ML20238C705
| ML20238C705 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/13/1987 |
| From: | Austin W GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20238C505 | List:
|
| References | |
| CIV-PEN, EA-84-137, NUDOCS 8712310172 | |
| Download: ML20238C705 (52) | |
Text
,
-OR GNEL o
UNITED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO: 50-320 (Civil Penalty)
GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION (Three Mile Island, Unit 2)
\\
LOCATION:
MIDDLETOWN, PENNSYLVANIA PAGES:
1--49 DATE:
TUESDAY, JANUARY 13, 1987 ACE-FEDERAL REPORTERS, INC.
h Official Reporters T
444 North Capitol Street Washington, D.C. 20001 (202) 347-3700 8712310172 871209 PDR ADOCK 05000320 NATIONWIDE COVERAGE T
1 UNITED STATES OF AMERICA
,')
dUCLEAR REGULATORY COMMISSION
__________________x In the Matter of:
Docket No. 50-320 GPU NUCLEAR CORPORATION (Civil Penalty)
(Three Mile Island Nuclear Station, :
License No. DOR-73 Unit No. 2)
EA 84-137
__________________x Pages 1 through 49 Nuclear Regulatory Commission 100 Brown Street Middletown, Pennsylvania Tuesday, January 13, 1987 Pursuant to notice, the deposition of WILLIAM EDWIN AUSTIN, JR. was taken before me, John Anthony Kelly, Notary Reporter, commencing at 9:39 a.m.
I
)
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 i
Oakland, California 94612 (For GPU Nuclear Corporation) 4 I
Commonwealth Reporting Company, Inc.
700 Lisburn Iload Carnp 11111. Pennsylvania 1*1011 Carup Hill Philadelphia (717) 761 7150 (115) 731-1687
__.-___2
_.___w
1 l
L-A APPEARANCES (Continued):
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J.
PATRICK HICKEY, Esquire Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W.
I Washington, D.C.
20037-(For GPU Nuclear Corporation) j ~.
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1 4
1 j
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l Commonwealth Reporting Company, Inc.
700 Lisburn Road l
Camp Hill, Pennsylvania 17011 Camp Hill Philadelphia l
(717) 161 7150 (215) 732 1687
J 2
0 1
sanzsura 2
WITNESS DIRECT CROSS REDIRECT RECROSS 3
William Edwin Austin, Jr.
By Mr. Johnson 3
4 EEHlalTE 5
NUMBER FOR IDENTIFICATION IN EVIDENCE 6
(None.)
7
?
8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 COMMONWE ALTH REPORTING COMPANY (717)761 7150
s1 3
O ta2casainaS 2
Whereupon, 3
WILLIAM EDWIN AUSTIN, JR.
4 having been duly sworn, testified as follows:
5 DIRECT EXAMINATION 6
BY MR. JOHNSON:
7 g
Would you please state your full name?
8 8
A.
William Edwin Austin, Jr.
9 0
Your business address?
10 A.
I work at GPU Nuclear, Box 480, Middletown, II PA.
O And you are currently working at the TMI-2 site?
13 A.
Right, TMI-2 14 0
What is your position?
15 A.
I am the manager of engineering tooling for the 16 defueling project.
17
.g Ilow long have you been in that position?
18 A.
Almost a year.
19 G
And before that?
20 A.
Before that, I was deputy manager of site 21 engineering.
O.
When did you become deputy manager of site 23 engineering?
24 A.
I held that position for about a year.
25 g
When did you --
COMMONWEALTH REPORTING COMPANY (717)761-7150
l s2 4
g) 1 A.
Let me get my years straight.
It would be the
(
2 year '85.
3 G
So in 1985 you became deputy manager of site 4
engineering?
5 A.
Right.
6 G
Prior to that, what position did you hold?
7 A.
I was supervisor of reactor disassembly and j
I 8
1 I
s 8
defueling.
9 0
When did you assume that position?
10 A.
That would be -- I think that was the initial Il title I had, come to think of it;.
s o it would be 1981.
1
<l Q.
In the organizational chart that I'm familiar i%j/
with for TMI-2 for the reorganization that occurred effective 14 August 31st, 1982, you're on a chart that comes under site 15
{
engineering and you report to Dave Buchanan and Rich Gallagher 16 I
Was that true at that time?
i l
17 A
I'm trying to remember the chart.
In 1982, Dave 18 Buchanan was manager of site engineering; correct?
19 G
Right.
20 A
I reported directly to Dave Buchanan.
Rich 1
21 Gallagher was the deputy manager.
1 22 0
So the way things went:
you're a GPU umployee?
23 A.
Right.
l 24 G
And you reported to Buchanan directly?
l 25 A.
Typically.
COM MONWE ALTH RE PORTING COM PANY (717)761-7150
s3 5
()
1 0
Typically.
2 A.
Most of the work that I did was on reactor 3
disassembly; and Buchanan, since there was so much work in 4
the site engineering department, he handled the management of 5
the phase that I worked.
Rich Gallagher, who was the deputy, 6
handled a lot of other stuff.
7 Typically the work that I did did not go through Rich 8"
8 in 1982 9
g And your title in the site engineering department 10 from September 1982 through 1985 was supervisor, reactor 11 disassembly and defueling or something --
I2 A.
Something like that.
It might have been engineering 13 supervisor.
14 g
Did you ever serve as a representative of site 15 engineering to the TWG?
16
. A.
No.
G And that goes as alternate as well; you never were 18 an alternate?
A.
Right.
~0
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g Was that because what you did was out of the genera:
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area of approving procedures?
Was there an easy way to explain why you wouldn't have been assigned to that kind of 23 role?
8
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A I'm not that familiar with the TWG.
The work that o
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I was hired to do is entirely separate of anything that has to COMMONWEALTH REPORTING COMPANY (717)761-7150
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I do with the TWG.
2 0
Could you characterize that?
3 A.
What I do?
4 0
Yes.
I 5
A.
Sure.
I was hired to spend my time working the 6
planning and the engineering for removing the fuel out of 7
the reactor vessel.
8 There are a lot of other tasks that have to go on to 9
support that, but I typically stayed right with the disassembly 10 and developing the plant conditions that would allow us to 11 access the fuel.
}
G Are you a licensed engineer?
13 A.
Yes.
14 g
Do you have a No. III or certified to the third 15 level?
16 A
No.
You have it confused.
That's for testing.
17 You're thinking of testing.
18 I
am a
licensed professional engineer in the 19 Commonwealth of Virginia.
20 MR. JOHNSON:
Were we able to determine whether ol
~
Mr. Austin's resume was produced?
2 MR. HICKEY:
I believe it was, but I don't have a copy 23 of it with me.
I think it was.
If it was not, we will 24 certainly provide it.
25 COMMONWEALTH REPORTING COMPANY (717)761-7150
s5 7
()
1 BY MR. JOHNSON:
1 2
G Did you ever work for Bechtel?
3 A
Absolutely not.
4 G
When did you first come to work for GPU Nuclear or
(
5 its predecessor organizations?
6 A.
I was hired August of
'81.
7 G
Generally, what did you do before then?
8 A
I worked with Newport News Shipbuilding through 9
the various jobs dealing with reactor disassembly, refueling, 10 installation, back fit types of things.
11 G
Did you say Newport News?
I A
Newport News Shipbuilding and Dry Dock in 13 Virginia.
14 (Pause.)
15 g
In your work on reactor disassembly and defueling, 16 did you have occasion to work with Ben Slone in the 1982 17 time frame?
I A.
Yes.
