ML20238C798
| ML20238C798 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 06/23/1987 |
| From: | Parks R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20238C505 | List:
|
| References | |
| CIV-PEN, EA-84-137, NUDOCS 8712310219 | |
| Download: ML20238C798 (450) | |
Text
{{#Wiki_filter: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 STATION NO. 2 License No. DPR-73 EA 84-137 i DEPOSITION OF RICHARD DALE PARKS June 23, 1987 VOLUME II BARKLEY COURT REPORTERS 4000 MAC ARTHUR BOULEVARD, SUITE 5500 REPORTED BY: NEWPORT BEACH, CALIFORNIA 92660 (714)752 1090 PENNY SANDER, CSR #4769 2566 OVERLAND AVENUE, SUITE 570 FILE NO. 87-244 LOS ANGELES, CALIFORNIA 90064 (213)202 6666 8712310219 871209 PDR T ADOCK 05000320 PDR
I l B- 1 UNITES STATES OF AMERICA l 2 NUCLEAR REGULATORY COMMISSION 3 i 4 BEFORE THE ADMINISTRATIVE LAW JUDGE 5 l q 6 1 7 IN THE MATTER OF )
) DOCKET NO. 50-320 8 GPU NUCLEAR CORPORATION ) (CIVIL PENALTY) j
) l 9 (THREE MILE ISLAND NUCLEAR STATION ) LICENSE NO. l NO. 2) } DPR-73 10 ) EA 84-137 11 12 13 14 EXAMINATION OF RICHARD DALE PARKS, 15 TAKEN ON BEHALF OF THE RESPONDENTS, AT l l
16 4100 MAC ARTHUR BOULEVARD, NEWPORT BEACH, ; 17 CALIFORNIA, COMMENCING AT 9:05 A.M., TUESDAY, j 18 JUNE 23, 1987, BEFORE PENNY SANDER, CSR NO. 4769, 19 A NOTARY PUBLIC IN AND FOR THE STATE OF CALIFORNIA l 20 AND COUNTY OF ORANGE. 1 21 22 23 ! 24-f l 25 I l 11-2 l
'l APPEARANCES: l 2 FOR U.S. NUCLEAR REGULATORY COMMISSION: i 3 *FICE OF THE GENERAL COUNSEL 67 THE NUCLEAR REGULATORY COMMISSION 4 BY: GEORGE E. JOHNSON, ESQ.
AND 5 GREGORY ALAN BERRY MAIL STOP 9604 6 WASHINGTON D.C. 20555 - (301) 492-7445 7 FOR GPU NUCLEAR CORPORATION: 8 SHAW, PITTMAN, POTTS S TROWBRIDGE 9 A PARTNERSHIP INCLUDING PROFESSIONAL CORPORATIONS 10 BY: J. PATRICK HICKEY, ESQ. AND l 11 DAVID R. LEWIS, ESQ. 2300 N STREET, N.W. 12 WASHINGTON D.C. 20037 l (202) 663-8103 l 13 l AND 14 THELEN, MARRIN, JOHNSON & BRIDGES 15 BY: KENNEDY P. RICHARDSON, ESQ. ONE KAISER PLAZA, SUITE 1950 16 OAKLAND, CALIFORNIA 94612 i (415) 893-5195 l 17 18 19 20 21 22 ( 23 24 25 l 11-3
1 1 ND E X 2 3 EXAMINATION BY PAGE 4 MR. HICKEY - - - - - - - - - - - - - - - - --- 7 5 6-7 E X H I B 1 T S 8 9 RESPONDENT'S DESCRIPTION INTRODUCED MARKED 10 31 MARCH 1, 1983 INTEROFFICE 9 7 .
- MEMORANDUM GPU NUCLEAR .f I
11 j 32 INTEROFFICE MEMORANDUM OF 12 7 12 GPU NUCLEAR -
SUBJECT:
TWG MINUTES OF 2/25/83 13 ! 33 MARCH 7, 1983 INTEROFFICE 16 7 f 14 MEMORANDUM OF GPU NUCLEAR q
SUBJECT:
TWG MINUTES OF q 15 3/4/83 MEETING 1 16 34 MARCH 31, 1983 INTEROFFICE 46 7 j MEMORANDUM, GPU NUCLEAR, 17
SUBJECT:
TWG MINUTES OF ' 3/28/83 MEETING 18 l 35 MARCH 18, 1983 INTEROFFICE 47 7 l 19 MEMORANDUM, GPU NUCLEAR l l
SUBJECT:
POLAR CRANE MAIN ] 20 HOIST UPPER LIMIT SWITCHES AND l MAIN TROLLEY LIMIT SWITCHES 21 j 36 FEBRUARY 18, 1983 LETTER TO , 24 24 j 22 MR. BARRETT FROM MR. KANGA wlTH SAFETY EVALUATION REPORT 23 FOR THE POLAR CRANE LOAD TEST 1 24 37 ROUGH DRAFT OF AFFIDAVIT 52 52 i 25 l 11-4 l
1 INDEX (CONTINUED) 2 PAGE PAGE RESPONDENT'S DESCRIPTION INTRODUCED MARKED 3 38 ROUGH DRAFT DOCUMENT SIGNED 56 56 ' 4 JUNE 6, 1983 5 39 ROUGH DRAFT DOCUMENT SIGNED 58 56 JULY 25, 1983 6 40 ROUGH DRAFT DOCUMENT SIGNED 59 56 7 JULY 25TH, 1983 8 41 HANDWRITTEN NOTE DATED 62 62 l JULY 25, 1983 SIGNED BY 9 RONALD.A. MEEKS 10 42 THREE-PAGE DOCUMENT 63 63 FIRST PAGE SAYS " PARKS LOGS" 11 43 HANDWRITTEN DOCUMENT ENTITLED 65 65 12 TMI - THE BECHTEL CONNECTION 13 44 PHOTOCOPY OF NEWSPAPER 104 104 i ARTICLE BY SUSAN Q. STRANAHAN 14 "THE REAL THREE MILE ISLAND STORY LEAKS OUT" 15 45 DOCUMENT ENTITLED " DRAFT FOR 119 119 16 MYSTERY MAN AFFIDAVIT" 17 46 HANDWRITTEN DOCUMENT 135 135 4 18 47 DOCUMENT ENTITLED " RESPONSE 159 159 TO REQUEST FOR PRODUCTION OF 19 DOCUMENTS" IN PARKS VERSUS BECHTEL POWER CORPORATION 20 48 MARCH 23, 1983 LETTER FROM 176 261 21 GOVERNMENT ACCOUNTABILITY PROJECT, THOMAS DEVINE TO , 22 NUNZIO J. PALLADINO 23 49 RESUME OF RICHARD PARKS 188 188 FOR NUS 24 25 11-5
1 INDEX (CONTINUED) i 2 PAGE PAGE RESPONDENT'S DESCRIPTION INTRODUCED MARKED 3 50 QUILTEC INCORPORATED 240 248 4 PROPOSAL FOR STARTUP ASSISTANCE FOR DUQUESNE 5 LIGHT COMPANY'S BEAVER VALLEY POWER STATION 6 51 FEBRUARY 28, 1983 LETTER 254 254 7 FROM MR. ARNOLD TO LARRY KING AND LARRY KING'S RESPONSE 8 DATED MARCH 9, 1983 9 10 QUESTIONS WITNESS INSTRUCTED NOT TO ANSWER 11 PAGE LINE l 221 22 l 12 222 20 13 14 15 16 17 18 19 20 21 22 23 24 25 l 11-6
- 2- 1- TUESDAY, JUNE 23,-1987, AT 9:05 A.M..
2 3~ (WHEREUPON RESPONDENT'S EXHIBITS 31 THROUGH 4 /35 WERE MARKED FOR IDENTIFICATION BY THE NOTARY PUBLIC, 5 AND COPIES ARE ATTACHED HERETO.')- ! 6 7 RICHARD D. PARKS,. 8 CALLED AS A WITNESS BY AND ON BEHALF-OF THE RESPONDENTS, H 9 AND HAVING BEEN PREVIOUSLY DULY SWORN BY THE' NOTARY 10 PUBLIC, WAS EXAMINED AND. TESTIFIED AS FOLLOWS: 11 12 . EXAMINATION 13 BY MR. HICKEY: 14 Q MR. PARKS, AT THE END OF THE DAY YESTERDAY, I q 15 WAS ASKING YOU ABOUT A MEETING THAT YOU ATTENDED ON 16 MARCH -- I'M SORRY, ON FEBRUARY 23 AND DESCRIBED lN YOUR 17 AFFIDAVIT. LET ME SEE IF I CAN JUST REFRESH ALL OF_OUR l 18 RECOLLECTIONS ABOUT THE CONTEXT OF MY QUESTIONS COMING. 19 I SHOW YOU PAGE 25 0F YOUR AFFIDAVIT, WHERE 20 IN THE MIDDLE OF THE PAGE YOU STATED THAT YOU SUGGESTED AT 1 i 21 THE FEBRUARY 23RD MEETING THAT ONE ISSUE WAS WHETHER THE l 22 POLAR CRANE LOAD TEST PROCEDURE WAS A FUNCTIONAL TEST 23 PROCEDURE OR NOT. AND THEN LATER ON, ON THE SAME PAGE, l 1 24 SUGGESTED THAT IT COULD BE CLASSIFIED AS A CONSTRUCTION I 25 TEST WHICH COULD BE PERFORMED PRIOR TO TURNOVER AND HOW IT 11-7 _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - - _ D
1 WOULD DE HANDLED IF THAT OPTION WAS TAKEN. THERE WERE A 2 NUMBER.0F PEOPLE AT THE MEETING, YOU SAID. I DON'T THINK 3 YOU IDENTIFIED VERY MANY THAT WERE THERE. MR. BALLARD WAS q 4 THERE; IS THAT RIGHT? 5 A YES. I 6 Q DO YOU REMEMBER MR. BARTON AND OTHERS BEING 7 THERE? 8 A YES, MR. BARTON AND OTHERS WERE THERE. 9 Q OKAY. DIDN'T MR. BARTON RECOMMEND AT THE 10 MEETING THAT ONLY ONE TEST SHOULD BE PERFORMED AND THAT' IT 11 SHOULD BE PERFORMED IN A MANNER TO SATISFY ALL PARTIES, 12 WHICHEVER WAY THE TEST WAS TO BE PERFORMED? 13 MR. JOHNSON: BREAK IT -- IT'S TWO QUESTIONS. 14 THE WITNESS: HE MAY HAVE MADE SUCH 15 RECOMMENDATIONS. AT THIS MOMENT IN TIME, I CAN'T RECALL 16 IF MR. BARTON SUGGESTED THAT OR NOT. 17 Q BY MR. HICKEY: AND THE NEXT EVENT I WANT TO 18 DIRECT YOUR ATTENTION TO IS A TWG MEETING THAT WAS HELD 19 TWO DAYS LATER ON FEBRUARY 25. DO YOU RECALL ATTENDING 20 SUCH A MEETING? 21 A ON FEBRUARY 25TH? 22 Q YES. 23 AND, LET'S SEE, I BELIEVE THAT WOULD HAVE 24 BEEN A FRIDAY. 25 A I RECALL A TWG MEETING, BUT THE DATE DOES NOT 11-8
'l JUMP'INTO MIND IMMEDIATELY. IT MAY DE IDENTIFIED IN MY 2 AFFIDAVIT.
3 Q LET ME SHOW YOU WHAT HAS BEEN MARKED AS 4 RESPONDENT'S 31 TO YOUR DEPOSITION, WHICH IS A MARCH 1 5 MEMORANDUM ADDRESSED TO MR. KITLER ANi SIGNED BY 6 MR. CHWASTYK, ALTHOUGH IT HAS YOUR INITIALS. 7 FIRST OF ALL, WILL YOU LOOK AT THAT 8 MEMORANDUM AND TELL ME IF YOU PREPARED IT? 9 A IF MY MEMORY SERVES ME CORRECTLY AT THIS 10 TIME, I DID PREPARE THIS MEMO FOR MR. CHWASTYK'S 11 SIGNATURE.
'12 Q IF YOU'LL READ THE FIRST PART OF THE 13 MEMORANDUM PARTICULARLY TO SEE IF THAT REFRESHES YOUR 14 RECOLLECTION ABOUT THE TEST WORKING GROUP MEETING THAT WAS 15 HELD ON FEBRUARY 25.
16 A SIR, 1 SEE A STATEMENT IN THIS FIRST OR 17 INTRODUCTORY PARAGRAPH THAT ALLUDES TO THE EXISTENCE OF 18 THE TEST WORKING GROUP WHERE THE TEST WORKING GROUP WOULD 19 BE CONVENED ON FEBRUARY 25TH. BUT I SEE NOTHING TO 20 SUBSTANTIATE THAT A MEETING TOOK PLACE ON FEBRUARY 25TH. f 21 Q l'M NOT UNDERSTANDING YOUR POINT. 22 A WELL, MY -- 23 Q YOU'RE REFERRING TO THE LANGUAGE -- LET ME ] l 24 DIRECT YOU SPECIFICALLY TO THE LANGUAGE IN THE MIDDLE OF 25 THE FIRST PARAGRAPH THAT SAYS, QUOTE: j i 11-9
l l 1 " SUBSEQUENT TO THIS MEETING," REFERRING TO ! I 2 THE FEBRUARY 23RD MEETING, SUBSEQUENT TO THAT 3 MEETING, "THE TEST WORKING GROUP WAS CONVENED 4 ON FEBRUARY 25, 1983, TO REVIEW AND DISCUSS 5 THE NECESSARY METHODS FOR ENSURING THAT TESTING 6 ' PERFORMED TO DATE AND ANY FUTURE TESTINGS COMPLIES 7 WITH AP 1045 REQUIREMENTS," CLOSE QUOTE. ; 8 A I BELIEVE THAT'S EXACTLY WHAT THE MEMO SAYS. 9 MY POINT IS SIMPLY AT ONE P0lNT IN TIME, 4 10 AFTER FEBRUARY 23RD, THE TEST WORK GROUP DID MEET IN A 11 MEETING TO DO JUST THOSE FUNCTIONS. NOW WHETHER OR NOT 12 THAT MEETING OCCURRED INITIALLY ON FEBRUARY 25TH, 1 DO NOT 13 RECALL AT THIS MOMENT, NOR DO I THINK THAT MEMO STATES 14 EMPHATICALLY THAT MEETING DID OCCUR RATHER THAN POSSIBLY 15 TWG WAS JUST CONVENED. j 16 Q WHAT DO YOU UNDERSTAND " CONVENED" TO MEAN? l 17 A WELL, IN MOST SENSE WHEN A MEETING 15 18 CONVENED OR A GROUP, IT IS IN A MEETING, A JOINT FUNCTION 1. 19 TO ACCOMPLISH A COMMON GOAL. I DO NOT KNOW IF THAT'S 20 NECESSARILY THE INTENT OF THAT PARAGRAPH. 21 Q WELL, l'M TALKING TO THE AUTHOR THOUGH. WHAT l l 22 DID YOU INTEND WHEN YOU WROTE THAT PARAGRAPH WHEN YOU SAID 23 " CONVENED"? I 24 A I COULD NOT TELL YOU, AT THIS MOMENT IN TIME, i 1 25 IF THAT'S THE MEANING 1 WAS ATTEMPTING TO CONVEY OR IF i 1 11-10 1 E_______________ _ _ _ _ _ _ - - - .__
i 1 WAS JUST MAKING A STATEMENT THAT EVERYONE AGREED THAT THE 2 TEST WORK GROUP HAD TO BE CONVENED AND THAT'WAS THEIR 3 FUNCTION, THEIR PRIMARY FUNCTION. 4 Q YOU WERE A MEMBER OF THE TEST WORKING GROUP 3
- 5. FOR SITE OPERATIONS AT THAT TIME, WERE YOU NOT?
6 A IF MY MEMORY SERVES ME CORRECTLY, I WAS 7 APPOINTED AS THE TEST WORK GROUP MEMBER FOR THE SITE 8 OPERATIONS ON FEBRUARY 25TH, 24TH, OR 23RD, SOMETHING LIKE 9 THAT. 10 Q I UNDERSTAND YOUR TESTIMONY TO BE, YOU DO NOT 11 HAVE ANY RECOLLECTION OF WHETHER YOU ATTENDED A TWG 12 MEETING ON FEBRUARY 25? 13 A THE ONLY THING I AM UNSURE OF, AT THIS 14 MOMENT, IS THE DATE. 15 Q LET ME ASK YOU THIS QUESTION. 16 FROM THE DATE OF YOUR APPOINTMENT ON 17 FEBRUARY 24 AS THE SITE OPERATION'S TWG MEMBER, DO YOU 18 REMEMBER ATTENDING ONE OR TWO TWG MEETINGS BEFORE YOU LEFT 19 THE SITE ON MARCH 24TH? 20 A I DON'T THINK I CAN STATE THAT WITH ANY
]
21 CERTAINTY AT THIS TIME. I 22 1 DO RECALL ATTENDING TWG MEETINGS; AND THE I 1 23 NUMBER OF THE MEETINGS 1 ATTENDED, I DO NOT RECALL AT THIS 24 MOMENT. IT MAY HAVE BEEN ONE; IT MIGHT HAVE BEEN TWO; IT , I 25 MIGHT HAVE BEEN MORE. I DON'T KNOW. I CAN'T RECALL. I 11-11 i i L1 ~ - I
1 .Q WELL, THE MEMORANDUM THAT YOU WROTE -- AND 2 .DID ~ YOU PREPARE THIS ON OR ABOUT MARCH IST, 1983? 3 A YES,= SIR, I DID,.IF MEMORY SERVES ME 4 CORRECTLY. 5 Q LET ME SHOW YOU WHAT_HAS BEEN MARKED EXHIBIT l 6 32 AND ASK YOU.TO TAKE A LOOK AT-THAT DOCUMENT. 7 DO YOU RECALL SEEING THAT DOCUMENT, EXHIBIT l 8- 32, BEFORE, MR. PARKS? i
- 9 A YES, 1 DO.
10 Q AND DID YOU SEE IT AT ABOUT THE' TIME 0F 11 FEBRUARY.25, 19837 12 A ON OR ABOUT THAT.DATE, YES. 13 Q AND WHAT IS THE DOCUMENT? 14 A WELL, THE DOCUMENT-APPEARS-TO BE AN. AGREEMENT '
-15 THAT ED KITLER TRIED TO GET APPOINTED TEST WORK GROUP 16' ' MEMBERS TO SIGN OFF IN LIEU OF A MEETING AND ACHIEVE 17 EVERYONE'S CONCURRENCE WITH THE STATEMENT.
18 MR. JOHNSON: MAY I HAVE A CHANCE JUST TO LOOK AT 19 THE DOCUMENT? 20 THE WITNESS: l'D LIKE TO FINISH READING IT FIRST. , l 21 MR. HICKEY: WHILE EVERYONE IS READING, WOULD YOU ] l 22 READ ME THE LAST ANSWER. 1 23 (WHEREUPON THE REPORTER READ THE ANSWER i j
- 24. APPEARING ON PAGE 12, LINES 14 THROUGH 17, INCLUSIVE.) )
l 25 MR. JOHNSON: OKAY. THERE'S NO DATE ON THIS 11-12 ]
-_a__=____-_ _ - - _ - - _ _ - _ - _ __ .i
I-1 DOCUMENT. 3U Q BY MR. HICKEY: THE DATE I WAS REFERRING TO 3 IN MY QUESTION WAS AROUND-FEBRUARY 25, 1983.- I'THINK I 4- .MAY HAVE SAID THAT. 5 WHY DO YOU CHARACTERIZE THE DOCUMENT, AS YOU 6 JUST DID, MR. KITLER, WITH REGARD TO'-- I'M SORRY, 7 MR.. PARKS, WITH REGARD TO MR. KITLER TRYING TO GET PEOPLE 8 TO SIGN OFF IN LIEU OF A MEETING? WHAT IS YOUR BASIS FOR 9 THAT STATEMENT? 10 A BECAUSE IF MEMORY SERVES ME CORRECTLY AT THIS i 11 TIME, THAT'S EXACTLY WHAT HAPPENED. - l 12 Q WHAT HAPPENED TO YOU? WHAT WAS YOUR 13 INVOLVEMENT? d 14 A THAT DOCUMENT WAS EITHER BROUGHT'TO ME BY l 15 ED KITLER OR WAS FORWARD 5D TO ME THROUGH THE. INTEROFFICE 16 Mall SYSTEM, AND I DECLINED TO SIGN IT.
)
17 Q DID YOU TELL ANYONE THAT YOU DECLINED TO SIGN 18 IT OR DID YOU JUST NOT SIGN? I 19 A WELL, 1 THINK BY THE ACT OF ME NOT SIGNING 20 IT, IT BECAME APPARENT THAT I WOULDN'T SIGN IT. I ALSO DO ' 21 BELIEVE I DISCUSSED IT WITH ED KITLER. 22 Q DID YOU TELL MR. KITLER THAT? 23 A I DIDN'T WANT TO SIGN IT.
.24 Q DID YOU TELL HIM WHY?
i 25- A THAT -- I'M SURE I DID, BUT AT THE MOMENT, I l 11-13 ;
'll CAN'T RECALL EXACTLY WHAT I CONVEYED TO HIM.
2- Q WELL, WHY DID'YOU NOT WANT TO' SIGN IT? 3 A. BECAUSE I FELT THE TEST' WORK GROUP MEMBERS 4 SHOULD' SIT'DOWN IN A MEETING AND REVIEW'EVERYTHING THAT
-5 EXISTED U P. TO AND INCLUDING WHERE'WE WERE AT, YOU KNOW, AS
- 6. FAR AS THE RECORDS PERTAINING TO THE POLAR CRANE.
7 .Q YOU THOUGHT THE TWG' GROUP SHOULD' SIT-DOWN AND 8 REVIEW EVERYTHING'THAT EXISTED. WHAT ARE YOU TALKING 9 ABOUT? 10 .A WELL, THE WORK PACKAGES THAT HAD BEEN 11 UTILIZED TO MODIFY THE CRANE, THAT TYPE OF THING. 12- Q WHAT OTHER KINDS OF THINGS? 13 A MOSTLY THAT'S IT. THE WORK PACKAGES,-THE 14 NO-LOAD TEST HAD ALREADY BEEN PERFORMED. THE OTHER 15 DOCUMENTS THAT EXISTED THAT VERIFIED THAT FUNCTION, SUCH { 16- AS LIMIT SWITCHES, HAD ACTUATED PROPERLY, THOSE TYPE OF 17 THINGS. AT LEAST THAT'S WHAT I CAN RECALL AT THIS MOMENT. 18 I BELIEVE THAT WAS MY REASON FOR NOT.WANTING TO SIGN THE l l 19 MEMO. , I 20 Q WHAT DID MR. KITLER RESPOND WHEN YOU l 21 EXPRESSED THESE REASONS TO HIM? ] 22 A I THINK WE ENDED UP HAVING THE TEST WORK I 23 GROUP SIT DOWN AND REVIEW AND HAVE A MEETING REGARDING THE l 24 POLAR CRANE. I THINK THAT MEETING OCCURRED SOME TIME IN 1 25 THE FIRST PART OF MARCH. 11-14
1 Q ALL RIGHT. AND YOUR ANSWER IS A LITTLE i l -2 INDIRECT, BUT DOES THAT INDICATE THAT MR. KITLER AGREED 3 THAT THERE SHOULD BE A TWG MEETING TO DISCUSS THESE THINGS 4 THAT YOU WANTED TO HAVE DISCUSSED? ,4 5 A WELL,.FROM WHAT 1 CAN RECALL AT THIS MOMENT, 6 I DON'T KNOW OR I DO NOT RECALL IF THEY HAD HAD A NEGATIVE 7 OR A POSITIVE RESPONSE. I GUESS l' DON'T REMEMBER THE END 8 RESULT, THE END RESULT BEING THAT WE CONVENED THE TEST
-9 WORK GROUP MEETING.
10 Q WELL, THE TWG MEETING THAT YOU REFERRED TO 11 THAT WAS HELD, YOU BELIEVE, EARLY IN MARCH, IT WAS HELD ON 12 MARCH 4; ISN'T THAT RIGHT? 13 A I DON'T REMEMBER THE EXACT DATE. l'M 14 PRESENTLY LEAFING THROUGH MY AFFIDAVIT TO SEE IF 1 CAN 15 REFRESH MY MEMORY. 16 ON PAGE 38 0F MY AFFIDAVIT, 1 STATE THAT THE 17 FIRST TEST WORK GROUP MEETING WAS HELD ON MARCH 4TH WHERE 18 THE MEMBERS ACTUALLY SAT DOWN IN A ROOM, AT A TABLE, AND 19 DISCUSSED THE STATUS OF THE POLAR CRANE: WHAT HAD TO BE 20 DONE; WHAT COULD BE DONE, ET CETERA, ET CETERA. 21 Q YOU ASKED MR. KITLER OR MR. WALKER TO CONVENE 22 THIS MEETING; IS THAT YOUR TESTIMONY? WAS IT MR. KITLER? 23 MR. JOHNSON: HOW MANY QUESTIONS? THAT SEEMED LIKE 24 TWO QUESTIONS. l 25 THE WITNESS: IT SEEMED LIKE THREE. i 11-15 { l
1 Q BY MR. HICKEY: DID YOU ASK MR. KITLER TO 2 CONVENE THIS MEETING? 3 A I THINK BY VIRTUE OF ONE OF THE MEMOS THAT 4 YOU HAD ALREADY SHOWN, EXHIBIT 31, THAT THAT WAS OUR 5 REPLY, NOT ONLY TO THE MINUTE'S REQUEST HERE, WHICH IS 6 EXHIBIT'32, BUT /.LSO EXHIBIT 31 STRONGLY SUGGESTED THAT WE 7 DO CONVENE THE TEST WORK GROUP AND, YOU KNOW, GO INTO IT. 8 Q OKAY. WHEN THE MEETING WAS HELD, AND I PUT l l 9 IT ON MARCH 4TH, AS YOU CONFIRMED, IT WAS DECIDED AT THE 10 MEETING, WAS IT NOT, THAT THE LOAD TEST PROCEDURE SHOULD 11 BE REFORMATTED TO COMPLY WITH.THE FORMAT REQUIREMENTS OF i l 12 PROCEDURE 1047 AND TEST CONSTRUCTION 17 i t 13 A AT THIS MOMENT IN TIME, I CAN'T RECALL IF IT , i 14 WAS. DECIDED THERE OR NOT. I DO RECALL THE END RESULT WAS 15 THE PROCEDURE WAS REFORMATTED. IT MAY HAVE'BEEN DECIDED 16 DURING THAT MEETING. j 17 Q LET ME SHOW YOU WHAT'S BEEN MARKED AS EXHIBIT i 18 33 TO YOUR DEPOSITION, WHICH IS A MEMORANDUM OF TWG 19 MEETING MINUTES OF MARCH 4, 1983. IT'S ADDRESSED TO A 20 NUMBER OF PERSONS INCLUDING YOURSELF. I DIRECT YOU TO THE l I 21 .LAST PAGE PARTICULARLY, MR. PARKS. ) i 22 A 1 PREFER TO READ THE ENTIRE DOCUMENT. j 23 Q BY ALL MEANS D0. 24 A OKAY. I HAVE COMPLETED MY REVIEW. 25 Q OKAY. MY QUESTION WAS WHETHER THE MINUTES 11-16 I a - - - - - - - - - - - -- - - - - - - - _ _ - - - _ _ - - - - - -
1 1 INDICATE TO YOU THAT THE TWG MEETING OF MARCH 4TH ;
)
2 DETERMINED THAT THE LOAD TEST WOULD BE REFORMATTED IN 3 ACCORDANCE WITH THE 1047 TEST INSTRUCTION? 4 A THERE'S A STATEMENT ON PAGE 3 OF THE TWG l I 5 MINUTES THAT SAYS THAT IT WAS AGREED THAT THE PERFORMANCE l 6 OF THE LOAD TEST WOULD BE IN COMPLIANCE WITH AP 1047. i 7 Q TO BE IN COMPLIANCE WITH 1047, AS YOU ' 8 UNDERSTAND, THAT WOULD BE REQUIRED TO BE REFORMATTED? i 9 A THAT WOULD BE AN ASSUMPTION ON MY PART. BUT 10 i WOULD ASSUME THAT IT WAS REFORMATTED AS A RESULT OF THAT 11 MEETING. 12 MR. JOHNSON: THAT WAS NOT REALLY THE QUESTION.THAT 13 HE ASKED YOU. l 14 THE WITNESS: WELL, I GUESS WHAT MY PROBLEM 15, YOU 15- TAKE A DEFINITIVE STATEMENT THAT SAYS THAT THE PERFORMANCE 16 OF THE TEST WOULD BE IN COMPLIANCE WITH THE PERFORMANCE. 17 Q BY MR. HICKEY: IN THE WAY THAT THE TEST IS 18 WRITTEN, THEY'RE NOT NECESSARILY ALWAYS THE SAME, BUT l'M 19 NOT GOING TO ARGUE THAT POINT OR BELABOR THE POINT FOR THE 20 SIMPLE REASON I DO RECALL THE REASON IT WAS REFORMATTED 21 WITH AP 1047. AND MY QUESTION IS WHETHER YOU HAD A 22 RECOLLECTION OF A DECISION OF THE MARCH 4TH MEETING; AND I 23 TAKE IT YOUR ANSWER INDICATES YOU DON'T SPECIFICALLY 24 RECALL, BUT YOU KNOW THE OUTCOME WAS THAT IT WAS 25 REFORMATTED? 11-17 l
1 A THAT'S CORRECT. I BELIEVE I ANSWERED THAT 2 BEFORE I HAD TO REVIEW THE DOCUMENT. 3 Q l WANTED TO SEE IF THE DOCUMENT WOULD HELP. 4 THAT'S WHY I SHOWED IT TO YOU. I 5 A THANK YOU. l 6 Q IF YOU'LL LOOK JUST BRIEFLY, MR. KITLER, l; 7 AT -- 8 MR. JOHNSON: MR. PARKS. .j 9 Q BY MR. HICKEY: .I'M SORRY, MR. PARKS. SECOND 10 TIME l'VE DONE THAT THIS MORNING. 11 A 28? 12 Q YES, THAT'S A COPY OF THE -- OF YOUR COMMENTS i 13 AND MR. RADBILL'S RESPONSE. IF YOU LOOK AT THE 7TH 14 COMMENT THAT YOU MADE. 15 A OKAY 16 Q YOU WERE WOTING THEkF. THAT THE LOAD TEST a7 ! SAFET/ EVALUATION REPORT HAD NOT BE6N REVIEWED AND l 18 APPROVED BY TWC AS REQUIEED BY THE PROCEDURE 1047 AND THE 19 i TEST INS *EUCilON 1, E NC L O S $J R E 7, CORRECT? 20 A THAT'S WHAT IT SAYS. 21 Q OKAY. THE SITE OPERATIONS DEPARTMENT HAD l 22 PREVIOUSLY APPROVED THE SAFETY EVALUATION REPORT ON 23 FEBRUARY 17TH, HADN'T THEY?
- 5 24 A AT THIS MOMENT IN TIME, I COULD NOT TELL YOU 25 IF THEY HAD OR NOT.
I 11-18 ____---_______1
1 Q DID YOU PARTICIPATE IN THE REVIEW OF THE 1 2 SAFETY EVALUATION REPORT THAT WAS PERFORMED BY SITE
'3 OPERATION PERSONNEL? i l
4 A AT THIS MOMENT IN TIME, I CANNOT TELL YOU IF 5 1 DID OR NOT. 6 MR. VOHNSON: THAT QUESTION REFERRED BACK TO THE 7 PREVIOUS QUESTIONS, THE REVIEW OF THE SER? I 8 MR. HICKEY: YES. i 9 Q BY MR. HICKEY: DO YOU KNOW WHETHER SITE 10 OPERATIONS, WHEN THEY REVIEWED THE SAFETY EVALUATION 11 REPORT, RAISED THIS CONCERN IN 1 HEIR REVIEW OF IT? 12 A I DO NOT KNOW, AT THIS POINT IN TIME, IF THEY 13 RAISED THAT CONCERN OR NOT. 14 Q HOW WAS THIS MATTER BROUGHT TO YOUR ATTENTION l 15 30 THAT YOU INCLUDED li IN YOUR FEBRUARY 17TH COMMdHTS? <
. I 16 MF. JOHNSON: FXCUSE M t' , "THIS MATTI.2"? f 17 j Q BY MRs MICKEY: TH I S MAT TER" BEING THE LOAD l
18 TEST S?R NOT HA'v1NG BEEN REVICWED AND APPROVED BY TWG, 59 A AT THIS POINT IN TIMEg 1 COULDN'T TELL Y O U.. f 20 PROBABLY FROM MY OWN REVIEW. 21 Q OF WHAT? 22 A OF THE PROCEDURE OR THE SER, 23 Q LET ME ASK YOU TO TAKE A LOOK AT EXHIBIT 25 24 ALSO. THAT'S THE TEST INSTRUCTION NUMBER 1, THAT YOU i 25 REFERRED TO IN YOUR COMMENT 7. IF 1 CAN DIRECT -- THE 6 11-19
)
'l ENCLOSURE'7 THAT YOU REFERRED TO WAS TOWARDS THE END OF 2 THAT EXHIBIT.
3 A OKAY. 4 Q WHEN YOU WROTE IN YOUR FEBRUARY 17TH COMMENT 5 NUMBER 7 THAT THERE WAS A REQUIREMENT IN TEST INSTRUCTION 6 1, ENCLOSURE 7,_FOR APPROVAL OF THE' LOAD TEST SER BY TWG, 7 WHAT WERE YOU REFERRING TO IN ENCLOSURE 77-8 A PAGE 4. NUCLEAR SAFETY EVALUATION FOR 9 STARTUP AND TEST. 10 Q AND CAN'YOU POINT ME TO ANYTHING IN THE 11 ENCLOSURE THAT THAT DIRECTION BE COMPLETED? 12 A I BELIEVE IT.WOULD PROBABLY FALL UNDER,- IN A 13 GENERIC TERM, THE DISCUSSION PARAGRAPH 2.0: 14 "TWG MAY D 'i R E C T PREPARATION AND 1 15 APPROYAL OF SArdTY OR ENVIRONMENTAL
'16 VVALUATION TO SUPPORT CERTAIN ACTIONS i
17 TAKEN SUCH AS SUPPORT ESTABLISHING 'I l 18 THE TEST'DROCEDURE FOR CLASS 1 SY3 TEM, ! l
! !:. SLASH, TASK AS A CATEGORY C PROCEDURE." ]
1 ! 70 Q THE LANGUAGE THAT YOU JUST READ IS PHRASED IN l 21 LANGUAGE, QUOTE, "THE TWG MAY DIRECT," CLOSE QUOTE. DOES
]
22- THAT MEAN THAT IT IS NOT REQUIRED, BUT IT'S DISCRETIONARY I 23 WITH THE TWG? 24 A THAT'S TRUE. 25 Q AND IF THEY DIRECT IT, THEN WHAT THIS SAYS 11-20 f'
'l THEY MAY DIRECT IS THE COMPLETION OF A FORM LIKE YHAT ON
- 2. PAGE 4 OF THIS --
3 A THAT'S TRUE. 4 Q -- ENCLOSURE? 5 NOW IS THE PAGE 4 TYPE FORM, WHICH IS TITLED 6 "STARTUP AND TEST NUCLEAR SAFETY EVALUATION," THE SAME 7 THING AS THE " SAFETY EVALUATION REPORT"? 8 A THAT'S CORRECT, IN A -- GENERIC TERMS IT IS, 9 YES. 10 Q WHAT DO YOU MEAN BY "IN GENERIC TERMS"? 11 A IT REQUIRES THE SAME REVIEW PROCESS THAT 12 EXISTS ON A NUCLEAR SAFETY EVALUATION FORM. THEY JUST 13 REQUIRE DIFFERENT PEOPLE TO APPROVE IT. 14 Q l'M SORRY, I DIDN'T HEAR THE FIRST PART OF ), 15 WHAT YOU SAID. f l 16 , A IT FSTABL)Shd5 THE SAME REVIEW PROCESS, LOOKS T 17 AT THE S A NF. ITEMS OF CONCERN AS A NUCLEAR SAFETY 18 EVALUATION FORM DOES IN ANY ?ROCEDURE. JUST REQUIRES 19 DlFFERENT PEOPLE TO REVIEW AND APPROVE IT, THAT?S ALL. 20 Q WHAT'S THE "IT" THAT WAS THE SUBJECT OF YOUR
'21 SENTENCE?
22 A THAT PAGE 4 ON EXHIBIT 87 (SIC), ENCLOSURE.7. l 23 Q LET ME TRY AGAIN. l'M NOT UNDERSTANDING WHAT 24 YOU'RE SAYING. 25 A WELL, MAYBE I'M, YOU KNOW, NOT EXPLAINING IT j 11-21
l
~l 1 CLEAR ENOUGH. THIS FORM -- I 2 Q REFERRING TO --
3 A -- THE SAFETY EVALUATION STARTUP AND TEST 4 ' ESTABLISHES THE SAME OR THE IDENTICAL. REVIEW REQUIREMENTS L 5 IN THE SAME ITEMS TO BE CONSIDERED AS ANY STANDARD SAFETY I 6 EVALUATION -- NUCLEAR SAFETY EVALUATION REPORT THAT WOULD , 1 7 HAVE BEEN INCLUDED ON THE Uh3 OP ANY OTHER PROCEDURE. THE 8 .ONLY DIFFERENCE BEING 15 IT REQUIRES THE TWG TO APPROVE IT 9 SPECIFICALLY. 10 Q AND THAT IS THE TWG IS REQUIRED TO APPROVE 11 THIS NUCLEAR SAFETY EVALUATION FORM, LIKE PAGE 4 OF THE 12 EXHIBIT, RIGHT? 13 A RUN THAT PAST ME AGAIN. 14 Q SURE. 15 YOU SAID THE ONLY OlFFERENCE IS THIS IS 15 PJ. QUIRED TO DE APPROVED SY TWG, AND 1 WANT TO CLEAR IT UP 17 ON THE RECO9D, WHAT THIS REFERS TO. Y O U ' P.E SAYING THAT 18 THE NUCLEAR SAFETY EVALUATION FORM, WHICH 15 PAGE 4 OF 19 . E N C L O'.i U R E 7, IS REQUIR2D TO BE APPROVED BY TWG; AND TME
)
20 O'lHER KIND OF SAFETY EVALUATION REPORT 15 NOT -- 21 A THAT'S TRUE. THIS PROCEDURE IS -- AND THIS 22 FORM MANDATES THE TEST WORK GROUP TO REVIEW AND APPROVE 23 THE SAFETY EVALUATION FOR THE TEST. THE NUCLEAR SAFETY 6 24 EVALUATION REPORT THAT WAS INCLUDED WITH THE DRAFT, OR 25 WHICHEVER REVISION IT WAS OF THE POLAR CRANE TEST LOAD 11-22
-1 -PROCEDURE, DID.NOT MANDATE THE TEST PROCEDURES SEPARATE 2 FROM THE FORMAL PROCEDURE REVIEW PROCESS.
3 Q WHEN WE BEGAN THIS DISCUSSION, I THINK YOU 4 TOLD ME THAT UNDER PARAGRAPH 2.1 THAT PREPARATION AND 5 APPROVAL OF A SAFETY EVALUATION WAS DISCRETIONARY TO START 6 WITH7 7 A THAT'S TRUE. 8 Q IT DOES NOT HAVE TO BE DONE AT ALL UNLESS THE 9 TWG DECIDES IT SHOULD BE DONE? 10 A THAT'S TRUE. 11 Q AND THAT REFERS TO A NUCLEAR SAFETY 4 12 EVALUATION REPORT FORM BEING COMPLETED? 13 A THAT'S TRUE, IT REFERS TO A SPECIFIC FORM 14 BEING COMPLETED, THAT SPECIFIC FORM BEING PAGE 4 0F 15 E N Ct. 0 5 U R E 7 0F T.I. I, AND IN MY CAPACITY AS TME , 16 ALTERNATE STARTUP AND TEST MANAGER, I WAS RECOMMENDED THAT 17 %E HAVE THE TWG REVIEW THAT PROCEDURE AND Fil L OUT THAT 18 l FORM FOR THE TEST. 19 Q WELL, THE SAFETY EVALUATION REPORT, THE LOAD 20 TEST SAFETY EVALUATION REPORT THAT YOU WERE REFERRING TO 21 IN YOUR COMMENT, WERE YOU REFERRING TO A FORM LIKE PAGE 4 22 0F ENCLOSURE 7? 23 A I WAS REFERRING TO EITHER THEY COULD USE THAT 24 FORM OR THEY COULD PUT ANY FORM ON THERE THEY WANTED TO, 25 BUT I WANTED THE TWG TO REVIEW THE SAFETY EVALUATION 11-23 i
1 REPORT, AND THAT'S EXACTLY WHAT I WANTED THEM TO DO. 2 Q LET ME GET IT CLEAR. l'M GOING TO ASK THE 3 REPORTER TO MARK, 50 1 CAN BE SURE I UNDERSTAND THE 4 WITNESS -- AND IT WILL BE EXHIBIT 36. 1 HAVE SOME OTHERS 5 PREMARKED HERE THAT WE HAVEN'T GOT TO YET, BUT THIS ONE I 6 FITS IN NOW. 7 EXHIBIT 36 15 A FEBRUARY 18, 1983, LETTER TO 8 THE NUCLEAR REGULATORY COMMISSION FROM B.K. KANGA, 9 TRANSMITTING THE SAFETY EVALUATION REPORT FOR THE POLAR 10 CRANE LOAD TEST. AND ATTACHED TO IT IS A DOCUMENT, MANY 11 PAGES, TITLED " SAFETY EVALUATION REPORT FOR THE POLAR 12 CRANE LOAD TEST." IT'S REVISION 0, DATED FEBRUARY 14, 13 1983. 14 (WHEREUPON RESPONDENT'S EXHIBIT 36 WAS MARKED 15 FOR IDENTIFICATTOM DY THE NOTARY PUBLIC. AND A COPY IS 16 ATTAUMED 11ERETO.) I 17 1HE WITNESS: ISN'1 THIS ALSO THE SAME THAT WAS - - - i k 18 IT'S JV$T ALMCST IDENTICAL TO A PRE \ 10US EXHI91 T WE HAD j 19 YESTE40AY TMAT WAS DATED F E B kil AR Y 17TH OR FEBr<UARY 18TH? 20 Q BY MR. HlCKEY: i DON'T BELIEVE 50. 21 A OKAY. 22 Q LET ME UNDERSTAND YOUR PREVIOUS ANSWERS. 23 WHEN YOU WROTE IN COMMENT 7 0F YOUR FEBRUARY 17 COMMENTS, 24 THAT "THE TEST WORKING GROUP SHOULD REVIEW AND APPROVE THE 25 LOAD TEST SAFETY EVALUATION REPORT," WERE YOU REFERRING TO j 11-24
1 THE DOCUMENT THAT IS EXHIBIT 36 WHICH IS IN FRONT OF YOU? 2 A I THINK, MR. HICKEY, YOU'RE MISCHARACTERIZING 3 THAT. STATEMENT. STATEMENT NUMBER 7 ON EXHIBIT NUMBER 28 4 SAYS " NUCLEAR SAFETY EVALUATION," NOT-REVIEWED AND 5 APPROVED BY THE TEST WORK GROUP AS REQUIRED BY AP 1047, 6 T.I. ENCLOSURE 7, " NUCLEAR SAFETY EVALUATION," NOT THE 7 " SAFETY EVALUATION REPORT." IT IS VERY CONFUSING. GOT TO l 8 BE VERY CONFUSING AT TMI-2 EXACTLY WHICH ONE WE WERE 9 TALKING ABOUT. 10 Q WELL, THEN YOUR ANSWER TO EXHIBIT 36 IS NOT 11 WHAT YOU WERE TALKING ABOUT -- 12 A THAT'S CORRECT. 13 Q -- WHEN YOU WROTE YOUR COMMENT NUMBER 7? , I 14 A YES. 15 Q BUT WHAT YOU WERE TALKING ABOUY IS A FORM 16 LIK6 ENCLOSURE 4 OF PAGE 4 -- OF ENCL 6SURE 7, T H F. TEST 17 INSTRU' TION I? 18 A RiGHT. 19 NOW l'M NOT FOR SURE I F- IT IS THE ACCURATE R 1 ) 20 VERSION OR NOT, BUT THIS IS -- EXHIBIT 26, FIRST THREE 21 PAGES OF IT IS UNIT WORK INSTRUCTION. PART OF THAT UNIT 22 WORK INSTRUCTION IS NUCLEAR SAFETY EVALUATION. THAT'S 23 WHAT I WAS IDENTIFYING HAD TO BE REVIEWED AND APPROVED AS j 24 PART OF THE REVIEW PROCESS TO APPROVE THE LOAD TEST . 25 PROCEDURE. IT HAD TO BE REVIEWED AND APPROVED BY THE TEST
!!-25 j l
l 1
- - - - - _ _ - - _ __-_ _ _ _m
1 _ WORK' GROUP.
- l. .
\
l- 2 Q OKAY. THANK YOU. I 3 MR. PARKS, IF l'CAN DIRECT YOUR ATTENTION TO j l 4 THE 8TH COMMENT ON THE FEBRUARY 17 ITEMS AND GIVE YOU A 5 CHANCE TO READ IT. 6 MR. JOHNSON: WHICH ITEM? DID YOU DIRECT HIM TO A 7 PARTICULAR ITEM? 8 MR. HICKEY: EIGHT. 9 MR. JOHNSON: l'M SORRY. 10 THE WITNESS: OKAY. 11 Q BY MR. HICKEY: YOU REFERRED IN THIS ITEM 12 "THAT TESTING TO DATE DOES NOT COMPLY WITH CERTAIN 13 TURNOVER PROCESS, TESTING PROCESS PROCEDURES," AND YOU 14 CITE THE AP,PLICABLE PROCEDURES. THE TESTING TO DATE THAT 15 YOU WERE RE"JRRING TO, THAT REFERRED TO THE NO-LOAD TEST 16 THAT HAD A. READ \ BEEN PERFORME07 17 A THAT, AND I SELIE\E AT THAT POINT IN TIME, nF 7 18 MEMORY SERV;is ME CORRECTLY, THERE WAS O Trt E R TESTING T H A. 19 WAS PERFORMED UNDER VARIOUS CONTAINMENT E N T f; I E S , VERIFY 20 LIM 1TS, WHICH 15 VERIFIED LIMIT SWITCHES. PULL A PIECE OF 21 THE CABLE, SEND IT OFF, THAT TYPE OF THING. MY MEMORY IS 22 KIND OF VAGUE RIGHT NOW ON ALL THE TESTING THAT HAD BEEN 23 PERFORMED. 24 Q TESTING OF A PART -- LET ME EXCLUDE THE 25 NO-LOAD TEST FROM THIS QUESTION. 11-26
1 THE OTHER TESTING THAT YOU JUST REFERRED TO, 2 THAT WAS CLEARLY CONSTRUCTION TESTING, WAS IT NOT7 3 A IT COULD BE -- I WOULD IMAGINE, AT THIS P0lNT 4 IN TIME, IT COULD BE CONSIDERED CONSTRUCTION TESTING, YES. 5 Q AND.THEREFORE IT WOULD BE TREATED UNDER THE l 6 PROCEDURES IN A DIFFERENT FORMAT THAN IF IT WAS TREATED AS 7 A FUNCTIONAL FORM 7 8 A I DON'T THINK IT WAS MUCH A QUESTION OF 9 FORMATTING AS I WAS QUESTIONING THE SUBSTANTIVE RESULTS 10 THAT WERE OBTAINED AND HOW THEY WERE OBTAINED AND WHETHER l 11 IT COMPLIED WITH THE REQUIREMENTS ESTABLISHED BY THE TEST 12 MANUAL. 13 Q AND SPECIFICALLY -- MAYBE I CAN PUT IT l 14 BASICALLY YOUR CONCERN WAS THE TESTING WAS BEING PERFORMED l 15 PRIOR TO ThE POLAR CRANE BEING ADMINISTRATIVELY RETURNEO l l 16 TO SITE OPERATIONS? j 17 A WELL, THAT MAY HAVE BEEN ONE OF MY CONCERNS, j 10 BUT 1 CON'T RECALL THAT AT THE PRESENT MOMENT, WHAT I DO 19 RECALL IS TFE DOCt!MENTAT10N WAS MORE WHAT I WAS CONCERNED 20 ABOUT AND COMPL?ED WilH THE REQUIREMENTS OF THE WORK 21 ALTERATION PROCEDURE OR THE TEST MANUAL AND*lF THE PEOPLE 22 THAT WERE SIGNING ACCEPTABILITY OF THOSE RESULTS WERE 23 QUALIFIED TO BE SIGNING FOR THEM. 24 Q DOCUMENTATION OF THE TEST, PARTICULARLY THE 25 NO-LOAD TEST? i 11-27 t
1 A I THINK, YOU KNOW, NOT ONLY THE NO-LOAD TEST, t 2 BUT ANY OTHER TESTING THAT WAS PERFORMED UNDER WORK 3 PACKAGES. 4 Q AND THE PEOPLE YOU ALSO RAISED A CONCERN i. 5 ABOUT WERE THE PEOPLE WHO WERE REVIEWING THE TESTS WERE 1^ 6 QUALIFIED? 7 A I WONDERED IF THEY WERE, YES. I KNEW THERE 8 WERE NO RECORDS ON FILE FOR THEM IN THE TEST DEPARTMENT l 9 WHICH WOULD BE AN INFRACTION, 10 Q WHEN DID YOU LEARN THAT? 11 A WHEN I LOOKED THROUGH THE TEST DEPARTMENT 12 FILES. 13 Q WHEN DID YOU DO THAT? 14 A SOMETIME D*JRING THE TIME FRAME OF WHEN I WAS i 15 THE ACTING STARTUP AND TEST SUPERVISOR WHEN ED KITLER hAS 16 CONE, WHICF. WAS PROBABLY LIKE DECEMBER TIME FRAME, 17 SOMErHING LIKE THAT. ' 18 C TEST IN 1982 T H l .S WOULD HAVE BSEN? 19 A RIGHT. 20 Q AND MR. KITLER WAS ON LEAVE OR SICK OR 21 SOMETHING AND YOU REPLACED HIM? 22 A I DON'T REMEMBER EXACTLY WHAT WAS GOING ON. 23 HE WAS NOT THERE FOR A WHILE. AND 1 HAD TO GO UP AND -- 24 OR MAYBE IT WAS WHEN MIKE HERLlHY WAS SOMEWHERE. I DON'T 25 REMEMBER. THERE WAS A POINT IN TIME IN THE LAST PART OF 11-28
1 1982 WHEN IT WAS ED KITLER OR MIKE HERLlHY, THAT ONE OF 2 THEM WAS ABSENT FROM THE JOB SITE AND I WAS FILLING IN 3 THAT JOB. k I 4 Q IN THE COURSE OF FILLING IN FOR THEM, YOU HAD 5 OCCASION TO GO LOOK AT THESE -- WHAT DID YOU CALL THEM? I 6 A THERE'S A REQUIREMENT IN THE TEST MANUAL TO 7 MAINTAIN RECORDS OF ALL QUALIFICATION RECORDS, IF YOU 8 WILL, OF THE PERSONNEL ASSIGNED TO THE TEST DEPARTMENT; ' 9 WHO'S AUTHORIZED TO PERFORM TESTING, SIGN FOR TESTING, AND , 10 WHICH LEVEL OF TEST ENGINEER OF QUALIFICATION THEY l l 11 MAINTAINED. 1 12 Q AND YOU WENT, FOR SOME REASON, TO LOOK AT 13 THOSE FILES AND YOU SAW THERE WERE PEOPLE WHO WERE DOING
'l 14 THIG WORK WHO DIDN'T HAVE PROPER RECORDS ON FILE?
15 A THAT'S NOT WHAT I SAID. I CHALLENGED WHETHUR 16 OR NOT WE HAD RECORDS IN THE FILE AND WHETHER Ok NOT THESE 17 PEOPLE WERE QUALIFIED BECAUSE, TO MY KNOWLEDGE, THE LAST 18 TIME I LOOX5D IN THAT FILE, NONE OF THE PEOPLE THAY WEPE j 19 l PERFORMING THE TESTING WAS CERTIFIE0 ON THE JOB SITE TO DO 20 THE TESTING. l i 21 Q l'M GETTING CONFUSED BY THE CHRONOLOGY OF 22 WHAT YOU'RE DESCRIBING. l I 23 A LET ME TRY TO REALIGN MY ANSWER FOR YOU TO I l L 24 PUT IT IN A PROPER PERSPECTIVE. AT ONE POINT IN TIME, IN 25 THE LAST PART OF 1982, I HAD REASON TO GO INTO THE FILES l 11-29 , i
1 TO SEE-WHO WAS QUALIFIED TO DO TESTING, WHOSE RECORDS WE i l 2 MAINTAINED, AS WE WERE REQUIRED TO DO BY AP 1047 l f 3 NOW ALL THE TESTING THAT HAD BEEN -- THAT WE 4 WERE TAKING CREDIT FOR, PREVIOUS TO THE LOAD TEST 5 PROCEDURE, HAD BEEN PERFORMED UNDER THE JURISDICTION OF 6 WORK PACKAGES. AND VARIOUS PEOPLE HAD SIGNED THEM OFF AS 7 BEING OKAY. NOW WHO THOSE PEOPLE ARE, AT THIS POINT I 8 CAN'T RECALL. 9 BUT WHAT I WAS CHALLENGING ARE THESE PEOPLE, 10 YOU KNOW, THIS WHOLE THING, THE WAY WE TESTED EVERYTHING 8-11 UNDER THE WORK PACKAGES AND ALL DID NOT COMPLY WITH AP 12 1047 OR 1043, AND I SERIOUSLY DOUBTED IF WE HAD THE 13 DOCUMENTATION AVAILABLE. IT WAS A BROAD -- VERY BROAD 14 COMMENT. 15 Q ALL RIGHT. THE BASIS FOR IT WAS THAT YOU HAD 16 GONE AND LOOKED AT THE FILES A1 THE END OF 1982, SO YOU
'17 SAW WHO5VER It WAS --
RECORDS YOU KEPT TLf E N . YOU KNEW THEN WHO HAD THE PROPER RECORDS TO DO TESTING AS OF THIS 18 19 TIME IN THE LAS1 HALF OF 1982? I 20 MR. JOHNSON: THAT'S TWO QUESTIONS. 21 THE WITNESS: ! GUESS -- 22 MR. JOHNSON: WAIT A M l i!U T E . ; 23 MR. HICKEY: 1 THINK THE WITNESS UNDERSTANDS IT, j I 24 BUT I WILL REPHRASE IT. ' 25 MR. JOHNSON: BUT -- 11-30 i
I WILL REPHRASE'IT. [1 MR.. HICKEY:
'2. Q BY MR. HICKEY: WHEN YOU LOOKED, IN THE LAST-3 HALF OF.1982, YOU SAW THOSE PERSONS, YOU IDENTIFIED.THOSE' 4' PERSONS WHO HAD RECORDS ON FILE SHOWING THEY WERE 5 QUALIFIED FOR TESTING.
6- A RIGHT. ' 1 7 Q' WHEN YOU CAME TO EXAMINE THE RECORDS IN THE I 8 EARLY PART OF 1983, DID YOU RECOGNIZE THAT THE PERSONS WHO . 9 WERE SIGNING OFF THE TESTING HAD NOT HAD FILES WHEN YOU 10 LOOKED 11N 1982? 11 A I SERIOUSLY DOUBT -- WHEN I LOOKED IN 1983, 1 i 12 SERIOUSLY DOUBT IF ANY OF THE PEOPLE SIGNED OFF THE TEST 13 RESULTS AND ACCEPTABILITY OF TESTING IN 1982 AND '83 WERE
.14. QUALIFIED UNDER OUR PROCEDURES. NOT THAT THEY DID NOT 15 NECESSARILY HAVE THE QUALIFICATIONS OR THE EXPERIENCE, 16 JUST THEY DIDN'T HAVE THE PROPER PAPERWORK SIGNED OFF.
I 17 Q O K A Y ., AND THE REASON 100 EERIOUSLY DOUBTED 18 THA1 1S YOU HAD SOME RECOLLECTION OF WHAT YOU HAD SCEN IN 1$ TL!E FILES W H Eid YOU HAD G0kE AND LOOKED THERE BEFORE AND 20 YOU DIDN'T THINK YOU HAD SEEN THESE? 21 A THAT'S CORRECT. 22- Q AND -- 23 A SEE AP 1043 AND AP 1047 ARE VERY -- NOT 24 STRICT, BUT VERY STRAIGHTFORWARD IN-THE WAY THINGS ARE TO i 25 BE DOCUMENTED OR WERE TO BE DOCUMENTED. AND WE HAD GOT I 11-31 ( . L !
1 OUR BUTT IN A SLING ON OCCASIONS BEFORC IN THAT STARTUP 2 TEST DEPARTMENT BECAUSE OF IMPROPER DOCUMENTATION OF TEST 3 PEOPLE, IMPROPER DOCUMENTATION OF TEST RESULTS, THAT TYPE i 4 OF THING. THAT WAS ONE OF THE THINGS 1 WAS CONCERNED 5 WITH. 6 Q AND THE CONCERN THAT YOU ARE TALKING ABOUT,. 7 DID YOU HAVE A CONCERN ABOUT THIS IN 1983? 8 A I THINK MY CONCERN WAS EXPRESSED RIGHT THERE. 9 THE WAY THE MODIFICATION HAD BEEN PERFORMED DID NOT COMPLY 10 WITH -- 11 MR. JOHNSON: YOU SAY "THERE." YOU'RE REFERRING 12 TO -- 13 THE WITNESS: TO MY COMMENTS. 14 Q BY MR. HICKEY: YOUR FEBRUARY-17 COMMENT? 15 A RIGHT, 16 Q ALL RIGHT. LET ME MAKE SURE I UNDERSTAND. ) li WHAT YOU WROTE IN COMMENT 8 ON FEBRUARY 17, INCLUDED, IN b 18 YOUR MING, A CONCERN WHETHER THE PEOPLE WHO HAD SIGNED OFF 19 1HS TESTING HAD THE APPROPRIATE QUALIFICATIONS ON F'LE AS , 20 REQUIRED BY 1043 AND 1047? ' 21 A THAT WAS NOT THE ONLY CONCERN I HAD. 22 Q NO, 1 DIDN'T SAY IT WAS THE ONLY CONCERN. 23 ONE OF THE CONCERNS THAT YOU HAD WHEN YOU WROTE THIS i i 24 COMMENT ON FEBRUARY 17, COMMENT NUMBER b, WAS THE ONE I i 25 HAVE JUST EXPRESSED -- 11-32
i l' A YES. s 2 Q ~ - -'IS THAT RIGHT? 3 A THE OVERRIDING STATEMENT OR, YOU KNOW, KIND LE OF AN ALL-ENCOMPASSING STATEMENT THERE-15 WHY 1 IDENTIFIED : 5' 'AS GENERAL ---lN MY OPINION, FROM MY REVIEW OF.THE DATE, 6 FROM WHAT 1 UNDERSTOOD HOW THE THINGS HAD BEEN-PERFORMED,. j 7 WE WERE NOT A-NONCOMPLIANCE-WITH OUR TWO EMPIRICAL 8- DOCUMENTS GOVERNING TESTINGS AND MODIFICATION. 9 Q YOU DIDN'T KNOW, BUT'YOU HAD A S U S P I C I'O N ; YOU l '0 - . THOUGHT IT'HAD,TO BE CHECKED OUT?
.11- A YEAH. THAT'S1WHY THE
GENERAL COMMENT
,12 MR. JOHNSON: WOULD YOU READ BACK THE PREVIOUS 13 ANSWER, PLEASE.
14 (WHEREUPON THE REPORTER READ'THE ANSWER 15 APPEARING ON PAGE 33, LINES 3'1HROUGH 8, INCLUSIVE.) 16 THE L'lTHESS: WE WERE IN COMP?_ LANCE. I MISSPOAE.IN l 17 Wi ANSWOR. ' 1
.18 -Q BY MR. HICKEY: WAS IT YOUR CONCERN IN I l
19 FEBRUARY 1983, WhEN YOU WROTE THIS COMMENT, THAT THC j i 20 PEOPLE WHO PERFORMED THE TE S T S WERE NOT QUALIFIED OR THE 21 PEOPLE WHO REVIEWED THE TESTS OR BOTH? 22 A PROBABLY A COMBINATION OF BOTH. I HAD AN I 23 OVERRIDING CONCERN FROM MY DETERMINATION TO DATE IN REVIEW ] 1 l 24 OF THEIR PROCEEDURE, 1 STRONGLY SUSPECTED THAT THE PROCESS i 25 THAT THEY GOT UP TO THAT POINT HAD LEFT US IN DIRECT 11-33 i
1 NONCOMPLIANCE WITH 1043 AND 1047, AMONGST OTHERS. 2 Q~ LET ME PUT THAT QUESTION AGAIN A LITTLE MORE 3 SPECIFICALLY BECAUSE I THINK 1 LEFT IT VAGUE. YOU WERE l 4 TALKING ABOUT A DEFICIENCY REGARDING PERSONNEL NOT HAVING 1 l i 5 RECORDS ON FILE TO DOCUMENT QUALIFICATIONS, RIGHT? l 6 A YES. . l l l ' 7 Q AND MY QUESTION NOW IS, WAS-THAT DEFICIENCY, 8 IN YOUR JUDGMENT, APPLICABLE TO PEOPLE WHO HAD PERFORMED 9 THESE TESTS OR TO PEOPLE WHO HAD REVIEWED THE TESTS? l9 10 A THE COMBINATION OF BOTH, BECAUSE I THINK IF 11 YOU'LL CONTINUE TO REVIEW MY COMMENTS, YOU WILL SEE OTHER 12 P0lNTS IN THE COMMENTS IDENTIFIED THAT SIGN-OFFS HAD TO BE 13 EFFECTED BY PROPERLY QUALIFIED STARTUP AND TEST PERSONNEL. 14 AND 1 BELIEVE SOMEWHERE IN HERE THAT I IDENTIFIED THAT -- 15 WELL, 1 DID -- YOU KNOW, TWG HAD TO REVIEW AND APPROVE 16 EVERYTHING, THAT TYPE OF THING. SO LIKE A
GENERAL COMMENT
17 JUST "O LUMP EVERYTHING IN THAY, 1 DIDN'T SEE WiiE RE WE 18 COMPLIED WITH AP 1043 OR 1047 IN ANY WAY. 19 Q YOU S P' " SIGN-OFF," AS YOU DID IN COMMENT 10, 20 WHAT DO YOU MEAN BY " SIGN-OFF"? 21 A WELL, SOMEWHERE, JUST BASED ON THIS REVIEW 22 WITHOUT GOING BACK AND LOOKING AT THE ACTUAL PROCEDURE 23 THAT I WAS REVIEWING AT THE TIME, THERE WOULD HAVE BEEN A 24 SIGN-OFF FOR A PARTICULAR SECTION FOR EXPRESSION OF EITHER 25 THAT SECTION OR THE RESULTS OBTAINED FROM THAT SECTION TO II-34
1 APPROVE THEM OR DISAPPROVE THEM. AND THAT'S WHAT I WAS 2 SAYING; THAT WHOEVER SIGNS THAT FOR THAT PROCEDURE HAS TO 3 BE A PROPER STARTUP AND TEST ENGINEER. 4 Q IS THAT IN 1047? 5 A I BELIEVE SO, YES. 6 Q TAKE JUST A MOMENT, MR. PARKS, TO LOOK AT 7 EXHIBIT 24 THAT'S IN FRONT OF YOU AND LOOK AT 1047 AND SEE 8 IF YOU CAN IDENTIFY WHAT YOU'RE TALKING'ABOUT. 9 A YOU WON'T BE ABLE TO FIND IT IN THIS BECAUSE 10 YOU DO NOT HAVE THE COMPLETE ENCLOSURES OF THE TEST 11 INSTRUCTION. WHAT YOU HAVE IS THE APPENDICES TO A GENERIC 12 PROCEDURE. CONTAINED WITHIN THE T.I.'S THEMSELVES, YOU 13 WOULD HAVE THAT. 14 Q DO YOU WANT TO LOOK AT THE TEST INSTRUCTION? 15 A YES. 16 Q I THINK THAT'S EXHIBIT 25. 17 A I WOULD ALSO LIKE TO HAVE THE REST OF THE l 18 T.I.'S BECAUSE l'M NOT SURE WHAT T.I. IT WA$ IN. IN FACTj 19 MAVEE I CAN CIRCUMVENT COME OF THIS. 20 Q I HAVE HERE, MR. PARKS, TEST INSTRUCTION l 21 NUMBER 10, " QUALIFICATION OF TEST PERSONNEL." IS THAT THE 22 ONE YOU'D LOOKED AT PREVIOUSLY? I 23 A l'M NOT SURE WHICH IT IS. I WILL SIT AND i 24 REVIEW THE T.I.'S UNTIL I FIND THE APPROPRIATE SECTION. 25 Q OKAY. THE BULK IS SUCH THAT I WON'T MARK ALL l l 11-35
1 0F THESE, BUT I'LL PUT IN FRONT OF YOU T.I.'S 2 THROUGH 7 2 AND 9, 10 AND 11. I DON'T KNOW WHERE 8 IS AT THE MOMENT. 3 S0 1 LOOK AT -- ' 1 4 A WELL, THE FIRST THING I BETTER DO IS LOOK AT 5 SECTION 4.0 BECAUSE I THINK THAT'S WHAT I WAS 6 CHALLENGING -- 7 Q YOU JUST LOOKED AT SECTION 4.0 IN EXHIBIT 26, 8 THAT'S PART OF THE PROCEDURE ON WHICH YOU WERE COMMENTING 9 IN COMMENT NUMBER 107 10 A RIGHT. i 11 MR. JOHNSON: ALTHOUGH, I THINK, JUST FOR THE 12 RECORD, I THINK YESTERDAY THERE WAS SOME QUESTION ON THE 13 PART OF MR. PARKS WHETHER THIS PARTICULAR VERSION WAS THE 14 VERSION THAT HE REVIEWED BECAUSE OF THE -- WELL, I WILL 15 LEAVE IT AT THAT. 1 16 l THE WITNESS: WHAT WAS THE QUESTION? 17 MR. JOHNSON: DO YOU WANT HIM TO REPEAT THE
)
18 QUESTION? I 19 THE WITNESS: NO, HUH-UH. 20 OKAY. NOW YOU'RE ASKING ME ABOUT AP 1047, { 21 RIGHT?
.22 Q BY MR. HICKEY: WELL, I'M ASKING YOU ABOUT --
23 A I MEAN COMMENT NUMBER 10. 24 Q YES, COMMENT NUMBER 10. 25 A OKAY. NOW YOU'RE ASKING -- YOUR EARLIER 11-36
F 1 QUESTION, WMERE DOES IT SAY IN AP 1047 THAT THE COMMENT 2 THAT HAS TO BE SIGNED OFF BY A STARTUP AND QUALIFIED TEST 3 ENGINEER? 4 Q YES. 1 5 A I JUST WANT TO REFRESH MY MEMORY. 1 6 Q I ASKED YOU WHAT SIGN-OFF MEANT, AND YOU WERE l
.I 7 TRYING TO EXPLAIN SPECIFICALLY WHAT IT REFERRED TO 8 SPECIFICALLY BY LOOKING AT TEST PROCEDORES OR 9 INSTRUCTIONS.
10 A RIGHT. T.I. 10, YOU'RE RIGHT. TOO MANY 11 YEARS. 12 DO YOU HAVE THE ONE FOR TEST PERFORMANCE AND 13 THE TEST LOG AND ALL OF THAT, THE T.I? 14 NO, THAT IS TEST INDEX. 1 15 Q THE T.I.'S THAT I HAVE ARE IN THE PILE IN 16 FRONT OF YOU. 17 A I THINK WHAT WE WERE LOOKING AT HERE, AT THIS 33 POINT IN TIME, SAYS SIGN-OFFS HAVE TO BE EFFECTED BY A 19 QUALIFIED AND STARTUP AND TEST ENGINEER. AND IN -- 20 Q WHERE DOES IT SAY THAT7 WHERE ARE YOU 21 READING THAT FROM7 22 A THAT WAS ON MY COMMENTS. 23 Q OH. 24 A LOST IN THE PAPERWORK TRAll HERE. 25 IN T.I. 3, CONDUCT OF TEST, I BELIEVE WHERE 11-37 1 _ _ _ _ _ _ _ ___._.._________m._ _ _ - - - - . - _ _ _ _ - - - - _ _
l 1 IT IDENTIFIES THE STARTUP AND TEST' ENGINEER RESPONSIBLE 2 FOR ASSURING-ALL PREREQUISITES FOR SATISFACTORY l 3 APPLICATION, IT DOES STATE, "0THER PERSONNEL MAY BE [0 4 ASSIGNED BY THE STARTUP TEST ENGINEER TO INSPECT THE 5 PREREQUISITE ITEMS AND SIGN THE ITEM FOR THE STARTUP TEST 6 ENGINEER." THAT'S WHAT IT SAYS. SECTION 3.1.1, STARTUP 7 AND TEST ENGINEER, 8 BUT THEN YOU GET DOWN IN THE POINT WHERE IN 9 THE OTHER T.I.'S IT IDENTIFIES THAT: 10 "IN ORDER FOR A PERSON TO SIGN f 11 ANYTHING ON A TEST REPORT, INDEPENDENTLY l 12 WITHOUT HAVING SUBSEQUENT VERIFICATION l 13 0F A TEST ENGINEER, HE HAS TO BE QUALIFIED 14 AS A LEVEL TWO TEST ENGINEER." ] 15 LEVEL ONE TEST ENGINEER CAN ONLY BE USED AS 1 1 16 LIKE A DATA TAKER UNDUR THE DIRECT SUPERVISION OF A LEVEL j 17 TWO OR LEVEL THREE. i 18 Q ALL RIGHT. THIS PORTION THAT YOU JUST READ 19 INTO THE RECORD, MR. PARKS, FROM SECTION 3.1.1; 0F TEST _ 20 INSTRUCTION NUMBER 3, RELATES TO THE PREREQUISITES FOR THE ' 21 TEST, NAMELY THE TEST PREPARATION, DOES IT NOT? 22 A RIGHT, YES, WHICH WAS THE SECTION IN THE TEST f 23 PROCEDURE THAT I WAS CHALLENGING, SECTION 4.0. i 24 Q OKAY. 25 A AND IN THE SECTION OF THE TEST -- OF THE TEST ; 1 ) 11-38 i a l _ _ _ _ _ _ _ _ - -- _ J
'l PROCEDURES THAT I' W A S CHALLENGING, THE POLAR CRANE LOAD
'2~ ' TEST PROCEDURE, SECTIO' 4.0.1S' IDENTIFIED AS 3 PREREQUISITES. AND THE ONLY PERSON REQUIRED TO SIGN THEM, 4 OFF WAS THE TASK SUPERVISOR. IN ORDER FOR A TASK 5 SUPERVISOR TO BE ABLE TO SIGN THOSE OFF, HE'D HAVE'TO BE 6 QUALIFIED AT LEAST A LEVEL TWO TEST ENGINEER.
l 7; -Q WELL, THIS-SECTION 3.1.1-SAYS THAT "OTHER 8 PERSONNEL MAY BE ASSIGNED BY.THE STARTUP TEST. ENGINEER TO 9 INSPECT PREREQUISITE ITEMS AND SIGN THE ITEM FOR THE 10 STARTUP TEST ENGINEER." 11 A THAT'S CORRECT. 12 Q YOU'RE NOT SAYING THAT SECTION 3.1.1 REQUIRES 13 THAT THAT. PERSON, WHO YOU JUST REFERRED TO -- 14- A THE TASK SUPERVISOR.
'15 Q 'THE TASK SUPERVISOR. 3.1.1:DOES NOT REQUIRE' 16- "THAT'HE BC QUALIFl?D?
17 A NO. 18 Q BUT ANOTHER SECTION THAT YOU JUST REFERRED TO 19 ALSO DOES? 20 A YES. 21 Q WHAT SECTION IS THAT? 22 A I BELIEVE IT'S CONTAINED IN T.I. 10. I MAY 23' BE WRONG. LET ME REVIEW IT FIRST. j i 24' OKAY. ENCLOSURE 3 OF T.I. 10 IDENTIFIES 25 MINIMUM LEVEL CAPABILITY FOR LEVEL ONE, LEVEL TWO, AND 11-39 V
1
' l- LEVEL'THREE TEST E'NGINEER.
- 2 OKAY. LEVEL ONE'S ARE LIMITED TO RECORDING
'3 TEST DATA AND' IMPLEMENTING TEST PROCEDURES. AS FAR AS 4 PLANNING TESTS, SETTING UP THE TEST, INCLUDING THE l' 5 PREPARATION FOR THE TEST, THAT TYPE OF THING, ANYTHING 6 ABOVE AND BEYOND THAT, A MAN HAD TO BE A PERSON --
NOT 7 NECESSARILY A MAN, IT COULD.BE A WOMAN,.HAD TO.BE 8 QUALIFIED AS A LEVEL TWO TEST ENGINEER. 9 IN SECTION 5.4 OF THE REQUIREMENTS, MUCH THE 10 SAME PROCEDURE STATES: : 11 "IN CASES WHERE ON-THE-JOB PARTIC.IPATION 12 HAS.BEEN USED FOR A CAPABILITY LEVELLABOVE WHICH 13 THE INDIVIDUAL IS QUALIFIED, l.E., A PERSON IS 14 NOT A QUALIFIED TEST ENGINEER, THE PERFORMANCE 15 OR RESlfLTS OF THE PERFORMANCE SHALL BE REVIEWED 16 BY PERSONNEL QUALIFIED TO A HIGHER LEVEL." 17 HENCE MY COMMENT HAD TO BE REVIEWED BY A -- 18 SIGNED OFF BY A QUALIFIED STARTUP AND TEST ENGINEER. 19 , Q OKAY. SO SIGN-OFF COULD INCLUDE THEN A-20 REVIEW OF WORK THAT'WAS DONE BY SJMEONE OF A LOWER LEVEL 1 21 IF THE PERSON WHO DID THE REVIEW WAS QUALIFIED? 22 A YES. I DON'T THINK IT SAYS ANYTHING ELSE. 23 JUST SAYS WILL BE QUALIFIED AS A STARTUP AND TEST 24 ENGINEER. 25 Q OKAY. THANK YOU. 11-40 \
-1 MR. JOHNSON: 'OKAY. IS IT IMPORTANT'TO IDENTIF'Y 2 ANY MORE CLEARLY WHAT THE DOCUMENT WAS THAT HE WAS l 1
3 REFERRING TO? f 4' MR. HICKEY: I THINK HE DID. .IT'S,THE ENCLOSURE, l l TEST INSTRUCTION NUMBER ONE. 5 6- 'THE WITNESS: 'AND ALL REVISIONS HE WROTE. 7- .MR. JOHNSON: BUT THF VERSION HE WAS LOOKING'AT -- i
'8 MR. HICKEY: HE WAS LOOKING AT REVISION Z E R O '. - .IT'S 9 . TITLED STR - 1. l 10 MR. JOHNSON:' OKAY.
DO YOU WANT BACK -- THESE AREL l ' i 11 NOT MARKED.- I 12 MR. HICKEY: OFF THE RECORD FOR A MINUTE. , 13 (DISCUSS 10N' HELD OFF THE RECORD.) 14 Q BY MR. HICKEY: MR. PARKS, LET ME DIRECT YOU l 15 NOW TO TWJ OF YOUR COMMENTS THAT RELATE TO THE NO-LOAD 16 YEST. IT'S NUMBER 4 AND NUMBER 9. 17 A OKAY. 1 18 Q BOTH OF THOSE COMMENTS NUMBER 4 AND NUMBER 9 19 ALSO RELATE T'O THE NO-LOAD TEST, DO THEY NOT? j 20 l A THEY APPEAR TO, YES. ; 21 ~Q AND IN SUBSTANCE YOU ASSERTED THAT THESE 22 TESTS SHOULD HAVE BEEN PERFORMED AFTER TURNOVER. 23 A JUST A SECOND. , 24 AT THIS POINT IN TIME, WHEN I MADE THESE 25 COMMENTS ON FEBRUARY 17TH, 1983, THE TEST PROCEDURE IN ; i 11-41 i
1 QUESTION, THE NO-LOAD TEST PROCEDURE, WAS CLASSIFIED AS AN 1 2 OPERATIONAL TEST. AND I THINK THAT MY UNDERSTANDING OF AN 3 OPERATIONAL TEST WOULD REQUIRE IT TO BE A FUNCTIONAL TEST. 4 AND I FURTHER IDENTIFIED THAT SINCE THE TWG HAD NOT 5 APPROVED, THAT PROCEDURE WAS NOT LEGAL. , 6 Q DOES YOUR COMMENT INCLUDE THE IDEA THAT 7 THE -- THESE TESTS SHOULD HAVE BEEN PERFORMED AFTER 8 TURNOVER? 9 A IF THEY WERE GOING TO CLASSIFY THEM AS 10 OPERATION TURNOVER, YES. 11 Q IF THE NO-LOAD TEST WERE A CONSTRUCTION TEST, 12 THEN IT COULD BE DONE BEFORE TURNOVER? 13 A IF 1 REMEMBER THE WAY AP 1047 OR 1043 WORKED, 14 YES, I BELIEVE THAT WOULD BE TRUE. 15 Q AND YOU SAID IN YOUR COMMENTS THAT TWG HAD TO 16 REVIEW THE NO-LCAD TEST RESULTS. 17 A CORRECT. 18 Q AT THE FEBRUARY 23 MEETING THAT YOU ATTENDED 19 WITH MR. BALLARD AND MR. B A R O N AND NUMEROUS OThCR P E O P'. E , 20 WASN'T IT DECIDED THAT TWG WOULD REVIEW THE RESULTS OF T'iE 21 NO-LOAD TEST? 22 A I BELIEVE SO, YES, IT MAY BE. I DON'T REALLY 23 RECALL DISTINCTLY. 24 MR. JOHNSON: WHAT MEETING? WHAT WAS THE DATE? 25 MR. HICKEY: FEBRUARY 23. 11-42
1 MR. JOHNSON: -I'M NOT SURE'THAT CHARACTERIZES IT,
.2 ,
-NOTTBASED ON ANY. THING.YOU SHOWED HIM IN THIS DEPOSITION.
