ML20238C794
| ML20238C794 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 06/22/1987 |
| From: | Parks R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20238C505 | List:
|
| References | |
| CIV-PEN, EA-84-137, NUDOCS 8712310217 | |
| Download: ML20238C794 (800) | |
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ORIGINAL UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE ]
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IN THE MATTER OF i
GPU NUCLEAR CORPORATION, THREE MILE ISLAND NUCLEAR C ' e lt ION NO. 2 License No. DPR-73 EA 84-137 l
DEPOSITION OF RICHARD DALE PARKS June 22, 1987 VOLUME I BARKLEY COURT REPORTERS 4000 MAC ARTHUR BOULEVARD. SUITE 5500 REPORTED BY: NEWPORT BEACH, CALIFORNIA 92660 (714)752 1090 ROSEMARY SCHWARTZ, CSR #4836 2566 OVERLAND AVENUE, SUITE 570 FILE NO.87-242 LOS ANGELES, CALIFORNIA 90064 (213)202 6666 8312310217 ADOCK O8 h 320 PDR PDR T
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE IN.THE MATTER OF ) Docket No. 50-320
) (Civil Penalty)
GPU NUCLEAR CORPORATION ) License No. DPR-73 (THREE MILE ISLAND NUCLEAR ) EA 84-137 STATION UNIT NO. 2) )
) VOLUME I DEPOSITION OF RICHARD DALE PARKS, taken on behalf of the Respondent, at 4100 MacArther Blvd, Suite 300, Newport Beach, California, commencing at 10:40 a.m., Monday, June 22, 1987, before Rosemary Schwartz, CSR #4836, a Notary Public.
2
. _ _ _ _ _ _ _ - _ _ _ _ _ _ _ __ _ i
1 MONDAY, JUNE 22, 1987 - NEWPORT BEACH, CALIFORNIA 2 10:50 A.M.
3 4 (Whereupon Respondent's Exhibits 1 through 5 12 were marked for identification by the Notary Public, 6 and attached hereto.) {
f 7
8 RICHARD DALE PARKS, ,
I 9 called as a witness by and on behalf of the Respondent, 10 and having been first duly affirmed by the Notary '
11 Public, was examined and testified as follows: {
12 j 13 EXAMINATION 14 15 BY MR. HICKEY: Q. Good morning, Mr. Parks.
16 Would you state your full name and address for the 17 record, please.
18 A. Richard Dale Parks. My address is 19 unnecessary for this proceeding.
l 20 Q. Well, the reporter, when she completes the i l'
l 21 transcript of your deposition, will type it up and send 22 it to you and ask you to review it and make any /
23 corrections.
24 MR. JOHNSON: She can do that through -- through 25 me. I can forward it to Mr. Parks.
7
1 I
APPEARANCES: . ,
FOR THE UNITED STATES NUCLEAR REGULATORY
-COMMISSION:
GEORGE E. JOHNSON, ESQ.
AND ;
GREGORY ALAN BERRY, ESQ- 1 Office of the. General Counsel L Nuclear Regulatory Commission-Washington, D.C. 20555 (301) 492-7000-FOR THE RESPONDENT:
SHAW, PITTMAN, POTTS & TROWBRIDGE A Partnership Including Professional Corporations BY: J. PATRICK HICKEY, P.C.
AND !
DAVID R. LEWIS _uRSR._S i 2300 N Street, N.W.
Washington, D.C. 20037 n-(202) 663-8103 i l
and- l I
i THELEN, MARRIN, JOHNSON & BRIDGES :
BY: . KENNEDY P. RICHARDSON, ESO.
One Kaiser' Plaza Suite'1950 Oakland, California 94612 (415) 893-5195 j l
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l 3 i I
1 1
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-I EDEX i W ITNE S S:
RICHARD DALE PARKS Page Examination by Mr. Hickey 7
'EXHIB IT S:
RESPONDENT'S NO. DESCRIPTION MARKED 1 Letter Dated 11/3/80 7 2 Letter Dated 12/17/80 7 3 Internal Correspondence Dated 7 7/31/81 4 Internal Correspondence Dated 7 8/25/81 5 Internal Correspondence Dated 7 10/1/81 6 Internal Correspondence Dated 7 10/28/81 7 Copy of Notebook 7
(
L 8 Rick Parks: Startup/ Test Log 7 for 10/16/80 -
4/6/81 9 Notes from Notebook Dated 7 2/28/82 10 Notes from Notebook Dated 7 3/3/83 11 Handwritten Notes from 7 Notebook 4
RESPONDENT'S'NO. DESCRIPTION MARKED 12 Copy of Notebook 7 13 Job Ticket Form (Work Request) 64 Three Mile Island 14- Unit No. 2 Administration 76 Procedure 1021 Engineering Change Memorandum 15 Unit No. 2 Administration- 82 Procedure 1043 Work Authorization Procedure 16 Unit No. 2 Maintenance 87 Procedure 1407-1 Job Ticket Form (Work Request)
Preparation and Administration 17 Unit No. 2' Administrative 91 Procedure Manual, Access To and Work in the containment Building 18 Unit No. 2 Containment 100 Procedure, Access To and Work in the Containment Building 19 Inter-office Memorandum 114 Dated 2/8/83 20 Letter Dated 10/8/82 129 21 Polar Crane Functional 130 Description 22 Letter Dated 3/7/83 140 23 Letter Dated 10/8/82 154 24 Unit No. 2 Administrative 159 Procedure 1047 Startup and Test Manual 5
'E X'H I B IT S:
RESPONDENT'S NO. DESCRIPTION MARKED 25 Unit No. 2 Startup and. Test 159 Test Instruction Number 1 Test Procedure Documents Revision O 26 Unit Work Instruction. 166 27' Comment Resolution- 166 1
28 Inter-Office Memorandum 179 Dated'.2/28/83 29 Inter-Office Memorandum 180 ,
Dated 3/1/83 )
1 1
30 Unit Work' Instruction 182 ]
Revision 4 l
6
1 BY MR. HICKEY: Q. Is that agreeable to you, Mr.
~
-2. Parks?
3 A.- Yes.
4 MR. JOHNSON: I'll supply the address for the 5 Nuclear Regulatory Commission if you'd'like.
6 THE REPORTER: Yes.
7 MR. HICKEY: Why' don't we put it on the record.
8 MR. JOHNSON: Okay. Well, send it to George E.
9, Johnson, Office of General Counsel, U.S. Nuclear 10 Regulatory Commission,-Mail Stop 9604, Washington, D.C.
11 20555.
212 BY MR. HICKEY: Q. As I told.you informally,a 13- moment-ago, Mr. Farks, Mr. Lewis and I are here
- 14. representing GPU Nuclear Corporation.
t l 15 I assume you've been informed by Mr.
7 16- Johnson of the NRC staff that'we had asked to take your 17 deposition in connection with an enforcement proceeding 18 that-is pending before the Nuclear Regulatory 19 Commission, and that's what the nature of this 20 proceeding is.
21 He explained that to you, didn't he?
22 A. That's correct.
23 Q. Is Mr, Johnson representing you here 24 today --
25 A. No.
i 8 l l
1~ Q. -- or do you.have separate counsel?
2- A. No, the record should reflect that I'm here i l
3 voluntarily, without benefit of counsel.
4 Q. All right. I did receive --
and my copy _ of 5 the letter reflected a carbon copy being sent to you --
6 a letter from Barbara Zuras on Friday of last week j 7 relating to a document request that we had made to you !
8 in connection with this deposition.
9 Did you get a copy of Miss Zuras' letter?
10 She showed a copy to you.
11 A. Yes, I did.
12 Q. Miss Zuras previously was representing you 13 with regard to a civil action that you had pending
-14 against Bechtel Power Corporation; is that right?
15 A. They still represent me.
16 Q. Okay. That action has been settled, has it 17 not?
18 A. That action has been settled.
19 Q. Okay. Okay.- I want to show you initially 20 this morning some documents, I hope fairly quickly, to 21 just fill in a few details about some of your background 1
o 22 and then we'll try to move directly into the areas of 23 interest here.
24 I know you've testified before. Let me 125 just repeat that if you at any point are unclear about 9
l 1 my questions.or what am I'm asking or don't understand
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2 what I'm trying to learn, if you'l1 please indicate 3' that, I'll be happy to try to clarify the question for 4 you so ~that you can understand it and so that the record 5 will reflect what your best answer is to the questions 6- that I ask, all right?
7 A. Yes.
8 Q. Okay. I know, Mr. Parks, that you were 9 employed by the NUS Corporation and assigned to Three 10 Mile Island from approximately July 2nd, 1980 until a 11 later period.
12 And I have some documentation that I want i 13- to show you that I think reflects generally what.your 14 duties were. I thought that would be an efficient way 15 to do it rather than ask you a lot of questions. ]
16 Let me show you what the reporter has 17 already marked as Respondent's Exhibit Number 1 to your
( 18 deposition. I'll ask you to take a look at that and 19 tell me if you recognize it.
l 20' MR. HICKEY: For the. record, it's a November 3, 21 1980 memorandum to G. Meyers, M-e-y-e-r-s, of NUS 22 Corporation from R. Parks, signed on the second page by 23 Mr. Parks.
24 BY MR. HICEEY: Q. Is that your signature, Mr.
25 Parks?
r 10
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ _ ___ _ _ _ ._ _a
1 A. Sir,-I was of the impression -- or the 2 understanding anyway - that we had agreed, prior to the 3 start of this deposition, that we would cover no ground 4 that had already-been covered in my Bechtel civil
)
5 action. .
6 Q. I told Mr. Johnson, if that's what'you're i 7 referring to, that I was familiar with your testimony in 8 the Bechtel civil action and that I would make every 9 effort to avoid going over ground that was covered 10 there.
11 A. That is correct, or at least it was my 12 understanding, also, my duties at NUS at Three Mile 13 Island have already been discussed.
14 Q. What I would like you to tell me is whether 15 that document was something you prepared and whether it 16 relates to your duties.
17
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A. I signed that page -- the second page.
- j. 18 Q. Does it describe your duties at Three Mile 19 Island as they existed in the period described in the 1
20 memorandum?
21 A. From what I can recall at the moment, they 22 appear to be an accurate reflection of activities I was 23 involved in at Three Mile Island during the time in 24 question.
25 Q. And Mr. Meyers was your supervisor in the i 11 l
1- NUS Corporation?
l0 A. I cannot recall at the moment if he wasumy 3 supervisor or what his functionary role was.
l 4 Q. Let me ask you just one question here. '
.5- You've indicated in the memorandum, at the top of the 6' page:there, that your primary responsibility has been 1
7 the research and development of Functional Test -j l
.8 Procedures for the Submerged Demineralized System.
-9 Does that mean you were writing procedures-s 10 when you say it was research and development?
i
- 11. A. Yes, not limited to writing the procedures. .
I 12 Q. What else did you do with the procedures !
13 besides write them? ;
14 A. As it implies, research, development, )
l 15 implementation. ;
i 16 Q. Okay. I'll show you now what has been '
l 17 marked as Respondent's Exhibit 2 to your deposition, a l
18 four-page handwritten document dated December 17, 1980, j 19 addressed to Glen and signed on page 2 by Rick Parks. l 20 Would you take a look at that. j 21 A. Will I receive a copy of all'these?
22 Q. With your deposition, yes. And you're free t
23 to take the time now to read the whole document if you'd j i
24 like. i 25 MR. ' JOHNSON: Did you request the witness to read !
12 I
1 the entire document?
2 MR. HICKEY: No, I offered him the opportunity to )
3 if'he wanted to.
1 4 (Whereupon Mr. Richardson left the l l
5 deposition room.)
6 THE WITNESS: Now, could you repeat your 7 question, sir?
8 BY MR. HICKEY: Q. Let me direct you l l
1 9 specifically to -- well, is the signature on page 2 of 10 of the document yours?
11 (Whereupon Mr. Richardson reentered the 12 deposition room.)
13 THE WITNESS: It appears to be.
14 BY MR. HICKEY: Q. And is this a memorandum that i I
15 you wrote to Glen, and is that Mr. Meyers of the NUS 16 Corporation?
17 A. I would only have to assume it was and 18 assumptions aren't relevant.
1 19 Q. Okay. Was there someone else at NUS that 20 you sent memoranda about your work duties to named Glen 1
21 besides Mr. Meyers? i l
22 A. I do not recall at this moment who I sent 23 memos to during that time frame.
24 Q. Look at the third page of the document, l
35 would you, please. ;
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T i
L '1' A. (Witness comp 3d 8.)
2 Q. By/the way, this is'all in your-3 handwriting, isn't it?
4 A. It-appears to be.
5 Q. Look on page 3, where it-starts up at the ,
6L top, " Arrival on site July 2nd." Look down about four 7 , lines, I think the fourth entry there, the fifth entry,
-8 it says, " Test Program Administration Documents - Unit 2 9 Review - five work days." _
'10' I want to know what kind'of test program 11' administration documents you.were reviewing when you-12 were working at TMI-2 for NUS.
13 A. On this date or during the entire time I 14 was there?
15 Q. During this time when you were there for 16 NUS, beginning of July of 1980.
17 A. At this' moment I could not recall 18 .specifically which documents I was reviewing.
19 Q. Well, what kind of documents would they be, 20 .if you don't recall the specifics?
p 21- A. I cannot state categorically, but I believe 22- it would have been the test program manual.
231 Q. Would that include procedures that applied 24 to the Test Program-2?
25' A. I would only have to guess.
14 ,
1 Q. Well, didn't you review and prepare I
2 procedures as part of your duties? j
.3 A. Yes, I did.
4 Q. And were there procedures that applied to j I
5 the administration of the test program?
6 A. Yes, there were.
7 Q. And were you required to be familiar with ]
8 the procedures that applied.to the test program. H 9 administration?
10 A. Yes, I was.
11 Q. And this five work days that you spent 12 reviewing materials related to the test program, you 13 believe would have included procedures covering the test-14 . program, if you weren't familiar with them already? I 15 A. It may have been. That may not be what 16 that statement implies.
17 Q. What do you think it might imply other than I
18 that?
19 A. At this moment, I do not know.
j 20 Q. The last entry on that same page, Mr.
l l 21 Parks, the bottom line says, " Alternate member for Test l
22 Working Group (Alternato to UII Test Manager)."
23 Were you serving during this period as-the 24 alternate mem.Ser for the test working group?
l 25- A. Yes, I was.
15
1 Q. Was Mr. Herlihy a person that was the 2 UII test manager for whom you were the alternate?
3 A. Yes, he was.
l l 4 Q. And did you get appointed by Mr. Herlihy to 5 be his alternate because Mr. Herlihy was going to be 6 away or unavailable or on vacation?
7 A. It depends.
8 Q. In July of 1980?
9 A. If memory serves me correctly at the 10 moment, I was appointed the alternate test work chairman 11 by virtue of being the alternate startup and test 12 manager.
13 There was a point in time where Mike 14 Herlihy appointed me to be the acting startup and test 15 manager because he was either on vacation or an extended 16 training program.
17 Q. All right. I see.
18 But if I understood what you just said, you 19 had already been named --
or you were Mr. Herlihy's 20 alternate startup and test supervisor; is that correct?
21 A. That is correct.
22 Q. And was there some specific formal document 23 that also named you as the alternate test working group 24 supervisor?
25 A. I cannot recall if -- at this moment -- if l 16
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ J
1 Mike issued a separate memorandum. He may have.
2 However, it was established practice on the job site 3 that the alternate startup and test manager was also the l 4 alternate startup -- I mean, alternate test working 5 group chairman.
6 Q. What were your duties as the alternate to 7 Mr. Herlihy on the test working group?
8 A. As it implies, if he was unavailable for 9 any reason, I was to fill in his stead.
10 Q. Do you remember if you actually did 11 anything in his stead because he was unavailable?
12 A. Yes.
13 Q. In the summer of 1980?
14 A. Yes.
15 Q. Did you attend TWG meetings?
16 A. Yes, I believe I did.
17 Would you repeat the last question?
18 MR. HICKEY: I'll ask the reporter if she'd read 19 it back to you, please.
20 (Record read.)
21 BY MR. HICKEY: Q. And would that have been in 22 the summer of 1980, Mr. Parks, shortly after you came to 23 TMI from NUS?
24 A. At the moment, Mr. Hickey, I cannot recall 25 definitively whether I attended the meetings or not. I 17 l
l l
1- may have; I may not have.
2' Q.- Well, I'm just asking for your best 3 recollection.
4 What do you recall?
5 A. My best recollection, I don't recall at the' 6 moment whether I did . cur no t .
7 Q. Do you have a recollection of attending 8 many TWG meetings or only a few, Mr. Parks?
9 A. I have a recollection of many TWG meetings.
10 Q. Can you give me some approximation of~how 11 many you attended?
12 A. I cannot state with any accuracy the 13 quantity of. meetings that I attended, no.
14 MR. JOHNSON: You didn't preface it in a time 15 bracket. You're talking about the summer of 1980?
16 MR. HICKEY: No, I was really talking more 17 broadly; but if it helps you to break it up in periods, 18 I'll be glad to do it that way, too.
19 BY MR. HICKEY: Q. In 1980, do you recall about-20 how many TWG meetings you attended?
21 A. I can save you some time. I don't recall 22 during which year how many TWG meetings I attended at 23 any one given time.
24 Q. Do you think you went to five or 50 or --
25 A. I believe, sir, I've already stated I could 18 f
w__ _ _ _- . - - - - - - . - -_
i 1 not quantify the number of TWG meetings I attended 2 during my tenure at TMI.
3 Q. Mr. Parks, I'm asking you to give us your 4 best approximation of how many TWG meetings you went to.
5 Are you unwilling to do that?
6 A. It's not that I'm unwilling, sir; it's that 7 I'm incapable of providing an accurate reflection of TWG 8 meetings I attended. And if you assume something else, 1.
1 9 I'm sorry.
10 Q. Can you tell us whether it's closer to a 11 hundred or one?
12 MR. JOHNSON: He's said he's unable to quantify.
13 MR. HICKEY: I'm entitled to ask him whether he 14 can approximate. I think that's what I'm doing.
15 THE WITNESS: I do not choose to issue an 16 approximation, no.
17 BY MR. HICKEY: Q. Are you aware of any TWG 18 meetings -- you understand when I say, "TWG," I'm l l
19 referring to the test working group, don't you, Mr.
20 Parks? You remember that?
l 21 A. Yes, I do.
22 Q. Are you aware of any TWG meetings being 23 held prior to the issuance of the Startup and Test ,
24 Manual Procedure 1047 that created the test working 25 group? '
19 I
I 1 i u__--_--- 1
I 1 A. At the moment I do not have any 2 recollection one way or the other.
3 Q. I show you now what has been marked by the 4 reporter as Respondent's Exhibit 3. It's a three-page 5 typed memorandum to Mr. Presgrove from Mr. Parks, 6 "
Subject:
Activities accomplished on site 7/80 to 7 7/81." I ark you to take a look at that document, Mr.
8 Parks.
i 9 Is that document a document that you 10 prepared, Mr. Parks?
11 A. From my brief review, it appears to be a 12 document I prepared, yes.
13 Q. And was it prepared to inform Mr. Presgrove 14 of your duties and your accomplishments during your year 15 on THI-2 up through July of '817 16 A. I can only state that the purpose of that 17 document appears to be reflected in the document. At 18 this time I have no additional recall as to what the 19 purpose of that document was.
20 MR. HICKEY: Okay. I'd like the witness to have 21 an opportunity to see the document again, too, please.
22 BY MR. HICKEY: Q. Mr. Parks, look there at the 23 top half of the first page of the document where it has 24 the months of June and July 1981 indicated. And it 25 describes you fulfilling the function of TWG chairman.
20 l
i
e 1 Do you remember convening, in the months of ,
2 June or July 1981, TWG meetings in your role as chairman 3 of the TWG7 4 A. At the moment I have no recall whether we 5 did it or not.
6 C. Do you recall the TWG group reviewing and 7 accepting the Submerged Demineralized System Functional 8 Testing Procedures?
9 A. I recall the evolution occurring, yes.
10 Q. Did you participate in the TWG review of 11 those procedures?
12 A. From -- if my memory serves me correctly, I 13 believe I did, yes.
14 Q. Is this the time period that you referred 15 to earlier when Mr. Herlihy was on vacation or leave and 16 you served as the chairman in his stead?
17 A. I cat. re.all at this moment that 18 Mr. Herlihy was on vacation sometime during the summer i 19 of 1981, and that would have been the time frame when I 20 was the acting startup and test manager, yes.
'J 1 Now, whether that is this particular time 22 period, at this moment, I have no additional recall.
33 Q. Look on the second page of the document, 24 would you, please.
25 You, at the bottom, under item B, list a 21
1 number of departmental procedures or schedules that you 2 authored. One of them is the SU&T Training Program 3 Draft.
4 Do you remember what that document was, Mr.
5 Parks, that you wrote?
6 A. Not at this moment, I do not.
7 Q. SU&T stands for startup and test, does it 8 not?
9 A. I can only assume so, yes.
10 Q. Is there something else you think it might 11 stand for, Mr. Parks?
12 A. Not at the moment, no.
13 Q. You worked you in the startup and test 14 program at Three Mile Island for more than a year; is l
15 that correct?
16 A. That is correct.
17 Q. Was it commonly referred to by the initials 18 SU&T at the time that you were there?
19 A. At the time that I was there, yes.
20 Q. I ask you to look on page 3 of the 21 memorandum, which is Exhibit 3 in front of you.
22 Item 2 reflects that you participated in 23 MDHR, SDS and other Task Testing on an ongoing basis.
24 What is the MDHS?
25 A. If memory serves, Mini Decay Heat Removal 22
1 System.
2 Q. And what was the Mini Decay Heat Removal 3 System?
4 A. It was a system, if I remember correctly, 5 that was designed and installed shortly after the 6 accident to remove decay heat.
7 Q. Was there already a decay heat system
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8 installed at the Island?
9 A. If memory serves me correctly, there was.
10 Q. What was the purpose for installing a Mini 11 Decay Heat Removal System? ,
12 A. At the moment I cannot provide you any 13 reasons that system was installed.
14 Q. Did you participate in the installation of 15 that system?
16 A. No, sir, I participated in the testing of 17 it.
18 Q. Was that a significant part of your 19 activities? Do you recall spending a good deal of your 20 time on that task?
21 A. No, sir, I do not recall spending a good 22 deal of time on that test.
23 Q. How about the testing for the SDS, was that 24 a major part of your duties?
25 A. I believe it was, yes.
23 i
1 Q. And I believe we've, I think, already 3 identified that the SDS refers to the Submerged 3 Demineralized System; is that correct?
4 A. That is correct.
5 Q. Okay. I ask you to look, Mr. Parks, now at 6 a document marked Respondent's Exhibit 4. It's dated 7 August 25, 1981, from you to Mr. Presgrove.
8 Do you recall who Mr. Presgrove was, by the 9 way?
10 A. I believe Mr. Presgrove was another -- or a 11 fellow NUS Corporation employee.
12 Q. I have a number of these reports that I'm 13 going to show you here, all addressed to -- it appears 14 that they are monthly reports prepared by you for a 15 series of months in the fall of 1981, all addressed to 16 Mr. Presgrove. And the subject of all of them is 17 activities performed during the past month.
18 Did you give monthly written reports to Mr.
19 Presgrove, and is Exhibit 4 an example of those reports?
20 MR. JOHNSON: Do you understand the question?
s 1
21 THE WITNESS: I understand the question.
22 At the moment I have no recall that 23 provides any insight regarding whether or not I 24 intentionally provided a monthly update of my activities 25 to Mr. Presgrove or not.
24
l 1 I can only assume from your statement that 2 you're stating that I did.
3 BY MR. HICKEY: Q. Well, I'm showing you the 4 documents to see if that refreshes your recollection.
5 I'll also put in front of you Respondent's
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6 Exhibit 5, which is the same kind of document, dated 7 October 1 1981, and Respondent's Exhibit 6, which is 8 the same kind of document, dated October 28, 1981.
9 Why don't you look at 4, 5 and 6 together 10 and maybe you'll have a better recall.
11 A. Now, what was the question?
12 Q. Yes, I'm asking you if, having looked at 13 Respondent's 4, 5 and 6, you now recall that in the fall 14 of 1981, you were submitting monthly reports of your 15 activities to Mr. Presgrove and whether those are 16 examples of those reports.
17 A. My review of those documents does not 18 improve my memory at this moment, no.
19 Q. And is it your testimony that you have no 20 recollection of submitting any reports to Mr. Presgrove?
21 A. I did not say that.
22 Q. Well, what is your recollection?
23 A. My recollection is based on what I just 24 read, and those appear to be monthly reports.
25 Q. Well, my question to you is whether you L-25
1 have any recollection of submitting monthly reports to 2 Mr. Presgrove. And when I said is your testimony that 3 you don't have any such recollection, you said no.
4 So what is your recollection?
5 A. My recollection is that I -- I do not have 6 any recollection of having to submit monthly reports to 7 Brock Presgrove.
8 Q. What was his name?
9 A. Brock Presgrove.
10 Q. Brock, B-r-o-c-k?
11 A. Right.
12 Q. Well, as you've looked at Exhibit 4 and 13 Exhibit 5 and Exhibit 6, that's what those are, isn't 14 it?
15 A. That's correct.
16 Q. It is your signature on the bottom of those 17 documents, isn't it?
18 A. Yes, it is.
19 Q. And as you look at the activities that are 20 described in the document, those were the kinds of 21 activities that you were performing in those months at 22 TMI, weren't they, Mr. Parks?
23 A. I believe them to be, yes.
24 Q. Let me just make sure I understand your 25 testimony. Are you saying that you don't recall 26
7 1 physically sending such a report as Exhibit 4 to 2 Mr. Brock Presgrove?
3 A. If I remember your initial question .
4 correctly, it dealt with me having to submit monthly s
5 statements or monthly reports to Brock Presgrove.
I thought I asked -- what I meant was just '~#
6 Q.
7 whether you did submit monthly reports to Mr. Presgrove.
8 9 A. The evidence speaks for itself. There was 10 a period of time there that I did submit monthly 11 reports.
12 Q. Is your testimony that you don't recall 13 being required to, it was some kind of volunteer effort:
14 is that what yod're saying?
15 A. That is correct.
16 Q. Let me just suggest to you, in the interest 17 of your time as well as all of ours, if there's 18 something in my question that you find you can't agree 19 with, but a slight change in it, you could agree with, 20 you might save us all some time if you indicate that.
21 And if you would tell me, for example, that 22 you don't believe you were required to submit reports to 23 Mr. Presgrove; but you do recall that you did submit l
l 24 them.
25 A. Mr. Hickey, I'm not trying to compound your 27
1 job or complicate matters; but I will answer any 2 question you put to me.
3 And I understood you questioned whether or 4 not I was required to submit them. Possibly I was 5 misunderstanding your line of questioning.
6 Q. It's possible you were. I don't claim the 7 contrary. I'm just suggesting to you something that I 8 think is probably pretty obvious anyhow.
9 MR. JOHNSON: Also, I just want to indicate that 10 it seems as though you're asking the -- well, put it 11 this way: The witness is clearly trying to answer the 12 questions that you're asking. I think that's a proper 13 way to proceed, and we'll leave it at that.
14 MR. HICKEY: Well, I'm not sure I agree with your 15 characterization; but I hope the witness is.
16 BY MR. HICKEY: Q. Let me ask you a couple 17 specifics about these documents, Mr. Parks.
18 If you'll look at the memorandum which is 19 dated October 1, that's Exhibit 5, in front of you.
20 Down at Item 2, on the first page, you'll see it deals l 21 with " Procedures in Process," and lists "MTX, Revision l 22 2."
l 23 Do you believe it refers to the Master Text 24 Index as MTX?
.25 A. I believe that's what they were referring l
28
1 to, yes.
2 Q. Did you write or revise a procedure for the 3 MTX index? s 4 A. I might have. I don't recall at the moment 5 if I did or not.
6 Q. And that the last item on page 2 of that 7 Exhibit 5, Mr. Parks, is a handwritten note, Number 10, 8 " Acting SU&T manager until M. Herlihy completes license 9 training."
10 Is that another occasion when you served as 11 Mr. Herlihy's replacement as startup and test manager 12 because he was unavailable for those duties?
13 MR. JOHNSON: I'd ask you to clarify the 14 question. What occasion are you referring to?
15 BY MR. HICKEY: Q. During your month of 16 September 1 to September 30, 1981, which is the period 17 covered by Exhibit 5, did you serve as acting startup 18 and test manager for Mr. Herlihy?