We worked on the Quick Look, what they call 19 Quick Look Tiger Team together, oo
~
G Tiger Team?
91
~
A Yes.
That was a nickname for it.
22 G
What was your role in relation to Mr. Slone?
og
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Were you colleagues or was he a supervisor?
94
~
A.
No.
It basically was a committee of one representa-tive from various organizations.
Ben Slone represented site COMMONWEALTH REPORTING COMPANY (717)761-7150
's6 8
l 1
ops. department.
I represented recovery engineering.
We 2
had several other members to the committee, and our charter 3
was to produce the Quick Look.
4 G
When Ben Slone left TMI in approximately June or 5
July -- or was it as early as May?
Do you remember when he G
left TMI?
7 A
The exact date?
8 G
Not the exact date, but the month.
9 A
No.
I don't even remember that.
10 G
When he did leave, which I believe there is 11 information in the record that we have -- well, let me see
~
19
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'~
if I can pin it down.
(-
You had an interview with Mr. Aulick on May 18th, 1983.
A.
1983?
G May 18th, 1983.
16 A.
Okay.
MR. JOHNSON:
Pat, do you have a copy of that if he 18 wants to follow?
It's not necessary, but if you want to show 19 it to him because I want to ask him a couple questions about oo
~
what he said.
91
~
BY MR. JOHNSON:
G On paragraph 6 of that interview -- first of all, 93
~
would you tell me the circumstances under which you came to 9.j
~
be interviewed by Mr. Aulick on May 18th, 1983?
MR. RICHARDSON:
The question is vague.
Do you mean COMMONWEALTH REPORTING COMPANY (717)761-7150
s7 9
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1 did he get a phone call?
i 1
2 BY.MR. JOHNSON:
3 G
How were you contacted concerning this?
4 A
I don't remember, to be honest with you.
I'm sure 5
one of my superiors said to go back and talk to him, but the 6
exact details of that I don't remember.
I 7
G Did you know anything about the purpose of his 8
I 8
inquiries, his interview?
9 A.
The way I understand it, it was a prelude for the l
l 10 intervie./ by Stier.
11 Q
In paragraph
- tarting on page 1, it says, " Austin I2 first became aware of the word 'Quiltec' either at the first I3 of the, year 1983, which is the more probable time, or when 14 Slone left in the summer of 1982."
4 I
Does_that refresh your recollection as to when Slone 16 left?
17 A
As to when Slone left?
18 G
Yes.
19 A
Sure.
Slone left prior to Quick Look, which was oo
~
in June-July of '82 He left before that.
So it would make 91
~
sense, May-June of '82 But to your question as to does this refresh my memory, no, that doesn't have anything to do with 23
.it.
94
~
G Sobeit.
I asked you, and you couldn't fix a month 25 to it.
I was just trying to --
coMMoNWE ALTH REPORTING COMPANY (717)761 7150
s8 10
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1
. R. HICKEY:
I think there is an exhibit'in the Stier M
i 2
report that has the date of Mr. Slone's resignation.
l 3
BY MR. JOHNSON:
)
'4 0-Going back to the statement about, " Austin first 3
became aware of the word 'Quiltec' either at the first of the'
,)
l 6
year 1983, which is.the more probable time, or when Slone left
- l 7
in the summer of 1982," did you have a conversation with E
e-E
. Ben.Slone.-just before.he left concerning Quiltec?
l
.1l 9
MR. IIICKEY:
Can I. interrupt just one-minute?. I think I
to it's frankly distracting to the witness to be reading to him Il from a memorandum and then.just asking'him'a question.
Because i
3.>
"Did you have a conversation with Ben Slon if the question is, m
~
13 beforeihe left," there's nothing in what you read that says 2
14 anything about that.
- 1 15
- If.you,want.to'ask him'whether he did and he remembers i
16 it, then I think that would be the way to go.
I don't know why you wan't"to have the memorandum in' front'of him and be 18 reading from'the memorandum and then ask him another question.
19-MR. JOHNSON:
Do you want to take the memorandum away
o
~
from him?
"I
^
MR. HICKEY:
Okay, unless there is some reason to have no
^^
it there.
93
~'
(Document handed to Counsel llickey.)
94
~
MR. HICKEY:
I think the question is whether you 25 remember having a conversation with Mr. Slone when he left.
COMMONWEALTH REPORTING COMPANY (717)761-7150
1 m
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1 THE WITi4ESS:
Yes is the' answer.
2 BY MR. JOHNSON:
1 3
O.
Did you discuss Quiltec with him at that time?
l 4
A.
No.
1 5
Q.
What was the subject of your discussion?
6 A.
There was a very short conversation.
I think it 7
probably occurred the ver y day Ben Slone lef t.
Helwas epming 8*
8 by and shaking hands with cJerybody leaving.
9 We basically discussed what his future was going to be.
10 At that time, he told me he' 4as going to be an independent consultant to the Shoreham plant.
ThatAs kind ok'urst we Il l
12 t'l i tciYned about, those type issues; his future.
1 we#
0 Duringe that conversation, d ut he ask you for a copy of your reswae?. '
15 A.
Yes.
16
.0 And you gave it to feita?
I g:
A.
Y ?s.
18 Q.
What was your un It'.7standinn.,as to wh 2t Slone was 19 E going to do with the resume?
1 20 A.
The way he expressed himself to me was that he 21 was an independent consultant, and I expressed an interest in 22 that same type of job.
HesMd that there were some people, for instance, 24 Stone and Fichster, who was working at Shoreham.
There was t
25 the utility itself that possibly c:i;dQ have openirgs for peopl o
COMMONWE ALTH REPORTid.3 LOMPAN
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1 like myself; give him my resume and he'd pass it on, and 2
that's what I did.
3 0
Do you recall how the subject came up, giving him 4
your resume?
He mentioned that there might be opportunities 5
and you suggested giving him your resume; or was it the other 6
way around, that you asked hin about the possibilities?
~
7 Do you recall how it came up?
t 8
A.
I don't think I recall that.
9 G
In this interview wtth Mr. Aulick --
10 MR. HICKEY:
I'll give him this copy.
11 MR. JOHNSON:
That would be convenient if you would.
'~ ')
(Document handed to witness.)
V BY MR. JOHNSON:
s 14 0
On page 3, you characterize the circumstances under 15 which you gave your resume.
At the top, you say --
16 MR. HICKEY:
Wait a minute; Aulick's notes say, s
17 BY MR. JOHNSON:
18 g
Aulick's notes say, starting with the previous 10 page, "Anway, just before he left, Slone came in and asked for 20 a resume."
~I Is that the way you recollect it happening -- let me
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~~
ask you it another way.
o.,
l As far as you can remember, is that a true
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24 statement at the time; that that's what you told Aulick?
}
A.
Are you asking me to verify that this is correct?
COMMONWE ALTH RE PORTING COM P ANY (717)761-7150
sll 13 1
g yes.
2 A.
Which statement exactly?
3 G
Slone 'came in just before Slone left and asked for 4
your resume.
5 A.
I think that's probably correct, to the best of my i
memory now.
l 6
7 G
Basically, my understanding from reading this is 3*
8 that you gave him the resume and you had an understanding with 9
Slone that if Slone found anything, a suitable job for you, 10 an opportunity with a consulting firm or with Slone, that he l
11 would let you know.
1 1 ~9 l
A.
No.
I think you're putting words in what this 13 says.
14 G
Could you put it in better words?
15 A.
Yes.
I think I just said it a while ago, too.
