ML20238C682
| ML20238C682 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 01/14/1987 |
| From: | Buchanan D GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20238C505 | List:
|
| References | |
| CIV-PEN, EA-84-137, NUDOCS 8712310153 | |
| Download: ML20238C682 (35) | |
Text
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N ORENA'" UlN11ED STATES l
4 NUCLEAR REGULATORY COMMISSION O
i IN THE MATTER OF: DOCKET NO: 50-320 (Civil Penalty) ,
GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION (Three Mile Island, Unit 2)
I .
h LOCATION: MIDDLETOWN, PENNSYLVANIA PAGES: 1-32 DATE: WEDNESDAY, JANUARY 14, 1987 ACE-FEDERAL REPORTERS, INC.
CWi:ial Reporters
~&. 444 North Capitol Street Washington, 'D.C. 20001 (202) 347-3700 0 NAT!oNw:CE COVERACE T
i l UNITED. STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
- - - - - _ - - - - - - - ... _ _ - x.
In the Matter of: :
- Docket No. 50-320 GPU NUCLEAR CORPORATION : (Civil Penalty)
(Three Mile Island Nuclear Station, : .Licens'e No. DOR-73 3 Unit-No. 2) : EA 84-137 1 I
- l
..--x .
Pages lthrough -
.3 2 - Nuclear. Regulatory Commission-100 Brown Street j Middletown,. Pennsylvania Wednesday, January 14, 1987=
Pursuant..to. notice, the. deposition of David'R.
Euchanan~.was taken before Inc,.J.udith A.~Toberman, Notary Reporter, commencing at 2:10 p.m.
'(
~
APPEARANCES:
GEORGE E. JOHNSON, Esquire COLLEEN P. WOODHEAD,' Esquire United States Nuclear Regulatory Commission Office of General-Counsel-Washington, D.C. 20555..
(For the Nuclear Regulatory Commission)
KENNEDY P. RICHARDSON, Esquire Thelen, Marrin, Johnson & Bridges One Kaiser Plaza, Suite 1950 Oakland, California 94612 (For GPU Nuc3 ear Corporation)
Commonwealth Reporting Company, Inc.
700 Lisburn Road Camp Hill, Pennsylvania' 17011
%/ Camp Hill Phltadelphia ,
(717) 761 7150 (215) 732 1687 l 1
,.M o
~
MR. JOHNSON: Mr. Hickey, would you introduce yourself?
21
'MR. ' HICKEY i ' Patrick Hickey, counsel for GPU Nuclear; 22 and momentarily absent is Kennedy P. Richardson, also counsel 23 for GPU Nuclear. i L( 24 BY MR. JOHNSON:
25 g Mr. Buchanan, you said you are currently' manager of i COMMONWEALTH REPORTING COMPANY (717)761-7150 C_m_ -
_______m _
s2. 4
- <*
- l f I recovery engineering?
t f.
s
-1 2 .A That is correct. '
3 g Is that the position, manager of recovery engineer-l 4 ing, that Mr. Thiesing had in 1982?
5 A. No. He was the manager of recovery. programs. Mine !
6 is simply an engineering group, i
-- 7 g Is it for TMI-2?
8 A For TMI-2, yes.
9 g So you are manager of recovery engineering at ,
t 10 TMI-27
-11 A. That's correct.
~ 1~0 j-~g - G How long have you had that position?'
\J I
A. The section was created just a.few months ago, 14 no more than three or four moths ago.
15 g Your are a GPU Nuclear employee?
16
- 5. That's correct 17
~(F Fbr how'lbng bave y'uo been a GPU Nuclear employee?
18 A Since July of 1980 19 G' ' Continuously?
"O
^
A' Continuously.
21 g When the management of TMI-2 was reorganized on 29 approximately September 1st, 1982, you were the director of l
23 site engineering?
. /
i 'l
' 2'1 A. Manager of uite engineering.
05 O And before that, what was your position?
q COMMONWEALTH REPORTING COMPANY (717)761 7150
IJs3 -5 j F ,
j I
~1 A .I was manager of project engineering.
2 g When'did you become. manager of project engineering?
-j 3 A- This goes back to'about sometime in 1981. . )
4 'MR. RICHARDSON: That was manager of --
5 THE WITNESS: Project engineering.
6 BY MR. ' JOHNSON:
1
- 7 g- And you had as your deputy manager after the
- g. ..
O' -
8 September '82 reorganization Richard Gallagher? 4 9- A' That's correct. ;
10 .O And this-was a department,. site engineering was 11 a department?
12 g 7.think the proper term is "section." It is a' 13' '
section within the recovery programs department, which was -;
I4
' headed by Jim Thiesing,=who reported to the plant director 15 or division director. .
la g And you liad .a: subdivision within your section or i I7 department which was startup and test, and Ed Kitler was the !
18
' supervisor' in that. position from September of '827 9
A. That's correct.
20
- g. cJu s't as a preliminary matter, we have two statements 21 or records of statements that you gave. One is one taken 22 -
as part of the Edwin Stier investigation in 1983. That was !