3 MR. HICKEY: WELL) THE' WITNESS SAID THAT.HE HAD A' 1 4 RECOLLECTION THAT;THAT MAY HAVE BEEN THE CASE, BUT HE
'5 WASN'T CERTAIN.
.6 THE WITNESS: WHAT l'M TRYING TO SAY IS MY' RECALL 7 AT THE MOMENT DOESN'T-LED ME TO BELIEVE ONE.WAY-OR THE 8 OTHER. IT MAY HAVE. I DON'T KNOW.
9 Q BY MR. HICKEY: WELL, THE DOCUMENT THAT I 10 SHOWED YOU REFLECTING A TWG MEETING OF FEBRUARY 25, THAT 11 REFLECTS AN AGREEMENT TO REVIEW ~THE NO-LOAD TEST RESULTS 12 BY TWG, DOES IT NOT? THAT'S EXHIBIT 32. 13 A I THINK WE'VE DISCUSSED IT ALREADY.THAT THE 14 FEBRUARY 25 MINUTES OF THE TEST WORK GROUP I DIDN'T CONCUR 15 WITH BECAUCE 'THE MEETING HAD NOT BEEN HELD AND THAT 16' RESULTED IN THF. MARCH IST L f:TTER MEMO Wh.lCH-15 ONE-OF 17- THESE. P
- 18. O RIGHT. WE'VE LOOKED AT THAT.
19 A EXHIBIT 29. 20 Q WELL, THE NO-LOAD TEST RESULTS WERE REVIEWED 21 BY .T W G AND THEY WERE DISCUSSED .A T THE TWG MEETING OF-22 MARCH 4, WERE THEY NOT? 23 A I DO RECALL -- I BELIEVE THAT WE DISCUSSED 24 THE NO-LOAD TEST RESULTS, BUT I'M NOT ABSOLUTELY CERTAIN
' 25 AT THIS MOMENT WHETHER WE DID OR NOT.
11-43
1 Q WHY DON'T YOU LOOK AT EXHIBIT 33, WHICH IS 2 THE TWG MEETING MINUTES OF MARCH 4TH. 3 A RIGHT. THOSE MINUTES WILL IDENTIFY THAT WE 4 DID, IN FACT, DISCUSS A NO-LOAD TEST AND HAD SOME CONCERNS 5 REGARDING THE ACCEPTABILITY OF THOSE TESTS. 6 CAN WE TAKE A SHORT BREAK? 7 (RECESS.) 8 Q BY MR. HICKEY: THE CONCERNS THAT YOU l l 9 EXPRESSED AT THE MARCH 4 TWG MEETING REGARDING THE NO-LOAD l i 10 TEST WERE RELATED TO THE FUNCTIONING OF THE LIMIT ! 11 SWITCHES; IS THAT RIGHT, MR. PARKS? 12 A ARE YOU QUESTIONING ME REGARDING ONLY MY : 13 CONCERNS -- 1 14 Q YES. 15 A -- OR ANYONE'S? i i 16 Q YE3, YOURS. 17 l A I KNOW ONE OF THE THINGS ! BAS CONCEhNED 1 13 ABOUT WAS THE FUNCTIONING OF THE LIMIT SWITCHES. j l 19 Q DID YOU EXP7.5$5 ANY OTHER CONCbRNS ABOUT ThE j 20 NO-LOAD TEST AT Td6 MARCH 4 TWG MEETING? 21 A I BELIEVE I DID, BUT THE MEETING -- I DON'T I
)
22 RECALL WHAT THEY ARE. 23 Q REGARDING THE NO-LOAD TEST? 24 A YES. 1 25 Q DO YOU SEE ANY REFLECTED IN THE MINUTES? 11-44 I _ _ - _ _ -__-____-_--_w
1 'A; NO. l
-2 Q YOU HAVE LOOKED AT THE MINUTES, RIGHT7
-3 A- YES.
l 4 Q 'YOU.DID SIGN THE MINUTES'ON THE FRONT THERE?- .l 15 A YES, 1 DID.
'6 _ Q_ DID YOU SUGGEST ANY ADDITIONS TO THE MINUTES?
7 A AT THIS MOMENT lN TIME, I DON'T RECALL'IF I 8 DID OR NOT. 9 Q MR. RADBILL AGREED TO PROVIDE CLARIFICATION
- 10' ABOUT THE LIMIT SWITCHES AND THEIR FUNCTIONING'AT THE 4
11 MARCH 4 TWG MEETING, DID HE NOT? 1 E < 12 A COULD YOU REPEAT THAT? .] l 13 Q SURE.
)
14 .AT THE MARCH 4 TWG' MEETING, MR. RADBILL i 15 AGREED TO PROVIDE- CL ARIFICATION CONCERNING THE FUNCTIOtilNG l 1
- 16 OF THE' LIMIT SWITCHES DURING THE NO-LOAD TEST?'
17 A 1 BELIEVE HE COMMITTED TO SUPPLY VERIFICATION l 18 ON.EEVERAL ITEMS, YES. L i L 19 Q INCLUDING THA1 ONE? l 1 20 A 1 BEL IEVE SO. l'M NOT ABSCLUTELY CERTAIN At 21 THIS TIME. AND THE MINUTES AREN'T EXACTLY EXPLICIT ON 3 22 THAT. 2.3 Q WERE YOU AWARE AT THE END OF THE MARCH -- j 24 DURING THE MARCH 4 TWG MEETING THAT THERE WAS A FURTHER l
\'
l 25 TWG MEETING TO BE SCHEDULED FOR MARCH 28, 1983? ! 11-45 ) l [ !;
.________._.____.__m_____ _ _ _ _ _ . _ _ _ ______._._._._____._.t ___________._____.-_____..________.____._..____m____ _ _____ _ _ ____ _ _m_ _ _ _ J
o ly ,P a I L1- A I DON'T RECALL, AT THIS MOMENT, IF I WAS-2' AWARE 0FfTHAT 0N MARCHL 4TH.OR NOT. 3' Q LET.ME PUT IT A LITTLE MORE BROADLY. 4 WERE YOU AWARE ON MARCH 4 THERE'WAS TO BE 5 ANOTHER TWG MEETING TO BE SCHEDULED IN THE FUTURE? 6: -A AT THIS POINT IN TIME, l'M NOT CERTAIN-OR 7 CAN'T RECALL WHETHER THERE WAS A DISCUSSION REGARDING A 8 FUTURE TWG MEETING OR NOT. 2 9 Q. DID YOU LATER LEARN AFTER MARCH 4, AT'ANY ; i 10 . TIME, THAT A FURTHER TWG MEETING HAD BEEN HELD ON-11 MARCH 28, 1983 REGARDING POLAR CRANE ISSUES? 12 A AT THIS POINT IN TIME, SIR, MY MEMORY DOES
'13 NOT SERVE TO RECALL WHETHER 1 WAS EVER AWARE THAT THERE 14' WAS A MARCH 20 TWG MEETING OR NOT.
15 Q LET ME SHOW YOU WHAT'S BEEN MARKED AS EXHIBIT 16- 34 TO THIS DEPOSITION, A MEMORANDUM DATED MARCH 31 17 PURPORTING TO BE MINUTES OF THE TWG MEETING HELD ON 18 MARCH 28, 1983, AND ASK YOU IF YOU HAVE SEEN THIS DOCUMENT 19 BEFORE. 20 A SIR, I WAS ESCORTED OFF THE JOB SITE ON MARCH i' 21 23 AND 1 WOULD HAVE NOT HAVE BEEN ON THE JOB SITE TO HAVE 22 SEEN IT. 23 Q l UNDERSTAND THAT. 24 MY-QUESTION IS WHETHER YOU HAVE SEEN IT - 25 BEFORE. i 11-46
j 1 A NO, l' HAVE NEVER SEEN THIS BEFORE. 2 Q OKAY. .LET ME ALSO SHOW YOU, MR. PARKS, WHAT 3 HAS.BEEN MARKED AS EXHIBIT 35 TO THIS DEPOSITION, A
.4 MEMORANDUM DATED MARCH 18TH, 1983, SIGNED BY MR. LAKE, 5 ADDRESSED TO MR. BUCHANAN TRANSMITTING INFORMATION 6 REGARDING ADJUSTMENT OF THE POLAR CRANE UPPER' LIMIT 7 SWITCHES. HAVE YOU SEEN THAT DOCUMENT BEFORE?
8 A I REALLY CANNOT TELL YOU AT THIS MOMENT IN j l 9 TIME IF 1 HAVE SEEN IT OR NOT BEFORE. 10 Q YOU NOTE AT THE BOTTOM LEFT OF THE DOCUMENT 11 IT SHOWS A CARBON COPY TO ED KITLER? 12 A YES, I NOTE THAT. 13 Q AT THE TIME PERIOD OF THIS MEMORANDUM, 14 MARCH 18, 1983, WAS MR. KITLER THE CHAIRMAN OF THE TEST
.15 WORKING GROUP?
16 A I REALLY COULDN'T TELL YOU. ON MARCH 17TH, 17 1983, I WAS REMOVED FROM THE TEST WORK GROUP, 18 Q AND DO YOU REMEMBER WHO WAS THE CHAIRMAN OF ) i 19 THE TEST WORK GROUP ON MARCH 17? l 1 I 20 A AS FAR AS I CAN RECALL AT THIS MOMENT, 1 21 BELIEVE ED KITLER WAS THE CHAIRMAN OF THE TEST WORK GROUP. I 22 Q AND YOU DON'T HAVE ANY RECOLLECTION OF ] 23 ANYTHING HAPPENING ON MARCH 18 REGARDING MR. KITLER'S i 24 STATUS AS CHAIRMAN OF THE TWG WORKING GROUP, DO YOU? ! 25 A 1 DO NOT RECALL IF THAT STATUS HAD CHANGED, 11-47
- - _ _ _ 3
L1; NO . ' < 2 -Q BEFOREL-YOUR FEBRUARY 17 COMMENT 5 ON THE LOAD 3 TEST? PROCEDURE, WHICH'WE'VE JUST BEEN LOOKING AT AND -- 4 .LET ME PUT THE'QUESTIONf AFTER SEPTEMBER 1, 1982, THE 5 ORGANIZATION OF TMI -- DID.YOU EVER RAI.SE QUESTIONS , 6- CONCERNING COMPLIANCE WITH.AP 1047? 7 A COULD YOU REPEAT THAT QUESTION? L l . 8' Q SURE. 9 FROM THE SEPTEMBER 1, 1982' REORGANIZATION UP' 10 TILL FEBRUARY 17 WHEN YOU WROTE THE COMMENTS THAT lVE HAVE 11 JUST BEEN.LOOKING AT, IN THAT TIME PERIOD DID YOU EVER 12 RAISE. QUESTIONS CONCERNING COMPLIANCE WITH AP 1047? 13 A EXTERNAL'TO MY COMMENTS ON FEBRUARY 17TH? ! 1 14 Q YES,.NOT INCLUDING YOUR FEBRUARY 17TH 15 COMMENTS. 16 A I DO'NOT RECALL, AT THIS MOMENT, IF 1 DID'OR' 17 NOT. ; 18- Q AND PRIOR TO FEBRUARY.17, DID YOU EVER
.19 DISCUSS THE NEED TO SCHEDULE TWG MEETINGS WITH MR. KITLER?
20 A I DON'T RECALL AT THE MOMENT IF 1 DID OR NOT. 21' Q MR. PARKS, AFTER YOU HAD YOUR PRESS
'22 CONFERENCE ON MARCH 23RD, 1983, AT THAT TIME YOUR COUNSEL l
.i 23 .SENT A LETTER TO THE NRC TRANSMITTING A COPY OF YOUR !
i 24 AFFIDAVIT TO HIM, DID HE NOT? j 25 A I DON'T THINK THAT'S QUITE TRUE. I THINK HE I 11-48 J l
1 SENT IT BEFORE THE NEWS CONFERENCE. 2 Q- OKAY. AND YOU AGREED -- YOUR COUNSEL 3 EXPRESSED YOUR WILLINGNESS TO MEET WITH THE NCR AND 4 DISCUSS THE. EVENT YOU WERE PUBLIC1 ZING IN YOUR' AFFIDAVIT? 5 A I BELIEVE MY COUNSEL MAY HAVE MADE THAT 6 STATEMENT, YES. I KNOW I WAS PERSONALLY WILLING TO MEET 7 WITH THE NRC. DID YOU SET ANY CONDITIONS UNDER WHICH YOU 8 Q 9 WOULD MEET WITH THE NRC7 10 A AT THE MOMENT, 1 DON'T RECALL IF 1 DID OR 11 NOT. 12 Q OTHER EVIDENCE IN THE RECORD INDICATES THAT 13 YOU WERE INTERVIEWED BY NRC REPRESENTATIVES ON APRIL 27TH 14 IN BETHESDA, MARYLAND, AND THEN AGAIN ON MAY 2ND AND 3RD , i 15 IN THE HARRISBURG AREA. THESE DATES ARE ALL 1983. DO YOU 16 HAVE A RECOLLECTION OF BEING INTERVIEWED IN BETHESDA AT 17 THE NRC OFFICES BY NRC INVESTIGATORS? 18 A MR. HICKEY, I HAVE A RECOLLECTION OF BEING l l 19 INTERVIEWED A LOT BY THE NRC, YOU KNOW, FREQUENTLY, AT 20 DIFFERENT TIMES, DIFFERENT PLACES. YOU MAY HAVE MORE ! 21 ACCURATE INFORMATION REGARDING THE DATES AND THE TIMES 22 THAN I DO. 23 Q WELL, LET ME PUT IT THIS WAY. i 24 DO YOU HAVE A RECOLLECTION OF THE FIRST TIME 25 YOU WERE INTERVIEWED BY THE NRC? 11-49 i 1
13: 1 A I HAVE A RECOLLECTION OF IT HAVING OCCURRED, 2 BUT WHERE AND WHO WAS THERE AND WHEN, I REALLY COULD NOT 3 ANSWER YOU AT THIS TIME. 4 MR. JOHNSON: COULD YOU -- I WAS A LITTLE UNCLEAR 5 ABOUT THE SCOPE OF THAT LAST QUESTION. DID YOU MEAN AFTER
'6 HE --
AFTER MARCH 23RD OR BEFORE? 7 MR. HICKEY: NO, AFTER MARCH 23RD. 8 THE WITNESS: SERIOUSLY I HAVE A DISTINCT MEMORY OF l 9 MEETING WITH THE NRC ON NUMEROUS OCCASIONS, YOU KNOW, 10 DIFFERENT INDIVIDUALS FROM THE NRC. BUT WHEN AND WHERE 1 11 AND HOW IT ALL CAME ABOUT, I REALLY DON'T HAVE A GOOD 12 ENOUGH MEMORY AT THIS TIME TO ANSWER YOUR QUESTION ANY
- 13. MORE DIFFERENTLY.
14 Q BY MR. HICKEY: OKAY. WHEN YOU MET WITH THE 15 NRC, WAS YOUR COUNSEL, MR. DEVINE, NORMALLY PRESENT WITH 16 YOU? 17 MR. JOHNSON: AGAIN -- 18 Q BY MR. HICKEY: THE QUESTIONS l'M ADDRESSING, 19 MR. PARKS, ARE AFTER YOUR PRESS CONFERENCE. L 20 A IF MEMORY SERVES ME CORRECTLY AT THIS TIME, 1 21 BELIEVE THAT MR. DEVINE WAS PRESENT, 22 Q DID YOU NORMALLY TAKE NOTES WHEN YOU WERE l l 23 INTERVIEWED BY THE NRC? l l 24 A NO. l l 25 Q DID MR. DEVINE? l I 11-50 l [
- _ _ _ _ - _ _ - _ - - - _ - _ _ _- . - - - _ - -_ - - - - a
l' 'A I REALLY DON'T REMEMBER IF HE DID OR NOT. AT 2 LEAST MY MEMORY AT THIS TIME, DOES NOT SERVE TO PROVIDE ] l 3 ANY RECALL. ! l 4 Q DID YOU EVER TAPE RECORD ANY OF YOUR ,
- i' 5 INTERVIEWS WITH THE NRC?
6 A I DON'T BELIEVE I DID, NO. AT LEAST-1 DON'T 4 7 RECALL AT THIS MOMENT IF 1 DID OR NOT. 8 Q WHEN YOU MET WITH THE NRC INVESTIGATORS, DID 9 THEY INFORM YOU THAT THEY WANTED TO PREPARE A STATEMENT 1 10 FOR YOU TO SIGN THAT WOULD INCORPORATE YOUR INFORMATION? 11 A ARE YOU -- LET ME SEE IF 1 UNDERSTAND YOU. I 12 CORRECTLY. ARE YOU ASKING ME IF ! WAS MADE AWARE OR IF 13 THE NRC OVERTLY STATED THEY WISHED TO PREPARE A STATEMENT ' 14 FOR MY SIGNATURE? j 15 Q EITHER WAY. 16 A AT SOME POINT DURING THE MEETINGS, WHEN THE 17 PROCESS GOT STARTED, I WAS MADE AWARE OF THE FACT THAT 18 EVENTUALLY THERE WOULD BE STATEMENTS THAT KIND OF I 19 CONDENSED THEIR ANALYSIS OF WHAT THE CONCERNS WERE, THAT 20 TYPE OF THING. 21 Q WHEN YOU SAY " STATEMENTS," YOU MEAN WRITTEN 22 STATEMENTS? 23 A RIGHT. l 24 Q AND DID YOU LATER RECEIVE FROM THE NRC l l 25 WRITTEN STATEMENTS FOR YOUR REVIEW? 11-51 1 u_________.________._.
1 A I -- LET ME SEE. I BELIEVE AT SOME POINT IN ; l
- 2. TIME I WAS SHOWN SOME STATEMENTS WRITTEN BY THE NRC, ASKED )
i 3 TO COMMENT ON THEM, TO SEE THEM, THAT TYPE OF THING. BUT l 4 1 REALLY DON'T RECALL RIGHT NOW. , l l 5 MR. HICKEY: MARK THIS, PLEASE. l 6 (WHEREUPON RESPONDENT'S EXHIBIT 37 WAS M.\RKED 7 FOR IDENTIFICATION BY THE NOTARY PUBLIC, AND A COPY 15 8 ATTACHED HERETO.) 9 Q BY MR. HICKEY: MR. PARKS, I'VE HAD THE 10 REPORTER HAND YOU A DOCUMENT THAT HAS BEEN MARKED AS
- 1) EXHIBIT 37. IT'S A 13-PAGE UNSIGNED, TYPEWRITTEN 12 STATEMENT DESCRIBED IN THE BODY AS BEING A STATEMENT OF 13 YOURS. WOULD YOU TAKE A LOOK AT THAT DOCUMENT, PLEASE.
14 A OKAY. 15 MR. JOHNSON: ARE YOU ASKING HIM TO READ THE WHOLE 16 THING 7 17 MR. HICKEY: NO, NOT AT MOMENT. I'M GOING TO ASK 18 HIM A COUPLE OF QUESTIONS ABOUT IT. 19 THE WITNESS: WELL, I MIGHT SAVE YOU SOME TIME. 20 SINCE I DIDN'T SIGN IT, l'M NOT WILLING TO STATE THAT I 21 HAVE EVER SEEN THIS BEFORE. 22 Q BY MR. HICKEY: THAT'S WHAT I WANTED TO ASK 23 YOU BEFORE, IS WHETHER YOU HAVE EVER SEEN IT BEFORE. 24 A AT THIS POINT IN TIME, MY MEMORY WOULD NOT 25 SERVE TO DISTINCTLY IDENTIFY THIS STATEMENT AS EVER HAVING 11-52
I' 1 BEEN REVIEWED OR AUTHORED OR SIGNED BY ME SINCE MV r 2 SIGNATURE DOES NOT APPEAR ON IT. 3 Q WELL, DO YOU RECALL MR. MEEKS, OF THE NRC 4 OFFICE OF INVESTIGATIONS, TELLING YOU IN THE COURSE OF 5 YOUR INTERVIEWS WITH HIM IN APRIL AND MAY THAT HE WOULD 6 WRITE UP A STATEMENT BASED ON WHAT YOU HAD TOLD HIM AND 7 SEND IT TO YOU? 8 A NO, SIR, 1 DO NOT RECALL, AT THIS MOf!E N T , 9 EVER HAVING BEEN TOLD THAT THE NRC WOULD FORWARD A 10 STATEMENT TO ME. 11 Q BUT YOU DID LEARN THAT SOMEHOW? YOU 12 TESTIFIED TO IT A FEW MOMENTS AGO, DID YOU NOT? 13 A ! BELIEVE MY PREVIOUS TESTIMONY WAS I WAS 14 MADE AWARE THAT I WOULD BE PRESENTED WITH SUCH A TYPE OF 15 WRITTEN DOCUMENT. 16 Q HOW WERE YOU MADE AWARE OF THAT? 1 J 17 A APPARENTLY DURING CONVERSATIONS WITH THEM. I' l 18 REALLY DON'T RECALL, AT THIS MOMENT, HOW I BECAME AWARE OF 19 IT. 20 I DO DISTINCTLY REMEMBER HAVING SEEN 21 STATEMENTS PREPARED BY THE NRC. AND THOSE STAT 5MENTS THAT 22 WERE MORE OR LESS THERE WERE WRITTEN UP, IF YOU WILL. IF 23 THOSE STATEMENTS -- WHEN I WAS SHOWN THOSE BY THE NRC 24 PEOPLE INVOLVED, AFTER I REVIEWED THEM, MADE ANY CHANGES 25 TO THEM, THAT TYPE OF THING, I SIGNED THEM. AND 1 SIGNED 11-53 I
1 EVERY PAGE. THAT'S ABOUT THE EXTENT OF MY MEMORY OF THE i 2 WHOLE PROCESS AT THIS MOMENT. 3 Q WELL, MR. MEEKS HAS JUST RECENTLY GIVEN US 4 ,SOME ADDITIONAL INFORMATION. LET ME SEE IF IT WILL HELP 5 YOUR MEMORY. 4 6 MR. MEEKS HAS TESTIFIED THAT. HE SENT TO YOU , 7 AN ORIGINAL STATEMENT, LIKE THE EXHIBIT THAT I HAVE JUST 8 PUT IN FRONT OF YOU, EXHIBIT 37, AND THAT Th5RE WAS AN 9 AGREEMENT WITH YOU TO BREAK DOWN THAT STATEMENT INTO A 10 SERIES OF SEPARATE STATEMENTS. DO YOU REMEMBER THAT, 11- MR. PARKS? i 12 A NOT AT THE MOMENT I DO NOT, NO. 13 Q DID YOU SIGN MORE THAN ONE SEPARATE 14 STATEMENT? l i 15 A I BELIEVE I MAY HAVE, BUT Ar THE MOMENT I i 16 CAN'T RECALL HOW MANY I SIGNED. i 17 Q WELL, DO YOU KNOW THAT IT WAS MORE THAN ONE? I 18 A I BELIEVE IT WAS MORE THAN ONE. . I 19 Q IN THE COURSE OF YOUR MEETINGS WITH THE NRC, 20 DID YOU NOT MEET WITH THEM TO REVIEW YOUR STATEMENT? , 21 A 1 BELIEVE THAT ANY TIME A STATEMENT WAS 22 GENERATED THAT I HAD TO SIGN, 1 MET WITH THEM AT ONE POINT 23 OR ANOTHER AND SIGNED THE STATEMENT. AT LEAST THAT'S WHAT 24 MY MEMORY SERVES ME TO RECALL AT THE MOMENT. 25 Q WOULD YOU .00K, MR. PARKS, AT EXHIBIT 11, 1 i 11-54
1 YOUR.' CALENDAR,.THAT WE'VE IDENT]FIED EARLIER, FOR THE DATE i
'2 OF MAY 19, 1983.
1 i 3- A 19TH? l I 4 Q YES. 5 A OKAY. ' i 6 Q IF YOU WOULD READ THAT PAGE THERE TO 7 YOURSELF, PLEASE.
- 8. (WITNESS COMPLIES.) !
9 Q BY MR. HICKEY: PARTICULARLY THE TOP HALF 10 THAT l'M DIRECTING YOU TO. 11 A OKAY. I HAVE READ IT.
.12 Q DOES THAT REFRESH YOUR RECOLLECTION THAT AT A l
13 MEETING WITH THE NRC ON MAY 19TH, YOU hdRE INFORMED THAT 14 THE NRC REPORT WAS TO BE ISSUED IN PARTS AND THAT YOU 15 DISCUSSED WITH THEM A REHASH, AS YOU PUT IT, OF YOUR 16 STATEMENT? 17 A THAT'S WHAT IT SAYS HERE. THAT MAY OR MAY l 18 NOT NECESSARILY BE -- IT MAY OR MAY NOT NECESSARILY BE 19 MEANING THAT TYPE OF A STATEMENT. MAY MEAN NRC REPORTS . 1 20 WERE TO BE GENERATED FOR PUBLIC ISSUE. 21 Q WELL, DO YOU HAVE A RECOLLECTION WHEN YOU j 22 TALKED ABOUT " REHASHING MY STATEMENT" WHETHER OR NOT YOU 23 TALKED TO THEM ON THE SAME DATE ABOUT SEPARATING YOUR 24 STATEMENT INTO SEVERAL STATEMENTS? 25 A I HAVE NO ADDITIONAL RECALL OTHER THAN WHAT'S 1 11-55
1 READ HERE, AND MY NOTES DURING THIS TIME WERE VERY BRIEF 2 IN NATURE. AND THAT STATEMENT RIGHT THERE DOES NOT 3 REFRESH MY MEMORY, ONE WAY OR THE OTHER, WHICH TYPE OF l 4 REPORT BREAKUP WE'RE TALKING ABOUT. I KNOW AT SOME POINT 5 IN TIME 1 WAS MADE AWARE BY THE NRC THAT THEY WOULD ISSUE 6 A REPORT TO THE COMMISSION, AND THOSE REPORTS TO THE 7 COMMISSION WOULD BE COVERING SPECIFIC ITEMS OR AREAS OF MY 8 AFFIDAVIT. THAT MAY BE WHAT l'M TALKING ABOUT THERE. 9 Q OKAY. 10- A I REALLY CAN'T RECALL AT THE MOMENT. 11 Q BUT YOU DON'T HAVE ANY RECOLLECTION OF 12 AGREEING TO ISSUE SEPARATE WRITTEN STATEMENTS -- YOU 13 SIGNING SEPARATE WRITTEN STATEMENTS? 14 A NO, NOT AT THE MOMENT, 1 DON'T. I BELIEVE I j l 15 DID SIGN MORE THAN ONE STATEMENT, BUT NOW THAT DOES NOT -- J l 16 THAT SHOULD NOT NECESSARILY BE CONSTRUED THAT I AGREED TO I 17 BREAK MY CONCERNS INTO SEPARATE STATEMENTS BECAUSE I DON'T l 18 HAVE ANY INDEPENDENT RECOLLECTION OF THAT AT THE MOMENT. l 19 MR. HICKEY: l'M GOING TO ASK THE REPORTER TO MARK 20 AS EXHIBIT 38 A SIX-PAGE TYPED STATEMENT SIGNED APPARENTLY 21 BY MR. PARKS DATED JUNE 6, 1983. 22 (WHEREUPON RESPONDENT'S EXHIBIT 38, 39 AND 40 23 WERE MARKED FOR IDENTIFICATION BY THE NOTARY PUBLIC, AND 24 COPIES ARE ATTACHED HERETO.) l 25 THE WITNESS: IS THERE A QUESTION PENDING? . I1-56 l l l
l
)
1 : -Q BY'MR. H I C K E Y.: HAVE YOU HAD A CHANCE TO 2 -REVIEW-THE EXHIBIT?.
I 3 A l'HAVE NOT REVIEWED IT IN ITS ENTIRETY. 1 4 Q WHAT IS THE DOCUMENT? 5 A iAPPEARS TO BE THE STATEMENT PREPARED BY THE j [6: NRC AND SIGNED BY M E .- 7 Q WHEN DID .YOU SIGN IT? 8 A JUNE 6TH, 1983. 9 Q WHEN YOU SIGNED IT, DID YOU MEET WITH THE NRC 10 TO' DISCUSS IT BEFORE SIGNING IT?- 11- A I COULD NOT TELL YOU, AT THIS-MOMENT, !F'I 12 MET WITH THEM BEFORE.I SIGNED IT OR IF I MET WITH THEM 13 WHEN 1 SIGNED IT, IF'THAT MAKES: SENSE.
' 1 41 Q WELL, MR. MEEKS, WHO'S LISTED THERE AS THE' 15 INVESTIGATOR, HE WAS PRESENT WHEN YOU SIGNED THE DOCUMENT, 16 'WAS HE NOT?
17 A .I BELIEVE HE WAS, YES. 18- Q DID YOU TELL MR. MEEKS THAT THE MATERIAL IN 19 THIS STATEMENT WAS TRUE AND CORRECT 7 20 A 1 BELIEVE, SIR, THAT ON THE VERY BACK PAGE 21 THERE'S A STATEMENT THAT SAYS "I SWEAR THE FOREGOING 22 STATEMENT IS TRUE AND CORRECT.TO THE BEST OF MY 23 KNOWLEDGE." 24 Q IF YOU LOOK AT THE FIRST PARAGRAPH ON THE 25 FIRST PAGE, YOU STATED THAT AT THE REQUEST OF MR. VORSE 11-57
1 AND.MR. MEEKS THE FOLLOWING STATEMENT IS ONE OF FOUR l i 2 SEPARATE STATEMENTS THAT YOU WOULD BE SUBMITTING ON ! 3 TMI-2;lS THAT CORRECT? I 4 A- THAT'S WHAT IT SAYS, YES. l 5- Q DO YOU REMEMBER TELLING THESE GENTLEMEN THAT?
)
1 6 A I DO NOT HAVE ANY INDEPENDENT RECOLLECTION AT 7 THE MOMENT, NO. BUT, YOU KNOW, THE DOCUMENT SPEAKS FOR
-)
I 8 ITSELF. ! 1 9 Q LET ME ASK YOU TO TAKE A LOOK, MR. PARKS, AT 4 10 EXHIBIT 39. 5 11 A OKAY. j! 12 Q CAN YOU IDENTIFY THAT DOCUMENT? 13 A IT APPEARS TO BE ANOTHER STATEMENT PREPARED 14 BY THE NRC. 15 Q AND DID YOU REVIEW THE STATEMENT? ! 16 A I CAN ONLY STATE, AT THIS TIME, APPARENTLY I 17 DID BEC#-'d i NOTICE CHANGES MADE TO IT AND MY INITIALS DO 18 APPEAR O h, IT AND I DID SIGN IT. 19 Q WHEN DID YOU SIGN IT? 20 A ACCORDING TO THE DOCUMENT, IT'S THE 25TH DAY 21 OF JULY, 1983. , 22 Q OKAY. AND THERE ARE TWO OTHER GENTLEMEN'S l 23 NAMES ON THE SIGNATURE PAGE, MR. MEEKS AND MR. BEACH. 24 A RIGHT. 25 Q WERE THEY PRESENT WHEN YOU SIGNED THE 11-58
.___________.________._____________________._________J
l 2 DOCUMENT? 2 A I BELIEVE THEY WERE. ';
'3 MR. JOHNSON: COULD YOU CLARIFY? THE VERSION THAT 4 YOU GAVE HIM HAS SOME EXTRANEOUS THINGS ON IT.
5 Q BY MR. HICKEY: YES. THE DOCUMENT, EXHIBIT.39. l 6 THAT YOU HAVE IN FRONT OF YOU, MR. PARKS, 7 HAS, AT THE UPPER RIGHT-HAND CORNER AT THE TOP OF THE PAGE j 8 TYPED IN " EXHIBIT 27." 1 THINK ALL COUNSEL AGREE THAT WAS 9 N3T ON THE DOCUMENT WHEN YOU SIGNED IT. THERE ARE -- ALSO 10 IS UNDERLINING IN PORTIONS OF THE DOCUMENT, AND THE I 11 ORIGINAL VERSION SIGNED BY YOU DID NOT HAVE UNDERLINES IN 12 IT EITHER. 13 A RIGHT. I GUESS. I DON'T REALLY RECALL IF IT 14 HAD UNDERLINING OR NOT. j 15 Q OKAY. WOULD YOU LOOK NOW AT EXHIBIT 40, 16 PLEASE, MR. PARKS. 17 A OKAY. l
'I 18 Q ALL RIGHT. CAN YOU IDENTIFY THAT?
19 A IT, TOO, APPEARS TO BE A STATEMENT PREPARED l 20 BY THE NRC AND SIGNED BY ME, ALSO ON THE 25TH DAY OF JULY 21 0F 1983. 22 Q DID YOU REVIEW THAT STATEMENT BEFORE SIGNING 23 IT? I 24 A I CAN ONLY BELIEVE THAT I DID IN THAT THERE j 25 ARE CORRECTIONS MADE IN THE BODY OF THE STATEMENT AND 11-59 I 1
l' INITIALED BY'ME. 2 Q WHEN YOU WERE SIGNING AND SWEARING TO THESE 3 STATEMENTS THAT ARE EXHIBITS 38, 39, AND 40, WHAT DID YOU l 4 DO, IF'ANYTHING, TO ENSURE THAT THE STATEMENT, THE TYPED i 5 DOCUMENT, ACCURATELY REFLECTED WHAT YOU HAD TOLD THE NRC? i 6 A I REVIEWED-THE DOCUMENTS; AND IF THE DOCUMENT 7 ' AGREED WITH WHAT MY MEMORY WAS OF THE FACTS, AS I BELIEVE 8 THEM TO BE TRUE, TO THE BEST OF MY KNOWLEDGE, THEN I MADE 9 ANY CHANGES THAT WAS NECESSARY OR SIGNED THEM, WHATEVER ; l 10 THE CASE MAY HAVE BEEN.. l
.11 Q DID YOU REVIEW, IN THE COURSE OF DECIDING i
12 WHETHER TO SIGN THESE STATEMENTS, ANY NOTES THAT HAD BEEN ; 13 TAKEN DURING THE INTERVIEWS WITH THE NRC? ! 14 A I BELIEVE, SIR, THAT I TESTIFIED PREVIOUSLY I 15 DIDN'T TAKE NOTES. 16 Q I WAS NOT ASKING ABOUT NOTES THAT YOU TOOK. 17 DID YOU REVIEW ANYBODY'S NOTES THAT WERE TAKEN DURING THE 18 INTERVIEWS WITH THE NRC? 19 A I DO NOT RECALL EVER SEEING ANY NOTES THAT 20 WERE TAKEN BY ANYONE DURING THE -- MY CONVERSATIONS WITH 21 THE NRC; NOT AT THIS MOMENT, I DON'T. 22 Q OKAY. WELL, BOTH MR. MEEKS AND, 1 THINK, , i 23 MR. DEVINE HAVE TESTIFIED THAT THEY TOOK NOTES DURING YOUR 24 INTERVIEWS. DO YOU HAVE ANY RECOLLECTION OF REVIEWING < 25 THOSE NOTES BEFORE SIGNING THESE STATEMENTS? 11-60
L 1" A NOT AT THE~ MOMENT, I DO NOT HAVE ANY 2 RECOLLECTION OF DOING THAT. IF MR. MEEKS'TOOK NOTES-l 3' ;DURING THE COURSE OF HIS INTERVIEW, THOSE NOTES DEFINITELY g
' 4' .WOULD NOT HAVE'BEEN SHARED WITH M E ~.
5 .Q WHY DO YOU SAY THAT? 6- A I THINK THAT NRC POLICY WOULD PREVENT THAT. 7 BUT l'M --.THAT'S A GUESS ON MY PART.
-8 Q WELL, YOU HAVE NO RECOLLECTION OF MR. MEEKS 9 GOING OVER HIS NOTES-WITH YOU SO THAT YOU COULD ENSURE 101 THAT WHAT WAS IN HIS NOTES WAS CORRECT?
11 A THAT'S TRUE, I DO NOT HAVE ANY INDEPENDENT' 12 RECOLLECTION OF THAT EVER HAVING OCCURRED. 13 Q WERE YOU ASKED BY THE NRC TO PROVIDE ANY ADDITIONAL DOCUMENTS OR NOTES OR SUPPORTING MATERIALS THAT 15 YOU COULD GIVE TO TMEM IN CONNECTION WITH THEIR 16 INVESTIGATION? 17 A I BELIEVE, IF MY MEMORY SERVES ME CORRECTLY, 18 THE'LAST PART OF THE YEAR IN 1983 THE NRC REQUESTED'THAT I
.19 RETURN TO THE WASHINGTON D.C. AREA AND MEET WITH THE NRC 20 DIVISION REGARDING THE ACCIDENT AT TMI.
21 Q l'M NOT SURE YOU HEARD MY QUESTION, 22 MR. PARKS. WHAT I WAS REALLY ASKING WAS SOMETHING E L S E..
'I 23 WERE YOU ASKED BY THE NRC TO PROVIDE 24 DOCUMENTS TO THEM, NOTES, DOCUMENTS OR RECORDS, IN 25 CONNECTION WITH THEIR INVESTIGATION OF YOUR ALLEGATIONS AT II-61
______.___________m_____.________ _ _ _ _ . . _ _ . _ .__ _ _}
i 1 ANV TIME? 2 A OH, I BELIEVE THAT, AT ONE POINT IN TIME, I i 3 WAS ASKED IF- 1 HAD ANY DOCUMENTS. 4 Q AND DID YOU TURN OVER DOCUMENTS TO THE NRC? i 5 A WELL, 1 THINK, IF 1 REMEMBER YOUR STATEMENT
~6 YESTERDAY, I TURNED OVER 639 PAGES OF DOCUMENTS.TO'THEM.
7 Q LET -- 8 A I MAY BE WRONG WITH THE NUMBER, BUT l'M SURE 9 YOU CAN CORRECT ME. j I 10 MR. HICKEY: l'LL ASK THE REPORTER TO MARK THIS AS 11 EXHIBIT 41, PLEASE. 12 (WHEREUPON RESPONDENT'S EXHIBIT 41 WAS MARKED 13 FOR IDENTIFICATION BY THE NOTARY PUBLIC, AND A COPY IS 14 ATTACHED HERETO.) 15 Q BY MR. HICKEY: I HAVE SHOWN YOU WHAT'S BEEN , 6 16 MARKED EXHIBIT 41 TO YOUR DEPOSITION, MR. PARKS. 17 DO YOU RECALL ON OR ABOUT JULY 25 PROVIDING 18 APPROXIMATELY 639 PAGES OF DOCUMENTS AND NOTES OF YOURS ; 19 RELATING TO THE TMI-2 OPERATION TO THE NRC THROUGH YOUR 20 LAWYER, MR. DEVINE? l 21 A I RECALL TURNING DOCUMENTS OVER TO THE NRC 22 PRIOR TO REVIEWING THAT NOTE THERE THAT YOU IDENTIFIED AS 23 EXHIBIT NUMBER 41. I COULD NOT HAVE TOLD YOU THAT DATE, 24 BUT THAT DATE IS JULY 25TH, ACCORDING TO THE NOTE. 25 Q YOU REMEMBER GIVING A STACK OF DOCUMENTS TO 11-62
1 1 THE NRC; VOU JUST-DON'T REMEMBER THE DATE? 2 A YES,_ SIR, THAT'S CORRECT. I 3 Q DID YOU GIVE THE NRC ALL THE DOCUMENTS THAT 4 YOU HAD THAT WERE RELATED TO-THE INFORMATION YOU WERE 5 PROVIDING THEM? 6 A 1 -- AT Th!S TIME, MY MEMORY SERVES TO , 7 PROVIDE ME WITH THE BELIEF THAT I DID PROVIDE ALL MY I 8 DOCUMENTS THAT I HAD IN MY POSSESSION TO THE NRC. 9 Q LET ME PHRASE THE QUESTION THE OTHER WAY 10 BECAUSE SOMETIMES THAT'S THE WAY PEOPLE'S-MEMORY WORKS. 11 DO YOU HAVE A RECOLLECTION OF SPECIFICALLY
\
12 HOLDING BACK SOME DOCUMENTS THAT YOU DID NOT GIVE TO THE l 13 NRC? i 14 A NO, I DO NOT. NOT AT THE MOMENT. 15 Q AND YOU KEPT, YOU OR YOUR COUNSEL, KEPT, DID 16 YOU NOT, A COPY OF THE SET OF DOCUMENTS THAT YOU WERE 17 PROVIDING? 18 A I DID NOT KEEP A COPY OF THE DOCUMENTS I 19 PROVIDED, AND 1 CANNOT REALLY ANSWER, AT THIS MOMENT, 20 WHETHER OR NOT MY COUNSEL DID. I REALLY DON'T RECALL. 21 MR. HICKEY: l'LL ASK THE REPORTER TO MARK THIS AS 22 42, 23 (WHEREUPON RESPONDENT'S EXHIBIT 42 WAS MARKED 24 FOR IDENTIFICATION BY THE NOTARY PUBLIC, AND A COPY IS 25 ATTACHED HERETO.) 11-63
-------__________J
- . _ _ - _ _ _ _ _ __ .- .- . _ = - . ._. __ -_ - _ l 1 Q BY MR.. HICKEY: IF YOU WOULD LOOK AT l 2 EXHIBIT 42, MR. PARKS, I'LL REPRESENT TO YOU THAT THE
)
3 THREE PAGES THAT CONSTITUTE THAT EXHIBIT WERE PART OF A l 4 PACKAGE OF APPROXIMATELY 639 PAGES PROVIDED TO US BY THE .l l 5 NRC AND REPRESENTED TO BE THE DOCUMENTS THAT MR. MEEKS 6 RECEIVED ON OR ABOUT JULY 25 FROM YOU OR YOUR COUNSEL. l 7 DO YOU RECOGNIZE THE HANDWRITING ON THE TOP 8 SHEET WHERE IT SAYS " PARKS LOGS"? 9 A BEFORE I ANSWER THAT, CAN I RESTATE YOUR j 10 QUESTION AND MAKE SURE I UNDERSTAND? 11 DID YOU CHARACTERIZE THIS DOCUMENT AS, IN 12 FACT, BEING-PART OF THE DOCUMENTS THAT WERE TURNED OVER TO 13 THE NRC? 14 Q I WAS REPRESENTING TO YOU THAT IT WAS 15 RECOMMENDED TO US BY THE NRC THAT THIS WAS -- THIS 16 DOCUMENT WAS PROVIDED TO US IN A STACK OF ABOUT 639 f 17 DOCUMENTS, AND THEY TOLD US THAT THOSE WERE THE 639 PAGES , 18 OF DOCUMENTS TURNED OVER BY YOU OR YOUR COUNSEL TO THE 19 NRC. ; 20 A WELL, I COULD NOT, AT THIS POINT IN TIME, 21 TELL YOU IF THIS WAS, IN FACT, PROVIDED TO THE NRC OR NOT. ; 22 Q OKAY. WELL, DO YOU RECOGNIZE THE HANDWRITING 23 ON THE DOCUMENTS? 24 MR. JOHNSON: THE ORIGINAL QUESTION IS -- WAS ON 25 THE FIRST PAGE, I THOUGHT. 11-64
1i k 1- 'MR. HICKEY: YES. 2 Q BY MR.. HICKEY: START WITH THE.FIRST-PAGE. 3 A NO, 1 DO NOT. 4- -Q HOW ABOUT THE SECOND4 AND THIRD PAGE? S' .~A THE SECOND AND-THIRD PAGE IS DEFINITELY MY 6-' HANDWRIT 1NG.
.7 Q AND.D0 YOU RECOGNIZE WHAT THOSE TWO PAGES 8 ARE?
9' A 1- WOULD SAY, THIS IS PURELY SPECULATION ON MY 10 PART, THAT THEY. APPEAR TO BE AN ATTEMPT TO PROVIDE A 11 CHRONOLOGY OF EVENTS. 12 Q WERE THESE TWO PAGES A PORTION OF.SOME-LARGER 13 DOCUMENT? 14 A AT THIS POINT.IN TIME, SIR, I COULDN'T REALLY 15 TELL YOU IF THEY WERE OR THEY WEREN'T. THEY APPEAR JUST j
.16 TO BE HANDWRITTEN NOTES.
17 Q IS ALL THE HANDWRITING ON THOSE TWO PAGES 18 YOURS? 19 A IT APPEARS TO BE, YES. l i 20 Q BUT YOU DON'T HAVE ANY RECOLLECTION OF UNDER I 2 1' WHAT CIRCUMSTANCES YOU WROTE THOSE TWO PAGES? 22 A NOT AT THE MOMENT I DO NOT, NO.
'23 MR. hlCKEY: MARK-THIS 43.
24 (WHEREUPON RESPONDENT'S EXHIBIT 43 WAS MARKED l l 25 FOR IDENTIFICATION BY THE NOTARY PUBLIC, AND A COPY IS l 11-65
l
'1 ATTACHED HERETO.)
2 Q BY MR. HICKEY: HAVE YOU REVIEWED EXHIBIT 43, 3 MR. PARKS? i 4 A I HAVE LEAFED THROUGH IT. 5 Q l'LL ALSO REPRESENT'TO YOU THAT THIS DOCUMENT 6' ALSO WAS IN THE PILE OF APPROXIMATELY 639 PAGES PROVIDED I l 7 TO US BY THE NRC AND. REPRESENTED TO BE COPIES OF THE i 8 MATERIALS PROVIDED BY YOU TO THE NRC. 9 DO YOU RECOGNIZE EXHIBIT 43? ! 1 l 10 A 1 REALLY -- l 1 11 THE REPORTER: 1 CAN'T HEAR YOU. I i 12 THE WITNESS: NO, NOT AT THIS MOMENT, NO. IT 13 APPEARS TO BE IN MY HANDWRITING THOUGH. 14 Q BY MR. HICKEY: 1 DIDN'T UNDERSTAND YOUR l '15 ANSWER TO MY FIRST -- 1 16 A YOU ASKED ME IF 1 RECOGNIZE IT AND 1 SAID l 1 17 "NOT AT THIS MOMENT I DO NOT, NO." I DO NOT RECALL THIS 18 DOCUMENT. 19 Q BUT IT'S IN YOUR HANDWRITING, THE FIRST SIX 20 PAGES, 1 MEAN? 21 A SURE. IT DOES APPEAR TO BE. 22 Q WHY DON'T YOU TAKE A MINUTE AND READ THROUGH i 23 THE SIX PAGES THAT YOU WROTE. 24 (WITNESS COMPLIES.) 7 25 THE WITNESS: OKAY. I HAVE READ THE FIRST SIX 11-66 l
---- __ _ - - - - _ - - _ - -_- -- _ a
[ 1 PAGES.- 2 Q BY MR. HICKEY: HAVING READ.THE FIRST-SIX ; 3' PAGES, MR. PARKS, D0'YOU NOW HAVE SOME BETTER'RECOLLECTI'ON 4 0F WHAT THIS DOCUMENT IS? 5 A~ NO, I DO NOT. I WOULD SAY THAT I.BELIEVE l-
~6 HAVE SEEN THIS DOCUMENT BEFORE. I BELIEVE I SAW A' PORTION 7- OF ONE OF THE'PAGES OR POSSIBLY TWO OF THE PAGES IN MY 8 CIVIL PROCEEDING AS PRESENTED TO ME BY MR. RICHARDSON.
- 9. Q WHICH PORTION OF IT DO YOU THINK YOU SAW?'
10 A I REALLY DON'T RECALL. 11 Q 'D I D IT INCLUDE THE TITLE PAGE THAT7 SAYS " T M I ,- h
- ]
12 THE BECHTEL CONNECTION"? ; i 13 A THAT'S WHAT I SEEM TO RECALL, RIGHT. j i 14 Q THAT IS WHAT YOU SEEM TO RECALL? 15 A RIGHT. JUST THAT, "TMI, THE BECHTEL 16 CONNECTION." 17 Q BUT YOU DON'T RECALL HAVING SEEN THE REST OF 18 IT IN THE COURSE OF YOUR CIVIL LITIGATION? I 19 A NO, I DO NOT. NOR DO I RECALL HAVING SEEN 20 THIS DOCUMENT BEFORE TODAY OTHER THAN IN MY CIVIL 21 PROCEEDING. 22 Q WELL, LOOK AT THE ATTACHMENTS THAT ARE 1 23 THROUGH 5. YOU IDENTIFY THEM ON PAGES 5 AND 6, BUT THEN 1 24 THEY'RE ATTACHED AFTER THAT. LOOK AT THOSE ATTACHMENTS I 25 FOR ME, PLEASE, SPECIFICALLY ATTACHMENT ONE. IT'S A ) l i 11-67 _ _ _ _ _ _ _ _ _ _ _ _ - _ - . - - - _ - - - _ - - -- - J
1 JANUARY 14, 1982 MEMORANDUM. DO YOU RECALL SEEING THAT 2 DOCUMENT BEFORE? AND PLEASE TAKE YOUR TIME AND READ IT.
'3 A WELL, AT THIS POINT IN TIME, 1 CANNOT TELL
- 4 YOU IF I HAVE SEEN THIS BEFORE OR NOT. !
5 Q DO YOU SEE THAT THERE IS MATERIAL ON THE 6- BOTTOM -- THIRD AND FOURTH LINE FROM THE BOTTOM.THAT 7 APPEARS TO HAVE BEEN BLACKED OUT OR COVERED OVER IN SOME 8 WAY? DO YOU HAVE A RECOLLECTION OF BLACKING OUT 9 INFORMATION ON THIS DOCUMENT? 10 A WELL, SIR, IF 1 SAID THAT I HAD RECOLLECTION !
\
11 OR NO RECOLLECTION OF BLACKING OUT INFORMATION ON THIS 12 DOCUMENT, THEN IT WOULD IMPLY THAT I HAVE SEEN THIS 13 DOCUMENT BEFORE. AND 1 HAVE AL R E ADY TESTIFIED THAT I HAVE 14 NO RECOLLECTION, AT THIS MOMENT, OF HAVING SEEN THIS 15 DOCUMENT BEFORE. 16 Q OKAY. WOULD YOU LOOK.AT THE REMAINDER OF THE { 17 ATTACHMENTS. ATTACHMENT 2 DOESN'T SEEM TO BE MARKED, BUT I 18 YOU'LL NOTE THAT ON PAGE 5 YOU DESCRIBE ATTACHMENT 2 AS ) l 19 THE, QUOTE, " TECHNICAL PLAN REFERENCING HIGHER THAN l l 1 20 EXPECTED RADIATION LEVELS AND CHANGE IN SCHEDULE WHICH
-21 DEMANDS USE OF POLAR CRANE BEFORE IT'S COMPLETED AND 22 SAFE" --
23 MR. JOHNSON: COULD YOU -- l 24 Q BY MR. HICKEY: -- PERIOD. ) 1 l 25 l GUESS l'M TRYING TO READ THE ATTACHMENT l i
!!-68 l l
l
l
~
- 1. DESCRIPTION THAT~YOU WROTE. LET ME'ASK YOU TO READ--IT, l.
'2 MR.-PARKS. I CAN'T..TELL WHETHER THAT'S A PERIOD.ON PAGE-3 5, ATTACHMENT 2 - WHERE YOU DESCRIBE' ATTACHMENT 2. CAN 4 YOU JUST; READ WHAT YOU WROTE THERE BECAUSE I CAN'T READ
-5 IT.
6- A WELL, SIR, I HAVE TO--TAKE EXCEPTION-WITH'THE 7 STATEMENT THAT-YOU'RE SAYING THAT'l WROTE IT. I DON'T 4 8 RECALL EVER. ACKNOWLEDGING'THAT I WROTE THIS. 9- Q ALL RIGHT. 10 A I SAID THE HANDWRITING APPEARS TO ME MINE.. I 11 'DID NOT ACKNOWLEDGE THAT IT IS.MY HANDWRITING. 12 Q WELL, DO YOU HAVE SOME BASIS FOR DOUBTING-13 THAT IT'S YOUR HANDWRITING, MR. PARKS? 14 A I DON'T RECALL HAVING EVER WRITTEN THIS.
-15 THAT'S WHY.
i 16 Q IT'LOOKS LIKE YOUR HANDWRITING, DOESN'T IT? 17 A SURE. 18 Q OKAY. WELL, TELL ME WHAT ATTACHMENT 2 IS 19 DESCRIBED AS -- THE WORDS THAT YOU MAY HAVE WRITTEN, BUT 20 AREN'T CERTAIN ON PAGE 5. 21 I THINK THE WORD THAT YOU YOU'RE GROPING ON i 22 LOOKS LIKE " EXPEDITIONS" OR SOMETHING TO THAT NATURE. ; 23 MR. JOHNSON: " EXPEDITIOUS." 24 THE WITNESS: COULD BE. I 25 Q BY MR. HICKEY: IS THAT A PERIOD BEFORE 11-69 i
- - - - - . _ - - - _ _ . - - - - _ _ _ _ _ _ __ . _ _ _ _ _ _ _ _ __ _ _ __ _ _ J
I 1 " EXPEDITIOUS"? ] i 2 A IT'S GOT TO BE A PERIOD OR A COMMA OR A MARK. 3 Q THAT DOESN'T ENLIGHTEN ME VERY MUCH. READ 4 THE SENTENCE AND SEE IF YOU UNDERSTAND. i 5 .A " TECHNICAL PLAN REFERENCING HIGHER THAN q l 6 EXPECTED RADIATION LEVELS AND CHANGE IN SCHEDULE WHICH 7 DEMANDS USE OF POLAR CRANE BEFORE IT'S COMPLETED AND ! 8 SAFE."" EITHER " EXPEDITION" OR " EXPEDITIOUS SCHEDULE , 9 RESULTED BECAUSE OF HEAD LIFT TASK GROUP'S WRONG l
)
10 ASSUMPTION" 15 WHAT IT LOOKS L I KE . ) i 11 Q NOW, LOOK AT THE DOCUMENT THAT IS ATTACHMENT 12 2. IT'S A TYPED DOCUMENT OF FOUR PAGES, TITLED " TECHNICAL 13 PLANNING." 14 A WELL, THE ONE THAT YOU HAVE -- THE COPY THAT 15 YOU HAVE GIVEN ME DOES NOT HAVE ANYTHING HERE SPECIFICALLY 16 IDENTIFIED AS ATTACHMENT 2. 17 Q THAT'S RIGHT. THE COPY THAT I HAVE DOES NOT 18 EITHER, AND THE COPY THAT WAS PROVIDED TO US DOESN'T 19 EITHER. 20 A OKAY. 21 Q DO YOU THINK YOU CAN CONFIRM THAT THOSE FOUR 22 TYPEWRITTEN PAGES TITLED " TECHNICAL PLANNING" ARE 23 ATTACHMENT 2 AS DESCRIBED ON PAGE 5? 24 A I WOULD JUST HAVE TO SPECULATE THAT'S 25 PROBABLY WHAT IT IS, RIGHT, SEEING AS HOW THEY'RE 11-70 l
h 1- IDENTIFIED AS ATTACHMENT 2 AND EVERYTHING ELSE SEEMS TO i 2 HAVE AN ATTACHMENT NUMBER. 3- Q HAVE YOU SEEN WHAT WE'LL CALL ATTACHMENT 2 I 4 BEFORE, MR. PARKS? 5 A IF MEMORY SERVES ME CORRECTLY, THERE WAS A l 6 POINT'IN TIME WHERE INFORMATION OF THIS NATURE DID -- I 7 MEAN I BECAME AWARE OF IT. NOW WHETHER THAT WAS THE 8 DOCUMENT THAT I WAS PROVIDED WITH WHEN I WAS AT THE JOB ] 9 SITE OR NOT, I DON'T KNOW. I REMEMBER THE WHOLE DEAL WITH l 10 THE QUICK SCAN AND PROBLEMS WE WERE GOING ThROUGH. 11 Q YOU REMEMBER THE DEAL WITH THE QUICK SCAN AND 12 WHAT? 13 A AND THE PROBLEMS WE WERE GOING -- LEFT WITH ! 14 BECAUSE OF HYPOTHESIS OF THE RADIATION LEVELS. 15 Q AND ARE YOU TESTIFYING THAT YOU RECALL OR DO 16 NOT RECALL HAVING SEEN THESE TECHNICAL PLANNING MEETING 17 MINUTES BEFORE? 1 18 A I CANNOT TELL YOU, AT THIS POINT IN TIME, IF 19 1 HAVE SEEN THIS DOCUMENT BEFORE OR NOT. I CAN STATE, AT I 20 THIS TIME, THAT AT ONE POINT IN TIME WHEN I WAS AT TMI, I i 21 WAS AWARE OF THE QUICK SCAN AND QUICK SCAN RESULTS. 22 Q THERE ARE, ON PAGE 2 OF THAT ATTACHMENT, SOME 4 23 HANDWRITTEN ARROWS AND LINES AND THE WORDS "BECHTEL l- 24 ORGANIZATION." DID '/ O U WRITE THOSE, MR. PARKS, THE 25 HANDWRITTEN PARTS, 1 MEAN? I l 11-71 l l c_________________________________ __ __ _ _ _ _ _ _ _ _ 1
1 A I DO NOT HAVE A RECOLLECTION AT THIS MOMENT 2 0F HAVING ~ WRITTEN THAT.
.3 Q DOES THE HANDWRITING IN WHICH "BECHTEL 4 ORGANIZATION" APPEARS APPEAR TO BE YOUR HANDWRITING?
5 A IT COULD BE MY HANDWRITING. 6 Q HOW ABOUT THOSE ARROWS THAT ARE THERE, IS 7 THAT HOW YOU MAKE YOUR ARROWS? 8 A WELL, I THINK THAT'S -- YOU KNOW, WOULD BE A 9 SCIENTIFIC WILD GUESS. I DO NOT KNOW I HAVE ANY WAY -- 10 ANY SPECIFIC WAY OF ALWAYS MAKING AN ARROW. 11 Q YOU CAN'T TELL WHETHER THOSE LOOK LIKE THE 12 WAY YOU MAKE YOUR ARROWS OR NOT? 13 A NO, 1 CANNOT. l 14 Q LOOK AT ATTACHMENT 3. THAT'S A TWO-PAGE 15 TYPED MEMORANDUM DATED JANUARY 12, 1983 16 A OKAY. 17 Q HAVE YOU SEEN THAT DOCUMENT BEFORE? 18 A I CANNOT STATE, AT THIS MOMENT, THAT I HAVE i l 19 SEEN THIS DOCUMENT BEFORE, BUT I AM AWARE OF THE ISSUES l 4 20 THAT THE DOCUMENT DISCUSSES -- OR I WAS AWARE OF IT AT ONE j 1 21 TIME OR ANOTHER. l l 22 Q AND WILL YOU LOOK AT ATTACHMENT 4, A TWO-PAGE ) 1 23 LETTER OF FEBRUARY 7, 1983 TO MR. KANGA FROM MR. BARRETT. 24 A OKAY. 25 Q HAVE YOU SEEN THAT DOCUMENT BEFORE? l 11-72 {
1 A 1 DO NOT RECALL, AT THIS TIME,.EVER HAVING 2 SEEN THAT DOCUMENT BEFORE, NO. 3 Q THE HANDWRITING IN WHICH THE WORDS 4 " ATTACHMENT NUMBER 4" APPEARS ON THAT DOCUMENT, DOES THAT 5 LOOK LIKE YOUR HANDWRITING? 6 A- AGAIN, SIR, IT COULD BE MY HANDWRITING, YES. 7 Q WELL, DOES IT LOOK LIKE YOUR HANDWRITING TO 8 YOU? 9 A IT DOES LOOK LIKE MY HANDWRITING. l l 10 Q HOW ABOUT ATTACHMENT 3'THAT'S WRITTEN ON THE 11 PRIOR ATTACHMENT? I DIDN'T ASK YOU ABOUT THAT, THE 1 12 JANUARY 12, 1983 LETTER. DO THE HANDWRITTEN WORDS 13 " ATTACHMENT 3" LOOK LIKE YOUR HANDWRITING TO YOU? l 14 A YES, SIR, IT DOES LOOK LIKE MY HANDWRITING. 15 Q NOW, WILL YOU LOOK AT ATTACHMENT 5,- 16 MR. PARKS, WHICH IS A FEBRUARY 17, 1983 MEMORANDUM TO 17 MR. THE! SING REGARDING THE POLAR CRANE LOAD TEST SAFETY 18 EVALUATION. 19 A OKAY. l'M LOOKING AT IT. 20 Q HAVE YOU SEEN THAT DOCUMENT BEFORE? 21 A 1 BELIEVE I HAVE SEEN THIS DOCUMENT BEFORE, 1 22 NOT THIS PARTICULAR DOCUMENT, IDENTIFIED AS ATTACHMENT 5, 23 BUT I THINK I HAVE SEEN THE POLAR CRANE -- THIS MEMO, IN 24 ITS UNBLACKENED-OUT FORM. 25 Q WHERE DID YOU SEE THE MEMO IN ITS I 11-73 , i 1
. _ _ _ _ . _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . J
1 UNBLACKENED-0UT FORM? 2 A I BELIEVE 1 HAD REASON TO REVIEW THAT MEMO IN 3 MY ROLE AS SITE OPERATIONS ENGINEER AT TMI. 4 Q AND 1 ASSUME -- WELL, WAS THAT SHORTLY ON OR 5 SHORTLY AFTER FEBRUARY 17, 1983? 6 A I THINK I WAS MADE AWARE OF THIS JUST ABOUT 7 THE SAME TIME THAT I WAS REVIEWING THE POLAR CRANE TEST 8 PROCEDURE, WHICH WOULD HAVE BEEN JUST ABOUT THE SAME TIME 9 THIS MEMO WAS DATED. 10 Q DID YOU MAKE A COPY OF THE MEMORANDUM IN ITS 11 UN3LACKENED-OUT FORM IN THE COURSE OF YOUR REVIEW 7 12 A I DON'T KNOW IF 1 MADE A COPY OF IT DURING 13 THE COURSE OF MY REVIEW OR NOT, BUT I DO BELIEVE, IF 14 MEMORY SERVES ME CORRECTLY AT THIS TIME, THAT I DID 15 PROVIDE A COPY OF THIS MEMO TO THE NRC. 16 Q BLACKENED OUT OR NOT BLACKENED OUT? 17 A 1 WOULD ASSUME NOT BLACKENED OUT BECAUSE I 18 DON'T RECALL HAVING SEEN IT IN ITS BLACKENED-0UT VERSION 9 19 BEFORE TODAY. 20 Q DID YOU PROVIDE ANY DOCUMENTS REGARDING THREE 21 MILE ISLAND, MR. PARKS, To THE FEDERAL BUREAU OF 22 INVESTIGATION IN THE TIME PERIOD FROM FEBRUARY 1983 TO 23 JULY 1983? 04 A I DID PROVIDE ROUGHLY THE SAME DOCUMENTS TO 25 T H ". FBI THAT I PROVIDED TO THE NRC. BUT NOW IF IT WAS 11-74
1- DURING THAT TIME FRAME, I COULD NOT STATE WITH ANY 2 CERTAINTY, 3 Q BUT YOU BELIEVE IT WAS APPROXIMATELY THE SAME 4 DOCUMENTS THAT YOU GAVE TO MR. MEEKS? 5 A I BELIEVE'SO, YES. I
-6 Q DID YOU GIVE THESE DOCUMENTS TO MR. BRINKLEY 7 OF THE FBI? 1 8 A I BELIEVE THAT WAS THE GENTLEMAN'S NAME, YES.
9 Q DID YOU KEEP A COPY OF THE DOCUMENTS THAT YOU ! 10 TURNED OVER TO THE FBI TO MR. BRINKLEY? 11 A I DON'T REALLY RECALL, AT THIS MOMENT, IF I 12 HAD A COPY OF THEM OR IF HE TOOK A COPY OF THEM OR IF HE 13 TOOK THE ORIGINALS OR WHAT. 14 Q DID YOU EVER RECEIVE A LIST OR SOME l
)
15 IDENTIFICATION OF THE DOCUMENTS THAT WERE TURNED OVER -- l 16 A AT THIS -- 17 Q -- EITHER RECEIVE OR PREPARE, I SHOULD ASK?' 18 A AT THIS POINT IN TIME, I DON'T RECALL IF I 19 RECEIVED AN ITEMIZED LIST FROM HIM OR NOT. l 20 Q BEFORE YOU TURNED THEM OVER, DID YOU MAKE AN I 21 ITEMIZED LIST OR MAKE AN ITEMIZED LIST OF THE DOCUMENTS? 22 A I DON'T BELIEVE I DID. I DON'T RECALL IF 1 I 23 DID AT THIS MOMENT. 24 Q CAN YOU TELL US, MR. PARKS, LOOKING AT THE 25 FIRST PAGE OF EXHIBIT 43, THE DOCUMENT WE'VE JUST BEEN I1-75 I
1 TALKING ABOUT, WHETHER THE -- WHETHER YOUR PRACTICE IN 2 WRITING MEMORANDA WAS TO PUT THE DATE IN THE UPPER 3' RIGHT-HAND, CORNER WHERE THERE IS THIS BLACK SMUDGE MARK ON 4 THIS DOCUMENT? 5 A I DON'T THINK I REALLY HAVE A PRACTICE WHEN 6 IT COMES TO WRITING MEMORANDA. IT'S USUALLY WHEN I WRITE 7 A MEMORANDA, 1 TYPE IT. 8 Q LOOK ON PAGE 2 AT THE TOP. WHEN YOU WERE 9 DRAFTING DOCUMENTS, DID YOU NORMALLY PLACE THE DATE OF THE 10 MEMORANDUM ON EACH CONTINUED PAGE? 11 A AGAIN, SIR, I DON'T THINK I HAVE A PRACTICE 12 FOR IT, BUT THERE APPEARS TO BE A SMUDGE MARK ON ONLY PAGE 13 1 AND 2 0F THE DOCUMENT I HAVE. 14 Q AND YOU DON'T RECALL WHETHER YOU HAD A 15 GENERAL PRACTICE? 16 A NO, I DO NOT. 17 Q LOOKING AT THE_ ATTACHMENT NUMBER 5, WHICH IS 18 DATED FEBRUARY 17, WHICH SUGGESTS THAT THIS DOCUMENT WAS 19 PREPARED AFTER -- ON OR AFTER FEBRUARY 17, 1983, DOES THAT 20 HELP YOU FOCUS YOUR RECOLLECTION ANYMORE ON WHEN -- OR i 21 WHETHER YOU MIGHT HAVE PREPARED THIS DOCUMENT? 22 A NO, SIR, IT DOES NOT. BUT I DO NOT HAVE ANY i 23 INFORMATION AT HAND TO DISPUTE YOUR CONCLUSION THAT YOU 24 HAVE DRAWN THAT THIS DOCUMENT WAS PREPARED AFTER l 25 FEBRUARY 17TH, 1983. 11-76 8 m_______.__..____________._.__________.___._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .._ .__ _
i 1 Q YOU SAY YOU DON'T DISPUTE THAT? , j 2 A 1 DON'T HAVE ANY INFORMATION AT MY DISPOSAL 3 TO DISPUTE THAT. i 4 MR. JOHNSON: HE SAID HE MAY HAVE -- HE MAY HAVE j 5 PREPARED. HE DIDN'T CONCEDE THAT HE HAD PREPARED IT; HE 6 SAID HE DIDN'T KNOW WHETHER HE HAD OR NOT. 7 THE-WITNESS: NO. I'M NOT CONCEDING THAT I 8 PREPARED THIS DOCUMENT. 9 Q BY M R ., HICKEY: I UNDERSTAND THAT, MR. PARKS. 10 DID YOU PREPARE DOCUMENTS, AT ANY TIME PRIOR 11 TO YOUR PRESS CONFERENCE AT THE END OF MARCH OF 1933, FOR 12 TRANSMISSION TO NEWSPAPERS GIVING YOUR VIEWS ABOU' THE 13 THINGS AT THREE MILE ISLAND? 14 A NO, SIR, I HAVE NO RECOLLECTION OF PREPARING 15 DOCUMENTS FOR TRANSMITTAL TO NEWSPAPERS OTHER THAN MY 16 AFFIDAVIT. 17 Q RIGHT. AND 1 WAS SPECIFICALLY ASKING YOU 18 ABOUT PRIOR TO YOUR AFFIDAVIT. 19 A RIGHT. 20 Q AND DID YOU SEND ANY LETTERS OR MEMORANDA OR 21 DOCUMENTS TO NEWSPAPERS BEFORE YOUR AFFIDAVIT? 22 A NO, SIR, 1 DID NOT. 23 Q WELL, YOU DID TALK ABOUT SENDING DOCUMENTS TO 24 THE NEWSPAPERS BEFORE YOUR AFFIDAVIT, DIDN'T YOU, 25 MR. PARKS? Il-77
- 1. MR. JOHNSON: TO WHOM?
{ 2 MR. HICKEY: WELL -- l 3 MR. JOHNSON: WHAT DATE? l 4 MR. HICKEY: LET'S SEE IF HE CAN RECALL. i 5 THE WITNESS: THERE WAS A DISCUSSION AT ONE POINT y 6 IN TIME THAT I CAN RECALL, BUT THAT DISCUSSION WAS WITH 7 COUNSEL. 8 Q BY MR. HICKEY: OTHER THAN WITH COUNSEL. 9 A I.BELIEVE-THERE WAS A POINT IN TIME WHERE I 10 SERIOUSLY ENTERTAINED THE THOUGHT OF SUBMITTING AN ARTICLE 11 TO -- AN ANONYMOUS ARTICLE TO THE LOCAL NEWSPAPERS. 12 Q WHAT POINT IN TIME WAS THAT? 13 A DURING THE HEIGHT OF THE CONTROVERSIES OVER 14 THE POLAR CRANE, WHICH WOULD HAVE BEEN THE LAST PART OF 15 '82, THE FIRST PART OF '83. 16 Q AND YOU WERE CONSIDERING SUBMITTING IT 17 ANONYMOUSLY? 18 A YES. 19 Q WHY? 20 A WELL, I SHOULD LISTEN TO MY FORESIGHT TO 21 BEGIN WITH, BUT I DID NOT WANT TO LOSE MY JOB OVER IT. I 22 WAS EXPERIENCING ENOUGH HARASSMENT AND RETALIATION ON THE D > 23 JOB SITE, AND I DID NOT WISH TO EXPERIENCE MORE. I 24 Q AND IS IT YOUR TESTIMONY THAT YOU WERE 25 THINKING ABOUT THIS IN THE LATTER PART OF 1982? ; l 11-78
)
1
]
1 A I CAN RECALL HAVING ENTERTAINED THAT-THOUGHT 2~ DURING THE HEIGHT OF THE CONTROVERSIES. 3 Q WELL, THAT'S A LITTLE -- 4 A THAT'S THE WAY I CHARACTERIZE IT. I REMEMBER S THE CONTROVERSY OF THE POLAR CRANE GOING ON THE LAST PART 6 OF 1982, THE FIRST PART OF 1983. 7 Q WHAT DO YOU MEAN WHEN YOU SAY THE LAST PART 8 OF 1982 AND THE FIRST PART OF 1983? 9 A LAST COUPLE OF WEEKS IN '82 UP UNTIL I WAS , 10 REMOVED FROM THE JOB SITE IN '83. 11 Q YOU LEFT THE JOB SITE ON MARCH 24, DID YOU 12 NOT? 13 A RIGHT. I BELIEVE THAT WAS THE DATE. 14 Q SO THE LAST COUPLE OF WEEKS OF DECEMBER 1982 15 UP UNTIL MARCH? 16 A I BELIEVE THAT WAS WHEN I WAS ENTERTAINING 17 THE THOUGHT, YES. I WAS TRYING TO FIGURE OUT A WAY I 18 COULD GET OUTSIDE AUTHORITIES TO LOOK AT WHAT WAS GOING ON 19 WITHOUT EXACERBATING THE HARASSMENT THAT I WAS ALREADY 20 EXPOSED TO AND EXPERIENCING. l j 21 Q DID YOU COME UP WITH THIS IDEA ON YOUR OWN OR I' 22 DID SOMEONE SUGGEST IT TO YOU? 23 A WHICH IDEA. 24 Q THE IDEA OF SENDING SOMETHING ANONYMOUSLY TO ) I 25 THE NEWSPAPERS? i l 11-79 l l
1 -MR. JOHNSON: TO THE EXTENT IT MAY INVOLVE 2 CONVERSATIONS YOU MAY HAVE HAD WITH COUNSEL, HE'S ENTITLED. .l L- 3L TO. PROTECT.THOSE COMMUNICATIONS IF'IT INVOLVES SUCH. , l l 4 THE WITNESS: 1 THINK THAT ORIGINALLY l'HAD 5 CONCEIVED THE IDEA MYSELF AND LATER CHANGED MY MIND. 6 Q BY MR. HICKEY: DID YOU DISCUSStYOUR IDEA 7 WITH PERSONS.OTHER THAN COUNSEL? 8- A NOT THAT I CAN RECALL. 9- Q .LET ME'JUST --
- 10 A NOT AT THIS MOMENT.
'11 Q SO THE RECORD WILL BE CLEAR,;WERE YOU 12 REPRESENTED BY AN ATTORNEY IN THE LATTER PART OF DECEMBER 13 OF 1982 AND JANUARY AND FEBRUARY 19837 14'- , A NO, SIR, I WAS NOT.
15 Q OKAY. LATER IN MARCH YOU DID BECOME l 16 REPRESENTED BY AN ATTORNEY, DID YOU NOT? l-17 A YES. 18 Q AND AT THE MOMENT THE DATE ISN'T PARTICULARLY 19 IMPORTANT. I BELIEVE IT WAS AROUND MARCH 10 OR 11; IS 20 THAT RIGHT? 21 A IT WOULD HAVE BEEN SHORTLY AFTER THAT, RIGHT. 22 Q ALL RIGHT. WELL, IN ANY EVENT, DURING . i 23 ' DECEMBER AND JANUARY AND FEBRUARY, YOU WEREN'T HAVING 24 CONVERSATIONS WITH COUNSEL ABOUT ANYTHING? 25 A I WAS LOOKING FOR AN ATTORNEY. 11-80 1
1 Q WHEN DID YOU START LOOKING? 2 A FIRST PART OF 1983. 3 Q JANUARY? 4 A. I CAN'T RECALL EXACTLY WHEN, BUT 1 CAN RECALL 5 STARTING TO LOOK FOR AN ATTORNEY. 6 Q AN ATTORNEY TO REPRESENT YOU IN CONNECTION 7 WITH WHAT? 8 A AFTER-I WAS THREATENED ON THE JOB SITE, I 9 BELIEVE WAS WHEN I ACTUALLY STARTED LOOKING FOR AN 10 ATTORNEY, WHICH WOULD HAVE MADE IT THE MIDDLE OF FEBRUARY. Il Q THAT'S.AFTER THE CONVERSATION YOU HAD WITH 12 MR. KITLER IN THE PARKING LOT AT.THE THREE MILE ISLAND, 13 UNIT TWO IN THE MORNING OF FEBRUARY 18TH? 14 A YES. 15 Q AFTER THAT YOU BEGAN LOOKING FOR AN ATTORNEY? 16 A SOMETIME AFTER THAT. 17 Q BEFORE THAT, YOU HAD NOT LOOKED FOR AN 18 ATTORNEY? 19 A NOT THAT I CAN RECALL AT THIS MOMENT, NO. I 20- .MAY HAVE, BUT I CAN REMEMBER DISTINCTLY LOOKING FOR AN 21 ATTORNEY AFTER THAT. 22 Q A MOMENT AGO YOU GAVE AN ANSWER THAT 1 DIDN'T 23 COMPLETELY UNDERSTAND. YOU SAID SOMETHING ALONG THE LINES 24 THAT YOU CONSIDERED SENDING AN ANONYMOUS DISCLOSURE TO THE l-25 NEWSPAPERS AS A WAY OF GETTING ATTENTION OR SOMETHING LIKE 11-81 1
I
-1 THAT FOR THE CONCERNS'. CAN YOU TELL ME WHAT YOUR PURPOSE ;
j L 2 WAS? 3 A I DON'T THINK THAT WAS A PROPER 4 CHARACTERIZATION OF MY RESPONSE. I 5 Q OKAY. THAT'S WHY l'D LIKE YOU TO TELL ME THE I 6 RESPONSE AGAIN BECAUSE I DIDN'T UNDERSTAND IT.