16 I wasn't given -- nowhere in this conversation did Slone give 17 me the impression that he had a company that I'd be working 18 for him and he was going out job-shopping me.
I never got 19 that impression anywhere.
90
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O But, on the contrary, he was just going to see "I
~
if he saw an opportunity for you personally?
A.
Yes; and that's not uncommon.
That's not uncommon 93
~
in our profession when you're working with people, friends,
4
~
whatever, to look after friends.
If you see another job up o r,
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there where you go, hey, give me a call.
COMMONWE ALTH REPORTING COMPANY (717)761-7150
I s12 14 i
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G Did there come a time where you learned that Slone 2
was, in fact, using your resume to job-shop?
3 A
Yes.
I 4
G When was that?
l 5
A.
That was months later when Secretary Rose Pavalonis I
6 told me -- interrupted a conversation that I was having with 7
somebody else and said that she typed my resume on Quiltec's a
E" 8
stationery.
9 G
Can you fix a date to that conversation?
10 A
It was a while after that.
I don't remember the 11 exact date.
Even if you're looking for the excet month, I lo don't;know.
It was'a long time after that; probably the
~
spring.of
'83, almost a year later.
4 G'
'Was it after King was separated from TMI-2 or before?
MR. RICHARDSON:
Excuse me.
By separation, keep in II mind there are two events; a suspension when he was taken off site and then his later formal termination.
THE WITNESS:
Do you know those dates?
I don't know
~o o
what those dates were.
') 1
~
BY MR. JOHNSON:
22 O
Was it before February 24th, 1983, which was the
.y'
~
date that King was ordered off the site?
q MR. IIICKEY :
The day he was suspended was February 24 95
~'
THE WITNESS:
I don't know, but it seems to me like that COMMONWE ALTH REPORTING COMPANY (717)761 7150
sl3 15 k
1 kind of information has been said somewhere before.
I thought 2
that had been established.
3 BY MR. JOllNSON:
4 G
That may be, but --
5 A.
I don't remember.
I would think that it's somewhere i
l 6
in that time frame, but I don't know.
l 1
7 g
I'll just remind you that you're under oath.
8 A.
I understand.
9
.G Once you overheard -- you said Rose Pavalonis.
She 10 was the former Rose Rittle.
I take it she got married.
11 A
Right.
She used to: work for me, my secretary.
I2 Q
Do you remember the time frame in which she worked 13 for you?
14 A.
It was a fairly short time frame.
Q And when was that?
A.
I don't remember.
TE1 I.'
g was the conversation that you're referring to 18 that she told you that your resume had been among those that 19 had been typed, did that conversation occur when she was your 20 secretary?
21 A
Yes.
g Did you say anything to Rose Pavalonis about that 93
~
when she told you that?
What was your reaction?
Did you say 94
~
something to her?
o.
A.
I might have asked her to clarify to make sure I COMMONWE ALTH REPORTING COMPANY (717)761-7150
s14 16 llh I
heard her correctly, other than that, I don't think I did say 2
anything.
3 G
Did you ask her if she had any evidence of that 4
fact?
I 5
A.
No.
6 G
Did she have a copy of the resume?
l 7
A.
I didn't ask her.
8' 8
G
-Did you go to your supervisor at that time and 9
tell him that'you had just learned that your resume had been 10 typed apparently,'according to Rose's statement, on Quiltec's II stationery?
A.
Right.
I attempted to.
I went to Mr. Buchanan's 13 office, and he was not there.
Then I went straight to the 14 next level manager, who was Jim Thiesing, and I told Jim in exactly what I had just been told by Rose.
16 G
Do you have any recollection of when that was that 17 you went to Mr. Thiesing?
18 A
It was immediately.
I mean, it was in minutes 19 after I learned.
O
~
G And what did Thiesing say?
91
~
A.
He said he would tell Kanga and he'd get back in f)')
~~
touch with me.
O']
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G Did Thiesing indicate to you in any way that he 24 was aware at that time that Rose had typed resumes for Quiltec?
25 MR. RICHARDSON:
Excuse me.
Did Thiesing tell him COMMONWE ALTH REPORTING COMPANY (717)761-7150
l sl5 17 I
whether or not Thiesing was aware?
2 MR. JOHNSON:
Yes.
3 THE WITNESS:
Thiesing didn't say anything to me about 4
it.
5 BY MR. JOHNSON:
b 6
4 Was this before or after you went on a trip to 7
Idaho with Thiesing on the 2nd of February, approximately, of l
8
'837 I
'i 9
A.
I think this was after.
I think so.
I 10 G
Did you tell Thiesing that,as far as you were 11 concerned, having your resume typed on Quiltec was not authorized by you?
13 A.
Yes.
I told him that.
14 G
Was his reaction favorable?
What was his response 15 when you told him that?
16 A.
Very concerned.
I think he immediately realized 17 that I was very upset about it.
I think he took the proper action.
He said he'd go talk to Mr. Kanga immediately about 19 it.
20 G
Do you know of anything else he did?
e 21 A.
No.
G Did you contact anybody else besides Mr. Thiesing?
23 A.
Well, when I did find my supervisor, Mr. Buchanan, 21 I told him also.
25 G
And what did he say?
COMMON WC ALTH RE PORTING COMPANY (717)761-7150
18 sl6 7
1 A.
I think he also had the same concern that the facts q,,/
f 2
were properly transmitted to the right level of management.
I 3
G In November of 1982, you attended an ANS meeting.
)
i 4
You gave a paper there?
5 A.
Right.
l 6
O Did you learn that Mike Herlihy and Ted Reckart 7
were at Shor'eham with Slone?
O' 8
A.
Yes.
9 0
You learned that byl talking with somebody who was 10 working at Shoreham?
11 A.
Right.
It was a person I met from Stone and I2
('~'j
- Webster, s-G Did the subject of either Quiltec, the name Quiltec or Larry King come up in connection with that conversation?
14 15 A.
No.
G When you returned from the ANS meeting in November, 16 did you recount this incident concerning Herlihy and Reckart 18 working with Slone at Shoreham to Mr. Buchanan?
19 A.
Yes.
"o
~
G And what was his reaction?
oi
~
A He was amazed.
G Did he say anything to you?
23 A.
Oh, yes.
"4
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G What did he say?
A.
He was amazed that Rockart primarily was associated,
~'
cOMMONWE ALTH REPORTING COMPANY (717)761-7150
- ------- a
19 sl7 l k I
up there, because basically Ted Reckart had worked for Dave 2
and left and told him he was going to do something entirely 3
different.
4 Basically, he lied to him.
That was part of the 5
amazement.
6 G
Did you have any discussion at that point -- did 7
Mr. Buchanan or you bring up the subject of a connection 8
between Herlihy and Reckart leaving and King being their I
9 supervisor?
10 A.
No connection was made.
11 G
Did Buchanan say he was going to look into it or 12 do anything?
13 A
No.
He didn't say that either,to my recollection, j
I4 G
Toward the end of 1982, did you hear of rumors 15 concerning connecting King with Quiltec?
16 A.
Yes.
l I7 G
What was the source of those rumors, if you can 18 remember?
19 A
Just talk; people.
G People at your level, people at higher levels?
l 20 l
oj
~
A.
Probably at my level.
The name "Quiltec" was not 22 firm even in the rumors that I remember.
n.3 G
But do you remember that the connection between 8
1 "4
~
Slone and King was firm?
n e, A
I can't even answer that, to be honest with you.
