency Report. t? '
-C s xis ; The Quality Control activities associated with the Polar Crane were reviewed.
g The QA/QC scope is identified in the Polar Crane Functional Description, 9;p 2-M7 2-miO2. This is consistent with the safety classificatica in ES-Cll.
- (( '
Quality Control perfor=ed visual weld inspections, magnetic particle examination g* of the main hook, and uitnessed the operational (no load) test as inspections 3{k
@.s required by Engineering in the Functicnal Description. In addition, Quality Control provided additional inspection support, visual and nondestructive g exa=1 nation, on so=e Not Important to Safety items. The Inspectors certifications R
M : and eye examinations were reviewed and all found satisf actory. Ne The testing that was perfor=ed on the replaced or modified components and the M operational test was reviewed. The tests were technically adequate. The results h$p of the tests were not always clearly docu=enced and a TWG review of the test Ud ; results generated ccm=ents requiring clarifit: tion of test results to the D Operational (no lead) Test. The Ad=inistrative Program controls for testing g (A? 1047) were not followed. The Administrative Program violation will be
- n. iw .
documented on a Quality Deficiency Report. d The training program for operators and for personnel directing the load test M. . was reviewed. A Quality Assurance Monitoring was also performed on the training
& sessions being conducted. All operators -invol.*ed in the load test are to be 4 qualified-under the standard c:ane operator training program and specific polar j d($@ @ crane (as refurbished) training . Practical factors are demonstrated by hands-on d/' experience with U-l Polar Crane and the Operational No Lead test of U-2 Polar
- -- \
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4
.A-A . ~4 l
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___.__o
Memorandus 6110-83-0!.6 March 10, 1983 I c ge Pa 3
,f Crane.
The training program was considered satisfactory. Calibration of the load cell has been incorporated into the load test procedure with a specific sign off verifying the calibration date.
'&C
- 0-<4 B. E. Ballard, Sr.
Manager - TMI QA Modifications / Operations i 1: f 1' LIB /JFM/crf ' cc: J. J. Barton ' D. Buchannon 2-J. Chuastyk i R. F. Fenti [' J. C. Fornicola E. Gischel B. K. Kanga N. C. Ka::anas G. Kunder O D. Lake J. F. Marsden M. Radbill f R. Rider . l S l l a s _
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_ 509 M L Inter-Office Memorandum
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Idd Muclear al Suolect %'G Minutes of 2/25/83 iocat'on Administration Building To Distribution Second Floor The Test Working Group agreed that the polar crane load testHowever, will be a l construction test performed by the po.ar l crane task group. since the load test demonstrates the operation of the crane the TWG ;1-will review and approve the test proced0re based on technical content and demonstrated functional operation of the crane for turnover to plant operations. The TWG will review the polar crane no load test data to ensure adequate testing has been performed prior to performance of the load test.
/! / /)
[l $ G C Stptup lind Test TWG Rep. Mant Ops. TWG Rep. El Plant Eng. TWG Rep. Wh0db '-- Site EnfiWG R6p. G QC TWG Rep. EJK:cle Distribution: J. W. Thiesing
@MM Yhf! b-R. P. Warren R. E. Gallagher M[hgMj;j J,ysem
"<dPS E. J. Kitl er R. Parks J. J. Fornicola a . ._m
33;,: 3/17/83 u . ~ .R: tl1
-.7
Subject:
TWG Membership
~
O L/ 4200-63-147 Tc: E. Kitler, Supervisor of Stsrt i*p Lo ca - t er. : TM1/..
- c. . Site Operations and Test Bldg. 222 1
Effective immediately, please consider V. Marshall as the , Primary Site Operations Departrent representative to the T4G. Mr. Marshall will replace Mr. R. ? arks as the primary member only for the Reactor Build 1ng Polar Crane prcject. This action is considered ap7r- riate for the present situation and is not considered a negative reflection of Mr. Park's ability, conduct or performance.