]
I 7 A WHEN 1 -- 1 DID CONSIDER SENDING IN A J 8 DISCLOSURE, TO USE YOUR TERMS, TO THE NEWSPAPERS TO BRING 9 THE SITUATION THAT WAS GOING ON AT TMI TO LIGHT, INCLUDING I 10 THE PROBLEMS THAT HAD BEEN IDENTIFIED ON THE POLAR CRANE 11 AND WITH THE CLEANUP IN QUESTION AND THE WAY THAT THE 12 PEOPLE WHO HAD IDENTIFIED THESE PROBLEMS TO MANAGEMENT 13 HAVE BEEN HARASSED AND RETALIATED AGAINST. 14 Q SO YOU'RE REFERRING TO PROBLEMS WITH THE ; 15 POLAR CRANE, BUT NOT JUST THE POLAR CRANE, ALSO PROBLEMS 16 WITH TMI, IN GENERAL, WAS WHAT YOU WANTED TO BRING TO 17 LIGHT? 18 A RIGHT. 19 Q YOU MENTIONED A THIRD THING, THE PEOPLE WHO 20 RAISED THESE PROBLEMS WERE BEING HARASSED OR RETALIATED 21 AGAINST. 22 A CORRECT. 23 Q WHAT WERE THE PROBLEMS THAT YOU WERE TROUBLED 24 BY REGARDING THE POLAR CRANE THAT YOU FELT NEEDED TO BE 25 BROUGHT TO LIGHT AND LED YOU TO CONSIDER SENDING THIS 11-82
'l ANONYMOUS PUBLICATION?
1 2 A I THINK ALL THE PROBLEMS THAT I HAD WITH THE 3 POLAR CRANE WERE PARTICULARLY ADDED TO MY AFFIDAVIT THAT I 4 SUBMITTED TO THE NRC IN MARCH OF 1983. , 5 Q WELL, I'M TRYING TO HELP WITH THE TIMING OF 6 THIS CONSIDERATION BY YOU. AND SOME THINGS ABOUT THE 7 POLAR CRANE YOU LEARNED ABOUT AT ONE POINT IN TIME AND 8 SOME THINGS YOU LEARNED ABOUT LATER AND SOME YOU LEARNED 9 AT THE TIME YOU WERE THINKING OF SENDING A DISCLOSURE TO 10 THE NEWSPAPER. WHAT WAS YOUR CONCERN ABOUT THE POLAR 11 CRANE THEN? 12 A THE WAY IT WAS BEING REFURBISHED. 13 Q CAN YOU BE SPECIFIC? ! 14 A BASICALLY THE CONCERN CENTERED AROUND 15 MANAGEMENT'S IRRESPONSIBILITY OF THE WAY THAT THEY WERE, 16 IN MY OPINION, INTENTIONALLY VIOLATING EXISTING PROCEDURES 17 TO EXPEDITE THE WHOLE PROCESS OF LIFTING THE REACTOR 18 VESSEL HEAD, THEREBY THE POLAR CRANE CONCERNS WOULD HAVE 19 BEEN INTEGRAL PARTS OF THAT CONCERN. 20 Q AND THEY WERE -- MANAGEMENT WAS 21 INTENTIONALLY -- WHEN YOU SAY " MANAGEMENT," ARE YOU 1 22 TALKING ABOUT BECHTEL OR GPU-N? WHO ARE YOU TALKING 23 ABOUT? 24 A WELL, SIR, IF YOU REMEMBER DURING THAT TIME 25 FRAME, IT WAS AN INTEGRATED MANAGEMENT SETUP, SO IT WOULD 11-83
I i 1 HAVE BEEN BOTH BECHTEL AND GPU-N. I t l 2 Q INTENTIONALLY VIOLATING EXISTING PROCEDURES 3 IN WHAT FASHION? ) l i 4 A WE WEREN'T ADHERING TO THEM. l 5 Q WHAT PROCEDURES? THE PROCEDURES YOU WERE i i 6 USING? ! 7 A THE PROCEDURES THAT WE WERE USING TO 4 8 ACCOMPLISH WORK INSIDE CONTAINMENT, WORK PACKAGES, THAT 9 SORT OF THING. IT JUST SEEMED TO ME THAT AT ONE POINT IN 10 TIME IT BECAME MORE IMPERATIVE TO GET THE WORK DONE THAN 11 TO ADHERE TO THE PROCEDURES THAT GOVERN HOW WE WERE TO DO 12 WORK. 13 Q AND WHEN YOU WERE THINKING ABOUT BRINGING 14 YOUR CONCERNS TO THE ATTENTION OF THE PUBLIC THROUGH A 15 LETTER TO THE NEWSPAPER, WHAT WERE THE CONCERNS, NOT ABOUT 16 THE POLAR CRANE, BUT ABOUT THE SITUATION AT TMI IN 17 GENERAL, THAT YOU FELT NEEDED TO BE BROUGHT TO LIGHT? 18 A AT THIS POINT IN TIME, RIGHT NOW, SIR, 1 19 COULDN'T REALLY ELABORATE ANYMORE. THAT WAS TOO MANY 20 YEARS AGO. 21 1 EVENTUALLY TOOK ALL MY CONCERNS PUBLIC, 22 AND -- 50 1 WOULD BE SAFE -- OR I THINK I WOULD BE SAFE IN 23 ASSUMING THAT ALMOST ANY CONCERN WAS EXPRESSED IN MY 24 AFFIDAVIT AT ONE POINT OR ANOTHER I WAS CONCERNED ABOUT. 25 Q WELL, DID ONE OF YOUR CONCERNS ABOUT TMI I 11-84
g x. 1 1l INCLUDE.THATJMONEY-WAS BEING SPENT IN AN' IRRESPONSIBLE WAY 2 OR WAS1BEING WASTED?' (' 3' A I THINK THAT WAS LESS OF A CONCERN OF MINE
- 4 THAN IT WAS OF LARRY KING'S, BUT I BELIEVE THAT MONEY WAS l
5 BEING WASTED, YES. 6 Q .DID YOU.HAVE A BELIEF OR A VIEW THAT BECHTEL 7 WAS' DIRECTING THE WORK IN A WAY.TO ENSURE THAT'BECHTEL.GOT l 8 THE MOST PROFIT OUT OF THE PROGRAM 7~ 9 A I BELIEVE I WAS.0F THAT'0 PINION WHEN I WAS AT 10 TMI. 11 Q WERE YOU CONCERNED ABOUT WHAT YOU VIEWED AS 12 BECHTEL TAKING OVER THE MANAGEMENT AND GPU-N LETTING THEM 13 DO IT? 14- A TO BE PERFECTLY HONEST WITH YOU, SIR, I COULD i 15 CARE LESS WHO WAS IN CHARGE AS LONG AS THEY.DID IT
'16 CORRECTLY'.
17 Q' -DIDN'T YOU THINK IT WAS A BAD IDEA OF BECHTEL 18 TO BE IN CHARGE SINCE THEY HAD A FINANCIAL INTEREST? 19 A NO MORE SO THE FINANCIAL INTEREST THAT GPU 20 HAD. I GUESS WHAT l'M TRYING TO SAY, SIR, IT DIDN'T. 21 MATTER TO ME WHO WAS IN CHARGE.AS LONG AS IT WAS -- PULLED I 22 THE SHOW OFF PROPERLY. 1 23 Q WHAT WERE THE CONCERNS THAT YOU'HAD IN MIND 24 AT THE TIME YOU CONSIDERED SENDING AN ANONYMOUS STATEMENT 25 TO THE NEWSPAPER RELATING TO HARASSMENT OF PEOPLE WHO
)
11-85
]
, , l
}
1 RAISED CONCERNS? 2 A WELL, LARRY KING AND ED GISCHEL AND I HAD ALL 3 IDENTIFIED PROBLEMS, AS WE SAW THEM ANYWAY; IN FACT, l 4 PROBLEMS WITH THE WAY THE CLEANUP WAS BEING HANDLED AND 5 THE WAY THE POLAR CRANE WAS BEING PUSHED AND THAT TYPE OF 6 THING. AND EACH AND EVERY ONE OF US SUFFERED SYSTEMATIC 7 RETALIATION AND/OR HARASSMENT FOR IDENTIFYING THOSE 8 CONCERNS. I BELIEVE WE WERE VIEWED AS AN IMPEDIMENT TO 9 PROGRESS AS SOMEONE BEING ASSURED THAT WE COMPLIED WITH 10 THE RULES. 11 Q IS IT YOUR TESTIMONY THAT THOSE EVENTS HAD 12 HAPPENED AT THE TIME THAT YOU WERE THINKING ABOUT SENDING 13 SOMETHING TO THE NEWSPAPER? , 14 A THOSE EVENTS HAPPENED. 15 Q l UNDERSTAND THAT. l'M TRYING TO DIRECT YOU 16 TO THE TIMING OF IT. 17 DO YOU BELIEVE THAT AT THE TIME YOU f 18 CONSIDERED SENDING SOMETHING TO THE NEWSPAPER, WHICH I i 19 THINK WE'VE IDENTIFIED WAS BEFORE YOUR AFFIDAVIT -- 20 A UH-HUH. 21 Q -- HAD THESE EVENTS OF WHAT YOU TAKE TO BE 22 HARASSMENT OF MR. KING AND MR. GISCHEL AND YOURSELF 23 HAPPENED? 24 A IF I UNDERSTAND YOUR QUESTION CORRECTLY, 25 YOU'RE TRYING TO ASK ME IF I WAS EXPERIENCING HARASSMENT I1-86
1 AND THE OTHER GENTLEMEN WERE EXPERIENCING HARASSMENT 2 CONCURRENTLY WITH MY CONSIDERATION OF SENDING AN 3- ANONYMOUS -- 4 Q THAT'S EXACTLY RIGHT. l 5 A I BELIEVE I ENTERTAINED THE THOUGHT OF 6 SENDING AN ANONYMOUS DISCLOSURE TO THE NEWSPAPERS UP UNTIL 7 THE DAY I SENT THE PUBLIC DISCLCSURE TO EVERYBODY. I 8 Q WELL, WHEN DID IT BEGIN THOUGH? WHEN DID YOU 9 BEGIN TO CONSIDER THIS? 10 A SIR, AT THIS POINT IN TIME, I COULDN'T REALLY 11 GIVE YOU A DEFINITIVE START DATE. I BELIEVE I HAVE 12 ALREADY. I'D LIKE TO PIN IT DOWN FOR YOU AS BEST I CAN 13 RECALL. 14 (RECESS.) i l 15 Q BY MR. HICKEY: AT THE TIME YOU WERE ] 16 CONSIDERING SENDING THIS -- SENDING AN ANONYMOUS 17 DISCLOSURE TO THE NEWSPAPERS, DID YOU HAVE PARTICULAR l l 18 NEWSPAPERS IN MIND, MR. PARKS? j i 19 A OH, I PROBABLY DID AT THE TIME, BUT I DON'T i l 20 RECALL, AT THIS MOMENT, WHICH ONES THEY WERE. j i 21 Q ARE YOU FAMILIAR WITH A NEWSPAPER CALLED THE 22 PAXTON HERALD? l 1 23 A 1 REMEMBER THAT THERE WAS A NEWSPAPER BY THAT j l 24 NAME IN THE AREA. I 25 Q IN THE AREA OF THREE MILE ISLAND? l i l l 11-87 1 1 ( i l
1 A RIGHT. 2 Q' WAS THAT ONE OF THE NEWSPAPERS THAT YOU 3 CONTEMPLATED SENDING AN ANONYMOUS DISCLOSURE TO? l 4 A I REALLY COULDN'T TELL YOU, AT THIS MOMENT, 5 WHETHER IT WAS ONE OF THEM OR NOT. 6 Q HOW ABOUT THE HARRISBURG PATRIOT? 7 A THAT WAS, I BELIEVE, ANOTHER NEWSPAPER IN THE 8 AREA. 9 Q DID YOU CONSIDER SENDING A DISCLOSURE TO THE 10 HARRISBURG PATRIOT? j 11 A NO. TO BE PERFECTLY HONEST WITH YOU, 12 MR. HICKEY, 1 DON'T THINK I IDENTIFIED WHO, IN MY MIND, I l 13 WOULD SEND ONE TO. IF I DID OR IF 1 DID IDENTIFY ONE IN 14 MY MIND, I DON'T HAVE A RECOLLECTION OF IT AT THIS MOMENT. 15 Q OKAY. ; 16 WAS AN ADDITIONAL CONCERN THAT YOU HAD AT THE 17 TIME THAT YOU WERE CONTEMPLATING SENDING AN ANONYMOUS 18 DISCLOSURE TO THE NEWSPAPERS, THE FACT THAT MR. KUNDER HAD 1 19 BEEN APPOINTED AS THE MANAGER OF THE SAFETY REVIEW GROUP 20 OR -- STOP THE QUESTION THERE. WAS THAT ONE OF YOUR i
-21 CONCERNS, MR. PARKS?
22 A WHAT? THAT HE HAD BEEN APPOINTED MANAGER OF 23 THE SAFETY REVIEW GROUP? 24 Q YES. l 25 A I DON'T THINK I HAD A CONCERN THAT 11-88 J
1 GEORGE KUNDER HAD BEEN APPOINTED MANAGER OF THE SAFETY 2 REVIEW GROUP. I DID BELIEVE, DURING THAT TIME FRAME, THAT 3 THAT HE WAS THE MYSTERY MAN. l l 4 Q WHEN YOU SAY "HE WAS THE MYSTERY MAN," YOU'RE 5 REFERRING TO THE TERM THAT WAS USED IN THE COURSE OF SOME 6 LITIGATION BETWEEN GPU-N AND BABCOCK & WILCOX COMPANY 7 CONCERNING THE TMI ACCIDENT? j 8 A 1 BELIEVE THAT'S PROBABLY WHERE THE PHRASE 9 ORIGINATED AT, BUT 1 THINK THE PHRASE BECAME MORE INTO THE 10 PUBLIC DOMAIN THROUGH AN ARTICLE WRITTEN BY SUSAN 11 STRANAHAN. 12 Q THAT WAS AN ARTICLE THAT APPEARED IN THE 13 WASHINGTON POST? 14 A IT COULD HAVE BEEN THE WASHINGTON POST. I 15- REMEMBER THE NAME OF THE AUTHOR, NOT THE NEWSPAPER. 16 Q DID YOU READ THE ARTICLE BY SUSAN STRANAHAN? 17 A 1 HAVE READ THE ARTICLE BY SUSAN STRANAHAN. 18 Q DID YOU READ IT AT THE TIME IT CAME OUT OR 19 DID YOU LEARN ABOUT IT LATER, AFTER IT HAD BEEN PUBLISHED? 20 A I THINK I READ IT BEFORE 1 WENT PUBLIC, BUT I 21 WOULDN'T SWEAR TO IT.
- 22. WELL, SINCE I USED THE PHRASEOLOGY OF "THE 23 MYSTERY MAN" IN MY AFFIDAVIT, I PROBABLY DID READ IT 24 BEFORE I WENT PUBLIC.
25 Q l'M NOT SURE I HEARD YOU ACCURATELY. YOU 11-89
1 SAID "SINCE I USED THE PHRASEOLOGY 0F THE MVSTERY MAN IN 2 MY AFFIDAVIT I" -- 3 A PROBABLY. 4 Q -- PROBABLY READ THE ARTICLE OF SUSAN 5 STRANAHAN BEFORE YOU WENT PUBLIC? 6 A RIGHT. IF I REMEMBER THAT ARTICLE WAS ! 7 PUBLISHED IN FEBRUARY OR JANUARY OF.1983 8 Q l BELIEVE THAT THE ART I CL'E ' THAT YOU'RE l l 9 REFERRING TO WAS PUBLISHED IN THE WASHINGTON POST IN 10 JANUARY AND FEBRUARY OF 1983. j 11 DID YOU NORMALLY RECEIVE OR READ COPIES OF 12 THE WASHINGTON POST 7 l l 13 A YES, 1 DID. l 14 Q YES, YOU DID? 15 A YES, 1 DID NORMALLY READ THE WASHINGTON POST. l 16 Q IN JANUARY AND FEBRUARY OF 1983? 17 A WHEN I LIVED ON THE EAST COAST, I CONSIDERED 18 THE WASHINGTON POST, THE NEW YORK TIMES TO BE THE TWO BEST 19 NEWSPAPERS ON THE EAST COAST. 20 Q SO DID YOU HAVE A SUBSCRIPTION TO THE POST? 21 A NO. 22 Q TO THE TIMES? , 1 i 1 23 A NO. l 24 Q HOW DID YOU GET IT IN JANUARY AND FEBRUARY -- 9 25 HOW DID YOU GET THE POST IN JANUARY AND FEBRUARY OF 1983? 11-90
i 2 A THERE WAS A LITTLE NEWS SHOP, I GUESS FOR L l 2 LACK OF A BETTER DEFINITION, IN THE MIDDLE OF TOWN THAT I 3 CARRIED OUT-OF-TOWN NEWSPAPERS. 4 Q WAS IT YOUR PRACTICE ON A DAILY BASIS TO BUY 5 THE POST? 6 A IT WAS MY PRACTICE, WHEN I WOULD BUY A 7 NEWSPAPER, THAT I WOULD EITHER READ THE LC AL NEWSPAPER OR 8 THE WASHINGTON POST, IF THERE WAS STILL ONE LEFT BY THE ' 9 TIME I GOT THERE.
'l 10 Q HOW OFTEN DURING A WEEK WOULD YOU CUSTOMARILY l 11 GET A COPY OF THE POST?
12 A I REALLY COULDN'T ANSWER THAT DEFINITIVELY , 13 FOR YOU. IT WAS NOT A HABIT WITH ME TO BUY ONE EVERY DAY. 14 IT WAS -- THAT LITTLE NEWSSTAND WAS NOT TOO FAR FROM MY 15 HOUSE, AND WHEN I HAD THE TIME, I STOPPED AND PICKED UP AN 16 0UT-OF-TOWN NEWSPAPER. 17 Q YOU SAID IT WAS NOT YOUR HABIT TO BUY IT l 18 EVERY DAY, 19 A THAT'S CORRECT. I 20 Q IS IT YOUR TESTIMONY THAT YOU LEARNED THE 21 EXPRESSION " MYSTERY MAN" FROM READING SUSAN STRANAHAN'S
.a 22 ARTICLE?
23 A THAT IS CORRECT. 24 Q WHEN DID YOU LEARN THAT PHRASE OR -- WHEN YOU 25 READ THE ARTICLE? 11-91 l
1 A I BELIEVE I HAVE ALREADY STATED I THOUGHT THE 2 ARTICLE WAS PUBLISHED IN, LIKE, JANUARY, FEBRUARY; AND I 3 BELIEVE I READ IT BEFORE I WENT PUBLIC, AND I WENT PUBLIC 4 IN MARCH. 5 Q MARCH 23RD? 6 A RIGHT. ] 7 Q YOU ALSO TESTIFIED A MOMENT AGO THAT -- 8 CORRECT ME IF I'M WRONG -- THAT YOU DIDN'T HAVE A CONCERN 9 AT THE TIME YOU WERE CONSIDERING SENDING A DISCLOSURE TO 10 THE NEWSPAPERS ABOUT MR. KUNDER'S APPOINTMENT AS MANAGER 11 OR CHAIRMAN OF THE SAFETY REVIEW GROUP; IS THAT RIGHT? 12 A IT DIDN'T OVERLY CONCERN ME THAT GEORGE HAD 13 BEEN APPOINTED TO THE SAFETY REVIEW GROUP. WHAT DID 14 CONCERN ME WAS THAT IF, AS I BELIEVED, GEORGE WAS i 15' RESPONSIBLE FOR SHUTTING DOWN EQUIPMENT DURING THE 16 ACCIDENT, THAT GPU AND/OR OTHER MEMBERS OF MANAGEMENT WERE 17 NOT BEING FORTHCOMING AND STRAIGHTFORWARD WITH THE NRC. j i 18 Q WELL, LOOK AT YOUR AFFIDAVIT ON PAGE 36. 19 THIS IS YOUR AFFIDAVIT OF MARCH 21, OF COURSE. f 20 A WHAT PAGE? 21 Q THIRTY-SIX. l 22 ABOUT THE MIDDLE OF THE PAGE THE PARAGRAPH 23 BEGINS WITH MR. KUNDER'S NAME. 24 A RIGHT. l l 25 Q YOU STATED IN THAT AFFIDAVIT THAT l 11-92 i l
1- .MR .- KONDER ' S , QUOTE, "MEY POSITION AS CHAIR OF THE l 2 .PORC/ REVIEW' GROUP'IS INEXPLICABLE," CLOSE QUOTE. DOESN'T j t 3 THAT REFLECT A CONCERN ON YOUR.PART_ ABOUT MR. KUNDER i 4- OCCUPYING'THAT POSITION? 5 A TO A DEGREE, YES. CERTAINLY INEXPLICABLE. i f6 Q DID.YOO HAVE SOME CONCERN FOR SOME TIME 7 BEFORE MARCH'21ST,- 1983, WHEN YOU. SIGNED THE~ AFFIDAVIT? 8- A YES, I DID. 9 Q ABOUT HOW LONG? .$ 10 A I COULDN'T.REALLY TELL YOU. 11 Q WHEN_DID MR. KUNDER BECOME CHAIR OF THE PORC; 12 SAFETY REVIEW GROUP AS YOU DESCRIBED? 13 A GEORGE WAS CHAIRMAN OF,THE PORC FOR QUITE A 14 LONG TIME. ANG I BELIEVE, AS PART OF THE REORGANIZATION 15 IN THE LAST PART OF '82, THEY RELATED TO THE SAFETY REVIEW 16 GROUP, BUT I DO NOT BELIEVE THE SAFETY REVIEW GROUP WAS f
.17 EVER OFFICIALLY SANCTIONED BY REVISION OF APPENDIX A TO 18 THE OPERATING LICENSE TO ACKNOWLEDGE THE EXISTENCE'0F THE 19 SAFETY REVIEW GROUP.
20 Q YOU MEAN BEFORE YOU LEFT THE ISLAND? 21 A RIGHT. 22 I MAY BE WRONG ON THIS PART, BUT IT SEEMS MY 23 RECALL, AT THIS MOMENT, TELLS ME IT WAS NEVER OFFICIALLY i 24 SANCTIONED. 25 Q WELL, DID YOUR CONCERNS ABOUT MR. KUNDER, WHO l 11-93 l
1 YOU IDENTIFIED AS THE MYSTERY MAN, SERVING AS CHAIRMAN OF 2 PORC GO BACK FOR AS LONG AS MR. KUNDER HAD BEEN THE 3 CHAIRMAN? 4 A NO, IT REALLY DIDN'T, THAT IS RIGHT, BECOME A 5 CONCERN UNTI.L THE CONVERSATIONS OCCURRED THAT I REFERENCE 6 IN MY AFFIDAVIT. 7 Q WELL, WE LOOKED YESTERDAY, AND I'LL BE GLAD 8 'TO FIND THE REFERENCE FOR YOU, IF YOU LIKE, AT SOME NOTES l 9 IN YOUR EARLIER TENURE AT TMl WHEN YOU MAY RECALL YOU 1 10 WROTE A LETTER FOR MR. KING AS PART OF YOUR DUTIES TO THE l 11 PORC AND I THINK ADDRESSED IT TO MR. KUNDER TO COMPLAIN 12 ABOUT -- OR TO URGE SPEEDY ACTION ON THESE PROCEDURES. DO 13 YOU REMEMBER THAT? THAT WAS BACK IN THE 1980-81 TIME 14 FRAME, WASN'T IT? 15 A RIGHT. 16 Q DID YOU HAVE CONCERNS AT THAT TIME PERIOD, 17 1980-81, ABOUT MR. KUNDER'S -- WHETHER MR. KUNDER WAS THE 18 APPROPRIATE PERSON TO BE THE PORC CHAIRMAN? 19 A NO, 1 DID NOT. I WAS NOT -- THE WAY I BECAME 20 CONCERNED OVER GEORGE'S FULFILLING THE POSITION THAT HE 21 FULFILLED WAS WHEN I WAS MADE AWARE OF HIS ROLE DURING THE b 22 ACCIDENT, AND THAT DID NOT OCCUR UNTIL -- AS I STATE RIGHT 23 HERE IN THE AFFIDAVIT, I BELIEVE IT WAS NOT TOO LONG 24 BEFORE I WAS ESCORTED OFF THE JOB SITE. 25 Q ARE YOU REFERRING TO SOME PORTION OF THE 11-94
1 AFFIDAVIT SPECIFICALLY HERE WHEN YOU TALK ABOUT THE DATE 2 WHEN YOU BECAME AWARE OF THIS? 1 3 A I DON'T THINK IT ACTUALLY REFERENCES AN EXACT l l 1 4 DATE IN THE AFFIDAVIT. BUT I CAN RECALL CONFERENCES i I 5 WITHIN THE -- CONVERSATION THAT OCCURRED AFTER THE B&W AND l 6 GPU -- 7 THE REPORTER: BNW? I DIDN'T HEAR YOU. 8 THE WITNESS: B&W. 50 THOSE CONVERSATIONS -- AND q 9 SUSAN STRANAHAN'S ARTICLE AND ALL OF THAT STUFF WOULD HAVE 10 COME OUT IN FEBRUARY TIME FRAME, JANUARY TIME FRAME, 11 SOMETHING LIKE THAT. I BELIEVE THE LAWSUIT WAS SETTLED IN 12 JANUARY OF '83. AND IF MY MEMORY SERVES ME CORRECTLY AT 13 THIS MOMENT, THAT'S WHEN THOSE CONVERSATIONS OCCURRED. 14 Q BY MR. HICKEY: MR. PARKS, YOU H 7 MADE 15 COMMENTS IN THE FALL OF 1982 INDICATING THAT YOU WERE 16 GOING TO SEND A LETTER TO THE NEWSPAPERS EXPOSING 17 MR. KUNDER, HADN'T YOU? 18 MR. JOHNSON: I DON'T THINK THAT'S A CORRECT 19 CHARACTERIZATION OF HIS TESTIMONY. HE SAID THAT HE -- THE 20 TIME FRAME WAS THE LAST TWO WEEKS IN DECEMBER. THIS 21 DOESN'T QUALIFY AS THE FALL. l 22 MR. HICKEY: l'M NOT CHARACTERIZING HIS TESTIMONY. 23 l'M ASKING HIM A DIFFERENT QUESTION. 24 MR. JOHNSON: OH, OKAY. 25 THE WITNESS: WOULD YOU REPEAT THE QUESTION? I 11-95
1 Q BY MR. HICKEY: YES. 2 YOU MADE COMMENTS IN THE FALL OF 1982 3 INDICATING THAT YOU PLANNED TO SEND A LETTER TO THE 1 4 NEWSPAPERS EXPOSING MR. KUNDER, DIDN'T YOU? ) i 5 A ARE YOU STATING THAT AS A FACT OR ASKING FOR 6 MY RECOLLECTION? , i 7- Q l'M ASKING YOU A QUESTION, MR. PARKS, JUST l 8 LIKE l'VE BEEN DOING ALL DAY. l 9 A AT THIS PRESENT MOMENT, 1 DO NOT RECALL 10 HAVING MADE THOSE TYPE OF COMMENTS IN THE FALL OF 1982. l 11 .Q ON PAGE 37 0F YOUR AFFIDAVIT YOU STATE THAT 12 ON AT LEAST TWO OCCASIONS SINCE CHRISTMAS THAT YOU CAN ' 13 RECALL, YOU BECAME FRUSTRATED IN YOUR DEALINGS WITH KUNDER , 14 AND STATED THAT YOU WERE THINKING ABOUT WRITING A LETTER 15 TO THE LOCAL NEWSPAPER AND SO ON. 16 A YES. I 17 Q CAN YOU CONFIRM FOR ME THAT THOSE OCCASIONS ] 1 18 WOULD HAVE BEEN SOMETIME AFTER THE SUSAN STRANAHAN ARTICLE l i 19 CAME OUT* 20 A AT THIS POINT IN TIME, THE ONLY THING I CAN 21 CONFIRM FOR YOU IS THAT THOSE TWO OCCASIONS OCCURRED AFTER 22 CHRISTMAS OF 1982. 23 Q CAN YOU PLACE IT ANY MORE SPECIFICALLY IN ! i 24 TERMS OF THE TIMING? 25 A NOT ANY BETTER THAN WHAT I HAVE ALREADY 4 1 11-96
I
-1 . TESTIFIED TO, SIR.
2 Q DID YOU HAVE DISCUSSIONS WITH MR. KING IN THE 3 LATTER PART OF DECEMBER 1982 AND THE FIRST THREE MONTHS OF 4 JANUARY 1983 REGARDING HIS CONCERNS ABOUT THE BUDGET AT 5 TMI AND HOW MUCH HOW MONEY WAS BEING SPENT? 6 A I BELIEVE THAT DURING THAT TIME FRAME A 7 QUESTION -- THAT THERE WERE DISCUSSIONS THAT I WAS A PART 8 OF WHERE THAT TOPIC WAS DISCUSSED.
.9 Q WITH MR. KING?
~ 10 A I BELIEVE MR. KING WAS A PARTICIPANT IN THE l 11 DISCUSSIONS.
12 Q AND DID YOU HAVE OCCASION TO DISCUSS WITH . 1 13 MR. KIf0G, MR. KUNDER'S ROLE IN THE ACCIDENT IN THE TIME i 14 PERIOD OF DECEMBER 1982 PRIOR TO YOUR LEAVING THE SITE? 15 A 1 DON'T RECALL, AT THIS MOMENT ANYWAY, 16 DISCUSSING WITH LARRY KING THAT TOPIC PRIOR TO HIS 17 DISMISSAL. 18 Q HOW ABOUT AFTER HIS -- WELL, LET'S SAY AFTER 19 HIS SUSPENSION, WHICH WAS ON FEBRUARY 24, IN THE MONTHS l 20 AFTER THAT WHEN YOU WERE STILL ON THE SITE, DID YOU 21 DISCUSS MR. KUNDER'S ROLE WITH MR. KING THEN? 22 A I BELIEVE I MAY HAVE, BUT MEMORY DOES NOT 23 SERVE AT THIS POINT IN TIME TO CLEARLY DEFINE THAT. 24 Q THIS WOULD HAVE BEEN WHEN MR. KING WAS NO l 25 LONGER ON THE SITE THAT WE'RE TALKING ABOUT. ) 1 1 11-97 I
-a_-.___-_m. .--_ma. .-
1- .A RIGHT. 2 Q DID YOU MEET WITH HIM AT HIS HOME TO DISCUSS 3 IT? 4 A I COULDN'T REALLY TELL YOU, AT THIS POINT IN 5 TIME, WHETHER WE MET OR IF IT WAS A PHONE CONVERSATION, OR 6 IF IT WAS OVER A GLASS OF BEER IN A BAR. 7 I WOULD LIKE TO ADD TO THAT THAT I 8' INTERPRETED YOUR QUESTION OR UNDERSTOOD YOUR QUESTION TO 9 BE SPECIFICALLY A CONVERSATION OCCURRING BETWEEN LARRY 10 KING AND MYSELF. 11 Q AS DISTINGUISHED FROM WHAT? 12 A THAT ANYONE ELSE HAD BEEN INVOLVED IN THE 13 CONVERSATION. 14 Q YOU WERE SAYING THAT YOU DON'T REMEMBER 15 HAVING A SPECIFIC MEETING WITH JUST YOU AND LARRY KING; IS 16 THAT YOUR TESTIMONY? 17 A THAT'S CORRECT. 18 Q WELL, DO YOU REMEMBER A MEETING WITH YOU AND 19 LARY KING AND SOMEONE ELSE TO DISCUSS MR. KUNDER'S ROLE IN 20 THE ACCIDENT? 21 A I DO NOT RECALL DURING THE TIME FRAME IN 22 QUESTION OF HAVING A SPECIFIC MEETING WITH ANYONE TO ( 23 DISCUSS GEORGE KUNDER'S ROLE IN THE ACCIDENT. 24 Q AND THE TIME FRAME YOU'RE REFERRING TO IS? I 25 A JANUARY TO MARCH OF '83. I THINK THAT'S WHAT 11-98 1
l 1 VOU ASKED. ) i i 2 Q DID YOU HAVE MEETINGS WITH ANYBODY IN THAT 3' SAME TIME PERIOD, JANUARY THROUGH MARCH OF '83, PRIOR TO ] 4 YOUR LEAVING.THE SITE, WHERE THE SUBJECT WAS DISCUSSED 5 EVEN THOUGH THAT WASN'T THE PURPOSE FOR THE MEETING? 6 A I BELIEVE THAT THE POINT YOU'RE TRYING TO l 7 ARRIVE AT, SIR, 15 IN THE AFFIDAVIT -- AND 1 DO NOT RECALL 8 AT THIS POINT IN TIME IF THERE WAS A SPECIFIC MEETING 9 GOING ON OR IF IT WAS JUST A GENERAL BULL SESSION IN THE I 10 SITE OFFICE. I CAN RECALL THE CONVERSATION OCCURRING, BUT j 11 1 CANNOT AMPLIFY ANYTHING OTHER THAN WHAT'S IN MY ; i 12 AFFIDAVIT. j 13 Q YOU SAID THAT YOU CAN RECALL THE CONVERSATION 14 OCCURRING. 15 A YES, ! CAN RECALL THAT A CONVERSATION ! 16 OCCURRED, PUT IT.THAT WAY. 17 Q AND THE CONVERSATION YOU'RE REFERRING TO IS A 18 CONVERSATION REGARDING MR. KUNDER'S ROLE IN THE ACCIDENT? 19 A RIGHT. COMMENTS MADE TO THAT EFFECT, RIGHT. 20 I BELIEVE I FAIRLY WELL IDENTIFIED THE TOPIC IN MY 21 AFFIDAVIT. ; 22 Q WERE YOU AWARE THAT IN THE FIRST FEW MONTHS 23 0F 1983 THE FBI AND THE DEPARTMENT OF JUSTICE BEGAN AN 24 INVESTIGATION CONCERNING THE OPERATORS WHO HAD BEEN 25 OPERATING UNIT 2 AT THE TIME OF THE ACCIDENT AND BEFORE? 11-99
'l L 1 A' COULD'VOU REPEAT THE TIME FRAME? ! 2 Q SURE. 3 DID YOU KNOW OR HEAR IN JANUARY, FEBRUARY, 4 MARCH, 1983, THAT THERE WAS AN INVESTIGATION GOING ON BY
'5 THE JUSTICE DEPARTMENT AND THE FBl?
6 A I BELIEVE WHEN I WAS CONTACTED BY THE FBI IN 7 MARCH OF 1983 THAT I WAS INFORMED OF THAT, YES. 8 Q WERE YOU AWARE OF IT BEFORE THEN? A I 9 I DO NOT RECALL, AT THIS TIME, BEING MADE 10 AWARE OF IT BEFORE THEN, NO.
. 11 Q WERE YOU CONTACTED BY THE FBI AFTER YOU LEFT-12 THE SITE OR BEFORE?
13 A BEFORE. I BELIEVE SO ANYWAY. 14 Q MR, PARKS, YOU WERE OBVIOUSLY NOT AT THE 15 ISLAND AT THE TIME OF THE ACCIDENT IN 1979. WHEN DID YOU 16 BEGIN TO REVIEW OR INVESTIGATE INFORMATION CONCERNING THE i 17 1979 ACCIDENT? 18 A I DON'T THINK I UNDERSTAND WHAT YOUR QUESTION I 19 IS GETTING AT. I MEAN 1 DON'T THINK I UNDERSTAND WHAT 20 YOU'RE ASKING. 21 Q OKAY. LET ME REPHRASE IT THEN. 22 YOU CAME BACK TO THREE MILE ISLAND IN ABOUT i 1 23 MAY OF 1982. YOU'D BEEN THERE MONTHS BEFORE, BUT YOU 1 24 RETURNED FROM SHOREHAM IN MAY OF 1982. 25 A THAT'S CORRECT. 11-100 f
l 1 Q DID YOU, AFTER MAY OF 1982, DEGIN TO LOOK 2 INTO OR TRY TO LEARN ABOUT THE CIRCUMSTANCES SURROUNDING 3 THE MARCH '79 ACCIDENT? 4 A WHILE I WAS STILL EMPLOYED AT TM1? 5 Q YES. i 6 A NOT THAT I RECALL AT THIS MOMENT. , 7 Q SO AT THE TIME YOU HAD THIS CONVERSATION OR 8 CONVERSATIONS IN FEBRUARY OR MARCH OF 1983 ABOUT 9 MR. KUNDER, YOU HAD NOT, BEFORE THEN, BEEN MAKING SOME i 10 INDEPENDENT STUDY OF THE ACClDENT, HAD YOU? l 11 A NOT THAT 1 CAN RECALL AT THIS MOMENT. 12 Q HAD YOU SPOKEN TO OTHER OPERATORS OR i 13 PERSONNEL AT TMI PRIOR TO THIS -- THESE DISCUSSIONS 14 REFLECTED IN YOUR AFFIDAVIT ABOUT WHAT HAPPENED AT THE 15 TIME OF THE ACCIDENT? 16 MR. JOHNSON: WHAT DISCUSSIONS ARE WE TALKING l 17 ABOUT? l 18 MR. HICKEY: THE WITNESS JUST REFERRED TO 19 DISCUSSIONS THAT HE HAD REFERENCED IN HIS AFFIDAVIT. l 20 THE WITNESS: 1 THINK 1 HAVE TO GET YOU TO I 21 ELABORATE A LITTLE BIT ON YOUR QUESTION. I DON'T THINK I ; i 22 UNDERSTAND WHAT YOU'RE TRYING TO GET AT. l 23 Q BY MR. HICKEY: WELL, LET'S SEE IF ! CAN MAKE 24 IT MORE DIRECT. I l 25 HAD YOU INQUIRED OF OTHER OPERATORS OR l I 11-101 l
1 PERSONNEL AT THE ISLAND, BEFORE THE DISCUSSIONS THAT ARE 2 DESCRIBED IN YOUR AFFIDAVIT, ABOUT WHAT HAD HAPPENED AT 3 THE TIME OF THE ACCIDENT? 4 A I THINK I WAS FAIRLY WELL -- MAYBE THIS MAY 5 NOT dE A DIRECT RESPONSE TO YOUR QUESTION, BUT I THINK I 6 WAS FAIRLY WELL COGNIZANT OF WHAT HAPPENED DURING THE 7 ACCIDENT, IF THAT'S AN ANSWER TO YOUR QUESTION. 8 C LOOK, AGAIN IF, YOU WOULD PLEASE AT EXHIBIT 9 43. 10 A OKAY. 11 MR. JOHNSON: ANY rrp.lCULAR PART? i 12 Q BY MR. HICKEY: SPECIFICALLY THE FIRST PAGE, 13 THE OPENING SEVERAL LINES. WOULD YOU READ THOSE SENTENCES 14 TO YOURSELF DOWN THROUGH -- WELL, WHY DON'T YOU READ THE 15 WHOLE FIRST PAGE. READ THE WHOLE FIRST PAGE, WOULD YOU. 16 (WITNESS COMPLIES.) 17 THE WITNESS: OKAY. 18 Q BY MR. HICKEY: THAT PAGE EXPRESSES WHAT IT 19 CALLS - EXPRESSES THE WRITER IS PUZZLED ABOUT GPU TURNING 20 OVER THE DIRECTORSHIP OF ONE THE NUCLEAR PLANTS TO AN 21 EMPLOYEE OF ANOTHER COMPANY, NAMELY BECHTEL. DID YOU 22 DISAPPROVE OF -- OR NOT SUPPORT THE DECISION TO HAVE A 23 BECHTEL EMPLOYEE BECOME THE DIRECTOR OF UNIT 2, MR. PARKS? 24 A IT MADE NO DIFFERENCE TO ME. I WAS A BECHTEL 25 EMPLOVEE. 11-102 i I
1 Q DID YOU THINK IT WAS A GOOD IDEA? l l 2 A I DIDN'T HAVE ANY PROBLEMS AT THAT TIME -- l l 3 DURING THAT TIME FRAME WITH ANY BECHTEL EMPLOYEE BEING j l 4 SECONDED TO GPU BECAUSE I, MYSELF, WAS SECONDED. 5 MR. JOHNSON: 15 THAT ALSO PRONOUNCED SECONDED? 6 THE WITNESS: THAT IS SECONDED. ) 7 Q BY MR. HICKEY: DID MR. KING HAVE THE VIEW 8 THAT IT WAS PUZZLING OR UNDESIRABLE TO HAVE A BECHTEL 9 EMPLOYEE AS THE DIRECTOR OF TMI-27 10 A I THINK THAT WOULD CALL FOR SPECULATION ON MY 11 PART AS TO WHAT MR. KING'S OPINION WAS. 12 Q WELL, LET ME ASK IT MORE DIRECTLY. 13 DID MR. KING EVER EXPRESS TO YOU HIS VIEWS 14 ABOUT HAVING MR. KANGA OR A BECHTEL EMPLOYEE AS A DIRECTOR 15 OF TMI-2? 16 A HE MAY HAVE, BUT AT THIS MOMENT I DON'T 17 RECALL SPECIFIC OCCURRENCES WHERE HE EXPRESSED THAT VIEW. 18 Q WELL, DO YOU HAVE A GENERAL RECOLLECTION THAT 19 HE DID AT SOME POINT, EVEN THOUGH YOU DON'T REMEMBER THE l l 20 PARTICULAR OCCASION, EXPRESS THAT VIEW 7 21 A I DO NOT THINK I CAN PROVIDE ANY BETTER , l l 22 ELABORATION TO MY PREVIOUS ANSWER. I JUST DON'T RECALL 23 ANYTHING AT THE MOMENT. l 24 Q WELL, l'M TRYING TO PROBE WHAT THAT MEANS 25 WHEN YOU SAY YOU DON'T RECALL ANYTHING. DO YOU HAVE A 11-103
1: RECOLLECTION THAT-MR-. KING ATfSOME TIME EXPRESSED TO 'YOU> 2 THE VIEW.THAT IT WAS INAPPROPRIATE.TO HAVE A BECHTEL 3 EMPL'OYEE ' AS THE DIRECTOR?
'4 A WELL, I THINK, YOU KNOW, THIS IS MY OWN 5: PERSONAL OPINION OF' LARRY KING'S BEHAVIORAL-6! CHARACTERISTICS, IF YOU WILL. LARRY KING ALSO STRUCK 7 PEOPLE AS THE TYPE OF GUY HE DIDN'T CARE WHO HE WORKED FOR 8 AS LONG AS THE JOB GOT DONE AND THE JOB GOT DONE PROPERLY.
9 Q- CAN YOU' ANSWER THE QUESTION? 10 A' I GUESS THAT IS'AN ANSWER TO YOUR. QUESTION. 11 I DON'T RECALL HAVING LARRY KING MAKE A-STATEMENT TO ME 12 ONE WAY OR ANOTHER, AT THIS MOMENT, IF HE DID. 'AND IF I 13 . DOCUMENTED IT SOMEWHERE, THEN APPARENTLY HE DID, BUT I
=14 DON'T RECALL ANYTHING AT THIS MOMENT.
15 MR. HICKEY: LET ME ASK THE REPORTER TO MARK THIS 16 TWO-PAGE DOCUMENT AS EXHIBIT 44. 17 (WHEREUPON RESPONDENT'S EXHIBIT 44 WAS. MARKED l 18 -FOR IDENTIFICATION BY THE NOTARY PUBLIC, AND A COPY IS , 19 ATTACHED HERETO.) i 20 THE WITNESS: I HAVE LOOKED AT THIS, IF YOU'RE 21 WAITING TO ASK ME A QUESTION. I 22 Q BY MR. HICKEY: YES. IS EXHIBIT 44, WHICH 1 23 APPEARS TO BE A COPY OF A NEWSPAPER STORY FROM THE 24 WASHINGTON POST BY SUSAN Q. STRANAHAN ENTITLED "THE REAL j 25 THREE MILE ISLAND. STORY LEAKS OUT," IS THAT THE ARTICLE ) u 1 11-104
)
l l \ l 1 THAT YOU WERE REFERRING TO EARLIER WHEN VOU SAID YOU READ 2 A SUSAN STRANAHAN Ak?!CLE? 3 A 1 DON'T KNOW IF THAT'S THE ARTICLE OR NOT. 4 Q DO YOU RECALL HAVING SEEN THIS ARTICLE 5 BEFORE? 6 A I DON'T KNOW IF THAT -- AGAIN, YOU KNOW, MY
- 7. MEMORY DOES NOT SERVE TO ASCERTAIN ACCURATELY IF THAT'S 8 THE ARTICLE I WAS TALKING ABOUT BEFORE OR NOT.
9 Q BUT l'M REALLY ASKING YOU A DIFFERENT 10 QUESTION. I DO NOT UNDERSTAND -- YOU DO NOT KNOW FOR SURE 11 IF THIS IS THE ONE, BUT HAVE YOU SEEN THIS ARTICLE BEFORE? 12 A I DON'T KNOW IF 1 HAVE OR NOT. 13 Q LET ME ASK YOU TO LOOK, MR. PARKS, AGAIN, IF l 14 YOU WOULD PLEASE, AT YOUR CALENDAR, WHICH IS THERE IN 15 FRONT OF YOU. IT'S EXHIBIT NUMBER 11. LOOK ON THURSDAY, 16 MARCH 31. 17 A OKAY. 18 Q THERE'S A COUPLE OF THINGS ON THAT PAGE AT 19 ABOUT 9:30, I GUESS. I WOULD SAY THERE'S AN ENTRY " SPOKE 20 WITH RON BRINKLEY, FBI. HE'S PICKING ME UP AT NINE 21 O' CLOCK TOMORROW FOR A DOCUMENT REVIEW." 22 A RIGHT. 23 Q DOES THAT REFER TO THE OCCASION WHEN YOU MET l 24 WITH MR. BRINKLEY TO GO OVER DOCUMENTS THAT YOU WERE 25 PROVIDING TO HIM? 11-105
1: A :1 COULD NOT TELL YOU IF THAT'S, IN F ACT, WHAT
-2 LTHAT ENTRY'MEANSHOR NOT. WHAT THAT ENTRIES MEANS TO ME IS 3 THAT.HE WAS PICKING ME UP AT NINE O' CLOCK THE FOLLOWING l
4 DAY TO; REVIEW DOCUMENTS. I l 5 Q BUT YOU DON'T KNOW WHAT DOCUMENTS -- i 6 .A .NO . 7 Q -- YOU WERE REFERRING TO THERE? L 8 OKAY. LOOK DOWN AT 11:15 WILL'YOU READ 1
.I
.9- THAT ENTRY, PLEASE. FOR THE RECORD, WOULD YOU READ IT OUT !
10 LOUD, MR. PARKS. i 11 A SAYS " GOT TO MEET WITH L.P.K." l 12 Q L.P.K. WERE THE INITIALS OF MR. KING? 13 A RIGHT. 14 "HE IDENTIFIED THE NAME OF MAN WHO WROTE B --
'15 Q .I'M SORRY. STARTED YOU IN THE WRONG PLACE.
16 LOOK DOWN AT ABOUT TWELVE O' CLOCK.. AT THE Y , 17 END OF THAT LINE WHERE THE LANGUAGE BEGINS "ON 2/14 OF" 18 SOMETHING. 19 A RIGHT. "ON 2/14/83 SUSAN STRANAHAN WROTE 20 ARTICLE FOR WASHINGTON POST, PHILADELPHIA INQUIRER." 21 Q AND IF YOU'LL KEEP READING, THERE'S SOME MORE 22 LATER ON THAT REFERS TO IT. 23 A OKAY. " LARRY WAS REQUESTED TO GO f 24 TO NEW YORK DURING TRIAL. DICK SKILMAN i 25 ASKED HIM IF HE WOULD BE HOSTILE WITNESS. 11-106 l 1
l 1 THEY WERE INTERESTED IN WHAT L.P.K. KNEW l l 2 FROM BSW DAYS, GLORIA IS TO DROP OFF COPY l 3 OF ARTICLE TOMORROW." 4 Q WHO IS GLORIA THAT IS REFERRED TO IN THOSE 5 NOTES? 6 A L A R F. Y KING'S WIFE, I WOULD ASSUME. 7 Q AT THE BOTTOM OF THAT PAGE YOU HAVE A NAME 8 AND PHONE NUMBER, RIGHT? 9 A RIGHT. 10 Q WHERE DID YOU GET SUSAN Q. STRANAHAN'S PHONE 11 NUMBER? 12 A PROBABLY FROM THE OPERATOR. 13 Q BY CALLING INFORMATION YOU MEAN? 14 A PROBABLY. 15 Q MR. KING DIDN'T GIVE IT TO YOU? 16 A HE MAY HAVE. I DON'T REALLY KNOW_IF HE DID 17 OR NOT. NOT AT THIS TIME. 18 Q IF YOU'LL FLIP THE EXHIBIT OVER TO THE DATE 19 OF APRIL 1, LOOK AT 9:15. WOULD YOU READ THAI' PLEASE OUT 20 LOUD. 21 A " READ THE SUSAN STRANAHAN EDITORIAL OF 22 2/13/83. HITS THE NAIL ON THE HEAD." 23 Q THE DATE THAT YOU PUT ON YOUR APRIL 1 24 CALENDAR -- BY THE WAY DID YOU MAKE THESE NOTES OF 25 MARCH 31 AND APRIL 1 ON OR ABOUT THOSE DAYS? 11-107
1 A PROBABLV. 2 Q AND YOU PUT IN A DATE ON APRIL 1 FOR T:HIS R i 3 ARTICLE OF FEBRUARY 13. DO YOU KNOW HOW YOU GOT THAT 4 DATE? 5 A PROBABLY OFF THE NEWSPAPER ARTICLE. 6 MR. JOHNSON: l'M SORRY, l'M NOT FOLLOWING. WHERE 7 IS THIS DATE THAT'S BEING REFERRED TO? 8' MR. HICKEY: ON THE 9:15 LINE ON APRIL 1. 9 THE WITNESS: RIGHT HERE (INDICATING). 10 Q BY MR. HICKEY: IN YOUR VIEW OF THE STORY 11 AFTER YOUR PHRASE " HITS THE NAIL ON THE HEAD," THAT MEANS 12 YOU AGREED WITH THE ARTICLE? l 13 A 1 WOULD SAY THAT'S PROBABLY A SAFE ASSUMPTION 14 ON YOUR PART. 15 Q AND WOULD YOU MAKE THE SAME KIND OF COMMENT 16 ABOUT THE ARTICLE THAT IS BEFORE YOU AS EXHIBIT 44, THE , 17 ARTICLE ABOUT THREE MILE ISLAND BY MISS STRANAHAN THAT YOU 18 READ? 19 A I HAVEN'T READ IT. I JUST SCANNED IT. 20 DO YOU WANT ME TO READ IT? 21 Q WELL, NO. I THOUGHT YOU DID SINCE YOU TOOK 22 SOMETIME TO LOOK AT IT, BUT THAT'S ALL RIGHT. I'M SURE 23 WE'LL GET BACK TO IT. 24 A l'M SURE. 25 Q WHEN YOU SAW THE ARTICLE IDENTIFYING 11-108 - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - - _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ - i
i l i 1 MR. KUNDER -- NO. WHEN YOU READ THE ARTICLE THAT REFERRED l 2 TO THE MYSTERY MAN BEING AN ISSUE IN THE B&W LITIGATION, ) l ! 3 THE ARTICLE I T.S E L F , THE NEWSPAPER ARTICLE DIDN'T IDENTIFY l i 4 ANY PARTICULAR PERSON AS BEING THE MYSTERY MAN, DID IT? j l 5 A THAT'S CORRECT, IF MY MEMORY SERVES ME 6 PROBABLY AT THE MOMENT. ! 7 Q IT JUST DESCRIBES THE THEORY IN THE B&W 8 LITIGATION THAT THERE WAS A MYSTERY MAN, AN UNKNOWN 9 PERSON? 10 A IT DESCRIBED IT IN A FASHION MORE IN LINE 11 WITH THE MAN'S ACTIONS, OR LACK OF ACTIONS, RATHER, THAN 12 SAY THIS MAN AND GIVEN IT IS THE MYSTERY MAN. 13 DID 1 MAKE MYSELF CLEAR? 14 Q YES, I THINK YOU DO, TO ME ANYHOW. 15 AND WHAT DID YOU UNDERSTAND FROM THIS ARTICLE 16 THAT THE MYSTERY MAN'S ACTIONS WERE? 17 A IF I RECALL CORRECTLY AT THE MOMENT, IT'S THE 18 CONTENTION ESTABLISHED BY THE B&W LAWYERS THAT THERE WAS A 19 MAN WHO EITHER ORDERED THE SHUTDOWN OF THE SECOND SAFETY 20 INJECTION PUMP OR ORDERED IT NOT BE STARTED ON OR ABOUT 21 THE TIME THAT THE REACTOR COOLANT PUMPS WERE SHUT DOWN, 22 SOMEWHERE IN THAT TIME FRAME, DURING THE ACCIDENT l 23 CONDITIONS, ABOUT AN HOUR AND A HALF OR SO INTO THE 24 ACCIDENT AND THEREBY HIS ACTION RESULTED IN CORE DAMAGE, 25 EXTENSIVE CORE DAMAGE. I BELIEVE THAT'S, YOU KNOW, WHAT 11-109
1 THE POINT WAS THAT THE B&W LAWYER.WAS TRYING TO PROVE. 2 Q HIS ACTION WITH REGARD TO EITHER ORDERING THE 3 SHUTDOWN OF THE SECOND SAFETY INJECTION PUMP OR ORDERING 4 IT NOT BE STARTED UP? 5 A SOMETHING TO THAT EFFECT. THAT'S WHAT MY 6 MEMORY SERVES TO TELL ME AT THE MOMENT IN TIME. 7 Q .WELL, WHAT YOU LEARNED ABOUT THIS ALLEGATION 8 WAS WHAT YOU GOT OUT OF THE NEWSPAPER YOU MEAN? YOU 9 DIDN'T GO TO THE B&W TRIAL, DID YOU? 10 A NO, SIR, I DID NOT GO TO THE BSW TRIAL. 11 Q DID YOU HAVE OTHER SOURCES OF INFORMATION 12 BESIDES THE NEWSPAPER ABOUT WHAT HAD BEEN SAID AT THE B&W 13 TRIAL WITH REGARD TO THE MYSTERY MAN? 14 A AT ONE POINT IN TIME, YES, 1 DID. 15 Q BEFORE YOU LEFT THE ISLAND? 16 A I BELIEVE AT ONE POINT IN TIME I MAY HAVE 3 17 BEEN PROVIDED WITH ADDITIONAL INFORMATION, 18 Q WHEN WAS THAT? 19 A PROBABLY A DAY OR DAY BEFORE I WAS ESCORTED 20 OFF THE JOB SITE. 21 Q WHERE DID YOU GET THAT INFORMATION? 22 A 1 DON'T REMEMBER, AT THIS MOMENT, HOW IT CAME 23 INTO MY POSSESSION. 24 Q WAS IT SOMETHING IN WRITING YOU MEAN? 25 A YES. I 11-110 I
l 1 Q DOCUMENT? ] 2 A RIGHT. l-3 Q WHAT KIND OF DOCUMENT? 4 A I BELIEVE IT WAS TRANSCRIPTS OF THE { 5 B&W/GPU -- I MEAN THE TRIAL PROCEEDINGS, SELECTED PORTIONS 1 l 6 OF IT. 7 Q AND IS YOUR TESTIMONY THAT YOU DON'T RECALL 8 WHERE YOU GOT THOSE TRANSCRIPTS? 1 9 A NOT FOR CERTAIN, NO. 10 Q DO YOU HAVE A GENERAL RECOLLECTION OF WHERE 11 YOU GOT THEM? 1 12 A 1 BELIEVE THEY CAME TO ME THROUGH MY COUNSEL. I i 13 BUT ! WOULDN'T SWEAR TO IT AT THIS MOMENT BECAUSE MY l 14 MEMORY JUST DOES NOT PROVIDE ANY ADDITIONAL INFORMATION AT 15 THIS MOMENT. 16 Q LET ME ASK YOU TO LOOK BACK AGAIN, MR. PARKS, ! l 17 AT EXHIBIT 43, PAGE 3. I GUESS YOU NEED TO START ON THE 18 BOTTOM OF PAGE 2, THE LAST SENTENCE THAT BEGINS "THERE i 19 HAVE BEEN SERIOUS SAFETY QUESTIONS." THEN IF YOU'LL READ I 20 OVER TO THE END OF THE TOP PARAGRAPH ON PAGE 3. 21 A DID YOU SAY INCLUDING THE TOP PARAGRAPH ON l l i 22 PAGE 3? 23 Q YES. 24 A OKAY. I HAVE READ IT. 25 Q THAT PORTION OF THIS EXHIBIT 43 RELATES TO A 11-111
1 CONDITION WHERE MANAGEMENT HAD ANNOUNCED TO THE WORLD THAT 1 2 THE RADIATION LEVELS, APPARENTLY REFERRING TO THE l ; L 3 RADIATION LEVELS UNDER THE REACTOR VESSEL HE\D, WOULD 4 PROBABLY BE TOO HIGH TO ALLOW HEAD REMOVAL, BUT HEAD l I ! 5 REMOVAL WAS STILL SCHEDULED FOR JUNE OF '83. THAT WAS THE 6 SUBJECT THAT YOU WERE AWARE OF? IT'S NOT IN JANUARY AND 7 FEBRUARY OF 1983? 8 A OH, I WOULD SAY I WAS PROBABLY AWARE OF IT-9 LIKE EVERYBODY ELSE ON THE JOB SITE WAS AWARE OF IT. 10 Q NOW IT WAS A MATTER THAT CONCERNED YOU, WAS 11 IT NOT? l 12 A I BELIEVE I MADE A PASSING COMMENT OR TWO IN 13 MY AFFIDAVIT REGARDING THE REACTOR VESSEL HEAD LEVELS, THE 14 RADIATION LEVELS. 15 Q NOW READ THE PARAGRAPH THEN AT THE BOTTOM OF l 16 THE -- THAT STARTS, OH, THE BOTTOM THIRD OF THE PAGE "IT 17 HAS BEEN POSTULATED." i 18 A OKAY. 19 Q CORRECT ME IF l'M WRONG, BUT THAT APPEARS TO j l 20 ME TO DESCRIBE A CONDITION OR A CONCERN ABOUT THE 21 POSSIBILITY THAT THE REACTOR BUILDING SUMP MAY CONTAIN 22 ENOUGH NUCLEAR FUEL TO GO CRITICAL AND CONTINUES TO 23 CRITIClZE A DECISION BY BECHTEL AND GPU, I GUESS, TO ALLOW i 24 ALL FOUR DOORS TO THE REACTOR BUILDING OPENED FOR EASIER i I l 25 ACCESS. YOU HA- A CONCERN AT ONE POINT ABOUT THE f 1 11-112
1 1 POSSIBILITY 0F THE REACTOR BUILDING SUMP GOING CRITICAL, I 2 DIDN'T YOU, MR. PARKS? 3 A NO, SIR. I THINK THAT'S A 4 MISCHARACTERIZATION OF MY STATEMENTS IN MY AFFIDAVIT. I 5 PERSONALLY THOUGHT THE REACTOR SUMP WOULD BE COMPLETELY 6 FARFETCHED FOR IT TO GO CRITICAL. IN FACT I WAS MORE 7 CONCERNED WITH TRYING TO GET THE COMPANY TO EITHER PROVE 1 8 OR DISPROVE BY WAY OF CALCULATIONS THAT WE HAD ENOUGH FUEL 9 IN THERE TO CREATE A CRITICAL MASS. 10 Q WELL, WHY DID YOU THINK IT WAS MORE IMPORTANT
-11 TO PROVE OR DISPROVE BY CALCULATION?
i 12 A BECAUSE I THOUGHT THAT WE WERE SPENDING AN 13 AWFUL LOT OF TIME BORATING THE REACTOR BUILDING SUMP. 14 Q YOU SAID YOU HAD SPENT AN AWFUL LOT OF TIME l 15 IN BORATING THE REACTOR BUILDING SUMP. 16 A RIGHT. IF IT WAS, YOU KNOW, AN IMPOSSIBILITY 17 FOR IT TO GO CRITICAL. < 18 Q WELL, LOOK AT PAGE 13 0F YOUR AFFIDAVIT. 19 A OKAY. 20 Q ITEM 1 THERE ABOUT FIVE LINES DOWN YOU TALK 21 ABOUT THE LONG-STANDING HYPOTHETICAL PROBLEM THAT HAD TO 22 BE OVERCOME, NAMELY, UNCONTROLLED CRITICALITY IN THE 23 REACTOR BUILDING SUMP DUE TO THE SUSPECTED PRESENCE OF 24 FUEL IN THE SUMP. 25 A RIGHT. 11-113
l-1 .Q AND THEN YOU, CONTINUED TO DISCUSS THAT 2 SECTION THERE. IS IT YOUR TESTIMONY THAT YOU DID NOT.HAVE 3 A CONCERNLTHAT THERE WAS. POSSIBILITY OF CRITICALITY IN'THE 4 SUMP? 5 A. 1 THINK, SIR,'WHAT'MY CONCERN WAS'AT.THAT 6 TIME, AS ACCURATELY' REFLECTED IN THE SECOND FULL. PARAGRAPH l l
.7 ON-PAGE 13, THAT --
YOU KNOW, IF YOU WISH, I'D READ IT j I
-8 INTO THE RECORD.
9 Q WELL, MAYBE YOU.CAN SUMMARIZE FOR ME WHAT I 10 YOUR CONCERN WAS. j i 11 A MY MAJOR CONCERN WAS THAT WE HAD ASSUMED FOR 12 A LONG PERIOD OF TIME THAT THERE'WAS FUEL IN THE REACTOR 13 BUILDING SUMP AND IT HAD NEVER GONE CRITICAL BECAUSE AT i 14 ONE POINT IN TIME THE BORAN LEVEL IN THE SUMP HAD 15 DECREASED TO 1700 PARTS PER MIL AND THE SUMP HAD NOT GONE 16 CRITICAL. SO.FROM THAT DAY FORWARD WE TRIED TO KEEP THE 17 SUMP BORATED TO A LEVEL OF AT LEAST 1700 PPM, PARTS PER 18 MILLION. I THOUGHT IF IT WAS POSSIBLE FOR IT TO GO 19 CRITICAL, THEN GREAT, BUT IF THERE WAS'NOT SUFFICIENT 20 ENOUGH FUEL IN THERE TO GO CRITICAL, WE WERE WASTING TIME 4 21 AND MONEY AND EXPOSURE. 22 Q DID YOU HAVE A CONCERN WHILE YOU WERE i 23 CONSIDERING WRITING AN ANONYMOUS LETTER TO THE NEWSPAPERS 24~ ABOUT A PROCEDURE THAT ALLOWED ALL FOUR DOORS TO THE 25 REACTOR BUILDING TO BE OPENED? 11-114 l i (
1 i 1 A IF I HAD A CONCERN ABOUT IT, SIR, I WOULD f l 2 HAVE PUT IT IN MY AFFIDAVIT BECAUSE THAT AFFIDAVIT WAS A 3 CHRONOLOGY OR A SEQUENCE OF EVENTS, IF YOU WILL, OF A I 4 HISTORICAL PERSPECTIVE OF EVERYTHING THAT MYSELF AND OTHER 5 GENTLEMEN HAD BEEN INVOLVED IN THAT HAD RESULTED IN US 6 SUFFERING RETALIATION AND HARASSMENT FOR SAFETY CONCERNS. 7 Q WELL, I HEARD WHAT YOU SAID. BUT YOU'RE NOT 8 SAYING THAT YOUR AFFIDAVIT -- OR ARE YOU SAYING THAT YOUR 9 AFFIDAVIT HAS ALL OF YOUR CONCERNS STATED IN IT? l 10 A NO, THAT'S NOT WHAT I'M TRYING TO SAY. AND 1 i L 11 GUESS TO PUT IT VERY SUCCINCTLY, NO, I COULD CARE LESS HOW l l 12 MANY DOORS THEY OPENED AS LONG AS THEY HAD A PROCEDURE TO 13 . APPROVE ABOUT EVERYTHING IN THE BUILDING AND IT WAS SAFE. 14 Q DID MR. KING EXPRESS TO YOU A VIEW THAT IT 15 WAS NOT DESIRABLE TO HAVE A PROCEDURE THAT ALLOWED ALL 16 FOUR DOORS TO BE. OPENED? 17 A IF HE DID, I HAVE NO RECALL OF IT AT THIS 18 MOMENT. 19 Q HOW ABOUT ANYONE BESIDES MR. KING? DID YOU 20 HEAR THAT VIEW EXPRESSED BY ANYONE? 21 A NOT THAT 1 CAN THINK OF AT THE MOMENT. l t 22 Q OKAY. WHY DON'T YOU READ THE NEXT PORTION OF 23 THIS EXHIBIT, MR. PARKS. IT'S THE LAST TWO LINES ON l l 24 PAGE 3. 1 i 25 A THE LAST HOW MANY LINES? ] 1 11-115 i
)
l l 1 .Q LAST TWO LINES ON PAGE 3. AND THEN IT GOES 2 ONTO PAGE 4. 3 A OKAY.
]
4 Q HOW FAR DID YOU READ ON PAGE 4? ! i 5 A I STOPPED AT THE LINE THAT BEGINS "RECENTLY 6 THE FBI."
- 7. Q OKAY. WELL, THAT WILL BE ENDUGH. YOU CAN 8 READ MORE IF YOU'D LIKE, BUT THAT'S ENOUGH FOR THE 9 QUESTIONS I WANTED TO ASK YOU.
10 THE MATERIAL THAT YOU JUST READ INDICATES, 11 DOES IT NOT, THAT THE AUTHOR OF THIS DOCUMENT BELIEVED 12 THAT THE ARGUMENT AT THE BSW TRIAL WAS THAT THE, QUOTE, 13 " CONTROL ROOM MYSTERY MAN," CLOSE QUOTE, " ORDERED THE 14 STOPPING OF THE REACTOR COOLANT PUMPS DURING THE ACCIDENT 15 AND SINGLE-HANDEDLY CAUSED MORE DAMAGE TO THE CORE THAN 16 ANY OTHER SINGLE ACTION"? i 17 A THAT'S -- I THINK YOU STATED ALMOST WHAT THIS 18 PAGE SAYS, YES. 19 Q DID YOU UNDERSTAND AT SOME POINT, MR.' PARKS, 20 THAT THE MYSTERY MAN REFERRED TO IN THE BSW LITIGATION HAD . I 21 ORDERED THE STOPPING OF THE REACTOR COOLANT PUMPS? 22 A NO, NO, SIR. I UNDERSTAND IT TO BE THE 23 SAFETY INJECTION PUMPS, COOLANT PUMPS. l 24 Q DO YOU HAVE ANY UNDERSTANDING OF HOW THIS 25 DOCUMENT, WHICH APPEARS TO BE IN YOUR HANDWRITING AND WAS )
)
11-116 i
~
usm 4 1- PRODUCED FROM A PILE OF PAPERS WHICH YOU REPORTEDLY MADE'
.2 AVAILABLE TO THE-NRC, WOULD'HAVE:THIS LANGUAGE IN IT ABOUT 3- THE MYSTERY MAN ORDERING THE STOPPING OF THE REACTOR 4 . COOLANT PUMPS?
L5 A 1-SURE DON'T. 6 PLUS I'D-LIKE TO CLARIFY-THAT IT IS NOT IN 7' . HANDWRITING; IT IS IN PRINTING. 8- Q OH. WELL, IT LOOKS LIKE IT APPEARS TO.BE L 9' 'YOUR PRINTING, DOES IT NOT? 10- A PRINTING IS EASY TO DUPLICATE, BUT, YES, IT 11' DOES-APPEAR TO RESEMBLE MY PRINTING. 12 Q DO YOU HAVE SOME SUSPICION THAT THIS DOCUMENT 13- IS A FORGERY, M R .- PARKS? 14 A 1 HAVE NO THOUGHTS ON IT ONE WAY OR THE 15 OTHER. 16' Q DO YOU KNOW WHETHER MR. DEVINE WOULD HAVE ANY 17 RECORDS WHICH WOULD INDICATE WHETHER YOU PROVIDED THIS 18 DOCUMENT TO HIM? 19 A I WOULD NOT BE ABLE TO TELL YOU ONE WAY OR 20 THE OTHER. I DON'T KNOW. I DON'T THINK HE DOES. ] 21 Q DO YOU KNOW ANYONE ELSE WHO WOULD HAVE ANY l
- 22. RECORDS REFLECTING WHERE THIS DOCUMENT CAME FROM? I i
23 A NO, I WOULD NOT. AS I SAID PREVIOUSLY, I WAS j
-24 SHOWN AT LEAST A COVER PAGE OF THAT DOCUMENT IN MY CIVIL ),
25 PROCEEDINGS AND I INFORMED MR. RICHARDSON AT THE TIME IT q i 11-117 j 1
1 WAS NOT MINE. I HAVEN'T1 SEEN.ANYTHING TODAVE TO MAKE ME
-2 CHANGE MY OPINION.
l
.3 MR. HICKEY: LET!S GO OFF THE~ RECORD JUST A MOMENT.
4 (DISCUSSION HELD-OFF THE RECORD.)-
-5 MR. HICKEY: WOULD YOU READ THE LAST-ANSWER. l 6 (WHEREUPON THE REPORTER READ THE ANSWER f
7 APPEARING'ON PAGE 117, LINE 23 THROUGH PAGE 118,:LINE-2,- l 8 INCLUSIVE.) i 9 Q BY MR. HICKEY: YOU'RE SAYING "IT IS NOT D' 10- MINE," WHAT DO YOU MEAN WHEN YOU SAY'THAT? 11 , A WELL, IF 1 RECALL CORRECTLY AT THIS! MOMENT,
'12 MR. RICHARDSON SHOWED ME THAT AND ASKED ME IF I WROTE IT, 13 OR SOMETHING TO THAT EFFECT. AND I DON'T RECALL WRITING 14 THAT, AND I BELIEVE I TOLD MR. RICHARDSON SOMETHING TO i
15 THAT EFFECT. BUT THEN AGAIN, MAYBE IT WAS NOT EXACTLY AS 16 I RECALL IT WITH RESPECT TO MR. RICHARDSON SHOWING'IT TO 17 ME. 18 Q OKAY. LET ME ASK YOU TO LOOK AT YOUR , 19 AFFIDAVIT AGAIN, MR. PARKS, PAGE 36. 20 A OKAY. 21 Q WHY- DON'T YOU READ THOSE TWO PARAGRAPHS THERE
'22 ON 36 AND THEN THE TWO PARAGRAPHS ON 37 WHERE YOU TALK 23 ABOUT THE' MYSTERY MAN SO YOU CAN HAVE IT FRESH IN YOUR 24 MIND.
25 A OKAY. 11-118
1 Q YOU REFER ON PAGE 36 "ON SEVERAL OCCASIONS 2 WHEN JOE CHWASTYK AND SHIFT SUPERVISOR BERNIE SMITH 3 IDENTIFIED KUNDER AS THE MYSTERY MAN." CAN YOU TELL ME 4 ABOUT THE DATES OR TIMES OF ANY OF THOSE OCCASIONS? 5 A NOT AT THIS POINT IN TIME, I COULD NOT. 6 YOU KNOW, AGAIN, SIR, IN LIEU OF THE FACT YOU f 7 STILL HAVE A LOT OF GROUND TO COVER AND THE SHORT TIME TO 8 DO IT IN, I THINK MR. RICHARDSON AND I PRETTY WELL 9 BELABORED THIS POINT IN MY CIVIL PROCEEDINGS. 10 Q YOU HAVEN'T HAD ANYTHING TO REFRESH YOUR 11 RECOLLECTION FURTHER SINCE YOU DISCUSSED IT WITH 12 MR. RICHARDSON; IS THAT WHAT YOU'RE SAYING? 13 A NO, SIR. IN FACT SINCE MY -- SINCE I LAST 14 MET WITH MR. RICHARDSON, I HAVE TRIED TO PUT AS MUCH AS I 15 COULD REGARDI JG TMI AND MY ROLE AT TMI AS FAR BEHIND ME AS 16 I COULD. 17 MR. HICKEY: WOULD YOU MARK THIS, PLEASE. 18 (WHEREUPON RESPONDENT'S EXHIBIT 45 WAS. MARKED 19 FOR IDENTIFICATION BY THE NOTARY PUBLIC, AND A COPY IS
'20 ATTACHED HERETO.)
21 Q BY MR. HICKEY: MR. PARKS, THE REPORTER IS 22 SHOWING YOU EXHIBIT 45, A DOCUMENT OF SEVEN PAGES TYPED, 23 TITLED " DRAFT FOR MYSTERY MAN AFFIDAVIT." WILL YOU TAKE A 24 LOOK AT THAT, PLEASE. 25 HAVE YOU SEEN THAT DOCUMENT BEFORE? 11-119
1 A I CAN'T TELL VOU AT THIS MOMENT IN TIME IF I 2- HAVE OR HAVEN'T. 3 Q .WELL, WHY DON'T YOU TAKE TIME AND READ IT 4 THEN SO YOU ARE -- 5 A I CAN SAVE YOU SOME TIME. THE HANDWRITING ON 6 THIS THAT YOU.SEE AT VARIOUS POINTS THROUGHOUT HERE IS NOT 7 MINE. 8 Q YOU'RE TALKING ABOUT THE LETTERS THAT ARE 9 CHANGED ON THE FIRST PAGE? 10 A NO. I'M TALKING ABOUT POINTS WHERE WORDS ARE 11 ADDED. 12 Q WELL, EVEN APART FROM THE HANDWRITING, 13 MR. PARKS, WHY DON'T YOU READ THE SUBSTANCE OF THE TYPED 14 MATERIAL THERE AND SEE 1F THAT REFRESHES YOUR 15 RECOLLECTION. 16 (WITNESS COMPLIES.) 17 THE WITNESS: OKAY. I HAVE READ IT. 18 Q HAVING READ THAT DOCUMENT, MR. PARKS, ARE YOU 19 ABLE TO RECALL WHETHER YOU HAVE SEEN IT BEFORE? 20 A 1 MAY HAVE, BUT MY MEMORY, AT THIS POINT, 21 DOES NOT REASONABLY ASCERTAIN THAT I HAVE. 22 Q WELL, IS THE TEXT OF THE MATERIAL IN IT 23 FAMILIAR TO YOU? 24 A ONLY RELEVANT TO THE REFERENCES TO THE EDS 25 REPORT. 11-120 i
J 1 1 Q DID YOU WRITE THIS DOCUMENT, MR. PARKS? i 2 A I MAY HAVE HAD AN INPUT INTO IT. 3 Q WHAT IS YOUR RECOLLECTION ABOUT THAT? 4' A JUST THAT I DON'T RECALL, AT THIS MOMENT, IF 5 .I DID OR DION'T. 1 6 Q WHY DO YOU THINK YOU MAY HAVE? 7 A WELL, BECAUSE WHOEVER WROTE IT HAD AN 8 UNDERSTANDING OF HOW THE MAKEUP SYSTEM WORKED AT TMI-2. 9 Q WELL, MR. PARKS, IT STARTS OUT "ON PAGES 10 36-37 OF MY AFFIDAVIT I EXPRESSED RESERVATIONS AT GEORGE 11 KUNDER'S ROLE." 12 A THAT'S TRUE, BUT WHAT l'M SAYING.IS, SIR, IT i 13 COULD VERY WELL HAVE BEEN REWRITTEN BY SOMEONE ELSE, LIKE 14 THE NRC, WHAT HAVE YOU. I WAS IN THE HABIT OF SIGNING 15 WHAT I WROTE, AND THIS IS UNSIGNED. 16 Q WELL, IF IT HELPS YOUR RECOLLECTION ANY, I 17 WILL REPRESENT TO YOU THAT MR. MEEKS TESTIFIED THAT THAT 1 18 WAS SENT TO HIM BY YOU IN RESPONSE TO HIS REQUEST FOR A , 19 STATEMENT ABOUT THE MYSTERY MAN. 20 A WHETHER THAT BE TRUE THEN, SIR, I WOULD SAY 21 MR. MEEKS HAS A BETTER RECOLLECTION OF IT THAN I DO. 22 Q WELL, LOOK DOWN AT THE BOTTOM OF THE FIRST 23 PAGE THERE, MR. PARKS. YOU'VE READ THE ENTIRE FIRST PAGE, 24 HAVEN'T YOU? 25 A YES. 11-121 h
1 i l 1 1 Q AS A MATTER OF FACT, YOU HAVE READ ALL OF.THE j
-I 2 DOCUMENT? j i
3 A YES, I DID NOT STUDY IT, BUT I DID READ IT. 1 > 4- Q ON THE FIRST PAGE THERE IS'A CONCERN 1 5 EXPRESSED BY THE WRITER THAT THE PORTION OF THE PARKS l 6 AFFIDAVIT, PAGE 36 AND 37, WAS EXTREMELY CONDENSED AND IS 7 APPARENTLY ISSUING THIS STATEMENT THAT MORE FULLY 6 8 DISCLOSES IT AND INDICATES THEY NEED TO BE CLARIFIED AND 9 PRESENTED IN THEIR PROPER CONTEXT. WAS THAT A VIEW THAT 10 YOU HELD ABOUT YOUR DISCUSSION OF THE MYSTERY MAN ON PAGES 11 36 AND 37 OF YOUR AFFIDAVIT? 12 A I BELIEVE, AT SOME POINT IN TIME, WHAT I -- 13 WHEN I WAS REQUESTED BY THE NRC REGARDING THAT ENTRY IN MY 14 AFFIDAVIT, THAT IT BECAME APPARENT I WAS GOING TO HAVE TO
-15 EXPAND THE INTENT BEHIND THAT PARAGRAPH, YES.