~'
COMMONWEALTH REPORTING COMPANY (717)761-7150
s18 20 lh I
G Once you heard these rumors about connecting King 2
with these people leaving, did you have a conversation with 3
Mr. Buchanan and with Mr. Thiesing concerning that?
4 A
I had a conversation with Mr. Thiesing.
l 5
G Was that in December of 1982?
6
.A No.
The first time that I can recall talking about 7
that to Jim was on that ski trip -- I shouldn't say ski trip E'
'usiness trip that wound up a ski trip at the end of it.
8 b
9 G
I was wondering about that.
I saw different 10 references to business trip and ski trip.
11 A-It was both.
MR. HICKEY:
I might add on the witness' behalf that 13 before the deposition began, we were teasing him about ski 14 trips, which may be part of the explanation for his answer.
15 (Pause.)
16 MR. HICKEY:
You used a December '82 date?
17 MR. JOHNSON:
Yes.
18 MR. HICKEY:
Is there some reference to that in this 19 memorandum?
oo
~
MR. JOIINSON:
On page 8 of the interview by Aulick, ol
~
paragraph 15 references somewhere around the end of the year.
Then the third sentence says, "Also, Austin thinks that some-9.3
~
time during this time period, Buchanan had a conversation 24 with Thiesing."
25 COMMONWEALTH REPORTING COMPANY (717)761-7150
ls19 21
(/)
1 BY MR. JOHNSON:
~.
2 g
Did you identify Rich Gallagher as a possible sourc e 3
of the information that put King together with IIerlihy and 4
Rockart?
5 A.
Did I or can I?
6
. g Did you?
7 A.
I don't recall that.
Where abouts are you reading 8"
8 from so I can maybe follow this?
9 g
Do you have a copy of this interview memorandum?
10 A
Yes.
11 g
It's on page 8, paragraph 15.
It does say that r1 at the time -- Mr. Aulick stated in his record of this i
/
x/
13 interview, "As to the source of the rumors, Austin identifies 14 Rich Gallagher as the individual who tended to put King with the other guys.
There were others, but Austin can't 16 specifically recall them.
In January, the rumors started to 17 become hot and heavy."
18 Are you saying that you may have misspoken when you 19 gave this information or that Mr. Aulick misunderstood your
~o o
statements or wrote them don't incorrectly or you just don't
~l o
remember having said it?
A.
I'm saying I can't remember that today.
,v;
~'
G Did Mr. Aulick show you his notes at any time 04
~
or this memorandum contemporaneous with May 18th, 1983 after 25 he interviewed you to verify that what he got down was correct?
COM MONWE ALTH RE PORTING COM PAN Y (717)761-7150
s20 22
- )
1 A.
Not to my recollection.
2 g
Did you ask him?
3 A.
No.
My understanding of this was to try to in 4
general see what I understood, and they gave that to Stier; 5
and then Stier and I had the formal deposition.
I don't fi even remember this thing.
7 MR. HICKEY:
Are you saying you don't recall having 8
8 seen this document before?
9 TIIE WITNESS:
I really don't.
10 BY MR. JOHNSON:
11 g
Let me show you the record of your deposition.
12 On page 5 -- let me see if I can get the first page to show
.s
'v) 13 you what it is.
It is the July 27, 1983 interview that you had with Mr. Stier.
M A
Right.
O On page 5 -- well, starting on the bottom of II page 4, you're asked, "Can you identify where those rumors I8 were circulating; that is, did you hear it from your superiors in GPU?"
You respond, "Yes; I believe Rich Gallagher told me oo
~
that it was rumored that King was associated with Quiltec; og also probably in January of this year when my immediate boss 22 told me that he thought there was some connection."
y
~
A.
Yes; okay.
94 G
As far as you can remember, that's what you said?
l 95 A.
Sure.
I went over that document very well at the i
COMMONWE ALTH REPORTING COMPANY (7171761-7150
r s21 23
/
1 end, and I've signed it based on its accuracy.
But I'm having 2
a lot of trouble three years later remembering what I said 3
on that document.
4 G
Right.
I appreciate that.
5 (Pause.)
1 6
G Did Mr. Thiesing ever ask you to find out more I
7 information about Larry King and Quiltec?
8" 8
A.
No.
9 Q
At some point, though, in time, you told 10 Mr. Thiesing about the resumes and yours being part of it, 11 the resumes being typed on Quiltec's stationery by Rose Rittle-1 ~9
(~)
Pavalonis?
\\./
A.
That was that immediate response I had.
14 Q
Did you have any other conversations with 15 Thiesing about that, about Parks getting the resumes typed?
A.
I think at the time I didn't even know who did it.
You see, you said " Parks."
The only comment Rose made to me 18 was that, "I typed your resume on Quiltec's stationery."
19 She didn't tell me who told her to do that; so I never even 90
~
put Parks with having the resumes typed.
I didn't know who "I
~
did it.
O So before she told you -- and the time frame I think r;
~'
we established generally before -- you had no idea about the 04
~
typing of resures on Quiltec's stationery, yours or anybody 25 else's?
{
COMMONWE ALTH REPORTING COMPANY (717)761-7150
24 s22 1
A.
Absoultely correct.
2
(
And you learned from Mr. Buchanan of the connection 3
between King'and Quiltec -- let me start again.
You learned 4
from Mr. Buchanan that he had been told at a New Year's Eve party,by Ted Rockart of the connection between King and 5
6 Quiltec?
7 A.
I remember him telling me about the New Year's Eve B
8 party where he talked with Ted.
9 0
And what's your recollection of that?
10 A..
I really don't remember the exact details.
I'd 11 have to go back and read that.
12 (Document handed to witness.)
I3 0
But as far as your statement here --
A.
Whatever is in here, I feel pretty confident that I4 15 it's right.
16 Where is it?
II G
It's right in the middle of the page there at line 8.
(Witness perusing document.)
oo
~
A.
"It is rumored that King was associated with
'> l Quiltec."
I think that's probably true.
MR. HICKEY:
I don't know if you want to direct him, O '}
but lines 16 and 17 say "I do not know - " this is your
~'
04
~
answer -
"I do not know whether ny immediate supervisor os
~
mentioned the name ' Larry King' at that time or not.
I just COMMONWE ALTH REPORTING COMPANY (717)761 7150
s23 25 (o)
I don't remember."
~./
2 THE' WITNESS:
I don't remember that to this day.
The 3
conversation centered around Ted Reckart primarily.
4 BY MR. JOHNSON:
5 G
And his association with --
G A
His association.with Shoreham.
7 G
And Quiltec?
O 8
A.
I reckon.
Or lack of association with this firm 9
in Texas.
That's probably what they really talked about more.
10 0
What did you learn betwoon January 1st -- obviously, 11 Buchanan couldn't have told you about this New Year's Eve 12
.f}
party before January 1st, but I presume that he told you this L.J U
information sometime after that, presumably early January.
What did you learn between that time and your trip U
to Idaho with Mr. Thiesing that caused you to -- let me back up.
Did you raise the question of King's connection with I
Quiltec and Slone during that trip with Mr. Thiesing in I
February?
19 A.
Yes.
"O
~
Q What did you learn between early January when ol
~
Mr. Buct'. nan told you about the New Year's Eve party and 22 February 2nd which caused you to raise the question with 03
~'
Mr. Thiesing on the trip?
og
~'
A Can you refresh my memory based on that?
I just
)
l 25 remember rumors.
l l
COMMONWE ALTH REPORTING COMPANY (717)761-7150 j
s24:
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1 MR HICKEY:
.I think the form of the question' implies-2 that you' learned sbmething more, and I don't know if 3
Mr. Johnson intended that or'not.
i l
4 I"think hes $sking Nhat prompted you to bring it up.
5 to Mr. Thiesing;on the trip.