- The designation of Mr. Marshall should not adversely affect the Polar Crane Refurbishment Schedule.
t
, s. .& //
/ .//
/ , f lyRV, a f Ch'astyk w
.ite Operatiens O_.e:trr, g
,f,,/ (Acting) l
) JJC/bjs cc: W. Marshall R. Parks
.. J. Barton B. Kanga File I
.76= -
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- . .- 0
,2 g+g p -
y i I' TMI-2 : POLAR CRANE RECOVERY ;f ),j
', WEEKLY REPORT ,
( .. f30 MARCH 4 1983 l WEEKLT 51 W ARY
- Tha Polar Crane Recovery effort has continued to concentrate on approval of ths Load Test Procedure and the Crane operating Procedure. During the last' five weekly reports, the projected date for approval of the Load Test Procedure ,/ l has slipped accordingly. This is directly attributable to the repeated rounds ,
cf coussents from the various site review groups. The Load Test Procedure is 'l cow in it's third revision and is about to be issued for the fourth time since L January 31, 1983. Each additional round of counnants and the subsequent re-visions delay completion of the procedure by approximately one week. Revision 3 of the Load Test Procedure vill be issue'd for final sign-off on Tuesday. 4 , March 8, 1983. The Crane operating Procedure is still Revision 0, however it jl l has also been subject to repeated rounds of comments from the site reviev groups. H Both procedures are now expected to be signed-off by all site groups no later than . Friday, March 11, 1983. This date is predicated on the assumption that no addi- j haicommentswillbereceivedfromsitegroupsinthesign-offcycle. The ] l Dirsetor of TMI-2 has placed a hold on implementation of the Load Test Procedure pl l lpandingtheoutcomeofaformalreadinessreview. GPU upper management has con- l 4 h, vansd the review to insure that polar crane refurbishment has proceeded in a safe cod technically correct manner and that the load test procedure is safe. Upon , i j co=pletion of the review on March 12, it is axpected that the Review Board will conclude that the refurbishment work was done well, is sufficient, and that the pro- h
! cadure is safe. This favorable conclusion vill .in-tum trigger release of the hold I q
! on implementing the load test.
. j j'
. O p
O - l <. I w o (g
r i TMI-2 POLAR CRANE RECOVERY M v
. WEEKLY REPORT
__#30 MARCH 4. 1983 THIS WEEK
. During the week of February 28 - March 4. the Polar Crane Task Group concentrated
- on expediting and coordinating approval of the Crane Operating Procedure and the Lead Test Procedure. Both procedures prompted additional comments during last 3 j
. week's sign-off. As a result, procedure revisions have been made throughout the '
week as comments have come in. The procedures will be reentered into the sign-off cycle next week. Sign-off is expected to continue until late.next week, followed by NRC review and approval. Incontainment work this week has been limited to two entry days. Lack of an ap-proved Crane operating Procedure has prevented assembly of the load test frame
'eteel. The steel's location on elevation.305' has also restricted access for other l incontainment work such as decontamination. This week's entire entry program has j been limited to approximately 30 jobbours. ~
i Incontainment Polar Crane Recovery work this week consisted of checking and adjust-ing the polar crane main hoist geared limit switch. First .the electricians veri-fied that the weight limit switch was operational. The load block was then lowered and the geared limit switch was set at the specified elevation. As a final check, operation'of the geared limit switch was verified several times by raising the load h block until the limit switch stopped the hoist. During the entry, the polar crane electricians also replaced the L-60 interlock on the main power contactor in the polar crane cab. The interlock had been causing difficulty getting the crane " turned or." . Other incontainment work this week included a checkout of the polar crane spider
. es a result of last week's difficulties.