16 Q AND DID YOU BECOME-AWARE THAT THERE WAS 17 CONGRESSIONAL TESTIMONY PRESENTED BY GENERAL PUBLIC 18 UTILITIES NUCLEAR CORPORATION AGAIN ABOUT THE FINDINGS OF 19 THE STIER INVESTIGATION REGARDING YOUR MYSTERY MAN 20 ALLEGATION? 21 A YES, SIR, IF MEMORY SERVES ME CORRECTLY, BOTH 22 YOU AND I WERE AT THAT HEARING. 23 Q WHEN DO YOU THINK THE HEARING WAS? 24 A APRIL 26TH, I BELIEVE, 1983. IT WAS SOMETIME 25 IN APRIL OF '83. 11-122
1 Q IS THAT THE CONGRESSIONAL TESTIMONY THAT'S ; i 2 REFERENCED IN THE THIRD PARAGRAPH OF EXHIBIT 45? -i 3 A PROBABLY.
)
l 4' Q THE LAST PARAGRAPH ON THE FIRST PAGE SAYS l 1 5 THAT "BERNIE SMITH DISCUSSED KUNDER'S ACTIVITIES AT THE- ! i' 6 ACCIDENT lN MUCH MORE GENERAL TERMS THAN JOE CHWASTYK, WHO 7 IDENTIFIED THE SAFETY INJECTION PUMPS." WAS THAT YOUR 8 VIEW OF MR. SMITH'S COMMENTS ABOUT KUNDER'S ACTIVITIES? . 9 A I SEEM TO RECALL, AT THIS MOMENT, THAT f
\
10 JOE CHWASTYK WAS MORE DEFINITIVE IN HIS CONVERSATIONS THAN ! 11 BERNIE SMITH WAS, RIGHT. I HAVE PUT THIS -- 1 HAVE NO 12 INFORMATION AT MY DISPOSAL AT PRESENT TO DISPUTE THAT 13 STATEMENT. 14 Q WELL, MR. SMITH, ARE YOU SAYING, NEVER 15 REFERRED TO THE SAFETY INJECTION PUMPS? 16 A I CAN'T REALLY PROVIDE ANY MORE DETAILS, AT 17 THIS MOMENT, THAN WHAT THIS STATEMENT PROVIDES OR THAN 18 WHAT I HAVE PREVIOUSLY TESTIFIED TO. 19 Q WELL, YOU HAVE A RECOLLECTION OF WHETHER 20 MR. SMITH DID OR DID NOT REFER TO THE SAFETY INJECTION I 21 PUMPS? . 22 A NOT AT THIS POINT IN TIME, 1 DO NOT. 23 Q HOW ABOUT WHEN MR. SMITH USED THE WORDS 24 " MYSTERY MAN" IN REFERENCE TO MR. KUNDER? 25 A I DON'T THINK ANYONE SPECIFICALLY SAID 11-123
1 " GEORGE KUNDER IS A MYSTERY MAN." BUT THERE AGAIN, 2 MR. HICKEY, YOU KNOW, YOU'RE ASKING ME TO RECALL EVENTS ' 3 SOME.FOUR YEARS AGO. AND MY MEMORY, AT THIS POINT IN 4 TIME, IS PROBABLY NOT AS DEFINITIVE AS IT WAS WHEN ALL 5 THESE DRAFTS AND AFFIDAVITS AND EVERYTHING WERE WRITTEN. 6 Q WELL, YOU UNDERSTAND THEN, MR. PARKS, WHY I'M 7 ASKING ABOUT IT. IT'S A FAIRLY ~IMPORTANT ISSUE TO SOME 8 PEOPLE. YOU KNOW THAT, DON'T YOU? 9 A I HAVE BEEN LED TO BELIEVE THAT SOME PEOPLE 10 CONSIDER IT A VERY IMPORTANT ISSUE. ' 11 Q DON'T YOU? 12 A TO A DEGREE, YES. NOT AS MUCH AS I USED TO 13 THINK IT WAS AN IMPORTANT ISSUE. 14 Q WHEN DID YOUR VIEW CHANGE? 15 A AFTER THE NRC SUPPOSEDLY LOOKED INTO IT AND 16 WERE SATISFIED. 17 Q WELL -- 18 MR. BERRY: SATISFIED THAT WHAT? ^ 19 THE WITNESS: THEY DIDN'T LOOK ANY FURTHER. SO 20 APPARENTLY THE NRC LOOKED AT THE WHOLE ISSUE, AND THEY 21 DECIDED THEY WERE HAPPY WITH WHAT THEY FOUND OUT. 22 MR. HICKEY: EXCUSE ME, ONE MOMENT. 23 (DISCUSSION HELD OFF THE RECORD.) 24 (WHEREUPON THE NOTARY PUBLIC READ THE ANSWER 25 APPEARING ON PAGE 123, LINE 25 THROUGH PAGE 124, LINE 5, 11-124 )
.1 INCLUSIVEo) 2 Q BY MR. HICKEY: LOOK AT PAGE 36 OF YOUR ]
l 3 ' AFFIDAVIT, AND I'M DIRECTING YOUR ATTENTION TO THE f i 4 SENTENCE, THE BOTTOM PARAGRAPH, THAT SAYS, QUOTE, "0N J I 1 1 5 SEVERAL OCCASIONS JOE CHWASTYK AND SHIFT SUPERVISOR, ' l 6 BERNIE SMITH, IDENTIFIED GEORGE KUNDER AS THE MYSTERY 7 MAN." THE ANSWER THE REPORTER JUST READ BACK, ARE YOU i 8 CONTRADICTING THAT STATEMENT? 1' I 9 A NO, SIR, I'M NOT CONTRADICTING THAT 10 STATEMENT. I BELIEVE THAT WAS ONE OF THE REASONS WHY THIS 11 DRAFT EVER CAME INTO BEING HERE SIMPLY BECAUSE, LIKE THE 12 GPU, THE NRC INITIALLY JUMPED ON THAT DEFINITIVE TERM OF 13 JOE -- I MEAN " GEORGE KUNDER IS THE MYSTERY MAN." AND AS 14 I STATED NOT MORE THAN A FEW SECONDS AGO AND THE COURT 15 REPORTER READ BACK, I DO NOT THINK GEORGE KUNDER IS THE 16 MYSTERY MAN. THE DISCUSSION REVOLVED AROUND THE ACTIONS t 17 TAKEN BY MR. KUNDER, NOT A LITERAL DESCRIPTION OF HIM 18 BEING THE MYSTERY MAN. 19 Q WELL, WHAT DID YOU MEAN TO COMMUNICATE IN 20 YOUR AFFIDAVIT WHEN YOU SAY CHWASTYK AND SMITH IDENTIFIED 21 KUNDER AS THE MYSTERY MAN 7 WHAT DID YOU MEAN BY THE WORD 22 " IDENTIFIED" IN THAT SENTENCE? l 23 A JUST THAT THEIR DISCUSSIONS IDENTIFIED HIM AS l l 24 BEING THE MYSTERY MAN, THE SAME AS IF 1 COULD SAY j f i 25 MR. HICKEY IS A LAWYER OR I COULD SAY MR. HICKEY IS 11-125
.- .. s -
1 COUNSEL FOR GPU. BOTH CASES DESCRIBES YOU AS BEING A 2 LAWYER. 3 I GUESS WHAT l'M TRYING TO SAY IS THEY DID 4 NOT SAY GEORGE KUNDER IS THE MYSTERY MAN EVERYBODY IS 5 LOOKING FOR. THE DISCUSSION DEALT WITH THE ACTIONS THAT d 6 GEORGE KUNDER HAD TAKEN DURING THE ACCIDENT. THOSE 7 ACTIONS WERE THE SAME ACTIONS BEING CHALLENGED BY THE B&W 8 LAWYER IN THE BSW -- IN THE GPU AS THE MAN WHO SHUT DOWN 9 THE SAFETY INJECTION PUMPS AND/OR DID NOT START THEM 10 AND/OR DID NOT DO WHAT HE WAS SUPPOSED TO DO. l 11 Q YOUR TESTIMONY, WHEN YOU WROTE YOUR AFFIDAVIT 12 ON PAGE 36 AND SAID THAT CHWASTYK AND BERNIE SMITH s 13 IDENTIFIED KUNDER AS THE MYSTERY MAN, YOU DIDN'T MEAN TO 14 INDICATE THAT EITHER OF THOSE PEOPLE HAD USED THE WORDS 15 " MYSTERY MAN" IN REFERENCE TO KUNDER? 16 A I THINK THE STATEMENT Ib STRAIGHTFORWARD. 17 Q WHICH STATEMENT? MY STATEMENT JUST NOW? 18 A THE STATEMENT IN THE AFFIDAVIT. 19 Q WELL, l'M ASKING YOU A SPECIFIC QUESTION 20 ABOUT IT. WHEN YOU WROTE THE STATEMENT THAT WE'VE JUST 21 READ, IS IT YOUR TESTIMONY TODAY THAT YOU INTENDED TO 22 COMMUNICATE THAT -- THAT YOU -- LET ME REPHRASE THE 23 QUESTION. 24 WHEN YOU WROTE THE STATEMENT IN YOUR l 25 AFFIDAVIT, IS IT YOUR TESTIMONY THAT YOU DID NOT INTEND TO u 11-126
1: INDICATE THAT CHWASTYK AND SMITH CALLED KUNDER THE. MYSTERY I 2 MAN? j 1 3' A MY RECOLLECTION, AT THIS MOMENT, IS THAT WHEN 4 I. WROTE THE' AFFIDAVIT, I DID NOT INTEND TO IMPLY THAT I 5 GEORGE -- OR SMITH AND CHWASTYK HAD SPECIFICALLY { 6 IDENTIFIED GEORGE KUNDER -- USED THE TERMINOLOGY THAT HE , 7 IS THE MYSTERY MAN. 8 Q DID YOU EVER HEAR ANYBODY, BEFORE YOU WROTE 9 YOUR AFFIDAVIT, USE THE WORDS " MYSTERY MAN" AND APPLY THEM 10 TO GEORGE KUNDER? j 11 A I THINK I TESTIFIED PREVIOUSLY, SIR, THAT -- 12 1 MEAN WE'VE ALREADY BELABORED THIS POINT. I TESTIFIED 13 PREVIOUSLY I -- IT WAS NOT A DISCUSSION THAT GEORGE KUNDER 14 IS THE MYSTERY MAN; THAT IT WAS GENERAL CONVERSATIONS 15 REGARDING HIS ACTIONS. 16 Q ! CAN HAVE THE QUESTION READ BACK OR'I'LL 17 REPEAT IT, BUT I WOULD LIKE YOU TO ANSWER IT BECAUSE I 18 THINK IT'S IMPORTANT. 19 DID YOU EVER HEAR ANY PERSON, BEFORE YOU 20 WROTE YOUR AFFIDAVIT, USE THE WORDS " MYSTERY MAN" IN 21 REFERENCE TO GEORGE KUNDER? 22 MR. JOHNSON: COULD YOU CLARIFY NOW -- I'M NOT TOO 23 SURE, YOU KNOW, WHAT YOU'RE REFERRING TO BECAUSE YOU'VE 24 ASKED THE QUESTION AND HE'S ANSWERED IT. 25 MR. HICKEY: NOT ABOUT ANY PERSON. I ASKED HIM II-127
l l 1 COUNSEL FOR GPU. BOTH CASES DESCRIBES YOU AS BEING A 2 LAWYER. 3 1 GUESS WHAT l'M TRYING TO SAY IS THEY DID 4 NOT-SAY GEORGE KUNDER IS THE MYSTERY MAN EVERYBODY 15 q l 5 LOOKING FOR. THE DISCUSSION DEALT WITH THE ACTIONS THAT l
'I 6 GEORGE KUNDER HAD TAKEN DURING THE ACCIDENT. THOSE k
7 ACTIONS WERE THE SAME ACTIONS BEING CHALLENGED BY THE B&W j 8 LAWYER IN THE B&W -- IN THE GPU AS THE MAN WHO SHUT DOWN 9 THE SAFETY INJECTION PUMPS AND/OR DID NOT START THEM 10 AND/OR DID NOT DO WHAT HE WAS SUPPOSED TO DO. 11 Q YOUR TESTIMONY, WHEN YOU WROTE YOUR AFFIDAVIT 12 ON PAGE 36 AND SAID THAT CHWASTYK AND BERNIE SMITH
'13 IDENTIFIED KUNDER AS THE MYSTERY MAN, YOU DIDN'T MEAN TO 14 INDICATE THAT EITHER OF THOSE PEOPLE HAD USED THE WORDS 15 " MYSTERY MAN" IN REFERENCE TO KUNDER? i 16 A I THINK THE STATEMENT IS STRAIGHTFORWARD.
17 Q WHICH STATEMENT? MY STATEMENT JUST NOW? 18 A THE STATEMENT IN THE AFFIDAVIT. l 19 Q WELL, l'M ASKING YOU A SPECIFIC QUESTION 20 ABOUT IT. WHEN YOU WROTE THE STATEMENT THAT WE'VE JUST 21 READ, IS IT YOUR TESTIMONY TODAY THAT YOU INTENDED TO 22 COMMUNICATE THAT -- THAT YOU -- LET ME REPHRASE THE 23 QUESTION. 24 WHEN YOU WROTE THE STATEMENT IN YOUR 25 AFFIDAVIT, 15 IT YOUR TESTIMONY THAT YOU DID NOT INTEND TO 11-126
1: !NDICATE THAT CHWASTYK AND SMITH CALLED KUNDER THE MYSTERY 2 MAN? 3 A- MY RECOLLECTION, AT THIS MOMENT, IS THAT WHEN 4 I WROTE THE AFFIDAVIT, 1 DID NOT INTEND TO IMPLY THAT 5 GEORGE -- OR SMITH AND CHWASTYK HAD SPECIFICALLY 6 IDENTIFIED GEORGE KUNDER -- USED THE TERMINOLOGY THAT HE 7 IS THE MYSTERY MAN. 8 Q DID YOU EVER HEAR ANYBODY, BEFORE YOU WROTE 9 YOUR AFFIDAVIT, USE THE WORDS " MYSTERY MAN" AND APPLY THEM
.3 0 ' TO GEORGE KUNDER?
11 A I THINK I TESTIFIED PREVIOUSLY, SIR, THAT -- 12 I MEAN WE'VE ALREADY BELABORED THIS PolNT. 1 TESTIFIED 13 PREVIOUSLY I -- IT WAS NOT A DISCUSSION THAT GEORGE KUNDER 14 IS THE MYSTERY MAN; THAT IT WAS GENERAL CONVERSATIONS 15 REGARDING HIS ACTIONS. 16 Q l CAN HAVE THE QUESTION READ BACK OR I'LL 17 REPEAT IT, BUT I WOULD LIKE YOU TO ANSWER IT BECAUSE I 18 THINK IT'S IMPORTANT. 19 D!D YOU EVER HEAR ANY PERSON, BEFORE YOU 20 WROTE YOUR AFFIDAVIT, USE THE WORDS " MYSTERY MAN" IN 21 REFERENCE TO GEORGE KUNDER? 22 MR. JOHNSON: COULD YOU CLARIFY NOW -- I'M NOT TOO 23 SURE, YOU KNOW, WHAT YOU'RE REFERRING TO BECAUSE YOU'VE l 24 ASKED THE QUESTION AND HE'S ANSWERED IT. 25 MR. HICKEY: NOT ABOUT ANY PERSON. I ASKED HIM 11-127 l
1 .ABOUT MR. SMITH AND MR. CHWASTYK. l 2 MR. JOHNSON: OKAY. WHAT I'M FOCUSING ON -- I'M 3 NOT UNDERSTANDING WHAT YOU MEAN BY " HEARD" BECAUSE HE ALSO I 4 TESTIFIED' ABOUT READING AN ARTICLE AND BLAH, BLAH, BLAH AT l 5 THE BSW TRIAL, SO I'M NOT SURE EXACTLY WHAT YOU'RE ASKING. 6 MR. HICKEY: WELL, I'LL MAKE IT CLEAR. 7 Q BY MR. HICKEY: I'M TALKING ABOUT WHETHER ! 8 YOUR EARS EVER HEARD ANY HUMAN BEING, BEFORE YOU WROTE THE 9 AFFIDAVIT, USE THE WORDS " MYSTERY MAN" ABOUT GEORGE 10 KUNDER? 11 A ARE YOU -- LET ME SEE IF I UNDERSTAND YOU 12 CORRECTLY. ARE YOU ASKING ME IF I EVER HEARD SOMEONE SAY 13 " GEORGE KUNDER IS THE MYSTERY MAN" BEFORE I WENT PUBLIC? 14 Q YES. 15 A NO, NOT THAT I CAN RECALL AT THIS MOMENT. l l 16 Q DID YOU EVER HEAR.ANYONE SUGGEST THAT 17 GEORGE KUNDER WAS THE MYSTERY MAN BEFORE YOU WENT BACK AND 18 USED THE WORDS " MYSTERY MAN" ABOUT HIM? 19 A NOT THAT I CAN RECALL AT THIS MOMENT. 20 Q NOW YOU MAKE A DISTINCTION IN YOUR AFFIDAVIT, 21 MR. PARKS, ON PAGE 36, IF YOU WANT TO LOOK AT IT THERE, 22 AFTER YOU SAY THAT "CHWASTYK AND SMITH IDENTIFIED KUNDER 23 AS THE MYSTERY MAN, ONE OR THE OTHER HAS IDENTIFIED THEM 24 TO KING, JOE SMITH, JOHN PERRY, JOHN AUGER, JOYCE WENGER, 25 AND MYSELF." THEN YOU SAY THAT ANOTHER GROUP OF PEOPLE
)
11-128 l I
l
-1 HAVE ACKNOWLEDGED THAT CHWASTYK OR SMITH HAVE IDENTIFIED 2 KUNDER AS THE MAN WHO SHUT DOWN SAFETY INJECTION PUMPS.
l 3 WEREN'T YOU TRYING, ON PAGE 36 OF YOUR I 4 AFFIDAVIT, TO DRAW A DISTINCTION BETWEEN PEOPLE WHO l 5 IDENTIFIED KUNDER AS THE MYSTERY MAN AND PEOPLE WHO ) l
- 6. IDENTIFIED KUNDER AS THE MAN WHO SHUT DOWN SAFETY j
)
7 INJECTION PUMPS? 8 A NO, I DON'T THINK I WAS TRYING TO DRAW THAT 9 DISTINCTION. 10 Q YOU'MADE A COMMENT A MOMENT AGO THAT YOU 1 11 THOUGHT ONE OF THE REASONS WHY THE DRAFT AFFIDAVIT WAS 12 WRITTEN WAS BECAUSE INITIALLY THERE WAS SOME CONFUSION OR 13 MISPERCEPTION. THAT SUGGESTS TO ME THAT YOU MAY THINK YOU l 14 WROTE THIS DRAFT AFFIDAVIT, MR. PARKS; IS THAT YOUR l 15 BELIEF? 16 NO, A I HAVE NOT SEEN OR LEARNED ANYTHING IN 17 THESE PROCEEDINGS THAT MAKES ME CHANGE MY ORIGINAL 18 OPINION. I BELIEVE I STATED I DO NOT RECALL, AT THIS 19 MOMENT, IF I WROTE THAT OR NOT. IT MAY HAVE BEEN WRITTEN 20 BY SOMEONE ELSE. 21 Q WHO?
'22 A I COULDN'T TELL YOU AT THIS POINT IN TIME.
23 AS I STATED PREVIOUSLY, I WAS IN THE HABIT OF SIGNING 24 ANYTHING I WROTE. 25 Q HOW ABOUT DRAFTS, DID YOU SIGN DRAFTS? 11-129 k __ -__ -----___-___a
4 1 A PROBABLY. I WOULD SAY I USUALLY DID. 2 Q IF YOU WILL TAKE A LOOK AT EXHIBIT 37 -- WAIT T 3 A MINUTE, 37, YES, PLEASE. IT'S A 13-PAGE DOCUMENT, 4 UNSIGNED. 3 A RIGHT. 6 Q AND LET ME DIRECT YOUR ATTENTION TO THE -- 7 LET ME GET A PAGE FOR YOU. NINE. THERE'S TWO PARAGRAPHS, 8 THE TWO MIDDLE PARAGRAPHS, ON THAT PAGE, DISCUSS YOUR 9 MYSTERY MAN ALLEGATION. COULD YOU READ THOSE, PLEASE. 10 A DO YOU WANT ME TO READ THEM OUT LOUD OR TO 11 MYSELF? 12 Q NO. JUST READ THEM TO YOURSELF. 13 (WITNESS COMPLIES.) 14 THE WITNESS: OKAY. 15 Q BY MR. HICKEY: DO YOU RECALL MAKING j 16 STATEMENTS IN SUBSTANCE LIKE THOSE TWO PARAGRAPHS TO l 17 MR. MEEKS AND VORSE OF THE NRC? 18 A AT THIS POINT IN TIME, SIR, I COULDN'T TELL 19 YOU IF I DID OR NOT. 20 Q IF MR. MEEKS AND MR. VORSE WERE TO SWEAR 21 UNDER OATH THAT THEY MADE NOTES OF AND RECORDED YOUR 22 STATEMENTS TO THEM AND THAT THIS IS AN ACCURATE RECORDING j 23 OF THEIR -- OF YOUR STATEMENTS TO THEM, WOULD YOU 24 DISBELIEVE THEIR TESTIMONY? 25 A WELL, YOU'RE ASKING ME TO ISSUE A l 1 I 11-130 I - _ _ _ - _ _ - - _ i
7-__-___. l
'li
- 1. HYPOTHETICAL OPINION ON A HYPOTHETICAL SITUATION.- j l
2 Q .WELL,- I'M ASKING YOU IF YOU HAVE ANY~ BASIS TO r 3 DISBELIEVE IT? , 4 A MY ONLY RESPONSE TO.THAT WAS THAT IF -- YOU 5 -. KNOW, IF'THEY'WERE TO DO SUCH AN ACTION,- I WOULDDONLY ASK j 1 6 THEM HOW COME-I WAS'NOT ALLOWED TO SIGN IT AND AGREE'THAT j 7 THAT WAS AN ACCURATE REFLECTION OF'WHAT:WE DISCUSSED. 3 8 Q -AND YOU DON'T HAVE ANY RECOLLECTION OF BEING 9 GIVEN-AN OPPORTUNITY TO SIGN.OR REVIEW OR MAKE~ CHANGES TO 10 THIS DOCUMENT, WHICH.IS. EXHIBIT 40 -- EXHIBIT'37? '
- 11 A ALL-I CAN SAY, SIR, IS BASED ON MY. OPINION 12 FROM LOOKING AT THIS DOCUMENT IN MY HAND, IN MY HAND RIGHT
- 13. NOW, WHICH IS NOT SIGNED, WHICH IS EXHIBIT 37, AND IT'S
~
14- NOT SIGNED BY ME. S0 I DON'T KNOW' IF I ANSWERED YOUR
. 15 QUESTION OR NOT BECAUSE --
I GUESS WHAT I'M TRYING TO SAY 4 16 IS I DON'T HAVE ANYTHING PRESENT IN MIND, AT THE MOMENT, 17 THAT I CAN RECALL TO DISPUTE OR TO AGREE WITH THAT. 18 MR. HICKEY: ilH Y DON'T WE BREAK FOR LUNCH.
. 19 (LUNCH BREAK.)
20' (MR. BERRY IS NOT PRESENT IN THE DEPOSITION
- 21 PROCEEDINGS.).
22 MR. . JOHNSON: YESTERDAY.YOU ASKED MR. PARKS ABOUT. 23 WHETHER HE HAD REVIEWED ANY DOCUMENTS IN PREPARATION FOR 1 24 THE DEPOSITION, AND MR. PARKS GAVE HIS ANSWER. 25 JUST FOR THE SAKE OF COMPLETENESS, I WANTED 11-131
1 TO INDICATE THAT NOT DIRECTLY IN CONNECTION WITH THIS 2 DEPOSITION AND, I THINK, BEFORE THE NOTICE WAS TRANSMITTED i 1 3 TO HIM, I TRANSMITTED TO MR. PARKS COPIES OF THE 4 DEPOSITIONS THAT WERE TAKEN IN THIS CASE SO THAT Hu HAD 5 THEM AT HIS DISPOSAL, THOSE DEPOSITIONS. l 6 MR. HICKEY: THE DEPOSITIONS OF ALL THE WITNESSES 7 THAT HAVE BEEN'TAKEN UP TO THIS TIME? l 8 MR. JOHNSON: BELIEVE IN OUR PROCEEDING. i 9 MR. HICKEY: AT HIS REQUEST? 10 MR. JOHNSON: 1 DON'T THINK THAT'S RELEVANT, BUT I 11 DID. 12 MR. HICKEY: I'LL ASK HIM. 13 MR. JOHNSON: SURE. l 14 Q BY MR. HICKEY: MR. PARKS, YOU HAVE HEARD 15 MR. JOHNSON'S STATEMENT. DID YOU ASK HIM TO SEND ALL OF 16 THOSE DEPOSITIONS TO YOU? l 17 A I CAN RECALL TALKING WITH MR. JOHNSON ON A l 18 COUPLE OF DIFFERENT OCCASIONS, BUT NOW WHETHER THE REQUEST 19 CAME FROM ME OR WHETHER IT WAS VOLUNTEERED BY HIM, I 20 REALLY COULDN'T TELL YOU. 21 Q DID YOU READ THE DEPOSITIONS? 22 A I READ SOME OF THEM. 23 Q WHOSE DID YOU READ? 24 A 1 DON'T REMEMBER EXACTLY WHICH ONES I READ. 25 THE ONES THAT SEEMED TO HAVE MOST INTEREST TO ME. 11-132
1- Q DID YOU READ MR. GISCHEL'S? 2 A I THINK ED'S WAS PROBABLY ONE OF THE ONES I 3' READ. 4 Q HOW ABOUT MR. KITLER'S? 5 A I THINK I MAY HAVE. 6 Q HOW ABOUT MR. BUCHANAN AND MR. AUSTIN, EITHER ; i 7 ONE? I 8 A I DON'T REALLY RECALL IF I READ THEIRS OR 9 NOT. 10 Q HOW ABOUT TOM MORRIS' DEPOSITION, DID YOU l 11 READ THAT? 12 A YES, I DID. l 13 Q HOW ABOUT RON WARREN'S? 14 A PROBABLY. I GUESS, YOU KNOW, TO -- IN LIEU 15 OF THE TIME, RATHER THAN HAVE YOU SIT THERE AND ASK ME 16 EACH INDIVIDUAL PERSON'S THAT I READ, I DO NOT THINK I i 17 READ ANY OF THEM IN THEIR ENTIRETY, BUT ONLY READ SELECTED 18 . SECTIONS. 19 Q WELL, I'M STILL INTERESTED IN KNOWING WHAT 20 YOU DID REVIEW. LET ME ASK YOU A FEW MORE. < i 21 DID YOU READ ALL OR PORTIONS OF THE I l 22 DEPOSITION TRANSCRIPT OF MR. KANGA? l 23 A I PROBABLY READ PORTIONS OF IT. 24 Q HOW ABOUT MR. SANFORD? l 25 A I THINK I PROBABLY READ HIS IN ITS ENTIRETY. 11-133
1 THAT WOULD BE A GUESS. SEE, WHEN I RECEIVED THESE l 2 DOCUMENTS I WAS STILL IN THE MIDST OF TRYING TO REVIEW 3 OTHER DOCUMENTS. AND IT GETS KIND OF CONFUSING AT'WHAT 4' POINT I REVIEWED WHOSE FOR WHAT REASON. THAT'S WHY l'M A 5 LITTLE BIT RELUCTANT TO SAY WITH CERTAINTY, AT THIS PolNT 6 IN TIME, WHICH ONES I READ AND TO hHAT DEGREE. 7 Q HOW ABOUT MR. GALLAGHER'S, DO YOU REMEMBER-8 READING HIS? ) 9 A NOT OFF THE TOP OF MY HEAD I DON'T. 10 Q TAKE A MOMENT AND REFLECT ON IT, WOULD YOU 11 PLEASE. COULD'YOU TELL ME WHETHER YOU THINK YOU DID? 12 A I DON'T RECALL WHETHER I DID OR NOT. 13 Q ANYONE ELSE'S THAT YOU CAN RECALL? 14 A BUBBA'S. 15 Q BUBBA MARSHALL. DID YOU READ ALL OF THAT? I 16 A I REALLY COULDN'T TELL YOU IF I READ IT ALL , 17 OR NOT. 18 Q HOW ABOUT MR. THEISING'S? 19 A I SEEM TO RECALL I READ AT LEAST PORTIONS OF 20 HIS. 21 Q LET ME SEE IF I CAN CLEAR UP ONE OTHER THING. / 22 YOU EXPRESSED THIS MORNING, REFERRING TO i 23 EXHIBIT 43, THE DOCUMENT CALLED "TMI, THE BECHTEL l 24 CONNECTION," THAT YOU HAD A RECOLLECTION THAT YOU BELIEVED 25 YOU HAD BEEN SHOWN THAT DURING THE COURSE OF 11-134 1 l i
i 1 MR. RICHARDSON'S DEPOSITION OF YOU IN THE CIVIL LITIGATION
-2 THAT YOU PREVIOUSLY HAD WITH BECHTEL. I l
I3 DURING THE LUNCHEON RECESS WE! CAUSED A REVIEW 1 4 TO BE-MADE OF THELTRANSCRIPT SO THAT WE COULD DETERMINE IF 5 THAT. APPEAREDLTO BE THE CASE AND-HAVE BEEN INFORMED THAT 6 THAT-DOCUMENT IS NOT MARKED AS AN' EXHIBIT =TO YOUR ) 7: DEPOSITION IN THE'BECHTEL CASE. AND THERE'S-NO INDICATION { 8 ON THE RECORD THAT IT WAS SHOW'N TO YOU. DO YOU HAVE ANY 9 OTHER' RECOLLECTION'NOW OF WHEN YOU MIGHT HAVE SEEN THIS 10 DOCUMENT, EXHIBIT 43, IF YOU DID NOT.SEE IT AT THE'BECHTEL ; 11 DEPOSITION 0F YOU?
.12 A NO, I'DO NOT.
13 MR. HICKEY: WOULD YOU MARK THAT, PLEASE. 14- (WHEREUPON RESPONDENT'S EXHIBIT 46 WAS MARKED 15 FOR IDENTIFICATION BY THE NOTARY PUBLIC, AND A COPY ~ Is 16 ATTACHED HERETO.) 17 Q BY M R .- HICKEY: SO WE CAN TRY AND.MAKE THE 18 RECORD AS COMPLETE AS POSSIBLE, MR. PARKS, I'M SHOWING YOU 19 WHAT'S BEEN MARKED AS EXHIBIT 46. IT'S A-ONE-PAGE SHEET 20' WITH SOME HANDWRITING ON IT. IGNORE THE " EXHIBIT'B" WHICH l 21 IS UP AT THE TOP IN'THE UPPER RIGHT-HAND CORNER. THAT WAS
)
22' TYPED ON LATER. BUT I WILL REPRESENT TO YOU THAT THIS
- 23. SHEET WAS NEXT TO EXHIBIT 43, THE BECHTFL CONNECTION e
24 DOCUMENT, IN THE PILE OF DOCUMENTS THAT WE RECEIVED FROM 25 THE NRC. DO YOU RECOGNIZE THE HANDWRITING ON EXHIBIT 46? 11-135
1 A I THINK I DO. 2 Q WHOSE IS IT? 3 A I BELIEVE IT TO BE TOM DEVINE'S, BUT I 4 WOULDN'T SWEAR ON A STACK OF BIBLES THAT IT WAS. 5 I WOULD ALSO LIKE TO AT THIS TIME PAUSE WHILE 6 1 REVIEW TWO OF MY PREVIOUS DEPOSITIONS FROM MY CIVIL CASE 7 BECAUSE I DO NOT AGREE WITH YOUR CONTENTION THAT I WAS NOT 8 SHOWN ANY DOCUMENT ALONG THE LINE -- OR WITH THIS TYPE OF 9 A HEADING IN MY CIVIL CASE. AND I WOULD LIKE TO HAVE THAT 10 TIME TO REVIEW THOSE. 11 Q I THINK YOU MISUNDERSTOOD ME. I'M NOT 12 REFERRING TO EXHIBIT 46 WHEN I MADE THAT STATEMENT. 13 A I REALIZE THAT. YOU WERE REFERRING TO 14 EXHIBIT 43. AND I SEEM TO RECALL SOMETHING ALONG THIS 15 LINE, SOMETHING ABOUT AN ANONYMOUS WHISTLEBLOWER AND SOME 16 SORT OF INFERENCE OR REFERENCE TO TMI, THE BECHTEL - 17 CONNECTION IN MY CIVIL CASE. G 18 Q LET ME MAKE A SUGGESTION. THAT WAS MY 19 REPRESENTATION, AND I DIDN'T DO THE REVIEW MYSELF. SO l'M 20 NOT CLAIMING THAT I HAVE CHECKED ALL THE EXHIBITS. 21 BUT IN THE INTEREST OF TIME, l'M GOING TO GO 22 AHEAD AND ASK YOU SOME QUESTIONS. IF YOU WOULD LIKE TO 23 REVIEW THAT DOCUMENT, THOSE COPIES OF THE DEPOSITIONS THAT 24 YOU HAVE, LET ME ASK YOU TO DO THAT OVER THE COURSE OF THE 25 EVENING OR OVER THE COURSE OF THE MORNING HOURS TOMORROW 11-136
l l' BEFORE WE CONVENE BECAUSE I DON'T REALLY NEED -- YOUR l l 2 POSITION IS THAT YOU BELIEVE YOU WERE SHOWN THAT, AND 3 .THAT'S FINE. YOUR STATEMENT IS ON THE RECORD. AND THE 4 DEPOSITION EXISTS. AND AT SOME POINT, ANYBODY WHO WANTS 5 TO CAN CHECK IT, BUT l'D LIKE TO GO AHEAD WITH THE 6 DEPOSITION. 7 A BEFORE WE DRIFT TOO MUCH FURTHER OFF, OVER 8 THE COURSE OF LUNCH I HAD TIME TO REFLECT AND l'D LIKE TO 9 TAKE THIS OPPORTUNITY TO TRY TO CORRECT THE RECORD ' 10 SOMEWHAT BECAUSE WE SPENT AN INORDINATE AMOUNT OF TIME ON 11 BOTH EXHIBIT 37 AND, I BELIEVE, EXHIBIT 45, BOTH OF WHICH 12 ARE DOCUMENTS OF ONE TYPE OR ANOTHER, STATEMENTS THAT WERE 13 UNSIGNED BY ME. BUT WHAT I WOULD LIKE TO SAY IS THAT I 14 THINK I MAY HAVE LEFT YOU WITH THE WRONG IMPRESSION. 15 1 DON'T DISAGREE NECESSARILY WITH ANYTHING 16 THAT'S CONTAINED IN THOSE DOCUMENTS, BASED ON MY LIMITED 17 REVIEW OF THOSE DOCUMENTS. BUT I ALSO BELIEVE THAT ANY 18 AND ALL REFERENCES REGARDING ANY STATEMENTS THAT ARE 19 CONTAINED WITHIN THOSE -- THAT TWO DOCUMENTS WERE LATER 20 EXECUTED BY ME AS PART OF A SWORN STATEMENT TO THE NRC. 21 AND NOW THE ONE IN PARTICULAR YOU HAD A 22 QUESTION REGARDING WHETHER OR NOT I HAD PREPARED IT AND 23 SENT IT TO RON MEEKS, I DO NOT RECALL PREPARING AND 24 SENDING THAT DOCUMENT TO RON MEEKS, BUT MY LAWYERS MAY 25 HAVE. 11-137
1 Q WELL, YOUR LAWYERS WOULDN'T HAVE PREPARED IT b l 2 WITHOUT YOUR PARTICIPATION, WOULD THEY? ' 3 A WE MAY HAVE REVIEWED IT OVER THE PHONE. 4 4 Q LET ME UNDERSTAND SOMETHING THAT YOU JUST 5 SAID. YOUR TESTIMONY IS THAT THE INFORMATION THAT IS 6 CONTAINED IN EXHIBIT 37 AND IN EXHIBIT 45 -- LET'S TAKE l 7 THEM ONE AT TIME. 8 YOU DIDN'T SEE ANYTHING IN EXHIBIT 37 THAT 9 LOOKED TO YOU LIKE IT WAS IN ERROR; IS THAT YOUR 10 TESTIMONY? 11 A I GUESS WHAT I'M TRYING TO SAY IS AT ONE 12 POINT IN TIME I ENDED UP EXECUTING A DOCUMENT OR A l l 13 STATEMENT THAT WENT ALONG WITH THE SAME TYPE OF. LINES OR 14 INFORMATION PROVIDED BY EXHIBIT .X 7 . IN FACT, I ACTUALLY 15 ENDED UP DOING IT IN A COUPLE OF DIFFERENT ONES. 16 Q LET ME JUST S'OP YOU SO WE CAN GET IT CLEAR. 17 THAT'S WHY I SHOWED YOU AND THAT WHY I RE-MARKED THE 18 THREE SWORN STATEMENTS THAT ARE THERE IN FRONT OF YOU. 19 AND CHECK BACK ON IT FOR JUST A MINUTE, BUT THAT'S EXHIBIT 20 38, WHICH IS A SIX-PAGE STATEMENT YOU SWORE TO ON 6/6. 21 MR. JOHNSON IS GOING TO GRACIOUSLY PUT IT IN FRONT OF YOU. 22 MR. JOHNSON: GIVE ME A SECOND. THESE THINGS ARE , l 23 OUT OF ORDER. HERE'S 40, 38 AND 37. ARE THOSE THE THREE? 24 MR. HICKEY: YES. 25 Q BY MR. HICKEY: 38 IS THE SIX-PAGE OF JUNE 6, 11-138 l l l
1 AND 39 AND 40 ARE TWO STATEMENTS DATED JULY 25, '83? 2 A RIGHT. ) 3 Q NOW IS IT YOUR TESTIMONY THAT IN ADDITION.TO 4- THOSE THERE'S ANOTHER SWORN STATEMENT THAT YOU SIGNED? 5 (MR. BERRY HAS RETURNED TO THE DEPOSITION 6 PROCEEDINGS.) i
\
7 THE WITNESS: I SEEM TO RECALL THAT THERE WAS I 8 ANOTHER SWORN STATEMENT THAT I SIGNED, BUT I AM NOT 9 ABSOLUTELY CERTAIN ON IT. WHAT I AM STATING OR TRYING TO l i 10 GET MY MESSAGE ACROSS IS THAT THIS DRAFT -- AND THAT'S ? 11 EXACTLY WHAT IT LOOKS LIKE -- I 12 Q BY MR. HICKEY: 37? 13 A i
-- WHICH IS EXHIBIT 37. l 14 I, AT SOME TIME, EXECUTED DOCUMENTS OR ,
15 STATEMENTS THAT CONTAINED BASICALLY THE SAME INFORMATION 16 AS CONTAINED IN EXHIBIT 37. 17 Q AND -- 18 A MY PROBLEM TO BEGIN WITH WAS VMETHER OR NOT 19 YOU ASKED ME WHETHER OR NOT I HAD SEEN IT OR WHETHER OR 20 NOT I HAD HELPED PREPARE IT, THAT TYPE OF THING. IT DID 21 NOT HAVE MY SIGNATURE. THAT WAS MY PROBLEM WITH IT. THE 22 INFORMATION I DON'T DISAGREE WITH BECAUSE THE SAME ! 23 INFORMATION IS CONTAINED IN THE LATER EXHIBITS THAT I DID , 24 SIGN. I 25 AND REGARDING THE ONE ON THE MYSTERY MAN, 11-139 m__________...___ _ _ . _ _ _ _ _ _ . .
E 4 i 1 WHICH IS EXHIBIT 45, IT BASICALLY FITS THE SAME CATEGORY. 2 Q THAT IS -- 3 A I DON'T HAVE ANY PROBLEM WITH THE INFORMATION 4 CONTAINED IN IT. AND IT MAY HAVE BEEN TRANSMITTED TO 5 RON MEEKS BY MY LAWYERS. 6 Q WHY DO YOU THINK THAT? 7 A WELL, IT SEEMS TO ME, IF MEMORY SERVES ME 8 CORRECTLY, THAT AFTER I SETTLED MY DEPARTMENT OF LABOR 9 DISPUTE WITH B E C H T E L- ON. JULY 25TH, 1983, THAT ONE OF THE 10 ISSUES THAT WAS STILL PENDING,'IF YOU WILL, WAS THE 11 MYSTERY MAN ISSUE. AND 1 KNOW'THAT LATER ON IN THE YEAR, 12 IN 1983, THE NRC REQUESTED I COME BACK AND TALK WITH NRR 13 REGARDING THE ISSUES DISCUSSED IN THAT MYSTERY MAN 14 STATEMENT REGARDING THE ACTUATION OF THE HIGH PRESSURE 15 INJECTION BORATED WATER STORAGE TANK LEVELS. 16 SO AT SOME POINT IN TIME, MY LAWYERS MAY VERY 17 WELL HAVE PREPARED THAT STATEMENT AND DISCUSSED IT WITH ME t 18 OVER THE PHONE AND TRANSMITTED IT TO THE NRC WITHOUT ME 19 HAVING REVIEWED THE FINAL PRODUCT OR ME SIGNING THE FINAL 20 PRODUCT. i
- 21. Q WERE YOU EVER ASKED BY THE NRC TO SIGN A 22 STATEMENT ABOUT THE MYSTERY MAN, LIKE EXHIBIT 45?
23 A AT THE MOMENT I DO NOT RECALL BEING ASKED BY j 24 THE NRC TO SIGN SUCH A STATEMENT, NO. 25 Q WHAT DID YOU EVER LEARN ABOUT THE RESULTS OF l 11-140
i
.1 THE NRC: INVESTIGATION INTO THE MYSTERY MAN ALLEGATIONS? j i
2 A' WELL, I DON'T THINK I EVER READ A PUBLISHED 3' RESULT. 4 Q WELL, WHETHER'YOU READ IT'OR NOT, WERE YOU i
'5 TOLD?
6 A NOT THAT I CAN' RECALL AT THE MOMENT.- I 7 BELIEVE AT ONE POINT IN TIME I WAS TOLD THAT THEY HAD 8 LOOKED INTO THE SITUATION OF THE MYSTERY MAN, THAT TYPE.0F 9 THING, WERE SATISFIED WITH THEIR RESULTS. BUT l'M-NOT SO 10 SURE I KNOW WHAT THOSE RESULTS WERE.
- 11 Q DO YOU.KNOW WHETHER THE NRC CONCLUDED THAT
'12 HIGH PRESSURE INJECTION ACTUATION HAD OCCURRED OR'NOT?
13 A NO, I DO NOT AT THE MOMENT. 14 Q HOW ABOUT YOU? DID YOU EVER REACH A 15 CONCLUSION ABOUT THAT, MR. PARKS 7 16 A I -- AT ONE POINT IN TIME, I REACHED A 17 CONCLUSION THAT I DISAGREED WITH THE'EDS REPORT WHICH 18 STATED THAT HIGH PRESSURE INJECTION ACTUATION DID NOT 19 REALLY OCCUR AT THE TIME PERIOD IN QUESTION. 20 Q THAT' VIEW OF YOURS IS EXPRESSED ON PAGES 5 21 'THROUGH 8 0F EXHIBIT 45, ISN'T IT? 22- A I BELIEVE S0. I SEEM TO RECALL REVIEWING
't 23 THAT PREVIOUSLY, DISCUSSING IT IN DETAIL. l l
24 Q AND WAS THAT THE LAST VIEW THAT YOU HAD ON I 25 THE MATTER OR DID YOU LATER FORM A DIFFERENT OPINION? l l l
!!-141 j l
i
-- - -- -- _. - __a
- 1. A- WELL, IT SEEMS TO ME, IF I RECALL CORRECTLY, 4
2 AT SOME POINT IN TIME EXTERNAL'TO ALL THESE PROCEEDINGS " 3 THAT GPU RETAINED B&W TO DO AN ANALYSIS TO -- REGARDING 4 HIGH PRESSURE ACTUATION ON THE MORNING OF THE DAY OF THE 5 ACCIDENT, I THINK, SOMEWHERE ALONG THE LINE I READ THEIR 6 RESULTS, TOO. I 7 Q WERE YOU PERSUADED BY THEM? 8 A NO. I 9 Q DO YOU REMEMBER WHAT THE RESULTS WERE? , 10 A NO. I JUST REMEMBERED THEY DIDN'T CHANGE MY 11 OPINION. 12 Q THE LAST OPINION THAT YOU HELD WAS THE ONE 13 EXPRESSED ON THE LAST FOUR PAGES OF EXHIBIT 45, IN 14 SUBSTANCE THAT -- WELL, LET'S NOT CHARACTERIZE. 15 WHAT WAS YOUR LAST VIEW OF THE MATTER? 16 A MY LAST VIEW OF THE MATTER IS BASED ON THE 17 INFORMATION I HAVE HAD AVAILABLE TO ME OVER THE YEARS THAT l 18 IF THE SAFETY INJECTION PUMP WAS NOT SHUT DOWN BY OVERT l 19 ACTION, IT SHOULD HAVE BEEN STARTED BY OVERT ACTION BASED ! l 20 ON THE INDICATIONS AVAILABLE TO THE CONTROL ROOM OPERATORS l 21 DURING THE ACCIDENT WHEN -- OR ABOUT THE TIME THE REACTOR 22 COOLANT PUMPS WERE SECURED. ) i l 23 Q DID YOU CONCLUDE WHETHER THE HBI PUMPS HAD ] L 24 BEEN SHUT DOWN? l 25 A I DON'T THINK THAT WITHOUT -- I'LL GO ON. 1 11-142 ] i _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ . _ - _ . _ _ _ _ .__ ._ A
1 Q I DON'T THINK THAT QUESTION IS CLEAR. LET ME 2 REPHRASE IT FOR YOU. 3- DID YOU CONCLUDE THAT THE HIGH PRESSURE 4 INJECTION PUMPS WERE ON AND THEN WERE SHUT OFF AT OR ABOUT 5 5:41?
.I 6 A AT THIS POINT IN TIME, I DON'T REMEMBER 7 WHETHER THE PUMPS WERE ON AND SHUT OFF AND WHETHER THE 8 SECOND ONE WAS ON. AND I DON'T RECALL THE ACTUAL 9 SEMANTICS OF THE SEQUENCE OF EVENTS.
10 Q AND HOW ABOUT MR. KUNDER? DID YOU REACH A -j 11 CONCLUSION ABOUT MR. KUNDER'S INVOLVEMENT WITH REGARD TO l 12 THE PRESSURE? 13 A WOULD YOU GIVE IT A TIME FRAME? 14 Q ANY TIME. 15 A I BELIEVE I STATED THAT OPINION REGARDING 16 MR. KUNDER'S' ROLE DURING THE ACCIDENT DURING MY CIVIL' 17 PROCEEDINGS, BUT I DON'T MIND REHASHING. 18 GEORGE KUNDER WAS THE ON-CALL DUTY 19 SUPERINTENDENT, I BELIEVE WOULD BE AN ACCURATE TITLE FOR 20 HIS ROLE DURING THE ACCIDENT. AS SUCH, SE WAS THE FIRST 21 . PERSON CALLED IN AFTER THE INITIATION OF THE SEQUENCE OF 22 EVENTS THAT LED UP TO CORE DAMAGE. 23 GEORGE, IN HIS ROLE, WOULD HAVE BEEN AT LEAST 24 IN AN ADVISORY CAPACITY TO THE OPERATORS AND ONE OF THE 25 SENIOR SRO'S IN THE CONTROL ROOM. I AM OF THE BELIEF THAT 11-143 I
1 HE WAS THE ONE THAT ORDERED THE SHUTDOWN OF REACTOR 2 COOLANT PUMPS. I'M ALSO OF THE BELIEF THAT HE WAS THE ONE 3 THAT GAVE THE ORDERS REGARDING THE HEAT PRESSURE INJECTION 4 PUMPS. 5 IN HIS CAPACITY IN T'HE ROLE THAT HE WAS l 6 FULFILLING, IF HE DID NOT ORDER THE SHUTDOWN OF THE SECOND 7 SAFETY INJECTION PUMP OR IF HE DID NOT -- OR ORDERED THE t 8 FORBIDING OF THE SECOND SAFETY INJECTION PUMP, THEN HE l l 9 SHOULD NOT HAVE DONE THE ROLE -- OR DID THE EVOLUTION OR 10 GIVE THE ORDERS THAT WERE GIVEN BECAUSE PLANT CONDITIONS 11 REQUIRED THAT PUMP TO BE RUNNING. 12 Q GIVE WHAT ORDERS THAT WERE GIVEN? 13' A WELL, SEE, I GUESS THAT'S THE PART I'M STILL 14 UNSURE OF, I DON'T REMEMBER ANYMORE IF THE TWO PUMPS WERE 15 RUNNING AND ONE WAS SHUT DOWN OR THE FIRST PUMP WAS 16 RUNNING AND THE SECOND PUMP IN ACTUATION AND IT WAS 17 BLOCKED BY MANUAL OPERATION OF THE OPERATORS. 18 Q ALL RIGHT. BUT -- 19 A UNDER ORDERS. 20 Q BUT YOUR OPINION IS THAT MR. KUNDER DIRECTED 21 THE SHUTDOWN OF AN OPERATING HIGH-PRESSURE INJECTION PUMP? 22 A OR FORBADE. 23 Q PRECLUDED -- l 24 A RIGHT. 25 Q -- THE STARTUP OF AN ALREADY SHUTDOWN i l 11-144 l l j l
) 'l HIGH-PRESSURE INJECTION PUMP?
2 A THE SECOND SAFETY INJECTION PUMP, RIGHT. I'M 3 OF THE OPINION THAT IF HE DID NOT OVERTLY ORDER OR CAUSE 1 4 TO BE ORDERED, THEN HE SHOULD HAVE PERFORMED THE ACTION 5 THAT WOULD HAVE MITIGATED CORE DAMAGE. 6 DID I MAKE MYSELF CLEAR? 7 O AND YOUR BASIS FOR THAT, BESIDES THE REVIEW , 8 OF THE EDS ANALYSIS AND THE BSW ANALYSIS, IS WHAT? { 9 A AFTER I WAS ESCORTED'OFF THE JOB SITE, I 10 REVIEWED A LOT OF THE TRANSCRIPTS FROM THE NRC l l 11 INVESTIGATION INTO THE ACCIDENT AND UNDERSTANDING THE WAY f . 12 THE POWER PLANT WORKS AND THE HIERARCHY OF AUTHORITY WITH 13 HIM BEING THE ON-CALL DUTY SUPERINTENDENT, IT WAS HIS l 14 RESPONSIBILITY TO ASSURE THAT THOSE FUNCTIONS WERE l I 15 PERFORMED PROPERLY. l l 16 Q HIS FUNCTION MORE THAN THE SHIFT SUPERVISOR l 17 YOU MEAN? I { 18 A WELL, IF HE WAS THE ONE THAT WAS ORDERING THE j l 19 SHUTDOWN OF THE REACTOR COOLANT PUMPS, CHANCES ARE HE WAS j 20 THE ONE THAT GAVE THE ORDER REGARDING THE SAFETY INJECTION l 21 PUMPS. 22 Q WAS IT YOUR UNDERSTANDING THAT MR. KUNDER HAD i 23 ORDERED THE SHUTDOWN OF THE REACTOR COOLANT PUMPS AS
-24 DISTINGUISHED FROM SUGGESTING OR RECOMMENDING?
25 A THAT IS MY IMPRESSION, YES, THAT I CAN RECALL
!!-145
l 1 i 1 AT THIS' MOMENT. I 2 DO YOU REMEMBER WHAT THAT IMPRESSION WAS Q ) 3 BASED ON? I i L 4 A JUST BASICALLY EVERYTHING I HAVE ALREADY TOLD l l 5 YOU. 6 Q DID YOU EVER READ MR. KUNDER'S VERSION OF HIS j 7 ACTIVITIES DURING THE ACCIDENT?
.8 A I MAY HAVE AT ONE' POINT IN TIME. 1 9 Q DO YOU REMEMBER WHAT HE SAID? I l
10 A NO, 1 DO NOT. THE OVERALL CONCLUSION THAT I 11 WAS LEFT WITH WAS, IN MY OPINION, SUFFICIENT INFORMATION 12~ TO SUGGEST THAT THE NRC PERFORM A MORE IN-DEPTH REVIEW OF 13 THE WHOLE SEQUENCE OF EVENTS DURING THE ACCIDENT. 14 Q AND I GATHER IT'S YOUR TESTIMONY THAT YOU 15 NEVER WERE MADE AWARE IF IT IS THE FACT THAT THE NRC 16 DIDN'T FEEL THAT WAY? 17 A I REALLY DON'T KNOW WHAT THE-OUTCOME WAS OF 18 1HE NRC OF THOSE REVIEWS OF THE SET OF CIRCUMSTANCES. 19 Q WELL, JUST SO l'M CLEAR ABOUT WHAT YOU'RE 20 ADOPTING OR NOT DISAGREEING WITH, EXHIBIT 45, THE DRAFT 21 MYSTERY MAN AFFIDAVIT, YOUR' TESTIMONY TODAY 15, TO THE 22 BEST OF YOUR KNOWLEDGE, ON PAGE 2 0F THAT DOCUMENT, THAT 23 GEORGE -- THAT JOE CHWASTYK IN MARCH SAID THAT KUNDER SHUT 24 OFF THE SAFETY INJECTION PUMPS; IS THAT RIGHT? l 1 25 A I HAVE NOTHING AVAILABLE AT MY DISPOSAL 11-146 t
1 PRESENTLY TO DISAGREE WITH THAT STATEMENT, NO. 2 Q 00 YOU HAVE ANYTHING IN YOUR RECOLLECTION 3 THAT TELLS YOU THAT YOU REMEMBER THAT HAPPENING? 4 A I HAVE NOTHING IN MY RECOLLECTION AT THE j 5 PRESENT MOMENT THAT WILL ELABORATE ON THAT STATEMENT 6 EITHER. SO I GUESS, TO ADOPT YOU R WORD'3, YES, I'M 7 ADOPTING THAT STATEMENT. 8 Q WELL, l'M TRYING TO FIND OUT WHAT THE BASIS 9 IS FOR YOUR ADOPTING IT. DO YOU HAVE A RECOLLECTION, AS 10 YOU SIT HERE TODAY, OF HEARING MR. CHWASTYK SAY THAT 11 "KUNDER SHUT OFF THE SAFETY INJECTION PUMPS"? ' 12 A I HAVE A RECOLLECTION TODAY THAT I WAS 13 REQUESTED TO EXPAND THAT STATEMENT IN MY ORIGINAL 14 AFFIDAVIT REGARDING GEORGE KUNDER, AND I AM OF THE BELIEF 15 THAT THIS WAS THE EXPANDED STATEMENT. AND THAT'S ABOUT i 16 THE MOST AMPLIFICATION I CAN GIVE YOU AT THE GRESENT TIME. ; 17 Q WELL, THAT'S A PRETTY SIMPLE QUESTION. DO l 18 YOU HAVE A RECOLLECTION, AS YOU SIT HERE TODAY, MR. PARKS, 19 OF HEARING MR. CHWASTYK IN MARCH SAY THAT "KUNDER SHUT OFF 20 THE SAFETY INJECTION PUMP"? 21 A NOT AT THE PRESENT MOMENT I DO NOT HAVE, BUT 22 I DO NOT HAVE ANYTHING PRESENT IN MY MIND TO DISPUTE THAT 23 STATEMENT EITHER. l 24 Q WERE YOU TRYING ALSO IN EXHIBIT 45 -- I'M REFERRING TO THE LANGUAGE IN THE FOLLOWING PARAGRAPH ON I 25 l' 11-147
)
h 1 PAGE 2 -- TO CLARIFY SOME QUESTION THAT HAD ARISEN ABOUT 1 2 YOUR MOTIVE REGARDING MR. KUNDER AND YOUR ATTITUDE TOWARDS 3 HIM7 4 A WELL,' IF MEMORY SERVES ME CORRECTLY, DURING 5 THE CONGRESSIONAL HEARING ON THIS MATTER, THAT SEEMED TO 6 BE -- THAT'S WHAT I INTERPRET AS AN OVERT ATTEMPT ON B.F. l l 7 TO PAINT.ME AS A MAN WITH A GRUDGE AGAINST GEORGE KUNDER, l 8 BUT, IN FACT, I THOUGHT HE WASN'T DOING HIS JOB PROPERLY. l 9 IF ANYTHING, I TESTIFIED TO THAT REGARDING HIS ROLE IN THE 10 ACCIDENT. , 11 Q WELL, I DON'T WANT TO REHASH MATERIAL THAT l 12 YOU HAVE ALREADY COVERED BECAUSE I KNOW YOU'RE ANXIOUS NOT 13 TO. SPEND YOUR TIME THAT WAY. 14 YOU DID TELL MR. RICHARDSON, OF COURSE, THAT l 15 YOU HAD THREATENED TO RIP OFF MR. KUNDER'S FACE AROUND { l l 16 CHRISTMASTIDE IN 19827 l i 17 A YES, I DO RECALL 1ELLING HIM SOMETHING TO l k 18 THAT EFFECT. I ALSO RECALL TELLING HIM THAT I IMMEDIATELY j l 19 APOLOGIZED. AND THE APOLOGY WAS ACCEPTED. 20 Q MR. RICHARDSON DIDN'T ADDRESS THIS WITH YOU, 21 BUT DO YOU REMEMBER EXPRESSING TO JOE CHWASTYK IN LATE '82 22 AND EARLY '83 PHYSICAL THREATS AGAINST GEORGE KUNDER ON l 23 OTHER OCCASIONS? 1 24 A NO, 1 DO NOT. l l 25 Q AND YOUR THREATS ON SEVERAL OCCASIONS TO GO j l 11-148 I 1
1 TO THE PRESS ABOUT GEORGE KUNDER, YOUR TESTIMONY IS THAT 2 THOSE WERE NOT MOTIVATED TO ANY DEGREE BY DISLIKE OF 3 MR. KUNDER; IS THAT YOUR TESTIMONY? 4 A THAT'S CORRECT. 5 MR. JOHNSON: THAT QUESTION PRESUMES EVIDENCE IN ) 6 THE RECORD THAT HE HAD MADE THREATS TO GO TO THE 7 NEWSPAPER. 8 MR. HICKEY: ON MORE THAN ONE OCCASION. ) 9 MR. JOHNSON: CAN YOU ASK HIM THAT QUESTION? 10 MR. HICKEY: I THINK WE COVERED IT IN HIS AFFIDAVIT 11 AND I ASKED HIM ABOUT IT THIS MORNING, ABOUT OTHER . 12 OCCASIONS. 13 THE WITNESS: I GUESS I CAN SUMMARIZE YOUR ENTIRE 14 LINE OF QUESTIONING. I HAD NO PERSONAL- MOTIVE AGAINST f 15 GEORGE KUNDER. 16 Q BY MR. HICKEY: ON THE DAY BEFORE YOU WERE 17 SUSP6NDED, DID YOU MAKE A STATEMENT TO THE EFFECT THAT YOU { 18 THOUGHT IT WAS A SHAME THAT MR. KING HAD BEEN SUSPENDED { l 19 FROM HIS DUTIES AT THAT TIME ON THE ISLAND AND ULTIMATELY. 20 TERMINATED, AND MR. KUNDER WAS STILL THERE WORKING? DO 21 YOU REMEMBER THAT STATEMENT? 22 A WHO WAS I SUPPOSED TO HAVE MADE THE STATEMENT : 23 TO? 24 Q I BELIEVE THE STATEMENT WAS MADE TO l 25 MR. SMITH, BUT LET ME CHECK MY NOTES ON THE MATTER. YOU II-149 j i _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ . . _ _ . _ . _ _ _ _ . _ _ __ _.. .]
1: DON'T REMEMBER MAKING THE STATEMENT TO ANYONE, I TAKE IT? 2 MR. JOHNSON: I'M SORRY, IS THIS SOMETHING THAT 3 THERE'S A REFERENCE TO? 4 MR. HICKEY: BEAR WITH ME A MINUTE AND LET ME ASK , 5 THE WITNESS. 6 Q BY MR. HICKEY: YOU DO NOT HAVE ANY 7 RECOLLECTION WITHOUT ANY FURTHER DESCRIPTION OF MAKING 8 SUCH A STATEMENT? d l 9 A AT THE PRESENT MOMENT, I DO NOT RECALL HAVING 10 MADE SUCH A STATEMENT. , k 11 Q LET ME DIRECT YOUR ATTENTION SPECIFICALLY TO l 12 THE FOLLCWING TIME AND PLACE. DO YOU REMEMBER ON THE DAY 13 BEFORE YOUR AFFIDAVIT WAS RELEASED HAVING A CONVERSATION ; 1 ! 14 WITH MR. ROBERT GUMMO -- YOU DO KNOW MR. GUMMO, DON'T YOU? I 15 A I REMEMBER A BOB GUMMO, RIGHT. l ) I 16 Q -- IN WHICH YOU CRITICIZED GPU-N FOR HAVING ) l 17 TERMINATED MR. KING WHILE KEEPING MR. KUNDER? DO YOU { 18 REMEMBER MAKING SUCH A STATEMENT? l l 19 A NOT OFF THE TOP OF MY HEAD I DON'T. 20 Q I DIDN'T GIVE YOU A SPECIFIC SITUATION, 1 21 DON'T THINK, THIS MORNING WHEN I ASKED YOU ABOUT THE 22 PAXTON HERALD. BUT DID YOU EVER ADVISE MR. BUBBA MARSHALL 23 THAT YOU WERE GOING TO TELL THE PAXTON HERALD THAT 24 GEORGE KUNDER TURNED OFF THE PUMPS DURING THE ACCIDENT? 25 A WELL, I MAY HAVE. AT THE MOMENT I COULDN'T l 11-150
1 TELL YOU DEFINITIVELY IF I DID OR NOT. 2 Q DID YOU MAKE A SIMILAR THREAT ON MORE THAN 3 ONE OCCASION TO JOE SMITH DURING THE LAST QUARTER OF 19827 4 A NOT THAT I CAN RECALL AT THIS MOMENT. 5 Q ARE YOU AWARE, MR. PARKS, THAT MR. ED STIER i 6 INVESTIGATED YOUR ALLEGATIONS ABOUT THE CONVERSATIONS YOU ; 7 REFERRED TO IN YOUR AFFIDAVIT ON PAGE 36 AND 37 REGARDING. 8 THE MYSTERY MAN AND THAT NONE OF THE 13 WITNESSES YOU { 9 REFERRED TO SUPPORT YOUR CLAIM IN THOSE PARAGRAPHS? DID j 10 YOU KNOW THAT? 11 A YES, I KNEW THAT. I SUPPOSE THEN, TOO, SIR, 12 YOU'RE AWARE OF THE LINE OF QUESTIONING THAT I RESPONDED ; 13 TO MR. RICHARDSON DURING MY DEPOSITION FOR MY CIVIL CASE 14 WHERE I STATED TO HIM THAT PRIOR TO ME GOING PUBLIC, MY 15 COUNSEL CONFIRMED IT WITH AT LEAST ONE OF THOSE WITNESSES ! I 16 THAT CONVERSATION TOOK PLACE AS STATED IN MY AFFIDAVIT. {
)
17 Q WHO DID HE CONFIRM IT WITH? l l. 18 A I SUGGEST, SIR, YOU TAKE IT UP WITH MY LAWYER ] 19 AT THE TIME. 20 Q BUT DON'T 10U KNOW7 21 A IF I REMEMBER CORRECTLY, I BELIEVE IT WAS 22 JOHN AUGER, 23 Q AND THIS IS BEFORE YOUR AFFIDAVIT WAS 24 RELEASED? 25 A YES, SIR. 11-151 i
)
1 Q WERE YOU PRESENT WHEN MR. AUGER CONFIRMED 2 THIS CONVERSATION?
'3 A I, AT THIS POINT IN TIME, CAN'T REMEMBER IF I 4 WAS PRESENT OR IF IT WAS RELAYED TO ME BY MY LAWYER.
5 Q YOUR LAWYER, MR. DEVINE? 6 A YES. 7 Q AND THIS WAS BEFORE YOU RELEASED YOUR 8 AFFIDAVIT? 9 A YES, SIR. 10 Q DID MR. DEVINE ATTEMPT.TO CONFIRM YOUR 11 STATEMENTS WITH ANY OF THE OTHER 13 WITNESSES THAT ARE ON-j -12 PAGE 36 AND 377 13 A I REALLY COULDN'T TELL YOU AT THIS MOMENT, j 14 SIR. 15 Q DID YOU MAKE ANY EFFORT, BEFORE RELEASING 16 YOUR AFFIDAVIT, TO CHECK WITH ANY OF THESE 13 PEOPLE ABOUT , I I 17 THE ACCURACY OF YOUR STATEMENTS CONCERNING THEM? 1 18 A NOT THAT I CAN RECALL- AT THE MOMENT. 19 Q IF YOU DIDN'T CHECK, WOULD YOU SAY THAT WAS A 20 LITTLE CARELESS, MR. PARKS 7 21 A NO, SIR, I WOULD NOT. , l 22 Q YOU DID VIEW IT AS A SERIOUS CHARGE YOU WERE i 23 MAKING AGAINST MR. KUNDER, DIDN'T YOU? , 24 A YES, I DID. 25 Q DID YOU ANTICIPATE, MR. PARKS -- YOU MUST i 11-152 l
\
s l' I HAVE -- THAT IT WOULD HOLD MR. KUNDER UP TO SOME I l 2 SUBSTANTIAL SCORN IN THE PUBLIC EYE IF HE WAS, IN FACT, ; l 3 THE PERSON WHO HAD SHUT OFF THE PUMPS AND CAUSED MOST OF 4 THE DAMAGE IN THE ACCIDENT? I , 5 A NO, SIR, I DID NOT FEEL MR. KUNDER WOULD BE l 6 HELD UP TO PUBLIC SCORN. I FELT POSSIBLY GPU'S ACTIONS 7 HAD NOT BEEN FORTHWIlH (SIC) AND STRAIGHTFORWARD TO THE 8 NRC AND MIGHT BE HELD UP TO PUBLIC SCORN. l 9 Q YOU DIDN'T THINK MR. KUNDER WOULD LIKE YOUR 10 STATEMENTS ABOUT HIM, DID YOU? l 11 A IF HE WAS GUILTY OF IT, PROBABLY NOT. 12 Q AND WHAT IF HE WAS INNOCENT? j 13 A THEN HE FELT THE NRC WOULD EXONERATE HIM. 14 Q WHAT ABOUT IN THE MEANTIME?
- 15 A WELL, YOU KNOW, IT'S LIKE THIS. I FELT THAT l 16 THE WHOLE THING THAT HAD GONE ON, I WAS INNOCENT OF, AS 17 LARRY KING WAS INNOCENT OF; AND YET GPU NOT ONLY TOOK AN i
18 ACTIVE ROLE IN HARASSING AND RETALIATING AGAINST US, WHICH 19 HELPED, IN MY SENSE ANYWAY, TO CONFIRM THAT GPU WAS 20 SYSTEMATICALLY TRYING TO RETALIATE AGAINST US. I WAS MORE l 21 CONCERNED WITH GETTING GPU LOOKED INTO THEIR ACTIVITIES AT 22 THAT TIME THAN I WAS TRYING TO LAY ANY ALLEGEDLY FALSE 23 CLAIM AGAINST GEORGE KUNDER. 24 Q BECAUSE YOU WERE TRYING TO GET BACK AT GPU 25 FOR RETALIATION?? 11-153 L_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _
l I 1 A. YOU'RE MISCHARACTERIZING MV -- l 2 Q LET ME. YOUR TESTIMONY IS THAT BECAUSE OF 3 YOUR VIEWS ABOUT WHAT GPU-N WAS DOING TO YOU, YOU DIDN'T 4 REALLY CARE WHAT THE IMPACT WAS ON GEORGE KUNDER; ISN'T j 5- THAT RIGHT? 6 A I THINK THAT'S A MISCHARACTERIZATION, SIR. 7 Q WELL, YOU TELL ME. 8 A I THINK I MADE MY OPINION AND MY VIEWS VERY i 9 CLEAR. 10 Q IS IT ACCURATE TO STATE, MR. PARKS, THAT YOUR 11 VIEW IS THAT BECAUSE YOU WERE BEING RETALIATED AGAINST, 12 STRONG MEASURES WERE WARRANTED, INCLUDING POSSIBLE STEPS 13 THAT MIGHT CAUSE MR. KUNDER SOME PAIN OR SHAME? 14 A NO, SIR. GEORG'i KUNDER NEVER INTERFERED OR 15 NEVER -- I SHOULD SAY NEVER WAS A CONSIDERATION. I WAS 16 NOT OUT TO HURT GEORGE OR BRING UNDUE SCRUTINY ON GEORGE. 17 I WANTED THE NRC TO INVESTIGATE GPU-N'S ROLE IN IT, AND 1 i 18 BELIEVE THE INFORMATION THAT I RELEASED IN MY AFFIDAVIT TO . 19 BE TRUE AND ACCURATE TO THE BEST OF MY BELIEF. I HAVE NO 20 REASON TO DOUBT IT. 21 Q WELL, YOU SUGGESTED OR STATED PRETTY 22 STRONGLY, DIDN'T YOU, THAT MR. KUNDER WAS NOT DOING HIS 23 JOB AS CHAIRMAN OF THE PLANT OPERATION REVIEW COMMITTEE? 3 24 A I WAS OF THAT OPINION, THEN AND NOW. i l 25 Q AND YOU BASE THAT CPINION ON THE FACT THAT HE i l 11-154 l l l _ _ _ _ _ _ _ _ . - - _ _ _ _ _ _ - _ __ _ _ _ _ - __ A
1 ONLY.DID CURSORY AND BIASED REVIEWS OF REACTOR OPERATIONS i 2 AND REACTOR PROGRAM MANAGEMENT PROPOSALS; IS THAT RIGHT? l 3 A I THINK A MORE ACCURATE REFLECTION ON THAT, 4 SIR, WOULD BE THAT IF HE HAD BEEN DOING HIS JOB, I WOULD 5 NOT HAVE ULTIMATELY HAD TO GO PUBLIC TO GET THE SITUATIONS 6 CORRECTED THAT WERE GOING ON ON THE JOB SITE. 7 Q WELL, PART OF THE PURPOSE OF THIS PROCEEDING 8 IS TO EXPLORE WHAT YOUR MOTIVATIONS WERE IN GOING PUBLIC, 9 LET ME ASK YOU TO ANSWER MY QUESTION. 10 A THAT WAS AN ANSWER TO YOUR QUESTION. 11 Q WELL, YOU HAVE SAID IT IN YOUR AFFIDAVIT, 12 MR. PARKS, THAT YOU THOUGHT KUNDER WAS MAKING ONLY BIASED 13 AND CURSORY REVIEWS OF THE REACTOR OPERATIONS AND REACTOR 14 PROGRAM MANAGEMENT PROPOSAUS? 15 A THAT'S CORRECT. I BELIEVE THAT. 16 Q YOU ALSO FELT, DIDN'T YOU, THAT HE WAS.BEING 17 UNDULY CAUTIOUS IN GIVING SCRUTINY TO THE SITE OPERATIONS 18 PROPOSAL, DIDN'T YOU?
.i 19 A 1 THINK THE INTENT THERE WOULD BE BEST 20 CHARACTER! ZED AS THE FACT THAT THE MAN APPARENTLY HAD A
]
21 DOUBLE STANDARD. IF BECHTEL, IN THE RECOVERY GROUP, 22 WANTED SOMETHING DONE, THEN HE DID NOT FORCE THEM TO ; 23 COMPLY WITH THE REQUIREMENTS. IF THE OPERATORS WANTED TO 24 DO SOMETHING, WE WERE FORCED TO ADHERE TO THE LICENSE ] l 25 REQUIREMENTS. THAT WAS IT. 1 4 I1-155 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ J
o I L a 1I l 1 ,Q "THE OPERATOR,"~ MEANING THE SITE OPERATIONS
.)
2- DEPARTMENT? ) r3-. A CORRECT.- i l 4' Q YOU ADDRESS SOME' DETAILS ABOUT THATEVIEW-YOU' l u
'l 15' DUST-EXPRESSED' IN EXHIBIT 45 AT THE BOTTOM OF PAGE 3. j
'6' LOOKLAT THAT PARAGRAPH AND SEE IF THAT APPEARS'TO YOU.TO .4
-7 BE ACCURATE AND REFLECTS WHAT.YOU JUST'SAID. IT'S THE
- 8 PARAGRAPH THAT'BEGINS, QUOTE, "TO ILLUSTRATE, MR.'KUNDER q l
9 DID NOT' APPEAR OBJECTIVE."
)
1 10' A I BELIEVE THAT ALLUDES TO MY7 STATEMENT 11N A
-i 11 . CURSORY FASHION, YES,-SPECIFICALLY THE STATEMENT THAT- l l
12 READS, "I FELT KUNDER'S QUICK APPROVALS OF INADEQUATE. l
)
13 HEADLIFT PROCEDURES.COULD LEAD TO SAFETY HAZARDS." ! l 14' AND I.WOULD LIKE TO REMIND COUNSEL THAT UPON ! 15 INTENSE REVIEW BY THE NRC TECHNICAL STAFF, THEY DID l l 16 CONFIRM THAT THE PROCEDURES GEORGE KUNDER WAS APPROVING l i 17 WERE NOT APPROPR'ATFLY REVIEWED AND/OR CONSTRUCTED IN l 1 18 COMPLIANCE WITH THE ADMINISTRATIVE REQUIREMENTS. 19 Q WHAT PROCEDURES ARE YOU TALKING ABOUT? j 20 A THE ONES WHEREBY VARIOUS MODIFICATIONS WERE 21 MADE TO THE POLAR CRANE THAT REQUIRED AN ECM. l 22 Q YOU'RE SAYING --
.l 23 MR. JOHNSON: WHAT WERE THE LAST TWO WORDS?
L 24 THE WITNESS: "THAT REQUIRED AN ECM."
- 25 Q BY MR. HICKEY: YOU'RE REFERRING TO THE ,
I 11-156 l ll
1 Q "THE OPERATOR," MEANING THE SITE OPERATIONS l l 2 DEPARTMENT? l 3 A CORRECT. 4 Q YOU ADDRESS SOME DETAILS ABOUT THAT VIEW YOU 5 JUST EXPRESSED IN EXHIBIT 45 AT THE BOTTOM OF PAGE 3. 6 LOOK AT THAT PARAGRAPH AND SEE IF THAT APPEARS TO YOU TO 7 BE ACCURATE AND REFLECTS WHAT YOU JUST SAID. IT'S THE 8 PARAGRAPH THAT BEGINS, QUOTE, "TO ILLUSTRATE, MR. KUNDER 9 DID NOT APPEAR OBJECTIVE." 10 A 1 BELIEVE THAT ALLUDES.TO MY STATEMENT IN A 11 CURSORY FASHION, YES, SPECIFICALLY THE STATEMENT THAT 12 READS, "I FELT KUNDER'S QUICK APPROVALS OF INADEQUATE 13 HEADLIFT PROCEDURES COULD LEAD TO SAFETY HAZARDS." I 14 AND I WOULD LIKE TO REMIND COUNSEL THAT UPON 15 INTENSE REVIEW BY THE NRC TECHNICAL STAFF, THEY DID 16 CONFIRM THAT THE PROCEDURES GEORGE KUNDER WAS APPROVING 17 WERE NOT APPROPRIATELY REVIEWED AND/OR CONSTRUCTED IN 18 COMPLIANCE WITH THE ADMINISTRATIVE REQUIREMENTS. 19 Q WHAT PROCEDURES ARE YOU TALKING ABOUT? 20 A THE ONES WHEREBY VARIOUS MODIFICATIONS WERE , 21 MADE TO THE POLAR CRANE THAT REQUIRED AN ECM. 22 Q YOU'RE SAYING -- 23 MR. JOHNSON: WHAT WERE THE LAST TWO WORDS? 24 THE WITNESS: "THAT REQUIRED AN ECM." 25 Q BY MR. HICKEY: YOU'RE REFERRING TO THE 11-156 l
l
' 11 PROCEDURES THAT FOUND MR. KUNDER IMPROPERLY APPROVED SOME 2' MODIFICATION'THAT;SHOULD HAVE BEEN DONE BY~AN ECM?'