6 MR. JOHNSON:
That's right.
7 THE WITNESS:
I think it's just basically rumors.
8 That's all that I ever heard.
I didn't have any concrete 9
facts,'but pieces of the puzzle were starting to fall in 10 place.
11 BY MR. JOHNSON:
O My understanding of the deposition record and 13 other pieces that were supplied to us is that, as you'say, the pieces started ' falling together; you knew that Lionaroms-I had left, that Reckart had left, that Herlihy had left, and 16 they were all going with Slone or some of them were working-I 17 at Shoreham, if not all of them; and that there seemed to be 1
18 a connection between Slone and King; and that once you suspect 3d 1 19 tnat King was connected with these people leaving and these
'l oo
~
people had been working for King, you brought it to Thiesing's l
l 21 l
attention.
q l
99
~~
A.
That's correct.
93 f
G I'm asking:
was there anything specific that you
~
l V
24 learned in January of '83 that led you to bring it up, that Capped it, that made you say, "Well, I know enough now to go to COMMONWE ALTH REPORTING COMPANY (717)761-7150
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27 4
J Y
Mr. Thiesing 'and tell(him."?
1-G 2
fA.
No.
I never had any facts that I considered facts.
,c
-3 The only thing I can' remember is-rumors,. people talking, lots 4
.of three, people.. going to._ work for the.same firm.
5 I Yhink my point was that'they ought to.look into 6
it.
Because if there was a connection, in my opinion, it was 7
truly unethical.
8 g
Did Mr. Thiesing seek your advice on'that
~
9 question as to the ethics of it?
10 A,
Yes.
11 g
And that's what you told him; 'that it was unethical?
12 A.
Yes.-
I told him that, and it's'also stated'in-13 the Code of Ethics of Engineers.
It's very' clear, that type 14 of conflict with'your employer.
15 g
.In the course of.your work, say during the.. fall 16 of '82, early winter '83 period, were you working with King 17 at all?
18 A.
No.
19 1
0 You had no day-to-day contact with him?
l 20 A.
Not a bit.
9
~
g So you didn't have any occasion to bring this matter up bsfore him directly?
.n'
~
p A.
No.
I never talked to King.
Ile never talked to
.b) 24 me.
25 0
Was that something you did consciously?
COMMONWEALTH REPORTING COMPANY (717)761-7150
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- /Y I
1 A
No.
It'was jus't a' matter of our role responsibili-
,c t
N 2
ties.
He was the director of.an entirelyLseparate department from myself,.andI'was basically an engineering supervisor-3 I
4 doing another scope of work.
We had no reason to even talk.
=5 O
Did you have any contact with Parks?
'O A.
No.
As I stated earlier, my entire work scope ~was 7
based on reactor disassembly. _That was the part that fell
!O' 8
under Jim Thiesing's directorship.
King and Parks didn't' t
9 have_anything to do with it.
10 0
So you had no day-to-day' contact with King or 11 Parks?-
lo e'T-A No, neither one.of them.
~
.U 13 MS. WOODHEAD:
If.all you knew was rumors about this:
34 '
possible connection of some sort of vague idea of employees 15 leaving, how could you make an ethical judgment?
16 THE WITNESS:
It's in the Code of Ethics.
MS. WOODHEAD:
I mean, on what basis did you make an j
I8 ethical judgment if all you knew was rumors?
I think the witness' testimony was that 20 he thought it should be looked into; because if it was going 21 i
on, it was unethical.
i 20
~
THE WITNESS:
Yes.
~
MR. WOODHEAD:
If what was going on?
j 93 r~
THE WITNESS:
If the rumors were true, then there is l
9'
~
a conflict there.
And asking me about why I feel it's from COMMONWE ALTH REPORTING COMPANY (717)761-7150
4 s27.
29
.]
7
)
I an ethical stabdpoint, I'think that is the ethical thing to
~
2 do, and I think.it's also one of the sections in the Code of-3 Ethics if you look at.that, i
4' MS. WOODHEAD:
Well, what~were the rumors, I guess I 5
would like to know?
6 THE WITNESS:
The association of a director'of our i
corporation with another firm that was possibly competing for 7
s 8
resources within our corporation -- not within.our corpora.
i 9
tion -- in our corporation for use;for'his own private gain.
10 That's the question.
11 MS. WOODHEAD:
Okay; so.the rumor you heard was that l
Larry King was instrumental through his company in. hiring 13 people away from the general-GPU. organization?
14 THE WITNESS:
I don't think it was quite that. clear.
I'd say it was more that Mr. King was somehow or another-IG associated with these people; but exactly how, I don't know.
I I didn't know that.
18 MS. WOODHEAD:
These people meaning?
19 THE WITNESS:
Reckart, Slone, Herlihy, maybe Lionarons.
90
~
MS. WOODHEAD:
So it was sort of a vague connection?
i oj THE WITNESS:
It was very vague.
l
~
MS. WOODHEAD:
And the rumors --
o3
~
"N THE WITNESS:
The rumors were just as vague as I
\\
24 stated it, o r,
~'
MR. HICKEY:
In fairness to the witness, you testified COMMONWEALTH REPORTING COMPANY (717)761-7150
__u.__
s28 30 1
earlier to something that was more than a rumor.
You i
l 2
testified,that you learned from a pretty good source that l
3 Mr. Reckart was at Shoreham and you knew what Mr. Reckart 4
had told you when he left TMI, and it was not that he was 5
going to Shoreham.
6 THE WITNESS:
True.
7 MR. HICKEY:
You talked about the lie that Mr. Reckart 8
8 had told.
9
.THE WITNESS:
True.
10
.MS.
WOODHEAD:
The lie being that he was going to 11 Texas?
19
~
THE WITNESS:
Something like that.
13 BY MR. JOHNSON:
14 0
You had occasion to talk to Mr. Arnold about 15 Quiltec.
Do you remember when that was?
16 A.
Probably February.
It was I would guess sometime 17 in February.
18 MR. HICKEY:
I think there is a memorandum in the file 19 from Mr. Arnold that puts the date on March 11th.
20 THE WITNESS:
Sorry; I'm not good on dates.
21 MR. HICKEY:
You don't remember the exact date; is 22 that right?
23 THE WITNESS:
Now I do.
e 24 BY MR. JOHNSON:
25 G
Did you tell Mr. Arnold during that interview --
COMMONWEALTH REPORTING COMP ANY (717)761-7150
s29 31 lh I
first of all, it was a one-on-one interview?
2 A
Yes.
3 G
Did you tell him that you had heard these rumors-4 about King?
5 A
Yes.
6 G
Him being involved with Quiltec and the possibility 7
of having hired away GPU employees?
8' 8
A Yes.
9 G
Did you tell him when you had first heard those 10 rumors?
11 A.
I don't specifically remember if I told him when 12 I heard those rumors.
13 G
Did he express dismay or upset to you that you had.
14 not come to him before March lith to tell him about this?
15 '
A.
Yes.
1G G
Do you remember what he said?
A.
I think basically from what I remember of the 18 conversation, he was very concerned.
He was upset that he 19 had not heard prior to this investigation.
I reckon that
<>0
~
that was his response that I remember, oj
~
G Would it have been something unusual for you to approach Mr. Arnold about anything?
23 A.
Yes.
"4
~
G Did you feel that it was justified, his being upset with you for not coming and bringing this information to COMMONWEALTH REPORTING COMPANY (717)761-7150
.i 1
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.t df 32 i:
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1
.him earlier, given your relationship?