23 taken -- it was a deposition taken September 7, 1983.
-O. ~,
Do.you recall giving that statement and being deposed
, "os by Mr. Maleta?
COMMONWEALTH REPORTING COMPANY (717)761-7150 i
_ _ _ _ _ _ _ . _ . . _ _ _ _ _ . _ _ _ . . . _ _ _ _ . _ . . _ _ _ _ _ _ _ ____ _ I
s4l .6 j{ }_ .1 ' -A. Did that gentleman work for Mr..Stier?
2' G. .Yes.
'3 A: .Okay; I remember that.
4 g JIt is in the.so-called Stier report documents.
5 A- .okay.
6 G And also I have been given in discovery a record
,- 7 - of an interview with .you on May 18,19'83 by Dean'D. Aulick'.
E
'8 Have you ever seen the record of this interview?
9 (Document-handed to witness.)
10 (Witness perusing document. )
11' A. ' No. I don't recognize this, no.
12 0' Do you remember being interviewed by Mr. Aulicke CJ 13
.on.Ma'y 18th, 1983?
I4 A I think so, vaguely.
M g: _The; thrust _of it has to do mainly with knowledge-16 about Quilt'ec.
II
, A 'Okay;,I remember 4 i.
M g' ~ And Larry' King abd so on.
W A Yes-.
20 i g Do you recall having any other interviews in 21 L connection with the Stier investigation other than the two 1 22 that I just mentioned?
23 A. I think I had a couple with Stier later on the L [s,/ 24 polar crane hand brake release mechanism. Is that the same 2r>
one or is that a later time?
j COMMONWE ALTH REPORTING COMPANY (717)761-7150
s 5. 7 l
lllh 1 G I think it's a different investigation, but you're j 2 probably right. You did give a statement. I think I have 3 that back in my office.
4 A So we're just talking --
5 g We're talking about the investigation into 6 management and safety allegations.
- 7 A. Okay. No, I don't recall any others.
!O 8 G Did you ever give any statements to Bechtel 9 lawyers?
10 A. I don't remember.
11 g Were you interviewed as part of -- let me back up 12 for a second. In connection with the Bechtel internal audit 13 in I guess it was March 1983, several individuals-I4 from Bedhtel, including somebody from their internal audit, 15 did an'investiga' tion concerning Quiltec.
- Were you. interviewed;by,them?
1 a A. No, I was'not.
G So as'far as.you can remember, the only two I
interviews that you had concerning the matters that relate to Richard Parks and Quiltec were the Stier --
91 A. Let me be clear. When you talk about Quiltec, oo
~~
are we talking about all of the other Larry King activities?
03
~'
g I jumped the gun. There was a DOL proceeding "4
involving Larry King and also one involving Richard Parks.
25 Did you give depositions in either of those?
COMMONWEALTH REPORTING COMPANY (717)761-7150
s6 8 \
l g 3 A Only in the Larry King affair, but that was 2
a civil suit arrangement, I believe.
3 B A civil suit?
4 A Yes.
5 g And you were deposed in that case?
6 Yes.
_ 7 MR. JOHNSON: Pat, was that included in the documents
?
2 g thct you produced to me?
9 MR. HICKEY: No.
10 MR. JOHNSON: You must have thought it was not jg responsive?
12 MR. HICKEY: That's right.
O 13 MR. JOHNSON: Why wasn't it responsive? What was the 14 basis?'
15 MR. HICKEY: You can look at your request and my t
16 response, '.ut my ' recollection was that you asked for interviews 17 that were conducted by GPU attorneys.
18 MR. JOHNSON: Oh, I'see; okay. Well, I had requested 19 that you produce another deposition of the other prior 20 witness; and on the same basis, I would be interested, if 21 you were willing to, to produce that deposition of Mr. Buchanan 22 from that proceeding.
23 MR. HICKEY: I will get you a response promptly.
24 MR. JOHNSON: Thank you.
25 COMMONWtIALTH REPORTING COMPANY (717)761 7150
S7 9 t
llh 1 BY MR. JOHNSON:
\
2 G Apart from that statement, were there other 3 statements that you gave?
4 A I do not remember any.
5 g It would be helpful if you had a copy of your s
6 deposition to Mr. Stier, because I am going to ask you several
- 7 questions arising out of your statements there.
8 (Document handed to witness.)
9 G On page 3 of your deposit' ion, you discuss --
10 you were asked the question: "Do you know how Dwight Walker 11 became an alternate on the startup and test department?"
12 Would you just review your answer there on pages 3 and I3 4?
I4
.(Witness perusing document. )
15 A. Okay. ;
D Q' Did Mr. Kitler approach you around the first of II the year, shortly after the first of the year, to discuss D
the general topic of replacing Rick Parks as Mr. Kitler's D
alternate startup and test sularvisor?
- A Yes.