3 A IF MEMORY SERVES ME CORRECTLY'AT'THIS MOMENT,
'4 BUT..! MAY. BE~ WRONG ON THAT, IT SEEMS TO ME THAT THERE WERE 1 5 CERTAIN PROCEDURESLTHAT.HAD BEEN APPROVED BY GEORGE KUNDER 6 THAT WERE, IN FACT, IMPROPERLY STRUCTURED OR DID NOT i
7 COMPLY.WITH THE ADMINISTRATIVE PROCEDURES. l I'M NOT 8 Q YOU'RE. TALKING ABOUT PROCEDURES -- ! 9 SURE WHAT YOU'RE REFERRING TO BECAUSE YOU ALSO TALKED 10 ABOUT MODIFICATIONS. 11- A RIGHT. THE WORK PACKAGE WAS
A. PROCEDURE
12 Q YOU'RE TALKING THOUGH ABOUT WORK PACKAGES 0N
' 13 ' .THE POLAR CRANE?
14 A I AM REALLY, YOU KNOW, TRYING.TO REMEMBER 15 EXACTLY WHICH' PROCEDURES THEY WERE; AND IT'S FOUR. YEARS 16 SINCE I REVIEWED THE REPORT. 17 Q BUT YOU JUST MADE A STATEMENT, MR. PARKS, 18 THAT YOUR VIEW OF MR. KUNDER WAS CORROBORATED BY THE FACT 19 THAT THE NRC FOUND VIOLATIONS IN SOME PROCEDURES THAT 20 MR. KUNDER HAD APPROVED. WHAT'RE THE PROCEDURES THAT 21 YOU'RE TALKING ABOUT? 22 A I DON'T REMEMBER SPECIFICALLY OR WITH CERTAIN 23 ACCURACY, BUT THEY'RE CONTAINED WITHIN THE REPORT. I 24 Q WHAT REPORT? 25 A JULY -- SEPTEMBER IST REPORT, I BELIEVE, 11-157
1 REGARDING THE TECHNICAL ISSUES. 2 Q THESE ARE WORK PAGES ON THE POLAR CRANE THAT l 3 MR. KUNDER APPROVED PROBABLY; THAT'S THE BEST YOU CAN l 4 DESCRIBE IT? 5 A THAT'S THE BEST -- I'LL JUST SAY PROCEDURES. 6 1 DON'T REMEMBER EXACTLY WHICH ONES THEY ARE. 7 Q WELL, SEE, IT'S A LITTLE HARD TO EVALUATE 8 WHEN YOU'RE STATING YOUR BELIEF ACCURATELY IF YOU WON'T 9 IDENTIFY. 10 A IT'S NOT I DON'T -- I WANT TO IDENTIFY, SIR. 11 1 CANNOT RECALL WITH CERTAINTY; AND THEREFORE, l'M 12 RELUCTANT TO STATE SOMETHING THAT MAY NOT BE, IN FACT, 13 ABSOLUTELY TRUE. 14 Q YOU DIDN'T SEEM RELUCTANT TO STATE 15 CONCLUSIONS ABOUT IT, MR. PARKS. 16 A I SEEM TO RECALL REVIEWING IT AT THE TIME. 17 MR. JOHNSON: YOU'RE ARGUING WITH THE WITNESS. IF 18 YOU HAVE A QUESTION, ASK HIM A QUESTION. 19 THE WITNESS: I WILL REFER YOU THOUGH TO, SIR, THE 20 SITE OPERATIONS PROBLEM REPORT THAT I SUBMITTED PRIOR TO 21 MY DISMISSAL FROM TMI REGARDING PROCEDURES THAT WERE 22 ' APPROVED BY GEORGE KUNDER THAT WERE IN VIOLATION OF THE 23 ADMINISTRATIVE PROCEDURES. THEY ARE REFERENCED IN MY l 24 ORIGINAL AFFIDAVIT. 25 Q BY MR. HICKEY: 1 TAKE IT FROM ALL YOUR 11-158
.i 1 COMMENTS, MR. PARKS, THAT IN YOUR.0WN MIND YOU FIND NO 2 FAULT WITH YOUR INCLUDING THE ALLEGATIONS ABOUT MR. KUNDER 4 1
3 BEING THE MYSTERY MAN IN YOUR AFFIDAVIT.0F MARCH 21, THOSE
.4 STATEMENTS THAT WE'VE JUST BEEN TALKING ABOUT, THOSE 5 STATEMENTS ON PAGE 36 AND 377 6 A COULD YOU REPEAT THE QUESTION?
7 Q l'M UNDERSTANDING FROM YOUR COMMENTS THAT IN 8 YOUR OWN MIND YOU FIND NO FAULT WITH YOURSELF FOR 9 INCLUDING IN THE AFFIDAVIT OF MARCH 21 THAT YOU FILED THE { i 10 STATEMENTS ABOUT MR. KUNDER ON PAGES 36 AND 37? j 11 A THAT'S ABSOLUTELY CORRECT. 12 Q YOU CAN'T REMEMBER ALL THE BASES FOR IT, BUT i l l 13 TO THE EXTENT YOU CAN REMEMBER, YOU BELIEVE YOU WERE l l l 14 JUSTIFIED? l 15 A I BELIEVE THAT THE INFORMATION I HAVE 16 AVAILABLE TO ME AT THAT TIME LEFT ME WITH AN OPINION THAT 17 I FELT WAS ACCURATE AND FAIR AND TO THE BEST OF MY 18 KNOWLEDGE TO BE TRUE. 19 MR. HICKEY: WOULD YOU MARK THIS, PLEASE. I 20 (WHEREUPON RESPONDENT'S EXHIBIT 47 WAS MARKED l l 21 FOR IDENTIFICATION BY THE NOTARY PUBLIC, AND A COPY IS I 22 ATTACHED HERETO.) 23 Q BY MR. HICKEY: MR. PARKS, I'M SHOWING YOU ) i 24 EXHIBIT 47. I HAVE ONLY COPIED A PORTION OF IT BECAUSE I 25 IT'S A LENGTHY DOCUMENT, BUT I COPIED THE TITLE PAGE SO i 11-159 l l c -_ -_ __- -_ _ _ a
1 YOU COULD SEE THAT IT IS A DOCUMENT FILED IN THE CIVIL f 1 2 ACTION IN WHICH YOU WERE PREVIOUSLY INVOLVED, PARKS VERSUS j 3 BECHTEL POWER CORPORATION, NUMBER 831 846, AND THIS IS THE 1 4 PLAINTIFF'S RESPONSE TO REQUEST FOR PRODUCTION OF 5 DOCUMENTS. ' 6 AND IN THE MATERIAL THAT'S COPIED WHICH, 1 7 THINK, BEGINS WITH PAGE 19 -- DO YOU SEE IT THERE -- OR 8 20 -- 9 A OKAY. 10 Q -- THERE IS A LIST OF PRIVILEGED DOCUMENTS 11 WHICH YOU AND YOUR ATTORNEYS IN THE CIVIL CASE IDENTIFIED 12 AS BEING IN YOUR POSSESSION, CUSTODY OR CONTROL, BUT WHICH 13 WERE NOT BEING PRODUCED BECAUSE OF A CLAIM OF PRIVILEGE. I 14 YOU'RE FAMILIAR WITH THIS DOCUMENT IN GENERAL TERMS. AND 15 I REALIZE YOU'RE NOT A LAWYER, BUT HAVE YOU SEEN IT 16 BEFORE7
)
l 17 A I DON'T THINK 1 HAVE. I MAY HAVE. I DON'T l 18 KNOW. I'D HAVE TO REVIEW THE WHOLE THING. ; 19 Q WELL, 1 JUST WANT TO DIRECT YOU TO A COUPLE 20 SPECIFIC PARTS OF IT AND SEE IF YOU HAVE ANY RECOLLECTION. 21 ON PAGE 22 YOU'LL SEE THAT THERE ARE 22 REFERENCES TO SOME DOCUMENTS, DOCUMENT I, THAT'S AT LINE 23 17, WHICH IS MR. DEVINE'S " DRAFT OF ALLEGATIONS FOR PARKS' 24 AFFIDAVIT REFLECTING DEVINE'S CONVERSATIONS WITH RICK 25 PARKS, NO DATE, EIGHT PAGES, NO COPIES SENT, RE: GEORGE 11-160 i
i 1 YOU COULD SEE'TMAT IT IS A DOCUMENT FILED IN THE CIVIL { l 2 ACTION IN WHICH YOU WERE PREVIOUSLY INVOLVED, PARKS VERSUS 3 BECHTEL POWER CORPORATION, NUMBER 831 846, AND THIS IS THE 4 PLAINTIFF'S RESPONSE TO REQUEST FOR PRODUCTION OF 5 DOCUMENTS. 6 AND IN THE MATERIAL THAT'S COPIED WHICH, 1 4 7 THINK, BEGINS WITH PAGE 19 -- DO YOU SEE IT THERE -- OR , 8 20 -- { 1 9 A OKAY. 10 Q -- THERE IS A LIST OF PRIVILEGED DOCUMENTS k 11 WHICH YOU AND YOUR ATTORNEYS IN THE CIVIL CASE IDENTIFIED , 12 AS BEING IN YOUR POSSESSION, CUSTODY OR CONTROL, BUT WHICH 13 WERE NOT BEING PRODUCED BECAUSE OF A CLAIM OF PRIVILEGE.- 14 YOU'RE FAMILIAR WITH THIS DOCUMENT IN GENERAL TERMS. AND 15 i REALIZE YOU'RE NOT A LAWYER, BUT HAVE YOU SEEN IT i 16 BEFORE? ' 17 A I DON'T THINK I HAVE. I MAY HAVE. I DON'T l l 18 KNOW. l'D HAVE TO REVIEW THE WHOLE THING. 19 Q WELL, I JUST WANT TO DIRECT YOU TO A COUPLE 20 SPECIFIC PARTS OF IT AND SEE IF YOU HAVE ANY RECOLLECTION. 21 ON PAGE 22 YOU'LL SEE THAT THERE ARE 22 REFERENCES TO SOME DOCUMENTS, DOCUMENT I, THAT'S AT LINE 23 17, WHICH IS MR. DEVINE'S " DRAFT OF ALLEGATIONS FOR PARKS' ! 24 AFFIDAVIT REFLECTING DEVINE'S CONVERSATIONS WITH RICK l l 25 PARKS, NO DATE, EIGHT PAGES, NO COPIES SENT, RE: GEORGE l 11-160 l
- _ _ - _ - - _ - _ - - - - - - - - - - - - - - - - - - - - - - - 1
1 'KUNDERDAND TMI PUMP' SHUTDOWN."
-2' DO YOU RECALL =EVER SEEING'THAT DOCUMENT, 6
3' MR. PARKS? 4- A NO, I DO NOT.
~5' Q DOES IT SOUND --
6 A' I THINK IT STATES RIGHT THERE IT'S TOM ~ 7 DEVINE'S DRAFT OF ALLEGATIONS. 8 Q. RIGHT. 9 REFLECTING HIS CONVERSATION WITH YOU? 10 A RIGHT. 11 Q l ASSUME YOU HAD A NUMBER OF CONVERSATIONS 12 WITH MR. DEVINE IN THE COURSE OF DRAFTING YOUR AFFIDAVIT? 13 A l'VE.HAD A NUMBER OF CONVERSATIONS'WITH.
-14 TOM DEVINE OVER THE YEARS, YES. l
- 15. Q 'WELL, THIS IS PRIOR TO YOUR AFFIDAVIT COMING l 16 OUT.
17 A I DON'T SEE ANYWHERE IT SAYS THAT.
-18 Q WELL, I'M ASKING YOU WHETHER YOU DIDN'T HAVE 19 A NUMBER OF CONVERSATIONS WITH DEVINE PRIOR TO YOUR j 20 AFFIDAVIT COMING OUT.
'21 MR. JOHNSON: YOU'RE TALKING ABOUT THE 56-PAGE i 22 AFFIDAVIT? '
23 'MR. HICKEY: YES. 24 THE WITNESS: NO. I HAD ONE CONTINUOUS 25 CONVERSATION WITH TOM DEVINE AFTER I DECIDED TO RETAIN HIM 11-161 l I
l 1 AS AN ATTORNEY. 2 Q BY MR. HICKEY: WHEN WAS THAT? I 3 A I MADE THE DECISION, I BELIEVE, OH, 1 DON'T l l 4 KNOW, PROBABLY AROUND THE 15TH OF MARCH OR 50. I BELIEVE 5 WE HAD THAT ONE CONVERSATION AND DISCUSSED VARIOUS THINGS 6 AND THEN AFTER THAT WE HAD A " CONTINUOUS" CONVERSATION FOR 7 A PERIOD OF SEVERAL DAYS, 8 Q WHEN YOU SAY CONTINUOUS, DO YOU MEAN 9 LITERALLY NONSTOP? 10 A YES, SIR. 11 Q HOW LONG DID IT LAST? 12 MR. JOHNSON: YOU DON'T REALLY HAVE TO GO INTO ANY 13 SUBSTANTIVE DETAILS, IF YOU DECLINE TO DO SO, IN REGARD TO 14 YOUR ATTORNEY CONTACTS. I THINK HE'S RIGHT ON THE EDGE 15 HERE, 50 1 JUST CAUTION YOU. 16 Q BY MR. HICKEY: HOW LONG DID THE CON 1"NUOUS 17 CONVERSATION LAST? 18 A IF I UNDERSTAND MR. JOHNSON'S STATEMENT 19 CORRECTLY, 1 DO NOT HAVE TO DIVULGE ANY ATTORNEY-CLIENT 20 DISCUSSION. 21 Q l'M NOT ASKING WHAT YOU TOLD HIM. l'M ASKING, 22 WHAT YOU MEAN WHEN YOU HAD A CONTINUOUS CONVERSATION. HOW 23 LONG WAS THE CONVERSATION? 24 A I DON'T RECALL, NOT AT THE MOMENT. LONG TIME 25 THOUGH. 11-162
2 1 Q MORE THAN A DAY? MORE THAN 24 HOURS? 2 A I DON'T RECALL AT THE MOMENT, SIR. 3 Q YOU SEE DOCUMENT J ON PAGE 22. IT'S A 4 MEMORANDUM BY YOU TO GAP ATTORNEYS, "RE: PARKS' ANALYSIS 5 0F TESTIMONY OF GPU BECHTEL EMPLOYEES, DATED MARCH 31, 6 1983, 17 PAGES." IS THAT A MEMORANDUM IN WHICH YOU , 1 7' DISCUSSED THE TRANSCRIPT FROM THE BEW TRIAL THAT YOU TOLD ! 8 US EARLIER TODAY YOU HAD REVIEWED? i 9 A NO, SIR. THAT'S NOT WHAT I RECALL AT ALL. 10 Q WHAT TESTIMONY 15 IT THAT YOU WERE ; 11 DISCUSSING? i 12 A I BELIEVE AT ONE POINT IN TIME -- 13 MR. JOHNSON: THIS IS, AGAIN -- IF THIS INVOLVES A l l 14 COMMUNICATION BETWEEN YOU AND YOUR ATTORNEYS, THIS IS -- 15 YOU CAN CLAIM CONFIDENTIALITY IN THE ATTORNEY-CLIENT 16 PRIVILEGE. 17 MR. HICKEY: 1 ASSUME THAT MR. PARKS HAS BEEN 18 ADVISED BY HIS COUNSEL ABOUT WHAT HIS RIGHTS ARE WITH 19 REGARD TO ATTORNEY-CLIENT PRIVILEGE. IF HE HASN'T, HE'S 20 BEEN TOLD BY HIS ATTORNEY. HE TOLD US YESTERDAY THAT SHE 21 WAS AVAILABLE ON A TELEPHONE CALL. SO MY QUESTION IS 22 WHETHER IT'S NECESSARY FOR YOU TO CONTINUALLY INFORM THE 23 WITNESS ABOUT HIS RIGHTS NOT TO ANSWER THE QUESTION OR 24 THAT HE'S ON THE VERGE OF SOMETHING. 25 THE WITNESS: 1 THINK YOU'RE ABSOLUTELY RIGHT, SIR. 11-163
1 'AND I THINK I SHOULD ADJOURN THIS AND -- 2 Q BY MR. HICKEY: WELL, MR. PARKS, AND I DON'T 3 HAVE ANY LEGAL POWER TO MAKE YOU STAY. I THINK I WOULD 4 ASSUME THAT YOU WOULD WANT TO STAY AND GET THIS OVER WITH. 5 A AND 1 WOULD ASSUME, SIR, YOU SHOULD NOT 6 OBJECT WHEN ANOTHER LAWYER REMINDS ME OF MY RIGHTS WHEN MY 7 LEGAL REPRESENTATION IS NOT AVAILABLE. 8 Q MR. PARKS, l'D BE HAPPY IF MR. JOHNSON MAKES 9 THAT STATEMENT AT EVERY QUESTION I ASK YOU. ALL RIGHT? 10 DOES THAT HELP? 11 A THAT'S FINE. 12 Q NOW TELL ME, DO YOU KNOW WHAT THE TRANSCRIPT 13 OF TESTIMONY WAS, IF IT WASN'T TESTIMONY IN THE B&W 14 LITIGATION THAT'S THIS DOCUMENT J? 15 A I BELIEVE THAT WOULD BE ATTORNEY-CLIENT 16 PRIVILEGE. 17 Q WELL, DIDN'T YOU READ THE TRANSCRIPT? 18 A I THINK I TESTIFIED EARLIER TODAY, AT ONE 19 POINT IN TIME, I READ EXCERPTS FROM IT. 20 Q FROM A BSW TRANSCRIPT? 21 A RIGHT. 22 Q BUT YOU'RE SAYING THERE IS SOME OTHER 23 TRANSCRIPT? I 24 A l'M TELLING YOU THERE IS NOT. 25 Q DOESN'T IT SAY ON THE TRANSCRIPT WHAT IT'S A I 11-164 ' i
l 1 TRANSCRIPT OF? 2 A WHERE?. L I 3 Q ! DIDN'T'SEE THE TRANSCRIPT. YOU'RE THE ONE , .4 WHO ANALYZED THE TRANSCRIPT. WHAT DOES THE TRANSCRIPT SAY L l 5 ABOUT WHAT IT'S TESTIMONY OF? 6' A I DON'T SEE THAT IT SAYS IT'S'A TRANSCRIPT. 7 Q SAYS " ANALYSIS OF TESTIMONY." WHAT IS1THE 8 TESTIMONY FROM7 9 A AGAIN, SIR, I'LL HAVE TO CLAIM 10 ATTORNEY-CLIENT PRIVILEGE.
'll Q HOW ABOUT K? ARE YOU FAMILIAR WITH THAT 12 DOCUMENT, "A HANDWRITTEN DRAFT BY MR. DEVINE RE:
13 ALLEGATIONS FOR PARKS' AFFIDAVIT REFLECTING CONVERSATION l 14 WITH RICK PARKS, FOUR PAGES, NO DATE, RE: PUMPS SHUTDOWN 15 AT TMI, NO COPIES ISSUED." 16 A AGAIN, SIR, I IMAGINE THAT WOULD FALL UNDER , 17 THE ATTORNEY-CLIENT PRIVILEGE. 18 Q HAVE YOU SEEN THESE DOCUMENTS THAT ARE 19 IDENTIFIED AS I, J, AND K? LET ME BREAK IT UP. HOW 20 ABOUT -- 1 AND K ARE MR. DEVINE'S DRAFTS. HAVE YOU EVER
.21 SEEN DuCUMENT I AND DOCUMENT K7 ;
22 A AT THE MOMENT I HAVE NO RECALL WHETHER 1 HAVE ' 23 OR NOT. 24 Q DO YOU THINK IT MIGHT REFRESH YOUR 25 RECOLLECTION ABOUT WHAT YOU KNEW AT THE TIME YOU FILED 11-165 4 i
)
1 YOUR AFFIDAVIT.REGARDING MR. KUNDER AND PUMP SHUTDOWN IF
.2 YOU REVIEWED NOTES OF WHAT YOU TOLD MR. DEVINE?
.3 A I SERIOUSLY DOUBT IT.
4- Q WHY? 5 A BECAUSE l'M NOT FULLY INTERESTED IN READING 6 IT. I GUESS, YOU KNOW, WHAT l'M REALLY TRYING TO SAY, i 7 SIR, IS I DON'T KNOW WHETHER THOSE DOCUMENTS EVEN REALLY 8 EXISTED UNTIL I READ THIS. 9 Q WELL, IF THIS STATEMENT BY'YOUR ATTORNEY IS 10 ACCURATE, THEY DO EXIST. 11 A APPARENTLY IT'S ACCURATE. I DON'T THINK THE 12 HOBERG LAW FIRM WOULD MAKE AN INACCURATE STATEMENT. 13 Q I DON'T EITHER IN THIS DOCUMENT. 14 i BELIEVE THE QUESTION 15 WHETHER IT WOULD 15 REFRESH YOUR RECOLLECTION. YOU HAVE ANSWERED THAT ONE, SO 16 l'M MOVING ON TO THE NEXT QUESTION, WHICH IS DOCUMENT M. 17 A I GUESS THAT WAS PROBABLY A FLIPPANT REMARK 18 ON MY PART. IT MIGHT, BUT I DON'T KNOW AT THIS TIME l 19 WITHOUT HAVING REVIEWED THE DOCUMENT, IF IT WOULD REFRESH 20 ANYTHING AT ALL. I SEEMED TO HAVE A FAIRLY REASONABLE 21 REPRESENTATION OF ANYTHING 1 HAD TO SAY REGARDING THOSE 22 INCIDENTS PRESENTED TO ME BY YOU TODAY. 23 MR. JOHNSON: CAN WE TAKE A VERY SHORT BREAK. l'D 24 LIKE TO CONSULT WITH MR. PARKS. LET'S GO OUTSIDE. 25 (WITNESS AND COUNSEL CONFERRING.) 11-166 i ____-_____-_________m.-.___mm_.m___ _____m_ _ _ _ _ . _ _ . _ _ _ _ _ _ . _
~1 -(RECESS.)
I 2 Q BY MR. HICKE 1 CAN ASK YOU, MR. PARKS, I' 3 PLEASE TO LOOK JUST AT e, tW MORE OF THE ITEMS IN i l 4 EXHIBIT 47 WHICH IS STILL 1ERE 'IN FRONT OF YOU. THE LAST i 5 ONE WE WERE TALKING ABOUT IS ON PAGE 22 AND IT WAS 6 DOCUMENT d. DO YOU KNOW WHETHER THAT MEMORANDUM THAT YOU 7 PREPARED WAS TRANSMITTED TO ANYONE OTHER THAN MR. DEVINE 8 AND -- 9 MR. JOHNSON: TO THE EXTENT THIS MAY DIVULGE A 10 CONFIDENTIAL COMMUNICATION, I THINK IT'S CLEARLY 11 DESIGNATED HERE AS BEING SUBJECT TO PRIVILEGE, AND AS'A 12 RESULT, IF THE ANSWER WOULD REQUIRE HIM TO DIVULGE ANY OF 13 THE SUBSTANCE OF THAT COMMUNICATION, I WOULD CAUTION HIM 14 ABOUT YOUR ATTORNEY-CLIENT PRIVILEGE. 15 Q BY MR. HICKEY: YOU UNDERSTAND MY QUESTION, 16 MR. PARKS. I'M ASKING YOU WHETHER YOU KNOW IF ANYBODY i
- 17. SENT THAT OUT TO ANYONE OTHER THAN YOUR ATTORNEYS?
18 A AGAIN, SIR, THAT IS PRIVILEGED INFORMATION, 19 AND I WILL NOT ANSWER ANY QUESTIONS REGARDING PRIVILEGED 20 INFORMATION. 21 Q I'M NOT ASKING YOU WHAT'S IN THE MEMORANDUM; 22 l'M ASKING YOU WHETHER YOU'RE AWARE OF ANYONE SENDING IT 23 TO ANYONE OTHER THAN AN ATTORNEY? 24 A APPARENTLY, IF 1 UNDERSTAND EXACTLY, THIS -- 25 AS THIS IS STATED HERE, IT'S MY MEMO -- YOU SAID d OR K? l 11-167 (
1 Q J. 2 A MY MEMO TO GAP ATTORNEYS. 3 Q RIGHT. 4 A I SENT'IT TO GAP. r 5 Q DID YOU SEND TO IT ANYONE ELSE WHO WASN'T AN 6 ATTORNEY? 7 A NOT THAT I KNOW OF. 8 Q DO YOU KNOW WHETHER IT WAS PROVIDED TO 9 MR. MEYERS, DR. MEYERS OF THE HOUSE INTERIOR COMMITTEE 10 STAFF? 11 MR. JOHNSON: OBJECTION. HE'S BEEN ASKED WHETHER 12 HE WAS AWARE OF IT BEING SENT TO ANYONE ELSE, AND HE SAID 13 HE'S NOT AWARE OF IT BEING SENT TO ANYBODY ELSE; AND THAT 14 WOULD INCLUDE HENRY MEYERS. 15 MR. HICKEY: 1 THINK HE DIDN'T REMEMBER, AND 1 WAS 16 ASKING HIM SPECIFICALLY TO SEE IF HE REMEMBERED THAT. 17 THE WITNESS: I SAID NOT THAT I WAS AWARE OF, 18 Q BY MR. HICKEY: l'M ASKING YOU SPECIFICALLY, 19 DID YOU SEND IT TO DR. MEYERS? 20 'A IF 1 WAS AWARE OF SENDING IT TO DR. MEYERS, I 21 WOULD HAVE STATED SO TO BEGIN WITH. l 22 Q WOULD YOU LOOK PLEASE AT EXHIBIT M -- 23 DOCUMENT M ON PAGE 23 OF THIS EXHIBIT. 24 A OKAY. 25 Q HAVE YOU SEEN THOSE NOTES IN THE RECENT PAST, 11-168 i
1- IN THE LAST VEAR? 2 A AT THE MOMENT I CANNOT RECALL IF 1 HAVE OR 3 NOT.
'4 Q DO YOU KNOW WHETHER THOSE NOTES WERE PROVIDED 5 TO ANYONE OTHER THAN TOM DEVINE?
6 A I AM NOT AWARE THAT THOSE NOTES WERE PROVIDED 7 TO ANYONE OTHER THAN TOM DEVINE. 8 Q FROM THE DESCRIPTION OF THE NOTES THERE, IS 9 IT YOUR RECOLLECTION THAT IT WAS A -- WELL, 1 DON'T NEED 10 TO ASK THAT. NEVER MIND. 11 LOOK AT PAGE 27 0F THAT EXHIBIT, WOULD YOU, 12 PLEASE, MR. PARKS. DOCUMENT MM IS DESCRIBED AS: 13 " NOTES AND MEMOS OF THOMAS DEVINE'S GAP 14 STAFF, NO DATES, RE: BECHTEL/GPU POTENTIAL 15 WITNESSES AND WHAT THOSE WITNESSES KNOW 16 REGARDING PARKS' ALLEGATIONS AGAINST BECHTEL." 17 AND THEN IT LISTS APPARENTLY THE WITNESSES: 18 BONNIE SHERWOOD, JOHN PERRY, RON WARREN, MARK KOBI, 19 JOHN AUGER, JOYCE WENGER, CARL HRBAC, JIM FLOYD, 20 RON BRINKLEY. SAYS BILL WILLIAM MARSHALL. DO YOU THINK 21 THAT MIGHT BE WALTER MARSHALL, MR. PARKS? 22 A l'M SURE THAT'S WHO THEY INTENDED. 23 Q WALTER MARSHALL IS BUBBA MARSHALL? 24 A RIGHT. 1 25 Q YOU DO NOT KNOW ANY WILLIAM MARSHALL, DO YOU? l l 11-169
1 A NO, 1 DO NOT. 2 Q GEORGE CLEMENTS, JOE CHWASTYK. SAYS 3 ED GISCHEL. DO YOU THINK THAT MEANS ED GISCHEL OR i 4 ED KITLER MAYBE? YOU DON'T KNOW7 5 A l'M NOT FOR SURE WHICH IT WOULD MEAN. IT 6 COULD BE EITHER ONE. 7 Q AND GEORGE KUNDER. "NO COPIES ISSUED, 69 i 8 PAGES." HAVE YOU EVER SEEN THOSE PAGES? ' 9 A AT THE MOMENT 1 CAN'T RECALL IF I HAVE OR 10 NOT. 11 Q BEFORE FILING YOUR AFFIDAVIT, DID YOU REVIEW 12 ANY STATEMENTS, WRITTEN STATEMENTS BY ANY OF THE WITNESSES 4 13 LISTED IN THE IDENTIFICATION OF DOCUMENT MM? 14 A AT THE MOMENT I CANNOT RECALL HAVING REVIEWED 15 ANY WRITTEN STATEMENTS BY ANYONE MENTIONED HERE. 16 Q AFTER YOUR AFFIDAVIT WAS PREPARED, DID YOU 17 REVIEW ANY STATEMENTS ABOUT THE TESTIMONY OF THESE 18 CONDITIONS? 19 A WOULDN'T THAT BE ATTORNEY-CLIENT PRIVILEGE? 20 MR. JOHNSON: COULD WE JUST WAIT A SECOND? 21 COULD YOU REPEAT THE QUESTION PLEASE OR READ l 22 IT BACK? 23 MR. HICKEY: l'LL JUST REPEAT IT. I ASKED THE 24 WITNESS IF, AFTER HIS AFFIDAVIT WAS RELEASED ON MARCH 25 23RD, HE REVIEWED ANY STATEMENTS REGARDING THE TESTIMONY l l i l f 11-170 l i ,
1 OF THE WITNESSES LISTED IN~MM. 2 THE WITNESS: I WOULD HAVE TO CORRECT MY ANSWER 3 THEN BECAUSE I DO BELIEVE I REVIEWED SOME OF THE 4 STATEMENTS THAT WERE A PART OF THE STEERAGE REPORT. - 5 Q BY MR. HICKEY: OTHER THAN IN THE STEERAGE q. 6 REPORT, DID YOU REVIEW ANY NOTES AND MEMORANDA PREPARED BY THE GAP STAFF OF THOSE WITNESSES LISTED THERE? l 7 ( l 1 8 MR. JOHNSON: THIS IS AFTER HE PREPARED HIS 9 AFFIDAVIT? 10 MR. HICKEY: YES. I 11 THE WITNESS: WOULDN'T THAT BE PROTECTED BY THE 12 ATTORNEY-CLIENT PRIVILEGE? 13 Q BY MR. HICKEY: YOU CAN ASK EITHER 14 MR. JOHNSON OR ANYONE ELSE. MY UNDERSTANDING OF THE : 15 PRIVILEGE IS THAT IT APPLIES TO CONFIDENTIAL I 16 COMMUNICATIONS BETWEEN YOU AND YOUR ATTORNEY. l'M NOT ) i i 17 ASKING YOU WHETHER YOU HAD A DISCUSSION WITH YOUR ! 18 ATTORNEY. I'M ASKING YOU WHETHER YOU REVIEWED ANY NOTES, 19 AND 1 HAVEN'T EVEN ASKED YOU WHAT'S
- IN THE NOTES EXCEPT TO I
20 DESCRIBE THE NOTES. I 21 MR. JOHNSON: WELL, I WOULD OBJECT ON THE GROUNDS 22 OF RELEVANCE. SINCE IT OCCURS AFTER WHAT HE REVIEWED I I 23 AFTER HIS AFFIDAVIT, I WOULD SUGGEST IT IS IRRELEVAN't. j 24 BUT AT THIS POINT, I DON'T SEE THAT IT NECESSARILY l 25 INVOLVES ATTORNEY-CLIENT PRIVILEGE AT THIS POINT. 11-171 l I
1 THE WITNESS: I PROBABLY SHOULD HAVE GIVEN MY
.2. ANSWER TO BEGIN WITH. I DON'T RECALL REVIEWING ANYTHING i
3 AT THIS: MOMENT. l 4 , Q BY MR. HICKEY: BEFORE RELEASING YOUR l 5 AFFIDAVIT, MR. PARKS, YOU HAVE MET ON A COUPLE OF 6' OCCASIONS WITH DR..MEYERS OF THE HOUSE INTERIOR COMMITTEE 7 STAFF, HAVE YOU NOT? 8 A IF MEMORY SERVES ME CORRECTLY, 1 MAY HAVE MET 9 WITH THE MAN AT LEAST ONCE. 10 Q IF YOU WANT TO REFRESH YOUR RECOLLECTION BY 11 LOOKING AT YOUR LOG, WHICH IS AN EXHIBIT THERE IN FRONT OF 12 YOU -- 13 MR. JOHNSON: BY THE WAY THIS DOCUMENT IS STAPLED 14 WITH HALF THE PAGES UPSIDE DOWN. YOU MAY WANT TO FIX THAT 15 BEFORE IT GETS BOUND INTO THE RECORD. 16 MR. HICKEY: THANK YOU. 17 Q BY MR. HICKEY: THE FIRST ONE THAT WE'VE 18 LOCATED, MR. PARKS, 15 ON TUESDAY, MARCH 15. DO YOU SEE 19 YOU HAVE AN ENTRY THERE THAT "LATER THAT AFTERNOON I MET 20 WITH HENRY MEYERS OF CONGRESS"? 21 A RIGHT. 22 Q AND THEN THERE'S ANOTHER ONE ON MARCH 21, 23 MONDAY. 24 A I THINK THAT STATEMENT SAYS " TALK WITH HENRY > 25 MEYERS." 11-172
( :1 Q " TALK.". DO YOU:THINK THAT MEANS A PHONE l ." 2 CONVERSATION? I 3' A- ' P RO B A'B L Y. . l l- 4 Q S0 THE ONLY MEETING IN PERSON WITH DR. MEYERS .l 5 THAT YOU. RECALL -- YOU ONLY RECALL ONE MEETING WITH 6 DR."MEYERS IN PERSON? 7 A. BEFORE I WENT PUBLIC, YES. l 8 Q YES.
.9 AND TO SUGGEST THAT WAS ON MARCH 15TH, 1983?
10 A I WOULD STATE THAT BASED ON THE REVIEW OF MY 11 NOTES TAKEN BACK IN 1983 THAT.WOULD HAVE BEEN WHEN IT 12 ' HAPPENED. 13- Q DID YOU MEET.WITH HIM TO DISCUSS IN PART i i
- 14 MR. KUNDER AND THE MYSTERY MAN?
15 A WHAT'I RECALL MEETING WITH HIM ABOUT WOULD .
~J 16 HAVE BEEN -- WELL, 1 DON'T KNOW IF I SHOULD REALLY ANSWER 17 THIS.OR NOT BECAUSE IT WAS'AFTER 1 RETAINED TOM DEVINE. !
18 Q WELL, l'M NOT ASKING YOU WHAT YOU TOLD )
'19 MR. DEVINE. I'M ASKING YOU WHAT YOU TOLD DR. MEYERS.
20 A WHAT'I TALKED WITH DR. MEYERS ABOUT WAS THE 21 RECOVERY PROGRAM AT TMI. 1
' 12 2 Q DID-YOU ALSO DISCUSS GEORGE KUNDER AND THE I
'23 MYSTERY MAN?
l 24 A I DON'T RECALL, AT THE MOMENT, IF WE DID OR 25 NOT. I WAS MORE CONCERNED WITH THE HARASSMENT 11-173 l _ o
L. 11 - RETALIATION. 2 -Q DID DR. MEYERS EXPRESS TO YOU ANY' INTEREST IN i 1 3' THE MYSTERY MAN AND MR. KUNDER WHEN YOU MET WITH HIM ON
.4 L MARCH 15TH?
L . 51 A WELL, AT THE MOMENT I REALLY DON'T RECALL. 6 Q WERE.YOU INFORMED BY DR. MEYERS THAT HE WAS 7 CONTEMPLATING AN INQUIRY INTO THE CIRCUMSTANCES 8 SURROUNDING THE MYSTERY MAN AND THE PUMP SHUTDOWN? j 9 MR. JOHNSON: AT WHAT POINT? l 10 MR. HICKEY: WHEN YOU MET WITH HIM ON MARCH ISTH. I 11 THE WITNESS: I DON'T RECALL HIS MAKING ANY 12 STATEMENT TO ME. I-RECALL THAT THERE WAS A LETTER SENT TO 13 GPU REQUESTING PEOPLE BE MADE AVAILABLE. 14 Q. .BY MR. HICKEY: YOU WERE ONE OF THOSE 15 PERSONS, WEREN'T YOU? ( 16 A THAT'S CORRECT. 17 Q ! HAVE THE' LETTER HERE, WHICH I'LL BE GLAD TO l 18 SHOW YOU. IT LISTS EIGHT PEOPLE: MR. AUGER, MR. FAUST, l 19 MR. GUMMO, MR. KING, MR. PARKS, MR. PERRY, MR. JOSEPH l i 20 SMITH, AND MISS JOYCE WENGER. THOSE ARE ALL PEOPLE THAT j 21 ARE NAMED ON PAGES -- PAGE 36 OF YOUR AFFIDAVIT AS HAVING j
'22 INFORMATION ABOUT MR. KUNDER BEING THE MYSTERY MAN, ARE 23 THEY NOT?
24 A I DON'T BELIEVE CRAIG FAUST IS LISTED ON THAT , 25 PAGE, NO. l 11-174
'l Q VOU'RE CORRECT. THANK YOU.
2 OTHER THAN CRAIG FAUST? 3 A YES, I THINK I HAD HAD EVERY ONE OF THOSE 4 PEOPLE. 5 Q DiT YOU IDENTIFY THOSE PEOPLE TO DR. MEYERS I 6 ON THE 15TH? 7 A REGARDING THE INCIDENTS SURROUNDING 8 LARRY KING, THE HARASSMENT I WOULD HAVE BEEN FACED WITH, I 9 PROBABLY DID. I 10 Q DID YOU IDENTIFY THEM TO HIM AS HAVING 11 INFORMATION REGARDING THE MYSTERY MAN? , 12 A I BELIEVE I ALREADY STATED, SIR, 1 DIDN'T 13 RECALL IF 1 TALKED IT OVER WITH DR. MEYERS OR NOT WHEN I 14 MET WITH HIM ON THE 15TH OF MARCH. 15 Q WHEN YOU TALKED TO DR. MEYERS ON THE 15TH, 16 WAS THERE A TRANSCRIPT MADE OF YOUR DISCUSSION? 17 A NOT THAT I KNOW OF. BUT REMEMBER HOW THINGS 18 HAPPENED WHEN -- WATERGATE AND THE SECRET TAPE RECORDINGS, 19 NOTHING WOULD SURPRISE ME. I DON'T REALLY THINK THERE 20 WAS, THOUGH, NOT THAT l'M AWARE OF. 21 MR. HICKEY: WITH THE AGREEMENT OF COUNSEL l'D LIKE 22 TO USE BRIEFLY, IN EXAMINING THIS WITNESS, THIS TELECOPIED 23 VERSION OF A LETTER. l'LL GET A COPY OF IT MADE WHEN WE 24 TAKE A BREAK SO THAT WE CAN MARK A XEROX COPY INSTEAD OF 25 THE TELECOPY. 11-175 E
i i 1 1 MR. JOHNSON: OKAY. I I 2 MR. HICKEY: l'M GOING TO ASK THE REPORTER TO MARK 3 AS EXHIBIT 48 THIS DOCUMENT WHICH IS OF A MARCH 23, 1983 l l 4' LETTER SIGNED BY THOMAS DEVINE TO CHAIRMAN PALLADINO OF l l 5 THE NUCLEAR REGULATORY COMMISSION STATING THEIR l 6 REPRESENTATION OF MR. PARKS AND SOME OTHER MATTERS. l 7 Q BY MR. HICKEY: MR. PARKS, l'D ASK YOU TO l 8 TAKE A LOOK AT THIS LETTER. AND I HAVE A QUESTION FOR YOU I 9 ABOUT IT. 10 A OKAY. 11 Q THAT'S GOING TO BE MARKED AS EXHIBIT 48. 12 1 ASSUME YOU'VE SEEN THAT LETTER BEFORE, 13 MR. PARKS? YOU'VE SEEN THAT LETTER BEFORE? IT l ! 14 ACCOMPANIED YOUR AFFIDAVIT WHEN IT WAS RELEASED IN MARCH 15 0F 1983. I 16 A I THINK AT SOME TIME OR ANOTHER l'VE READ 17 THAT, YES. 18 Q WELL, 1 ASSUME SINCE IT STATES THAT THE 19 GOVERNMENT ACCOUNTABILITY PROJECT IS REPRESENTING YOU THAT 20 THE LETTER AND -- OR AT LEAST ITS CONTENTS WERE REVIEWED 21 WITH YOU BEFORE IT WAS RELEASED? 22 A I DON'T RECALL IF IT WAS REVIEWED WITH ME 23 BEFORE IT WAS RELEASED. 24 Q WELL, YOUR COUNSEL MR. DEVINE TOLD CHAIRMAN 25 PALLADINO THAT HIS DECISION -- OR THE GAP DECISION TO 11-176
1 REPRESENT YOU WAS BASED NOT ONLY ON YOUR AFFIDAVIT, BUT ) l 2 ALSO ON " VERIFICATION INTERVIEWS WITH ADDITIONAL WITNESSES l , 3 WHO SUPPORTED BOTH HIS CHARGES AND PERSONAL CREDIBILITY." 4 DO YOU KNOW WHO THOSE WITNESSES ARE? 5 A NOT OFF -- 1 STARTED TO STAY NOT OFF THE TOP 6 0F MY HEAD, BUT NOT AT THE MOMENT, NO. 7 I TH!NK I, YOU KNOW, TOLD YOU EARLIER TODAY 8 THAT I BELIEVE AT LEAST ONE OF THE PERSONS, YOU KNOW, THAT 9 TOM DEVINE HAD CONTACT WITH WAS JOHN AUGER, BUT I DON'T 10 KNOW WHO THE OTHER PEOPLE WERE HE MAY HAVE CONTACTED. 11 Q MR. PARKS, YOU CLAIM SEVERAL TIMES, INCLUDING ! 12 MOST'RECENTLY HERE TODAY, THAT THERE WAS NO LEGITIMATE 13 BASIS FOR GPU-N TO SUSPEND AND THEN TERMINATE MR. KING, l l 14 THAT THAT WAS A RETALIATORY HARASSING ACT. THAT'S RIGHT, 15 ISN'T IT7 16 A THAT'S MY OPINION, YES. 17 Q AND YOU ALSO HAVE CLAIMED THAT BECHTEL HAD NO 18 BASIS TO INVESTIGATE YOU CONCERNING YOUR ACTIVITIES IN 19 CONNECTION WITH THE QUILTEC COMPANY, THAT THAT ALSO WAS 20 HARASSMENT; ISN'T THAT RIGHT? 21 A I CONSIDERED THE WAY THEY HANDLED THE 22 INVESTIGATION TO BE HARASSING, YES. 23 Q WITH REGARD TO MR. KING, 1 BELIEVE THAT YOU 24 HAVE PREVIOUSLY STATED THAT MR. KING -- LET ME FIND THE 25 REFERENCE FOR YOU. IN YOUR STATEMENT OF JULY 23RD, 1985, 11-177
I l 1 WHICH IS EXHIBIT 39 --
] J
- 2. MR. JOHNSON: JULY-25TH MAYBE? I 3 MR. HICKEY: l'M SORRY, JULY 25, 1983. I KIND OF l )
i 4 STATED IT BACKWARDS, BUT IT'S JULY 25, 1983, EXHIBIT 39, j l l 5 ON PAGE 4, YOU STATED
- d l
5 "THAT THE QUILTEC MATTER DISPLAYED j I 7 A DOUBLE STANDARD" AND-THAT "ONLY TWO GPU l 8 EMPLOYEES LEFT FOR QUILTEC, MIKE HERLlHY
]
f 9 AND TED RECKERT. BOTH OF THEM WERE LEAVING ; 1 10 ANYWAY, HOWEVER. FURTHER, THEY APPROACHED I 11 QUILTEC FOR A JOB. KING DID NOT RECRUIT 12 THEM. IN FACT, 1 AM NOT AWARE OF ANY 13 INSTANCE WHERE KING SOLICITED OR TRIED i 14- TO SEDUCE GPU EMPLOYEES TO WORK FOR i 15 QUILTEC," ET CETERA. 16 Q BY MR. HICKEY: I TAKE IT THAT ACCURATELY 17 EXPRESSES YOUR VIEW OF MR. KING'S RECRUITING ACTIVITIES? 18 A THAT'S WHAT I BELIEVED AT THE TIME, YES. 19 Q HAVE YOU SINCE CHANGED YOUR MIND? i 20 A NO. 21 Q AND DID YOU BELIEVE THAT LARRY KING WAS 22 TRYING TO CONCEAL HIS QUILTEC ACTIVITIES FROM THE GPU 23 MANAGER? 24 MR. JOHNSON: l'M GOING TO OBJECT ON THE GROUNDS OF
- 25 RELEVANCE. THIS LINE OF QUESTIONING 15 NOT RELEVANT TO ]
i l \ 11-178 l l l
1 THIS PROCEEDING. 2 MR. HICKEY: 1 THINK IT'S RELEVANT TO THE CLAIMS 3 THAT MR. PARKS HAS MADE. MR. PARKS APPARENTLY THINKS IT 4 IS, TOO, SINCE HE MADE THE CLAIMS EARLIER TODAY IN THE 5 COURSE OF THE DEPOSITION. 6 THE WITNESS: COULD YOU REPEAT THE QUESTION? 7 Q BY MR. HICKEY: SURE. 8 DID YOU BELIEVE THAT MR. KING WAS MAKING ANY 9 EFFORT TO CONCEAL HIS QUILTEC ACTIVITIES FROM GPU 10 MANAGEMENT? 11 A BACK DURING THAT TIME FRAME BEFORE LARRY KING 12 WAS SUSPENDED, I DON'T BELIEVE HE EVER TRIED TO CONCEAL 13 ANYTHING. THAT'S MY BELIEF. 14 Q YOU KNOW BEN SLONE DON'T YOU, MR. PARKS? 15 A I KNEW BEN SLONE, YES. 16 Q HE WAS A BUSINESS ASSOCIATE AND FRIEND OF 17 YOURS DURING THE TIME BEFORE YOU WERE SUSPENDED FROM THREE 18 MILE ISLAND? 19 A NO, SIR. HE WAS A FRIEND OF MINE. l 20 Q ! DIDN'T PHRASE THAT VERY PRECISELY. i 21 MR. SLONE WORKED WITH YOU ON SOME OCCASIONS 22 AT THE SAME JOB SITE, DID HE NOT? 23 A HE WORKED AT TMI THE SAME TIME I DID WHEN I l 24 WAS THERE THE FIRST TIME, YES. HE LEFT TMI ABOUT THE SAME 25 TIME I RETURNED. 11-179 ,
1 Q AND YOU WARNED MR. SLONE, DIDN'T YOU, THAT 2 MR. KING AND MR. CHWASTYK WERE NOT BEING CAREFUL ENOUGH 3 ABOUT THEIR QUILTEC ACTIVITIES? DO YOU REMEMBER DOING l 4 THAT? 5 A NOT OFF THE TOP OF MY HEAD I DON'T REMEMBER. 6 Q WELL, IN THE LATE FALL OF '82 OR THE EARLY 7 PART OF '83? 8 A NOT AT THIS MOMENT I CAN'T RECALL HAVING SAID 9 THAT. 10 Q AND DID YOU EVER MAKE A SIMILAR COMMENT TO 11 MR. KITLER, THAT MR. KING WASN'T BEING DISCREET ENOUGH l l l 12 ABOUT HIS ACTIVITY? 13 A I CAN RECALL AT,0NE POINT MR. KITLER MAKING A 14 COMMENT TO ME ABOUT LARRY KING AND NOT BEING VERY 15 DISCREET, AND I THINK MY REPLY TO HIM WAS SOMETHING ALONG 16 THE LINE "I DON'T THINK HE'S TRYING TO KEEP IT A SECRET." l I 17 Q WHEN WAS THAT COMMENT? l 18 A OH, THE BEST ESTIMATE I CAN GIVE YOU AT THIS l 19 MOMENT WOULD PROBABLY HAVE BEEN AFTER JULY OF 1982. I 20 Q HOW ARE YOU ABLE TO PLACE IT AFTER JULY? IS 21 THERE SOME EVENT THERE YOU'RE TYING IT TO? l 22 A YES. IF I REMEMBER CORRECTLY, ED KITLER AND j I 23 I WERE WORKING TOGETHER IN A TRAILER AND THAT WOULD HAVE I 24 BEEN JUST ABOUT JULY, AUGUST TIME FRAME. 25 Q DID KITLER INDICATE WHY lE THOUGHT MR. KING
!!-180
1 SHOULD HAVE BEEN MORE DISCREET? 2 A IF HE DID, I DON'T RECALL IT AT THE MOMENT; 3 WHY, I MEAN. ] 4 Q WHAT DID YOU KNOW ABOUT MR. CHWASTYK'S 5 INVOLVEMENT WITH QUILTEC, MR. PARKS? 6 A I KNEW HE WANTED TO BE INVOLVED IN QUILTEC, ) 7 AND 1 KNOW HE WANTED TO HAVE A MORE -- I GUESS -- i 8 MR. JOHNSON: COULD YOU PUT A TIME FRAME ON THIS? i 9 MAYBE IT WILL HELP THE WITNESS. 10 MR. HICKEY: WELL, I THINK THE WITNESS WAS 11 RESPONDING. 12 Q BY MR. HICKEY: IF YOU NEED TO LIMIT IT BY 13 TIME, WHEN YOU LEARNED SOMETHING, PLEASE D0. 14 A WELL, AS FAR AS I KNOW, THE ONLY INVOLVEMENT 15 JOE EVER HAD WITH QUILTEC WAS AFTER I RETURNED TO TM1 THE i 16 SECOND TIME. I KNOW HE WANTED TO GO TO WORK FOR QUILTEC. 17 Q AND ANYTHING ELSE THAT YOU'RE-AWARE OF ABOUT f l 18 HIS INVOLVEMENT? 19 A SOMEWHERE ALONG THE LINE I BECAME AWARE OF 20 THE FACT THAT HE WENT TO ANOTHER POWER STATION TO 21 REPRESENT QUILTEC TO TRY TO GET A PROPOSAL. 22 Q THAT WAS TO THE BEAVER VALLEY STATION? 23 A I BELIEVE THAT COULD HAVE BEEN THE POWER 24 PLANT. 25 Q WERE YOU AWARE OF THIS AT THE TIME IT WAS 11-181
i 1 GOING ON OR LATER? l 2 A I COULD NOT REASONABLY STATE, AT THIS MOMENT l 1 1 3 IN TIME, IF I KNEW, YOU KNOW, WHEN IT WAS GOING ON OR IF I q I 4 LEARNED IT AFTER I WENT PUBLIC AND CAME OUT IN SOME OF THE ) i 5 DEPOSITIONS.
]
6 Q YOU DON'T RECALL WHEN YOU LEARNED IT? ! 7 A NO, NOT ACCURATELY AT THIS MOMENT. J 8 I WAS AWARE OF THE FACT THAT HE WENT THERE l 9 THOUGH OR AM AWARE, I SHOULD SAY. I 10 Q YOU'RE AWARE OF IT NOW; YOU'RE NOT SURE WHEN 11 YOU BECAME A E OF IT? 12 A RIGHT. 13 Q YOU HAD PREVIOUSLY WORKED AT BEAVER VALLEY, 14 HADN'T YOU, MR. PARKS? 15 A YES, I HAD. 16 Q YOU KNEW MR. DON SKIDMORE OF BEAVER VALLEY, 17 DID YOU? 18 A NOT THAT I CAN THINK OF. MAYBE I MIGHT HAVE 19 KNOWN HIM BY HIS TITLE, BUT NOT THE MAN. 20 Q IN YOUR STATEMENT, THAT'S EXHIBIT 39, ON 21 PAGE 3 YOU SAY, QUOTE: 22 "AT BEAVER VALLEY CHWASTYK 23 CONTACTED DON SKIDMORE OF DUQUESNE 24 LIGHT COMPANY, THE LICENSEE AT BEAVER 25 VALLEY, ABOUT A QUILTEC PROPOSAL AND l 11-182 I
._____-_ ___- __ _ ___---_-__-_________ _ a
1 A POSSIBLE CONTRACT AT BEAVER VALLEY." 2 THAT' SUGGESTS TO ME THAT YOU KNEW 3 MR. SKIDMORE'S NAME AT LEAST. i 4 MR. JOHNSON: IS THERE A QUESTION? 5 Q BY MR. HICKEY: YES. DID YOU KNOW 6 MR. SKIDMORE'S NAME7 7 A IF I DID, 1 DON'T RECALL KNOWING IT. BUT ! l 8 THAT DOES NOT MEAN I DISAGREE WITH THAT STATEMENT THAT 9 APPEARS THERE EITHER. 10 Q WELL, I WOULD ASSUME NOT SINCE YOU SWORE TO 11 THE TRUTH OF IT, DIDN'T YOU, ON THE LAST PAGE? 12 A YES, 1 DID. 13 Q IS IT YOUR BELIEF THAT SOMEONE ELSE PUT THAT 14 NAME IN THE STATEMENT? l 15 A NO. I'M NOT TRYING TO INSINUATE THAT AT ALL. 16 WHAT l'M TRYING TO SAY 15 I DO NOT RECOLLECT AT THIS i l 17 MOMENT IN TIME OF HAVING EVER KNOWN DON SKIDMORE. i 18 Q WELL, HOW LONG WERE YOU AT BEAVER VALLEY? l 19 A OH, ABOUT FIVE OR SIX MONTHS. 20 Q DIDN'T YOU TELL MR, SLONE AND MR. KING ABOUT ; 21 THE POSSIBILITY OF AN OPENING AT BEAVER VALLEY? l 22 A I THINK IF I DID, I DON'T RECALL IT. BUT I j l 23 WOULD NOT DOUBT IT EITHER. I 24 Q HAD YOU HELPED SET UP THE MEETING FOR 1 25 MR. CHWASTYK TO GO TO MEET AT BEAVER VALLEY WITH MR. HOAG l I 11-183 I l
1 AND MR. SKIDMORE? ' 2 A I DO NOT BELIEVE I DID, NO. 3 Q YOU DIDN'T MAKE ANY PHONE CALLS OR DO ANY 4 INQUIRES TO GET ACCESS FOR QUlLTEC TO BEAVER VALLEY? 5 A THE ONLY TIME I CAN RECALL EVER TALKING TO 6 .ANYONE AT BEAVER VALLEY WAS WHEN I CALLED UP AN OLD BUDDY 7 0F.MINE AT BEAVER VALLEY. 8 Q WHO WAS THAT? 9 A LEE HENDRICKSON. 10 Q WHAT DID YOU CALL HIM ABOUT? 11 A WELL, WE USED TO SEE EACH OTHER SOCIALLY. HE 12 WAS A FRIEND. AT ONE POINT IN TIME, I TRIED TO GET LEE TO 13 COME TO WORK FOR GPU. 14 Q NOT FOR QUILTEC? 15 A NO. FOR GPU. l 16 IN FACT, HE EVEN CAME AND INTERVIEWED FOR THE ] i 17 POSITION AT GPU. AND IF I REMEMBER CORRECTLY, HE WAS 18 0FFERED A POSITION AND HE TURNED THEM DOWN. I l 19 Q BUT IT'S YOUR TESTIMONY THAT YOU DON'T RECALL l 20 HAVING ANY DISCUSSIONS WITH PEOPLE AT BEAVER VALLEY ABOUT 21 THE POSSIBILITY OF INTERVIEWING OR HIRING QUILTEC? { 22 A NOT THAT I RECALL. DURING MY CONVERSATIONS 1 23 WITH LEE, IT MAY HAVE COME OUT THAT THEY WERE LOOKING FOR j 24 PEOPLE THERE AT BEAVER VALLEY. 1 25 Q LEE MAY HAVE TOLD YOU THAT, YOU THINK? IS
]
l 11-184
I 1 THAT WHAT YOU'RE SAYING? 2 A HE MIGHT HAVE. I CAN'T SAY ONE WAY OR THE l 3 OTHER WHETHER HE DID OR NOT. I 4 Q IF HE DID, YOU MAY HAVE PASSED IT ON TO ) 1 5 MR. KING OR MR. SLONE? l I 6 A IT PROBABLY WOULD HAVE BEEN SLONE. BEN USED 1 7 TO CALL ME FREQUENTLY. 8 Q WAS THIS IN THE TIME PERIOD WHEN, AFTER THE 9 REORGANIZATION, YOU'D BEEN ASSIGNED TO THE SITE OPERATIONS 10 ORGANIZATION? 11 A WHAT? 12 Q THAT YOU SPOKE TO MR. LEE HENDRICKSON AND HE 13 MAY HAVE THOUGHT THERE WAS A POSSIBLE OPENING AT BEAVER 14 VALLEY. 15 A I DON'T RECALL REALLY WHEN IT WAS, NOT AT 16 THIS MOMENT IN TIME. 17 Q WELL, I THINK OTHER EVIDENCE IN THE RECORD 18 REFLECTS THAT CHWASTYK WENT TO BEAVER VALLEY ON OCTOBER i i 19 29, 1982. PRESUMABLY IT WOULD HAVE BEEN BEFORE THAT TIME 1 1 20 PERIOD, RIGHT? 21 A WELL, IF HE GLEANED ANYMORE FROM THEM AND 1 22 THEY ACTED UPON IT, THEN APPARENTLY THEY WOULD HAVE HAD TO ) l 23 HAVE DONE SO BEFORE JOE CHWASTYK WENT OVER THERE. BUT I I 24 AGAIN, I CANNOT CLEARLY DEFINE TO ANY BETTER EXTENT WHEN I ) 1 25 TALKED WITH LEE THAN I ALREADY HAVE. 11-185 - -_ --- - i
1 Q IN THE LATE SUMMER OR FALL OF 1982, YOU GOT . 2 MISS RITTLE TO TYPE SOME QUILTEC RESUMES FOR MR. KING, I 3 DIDN'T YOU? 4 A I BELIEVE IT WAS IN THE SUMMER OF 1982. ! 5 Q WHY WAS IT THAT'YOU DID THAT FOR MR. KING? 6 WHY COULDN'T MR. KING DO IT FOR HIMSELF? DO YOU KNOW7 7 A I DIDN'T THINK TO QUESTION HIM WHY HE DIDN'T 8 DO IT. TO BEGIN WITH, HE ASKED ME IF 1 KNEW SOMEONE THAT 9 COULD GET IT DONE. I CAN ONLY SPECULATE AS TO HIS REASONS 1 1 10 WHY HE CHOSE ME. J 11 Q WHAT'S YOUR SPECULATION? j 12 MR. JOHNSON: I WOULD ASK THE WITNESS NOT TO 13 SPECULATE. 1 14 MR. HICKEY: WELL, ASSUME. IF HE DOES NOT KNOW, IT 15 SEEMS TO ME IT -- i 16 MR. JOHNSON: WHAT DO YOU KNOW; NOT WHAT YOU CAN 17 SPECULATE ABOUT. 18 MR. HICKEY: WELL, I WAS THINKING IT WAS, AT LEAST, 19 POSSIBLE, MR. JOHNSON, THAT WHEN MR. PARKS USED THAT 20 EXPRESSION "I CAN ONLY SPECULATE," HE USED IT AS MANY 21 ORDINARY PEOPLE DO; THAT HE HAD SOME KIND OF RECOLLECTION. 22 I'M ASKING HIM IF HE DOES -- 23 MR. JOHNSON: IF HE HAS A RECOLLECTION, THAT'S 24 FINE. 25 THE WITNESS: 1 CANNOT REALLY STATE WITH ANY 11-186
l I 1 CERTAINTY EXACTLY WHY LARRY KING ASKED ME. I 2 Q BY MR. HICKEY: KING HAD A SECRETARY ASSIGNED l 3 TO HIM, DIDN'T HE? l 4 A I BELIEVE HE DID AT THE TIME, YES. I 5 Q NOW WHEN YOU GOT MISS RITTLE TO AGREE TO DO 6 THIS TYPING, YOU TOLD MR. KING THAT YOU LET HER USE YOUR
)
l 7 RESUME AS A FORMAT FOR THESE QUILTEC RESUMES, DIDN'T YOU? ) 8 A- I BELIEVE THAT'S PROBABLY FAIRLY ACCURATE. i 9 Q WHAT DID YOU HAVE IN MIND, WHAT DID YOU MEAN i 10 YOU WERE GOING TO DO -- OR WHAT DID YOU DO WITH REGARD TO 11 USING YOUR RESUMES AS A FORMAT? 12 A WELL, IT SEEMS TO ME WHEN -- AFTER LARRY HAD 13 ASKED ME TO GET THE TYPING DONE OR IF 1 KNEW SOMEONE TO ) 14 GET THE TYPING DONE FOR HIM, THAT I QUESTIONED HIM 15 REGARDING THE TYPE OF FORMAT THAT HE WANTED. AND IF 16 MEMORY SERVES ME CORRECTLY, HE KIND OF HEMMED AND HAWED 17 AROUND. AND 1 SUGGESTED HE USE THE FORMAT, AND IT HAD 18 ALWAYS BEEN SUCCESSFUL IN GETTING ME A JOB. 19 Q YOU SAID YOU'D PROVIDE A COPY OF YOURS SO 20 THAT PEOPLE COULD SEE WHAT THE FORMAT WAS? 21 A SOMETHING ALONG THAT LINE, RIGHT. I BELIEVE 22 I DID GIVE MISS RITTLE A COPY OF MY RESUME TO USE AS A 2.3 GUIDELINE. ! I 24 MR. HICKEY: I'D ASK THE REPORTER TO MARK THIS AS 25 EXHIBIT 49, THE DOCUMENT I HAVE GIVEN HER. 11-187 I
- ----- -_ _ D
1 (WHEREUPON RESPONDENT'S EXHIBIT 49 WAS MARKED 2- FOR IDENTIFICATION BY.THE NOTARY PUBLIC, AND A COPY IS I 3 ATTACHED HERETO.) 4 Q BY MR. HICKEY: I'M SHOWING YOU, MR. PARKS, l
.5 WHAT HAS-BEEN MARKED AS EXHIBIT 49, A RESUME OF RICHARD D. j l
6 PARKS ON NUS CORPORATION STATIONERY WITH A RECEIVED STAMP l 7' IN.THE UPPER'RIGHT-HAND CORNER THAT APPEARS.TO SAY' h I 8 " RECEIVED, BECHTEL CORPORATION APRIL," SOMETHING, "1982." l
.l 9 WAS THAT THE RESUME THAT YOU PROVIDED TO 10 BECHTEL WHEN YOU WERE IN THE PROCESS OF TRANSFERRING FROM j 11 THE SHOREHAM PLANT BACK TO TMI IN APRIL OR MAY OF 1982?
12 A I BELIEVE IT TO BE,.YES. 13 Q IS THAT THE RESUME THAT YOU GAVE TO 14 MISS RITTLE TO USE AS A FORMAT FOR THE QUILTEC RESUMES? 15 A IT PROBABLY WOULD HAVE BEEN. 16 Q NOW YOU KNEW FROM MR. KING THAT THE RESUMES 17 THAT WERE TO BE TYPED WERE GOING TO BE TYPED FOR THE 18 QUILTEC. COMPANY, QUILTEC, INC., I GUESS I SHOULD SAY? 19 A RIGHT. 20 Q AND DID YOU TALK TO MR. KING ABOUT WHOSE 1 21 RESUMES.THEY WERE? 22 A I DON'T REMEMBER IF WE HAD CONVERSATION ABOUT 23 WHOSE RESUMES WERE INCLUDED OR NOT. 24 Q WHEN YOU GAVE THE WORK TO MISS RITTLE AND YOU 25 GAVE HER THE RESUMES THAT YOU RECEIVED -- I ASSUME YOU 1 11-188 I
l 1 RECEIVED THE RESUMES FROM MR. KING, RIGHT, TO GIVE TO 2 MISS RITTLE TO RETYPE? 3 A IF I REMEMBER, EVERYTHING WAS IN A PACKAGE, , 4 LIKE IN A BIG ENVELOPE. l 5 Q AND SO YOU GAVE THEM TO MISS RITTLE AFTER YOU l [ 6 MADE THE ARRANGEMENTS AND ALSO GAVE HER A COPY OF YOUR 7 RESUME AND ASKED HER TO TYPE THEM? 8 A I BELIEVE THAT'S ABOUT THE WAY IT OCCURRED. 9 Q DID YOU DO ANYTHING ELSE TO HELP MISS RITTLE 10 ACCOMPLISH THIS TASK FOR MR. KING? 11 A I DON'T KNOW WHAT YOU MEAN BY " HELP." 12 Q WELL, I DIDN'T MEAN ANYTHING PARTICULARLY. 13 YOU GAVE HER THE RESUMES, AND YOU GAVE HER YOURS AS A i 14 FORMAT SAMPLE. DID YOU DO ANYTHING ELSE TO GET THE JOB l 15 DONE? l 16 A NO. EVERYTHING -- IF I REMEMBER CORRECTLY, l i 17 EVERYTHING WAS IN THE PACKAGE THAT SHE HAD TO -- NEEDED TO , 18 USE TO GET THE JOB DONE. 19 Q DID YOU GIVE HER ANY SPECIFIC INSTRUCTIONS ] 1 20 ABOUT HOW TO DO IT? 21 A 1 THINK I MAY HAVE TOLD HER, YOU KNOW, " TYPE l 22 THESE RESUMES UP. FOLLOW THE FORMAT THAT'S IN MINE." BUT i 23 I COULDN'T REALLY SWEAR TO THAT AT THIS MOMENT. j i I 24 Q NOW MR. PARKS, YOU TOLD MISS RITTLE TO KEEP l l 25 IT CONFIDENTIAL THAT SHE WAS TYPING THESE RESUMES, DIDN'T I l l 11-189 l _ _ _ ---- _ A
1 VOU? 2 A I DON'T RECALL, AT THIS MOMENT, IF I DID OR 3 NOT. 4 Q WELL, WHEN YOU WERE INTERVIEWED BY 5 MR. HOFMANN AND MR. WHEELER IN MR. KOBI'S PRESENCE ON 6 MARCH 14, 1983 -- DO YOU REMEMBER THAT OCCASION? 1 7 A I REMEMBER BEING INTERVIEWED BY THOSE 8 GENTLEMEN, YES. i 9 Q MR. KOBI WAS PRESENT, TOO? 10 A YES. 11 Q AND DURING THE COURSE OF THAT INTERVIEW YOU 12 REMEMBER BEING ASKED ABOUT MISS RITTLE'S TYPING THE l 13 RESUMES? j l 14 A YES. l 15 Q AND ON THAT OCCASION DO YOU RECALL TELLING 16 THE GROUP PRESENT THAT YOU HAD DIRECTED MISS RITTLE TO j 17 KEEP THE INFORMATION CONFIDENTIAL? i 18 A I DON'T RECALL TELLING THEM THAT I DIRECTED 19 MISS RITTLE TO KEEP IT CONFIDENTIAL. I THINK WHAT I MAY l 20 HAVE SAID TO THEM WAS FOR HER TO DO IT AFTER WORK, AFTER 21 BUSINESS HOURS. 22 Q LET ME BACK UP FOR A MINUTE. I MAY HAVE 23 MISSTATED THE EVIDENCE. l 24 i CANNOT REPRESENT TO YOU -- MY MEMORY IS 25 SLIPPING. I CANNOT REPRESENT TO YOU THAT I BELIEVE THAT j i 11-190 l
1 STATEMENT WAS MADE DURING YOUR HOFMANN INTERVIEW. l'M NOT < l' l 2 SURE NOW. i 3 YOUR TESTIMONY IS YOU DON'T REMEMBER'SAYING 4 DURING THE HOFMANN INTERVIEW THAT YOU TOLD MISS RITTLE TO .I 5 KEEP 1T CONFIDENTIAL? j 6 A THAT'S WHAT I BELIEVE TO BE TRUE, RIGHT. THE
.7 ONLY 0THER INSTRUCTION I GAVE TO MISS RITTLE WAS TYPE'THEM 8 ON HER OWN TIME.
1 9 Q WAS THERE ANY REASON THAT YOU CAN THINK OF 10 WHY YOU WOULD HAVE TOLD MISS RITTLE TO KEEP THE 11 INFORMATION CONFIDENTIAL 7 12 , A THAT ASSUMES, SIR, THAT I TOLD HER TO KEEP IT I 13 CONFIDENTIAL, AND I DON'T REMEMBER SAYING THAT. I DON'T l 14 REMEMBER IF I TOLD HER THAT. 15 Q CAN YOU THINK OF ANY REASON WHY NOT? 1 16 A NOT AT THIS MOMENT. 17 MR. JOHNSON: YOU'RE ASKING THE WITNESS TO 18 SPECULATE ON A HYPOTHETICAL. J k 19 MR. HICKEY: NO. I'M REALLY ASKING THE WITNESS 20 WHETHER THERE IS ANYTHING IN HIS RECOLLECTION OR MEMORY 21 THAT WOULD INDICATE TO HIM A NEED TO KEEP THE INFORMATION 22 CONFIDENTIAL. 23 THE WITNESS: WELL, I THINK I HAVE ALREADY STATED 24 THAT I DIDN'T TELL HER TO DO THAT OR WOULD -- DON'T RECALL i 25 TELLING HER TO DO THAT. AND I GUESS THE BEST WAY -- THERE II-191
.____ ___ _____ _ _ _ _ __d
1 IS NOTHING THAT COMES TO MY MEMORY AT THIS MOMENT THAT 2 WOULD MAKE IT SEEM TO BE CONFIDENTIAL. 3 Q BY MR. HICKEY: I UNDERSTAND YOUR NOT 4 REMEMBERING TO KEEP IT CONFIDENTIAL, BUT YOU DON'T RECALL 5 TELLING HER? 6 A I DON'T REMEMBER TELLING HER THAT. NO, I 7 DON'T BELIEVE I DID. 8 Q AND YOU KNEW, DID YOU NOT, MR. PARKS, THAT 9 THE RESUMES WERE GOING TO THE BEAVER VALLEY POWER PLANT _OF 10 DUQUESNE POWER AND LIGHT? j l 11 A I CAN'T STATE, AT THIS MOMENT IN TIME, IF I I 12 KNEW THAT AT THAT POINT IN TIME OR NOT. 13 Q WELL, INCLUDED IN THE PACKAGE THERE WAS A 14 PROPOSAL TO BEAVER VALLEY, WASN'T THERE? l 1 15 A I BELIEVE THERE WAS A PROPOSAL. BUT AGAIN 16 I'M REALLY SEARCHING BACK IN MY MEMORY. I THINK YOU'LL 17 FIND A F A T U.Y ACCURATE REFLECTION OF EVERYTHING THAT 18 OCCURRED DURING THAT WHOLE ESCAPADE REFLECTED IN THE 19 INTERVIEW OF MR. HOFMANN AND MR. WHEELER -- YEAH, WHEELER. 20 Q THAT'S THE MARCH 14TH INTERVIEW WE TALKED 21 ABOUT JUST A MOMEN1 aGO? 22 A RIGHT. 23 Q WHEN YOU MET WITH THOSE GENTLEMEN, THEY ASKED 24 YOU TO RECALL, IF YOU COULD, THE NAMES OF PERSONS WHOSE 25 RESUMES WERE BEING TYPED. WHAT DO YOU REMEMBER TODAY 11-192
i l'- ABOUT WHOSE RESUMES WERE THERE, MR. PARKS? 2 A I DON'T REMEMBER TODAY WHOSE RESUMES WERE k 3 THERE. BUT I DO REMEMBER TELLING THOSE GENTLEMEN, AT THE l 4 TIME, WHOSE RESUMES I COULD REMEMBER. 5 Q DO YOU REMEMBER TELLING THEM MR. KING'S 6- RESUME WAS THERE? f 7 MR. JOHNSON: HE SAID HE DOES NOT REMEMBER THE l 8- NAMES. HE JUST REMEMBERS THAT HE TOLD THE INTERVIEWER 9 NAMES HE REMEMBERED AT THAT TIME. IF YOU HAVE A DOCUMENT 10 THAT -- THE NAMES THAT WERE RECORDED BY THE INTERVIEWERS 11 AT THIS INTERVIEW THAT COULD REFRESH THE WITNESS' i i 12 RECOLLECTION, FEEL FREE TO PROVIDE IT TO HIM. I 4 13 MR. HICKEY: THAT'S WHAT l'M DOING. I DON'T THINK 14 I HAVE TO SHOW HIM THE DOCUMENT TO DO THAT. I ASSUME IT'S 15 NOT A DOCUMENT THAT HE'S EVER SEEN. 16 Q BY MR. HICKEY: DO YOU REMEMBER GIVING -- 17 A NO. 18 MR. JOHNSON: NO REASON TO ASSUME HE HAS SEEN IT OR 19 HAS NOT SEEN IT. 20 MR. HICKEY: ! THINK THERE IS SOME REASON HE I 21 COMPLAINS IN HIS AFFIDAVIT THAT HE WASN'T ALLOWED TO 22 REVIEW THE NOTES. 23 Q BY MR. HICKEY: DID YOU REVIEW THE NOTES THAT, 24 WERE TAKEN BY MR. HOFMANN OR MR. WHEELER OF THE INTERVIEW 25 THAT HAPPENED ON MARCH 14TH? 11-193
.1' .A NO. 'THEY,WOULD NOT ALLOW .ME TO' REVIEW THEIR .]
2 NOTES'ON THAT. DAY.
.3 Q DO YOU REMEMBER TELLING THE GENTLEMEN THAT-
, 4 YOU. KNEW THAT MR. LARRY KING'S. RESUME WAS IN THE PACKAGE? 5 A YOU K N O W ,- AGAIN, M R .' HICKEY, ALL I CAN TELL' I 6 YOU TODAY, AT THIS VERY MOMENT, THAT'MY' MEMORY SERVES TO 7 TELL ME IS:THAT l-TOLD THOSE-GENTLEMEN THAT DAY THE: PEOPLE 8 WHOSE NAMES I WAS REASONABLY SURE WERE INCLUDED IN THAT 9- PACKAGE. AND IT WOULD JUST BE A GUESS TODAY IF 1.TRIED TO - 10- RECALL WHOSE NAMES I . TOLD THEM FOUR YEARS AGO. T
. 11 Q OKAY. WELL, I UNDERSTAND THAT YOU DON'T HAVE 12 .ANY RECOLLECTION OF EVENTS AND THE NOTES WILL SPEAK FOR l
.1 I
.13 THEMSELVES. I THOUGHT IT MIGHT REFRESH YOU THAT THEY 14 SUGGEST YOU TOLD MR. KING, MR. HANBY, AND MR.-KINGSLY 15 DRAPER. YOU DON'T HAVE ANY RECOLLECTION ONE WAY OR THE 16 OTHER7 17 A THAT'S CORRECT.