19 A. I believe I did, yes.
20 Q. About how long was Mr. Herlihy engaged in 21 licence training -- or put it another way: About how 22 long on this occasion did you serve as his acting 23 startup and test manager? -
24 A. At the moment I have no precise recall 25 regarding how long I served in that position.
29 4
]
1 Q. Do you have any general recollection, i 2 Mr. Parks?
3 A. I think I served in that position up until 4 the time I left Three Mile Island.
5 Q. Let me focus you a little more !
I 6 specifically. This appears to relate to an occasion 7 when Mr. Herlihy was engaged in taking license training, 8 and I was asking you if you recall about how long that 9 condition went on when you were substituting for 10 Mr. Herlihy because he was taking license training.
11 A. That's what my answer was.
12 Q. Until you left the Island, in other words?
13 A. Right, I believe that to be about the time 14 frame.
15 Q. Was there a formal designation of you as l
16 Mr. Herlihy's acting startup and test manager while he 17 was engaged in this license training?
18 A. If memory serves me correctly, there was.
19 Q. Was there a formal designation of you as 20 Mr. Herlihy's replacement as TWG chairman during this 21 same period?
22 A. I do not recall at the moment if there was 23 a formal designation for that or not; however, 34 established past practices on the job site would have 25 automatically placed me into that position by virtue of 30
1 holding startup and test manager position and by virtue 2 of the test manual.
3 It may have been unnecessary, since I was j 4 already'the alternate test work group chairman anyway.
5 And in the absence of Mike Herlihy, I would have served
-6 as my own replacement.
7 Q. I didn't follow that last thing.
8 You said in the absence of Mike Herlihy, 9 you would have served as your own replacement?
10 A. That's right.
11 Q. What do you mean?
12 A. I was already the acting startup and test 13 manager; but prior to me being appointed to that role, I 14 was the alternate test work group chairman and alternate 15 startup and test manager.
16 So if Mike was unavailable, it would I 1
l 17 have -- may have been unnecessary to appoint me as the !
18 test work group chairman anyway because I was already 19 the alternate test work group chairman and serving as a 30 dual role.
21 Q. You referred in your answer a moment ago to i 22 the established practice at the Island.
23 What is the practice you're referring to?
24 A. From what I can recall at the moment, i
25 whether it was in the procedure or not -- that's where !
31
)
1 the vagueness comes in to play -- the alternate startup 2 and test manager or an assistant startup and test '
3 manager, whatever classification you wish to give him, 4 held that position of alternate test work group chairman 5 by virtue of that position.
6 That is what I am referring to that's past 7 practice.
8 Q. Okay. And you have some vagueness in your 9 recollection about whether that was spelled out in a 10 procedure or was something that was unwritten, but 11 believed by you to be the case; is that what you just 13 expressed?
13 A. That's not quite what I was trying to 14 state. I'm saying that I cannot recall at the moment 15 what the details were of the procedure that delegated 16 authority and with certain functionary roles, but what I 17 am trying to distinctly point out is that it was i
18 established practice that the person that held those 19 roles held those collateral duties.
20 Q. All right. What I understand you to mean, 21 when you talk about established practices, that it had !
22 been going on before, that that was what your i
23 understanding was of what had been happening before; is j 24 that what you mean? ;
I 25 A. I believe that to be true, yes. I 32 i
1 Q. Are thera other individuals or examples you 2 were aware of where that had happened as being an 3 established practice?
4 A. If memory serves me correctly, it was an 5 established practice during the construction of Unit 2 6 and under the original test procedure or test manual 7 which Mike'Herlihy and I used to whatever extent 8 possible when the recovery test manual was developed.
9 Q. Okay. You weren't present yourself during 10 the construction of Unit 2, were you?
11 A. No, sir, I was not.
12 Q. So I understand you to be saying that you 13 somehow understood that during the construction of Unit 14 2, the practice was that the alternate startup and test 15 supervisor served as the alternate TWG chairman, is that 16 your testimony?
17 A. That is my recollection at the moment, yes.
18 Q. Did you learn that from Mr. Herlihy or from 19 someone else?
20 A. If memory serves me correctly, I learnad 21 that by reviewing Unit 2's original test plan and Unit 22 l's original test plan.
23 Q. That would be the procedures that applied 24 to setting up the test working group in the days when j l
l 25 Unit 2 and Unit 1 were being built; is that what you're '
1 33 k
l
1 saying?
3 A. Yes, sir, and theC practice was -- became 3 more of an institution, I s ' of 'd say, under Mike 4 Herlihy. ,
5 Q. What do you mean by that?
6 A. Well, when the recovery test manual was 7 approved, I was appointed as the alternate test work 8 group chairman by Mike Herlihy. So from that point on, 9 that was the established practice.
10 Q. And I think -- but correct me if I'm 11 wrong -- that you testified earlier you don't remember 12 whether Mr. Herlihy appointed you as the alternate test 13 working group chairman in writing or not.
14 A. That may be a fair characterization in my 15 previous testimony. I believe my previous testimony 16 regarded whether or not he documented it, and that is 17 the only thing I cannot recall, whether it was 18 documented or whether it was verbal or whether it was 19 just generally put out to the test work group.
l 20 I believe it may have been documented, but l
21 I'm unsure of that fact. The more I think of it, the 22 more I'm confident that he did document it.
23 Q. Let me ask you to look briefly at Exhibit 6 24 in front of you, which is the memorandum dated October 25 28, 1981.
34
f i
1 I'want to direct your attention to Item 2 2 on the first page, " Procedures in Process: AP-1043 3 (Work,".I assume, " Authorization Procedure)." It's 4 abbreviated.
5 Did you work on some revision of procedure 61 AP-1043 in about October 1981? (
7 A. 1[f memory serves me correctly, I believe I-8 did. t i
9 Q. What was the nature of your work on that 10 procedure? )
11' A. At the moment I do not recall the 12 particulars of the revision, only that I revised'it.
13 Q. The item above that refers to procedures 14 written and issued for approval, Item 1, and lists 15 ini'tially the master test index, which we referred to 16 earlier, did you complete the preparation of a' revision 17 of'the master test index procedure in about' October of 18 1981?
19 A. If memory serves me correctly at the 20 moment, I believe I did.
21 Q. Can you describe generally for me what the 22 master test index was? j 23 A. At the moment, sir, I cannot.
24 Q. Do you have any recollection of what the 35 ' master test index related to, Mr. Parks?
35 i
r 1 A. I have a vague recollection, yes.
2 Q. What is your best recollection of what it 3 was?
4 A. Once again, if memory serves me correctly, 5 I believe it was an index that identified the testing to 1
l 6 be performed on various components, systems and/or 7 modifications and how they would be performed, what 8 documentation would -- would be provided to document 9 that type of thing.
10 Q. Did you -- as we've looked at all these 11 various subject matters in the memoranda, am I correct 12 that your duties involved in large extent the writing or 13 revision of procedures; is that accurate?
14 A. That's partially accurate, yes.
15 Q. Is there some part of it that's wrong, or 16 can you make it more accurate?
1 17 A. Well, it's only inaccurate by omission.
)
i 18 Q. What were the other major functions in your l l
19 duties at this time period?
20 A. Performing the test, documenting the test, 21 getting the test results approved, those type of things, 23 and various assorted and sundry other duties that were 23 collateral assignment --
24 (Whereupon Mr. Berry left the deposition 25 room.)
36
1 THE WITNESS: -- by virtue of the assignment I 2 was in.
3 (Whereupon Mr. Berry reentered the 4 deposition room.)
5 BY MR. HICKEY: Q. Let me pause for just one 6 moment, Mr. Parks, and get a couple other background 7 facts about you, if you don't mind.
8 How old are you?
9 A. I am 36 years old.
10 Q. And I don't need to go through the details 11 of your background because I've get it on resumes.
12 By whom are you presently employed?
/
13 A. Sir, I do not believe that to be relevant 14 to this proceeding.
15 Q. Well, I think it is, Mr. Parks. To know 16 who you work for, it might have some impact on the 17 testimony.
i 18 Will you answer the question, please?
19 A. Sir, I kindly refuse to answer that 20 question. .
21 Q. Well, is it a secret by whom you're 22 employed by, Mr. Parks?
23 A. As far as I'm concerned, it is.
24 Q. Does Mr. Johnson know by whom you're 25 employed?
37
1 1 A. No, he-does not. Put it thic way: To my 2' knowledge, he-does not. l 3 MR. BERRY: I can state Mr. Berry does not know.
1 4 THE WITNESS: And I wish to clarify for the 5 record, I'm not-trying to be obstinate. I just do not.
1 6 wish to provide that information to GPU or Bechtel.
7 BY MR. HICKEY: Q. And why is that?
8 A. Because I do not trust GPU or Bechtel.
9 Q. Are you currently working in the nuclear 10- industry, Mr. Parks,.or related?
11 A. No, sir, I'm not.
12 Q. Okay. I'll leave it there for now.
13 Your tenure at Three Mile Island ended or 14 was interrupted by assignment to go work at the'Shoreham 15 facility?
16 A. Yes, sir, it was.
17 Q. And that was in approximately the first 18 part of 1982; is that about right?
19 A. I believe that to be an approximate time 30 frame, yes.
21 Q. And you left Shoreham and returned to THI 23 in about May of 1982, didn't you?
23 A. I believe that to be correct, yes.
24 Q. And do you recall that you were approached, 25 while you were at Shoreham, by representatives of the 38
l 1 Bechtel Corporation?
I 2 A. Sir, I believe I've already covered this in !
3 great detail with Mr. Richardson during my civil l
I 4 proceedings.
5 Q. Well, it was really just preliminary; but j i
6 we can go on.
7 The return to TMI-2 by you in about May of 8 1982 was to do work emphasizing duties in the area of 9 writing and reviewing procedures, was it not?
10 A. I do not remember at this moment, sir, if i 11 there was any particular emphasis assigned to me when I 12 assumed the job. l 13 (Discussion between Mr. Hickey and 14 Mr. Lewis.) ,
-15 BY MR. HICKEY: Q. Mr. Parks, I'm not going to 16 mark this just to avoid making the record any bigger 17 than it already is; but I'll put in front of you -- and I
18 it will be available here throughout your deposition any l 19 time you want to refer to it --
1 l
20 A. Could I ask you for a favor and to make 31 that as an exhibit because I don't have a copy to my 22 original affidavit and I'd like to have one? 1 l
23 Q. I'll give you one copy here. I'd like not l I
24 to put it in the record, but you can keep this one.
25 A. Thank you, I'd appreciate that.
39
1 MR. HICKEY: This is a 56-page affidavit typed 2 and signed by Mr. Parks on the last page indicating it 3 was sworn to on March 21st, 1983, before a notary public 4 in the District of Columbia.
5 BY MR. HICKEY: Q. Take a look at it, Mr. Parks, 1 6 if you would, so you can confirm that is your affidavit.
i l
7 A. It is.
8 Q. I should note that this copy does not have 1
9 an attached exhibit which I believe was on your original 10 one and I'll see that you get that, too. There was a 11 letter attached to your affidavit. l 13 Don't you recall that, Mr. Parks?
13 A. Yes, sir, I do.
14 Q. This copy doesn't seem to have it, but I'll 15 get you a copy that does.
16 MR. JOHNSON: I have a copy that has it if it 17 comes up.
18 BY MR. HICKEY: Q. Look briefly, if you will, 19 Mr. Parks, at page 3 of your affidavit --
20 MR. RICHARDSON: Do you want me to have the 21 letter copied now?
22 MR. JOHNSON: I'm sorry?
23 MR. RICHARDSON: Do you want me to have the 24 letter copied now?
25 MR. HICKEY: We can do it at the break.
40
.j
'l BY MR. HICKEY:. Q. Inithe middle paragraph on l 2 page 3, if you'll just read that paragraph to yourself,
.3 the one that starts, quote, "The first time I was at j i,
d' TMI-Unit II," down to the end of the paragraph.
5 A. I have read it.
6 Q. Okay. Does that. refresh your recollection 7 about-the circumstances of your coming back to the 1 8 Island involving a request for you to assist in l'
9 developing procedures related specifically to the j 10 Quick-Look Program? .
11 A. Well, Mr. Hickey, it's -- I think -- I 12 don't want to get into a play on words like what we 13 apparently inadvertently fell into previously in this 14 deposition.
15 I misunderstood your'line of questioning 16 before. I assumed -- well, not' assumed -- I can' answer
- 17. your question that ~ when I was first at TMI on the second
'18 time around when I was hired by Bechtel, my initial job l
19 assignment was the development of procedures for 20 Quick-Look.
21 Q. Fine, thank you.
22 A. I misunderstood what your line of 23 questioning was before.
-24 Q. Fine, I appreciate your clarifying.
25 I'll just leave that copy of the affidavit 41
c: .
I' 1 with you there, Mr. Parks, so if you feel it desirable, 2 during the course of the deposition, to refer to it or 3 if you want to look up something, just say the word. l 4 Okay. I need your assistance, Mr. Parks, j 5 just to identify for the record, please, a series of 1
i f 6 documents just so we have them marked in this i 7 proceeding.
i 8 First, I'm showing you a document that's I 9 Respondent's Exhibit 7. I don't have questions for you 10 about it in detail.
11 Will you just look at it, and then I'm 12 going to ask you in general if you remember what it is.
13 And if there are specific things, I can point you to 14 them.
15 MR. JOHNSON: Are you going to put this in the 16 record; is that my understanding?
17 MR. HICKEY: Yes.
18 BY MR. HICKEY: Q. Okay. Let me see if I can 19 characterize it.
20 Is this your -- your 1980 to '81 log, Mr.
21 Parks, or how would you describe it?
22 A. I think that might be a fairly accurate 23 representation of that. It was -- I -- during that time 24 frame, I did maintain a notebook that I jotted things 25 down in occasionally. That is not to say it was a 42
1 . detailed diary.
2 Q. I understand that.
- 3. I assume the purpose of it was, in
-4 connection with your work, just to note particular
- 5. things you needed to recall or wanted to recall?
6 -A. I would only be speculating at this point, 7 but it appears to have a lot of entries relating to work l
8 in it. It appears to have some personal enteries in it.
9 Q. I do want to ask you just about two or 10 three particular entries in it. Let me direct you to 11 the-date of December 11, 1980, if you can find that
.12 page.
-13 A. Okay.
14 Q. Halfway down the page or so, there's.an 15 item that reads, quote, " Generated memo for LPK telling 16- Kunder to review SDS procedures."
'17 When you were working at the Island in the 18 1980 '81 time frame, Mr. Lawrence Peter King was someone l
19 with whom you came in contact in your duties, was he 20 not?
31 A. Yes, sir, he was.
.l 22 Q. And do you think that the LPK refers to l 23 Mr. King in this entry in your diary?
l 24 A. I'm sure it does, sir.
l 25 Q. Do you recall writing some memorandum for 43
(
_ _ _ _ _ - _ - - - - )
1 Mr. King to Mr. Kunder telling him to review the SDS 2 procedures?
3 A. Yes, sir, I do.
4 Q. What was the circumstances of the 5 memorandum, Mr. Parks?
l 6 A. If memory serves me correctly, Larry King 7 at that time frame was like, for lack of a better !
8 definition, the project manager for the SDS system.
9 Somewhere along that time frame, he also became manager l
10 of front operations.
11 And we were in the process of trying to get l
12 all the procedures approved relevant to the testing of 1
13 the SDS system, and we had a few organizations -- or l
14 departments, I should say, within the organization that 15 were not responding in a fast enough fashion, I guess 16 you could say.
17 We had established review deadlines for 18 people to review the procedures. And as a result of 19 that, when those procedures weren't met, Larry King 20 reviewed -- usually would send out a memo telling these 21 departments to please hurry up and review it.
22 Q. And what department was Mr. Kunder 23 connected with?
24 A. PORC, P-O-R-C.
25 Q. That's the Plant Operation Review 44
1' Committee,'is it not?
2 A. Yes,,it is.
'3- Q. And you~ recall spec'ifically that.there was 4 'some difficulty with the PORC responding fast enough for' 1
- 5 Mr. King's satisfaction on getting these procedures out?
I h 6 A. Well, if the circumstances are correct that I 7: I can recall, we usually established it between two.
'8 weeks'and four weeks'for'every department to review and 9 comment on the procedures, which we felt was ample time 10 'for everyone.
11 And it-was not restricted to PORC. There 12 were other instances where other departments were slow 13- to respond.
14 Evory other department had completed their 15- review in a timely fashion and we'd resolve the comments 16 and we were still' waiting for input from someone.else.
17 and we could not proceed until we had that input, so it 18 was like a kindly reminder that we need this.
19 Q. Okay. Look just quickly at the next page, j 20 too, would you please -- I'm sorry, it's 12/18/80. It's 21 five pages.
22 Way down at the bottom, the next to the !
23 last entry, says, quote, " Reviewed TI-1 and AP-3001 for 24 procedures (as written by us) compliance. Score 1 for 25 the lions," closed quote.
45 4
)
i 1 Do you know what TI-1 is?
2 A. No, sir, I do not. .I do recall vaguely 3 that it was an instruction contained within AP-1047, the 1
4 test manual.
1
- 5. Q. Does it help if I suggest to you that'TI-1 6 sets out the format for tests.and discusses the review 7' process for' tests? Does that sound consonant with your y i
8- recollection, to the extent you have one? l l
9 A. I don't have any additional recollection t
10 other than.I know by the fact that the TI meant test 11' instruction.
12 Q. You don't happen to recall the incident 13 that's reflected in this note with the phrase, " Score 1 14 for the lions," do you?
i 15 A. No, sir, I do not; but I can tell you that i 16 " Score 1 for the lions" has absolutely nothing to do 17 with the preceding statement. !
18 Q. How do you know that?
19 A. Because I know what " Score 1 for the lions" 20 stands for.
21 Q. What does it stand for?
22 A. That, sir, is personal.
23 Q. Are you saying it doesn't relate to work?
24 A. That's correct.
25 Q. Look on January 26th. Do you see there's 46
i 1 an entry, about the third one down, " Review AP-1043"?
2 That stands for administrative procedure 3 1043, doesn't'it, Mr Parks?
4 A. I believe it does, yes.
1 5 Q. Was that a procedure that you used in your l 1
6 work on a regular basis?
7 A. If me. y serves me correctly, I relied 8 upon it frequently.
9 Q. Did you have some training in AP-1043, or 10 did you instruct yourself in learning what the 11' procedural requirements were?
12 A. At the moment I really don't recall how I 13 became familiar with AP-1043.
-14 Q. But as part of your duties, you did have to 15 be familiar with it?
16 A. Yes, sir, if memory serves me correctly, I 17 did.
18 Q. Okay. Let me show you now Respondent's 19 Exhibit 8. That's that document.
20 Do you recognize that document, Mr. Parks?
21 What is it, Exhibit 87 23 A. It appears to be -- if the cover sheet on 23 it's correct, it says, "Startup and Test Log for 24 10/16/80 to 4/6/81."
25 Q. Did you write that cover sheet?
47 h
1 A. No, sir, I did not write that cover sheet.
2 Q. Forget about the cover sheet for a minute.
3 Can you tell what the rest of the do cun.e n t is?
4 A. It appears to be entries relevant to the 5 test program and test performance, that type of thing.
6 Q. All right. The first page is dated October 7 16, 1980, and it goes up to about mid-March or so or e early April of 1981 is the last page.
]
9 Was there a -- a log that was kept in the 10 startup and test department at THI during that time ;
l 11 period of -- of tests and other activities? j 12 A. I believe there was, yes. I'm not for l
13 sure. j 14 Q. Did Mr. Herlihy keep such a log?
15 A. If memory serves me correctly, both 16 Mr. Herlihy and I kept one.
17 Q. Do you know if this document, Exhibit A, 18 looks to you like Mr. Herlihy's log?
19 A. I would only have to guess. It looks to me i
20 like we have both our handwritings on there. l 21 Q. Okay. And was that practice of keeping a 22 startup and test log continued when you returned to the 23 Island in 1982?
24 A. At the moment, I can't recall if it was or 25 not.
48
l 1 Q. Okay. l
)
2 A. Are you asking me should it have been, or
, 3 are you --
1 4 Q. No, I'm just asking whether it was.
1 5 A. I don't know.
l 6 Q. This cover page -- just so you're not ]
l 7 concerned about the significance of it, the cover page 8 of Exhibit 8 was attached to the document as it was 9 produced to us by the Nuclear Regulatory Commission in a 10 pile of documents that were represented as being 639 11 pages of documents that were presented to Mr. Meeks of 12 the Office of Investigations by Mr. DeVine of the 13 Government Accountability Project, consisting of 14 Mr. Parks' documents and notes.
15 So that's where it came from, and I don't 16 know who put that cover sheet on Exhibit 8; but I didn't 17 think it was your handwriting.
18 A. It's not my handwriting.
19 Q. Do you recall the incident, just generally, 20 where you gave to your lawyer Mr. Devine a number of 21 documents or a pile of documents to be provided by him 22 to the NRC Office of Investigations, I think, in July of 23- 1983?
24 A. Wouldn't th'at be privileged information, 25 anything I had provided to my lawyers or any discussions i
49
I 1 I had with my lawyers? Isn't that protected by the ;
2 attorney / client privilege?
3 Q '. - Well, I really am not in a position to give 4 you legal advice; but I can tell you that'Mr. Devine got 5 a receipt from Mr. Meeks for -- for a pile of documents 6 that were presented to us.
7- Mr. Meeks testified that the documents were L
l 8 'given to him by Mr. Devine and represented that they 1
9 were documents from Mr. Parks. j 10 You may not know; but I'm asking you 11 whether you gave to the NRC, through Mr. Devine or la anybody else, a pile of documents of about 639 pages in 13 July of '83.
1 14 A. Sir, I can recall providing a lot of 15 documents to the NRC and other people, yes.
16 Q. Okay. Do you remember specifically having 17 a copy of the startup and test log from -- from Unit 2 18 in your possession?
19 A. At the moment I cannot definitively say 20 that I had that in my possession; apparently, I did.
21 Q. All' right. Let me go to the next one here.
22 I'm going to show you now what's been 23 marked as Respondent's Exhibit 9, and I think you need 24 to look at it with Exhibit 10, also, two separate 25 exhibits.
50
~ ~ - ~ ~ _ _ - _ - - - - _ - - - - _ - . ._ ___--.
1 MR. JOHNSON: May I ask, are these documents that 2 were appended to the Notice of Deposition?
3 MR. LEWIS: Yes.
4 HR. HICKEY: Yes.
5 MR. JOHNSON: Okay.
6 BY HR. HICKEY: Q. I'm showing you, Mr. Parks, a 7 copy of the Notice of Deposition dated June 1, which set 8 up your deposition for today. And you'll see that 9 attached to it are four pages of documents that are 10 copies of the two exhibits that I just put in front of 11 you.
12 Have you seen this Notice of Deposition 13 before just now?
14 A. Yes, I have.
15 Q. Okay. So then I assume that you've seen 16 the documents that are Exhibits 9 and 10 that are in 17 front of you?
18 A. I can state that I saw only the copies that 19 were appended to my Notice of Deposition.
20 Q. Okay. Prior to seeing them attached to 1
l 21 your Notice of Deposition, had you ever seen those l 23 documents before?
23 A. At some time in the past, I believe I have.
24 -Q. Is it your handwriting, Mr. Parks?
j 25 A. Parts of it is -- parts of it are, I should i
51 l
1 say.
l 2 Q. What book or journal or log were these l
3 pages taken from?
L 4 A. At the moment, I do not recall.
5 Q. Did you keep a log in the 1983 time period 6 -at TMI?
7 A. I believe I may have. My memory does not 8 serve to provide any better knowledge, not at the moment 9 anyway.
10 Q. Well, you can see, from looking at the .
11 exhibit, that it appears to be a small spiral pad with 12 handwritten notes in it.
13 Do you have such a book today?
14 A. No, sir, I do not have such a book today.
15 Q. Did you -- do you know whether documents 16 that you provided to your counsel Mt, Zuras are still in 17 the possession of Miss Zuras?
18 A. Sir, I would say that you should ask 19 Miss Zuras.
20 Q. Well, we did ask her; but we thought you 21 could clear it up.
22 A. Again, sir, contact Miss Zuras. She's in 23 your office.
24 Q. But your testimony is that you don't have 25 any documents in your personal possession?
52
__ _ - - - _ _ _ _ _ _ _ _____________________________i
'l- A. My. testimony is I don't have any documents 2 : relative-to this proceeding in my personal possession.
, , 1 3 Q. And that would include Exhibits 9 and 10 or 4 -the books which they came?-
5 A. If I ever had possession of the documents W
6 .in question.
7 Q. Okay. Now, look1at -- look,at Exhibit 9
'8 for just a minute.
.9 Can you identify for me whether any portion.
l 10 of: that page is not in:your-handwriting? <
11 A. I am uncertain at the moment, but'I do not 12 believe the top half of the page is in my handwriting.
13 Q. That's the material before the line under 14 "This could be a problem"?
15 A. Yes, sir, I believe it to be.
16 Q. Whose handwriting do you think.that is?
17 A. At the moment, sir, I cannot state with any 18 certainty.
19 Q. But the bottom half of the page, you 20 believe is yours?
21 A. It appears to be, yes.
22- Q. How about the next page of that exhibit?
23 A. It appears to be.
24 Q. And look, then, at Exhibit 10, would yott ,
25 please.
53
=-- _ _ - _ _ _ _ _
1 A. It appears to be my handwriting.
2 Q. On all the pages of that exhibit?
3 A. Yes, sir.
4 Q. Mr. Parks, looking at Exhibit 9, given just 5 briefly what you have there in front of you, the top 6 half of that page, do you have any idea whose 7 handwriting that may be if it's not yours?
8 A. I believe I previously testified that I do 9 not recall with any certainty whose handwriting it is.
10 Q. Well, what is your -- do you have any 11 . recollection at all of whose it would be?
12 A. Sir, I would not care to guess.
13 Q. I'm not asking you to guess. I'm just 14 asking you if you have any reasonable opinion about 15 whose handwriting it is.
16 A. Not at the moment, I do not. If I recall 17 at a later time, I'll be more than happy to inform you.
-18 (Discussion between Mr. Hickey and Mr.
19 Lewis.)
20 BY MR. HICKEY: Q. Okay. Let me ask you, 21 Mr. Parks, to look at what's been marked Respondent's l
23 Exhibit 11.
23 (Discussion between Mr. Hickey and Mr.
24 Lewis.)
25 BY MR. HICKEY: Q. Let's see, just to maybe ease 54
.l
)
_ ___ _ _ _ _ - - I
l 1
1 this a little bit, Mr. Parks, I think you can confirm 2 with me that the first five pages seem to be a bunch of ;
3 separate sheets; but then the rest of the exhibit 4 appears to be the pages of a desk calendar or some kind 1
1 5 of daily memo log; is that right?
6 A. That is correct. J 7 Q. And on the very bottom page of the exhibit, 8 there's a note that says, " Entries in this book started 9 as means to help keeping days events in order so as to 10 not confuse facts. Started on Friday, 3/18/83." And 11 then there's a signature.
12 Did you write that, Mr. Parks?
13 A. Yes, I did.
14 Q. Is that why you began keeping this book?
15 A. The reason why I began keeping that book, 16 it's fairly accurate representation. Prior to that, I 17 had a large group of loose-leaf documents, that type of i
18 thing, I believe, and I started putting everything down l
19 in here.
l 20 Q. Okay. Now, as you look through the l i
21 calendar, starting at the back, as it runs from the back 22 to the front chronologically, it seems to me that the 23 first entry appears on the date of February 14.
24 Did you attempt, after you started this I l
25 book on Friday, March 18th, to go back and -- and recall j l
55
1 events that had happened prior to March 187 2 A. 'Yes.
3 Q. And did you have notes that you used to do 4 that?
5 A. I believe at this moment that I did, yes.
6 Q. Okay. So you just would go back from your 7 notes and enter in, on days before March 18, things that 8 had happened to you then?
9 A. I believe that's an accurate 10 characterization, reasonably accurate anyway.
11 Q. Starting on March 18, then, did you try to 12 keep this book contemporaneous 1y with the books?
13 A. As much as my self-discipline allowed at 14 the time.
15 Q. Throughout the book, at a number of 16 places -- you can look at March 31, for example -- there 17 are some entries that have been blacked out or lined 18 out.
19 Was that privileged information that --
l 20 that you blacked out?
21 A. Sir, I did not black it out.
I 22 Q. Okay. Do you know who did black it out?
23 A. My lawyers, I would only assume.
24 Q. Okay. Let me ask you now about the top 25 five pages because that seems to be something different 56 l
4
1 in this exhibit.
2 What is the first page of this exhibit?
3 A. Are you asking me a question, sir?
i I 4 Q. Yes. What is it?