91
~
g Could you tell me as best as you can recollect 22 what the substance of that conversation was?
o; A. My recollection is that since Rick Parks was at 9
- 4 the time the alternate, but Rick was in a different group --
o"r
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he worked down at site operations -- and if Ed needed some COMMONWE ALTH REPORTING COMPANY (717)761-7150
10 s8 1 help or was going to be on. vacation or what have you and 2 an alternate was necessary,-it would seem to be an increase in l
.3 administrative cleanliness and the ability to keep the I 4 . job support and what have you if we had somebody within site 5 engineering designated as the alternate.
6 If that was to be the case, then since I controlled
_ 7 the;. time and-how people-in the site engineering -- you
?
E 8 know, what they did for their eight hours and if I felt it 9 was important to keep a test going and Ed wasn't there, then 10 I could easily make it happen and not have to rely upon 11 somebody from another department for whom I.did not control 12 their time.
13 Did Ed Kitler mention the unavailability of 0
14' Mr. Parks around Christmastide, like Christmas Eve, to do
~
15 a flush, that he wanted to be'away and he couldn't get 16 Mr. Parks to do it for him or anybody else, as one of the I7 matters that was in his thinking?
18 A. I don't have any reco.tlection of many details, 19 to be honest.
20 Did the subject of Dwight Walker come up? Did his 0
21 name come up in your discussion?
22 A. Oh, yes, because Ed offered Dwight as the replace-23 ment.
~4 0 As somebody who you had control over his time?
25 A. Right, Dwight Walker worked for me in site COMMONWEALTH REPORTING COMPANY (717)761-7150
s'9 11'
. I engineering.
2' g lie was a supervisor in the f acility 'and . liaison 3 group?
4 A That's correct.
5 g Is that one of the subsections of your section? !
6 A That's correct.
. '7 .g.
.It.says here that he came into that position in E.
8 the fall of '82.
9 A That is my recollection, yes.
10 g Do you have any more precise recollection than 11 ~just' fall:of.'82?
12 g f,. ;.-No,.5 don't. l 13 g -g When he' discussed the replacement of Mr. Parks,
- a , ,. .
I4 [didhesayanythingconcerNinkNr. Parks' qualifications
- s. .
15 or abilities as being a factor in this decision?
16 ,
A. ' No. My memory is the' thrust was his availability II on any given day and the control of his time. That's.all.
18 g Did you hear anything more from Mr. Kitler 39 concerning the substitution of Dwight Walker for Rick Parks 20 until Mr. Kitler actually signed a memorandum designating 21 him to be --
22 A. Ed and I spent a little bit'of time going over 9
~3 Dwight's qualifications and we talked about it a little bit.
N 24 g At what time did you do this?
Or
")
? Oh, I don't have a clear recollection of when it COMMONWEALTH REPORTING COMPANY (717) 761 71 $0
- l. . .
s10: 12 1 was. It would have- b'een .sometime -- well, Ed eventually 2 put .out a memorandum to. the effect.; so our discussion would 3 .have;taken place sometime before,the issuance of that
'4 memorandum. .
1 4
5 g What was this discussion?
6 A Well, it was really just whether or not I was-
- - '7 satisfied with Dwight to do the job and whether Dwight met
'O 8 .the' qualification requirements for the position.
i 9 'S And Ed presented you.with his qualifications'and ,
~!
10 you said, "This.seems sufficient," or how did it go? 1
.. .s . ,.,
11 k9 IJdon(t remember.the details.of just how it went,
-X .12 but we pooled t'gether"the o information and reached a V IO
,conblusion.r sj ,
,, .j
- ~
I4 S' Was this in t-he"same conversation that you were -
15 describing"in your eai-lier; deposition?
16 A Yes. I'm not sure whether it was all just one II - conversation. There may have been more than-one conversation I8 taking place.
39 g Because it'says here that you told him that it 20 sounded like a' good idea, and we interpreted this in our 21 I discussion yesterday with Mr. Kitle,r as the go-ahead, that 22 he had your_go-ahead.
.v3
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A I agree with that, yes.
24 g And apart from that discussion until-February 18th o5 when he actually did designato Mr. Parks, did you discuss it COMMONWEALTH REPORTING COMPANY (717)761-7150
_._2___________-___._.__________..__.____.______.__.______._.___________.____._. . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ .
isill 13
'I lt 'l further with him?
2 A I have no recollections of.any other real-3 conversations.
4' >
0 If I may just go back to the two-statements, was 5 there any reason'wh'y there was such a long.. gap between the.
6J May;18th interview with Mr. Aulick and the September 7
- 7 interview with Mr. Stier and Mr. Maleta? Was there any 2' '8 reason for that.large' time gap?
9 A. I have no control over the' timing ~of the-
~
10' interviews. I cannot answer that.
11: g Let'me justr shift forward in time'to March 23, 1983 ,
12 There was.a meeting which was chaired,. I believe, by Mr.
13 L Arnold'at'8':30 in the morning"dn March. 23, 1983, at which I4
'the fact.that Parks was. going'to go'public was discussed.
15.