18 Q LET ME ASK YOU ONE THAT MIGHT STIR A BELL IN 19 YOUR MEMORY A LITTLE MORE DIRECTLY. DID YOU TELL THEM 20 THAT.YOUR RESUME WAS IN'THE PACKAGE? 21 A I-MIGHT HAVE. I DON'T RECALL IF I TOLD THEM 22- AT THAT TIME OR NOT. 23 Q IT WAS IN THE PACKAGE, WASN'T IT? , 24 A I REALLY COULDN'T TELL YOU TODAY IF IT WAS IN 25 THAT PACKAGE OR NOT. 1 11-194
1 Q YOU DON'T REMEMBER? 2- A I DO NOT HAVE ANY RECALL AT THIS MOMENT. ! 3 Q WHETHER FROM REVIEWING THE RESUMES OR NOT, i 4 YOU WERE AWARE IN THE FALL OF 1982 THAT MR. L10NARONS AND ) i 5 MR. DRAPER AND MR. BERNIE SMITH AND MR. DIM FLOYD AND ] l 6 MR. CHWASTYK AND YOU WERE ALL HAVING YOUR RESUMES ] i 7 SUBMITTED TO BEAVER VALLEY ON QUILTEC STATIONERY? 8 A AGAIN, SIR, IF l'D BEEN ABLE TO REMEMBER THAT 9 WHEN I INTERVIEWED ON MARCH 14TH, I WOULD HAVE TOLD YOU 10 THAT. AND 1 DON'T HAVE ANY ADDITIONAL RECALL TODAY, AT 11 THIS VERY MOMENT, WHOSE NAMES WERE INCLUDED. I 12 Q WELL, YOU KEPT THIS OUT OF THE RESUMES AND 13 PROPOSAL YOU HAD MISS RITTLE TYPE, DIDN'T YOU? 14 A TRUE. 15 Q BUT YOU DIDN'T KEEP IT AS LONG AS THE -- UP l 16 UNTIL THE TIME OF THE INTERVIEW WITH MR. HOFMANN? 17 A NO, I DID NOT. 18 Q WHY DID YOU KEEP IT? 19 A NO REASON NOT TO. 20 Q WELL -- 21 A I MEAN l'M NOT TRYING TO GIVE YOU A FLIPPANT 22 ANSWER. I CANNOT GIVE YOU A REASON, AT THIS MOMENT IN 23 TIME, WHY I KEPT IT. 24 Q WELL, THESE WERE PACKAGES OF RESUMES ON I 25 QUILTEC STATIONERY AND A PROPOSAL FROM QUILTEC TO PROVIDE I 11-195 l l
l 1 SERVICES TO BEAVER VALLEY THAT YOU WERE GETTING TYPED ON I 2 BEHALF OF MR. KING OR QUILTEC. I ASSUME THAT'S A l 3 CONVENIENCE TO MR. KING; IS THAT YOUR TESTIMONY? 4 A I BELIEVE THAT'S WHAT I HAVE TESTIFIED TO { 5 PREVIOUSLY AND THAT'S WHAT l'LL TESTIFY TO TODAY. 6 Q AND WHY WOULD YOU WANT TO KEEP A COPY OF THAT 7 MATERIAL? l 8 A OUT OF CURIOSITY OR FOR SOME OTHER REASON. I 9 GUESS WHAT l'M TRYING TO SAY, 1 DO NOT HAVE A SPECIFIC 10 REASON WHY I KEPT IT. AND I BELIEVE I CONVEYED THAT 11 INFORMATION TO MR. HOFMANN AND MR. WHEELER ON THE DAY THEY 12 INTERVIEWED ME. 13 Q YOU DESTROYED THE MATERIAL SHORTLY BEFORE THE 14 INTERVIEW, DIDN'T YOU? 15 A I THREW IT AWAY. I 16 Q WHEN DID YOU DO THAT? 17 A GOD, I DON'T KNOW. AT THIS MOMENT IN TIME, 1 18 DO NOT REMEMBER. 19 Q AFTER MR. KING WAS SUSPENDED ON FEBRUARY 24? 20 A PROBABLY. I COULDN'T REALLY SWEAR TO IT ONE 21 WAY OR THE OTHER. ! 22 Q DO YOU THINK IT WAS SIMPLY A MATTER OF A FEW 23 DAYS BEFORE THE INTERVIEW WITH MR. HOFMANN? ! I 24 A I DON'T BELIEVE IT WAS A MATTER OF A FEW i 25 DAYS, NO. 1 11-196 l
i 1 Q VOU SAID YOU DIDN'T HAVE ANY SPECIFIC REASON 2 WHY YOU KEPT IT. WHY DID YOU THROW IT AWAY? 3 A WELL, WHEN LARRY KING WAS SUSPENDED, HE WAS 4 SUSPENDED FOR,.YOU KNOW, CONFLICT OF INTEREST OVER 5 QUILTEC. AND 1 THREW THOSE DOCUMENTS AWAY AFTER HE WAS 6 SUSPENDED. THAT PROBABLY WOULD HAVE BEEN WHY I THREW THEM / 1 7 AWAY. . i 8 Q l DO NOT UNDERSTAND WHY -- WHY, BECAUSE LARRY , 9 KING WAS SUSPENDED, WOULD YOU THROW DOCUMENTS AWAY? 10 A BECAUSE THEY WERE IN MY POSSESSION, AND I DID 11 NOT WANT TO BE IMPLICATED. 12 Q DJD YOU FEEL IT WAS NECESSARY TO CONCEAL YOUR 13 INVOLVEMENT WITH MISS RITTLE IN THE TYPING OF THE QUILTEC 14 RESUME AFTER LARRY WAS SUSPENDED? 15 A I NEVER FELT IT WAS NFCESSARY FOR ME TO 16 CONCEAL ANY INVOLVEMENT BECAUSE I HAD NO INVOLVEMENT OTHER 17 THAN JUST GETTING IT TYPED. 18 WHEN I WAS INTERVIEWED BY MR. SANFORD ON THE 19 DAY PRIOR AND BY MR. WHEELER AND BY MR. HOFMANN, I GAVE 20 BECHTEL MY PERMISSION TO GO THROUGH MY BANK RECORDS AND 21 FIND ANY INFORMATION THAT I HAD NEVER RECEIVED A PENNY FOR 22 ANYTHING FROM QUILTEC OR LARRY KING OTHER THAN THE TIME HE 23 REIMBURSED ME FOR THE MONEY I PROVIDED TO ROSE RITTLE. I 24 THINK HER NAME IS R-I-T-T-L-E. 25 Q WELL, l'M STILL UNCLEAR ABOUT WHAT YOU MEAN 11-197
1 BV YOUR ANSWER. IF LARRY KING GETS SUSPENDED ON 2 FEBRUARY 24 OVER AN ALLEGED CONFLICT OF INTEREST WITH 3 QUILTEC AND YOU DIDN'T FEEL ANY NEED TO CONCEAL IN ANY WAY 4 YOUR OBTAINING MISS RITTLE TO TYPE THESE RESUMES, WHY DID 5 YOU FEEL IT WAS NECESSARY TO THROW AWAY THE RESUMES AND 6 THE PROPOSAL? 7 A TO PUT EVERYTHING IN THE PROPER PERSPECTIVE 8 FOR YOU, SIR, THIS WAS AFTER I'D ALREADY BEEN THREATENED 9 AND AFTER I'D ALREADY BEEN REMOVED FROM THE ALTERNATE 10 STARTUP AND TEST SUPERVISOR'S JOB. I FELT, AT THAT TIME, 11 OR I STRONGLY SUSPECTED, AT THAT TIME, THAT I WAS ALREADY 12 RECEIVING RETALIATION. AND I WANTED TO MAKE SURE THAT I 13 DID NOT HELP PROVIDE ANY ADDITIONAL FUEL FOR THE' FIRE TO 14 JUSTIFY BECHTEL OR GPU MANAGEMENT FROM JUST UP AND FIRING 15 ME -- 16 Q I SEE. 17 A -- FOR SOME FABRICATED REASON. , 18 Q AND YOUR BELIEF WAS THAT IF THEY KNEW THAT 19 YOU HAD THESE RESUMES AND PROPOSAL, THEY MIGHT ATTEMPT TO g 20 USE THAT AS A BASIS FOR FIRING YOU EVEN THOUGH, IN YOUR , 21 MIND, THAT WOULDN'T BE LEGITIMATE? 22 A IRRESPECTIVE OF WHAT MY BELIEF WAS, AT THE 23 TIME, SIR, I BELIEVE THE CIRCUMSTANCES BEAR OUT MY FEAR 24 THAT THEY WERE GOING TO TRY TO RAILROAD ME ON SOME { 25 PREFABRICATED CHARGE. i 11-198 f
'l Q WELL, MR.~ PARKS, I'D LIKE YOUHTO ANSWER THE 2 QUESTION I ASKED.
~ .3 WAS IT YOUR BELIEF, AT THE TIME, THAT YOU 4 WERE IN DANGER BECAUSE GPU OR BECHTEL MANAGEMENT MIGHT USE 5 THESE . RESUMES- AND PROPOSAL AS A BASIS FOR TAKING .
.1 6 RETALIATORY ACTION.AGAINST YOU AND THAT'S.WHY YOU THREW .
7 THEM AWAY? 8- A I BELIEVE THAT THOUGHT ENTERED MY MIND, YES. i 9 Q CAN YOU THINK OF ANY OTHER REASON WHY YOU ! 10 THREW THEM AWAY?- I
.I 11- A NOT ATeTHE MOMENT.
I 12 Q DID YOU TALK TO ANYONE ABOUT THE DESIRABILITY i 1 13 0F THROWING THEM AWAY? 14 A N O T' THAT I CAN RECALL AT THIS MOMENT. 15' Q HOW ABOUT MR. KING SPECIFICALLY? DID-YOU l
'16 DISCUSS IT WITH;HIM?
17 A NOT THAT I.CAN RECALL AT THIS MOMENT. I 18 Q YOU WERE LOOKING TO FIND OTHER EMPLOYMENT OR ) 19 CONSIDER OTHER EMPLOYMENT AWAY FROM TMI IN THE LATTER PART 20 OF '82 AND THE SPRING OF '83, WEREN'T YOU, MR. PARKS? 21 MR. JOHNSON: IS THERE A FOUNDATION FOR THAT? 22 MR. HICKEY: IT'S A LEADING QUESTION. THE {
\
23 QUESTION -- HE CAN DENY IT IF IT'S NOT ACCURATE. l 24 THE WITNESS: COULD YOU RUN IT PAST ME AGAIN? 25 Q BY MR. HICKEY: SURE. i 11-199 i
1 WERE YOU LOOKING TO LEAVE TMI IN THE FALL OF 2 '82 AND THE SPRING OF '83, LOOKING FOR OTHER EMPLOYMENT, 3- OR CONSIDERING OTHER EMPLOYMENT? 4 A NO, SIR, I WAS NOT. 5 Q DID YOU PLAN TO STAY ON THERE INDEFINITELY? 6 A YES, SIR, 1 DID. IT WAS ONE OF THE MAJOR 7 MOTIVATING FACTORS FOR ME RETURNING TO TMI. 8 Q OF COURSE, I TAKE IT THAT YOUR SUBMITTING l 9 YOUR RESUME TO BEAVER VALLEY WOULD BE SOMEWHAT l 10 INCONSISTENT WITH AN INTENT TO STAY ON AT TMI? 11 A SIR, I'VE BEEN EMPLOYED AT MANY PLACES FULLY 12 INTENDING TO STAY AT MANY PLACES, THE SAME PLACE -- 13 STAYING AT THAT PLACE WHILE AT THE SAME TIME I WAS 14 SUBMITTING A RESUME SOMEWHERE ELSE. 15 Q I DON'T QUITE UNDERSTAND. WHY WOULD YOU DO 16 THAT? 17 A WELL, PEOPLE IN THE NUCLEAR INDUSTRY, OR AT 18 LEAST BACK WHEN I WAS IN THE NUCLEAR INDUSTRY, ALWAYS KEPT 19 FEELERS OUT BECAUSE THEY NEVER COULD TELL WHEN THEY MIGHT 20 GET A REAL GOOD JOB OFFER THEY COULDN'T TURN DOWN. 21 Q IF YOU GOT A REAL GOOD JOB OFFER, YOU WOULD 22 CONSIDER IT? 23 A WELL, IF I GOT A JOB 0FFER TO HAVE A 1 24 COMMISSION AT A NUCLEAR POWER PLANT IN THE OZARKS, I I 25 PROBABLY WOULD HAVE JUMPED ON IT BECAUSE -- I GUESS WHAT 11-200
1 l'M TRVING TO SAY,-l WAS NOT ACTIVELY PURSUING EMPLOYMENT 2 ELSEWHERE. 3 Q YOU DIDN'T SUBMIT YOUR RESUME TO ANY NUCLEAR 4 POWER PLANT IN THE OZARKS OR ANY PLACE OTHER THAN BEAVER 5 VALLEY, DID YOU, MR. PARKS? 6 A I DON'T RECALL WHO I MAY HAVE SUBMITTED MY l 7 RESUMES TO DURING THAT TIME PERIOD. ! 8 AT ONE POINT IN TIME, I BELIEVE I EVEN TALKED i
-9 TO BECHTEL MANAGEMENT ABOUT TRANSFERRING ME TO WOLF CREEK.
10 BUT I THINK THAT WAS BEFORE I WENT TO WORK FOR BECHTEL. I 11 WOULDN'T REALLY SWEAR TO IT AT THIS MOMENT. 1 12 Q PART OF YOUR SALARY SITUATION AT TMI DURING i 13 THE TIME PERIOD AFTER MAY 1982 WHEN YOU RETURNED WAS THAT, 14 IN ADDITION TO YOUR SALARY, YOU WERE PAID A PER DIEM i 15 ALLOWANCE, WERE YOU NOT? 16 A THAT'S CORRECT, SIR. 17 Q AND THAT'S A SUBSTANTIAL FINANCIAL ADVANTAGE 18 OVER NOT HAVING A PER DIEM ALLOWANCE, ISN'T IT? 4 l 19 A YES, SIR, IT IS. 20 Q WHAT KIND OF DIFFERENCE DID IT MAKE IN YOUR ; 1 21 SALARY, MR. PARKS? 22 A OH, I DON'T RECALL WHAT THE EXACT AMOUNT WAS 23 ANYMORE, BUT I BELIEVE IT WAS RIGHT AROUND A THOUSAND 24 DOLLARS A MONTH. 25 Q AND WAS THE PER DIEM NOT TAXABLE AS INCOME, 11-201 l
1 IF I RECALL? 2 A I BELIEVE SO, AS LONG AS YOU'RE ON A 3 SHORT-TERM' ASSIGNMENT. 4 Q WAS THE PER DIEM THAT YOU WERE RECEIVING AT 5 TMI EXPECTED.TO END AFTER A 12-MONTH ASSIGNMENT THERE7
- 6 A YES, SIR, IT'WAS.
7 Q' SO IF .YOU CAME IN MAY '82, ABOUT MAY '83 YOUR 8 PER DIEM, UNDER NORMAL CIRCUMSTANCES,.WOULD HAVE BEEN 9: TERMINATED? 10 A YES, SIR. 11 Q AND THAT WOULD HAVE REDUCED YOUR INCOME BY ;
- 12. WHATEVER.THE AMOUNT OF THE PER DIEM WAS?
13 A .YES, SIR, 14 AND REALIZING -- PROJECTING FORWARD THAT I
- 15. 'WAS GOING'TO SUFFER A THOUSAND DOLLARS A' MONTH PAY LOSS, I 16 STARTED MY OWN PRIVATE BUSINESS THAT MORE THAN REIMBURSED.
17 ME.FOR.THE AMOUNT OF MONEY I WOULD HAVE LOST IN THE CUT OF 18 PER DIEM AND WOULD HAVE ALLOWED ME TO STAY IN MIDDLETOWN,
~19 PENNSYLVANIA.
20 Q WHERE DID YOU START THIS BUSINESS? -21 A MIDDLETOWN, PENNSYLVANIA. .22 .Q WHEN? 23 A OH, IT WOULD HAVE BEEN SHORTLY AFTER I 24 RETURNED. PROBABLY DURING THE SUMMER. 25 Q WHAT WAS THE BUSINESS? 11-202
l 1 A I BOUGHT AND RESOLD WICKER. 2 YOU SAID WICKER? l l Q 1. 3 A WICKER, YOU KNOW, LIKE FURNITURE, THAT TYPE I 4 0F THING. BOUGHT IT FROM IMPORTERS AND SOLD IT TO THE . 5 PUBLIC. I l 6 Q LET ME ASK YOU TO JUMP BACK CHRONOLOGICALLY. 7 EVEN BEFORE YOU HAD MISS RITTLE TYPE THESE RESUMES AND i 8 THIS PROPOSAL, YOU HELPED QUILTEC GET STARTED AT SHOREHAM, ) i 9 DIDN'T YOU, MR. PARKS? l l , 10 A YES, SIR. IF IT HAD NOT BEEN FOR MY 11 ACTIVITIES, QUILTEC WOULD NEVER HAVE HAD A JOB AT 12 SHOREHAM. l l 13 Q WHAT DID YOU DO TO ASSIST THEM? 14 A WHEN I WAS READY TO LEAVE SHOREHAM, THE 15 ASSISTANT STARTUP TEST MANAGER OR THE TEST MANAGER ASKED 16 ME IF 1 KNEW OF SOMEONE THAT HE COULD REPLACE ME WITH. I l 17 AND I TOLD HIM, WELL, I KNEW A GENTLEMAN THAT HAD HIS OWN 1 18 COMPANY WHO WOULD PROBABLY CONSIDER IT, AND THAT WOULD BE 19 BEN SLONE. 20 SO BEN SLONE AND THIS GUY TALKED, AND THEY 21 MORE OR LESS REACHED A VERBAL AGREEMENT. AND THAT 22 GENTLEMAN TOLD ME THAT IF I COULD GET A P.O. APPROVED 23 BEFORE I LEFT, HE'D SIGN IT. SO 1 G01 A P.O. APPROVED FOR 24 HIM BY TAKING IT THROUGH THE REQUISITE CHAIN OF COMMAND 25 THERE AT SHOREHAM. 50 BEN SLONE WENT TO WORK AT SHOREHAM 11-203 __-______-_-________a
1 AS QUILTEC. 2 Q AT THE TIME YOU WERE DOING THAT, 1 ASSUME YOU 3 WERE AWARE OF MR. KING'S INVOLVEMENT IN QUILTEC, WERE YOU 4 NOT? 5 A I THINK SOMEWHERE BACK IN 1981 OR 1982 q 6 BEN SLONE AND'I HAD A CONVERSATION THAT LEFT ME WITH THE 7 BELIEF THAT LARRY KING MAY HAVE BEEN INVOLVED IN QUILTEC. 8 Q IS IT YOUR TESTIMONY THAT AT THE TIME YOU j i 9 HELPED GET QUILTEC ENSCONSED AT SHOREHAM, THAT YOU.DIDN'T I 10 KNOW WHAT MR. KING'S STATUS WAS IN THE. COMPANY? I 11 A THAT'S BASICALLY TRUE. I WAS NOT 100 PERCENT l I 12 CERTAIN OF WHAT LARRY KING'S POSITION WAS IN THE COMPANY. I 13 Q DID YOU EVER ASK MR. SLONE? 14 A I DON'T RECALL, AT THIS MOMENT, IF BEN AND 1 15 EVER DISCUSSED THAT. 16 Q EVEN IF YOU WEREN'T 100 PERCENT SURE, WHAT I 17 DID YOU UNDERSTAND WAS MR. KING'S POSITION IN THE COMPANY?
)
18 A AT THIS POINT IN TIME, I REALLY COULDN'T SAY. l 19 HE'D ONLY PUT UP THE MONEY, YOU KNOW, AND LIKE PERSONAL j 20 GUIDANCE, THAT TYPE OF THING. 1 21 Q DO YOU RECALL SPEAKING TO A MR. TOM I I 22 PALANTONIO AT THE SHOREHAM FACILITY ABOUT BRINGING SLONE I l 23 AND QUILTEC ON BOARD? ) i 24 A THAT COULD HAVE BEEN THE GENTLEMAN'S NAME. I I 25 Q RECOGNIZE THE NAME, DON'T YOU? l l 11-204 l
l
- 1. A PALANTONIO, I RECOGNIZE THE NAME. IF THAT'S 2 THE SAME GENTLEMAN OR NOT, I REALLY COULDN'T TELL YOU AT !
3 THIS PolNT IN TIME. 4 Q WHO DID YOU WORK FOR WHEN YOU WERE AT 5 SHOREHAM? WHO WERE YOUR SUPERVISORS, 1 MEAN? I 6 A DENNIS DURAND OR SOMETHING LIKE THAT, I l 1 7 .BELIEVE. BUT THAT'S REALLY -- THAT'S JUST A GUESS. j i 8 Q WELL, MR. PALANTONIO WAS SOMEONE WHO HAD A j l 9 POSITION THAT YOU CAME IN CONTACT WITH AT SHOREHAM7 I l 10 A MR. PALANTONIO WAS SOME SORT OF OFFICIAL I i 11 WITHIN THE STARTUP. ORGANIZATION. WHETHER HE WAS MY DIRECT { 12 SUPERVISOR OR NOT, 1 DON'T REALLY RECALL. ONE THING THAT 13 DOES STICK IN MY MIND IS DENNIS DURAND. I 14 Q I'M SORRY, I CAN'T HEAR YOU.
]
15 A I'M SORRY. THAT'S THE ONE THING THAT STICKS 16 IN MY MIND IS DENNIS DURAND. BUT THAT MAY OR MAY NOT BE 17 THE GENTLEMAN THAT I TALKED TO REGARDING BEN SLONE. 18 Q WHEN YOU WERE AT SHOREHAM, YOU WERE THERE AS l 1 19 AN EMPLOYEE'0F NUS, WERE YOU NOT, MR. PARKS? l 20 A THAT'S CORRECT. 1 21 Q AND NUS WAS PROVIDING ENGINEERING AND OTHER l 22 SERVICES THROUGH PEOPLE LIKE YOURSELF TO THE LICENSEE, 23 LONG ISLAND LIGHTING COMPANY? 24 A THAT'S CORRECT. 25 Q WAS NUS IN THE NATURE OF A BODY SHOP OR JOB 11-205 i
1 -SHOP ON SITE THAT PROVIDED PERSONNEL? 2 A JUST ABOUT -- WELL, I GUESS THEY WOULD FIT 3 THOSE DESCRIPTIONS OF THAT, YES, l 4' (MR.' RICHARDSON HAS LEFT THE DEPOSITION l 1 5 PROCEEDINGS.) i 6- Q BY MR. HICKEY: ARE YOU NOT COMFORTABLE WITH 7 THAT DESCRIPTION?. 8 A THEY WOULD PROBABLY BE LESS COMFORTABLE WITH-9 THAT DESCRIPTION THAN I AM.
- 10. Q YOU KNEW A GENTLEMAN AT SHOREHAM NAMED !
l 11 RENE PARADISE WHO ALSO WAS INVOLVED WITH THE BODY SHOP, 12- DIDN'T YOU, MR. . PARKS? 13 A IF I -- RENE PARADISE WAS THE BODY SHOP. i 14 Q DID YOU RECOMMEND BEN SLONE AND QUILTEC TO l L .15 MR. PARADISE AS A POSSIBLE WAY OF GETTING SLONE AND 16 QUILTEC IN THE LILCO JOB 7 'l
- i
'17 A I BELIEVE'THAT WAS DISCUSSED BETWEEN ME AND j 1
18 THE LILCO OFFICIAL AS A MEANS OF HAVING ME REPLACED AND 1 19 SHORTENED THE AMOUNT OF PAPERWORK THAT WOULD BE REQUIRED l 20 TO GET THE P.O. APPROVED, YOU KNOW, TO BRING SOMEBODY ELSE 21 ON. 22 Q AT SHOREHAM, WHEN YOU WERE THERE, THE NEED TO 23 HAVE SOME HELP IN GETTNG THE PAPERWORK APPROVED WAS CAUSED 24 IN PART BY THE FACT THAT THERE WERE ALREADY A NUMBER OF 25 CONTRACTORS OR JOB SHOPS ON SITE; ISN'T THAT RIGHT? 11-206 i l
1 A- THERE WERE A LOT OF CONTRACTORS ON SITE AT 2 LILCO; THAT'S RIGHT. 3 Q AND TO GET APPROVAL TO BRING ON A NEW I-4 CONTRACTOR OR BODY SHOP LIKE QUILTEC TOOK SOME EFFORT, DID ! 5 IT NOT? j 6 A ALL I CAN TELL'YOU IS WHAT I REMEMBER. IT
.7 TOOK A COUPLE ~OF DAYS OF JUST, YOU KNOW, PUSHING PAPERWORK 8 THROUGH THE SYSTEM. NOW IF THERE WAS MORE, l'M NOT 9 QUALIFIED TO TELL YOU.
10 Q AND WHAT YOU DID IN THAT REGARD WAS 11 ENCOURAGED PEOPLE UP THE CHAIN OF COMMAND TO APPROVE THE l 12 PAPERWORK AND THEN GET IT MOVED TO THE NEXT PERSON AND GET i 13 THEM APPROVED? 14 A I THINK A MORE ACCURATE DESCRIPTION OF WHAT I L i W 15 DID WAS WALK THE PAPERWORK THROUGH RATHER THAN TAKE ITS l 16 NORMAL COURSE OF CIRCULATION. , 17 Q WELL, DID YOU PROVIDE INFORMATION TO THESE 18 VARIOUS APPROVAL PEOPLE ABOUT QUILTEC AND MR. SLONE ABOUT l 19 HIS QUALIFICATIONS AND SO ON? i 20 A I DON'T RECALL IF 1 DID OR NOT. l'M SURE IF 21 1 WAS ASKED ANY QUESTIONS, IF 1 HAD THE ANSWER, I PROVIDED 22 THOSE ANSWERS TO WHOEVER WAS ASKING THE QUESTIONS. 23 Q DID YOU TELL PEOPLE AT SHOREHAM THAT YOU WERE 24 CONNECTED WITH QUILTEC? 25 A NO. I THINK I PROBABLY INFORMED PEOPLE THAT 11-207
1 I WAS FRIENDS.WITH THE GUY THAT WAS QUILTEC. 2- Q HOW ABOUT THE PEOPLE AT BEAVER VALLEY, DID 3 YOU TELL THEM THAT YOU WERE CONNECTED WITH QUILTEC? 4 A NO. BECAUSE THAT'S THE ONLY PERSON I EVER 5 TALKED WITH WAS LEE HENDRICKSON, THAT I CAN RECALL IN ANY
-6 EVENT.
1 7 Q DID YOU HELP IN ANY OTHER QUILTEC MARKETING- l l 8 EFFORTS? 9 A AT ONE POINT IN TIME, ED KITLER ASKED ME TO l 10 HELP HIM GET IN TOUCH WITH BEN SLONE TO HAVE BEN SUBMIT A 11 PROPOSAL TO SOME UTILITY DOWN IN FLORIDA. -) 12 Q IS THAT THE SEMINOLE PROPOSAL? I 13 A I BELIEVE IT MIGHT HAVE BEEN. 1 THINK 1 HAT 14 MIGHT HAVE BEEN THE NAME OF THE COMPANY. 15 Q WHAT DID ED ASK YOUR HELP FOR? 16 A WELL, LIKE I SAY, IF I REMEMBER CORRECTLY AT 17 THIS MOMENT, HE ASKED ME HOW TO GO ABOUT GETTING IN TOUCH 18 WITH BEN BECAUSE HE WANTED TO PUT TOGETHER A PROPOSAL FOR 19 THIS COMPANY DOWN IN FLORIDA FOR HIM AND -- OR A BUDDY OR 20 TWO OF HIS THAT HAD SOME NEED TO BE FILLED OR FOR SOME 21 TYPE OF WORK TO BE FILLED DOWN THERE. SO I PICKED UP THE 22 PHONE AND CALLED BEN SLONE AT QUILTEC AND TURNED AROUND 23 AND HANDED THE PHONE BACK TO ED. 24 Q l SEE. YOUR CONTRIBUTION WAS THAT YOU 25 PROVIDED THE PHONE NUMBER FOR MR. SLONE THEN? 11-208 ___..._.___._____.______________d
'l 'A' MORE.OR LESSa 2 Q' DID YOU DO ANYTHING ELSE TO HELP MR. KITLER
'3 IN HIS EFFORTS TO GET QUILTEC INTERESTED IN THIS SEMINOLE 4 PROPOSAL?
5 A NOT AT THIS MOMENT. I THINK THAT WAS THE 6' EXTENT OF MY INVOLVEMENT WITH THAT.
'7 (L HOW ABOUT-QUILTEC MARKETING' EFFORTS AT.
8 'PALO VERDE, DID YOU ASSIST IN THOSE IN ANY WAY? 9 A NO, SIR. IN FACT I WAS UNAWARE THAT THEY 10 APPROACHED ANYBODY AT PALO VERDE.
'l 11 Q DID YOU EVER ATTEND ANY QUILTEC. BOARD L '12 ' MEETINGS, MR. PARKS?
13 A NO, SIR, I DID NOT. NOT-THAT I CAN RECALL. 14 Q DO YOU THINK IF YOU HAD ATTENDED A BOARD 15 MEETING.0'F QUILTEC, YOU'D BE LIKELY TO REMEMBER THAT? 16 A PROBABLY. l-17 Q DID YOU WRITE ANY LETTERS ON BEHALF OF l .. 18 QUILTEC? I'M TALKING ALL IN THE TIME PERIOD BEFORE YOU 19 WENT PUBLIC. 20 A NOT THAT I RECALL. 21 Q DID YOU MAKE ANY TELEPHONE CALLS ON BEHALF OF 22- QUILTEC? 23 A NOT THAT I CAN RECALL. 24 Q DID YOU EVER IDENTIFY YOURSELF AS A QUILTEC 25 REPRESENTATIVE? 11-209
1- .A NO, SIRO 2 Q DID YOU.EVER? 3 A NOT THAT I CAN RECALL. 4 Q DO YOU HAVE ANY QUILTEC BUSINESS CARDS OR I I 5 STATIONERY? j 6 A 1 HAD SOME QUILTEC BUSINESS CARDS LARRY KING ; i 7 GAVE TO ME AS A GIFT. I 8 Q- WHEN WAS THAT? 9 A HAD -- OH, PROBABLY RIGHT ABOUT THE SAME TIME f 1 10 HE ASKED ME TO GET THE TYPING DONE, RIGHT AFTER BEN SLONE 11 WENT TO WORK AT SHOREHAM. 12 Q WHAT DID THE BUSINESS CARD SAY? 13 A " CONSULTANT." j 14 Q HAD YOUR NAME ON THEM? 15 A YES. AND 1 TOLD LARRY KING AT THE TIME I i 16 THOUGHT IT WAS IMPROPER BECAUSE I WASN'T EMPLOYED BY I l 17 QUILTEC. AND HIS RESPONSE TO ME WAS SOMETHING Au S THE l j 18 LINES THAT, YOU KNOW, HE WAS JUST DOING IT TO SHOW HIS 19 APPRECIATION FOR ME HELPING BEN OUT. I 20 Q LET ME UNDERSTAND. , 21 TO SHOW HIS APPRECIATION TO.YOU FOR HELPING
.22 BEN SLONE, YOU MEAN, GET THE JOB AT LILCO?
23 A YES. 1 24 Q MR. KING GAVE YOU A PRESENT, RIGHT, A GIFT?
]
25 A RIGHT. HE JUST GAVE ME A BOX OF BUSINESS 11-210 i 1 1
. _ _ _ _ _ _-______--_-_-_--___-______N
1 CARDS..
'2 Q. THE GIFT-WAS A BOX OF BUSINESS CARDS THAT 3 SAID " RICHARD PARKS, CONSULTANT FOR QUILTEC"?
4 A NO. IT SAYS "QUILTEC." l 5 Q- WELL, IT SAID "QUILTEC" ON THE BUSINESS l I 6 CARDS? I 7 A I BELIEVE IT DID, YES. { l 8 Q I DON'T UNDERSTAND WHAT WAS WRONG WITH MY l 9 STATEMENT.. IT ISN'T FOR QUILTEC. IT SAYS "QUILTEC, INC., , l 10 CONSULTANT, RICHARD PARKS"? i 11 A NO. 12 IF 1 REMEMBER CORRECTLY IT HAD THE QUILTEC ] I 13 LOGO, OKAY, W H I C H_, IF 1 REMEMBER CORRECTLY, WAS SOME SORT < 14 0F A QUILL PEN, AND HAD MY NAME ON IT AND DOWN AT THE 15 BOTTOM SAID " CONSULTANT," WHICH TO ME MEANS "I AM 16 EMPLOYED." I WAS A CONSULTANT TO THE COMPANY. AND I 17 WASN'T. i 18 Q WHY WERE YOU NOT? 3 1 19 A BECAUSE THE ADVICE OR INFORMATION I EVER 20 HELPED THOSE GUYS WITH WAS JUST STRICTLY OUT OF THE FACT 21 THEY WERE MY FRIENDS BECAUSE I NEVER RECEIVED ANY 22 REMUNERATION FOR ANY OF MY, QUOTE, UNQUOTE, " WORK" ON 23 THEIR BEHALF. l 24 Q WHAT DID YOU SAY TO MR. KING WHEN HE GAVE YOU 25 THIS GIFT? 11-211 i I
1 A JUST.WHAT'I HAVE AL R E AD Y ' S A'I D . I DIDN'T 2 THINK-IT WASLPROPER. I WASN'T AN EMPLOYEE OR CONSULTANT 3' IN QUILTEC..
-j 4 Q WHAT DID YOU DO WITH THE CARDS? j J
l 5 A 'I. THREW THEM IN MY. DESK AT WORK. 6- Q- WHY DID YOU DO THAT, MR. PARKS? l l 7 A WELL,'I.DIDN'T'WANT TO OFFEND THE. GUY BY j 8 THROWING THEM AWAY. I DIDN'T KNOW WHAT ELSE TO DO WITH l i 9 THEM. I DIDN'T U3E THEM. ; 10' :Q WAS MR, KING THERE WHEN YOU THREW THE CARDS 11 IN YOUR DESK AT WORK? I 12 A I DON'T BELIEVE HE'WAS. 13 IF I REMEMBER CORRECTLY, THE.-- 'SAY THE WHOLE' 14 EVENT HAPPENED AS I WAS WALKING OUT.0F THE BRICK-ADMIN 15 BUILDING, AND LARRY KING WAS PULLING UP. BY VIRTUE OF HIS 16 POSITION, HE COULD PARK THERE. -AND HE MOTIONED FOR ME OR 17 HOLLERED FOR ME. AND I WALKED OVER. AND HE SAYS "HERE" 18 -AND HANDED ME THIS BOX OF BUSINESS CARDS. AND I OPENED 19 THEM UP AND THAT'S WHAT THEY WERE. 20 THEN THE DISCUSSION WE ALREADY TALKED ABOUT 21 HAPPENED, AND I WALKED ON DOWN TO MY DESK, WHICH AT THAT 22 TIME WAS DOWN AT THE GREEN ADMIN BUILDING. AND I JUST PUT 23 THEM IN THE DRAWER IN MY DESK AND LEFT THEM THERE. 24 Q DID YOU TELL MR. KING WHAT YOU WERE GOING TO 25 DO:WITH THE CARDS? 11-212
l 1 A NO. 2 Q WHAT DID MR. KING SUGGEST YOU DO WITH THE 3 CARDS? 4 A NOTHING. 5 Q DIDN'T HE INDICATE TO YOU IN SOME WAY THESE 6 WERE FOR YOU TO USE, MR. PARKS? 7 A I BELIEVE, SIR, I HAVE ALREADY ANSWERED THAT 8 QUESTION; THAT HE WAS MORE OR LESS -- AT LEAST LEFT ME 9 WITH THE IMPRESSION THAT WAS JUST HIS WAY OF SAYING 10 "THANKS FOR HELPING BEN OUT." 11 Q WELL, l'M ASKING YOU WHETHER MR. KING DIDN'T 12 INDICATE TO YOU IN SOME FASHION WHAT HE EXPECTED YOU TO DO 13 WITH THE CARDS? 14 A NO, SIR, HE DID NOT. 15 Q JUST GAVE THEM TO YOU AND DIDN'T GIVE ANY 16 CLUE WHAT USE YOU WERE TO MAKE OF THEM? 17 A THAT'S CORRECT. 18 Q AND YOU TOOK THE BOX OF BUSINESS CARDS. DID 19 YOU TAKE THE WHOLE BOX AND JUST THROW IT IN YOUR DESK OR 20 MOST OF IT OR SOME OF IT? 21 A I PUT THE BOX IN MY DESK. 22 Q WHEN WAS THAT, THAT KING GIVE YOU THIS GIFT? 23 A MIDDLE OF THE YEAR, PROBABLY -- IT WAS BEFORE 24 FALL OF 1982. 25 Q SO YOU CAME BACK TO THE ISLAND MAY OF '82. 11-213 I
r
~
1- IT.WOULD BE'IN THE SUMMER OF'MAY OF '82? l 12 A PROBABLY.- j
.q 3 Q- DID YOU GIVE ANY THESE QUILTEC BUSINESS CARDS l 1
4 TO ANYONE, MR. PARKS? i 5 A 1 BELIEVE 1 GAVE ONE TO MY GIRL FRIEND, BUT I
- 6. DON'T RECALL GIVING THEM TO'ANYBODY IN THE BUSINESS WORLD. {
7' Q' ONE TO MISS-QUACKENBUSH?- 8 A RIGHT. 9 Q AND YOUR. TESTIMONY IS THAT YOU DON'T RECALL 10 WHETHER YOU GAVE ANY TO ANYONE IN THE BUSINESS WORLD?. i 11 A I DON'T.BELIEVE I DID, NO. 12 Q HOW LONG DID THE CARDS STAY IN YOUR-' DESK? 13 A I THINK THEY'RE -- JUST ABOUT RIGHT UP TO 14- WHEN I LEFT TMI. I 1 15 Q DESCRIBE THE CIRCUMSTANCES WHEN YOU TOOK THEM 16 OUT. 17 A I TOOK THEM OUT AND THREW THEM AWAY WITH THE. ! 1 18 REST OF THE QUILTEC STUFF. l 19 Q THIS WAS BEFORE YOU WERE INTERVIEWED'BY : 20 MR. HOFMANN? 21 A I THINK I HAVE ALREADY TOLD YOU BEFORE 1 22 DON'T RECALL EXACTLY WHEN I THREW STUFF AWAY, BUT I l i 23 BELIEVE THE TIME LARRY KING WAS ESCORTED OFF THE SITE. I l l 24 Q HAVE YOU EVER TOLD ANYONE BEFORE TODAY, ) I 25 MR. PARKS, OTHER THAN YOUR LAWYER, OF COURSE, MR. KING HAD j
. 11-214
1 GIVEN VOU QUILTEC BUSINESS CARDS THAT YOU KEPT UNTIL JUST 2 BEFORE -- UNTIL YOU THREW THEM AWAY WITH THE RESUME'AND 3 THE BEAVER VALLEY PROPOSAL? ! 4 A I DON'T KNOW IF 1 -- OR AT THIS MOMENT. IN 5 TIME. I CAN'T RECALL TELLING ANYBODY THAT OR NOT. 6 Q YOU DON'T REMEMBER IT APPEARING ON ANY OF 7 YOUR NRC STATEMENTS WHERE THEY WERE ASKING YOU ABOUT YOUR 8 CONNECTION WITH QUILTEC? 9 A I DON'T. BUT AT THE PRESENT TIME, I CAN'T 10 RECALL IF IT'S IN ANY OF MY NRC STATEMENTS OR NOT. 11 Q WHEN YOU WERE TALKING TO THE NRC IN APRIL OR 12 MAY OF 1983 AND THEY ASKED YOU ABOUT YOUR QUILTEC 13 INVOLVEMENT,-DID YOU FORGET TO TELL THEM ABOUT THE 14 BUSINESS CARDS? 15 A I DON'T KNOW. OR 1 GUESS WHAT l'M TRYING TO 16 SAY, AT THIS PRESENT TIME I CAN'T RECALL IF I TOLD THEM OR l 1 17 NOT. i 18 Q WELL, DO YOU WANT TO LOOK AT YOUR STATEMENTS, 19 THEY'RE THERE IN FRONT OF YOU, AND SEE IF THERE'S SOME i i 20 REFERENCE IN THERE TO YOUR QUILTEC BUSINESS CARDS? YOU 21 MIGHT WANT TO LOOK. JUST SO YOU HAVE THE NUMBER, 37, 38, i 22 39 AND 40. BUT MOST OF YOUR QUILTEC INFORMATION 15 iN 23 EXHIBIT 39, MR. PARKS. 24 A OKAY. l 25 1 DON'T SEE ANYTHING SO FAR THAT REFERENCES l 11-215 i
1 IT. 2 Q I DON'T THINK YOU'LL FIND ANYTHING', 3 MR. PARKS. I 4 A YOU MAY BE RIGHT. 5 Q I BELIEVE YOU'RE TALKING ABOUT QUILTEC 6 BUSINESS CARDS, BUT I ALSO ASKED ABOUT QUILTEC STATIONERY. 7 DID YOU HAVE ANY'QUILTEC STATIONERY, AT THIS POINT IN 8 TIME, OTHER THAN THE STATIONERY YOU GAVE TO RITTLE TO TYPE 9 THE RESUMES ON? 10 A I BELIEVE THERE MIGHT HAVE BEEN SOME LEFT IN 11 THE PACKAGE I HAD, BUT I COULDN'T TELL YOU, AT THIS POINT 12 IN TIME, IF THERE WAS OR NOT. 13 Q YOU DIDN'T TAKE THE EXTRA QUILTEC STATIONERY 14 BACK TO MR. KING, DID YOU? 15 A I DON'T RECALL THAT I DlD, NO. I MIGHT HAVE 16 THOUGH. I DON'T'REALLY RECALL AT THE MOMENT. 17 Q DO YOU HAVE ANY RECOLLECTION WHEN YOU MET i 18 WITH THE LABOR DEPARTMENT, MR. FEINBERG, AFTER YOU FILED l 1 19 YOUR RETALIATION CLAIM TELLING MR. FEINBERG THAT YOU HAD j i 20 HAD SOME BUSINESS CARDS GIVEN TO YOU BY MR. KING WITH YOUR j i 21 NAME AND " CONSULTANT FOR QUILTEC" ON IT? ) l 22 A I THINK YOU'RE MISCHARACTERIZING WHAT THE i 23 BUSINESS (CARDS SAY. IT DID NOl SAY " CONSULTANT FOR 24 QUILTEC." IT JUST SAYS " CONSULTANT." i 25 Q AND "QUILTEC"? 11-216 :
'1; A 'RIGHT.
2 BUT TO ANSWER YOUR QUESTION, I CANNOT.TELL ! 1 3' YOU,.AT_THIS PRESENT TIME, IF MR. FEINBERG AND I DISCUSSED
'4 THAT-OR NOT'
)
- 5. Q I'M NOT SURE ABOUT THE. DISTINCTION THAT YOU N 6 :SEEM TO BE INSISTING ON. THE POINT YOU'RE MAKING IS THAT 7 THE CARD DIDN'T HAVE THE WORD "FOR" ON IT; IS'THAT RIGHT?
'8 A .THAT'S TRUE.
9 Q THE CARD INDICATED, DID IT NOT, THAT YOU' , 10 RICHARD PARKS, WERE A CONSULTANT FOR QUILTEC, DIDN'T IT? 11 A .UH-HUH. 12 Q DIDN'T'THE CARD INDICATE.TO ANYONE LOOKING AT - 13 IT THATl RICHARD PARKS WAS A CONSULTANT FOR THE QUILTEC 14 COMPANY? l 15 A NOT IN MY OPINION, IT DIDN'T, NO. '16 .Q WHAT DID.YOU MEAN WHEN YOU SAID A CARD SAID ( 17' "QUILTEC, RICHARD PARKS, CONSULTANT"? l i ~18 A JUST THAT, EXACTLY. I.TOOK IT AT FACE VALUE. 4 19 THAT CARD NO MORE MADE ME AN EMPLOYEE OR CONSULTANT, IN MY ! 20 OPINION, FOR QUILTEC THAN IF YOU GIVE ME ONE OF YOUR-21 FIRM'S BUSINESS CARDS WITH MY NAME AND THE WORD 22 " CONSULTANT" ON IT. IT WOULD NOT MAKE ME A CONSULTANT FOR 23 QUILTEC NO MORE THAN IT WOULD MAKE ME A CONSULTANT FOR 24 YOUR FIRM. ! 25 Q WELL, IF SOMEONE SAW A CARD THAT SAID MY LAW 11-217 l i
1 FIRM'S NAME AND " RICHARD PARKS, CONSULTANT," DO YOU 2 BELIEVE THEY MIGHT THINK YOU WERE A CONSULTANT EMPLOYED BY 3 MY LAW FIRM? 4 A THEY MIGHT; THEY MIGHT NOT. 5 Q WHAT WOULD YOU THINK IF YOb SAW THE CARD? 6 A l'D ASK THE PERSON. 7 Q YOU WOULDN'T MAKE A CONCLUSION BASED ON THE 8 CARD? 9 A TRUE. 10 Q THERE WAS AN NUS EMPLOYEE AT SHOREHAM -- 11 WELL, YOU KNEW TOM BULISCHECK, DO YOU RECOGNIZE THE NAME, 12 WHO IS THE SITE LEAD AT SHOREHAM7 13 A NO, 1 DO NOT REMEMBER THE NAME. 14 Q DO YOU REMEMBER TELLING SOMEONE WHO WORKED l 15 FOR NUS AT SHOREHAM IN THE SUMMER OF 1982, EITHER JUST 16 BEFORE YOU RETURNED TO TMI OR SHORTLY THEREAFTER, THAT YOU 17 WERE PART OF QUILTEC? l 18 A NO, SIR, 1 DO NOT. 19 Q DID YOU GO BACK UP TO SHOREHAM AFTER YOU 20 RETURNED TO EMPLOYMENT AT TMI IN MAY OF 1982? 21 A NO, SIR. 22 Q ON ANY OCCASION? 23 A NOT THAT I CAN RECALL, NOT AT THIS TIME. 24 Q ALL RIGHT. WITH THAT ADDITION THEN LET ME 25 ASK YOU TO FOCUS SPECIFICALLY ON BEFORE YOU LEFT SHOREHAM. l 11-218
1 VOU HAVE NO RECOLLECTION OF SAYING TO MR. BULISCHECK OR 2
'ANYONE ELSE AT.SHOREHAM THAT YOU WERE PART OF QUILTEC?
3 A NO, I DO NOT.
- 4. Q DID'YOU HAVE ANY INDICATION FROM MR. KING, l 5 WHEN HE GAVE YOU THE CARD, MR. PARKS, ABOUT WHAT IT WAS l
l 6 THAT HE BELIEVED YOU HAD DONE THAT WARRANTED LISTING YOU l 7; AS A CONSULTANT ON A BUSINESS CARD? 8 A GETTING THE JOB FOR BEN SLONE UP AT SHOREHAM. , 9 THAT WAS THE IMPRESSION I GOT FROM HIM. 10 Q DID MR. KING EVER TALK TO YOU ABOUT DOING l 11 OTHER THINGS IN THE FUTURE FOR QUILTEC? 12 A WELL, YEAH. HE ASKED ME TO GET THAT TYPING 13 DONE. j 14 Q OTHER THAN THAT? 15 A NOT THAT I CAN RECALL AT THE MOMENT, BUT HE 16 MAY HAVE. HE MAY HAVE TALKED TO ME ABOUT OTHER THINGS i 17 THAT HAD BEEN GOING ON. I KNOW -- LET ME REPHRASE THAT. 4 18 I CAN RECALL THAT LARRY, ON OCCASIONS, ) l 19 MENTIONED TO ME ABOUT, YOU KNOW, MONEY THAT BEN WAS MAYBE I I 20 BEING AND -- You KNOW, HOW THEY WERE REARRANGING THEIR 21 COMPANY AND ALL THAT. BUT AT THAT TIME FRAME, I COULDN'T I 22 REALLY PINPOINT. 23 Q I'M SORRY, I THOUGHT YOU FINISHED. I 24 A l'M SAYING THE TIME FRAME THOSE CONVERSATIONS 25 TOOK PLACE, I COULDN'T REALLY PINPOINT. Il-21Y I l l l
1 Q DID YOU EVER TALK TO MR. KING ABOUT A-l 2 POSSIBLE' ROLE FOR.YOU IN'QUILTEC IN THE FUTURE? l 3 A NOT.THAT'l'CAN RECALL. 4 Q DID YOU EVER TALK TO HIM ABOUT THE 5~ POSSIBILITY.0F YOU BEING ALLOWED TO PURCHASE STOCK IN 6- QUILTEC? 7 A NOT-THAT ! CAN RECALL. 8 Q- DO YOU REMEMBER GIVING A' COPY OF'YOUR QUILTEC 9 BUSINESS CARD TO ED KITLER, MR. PARKS? I . I 10.. A 'I THINK ED K!TLER MAY HAVE HAD ONE OF THE 11 -CARDS. l ( L 12 Q WHEN DID YOU GIVE IT TO HIM? l l 13 A PROBABLY THE'SAME DAY I THREW THE BOX IN MY . I 14 DESK. 15 Q 'WHY DID YOU GIVE IT TO HIM? 16 A I THINK HE SAW THEM AND ASKED ME WHAT THEY 17 WERE AND 1 SHOWED HIM. 18 Q DID HE ASK FOR ONE? 19 A I DO NOT REALLY RECALL, AT THIS MOMENT, OR IF 20 I JUST "HERE, TAKE IT, GO AHEAD." 21 Q WHY DID YOU WANT TO GIVE MR. KITLER A COPY OF 22 YOUR QUILTEC BUSINESS CARD? l 23 A THAT IMPLIES I HAD A SPECIFIC REASON TO GIVE ! 24 IT TO HIM, AND l' DON'T RECALL MAKING SUCH A STATEMENT. 25 Q WELL, YOU HAD A REASON FOR GIVING HIM THE L 11-220 l i
1 CARD? f 2_ A NO, NOT SPECIFICALLY, NOT ONE THAT 1 CAN 3 RECALL, AT THIS MOMENT ANYWAY. 4 Q WHEN IS THE LAST TIME YOU SPOKE TO ED KITLER, j 5 MR. PARKS? i 6 A I THINK PROBABLY LIKE A WEEK OR SO SINCE I J 7 WAS SUSPENDED. l 8 Q NOT SINCE? j
.i 9 A NO.
l l 10 Q HAVE YOU HAD ANY INDIRECT COMMUNICATION ) I j 11 WITH MR. KITLER MORE RECENTLY THAN A WEEKHOR 50 AFTER YOU I I 12 WERE SUSPENDED? I l 13 A WHAT DO YOU MEAN BY " INDIRECT"? l 14 Q WHERE SOMEONE HAS GIVEN YOU A MESSAGE TO ) l 15 MR..KITLER OR YOU HAVE GIVEN A MESSAGE TO MR. KITLER? 16 A NO. IF I RECEIVED A MESSAGE INTENDED FOR 17 ME -- INTENDED FOR ED KITLER, THEN l'M UNAWARE UF IT. 18 Q l TAKE IT YOU HAVEN'T ANY WRITTEN 19 CORRESPONDENCE OR WRITTEN COMMUNICATION SHORTLY AFTER YOU 20 WERE SUSPENDED? 21 A THAT'S TRUE, I HAVE NOT. 22 Q DID YOU TELL MR. JOHNSON BEFORE YOU TESTIFIED 23 DURING THE DEPOSITION THIS AFTERNOON THAT YOU HAD A 24 QUILTEC BUSINESS CARD? 25 A I -- 11-221
l 1 MR.. JOHNSON: I DON'T THINK HE HAS TO ANSWER THAT 2 QUESTION. 3 MR. HICKEY: YOU'RE NOT HIS COUNSEL. THAT'S NOT ! 4 PRIVILEGED. 5 MR. JOHNSON: IT'S OUR POSITION THAT WE WILL d 6 REPRESENT THAT WE DON'T REPRESENT MR. PARKS AS HIS I 7 PERSONAL COUNSEL, BUT HE'S OUR WITNESS. AND.0UR ! 1 8 COMMUNICATIONS ARE FOR THE PURPOSE OF OUR LITIGATION IN 9 THIS MATTER, AND IT SEEMS TO ME IT'S PROTECTED BY.THE 10 ATTORNEY-CLIENT PRIVILEGE. i 11 MR. HICKEY: HE'S NOT YOUR CLIENT. HE'S NOT l 12. PROTECTED BY ATTORNEY-CLIENT PRIVILEGE. 13 THE WITNESS: 1 THINK HE MEANT WORK PRODUCT. 14 MR. JOHNSON: WE DON'T REPRESENT MR. PARKS IN HIS 15 ' PERSONAL' CAPACITY, BUT WE REP' RESENT HIM IN THE SENSE THAT 16 HE IS OUR WITNESS IN THE BRINGING OF THIS PROCEEDING. I 17 MR. HICKEY: HE'S NOT YOUR WITNESS; HE'S A WITNESS 18 WHO'S CALLED TO TESTIFY -- WELL, LET'S SEE IF WE CAN GET 19 IT STRAIGHT. 20 Q BY MR. HICKEY: I HAVE ASKED YOU A QUESTION, 21 MR. PARKS. THE QUESTION IS, BEFORE YOU TESTIFIED HERE 22 THIS AFTERNOON, A FEW MOMENTS AGO, IN RESPONSE TO MY 23 QUESTIONS, THAT MR. KITLER GAVE YOU A BUSINESS CARD, DID I 24 YOU TELL THAT INFORMATION TO MR. JOHNSONS I l 25 MR. JOHNSON: l'LL INSTRUCT THE WITNESS NOT TO 11-222 l j
I 1 ~ ANSWER,THE QUESTION ON THE BASIS OF THE ATTORNEY-CLIENT l I 2 PRIVILEGE. 1 3 MR. HICKEY: I. ASSUME IF THIS WITNESS IS YOUR I 4 CLIENT AND -- THAT'S WHAT YOU'RE SAYING? YOU SAID HE'S q 5 NOT YOUR CLIENT. 6 MR. JOHNSON: WE DON'T REPRESENT HIM AS HIS 7 PERSONAL COUNSEL BUT -- 8 MR. HICKEY: THAT MEANS HE'S NOT YOUR CLIENT. ARE 9 YOU TELLING ME THAT MR. PARKS IS OR IS NOT YOUR CLIENT AND 10 THAT YOU HAVE OR HAVE NOT AN ATTORNEY-CLIENT RELATIONSHIP 11 WITH HIM?. 12 MR. JOHNSON: FOR PURPOSES OF THIS CASE, HE IS OUR H 13 CLIENT. I 14 MR. HICKEY: AND YOU'HAVE NO RETAINER AGREEMENT 15 WITH MR. PARKS 7 16 MR. JOHNSON: OF COURSE NOT. 17 MR. HICKEY: HAVE YOU DISCUSSED WITH MR. PARKS THE 18 CIRCUMSTANCE OF YOUR REPRESENTATION WITH HIM? l 19 MR. JOHNSON: WE'VE STATED OUR POSITION. I HAVE I 20 STATED MY POSITION, AND I AM INSTRUCTING THE WITNESS NOT ' 21 TO ANSWER THE QUESTION. IF /0U HAVE A PROBLEM WITH 22 THAT -- 23 MR. HICKEY: OKAY. YOU DO RECALL, OF COURSE, THAT l
'24 AT THE START OF THE DEPOSITION MR. PARKS INFORMED US THAT I 25 HE WAS APPEARING HERE UNREPRESENTED AND THAT MISS ZURAS 11-223 i
l' WAS HIS ATTORNEY AND THAT SHE WAS AVAILABLE ON TELEPHONE 2 CALL,=BUT.HE WAS APPEARING'HERE WITHOUT COUNSEL. DID YOU
'3 . HEAR MR. PARKS,SAYiTHAT, COUNSEL, BECAUSE WE CAN GO BACK.
4 AND LOOK IN THE RECORD -- IN YOUR RECORD. 5: MR. JOHNSON: I RECOLLECT THAT CONVERSATION, SURE. 6 MR. HICKEY: HAS THE SITUATION CHANGED SINCE 7 MR. PARKS MADE THAT STATEMENT? 8 MR. J O H N S O N': NO, I THINK IT'S'NO SECRET THAT WE'RE 9 REPRESENTING.HIM -- MR. PARKS IN THIS. PROCEEDING AS AN 10 ELEMENT OF THE STAFF'S CASE IN.THIS MATTER. 11 MR. HICKEY: WELL, THE NOTION THAT THE' STAFF 12 REPRESENTS ANY WITNESS THAT THE STAFF BRINGS IS A NEW ONE l 13 TO ME. I SIMPLY NEVER HEARD OF THAT. 14 MR. JOHNSON: YOU'RE TALKING ABOUT THE. ATTORNEY'S l 15 CONTACT IN PREPARATION OF THIS STAFF'S CASE FOR THE ' 16 PURPOSES OF THAT -- THAT FOR THAT PURPOSE HE IS CONSIDERED 17 TO BE OUR' CLIENT. , 18 MR. HICKEY: WELL, I UNDERSTAND YOUR VIEW. LET ME 19 ASK ONE MORE POINT ~JUST SO WE GET IT GET CLEAR ON THE 20 RECORD. 21 I-TAKE IT THAT IN THE ORDINARY CIRCUMSTANCE 22 WHEREIN AN ATTORNEY FEELS THAT HIS CLIENT HAS A PRIVILEGE 23 NOT TO ANSWER A -QUESTION, NORMALLY WHAT THE ATTORNEY DOES , I 24 IS ADVISE THE CLIENT ABOUT THE EXISTENCE OF THE PRIVILEGE l l 25 AND LET.THE CLIENT DETERMINE WHETHER HE WISHES TO INVOKE 11-224 l
1 l I 1 THE PRIVILEGE OR NOT. 2 I WANT TO ASK MR. PARKS ACCORDINGLY WHETHER 3- HE IS ELECTING NOT TO ANSWER MY QUESTION ON THE BASIS OF i 4 AN ATTORNEY-CLIENT PRIVILEGE THAT EXISTS WITH MR. JOHNSON. ) 5 MR. JOHNSON: 1 THINK THAT MISREPRESENTS THE 6 PRACTICE, AND 1 STILL INSTRUCT HIM NOT TO ANSWER. 1 7 MR. HICKEY: WHETHER HE WANTS TO OR NOT, IN OTHER 8 WORDS? 9' THE WITNESS: l'THINK I CAN PROBABLY OVERSIMPLIFY l 10 IT. I WILL CHOOSE NOT TO ANSWER THE QUESTION UNTIL SUCH 11 TIME AS I HAVE HAD AN OPPORTUNITY TO REVIEW THIS WHOLE 12 ARGUMENT YOU GUYS ARE HAVING HERE. I DON'T UNDERSTAND 13 WHAT'S GOING ON, 50 l'M NOT GOING TO ANSWER THE QUESTION. 14 Q BY MR. HICKEY: REVIEW IT WITH MISS ZURAS. 15 A WHOEVER I CHOOSE TO REVIEW IT WITH, SIR, IS 16 MY BUSINESS. I WILL TRY TO ANALYZE WHAT YOU GUYS ARE 17 ARGUING ABOUT. YOU HAVE THOROUGHLY CONFUSED ME. 18 Q WELL, LET ME TAKE JUST A BRIEF BREAK AND THEN 19 WE CAN COME BACK. 20 (RECESS.) 21 Q BY MR. HICKEY: MR. PARKS, WHEN YOU INFORMED 22 US ABOUT YOUR HAVING HAD THESE QUILTEC BUSINESS CARDS, 1 23 ASKED YOU IF YOU HAD GIVEN THE CARDS TO ANYONE, AND I 24 UNDERSTOOD YOU TO SAY INITIALLY THAT YOU DIDN'T REMEMBER 25 GIVING THE CARDS TO ANYONE. WAS THAT YOUR TESTIMONY? DO 11-225
1 VOU RECALL? 2 A THAT'S.WHAT I BELIEVE I TESTIFIED TO, YEAH. i 1
-3 Q WHAT BROUGHT MR. KITLER TO YOUR MIND?
4 'A YOU JARRED MY MEMORY WHEN YOU ASKED _ME ABOUT j 5 IT. 6 Q BUT YOU HADN'T THOUGHT OF HIM BEFORE? l 7 A NO. i 8 Q IS THERE -- 9 A NOT AT THE MOMENT YOU ASKED ME THE FIRST i 10 TIME. j 11 Q IS THERE ANYONE ELSE THAT YOU CAN THINK OF 1 12 THAT YOU MIGHT HAVE GIVEN A CARD TO BESIDES MR. KITLER? j
- 13 A NOT THAT I CAN THINK OF AT THIS MOMENT.
l 84 MR. JOHNSON: ALSO THE RECORD WILL SHOW THAT HE l l 15 STATED THAT HE GAVE HIS CARD TO NO ONE ELSE. , 4 f 16 MR. HICKEY: HIS GIRL FRIEND. j 17 Q BY MR. HICKEY: I MEAN OTHER THAN 18 MISS QUACKENBUSH AND MR. KITLER, 19 A NO, NOT THAT 1 CAN RECALL AT THIS TIME. i 20 Q WHEN WAS THE LAST TIME YOU SPOKE TO 21 MR. SLONE, MR. PARKS? 22 A OH, MAYBE A YEAR OR TWO AGO. 23 Q WHAT WAS THE OCCASION? DO YOU RECALL? 24 A NO. 1 CAN JUST RECALL TALKING TO HIM OVER 25 THE TELEPHONE. 11-226
'l i i
i
.1 Q YOU DON'T REMEMBER WHAT.IT WAS IN CONNECTION; 2: - W I T H 7: ,
3- A NO.
'4 Q- ARE YOU STILL FRIENDLY WITH MR. SLONE?
5< A- I HAVEN'T TALKED TO BEN SLONE, L I K E,. I .S A I D , 1
'6 IN OVER A YEAR OR TWO.
7j Q THE LAST TIME YOU TALKED TO HIM, WAS YOUR 8 CONVERSATION CORDIAL?
.9 A' IT. APPEARED TO BE.
10 Q DO YOU RECALL, MR. PARKS, ON THE EVENING THAT l
' ll LARRY KING WAS SUSPENDED YOU WENT TO THE SITE WITH i
12 MISS WENGER?
- 13 A YES, I DO.
~14: Q THAT WAS AT MR. KING'S. REQUEST?
- 15 A YES, IT WAS.
16 Q HOW DID.MR. KING CONTACT YOU? 17 A BY THE TELEPHONE. 18 Q WHAT DID HE ASK YOU TO DO? 19 A ASKED ME IF I COULD GET JOYCE. I BELIEVE HE I 20 ASKED ME IF I COULD GET JOYCE, OR MIGHT HAVE JUST ASKED ME 21 TO GO DOWN AND GET STUFF OUT OF HIS OFFICE. 22- MR.-JOHNSON: I'M GOING TO -- 23 MR. HICKEY: I COULDN'T HEAR THE WITNESS' ANSWER. 24 LET ME GET THE ANSWER REPEATED SO I CAN UNDERSTAND YOUR 25 OBJECTION. 11-227 -__m.-m__ l__w__._____'.. __
1 WOULD YOU READ THE ANSWER. THERE WAS j 2 AIRPLANE NOISE. 3 (WHEREUPON THE REPORTER READ THE ANSWER 4 APPEARING ON PAGE 227, LINES 19 THROUGH 21, INCLUSIVE.) 5 MR. . JOHNSON: I'M GOING TO OBJECT TO THIS LINE OF 6 QUESTIONING. THERE'S NO CONCEIVABLE RELEVANCE TO.THE 7 INFORMATION THAT YOU APPEAR TO BE AIMING AT PURSUANT TO 8 THE SUBSTANCE OF THIS CASE. I, AT NO TIME, IN ANY OF MY 9 DEPOSITIONS INQUIRED INTO ANYTHING RELATING TO THESE 10 MATTERS RELATING TO JOYCE WENGER OR THINGS RELATING TO 11' ACTIVITIES OF MR. PARKS IN THESE MATTERS. 12 MR. HICKEY: WELL, YOUR OBJECTION IS NOTED. THE 13 POINT OF THE INQUIRY IS, IF IT PUTS YOUR MIND AT EASE, IS 14 NOT MISS WENGER. THE WITNESS MENTIONED MISS WENGER WENT 15 WITH HIM. BUT NOTWITHSTANDING THAT, 1 DON'T THINK THAT 16 THE AREA 0F YOUR INQUIRY DEFINES THE APPROPRIATE SCOPE OF 17 THE CASE. 18 MR. JOHNSON: WELL, IT'S NOT A NOTICE OF VIOLATION. f 19 MR. PARKS' ACTIVITY AND THE RETALIATION AGAINST HIM FOR 20 THAT IS WHAT'S INVOLVED HERE. AND ALTHOUGH WE'VE AGREED 1 21 TO PRODUCE DOCUMENTS WITH REGARD TO MR. KING, AND THE 22 STAFF MADE INQUIRES OF DEPOSITIONS THAT IT TOOK REGARDING ; I 23 THE KNOWLEDGE, THE TIMING OF THE KNOWLEDGE OF MEMBERS OF { l 24 THE STAFF OF GPU-N AND BECHTEL AND TMI-2 CONCERNING i 25 QUILTEC AND ACKNOWLEDGE OF QUILTEC AND II-228
1 MR. KING, WE.NEVER WENT INTO THE SUBSTANCE O F, THESE -- HIS L l 2 -ACTIVITIES. THIS IS CLEARLY BEYOND THE SCOPE OF THE CASE. I 3 IF YOU -- 4 MR. HICKEY. YOU'VE STATED YOUR OBJECTION. 5 MR. JOHNSON: IT'S ALSO BEYOND THE SCOPE OF THE 6 PREHEARING CONFERENCE ORDER BY THE' PRESIDING OFFICER. i 7 AND I JUST WOULD SAY THAT WE'VE LIMITED TIME 8 HERE, AND I DON'T THINK IT'S PRODUCTIVE EITHER. 9 MR. HICKEY: WELL, LET ME RESPOND JUST BRIEFLY 10 WITHOUT WASTING TOO MUCH OF OUR LIMITED TIME. i- 11 1 THINK ONE ISSUE IN THIS CASE IS MR. PARKS' 12 INVOLVEMENT WITH QUILTEC. AND I THINK THAT THE MOTION OF 13 THE NOTICE OF VIOLATION THAT INDICATES THAT MR. PARKS WAS 14 IPPROPERLY HARASSED AND RETALIATED CONCERNING HIS QUILTEC 15 ACTIVITIES AS WELL AS YOUR INTERROGATION OF NUMEROUS l 16 WITNESSES ABOUT KNOWLEDGE OF QUILTEC ACTIVITIES MAKES l 17 QUILTEC ACTIVITIES RELEVANT, AND MR. PARKS' RELATION WITH 18 MR. KING AS WELL AS WITH MR. VONE AND OTHERS RELATES TO
- 19. HIS QUILTEC ACTIVITIES.
20 Q BY MR. HICKEY: WHAT WAS IT THAT MR. KING 21 ASKED YOU TO GET FOR HIM WHEN YOU SAY HE WANTED YOU TO GET 22 STUFF OUT OF HIS OFFICE, MR. PARKS? l 23 A CAN I ANSWER? 24 MR. JOHNSON: YOU CAN ANSWER. 25 THE WITNESS: I WAS WAITING FOR SOMEBODY TO SAY -- 11-229
1- LET.ME -- YOU KNOW, IF YOU ALL RESOLVED YOUR DISCUSSION
~
2 HERE. t 3 MR. JOHNSON: WE DIDN'T RESOLVE ANYTHING, BUT YOU 4 MAY ANSWER. 5 THE WITNESS: IF 1 REMEMBER CORRECTLY, LARRY ASKED E 6' ME TO GET SUCH ITEMS AS PERSONAL BELONGINGS OUT OF H ' 7 0FFICE. AND I BELIEVE A MEMO THAT HE HAD WRITTEN TO -- I 8 DON'T KNOW. I DON'T REMEMBER WHO IT WAS, BUT IT WAS TO A l 9 GPU OFFICIAL. 10 Q BY MR. HICKEY: PERSONAL BELONGINGS REFERRING 11 TO WHAT, MR. PARKS? 12- A OH, PICTURES OF HIS WIFE AND KIDS, THAT TYPE 13 0F THING. 14 Q ANYTHING ELSE? 15 A NO, NOT THAT I CAN RECALL AT THIS MOMENT. 16 Q DID MR. KING TELL YOU THAT WHEN HE WAS BEING 17 ESCORTED OFF THE SITE OR TOLD THAT HE WAS TO BE ESCORTED 18 OFF THE SITE THAT HE HAD BEEN GIVEN AN OPPORTUNITY TO GO 19 BY HIS OFFICE AND PICK UP HIS PERSONAL BELONGINGS BEFORE 20 LEAVING THE SITE? 21 A DID I UNDERSTAND THAT? l 22 Q DID HE TELL YOU THAT? DID HE TELL YOU THAT 1 23 THAT EVENING? l l 24 A I DON'T RECALL THAT HE DID. l 1
-25 Q HE DIDN'T SAY ANYTHING TO YOU ABOUT WHY HE !
11-230
'l 1
1 HADN'T STOPPED TO PICK UP HIS PERSONAL BELONGINGS HIMSELF? { l 2 A NO. IF HE DID, I DON'T RECALL IT AT THIS i J 3 TIME. 4 .Q SO Dib YOU GET MISS WENGER TO GO TO THE SITE? 5 A YES, 1 DID. ! 1 1 6 Q WHY DID YOU GET MISS WENGER?
.7 A BECAUSE SHE KNEW WHAT WAS LARRY'S PERSONAL 8 STUFF AND WHICH WAS NOT AND 1 DIDN'T. SHE WAS -- JOYCE 9 WAS LARRY'S SECRETARY. I 1
l 10 Q WELL, WHAT. KIND OF THINGS WAS SHE GOING TO - i 11 IDENTIFY THAT WERE LARRY'S PERSONAL BELONGINGS? I MEAN I I 12 BESIDES HIS WIFE'S PICTURES OR HIS FAMILY PICTURES. 13 A JUST THAT -- THE OTHER THINGS THAT WOULD HAVE I I 14 BEEN ON HIS DESK OR IN HIS OFFICE. I HAD NO IDEA WHAT WAS i l 15 HIS AND WHAT WASN'T. l I 16 Q YOU WOULD NOT HAVE RECOGNIZED A PICTURE OF j i 17 HIS FAMILY? . 1 18 A I WOULD HAVE RECOGNIZED THE PICTURE OF HIS ) l 19 FAMILY. YOU KNOW, THERE WERE OTHER ITEMS THAT WERE HIS 20 THAT I WAS UNAWARE OF, OR AT LEAST I MADE THE ASSUMPTION l 21 THERE WAS. AND I FELT, TO MAKE SURE THAT I GOT EVERYTHING 22 THAT WAS LARRY'S, THE BEST I CAN DO WOULD BE TO HAVE JOYCE l l 23 GO WITH ME. SHE WAS HIS SECRETARY. 24 Q AND DID YOU PICK HER UP AND TAKE HER TO THE 25 SITE? 11-231
- 1. :A YES, I.DIDe 2 Q. WAS M P, . KING'S OFFICE LOCKED WHEN YOU GOT 3 THERE?
.4 ,
-A I DON'T THINK IT WAS.
5 Q So DID YOU AND MISS.WENGER GO IN'AND LOCATE 6' THESE ITEMS,YOU-WERE LOOKING FOR? 7 4 IF~ MEMORY SERVES ME CORRECTLY-AT THE MOMENT,_ 8 .I BELIEVE WE HAD PUT A FEW'OF1 LARRY KING'S PERSONAL 9 BELONGINGS 1 INTO A BOX WHEN JUST'ABOUT THAT TIME A COUPLE 10' '0F GUARDS CAME IN AND TOLD US: "STOP WHAT YOU'RE'DOING AND 1 1 '- GET OUT" AND "UNDER' AUTHORITY OF JOHN BARTON OR SOMEBODY." 12 Q -MR. PARKS, DIDN'T YOU GO TO MR. KING'S'0FFICE 13 AT HISl REQUEST T O --' G E T SOME QUILTEC MATERIALS.0UT OF HIS
-14 DESK?-
15' A NO, SIR, I DID'NOT. i i 16 Q. DIDN'T YOU OBTAIN SOME QUILTEC MATERIALS FROM 17 MR. KING'S DESK AND' REMOVE THEM FROM HIS'0FFICE BEFORE YOU 18- WERE CONFRONTED BY THE GUARD? 19 A NO, SIR, 1 DID NOT. l
. I 20' Q DID MRS. KING ASK YOU TO TAKE ANY QUILTEC.
21 MATERIALS FROM MR. KING'S OFFICE AFTER FEBRUARY 24? 22 A IF SHE DID, l'M UNAWARE OF IT.
'23 Q YOU DIDN'T REMOVE ANY QUILTEC MATERIALS FROM ,
24 YOUR DESK WHILE YOU WERE THERE ON FEBRUARY 24, THERE IN l
'l 25- THE EVENING, DID YOU?
'I 11-232 l l
1 1
l
, '1E A I DON'T REMEMBER IF THAT WAS WHEN I REMOVED-2 THAT STUFF.THAT l'HAD.0F QUILTEC'S OR NOT..
3- Q MIGHT HAVE-BEEN? 4 A IT MIGHT HAVE BEEN, BUT I COULDN'T SWEAR TO I L .5 IT, AT THIS MOMENT,- THAT IT WAS. l 6. Q. DID:YOU KNOW ON FEBRUARY 24, THAT MR. KING 7 HAD-QUILTEC MATERIALS IN HIS OFFICE? 8 A- NO, 1 DID-NOT. OR AT LEAST IF I KNEW THEN, I 9 DON'T. RECALL IT NOW. 10 Q YOU KNEW MR. KING HAD QUILTEC BUSINESS CARDS I 11 WITH HIS'NAME ON THEM, DIDN'T YOU? I DON'T.KNOW. I DON'T KNOW IF HE DID OR NOT, 12 A
- 13. BUT l'M NOT GOING' GOING TO ASSUME THAT HE DID.
14' Q YOU DON'T RECALL EVER SEEING THEM.BEFORE 15 ' FEBRUARY 24? 16 A 'NOT AT THE.PRESENT MOMENT, I DON'T.
'17 Q .AFTER YOUR' INCIDENT WITH THE GUARD, DID YOU
]
18 RETURN TO MR. KING'S HOUSE? 19 A NO. I RETURNED HOME. 20 Q WELL, YOU WENT TO MR. KING'S HOUSE SOMETIME i 21 - THAT EVENING, DIDN'T YOU?
'22 A NOT THAT I CAN RECALL AT THIS TIME. j 23' Q WELL, LET ME REFRESH YOUR RECOLLECTION. YOU r
l 24 . WERE THERE WHEN THE PHONE CALL CAME IN FROM MR. JUBBA; DO 25 YOU REMEMBER THAT? 11-233
- 1? A THAT SAME NIGHT?
2 Q THAT SAME NIGHT. ' 3 A l' DON'T RECALL THAT, NOT AT THIS MOMENT IN 4 TIME. IF'YOU HAVE A DOCUMENT TO SHOW OTHERWISE OR HAS ! 5 MORE ACCURATE REFLECTION OF THE INCIDENT THAT HAPPENED 6 FOUR YEARS AGO, l'D BE HAPPY TO REVIEW IT AND COMMENT ON 7 IT. 8 Q WELL, l'M REFERRING TO THE ENTRY IN EXHIBIT 9 39, YOUR SWORN STATEMENT OF JULY 25, 1983, AT PAGE 4, , 10 MIDDLE PARAGRAPH. YOU TALK ABOUT THE SECOND PHONE CALL. 11 FROM MR. JUBBA BEING AROUND THE TIME KING WAS SUSPENDED. 12 DO YOU REMEMBER --
.13 A WHERE?