5 A. I have no idea.
6 Q. Is that your handwriting?
7 A. It appears to be, yes.
8 Q. This document that I'm pointing to here 9 (indicating), you see it's got a reference to 10 " Wrongfully Discharged Law Public Policy Issue," and 11 then a phone number and address in Lancaster, 13 Pennsylvania.
13 Do you recall what that relates to?
14 A. I -- at this moment, I believe it to be the 15 phone number and address of a group of lawyers.
16 Q. In Lancaster?
17 A. I would believe so, yes.
18 Q. Do you know the name of it -- is it a law 19 firm?
20 A. No, sir, I really don't.
21 Q. You don't know the name?
22 A. No.
23 Q. Do you know whether it's a private law firm 24 or something else?
j 25 A. I really don't remember at this moment.
57
1 Q. Did you contact this group at some point, 2 Mr. Parks?
3 A. I contacted a lot of law firms. Now, s
4 whether I contacted this particular law firm or not, I 5' really don't recall, not at this moment.
6 Q. How about the name above it, " Joseph S.
- 7. Roda," R-o-d-a, do you recall who that gentleman was?
8 A. No, sir. )
9 Q. If you'll skip the next page and go to the 10 third page, which has a half of a piece of paper that's 11 torn. It's got some writing identifying the Government 12 Accountability Project, indicated GAP in parenthesis, 13 and then.some phone numbers and some names.
14 Is that your handwriting?
l 15 A. Yes, sir, it is.
16 Q. Where-did you get the telephone numbers and 17 names that are there of Mr. Garde, Billy Garde, and I 18 guess it's Marya Young?
19 A. I received those phone numbers from those 20 two people.
21 Q. During the course of the meeting with them?
22 A. Probably. I could only speculate.
1 23 Q. On the next page, Mr. Parks- there's just 24 an address of someplace on Georgia Avenue and then an 25 apartment number.
58
1 Do you know what that is?
2 A. No, sir, I do not.
l 3 Q. Okay. Okay. Now, I show you -- I think )
l l 4 that at least before lunch, this will be the last one.
5 This is Exhibit 12, which is an exhibit that I want you 6 to look at just briefly.
7 7 What is that document which has been marked 8 Exhibit 12, Mr. Parks?
9 A. Sir, I believe we've already covered this 10 testimony with Mr. Richardson.
11 Q. Well, I don't believe so. I think it might 12 be quicker, rather than stop to look for it, if you can 13 tell me what it is. Why don't we just do that.
14 A. Because I believe I've already answered 15 that question with Mr. Richardson, sir.
16 Q. Well, do you know what the document is?
17 A. fe s , sir, I know what the document is.
18 (Discussion between the witness and Mr.
19 Johnson.)
20 THE WITNESS: All right, I'll tell you. It's --
l 21 that document was what I --
at least from what I can 22 recall at this moment -- I used that document to help me 23 reconstruct the time line of activities to provide a 24 historical perspective of activities that had occurred 25 at the job site.that ultimately ended up in a 59
l-1 historically perspective-56-page affidavit.
2- BY MR. HICKEY: Q. Did you put this book i
3 together, Exhibit 12, prior to writing your affidavit? i 4 A. It may have.been contemporaneous 1y with 5 it --
6' Q. But the purpose --
4 1
7' A. --
and it may have been -- I know parts of )
8 it was -- was written -- parts were written before the 9 affidavit was written.
10 Like I said, I believe that leaf -- that 11 little notebook'was used strictly'to help me get my 12 facts in a row or ducks in a row, if you will.
13 MR. JOHNSON: And I would ask if this has been 14 covered in other depositions, that you not replow the 15 same ground.
16 BY MR. HICKEY: Q. I did make an effort, 17 Mr. Parks, to look back at your depositions and to
-18 exclude areas.that were previously covered.
19 I can't guarantee, just like you can't !
20 guarantee, that I won't go back over something; but to
~ .-
21- the extent-that I'm able to, I have tried to exclude
-22 from_this deposition anything that Mr.-Richardson 23 covered with you earlier. i 1
-24 A. I believe if you would drift off into an 25 area that's already been covered, it would be 60 !
_-.-_-____---____2-_-_-_----_____--_-___-_____-__-_ - - _ _ - _ _ _ - - - _ _ _ _ . _ _. - _ .-__ _ - __.
1 inadvertent on your part. And.if you do, I will 2 definitely hesitate to answer the question again.
13 Q. Is all the handwriting in this book yours, 4 Mr. Parks?
5 A. It appears to be, sir.
.6 -Q. Why don't we stop there.
l 7 A.: You know, just as a matter for record, as I 1 8 was late this morning, I'm willing to go through lunch. i 9 MR. HICKEY: How about off the record for a ;
i 10 . minute. Let's just talk about schedule. Off the 11' record.
12- (Discussion. held off the record.)
13 (Whereupon the noon recess is taken.)
14 BY MR. HICKEY: Q. Mr. Parks, just before lunch, 15 when we were looking at some of these documents, I 16 showed you one -- one that there was some question 17 about -- that was Exhibit 9 -- which you identified as 18 having somebody else's handwriting on a portion of the 19 top half of the page.
20 I'll put that back in front of you; but let a
21 .me direct you to your affidavit and ask you, please, to I i
22 look at page 31 --
or, actually, it starts at the bottom .I I
23 of page~30 of your affidavit, if you would.
I 24 A. Okay. l 25 Q. Okay. Do you see the reference -- it's j 61 l
l 1 really at the top of page 31 -- to a list of items I
2 relating to a February 28 meeting that, in the words of 1 1
3 your affidavit, "comes from Ron Warren and my notes of j l
4 the meeting"? Do you see that? l 5 A. Yes, I did.
6 Q. Look at now Exhibit 9, which is also here 7 in front of you.
8 Can you tell me whether those notes of the 9 February 28, 1983 meeting, on the top half of that first 10 page of that exhibit which are not yours, are 11 Mr. Warren's notes?
12 A. Again, sir, my memory does not serve at 13 this time to positively identify those as Ron Warren's 14 notes. I am unsure of who those notes are.
15 Q. Do you believe they're Mr. Warren's?
16 A. They very well may be.
17 Q. Well, the subject matter of the notes that 18 are there is the subject matter that's discussed at the 19 bottom of page 30 and the top of page 31 in your 20 affidavit; is that correct?
21 A. That's correct.
22 Q. Okay. ,Did you review any documents 23 before -- in preparation for your deposition here today, 24 Mr. Parks?
25 A. No, sir, I did not.
l 62 l
1 Q. And I take it you did not bring any 2 documents with you to this deposition?
3 A. Yes, sir, I did.
4 Q. Oh, you did.
5 What documents did you bring?
6 A. Copies of the deposition -- or some of 7 the -- copies of some of the depositions that were taken 8 in my civil proceeding.
9 Q. Your deposition, you mean?
10 A. Yes.
11 Q. Portions of your deposition in the civil 12 proceeding?
13 A. Yes.
14 Q. Anything else that you brought? I 15 A. No, sir.
16 MR. HICKEY: Okay. Mark that as the next in 17 order.
18 BY MR. HICKEY: Q. Now, Mr. Parks, you have in 19 front of you a copy of the affidavit which you published 20 on March 21, 1983. I have some questions I want to ask j 21 you about some particular areas in that affidavit.
22 The document -- you are, as I said earlier, l
23 free to refer to the do culaent so that you can see the 24 language that I'm interested in asking you about and go 25 from there.
63
_ _ _ _ _ _ _ - . - - _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ J
i 1 Let me first refer you to page 5 of your 2 affidavit. And if you'll read the material on page 5 to 3 yourself. I want to direct your attention primarily to 4 the bottom half of the page; but so you can put it in 5 context, why don't you go ahead and read that.
6 (Whereupon Respondent's Exhibit 13 was 7 marked for identification by the Notary Public, and 8 attached hereto.)
9 BY MR. HICKEY: Q. Okay. Mr. Parks, have you 10 had a chance to read that page?
11 A. Yes, I have.
12 Q. All right. You'll see that at the 13 paragraph that begins near the bottom, "On July 19, 14 1982," you refer to the assignment given to Bechtel to 15 " refurbish the reactor building polar crane in 16 accordance with the Bechtel containment entry program."
17 And you go on there to claim that the work 18 request making that assignment was deficient and explain 19 why you think it was deficient.
20 Am I correct that your allegation, as 21 ctated in that paragraph of the affidavit, is that the I
22 containment entry program under which the work request 23 was issued covers issues such as personnel protection i
24 from radiation, but does not cover engineering functions 25 or design Q'A engineering documentation?
64 u__ . -
l' i
l' MR. JOHNSON: Do you-understand the question?
2' THE WITNESS: No.
3- BY MR.' HICKEY: Q. Are you claiming'in this-4- paragraph or on this page that the assignment to Bechtel 1
5 to refurbish the reactor building polar crane under this 6 work request was deficient because the program.that was 7 being -- that would be used to refurbish it didn't_have 8 provisions dealing with engineering functions or design L 9 QA engineering documentation?
- 10. A. No, sir, that's not what the intent of this 11 paragraph was. ;
i 12- Q. What is deficient? What did you mean to l
)
13 say was deficient about the work request? ;
14 A. If memory serves me correctly at this time, 15 the problems that would'have existed with that 16 containment entry program did not provide an 17 all-encompassing procedure or a detailed procedure for 18 accomplishing engineering work; however -- please let me 19 finish --
20 Q. Sure.
21 A. -- this' affidavit was not necessarily as 22 filled with allegations as some parties to these
' 23 proceedings have chose to believe.
24 This affidavit, as I have testified 25 previously, and as I testified today or provided public 65
1 statements the day I went public with it, was to provide 2 a historical perspective of events that had occurred.
3 Q. Well, but you were trying in the affidavit 4 to state matters accurately, were you not?
5 A. Yes, most assuredly.
6 Q. And you said at the outset, if I remember 7 correctly -- bear with me just one minute -- yeah, it's 8 in the second line on the first page -- "I am submitting 9 this statement to express my personal knowledge and 10 concerns," and then you go on to talk about what the 11 personal knowledge and concerns that you're referring to 12 there are.
13 But your intent in publishing the affidavit 14 was, to the best of your ability, to state the facts 15 truthfully and accurately as you knew them; isn't that 16 right? ,
1 17 A. That is correct.
18 Q. Okay. So when you said that there was a I
19 problem -- and I've just pointed you to on page 5 --
20 with the work request, I understand you to be testifying 21 that the problem with the work request was that the 22 procedure under which it was entered didn't cover 23 engineering functions or design QA engineering l
l 24 documentation?
I 25 A. This whole paragraph identifies, in a very 66 i
1 cursory-fashion, I guess I should say, the fact that the 2 entire process to turn.the polar crane back to Bechtel 3 for the refurbishment work was deficient and the work 4 request procedure along with the containment entry 5 program was not the proper empirical document to 6 accomplish the work that had to be accomplished on the 7 polar crane.
8 Q. I'm not sure I completely understood your 9 answer.
10 What you state in the affidavit is, is it 11 not, that the deficiency, the absence of procedures to 12 govern the engineering function or design QA engineering 13 documentation, that's what you were stating was 14 deficient.
15 A. Run it by me again.
16 Q. What you state in the affidavit is what is 17 deficient about the containment entry program under 18 which the work request was issued is that it doesn't 19 cover engineering functions and it doesn't cover design 20 QA documentation; isn't that right?
21 A. That is true. That's what I believed at !
22 the time.
23 Q. Do you believe something different now?
24 A. No, sir, I do not.
25 Q. Now --
67
i i
1 A. However, I also point out that the 2 affidavit was to be considered illustrative, not 3 exhaustive of anything and everything that went on.
4 Q. I didn't hear you.
3 A. If the affidavit -- the information that i
6 was contained in the affidavit was to -- should be 1 7 reviewed -- or viewed that the information was 8 illustrative, not exhaustive.
9 Q. What did you mean when you were referring 10 there to " engineering functions and design QA 11 engineering documentation"?
12 A. Engineering change memorandums, the process 13 that governed how important the safety items should be 14 modified and documented and tested, that type of thing.
15 Q. Is that responsive to both of my questions?
16 I asked you earlier about two phrases, " engineering l l
17 functions and design QA engineering documentation."
18 A. I would say that was a fair answer to both 19 from what my memory serves at the time to provide me 20 with.
21 Q. And why is that -- why was that deficiency l
22 thought by you to be significant?
23 A. The whole process of how it was turned back 24 and work was governed was deficient. I provided only ,
I 25 two examples of how it was deficient. ,
68 l
'1 Q .' I understand that. And you've said that
'2 this was illustrative and not exhaustive; but I'm asking 3' you a different question now, which was why was that
'4 ~ deficiency thought now to be significant?
5 A. Again, to provide' historical perspective to j 6 the reader and to the investigative bodies.should one 1 7 elect to investigate.
8 Q. Well, let me put the question this way: In l 9 your mind, why was it.important to have engineering i
10 functions and design QA engineering documented for a 11 task such as this? l 12 A. Because at that time, I was of the belief 13 that we were governed by the work that was to be 14 performed on important safety items to be governed by 15 Appendix A of the tech specs.
16 Q. Yes.
17 Are you of some different belief now?
]
18 A. No.
19 Q. And what flows from the fact that you were j 20 governed by Appendix A of the tech specs?
21 A. Actually, Appendix A of the license which
.22 invokes certain review and documentation requirements to 23 comply with the Code of Federal Regulations, and I did
- 1 l
24 not feel that the process that we had -- had resulted in 25 us getting to the point where we were at on the polar
.i 69
( H
1 crane.
l l 2 At the time I wrote this document, I did 3 not believe that we had adhered to the Code of Federal 4 Regulations for the requirements for documenting and l 5 performing work on the nuclear power plant.
6 Q. And specifically with regard to the 7 documenting and performing work related to engineering 8 functions or design QA engineering documentation on the 9 polar crane?
10 A. No, sir, with the polar crane at large.
11 Q. I can't ask you about the affidavit 12 altogether; I can only ask you one part at a time.
13 Let me direct your attention to the 14 paragraph that we're talking about, okay?
15 I'm trying to understand if what you are 16 claiming in the paragraph that begins on page 5 that 17 I've indicated to you was that there was an -- an 18 absence of documentation and review of engineering f 19 functions and design QA engineering documentation --
l 20 A. I believe --
21 Q. -- under the procedure that this crane was l
l 23 turned over to Bechtel?
23 A. I believe at the time that I wrote this 24 affidavit, that there was a definite absence of proper 25 review and documentation for the all-enco~mpassing 70 L- - - - - - - - _
l l \
j 1 engineering functions and the QA documentation. l l
2 Now, whether those items in particular were 1 3 an outgrowth of CA258 or not, that was not the point I 4 was trying to make.
l 1
5 Q. That's what you said, isn't it?
l 6 A. I think that's open to the interpretation 7 of the reader, sir.
i 8 Q. Is it your testimony, Mr. Parks, that you 9 were not trying to communicate to the reader, in this i 10 statement that we're looking at on page 5, that the 11 deficiency in the containment entry program was its lack -
12 of procedures governing engineering functions and design -
13 QA engineering documentation?
14 A. Sir, my intent in the paragraph in that 15 document was to draw off the light that the whole 16 process that had resulted with -- with the process that 17 had resulted with us being at the point we're at at the 18 polar crane had begun by an improper turnback.
19 The procedure was to govern the work that 20 was to be performed on the polar crane; and, yet, the
\ \
21 procedure in question did not have the same checks and i 22 balances that were built in the procedure and ,
23 documentation review system cycle at TMI to make sure l l
24 all work was properly documented.
j 25 Q. So it was deficient. And what was 71
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ i
1 deficient about it specifically was it didn't provide j i
i
'2 for engineering functions and design QA engineering 3 documentation, at least -- and maybe other things, i I
4 too -- is that your testimony?
5 A. I think that's a fair characterization.
6 Q. Okay. I'm just trying to understand the 7 idea you were trying to communicate in this document, i
- 8 which I gather you took some pains to put together, did l
9 you not?
10 A. Yes, I did.
11 (Discussion between Mr. Hickey and Mr.
12 Lewis.)
13 BY MR. HICKEY: Q. Now, how did you learn of l
14 this deficiency in the process for turning the crane 15 over to Bechtel to do this work?
16 A. At the moment I do not recall.
17 Q. Well, you were aware at the time of a July l
l 18 14, 1982 work request CA258 that you reference in your 19 affidavit.
20 You don't recall how you learned about that 21 document?
22 A. Not at the moment, I do not.
23 Q. In the normal course of your duties, would 24 you have been at that time asked to review those kinds 25 of work requests?
72
1 A. At the moment I could not recall if I had 2 to or not.
3 Q. In the normal course of your duties?
4 A. Right.
l 5 Q. Was your earlier answer stating that it was 6 the ECM process that normally assured that modifications 7 had appropriate review of the engineering functions and 8 design QA engineering?
9 A. I don't think that's what my previous 10 testimony was, no.
11 Q. Well, what was the normal way that -- that 12 it was assured that these concerns you had here would 13 normally be dealt with?
14 A. Are you asking me for my recollection at ,
i l
15 the moment? )
l l
16 I'm asking you, yes, from your Q
17 recollection. And refresh your recollection by looking i i
18 at the affidavit that's in front of you.
19 A. At the moment, offhand, I do not recall i 20 what the proper format would have been or the proper !
i 21 vehicle to follow. I can only assume at this stage of I
22 the game.
23 Q. Well, you testified about five minutes ago 24 that engineering change memoranda were utilized in 25 connection with review or documentation of engineering 73
- _.--_a
1 work.
2 Do you remember that testimony?
'3 A. Yes, I do.
4 Q. And what kinds of engineering changes or 5 work would be documented on ECM's?
6 A. It depends.
7 Q. .Well, work that was being done of the kind 8 like to restore.the polar crane, would that be 9 documented on ECM's?
10 A. I'm of the belief at this present time, it 11 should have been documented on an ECM, yes.
12 Q. All work on the polar crane?
13 A. Not necessarily all work, no.
14 Q. What work?
15 A. The work that would be mandated to be 16 documented on an ECM.
17 Q. Well, what kind of work is mandated to be 18 documented on an ECM?
19 A. I guess the problem is, Mr. Hickey, at this 20 time, I cannot recall what the procedural requirements 21 were that mandated the use of an ECM. ]
'22 That would have been governed on at least 23 one procedure, possibly more, and one of those 24 procedures would have been the work authorization 25 process modifications procedures of which I don't recall l
74
[
1 the title or the number of them all anymore.
2 Q. Well, as we saw this morning -- I can 3 understand not recalling numbers and titles at this 4 stage.
5 A good part of your work, as we reviewed 6 your documents this morning, related to review of 7 modifications, did it.not? l t
l 8 A. Yes, sir, it did.
l 9 Q. And at that time, even if your memory has 10 slipped now, you were familiar with the procedures that 11 applied to modifications?
12 A. Yes, I was.
13 Q. Let me show you what the reporter has
'14 marked as Respondent's Exhibit 13.
15 Do you see it's a form titled, " Generation 1
16 Corrective Maintenance System Job Ticket Form (Work 17 Request)," and in the top line there, it's got a block l
18 that says, " Job Ticket Number." i I
19 And written in is "CA258,"-followed by the '
20- date, seventh month, 14th day, 1982 or July 14, 1982.
Do you recognize that form, that is, l 22 Exhibit 13, Mr. Parks? i 23 A. Yes, I do.
24 Q. What is it?
25 A. It is a maintenance form or job ticket form 75 i
1 11 used to perform work by the maintenance department.
>2 Q. .And-this-specific one -- you may need to 3 look at it:to confirm'this -- is-the job ticket-for the 4" task-of, quote, " Refurbish reactor building polar crane 5 ,in accordance-with the Bechtel containment entry
. 6 program"; is that not right?
7 A.- That's what it says, sir.
8 Q.- And this is the July 14, 1982 work request 9- CA258 that you are referring to in this paragraph of 10 your affidavit we're looking-at?
i
' ll .A. Yes, sir, it is.
12 MR. HICKEY: 14, please.
13 (Whereupon Respondent's-Exhibit 14 was 14 marked for identification by the Notary Public, and 15 attached hereto.)
16 BY MR. HICKEY: Q. Mr. Parks, I'll show you what 17 the reporter has marked as Exhibit Number 14 to your 18 deposition, a document titled, "TMI Unit 2 19 Administration Procedure 1021, Revision 10," dated June 20 2, '82, and the title on the procedure is " Engineering 21 Change Memorandum." Will you take a look at that, 22 please.
23 Do you recognize Exhibit 14, the procedure 24 that I just put in front of you, Mr. Parks?
25' A. Only in general terms.
76 -
1 Q. And what is it?
2 A. It says it's an engineering change 3 memorandum procedure.
4 Q. Okay. And in your duties at TMI in 1982 5 and '83, you worked frequently under the provisions of 6 this procedure; is that right?
7 A. I worked with the provisions of this 8 procedure. I don't know whether it was frequently or 9 not. I have no recall at the moment.
10 Q. All right. But1when we were looking this 11 morning at those enteries in the reports and logs that 12 talked about reviewing modifications, this would be the 13 procedure that you would have utilized in making such 14 reviews?
15 A. This one may have been -- this procedure 16 may have been one of the ones that I would have relied 17 upon in the performance of my work. There might have 18 been others.
19 Q. Okay. And looking at this procedure for 1'
20 just a moment, if you would, please, if you'll look at 21 page 3, you'll see down at the bottom of the page, under 23 paragraph B, there's directions for preparation of an 1
'23' engineering change memorandum, ECM, and it provides for )
I 24 preparation of these documents by responsible engineers, l 25 right?
l 77 '
l l
- - - _ _ _ _ - _ - _ _ _ _ _ _ - _ - _ _ _ i
'l A. Is there a question pending?
2 Q.- Yes,-the question is whether that's an 3 accurate statement I-just'made.
'4 A. I. don't'know. I'll have to have time to 5 read the whole' thing.
6 Q. Well, I'm directing you to paragraph.B at 7 'the bottom of'page 3.
, '8 (Discussion between Mr. Hickey and Mr.
9 Lewis.)
10 THE WITNESS: Okay.
11- MR. HICKEY: Do you want to read the question I 12 ' asked back to the witness, please.
13 (Record read.)
14 THE WITNESS: I do not see where it provides for
- 15 preparation by responsible engineers. It does reference l16 that engineers will compile the package, but I would not 17 contest your opinion of it.
18 BY MR. HICKEY: Q. Do you see the language about 19 filling out the ECM forms, a responsible engineer is 20 responsible for filling out the ECM forms?
21 A. I see thtt.
22 Q. Does that indicate that the engineer is to 23 complete the ECM form or review it?
24 A. It indicates to me that he's responsible i
25 for filling it out and compiling it and putting it all 78 1
1 together to comply with the procedure.
l 2 Q. And was that typically done by engineers l 1
3 when ECM's were used at TMI and you reviewed them? I 4 A. Again, I could not answer yes or no with my I 5 memory at the moment. I would only have to assume it 6 was.
7 I guess the problem is, Mr. Hickey, it's !
8 been too many years for me to recall how everything was 9 done there.
10 Well, I can appreciate your problems with Q.
11 your memory about details, Mr. Parks; but let me ask you 12 to try to do the best you can and to look at these 13 procedures and attempt to refresh yourself as much as 14 you can.
15 If your testimony is that you have no idea 16 whether engineers normally filled out ECM forms at TMI, 17 you should state that. And if your testimony is that 18 you just have no recollection of that at all, you should 19 state that; but I'd like you to give me your best answer 20 to my questions.
21 A. My best answer at the time was I don't 22 recall who -- or what was the practice at TMI when I was 23 there regarding who filled out or if it was always an 24 engineer that filled it out.
25 Q. I didn't ask you if it was always now. I 79
1 just want to make sure if you understand my question.
2 Was it the prrs ctice at TMI, when you were 3 reviewing ECM forms, that they were normally filled out 4 by engineers?
5 A. That would probably be a safe bet.
6 Q. Now, if you'll look over on page 6 of the 7 procedure, it talks about drawings.
8 And maybe in an effort to make the record a 9 little more clear, these engineering change memoranda
]
10 were preoared, were they not, Mr. Parks, to document and i 11 control modifications that were being made of certain
{
12 types to the plant structures? j 13 A. I believe that's what the intent was, yes.
14 Q. So, normally, there would be some drawings 1 15 by an engineer that would describe what the change is 16 that was going to be made; isn't that right?
l 17 A. I believe so, yes.
18 Q. And on page 6, it talks about the drawings 19 for these modifications being reviewed, if you look down 20 in paragraph 4, particularly.
21 I guess the werd it uses is " approved,"
22 " Base line drawings shall have been approved" and so on.
23 A. Yes, I see that statement.
24 Q. Okay. And it's the design engineering 25 director that is to have done that approval under this 1
1 80 l
,1- . procedure?
2 A. That's what the procedure states.
3 Q. And then over on page 12, there are j 4 different additional procedures in this document for S review of ECM's-under certain conditions by' personnel 6 such as.the. director of site operations, the plant 7 engineering director, the GPUN QA design and procurement 8 manager and the licensing manager under certain 9 circumstances, right?
10 A. Right.
11 Q. Now, let me show you -- well, let me just 18 see if I can step back-for one moment.
13 These procedures that we have just looked 14 at in 1021 -- and if you wish to look further at the 15 . procedure, you're welcome to do that -- these procedures 16 in 1021 provide for control of engineering and design QA 17 engineering documentation, do they not?
i 18 A. I would state yes,,they do.
l 19 Q. All right. But you felt that the turnover 20 of the polar crane was deficient because it wasn't l 21 incorporating this; isn't that right? l I
l 22 A. Sir, I believe that the work traveler 23 process that interrupted in CA258 is not a part of 24 AP-1021. I believe it's AP-1034, which is the 1
25 maintenance procedure. And, again, I'm probably wrong 81 1
)
1 ;with the number; but --
- 2. Q. Whether you're right or wrong to the 3 numbers, I don't think it was responsive to my question.
-4 Let me see if the reporter can read back my 5 question.
6 (Record read.)
7 THE WITNESS: I think you have to expand your 8 question a little bit, sir, because, in my opinion, the 9 answer that I gave to that question was a direct 10 response to it, that the procedure that governs work 11- procedures or work travelers, whatever that procedure ;
1 12 was that resulted in Exhibit 13, does not have all the 13 same controls on it that AP-1021 does, no.
14 There's a procedure to the best of my 15 recollection at this moment of itself that stands 16 entirely alone and governed only the maintenance 17 performed on the unit. And, you know, that's the best 18 answer I can give, as I understand your question.
19 BY MR. HICKEY: Q. Thank you.
20 MR. HICKEY: I'm going to ask the reporter to 21 mark this next document as Exhibit 15.
22 (Whereupon Respondent's Exhibit 15 was i 23 marked for identification by the Notary Public and !
24 attached hereto.)
35 BY MR. HICKEY: Q. Mr. Parks, I'm showing you i
82
1 what the reporter has marked as Exhibit 15 to your 2 deposition, a copy of Administrative Procedure 1043, l
3 Work Authorization Procedure. l 1
4 I think you may have referred earlier in ,
l 4
5 your answer a few moments ago to 1034, which is pretty 6 close; but I think 1043 may be the one you were j 7 referring to.
8 A. No, sir, it was not the one I was referring 9 to.
10 Q. Okay. Well, take a look at that one and 11 we'll get to the one you may have been referring to.
12 (Discussion between Mr. Hickey and Mr.
13 Lewis.)
14 BY MR. HICKEY: Q. Mr. Parks, let me direct your 15 attention to a specific part of the procedure that I 16 wanted to ask you about.
17 On page 1, you'll see, in paragraph 1.2, 18 the description of the scope of the procedure. The 19 procedure states just above that that "This procedure 20 establishes a means by which proposed changes to TMI-2 21 are initiated, reviewed, and approved, in accordance 22 with Plant Technical Specifications."
23 And looking at Section 1.2.1, is it correct 24 that this procedure 1043 complements or goes along with 35 procedure 1021, the one we just looked at, by describing 83
1 the process of' installation, test, turnover and records 2 retenticr. after an ECM is approved; is that right?.
3 .A. I'm of the belief, from -- based on my 4 cursory review of both documents, that they do
.5 complement one another, yes.
6 Q. And is that the relationship between the 7 two?
8 A. I could only speculate. Without having 9 reviewed both procedures in detail, it appears to be 10 that, yes.
11' Q. Look at paragraph 1.2.1. Isn't that what 12 it-says?
13 A. That's what it makes reference to, yes.
14 Q. And if the containment entry procedure had 15 incorporated these two procedures'that we've just looked 16 at, Mr. Parks, 1043 and 1021, then it would have 17 utilized procedures to cover engineering functions and j 18 design QA engineering documentation, would it not?