Were you at that~ meeting?
i 16 A. I don't recall being at that meeting. I have no I
recollections of the meeting.
'I8 Did you take part, were you consulted in the G
I9 decision to suspend Mr. Parks from the site?
20 A. No.
91
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g You didn't have any input into that?
99~~
A. I had no input.
23 g Do you recollect that there came a time sometime
(, .20 in the latter part of 1982 in which Mr. Gallagher came to you i
05
- 1 and discussed what he had learned concerning Rose Rittle doing 1
)
COMMONWE ALTH REPORTING COMPANY (717)761 7150 -
[
E__ _-- _ _ _ --- - -- )
.'s12L 14 1 some typing for-Rick Parks before hours?
2 A It is hard for me now to say when I knew that. It
-3 has been so long. It is probable. It is quite possible.
4 G It sounds familiar?
5 A. The -subject is familiar, b'ut I've got to be careful 6 in terms of when did I learn what.
, 7 I don't have any particular memory of it; though, that !
l E
8 time frame.
9 G.l Do you recollect _having a discussion with Mr. Austin when he came' back froni an~'ANS meeting concerning him learning
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to 11 that Mr. Reckart was at Shoreham working for Quiltec?
l s i
12 , A. That I remember.
0 U
?
13 O And that was at the end of November?
14 ,,A. .Right., That's correct.
15 O Could you' place any discussion-that you had 16 concerning Rose Rittle as being before that?
17 A. No. It doesn't do me any good -- no, I can't.
18 G I'would like to direct your attention to the May 19 interview, if you have a copy of that in front of you. It 20 is recounted by Mr. Aulick at paragraph 4, page 2, that you 21 first heard the word "Quiltec" probably in August of 1982 i 22 when,Slone left.
23 You knew Ben Slone?
-V 24 A. Slightly. I didn't know him that well, but I knew 25 of him slightly.
'COMMONWE ALTH REPORTING COMPANY (717)761-7150
isl3 15 l
v
) 1 G And do you remember him leaving?
2 A. I remember him leaving, yes.
3 G Could you describe the circumstances in which you 4 heard the word "Quiltec" for the first time?
5 A. No, I'm not able to do that. I really don't 6 remember how I first heard it.
- 7 G Here it is attributed to you that you told Mr. Aulick 8
8 that Slone quit in mid '82 and your impression was that he 9 left and incorporated himself as Quil or Quiltec or something 10 like that.
11 Do you recall saying that?
12
, -~'3 A Yes. That sounds good.
- l. ./
I3 G I believe that the record will show that Mr. Slone I4 left in approximately May-June of '82 and then he came back II' briefly for the Quick-Look in July of '82.
- Was it at the time -- you say he quit in mid '82.
I7 Is it possible that it was a little bit earlier than mid '82?
- A. I don't have a recollection. You stated he quit and came back, and I don't even remember that.
O MR. HICKEY:
~
You seem to be focusing on part of the oj
~
statement, but the first part of it is that Mr. Buchanan in 22 paragraph 4 first heard the word "Quiltec" probably in
.v3 August of '82 when Slone left.
')4 I just point that out to suggest that the record isn't very clear about when Mr. Slone left and neither is COMMONWEALTH REPORTING COMPANY (717)761-7150
sl.4 16
) 1 .Mr. Buchanan's memory of when Mr.-Slone left.
2 BY MR. JOHNSON:
3 G What I really was trying to get'at in perhaps an i
- 4 inartful way issthat it's possible that he left before 5 August of '82, and when you learned about Slone and Quiltec, im G may.have been before August?'
- 7 A' I can't deny it. I just don't remember.
8 G Do you recall a time in the fall of 1982 when you.
9 had discussions'abou't the possibility of Mr. King being.
10 a'ssociated with Quiltec? -
11 +
1As ,Again, i sit'here~and I don't know when I might 12 f- have first heard some rumors to that effect. 'If I heard 13
-anything at all at that time, you know, they would have:been I4 purely kind of low level rumors; but I really don't have any-15 recollection of.when I'first heard Kidg and Quiltec tied up 16 together.
II Obviously, from some of that testimony that I've'given, 18 obviously, sometime during the fall I did hear.
19 G On page 31 of the Stier deposition, you did say 90
~
you heard rumors about Ben and Larry being partners in the 1
21 f all of ' 82 99
'l'
~~
A Okay.
93 (Document handed to witness by Counsel Richardson.)
(_))
- r l "4
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} G Page 31 and it goes on to page 32 1
05
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L (Witness perusing document.)
COMMONWEALTH REPORTING COMPANY (717)761 7150
7 i
i 15- 17 p
1 0 This was a sworn deposition. You have no reason 2 to believe that this wasn't true when you said it?
3 A I believe it to be true.
4 G At the time that you did hear about or whatever 5 you did hear about King, did it occur to you to bring this 6 to your supervisor's attention?
i i'
. 7 A. No. You hear stories and you hear rumors. I'm 0
L 8 not going to go to my boss and pass them on just for the 9 heck of it.