Out-of-containment work has continued on the preparation and review of work psekages for upcoming Polar Crane Recovery work. Work piackage E0077 - Remove Head Sterage Stand Jib Crane Control Pendant has completed the Rad Engineering review and is in final UWI sign-off before implementation. The Polar Crane Task Group has completed writing the following work packages this week and entered them into the review cycle: E0083 - Install Brake, Clutch and Coupling Covers; Insta'11 Headstand and Reactor Centerline Markers. (UWI-4374-3891-83-PC-011) E0084 - Redress Trolley Bypass Cables; Reinstall Covers on Motors and f Pull Boxes. (UWI-4374-3891-83-PC012) ' E0085 - Set Trolley Limit Switches; Replace Resister Bank Covers; Tag-out circuit Breakers. (UWI-4374-3891-83-PC-013) 2' i l M0025 - Lubricate Polar Crane (Revision 2)-(UWI-4374-3891-83-PC014). M0046 - Clean-up Head Lift Pins Prior to Load Test (Reviaton 3)-(UWI- 4 4374-3891-83-PC009) . A 4.
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i < i t ;
, p 2rk packages' E0084 and 10085 consist' of miscellaneous items which .must be com-Work pachage M0025 - Lubricate Polr Crene has been \
)tsdpriortoloadtest.
revised to incorporate lubrication of the polar crane motors.
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l ochar activities this week include - e e LOAD TEST i The Polar Crane Recovery effort has continued to concentrate on , O"
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approval of the Load Test Procedure and the Crane operating Pro- " cedure. Both procedures have received additional cosaments during ". the_ current week. The Load Test Procedure was reviewed by 4 for /~ compliance with requirements.of AF 1047. Review comments were pro- ; vided on March 4, 1983. Revision 3 of the procedure will be issued l for finsi sign-off on Tuesday, hrch 8,1983. Additional comments l ; have been incorporated into the Crane Operating P'rocedure this week. 1 ) I The operating procedure will siso be reissued for final sign-off by Tuesday, h rch 8. Both procedures are now expected,to be signed- This. off by all site groups no later than Friday, March (!J (1983. i date is predicated on the assumption that no additional comments will
' be received from site groups in the sign-off cycle. k Ai'terThe site final sign-off, the Load Test Procedure must be approved by the NRC. '!
- Crane Operating Procedure will be reviewed by'the NRC, however formal sign-off is not required. ' Advance copies of both procedures have been hl sent to the NRC. This should expedite the final NRC review and approval 3 cycle.
Work package M0047 - Lead Test of Polar Crane is currently being re-O vised and will be reissued next week (March 7 - 11) under a new UVL Review and sign-off of the work package will be independent of the ! Load Test Procedure. Assembly of the lead test frame is scheduled to ; resume on Monday, March 7, 1983. Provisions have been made which bill g allow use of the 5 Ton Boist for assembly of the load test frame, e MANAGEMENT READINESS REVIEW f l 1 GPU upper manasteent has elected to convene a formal readiness review for the Polar Crane on Saturday, March 12. The purpose of.the review i
; is to insure that crane refurbishment has proceeded in a safe and Until tech-l nically correct manner and that the load test procedure is safe. I the Review Board has completed its review and given approval to perfom I the load test, the Director of TMI-2 has placed a hold on implementation ;
of the lead test procedure. At the review, representatives from Design Engineering, Recovery Operations, Licensing, Plant Operations, Site Engi-nearing and @ will brief management on progress and results of polar crane refurbishment work done to date. Upon completion of presentations,
' it is expected that the Review Board will conclude that the refurbishment work is well done, is sufficient, and the Icad test procedure is safe. I t
After notification from the Board, the Director of TMI-2 will remove.the ! hold and direct that the load test be performed. e POLAR CRANE SPIDER This week's incontainment work included a team to check-out Last Triday the(Tebruary polar
.h crane spider and replace the center safety cable.
- 25) the spider center safety cable was fouled by one of the personnel safety lines during remote operation. The safety cable was replaced due i
to a " kink" in the cable caused by the fouling. Changes have also been '( i R
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3
.made in the spider operating procedure to prevent similar occurrences O
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in the future. Before the spider is remoted down, two people will
' ascend to the polar crane by the ladder. They will insure that all lines are clear before they remote the spider down for additional personnel and equipment.
e REPORTS .