,j 2
A.
Was he justified in being upset at me; is that 3
the question?
l 4
-G Yes.
l 5
A.
No, I. don't think so.
I think that's.what you 6
have an organization for.
It's up to.~the. organization to-7 take care of it on up to the proper levels.
I don't normally 8
talk to Mr.' Arnold.
9 0
You were going to tell Mr. Buchanan, but -- well, 10 you then went to Thiesing -- I'm sorry; I'm confusing'two i
11
' things.
12 You went to Thiesing. 'Now, your immediate supervisor
%)
13 was Buchanan?
14 A.
Right.
15 G
Why didn't you go'to Buchanan first or'did.you IE' go to Buchanan first?
II A.
I probably did.
18 g
Do you remember whether you did or not?
I A.
No, I can't say for a fact.
l I
20 0
But you did go to Thiesing?
')1
~
A.
Yes.
MR. HICKEY:
Wait a minute.
I'm confused by the 23 questioning.
I don't know whether the witness is also, but
.)
8 b
')4 let me see if I can express my confusion.
l
~
There has been testimony about when he learned about COMMONWE ALTH REPORTING COMPANY (717)761-7150
\\~
_-_____-____-__--_A
s31 33 lh 1
Rose Rittle, he tried to go to Mr. Buchanan and he went to 2
Thiesing.
3 MR. JOHNSON:
Right.
4 MR. HICKEY:
You're talking about him going to Thiesing, 5
and that's the only testimony about going to Thiesing except 6
for the airplane trip.
7 He also testified about having a conversation with 8
Mr.
Buchanan about the New Year's Eve party.
But you're 9
talking about going to Mr. Buchanan, and I don't know whether 10 you mean something other than having the discussion about 11 New Year's Eve --
12 MR. JOHNSON:
No; it was ineptly phrased.
You're right 13 BY MR. JOHNSON:
14 G
I was just wondering:
you thought it wasn't 15 necessary or appropriate necessarily for you to'go to 16 Mr. Arnold about this matter.
17 A.
No.
g Then it just struck me:
well, why did you go to jg Thiesing or why did you tell Thiesing without telling Buchanan?
19 A.
Mr. Arnold was like four or five levels of management gg above me.
I tidnk in any organization, people tend to talk to not only their supervisor, but their supervisor's supervisor.
23 There are a couple of levels that overlap a lot, but 24 it's not typical for me to call up Herman Dieckamp and express 23 some concern.
I don't do that.
COMMONWEALTH RE PORTING COM PANY (717)761-7150
i i
T6:j47 l
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1 BY MR. JOHNSON:
v 2
G Did there come a time when you thought perhaps
)
3 that Carl Hrbac might be going with Slone and his outfit?
s 4
A.
I can remember that now, but I don't know whether 5
I can put a date on that or I knew that in tnis time frame j
6 that we've been talking here.
7 G
I'm just curious, how did the name of Carl Hrbac g
come up in this connection so that you would have thought it 9
might be possible, or why did you believe that Hrbac, 10 irrespective of the time frame, --
11 A.
Would want to go to work for Slone?
12 G
Yes; why he might be also about to leave.
-)
(
/
13 A.
To better himself I reckon; I don't know.
Found 14 a better job, more money.
15 0
Were you friendly with him?
16 A.
Yeah, sure.
I knew Carl quite well, Hrbac.
17 G
Do you still have contact with him?
18 A.
No, not at all.
To my knowledge, he went to Ohio 19 to get in the chicken and egg business, and he went broke.
20 I'm not sure where he is now.
21 O
You said something earlier, and I just want to try 22 to verify it.
You said that that conversation you had with 23 Rose Pavalonis occurred when she was your secretary.
I
{
9 I
24 A.
Correct.
20 g
Did you ever go to Larry King in the early 1983 COMMONWE ALTH REPORTING COMPANY (717)761-7150
35 j48 1
period and inquire about a job?
I 2
A.
Yes.
3 MR. HICKEY:
What is the time period?
4 MR. JOHNSON:
In early 1983.
5 THE WITNESS:
Wait a minute.
Let me make sure I under-
\\
6 stand the time period again in my own mind.
7 MR. HICKEY:
February is when you went to Idaho with g
Thiesing, February
'83, right; the first part of February
'83.
9 THE WITUESS:
I really don't know the time frame.
I to would have to go back and think about that.
11 BY MR. JOHNSON:
12 G
Just tell me what you can remember.
O 13 A.
But I did have a conversation with him concerning l
l 14 that subject.
l l
15 G
Was it about going to work for King?
10 A.
Yes.
Let me explain.
This conversation occurred l
l 17 when we were getting ready to have another organizational 18 change.
The background is that GPU was looking at an integratcd M'
organization where they brought in the Bechtel managers and 20 made GPU employees integrate into their organization.
In 21 fact, it seems to me like it was '82 that this happened.
I'm 22 not sure.
23 MR. HICKEY:
Well, I can clarify it for you this way.
24 Mr. King left February 24, 1983.
20 THE WITNESS:
It had to be
'82.
COMMONWEALTH REPORTING COMPANY (717)761-7100
j4S 36
i MR. HICKEY:
There was a reorganization that was j
7 a
2 effective September 1, 1982.
THE WITNESS:
Okay, that helps a lot, because this 3
4 occurred prior to that organization change.
5 MR. HICKEY:
So the summer of 1982?
6 THE WITNESS:
The summer of '82 would be a good time frame.
King was a GPU person, of which I had a lot of respect 7
a for.
I thought he did his job vcry well.
It was obvious 9
that the type of work that I did fell under the recovery jo part of the program, and my assessment was that I was going ti to be thrown over in the Bechtel world and I was going to be 12 reporting to Bechtel managers; I was going to be reporting to
- 7. -
/
13 Jim Thiesing, which I didn't want any part of at the time.
14 I stopped in Larry's office for a very brief moment --
15 I bet it didn't last two minutes -- and asked him, "When you 10 all are going through the personnel and deciding who works 17 for who in this new organization, how about keeping me in 18 mind?"
And that's kind of where I left it.
The job I asked 19 for had to do with going to work within the GPU organization 20 within the plan ops department, and to try to get away from 21 the Bechtel managers.
I didn't want to work for them.
22 That was -- he just said okay.
He didn't even say 23 anything to me.
He just kind of listened for a few minutes 9
24 and said, "Okay, I'll keep you in mind."
That was the end of 25 it.
COMMONWE ALTH REPORTING COMPANY (717)761 7150
1 l
j50 37 l
l 1
BY MR. JOHNSON:
2 Q
Did he ever get -- oh, he never got back to you?
3 A
Never said another word to me, and I got thrown 4
into the Bechtel organization working for Jim Thiesing.
1 n
G Can you just tell me very briefly what it was that i
6 you didn't want to get into the Thiesing/Bechtel organization i
1 7
for?
I i
8 A.
At the time I thought Bechtel was doing a lousy 9
job of cleaning up.
I had been involved in a couple projects 10 that were done by GPU in the reactor disassembly, the quick 11 look had been done; I did all of that.
It appeared that from 12 a political standpoint Bechtel was going to capitalize on a O
13 lot of work I did, and they were going to take it over, and 14 I was just going to be enveloped under them; and I didn't 15 want to do that.
I was a GPU employee, and I wanted to stay 16 a GPU employce.
17 G
How did it work out?
Is that the way it worked 18 out?
19 A.
No, it didn't work out that way.