There's no sense getting him stirred up about
[some hing unless it hadl> sorne basis.
10 11 0 Do you recall having a discussion -- there is a 12 x
reference to"page 33, line 18. It says, "And then I can 13 remember Bill and I talking about the possibility of any I4 involvement with Larry in all of this."
15 A. I missed your question. Did you put a question M
to me?
I7 No, I haven't. j G
18 A oh, I'm sorry.
E The context of this discussion of yours on page 33 G
20 ties it into this ANS meeting time period. ,
03 A. And as I remember, those meetings were, you know, ?
r no
~~
like Thanksgiving, mid to late November.
i 93
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G So that is the time frame in which this discussion l 24 would have taken place?
95
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A. That's correct. ,
I l
COMMONWE ALTH REPORTING COMPANY (717)761-7150 j i
sl6 18
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.w.
1 G And on page 34, you state that you went to 2 Mr. Reckart's home on New Year's Eve and you asked if Larry 3 King were involved in Quiltec, and he told you that he was.
4 That's correct? j 1
5 A. That is correct.
6 G On page 35, you say that you went to Jin Thiesing
. 7 after you learned from Reckart about King's connection to E
8 Quiltec and informed Mr. Thiesing of what you learned. Is 9 that correct?
10 A That's correct.
11 G Can you place that in time? Was that shortly after 12 you heard it in early January?
l 13 A. I really don't have a good memory of that. I 14 really don't remember. I think so, but I don't have -- I 15 think that was kind of implied at least if I didn't say it 16 here in this transcript, but I don't remember when I did go 17 talk to Jim.
18 You might want to direct the witness' MR. HICKEY:
Hi attention to page 37 where he addresses his discussion with 20 Thiesing and places it after the trip that Austin and Thiesing 21 took.
22 BY MR. JOHNSON:
23 G Was the first time you mentioned the possibility 24 of King's connection with Quiltec after Mr. Thiesing and 25 Mr. Austin returned from their trip to Idaho or could it have COM MONWE ALTH RE PORTING COM PANY (717)761-7150
ly17: 19-h 1 been earlier?-
'2 A. I believe,.as I read it, I would make the assump-3 tion that I did not~ talk to Jim until after the Idaho trip 4 that Thiesing and Austin had.
~
5- Definitely, I would not have talked to Thiesing about 6 it until,after the 1st'o'f January', but this implies that I f , .
. 7 did not, talk to'him"until after the Austin /Thiesing' airplane 8 o trip. , ,,
9 0 '- And you' don't'have any current basis to'know 10 precisely when.-- .
. e 11 A. No, I don't.
12 0 On page 39, there is reference to~a. discussion 13 between you and Mr. Arnold-in which you had a conversation 14 similar to the one you had with_Mr. Thiesing, it appears.
15 The thing _that you mention starting on-line.14 was 16 that he was not only interested in'your knowledge, but he 17 expressed a concern'that you-had not -- that it took so long 18 for Mr. Arnold to find out about this.
19 When did you speak to Mr. Arnold? Was that around .,
20 March lith, approximately? Was that in that time frame? .
a 21 A. It could be. It was a little bit after the news 22 broke, so'to speak. ,
l 23 G On King?
'd 24 A. Yes, King. And that was, what, like mid-February?
m, G February 24th was the date he was suspended.
COMMONWEALTH REPORTING COMPANY (7171761-7150
s18. 20
-J j( f- 1 A. March 11 could be'right.
~
It was.plus or minus a-2 few weeks. .
3 G. I assume that you mentioned .to him that you had I 1
4 told Jim Thiesing af ter the trip to Idaho what you knew. I f>
Did'you, mention,that to Mr. --
6 i k' I don't remember the details of the conversation
. 7 at.all.
!O' -
8 ,
I G. lOn'page 35, you s,ay,that you believe that Mr. King 9
had a role in' recruiting Mr. Reckart away from GPU after your 7
10 conversation with Mr~ Reckart on New-Year's Eve.-
. Is that 11 . correct? !
12 A. Repeat that again.
'13 ;
0 I' phrased.it.in a way which asked you'to.' verify I4 that you had come-to the conclusion that - .this is discussed, D'
'I think,fstarting on line 17-on page'35 -- after.the New Year' s Eve' discussion with Mri Reckart, you came to the conclusion
'I cn: to the belief that Larry King had recruited Mr. Reckart
- away.from GPU.
A That's correct.
"O O And the next time you mentioned that -- well, not o
~l the next time you mentioned it -- the time you mentioned it 99
~~
to Mr. Thiesing was after Mr. Thiesing returned from Idaho?
23
- f-s , A. That's what this says.
f 9
( ~4 G And that's to the best of your recollection? .
A. That's to the best of my recollection.
COMMONWEALTH REPORTING COMPANY (717)761-7150
- s19-I 1 0 Do you have .any better recollection than you did' 2 in 1983 about the source of the rumors in the fall of '82 3 concerning the. connection between Ben Slone.and Larry King 4 being partners in a business venture?