19 MR. JOHNSON: Could you just repeat the last --
I i
l 20 didn't quite follow the last part.
21 MR. HICKEY: Sure.
22 BY MR. HICKEY: Q. If the -- if the containment ,
1 1
23 entry program under which the polar crane was turned '
24 over to Bechtel for work had incorporated 1043 and 1021, 25 then the procedures would have adequately dealt with 84
1 engineering functions and design QA engineering i
- 2. documentation, would they not? I 3 A. I do not believe so, no.
4 Q. Well, aren't those the procedures that
- 5 govern normal. engineering documentation and design QA 6 engineering documentation?
1 7- A. Yes, they do.
8 Q. Are you saying you don't think those j l
l 9 procedures are adequate?
10 A. That's not what I'm saying, no.
11 Q. Those are the procedures that normally 12 would cover modifications, documentation of 13 modifications and design QA engineering functions?
14 A. That's true, but they do not incorporate 15 all the necessary testing requirements in all aspects.
16 Q. Well, your paragraph on page 5 of your 17 affidavit doesn't refer to a criticism of the turnover 18 because of testing, lack of testing programs, does it?
19 A. As I said, the paragraph was not meant to 20 be an all-encompassing complaint for identification of 21 all concerns.
22 Q. I understand that, but the concerns that l
23 you addressed in that paragraph are what we're 24 discussing at the moment.
35 A. There's nothing in reference to testing l
l 85 1
1 concerns contained within that paragraph of my original 2 affidavit.
3 MR. HICKEY: Okay. I ask the reporter to mark 4 this next document as Exhibit 16?
5 THE REPORTER: (Nods head affirmatively.) l 6 THE WITNESS: And plus, sir, that does not -- or 7 should you infer that I was in full agreement with the 8 conclusion that you drew that if all the requirements of 9 AP-1043 and 1021 were contained within the containment 10 entry process, that I would have had no problem with it.
11 BY MR. HICKEY: Q. Well, the criticism you're 12 voicing with it is that it lacks procedures to govern 13 engineering functions or design QA engineering 14 documentation; isn't that right?
15 A. Part of the design QA engineering 16 documentation is adequate proof of testing and 17 compliance with QA requirements.
18 And you have just limited it very narrowly 19 to two documents, and that's what I'm in disagreement 20 with your conclusion on, sir. ,
l 21 Q. Well, I'm trying to limit it to what you l 22 expressed in your affidavit.
23 A. Yes; but that's a very narrow definition 24 drawn by yourself, not by me.
25 Q. Is there something in this paragraph that ,
86 l
, _ _ _ _ _ _ _ = _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ - - _ - _ _ _ - _ _ _ _ _ _ _ _ _ - - - ___ - _ _ - _ - .
. l;
!?
p
- 1. refers to the testing deficiencies in the turnover of U 2 the polar crane? q f
[ 3 A. I guess, sir,' depending upon your )
, i I 4 definition of the problems that I had there of f l
i 5 engineering functions, design QA documentation. ]
o I
' ff 6 Q. Is it your testimony that this paragraph, l
7 beginning "On July 19," that in it, you intended to :
) \'
8 express that there was a deficiency in the turnover of 9 the polar crane because-of inadequate provisions for 1
10 testing provisions? l l
11 A. No, sir, and I have answered that question 12 before in this testimony.
13 MR. HICKEY: Can we mark the exhibit, please.
14 (Whereupon Respondent's Exhibit 16 was 1
15 marked for identification by the Notary Public, and 16 attached hereto.)
17 BY MR. HICKEY: Q. Mr. Parks, if you'll look at 18 Exhibit 16, which I'm placing in front of you, which is 19 a maintenance procedure 1407-1, titled, " Job Ticket Form 20 (Work Request) - Preparation and Administration."
21 (Discussion between Mr. Hickey and Mr.
1
'23 Lewis.) (
)
i 83 BY MR. HICKEY: Q. In the interest of time, j l 4 1
'24 Mr. Parks, let me direct you specifically to page 16 of 35 the Exhibit 16, which is titled, " Procedure for Use of 87
(
1 L_ __ _ . _ _ . _ _ _
1
j 1 Job Ticket with an Engineering Change Memorandum."
2 MR. JOHNSON: Page 16. 1 J
l 3 BY MR. HICKEY: -Q. Is this the procedure that l
4 you referred to earlier in your testimony, Mr. Parks, i
5 about. job tickets? ;
^
)
6 A. I believe it to be, yes.
- 7. . , Q. Okay. What does the procedure do in 8 substance?
9 A. Controls the maintenance performed on the l 10 unit, documents it.
l
- 11. Q. I'm sorry, I didn't hear you.
112 A. Controls the way maintenance is performed 13 on the unit, how it's initiated, documented, that type 14 of thing.
.15 Q. All right. And if the maintenance to be 16 performed involves a modification, that particular kind 17 of maintenance, then the procedure on page 16 says that -
l 18 you can use the job ticket with an engineering change 19 memorandum; is that right?
20 A. That's what the procedure says, yes; but 21 that's not what CA258 said.
'22 Q. All right.
23 A. The block on CA258 that should have been 24 marked with an X identifying that ECM's were required 25 was left blank, meaning no ECM required.
88
1 Q.- What is the block that you're referring to?
2' A. " Change mod required."
'3.
~
Q. Well, Exhibit 13, CA258 says that the 4 refurbishment is to be in accordance'with the Bechtel 5 containment entry' program.
6 You were familiar with-that program,.were 7 you not?
8 A. At the time that --
in question, I was. At 9 'least I recall that I was anyway.
10 Q. Yes, I mean, you -- if you want to look at 11 .page 11 of your affidavit, you talked about --
'12 A
.. I'm not disputing, sir, that I was familiar 1
I 13 with it at the time. I'm just.saying -- my recollection 14, at this time tells me that at that time, I was a lot 15 more familiar with it than I am now.
16 Q. I can understand that.
17 The procedure was commonly referred-to as 18 ATWIC; is that right?
19 A. It was commonly referred to as what?
20' Q. Standing for Access to and Work in the 21 Containment Building.
22 A. That's the first time I'can recall hearing 23 that acronym, but I'm not disputing it.
24 Q. That's a shorthand way that at least I've 25 referred to it.
89 l
l 1 MR. HICKEY: I'm asking the reporter to mark as l 2 Exhibit 17, Procedure Number 4300-ADM-3240.1, Access To 3 and Work in the Containment Building.
4 THE WITNESS: Before we go on, are we through 5 discussing AP 1407-17 6 BY MR. HICKEY: Q. You can leave it there.
7 A. I was not through with the point I was 8 trying to make. You were -- excuse me, Mexican food for 9 lunch -- you were --
10 Q. Well, let mo just ask -- I don't remember 11 whether there was a question pending; but --
12 A. I thought there was.
13 Q. What was the question?
14 A. You were questioning me regarding whether 15 or not this portion of the procedure contained on page 16 16 provided for use with ECM.
17 I thought there was still a question 18 hanging there because we went over on a tangent by 19 telling you why a 258 --
20 Q. I understood you to answer that yes, that l 21 it does provide for ECM.
22 A. Yes, that procedure does provide for it; 23 but it wasn't implemented to my knowledge. That was 24 more of my answer to your question.
25 Q. What do you mean it wasn't implemented?
90 l l
1 A. The job ticket that was_ filled out, you 2 know, refurnished the polar crane in accordance with the 3 containment entry procedure, did not invoke the use of 4 AP-1047 or whatever it is, 1407, in that the block that l
5 would have required an ECM to be used was left blank, 6 meaning no ECM required.
7 Could we take a short break? I need to 8 make a head call.
9 Q. Surely.
10 (A recess is taken.)
1 11 (Whereupon Respondent's Exhibit 17 was 13 marked for identification by the Notary Public, and 13 attached hereto.)
14 (Whereupon Mr. Berry left the deposition 15 room.)
16 BY MR. HICKEY: Q. Mr. Parks, I'm now showing 17 you what has been marked by the reporter as Respondent's 18 Exhibit 17, which is the Access To and Work in l
19 Containment procedure that we talked about a moment ago.
20 Would you take a look at that, please.
21 A. Okay.
22 Q. Do you see in this document, Mr. Parks, 23 procedures calling out the use of ECM's and work 24 permits?
25 A. I see that they're referenced.
91 I
c__-_______
1 Q. Well, it's more than a reference, isn't it?
2 Look at 4.1.1. It says that the schedule approval !
3 allows implementation subject to the availability of the 4 following properly approved documents where required.
5 All right. That list includes engineering 6 change memoranda, maintenance job ticket, procedure or 7 work package, itself; isn't that right?
8 A. That's exactly what it says.
9 Q. And if you look at the next page, it 10 provides that if you want to determine whether any of 11 these documents are needed, you look to the existing GPU 12 procedures.
I 13 Isn't that what the procedure says, 1
1 14 Mr. Parks?
15 A. That's exactly what the procedure says.
l 16 Q. So if the ECM procedure requires use of an 17 ECM in a particular circumstance, this procedure does, 18 too, does it not? i 19 (Whereupon Mr. Berry reentered the 20 deposition room.)
21 THE WITNESS: This procedure requires it. That 23 is not to imply that it was enacted. i 23 BY MR. HICKEY: Q. I beg your pardon? l 1
24 A. It's not to imply that the persons who 25 utilized this procedure to refurbish the polar crane 92 l
l l
1 followed all the requirements to that point.
2 Q. I'm asking you about the provisions of the l
3 procedure, and you're saying whether the procedure is l 4 complied with in practice is a separate question.
5 The procedure calls for use of engineering 6 change memoranda, does it not --
7 A. Yes, it does.
8 Q. --
in circumstances where it's required?
l 9 A. Yes.
. 10 Q. Not every circumstance requires an
[ 11 engineering change memoranda; but where it's required, l 12 it says it shall be used, right?
13 And if you look at 4.1.3, you'll see that i 14 activities in the containment building -- that would 15 include refurbishment of the polar crane -- that was an 16 activity in the containment building; is that correct?
l l 17 A. That's correct.
18 Q. -- will be described in a work package 19 prepared by Bechtel Northern Construction and work 20 packages shall comply with all requirements of this !
i 21 procedure; is that correct?
l 22 A. That's correct, that's what the intent of 1
23 this procedure was.
24 Q. Okay. And this is the procedure that is 25 called out by the CA258 reference to refurbishing the 93
t 1 reactor building polar crane in connection with the 2' contaiment entry program, right?
3 A. That's what it calls out for, yes.
4 Q. So your statement on page 5 in your 1 5 affidavit is in error when it says that the work request 6 was deficient because the containment entry program has 7 nothing to do'with engineering functions or design QA 8 engineering functions?
9 A.. Sir, when the requirement block specifying 10 ECM is.left blank, there is no requirement to document 11 anything except for ALARA. l 12 Q. Mr. Parks, I assume you -- I don't need to
- t. E13 assume. You've told us that you've looked at a lot of 14 these job tickets and work request forms.
l 15 Where there is a work package, wasn't it i 16' the package to describe, with regard to each portion of l
l l 17 the task, this block that says, " change modification 18 required"?
19 A. Run that past me again. I do not recall 20 ever testifying that I reviewed a lot of job tickets.
21 Q. Well, you've seen this form before that is 22 Exhibit 13, haven't you?
23 A. I have seen that form before, yes.
24 Q. All right. And this form contemplated its 35 use for the entire polar crane refurbishment, did it 94 L
L_____m_______ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _
1 not? That's what the function is, right?
l l
2 A. That's what the top part of that block code 3 says, yes. It continues to say that that job ticket is ;
i 4 to be used to document machinery history only.
5 Q. And wasn't it the fact, Mr. Parks, that 6 there would be, under this procedure, a separate l
7 package, with or without an ECM, for each particular 1 I
8 part of that job program?
I 9 A. What type of package?
10 Q. Well, you're saying that there was no check 11 here on this block, " change modification required." And 12 isn't that because this sheet was to be accompanied by a i
13 number of other specific sheets for specific tasks?
14 A. Sir, I would not care to speculate what was 15 the intent or in the mind of Mr. Pastor when he filled 16 out that job ticket and approved it.
17 Q. How could you fill out this job ticket, 18 Mr. Parks, if you had some work to be done on the polar 1
19 crane that required ECM's and some work that did not?
]
20 What would you put in that box that you're pointing to?
21 MR. JOHNSON: Are you asking him what he did in ,
i 1 \
l 22 his work, or is this a hypothetical? '
23 MR. HICKEY: He knows about the procedure. I'm J i
24 asking him what's supposed to go in the box. He pointed )
l 25 out the box.
l 95
_ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ 1
11 THE WITNESS: I wouldn't fill one of those out.
2 There was never a. requirement at my job to fill one'out.
3 BY MR. HICKEY:' Q.- Well, you.were confident a
- 4- moment ago that you thoughtuno modifications were being 5 used because this block ~was blank.
6 Wasn't that your testimony?
7 A. That's correct.
8 Q. Where did you get that idea, that it had to 9- be filled out in this' block on this sheet?
10 A. If there was work to be performed, it would 11 require an ECM prior to the implementation of either 12 this procedure (indicating) for containment access or to' 13 generate work performance along that work ticket.
14 The procedures require that the ECM be 15 identified and approved by the requisite authorities
- 16. prior to the. implementation of that maintenance.
17 Q. That's absolutely correct.
18 A. That's exactly correct; however, sir, that 19 block was not marked. There were no ECM's written to i 20' refurbish the reactor building polar crane.
,21- -Q. Well, that's not right, Mr. Parks. ,
22 A. Well, I should say that there was j l 23' insufficient number of ECM's generated to refurbish the l 1.
24 reactor building polar crane prior to March 23rd, 1983.
25 Q. There were some?
96 i
~_--____-_-____--__-___-_-_-_-__:.. k
1 A. I couldn't recall if there were or not.
2 Q. Well, you talked about them later in your 3 affidavit. I'll be glad to show.it to you later on.
4 Let me get back to the point we're trying to address 5 here.
6 It's not your contention, is it, that this 7 sheet, Exhibit 13, would be used to describe the 8 individuals who were going to do the work, each task 9 they were to do on the polar crane?
10 You wouldn't give this t.o a workman and 11 send him in the containment building, would you?
12 A. Sir, I do not care to speculate what could.
13 or could not be done. That's the work traveler, 14 Q. It has other material that goes with it, I
15 does it not?
16 A. Probably, probably.
17 Q. And if there was an engineering change 18 memorandum, that would accompany it, would it not?
19 A. It might.
20 Q. Doesn't the procedure call for checking the 21 boxes with regard to each task that is to be done?
22 A. Sir, that's my recollection, is that that 23 is the only work ticket I saw or ever reviewed regarding 24 refurbishment of the reactor building polar crane.
25 So it would have been awful hard to check i
l 97 i
lL that block with every function that's performed to the 2 . polar crane. Now, please feel free to correct me if I'm 13 wrong.
4 Q. Well, don't you recall reviewing ECM's on 5 the polar crane?
6 A. Not at the moment, I don't, no; but that's s
7 not to-say.that I didn't. I spot your better knowledge l
L 8 of-all the documents that exist on this whole l
.9- controversy.
10 Q. Well, let me see if I can get back to the 11 main issue I was trying to address with you, Mr. Parks.
12 I suggested to you that your paragraph on 13 page 5 of your affidavit is wrong.
14 A. And I suggested to you that I did not agree
- 15 with.your conclusion, j 16 Q. And the reason you don't agree is because i
17 the containment -- let me put it to you this way: Is it 18 not the fact that the containment entry program 19 procedure calls for use of ECM's when ECM's are 20 required?
21 MR. JOHNSON: Could you rephrase that because 22 there was a nod in there and I couldn't follow what kind 23 of answer was sought.
24 BY MR. HICKEY: Q. Isn't it the fact, Mr. Parks, 25 that the containment entry procedure requires the use of 98
1 ECM's when.ECM's are called for?
2 A. The intent of that procedure included that, 3 yes.
4 Q. It's the language of the procedure as well, 5 isn't it, Mr. Parks?
6- A. That is true. And as we all know, the 7 language of the procedures in question were not adhered 8 .to, so, therefore, that does not make my statement 9 wrong.
10 Q. Your statement is that the procedure is 11 inadequate and deficient, and you told the world under 12 oath that it was deficient because, quote, "It has 13 nothing to do with engineering functions or design QA 14 engineering documentation."
15 And that was wrong, wasn't it?
16 A. Sir, I guess you and I will remain at 17 loggerheads over the interpretation of the intent of 18 that paragraph.
19 Q. Did you review the ATWIC procedure, Exhibit 20 17, before you wrote your affidavit?
21 A. I don't recall at this moment if I reviewed i 22 it or not before I wrote my -- my affidavit.
23 Q. Well, if you had reviewed --
24 A. It was not my intent to deceive or mislead 25 any reader with the statements I put in my affidavit. J l
99
_ _ _ _ . i
1 Q. 'Well, presumably,. then, when you were 2: referring to' procedures, you had taken the time to look i
3 at the procedure to make sure you were right. ;
l 4 . Did you do'that? I
~5 A.. I think I've already answered your L 6 question, sir.
I 7 Q. .You don't know whether you did or not? I 8 A. I cannot recall at this moment whether I 9 did or not.
10 MR. HICKEY: 18, please.
11 (Whereupon Respondent's Exhibit 18 was 12 marked for identification by the Notary Public, and.
13 attached hereto.)
14 BY MR. HICKEY: Q. Mr. Parks, I'm going to show-15 you what's been marked as Exhibit 18. It's a draft 16 dated 12/29/82, of a revision to procedure --
to the 'I 17 ATWIC. procedure, which procedure was previously marked 18 as Exhibit 17.
.i 19 MR. JOHNSON: Some of the pages here are not good 20 pages.
21 MR. HICKEY: Oh.
22 (Discussion between Mr. Hickey and Mr.
23 Lewis.)
-24 MR. HICKEY: My colleague, Mr. Johnson, is 25 suggesting that the difficulty in the copying of the 1
I 100 l
1 exhibit is not one to lay at our door stop because the 2 document was produced by the NRC staff and all copies of 3 it are Xeroxed in that fashion.
4 I'm confident that your copies of it are 5 also Xeroxed --
6 MR. JOHNSON: I was just noticing it.
7 MR. HICKEY: I don't think it will harm my 8 ability to ask Mr. Parks about this.
I 9 BY MR. HICKEY: Q. I want to direct you 10 particularly to the last three pages of the exhibit, l
11 Mr. Parks, which are three pages of handwritten 12 comments.
13 Do you recognize those?
14 A. No, sir, I do not.
15 Q. Do you think you've ever seen them before?
16 A. No, sir, I do not.
17 Q. It's not your handwriting?
18 A. No, sir, it's not.
19 Q. Look back just one moment at Exhibit 17, 20 would you, which is the ATWIC procedure.
21 (Discussion between Mr. Hickey and Mr.
22 Lewis.)
23 BY MR. HICKEY: Q. Just so the record is 24 complete, I referred you to some references in that 25 procedure to some of the other procedures we had talked 101
l l
1 about; but I didn't address specifically 1407-1, the l
2 corrected maintenance procedure.
l 3 That's called out, also, on Exhibit 17, l
L 4 isn't it? You can see at page -- well, it's paragraph j l
l 5 6.24, for one instance.
l 6 A. I'm afraid you'll have to -- we'll have to l l
l
.7 be delayed momentarily because I'm still reviewing this 8 one for the time being.
9 Q. I'm sorry, you said you hadn't seen it 10 before and didn't recognize it, so I didn't plan to 11 pursue it with you; but you're welcome to look at it.
12 A. You're mischaracterizing my statement, sir.
13 You asked me did I ever see these or did I recognize 14 these handwritten comments, and my answer was no. I did 15 not say I didn't see this procedure before.
16 Q. I'm sorry, you're welcome to look at the 17 exhibit. Go ahead.
18 A. Thank you.
19 Q. When you come to page 5, let me know and 20 I'll ask you a question about it.
21 A. Which procedure?
22 Q. I thought You wanted to look at Exhibit 18, 23 MR. JOHNSON: That's this one (indicating).
24 MR. HICKEY: No, it's not.
25 MR. JOHNSON: Are we finished with this yet?
102
l' MR. HICKEY: No, we haven't gotten to it yet. He
.2 wants to talk about Exhibit 18.
3 THE WITNESS: I didn't say that. I said I wanted 4 to look at it.
5- MR. JOHNSON: As I recall, you had asked him a 1 6 question about this and he was then looking at that 7 other document.
8 BY MR. HICKEY: Q. I see you're at page 5 of 9 Exhibit 18.
10 Do you recognize that handwriting, Mr.
11 ' Parks?
12 'A. No, sir, I do not. I 13 Q. And that again is not yours?
14 A. No, sir, it's not.
'15 Q. I don't have any questions for you about 16 Exhibit 18, Mr. Parks, except for the ones I just put.
17 A. That's all right, sir, because I believe I 18 have a statement regarding Exhibit 18. I'm just wishing 19 to verify it.
20 MR. LEWIS: A statement?
21 (Discussion between Mr. Johnson and the 23 witness.)
23 THE WITNESS: Okay. I'm sorry. Go ahead.
24 BY MR. HICKEY: Q. Was there some statement you 25 wanted to make?
103
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _. _ i
1 A. I'll reserve time for that later. l 2 Q. Well, you may get it and you may not; 3 but -- let me ask you now to look at. Exhibit 17.
4 Do you see that document?
5 A. Yes.
6 Q. I was trying to direct your attention to 7 one additional procedure that's referred to in' Exhibit l
8 17; namely, the corrected maintenance procedure which-we l'
9 talked about a few moments ago, 1407-1.
10 I was directing your attention to paragraph 11 6.24, which also refers to procedure 1407.1, does it 12 not? l 13 A. Paragraph 6.2.4?
14 Q. No, 6.24.
15 A. Oh, okay, yes.
16 MR. HICKEY: Time out.
17- (A recess is taken.)
18 BY MR. HICKEY: Q. Okay. Mr. Parks, the 19 discussion that we had that we just completed about the 20 containment entry program appears in your affidavit, and 21 I think you have a copy there in front of you.
22 After you announce on page 4 that after a 23- few Head Lift Task Force meetings, it was clear that 24 there were problems or deficiencies; and then on page 5, 25 you talk about some of those, including the one we just l 104 1
l u_______._____.____.
l i
i discussed. !
l 2- Now, if you'll turn to page 6, you see that i
3 we started near the top of that page with our second i
4 initial concern; but I wanted you to see where that 5 comes in the context of your affidavit.
6 Okay. The concern, as you stated, is that 7 the plant, plant systems and components have been 8 modified without proper review of the engineering 9 paperwork.
l j l 10 And why don't you take a moment to just l'
L 11 read that page 6 to yourself so you've got it in mind 12 before I start to ask yoa questions to yourself.
12 A. Okay.
14 Q. Okay. On that page, you're talking about 15 this procedure that we've just had out a few moments 16 ago, 1043, governing' modifications.
17 And you state that it covers the process 18 for an engineering change modification, ECM.
l l 19 By the way, it is proper to call that 20 engineering change memorandum, is it not, in the 21 procedure?
l 22 A. I believe so. J t
23 Q. Rather than a modification?
24 A. Right.
25 Q. And "at the Head Lift meetings, we 105 l
l w_ - _- _ _ _ _ _
l 1 learned," you say, "that ECM's were not consistently 2 being issued to accomplish plant modifications."
3 When did you learn that? !
4 A. I --
from.what my memory serves and tells !
5 me at this moment, I learned it -- as I stated in this
-6 affidavit -- I learned it during the course of the Head l
7 . Lift meetings. :
8 .Q. And when did the Head Lift meetings begin?
l
'9 A. Sometimes towards the end of the year, 10 1982.
11 Q. Did you routinely attend most of them?
12 A. I routinely attended them after I was l
13 assigned to the task force. l l
14 Q. Who assigned you?
15 A. Larry King.
16 Q. When did he assign you?
]
1 17 A. Sometime towards the end of 1982.
18 Q. And did you learn about this on your own at 19 these meetings or did someone else tell you about it 20 from meetings that you did not attend?
21 A. At the moment, I can't recall if I learned .
)
1 22 it while present in the room'or whether it was relayed ]
23 to me by Bubba Marshall or someone else. I can just- !
24 recall being made aware of it.
25 Q. When you didn't go, did Bubba Marshall 106 I
1 l
l 1 t usually go'on behalf of site operations? j I
2- A. We usually attended together. i i
3 Q. Were there other people there -- usually 4 there from site operations besides'yourself and Bubba 5 Marshall?
6 A. Yes.
- l. 7- Q. Who?
8 A. Dick Sieglitz was also assigned, and at ;
9' varying times either Joe Smith or possibly -- I don't i
10 remember what the other. guy's name was. :
11 Q. John Perry, was that the other name?
12 A. John Perry, I believe that was the other-13 guy.
14 Q. Mr. Sieglitz -- in case we don't have his 15 name spelled right -- was the plant maintenance manager 16 at the time, right?
17 A. I believe so, yes.
18 Q. And he and yourself and Mr. Marshall, 19 Mr. Smith and.Hr. Perry all were in the broader site 20 operations department; isn't that right?
21 A. That's correct.
22- Q. Okay. So when you talk about the site 23 operations representatives, that would be the group you 24 were talking about?
25 A. Right.
107
1 Q. All right. Now, what was the modification 2 that you learned about, however you learned it, at the 3 task force meeting that had been made without an 4 engineering chance memorandum?
5 A. At the moment I do not recall a specific 6 modification that had been accomplished without use of f
7 an.ECH.
8 Q. Was it simply announced at the Head Lift 9 Task Force that this had happened?
10 A. I don't really recall at the moment how ,
i 11 it -- you know, how that information was conveyed to the ;
12 attendees, either individually or as a group. ;
J 13 Q. As you understood the requirements of the 14 applicable procedures at the time, did you think that 15 was a violation of procedure, to have modifications 16 being made without ECM's?
17 A. I don't recall at this time what I thought 18 at that time.
19 Q. Well, you state in your affidavit, this 30 page we're looking at, page 6, "we learned that ECM's 21 were not consistently being issued to accomplish plant i
l 22 modifications."
23 I assume you were referring to plant 24 modifications that require ECM't, were you not?
25 A. That's correct, I would only have to make 108 i
i 1 .
_ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ l
l 1 that same assumption.
2 Q. So weren't you of the view that the failure 3 to use an ECM for.a modification was a violation of the l l
l 4 procedure?
5 A. I believe it to be a violation of 6 procedere, yes.
7 Q. And believed it then?
8 A. Probably.
9 Q. Is there some doubt in your mind about 10 that?
11 A. Very little; but, again, you're asking me 12 to state categorically what was in my mind seven years 13 ago, and I'm telling you I don't recall at this time 14 what was in my mind seven years ago.
15 Q. It's not quite seven, but I agree it is 16 several.
17 A. You're right, it's four.
18 Q. If you read what you swore to under oath, 19 it might help you refresh your recollection of the 20 accuracy of what you stated.
21 The statement that you make here on page 6 22 indicates that an example was refurbishment of the 23 reactor building polar crane and that doing that by work 24 packages could totally circumvent the site modifications 25 control procedure AP-1043.
109
l 1 A. Yes, it is. It's work authorization 2 process, procedure. There's a difference. I agreed 3 with you only to the extent that AP 1043 is a work-4- authorization' procedure.
5 Q. And AP 1021 is the. engineering change 1
6 memorandum procedure that goes hand in hand with it, 7 right?
8 A. I didn't --
9 Q. And AP 1021 is the engineering change 10 memorandum procedure that goes hand in hand with it?
11 A. I believe so, yes.
12- Q. Okay. When you learned of this violation 13 of procedure the first time, did you learn that it had 14 happened just once or more than once?
15 A. At this time, sir, I do not recall any 16 additional particulars other than what I've already 17 stated in my affidavit or previous testimony.
18 Q. Now, there were minutes that were kept of
'19 the Head Lift Task Force meetings, were there not?
20 A. I believe there-were, yes.
21 Q. And the attendees at the meetings received 22 copies of - the minutes after the meetings were held?
23 A. I believe that to be a normal practice, 24 yes.
25 Q. Do you have any recollection of this event, 110
1- of: a procedure violation being reflected in any of1the 2 ' minutes?
13 A. No, sir; but that's to imply that the L 4: minutes accurately reflected everything.that was 5 discussed atLthe meetings, which I am not of that 6 contention.
7 LQ.. It wasn'tLto implyLanything.but just to ask I 8 what.your recollection.was that was in-the minutes.
9 A '. I did wish to add that amplification.
10 Q. I understand that.
11 You apparently have some recollection of'at 12 least one instance where you felt the minutes of the !
1 13 meeting did not adequately reflect the meeting; is that
't 14 right? Is that what prompted your comment?