We split it all 20 up and I went to work for Bechtel, a Bechtel manager; I'm 21 still a GPU employee.
We've managed to cope with that type 22 of an organization ever since.
I still work for a Bechtel w;
manager.
24 0
Who is?
20 A.
Rich Gallagher.
Currently, today, I work for COMMONWE ALTH REPORTING COMPANY (717)701 7150
j51 38 i
]
1 Bechtel.
- t. -
2 g
The information I have -- I can' t put my hams on
,/
3 it -- there is information I h ave from a. nether,, source and I could, $nt I'm having 4
would just like to pin it down, if '
(
5 trouble -- was that you went to King early, n ' J,9 81 ebout a 6
job.
You're saying that's not truel r
7 A.
No, that's not " rue.
.i 8
MR. HICKEY:
It it helps your --
9 THE WITNESS:
No, I've nev 3r hea rd thui before anywhere.
t 10 MR. HICKEY:
I haven ' t ei ther, 'out..] ik helps your
.i i
11 recollection, you previously producef on FrI<id,.,o1 last weer g) a few pages from a trc isc-ipt of an incyrniew /,f Tprry King
~j 12 l
h by an OIA investa.ptor that referg:to br,,Atst;in, 13 and it 14 says that abortly after Ben Slone left. to go to Shoreham, J
t 15 Mr. Austin came in to see Mr. King to.look for a jol, and' i;
V 16 Mr. Kino, therefore, knew -- with Ouiltec is whaj.Mr. King's,
}
17 transcript says, and that Mr. King says that "Mr. Aus t.i n kr.2r 18 I was involved with Quiltec because he came and asice.d me fo'-
a joc."
Toat's'ahat the transcript in summary says.G at you'.
19 20 gave me on Friday, a poitian of a.hich, a small portien'sf i
21 which, you gave me on Friday.
22 DY MR. JOHNSON:
G And your testimony, heving leard th'at summary, your 23
~
l 7
24 testi;nOny is th" - thc t is not tr w?
l l
2I' A.
Tnat is not true.
l COMMONWF.ALTH RF.PORTINQ: C C MPANY (717) 161-71/
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t MR. J011NSON :
Thank you.
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MS. WOODUELD: 'Do you recall that conversation with-2 King well enough at t.his' late date --
3 THE; WITNESS:
Absolutely.
There was another guy 4
standing there -- it was not a pri ate conversation -- a guy 5
named Kingsley Draper, who was standing thgre,
.It was one ct '
g those, youwIlkbythn hal] and you say something and you keep 7
going.
But I had no intention et all of going to work for g
some firm named Quiltec.
It solely had to do with our own g,
org inizati.on.
39 If you look at the time frame, we were reorganizing 33 12 when that conversation occurred.
jq
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I BY MR. JOHNSON:
5 t;3 i \\
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- 1. 1 G
Did you think it was pretty clear that that was f,
i.
i,he context?
Do you think there was a possibility of mis-10 t
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16 understanding?
17 A.
That was my intention.
I'm amazed that he drew 18 that conclusion '.~ rom chat.
There is nothing that could 19 possibly haue Ted him to draw that conclusion.
20 G
Unless, perhaps, you just talked generally and he 21 misunderstood; that is also possible.,
I l
22 r A.
Well, in order for him to' draw'that conclusion, he 0
23 h must have had to talk to me some other time and explain to me 24 his firm, or haw.' evidence that somebody else t. hat's in his 25 firm talked to me, and that slaply did not oc*nt.
COM MONWE N..*H REPORTING COMPANY (717)761-7150 o _
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j53 40
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i G
Is it possible that he may have believed that 2
Slone had talked to you?
3 A.
I could never draw that conclusion.
4 G
You had given a resume to Slone.
5 A.
For another purpose.
6 G
And then Slone apparently used it for a purpose i
7 which you say was not intended.
3 A.
Right, nor authorized at all, or that I was even 9
aware of.
10 G
But it is possible, isn't it, that Slone had mis-11 understood, done whatever he did with it, and had informed 12 King and misinterpreted your --
._l
/
k
/
13 A.
Intention?
14 g
- yes, 15 A.
I think that's possible.
16 MR. IIICKEY :
There are other possibilities, too.
]
i 17 (Pause.)
)
(
MR. HICKEY:
Let me clarify one thing while you're
{
18 j'
)
I 19 ))! l o o k i n g,if I may.
]
1 20 Mr. Johnson's last couple of cuestions implied that l
21 Mr. Slone was the source of the resumes that were being typed 22 by Ms. Rittle on Guiltec stationery.
Do you know that?
Do i
23 you know that Mr. Slone gave the resumes to Ms. Rittle to 24 type on Quiltec stationery?
l 25 THE WITNESS:
I don't know that.
The only thing that I
{
1 l
COMMONWEALTH REPORTING COMPANY (717)761-7150 i
J
41 j54 1
know is I gave out one resume in that entire frame of several l
g l
2 years, so it had to go through Slone somehow.
And I haven't 3
given out one since.
4 MR. RICHARDSON:
Did you have a resume on file with 5
GPU?
6 THE WITNESS:
As part of our qualification in engineer-7 ing, we keep a resume on file.
It is not the same type, and 8
it is typically not -- well, let me take that back.
I've 9
never seen the resume that was typed on Quiltec stationery.
10 I don't even today know that it exists, so I don't know what 11
-- whether they got the one out of the file and typed it, or 12 they got the one that I gave Slone, because I have never seen 0
13 it.
14 BY MR. JOHNSON:
13 0
Let me ask you a little bit about the one vou gave 16 Slone.
Who typed that resume that you gave Slone?
17 A.
I don't knov.
18 0
Did you type it?
M' A.
I might have.
I know how to type, and I typed 20 some of them years ago.
21 0
Is it possible that you got one of your secretaries 22 to type it?
23 A.
It's possible.
24 Q.
You don't remember?
25 A.
No.
I think it would probably -- no, I shouldn't COMMONWEALTH REPORTING COMPANY (717)"761-7150
j55 42 even say that.
I was there about a year.
I had resumes from
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3 t/
my previous job.
I'm guessing it's probably one of those.
2 G
One of your prior resumes?
3 A.
Yeah, something of that nature.
4 G
Prior to the time you came to TMI?
5 A.
Probably.
But I am guessing.
6 MR. RICHARDSON:
Maybe we're heading in the barn now.
7 3
You're holding up quite well, but you're also breaking our 9
record for going without a break.
THE WITNESS:
I've got to leave in a few minutes.
3o MR. JOHNSON:
We're going to be winding up by 4:00, 11 12 as far as my questioning is concerned, so there is no real
,s
)
13 need to take a break unless you feel like it is worth doing.
14 I would rather just try to wind up.
15 '
MR. RICHARDSGN:
Okay 16 THE WITNESS:
Fine with me.
I 17 MR. JOHNSON:
That's the reason I 6idn't take a break.
18 I knew that he had to leave.
19 (Pause.)
20 BY MR. JOHNSON:
21 G
There is a statement in the deposition by Larry 22 King, I think it was made to OI, Office of Investigations of 23 the NRC, in June 1983, page 369, in which he says, "I do know, 24 based on the Congressional hearings, Thiesing was made aware 25 of any involvement in Quiltec by Bill Austin.
Bill Austin i
COMMONWE ALTH REPORTING COMPANY (717)761-7150
i j56 43 ggg I
approached me about a job in Long Island.
I just found him 2
to be unacceptable.
I didn't tell him that.
He later got l
3 upset when he found out how much the people made up there.