5 A. J .My recollection is no better.
6 0 There you s'ida on page 32'that you heard from your
. 7 .own staff and that -- let,me;just see page 32 You said
.g: -
I s there: '"I'would'have heard them from members of my.own 9 staff."
t 10 Is that true?
11 A I'believe that's true.
t 12 I asked you earlier about'Mr. Parks in connection G.
la with the typing of resumes by Rose Rittle.for him. Is the
- 14. first time you learned that when Mr. Gallagher told you that 15 in a meeting with Mr. Thiesing?
16 A. I don't recall when I first heard it. I know 17 Rich was the one who made the observations, and he would have 18 told me. ,
19 Whether it was the first time in Thiesing's office 20 or sometime prior to that, I wouldn't want to have to say,because 21 I don't remember.
22 G But you may have heard before that?
23 A. It's possible. Rich and I worked pretty close 24 together.
25 G What did he tell you? Do you remember the COMMONWE ALTH REPORTING COMPANY (717)761 7150
s20 22-t r] 1 . substance of what he-told you?
2 A No, I'm afraid I don't. It's just too long ago.
3 I don't remember. 3 4 0, DidEyou ever speak to Mr. King -- Mr. King was ..
1 5 - at a slightly, higher. level than you in the organization at-i.
6 thst" time.
- Did you'ever. speak,to Mr. King about his connection-] ;
i .. ., I
_ 7 1with, Ben Slone? l E ,
8 A No, I:did not. ;
9 G Di d you have conversations with Mr. King from time . l 10 to time in the fall of '827 A
~
11 Yes. We would have had work-related discussions 12 occasionally. Not every day, by any means, but occasionally.
13 g Did you ever hear him say anything that related 14 to his association'with Mr. Slone? l 15 A No, I did not. I don't remember.
16 O Which is it? You really said two things. You ;
17 didn't hear it or you don't remember whether you heard it?
18 A I don't remember ever hearing him say anything 19 about Ben Slone.
l 20 Q Do you recall Rich Gallagher ever telling you that 21 he knew that King was involved in Quiltec as early as the 22 summer of '82?
23 A I sure don't remember going back that early, but 24 y,m not going to deny it either.
25 g He may have, but you just can't be certain?
COMMONWEALTH REPORTING COMPANY (717)761-7150
- s21 23
= ,
![ ) 1 A.. That's correct..
2 G Did Mr. .Gallagher ever come to you-to tell you 3 that'he. learned that his, resume was being marketed by r
4 ;Quiltec?'
5 - MR. RICHARDSON: Excuse me.
7 6 '
i MR,. IIICKEY : , Did y'ou mean to ask that about 7
- - Mr. Gallagher?
g; ,
8 ' MR.i RICIIARDSON: ' ' You said Gallagher ,
9 .MR.. HICKEY: You did say Gallagher. Is that what you 10 meant to say?
11
.MR. JOHNSON: Yes.
D BY MR. JOHNSON:
.. V I3 G' Did Mr. Gallagher ever come to you and tell you 14 that he had learned that a resume that he had given to Ben 15 Slone was being used to market him?
16 A I don't remember if it was Gallagher or not. There
-17 was somebody in my organization who found that out, although l 18 it seemed like that was somewhat after this 1982 time framer 19 although. I'm not certain of that, and the individual was 20 !
really upset about it, because his resume.was being thrown 1 1
21 ,
around and he didn't know anything about it. l 0 But you can't remember if it was Gallagher or not?
23 A. As I'm sitting here talking, it wasn't Gallagher.
)
It was somebody else.
25 MR. HICKEY: I don't know if you are just confused. ;
)
COMMONWE ALTH REPORTING COMPANY (717)761 7150
s22 24 l 1 There was testimony yesterday from Mr. Austin that it was 2 Mr. Austin.
3 THE WITNESS: Yes. 1 was going to say it was Bill 4 Austin.
5 MR. JOIINSON : I am confused.
6 BY MR. JOHNSON:
_ 7 G Mr. Austin?
E E Yes, Austin. I do remember that.
8 A.
9 G And you place it in the time frame of what?
10 A. Somehow I had in mind that he found out about that 11 later -- I have that after the February time frame. Now, I
- 12 may be wrong, but I was thinking he found that out later;
<3
~_/
i 13 and I don't know why I even remember it that way in that 14 context, but somehow that seemed like a later detail.
15 G Would you say that the rumors concerning Larry M King and Quiltec were fairly widespread in the fall of 1982 17 when you were hearing them?
- MR. HICKEY: Could you clari fy what you mean by that?
l l
l 19 Are you asking the witness whether he has any knowledge about 20 how maoy other people had heard rumors or that there were 2I rumors coming f rom a number of sources?
l 22 BY MR. JOHNSON:
l 23 G 11ad you heard rumors from enough sources to o4 indicate to you that the knowledge about Larry King and 20 Quiltec was fairly widespread?