14 Q THE MIDDLE PARAGRAPH STARTS "SOMETIME DURING 15 THE LATTER PART OF 1982." DO YOU SEE THAT? l 16 A RIGHT. 17 Q DO YOU SEE THE REFERENCE THERE TO GETTING -- 18 BEING PRESENT AROUND THE TIME KING WAS SUSPENDED WHEN THE 19 SECOND PHONE CALL FROM JUBBA WAS RECEIVED? DO YOU 20 REMEMBER THAT? 21 A 1 REMEMBER BEING AT LARRY KING'S HOUSE ONE 22 T!ME WHEN SOME GUY CALLED, AND I CAN ONLY ASSUME, AT THIS i 23 P0lNT, IT WAS JUBBA. 24 Q YOU DON'T REMEMBER BEING THERE THE NIGHT OF 1 1 25 MR. KING'S SUSPENSION? l 11-234 i 1 l
l 1 A IT WAS NOT THE NIGHT OF LARRY KING'S 2 SUSPENSION, IF MY MEMORY SERVES ME CORRECTLY. j I 3 Q YOU CALLED MR. KING LATER THAT EVENING AFTER l 4 YOU LEFT THREE MILE ISLAND? ] I 5 A I BELIEVE I DID. ) 1 6 Q DID YOU TALK TO HIM ABOUT HIS SUSPENSION?' i 7 A I DON'T REMEMBER, AT THIS POINT IN TIME, ! 8 EXACTLY WHAT WE TALKED ABOUT. l'M SURE I THOUGHT, "I i 9 WASN'T ABLE TO GET ANYTHING." J l 10 Q YOU TOLD HIM YOU WEREN'T ABLE TO GET ANYTHING 11 0F HIS, YOU SAY? j 12 A l'M SURE I TOLD HIM THAT, YES. J l 13 Q DID YOU TALK ABOUT HIS INVOLVEMENT WITH 14 QUILTEC THAT EVENING? 15 A NOT THAT I CAN RECALL AT THE MOMENT. 16 Q WHO ELSE DID YOU TALK TO THAT EVENING AFTER 17 YOU RETURNED FROM THE SITE, FEBRUARY 24? ! 18 A YOU MEAN OTHER THAN MY SONS OR MY GIRL 19 FRIEND? 20 Q YES. 21 A NOBODY THAT I CAN RECALL AT THIS TIME. 22 Q DID YOU HAVE ANY DISCUSSION WITH LARRY KING 23 ON FEBRUARY 24TH OR SHORTLY THEREAFTER ABOUT WHETHER 24 JOE CHWASTYK HAD INFORMED MANAGEMENT ABOUT LARRY'S QUILTEC 25 INVOLVEMENT? i 11-235 I
1 i 1 A NOT I THAT CAN RECALL. NOT AT THIS TIME. 1 2' Q DO YOU REMEMBER ANY INDICATION THAT 3 LARRY KING SUSPECTED JOE CHWASTYK HAD TOLD MANAGEMENT 4 ABOUT HIS QUILTEC ACTIVITIES? ! l 5 MR. JOHNSON: I'M SORRY, 1 DIDN'T HEAR. 6 MR. HICKEY: TOLD MANAGEMENT ABOUT HIS QUILTEC -- a l ) 7 TOLD MANAGEMENT ABOUT KING'S QUILTEC ACTIVITY. 8' MR. JOHNSON: IT WAS THE FIRST PART I DIDN'T HEAR. i i 9 Q BY MR. HICKEY: DO YOU RECALL ANY INDICATION 1 10 FROM MR. KING ON OR AFTER FEBRUARY 24 THAT HE SUSPECTED
- 11 THAT MR. CHWASTYK HAD TOLD MANAGEMENT ABOUT KING'S QUILTEC 12 ACTIVITIES?
i 13 A NO, NOT AT MOMENT, I DON'T. 1 14 YOU DID ASK ME, CORRECT, IF I RECALL 15 CONVERSATIONS OF THAT NATURE? h 16 Q YES. 17 A OKAY. NO, I DO NOT AT THIS TIME. 18 Q AND THE NEXT DAY YOU TALKED TO LAKE BARRETT 19 AND JOEL WEIBE OF THE NRC. THIS WOULD BE ON FEBRUARY 25. 20 DO YOU RECALL THAT MEETING? 21 A I RECALL THAT THE MEETING OCCURRED, YES. 22 Q THEY CALLED YOU AT THE OFFICE TO TELL YOU
.23 ABOUT SOME MATTERS THEY WERE LOOKING INTO?
l 24 A YET, THEY DID. 25 Q DID YOU TALK TO THEM ABOUT QUILTEC? j l 11-236 !
)
- _ _ _ -_____--__-______-___________--__-A
1- A I BELIEVE l'N THE COURSE OF THAT CONVERSATION 2 THAT I TOLD THEM i THOUGHT THAT LARRY KING WAS BEING 3 RAILROADED. 4 DID YOU TELL THEM WHAT LARRY KING'S Q 5 INVOLVEMENT WITH QUILTEC WAS? 6 A I DIDN'T RECALL EXACTLY HOW IN-DEPTH THE 7 CONVERSATION WAS. 8 Q WELL, DID YOU TELL THEM THAT HE WAS OR.WAS 9 BELIEVED BY YOU TO BE AN OWNER OF QUILTEC? 10 A I DON'T RECALL, AT THIS TIME, IF THAT CAME UP 11 IN THE CONVERSATION OR NOT. 12 Q DO YOU RECALL TELLING THEM ANYTHING ABOUT 13 YOUR KNOWLEDGE OF MR. KING'S PARTICIPATION OR INVOLVEMENT 14 IN QUILTEC? 15 A AGAIN, SIR, YOU KNOW, 1 DON'T RECALL HOW 16 IN-DEPTH THE CONVERSATION WAS. THE MEETING THAT I HAD ' 17 WITH NRC PEOPLE THAT DAY WAS NOT A REAL -LONG ONE. 18 Q WOULD YOU SAY IT WAS ABOUT AN HOUR? ) I 19 A IT MIGHT HAVE BEEN. I REALLY DON'T RECALL, 20 AT THIS TIME, EXACTLY HOW LONG IT WAS. l 21 Q DID YOU TELL MR. BARRETT AND MR. WEIBE ABOUT. l 22 YOUR HAVING QUILTEC RESUMES TYPED FOR MR. KING? I 23 A I DON'T KNOW IF WE DISCUSSED IT AT THAT TIME 24 OR NOT. I DON'T THINK WE DID. I 25 Q YOU UNDERSTOOD MR. KING HAD BEEN TOLD HE WAS I 11-237 ! 1 I
1 BEING SUSPENDED BECAUSE OF A CONFLICT OF INTEREST 2 REGARDING HIS QUILTEC ACTIVITIES? 3 A RIGHT. I WAS INFORMED THAT HE WAS SUSPENDED 4 FOR CONFLICT OF lNTEREST, THAT'S TRUE. 5 Q AND YOU 00 RECALL TELLING THE NRC 6 REPRESENTATIVES THAT YOU THOUG;!T MR. KING WA5 BEING 7 RAILROADED OR SOMETHING TO THAT EFFECT? 8 A YES. 9 Q YOU DIDN'T THINK THERE WAS ANY BASIS TO 10 CHARGE MR. KING WITH CCNFLICT OF INTEREST? 11 A THAT'S BASICALLY TRUE, YES. 12 Q AND WHAT WAS YOUR UNDERSTANDING OF WHAT 23 MR. KING'S ACTIVITIES WERE WITH QUILTEC THAT YOU FELT 14 DIDN'T CONSTITUTE A CONFLICT OF INTEREST? 15 A I DIDN'T THINK, EVEN IF HE WAS AS GUILTY AS 16 THEY WERE TRYING TO SAY HE WAS, THAT IT CONSTITUTED A 17 CONFLICT OF INTEREST. 18 Q l DON'T UNDERSTAND THE ANSWER, "EVEN IF HE 19 WAS AS GUILTY AS THEY WERE TRYING TO SAY HE WAS." 20 A "THEY" BEING THE GPU, FOR SUSPENDING FOR 21 CONFLICT OF I .'! T E R E S T . 22 Q YCU'RE CAYING THAT NO CONFLICT OF INTEREST 23 WARRANTS SUSPENSICN? 24 A NO, THAT'S NCT WHAT l'M SAYING. l'M SAYING 25 THAT I DID NOT BELIEVE THAT HE WAS GUILTY OF CONFLICT OF 11-238
1 INTEREST. AND, FURTHER, I BELIEVE THAT IF THERE WAS AN 2 OPPORTUN!TY, THAT THEY JUST JUMPED AT IT, OVERCAME THE 3 OPPOSITION OR THE PROBLEMS THAT LARRY KING AND 1 AND 4 ED GISCHEL, FOR THAT MATTER, HAD, IN FACT, REGARDING THE ! 5 CLEANUP ACTIVITIES. IN OTHER WORDS, I BELIEVE IT TO BE 6 HARASSMENT, RETALIATION AGAINST LARRY KING. 7 Q YOU HAVEN'T REALLY ANSWERED THOUGH WHAT YOU 8 UNDERSTOOD LARRY KING'S PARTICIPATION WITH QUILTEC WAS. R l 9 YOU HAVE GIVEN US.YOUR CONCLUSION THAT YOU DIDN'T THINK IT 10 CONSTITUTED A CONFLICT OF INTEREST. BUT WHAT WAS IT THAT i 11 YOU UNDERSTOOD AS OF FEBRUARY 24, 25, THAT MR. KING HAD 1 12 DONE WITH QUILTEC? 13 MR. JOHNSON: CAN I JUST BACK UP? THE PREFACE OF I 14 THE QUESTION WAS INCORRECT, I THINK, BECAUSE YOUR ORIGINAL f 15 QUESTION WAS BASED ON WHAT HE SAID IN TERMS OF THE GPU'S i 16 ALLEGATIONS OF -- IF HE WAS AS GUILTY AS GPU SAID HE WAS. l l 17 THAT IMPLIES THE REASON GPU HAD FOR SUSPENDING MR. KING, { 18 NOT WHAT MR. PARKS THOUGHT MR. KING'S ACTIVITIES WERE. 19 WITH THAT REFERENCE, GO AHEAD AND ASK YOUR QUESTION. f 20 MR. HICKEY: WOULD YOU READ MY LAST QUESTION TO THE 21 WITNESS, PLEASE. 22 (WHEREUPON THE REPORTER READ THE QUESTION 23 APPEARING ON PAGE 239, LINES 7 THROUGH 12, INCLUSIVE.) 24 THE WITNESS: AS I UNDERSTOOD THE REASON HE WAS 25 SUSPENDED FROM THE JOB SITE WAS BECAUSE HE WAS INVOLVED IN II-239
s 1 QUILTEC, AN OFFICER OF QUILTEC. 2 Q BY MR. HICKEY: I KNOW. MY QUESTION TO YOU 3 IS, WHAT DID YOU KNOW AS OF THAT DATE ABOUT MR. KING'S 4 INVOLVEMENT WITH QUILTEC? 5 A I BELIEVE, AT THAT TIME, THAT LARRY KING WAS , 6 INVOLVED IN QUILTEC, BUT I WAS UNSURE EXACTLY THE EXTENT 7 0F HIS INVOLVEMENT. 8 Q DID YOU BELIEVE HE WAS AN OFFICER? 9 A I BELIEVE HE MIGHT HAVE BEEN, YES. , 10 Q DID YOU BELIEVE HE HAD A FINANCIAL INTEREST , 11 IN THE FIRM? 12 A I BELIEVE I HAVE ALREADY STATED THAT I 13 THOUGHT HE'D PUT UP THE MONEY FOR THE FIRM. 14 Q DID YOU BELIEVE HE WAS RECEIVING ANY . ' 15 REMUNERATION FROM THE FIRM? 4 16 A I HAD NO WAY OF KNOWING IF HE WAS OR NOT. 17 Q DID YOU KNOW WHETHER HE WAS RECEIVING ANY 18 BENEFITS FROM THE FIRM? 19 A I HAD NO WAY OF KNOWING WHETHER HE WAS OR 20 NOT. 21 Q AND WHAT DID YOU KNOW ABOUT MR. KING'S 22 ACTIVITIES WITH REGARD TO THE RECRUITING OF GPU EMPLOYEES 23 FOR QUILTEC AS OF FEBRUARY 24 AND 25? 24 A I WAS NOT INVOLVED OR PRIVY, YOU KNOW, TO 25 WHATEVER HE MIGHT HAVE DONE TO HIRE PEOPLE, IF HE HIRED 8 11-240 4 4
/
1 PEOPLE. 2 Q YOU DIDN'T HAVE ANY INFORMATION ABOUT IT? 3 A NO. I KNEW THAT, YOU KNOW, TED REICHART AND 4 MIKE HERLlHY HAD, IN FACT, WENT TO WORK FOR QUILTEC, BUT I 5 WAS UNDER THE IMPRESSION EVERYTHING WAS HANDLED BY 6 BEN SLONE, REICHART, AND MIKE HERLIHY, 7 IN WATCHING YOUR COURT REPORTER, I CAN TELL 8 SHE'S GETTING TIRED AND l'M GETTING KIND OF DRIFTY AND 9 SPACEY MYSELF. DO YOU THINK WE CAN WRAP IT UP? 10 Q CAN YOU GIVE ME ANOTHER 10 MINUTES? I'LL SEE I 11 IF WE CAN COME TO THE END OF THIS. IF I HAVEN'T, WE'LL l 12 STOP ANYHOW. l 13 A SOUNDS LIKE A PLAN. 14 Q YOUR OPINION, YOU JUST SAID, WAS THAT 15 , EVERYTHING THAT WAS HANDLED WITH REGARD TO THE RECRUITING 16 0F MR. REICHART AND MR. HERLlHY WAS HANDLED BY MR. SLONE? 17 A AS FAR AS THE QUILTEC END OF IT, YES. AT 18 LEAST, THAT'S WHAT I BELIEVE AT THIS MOMENT. 19 Q WHAT DID YOU KNOW AS OF THAT SAME TIME, 20 MR. PARKS, FEBRUARY 24 OR 25, ABOUT QUILTEC'S EMPLOYMENT 21 0F KEN LIONARONS? 22 A I CAN'T RECALL AT THIS MOMENT IN TIME IF I 23 KNEW IN FEBRUARY OF 1983 THAT KEN LIONARONS HAD GONE TO l 24 WORK FOR QUILTEC. 25 Q WITH REGARD TO YHE HIRING OF QUILTEC BY 11-241 6 4 _
1 MR. HERLlHY, WHICH 100K PLACE APPROXIMATELY THE FALL OF 2 1982, YOU HAD SEVERAL DISCUSSIONS WITH MR. HERLlHY 3 ENCOURAGING HIM TO TAKE THE JOB WITH QUILTEC, DIDN'T YOU? 4 A MIKE AND I HAD SEVERAL DISCUSSIONS WHETHER OR 5 NOT HE SHOULD TAKE THE JOB WITH QUILTEC, YES. 6 Q AND YOU WERE RECOMMENDING TO HIM STRONGLY 7 THAT HE TAKE THE JOB, WEREN'T YOU? 8 A WELL, FROM WHAT I CAN RECALL AT THIS MOMENT, 9 MIKE'S ONLY QUESTION REGARDING WHETHER OR NOT HE SHOULD 10 TAKE THE JOB WAS HOW MUCH MONEY HE SHOULD ASK FOR. AND I 11 THOUGHT HE SHOULD GO FOR BROKE AND ASK FOR IT ALL. 12 Q SEE YOU IF CAN ANSWER MY QUESTION, MR. PARKS. 13 DID YOU TELL MR. HERLIHY THAT YOU WERE RECOMMENDING 14 STRONGLY THAT HE OUGHT TO TAKE THE JOB? 15 A I DON'T RECALL RECOMMENDING STRONGLY TO MIKE 16 HE OUGHT TO TAKE THE JOB. I THOUGHT IF HE WENT UP THERE 17 IT MIGHT BE A GOOD WAY FOR HIM TO GET STARTED IN AN 18 INDEPENDENT CONSULTANT BUSINESS, DOUBLE HIS SALARY, THAT 19 TYPE OF THING. MIKE ASKED ME ONE FRIEND TO ANOTHER, AND 1 20 GAVE HIM MY BEST OPINION. 21 Q IS THERE ANYTHING IN YOUR CONTACT WITH 22 MR. HERLIHY ABOUT QUILTEC, IN HIS TAKING THE JOB, THAT 23 WOULD SUGGEST TO MR. HERLIHY THAT YOU WERE ACTING AS 24 INTERMEDIARY BETWEEN QUILTEC AND MR. HERLIHY? 25 A NOT THAT I CAN THINK OF, EXCEPT TO RELAY 11-242
~ ~ > - --
1 CONVERSATIONS TO HIM THAT BEN SLONE HAD HAD WITH ME. 2 Q WOULD IT SURPRISE YOU TO LEARN THAT 3 MR. HERLIHY HAD THAT VIEW 7 4 A WELL, I WOULD SAY S0. TO A DEGREE, YES. 5 Q WHEN MR. HERLIHY LEFT AND WENT TO WORK FOR 6 QUILTEC AT SHOREHAM, HE DIDN'T TELL PEOPLE HE WAS GOING TO 7 DO THAT, DID HE? 8 A I DON'T KNOW WHAT HE TOLD OTHER PEOPLE. 9 Q YOU KNEW HE WAS GOING TO WORK FOR QUILTEC AT 10 SHOREHAM, DIDN'T YOU? 11 A YES, 1 DID. 12 Q YOUR TESTIMONY IS YOU WERE UNAWARE OF WHAT 13 INFORMATION OTHER PEOPLE HAD ON THE SITE ABOUT WHERE 14 HERLIHY WENT? 15 A THAT'S TRUE. I AM NOT AWARE, AT THIS POINT 16 IN TIME, WHAT MIKE HERLlHY TOLD ANYBODY ELSE. 17 Q NO ONE MADE ANY COMMENT TO YOU ABOUT WHERE 18 THEY THOUGHT HERLIHY WAS GOING? 19 A NO. BECAUSE MOST OF MY DEALINGS WITH PEOPLE 20 WERE IN SITE OPERATIONS, AND I THINK MOST OF THE FOLKS IN . 21 SITE OPERATIONS KNEW WHERE HE WAS GOING. 22 Q KNEW THAT HE WAS GOING TO WORK FOR QUILTEC? 23 A GOING TO WORK FOR BEN SLONE, YES. 24 Q WELL, QUILTEC WAS MORE THAN BEN SLONE, WASN'T 25 IT? 11-243 L _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . __
1 A THAT'S WHAT IT EVENTUALLY PROVED TO BE. 2 Q DIDN'T YOU KNOW THAT IN THE FALL OF '82 WHEN 3 MR. HERLIHY J0lNED THEM? 4 A ! BELIEVE I TOLD YOU PREVIOUSLY I HAD A 5 STRONG SUSPICION THAT LARRY KING HAD SOME INVOLVEMENT OF A 6 HIGHER LEVEL OTHER THAN AS A PASSING INTEREST, BUT I HAD 7 NO PROOF OF IT. 8 Q DIDN'T MR. HERLIHY MAKE ANY COMMENTS TO YOU 9 THAT MR. KING WAS INVOLVED IN QUILTEC WHEN HE WAS BEING 10 RECRUITED? 11 A NOT THAT I CAN RECALL AT THE MOMENT. . 12 Q YOU DID TELL MR. HERLIHY THAT YOU THOUGHT 13 QUILTEC WOULD BE A GOOD OPPORTUNITY FOR HIM IF HE GOT A 14 GOOD SALARY, BUT DON'T RECALL ADDRESSING THE PEOPLE WHO 15 WERE THERE? 16 A I CAN RECALL TELLING MIKE IT WOULD BE A GOOD 17 OPPORTUNITY FOR HIM. HE CAN GET GOOD MONEY FOR IT. 18 Q BUT NOT THE OTHER? YOU DON'T RECALL ANY , 19 SUSPICION ABOUT WHO WAS RUNNING QUILTEC? 20 A NOT AT THE MOMENT. I CAN DISTINCTLY REMEMBER ' 21 MIKE ASKING ME WHAT THE GOING RATE WAS THAT MOST OF THE 22 CONSULTANTS ON THE JOB CHARGE. THEY WERE CHARGING BY THE 23 HOUR, AND I ANSWERED TO THE BEST THAT I KNEW. 24 Q NOW HOW ABOUT TED REICHART? DID YOU 25 ENCOURAGE TED REICHART TO GO TO WORK FOR QUILTEC? 11-244
1 A TED AND I MIGHT HAVE DISCUSSED GOING TO WORK 2 FOR QUILTEC. 3 Q DID YOU ENCOURAGE HIM TO GO TO WORK FOR 4 QUILTEC? 5 A NO MORE SO THAN I WOULD HAVE ENCOURAGED 6 MIKE HERLIHY, FROM WHAT I CAN RECALL AT THIS MOMENT. 7 Q WELL, I BELIEVE YOUR TESTIMONY WAS THAT YOU 8 DID ENCOURAGE MIKE HERLIHY. 9 A NO. I BELIEVE MY TESTIMONY WAS THE FACT THAT 10 1 THOUGHT IT WAS A GOOD OPPORTUNITY AND GOOD BUCKS. 11 Q YOU TOLD HIM THAT -- ENCOURAGED HIM TO TAKE 12 THE OPPORTUNITY, DIDN'T YOU? 13 A THERE AGAIN, I HAD BEEN AT SHOREHAM, AND 1 14 BELIEVE BOTH MIKE AND TED TALKED TO ME ABOUT THE JOB SITE 15 AND WHAT WAS GOING ON AND WHO THE MAIN PLAYERS WERE AND 16 WHAT THE GOING RATE OF PAY WAS AND STUFF LIKE THAT UP 17 THERE. AND I TRIED TO ANSWER THEIR QUESTIONS THE BEST I 18 COULD. 19 Q YOU KNEW WHEN TED REICHART LEFT THAT HE TOLD 20 PEOPLE THAT HE WAS GOING TO WORK FOR A CHEMICAL COMPANY 21 OUT IN TEXAS, DIDN'T YOU, MR. PARKS? 22 A THAT'S WHAT I HEARD, YES. 23 Q YOU KNEW THAT WASN'T TRUE, DIDN'T YOU? 24 A THAT'S TRUE. I KNEW THAT WASN'T TRUE. 25 Q YOU KNEW HE'D GONE TO SHOREHAM TO WORK FOR 11-245
1 QUILTEC? 2 A YES. 3 Q DID YOU ASK ANYBODY ABOUT WHY MR. REICHART 4 WAS PUTTING OUT A FALSE STORY OF WHERE HE WAS GOING TO 5 WORK? 6 A I DIDN'T FEEL IT WAS ANY OF MY BUSINESS. 7 Q SO YOUR TESTIMONY IS YOU DIDN'T ASK ANYONE 8 ABOUT IT? 9 A NO. 10 Q DID YOU HEAR ANY DISCUSSION WITH ANYONE, 11 MR. KING OR MR. VONE, ABOUT MR. REICHART PUTTING OUT THIS 12 FALSE STORY? 13 A IF I DID, I DON'T RECALL AT THE MOMENT. 14 Q OR DID YOU HEAR ANYONE ELSE DISCUSS THE FACT 15 THAT MR. REICHART WAS PUTTING OUT A FALSE STORY ABOUT 16 WHERE HE WAS GOING TO WORK? 17 A NO. I DON'T RECALL HAVING DISCUSSED THAT OR 18 OVERHEARD THAT IN CONVERSATION WITH ANYONE ELSE. 19 Q MR. LIONARONS MADE A TRIP FOR QUILTEC TO 20 STONE AND WEBSTER IN CHERRY HILL, NEW JERSEY, TO ATTEND A 21 MEETING ON THE RIVERBEND RAD WASTE PROGRAM, RADIATION 22 WASTE, IN 19 -- IN JANUARY 1983. DID YOU KNOW THAT IN 23 JANUARY 1983? 24 A I COULD NOT TELL YOU, AT THIS POINT IN TIME, 25 IF I KNEW IN JANUARY 1983 OR NOT. 11-246
1 Q DID YOU TALK TO MR. LIONARONS BEFORE YOU LEFT 2 GPU'S EMPLOY IN LATE JANUARY 1983 OR EARLY FEBRUARY ABOUT 3 HIS INTEREST IN QUILTEC? 4 A I -- l 5 MR, JOHNSON: THERE'S NO FOUNDATION IN THIS RECORD 6 ABOUT THE DATES OF WHEN MR. LIONARONS LEFT. IF YOU WANT 7 TO OFFER SOME, THAT'S FINE. 8 THE WITNESS: I GUESS I CAN ANSWER YOUR QUESTION. 9 I DON'T RECALL HAVING TALKED WITH KEN LIONARONS ABOUT WHAT 10 HE WAS DOING OR WHERE HE WAS GOING, NOT AT THAT POINT IN 11 TIME. 12 Q BY MR. HICKEY: YOU DID WORK WITH 13 MR. LIONARONS, DID YOU NOT? 14 A NO, NOT REALLY. 15 Q WAS HE IN THE SITE OPERATIONS DEPARTMENT? 16 A I THINK HE WAS IN THE PLANT ENGINEERING 17 DEPARTMENT, RIGHT, WHICH WAS A PART OF SITE OPERATIONS, 18 BUT I DON'T RECALL HAVING INTERFACED WITH KEN LIONARONS 19 VERY FREQUENTLY DURING THE TIME FRAME IN QUESTION. I DID 20 INTERFACE WITH KEN LIONARONS FREQUENTLY DURING SDS. 21 Q WAS HE A FRIEND? DID YOU HAVE ANY SOCIAL -- 22 LET ME ASK YOU ONE QUESTION AT A TIME. 23 WAS MR. LIONARONS A FRIEND OF YOURS? 24 A ONLY AT WORK. 25 Q YOU DIDN'T HAVE ANY SOCIAL CONTACT WITH HIM7 11-247
_ . . ~ 1 A NO. THE ONLY TIME I CAN EVER RECALL GOING l l 2 ANYWHERE WHERE KEN LIONARONS WAS, WAS SOMETIME DURING THE 3 SUMMER OF 1982 HE HAD A PIG ROAST AT HIS HOUSE, AND I WAS l 4 THERE, ALONG WITH ABOUT 40 OR 50 OTHER PEOPLE. IT WAS 5 LIKE AN OPEN INVITATION FOR EVERYBODY THAT WANTED TO COME. 6 MR. HICKEY: OFF THE RECORD. 7 (DISCUSSION HELD OFF THE RECORD.) 8 MR. HICKEY: l'M GOING TO ASK THE REPORTER TO MARK, 9 I BELIEVE IT WOULD BE, EXHIBIT 50. 10 (WHEREUPON RESPONDENT'S EXHIBIT 50 WAS MARKED 11 FOR IDENTIFICATION BY THE NOTARY PUBLIC, AND A COPY IS 12 ATTACHED HERETO.) 13 Q BY MR. HICKEY: SO, MR. PARKS, I'VE SHOWN YOU ' 14 WHAT'S BEEN MARKED EXHIBIT 50. AND YOU CAN IGNORE THAT 15 MARKING DOWN AT THE BOTTOM THAT SAYS " RESPONDENT'S 16 EXHIBIT 31." THAT WAS NOT ON THE ORIGINAL. 17 BUT WILL YOU TAKE A BRIEF LOOK AT THAT 18 DOCUMENT AND TELL ME IF YOU'RE FAMILIAR WITH IT. 19 A I WOULD SAY IT APPEARS TO BE THE PROPOSAL 20 THAT QUILTEC SENT TO THE BEAVER POWER VALLEY STATION. 21 Q AND ONE THAT YOU KEPT A COPY OF FOR A WHILE 22 AFTER MISS RITTLE DID THE TYPING? 23 A I BELIEVE IT TO BE THE SAME, YES. 24 Q THE EXHIBIT ISN'T PAGINATED ALL THE WAY 25 THROUGH, BUT I PUT A MARKER WHERE YOUR RESUME IS. DO YOU 11-248
1 FIND IT? 2 A YES, I KIND OF ASSUMED THAT'S WHAT THAT WAS 3 IN THERE FOR. 4 Q THE RESUME THERE FOR RICHARD D. PARKS ON 5 QUILTEC STATIONERY, IS THAT THE ONE THAT MISS RITTLE 6 TYPED? , 7 A I WOULD ONLY HAVE TO SAY IT PROBABLY WAS. 8 Q LOOK AT EXHIBIT 39, WHICH WAS YOUR NUS 9 RESUME. DO YOU HAVE IT THERE? 10 A YES. 11 Q NOW YOU'LL NOTE THAT THE QUILTEC RESUME HAS 12 SOME ADDITIONAL INFORMATION THAT ISN'T INCLUDED ON THE NUS 13 RESUME. DO YOU SEE THAT I'M REFERRING SPECIFICALLY TO THE 14 PARAGRAPH THAT STARTS OFF, THE QUILTEC RESUME TITLE, 15 " EXPERIENCE, 1982 TO PRESENT"? 16 A RIGHT. 17 Q "BECHTEL NORTHERN, SENIOR STARTUP ENGINEER" 18 AND SO ON? 19 A RIGHT. 20 Q IT APPEARS THAT SOMEONE UPDATED YOUR NUS 21 RESUME FOR PURPOSES OF THE QUILTEC SUBMISSION. DID YOU DO 22 THAT, MR. PARKS? 23 A WELL, FIRST OF ALL, SIR, I THINK YOU'RE j 24 MAKING AN ASSUMPTION THAT IS NOT NECESSARILY FOUNDED. I 25 WILL SPOT YOU THAT AT ONE POINT IN TIME THAT MY RESUME WAS 11-249
1 UPDATED PRIOR TO IT GOING OVER TO BEAVER VALLEY, BUT I 2 DON'T THINK IT WAS NECESSARILY UPDATED PRIMARILY FOR IT TO 3 BE SENT TO BEAVER VALLEY. 4 Q WELL, WHEN WAS IT UPDATED? 5 A- REALLY COULDN'T TELL YOU. I BELIEVE IT WAS, 6 IF MEMORY SERVES ME CORRECTLY, STANDARD PRACTICE FOR 7 EMPLOYEES OF BECHTEL OR ANY COMPANY TO FREQUENTLY UPDATE 3 THEIR RESUME. 9 Q WELL, WHEN YOU GAVE YOUR RESUME TO ' 10 MISS RITTLE TO SERVE AS A FORMAT FOR THE QUILTEC RESUME, 11 YOU TESTIFIED EARLIER THAT YOU GAVE HER YOUR NUS RESUME 12 THAT'S EXHIBIT 49, DIDN'T YOU? 13 A I BELIEVE, SIR, IF YOU LOOK BACK ON THE 14 RECORD I WILL -- I STATED THAT THAT WAS PROBABLY THE 15 RESUME THAT WAS GIVEN TO HER. AND 1 BASE THAT ONLY ON THE 16 EVIDENCE THAT I REVIEWED THAT YOU PROVIDED AND THAT THIS 17 WAS THE ONE THAT YOU APPARENTLY OBTAINED FROM THE BECHTEL 18 FILES. 19 Q WELL - 20 A MEANING THAT I COULD NOT -- AT THIS POINT, 21 THIS LATE STAGE OF THE GAME -- WELL, WHICH OF THESE 22 RESUMES I GAVE TO ROSE RITTLE, IT COULD HAVE BEEN THIS 23 ONE, EXHIBIT 49, OR IT COULD HAVE BEEN ONE THAT'S 24 CONTAINED IN EXHIBIT 50, l'M UNSURE. 25 Q WELL, IF YOU GAVE EXHIBIT 50 TO MISS RITTLE 11-250
1 TO SERVE AS A FORMAT, THAT WOULD MEAN THAT YOU HAD A 2 QUILTEC RESUME PREPARED BEFORE MISS RITTLE DID THE TYPING. 3 A I THINK YOU'RE MAKING ANOTHER ASSUMPTION THAT 4 IT WAS A QUILTEC RESUME. 5 Q WELL, I MEAN A RESUME ON QUILTEC LETTERHEAD. 6 A NO, SIR. I THINK THIS WAS A VERSION OF THE 7 RESUME THAT I GAVE TO ROSE RITTLE. SHE OBVIOUSLY TYPED IT 8 ON QUILTEC LETTERHEAD. YOUR STATEMENTS ARE IMPLYING THAT 9 I HAD A QUILTEC RESUME THAT I GAVE TO HER, AND I DID NOT. 10 Q WELL, DID YOU PREPARE, AFTER YOU RETURNED TO 11 TMI IN 1982 IN MAY, A BECHTEL NORTHERN RESUME 7 I MEAN BY 12 THAT A RESUME ON BECHTEL NORTHERN PAPER, 13 A I CANNOT TELL YOU, AT THIS MOMENT IN TIME, IF 14 I PREPARED A RESUME SPECIFICALLY -- SPECIFICALLY FOR 15 BECHTEL NORTHERN, OR IF I HAD TO UPDATE MY RESUME AS PART 16 0F THE FILING SYSTEM REQUIRED FOR THE LICENSE AT TMI. 17 Q IN THE QUILTEC RESUME THAT'S THERE IN 18 EXHIBIT 50, MR. PARKS, IN THE FIRST PARAGRAPH YOU'LL NOTE 19 THAT IT SAYS, ABOUT HALFWAY DOWN, " PRIMARY RESPONSIBILITY 20 15 AS OPERATIONS ENGINEER REPORTING DIRECTLY TO SITE 21 OPERATIONS DIRECTOR." DO YOU SEE THAT LANGUAGE? 22 A YES. 23 Q WHEN DID THAT BECOME TRUE7 24 A AFTER THE REORGANIZATION IN 1982. 25 Q AFTER SEPTEMBER 1, 1982? 11-251
t l 1 A THAT'S CORRECT. UNLESS MEMORY FAILS ME AT 2 THIS MOMENT, I BELIEVE IT WAS A REQUIREMENT SOMEWHERE 3 ALONG THE LINE THAT THE PEOPLE ASSIGNED THE KEY FUNCTIONS, 4 KEY POSITIONS WITHIN THE SITE OPERATIONS GROUP HAD TO FILE 5 A RESUME TO BE PUT ON FILE TO BE IN COMPLIANCE WITH THE 6 APPENDIX B 0F THE LICENSE OR AN APPENDIX A LICENSE. 7 Q YOU DIDN'T FILE A RESUME TO BE IN COMPLIANCE 8 WITH THE APPENDIX LICENSE ON QUILTEC LETTERHEAD? 9 A NO, SIR. 10 Q WHAT LETTERHEAD DID YOU FILE YOUR RESUME ON? 11 A PROBABLY JUST PLAIN OLD WHITE PAPER. 12 THAT'S WHAT I'M TRYING TO STATE, SIR. YOUR 13 LINE OF QUESTIONS CONTINUES TO IMPLY OR ASSUME THAT I HAD 14 A RESUME PREPARED ON QUILTEC LETTERHEAD PRIOR TO ME GIVING 15 A COPY OF MY RESUME TO ROSE RITTLE, AND l'M TELLING YOU 16 EMPHATICALLY THAT'S INCORRECT. 17 Q THIS RESUME -- IS IT YOUR TESTIMONY THAT YOU 18 ACTUALLY RECALL PREPARING A RESUME TO BE FILED WITH THE 19 PLANT RECORDS OR THAT YOU MAY HAVE? l 20 A I AM TRYING TO TELL YOU THAT I BELIEVE THAT 21 HAPPENED. AT THIS POINT IN TIME, I CANNOT REASONABLY 22 ASCERTAIN WHETHER IT DID OR NOT. 23 Q WHERE WAS THE RESUME FILED? 24 A IT WOULD PROBABLY BE IN THE SITE OPERATIONS 25 AREA. AGAIN, I MIGHT HAVE JUST UPDATED MY RESUME TO 11-252 i
1 REFLECT WHAT I WAS CURRENTLY DOING. 2 Q WELL, THE FORMAT OF THE QUILTEC, 3 INCORPORATED, RESUMES, YOURS AND THE OTHERS THAT ARE 4 ATTACHED TO EXHIBIT 50,' DON'T FOLLOW THE FORMAT OF YOUR 5 NUS RESUME THAT'S EXHIBIT 49, DO THEY? 6 A THEY DON'T APPEAR TO, NO. BUT IT APPEARS TO 7 ME THE ONLY THING THEY LEAVE OUT IS THE EDUCATION. 8 Q WELL, THE EDUCATION ON YOUR QUILTEC RESUME 9 APPEARS AS THE LAST ITEM. 10 A OKAY. THIS APPEARS TO BE FOLLOWING THE SAME 11 FORMAT ROUGHLY. I 12 Q WELL, DEPENDS ON WHAT YOU MEAN BY " FORMAT." 13 IT'S CERTAINLY NOT THE MATERIAL IN THE SAME ORDER, is IT? i 14 A NO, SIR, IT'S DEFINITELY NOT THE SAME 15 MATERIAL IN THE SAME ORDER. THERE ARE A FEW THINGS 16 dUXTAPOSED. 17 Q AFTER MR. KING GOT SUSPENDED ON FEBRUARY 24, 18 YOU KNEW THAT HE GOT A LIST OF QUESTIONS IN WRITING FROM 19 MR. ARNOLD TO ANSWER CONCERNING HIS QUILTEC ACTIVITIES, 20 DIDN'T yod, MR. PARKS? 21 A YES, I DID. I CAME INTO THAT KNOWLEDGE 22 SOMEWHERE IN THAT TIME FRAME. 23 Q YOU HELPED MR. KING PREPARE HIS ANSWERS TO 24 MR. ARNOLD'S QUESTIONS, DIDN'T YOU? 25 A NOT THAT I CAN RECALL AT THIS MOMENT. 11-253
1 Q DO YOU RECALL DISCUSSING WITH MR. KING THE 2 INFORMATION HE WAS GOING TO COMMUNICATE TO MR. ARNOLD IN l 3 ANSWER TO MR. ARNOLD'S QUESTIONS? 4 A THERE MAY HAVE BEEN SOME DISCUSSION BETWEEN 5 LARRY KING AND MYSELF ALONG THOSE LINES, BUT AT THE MOMENT 6 I COULDN'T TELL YOU IF IT WAS OR NOT. 7 Q WELL, DID YOU HAVE OCCASION TO DISCUSS THESE 8 ISSUES AT MR. KING'S HOUSE WITH HIM? 9 A THE ONLY THING I CAN RECALL WITH ANY 10 CERTAINTY, AT THIS TIME ANYWAY, IS THAT AT ONE POINT IN 11 TIME LARRY KING CALLED UP AND TOLD ME THAT, YOU KNOW, HE 12 HAD BEEN ASKED TO ANSWER HIS QUESTIONS TO BOB ARNOLD, AND 13 HE ANSWERED THESE QUESTIONS TO BOB ARNOLD. LARRY KING -- 14 I MEAN BOB ARNOLD TRIED TO IMPLICATE ME IN QUILTEC AND 15 LARRY KING WAS ADVISING ME OF THAT. 16 AND I ASKED LARRY, AT THAT TIME, IF HE TOLD 17 BOB ARNOLD THAT I WAS AWARE OF QUILTEC OR KNOWLEDGEABLE OF 18 IT AND LARRY SAID "NO." AND 1 TOLD HIM, "WELL, YOU SHOULD 19 HAVE BECAUSE I WAS." 20 MR. HICKEY: ASK THE REPORTER TO MARK THIS AS 21 EXHIBIT 51. 22 ( W'15. R E U P O N RESPONDENT'S EXHIBIT 51 WAS MARKED 23 FOR IDENTIFICATION BY THE NOTARY PUBLIC, AND A COPY IS 24 ATTACHED HERETO.) 25 Q BY MR. HICKEY: MR. PARKS, l'M SHOWING YOU AN 11-254
1 EXHIBIT WHICH HAS BEEN MARKED EXHIBIT 51. LET ME MAKE ONE 2 REPRESENTATION TO YOU ABOUT IT. YOU'LL SEE THAT IT'S TWO 3 LETTERS AND THEY WERE PART OF THE 639 PAGES OF DOCUMENTS 4 PROVIDED TO US BY THE NRC AND PURPORTED TO BE WHAT YOU 5 PROVIDED TO THE NRC. I BELIEVE, BUT I'M NOT CERTAIN, THAT 6 THE DOCUMENTS WERE STAPLED TOGETHER AS WE RECEIVED THEM, 7 AT LEAST THEY WERE NEXT TO EACH OTHER, SO I HAVE STAPLED 8 THEM TOGETHER ON THAT COPY, BUT THEY MAY OR MAY NOT HAVE 9 BEEN PREVIOUSLY STAPLED TOGETHER. BUT THAT'S WHERE THEY 10 CAME FROM. 11 WOULD YOU TAKE A LOOK AT.THEM, PLEASE. 12 A DO YOU WANT ME TO READ THEM IN THEIR 13 ENTIRETY? 14 Q YES. 15 A THAT'S GOING TO USE UP THE LAST 15 MINUTES 16 WE'RE GOING TO HAVE. 17 Q WHY DON'T YOU LOOK AT THE FIRST ONE THAT IS 18 THREE PAGES AND TELL ME YOU IF YOU RECOGNIZE THAT 19 DOCUMENT. 20 A WITHOUT READING IT, I CAN TELL YOU ONE POINT 21 IN TIME, IF MEMORY SERVES ME CORRECTLY AT THE MOMENT, THAT 22 THESE DOCUMENTS DID COME INTO MY POSSESSION AND I DO 23 BELIEVE I DID PROVIDE COPIES OF THEM TO THE NRC. 24 Q I ASSUME YOU GOT THEM FROM MR. KING? 25 A PROBABLY. 11-255
1 Q DID YOU GET THEM FROM MR. KING BEFORE HE 2 SUBMITTED HIS FINAL ANSWERS TO MR. ARNOLD? 3 A WHEN DID HE SUBMIT HIS FINAL ANSWERS TO 4 MR. ARNOLD? 5 Q MARCH 9, 1983. 6 A IF MEMORY SERVES ME CORRECTLY AT THE MOMENT, 7 SIR, I BELIEVE I GOT THESE AFTER I WAS SUSPENDED, THE COPY 8 THAT I PROVIDED TO THE NRC. 9 Q THE FIRST PAGES OF THE DOCUMENT OF THE 10 EXHIBIT, THE FIRST THREE-PAGE LETTER, IS A FEBRUARY 28, 11 TYPED LETTER, ADDRESSED TO MR. KING FROM MR. ARNOLD, WHICH 12 INDICATES IT WAS HAND-DELIVERED TO MR. KING ON 13 FEBRUARY 28. AND THEN THERE'S SOME HANDWRITING YOU SEE 14 ALONG THE MARGINS OF THIS DOCUMENT. DO YOU RECOGNIZE THE 15 HANDWRITING AS MR. KING'S? 16 A I COULDN'T REALLY TELL YOU AT THIS STAGE OF 17 THE GAME WHOSE HANDWRITING IT IS. I 18 Q OKAY. WELL, MRS. KING IDENTIFIED IT AS 19 MR. KING'S. 20 A SHE'D PROBABLY KNOW MORE THAN I WOULD. 21 Q AND YOU RECALL DISCUSSING WITH MR. KING THE 22 PROPOSED ANSWERS OR THE DRAFT ANSWERS THAT ARE HANDWRITTEN 23 IN HERE TO THE VARIOUS QUESTIONS WHERE THERE ARE 24 HANDWRITTEN ANSWERS? 25 A ARE YOU ASKING ME OR MAKING A STATEMENT? II-256
1 Q I'M ASKING YOU, DO YOU REMEMBER? 2 A NOT AT THE PRESENT TIME, I DON'T. 3 Q THE LAST -- 4 A WAIT A MINUTE. ARE YOU ASKING ME DID HE AND 5 I LIKE SIT DOWN AT THE TABLE OR OVER THE PHONE UR WHAT? 6 Q DID YOU DISCUSS WITH MR. KING -- 7 A I BELIEVE I TESTIFIED PREVIOUSLY THAT WE 8 TALKED ABOUT THIS LETTER, JUST ABOUT THE LETTER AND HIS 9 REPLY, RIGHT AROUND MARCH 9TH OR 10TH TIME FRAME WHEN HE 10 CONVEYED TO ME THAT BOB ARNOI.D WAS TRYING TO IMPLICATE ME, 11 AND I WENT TO THE NRC WITH THAT. , 12 Q I UNDERSTAND THAT. BUT I WAS ASKING YOU , 13 SPECIFICALLY ABOUT THE PROPOSED RESPONSES THAT ARE 1 ' 14 INDICATED HERE IN HANDWRITING ON THE FIRST THREE PAGES. 15 DID YOU TALK TO MR. KING ABOUT THOSE? . 16 A NOT THAT I CAN RECALL AT THE MOMENT, SIR. 17 NOT SPECIFICALLY THOSE COMMENTS, NO. 18 Q THE LAST TWO PAGES OF THE DOCUMENT -- I'M 19 SORRY, THE LAST THREE PAGES IS ANOTHER TYPED DOCUMENT 20 DATED MARCH 9, NOT SIGNED, AND IT HAS HANDWRITING ON THE 21 SECOND DRAFT. DO YOU BELIEVE THAT TO BE A DRAFT OF a 22 MR. KING'S ANSWERS TO MR. ARNOLD? 23 A I CAN ONLY STATE THAT THEY PROBABLY ARE, SIR. , 24 Q AND DON'T YOU THINK, MR. PARKS, THAT IF 25 MR. KING GAVE YOU DRAFTS OF HIS ANSWERS TO MR. ARNOLD, HE 11-257
1 PROBABLY DID THAT BEFORE HE GAVE MR. ARNOLD THE FINAL 2 ANSWERS? 3 MR. JOHNSON: HE'S ALREADY ANSWERED THAT HE DIDN'T 4 SEE THIS UNTIL AFTER HE WAS SUSPENDED. l 5 MR. HICKEY: I THINK HE ANSWERED THAT HIS l 6 RECOLL ECTION WAS UNCERTAIN. I'M TRYING TO TEST IT. 7 THE WITNESS: AND I HAVE NOT SEEN ANYTHING TO MAKE 8 ME CHANGE MY OPINION OR MY IMPROVE MY RECOLLECTION, AT 9 THIS MOMENT. 10 Q BY MR. HICKEY: AND YOU FRANKLY DON'T KNOW 11 WHETHER YOU SAW IT BEFORE OR AFTER MR. KING DELIVERED HIS 12 FINAL ANSWERS ON MARCH 9? 13 A NO, SIR, I DO NOT RECALL, AT THIS MOMENT, 14 WHETHER I SAW THIS BEFORE MR. KING DELIVERED HIS FINAL 15 ANSWERS ON MARCH 9TH, BUT I HAVE THE BELIEF I DID NOT SEE 16 IT UNTIL AFTER I WAS SUSPENDED. 17 Q CAN YOU SUGGEST ANY REASON WHY MR. KING, 18 AFTER YOU WERE SUSPENDED, WOULD GIVE YOU COPIES OF DRAFT 19 ANSWERS TO MR. ARNOLD'S QUESTIONS? 20 MR. JOHNSON: DID THE WITNESS TESTIFY THAT MR. KING 21 GAVE THIS TO HIM OR JUST GOT IT -- OR IT CAME INTO HIS 22 POSSESSION? IT SEEMS TO ME IT WAS THE LATTER, 23 MR. HICKEY: I DON'T RECALL. 24 Q BY MR. HICKEY: DID YOU SAY MR. KING GAVE IT 25 TO YOU? 11-258
1 A I DON'T RECALL IF I SAID BEFORE THAT 2 LARRY KING GAVE THESE TO ME OR IF THEY JUST CAME INTO MY 3 POSSESSION. 4 Q WELL -- 5 A AND AT THE MOMENT -- AT THIS MOMENT IN TIME, 6 1 DON'T REMEMBER EXACTLY HOW THEY REALLY CAME INTO MY 7 POSSESSION. BUT IF LARRY GAVE THEM TO ME, IT WOULD HAVE 8 BEEN BECAUSE I WAS GOING TO BE TURNING OVER A L' O T OF 9 DOCUMENTS TO THE NRC. 10 Q YOUR SUGGESTION IS THAT PERHAPS LARRY KING 11 WAS USING YOU AS A MESSENGER OR DELIVERY TO GIVE 12 LARRY KING'S DOCUMENTS TO THE NRC? IS THAT WHAT YOU THINK 13 MAY BE THE EXPLANATION? 14 A THAT MAY BE YOUR IMPRESSION, SIR, BUT I DON'T 15 NECESSARILY THINK IT WAS MY IMPRESSION. 16 Q THAT'S WHAT I THOUGHT YOU WERE SAYING. 17 A NO. WHAT I SAID WAS LARRY WOULD HAVE 18 PROVIDED IT WI7H ME -- PROVIDED IT TO ME ONLY BECAUSE HE 19 KNEW I WAS GOING TO BE TURNING DOCUMENTS OVER TO THE NRC. 20 Q WELL, THE SAME TIME THAT YOU TURNED OVER YOUR 21 600-PLUS PAGES, MR. DEVINE TURNED OVER ANOTHER 500 OR SO 22 PAGES OF MR. KING'S DOCUMENT. DO YOU REMEMBER THAT? 23 A NO. 24 Q AND DID YOU KEEP A COPY OF THIS DOCUMENT 25 THAT'S BEEN MARKED EXHIBIT 51 FOR YOURSELF? 11-259
1 A NOT THAT I CAN RECALL AT THIS MOMENT. i 2 YOU MEAN OTHER THAN THE ONES I GAVE TO THE i 3 NRC OR ANY COPIES OF THE DOCUMENTS WE GAVE TO THE NRC? I 4 (INTERRUPTION IN THE PROCEEDINGS.)
)
5' THE WITNESS: I THINK I WAS TRYING TO CLARIFY YOUR l 6 QUESTION -- OR CL AR I FY 44Y UNDERSTANDING OF YOUR QUESTION. i 7 YOU ASKED ME A QUESTION REGARDING WHETHER I 8 KEPT A COPY OF THIS. AND I ASKED YOU, DID YOU MEAN DID I I 9 KEEP A COPY OTHER THAN THE COPIES OF THE DOCUMENTS -- IF 10 WE KEPT ANY COPIES OF THE DOCUMENTS THAT WE TURNED.0VER TO 11 THE NRC, OR WHAT ARE YOU ASKING? I DON'T UNDERSTAND. 12 Q BY MR. HICKEY: I JUST WANTED TO KNOW WHETHER 13 YOU KEPT ANY COPY OF THIS DOCUMENT. 14 A WELL, I THINK I PREVIOUSLY TOLD YOU I DON'T 15 RECALL IF WE HAVE COPIES OF THE DOCUMENTS THAT WE PROVIDED 16 TO THE NRC. I REALLY DON'T KNOW AT THE MOMENT. ,
-17 Q YOU DID TELL ME THAT EARLIER. ,
18 DO YOU REMEMBER KEEPING A COPY OF THIS 19 DOCUMENT? 20 A WHAT DOCUMENT IS THAT? 21 Q IT'S EXHIBIT 51. IT'S THE ONE THAT YOU'RE 22 HOLDING IN YOUR HAND. 23 A YOU LOST ME IN THE QUESTION. 24 Q DO YOU REMEMBER KEEPING A COPY OF THIS 25 DOCUMENT, EXHIBIT 51, AFTER YOU TURNED DOCUMENTS OVER TO 11-260
1 THE NRC? 2 A I DON'T RECALL WHETHER WE KEPT COPIES OF THE 3 DOCUMENTS WE GAVE TO THE NRC OR NOT, SO THEREFORE I DON'T 4 RECALL, AT THIS POINT IN TIME, IF I KEPT A COPY OF THIS 5 DOCUMENT OR NOT, IF IT WAS PROVIDED TO THE NRC. l 6 Q OKAY. THANK YOU. SEE YOU TOMORROW. j l 7 (WHEREUPON RESPONDENT'S EXHIBIT 48 WAS MARKED 8 FOR IDENTIFICATION BY THE NOTARY PUBLIC AND A COPY IS 9 ATTACHED HERETO.) 10 (DEPOSITION ADJOURNED AT 5:55 P.M.) 1 11 (DEPOSITION ADJOURNED TO JUNE 23, 1987 AT 1 12 9:00 A.M. DECLARATION UNDER PENALTY OF PERJURY ON THE j f 13 FOLLOWING PAGE HEREOF.) 14 15 l l 16 17 { 18 19 I l 20 1 21 1 22 1 23 l l 24 25 11-261
1 THE NRC? 2 A I DON'T RECALL WHETHER WE KEPT COPIES OF THE 3 DOCUMENTS WE GAVE TO THE NRC OR NOT, 50 THEREFORE I DON'T l 4 RECALL, AT THIS POINT IN TIME, IF I KEPT A COPY OF THIS l 5 DOCUMENT OR NOT, IF IT WAS PROVIDED TO THE NRC. 6 Q OKAY. THANK YOU. SEE YOU TOMORROW. 7 (WHEREUPON RESPONDENT'S EXHIBIT 48 WAS MARKED 8 FOR IDENTIFICATION BY THE NOTARY PUBLIC AND'A COPY 15 9 ATTACHED HERETO.) 10 (DEPOSITION ADJOURNED AT 5:55 P.M.) 11 (DEPOSITION ADJOURNED TO JUNE 23, 1987 AT 12 9:00 A.M. DECLARATION UNDER PENALTY OF PERJURY ON THE 13 FOLLOWING PAGE HEREOF.) 14 j 15 16 17 18 19 l 1 l 20
]
21 22 ] 1 23 i 24 25 11-261
1 DECLARATION UNDER PENALTY OF PERJURY 2 3 4 5 I HEREBY DECLARE UNDER PENALTY OF PERJURY 6 THAT THE FOREGOING IS MY DEPOSITION UNDER OATH; ARE THE 7 QUESTIONS ASKED OF ME AND MY ANSWERS THERETO; THAT I HAVE 8 READ SAME AND HAVE MADE THE NECESSARY CORRECTIONS, 9 ADDITIONS OR CHANGES TO MY ANSWERS THAT I DEEM NECESSARY. 10 IN WITNESS THEREOF, i HEREBY SUBSCRIBE MY 11 NAME THIS DAY OF , 1987. 12 13 14 15 W I T N E S S 16 17 18 19 20 21 22 23 24 25 11-262
1 STATE OF CALIFORNIA )
) SS.
2 COUNTY OF ORANGE ) 3 4 1, PENNY SANDER, CSR 4769, A NOTARY PUBLIC OF THE - 5 STATE OF CALIFORNIA, DO HEREBY CERTIFY: 6 THAT THE WITNESS NAMED IN THE FOREGOING DEPOSITION, 7 PRIOR TO BEING EXAMINED, WAS BY ME FIRST DULY SWORN; 8 THAT SAID DEPOSITION WAS TAKEN BEFORE ME AT THE 9 TIME AND PLACE HEREIN SET FORTH AND WAS TAKEN DOWN BY ME t 10 IN SHORTHAND AND THEREAFTER TRANSCRIBED INTO TYPEWRITING 11 UNDER MY DIRECTION AND SUPERVISION; - 12 THAT SAID DEPOSITION IS A TRUE RECORD OF THE 13 TESTIMONY GIVEN BY THE WITNESS AND OF ALL OBJECTIONS MADE 14 AT THE TIME OF THE EXAMINATION. 15 I FURTHER CERTIFY THAT I AM NEITHER COUNSEL FOR 16 NOR RELATED TO ANY PARTY TO SAID ACTION, NOR IN ANYWISE 17 INTERESTED IN THE OUTCOME THEREOF. 18 IN WITNESS WHEREOF, I HAVE SUBSCRIBED MY NAME AND 19 AFFIXED MY SEAL THIS 29TH DAY OF JUNE, 1987. 20 - 21
" #L 22 5 S%[y4 gh resMR CALWOWA newwrueuc 23 M p/ oner C00*
O awlaJd-24 0 25 NOTARY PUBLIC FOR THE STATE OF CALIFORNIA l 11-263
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 STATION NO. 2 r License No. DPR-73 EA 84-137
)
EXHIBITS TO THE DEPOSITION OF RICHARD DALE PARKS June 23, 1987 June 24, 1987 VOLUMES II & III BARKLEY COURT REPORTERS 4000 MAC ARTHUR BOULEVARD. SUITE 5500 REPORTED BY: NEWPORT BEACH. CALIFORNIA 92660 (714)752 1090 PENNY SANDER, CSR #4769 2566 OVERLAND AVENUE. SUITE 570 FILE NO. 87-244 LOS ANGELES. CALIFORNIA 90064 87-248 (213)202 6666
'. {
, f . -- Inter Office Memorandum hea: March 1, 1983 l
3)SubScts Applicability of AP 1047/1043 to Polar. Crane Test Program [ 4200-83-105 / T3: E.Kithr,Startup&TestSupvr. Location: THI/U-2 Site Operations -I Bldg. #222 - Room #109 F g [ $
REFERENCE:
10M #4200-83-102 - Rejection of Polar Crane Task Groups Resolution to Site Operations Comments on . Load Test Procedure Recently, much confusion has existed over the applicability of P 1047 and AP 1043 to the Polar Crr.ne Refurbishment / Test Program. On Febrmtry 23 1963 a meeting was held in B. Kanna's office at which time the attendees were it vrmed of Site Operations belief that the Polar Crane Refurbishment Program has to comply with AP 1043 and AP 1047. This belief was refninreed to the attendees by B. E. Ballard, Sr. . Manager of QA at TMI. Subsequent to this meeting, the Test Working Group was convened on February 25, 1983 to review and discuss the necessary methods for ensuring that testina per-formed to 6te and any future testing complies with AP 1047 requirements. It would be to the best interest of all involved if the following suggest-ions were implemented to resolve existing concerns. I l~ 1. Test Work Group review and concur that all testing performed to date was adequate for satisfying intent of required testing.
- 2. Test Working Group review modifientions performed on Polar Crane to determine if necessary testing has been identified / performed.
- 3. Implement turnover process for the Polar Crane Jess the performance of any remaining testing. This testing should be identiffed as an incomplete work list item from the cognizant department. Any defic-l iencies in the refurbishment program would be identified by this l process and adequate resolutions could be addressed.
l
- 4. Test Work Group issue memorandum to TWC Piles identifying inconsis-tencies/ deficiencies, to date, and necessary steps implemented to prevent recurrence of program violations.
In addition, it has become apparent that all requirements of AP 1043 and AP 1047 are not being incoperated due, primarily, to a lack of f amiliarity with these procedures. I suggest the Test Working Group members be made available to the various organizations involved with the Polar Crane Test Program for the purpose of indoctrination of personnel in the requirements of these procedures. j' Should you have any questions pertaining to the T;:1-2 Test Program R. Parks. ' W. Marshall, and R. Warrer. are the Site Operations representatives for the PLFS
. DEfTS MBR M F0f:IDENTlflCAil0N PENNY]AgN.P. f
~m L) r n I n A ) $L
a, e, 5 l Applicability of AP 1047/1043 to 4200-83-105 r Polar Crane Test-Program' March 1. 1983 i !. 1
~
Test Working Group and are available for your assistance.
- r *
~
v - a jygg, v 4 k L//C . I J. J. Chwestyk Site Operations Di tror (Acting) JJC/R.P/ jaw cc: 5. E. Ballard. Sr. J. J. Barton D. R. Buchanan J. C. Tornicola . l R. Freemerman B. K. Kanga C. A. Kunder D. M. Lake W. J. Marshall R. D. Parks R. Rider J. W. Thiesing
- R. P. Warren File (s) t
) I I l i 4 1 i k t .. l
509 Inter Office Memorandum
- [%ij Muclear Suoiect TWG Minutes of 2/25/83 tocaten Adr. ministration Building To Distribution Second Floor .
The Test Working Group agreed that the polar crane load test will be a construction test performed by the polar crane task group. However, since the load test demonstrates the operation of the crane the TWG will review and approve the test proced0re based on technical content and demonstrated functional operation of the crane for turnover to plant operations. The TWG will review the polar crane no load test data to ensure adequate testing has been performed prior to performance of the load test. 5tgttup Tind Test TWG Rep. Plant Ops. TWG Rep. Plant Eng. TWG Rep. W D ~tA- h ' SiteEnfTWGR6p.
~
QC TWG Rep. EJK:cle Distribution: J. W. TMesing R. P. Warren R. E. Gallagher E. ,1. Kitl er PLF'S R. Parks DEFTS EXHIBli c
- J. J. Fornicola FOR IDENTIFICATION PENNY SAND R N.P.
In 3 19 wi7: H/elaxE f
- :-u
-a 'pf Inter Office Memorandum suorect 4345-83-0005 m,ch 7. ' a' TWG Meeting Minutes of krch 4,1983 MNuclear l twabon Administration ~ Building To D. Buchanan G. Clements J. Fornicola -
R. Gallagher J. M rsden R. Parks M. Radbill J. Thiesing D. Walker R. Warren , Attached are the minutes of the TWG meeting held on %rch 4,1983 to discuss Polar Crane issues.
'3 v- 77 h w E. J. Kitler ()
Startup & Test knager - Unit 11
/h Plarit 0
$~ Y-13 TWG Representative 3' &3 Id t 0lJ)llN.L%
Plant Engineering TWG Representative
$0Ad 1 3 ~1'83 Site Engi eering G G Representative 0D i 3-7-13 QA %d/ Ops TWG Representative PlFS DRB/DDW/jaa DEFT'S EXHtBITd Attachment FOR IDENTIFICATION PENNY ND ,
N.P. WIT: H OJLtJJ An a hs awm
, TWG MEETING MINUTES i A TWG meet 1hg was held on March 4,1983. The following persons were present: TWG l Dwight Walker (SU&T) l Rick Parks (Plant Ops) - John Fornicola (QA) Ron Warren (Plant Engr.) i Rich Gallagher (.SE) l GUESTS Gordon Clements (PORC) ' Mike Radbill (PLTG) Dave Buchanan (SE) Joe Marsden (QA) The meeting was held to discuss the following polar crane issues: l
- 1. Load Test Procedure status
- 2. Review of all data given to QA/QC l
- 3. Results of No-Load Test
- 1. Load Test Procedure John Fornicola stated that QA had coments on the load test procedure.
All but one of the coments were administrative. Coments will be pro-vided to group members when issued. All TWG members were given a copy of the load test procedure for final review. Coments are to te given to Mike Radbill on Monday, March 7. Rick Parks considered it was inappropriate to provide separate SOP's to cover prerequisite valve lineups. It was agreed by TWG that lineups could be included on UWI 4370-3891-83-PC-0001 cover sheet.
- 2. Results of OA/0C Audit of Polar Crane Task Groups Documentation of Work on Crane Joe Marsden stated that all deficiencies would be covered with one QDR.
He noted that many of the modifications were made without ECM's. Back-fits could, however, be accommodated with engineered drawings instead of ECM's. He noted the following specific modifications made; not in accord-ance with AP-1043:
- 1. Trolley power and control bypass system
- 2. Installation of 200 amp fuses in main disconnect in cab of polar crane (vice 300 emps)
- 3. New pendent station and festoon cable
TWG Meeting Minutes l Page 2
- 4. Installation of two mounting brackets for , jib crane on trolley
- 5. Installation of temporary air supply on crane.
The QDR will be submitted to Jim Thiesing. It was noted that these 1.tems. had been discussed with Design Engineering. Other deficiencies noted were lack of compliance with AP 1047 and 1043, and missing signoffs on UWI's and Work Packages. ! 1 It was noted by John Fornicola that the no-load test should have been re- J viewed by TWG but was not.
- 3. No-Load Test John Fornicola stated that all QA coments were administrative in nature.
Rick Parks expressed concern that in the no-load test procedure, Steps 85, 92, 220, 228, 320, and 328, it is not clear whether the limit switches functioned. Mike Radbill agreed to provide written clarification. It was agreed that the following open items of UWI 4374-3891-83-PC-0002 ) would be resolved piror to the load test: q
- 1. Upper geared limit switch needs verification of operability.
- 2. Trolley limit switches need verification of operability.
- 3. Lubrication of main hoist gears on trolley.
l 4. Additional Discussion Mike Radbill noted that P.C.T.G. performed ad,1ustment and verification of , proper operation of the upper rotary type geared limit switch. This was j performed via an approved UWI. It was agreed that it should have been re-viewed and signed off by TWG members. Mike Radbill will initiate a , Startup Problem Report to address this. ] Rick Porks questioned whether the polar crane hook had been used to lift any loads. Mike Radbill stated that, to the best of his knowledge, the hook had not been used to lift any loads. John Fornicola noted that no testing has been listed on the PUX. It was . agreed that all further testing would be listed. . l In response to concerns from Rick Parks, it was agreed that TWG is not re-quired to approve lifts using the five ton hoist attached to the polar ; L crane main hook. 1 1 Mike Radbill noted that Recovery Ops was directed by Design Engineering to install dumy fuses vice 200 amp fuses in polar crane main disconnect.
l TWG Meeting Minutes Pa ge 3 It was agreed an ECM would be required. For the sake of expediency. Rich Gallagher agreed to prepare documentation utilizing AP.1013 to perform this modification in advance of ECM approval. i It was agreed that performance of the load test would be in compliance with AP-1047. l It was agreed that disposition of the QDR discussed in Section 2 shop 1d not affect acceptance of no load test results or TWG acceptance of the load test procedure based on technical content, i l l
-k e
-_5
1 Inter-Office Memorandum 43450-83 4 00 case musa m March 3i . > .8 Nuclear TWG Meetinji Ifinutes of suoject March 28,'983 ' i To J. Chwestyk 3 Location Administration Building J. Fornicola R. Gallagher ' J. tiarsden W. Marshal.1 . M. Radbill W. Re'am . \ J. Thiesing D. Walker R. Warren PLf'S DEFTS EXHIBli 3 FOR lDENilflCATION PENfRlSAfiDER n ,Q 4 gg??N.P. WIT:_f._t.clata VJ 4 Attached are the minutes of the TWG meeting held on March 28,1983 to discuss Polar Crane issues. *-
!?
,.7:..
$YbY y 3/19 /8 n' EF J. Kitler , . , , ...
Startup & Test Stipervisor,;-Unit II MN N' 3/2.9[A A Pl' Op TWG resentative f
, &' bl1!} l 0 Plagt Engineering TWG Representative p c4 7[k Site Engineering TWG Representative J f 3 P
3, c, (c en sus 's 3N ' '
'GPU QA P.oc/ Ops TWG Representative RB/EJK/jaa Attachment -
C M _ ________--i-------------------- ~~
i g TWG MEETING MINUTES l . . l A TWG meeting was held on March 28, 1983. The following persons were' present:
.WfG, Ed Kitler (.SU & T)
John Fornicola (.QA) . l Bubba Marshall (. Site Ops) Bill Ream (Plant Engr.) < Rich Gallagher (Site Engr.)
. 1 GUESTS Mike Radbill (.PCTF) i Joe Marsden (QA)
Joe Chwastyk (Site Ops) The meeting was held to discuss the following polar crane tssues: Discuss and resolve site operations coments to the polar crane lead test procedure (reference: 10M #4370 83-1019, IOM #4200-83-102 and UWI-4370-3891-83-PC01. Comment
" sheets genered by R. Parks dated 2/17/83.)
Discuss setting of the Polar Crane trolley limit switches.
~
- 1. Polar Crane Load Test Procedure coments as transmitted by 4200-83-102.
Comment #1:
' Resolved; TWE felt that the Safety Evaluation attached to '
the load test procedure was properly completed.in that it referenced the load test'SER. The load test SER concludes that the activity is not an unreviewed safety activity. WG will write a letter to licensing requesting confirmation that
,. the SER conclusions are correct.
Comment #2:,- Accept comment. The TWG has reviewed and approved the Polar
; Crane Load Test Procedure. !
Comment #3: Accept comment. The Load Test Procedure has been revised so that Revision 3 complies with AP 1047. Comment #4: Accept comment. To ensure that adequate testing has been per-formed to meet the requirements of the test program, the Test Working Group will request that PORC and Manager of site Opera-tions review and accept the test data documented in the UWI. This review will be completed prior to performance of the load test. Comment #5: Accept coment. The plant status, as required in the load test SER, is delineated in the UWI cover sheet. The SER will be reviewed to ensure that all plant status itens are covered (action fer D.D. Walker, who is the Cogni: ant Uha&rmL.
Page 2 4 Comand Center Manning is addressed in Procedure 4300-ADM-3240.01 and does not have to be specifically delineated in the load test procedure.- Coment #6: Resolved. See resolution to original coments in IOM 4370 _ 1019. Comment #7: Accept coment. The WG has reviewed and approved the WI , which includes the SER. However, TWG will not formally sign off on.the SER. I Coment #8: Accept coment. A QDR has been issued to address modifications l to the polar crane and any violations of administrative pro-cedures. TWG will review and approve the test data to ensure that ade- , quate testing was performed. (TWG has reviewed and approved I the test data with the exception of the setting of the trolley j limit switches which is scheduled for completion the week of 4/1/83.) Coment #9: Due to ALARA concerns, the results of construction testing prior to turnover per AP 1043 will be reviewed by TWG, PORC, { and Manager of Site Operations for acceptability. Favorable , acceptance of these test results will qualify these tests as functional tests satisfying the intent of AP 1047 Titus testing will not have to be performed again after turnover. (TWG has reviewed and approved the test data with the exception l of the setting of the trolley limit switches which is scheduled for' completion the week of April 1,1983.) Comment #10: Accept comment. The test director and task supervisor will be certified Startup and Test Engineers. - Comment ill: Resolved. See resolution to original coments in 4370-83-1019. Countent #12: Accept comment. The Load Test Procedure has been revised to comply with AP 1047. - Coment #13: Resolved. See resolution to original coments in 4370-83-1019. I Comment #14: Resolved., ' See resolution to original coments in 4370-83 1019. l i
- 2. Setting of the polar crane trolley limit switches.
TWG stated that setting of the limit switches would be considered a functional test and the UWI would require TWG, PORC, and Manager of Site Operations review and approval. i
. i
+
# intor Offico Memorandum I
Date March 18. 1983 ? f
-4370-83-2033 jQQ%hf l 5 oiect Polar Crane Main Eoist Upper Limit l Switches and Trelley Limit Switches RE: UWI-4374-3491-83-PC0002 - Location Three Mile Island Unit 2 To Trailer 105 D. R. Buchanan Tile: 0303.2/4700 NP.
Manager, Site Engineering This memorandum transmits information regarding adjustment of the polar crane l upper limit switches. It fulfilip a 'committment made by Mike Radbill at the Test Working Group Meeting of March 4, 1983. This information is intended to ; clarify results of work performed under referenced Unit Work Instruction on l upper weight-type limit switches and trolley travel limit switches. The main hoist upper weight-type limit switch was to be checked and verified as operational under work' items 85, 92, 320 and 328. Jim Graber, superintendent i for the job and present on the crane during the test has assured Mike Radbill ; that the upper weight-type limit switch did function properly, and that the re-suits of steps 85, 92 ' 320 and 328 should be so interpreted. Furthermore, the upper weight-type limit switch and the upper geared-ppe limit switch were ad- , l' jusc.ed and verified operational during performance of WI-4374-3891-83-pC0008. l A copy of the signed off part of this WI is attached. ! Regarding the trolley limit switches, steps 220 and 223 of the referenced WI in fact verify that the trolley limit switches function properly. Jim Graber assured Mike Radbill that during the test, these switches were first actuated manually and then by the " dogs" on the trolley as the trolley moved toward the bumpers. In fact, the limit switches did " cut" power to the trolley drive. So that there should be no misunderstanding, UWI-4374-3891-83-PC0013 is scheduled for March 25 to raset the trolley limit switches in accordance with recocemendation fron Whiting Corporation. . The above information should answer any questions the TWG may have on the polar crane limit switches. If you or the TWG have further questions, please call l Mike Radbill at extension 8865. , j
- k J c
. M. t.
d . er, Recovery Operations jri Attachant as stated pLpg cc: 15d T er[ w/a R. J. Barkanic, M!DS EXHIBli R. L. Freemerman, w/o M. E. Radbill, w/a FOR IDENilflCATION M. K. Pastor, w/o PENNY SAh N.P. WIT: RI M aAAf****
3m .- .... ..... g . .... fo-M7@ It sUNuclear = = = = =
- 7 1 titi-ts occ=
U*'"*** R$umO'es'8*e
# Otae. Men aewrs g pSeet'ea g Asse h Roewmements Este.etesiae1wei
.Posttose :1 808 ii h eeted A,ee K wSa 4I w :1 i uz.nt: nones ti TCN 4i Restrated Ares *l i ii ff5 SAS ei 1l MwP % '
c I WAAM Seewrev Area II ECA tI mes con ti Aamen. Seeg. ITA t( d 4cevery Opne g Sness. Laes. 0' hoe II 88 II TAG I8 ' Otmer i - Otmer ii RAD M # scene t 1 5 4lll eateseOwage afestSTon J . 4 M N AJCMJ 6AMwe swa.dtet P/c An A .as Not a r" 6. e ma 8 P Sw.TEWa2 80weverstees A e s Alt 58SC28PT80N or woms: V enswy. optrurtsN A cJ u st A ND U GRlPf OPEMnoH a tt
~
l- @ sT 5'u M E3 s OW..' M ha. cM us M4 sN Nst >r G E ARSD AND Loul VA tausn] [h.n. Att w .0 thoax.
' (VfP E A-
, '.T. M a u n e 5 o o 19. b .' . o ...e
?.e- e l .
s ee a t e Os O O
- e e OO .
O E 46 Mg e MO O b 0 engbeer-T- Revision W <
# MIL fS09 j!
N Date s m e m ,een m as ean ma W s D '?S/ .s .] 7/- R ) "* - '"' W M 2 4 0 -. . A W i , 7 " .".w a x , e
-c
-. ,~%, u,
. . - -l .e_ _ e...
T e< esa i 2 Nuclear
- a. -
p , tei n., ,.e , ... part 1
- postspuut U, M " "' Cesett 880 WEST C test
~~'
p e,m omes, 4 5~.1 to. - 39'sI - Mt R. -m> :oss arv.- l TIrwieuses: F/c,eaiu e rL/uiT h e m
. EK If .=orute n = w same w , of tse fenwies .nu.a.. is, s,.e.tw ,u.n to oneuered pee. .
3 smassertat - its a tae p es. ore /pe een en, saap/ art oserm a aluuter wt ttel nieue of (11.id or pus it natuetta t3 (( 1.1 .em.nei w w .1 1.2 Bees see prosesen/pcesseum sheage/ tar! seerese speteos, semeaente er estions'eIntch sentre) er esatter [] rolesses er poteettel releases of resteesttoe/asa-resteestin esterials to the omstressent (tssluding saapitag, este reeerstas sad Peteattee testPWe#4 setterettee. eneseremente and omsipets, ene estica to to tessa snea ' lisits are reeshed or esseesself 3 3 tese [] ((
.ssu the,eres,e,ewre/pmsseum
= .r,4 ebenge/Wir! emersee the etseestt1en er eterop for etspos1tien of esy non ree1 east if e;y of the esew est yes. semiete port !! sad teslees tes plaat Derettene Sovise Cassittee (p0RC) eas site teorettens Direster se pm.teeleenstetten reetow.
ft8 et
]. SAFETT RELAft3 3.1 Boes the preseeere/presseure sneage/imrt eserens stewteres, arstems or sempeness (tastastag see eestpa. () (
persnestag. fatrisating, need1tes, setpetag. storing, slocaias. ecosttag. taste 11 tog, tespecting, testing. speesting, estatetetag. repetetag er emetfytag of sean strustsees. arstees o' so seaeats) that enrest er ettipate the cense. eases of poet 1metas aestdoets tast seule sense oasse rios to the neelta and safety of tae puelsap
/ girl este stenges to a processee escribed',se the Flase festatset teelmetten ,,, [] ((
23Beesthepresekre/pesseeureshMe. tapert titsi er saanittee. (to Erstem tourtatica (581 er sees tae peesesare/presees*e ; sneage/lart sensect a test er esportesat,gi mestices ta see rnAa 15 or 38. l If either 21 or I.! ere res. semplete part !!! and tesisse the plaat Operettens Review Courtttee.
$tte Operatises Strester. and Haasger.1MI.2 Licensite se LAs pee.taelementattes mies of tae propstes peesseere/prosesses stenge/larf ens safev esatnetten.
TE3 oc ! J. Iw atTANT TO 3arfff 34 Sees tee preseeure/pessoeve: stease/ tart seres: e aretoo, seseneet. or estieite neetes etcest er tadirest effest () l ce see parstesi, feastionel er emmen 46111 4 to eserete the festity, to protest tas totegrity of tae sore ens to de es ettaset ensue riet to the heelth and safeV of the pub 11st 3.8 Sees the pnsecure/pmsekee ensaps/Wf! seerese e potes, sempement er setter eseresses las l A. The seeltsette eselity sleselfiestles 1969 f, [ i
- s. ameness a. se en se ,
; ;, L
- s. Appeasta A. UBeRC Sepleters teim 1.33 (ty gemarts title er awatt?
If esy of tme essee as pee, tastees the Fleet Operettens teeten Cesetttee (posti sat lite Operettens l streswr se tan pre tapleasausses eles of proposed pnseeere, away er meisten. l tss oc 3 efusa Boys the peepeace presseure/kesseem changs/Wrl teplanet asy of the fellesiag:
- 4. . bb 4.1 seserity ries 4J Essegsasy ples
~
~ ~~
. .. .. p -([ ,p % 1 4.3 Restettaa protesttee ples .
,/
f ' 4.4 tassoo n eseretten pies 4.5 gesavery nees (Sect. Rose. 6.8.3. D sof 31 G - ., $3l/CI,d ,f 3, jh i I s.s asso wry sueitty asseresse Plan 4 . A f f ear of the eksee are pen. talass the Fleet Operatione terter Capittee en the pre.telemeoutton rectow. - If e.4 or 4.5 essee are pen, les IEE ses11 resten ens esprese ses presesum/p asesore stampe prior te taplemoution. E atient1* =a.i if e11 m ee,= = . me we,me - / prae *= snea,m . w m*.e. , = moonst.se =p. If ear of tse esose esmers see pas, see presseee/pressesre stenge/ tart saa li swelete s,mtstes n,te, eng se e,pesees er sae site eporettens Meester. W eT1% SSPhrts pts / r, ' s_. ,.p ar}j ll" $yyg, h,
', f ! .an%. =
- I ") .. 'I 3
l l ; s , e sw 9 n t
- 1
- ~
c o . . A r h i E hDh " _'>
.A
_ 4 . F M-
~
~
s t S C A1
). $
1 l h mJ I hS L " f M 3
' nM .
f TJ' 1l
~
i sl
.a 2 -
f 3A M J fa J i' h I f J G E T - f- 3- & # s-
. ss 5-2-
P A 4 # s 3 2- - - S w 1 r - E 2 s 2 i s r- s B r _ E F i m i C k 'e L s tXU P t 9 L"- 'M F=W P ' W I I gl M 3 3 Ps.M M 6 v E
' i -
t . .