15 A. 'I -- my recollection is just based on what 16 I can recall, the' fact that the minutes very seldom ever 1
17 totally reflected everything that was discussed.
18 Q. Well, I can agree with that. Unless you 19 have a reporter like ours present here who takes down l
20' -every word, it's hard for minutes to reflect everything j i
21 that was totally discussed.
22 But is it your testimony that there was a ;
s 23 discussion of a procedural violation involving
'24 performing a modification without an ECM that occurred ,
25 at the Head Lift Task Force meeting and was not 111
1 documented in the minutes?
2 A. No, sir, I think that's an unfair
- 3 . characterization of the discussion that occurred.
4 Q. Well, what --
5 A. You prefaced it with a --
the fact that the 6 discussion dealt primarily with a violation of L 7 procedures, and that's not the way it went.
l l 8 Q. How did it go?
9 A. Just the fact that this modification had 10 been performed and when someone questioned how it was 11 being handled, what vehicle it was -- you know, with --
12 whatever you call it -- the Bechtel work procedures -- I 13 forget -- work package.
14 Q. You understood that to mean that that meant 15 not with an engineering change memorandum; is that )
16 right? k 17 A. I think that was definitely understood by 18 all involved, yes.
l L 19 Q. Did you say something about that?
20 A. I don't recall if anyone said anything 21 about that, not at this moment, I don't, 22 Q. Can you think of any reason why you 23 wouldn't say something if you were aware that that was a 24 procedural violation?
25 A. Because usually, from my recollection at 112 l
_ - - _ - - _ - - - - - - --- - - t
1 this moment anyway, any time someone in the side office I
2 brought up any procedural violation or brought up the 3 fact that we were not fully addressing the requirements I
4 of our procedure, it was unwelcome news and seldom acted 5 upon anyway.
6 Q. So your testimony is, though, that you 7 don't believe that you said anything about this 8 violation of procedure?
9 A. I didn't say that. I said I can't recall l
l 10 at this moment whether I said it or someone else said l
11 anything about it. I can't recall the entire q 12 conversation, only the gist of the conversation.
13 Q. And do you remember what the modification 14 related to at all about the polar crane?
15 A. No, sir, I do not, not at this moment.
l l 16 (Discussion between Mr. Hickey and Mr.
l 17 Lewis.)
18 BY MR. HICKEY: Q. Did Mr. King ever, to your 19 knowledge, attempt to supplement or correct the minutes 20 of the Head Lift Task Force meetings to make sure that 21 they more accurately reflected the subject matter of the 22 discussion?
23 A. Sir, I was not privy to all the activitien 24 nor the discussions that Mr. King had with any other 25 individuals, so any attempt on my part to answer your i
113
)
i
_ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ ____.-_l
'l question would be speculation other than what I've 2 already recorded.
3 Q. I don't agree with that, Mr. Parks. I 4 didn't anticipate that you had been privy to every 5 conversation that Mr. King had. I don't think that 6 would be a reasonable assumption.
7 My question was whether, to your knowledge, 8 Mr. King had ever made a comment about the inadequacy of 9 the Head Lift Task Force minutes in an attempt to make 10 the minutes more complete.
11 A. I'm of the opinion, of this moment in time, 12 as my memory serves me, that he did attempt to reconcile 13 differences regarding what he felt should be in the 14 minutes and what were in the minutes.
15 Q. And how did he do that?
16 A. I really don't know, sir.
l l 17 MR. HICKEY: Let me ask the reporter to mark as
'I 18 Exhibit 19 --
19 THE REPORTER: Yes.
20 MR. HICKEY: -- this memorandum of February 8, 21 1983, to Mr. Metzger from Mr. King.
22 (Whereupon Respondent's Exhibit 19 was I 23 marked for identification by the Notary Public and is 24 attached hereto.)
35 BY MR. HICKEY: Q. Mr. Parks, I'm showing you 114 l
_ _ _ _ _ _ _ - _ _ _ }
l 1 what the reporter has marked as Exhibit 19, the 2 memorandum I just identified.
3 Are you familiar with the document that's I
4 been marked Exhibit 19, Mr. Parks? l l
5 A. I may have seen it at some time in the d
6 past.
l 7 Q. Do you have any recollection whether you've I l
8 seen it or not?
l 9 A. Not independent recollection external to my 10 review of the memo.
11 Q. I don't understand your answer.
12 A. My answer is that I do not recall having 13 reviewed this memo until I just read it. That's not to 14 say I didn't.
15 Q. You don't know whether you've seen it 16 before or not; is that right?
17 A. I don't recall seeing it before, not at 18 this moment.
19 Q. Okay. Just from your looking at it here, 20 am I correct that it relates to a complaint by Mr. King 31 about the inadequacy of the minutes of a particular Head 22 Lift Task Force meeting?
23 A. I would say that that is a fairly accurate 24 reflection of Mr. King's concerns, or at least one of l
25 the concerns that he expresses in the memo.
115
\
l' Q. Now, did Mr. King customarily attend the 2 Head Lift Task Force meetings?
'3 A.' No, sir, he did not.
'4 Q. And this group .that you mentioned earlier, 5 you were there as his subordinates or delegates; is that.
6 right?
7 A. One or all of us at any one time, yes.
8 Q. 'And did you report to Mr. King what went on 9 at the Head Lift Task Force meetings?
10 A. Yes,' sir, we did.
11 Q. And did you tell Mr. King that there was 12 news of a modification being performed without proper l
13 ECM documentation?
14 A. At this moment, I do not recall whether we 15 did or not. I don't think it was any great secret.
16 Q. You were familiar at the time -- well, let 17 me -- let me ask you this question, Mr. Parks: Did you 18 think it was any obligation of yours to document or 19 report this violation of procedure when you learned of 20 it?
21 A. I think somewhere along the line, I did 22- document that procedures were being improperly reviewed-23 and/or work packages were being used in place of 24 procedures, yes.
25, Q. Did you ever document this allegation that 116
1 you made here -- that you made in your affidavit that 2 modifications were being performed in at least one case 3 without an ECM?
4 A. How do you -- would you like to qualify 5 " document"?
6 Q. Well, how did you -- what was the 7 procedures that were available at TMI for documenting 8 procedural violations?
9 A. At the moment, I do not recall what the 10 procedures were.
11 Q. Well, are you familiar with something 12 called a QDR, Quality Deficiency Report?
13 A. I seem to recall the QDR procedure, yes.
14 Q. And that was a procedure where someone who 15 felt that there was a violation of a requirement would 16 indicate that violation and transmit it to the QA 17 manager or the shift. supervisor and get a response?
18 A. I believe that's the way that -- that l I
19 procedure worked, yes.
s 20 Q. You never filled out a QDR on this alleged 21 violation of the ECM procedure, did you, Mr. Parks? l 22 A. No, sir, I think what I filled out relevant I
23 to procedure being violated was both verbal reports to j 24 my management, verbal reports to the Nuclear Regulatory 25 Commission and written reports in the way of site 117 )
I.
l
_______-____________-___D
1 operations. problem reports, which go not only to the 2 director of site operations, but also went to the 3 director of TMI-2, Bahman Kanga.
4 Q. I think your answer tried to encompass more 5 than my question was asking you, Mr. Parks.
6 Is it your testimony that you filled out 7 -any documentation to record a violation of the procedure 8 requiring ECM's to be used for modifications?
9 A. My testimony is at this moment, I can 10 recall filling out several different site operations i 11 problem reports and making several verbal notifications 12 to management regarding various problems with the use of
~13 procedures and/or the use of ECM's; that can I at this 14 moment recall distinctly who I reported it to and if I 15 generated a report totally relevant to the use of work ]
16 packages of ECM's, no, sir, I cannot, not at this 17 moment.
18 Q. That's a very long answer, Mr. Park. Let 19 me see if I understand it.
30 Your testimony is that you don't remember 21 filling out a written report about this violation of a l
23 modification procedure by doing it without an ECM; is j 23 that right?
24 A. I think my statement -- previous statement 25 to that, sir, was I don't recall at this moment whether 118 l l
_ _ _ _ _ _ _ _ _ - - - - - - - - - - - - - i
1 or not I filled out a specific report relevant only to d
2 the use of work packages of ECM's. That is not to say I 3 may not have.
4 Q. I assume that your memory about what you 5 did around the end of 1982 and the beginning of 1983 was 6 probably better in March 1983 than it is now.
7 Is that a fair assumption?
8 A. Yes, it probably was, yes.
9 Q. If you had filled out such a report, you 10 would have mentioned it in your affidavit, wouldn't you 11 have, Mr. Parks?
12 A. I might have; I might not have.
13 Q. Why would you not have?
1 14 A. My complaint, if you will, may only have 15 been lodged verbally.
16 Q. Well, Mr. Parks, I'm asking you about 17 written reports.
18 A. That's -- I still stand with my answer, 19 sir. I may or may not have.
30 Again, you're asking me to reflect 21 backwards four years as to if I did not include 22 something, why I did not, and I cannot answer that 23 question.
24 Q. Well, I'm asking you why you would not have 25 included a written -- a reference to a written report if 119 L__________._
1 you had written one in your affidavit.
2 A. Like most humans, I may have overlooked it.
3 Q. Or you may not have written one?
4 A. Or I may not have written one. And, then 5 again, I may have included it in my review process and 6 flagged it to the chairman of PORC, at which time it 7 would have become his responsibility.
8 Q. Flagged it in your review process refers to 9 what?
10 A. Meaning that I would have made a comment or 11 I might have made a comment relative to the procedure or l 12 the work package that I was reviewing at the time l
l 13 challenging that this work should have been done by way 14 of an ECM.
15 And at that point in time, it would have 16 had to be resolved either by PORC or QA.
17 Q. Did you review the work pachages on the l
18 polar crane?
19 A. Some of them I did; some of them I didn't.
20 Q. And those that you reviewed, you would 21 document your comments how?
22 A. On my review forms that I filled out, the l 23 comment on control form, I believe the acronym that we 24 used for the particular work involved.
25 Q. And were the work packages that you l
120 l
l
i 1 reviewed on the polar cranes ones that involved 2 modifications requiring'ECM's?
3 A. I seem to recall the reactor vessel off gas l 4 system -- and I believe it may have been this one; it 5 may have been a different one -- whereby the work was
-6 attempted to.be. performed by a work package and I 7 thought it should have been performed by an ECM and made 8 that comment; but I may be wrong on that'particular --
l 9 you know, that particular modification.
10 Q. Well, Mr. Parks, we were talking about the 11 polar crane. I understood you to be referring to the 12 polar crane.
13 The reactor vessel off gas system doesn't 14 refer to that, does it?
15 A. No, it was part of the process where we 16 could get to work on the polar crane. It was all work 17 covered under the same purview.
18 Q. Well, did you ever review a work package ,
l 19 for work done on the polar crane? I 20 A. I believe I did, yes.
31 Q. And was it work that involved a
-22 modification that required an ECM?
23 A. At the time I don't recall specifically if 24 it was or not. It may have been.
25 Q. And is it your testimony that if you had i
121 1
i i
1 ' filled out such a form, you may have indicated that 2 there was a modification of the procedure --
3' A. If I'--
4 Q. -- but you don't recall?
l 5 A. If I reviewed a work package involved 6 totally to the reactor building polar crane and if 1 7 felt that that work-that was accomplished by that work 8 package should have been performed by an ECM, I would 9 have made that comment.
-10 Q. In writing?
'11 A. Yes, sir.
12 Q. But you didn't feel the same way about 13 things that you learned at the Head Lift Task Force 14 meeting, apparently, right?
15 A. At that point in time, sir, I felt it was 16 easier just to bring comments to the attention of the 17 requisite management officials.
18 Q. Meaning who?
19 A. Larry King and/or others, the manager of 20 the Head Lift Task Force.
21 Q. Well, you don't recall whether you brought 23 this to Mr. King's attention, you testified a few 23 moments ago.
24 A. I also do not recall if I did not either.
25 And I'm not trying to intentionally try to be ambiguous, 122 1
c___----_. - - .
? l 1 sir; it's just that if I cannot recall with distinction, 2 that I'm not going to make such a statement that I do.
3 Q. Is it your recollection that you were .
I J
4 reviewing work on the reactor vessel off gas system in i 1
5 early 1983 or late 1982?
6 A. Somewhere in that time frame, yes, if my 7 memory serves me correctly at this moment.
8 Q. I recall that you did some work on the SDS 9 off gas system.
10 A. They're two separate systems, sir.
11 Q. Okay. And, Mr. Parks, on that page of your 12 affidavit -- do you want to take a break, Mr. Parks?
13 A. No, huh-uh, I'm fine.
14 Q. Okay. On that same page of the affidavit, 15 at the bottom of the page, you state under oath that "it 16 was immediately apparent to site operations that plant 17 management made this decision," meaning the decision to 18 do modifications without following the modifications 19 control procedure, " intentionally."
20 Were you present in any meetings where that 21 was stated or communicated in some way?
22 A. At this moment I do not recall if I was 23 present or not.
24 Q. When you said in your affidavit that it was 25 immediately apparent to site operations, were you 123
1 talking about.you or about somebody else in site i 2 operations?
3 A. I think it was a shared opinion.
4- MR. JOHNSON: Can I go back to -- there's j 5 ambiguity in the previous statement. l 6 You said were you present at a meeting. It 7 could have referred to either a site operations meeting. I 8 or some other kind of meeting. It wasn't clear from the 9 question which meeting you were asking him about with 10 respect to the first sentence in the last paragraph on J 11 6. ;
1 12 MR. HICKEY: Well, let me confirm it with the 13 witness.
14 BY MR. HICKEY: Q. These -- the meeting that you 15 are referring to in your affidavit where it was 16 apparent, the various meetings where it was apparent 17 that the top management --
t i
18 MR. HICKEY: Wait a minute.
19 MR. JOHNSON: I didn't --
20 HR. HICKEY: Wait a minute. Let me stop. Let me 21 stop. Off the record.
22 (Discussion held off the record.)
23 BY MR. HICKEY: Q. Torwards the bottom of the 24 page, Mr. Parks, you reflect an awareness of various 25 meetings where there was a discussion that the ECM 124
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 1
1 procedure was cumbersome and would force unnecessary 2 scheduled delays.
3 How did you learn of that view?
4 A. Now, you know, Mr. Hickey, in appreciation 5 of all the information we have to cover in a short 6 amount of time, I really think ws should probably delve 7 into questions that haven't been previously asked of me.
8 Q. I don't think that question's been 9 previously asked, Mr. Parks.
10 A. 1 believe that very question was asked to 11 me by Mr. Richardson during my civil proceedings, where 12 he asked me was I present during a management meeting 13 where the same statement was made.
14 I believe I answered it then. I really do, f
15 sir.
16 Q. Well, let me put this question to you, 17 then: You were aware, were you not, that there was a 18 procedure revision underway or under consideration to 19 attempt to revise the ECM procedure?
20 A. Are you asking me was 1 aware of it -- or 21 am I aware of it now or was I aware of it then?
23 Q. Were you aware of it then?
23 A. Not that I can recall at this moment. I 24 don't recall at the moment without reviewing any 1
25 documents to ascertain whether or not I was aware of it. j 125 l
l 1 Q. Well, how about now, do you have some 2 different knowledge now? J l
3 A. Nothing that comes to mind immediately, no.
i
! 4 Q. Did you -- did your experience indicate to ]
l 5 you that there were occasions when the ECM procedure was 6 cumbersome and caused delays beyond what you would have 7 liked?
8 A. At any time during my time at TMI?
9 Q. Yes.
10 A. Yes, sir, I am of the opinion that there 11 were certain instances whereby ECM was a cumbersome 12 process; but it was required.
13 Q. There was nothing in the procedures that 14 prevented or prohibited a refinement of the procedure to 15 modify it, was there, Mr. Parks?
16 A. I don't think I follow your line of 17 questioning.
18 Q. Why don't you see if you can answer the 19 question. You don't understand my question?
20 A. Probably not.
21 Q. The procedures at TMI, as you were aware, 32 contemplated revision of the procedures to improve them, 23 did they not?
24 A. There existed the capabilities to modify 25 any procedure.
126
_ = _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ -
1 Q. You spent a good part of your time doing i 2 that very work, didn't you?
3 A. Yes, I did.
l 4 Q. Was one of your goals in doing that work to l l 5 make the procedures less cumbersome and more efficient? }
l 6 A. More efficient and -- and strict compliance 1 i 7 with the government regulations, yes. !
l 8 Q. Of course; but efficiency and a lack of 9 cumbersomeness was what you were trying to accomplish in 10 the procedures, wasn't it?
I 11 A. Yes, sir, it was. 1 12 (Discussion between Mr. Hickey and Mr.
13 Lewis.)
14 BY MR. HICKEY: Q. Let me -- directing your 15 attention, Mr. Parks, in your affidavit to page 42. I 16 want to direct you specifically to the bottom of the 17 page; but you may want, just to get the context, to look 18 on page 41, where you begin by saying that you returned 19 to work on March 9 and did a number of things. And that i
20 included looking at some memoranda. I 21 At the bottom of page 42, you talk about a 22 document that you reviewed, polar crane functional 23 description.
24 A. Okay.
25 Q. Do you recall reviewing that document, 1 127 I l l
l
1 1 Mr. Parks, when you returned to work on March 9th?
2 A. I do not have any additional recall beyond l l
l 3 what I stated in my affidavit. l l
4 MR. JOHNSON: In other words, you recall 5 everything that's stated in the affidavit or you don't
! 6 recall what's in the affidavit, what's stated? Your 7 answer wasn't clear.
8 THE WITNESS: Okay. Well, what I'm trying to say 9 is I know I reviewed it at one time or another; but I 10 cannot amplify anything that's not already contained 11 in -- in my statement.
12 BY MR. HICKEY: Q. Well, don't give up too soon, 13 Mr. Parks. You might be able to. We'll give it a try 14 anyhow.
15 MR. HICKEY: Let me ask the reporter to mark as 16 Exhibit --
17 THE REPORTER: 20.
18 MR. HICKEY: -- 20, this document as Exhibit 20.
19 It's five pages on both sides, titled, " Polar Crane 20 Functional Description, Document Number 2-M72-MH02, 21 I show that --
this is Revision 1. I show 22 that to the witness.
33 (Discussion held off the record.)
24 MR. HICKEY: Let's go back on record and let me 25 clear this up. I meant that's Revision 1, and what the 128
1 witness refers to in his affidavit is Revision 0, so let 2 me ask the reporter instead to mark a different 3- document. I think that will keep the record clear. 1 4 I'm asking the reporter now to mark as "
5 Exhibit'20 -- we didn't mark the other document, right?
6 THE REPORTER: (Shakes head negatively.)
7 MR. HICKEY: -- to mark as Exhibit 20, this 8 letter of October 8, 1982, with an attachment, the Polar l
9 Crane Functional Description.
10 (Whereupon Respondent's Exhibit 20 was 11 marked for identification by the' Notary Public, and I 12 attached hereto.)
13 BY MR. HICKEY: Q. Mr. Parks, I'm showing you.
14 what the reporter has marked Exhibit 20. Would you take
- 15. a look at that, please.
16 Have you had an opportunity to review that 17 exhibit, Mr. Parks?
l 18 A. I have performed a cursory review, yes. ,
1 l 19 Q. In your affidavit, which you have there in 20 front of you, on page 42, you identify the polar crane 21 functional description and state that to the best of 22- your knowledge, the document has never been reviewed and 23 approved for use except by Bechtel.
84 The exhibit that's in front of you, Exhibit 25 20, is that a document that you've seen before? j 129
1 A. No, sir, it's not.
2 Q. Well, if you'll look at it, you'll see that 3 the first page is a letter of October 8, 1982, from 4 Mr. Kanga, K-a-n-g - a , to the Nuclear Regulatory 5 Commission transmitting the polar crane functional 6 description and then the attachment is the polar crane 7 functional description.
8 That's the document you were referring to 9 in your affidavit, is it not?
{
10 A. The attachment would probably be -- I don't
~ ~ ~ ~ ' ~~
11 know. I don't have the attachment in front of me.
12 Q. Yes, it's part of the exhibit.
13 A. This is not what I reviewed.
14 Well, when you -- you mean when you were '
Q.
15 writing your affidavit?
16 A. That's correct.
17 Q. You didn't review the document that is the 18 part of Exhibit 20 beyond the cover letter?
19 A. That is exactly correct.
20 MR. HICKEY: All right. Let me ask the reporter 21 to mark Exhibit 21.
9 22 (Whereupon Respondent's Exhibit 21 was 23 marked for identification by the Notary Public, and <
1 24 attached hereto.)
25 BY MR. HICKEY: Q. Let me show you now, 130 ,
1 Mr. Parks, this two-page document marked Exhibit 21, a 2 Document Number 2-M72-H2 -- I'm sorry, I misread it. ,
d s 3 It's Document Number 2-M72-MHO2, titled, " Polar Crane 4 Functional Description."
l 5 Will you take a look at Exhibit 21.
l 6 A. Not a whole lot here.
7 Q. Is that the document that you reviewed, 8 Mr. Parks?
9 A. I'd hate to even venture a guess without 10 seeing the rest of it because all I have here in front 11 of me is a table of contents.
12 HR. JOHNSON: I think the record should 13 reflect --
I guess the document will speak for itself Mh 14 when it's attached, but there's just four sides. One is 15 a cover sheet; the other one is a table of contents.
16 BY MR. HICKEY: Q. Look at the Exhibit 20 that's 17 in front of you there, Mr. Parks.
! 18 That document is described as the polar 19 crane functional description, is it not? -
20 A. That's what it says, yes.
21 Q. All right. I take it you had, in the 22 course of your work, seen functional description type 23 documents before?
24 A. I don't know if -- I cannot recall with 25 certainty if I have or not, but I know I did review the ,
4 131
i k j, . s-1 one in question.
2 Q. The polar crane --
3 A. Right. -
4 Q. -- functional description?
5 And do you believe that the document that 6 is part of Exhibit 20 is what you reviewed?
7 A. It may have been, but I would not care to 8 state with any certainty that it was or not.
9 Q. Well, that --
10 MR. JOHNSON: Would the witness like to compare e
11 the two documents?
12 THE WITNESS: Well, I guess what I'm having a 13 problem with is that there is a disparity between the 14 table of contents regarding the number of pages that 15 consist in the polar crane functional description and 16 over here, when you have the document status sheet that 17 shows, you know, more pages than what are contained here 18 in Exhibit 20, so I'm having a hard time correlating the .
i 19 two.
20 BY MR. HICKEY: Q. I understand what you're 21 expressittg. I'll see if I can find a fuller copy of 22 Exhibit 21 for you; but, in the meantime, you're ,
23 uncertain about Exhibit 20 as to whether that's what you 24 reviewed or not?
25 A. Yes.
132 4
i i
k
- 1. Q '. You're not sure? i E
L2 A. Right. I l
3 Q. Okay. Whatever you reviewed, the polar j 4' crane. functional description that you were talking about 5 in your. affidavit, you said that to the best of your 1
.6 knowledge, it had never been reviewed and approved for j 7 use except oy Bechtel.
8 How did you determine that?
9- A. I believe that the one that I reviewed had .i 10 a cove _ sheet similar to this (indicating). j 11 Q. Referring to Exhibit 21?
12 A. Right, and the only signatures for approval l 13 on it were Bechtel's' signatures, and there was no Rev. 1 14 in existence at that. time that I reviewed.
i 15 Q. When did you make this review; it was on l
16 March '9, 19837 17- A. I believe so, yes, or maybe I did review !
18 Rev. 1. I really don't recall at the moment; but any 19 fashion -- whichever one I reviewed was a document that 20 contained a cover sheet similar to this (indicating) '
21 with only Bechtel's signatures for review and approval.
22 Q. So this you're just holding up is Exhibit 23 21 for the record, right?
24 A. Right.
25 Q. And you're not sure that's the exact 133 1
l I
1 I
1 document; but that format was what was on the cover
)
2 sheet of the document that you did review and it showed l i
I 3 only Bechtel approvals, just like Exhibit 21 does? l 4 A. I am of that opinion, yes.
5 Q. How did you determine whether a functional 6 description had received reviews?
7 A. I pulled the file.
8 Q. And where would you get the file, in the 9 site operations department?
10 A. Yes, site operations maintained a file.
11 Q. So that if site operations had reviewed and 12 approved descriptions, functional descriptions of the I 13 polar crane, they would be in that file and you could 14 verify that by looking at the file?
15 A. Yes, that is what I recall at this moment.
16 Q. Now, looking at Exhibit 20 that is in front 17 of you, that does appear to be a functional description 18 of the polar crane, does it not?
19 A. That's what it says it is.
1 20 Q. If you look on the right-hand side of the j 21 front page, you'll see, down at the bottom half of that l
22 review form, distribution and review form.
23 Do you see that there?
24 A. Tes. ,
25 Q. You're familiar with that form; it appears i
134 4
1 on correspondence for GPU Nuclear?
2- A. Not necessari?y but I won't dispute that's 3 what it.is.
4- Q. Look at the bottom. You'll see " Reviews."
5 You'll see the entry, " OPS.," standing for operations.
6 Then do you see Mr.-Chwastyk's initials?
l 7 Do you see it says, "JJC" for LPK"?
8- A. I see that, yes.
9 Q. That's Mr. Chwastyk signing on behalf of 10 Mr. King?
11 A. That's what I can only assume it means, 12 yes.
13 Q.- October 1, '82, is that the date th'ere?-
14 A. That's what it appears to be.
15 Q. And then on the line below that, "RPW"? i 16 -A. Uh-huh -- yes, I mean --
17 Q. Was that Mr. Warren, Ron P. Warren?
18 A. I'm of that belief, yes.
i 19 Q. He was in the plant engineering portion of 20- the site operations department?
21 A. Right, I 22 Q. And he signed there, also.
23 And there are then reviews by a number of 24 other people indicated on the list.
25 If you looked at the functional description 135 )
1
)
j 1 file in the site operations building offices on March 9, 2 1983, you would expect that a copy of this exhibit, 3 which is Exhibit 20, would have been in that file?
4 A. I would have expected that a copy of this 5 exhibit or a copy of any other documents, any other l
6 problems that the guys had had would be in there and '
7 then signed off. !
8 Q. The version that you reviewed on March 9 9 that's reflected on page 42, did you get that from the-10 site operations file?
11 A. This functional description (indicating)?
12 Q. The one you're talking about on page 42, 13 che bottom of the page, the fifth document that I 14 reviewed, the polar crane functional description.
1 15 A. I would have to speculate where I got it 16 from because I don't recall where I got it from at the 17 moment.
18 Q. You say, "I did more research for my 19 decision as a TWG member," and then you list a bunch of 20 documents.
21 Does that indicate to you, from the nature 22 of those documents, where you probably got them?
23 A. No, because I got documents from various 24 places, various sources.
25 Q. Did you ask any site operations employees 136 I
L_ _ _ __ _ _-------- ------ ---- -
1 whether the polar crane functional description had been 2 approved by site operations? j
>3 A. I cannot recall at the moment whether I l l
l 4' specifically asked anyone in operations or not; but if I '
5 did, it would probably have been Joe Chwastyk, since he 6 was probably the acting manager at the time..
7 Q. If you asked Mr. Chwastyk, he would have 8 referred you to his approval on this document, Exhibit 9 207 10' A.- I'm sure he would have if he recalled it.
11 Q. Well, you were, I take it, being critical
'12 in.your affidavit on page 42 because this key document, 13' as you call it, the polar crane functional description, 14 had never been reviewed and approved for use.
15' Do you recall making any effort to confirm 16 whether that' fact was true or not?
, 17 A. Yes, I do recall making an effort to 18 confirm it.
19 Q. How did you do that?
l
- 20. A. I confirmed it by looking in our files to !
21 . verify whether or not it had been reviewed and approved.
22 And I'd also like to identify for the 23- record that this cover sheet is for Rev. O. Rev. 1 was 24 the one that was in effect, according to what you've .
25 provided me with Exhibit 21. f 137
1~ Q. Exhibit 20 --
- 2. A. Exhibit.20 is dated October 8th, 1982. All 3 the reviews are made and approved in October of 1982.
4 And, yet, during this time frame we're talking about, 5- Rev. 1 would have been involved.. And I do not believe 1
6 that I see-any cover sheets for the approval of the 7 change to Rev. O.
8 Q. Well, do you'know what you meant when you 9 wrote this affidavit --
10 MR. JOHNSON: Excuse me, you may have misspoken. )
1 11 You meant to say Rev. O. j 12 THE WITNESS: For what? Both of you are talking 13 kind of through me here.