COMMONWEALTH RE PORTING COMPANY (717)761 7150
s23 25
)
I s
I' 1 MR. RICHARDSON: I would add to the objection: wide-2 spread to what degree? Within his department, within his 3 office, all over the island, vertically, horizontally? j l
4 BY MR. JOHNSON:
f>
G Was widespread at the site or, alternatively, 6 in the department.
- 7 A I don't really remember it being widespread.
!O 8 That's my recollection; not widespread. A few people knew 9 about it, but I don't use the term " widespread," I guess.
10 G It wasn't general knowledge, as far as you knew?
11 A As far as I knew, no. Again, I'm not saying I 12
<~n knew everything by any means, but it was not what I would
.n)
U call widespread.
" MR. HICKEY: You were able to Mr. Stier to identify U
two people that you had heard rumors from. One was Bill Austin and one was Rich Gallagher at page 32 I
THE WITNESS: Yes.
BY MR. JOHNSON: a G At page 41 of your deposition, you indicate you oo
~
had a conversation with George Kunder and is it Jim Larson?
91
~ I A. Yes. j 1
G It sounds like it was in the February-March time ;
o-
~'3 l frame. Let me just get to that page, og
~'
(Counsel Johnson perusing document.)
U G According to your deposition, the discussion had l COMMONWE ALTH REPORTING COMPANY (717) 761-71 DO
_ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ /
s24- 26 to do with how to mend the rift between site operations
~
1 2 and recovery programs.
3 I just wanted to ask you whether the subject of prior 4 ;knowl dge of Larry King's' involvement in Quiltec came up in 5 the course of that discussion.
-6 A. .- Ifd'on't>have any memories. It's interesting. I
_: 7 do remember talking to George.on a few occasions about, you E
8 know, life has to go on sort of thing and we've got to get 9 our job done and we've got to do our job right and baseline 10 concerns with safety and compliance and all that, you know, 11 goes on anyway; so we have to make sure that our job gets 12 done properly in spite of what may be going on around us.
13 I remember those kinds of conversations.
14 g But you don't-remember discussing knowledge about 15 Quiltec and King with those two?.
16 A Prior to?
17 g yes, 18 A. Not prior to. .I don't remember prior to. l 19 0 To be precise, what I'm asking is: in that 3 20 1 discussion that you had which was after King left, at that 21 discussion, did you discuss with them what they had known 22 prior to his leaving?
23 A. I don't remember discussing it with them. I have d 24 no recollection.
25 g And the other answer was that you don't remember COMMONWEALTH REPORTING COMPANY (717)761-7150
s25 27
( [1 1 discussing it with Mr. Kunder and Mr. Larson prior to Mr. King 's 2 leaving?
3 A That's correct.
4 Q. Did you have occa'sion as manager of site engineering 5 to have regular. contacts of any sort with Mr. Parks before he 6 left?
- 7 A. No, I did not have regular contacts.
!O 8 0 Did anyone in your section, site engineering, 9 express to you an opinion that it would be difficult to work 10 with Mr. Parks after he had gone public? !
11 MR. HICKEY: On March 23rd?
1
(-) MR. JOHNSON: On March 23rd, I believe, or 24th, 1983.
L,J i I3 MR. RICHARDSON: He went public on March 23rd, 1983.
14 MR. JOHNSON: Oh , is that the date? Okay; on 15 March 23rd.
16 THE WITNESS: I don't recall having a discussion. I won't say that it didn't take place. I just can't remember 18 Nothing vividly sticks out in my mind. l those details. t 19 MR. JOHNSON: I appreciate you coming. Perhaps your ,
oo
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attorney has some follow-up, but I'm finished. Thank you.
ol
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THE WITNESS: Thank you.
MR. HICKEY: I just have one, Mr. 3uchanan, because 93
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your tone of voice won't come across in the transcript.
24 25 COMMONWE ALTH REPORTING COM PAN Y (717,761-7150
l l s26 28
- J l CROSS-EXAMINATION i I
2 BY MR. HICKEY:
3 G When you were being asked by Mr. Johnson about 4 your recollection about learning various items about Quiltec I
5 and so on, he inquired about your recollection of talking 6 to Mr. Austin on Mr. Austin's return from an American
- 7 Nuclear Society meeting in the end of No ember, and you said 8 with substantial emphasis, as I heard it, "That I remember."
9 I want to ask you what it was about Mr. Austin's 1
10 information that he brought back from the American Nuclear 11 Society that makes that stick in your mind.
12
, - , A. It was one of those hignlights -- he came back L) I3 with kind of the cat and mouse game. "Do you know where I4 Reckart is working?" And I said, " Yeah, he's down in Texas.
- What's he doing? He's working for a consulting outfit; that
" he's in partnership." ;
I7 He said, "Oh, no, he isn't. He's working up at IN Shoreham," and relayed thE story about Ted being there, and IU he knew it because he met a fellow at the ANS conference 20 who worked in a trailer adjacent to Ted, so he's absolutely l
"I
~
confident that that's where he was. !