He 4
wanted to get out of TMI.
I found out that he knew Austin j
I 5
talked to me, and he admitted later he did give us a resume."
6 I find this a little bit confusing.
7 A.
Me, too.
I a
G Let me just ask you:
we talked earlier about you 9
approaching King about a job, but did you ever apprcach him 10 about a job on Long Island?
11 A-No, never.
12 G
Did you ever express an interest in leaving TMI O
13 to King?
14 A
No, not to King.
15 0
To anyone, to --
16 A.
I've already said to Slone.
I 17 MR. HICKEY:
Can I see that?
18 (Document handed to F.r.
Hickey.)
19 MR. HICKEY:
Can I see the rest of the page; I mean, 20 is there another page?
21 MR. JOHNSON:
I don't know if I have it with me.
I d
might.
23 Do you have any questions?
24 MS. WOODHEAD:
Just one.
I don't know if this is 2
pushing your memory too far.since it was some years ago, but COMMONWEALTH REPORTING COMPANY (717)761-7150
j57 44 do you remember precisely what you told Thiesing during your 3
trip to the west in February of '83?
2 THE WITNESS:
" Precisely" is pretty strong language.
3 MS. WOODHEAD:
That's why I said I may be really push-l l
ing y ur memory.
5 l
THE WITNESS:
I don't think I could say precisely what 6
l we talked about at all.
l l
MS. WOODHEAD:
Just in general it was something to do g
h with --
g THE UITNESS:
In general it was a concern over the 10 ethical question, the conflict of interest, the potential for l
11 l
12 that.
That was the conversation.
It was not a discrete con-0 13 versation.
It occurred over a week; I don't know when.
It 14 might have occurred several times.
16 MS. WOODHEAD:
It was a subject that was discussed 16 more than once during your trip?
17 THE WITNESS:
Oh, I think so, yes.
18 MS. WOODHEAD:
I see.
Did you implicate Larry King by 19 name, or was it less straightforward than that?
20 THE WITNESS:
I think I probably used his name.
21 MS. WOODHEAD:
Was there anybody else at TMI that you 22 mentioned besides King in connection with these rumors?
23 THE WITNESS:
Well, other than the people we've already 24 talked about, just Slone and --
25 MS. WOODHEAD:
No.
I mean people that wer still COMMONWE ALTH REPORTING COMPANY (717)761 7150
j58 45
~'i 1
employed at TMI in February of
'83.
,)
2 THE WITNESS:
As far as other people?
3 MS. WOODHEAD:
Yes.
4 THE WITNESS:
Yes.
I recall the fact that I was con-5 cerned because I had various young engineers working for me, 6
and I thought that they would be really vulnerable to the 7
type of offers that a private contractor could give because, 8
you know, the money incentive.
I spent a lot of time train-9 ing those people, and I tried to hold on to them.
That was i
10 one of my biggest concerns, I didn't want them taking my 11 people.
12 MS. WOODHEAD:
What I meant to cet at was:
[ )
~
did you es 3
/
13 hear any rumors or convey any information to Thiesing that 14 someone besides King might be involved in this company, whether 13 you knew its name or not, someone else employed at the island?
i 16 THE WITNESS:
Other people?
U MS. WOOFHEAD:
Yes.
THE WITNESS:
I don't think I said anything like that.
19 MS. WOODHEAD:
All right.
That's the only question I 20 have.
21 MR. JOHNSON:
Let me just review something for a 22 second.
23 THE WITNESS:
Sure.
24 (Pause.)
2n COMMONWE ALTH REPOPTING COMPANY (717)761 7150
j59 l
46 BY MR. JOHNSON:
')
1 2
0 In addition to these two interviews with Mr.
3 Aulick -- I'm sorry; I'm not sure I established that you did have these interviews.
Let me just show you these notes.
One 4
5 is of an interview of May 18, 1983, and the other one is May 6
24.
7 A.
Okay.
g G
Do you recollect having those interviews with 9
Mr. Aulick?
19 A.
Yes.
il G
Aside from those two interviews, do you remember
/ )
~ other interviews with Mr. Aulick?
12 any
_m 13 A.
No.
14 G
Do you recollect, in addition to these two inter-15 views ar.d your deposition with Mr. Stier, any interviews con-16 cerning Quiltec during the same spring / summer 1982 time frame 17 with either lawyers for GPU or Bechtel?
18 A.
This type of stuff?
No.
l 19 G
Concerning Quiltec.
20 A.
Concerning Quiltec?
No.
21 0
The answer is?
22 A.
No.
I have never talked to a Bechtel lawyer, never 23 even met one till today.
24 G
And GPU lawyers?
25 A.
GPU lawyers, just Pat.
I COMMONWE ALTH REPORTING COMPANY (717)761-7150
1 9
j60 47 0
Did you talk to Pat or any other GPU lawyers con-S 3
L,1 cerning Quiltec, in addition to these two occasions?
2 A.
Not that I can recall.
I 3
MR. JOHNSON:
Thank you very much.
4 We will have the same arrangement on signature of the 5
6 deposition, if that's okay.
MR. HICKEY:
You can~ send the original to me, and I 7
will see that the witness gets it to sign.
g MR. JOHNSON:
Fine.
Thank you very much.
9 (Witness excused.)
10 ji
(%hereupon, at 3:55 p.m.,
the deposition was 12 concluded.)
, -s
)
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13 14 15 16 17 18 19 20 21 22 23 24 25 COMMONWE ALTH REPORTING COMPANY (717)761-7150
kS1 48 1l CERTIFICATE OF DEPONENT o
4 2j I, William Edwin Austin, Jr., have read this transcript.
i i' of my deposition taken on January 13, 1987, and with the exception of the corrections noted, if any, find it to y
i' 5 ! be a true and accurate record of my testimony.
6 b
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9 Date William Edwin Austin, Jr.
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signed, this I N day of
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(
1 CERTIFICATE OF DEPONENT s,
2 I, William Edwin Austin, Jr., have read this transcript
)
i 3
of my deposition taken on January 13, 1987, and with 4
the exception of'the corrections noted, if any, find it:to 5
be a true and accurate record of.my testimony.
0 7
s 8'
8 9
Date William Edwin Austin,.Jr.
10 11 1
12 la I'
Signed, this day _of 19 15 16 17 i
18 Notary Public i
I9 Municipality:
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My commission expires:
21 22 23
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24 25 COMMONWEALTH REPORTING COMPANY (717)761-7150
_1
k52 49 h
1 CERTIFICATE OF NOTARY REPORTER 2
I hereby certify, as the Notary Reporter, that the 1
3 foregoing proceedings were taken stenographically by me, and 4
thereafter' reduced to typewriting by me or under my direction; 5
that this transcript is a true and accurate record to the 6
best of my ability; that the witness whose testimony appears 7
in the foregoing pages was duly sworn by me; that I am 8
neither counsel for, related to, nor employed by any of the 9
parties to the action in which this deposition was taken; and 10 further, that I am not a relative or employee of any attorney 11 or counsel employed by the partjes hereto, nor financially 12 or otherwise interested in the outcome of the action.
13 COMMONWEALTH REPORTING COMPANY, INC.
rQ J,
s 1
By:
44 rKf#im X./ /
14 p'
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I" John Anthony Kelly Notary Public in and for the 16 Commonwealth of Pennsylvania Harrisburg, Pennsylvania My contmission expires:
October 13, 1990 20 21 22 23 4
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2a 25 l
COM MONWE ALTH RE PORTING COMPANY (7171761-7150