14 MR. JOHNSON: Your last statement was you didn't-15 see any --
16 THE WITNESS: I do not recall --
17 MR. JOHNSON: -- approval for Rev. O.
18 THE WITNESS: I don't recall ever finding any 19 approvals in our files for either Rev. O or Rev. 1. I 20 don't recall ever finding any approvals.
21 BY MR. HICKEY: Q. And I'm asking you -- or I 22 did ask you a moment ago whether you attempted to verify i
23 that there had been no review and approval of this key 24 document.
25 And I understood your answer to be that you 138
1 would have done that, you thought, and that the exhibit 2 that's in front of you is an approval and review of 3 Rev. O, not Rev. 1.
4 A. Right, right. l 5 Q. Did I understand you correctly?
l 6 A. That's true. i i
7 Q. Okay.
8 A. It is true that I did attempt to verify 9 everything before I put it down in writing.
10 Q. And, presumably, the way you would have 11 verified this statement of yours was to look in the site 12 operations file? t 13' A. That's correct.
14 Q. And to ask other site operations people l
l 15 like Mr. Chwastyk?
l l
16 A. Possibly.
l l
17 Q. You don't indicate in the paragraph on page ,
i 18 42 of your affidavit that Rev. O had been reviewed, but l l
19 Rev. 1, the current one, had been. !
20 That's not what you say there on page 42, 21 is it? i-l 22 A. That's correct, that's not what I say.
23 Q. If there were NRC approvals of documents 24 like the functional description, would they also have 25 been in the site operations file?
139
1 A. .I seriously' doubt it. They may have been.
i 2 'I t would depend.
3 Q. Well, what was the purpose of the file that l 4 was maintained in site operations for documents like 5 this functional description?
6 A. Approved procedures and procedures-that we-7 had intimate involvement with, that type of thing.
8 Q. And for those procedures that were covered 9 by files in the site operations department, if NRC 10 review was required or obtained, would that also be 11 recorded in the file?
12 A. If they were definitely approved, yes; but, 13 there again, I'cannot recall distinctly at this moment 1
.14 whether that was the case always or just sometimes or l 15 what.
16 Q. Well, apparently before you wrote your i
17 af fidavi t , you learned that the NRC had approved a l 18 functional description because on page 53 of your 19 affidavit, you refer to that fact.
1 20 Do you want to take a look at that, please. '
21 (Whereupon Respondent's Exhibit 22 was 22 marked for identification by the Notary Public, and 23 attached' hereto.)
24 BY MR. HICKEY: Q. Seeing your affidavit at page 25 53, Mr. Parks, does tha,t refresh your recollection that 140 1
____ ____ ____ _ ___ _ _ _ . J
l l
1 you were aware, when you signed the affidavit, that the j 2 NRC had approved the polar crane functional description?
l 3 A. That's what it states in my affidavit, that I 4 the NRC staff concurred with the functional description.
]
That means they approved it, right? I 5 Q.
- 6. A. I guess one could draw that conclusion.
7 Q. Well, didn't you when you read it?
8 A. Probably.
9 Q. Why did you say, on page 43, that the --
l 10 I'm sorry, I gave you the wrong page.
11 Why did you say, on page 42, that the polar 12 crane functional description, to the best of your l
l 13 knowledge, had never been reviewed for use, except by 14 Bechtel?
15 A. That's just what I meant to say at that 1
16 point in the affidavit.
17 Q. That may be what you meant to say; but that 18 wasn't true, was it?
19 A. I did not learn that it had been approved 30 by the NRC until March 18th.
31 Q. Your statement on page 42 is that "To the 22 best of my knowledge, this document had never been 23 reviewed and approved for use, except by Bechtel."
34 Are you saying that although that was true 25 as of March 9, you didn't feel any need to indicate that 141
1 it was false as you learned on March 18th?
2 A. I don't think I intended to mislead anybody 3 by my statement on page 53.
4 Q. It's your statement on 43 that I'm 5 suggesting is misleading.
6 You say that the key document, the polar l
l 7 crane functional description, had never.been reviewed 8 and approved for use, except by Bechtel.
9 When you signed and swore to that on March 10 21st, 1983, you knew that wasn't true, didn't you?
11 A. I think, sir, that you're trying to la mischaracterize the affidavit.
13 Q. Well --
14 A. I state on March 9th, that review showed 15 this and on March 18th, a subsequent review showed 16 something different.
17 And, again, I think you're taking the whole 18 intent by the affidavit out of perspective. This 19 affidavit was to provide historical perspective to the 20 reviewer and to the NRC and to the Department of Labor.
21 Q. You mean as opposed to accurate facts?
22 A. Those are both accurate facts.
23 Q. Well, it's not accurate, to the best of 24 your knowledge, the document had never been reviewed and 25 approved for use, except by Bechtel; that's just flat 142
_ _-_ __ _ _a
1 wrong, isn't it?
2 A. No, sir, it's not just flat wrong. It was 3 the opinion that I held on March 9th and the belief that 4 I had on March 9th.
5 Q. What belief did you have on March 21st, 6 Mr. Parks, when you swore that this statement was true?
7 A. That it was true; I still believe it to be i
8 true. I do not see where the statement contradicts j
, I 9 itself at all. i 10 Q. Let me show you what the reporter has 11 marked as Exhibit 22, which is a March 7th, 1983 letter, 12 the one referred on page -- on page 53 of your l
13 affidavit. l 14 MR. JOHNSON: Has this document been marked yet?
l
\
15 MR. HICKEY: Yes, Exhibit 22.
16 BY MR. HICKEY: Q. Now --
17 MR. JOHNSON: Could you just wait one second, j 18 please?
19 BY MR. HICKEY: Q. Your statement on page 53 of 20 your affidavit is that on March 18th, you reviewed 21 certain memorandum, one was a March 7, 1983 NRC letter 22 signed by Mr. Snyder, which concurred with the polar k 23 crane refurbishment program.
34 And then you quote the summary portion of 25 the letter, which I think you can find there. l i
143 l I
i l
1 A. You're right, I see that.
2 Q. Okay. That's the document that you i
)
1 1 3 reviewed on March 18 in your attempt to help update 4 Mr. Marshall; is that right? j 1
5 A. Right. I l
6 Q. Now, you say, on page 53, that your review 7 of that letter, Exhibit 22, also revealed that on I
8 February 17, GPU had sent the entire program to the NRC 9 for concurrence. "This, of course, rebutted the NRC's 10 claim of full prior review and approval."
11 Do you see that material there at the top 12 of page 53?
13 A. Yes, I do. s 14 Q. Okay. Take a minute and read the paragraph 15 to yourself, if you want.
16 What did you --
17 A. I've read it.
18 Q. Thank you.
19 What did you mean in the paragraph when you 20 said that this rebutted the NRC's claim of full prior 21 review and approval? What does the "this" refer to?
22 A. The act of the NRC saying that they 23 concurred fully --
24 Q. I'm sorry, I didn't hear you.
l 25 A. When the NRC sent this letter to GPU on 144
1 March 7th, or what have you, stating that they fully
(-
! 2 concurred with everything, they identified a few things l 3 in here, one being the summary portion that I quoted, 4 " safety considerations have been addressed under a 5- separate letter," the QA/QC licensing requirements that 6 did not comply and if the -- I mean, comply with our 7 existing procedures and requirements.
8 And if the NRC had fully concurred in 9 advance, then how could -- my question was how could 1 10 they concur knowing that violations existed?
11 It seemed to me they were talking out of 12 both corners of their mouth and not moving their lips.
13 Q. I'm not sure I understood your answer and I 14 want to understand it. !
15 The NRC claimed, you said, full prior 16 review and approval. Are you referring to the March 7 17 letter tihen you say that?
18 A. Right.
19 Q. Okay. Full prior review and approval of 20 what?
21 A. The entire process of refurbishing the 22 polar crane.
23 Q. That's not what the March 7 letter says.
24 A. It says, "The NRC staff concurs with the 25 Functional Description as it relates to the Reactor 145 j
1 Building Polar Load Test using the main host system.
2 "QA/QC has been involved at all-stages of 3 Lthe refurbishment process in addition to the NRC staff.
1 4 Safety considerations have been addressed under a l 5 separate letter."
I 6 That --
7 Q. That -- excuse me. l 8 A. - -statement in itself at face value 9 contradicts the NRC, its own position on the 10 refurbishment functional description and the polar crane 11 load-test.
~12 Q. And how does it contradict itself?
l 13 A. Because it violated the procedures.
'14 Q. Mr. Parks, I don't understand that answer.
'15. Let me --
16 A. All right.
17 Q. The NRC staff, in the document that is 18 Exhibit 22, March 7, is approving the polar crane 19 functional description, is it not?
20 A. Yes.
21 Q. Is this document, Exhibit 22, approving the 22 polar crane load test procedure?
23 A. It implies that they are not only 24 concurring with the functional description, but also 25- using the main hoist system to perform the reactor 146 t
l l
1 building polar crane load test. At least that's my 2- recollection at the moment. .
l 3 Q. I don't think you need to rely on your j 4 memory. You can look at the language of the exhibit )
l 5 that is in front of you.
6 This Exhibit 22 of March 7 doesn't address 7 the polar crane load test procedure, does it, Mr. Parks?
8 A. I don't know if I can agree with that i
9 comment or not. .
1 10 Q. Look at the exhibit.
11 MR. JOHNSON: Did you catch the previous 12 statement that he had made?
13 THE REPORTER: Yes, I did.
14 MR. JOHNSON: I'm sorry I interrupted.
15 MR. HICKEY: That's all right.
16 I asked the witness to look at the letter 17 that was Exhibit 22.
18 THE WITNESS: Oh, I didn't know there was a 19 question pending.
20 BY MR. HICKEY: Q. The question pending is 21 doesn't this letter approve only the polar crane 22 functional description, and your answer was you didn't f
23 know if you could agree with that or not.
l-24 And I asked you to look at the letter and 25 then tell me what your answer is.
147 i
1 A. In order for -- I guess I have to break my 2 answer down into two parts. A simplistic answer to your !
l 3 question would be yes, it only approves the functional l 1
4 description.
l 5 Q. What do you mean by simplistic? l 6 A. If I was to try to give you a yes-or-no l
7 answer without elabe-ating. j 8 Q. How about an accurate answer?
9 A. That is an accurate answer.
10 Q. That is an accurate answer, all right, go 11 ahead.
12 A. A simplistic, accurate answer.
13 The position that the NRC was trying to 14 imply, in my opinion, as I understood it at that time, 15 was that not only were they approving the functional 16 description that had been submitted to them; but their 17 statement that the -- "hile it related to the use of the 18 main hoist of the reactor building polar crane and how 4
19 (unintelligible) --
20 THE REPORTER: Excuse me, please slow down.
21 BY MR. HICKEY: Q. Why don't you take a minute 22 and, if you'd like, have her reread the question.
23 I understand you can get disrailed -- or l 24 3 derailed when you're interrupted; but it doesn't do any 4
25 good if you're going so fast that she can't take it down j 148
1 i
1 so she does have to interrupt.
2 A. Would you please repeat it back?
3' (Record read.)
4 BY MR. HICKEY: Q. Anyway you want to try to 5 complete your answer, Mr. Parks.
6 You were trying to explain something about 7 while this letter only specifically addresses the polar 8 crane functional description, you thought there was some 9 implication or something like that.
10 I'm not trying to put words in your mouth, 11 but I want you to have an opportunity to explain <
l l l
l 12 whatever it is you're trying to say. 1 1
13 A. My concern at the time was by the approval l t
14 of the functional description as it existed and by the 15 credit that management was taking with the functional 16 description as it existed implied that NRC had been on 17 board all along, there were no concerns, QA/QC had been 18 involved all along, all the safety considerations had 19 been addressed and that there were no problems with it.
20 And, yet, within the functional description 21 itself, there were several stated positions of the NRC 22 and management that had been concurred to by all partiec 23 involved that were inadequate and deficient.
24 So, therefore, I just did not see how 25 the -- that's where I came up with, you know, my 149
1 expression earlier.of~ talking out of both corners of
'2 .
your mouth and not moving your lips.
3 It seemed to me they were saying and taking 4 a lot of credit for things that had not been done
'S properly and that was my concern.,
6 Q. Well, you knew on February 17th, Mr. Parks,
'7 the polar crane load test procedure had.not been 8 approved because you were still writing comments on it
'9 on February 17th?
10- A. Yes, sir, I sure was aware of that fact..
11 Q. And you knew that the NRC as of that date 12 had not approved the polar crane load test procedure?-
13 A. That's true, but those are not some of the
.14 points that are made within this polar crane. load test 15 procedure.
16 Q. On page 53, Mr. Parks, you claim that the
.17 letter of February 17th rebuts the NRC's claim.of full 18 prior review and approval. -
l
'19 A. That's right.
20 Q. That's.not an accurate statement, is it?
21 A. I disagree.
23 Q. Well, the letter only addresses the 23' functional description, does it not?
24 A. I would not say that.
25 Q. What else does it address? 1 1
150 ,
i l
l
_ - - _ _ _ _ _ _ _ - - _ _ _ - _ _ . _ _ _ _ - 1
i E
l 6 1 A. The implications of testing the licensing I 2 of.QA/QC requirements.
3 Q. . Where do you find that in the letter which 4 is Exhibit 22?
5 A. On page 2.
'6 Q. What does it say?
7 A. Well, in fact, it addresses everything 8- with -- on the crane itself, unless I'm reading from the 9 wrong exhibit.
10 Q. No, you're looking at Exhibit 22, aren't 11 you?
12 A. .Right. That's what you asked me about, i 13 right?
14 Q.. Right, that's exactly right.
15 A. And it's just the statement very 16 straightforward.
17 Q. What is the statement where the NRC 18 approved something more than the functional description?
.19 A. Let me find it again here.
20 Okay. For instance, one, "The original 21 safety features identified in the TMI-2 FSAR are being l
22 restored with the same quality of components." We did
,, 23 not replace all with like kind; we replaced some with j
'24 unlike kind.
25 Q. Well, Mr. Parks, the sentence at the end of l 151 j l'
1 the first paragraph of page 1 says, "The following is a 2 discussion of your functional requirements for these 3 items."
4 Don't you think that applies to all the 5 statements that follow?
~6 A. I think that the NRC, by saying that, is
'7 stating here is the things that you committed to and 8 here are the things that we're approving by concurring 9 with everything that they propose to do and say, "You 10 guys are going to do this. We concur with everything 11 you did." However, they didn't do all that.
12 The NRC couldn't have been on board and 13 intimately involved with the whole process or they would 14 have known of that.
15 So the NRC was, in effect, approving things 16 on the polar crane procedures and/or functional 17 description, whatever you want to call them, that simply 18 did not have what was required.
19 Q. Procedures and functional. descriptions are 20 two different things.
21 A. I realize that.
22 Q. So is it your testimony that this March 7 23 letter constitutes an approval by the NRC of the polar 1
24 crane procedures? l l
25 A. No, that is not my contention.
1 I
152 I
~
l
1 HR. JOHNSON: I don't know if this is going to 2 clarify it or fog it, but it seems to me that the --
3 you're going back and forth over the same ground over ;
4 and over again. 3 5 You're saying isn't it true that the letter ,
1 1
6 covers the polar crane functional description and didn't )
l J
7 the NRC approve it, and he's saying, I think, in effect, j i
8 that may be the case; but they were wrong. And you seem i 9 to be arguing back end forth.
10 HR. HICKEY: If you've got an objection to the 11 form of the question that it's repetitive, I'd rather l 12 listen to that.
13 HR. JOHNSON: Well, yeah --
l 14 MR. HICKEY: I don't think you need to l
l 15 characterize and interpret the witness' statements.
16 HR. JOHNSON: You've been asking this question 17 three times now and he's just giving you the same l 18 answer.
19 BY HR. HICKEY: Q. Were you aware that the NRC 20 approved the load test safety evaluation report for the 21 polar crane? i 22 A. Could you run that past me again? l 23 Q. Sure.
24 Were you aware that the NRC had approved 25 the -- 1 I
153 l
l' A. I thought I saw your partner telling you 2' you were asking the wrong question.
3 Q. He may want to improve it slightly.
4 (Discussion between Mr. Hickey and Mr.
5 Lewis.)
6 BY MR. HICKEY: Q. Now, Mr. Parks, just a few 7 more brief questions and then I'll leave this. area.
8 . Exhibit 22, which is the March 7 letter 9 that I think you still have in front of you there; is 10 that right?
L11 A. Yes.
12 Q. Now, you'll see that it has two references 13 at the beginning of the letter. It refers to a letter 14 dated October 12, '82, polar crane refurbishment, and ,
-15 then the-first sentence after that refers to the subject f 16 letter dated' February 17, 1983.
17 I haven't shown you the February 17, 1983 18 letter yet, I don't believe.
19 A. (Shakes head' negatively.)
20 Q. But I'm going to ask the reporter to mark 21 it as Exhibit 23.
23 (Whereupon Respondent's Exhibit 23 was 23 marked for identification by the Notary Public, and i
L 24 attached hereto.) l 25 BY MR. HICKEY: Q. This Exhibit 23 that has been-154
_ _ _ _ _ _ _ _ _ _ _ - . . _ _ _ - - _ _ _ i
- 1. marked, Mr. Parks, is the February 17, 1983 letter -- ,
2 (Whereupon Mr. Berry left the deposition 3 room.)
4 BY MR. HICKEY: Q. --
referred to in Exhibit 22.
5 And you see on Exhibit 23 -- no, excuse me.
6 Do you want to look at the document further?
7 A. There seems to be a mistake here.
8 Q. What's the mistake that you see?
9 A. Well, the cover letter addresses the 10 Revision 2, and everything contained as an attachment is 11 all Revision 1.
12 Q. Well, I think if you will look at the title 13' page, which is on the back side of the letter, which is 14 Exhibit 23, you'll see that that refers to Revision 2.
I 15 A. Right.
I 16 Q. Does that indicate to you that the only 17 change was the change in the title page and the date?
18 A. That's the only change I can see contained 19 within the body.
20 Q. Uh-huh.
21 Well, let me put my question to you and see 22 if you can answer it. The Exhibit 23, the February 17th 23 letter, states that it is transmitting Revision 2 to the 24 polar crane functional description.
25 I think you referred earlier in your 155
I:
l l
1 ' testimony.to Revision 1; but if you had looked on March
'2 9 at the current version of the polar crane functional 3 description, Exhibit 23 indicates that that current l
4 version would have been' Revision 2, right?
l 5 A. I'm not so sure I can completely agree with i i
6 your characterization of this document because in the !
i 7 context of the letter, it says, "This document updates J 8 the minimum required crane functions and movements ,
i 1
9' necessary for crane recovery," implying to me that there 1
10 were changes to the body of the functional description. '
11 And, yet, there are no changes indicated in 12 the body of this functional description, which would 13 make it Rev. 2, not Rev. 1.
14 You would not need to make that statement 15 if you were only. changing.the cover page.
16 Q. You're saying what is attached in the 17 letter irr the exhibit bef ore you may not be all the l 18 changes that were made in Rev. 2, right?
19 A. That very well might be.
20 Q. Now, can you answer my question which is if 21 you looked at the current version of the functional 23 description on March 9, 1983, when you reviewed the file 23 in site operations, this letter, Exhibit 23, would tell t 12 4 - you that the current revision was Revision 2, not i
25 Revision 1, right, this letter, Exhibit 23, February 17, l
156
l l
1 1983?
2 A. I don't know if I can answer your question 1
3 directly or not; but what I will try to do is answer as j 1
1 4 directly as possible --
5 Q. Please do.
i 6 A. -- in that whichever procedure was current ]
l 7 at the time and was in the files was the one that I 8 would have reviewed.
9 Now, if there was another one floating 10 around the Island somewhere at one stage or another of 11 approval, it may not have been the one I reviewed.
12 Q. Well, we know that more than floating 13 around the Island; you had at least a few days to review 14 a copy of the NRC letter approving the functional 15 description.
16 A. That is correct.
17 (Discussion between Mr. Hickey and Mr.
18 Lewis.) ,
19 BY MR. HICKEY: Q. When you saw the reference in 20 the March 7 letter, Mr. Parks, which is Exhibit 22, did 21 you go and check for the reference letter?
l l 22 A. I do not recall at this moment if I did or l
- 23 not. That's not to imply that I did or did not.
24 MR. JOHNSON: What was the question, what did you 25 check?
157
~1 MR. HICKEY: Well, not quite. It was more ,
i 2 specific than that.
3 BY MR. HICKEY: Q. When you looked at the l
4 Exhibit 22, March 7 letter, did you check the letter !
5 referred to, namely, the February 17th letter; and your 6 answer was you didn't know whether you did or not?
7 A. That's right, I do not recall at this 8 moment.
9 Q. Following your normal procedures, when you 10 were attempting to review the status of a procedure or a 11 document liKe AP functional description, would you l
12 normally check the referenced documents to ensure the l
13 accuracy of your review?
l l
l 14 A. To whatever extent possible, yes.
15 MR. HICKEY: Okay. Why don't we stop there for a
( -16 minute.
1 17 (A recess is taken.)
18 BY MR. HICKEY: Q. Mr. Parks, I've got a 19 different area I want to turn to with you; but I think 20 one which you have some familiarity.
21 Let me just mark a couple documents first 22 and then we can turn to the specifics.
23 I'm asking the reporter to mark as Exhibit 24 24 to your deposition, Administrative Procedure 1047, 25 the Startup and Test Manual.
158
i j
1 1 And I'll also ask her to mark as Exhibit 2 25, Three Mile Island Unit 2 Startup and Test, Test 3- Instruction Number 1, Test Frocedure Documents.
4 (Whereupon Respondent's Exhibits 24 and 25 5 were marked for identification by the Notary Public, and 6- attached hereto.)
7 BY MR. HICKEY: Q. I assume, Mr. Parks, that 8 Exhibit 24, Administrative Procedure 1047, is a document
-9 with which, at least in 1982 and '83, you had some 10 familiarity in your work.
11 A. I think that's a safe assumption on your 12 part.
- 13. Q. Did you work with it frequently, routinely?
14 A. Yes, to both, frequently and routinely.
15 Q. Let me just ask a couple of basic questions 16 .about it.
17 The scope of the procedure is described on 18 page 2, Section 1.2.1; is that right?
19 A. Yes, sir, it is.
20: Q. And'it refers to construction and startup 21 testing of things in Section A.
22 What do you mean by construction testing?
-23 What is a construction test?
'24 A. Sir, at this time, you know, my memory 25 would not serve to be an accurate vehicle to explain the 159
1 difference between the construction and/or functional 2 testing or startup testing.
3 Q. Okay. Your answer implies that you use 4 functional testing and startup testing as synonyms.
5 A. That's what my memory at this moment serves 6 to tell me, that they were synonymous.
7 Q. And that's distinguished from construction 8 testing on the other hand?
9 A. Right.
10 Q. But you're not able to describe -- can you, 11 in general terms, describe the distinction. between the 12 two?
13 A. I could not even begin at this moment to 14 accurately explain what idiosyncrasies with each type of 1 ;
I 15 test mandated with that type of test be performed. i 1
16 Q. Look, also, at Exhibit, if you would, 17 please, 25, which is the TI, Test Instruction, Numbar 1.
18 I'm going to direct you to a specific portion of it; but 19 let me first ask whether in general you are familiar 30 with Exhibit 25, the Test Instruction Number 1, and was l
21 it something that you used routinely in your work at 23 TMI?
23 A. Well, that's a -- kind of a compound 24 question; but --
25 Q. That's right, but I was confident you can 160 l
- L . ' handle it.
2- 'A. That's all right. I'll give you a compound 3 answer.
4 At this moment,.no, I'm not intimately 5 familiar with it. During the time frame in question, 6 yes, I was intimately familiar with it.
7 Q. Okay. Let me direct your attention in 8' Exhibit 25 to Enclosure 6. It's way towards the back'.
9 And you'll see that in -- have you found it?
10' A. I believe~I have, yes.
11 Q. Okay.- Enclosure 6, what does that deal 12 with?
- 13. A. Well, if you and I are looking at the same 14 page, it's the instruction and content requirements for 15 generic. test procedures.
16 Q '. Okay. It says generic procedures.are what 17 you use to conduct construction tests.
18 A. Right.
19 Q. So this enclosure would tell you.how you 20 would do construction testing, whatever construction 21 . testing means,.right?
22 A. I would assume that to be correct, yes.
23 -Q. Okay. Now, functional tests, I think, are 24 covered by Enclosure 1 of TI-1. Could you look at that, 25 please.
161
1 ///
2 (Discussion between Mr. Hickey and Mr.
3 Lewis.) ,
4 THE WITNESS: Okay. I think I found it.
5 BY MR. HICKEY: Q. Is that the portion of this 6 test instruction that is applicable to functional tests?
7 A. Well, the identification in the enclosure 8 identifies it as individual test procedures, so I would 9 only have to speculate at this time regarding whether or 10 not an individual test procedure or function and 11 functional test procedure were one in the same.
I 12 Q. You don't have any recollection of what 13 that phrase refers to?
14 A. Not at this moment in time, I do not, no. ;
15 Q. Okay. Look on page 2 of that enclosure -- j l
.16 oh, I'm sorry, not of the enclosure; but of Test '
17 Instruction Number 1.
18 After saying that there are three types of 19 test procedures, individual test procedures, generic 20 test procedures and special procedures, they then go on 21 to describe, on page 2, what individual procedures are.
22 And, in substance, it says, does it not, 23 that the individual procedures are the most detailed and 24 have the most unique requirements and require a higher 25 level approval?
I 162 l 1
l _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
1 A. That's what it says.
2 Q. And then generic test procedures are less 3 specific in detail; is that right?
4 A. That's what the write-up in this procedure 5 tends to imply, yes.
6 Q. Okay. Do you have a general 7 recollection -- I'm not asking for specific details; 8 but, in general, do you recall that that was a l 9 difference in the formatting requirements for these 10 tests -- different kinds of test procedures?
11 A. I believe that there were different 13 formatting requirements, yes.
13 Q. And, generally speaking, the more detailed 14 ones were required for the individual --
the most 15 detailed were for the individual tests and then next 16 most for the generic tests?
17 A. I believe that to be true, yes.
18 Q. My colleague is pointing out to me that on 19 revision -- on page 1 and 2 of the test instruction, it j l
20 says, at the bottom of the page, " Individual procedures j I
21 are the highest-level procedure utilized by the test l 1
23 program and are used for post construction testing or 23 integrated system / plant tests."
24 Would you understand from that that the 25- functional or startup test that you talked to -- talked 163
L 11 about earlier.would be covered.by the individual 2 p r o c e'd u r e s'?
3 A. I would have to assume that that would be
'4 correct, yes, without sitting down and' reviewing the 5 entire procedure.
6 MR. JOHNSON: I don't think he wants you to 7 assume. I-'think he wants to know whether you know or 8 recollect.
l 9 THE WITNESS: At this time, no, I do not recall 10 .. at this moment the specificity -- or the requirements 11 inherent within both of those types of procedures which 12 would perform what; I really don't.
13 BY MR. HICKEY: Q. Do you recall when a 14 functional = test is required?
15 A. Not at this moment, I do not.
16 Q. Mr. Parks, I earlier showed you Exhibit 15, 17 which is Administrative Procedure 1043. I'm putting it 18' back before you again.
'19 I want to ask you whether that procedure 20- permits or authorizes this construction test. And I can 21 direct you specifically to paragraph ~5.6. You can start
.22 at 5.5 and read on.
33 (Whereupon Mr. Richardson left the 24 deposition room.)
25 THE WITNESS: Okay. I have read those pages. I 164 l
- - _ . _ _ _ _ - _ - - - - - - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ ___ _ ___ _-__ __ _ ____ _ _ _ ____a
1 don't recall what your question was, though.
2 BY HR. HICKEY: Q. Okay. I was asking you 3 whether this procedure AP-1043 doesn't permit !
4 construction testing.
5 A. Does not?
6 Q. No, my question is doesn't it.
7 A. Oh, doesn't it? Yes, it does permit it.
8 Q. And it does indicate, also, does it not, 9 the functional testing should be performed if the test 10 program documents require it?
11 I'm looking at paragraph 5.8.
12 A. Yes, there's a statement to that effect in 13 there.
14 Q. And the construction tests that are talked 15 about are done before turnover; is that right, looking i
16 at paragraphs 5.5 and 5.67 17 A. That's correct.
18 Q. I'll just leave those exhibits out so if 19 you want to refer to them, you can.
20 MR. HICKEY: But I'm going to ask the reporter 21 now to mark as 8xhibit 26, a Unit Work Instruction or 22 UWI, U-W-I, relating to the polar crane load test.
23 And then Exhibit 27 is four pages of 24 handwritten comments, I believe, by Mr. Parks on that 25 UWI test.
165
1 ///-
- 2. (Whereupon Respondent's Exhibits 26 and 27 3 were-marked for identification by the Notary Public, and
.4 attached hereto.)