- The Polar Crane Task Group has made a concerted effort this week to finalize Polar Crane Recovery work by issuing final reports to Design L Engineering. As noted previously, the final wire rope inspection re-
- port vaa issued the week of Tebruary 18. This week the followfng reports wn e completed and issued to Design Engineering:
i e Main Hook Inspection. l e Final Gear Case Oil Sample Results. e Bridge, Trolley and Main Hoist Drive Functional Tests and g Motor Refurbishment. e Resister Banks Static Tests; and Bridge and Trolley Banks Replacement. e Replacement of Control Pendant, Cable and Testoon; and Bypass of Trolley Collector / Rail System. The balance of the Polar Crane Recovery reports are scheduled for final issue to Design Engineering during the next two weeks. They are as O follows: e Runway Rail Inspection. e Final Results of the Initial Mechanical and Electrical Inspec-tions. e Structural inspection - Final Report. e Partial and Full Operation No Load Testing. e Main Beist Limit Switches. e Rigging Inspections. NEIT VEEK Incmstainnent Polar Crane Recovery work ne.xt week will concentrate almost exclusively on assembly of the load test frame. The load frame steel will be lif ted to elevation ~j l
- 347' and assembled as the final preparation before progressing into the ' lead test se- '
l qu2nce. Assembly is scheduled to be completed by March 10, 1983. These and other entries scheduled for next week (March 7 - 11) are as follows: s
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C0065 - Polar Crane Load Test Frame Assembly - March 7, 8 and 9. C0070 - Install Elevation 347' Removable Beams and Grating - March 8 0 and 9. ; ) .
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C00f44InspetLoadTest?rameAssembly-Thursday, March 10. M0046 - Clean-up Head Lift Fina Prior' to Load Test - begin Friday, March 11. . Other activities for next week (March 7 - 11)' include issuing the following reports to Design Engineering: . e Runway Rail Inspection. ' I l
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/> Final Results of the Initial Mechanical and Electrical Inspections.
1 e Structural Inspection - Final Report. ; I I e Partial and Full Operation No Lead Testing.
- Main Hook Limit Switches. '
l: l_, i Peler Crane Recovery /Requalification work next week (h rch 7 - 11) will also include: !- e Reissue the Load Test Procedure for final sign-off.
;i e Raissue the Crane Operating Procedure for final sign-off. .1 e l !I Revise work package,M0047 - Load Test of Polar Crane.
e Issue Revision 5 of the Polar Crane Recovery Intermediate t Schedule (TIS-101). ;; 1, MATERIALS i1 e New Load Cell Rigging for the Polar Crane Load Test is scheduled ! to arrive on site March 11.
!1 Any questions concerning Polar Crane activities should be directed to Mike Radbill :I cc extension 8865. ,
ll
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- Mn4k M. E. Radbill l !
i 7 sr Crane Task roup Leader l l]
- r. c, CONCURRENCE D. . Lake 'I Manager, Recovery Operations M N JKW:jcb *
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mg 3/17/83. ,17 l <__ -- (, 4, Tk'G Membership Cf y J_ w, sg\,,6) (, ;;
?a
Subject:
I9 Tc: E. Kitler, Supervisor of Start Up Locatio.: 4200-63-147 TMI/i*-2 Site Operations and Test Bldg. 222 1-I ' Effective immediately, please consider k*. Marshall as the Primary Site Operations Departr.ent representative to the T.JG. Mr. Marshall will replace Mr. A. Parks as the primary menber only for the Reactor Building ?clar Crane project. This action is considered appr- riate for the present situation and is not considered a negative reflection of Mr. Park's I ability, conduct or performance. The designation of Mr. Marshall should not adversely affect the Polar Crane Refurbishment Schedule. I / Ff ;h
/ Kf'/'Ch'astyk i.w .'/5 4
g _ite Operations 0..e::cr, p/ (Acting)
-l ,
3 JJC/bjs cc: W. Marshall '" ""
. R. Parks 1 J. Barton b' ' ,gfi I .
B. Kanga File Tij, .; Jy@G yc y.e I 3% 1:.
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