22 The reason that stuck in my mind was whenever Ted )
m3
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had lef t--I was disappointed in seeing Ted leave GPU. I
(
i 94
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thought he was a good man a.1d I really enjoyed having him l 2I' "Where are work for me-- because I spent some time with Ted.
COMMONWE ALTH RE POFTING COMPANY (717)761-7150
______________.__.o
I s27 -
, :+
() 1 you going?
Why are,you leaving?"
2 lHefwas kind of making,it'by1 . - - %-
going to do this job it q l
3 was working with environmental control' issues, which was j 4 going-back'to'hAs work' experience that he had or was employed 5 with before he:came to GPU. So his story made some sense 6 of going out to Texas, and I really believed him.
- ' 7- When Austin was telling me this story, I was really 5
8 . irritated at Reckart for feeding me this damn set of' lies.
9 That's why I really have this recollection of why that detail-10 sticks _in my mind after the passage of time.
11 G When Reckart left, though, he wasn't working specifically for you, was he?
} I3 A -No. J few months prior to that, he had been 14' transferred down to plan engineering.
15 B So when he left your organization'and went'to plan 16 engineering -- and that was a transfer within the company;-
17 right?
A Right.
19 g Is it your testimony that shortly after he went 9
~0 to plan engineering, he then lef t with the story that he 9
~1 was going to Texas?
A. Yeah.' It wasn't -- I don't really remember the 03
^
time, but it was short; a few months at the most.
( 24 g Who was he working for in plan engineering?
05
~
A He was working for -- I'm not sure whether he COMMONWEALTH REPORTING COMPANY (717)761 7150
s28: 30
(%
.() 1 Ereported directly1to,Ed Gischel,or at the time whether he
- c -
2 ~might have-been reporting to Ron Warren, who in turn reported 3 to Ed Gischel.
4 MR. HICKEY: I don't have anything further. Thank you.
5 MR. JOHNSON: Thank you'very much..
6 (Witness excused.)
1
-~ 7 (Whereupon, at 3:01 p.m., the deposition was 8
8 concluded.)
10 11 22 c.
Q. 13 l
14 'k l
.1 15 16 I
17 1 1
18 19 20 l
21 22 23
/
V 24 25 COMMONWEALTH REPORTING COMPANY F/17) 761 7150
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j, l
l 31 1.
1'
[} l CERTIFICATE OF DEPONENT j' ,
2 I, David R.' Buchanan, have read.this transcript of my- .
.3- deposition taken.on Wednesday, January 14, 1987, and with the 4 exception of the corrections noted, if any, find:it to-be a l 5 true.and accurate record of my, testimony.
l.
6 7
8 Date David R. Buchanan 9
10
'11
'12 13 14 Signed, this day of , 19 15 16 I 17 Notary Public I8 Municipality:
19 i My commission expires: l 20 21 l
i 23 24 25 COMMONWEALTH REPORTING COMPANY (717)761 7150
_____________________.________________.__._______.____________________.___._____.__________________________._____._____._____..__._._..___._u
l 32
} 'l ' CERTIFICATE OF NOTARY REPORTER 2 .I hereby certify, as the Notary Reporter, that 3 the. foregoing proceedings were taken stenographically be me, .;
4 and' thereafter reduced to typewriting by rne or under my j 5 direction; that this transcript is a true and accurate l
6 record to the best.of my ability; that the witness whose 7 testimony appears in these foregoing pages was duly sworn by 1
8 me; that I am neither counsel for, related to, nor employed l l
9 by any of the parties to the action in which this deposition j 10 was taken; and further, that.I am not a relative or employee 11
(
of any attorney or counsel employed by the parties hereto, 19~
. nor financially or otherwise interested in the outcome of 13 .
the action.
I4 COMMONWEALTH REPORTING COMPANY, INC.
15 16 gy; 7y ,
[y/gyy7 g /
n lM' '
Judith A. Toberman ;
Notary Public in and for the ',
is Commonwealth of Pennsylvania ;
g Cumberland County, Pennsylvania l MY mmissi n XP i res on: April 27, 1987 20 l-
.21 1' 22 l
- l 23 i
' yl 24 1
1 05 1 1 COMMONWEALTH REPORTING COMPANY (717)761 7150 1
l l 1 l
[h r v] CERTIFICATE OF DEPONENT 1, David R. Buchanan, have read this transcript of my depo-sition taken on Wednesday, January 14, 1987, and with the excep-tion of the corrections noted find it to be a true and accurate record of my testimony.
Marcti 12, 1987 , ,u - ru a~
Date David R. Buchanan Signed, this 1_2_tht day of March , 1987
-blC$rb VN '
N Notary Public Municipality: LONDONDERRY TOWNSHIP, DUAPHIN COUNTY My commission expires: August 21, 1989 O i N J'
(~.
j<
O V
l Corrections
~Page 29, line 2 should read: "He was kind of making it. By going to do this job, he. . ."
Page 29, in lines 14, 1S, 20, and 24, " plan" should be " plant".