5 BY MR. HICKEY: Q. Mr. Parks, I want to ask you 6 to identify Respondent's 26, and ask whether that is the 7 polar crane load test unit work instruction which you 8 then commented on in Exhibit 27. l 9 Can you determine, from your review of 10 those exhibits, Mr. Parks, that Exhibit 27 are your 11 comments of February 17, 1983, addressing various issues
~
'12 about Exhibit 26?
13 A. Exhibit 27, it's definitely a copy of my 14 comments relevant to the procedure in question; however, 15 Exhibit 26 is not the procedure in question that these 16 comments were written for.
17 Q. Okay. And what is it about the procedure, 18 Exhibit 26, that tells you that is not the one? How-can 19 you determine that?
20 A. On the Nuclear Safety Evaluation, Section 21 3.1, the original procedure that I reviewed had 3.1 22 marked no and I challenged it as a 50.59 submittal by 23 stating that I believe it should be marked yes. j l
I 24 Q. And you were referring to what portion?
25- A. The Nuclear Safety Evaluation, page 2, Item '
166 1
i
1:
1 3.1, under "Important to Safety."
3 Q. I think, Mr. Parks -- correct me if I'm -
3 wrong -- look on the third page of the exhibit. They're e not numbered, but the third page in where it says, 5 " Nuclear Safety Evaluation Part III" in the upper 6 right-hand corner.
7 A. Okay.
8 Q. Do you see that Item 1 is checked no, and 9 that's what you addressed in your comments, isn't it?
10 A. See, you have a better understanding of the 11 procedures after four years than I do.
12 Q. Well, maybe I just looked at it a little 13 more closely more recently.
14 A. I would not doubt that either.
15 Q. Okay. Does that clear up the confusion in 16 your mind?
17 A. Well, I would still be --
18 MR. JOHNSON: He didn't say he was confused. Is 19 that the question? He didn't say he was confused.
20 THE WITNESS: I --
21 MR. HICKEY: No, he didn't say he was confused.
22 He indicated that he did not believe Exhibit 26 was the 23 document; but he indicated that based on what I 24 perceived to be some confusion about the pages, that's 25 why I phrased the question that way.
167
)
l l
1 BY MR. HICKEY: Q. What I really want to know,. l 2 is Exhibit 26 the document you commented on when you 3 wrote Exhibit 27? j 4 A. The polar crane load test procedure was the 5 procedure that I commented on; however, I still do not
- 6. believe that this was -- or is the copy of the version 7 that I reviewed when I made those comments simply 1
8 because, if memory serves me correctly at this moment, I
.9 was in a habit of identifying a procedure by its i
10- revision. number, also.
i 11' Here, the document, Exhibit 27, I do not 12 see anywhere on the document number that identified it 13 as a Revision 1 of the procedure; but I'm not trying to
- 14. contest it.
15' That was a procedure that I was reviewing.
16 Now, whether this is the accurate version of it, I don't 17 know.
l 18 Q. Now, Mr. Parks, let me see if we can't 19 clear up this matter.
20 On your Comment Resolution, Exhibit 27, you 31 identify the document you are reviewing as 23 UWI-4370-3891-83-PC01.
23 A. That's correct, sir.
'24 Q. And the UWI, that is, Exhibit 26, is 25 4370-3891-83-PC-1.
168
.1 A. Revision 1.
'2- Q. .That's the same number, isn't it?-
3 A. Yes, sir, they're exactly the same number;
- 4. but_they could be different revisions. That's the only L5 point I'm trying to make.
6 I cannot reasonably ascertain in my mind at 7 .this moment in time, based on my review of these two j I
8 documents, if document Exhibit 26 is the same copy of,a
{
'9 procedure that I reviewed that resulted in Exhibit 27.
10 That's the only thing I'm saying.
11 Q. And you're not certain because you didn't 12 write on Exhibit 27 anything about Revision 1, is~that 13- .it?
14 A. That's. correct.
'15 Q. Well, if someone was reading your comments, 16 would-they -- what would they assume about what document
'17 it referred to, Mr. Parks?
18 A. They would assume that it was this 1
19 document. Now, which.particular revision number would 20 have been -- would have been identified on my review 21 sheet if it was anything other than Revision O.
1 4
33 Q. You're saying you would have identified on 23 your review sheet?
24 A. Memory serves me at this moment in time 25 that I always identified which procedure I was -- which 169 1
l
1 revision number of the procedure I was reviewing.
=2 And I'm not trying to delay or anything, so 3 feel free to-go ahead and pursue your line of j 4- questioning.
5 (Whereupon Mr.-Richardson reentered the 6 deposition room.)
7 BY MR. HICKEY: Q. First of all, did you review 8 more than one polar crane load test UWI?
9 A. I may have. At the moment I can't recall 10 if I-did or not.
11 Q. Do you think you may have reviewed more 12 than one?
13 A. There may have been. I really can't recall 14 at the moment if there were more than one copy.
- 15. Q. All right. And as you -- I'm going to ask 16 you about your comments, as I think you anticipate.
-17 If, as you look at these comments and you 18- look at Exhibit 26, you feel that your comment is !
I
^
19 relating to some other document, you be sure and point 20 that out to us, won't you?
21 A. Sir, once again, to appreciate the 22 shortness of time to walk down this long road, I believe 23 Mr. Richardson and I pretty well covered these comments 24 in my civil case.
35 There may be specific questions that you 170
(
1 have.-that we did not cover.regarding a certain comment L
21 or- two.
'3 Q. I think, actually, there's quite a'few, 4 Mr. ' Parks; but why don't we embark and then we'll get 5 home sooner.
.6 Let me ask you to direct your attention to 7 'the first item on Exhibit 27,.your comment. Your-
'8 criticism or comment of the Nuclear Safety Evalua' tion 9 Part III --
that's Roman numeral III - Number 1 is that 10 the performance of'this load test increases probability 11' of. loss of coolant. accident, among others, evaluated in 12 FSAR.
13 And, therefore, this' Item 1 under Roman 14 numeral III should be marked yes instead of no; is that 1
15 right?
A. That's what it says.
17 Q. How did you make that review? How did you 18 make that determination or that performance of the load i 19 test increased probability of loss of coolant accident? ,
I 20 A. By reviewing the procedure.
l 21 Q. Did you look at the FSAR?
22 A. I believe I may have, if memory serves me !
l 23 correctly at this time.
24 Q. You say.you think you did?
25 A. Yes.
171
______--D
I 1 Q. And what did you look at the FSAR to l
2 determine?
3 A. Loss of coolant accident, loss of 4 shielding.
l 5 Q. I'm not getting that word.
6 A. Shielding.
7 Q. Shielding?
8 A. S-h-i-e-1-d-i-n-g.
9 Q. And did you attempt to determine whether 10 the possibility of an -- an increased possibility of 11 loss of coolant accident had been addressed anywhere 12 else in the review of the polar crane?
13 A. If memory serves me correctly at this time, 14 sir, I believe that my research revealed at that time 15 that all of the load drop analyses were probablistic and 16 that was all that was available, if that, and I 17 challenged the validity of probablistic studies.
18 Q. You say you do or you did?
19 A. That comment challenges it.
20 Q. I see.
l 21 You were writing this because although 22 there were probablistic studies, your view was that 23 those kind of studies were inadequate?
24 A. No, sir, I think you're oversimplifying my l
25 reply in that, number one, although the polar crane load 172
1 test was not addressed in the FSAR, loss of coolant 2 accident and loss of shielding test was. 1 3 Performance of the polar crane load test 4~ using missile shields definitely increased the 5 probability of having either a light load special shape 6 load drop or pressurizer surge line, which would result
-7 in not only a loss of coolant accident; but the ;
8 potential of loss of shielding accidents.
9 And su) I just did not'think at that time I 10 that we could offhandedly check that block as no and 11 ignore the increase of the potential for danger.
12 Q. What indicated to you that the block was 13 checked no offhandedly?
14 A. Because I thought, as it stands to reason 15 right here, that --
where does it say -- okay.
16 They addressed only the polar crane load
'17 test in both -- it was not addressed in the FSAR, the 18 technical evaluation report or the system description, 19 that's true; but the intent of the load drop -- I mean, 20 of the load test could result in a different accident 21 that I do not believe was considered and I do not 32 believe whoever checked that block gave it enough 23 thought and that's why I flaggod that comment requesting 24 that they reconsider.
35 Q. Do you know who did do the evaluation 173
1 that's reflected by the check in the block?
2 A. It says Dwight Walker, but I'm not so sure 3 that Dwight did it.
4 Q. Do you have some reason for thinking he did 5 not?
6 A. His name appears on the cover sheet; that's 7 the only thing that I'm using for information to l 8 determine who did make the evaluation.
9 Q. Okay. And you asked by your comment that 10 the matter be reconsidered?
11 A. Well, any time you put comments in writing 12 as part of your review, the comment does have to be 13 considered and an answer provided, whether it's accepted 14 or -- or rejected.
15 Q. Right. I'm just saying that was why you 16 did it, that was the purpose of making the comment?
17 A. Yes, sir, it was.
18 Q. Let me go back to one other thing you said.
19 You made a comment about these evaluations 20 being based on probablistic risk assessment, and you 21 didn't agree with probablistic risk assessment, if I 22 understood you correctly.
23 A. If I can recall correctly at this moment, 24 the only analyses that I was ever provided with or was 25 ever alluded to me that existed were of a probablistic 174
1 sort; in other words, saying probability of a load drop 2 accident is low and acceptable.
3 Q. Well, in the FSAR, as you reviewed it, did 4 you find that they had evaluated the possibility of a 5 load drop during the course of a Head Lift?
6 A. I don't think that that was covered in the 7 FSAR; but, there again, I don't recall at this moment.
8 I really don't.
9 Q. If it was covered, was it covered, as best 10 you know, by a probablistic risk assessment?
11 A. I really don't recall, not at the moment.
12 Q. What I'm getting at, wasn't the 13 probablistic risk assessment a common way of evaluating 14 risks in FSAR?
l 15 A. It seems to me at this moment that during 16 that time frame, the whole evolution of reactor vessel 17 head lift using a reactor building polar crane was under 18 review by the NRC.
19 The potential upgrading of the 20 classification had been not only important to safety, 21 but nuclear safety related.
22 And I was concerned, when I reviewed that l l
23 procedure, considering net end result of what that 1
24 procedure would be, that if we suffered a load drop !
25 accident and lost the shielding that was contained 175
I 1
- 1. within the reactor vessel, we could be infa lot.of 2 trouble; the people inside the containment would be in a 3 . lot of trouble, especially since we are -- have the 4 worst possible radioactivity levels.that a' plant could n
5 .have. We had a damaged core. i l
1 6 Q. What do you mean when you say they could be- l 7 in trouble?
8 A '. They could be dead.
9 Q. From what?
i 10 .A. Radiation exposure. I 11 Q. Because of the condition of the core?
12 A. If we lost all the shielding in the core,.
13 water level.
14 Q. Pardon me?
15 A. The water level.
16 Q. If you lost the water level?
17- A. Right.
.18 Q. Or the shielding?
19 A. The water level is the shielding.
20 Q. If you lost the water level in the core, 21 there could be excessive radiation that would -- that 22 would injure or kill the workers in the containment?
23 A. I think it would definitely overexpose 24 them.
25 Q. And you might lose the water level in the 176 1.
1 core by a drop of the missile shield; is that what your 2 concern is?
3 A. You know, it's like this, Mr. Hickey, I '
4 wasn't providing the answer; I was asking the question 5 to see if everything -- every aspect of it had been 6 thoroughly reviewed.
7 We were in a very uninsual and unique !
l 8 situation, and I think it merited extra review.
)
9 Q. Were you aware that the possibility of an 10 accident had been evaluated in the safety evaluation for 11 the polar crane load test?
12 A. Was I aware of what?
13 Q. That the possibility of an accident from 14 the load test had been evaluated in the load test safety 15 evaluation report.
16 A. I think at one point in time, I had 17 reviewed that procedure.
18 Q. What point in time are you talking about?
19 A. Probably prior to me reviewing this 20 procedure (indicating).
21 MR. JOHNSON: Do you mean by " procedure," the 22 safety evaluation report?
23 THE WITNESS: Right, I think that's where I came 24 up with the opinion that the load drop analyses were 25 probablistic. .
I 1
177
F BY MR. HICKEY: Q. And, therefore, in your view,
- unsatisf actory?
A. Not that they were unsatisfactory, sir, and 91 ease don't misconstrue that information. I felt that possibly a more in-depth review and analysis was required.
I was asking the question, not making a broad general statement.
Q. Okay. What happened to your question, do you recall, or the question that you were raising?
A. I didn't hear you, sir.
Q. I wanted to ask you what happened to your guestion.
A. Well, sir, I'd have to share the quandary sith you because I have never received an answer from anyone within GPU or Bechtel regarding that question.,
and it's been four years.
Q. Well, that's not completely accurate, is Lt, Mr. Parks? Let me see if I can refresh your recollection a little bit.
MR. HICKEY: I'll ask the reporter to mark as Exhibit 28, a memorandum dated February 28, 1983,
- transmitting to Mr. King --
BY MR. HICKEY: Q. That was your supervisor at
- he time, wasn't it, Mr. Parks?
178
1 A. That's correct.
2 MR. HICKEY: -- the Polar Crane Task Group's 3 resolution of Mr. Parks' comments.
4 (Whereupon Respondent's Exhibit 28 was 5 marked for identification by the Notary Public, and 6 attached hereto.)
7 BY MR. HICKEY: Q. Do you want to take a look at 8 that Exhibit 28, Mr. Parks, please.
9 A. I'll be happy to.
10 Q. And if -- for the moment -- if you'll focus 11 particularly on the first comment, which is the one 12 we're talking about.
13 A. I have reviewed the reply.
14 Q. In substance, what did they tell you?
15 A. They rejected my comment. And if -- if 16 memory serves you correctly, I rejected their rejection.
17 Q. Now, I think maybe you're --
18 MR. JOHNSON: You're one exhibit ahead of him.
19 MR. HICKEY: But I'm --
20 THE WITNESS: Probably skip up a couple.
21 BY MR. HICKEY: Q. I'm afraid your memory may be 22 suffering a little.
23 MR. HICKEY: Let me ask the reporter to mark as 24 Exhibit 29, a March 3, 1983 memorandum to Mr. Lake, 25 signed by Mr. Chwastyk; but the initials indicate 179
1 BY MR. HICKEY: Q. And, therefore, in your view, 2 unsatisfactory?
3 A. Not that they were unsatisfactory, sir, and 4 please don't misconstrue that information. I felt that 5 possibly a more in-depth review and analysis was 6 required.
7 I was asking the question, not making a 8 broad general statement.
9 Q. Okay. What happened to your question, do 10 you recall, or the question that you were raising?
11 A. I didn't hear you, sir.
12 Q. I wanted to ask you what happened to your .
13 question.
14 A. Well, sir, I'd have to share the quandary 15 with you because I have never received an answer from 16 anyone within GPU or Bechtel regarding that question, 17 and it's been four years.
18 Q. Well, that's not completely accurate, is 19 it, Mr. Parks? Let me see if I can refresh your 20 recollection a little bit.
21 MR. HICKEY: I',11 ask the reporter to mark as 22 Exhibit 28, a memorandum dated February 28, 1983, 23 transmitting to Mr. King --
24 BY MR. HICKEY: Q. That was your supervisor at 25 the time, wasn't it, Mr. Parks?
178
e i A. That's correct.
3 MR. HICKEY: -- the Polar Crane Task Group's 3 resolution of Mr. Parks' comments.
4 (Whereupon Respondent's Exhibit 26 was 5 marked for identification by the Notary Public, and 6 attached hereto.)
7 BY MR. HICKEY: Q. Do you want to take a look at 8 that Exhibit 28, Mr. Parks, please.
9 A. I'll be happy to.
10 Q. And if -- for the moment --
if you'll focus 11 particularly on the first comment, which is the one - - - - -
12 we're talking about.
13 A. I have reviewed the reply.
14 Q. In substance, what did they tell you?
15 A. They rejected my comment. And if --
if 16 memory serves you correctly, I rejected their rejection.
17 Q. Now, I think maybe you're --
18 MR. JOHNSON: You're one exhibit ahead of him.
19 MR. HICKEY: But I'm --
20 THE WITNESS: Probably skip up a couple.
21 BY MR. HICKEY: Q. I'm afraid your memory may be 22 suffering a little.
23 MR. HICKEY: Let me ask the reporter to mark as 24 Exhibit 29, a March 3, 1983 memorandum to Mr. Lake, 25 signed by Mr. Chwastyk; but the initials indicate 179 4
e
1 prepared by -- I mean, the initials at the bottom say, 2 "JJC/RP," which I'm going to ask the witness, but I 3 assume refers to Mr. Parks. That's 29.
4 (Whereupon Respondent's Exhibit 29 was 5 marked for identification by the Notary Public, and 6 attached hereto.)
7 BY MR. HICKEY: Q. Yes.
8 A. I have reviewed the comment in question.
9 Q. Mr. Radbill, in Exhibit 28, told you with 10 regard to this comment that the nuclear safety aspects 11 had been evaluated and that the safety evaluation report 12 had been submitted to the NRC for approval and comment, 13 so he's telling you why he didn't think this constituted 14 an unreviewed safety question; is that right?
15 A. That was his opinion, yes.
16 Q. All right. And then your response to it is 17 reflected on Exhibit 29?
18 A. That's correct.
19 Q. Is that a memorandum that you prepared for 20 Mr. Chwastyk's signature?
21 A. Yes, it is.
22 Q. And your comment on that issue was, quote, 23 "Do not disagree with your resolution. This comment is 24 better addressed by licensing than at the departmental 25 level."
180
~
1 BY MR. HICKEY: Q. And, therefore, in your view, 2 unsatisfactory?
3 A. Not that they were unsatisfactory, sir, and 6 please don't misconstrue that information. I felt that 5 possibly a more in-depth review and analysis was 6 required.
7 I was asking the question, not making a l
- 8 broad general statement.
9 Q. Okay. What happened to your question, do 10 you recall, or the question that you were raising?
11 A. I didn't hear you, sir.
12 Q. I wanted to ask you what happened to your 13 question. ..
14 A. Well, sir, I'd have to share the quandary 15 with you because I have never received an answer from 16 anyone within GPU or Bechtel regarding that question, 17 and it's been four years.
18 Q. Well, that's not completely accurate, is 19 it, Mr. Parks? Let me see if I can refresh your 20 recollection a little bit.
l 21 MR. HICKEY: I'll ask the reporter to mark as 22 Exhibit 28, a memorandum dated February 28, 1983, 23 transmitting to Mr. King --
24 BY MR. HICKEY: Q. That was your supervisor at 25 the time, wasn't it, Mr. Parks?
178
1 A. That's correct.
2 MR. HICKEY: --
the Polar Crane Task Group's 3 resolution of Mr. Parks' comments.
4 (Whereupon Respondent's Exhibit 28 was 5 marked for identification by the Notary Public, and 6 attached hereto.)
7 BY MR. HICKEY: Q. Do you want to take a look at 8 that Exhibit 28, Mr. Parks, please.
l 9 A. I'll be happy to.
10 Q. And if -- for the moment -- if you'll focus 11 particularly on the first comment, which is the one 12 we're talking about.
13 A. I have reviewed the reply.
14 Q. In substance, what did they tell you?
15 A. They rejected my comment. And if --
if 16 memory serves you correctly, I rejected their rejection.
17 Q. Now, I think maybe you're --
18 MR. JOHNSON: You're one exhibit ahead of him.
19 MR. HICKEY: But I'm --
20 THE WITNESS: Probably skip up a couple.
21 BY MR. HICKEY: Q. I'm afraid your memory may be 22 suffering a little.
23 MR. HICKEY: Let me ask the reporter to mark as 24 Exhibit 29, a March 3, 1983 memorandum to Mr. Lake, 25 signed by Mr. Chwastyk; but the initials indicate 179
r
]
l prepared by -- I mean, the initials at the bottom say, i
"JJC / R P , " which I'm going to ask the witness, but I assume ref ers to Mr. Parks. That's 29.
(Whereupon Respondent's Exhibit 29 was marked for identification by the Notary Public, and attached hereto.)
BY MR. HICKEY: Q. Yes.
A. I have reviewed the comment in question.
Q. Mr. Radbill, in Exhibit 28, told you with regard to this comment that the nuclear safety aspects had been evaluated and that the safety evaluation report had been submitted to the NRC for approval and comment, so he's telling you why he didn't think this constituted on unreviewed safety question; is that right?
A. That was his opinion, yes.
Q. All right. And then your response to it is reflected on Exhibit 29?
A. That's correct.
Q. Is that a memorandum that you prepared for Mr. Chwastyk's signature?
A. Yes, it is.
Q. And your comment on that issue was, quote, "Do not disagree with your resolution. This comment is better addressed by licensing than at the departmental level."
180
1 A. That's correct.
2 Q. Okay. So you had thought, as you explained 3 yourself earlier, that there should be some further l
l 4 looking at this issue. And this indicates that that l 5 looking was occurring and you uare satisfied with that?
6 A. No, sir, that's not what that indicates.
7 Q. Oh, all right.
8 A. It indicated that I did not agree with his 9 rejection and that I felt the only way to get it 10 resolved would be if it was handled at the licensing 11 level and not at our level.
12 Q. But what you wrote, Mr. Parks, was "Do not 13 disagree."
14 A. If I do not disagree, then I do not agree 15 either, do I?
16 Q. I don't understand that.
17 Are you saying that when you write, "Do not 18 disagree," that means, also, that you do not agree; is 19 that your testimony?
20 A. Sir, if I agreed with his reply, I would 21 have put down, " Agreed," as I did under my " Comment 22 Number 6 Resolution," response " Accept Resolution."
23 If I accepted the man's resolution on face 24 value as he's resubmitted to me, I would have accepted 25 it; but I could see immediately that we were not going 181
1 prepared by -- I mean, the initials at the bottom say, 2 "JJC/RP," which I'm going to ask the witness, but I 3 assume refers to Mr. Parks. That's 29.
4 (Whereupon Respondent's Exhibit 29 was 5 marked for identification by the Notary Public, and 6 attached hereto.)
7 BY MR. HICKEY: Q. Yes.
8 A. I have reviewed the comment in question.
9 Q. Mr. Radbill, in Exhibit 28, told you with 10 regard to this comment that the nuclear safety aspects 11 had been evaluated and that the safety evaluation report 12 had been submitted to the NRC for approval and comment, 13 so he's telling you why he didn't think this constituted 14 an unreviewed safety question; is that right?
15 A. That was his opinion, yes.
16 Q. All right. And then your response to it is 17 reflected on Exhibit 29?
18 A. That's correct.
19 Q. Is that a memorandum that you prepared for 20 Mr. Chwastyk's signature?
21 A. Yes, it is.
22 Q. And your comment on that issue was, quote, 23 "Do not disagree with your resolution. This comment is 24 better addressed by licensing than at the departmental 25 level."
180
l 1 A. That's correct.
2 Q. Okay. So you had thought, as you explained 3 yourself earlier, that there should be some further 4 looking at this issue. And this indicates that that 5 looking was occurring and you were satisfied with that?
6 A. No, sir, that's not what that indicates.
7 Q. Oh, all right.
8 A. It indicated that I did not agree with his __ ,
9 rejection and that I felt the only way to get it ,
10 resolved would be if it was handled at the licensing 11 level and not at our level.
12 Q. But what you wrote, Mr. Parks, was "Do not 13 disagree."
14 A. If I do not disagree, then I do not agree 15 either, do I?
16 Q. I don't understand that.
17 Are you saying that when you write, "Do not 18 disagree," that means, also, that you do not agree; is 19 that your testimony?
20 A. Sir, if I agreed with his reply, I would 21 have put down, " Agreed," as I did under my " Comment 22 Number 6 Resolution," response " Accept Resolution." -
23 If I accepted the man's resolution on face l
l 24 value as he's resubmitted to me, I would have accepted l
25 it; but I could see immediately that we were not going 1
181
1 to get anywhere on that comment and the only way to 2 handle that comment was to boost it upstairs.
3 Q. So your testimony is that when you wrote, 4 "Do not disagree," you meant that you in fact did 5 disagree?
6 A. I meant that I felt licensing chould take a 7 look at it and resolve it because he was of one opinion; 8 I was of another.
9 Q. And df3 licensing look at it, Mr. Parks?
10 A. I could only assume that they did. Let me 11 rephrase that. If memory serves me correctly at the 12 moment, up t:ntil the time that I was escorted off the 13 job site by my Bechtel employer, to my knowledge 14 licensing had never came to a clear-cut decision 15 regarding whether it was a 50.59 submittal or not. If 16 licensing had, I was unaware of it.
17 MR. HICKEY: Okay. I'm going to ask the reporter 18 to mark as Exhibit 30, this Revision 4 of the polar 19 crane load test procedure.
20 (Whereupon Respondent's Exhibit 30 was 21 marked for identification by the Notary Public, and 22 attached hereto.)
23 BY MR. HICKEY: Q. Showing you what's been 24 marked as Exhibit 30, Mr. Parks, let me direct your 25 attention to the -- to the third page of that document.
182
l l
1 At the bottom of the page, that's the page J l
2 that has Part III of the Nuclear Safety Evaluation. l 3 A. Yes, I see that.
4 Q. And you see where the checks in the boxes ;
5 are the same noes that they were on the earlier version.
6 A. I see that, also.
7 Q. And do you see the approval at the bottom 8 by the manager of TMI-2 licensing Mr. Byrne, dated 9 3/18/837 10 A. Yes, I see that.
11 Q. Is it your testimony that you don't 12 remember being aware of this as of March 23rd?
13 A. That's exactly correct, sir, because I 14 reviewed and signed this procedure, with limited 15 proviso, on the 17th of March.
16 Jim Byrnes signed it and approved it on the 17 18th of March. I never saw that procedure again.
18 Q. But did you learn what Mr. Byrne had done 19 with it, before you left the Island, I mean?
20 A. Sir, after I signed that provision -- that 21 procedure, I had nothing left to do with anything on the 23 job site except go in and sit at my desk all day long.
23 Q. I don't think that's quite responsive to my
- 24. question, Mr. Parks.
25 Did you ask Mr. Byrne, at any time before 103
1 you left the Island, whether -- whet action he had taken 2 on this question?
I 3 A. No, sir, I did not.
4 Q. And you didn't learn in any other way what 5 action Mr. Byrne had taken prior to your leaving the 6 Island?
7 A. No, sir.
8 Q. Why didn't you ask Mr. Byrne?
9 A. After March 17th, when I was relieved of i
I 10 any responsibility associated with the reactor building 11 polar crane, I felt I just better find a nice little 12 hole and hide.
13 Q. Do you mean that you were no longer 14 interested in knowing what Mr. Byrne in licensing was i
15 going to do with your request for further evaluation? !
I 16 A. Sir, up until that point, es e,y time I had ;
-l 17 approached management to get any response to any of my l 18 concerns, it only exacerbated the retaliation and 19 harassment that I was experiencing.
20 You can only beat your head against the j 21 wall for so long until you finally realize that it l l
22 hurts. 1 0
23 Q. Did you go to Mr. Byrne at all, Mr. Parks.
I 24 from the date you issued your comments on March 17th?
25 A. No, I did not.
184
1 Q. Did you ask Mr. Marshall to check with him 2 for you?
3 A. No, I did not, not that I can recall at 4 this moment.
5 Q. Do you know, by the way, whether the -- oh, 6 you see on this exhibit that we were just looking at, 7 that the chairman of the PORC also concurred in the i 8 review, the approval that had been done by Mr. Byrne of 9 licensing? Do you notice that there at the bottom? '
10 A. Yes, sir, I noticed that he had done that 11 after I was escorted off the job site.
12 Q. Yes.
13 And Mr. Marshall, Bubba Marshall of site 14 operations, he was serving on the PORC at the time as 15 vice-chairman, was he not?
16 A. I don't really recall if he was or not.
17 Q. You do recall him being on the PORC at some 18 time?
19 A. If memory serves me correctly, Bubba was a i 20 *.
vice-chairman of PORC at one time or another.
l l 21 Q. And do you know what the NRC did with 22 regard to the safety evaluation of the load test?
23 A. I believe, sir, they eventually approved 24 it.
25 I am also of the belief that sometime in 185
1 July of 1983, the NRC person assigned to review my 2' affidavit concurred that the way the polar crane and the 3 procedures and the documentation existed at that time, 4 July of 1983, that it did constitute an unreviewed 5 safety question.
6 Q. And who are you referring to?
7 A. I don't remember the gentleman's name; but 8 the report in that statement was contained in the OI 9 submittal dated September 1st, 1983.
10 Q. Well, if I understood you correctly, you 11 were saying, as you expressed yourself earlier, that you 12 simply thought the matter ought to be looked at again; 13 but you didn't have a real position about whether it was 14 an unreviewed safety question or not, but you thought it 15 ought to be looked at more carefully?
16 A. Yes, sir, I felt it should be looked at 17 more carefully.
18 Q. Well, that happened, didn't it, Mr. Parks?
19 A. The results show that someone evaluated it.
20 Q. Several someones, the licensing department, 21 which is who you wanted to evaluate it, right?
22 A. Right.
23 Q. The NRC evaluated it, right? The PORC 24 evaluated it, right?
25 A. Right.
186
1 Q. Did TWG evaluate it?
2 A. Yes, eventually.
3 Q. Let me ask you to look briefly at your -- I 4 think you can do some of this in less detail.
5 If you'll look at your comments, please, on 6 the February 17th exhibit. Your Comment Number 2 7 addresses the need for test working group or TWG 8 approval of this procedure; is that right?
9 A. That's correct.
10 Q. And do you recall -- or, if not, you can 11 look at the procedure -- who were the primary TWG l
12 members that were required -- that served on TWG?
13 A. Are you asking me do I recall the 14 individuals' names?
15 Q. No, not really; the positions.
16 A. There would have been site operations, 17 plant engineering, recovery engineering or site 18 engineering -- they were synonymous -- QA, and I don't 19 remember the other group. s 20 Q. Startup and test?
21 A. Yeah, startup and test, a very obvious one 22 to forget.
23 Q. Okay. And if you look at the approval 24 sheet for the load test procedure --
25 MR. JOHNSON: Which exhibit is that?
187
1 MR.~ HICKEY: Well, I guess the one that he ought 2 to look at is 26.
3 BY MR. HICKEY: Q. -- aren't those positions 4 listed on the, approval sheet, with the exception'of 5 plant operations?
6 MR. JOHNSON: Where should he be looking?
7 MR. HICKEY: Sure, it's the fourth page in 8 Exhibit 26, fourth page.
9 MR.. JOHNSON: Okay. Thank you.
10 BY MR. HICKEY: Q. Let me. break the question 11 down. Maybe.it will be easier for you to handle that 12 way.
13 You said, Mr. Parks, a moment ago, that one 14 of the persons -- one of the positions on the TWG who l
15 would be, in your judgment, required to review this j 16 procedure would be the startup and test manager. )
17 And you see that there is an approval l
18 signature for the startup and test manager on the 19 procedure, right, and it's signed by Mr. Kitler on 20 February 16th? j 21 A. That's correct.
22 Q. And you also mention that the plant 23 operations -- I'm sorry, plant engineering manager was 24 another TWG member who would be required to sign off.
25 And although he hasn't signed it yet, 188
)
l
__1___ .
.l
1 there's a place for the plant engineering approval on 2 this form, also, is there not?
3 A. There is, but your answer -- your -- your 4 statement is incorrect. The plant engineering manager 5 is not a member of TWG, nor is site engineering manager 6 a member of TWG.
7 Q. I didn't think I said site engineering.
8 You said recovery engineering manager or site 1
9 engineering, I thought.
10 And I thought what you meant by that was 11 that there had been some change in the positions.
12 A. I guess to answer your question, sir, that 13 although the departments are represented on that cover 34 sheet, TWG membership is still not represented. And TWG 15 was required by our procedures to review and approve 16 that procedtce.
17 Q. I just want to understand the comment that 18 you're making.
19 You're saying that there was a need for a 20 meeting by the same people who otherwise would be 21 approving it, but in their specific role as TWG members; 22 is that right?
23 A. To comply with the procedures, yes.
24 Q. Okay. And then you comment, in Item 3, 25 that the procedure does not conform to AP 1047 --
189
1 A. Correct.
2 Q. -- in format compliance.
3 MR. JOHNSON: Where are you reading?
4 THE WITNESS: Off the comments.
5 MR. HICKEY: Off his comments.
6 BY MR. HICKEY: Q. And does that format 7 requirement apply only to functional tests?
8 A. At this moment, sir, I could not recall and 9 tell you if it does or not.
10 (Discussion between Mr. Hickey and Mr.
11 Lewis.)
12 MR. HICKEY: I don't know if it's the hour or the 13 heat; but let me suggest, in the interest of the witness 14 and counsel, let's take about a five-minute break and I 15 will try to collect my thoughts and the witness can get 16 some fresh air and maybe we can move a little more 17 expeditiously. I'm finding it very warm.
18 (A recess is taken.)
19 BY MR. HICKEY: Q. Mr. Parks, if you'll look at 30 your Comments Number 2, 3 and then 10, 11 and 12, let me 21 ask you if they don't all generally assert that the load 22 test procedure does not comply with Administrative 23 Procedure 1047.
24 MR. JOHNSON: Can you read that? The copy that 25 you gave him is not a very good copy. Can the witness 190
1 read the comments there?
2 THE WITNESS: Barely; but, yes, I would say that 3 they all tend to imply that the. procedure, as it existed 4 at that time, did not comply with AP-1047.
5 BY MR. HICKEY: Q. Okay. And the -- apart from 6 the -- Item 2, second comment, which we just talked 7 about regarding the TWG review, the others --
8 (Whereupon Mr. Richardson left the 9 deposition room.)
10 -BY MR. HICKEY: Q. --
3, 10, 11 and 12; 3 i
11 relates to the procedure not being in the proper format, 12 correct?
13 A. That's what it relates to, yes.
i 14 Q. And 10 is to who has to do the sign-off on L 15 the procedure.
16 And your point is that that has to be done 17 by a qualified startup and test engineer, right?
18 A. Correct.
19 Q. And then for 11 and 12, those are two more ;
i
.l 20 format points, are they.not; namely, that there needs to {
l 21 be a completion of a particular block on the form that i 22 was checked and there needs to be section headings j 23 included in the procedure, right?
24 A. Without reviewing the associated sections 25 of the procedure, that's what the comments appear to 191
1 reference, yes.
2 Q. Just going through the rest of them here, 3 Mr. Parks, so that I'm clear on them, the comments that 4 you made as to Item 11 and 12 --
5 (Whereupon Mr. Richardson reentered the 6 deposition room.)
7 BY MR. HICKEY: Q. --
those comments were 8 accepted, were they not?
9 A. I'd have to look back through the other 10 documents to find out.
11 Q. Yeah, I misstated, excuse me.
12 MR. JOHNSON: Let's see, looking at which exhibit 13 would he find whether they're accepted or not? V 14 MR. JOHNSON: Is that Number 28?
15 MR. LEWIS: I believe it's 28, yes.
16 BY MR. HICKEY: Q. 28 is Mr. -- is the February 17 28, 1983 response, and that says they accepted comments
- 18 3, 6, 11, 13 and 14, right?
19 A. Right.
20 Q. Okay. And I assume you agreed with all of 21 that since they were accepting the points you had made?
- 22 MR. JOHNSON: Could you run those by us again, 23 the numbers? d 24 MR. HICKEY: Sure, 3, 6 -- I didn't state it 25 accurately again. I apologize.
192
1 BY MR. HICKEY: -Q. Comment 3, you did not accept 2 their comment; you disagreed. I was trying to reduce 3 the scope by eliminating the ones that you agreed to, 4 Mr. Parks, and, that is, Item 6 and Item 11, 13 and 14.
I 5 MR. JOHNSON: 11, 13 and 147 6 .MR. HICKEY: Yes.
7 THE WITNSSS: Right.
l 8 BY MR. HICKEY: Q. So as to those, 6, 11, 13 and I 9 14, .they accepted your comments, and you agreed with 10 their acceptance of your comments?
l 11 A. That's correct. l l
12 Q. Now, the review procedure, as it was set up 1
- 13. at the time, required, as you testified earlier, the ]
14 response -- a response to be made to yo0r comments.
15 And that was transmitted by Mr. Radbill's 16 comments in the memorandum of February 28th that we just 17 looked at, right?
18 A. Right.
19 Q. The action by you responding to that on 20 March 1, in the form of a memorandum signed by Mr.
21 Chwastyk, also gave you the opportunity to evaluate what i
i 23 Mr. Radbill'had said? j 23 A. That's correct. '
24 Q. And, in the meantime, between your original 35 February 17th comments and your March 1 memorandum, 193
l' there had been some meetings to address your comments, !
2 had there not?
3 A. If memory serves me correctly at the time, 4 there was, yes.
5 Q. Specifically, you met with Mr. Dallard, the 6 QA manager, on February 23rd; and the day before that, 7 there was a meeting on February 22nd with a number of -
8 participants to discuss your comments?
9 MR. JOHNSON: Could you break it down if you're 10 going to be asking him to affirm anything?
11 MR. HICKEY: Sure.
12 BY MR. HICKEY: Q. Did you attend a meeting on 13 February 22nd to discuss your comments, Mr. Parks?
14 A. Yes, sir, I did.
15 Q. And again on February 23rd with Mr.
16 Ballard, the QA manager?
17 A. I met on February 23rd with a number of '
18 people.
19 Q. Yes.
20 A. One of which was Mr. Ballard.
21 Q. All right. Mr. Ballard indicated on 32 February 23rd his view that the load test procedure was 23 covered by 1047, did he not?
24 A. If memory serves me correctly at this 25 moment, I believe he expressed such an opinion. I think s
194
.1 that should'-- there should be some amplification 2 . applied =to that.
3' I think it'should be more stated that Mr.
4 Ballard was of the belief that that procedure should 5 have been under the auspices of AP-1047.
6 Q. What is the distinction you're making?
7 A. Well, I think it would be open to 8 interpretation as the way your question was with me 9 giving you a flat answer.
- 10. I think your question with my. response as
- 11. it stood could have been misconstrued that ~ that 12 procedure as it stood satisfied AP-1047, which, in 13 effect, it did not satisfy AP-1047.
14 Q. Oh, let me make sure I make it clear.
15 I meant to ask you -- strike that.
16 I was inquiring about Mr. Ballard's view at 17 the' February 23rd meeting. And I believe that on l
18 February 23rd, Mr. Ballard indicated that compliance 19 with 1047 was required.
20 A. That's correct.
21 Q. Didn't you point out, Mr. Parks, that the
- 22. load test could legally be performed as a construction
-23 test?
24 A. I don't think you're --
I guess what I'm 25 trying to say, sir, if memory serves me correctly, I 195
'l think you're mischaracterizing what I said could be 2 done.
3 Q. What did you say could be done, do you 4 recall?
5 A ., Without reviewing any additional documents, 6 relying totally on my memory at this moment, I believe I 7 suggested to attendees of tia a t meeting that, yes, we 8 could perform it as a construction test and then after 9 we turn it over, we'd have to repeat it as a function 10 test; but I may be wrong. My memory is pretty vague on 11 that point.
12 Q. I'm looking at page 25 of your affidavit, 13 the bottom half of the page.
14 Does that refresh your recollection, Mr.
15 Parks, about whether you suggested that the test could 16 be classified as a construction test?
17 A. That's what it says in my affidavit.
18 Q. And your further response was that if it 19 was so classified, then after turnover, there would need 20 to be either another functional test or else review of 21 the procedure by the test working group prior to 22 turnover, right?
23 A. I believe that's what the affidavit says, 24 yes.
25 MR. JOHNSON: Would it be possible to have that 196
1 question read back? s, 2 (Record read.)
3 MR. JOHNSON: Are you satisfied that you 4 understood the question?
5 THE WITNESS: Not really.
6 MR. JOHNSON: Could you repeat that? I really 7 had a great deal of difficulty following what you were 8 trying to get at -- get there.
9 MR. HICKEY: Off the record a minute.
10 (Discussion held off the record.)
11 MR. HICKEY: I think this is the prudent way to 12 proceed.
13 MR. JOHNSON: Okay.
14 15 (DEPOSITION ADJOURNED. TO BE CONTINUED ON 16 TUESDAY, JUNE 23, 1987, AT 9:00 A.M.)
l 17 j -
18 19 20 21 22 23 26 25 197
DECLARATION UNDER PENALTY OF PERJURY I HEREBY DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT.
SUBSCRIBED AT ,
CALIFORNIA, THIS _ DAY OF . ,
198 .
RICHARD DALE PARKS 198
STATE OF CALIFORNIA )
) SS:
COUNTY OF ORANGE )
I, Rosemary Schwartz, CSR #4836, a Notary Public of the State of California, do hereby certify:
That the witness named in the foregoing deposition, prior to being examined, was by me first duly sworn; That said deposition was taken before me at the time and place herein set forth and was taken down by me in shorthand and thereafter transcribed into typewriting under my direction and supervision; That said deposition is a true record of the testimony given by the witness and of all objections made at the time of the examination.
I further certify that I am neither counsel for nor related to any party to said action, nor in anywise interested in the outcome thereof.
IN WITNESS WHEREOF, I have subscribed my name and affixed my seal this 29th day of June 1987.
i.i NOTARY PUBLYC FOR THE STAKE OF CALIFORNIA i
.n\nnnd@@%i!\libilliikil;lgifinigsguklWanaiku
' O. ROSEMARY SCHWARTZ g4 . NOTARY PUBUC CAUFORNIA ORANGE COUNTf My comm. exones FE.8 6.1988 ',
e gEmmmmmummummum mmumiimummummmmumummmmumi 199
1 l
ORIGINAL UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ADMINISTRATIVE LAW JUDGE
\
IN THE MATTER OF GPU NUCLEAR CORPORATION, Docket No. 50-320 THREE MILE ISLAND NUCLEAR Civil Penalty S ION NO. 2 License No. DPR-73 EA 84-137 l
EXHIBITS TO THE DEPOSITION OF RICHARD DALE PARKS l June 22, 1987 VOLUME I (Exhibits 1 - 15) l BARKLEY COURT REPORTERS 4000 MAC ARTHUR BOULEVARD, SUITE 5500 REPORTED BY: NEWPORT BEACH, CALIFORNIA 92660 i (714)752 1090 1 ROSEMARY SCHWARTZ, j CSR #4836 2566 OVERLAND AVENUE, SUITE 570 )
- FILE NO.87-242 LOS ANGELES, CALIFORNIA 90064 (213)202-6666
Novanbar 3,1980 CORPORATION 4 AESEARCH PLACE ROCKVILLE. MAAYLANO 20050 301 948 7010 r
Subject:
TMI Assignment Status To: G. Meyers From: R. Parks Since my arrival on site I have been assigned to the Startup i Test Section in Unit II. My primary responsibility has been the research and development of Functional Test Procedures for the Submerged Demineralized System. Secondary responsibilitir'.s include '
the functional testing of other installed plant recovery systems (ie: Mini Decay Heat Removal, Sample System, etc.) and their turn-over to plant operations staff.
Following is a breakdown of assigned tasks to date, (85 work days since my assignment to SUT section).
Familiarization - 10 WD 4 MDHR/ Sample System Testing - 20 WD l
SDS System Functional Test Development - 20 WD Upon the completion of this first draft of Systen Functional ,
Test, it was decided that the test as written was to complex and was broken into five (5) major tests. Following is a breakdown of these procedures and their status (35 WD expended to date).
I SDS Off-Gas System Functional Test - 20 pg. Test Document i that establishes normal system operational parameters and functionally tests system. Approved by Plant Operations Review Committee (PORC).
SDS Dewetering System Functional Test - 30 pg. Test Document that establishes normal system operational parameters, function-ally tests the system and verifies capabilities to meet D.O.T.
and NRC shipping regulations for free standing water. Rev. 1 !
is out for review prior to PORC submittal on 11/10/80.
I SDS Leakage Containment System Functional Test - 20 pg. Test Document that establishes normal system operational parameters and functionally tests the system. Rev. I has been reviewed and submitted to PORC for approval. j
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OR IDENTIFICATION ROSEMARY SCHWARTZ N.P.
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0 Pcg2 2 ht:lF%6ftJiliill 1 CORPORATION M ASSEAACH P% ACE mOCKylLLE. MARYLAND 20050 301 948-7010 SDS Process Flow Functional Test - 70 pg. Test Document that is the controlling administrative test for the system as built. Establishes normal system operational parameters, functionally verifys system design capabilities, process design capabilities, operational capabilities of various support systems, etc. Rev. 1 of this procedure is presently i
out for review prior to PORC submittal of 11/24/80. .
SDS Feed Pump Functional Test - 10 pg. Test Document that establishes normal system operational parameters and func-tionally tests the feed system as built. Rev. I will be distributed for review on 11/17/80.
The review process for each of these procedures is as follows:
Rev. 0 - reviewed by eleven (11) on site departments /organiza-tions.
Rev. 1 - reviewed by same parties in Rev. O with all comments resolved.
Submitted to PORC for approval with Rev. I comment resolution.
During a " normal" work week approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> are expended !
for attendance of engineering meetings on the SDS system and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> i for syste= valkdown/ f ollowing of construction. Secondary responsi- !
bilities are performed on a not-to-interfere basis with primary responsibilities. My conversations with Mike Herlihy, has established that he fully intends to have the NUS personnel assigned to his group perform the functional testing of SDS also. q Functional testing is presently scheduled for completion in f February 1981, but I feel April 1981 will be a more accurate date. {
He has stated that he feels our services will be required at least until June 1981. I hope this report will serve to acquaint you better with my responsibilities and my expected availability date as )
it presently stands. )
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NO VI E MA Y NO 20850 F R IDEN C Tid 5 301 948-7010 ROSEMAR SCHWARTZ, N.P.
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tNUSCORPORATION INTERNAL CORRESPONDENCE o AESEAACM PLACE AAYLAND 20850 To: S. B. Presgrove DATE: July 31, 1981 FROM: R. Parks COPIES:
CUJJECT: ACTIVITIES ACCOMPLISHED ON SITE 7/80 TO 7/81 Following is a composite list of my activities accomplished during the last year on site. This data is being provided in two separate listings, the first being a listing performed during months of June and July this year (coincides with my tenure as Acting Startup Test Manager),
the latter being a listing of items accomplished during the last year.
June - July 1981 A. Test Manager - Unit II
- 8. Acting Startup(normally hold TWG Chain.an alternate posttion)
TWG Chainnan l 1. Completed Close Out Acceptance Testing for SDS
[ System.
I
- 2. Completed all Construction Test Data Review with affiliated Engineering Departments for SDS Con-
! struction Testing.
- 3. Completed TWG review, resolution and acceptance for all SDS Functional Testing.
- 4. Completed SDS Final Turnover (Phase I & II).
S. Completed Final Turnover on WG-61 (Sump Sucker System).
- 6. Completed Final Turnover on PWST's (WG-24).
July 1980 - July 1981 A. Authored the following procedures:
1
- 1. Leakage Containment Flow Manometers In Service Flow Checks (SDS-45) --- working.
- 2. Post Filter Back Flush Functional Test (SDS-44) ---
l working.
- 4. SDS Turbine Flow Meter / Utility Piping Functional Test (SDS-42).
- 5. SDS Intermediate Level Sample Lines Hydro (SDS-41).
l 6. SDS Turbine Flow Meter Piping Hydro RO,1 (SDS-40).
l 7. SDS Turbine Flow Meter Piping Hydro R1 (SDS-40).
- 8. SDS Prefilter Vessel Hydro (SDS-39).
- 9. SDS Spent Vessel Handling Tool Press. Test (SDS-38).
R / IBIT. ...
FOR IDENTIFICATION ROSEM Y SCHWARTZ, N.P.
... . . . . . . . ... . I 9 . ..
_ _ _ _ _ _ _ _ _ _ _ _ _ L
i l.E Page -'": ._
CX3RPCFLAT10N
$$55*** 1
- 12. Dewater Station Piping Vent Line Press. Test (SDS-35).
- 13. Hi Rad Feed Glove Box Press. Test R1 (SDS-09).
- 14. Warehouse #3 Fire System Hydro. .
- 15. Warehouse #2 Fire System Hydro. .
- 16. Elec. Warehouse Fire System Hydro.
- 17. Stanp Sucker Tie-In Pressure Test (SDS-33).
Test (SDS-31).
- 19. Surface Suction Purnp Test (SDS-27).
I 20. Off-Gas Separator Level Test (505-24).
- 21. Off-Gas Discharge Piping Pressure Test (SDS-10).
- 23. Demin Water Feed to Warehouse #3 Hydro.
- 24. SDS Hose Hydro (SDS-16).
- 25. Fire Protection Feed into Warehouse #3 Hydro.
- 26. BWST Drain Piping Hydro.
- 27. WG-P-1 Functional Test (cancelled - rewritten by Dan Salim - cancelled again).
- 28. Generic Hydro Test Procedure. 1 1
- 29. SDS Feed Pump Functional Test R0 & RI. l
- 32. SDS Dewatering System Functional Test R0., R1.
- 34. SDS Off-Gas System Functional Test R0, R1, R2. ;
- 35. Mini Decay Heat System Functional Test. i i
- NOTE: Each procedure notated required rewrite of Functional Test Procedure due to design changes in system.
B. Authored the following Departmental Procedures / Schedules:
- 1. 5U&T Training Program Draft. ;
i
- 3. SDS System Turnover Boundaries Identification List. l
- 4. SDS Test Sequence Document.
, S. Generic Hydro Procedure. l l 6. Construction Test Package (Mechanical).
l l
l
~
e Page CORPORATION NEdETE" * **
C. Other Responsibilities: l
- 1. Review of ECM's for Retest Assignments (on-goirg assignm::nt).
- 2. Participated in MDHR, SDS and other Task Testing .
(on-going). ,
- 3. Department representative in various meetings, functions, etc.
- 4. Provide support as necessary/ requested to Recovery Operations Director in capacity of Operations Engin-eer (future permanent assignment).
5 Responsible for all SDS Retest Assignments.
- 6. Post Accident Testing (Backfit) on-goin
- 7. Turnover of WG-11 (Site Sample Trailer)g. completed.
- 8. SU&T Good Housekeeping Inspection.,
RP/ro I
l
n.J4 -
NUS CORPORATION oaereames % Ace INTERNAL CORRESPONDENCE iSoTNs.'ioMo"******
To: S. B. Presgrove DATE: August 25, 1981 FROM: R. D. Parks COPIES:
WNECT:
Activities Perfomed During August,1981 Following is a list of activities perfomed/ assignments accomplished during the period 8-1 to 8-31,1981 (last report date 7-31-81). ~
- 1. Procedures written -
- a. SDS-40 R1 (Turb. Flow Meter Hydro Test).
NOTE: SDS-40 RO revised to incorporate modifications
(
incorporated into system design following approval i of SDS-40 R0.
b.
SDS-45 (Prefilter Inlet Hansen Tool Pneumo Test). i NOTE: This procedure number previously reported as Leakage Containment Flow Mar.ometers in service flow checks. However, SDS-44 (previously reported I
as Post Filter Back Flush Functional Test) was cancelled and test number assigned to Leakage L Containment In Service Flow Checks.
i
- c. SDS-46 (Sump Pumps Operability Test).
j d. SDS-47 (Monitor Tanks /Epicore Tie In Piping Hydro),
- e. WG-64-01 (WDL-V1175 Hydro - U1/U2 Segregation).
- 2. Resolved coments/obtained approval for:
- a. SDS-40 RO
- b. SDS-40 R1
- c. SDS-41 I
- d. SDS-42 1
3
- e. SDS-43 f* SDS-44 retr.j FOR IDENTIFICATION i
'50SEMARY SCHWARTZ, N.P
- g. SDS-45 ,_, igQ
..A/Ah ,
- h. SDS-46
- 1. SDS-47
_.._____________.______________________s
'o d Page CORPORATION
$?!$?T S' **
- 3. Perfonned following tests:
- a. SDS-21 R1 (Plugging / vent tools portion).
- b. SDS-40 R1 l
- c. SDS-42
- d. SDS-44
- e. SDS-45 (scheduled for week of 8/24/81)
- f. SDS-46 9 SDS-47 (scheduled for 8/25/81)
- h. Monitor Tank Piping Modifications In Service Leak Test (1410-Y-52) i
- 1. SDS Service Air In Service Leak Test (1410-Y-52)
- 4. Walkdown/ turnover of TS-42 (BWST enclosure) to plant staff.
- 5. Turnover of SDS Outage Mods to plant staff - on-going.
- 6. Retest assignments SDS/non-SDS - on-going. )
/ $
R'. D. rks RDP/ro ;
I i
A t NUS CORPORATION o ACEAACM PLACE INTERNAL CORRESPONDENCE EM."i$$"* ""
TO: S.B. Presgrove OATE: October 1,1981 FACM: R.D. Parks 1 COPIES.
CU~2 JECT: ACTIVITIES PERFORMED DURING SEPTEMBER,1981 l
1 Following is a list of activities perfonned/ assignments completed during the period 9-1 to 9-30,1981 (last report date 8-25-81). ;
l
- 1. Procedures written and approved.
- a. TS-158-01 --- NR Pump Piping Hydro
- b. TS-158-02 --- NR " " "
- c. TS-158-03 --- NR
- d. TS-158-04 --- NR G. SDS-44, Rev. 1 ---
Leakage Containment Flow Determination (new pump)
- 2. Procedures in process.
- a. MTX, Revision 2
- 3. Tests performed.
Feed Manifold Flush Connection In Service Leak Test (1410-Y-52)
- 4. Completed Turnover of SDS Outage Modifications to Plant Staff.
- 5. Turnover of TS-42 (BWST Enclosure) - on going.
- 6. Commenced Turnover Preparation for following tasks.
TS-48 WG-59 WG-63 l WG-64 i LM-35 1 TS-114 through TS-166 (Total of 40 Tasks) !
i
[,f,l / XHIBIT., .
FOR IDENTIFICATION ROSE Y SCHWARTZ, N.P ]
. .M.b 19 .
1 i
L-_____--_____-_ -
) 6 WNUS CORPORATION 4 AESEAACH PLACE
- 1 KV LL AYLAND 20B50 S.B. Presgrove October 1,1981 Page Two
- 7. Retest Assignments SDS/Non-SDS; on going
}
- 8. Four (4) sick days this report period.
- 9. Trip to Allentown, PA to obtain new Manifold Strnp Pump Check Valves.
lo . AT S o kT %s ud H. t4e>1j M& b
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I
tNLES CORPORATION o REZEAACH ALACE INTERNAL CORRESPONDENCE AOCKveLLE. MAAYLANO 20850 1301)948-7010 TO: S. B. Presgrove DATE: ; October 28, 1981 FAOM: R. D. Parks COPIES:
CU2 JECT: Activities Performed During October 1981
- 1. Procedures written / issued for approval:
- a. Master Test Index, Rev. 2 .
- b. SDS Ion Exchange Vessel (D-00001) Hydro Test '
- 2. Procedures in Process:
- a. AP-1043 (Work Auth. Proc.) Rev. 2
- 3. Tests Performed: I I
- a. 1410-Y-52 (Mech. Insp.) for Turnover Packages listed in #6.
- 4. On-Going Turnovers:
- a. TS-42 (BWST Enclosure)
- 5. Turnovers completed - none.
j
- 6. Turnover packages issued:
- a. TS-48 (Fire Systesm Modifications)
- b. Misc. Electrical (consists of 19 individual modifications packages).
- c. Misc. Structural (Consists of 8 individual modifications packages).
- d. Ul/U2 Separation (consists of 2 individual modifications packages).
- e. Misc. Piping Mods (consists of 8 individual modifications packages).
- 7. Retest assignments SDS/non-SDS - on going, reviewed and assigned retest re-quirements for 16 ECM's.
- 8. Miscellaneous:
- a. 2-day trip to Shoreham Nuclear Gen. Station.
- b. Acting Startup and Test Manager. .
- c. QA audit of department completed. Responses to finding on-going. Copy of findings attached.
~~1 A~
R.1 1/ s i t RDP:bh Attachment [
/t HIBIT.h-FOR IDENTIFICATION ROSEM RY SCHWARTZ. N.P b... ... .... 19 ..
j
9.4 I. , #
Audit Report No. S-TMI-81-16 October 23, 1981 l Finding 3 'of 3 Page 2 ATTACHMENT 1 The SDS functional test. procedures (SOPS) were reviewed and the following deficiencies were found:
a) Missing test data.
b) Illegible initials or proper identification of test personnel. Personnel, l
other-than test personnel, performed testing and signed the test procedures.
c) Incorrect calculations supporting test results, d) Records of failed tests were not in the test packages. .
e) Records of retests were not clearly defined.
f) Procedures and documents, other than test procedures, were used to effect value lineups and perform testing activities but were not included in the test packages.
l g) Original field copy of test procedures were missing from the test E packages. (Xeroxed copies available were of a quality that would not permit acceptable microfilming for record retention.)
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