- = n C C c C ^
C p I V c e
. E 2 t B
A E w t C
~
s a ' n e . r C G - 2
= 9 2 0
- 0 0
h u L 0 . , 1 _ E c r A 1 , R I t n 1 r ). P A t a r P . A - S e T3 N w n i l A ' M' - I R8 w i A/ 15 t i s. d
/
2' n' a . 5 2 e w n _ m 0 0/ I. a d d d d mC /( '..m.,. 3'
- L.
o r 7 1 sk A u t \ s t' E2 T e I d e E T A
~ A r t l e e e e i
r r r l i J' .
- r. .-
yU. _ s f d
- e r
e i D n us u ne ets i - e i r n .~/ _ i t m s e e q v e n v A i i E n o m e e e e d e u n. f
._ . / o t
l C t V E R
]
h M R R R c a t t t t o o o o i t m t Ef f , e . W i E_ e m r t n e 0 7 0 3 8 c l s C D S t t A N N N N l i f
. o.
o. s MT - s i m u u . s I k i
# N L '" .
. . e c a
m a/ v 9 u / s i ' j d t
- s s t - -
I n a nM r I n M l s
.5 a ua P % n - ^
a p t A I_ 1l 7 . e t v t y c J s - .. = y e Y a r r
& *. GW e V 1 M T h t 2 :.
t e I L >- t e o t l o J h d p f r a 1 f A
- r. ;h n e Ev t
4 E i a [ n S 0 e a n- l i il -
, ( l s S y e e
v a l 5 r C R o e r e D l t d-t n r O E M 1 w n i i l 4 ) a s y m a a a 1 n n a P 1 1 8 C r D - o o s r l1 l f D i n i o A e P o f e l E W c F1 # n C t y t c r e f r m 1 U r o A ar e a -
't $
S E W I a D P m i . n u w o p l1 e i S ,l t t e b p 7 w W o o TO a p I g f e o 1 1 j 5 t e
. l p PF r y l _
h y b o d m a b T a C p c r s n .D x i E_ i t a a y s in / A e n s v i r n
. l e t r n e 'i f e i e a b i E
n c or o k de C . w o i y on I1 9 c E e C - e s E d d u p L i T P lte I n p s . s s q s 5 h s n d s ; e 4 mn o e i m t e 1 7 C rres t . i a s F M p h A i h t 1 o n t c a s 1 0 s n n o s f et as "r r f DI mo t ( mc e u am d t o Ft c i i t nC 1 i i n d n e V l i n r 0w g i A n r . t e w r a h e a ac t V s e.P ug e . e l e w 11
= T p e s y e 4 t e es r t gJ u n us 1 5i . n c p c a c. r. r C e A t os e e e p
i s n nt . 0 p e wt s a i n t g n f r in e e yt r 0 ru N a ar o i s o d n m e t t s e p eCr a te ns p ss a 1 ws n O l 9t s f h e s s e i sr n a it)A ar l A t t a l e n o l P A i. ;
- s. detu T e Am t u .
hg I o = n C q p s Pr g f p - A o s n i E a C EG e; e i s n gn i r E 4 s i e e on e 'de e G
;t r
l s s e o 1 ep e I 8 i f A r A" i u f D - e de a e e 3 wy A 5 v i R aie A : g p r n t Lr o pe r e r s. 3 r E t6s A s in aI mD $ i t K 1 e s t a t Lc r t n V A . L en e . r - C A T i f K P e A e i 1s e e t g n
. rc are AA_ ssa t l L er pa e
c l
~
P C E r n s . er . ie ng n s C pe n
/rr 8
K F T o e m s es a a n p A l e w ns w'6 b
- s en C U n e
J A s C T I R O DD R r 3 e w~oAM e OA A o OoE ' a t W P V ".
' i2 3 4 58 7 e 9 f e
I 1 4 1 t I l - ~ [ t 0 L Jt [ f '
- l 1lll l(lflflllll l1 ll l )l' 1l
f( ) l' fllI lf. l j, Q y 1_ o _ 3' ._ 1
- 3 b
J 4 . L 9 L b~ h LA ' t s e f ~ 0 'f"
- d N E
G W E 4 c Wh/ ~ 1 i l f Q/I ' _I 3 l af 9.6
~
.if i
n S A f 3 S J - i
*d - -
R f xF J 8- _ O t i f 4- f /. f # J _ A y f- S f- ,' f- f. f Mer t / P_ L d L&
/ #
/ a tF _
n j r f~ 1
'ea f
T h ' f M su 7 e ' M < f
' C C e } C c
v t s sAdam ;*
*~
1 ) 3 e I T A t- - - T C 11 m
- t h
= i -
c
' rw d ee f
# i t
- e. 8T c %_ ra o m 4, M Z 1 ' p **
4' " t n 'md a d e a i ts pw e a J% O n h S g e n [ /f iI1 jI f r I'
. ll 9 , f e v
l T e e t e
- g r e
no e a s os l0 g l o t h t es n o l p a e i n p n.gF "p h u l c de i I k r t t r h i d c O e w L r c e m r w k - 'u o
, c o - '
e d s z ' w n l
' c n , I v n d h t
f s o e o o a e l u c r ). 4 a i n ts c p . = e e t e "T p 3 t c r a u n e p d p e s e s , i t t S i d i e y l w e s A c E n n . n c t o c t d e s ne t F s o a t u w t t p s d c J.e " _ r ye t n m o i e i n j t e s a e a n la l e } k y p a t i t n " 1 t a '2 d v 5 n o c o d b hg c w l s o o l s t s f. . i m n g i e 3 e p e d i a o i i e n p n r e e l l
- t. s i h b n ta fr l
l w d c e i n i t e n l i n f d ( l a o o h lu i r d o an t e _ e r d t e a l o i o e a t e t r c h t t r e e t
- p o e n a m f r in s a t p l r r e e e d d v n r o u f o f i t n
h' e e o o s a n 1 t a nni e a e l c f e a u d i le d i s n t o r l c e r s n t S e l r s p o o e e u d n a n p p r r t n p e o u p o p j u s e f e e a a g t i k . o t a v g r r. n a t . c d e t d i h a h o
, h c n i c a r o e l s I d V t c i r o c o l s e d r ,
t _re I T n t r e i l i t b pd y y o r t t d i v e i a b u n a . se sap l l c - u a e n . m r q e m w l s e l e e a p i n s o s e b me s d r e c n e a a t F l t m a " c ns o g i c i p i r c o T e c a n o T A a t l l S e i m , o pe el t t S m t c te e g g ae l c e h Ar t i d o r o n e t c h Ff a x e 4~ t e ad E y t o n i a a h l n c " n o r o n s v pn G i c no w k k s lu a t o r r f A H t A c c r i t u i o 3 c a w a ee t p c d m r. a r c r pp an t f c se e p K 1 i s w i a c
- i t e nt C
A w a e s e t i l a h d o Uf n o .
- d c r i ve e
P CT nd i i k k d t n t 2 r s 0 a t e p r r n i a i t p 3 p t d of K E J v s r s o oe w m k y h e i o 2 f o n n
=
s r 3 R O u s e w w p , s r I e cl t e t t s o a c f O R n nw a E 1 v . oe i t s u n o y P o a o i s rl c e e a r W w i p v i ee o r, v M d r e l t b a l c h . c p o r e l c ht r a r A e e l m1 p i t t i u i a t i e e t t t k e R r n d dt 1 t e t t o n c s C a h d n 0 a l c c i. r n s s f n o a b e o n au t r n t i n a I m o o n e i t a o p o M g e e 2 l s o t rl c r r I n c n 1 r u v n 2 n h , e c c A. s o e p o t . t u u c 1 e o t c e l I l e u - t n. e r r O s i s n ls p n m s a t a a P e t t e E m t a- . o l l I I c a l i a s o o f r f a u ; u o o r t N c t w n M i b t I f I c n ! O A T p p N ? 5 O % D - O' F J I 0 0 2 7 0 I 7
? 3 1
( b '_T tI! I ! llI lI, , )l
E L C , E G aW . A P M h - f ~ A # S - S ~ T P sf f: U S /~uf . W t '.i 7 - S dika l I .i' . V C
=
8 8 t N- f t a f ' 5 I d I I e
~ f l
l9 e v l 7 ~ sa t e d e r a l e - t s e o u lO n t s
- a. t. i s
e e e a t n f e
's t 1 .
l e i. s f n a a r l f n i i 0 . e k i - p i m t e
. r r i m n p I t n
s i n e e o e y m e e c u 6 l i a e m e v r p a n i s o i . l o i l e e r t t 5 e m t l r 7 a 1 ni i a e c. - e t t n o. e t a s s a t a i m n a t a m 3 t t .
. c we r e t an a
i l t e A m s r k v i s s e E 5 . o r s 4 e t a s F i e . l e ro r 5 4 e t l t
- . e y u n c m a
- l e 4 n l O
3 s. c .. n e e i t a . r 1 " 3 u t
\ t u (M n ie r l t t n e e n
(- o p o n c i n a - v e d n a c t p i o a a A o r i
- r m e a b c t k -
b h t l e f a e s c - - a t s e d 1 _ . n r n o a a I - u s e i s
- o r l -
l s n 5 c i w c l - l m t
. - s H e r r
e r t
= o d h b
' - t "5 430 I.
a t e t e . - e 1 l u t d - c a i i h a 1 a d
. s m l o
s l t e w n a n t a rn n e s.m o t e de i t r l
- 1 a ne e n e
s e l s p l a s ta s e e s 1 - 1 . h t t t t - t
. n n h u e 9
'5 "8 S k d v a a .
i o s - e l _ : s t ne n - o- n c "8 a A, r e o i t e o n w i a - i n p t w n t a t t - b Y 5
- r. ht e y sr i l s c e ) r s- e i e vo og
. e T 1 i o . I s e k 2 d o r o s s l
v t
._ r a t b ees ec o
t i v n en b t o si % d n
- t ei i
t b i m e n a o a - t e d t C e e d e a w t d a ne
- t d a b ee a me A t se e t n B
I t l f.e _ n lo mn e re ^ f d i n h t t a t = i ne f ev d d n e G _ ^ h a c r ts r nh nl e e E 7 8 t l l
- n. sC t os a f n 3 S t e a a vS oe rc rn r t r c G 5 A I
c d c r u A i t f p r
. A F . ae t
ua u a . A 1 C t i n o e mm F '5 w e t ao " v ct c t d K t n " 0 s n a cn e 1 a l p . u y o c s C T f l e e . n _ e e n '5 3 t ho ep n r n T t S n '5 lh oi - oar i A P CE t
% . a s k e e' i H n a i03 la s d p f
s y ? . a o b y l p K J l ? C o 3 o a r. w dna k c" od ot i R O g h nl l k 1 t e c n t5 t e t i t O R n n . f n c n t I s e f o a t- y s t uen a n P e r . o o e e- o o a U r o t l i n l W g h . t s W e l i v h t e d ( fo e e b r l c e . i cl s t m r . e r e a - e i t t n i _J e d ne a l d v tn t t t s t e a 0 . 1 t e t e l i
)
J v e ae a tb e es a f e e e aa n l nm a i i m se D n as i i 5 2 s. c c t . nl o K I r l 2 e o l. l r I e w o er c y i e l l t t e o c a. r u ts d
~
t m N r r n r o t p s e d l r e eo i mo r t u a.n e-m a e i d l f t i u a k r. e v h s u =! s s n e e a v s h r c E s-i e rA - i c wo j i a a t m m ha i. p a t e f e i i t c { t n I e. d e
- h. t i. .
r l -e I S n I 8 A a I p l
.b
. a". f A l
a e n I r n . h U 8
" 0 ) n 0 % n i M ~
8 4 N 7 l "E 3 1 N i l 2 1 1 l 1 7 f l tll
[ . u I _
- t M
A O
'W t a
c
." Y 4
aI f f W r E C 4 5 E.
- 3 4
t s I 3-s-
'w a f- W Me v A d' s 5" b
r a Fr~ - c <- . v a e
- w c 2 e 0
- e. 0 3
t a t P s e . A m . V
,l l1 . ) a
- 2 9 e $
1 7 k A e 4 4 Fe> c. o c <=e ,c k 1 2 t s = h a e e . 3 f. i e M f-f w d , i s di c 2 4 l e a o l e ,
,., a r g c r C c, -
l It t n '2 C : b a t i t e n e 53 ( H . T n a == t e %~ W M 4, aA
. r u a n r e e e n e -
c r ' m n - e e e m a a a , t a 1 m t 6n e 4 i l I
. g e44 c c . f t r _
a l a c I d e a e
'h , L w
~
\ e e t
e
)e s v s
r -m 2 l se n e a e a L t f n l e . r l c e l t.. T e F _e e y s e i t o N - a . e e t a v t ) t r t s t C b e e t s et b e i n a a tJ a s e m a o 7s a c k e l e e l e s t a t m ce t
= J "s u oJ r.
o
.I s 2-i r e r s o f o
o 5 s e v de e cs a en e w a o J m la r c ' nu l r n e M 3 m are e n Te *e , e e e 3 a n l a m l o c L. " fn me t e . r = an e a oM ( a e e t e s t e c d r m eo o, a. re e P. V r t e a s a c u - w v F T i e e c a r c a - ra j I s w
. f t e e
- e. a=
e t c r u c ts 1 1 0 1 r d h t r s eap s t e
. s n
dP T S no tn s t w/,a T o a c = i i a s e Y A T.o V F C eu. e b*_/. y h w n e n n e o : l T ( n y n a t t ul F A 0 e e e r . e e v 7 E re i T t o 4 t n a) l n r 7 '
. a f 4 G A s e e r r f a
A m E n 3
/
m hc
. e m
r na p t oe t u c s s se w, ie p ie a 1-K C w d 3 5 l u t c rc m n o d i d s T Te s o e e, d a A t i e e r P ce d 3 rop w I w - a er aa .a t v r t C r ) t p u s a r t e w t s r p l a e d l e i r a m o n e o o l n n u t s e r P e. m e s r e o t s b t a t t p o a e s r m e n G e I f m 7, c.-'0 oo c u ne 4 he as . s 7 w a A .=2 i n m o C , c 0 t t t e r t I e r o d n s = t 1 i 1 3 k r e r C c. e . . - t a n d I h a t t s n. me 6 ( n a Ta mj
. e n u e t l a v t e m o op c c = t e s e m o h t l
e e a n = r . a ee a. . m t u t c e c, a c e e o n n n t e n a c c. E 3 e ke T.m t4 ph e n a s s7 e e a i n r e o e. _ w S l a p r f e s r c t . e (A D M# a- 1 I e : h I n f T A C u i I I t 1
" 9 8 l 0 ~
b D
)
N 1 8 8 7 4 1 M 1 l 7 3 I S 4 4 4' 4 2 Ifll!I\'
1 l u. seu w e,e ,s NucIear - = = = - - Route 441 south Mgsd6etown.PennsyNama 17057 717 844 7621 TELEK 84 2386 Writer"s Direct DelNumber: f February 18 ,1983 f 4410-83-L-0037 M Program Office Attn: Mr. L. H. Barrett Deputy Progem Director US N clear Regulatory w maien c/o 'three Mile Island kle Station Midd1stom, PA 17057-0191 SC-2 am
' M Sir: as*.i
'three Mile Island Nelaar Statian, tinit 2 (M-2) W"" ' " " ' ' ~ '
**=8 = > e Operating License No. DPR-73 m. m ,
Docket No. 50-320 Polar Crane Refurbishnet mmr - c*
,,,u-w. ns Enclosed for your apprwal is the Safety Evaluation Report (SER) fa the - wu m Polar Crane load Test. '!his doctanent concludes that the load test does Eda *'
ret constitute an threvisued Safety Question and enn be accomplished with-out undae risk to the health and safety of the public. Yourcooperationl lTg= "y in expeditirs the review and apprwal of this doement in a tinnely ammer 6g%';, -7. .a . . is greatly w 4=ead, m .=
- If you have any questions or desire further M-*4=, please feel free Cggf "
- m. -
to contact Mr. J. J. Byrne of arf staff. T'" aver-Persit
+n a . e w
y
"--' -a = <
Sincerely, ; T?@.a.
/s/ B. K. Kanga yg= ,
, --= _
B. K. Ranga Director, M -2 : N /3*P a$25tYd ' m.h - r-i Attac+umare g "~ " " m 0:: Dr. B. J. hdyar, Progre Director 'IMI L, Office - 9 Y!Y "N mm er 1 l i J GPU Nucteer Co,poration is a subsahary of the GeneralPublic Utdates Corporaten PLPS l DETTSW _EXHIBli 36--
^
l FOR IDENTIFICATION PENNY , N.P. g 1 WIT: _/L*f #mA 1 E______________________ . _ _ _ _ . -- J
Safety Evaluation Report - for the Polar Crane Load Test l FeDruary 1983 Three Mile Island Lnit 2 REVISION O FEBRUARY I4,1963 l 1 1 1 i E
1 l.' 1.0 1.1 PURR)SE. SCON. 40 ORGANIZATION FUPOE The purpose of this Safety Evaluation Report (SER) is to demonstrate l that the polar crane load test can be accomplished without presenting urdue risk to the health and safety of the public. .. 1.2 SCOE The sccee of this SER encompasses polar crane specific activities associated with the performance of the load test. The major activities ircludeo in this effort are: o Relocating the internals indexing fixture. , o Assembly of the test load o the load test o Disassembly of test load The polar crane load test will include the reactor vessel head lift rigging and, hence, will serve as a load test for this device as well. 1.3 ORGANIZATION Section 2 of this SER describes the major activities associated with the polar crane load test. Section 3 Identifies conponents affected by the perfomance of the polar crane load test and presents infomation regarding the refurbished condition of the polar crane and lift rigging. Section 4 presents an analysis of postulated load drops av evaluates their effects from a safety standpoint. The organizational guicance provided in Section 2.3 and 2.4 of Generic Letter 82-07 (reference a) regarding control of heavy loacs has been followed in preparation of this section. Section 5 provides a 10 CTR 50.59 evaluation for the polar crane loac test. Section 6 addresses occupational exposure ano environmental releases, ard Section 7 presents the conclusions of the safety evaluation. Section 8 provides a list of references. i
2.0 MA2)R ACTIVITIES . The polar crane load test may be characterized by four ses;ential major activities. Each of these activities is discussed below. 2.1 fELDCATDC INTERNALS INDEXDC FIXTLAE In order to perform the movements associated with the polar crane load test, the Internals Indexing Fixture must first be relocated out of the area to be used for the load test. Prior to movig any of the missile shields, the Internals Indexig Fixture will be moved from its storage location on El. 347' and storea on the Head Storage Stand. Please see figun 2.1-1. 2.2 ASSEMBLY DF TEST LOAD . The test load will consist of a load test frame, the missile shieles from over the zwactor vessel and the pressurizer, the Ivector' vessel head lift rigging, and a load indicatig device. This assembly is shown in Figure 3.3-1. The load test frame will be constructed of steel members brought into containment through the airlock ocors in the M&==nt hatch. These members will then be moved to the floor hatch and lifted a to E1. 347', where the load test frame will be asseeled as shown in Figure 2.2-1. The test load will then be assembleo by i moving the zwactor vessel missile shields from over the zesctor vessel and stackig them on the load test frame as shown in Figure 2.2-2. Finally, the pressurizer missile shield will be moved from over the pressurizer and stacked on the load test frame as shown in Figure 2.2-3, and the lift rigging attached. 2.3 LDAD TEST The actual load test is presented in step-by-step detail in the test procedure covered by reference b. This procedure will be approveo by the USNRC prior to implementation. Sasically, the test loao will De lifted so it is s@ ported by the crane and held by the hoist brakes. The load will then be transported by the trolley and brioge a distarre sufficient to allow at least one full revolution of the trolley and bridge gearing. The bridge will then be rotated 1808 and the aforementioned steps repeated. This evolution is shown in Figure 2.3-1, 2.4 DISASSENS.Y OF TEST tDAD l Af ter completion of the load test, the test load will be disassembled. l This will be accomplished by removing the load test rigging anc the I movig the missile shields to their storage location. The pressurizer t missile shield will be moved back to its storage location over the pressurizer as shown in Figure 2.4-1. The reactor vessel missile l shields will then be moved from the load test frame to their storage location on the B D-rig as shown on Figures 2.4-2 and 2.4-3. Prior to movig the reactor vessel missile shields, spacers will be set on the B ; D-rig walls to avoid interference of the missile shields with existing l components. The missile shields will be stacked two high with spacers betosen them. Finally the load test frame will be disassembled. i C _ _ _ _
P'h ! g c 43-3 1 " I
, 7
- .[o... _]
i
;;, i.
n-h. 3 f 5
!!I I4si l'J i,. l .
at * >a s 3 = j
, ar
~~c *
"U ! gj i
5 in s "i ;5 I o!3
/% pG sq Jg9 r,T._ ,t-
~ s. ,,
4 .. ,; - .g $
\,s , f -C. o ..' .
f- ... h; g { ,5% ] y'4 ' g ,, y : p= % ... g !.! :
/, m mb _::L\ --
-)
__ [ != .x ->b. - .,, I l ggg'- nn 2g~o
;;;i su "2
. I \ { 3 j
'C [ ,M M..#
h ' g , y ! v a
'-{3_
, .o g
,3 g.
9 $$ ip* 5lsi Et Eh i ii Na_ _i - ed # e
, ._ ,e -
y 1 J .)' ;i
- I ;
.'17 o . .g ,
0 Elip $1 i en != l mm 1 b 3 I i f F a lt b . .1
<c a- d a se -a jje.E g
! -J!
I s
*jN '
j!!s , ggj l zeEE ga 5%$
!j1
- . 'o 1,* iL. V. / -
m . 4 N 9./
., y-
. 1 / +
g ,P "2.X \W' g , yo x [ fg p ?*'*I" /-
., a j
- =
a 4'*~ 7-s,. ,
===;ry yx Jy lg ,
I . I k
#1 ,
ll!!! fa #!!
. , = -
I & h.e e 1%*
- h 9 h,I . ,(d N -
l s"o 3 Nx '
.k cy 5
- l
- W.
4 4l. I f !< I l
, ,. n u,7 l" l$ Is 5 sf"l[1_ gu u8 li
7 0 jE.
!' I jj! cil lg y 49 : gling ui 8 -
EjggIl- *s M.\ s - f f, 3 4 f g d3
~
3;a r -!"g1=Eis Ewi. . g. E!s,ai?
! 3 se e- s ee is; &"54*g6 e
,5 f
58I@s
.I.e Uw2 -
2525I$5 i f 0 I 1 3 f e, e g z !!p!I 5*
- S! 1. -
5 GII yA?
- l ogg m 2 a ga p -
g i~,
//
U %,1- @x g
.g ,
< L l .
& '1 ' . . ..
.ie !.! 4 F m_.g"
~ ' J ,_-Lx-@i - . y
~ti . /..
a
.: ,_o_ _ a 1. -
19 If
?? .
fiM i uf a ri
! il f ,
- l 3iN
- imy-9}
g gi 'yl' , g3
%, I fs,i
>, .ll i-
; b II g- g a
5 M i
.$a-I a
s13,c,d i .
i t
~
- l. I s L I
l
.$.) 5 : 5 I m!
i'!.
!! i .
A8
~fU i 5!
ga i
=8 h
E n f j$ *o E 3,5 II y
. s f
a M, U $5 a ij !fc 1 O 0 >$ - a sl1s I ja 3 p-I e_:s ja . ml.'9 _ !d 55I h : q r s 4Ed Ax '
?
'A b
(, Q .. n ,
'o = ; [ 2 \ !?=
n= - 1 i
- o y i n. ,
e u-n, = 1 , ,a - 4 --, l cx %..k ) g2
.. "! i !
i I ii ' y U.( h
! E EI
!!l['a l ,-
'Id if ~g p? i il al Ign cd t 1 e - -
._...A 6
4> ' , . I m 5$ E f ,/ 3, b B sg = l a J f
- su:ub n , s. . .
#g;,
l I 222-rw 1* i p k N - 1 .E rd :it . 45 oi Je s: s.i ass
$ \d 2$ Y Ef E 8ll$ EU ii E 5
?! *f5 ms sa c8 m- s ce 5 !\. , ,,
A - w!.o 3- . aw - p. y _ L 1 U i g. n.
!a as F , ,
f l H '~,~*4T \ ,
' -- /
- 1 i l ... _ ig sh
}. ,
, _ [d'. .. -
),
- _.\;- m.l t
l s .- j i a ,'.'fC - f [* e-w 5 I 9 P lT , l* ,3
/g--~7 X yh l Y yll"
~
9 i [I a;-3 # f ^ " b ,iii d a
' i l ad ad si.,t g
ivi _ e 0 i . . . . . . _ _ . . . . - _ . - .
ii. ! E3 4>! M !u i a Y i EI
!! , 5 *. E i";; ji ~
- 6 l
===-a f
- d.
]w a
i C b l h !{ *
!! > n i= gq !!-l!
1 e' a og 1 !! Oa I su! l gh .
!.!n I e ed bI .
I
, E dg' ,
-[j d f' C i ,I im
,1 ; Ea
{ g [gj 7
, s 1
- \ y .- En
'I?
3= eV
's j p 'X' l.
/- !
a cs \\..).;D g/ y._ _
!s a
3'p i'!' f O h
. - .I "p
9lii ad 1 A a~ e,I , ! ! +lil!$
'gi 5
. .7 iF,11h4 5 e ,
=mm m .
~
- e
I hs ' j'? g I 3
<F s) 3 e
x, 1 2
- h_ -$
~
wi
? Q: "J
!. f N s3 N =s cf . 5-
- E s
!ii.,
=
5 '?" E l
? g g
- hE
- OI so l E z
hd 5! ES re
+ a* lie iga n- E [
* && - i s 11 I .
E h
$gh 2E33 I h !l[ '
!!! jfh*
i L.---!! I
.ft . .
O
'N rI'?
- w. :h w ,s
, [/ s
\
fI.i
. T Clu s!,
c li .
,1
,4u [ . Ik) .
w) {,a
<. ri . 1 t*) 4 i - .:
i ' L
- g / l l
!, -v ___!pi -a, 4e s.
- , o I,
=g 3; we E*j e
' . 3 53 5
sh , iM s I f. r* 3 E o"J
$b t
ift ! f * [h
** S f5
--- . ria l Ud n .
______--___._________a
I
. EO g - g --
3A ,
'I
. f 7,.aek- a 8
I' vs y g=E
.44
!. s z
w=se 5g-B E :gi " 3 s aj a s ==e I;
?
i$
=M ' h$ !!a- ! 8,g5 i
ee N 4: *in . it ., g -t :\ d'*8 b
.s 28 q %. DH WN sii 1 1 o si!
$li dd o
f
- w. ,m i: J .
1s x s x ai .. - ,/,\, ~ g 3
'N '
... I 4
- gg C ,.
l m ., s,' t
, ? gg a
AM . ftV .- I ~)g g .=' - __ I -- ix---r___k fs) i __ -i __. o.
~
0 ,I, a _-;~[p- i amme. l
.. . a, a h
!i Xv' ,
. i' s
^ ,
~T))
- t.-- ' - - - 1 2 5 i j 'i g SI y., : * -
. *x c= - !gt !W
* - 4.!.
os 5
. t. ;s ig e O ,I o WE EJ .A E *$$
2 3*" {jj EQ 1 ta $1
, !!- 11*l*!2d 5 w-. ====. ,
_________1________
?: .
3.0 CDFOENTS AFFECTED . 3.1 The co@onents af fected by this test are the reactor building polar crene, the liftire devices associated with the load test, and the testL load. Load testire of the polar crane will provine main hoist lift qualification to a anximum of 170 tons, which is sufficient to lift the reactor vessel head and service structure. Qualifyirg the polar crane to lift loads @ to 170 tons is also sufficient for all planned ; recovery activities. In addition, the polar crane load test will serve as a load test for the reactor vessel head lift rigging. 3.2 The refurbishto condition of the polar crane meets or exceeds the ,
- l. requirements stated in the Polar Crane Functional Description ' '
l l (Refentre c). Further, an extensive inspection and maintenance program will have been completed befon the load test. This program is < described in detail in the doceent entitled ' Clarification and Exceptions to the " Crane Maintenance Inspection Specification" Checklist' (Refarerces e and e). The Isactor buildirg polar crane was desired to allow for a rating of 500 tons. This includes the crane structure and main hoisting system, including load block with sister hook, brakes and two indivi' dual, though not recundant, wire rope systems. The main hoist braking system includes a load contro111rg eddy current brake and two main hoist (150 percent each) load holding brakes. The normal position of the holding brakes is engagement. Whenever the main hoist "@" or "down" circuits are energized the brake shoes are lifted from the brake drums by the action of direct. current clapper type mapets. Brake engagement is
- automatically accomplished by sprire action. Whenever the hoist motors or the crane is deenergized the brakes are set. The crane will be controlled usirs a push button pendant station. To stop a load during lowering, the operator need only release the "down" button, or push the crane power button to "of f", or have someone open a crane power breaker. Redundant @per limit switches are provided to prevent possible twckblorkirg.
Visual examinations and static electrical testing, as applicable, of the crane components necessary for the recovery effort will be completed prior to liftire any loads. These inspections encompass the . critical mechanical, electrical and structural components anc are directed by experienced crane inspectors. Also, a certifico welding inspector will visually inspect critical, load bearire welds. The main hoist ropes will be virtually 100 percent inspecteo to ANSI 830.2.0-1976, paragraphs 2-2.4.1 and 2 2.4.2 criteria to oeterrune it rope replacement is necessary. and main hoist control Functional cabinets, and tests of the bridge, component parts of trolley,ive each ctr system will preceoe operational testirg. These tests prove the schaastic function of each testec control cabinet and drive system component. 1 4 Y_-_ __ _ _
I l i j As nscessary, defective components will be replaced prior to operational testing. The replacement components whose failure could result in a load crop, including the brakes, are nplacement in kind i for the originals and therefon am sized for the 500 ton rating. ! An operational test will be performed in accordance wit $ ANSI B30.2.0-1976, paragraph 2-2.2.1. As a miniman, this test will verify ) operation of all crane functions necessary for head lift..- These furctions are the bridge, trolley, and main hoist motions inclucing the associated trolley and redundant main hoist tcper limit switches. l Mighlights of significant refurbishment activities are stanarizec as follows: . o Main hoist brakes replaced. Break drums cleaneo and brakes fully adjusted. < o Structure of crane inspected and accepted (ircluding welo & bolt inspection). . o Crane completely niubricated where required. All fluid levels l checked and corrected where necessary. i I o 011 samples from gear cases analyzed and considered in gooo ! condition. o All actors slip rirgs nfurbished. o All clutch plates cleaned and all clutches adjusted. o All coLplings checked. o All circuits meggered, or checked for continuity. o Electrical contactors and relays replaced where oefective. o All brioge actor and trolley resistor banks replaced. o New pandant station installed. o Festoon system for pendant station refurbished, o Cab controllers verified operational. o New power system to crane and trolley installed. o New fire extinguishers installed on crane. o Anway rt.11 inspected for alignment, gaps, loose bolts, level ano IDL#1dness. o Wire rope sample tasted by laboratory and reported to meet or exceed original certification.
1 o Wire rope completely labricated. o Wire rope inspection indicates rope in good condition. o All crane functions verified operational except under load. Additional and s@plemental documentation of the results of the inspection and refurbistinent program have been and will continue to be submitted as they a2e accomplished. l 3.3 The lifting device associated with the load test is composed of several conpanents: hook attachment shackles, a load cell, connecting shackles 1 to the haec lift rig tripod, the head lift rig proper, the load test , frane, and associated load bearing connectors. This lifting device is shown and described in Figure 3.51. The liftire device to be used for the missile shield block is shown and described in Figure 3.3-2. Because the reactor vessel head lift rig will be concurrently testeo as a part of the polar crane load test, it will receive special attention in that a rigorous visual examination will be conducted after it has lifted the test load. A acre detailed and comprehensive presentation regarding the requalification of reactor head lift rigging is contained in reference d. The test load frame component of this lifting rig assembly has been , specially designed for its purpose and will be used only during load testing. As such, it is desired in accordance with the AISC
" Specification for the Design, Fabrication, and Ezwetion of Structural Steel for Buildings". Desip load for this component is 220 tons.
3.4 The test load is composed of the four reactor missile shields weighing ; 4011 tons each and one pressurizer missile shield weighing 3211 ' tons. The combined weight of the discrete test load is, therefore, 19215 tons. The total lifted load also incluces the contribution from the weight of the test frame and associated rigging, brirging Tre the total lift to a mininum of 200 tons and a maximum of 220 tons. 1 actual test load is estimated as accurately as possible at 212 tons. i J
9 9 e h0MINA1. RATING) :
/. POLAR CRANE MAIN .
j klW LOAD C(LL RlGGING INTERNALS hANDUN( [ET[N$l0N DsLLON LOAD CELL (200 TON ORIGINAL N RATING, P'JLL TL3T[L 70 220 TONS) , w LIIs ' il '
- i yr P
gh !
, HCAD [lNTCRNAL3 HANDLING FirTUK[
, AS$[taBLY (170 TON NOMINAL, $ HOP 7t3f tD To 255 TONS)
,t-
,/
I t t ,
- o TURNEUCKL t P[NDANT b AS$' I l gttTENSION BAR LOAD,l3PREADN6 FRAME l l JAs di 4 [(ej"pmpgpopg 146 T 3 N #AN e.* u w c :e. --
_ - _- ' /, perta , ~ re,r.*w'
~
PRIS$URif f R Mt151LC $WILL C 2 i i l l iI I RE ACTOR f k Mi$$3L E SHIE L D ge 2 T 1 . i1 {( ,E REACTOR f n,, gg - _ Mi&SILE Shit L D 4 gh gpp .. b., .' .
,j M. ..
"o? TEST LOAD FRAMC fE~
dE
'(220 TON DESIGN)
Aonc, seAa r. ..e
\
i -~,
.i
# 9 e NOTE: TMt Missile SMitLD Stock Lirtai4G PAD gyts avg ,
A $AFETT F ACTOR Or 3 to ULTiM ATC (Fr(AxiMG) ' THE DC$lGN BA315 FOR TMt3 SAf tty rAC10R is
- f. DNLY TWO CABLES SUPPORT LOAD (INSTEAD Or a),
2,. CABLC LffT ANGLC WITH THE VERTICAL Lots NOT [KCit 0 30*. POLAR CRANE M AIN MOOK ($00 TON WOMikAL RATING) NEW LOAD CELL RIMtNG L I I DrLLON LOAD CCLL (200 f0N ORIGINAL RATING, PULL TE&TED 220 TONS) a INTCENALS NANDLING EritN540N I (ROTA1[D FOR CLARITY) Ml!$iLC $MitLD RIGGING ATTACMMENT P,AT[ g J L ' I-
)-
/
[ 75 TON $WL *hlDC PODY' $NACKL[
/
\ $AMr rIRC nort$ ( ATTA:nurnT3 TORFLOO LOOP LOCK SPLICf
/ s
/ r0s. A$ nrssuRinR uissac smctD f 0R R[ ACTOR M130sLE SMihC3 3
# . s f
1{Dtk WIRE RDPC$ l
/ 's l .
\ (txt$1lNi LUS$ WDR PRi$$$n:ls
% MISSILE $NltLD y %
,DIA $CRf WPiN ANCHOR f f
"A;KLI / \ tri!Tiui Lui! rom st Atmc g MilitLE SmILO
,1
\
3
/
M M __ i i i l i t
"RES$URIZER est$$1LE SHitLD RIACTDR Mt$$tLE 5HitLD E
-m -
8 22 , k;5 h5 apr mo? EP"
-m bb A m s sent f ..c- l f, =_
,,m, iI Im i i ,
' ' I
4.0 EAW LDAD DROP ANALYSIS - BACKGLOLND AND INTRODLETIDN
- The generic letter on the control of heavy IrMs wtyires licensees to
' address the guidelines of filREG-0612, " Control of Heavy Loads at NJclear Power Plants."
Section 2.3 of this letter requi'es r infomation be provioed which is sufficient to demonstrate that adequate measuns have been taken to ensuze that in the vicinity of the reactor core, either the likelihooo of a load drop which might damage spent fuel is extremely sena11, or that the estimated consequences of such a crop will not exceed the limits set by the evaluation criteria 1-111 of NJREG-0612, section 5.1. Section 2.4 of the generic letter nauires information to be providea - which is sufficient to demonstrate that in the vicinity of equipment or carnponents required for safe reactor shutdown and decay heat removal, either the likelihood of a load drop which might prevent safe reactor shutdown or prohibit continued decay heat removal is extremely small, or that damage to such equipment will be limited so as not to usult in the loss of these safety-related functions (Criterion IV). Even though TMI-2 polar crane is not a single - failure - proof crane in the classic sense as defined in NLREG 0554, this does not totally negate the argument that the probability of drop?ing a certain load on a certain target at a specific time is " extremely small". Approaching the particular case of a missile shield drop from a more mechanistic standpoint, it can be concluoed that the probability is indeed extremely small by taking into account the followirg factors: o The Polar Crane factor of safety is greater than 10 conpared to the original design rating and approximately 5 compared to the requalification rating. o The missile shield blocks are moved sequentially starting with the one farthest from the load test frame using the intervening blocks to pIctect the reactor from Grops of the block being moved. o Shield block lift rigging irrorporates a significant oegree of conservatism as may be seen in figure 3.3-2. o The amount of time during which these loads are lifted in the vicinity of the reacter essel will be minimized. In the case of the test load similar arguments regarding conservatism of crane and rigging capacities can be made. However, sirce the test load is approximately five times greater than a missile shield, the following accitional conservatism are introck.ced: o The test load area was carefully reviewed and selectec on the basis that a miniman amount of equipment was located directly beneath it in comparison to other areas of the contaminant. o Lifting time of the test load has been minimized to the greatest axtent compatible with crane retpalification.
1 i l 1 l Pzocedural conservation have also been considered and introduced. For I example, the initial loads to be lifted by the polar crane will be lighter than later loads. As described in section 2, the 6 ton Internals Index1rg Fixture du ce lifted prior toithe movement of a missile shield. E'ach time a load to be lifted is heavier than any pnviously lifted load, the procedure will require that the new load be lifted in steps to insure that, should a failure occur, consequences would be minimized. The procedure will require that the new load be , lifted initially only a small distance, held in place to verify that no I problems are encountered, and then complete the lift. An example of ; this is the initial lift of a reactor vessel missile shield. The j missile shield will be lifted only a small distance and held in place 1 while still on the guide studs. A load drop of the missile shield would have no unacceptable consequence as it would merely settle back into place on the D-rirgs across the refueling canal. Further, no reliance has been placed on the installation and use of i I electrical interlocks or mechanical stops to keep the load in its prescribed load path. The movement of the load will be controlled by the Test Director, who will be equipped with a voice actuated headset as will the other in-containment personnel associated with the load test. The Test Director can comunicate with a person stationed by the main power s@ ply breaker, 480V DCC-2-32A, in the Auxiliary and Fuel Handling Ebilding. In case of an amergency, the Test Director can have the main power s@ ply interr@ted. This will freeze the crane in the position it was in when the power was cut off. The above points, taken in conjunction with the refurbished condition ~ of the crane as delineated in section 3, lead to the conclusion that the probability of a load drop is in fact so small that it approaches the drop probability of the so-called sirgle failure proof cranes, which is to say, incredible. Notwithstanding this low probability of a drop in the first place, a detailed analysis has been conducted to examine the potential consequences of load drops in the vicinity of important equipment. These analyses encompassed all equipment in the load path down to the level of cetail of individual valves ano instrument lines. These analyses are starnarized below, taking selectea major equipment and systems or examples. 4.1 FEAW LOAD DRDP - CDRE VICINITY 4.1.1 Identification of load For the performance of the polar crane load test, the loads to be moved in the vicinity of the reactor core are the reactor vessel missile shields. Figures 2.2-2, 2.4 2 and 2.4-3 show the paths for the movement of the missile shields to the load test frame south of the D-rirgs on the 347' elevation and their movement from the test frame to their storage location on the "B" D-ring after completion of the test. These 641ssile shields a:e constructed in the shape of oblong blocks of concrete and robar, weighing approximately a0 tons each.
4.1.2 Lond/ Target Interaction in the event that a shield block were to fall onto the reactor heaa ano
, service structure, damage to the Ibntrol fbd Drive teechanism (CRm) motor tubes would usult causire lankage of reactor coolant into the reactor building. The maximum leakage would be the draining of the RCS l to the top'of the level of the reactor vessel closure head, since penetration of the 8" thick steel closure head is riot credible.
A shield block strikirg the nactor vessel (RV) closure head could also brirg about stune physical redistribution of loose core debris within the seactor coolant system. It should be noted that much of the kinetic energy of the falling
- shield block would be absorbed in physical deformation of the service structure and CRDM apparatus above the head and that an instantaneous impact directly on the RV head proper would not occur, 4.1.3 Criteria . Specific Evaluations (MJEG D612) 1 4.1.3.1 Criterion 1: (
Releases of radioactive material that may nsult from damt, e to spent fuel based on calculations involving accidental droA ',ng of a , postulated heavy load produce doses that an well within 10 CFR Part 100 limits of 300 rem thyroid, 25 zum whole body (analyses should show that doses are equal to or less than 1/4 of Part 100 limits). Evaluation: The impact of a missile shield block dropping onto the reactor vessel head and service structure might cause leakage of reactor coolant through the CRDM motor tubes into the nactor building as l described in Section 4.1.2. This liquid would be contained in the reactor buildirg; thus, the containment building would act as a physical barrier and prevent any liquid releases from escaping to the envirorynent. Likewise, any gaseous releases causeo by this postulateo drop would be physically contained, since the containment integrity will be set and maintained throughout the , load test. Containment integrity is further assured since there is l no larger any energy source capable of producing a ariving pressure which could transport this activity across the contairunent boundary. I Any gaseous activity released in the containment woulo be cirectes through the high efficiency particulate air (HEPA) filters and contairunent purge ahust system and eventually released in a controlled manner, so as not to exceed the limits established in Criterion 1. Further, any N1 eases which mi$t occur in spite of the factors presented above would be only a small fraction of the calculated release presented for a Loss-of-CDolant Accident (LOCA) in Chapter 15 of the TMI-2 TSAR; thus meeting Criterion 1. l
.p.
1
V 4.1.3.2 Criterion II: Damage to fuel and fuel storage racks based on esiculations involving accidental dropping of a postulated heavy load does not result in a configuration of the fuel such that kerr is larger than 0.95. Evaluation: , The precise configuration of the fuel is presently t,rknown; thenfore, the exact kert resulting from the potential redistribution of the fuel due to the impact of a missile shielo block on the reactor vessel head and service structure cannot be . calculated. Despite the inability to calculate the exact kerr, , bounding analyses performed for the 2005 fuel damage case, conclude ; that the fuel debris will not be critical when: it is in its most ' ! reactive condition, the effects of structural material are I secounted for in the analysis and the nactor coolant boron concentration is 3000 ppm. (References f & g) In view of this conclusion and the fact that the concentration of boron in the reactor coolant is .over 3500 ppm, a recriticality is precluceo. 4.1.3.3 Criterion III: 1 Damage to the nector vessel or the spent fuel pool baseo on ) calculations of damage following accidental droppire of a postulated heavy load is limited so as not to result in water leakage that could uncover the fuel, (maka@ water provioed to overccme leakage should be from a borated source of adequate concentration if the water being lost is borated). l Evaluation: 1 l ' As stated in section 4.1.2, the maximum leakage resulting frem a drop of a missile shield block onto the zwactor head ano service structum would be to drain the reactor coolant system to tne level ' of the top of the reactor vessel closure head. Drainage to this level does not uncover the fuel; thus, crition III is met. In addition, at least one make-up train capable of delivering water ] with a 3500 ppm boren emcentration to the reactor vessel woulo be available. 4.2 EA/Y LDAD DRP AN: LYSIS - SAFE SHUTDOWN APC DCA) tiAl etNin EQUIPENT 4.2.1 Identification of loads For performance of the polar crane load test, the loads to be moved in the vicinity of safe shutdown and decay heat removal equipment (or other agaipment specifically important at TMI-2 due to mimae site considerations) are: the internals indexire fixture (a six ton metal cylinoer as shown on figure 2.1-1), the missile shielos (including the 32 ton pressurizer shield), and the load test assembly composeo of the
- missile shielos stacked on a frame or shown on figure 3.3-1.
10 L ..
The indexirg fixtum is not specifically addressed in the analyses because the results of a drop of this item is enveloped and bounoed by !
; the missile shield loads. The assembled test load is specifically addressed.
4.2.2 Identification of targets A list of systems and components includirg valves and instrumentation, which wen considered essential functions for TMI-2 was' compiled. ine criteria by whitti this ecpipment was selecteo are:
- 1) that equipment within the mactor coolant pressure bomdary which is aquired for decay heat removal and nactivity control,
- 2) that equipment respired to be operable by the TMI-2 Recovery .
Tectinicial Specifications, and
- 3) that equipment recpired by plant procedures which were approved in l accordance with Tectinical Specification 6.8.2. - -
The followirg is a list of major fluid systems which were examinec as possibly pasentirg important targets: o Reactor Doolant o Make-@ & Purification c Decay Heat Removal o Mini Cecay Heat Removal o Standby Reactor Coolant Pressure Control System o Core Flood o Decay Heat Closed Coolirg Water o Reactor Builcirg Spray o chemical Addition o Nuclear Servloes Closed Coolirg Water o Feedwater and Condensate o sein Steam o Demineralized Service Weter o Intermediate Closed Coolirg Water o Nuclear Services River Water o Reactor Building ventilation o Reactor Buildirg Purge o Fire Protection o Stanm Cenerator Secondary Side Vent and Dzains 4.2.3 Load / Target Interactions ( The effects of a heavy load drop in areas over which heavy loacs are j expected to be moved have been analyzed to ascertain the worst creciole consequence. (These areas are shown on Figures 4.2-1, 4.2-2 and 4.2-3.) In determinirs the consequences of a heavy load drop, it was l determined that the floors on elevations 3478 6" and 305' woulo locally 4 collapse when impacted. The impact areas and load / equipment concinations have been presented in matrix format in Table 4.2-1. l s
)
Cogonents were not considered to be functional af ter a heavy load drop ) which was assumed to occur diztetly over the components. (The j availability of an unaffected alternative was ascertained in view of 4 sty the component was recpired. A component was considered to be an alternative only if it performad the same safe shutdown function as the , conponent subjected to a heavy load drop.) The location of each piece l of essential equipment was detezzined from the latest available t ! drswings. - l t The consequences of the loss of each component lyire within the I desig'ated areas was determined and is presented in the following i subsection 4.2.4. 4.2.4 Criterion IV - Specific Evaluation (NLMEG-0612) ) Damage to e7Jipment in redundant nr dual safe shutdown paths, based on j calculations assuming ttn accidental droppirg of a postulated heavy l load, will be limited so as not to asult in loss of recpired safe ( shutdown functions. l l Evaluation: l Criterion IV refers to "nquind safe shutdown functions" which are defined as those recpired to: maintain the Itactor coolant pressure boundary, reach and maintain subtriticality, nmove decay heat, and maintain the integrity of conponents whose failuzes could result in i excessive off-site nisases. I i' The required safe shutdown functions that apply to the THI-Unit 2 reactor in its cuzzent coolirg mode and core configuration are:
- 1) the capability to maintain suberiticality.
- 2) decay heat removal.
- 3) the capability to maintain the integrity of components whose failures could nsult in excessive of f-site releases.
The nactor coolant pItssure boundary needs only to be maintainec insofar as Itactor coolant must be maintained in the RCS for oe::ay heat i removal and zwactivitly control. Radiation shielcting is ciscussec c~ evaluated in section 5.2, part 4. Requind safe shutdown functions unique to TMI-2 are accresseo in the same order as above:
- 1) The capability to maintain suberiticality in the core due to load impact on the reactor itself is addressed in section 4.1.3.2. Due to the configuration of THI-2, the only credible mechanism by w* den criticality control could be compromised is debaration of the water in the nactor coolant system. Systems within load impact areas which contain unbarated water have been investigated and founc to fail in such a way as to drain their contents onto the reacter j
. I
l 1 building floor and not into the RC5. For example, the boron i concentration of the ES could be reduced by gross leakage from the unborated secondary side into the primary side as a result of a postulated load drop. Dausge to the MSGs severe enough to cause a { such leakage would undoubtably cause damage to the outer surface of the MSGs allowing the unbarated water to drain to the containment ] sump. Further, system capable of injecting highly boratec} water into the RCS are available and it is not feasible with one load drop to i reduce the furctional capability of these systems to such a point that baron injection could not be done. ,
- 2) Decay heat removal capability is ensund by maintaining water in the nector vessel. Analysis shows the water could be drained to the bottom of the cold leg nozzles (elev. 314'-4") and no actverse -
consequences such as boiling would be experienced. The only way to , drain the vessel below this level would be through damage to the incere instrument tubes. (See item C below.) In addition, if { damage to the RCS causirg Isakage of reactor coolant were to occur, make-up capability will exist at least through one loop since a drop in both D-rirgs at the same time is not cmdible by physical , separation. Damage to make-@ system penetrations will not occur sirce they an located on the northern side of the building away from the load paths.
- 3) Off-site nicases are prevented by the containment pressure boundary. The contairinent integrity, as recpired by the Technical ;
Specifications, will be set during the load test. All containment penetrations which have the potential for damage in the event of a , load drop have closed isolation valves outside the nactor building. I Please refer to section 5.2, part 3, for additional discussion. Additionally, a nunber of extraordinary accident scenarios have been postulated as having some finite although remote occurrence potential. These an: A) Criticality in s steam generator. B) Criticality in the reactor building sunp. C) Impa:t induced failuze of intore instrument piping. Extraordinary accident scenarios are accressed in the same order as they an stated above: A) A semantial series of low probability events must occur before the concern of criticality in the steam generators can be viewec as a 11gitimate safety issue. The following set of low probability events must occur in sequence, each conditioned on the occurrerce of all the prior low probability events, before a criticality in the staam generator could occur.
-D~
- 2. A missile shield aust be dropped above one of the D-rings.
l 2. The missile shield must travel far enough into the D-rigs to - impact a reactor coolant pump or cold leg pipirg. Et should be noted in this regard that there am massive structural beams crossire the D-ring above the reactor coolant pep elevation froin which the reactor coolant pJups am vertically-4 s@ ported. .-
- 3. The missile shield must impact the reactor coolant pung or other structure in such a way as to r@ture the pap suction line at a point well below the secondary sine water level.
- 4. M amount of fuel sufficient to raise criticality concerns must have been transferred to the steam generator and founc its way into the steam generator tubes and lodged there durirg the hccident.
- 5. That fuel must be in a high' density close pa$ configuration within the tubes in such a manner that would allow criticality.
if the borated water were drained from the tubes during the period of time that they were surnuruJed by unborated secondary water. As can be seen from the above description of events, even the application of conservative probabilities to each event of the required seguence will result in a probability of criticality occurmnce which is below any reasonable threshold for safety concern. This extraordinary accident is, therefort, appropriately dispatched. B) In regard to subcriticality in the containment sump, our evaluation - I indicates that the only point of potential concern would be the drop of a heavy load onto the systems listed on Table 4.2-2, which might, in turn, provide a source of mborated water to the sep and raise corcerns related to potential criticality within the sump. This problem any be addressed in two ways: First, to limit the amount of unborated water available for leakage to the sump from these systems, the water s@ ply to these systems will be isolated i for the period of time that the load test is being performeo. (Wte: The operable fire protection system is normally isolated.) Our evaluation shows that a sipificant quantity of unborated water would De recpirto to lower the sump water concentration from current values to a level below the 1700 ppm value which has been specified as the reasonable point for s m p reactivity problem avoidance. Secondly, several low probability events would have to have cccurred beforu valid concams regartiing sep criticality could arise, regardless of the amount of unborated water cielivered to the amp. First, an amount of fuel sufficient to create a critical mass would have to have been washed to the susp durirg the: THI-2 l accident. Secondly, this fuel would have to be in a configuration i l I
which could induce criticality if a global deboration of the sep won to occur. Our qualitative assessment indicates that the i acktinistrative controls described above (which limit the amount of unborated water whio, could be delivered to the sump) combined with l
- the low probability of simultaneous occurrence of the initial 1 conditions regardire fuel deposition in the sump which could lead to a criticality problem effectively eliminate this issue as a i legitimate safety corcern. .- j
- C) The third special consideration which has been evaluated is that regarding the potential consequences of a load drup which damaged {
the ircon instrument lines. i The reactor vessel lower head is penetrated by incore instrment i lines which run from beneath the very bottom of the vessel through . a ttainel in the base met of the containment to terminations at the seal table ama. This termination area is shown on Figure 4.2-3. Shown in phantom on the figure, the routing of these lines parallels a line drawn between the center of the reactor vessel anc the center of the seal table. The width of the an a occtoied by these lines is just smaller than the diameter of the seal table. As can be seen in Figure 4.2-3, the seal area is not located within ; the load path. A portion of the incore instrument lines is, however, physically located below the area of the load path for the reactor missile shield blocks. This portion of the lines is ; separated vertically from load impact surfaces by concrete and steel structures of such massive proportion as to render loao penetration incredible. The only remaining scenario by which a dropped load could damage an incore instrument line is as follows:
- 1) Drop of reactor missile shield into refueling canal.
Shield block to orient and reconfigure itself to fit between j 2) reactor vessel and primary shield wall. (Present dimensions preclude such an event).
- 3) Shield block to travel down to elevation of teactor vessel skirt, disintegrate into pieces small enough to fit through holes in the RV skirt, and travel horizontally far enosgn an:
with sufficient remainirg energy to damage the stainless steel incon lines. This scenario is-judged not credible based on the improbability of these three items; especially item 2 which violates the physical laws of nature. 1 l l~ - l
=. - - a g .: ~. =
j gl. g- - Mb N l d"
- E 4% 4-g5g W d d a a 9
E L3 7 * ^ 4 1 e5'i i i :8.do S 6 l u E E
"E lep
-n a e- a:-
01 E a E F . -i" Eg7 UT7 m - g E EM* a
- k kg"k
,h
~g 5
g a h
- sg , rec c
E a m . Am. E m 3 g .
- E _____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
N W 9 a - E Y g 5 [ g a B 4e s i w e . m AS A 1
. E W s-e s2 i N
.=
NN
- Ed6 5 Nat a m ye; ise !
M n t t t t Ye I I I I D Rr - NOe IGf lee ETR 4 2 4 2 4 2 4 2 A 4 4 4 4 OCdn ( ( ( ( 4 N Z 4 ( E E E E A , , , , H D D D D C C C C iIl llIlliIllIli l l e e e e g R y R n e i p e r p e s) ) s) i) or s) r or Pr Het l e He e lt t mt da - a da nW ea 1 nW eYW tW
- G N
a o n- a s A- ee iHd d yd I lF e ee Se R nt (t nt t m D
- ia Lr
)
Ndr a ia Lr
) a Nr 0 E o Dns o r Do 1 A )b ( at )t (b M
R F Sn FU rSt th Sr rU rt h F 0 (( e ( (( e( 0 C t e t X H e ag e a 2 I M T c) Wa) c) W) R L U i1 r1 i2 2 T E T 0 O S v - r2 do- v-r2 d - e2 0 et2 K M e S4 rS e z S G
, T l 4 S4 i 4 T N T N ld l C
A I N A E ee rr aae rer ee rr ae rr P D R P i u eHu iu eo l ng M I Fg n g Fg 1 I l U M U i ioi i ii
- / B U Q
Q E "2 F mtF e "2 F mr e 2 m R /e Dee /e De 4 o U T S 1 e S ne 1 e S e E L L T C A G N E W 2( "3i lS ( 2( "3 S ( I - IllIIlIllllIll1I1 M T E L D M ) I U
- U O "6 E B S N -
O ' M A R U I T 2 4 C T A 3 C V "6 "6 A E - - . E L ' t R E 7 7' '5 5' c 4 4 D 0a 3 3 3 3( IIl IiiIIIIll IIill1lIlI1II k c l o B A E d l M i e T h C S R F l e D i s s N i s O Mn I o T rT A e C z3 O i 3 r L S u D s) A s1 D L e-rP P( 1l IlIIIIIIliIlllll1ilIlIi
.~- _ _ _ _ _ .
y ------ ___
~
s s i I O E E E gl n i
,g, , ,
~
b
~
b
~
b dwva by - g g g g5g mm m m m m
& 6
= 6 & 6 'd l ca a a a a
___ ,,._____-a__ N O A- 8 R 4 W , E""R x c't n ysE W^b sE 7 5 Y C o.. f EE -o
*T y' &*
m 5 E
,. g
~
2
$ TE
- v $$ e
$Y ..
4 g a g E !.]2 e 19v - s m s 4 y g[3 3 pR
.". 5 E I 5 {9 4 $2 2 gs # 5
. - g
.4. I:gEgx- g4zmi 34
- g
, E -*
9 CE 8* S la }^b a IE E '8 >E& " E 'E-aE
-t
~g E
E E m clse -m 8 c sc pc p:
; O' & N M Nb N k k m
f-g g a a- eR - :- g g g g E $ g E : 5 5 m g s s s 9 e u- g -b -4 -? l R R n ~ R k s e c & I 3 E 2 u a m 8
$ .E
,il i
l0 -
* )
P P
)
B B
)
B
)
B
)
B
)
B O ) n I e m e m m e m m T c e e e e M n t t I t I t t t Y e I I I I D MOe Rr 4 4 4 4 4 4 IGr 2 lee 2 2 2 2 2 ETR A 4 4 4 4 4 4 DCdn ( ( ( ( ( ( N a E E E E E E Z ( A , , , - , , , H D 0 D C D D C C C D C C IlliIlIIllIIjlillillIIIIi: g ) n rr g i p ee vt l o i ) i a p
)
P ) E RW ) i l) r e mr ee - r d r e P a. gt tt Ee
- t gt e t
- m. -
na sa Ha r a ga te ., 1 iW yW AW l r nW sw _
- G p S l o i y -
A N id d ,d ob pd S ,~
- I Pe ) e De on ie H R- t St It CU( Pt ,.
) a Ma ( r - a a )
P E D Fr Eo o Er
- o y
c mr eo F E. 0 . 1 m A (b ab m Hb rg en sh (% tb R F rh et k A th vi y r. F ( C C e (t r( ,( ip S (t ee - t t C ei t 4 X H sw) s 1 nP , a, n) -) O ) )) T I R m. T U O d3 e-i3 a- E2 - ge- m2 W3F w d, e E T G S e2 M2 H2 nt2 . 2-. e-E S M P C
, T N
F y 4 .4 A ( 4 is d y4 ( r4 e F. T T D iS y C A P I D N A E ce nr .re se rr l s e t e ar a. i. P R eu eu k) r ERu wu M L P I gg 0u g l g Rg dg c y_ 1 I
/
I U @ U U Q ri eF "4 i F oi oF r(i o F ei eF r. e B Q E m / C 2- @ t r F m ree
. R Ee 1e e tee e E-4 O O T e e r et e e -
L T G S "6 ( S 9S o iS eaS "0 S - E C E 2( N A( RW( 2( "6 - . L A N W I - IliIIllIlIII lIl IlI I lIl lIl . B H A T E D L T I U U O E N B S M t I R I R O T C T A " " C V "6 "6 "6 6 6 A E ' E L 2 '2 '7 '5 '5 2 '2 E 6 8 4 D 0 8 8 2 2 3 3 3 2 2 lIilliIIIIIII IilIiII1llllIIIlI l lI ' k c l o l y - B A E d
@e l s m i e
A s T h C S t R s P e e l T D i s d s a . M i o m M L o _ t n i _ f r e _ A e n - t z a o L i r C r s n u S o _ r D s t _ A s a D e r l 2 L o 1 _ P P 2 llI ilIIIIIIIIlllilliilliIl1lIIllIl _ ! i
)
. ___________ymme O______mgggym_M E E E E E E gl = = ~ :
ag. . . a s a a a
~y a4 4 f 4 4 4 d5g g m m
m m d d d d d d a a a e a a E . i F l F u E E E E E E U gO ab 7 yi*O b3 t B O K - g S' en E =1 E2 5: \
]
g!
-e }I f 3 3e f.! gle l 2 , e
- 5 * !
El .i I; i!f ,El s g 8 5 3e x 5 m - l 5 5 5 a 5,9, E: E9 ,9 I? 5,9 e, e a-
-4
-- 1,- a_ ,- e,a,e e
c y m 5 le ce ag_sa e se g al a os l je 8e.".2. c Ir .c G a :, e s B E~ =. 5csa . ng@
- a g
g g8 eS m- *5 e hyS 68
~- ~.
>S m g _________________________
g , 3 a g ; E $ 5 Y : . . c: . . d L L h h L bn R R n R R M N W R R 5 G n h i
!sig e
f A*
=.a. g u
s m si
"" g
i f ,* E E E E E E E E E E % % % % flE 2%E a a a a a 4 4 4 l g5 g W W W W d d d d a a a a N E F - G E ^ E 72= T i F$ O= b Et Et o p = =
- f= t=
4 - it gE 28 ME$ E 2 ~1 i 5 'S E- es
~
m g s k W s #iLE _,5 3_~$
*5 g * ,_ $'n ~
-e g i- n, Ne g d~ .gs~, s E,-A m,~ .
y ,
. -- ax- t- ,-
y R
$ l [
- A&
~
CE E~E "E E a g 8E c & le& -
~
- g5 s
m 3e - el j;e& p .I . 3r m g g y . -- - .- g , g g ____________________ E $ k g . ! e e 9 9 9 w e asn X m R
~
R a
~
M E a W g 3 .
=
E S [' 5 s g, e-I s ~2 E ~
9 e _____________________p__gg m C B E EE a .e d - A' 9 5 5 RI - m - D d 9 F
'n En g
g m3 5 - -E f ] f" l49
$ e 8"8 b B 6 y2
- 5 E E, c~
-n g -
I4 d S M" g g s-m
~
E g E LC ng
- 5 -
~ z.
m m D p Ra g g g g
.. g 8 a s N a o
a G e. W d h R M EE ] i g a o I
- i E D \
[ a m h 2 2 i
MEe It f 4. e 4 4 e I lee ETR 2. ot 2 2. ot 4 A 4N 4 4N 2 DCd ( ( ( R n 4 A Z A ( E, E E, ( A H D, D D, E, C, , C, 0, B C B C IlIl llIIilI IlIllIIIIi1IIi g g n I n i r R-D D e e 1 d d i i
- g s g A s
- n i n i n n i i H r r M m - m -
0 E e D e D t t 1 N s e s e A y d y d F R S 0 C S i i s s 8 X R ) n ) n I
'A C i C I T R L H R E T O ( s) ( s)
E MA P t mr ee t mr ee S G n tt n tt T N T a se e sa C I N l yW l yw A O E o S o S P L M o yed o ye d P C C M l G 1 I u I rt rt
- /
B N U r ea r ea 2 D I Q o dr o dr A R R E t c no o t c no 4 O O - ct ob L T D e e eth e e cn eU E C G A R S( R S( L A N B E I E IIII IlIIlII 1lIIl!IIIIil1i A R D T D I L S
- I E U N N B I N A O t R I U O T T A C V A E l l l l E L l l l l R E A A A A III IIIlIII i1II IlIIilI1IlIIIIII 1I i 1 -
k c o s l k B A c E t l o d l M B ) e 4 i T d - h C l R S A e f i 3 e i h l l S - i R s e s N l , i O i 2 M I s h T s Rc r A i
,e a e C M z O 1 i r
L r - s s S o Rn u n D t o s) o A c T s1 T O s : e-L e 40 r 3 R (4 P (P 3 lI1 I IIllIIllIIlIIIlIIi1lIllIIIl1ll [
O h g a g a g g g" h % g -
"E E . - ' ~
aa s -
. 3 8
d2 N~ 5 3* N h - t l- l5 $ w 5
.! ag..:
- Y +
w-e w E
- J J d j -
e c -
- I
% 5
- - E'. .I g b i b' U z
d ;
+
'{
l l-
~
t N$
. :t ' ;t c
t B % e e
% T-g "k=k';
5 E g t a ya e: n a s g p: I a w ygy u 3 3-3 3
} h3
[% 1 s - B p - = t
-c- g :1 E 5 A E R
,_ g -
g 55n E l 1 : a m! e2 E Eo Siy!
*i E y s -
a - = E o e
]
I
~
s-s g 8 8 a- tas _ I . -=f 2 8
;Rs m
s g 2
. I 8
a jesg.nm ! 8e su -- 1 g w lg g g E !! 25 s' s t. ng 1 a=g I l a g g s--e ,< [ u s b f 1 yo C -
-o
%g 2
. ES !
l d
~
2 = E 14 "o E ~. '# W , g5
-- k~ r U e-5 f
e f.: _________ _._____ . my 35 e , a s. xe :g C . 4 E, a e: O t =as : g w s z 5 s z It
-s e
,"g 2 : ,2 5J=i.
4 g 4 E E 4 T4 . E e y ; E'
- x"-- w$ e dT. .
E :. ,. o . . .
- as , - u o .
2 2 3 l 9 ..
' s &~ Es 5
i ss :
wb t a t o, p a r tneo Sihbt t t gc n es t ne e heoc i f c t nta p t n i an o hlhm rI c c ci e iL te p n hMt y o . o r w tl e t nn o o "2 ea or t o t p D n w o t/d t m e2 1 nw e st a ew cI n k soel ywdu n n sti m ar u ) o si s t e rg n Jt e on e M t o po ( sit ul f ts l o ncod oepe o r i npt f n e 1 o s t t noa ao l A-
- ei a w i ccnu ot b s t f m H
P dn i n i ego rt np l e 0 um a usi 1 E op wi t n Pyrt s o N u o d Dn T ( R C mqe c nC aPAs i X i y S 0 1 I R hs e p e R A. wi m Uehp h ht o r T E T G tt t et
# P n e ,
u ke ,rd e K l G b S T m2 Nytd C N p- n l na A I D l 1 o el eo l P L aM p i t ha t cs M t T I I I e c iee
/
L B t n ef nl 1 da u gi i g 2 mR 0 O n ag n f t ocl n me i epJ s 4 L T C si n dSM A E A =t a L es t y e 0 E ti r a .s l i sx o p mde . T ye ehp s m gtT P E n i nc ie t p N f o rn . oi n A R t e - n gt C ei Donn l d m cia pn r e dl p o o hs1 o mc x f r ti1 oJ c ei e omI R r s p. te ni. h nt j o eca rt ist t t ea yi c spnee jp t dSl a asi a r od i e) de. nr g der l o lCa et c o hPHgn dt ol sS(li ni u e n e e p edi l or ll unp ct a sh n tt n isrofo ps i es uk er stdsi i son a ne inneh oo mbart
,t pn C r mt mu a erco yof eue o tbs i e cer fre ou1 es th ea s1hn ps1ti snt s ia ed hn oex rruf r a
hlf T po T a DPAot I 2 3 E E E T T T O O O N N N II iI1IiIIlliI' 1 l l
TAILI 4.2-2 l 1 Potential Sourt:es of thborated Water Reacter Building Fin Protection System Meactor Buildig Demineralized enter System ( , Reactar Building Nuclear Services Closed Cooling eter System Aeactor Building Intermediate Closed Cooling heter Systra
- Reactor Building Normal Cboling Water System Once-Through Steam Generators (Secondary Sioe) i e
6 1
h *p
~
l l 73Ek I 1Iair R_,.7 { !i il 5 jt d 01ld 0 sig 1 ch
- 5:ad 5
I 7
/' ~ iiI **-
N
~
L l i h
/ _O j wo.
!L ,. , , ,, , y x 0;j,o;if_y,0;;m;l:x-- ,,
g%y
/ ,- .j!!!!! T 4
\ f./
- :l s j:u - 'i if/(/
/
f o@. . ' r
~..
- .i z%',4 n
< /
C sL-
, : -- ( l N ,bi!.,f i
, 9
' i.
'i
@ CC.: 41_'+ \ b j,' S kk /T th l' [/3 T ' \ 7+ :h I' w \ x\
) i;'ij /I l. j
,\ \
s m.- .. \ l' 7. . '_p2 ,
.s- - -
( s !. x;. . 47
--, (
s
\= q, J. ,-
4,ga l' /
\% RQ~
i'-is l- :3. w*; V ; ~3
. i,.
[ g g e
m M $ WMQ M M. 9 O l -, by
'l - f.
- s. ' - -
g
.'f_
- L5gs;
. r^. i _ _ _ _ . . _ _ d _52
, ir d
- l. g$ I
-E -
3_C-: E 4 i
,i
- s. ,'
- _- - .. f M s ..s 3 l I
- g N l
# # s . :
/
/4r- '-
t.,. 1e, If
* \, *l 8' r;
,~, so 4
*# g 'n ) #
/
/ . . //j.'/,'**
g ~ i, l .!(,9 j . ( r s. < Q - 1,-
\, 1 1
+ g- . . , r ,.
/ f
. li.I y \
<, 1 i s .
y t T <., - ...; i e .4 :I w" ,a ...... w ! c a..s p. A --
-i. -
i
, .+ m - .i ~., ,. \
.,i , . - - ;;:l:.g
. . . . -?, L . _ -- --
.- i.'*. mm
-l. , . , !
-. l gl l \ -L Q .. ...e
/r f- w ml
,
- y. . /, i 1
- I
's ' #
lt * . \ , p. 3. ' d:1h '? :.-.*%
=,
, - s e -
- 6. -...- _ ,
u - s .- c,\_..u '
?. . .
- v s . . .
i j l m- 6 < ta% e ... .- ,r s
, .j e
.- -* y - % s. e pd i l
.Q" ~
i: Y / J P,'i k
- N. x ,j , :.('. . wI r.. B:fl'['
'N , i -
\~ -
' f **~~ f ...g- K-
, y /, *
\ ,o ,f. ' ! n j
, - -;, . s:',.+.; x.3...IN
, > , .;!i.c./, /
g
, -a i g '
C. N .;. l . :: .
.w 9, _
,b
.?
,, t c-
- tm. t.
[$
.i - -
e
;g r*W e-
;p . ,g e. -.
' 1 e er G ew ,
O
g
\ Eg.,
n II l (- . z~a g1 r,y . ,i, 5$ c. I f3 Il !. 23 z E=2
- 5 I !
l ikl i
; ., T'r y 7, I
A
*m J/
2: .' [ dh T* Ul ,
;x . 1- ,
., .1- s.
, k ,,1 k,
;. ;i.: r i..a i.. . . -
l
,p-+-_
I
$ (*s ._
~~
y. u l} :.3 ' v l
,1 sl .
1.,
- a. . . ..
*" s
- )
I \- i;. S ( , .. f . g =r
,r 1 .
7 #e ..
+
i p ; ; g f f. #f, . .. :. .
.g3 :=
<'.:\ s .
*e U. . .
. j.
,,,i
, , y
': .L s . ' . IL 8 5. } 'i k
;'. . . . .! i *
' O.. ,
s
, N % :9 e.
. s b ,.N.
.N ~y.i.', ;c . .
l@, )';, .. l'N% t N, :a 1 1 1 If Il 9 9 9 _-._--_J_.--________.______._____.
. . l
- 2) Decay host removal The decay heat prochetion rete has diminished greatly during the l time since the accident to a point at which active heat removal j
systems are no larger respired (and in fact have not been required > for some time). The present mode of decay heat removal is by . natural losseh to ambient via the reactor coolant system with the main punps idle. Recent analyses have shown that the. decay heat rate is now so saml1 that losses to ambient could be " accomplished' without undesirable sequelae (such as boiling) with a level of coolant in the nector vessel lowered to the elevation of the bottom of the cold leg nozzles. In other words, escay heat removal could be maintained even with the main loop cold leg piping shearec off at the vessel nozzles. , Notwithstanding the above, planned activities of the loao test do not inclu:le manipulation or use of any system associated with the maintenance of decay heat rea, al capability and, as elucioateo in section 4, no credible unplanned occurrence could result in a loss of this capability.
- 3) Confinement of radioactive material The mechanism for confinement of radioactive material presently consists of two major components: the physical barrier of the contairunent building and the lack of an energy source capable of movirg radioactive asterial across this barrier.
The reactor coolant system and especially the vessel itself also contribute to confinement but son in the sense of preventing further escape and dispersion within the containment builcing. As may be seen from section 2, no planneo activity of the load test involves bnachirg the physical barrier of the contairunent or providire a source of energy capable of transporting radioactive material across this boundary and further, as presented in section 4, no postulated urplanned occurrence yields a credible mechanism by which confinement of radioactive material within the containment could be compromised.
- 4) Radiation shieldirg Radiation shieldire is presently composed of major contributions fron.1) steel in the reactor vessel, 2) conente ano steel in tv primary shield and D-rirgs, ard 3) concrete and steel in the containment wall.
No planned activity or connetpance of any credible urplanned occurrence associated with the load test has the potential to degrade major shieldirp components to a degree at wh1ch their shieldf rg fmetion would be negated. This is based on engineer 1rg juopsment maultire from a comparison of lons/ target niative seights and strergths, as well as a review of load paths and
)
cmdible impact orientations. For example, it is not considend credible that a missile shield composed of concrete and nbar could penetrate the 8 indi thick steel mactar vessel head eben falling fma the lift heltit used in the load test. 5.3 A canful review of the bases (Section 8 3/4) for the TMI-2 technical specification has been conducted. Results of this investigation show that none of the planned activities associated with the, proposed test asults in diminution of safety margins stated in these bases. 5.4 The information presented in the above subsections, taken in the aggrepete, demonstrates that the proposed test does not constitute an unreviewed safety question and does not involve a modification of the ) plant tedinical specifications. - 1 I j
)
l l l 19 O
6.0 RADIOLOGICAL CONSIDERATIONS 6.1 (EWPATIDNAL EXPOSUE All individuals entering the reactor building will be monitored for , extemal exposure in accordance with GPU Radiological Control ! l Proceourts (RCP) to ensure personnel exposures are maintained within 10 CFR 20 dose equivalent guidelines. Achinistrative control points in ) l accordance with GPU Procedures will be used in order to assure apecified dose limits are not exceeded. Extremity monitoring will be performed in accordance with existing procedures. The total exposure for the polar crane load test is estimated to be 30 to 90 man-rem. This is based upon the scooe defined in Sections I anc 2 of this safety evaluation, which results in sn estimated irwcontainment man-hour figure of 540. Because of the uncertainty in the dose rates and man-hours, the man-rem for the activities are estimated to vary by 1 50 percent. Considering the uncertainties associated with the man-Irm estimate, 30 to 90 man-rem has been selected to be used as the estimate for the pclar ! crane load test. i Personnel enteririg the reactor building will be protected against the inhalation of particulate radioactivity in accordance with Radiological Control Procedures. As specified by Radiological Control Procedures analyses of expected ' airbomc contamination levels will be performed in order to select appropriate respiratory protective devloes. - Air sampling for particulate activity will be performed using devices such as lapel samplers and methods such as grab samples. Tritium air samples will also be taken as required. 6.2 EWIROP+LENTAL ELEASES Sirce the polar crane load test does not involve the use of any system containing radioactivity and since contairunent integrity will be set and maintained throughout the test, no release of radioactivity to the environment is expected. However, postulated occurrences identified and evaluated in Section 4 any result in some slight release. Since tre release path.ay Lc tre environment is through the containment boundary, these postulated releases would be strictly controlled such that they would be bomoed by the release estimate presented in Reference h. i 9
V c 7.0 SLMMARY AND CDCLUSION The analyses, investigations, and other information contained in this SER show that:
- The polar crane has undergone an extensive tofurbishment and inspection program and is ready in all reweets to be finally load tested. Indeed, the maxinun load to be lifted is less than onc half of the originally designed capability of the crane.
- Special attention has been given to the hardware and software to be used in the load test itself, thus rendering the probability of a load crop extremely small.
I'
- Notwithstanding the low probability of a load drop in the first place, an analysis has been perfo2ned which shows that the probability of unacceptable consequences arising from postulated load drop accident scenarios is extemely small as well.
- Occ@ational radiation exposure to personnel conducting the loac test will be maintained as low as reasonably achievable.
- Environmental releases of radioactivity will not occur in connection with the planned test.
- The polar crane load test does not constitute an unreviewco safety question as stated in 10 CFR 50.59.
In view of the evaluation components summarized above, it is the conclusion of this SER that the polar crane load test may proceed without presentirg undue risk to the health and safety of the public.
8.0 EFDENCES (a) MtC letter of February 27, 1981 containing Generic Letter 81-07 zopardire control of heavy loads. (b) Polar Crane Load Test Procedure - WI 4370-3891-83-PC0001. (c) GPU letter 4410-82-L 4021 of October 8,1962 containing the Polar
- Crane Functional Description and Maintenance Checklist as socified.
(d) GPU lett,ar 4410-43-L-0004 of January 4,1983 containirg the Polar Crane HWad Lift Riggirg description of requalification. tCp (e) GPU letter 4410-83-L.0007 of January 12, 1963 containing additional ' clarification to the Polar Crane Maintenance Checklist. (f) GPU letter 4400-42-L-0110 of July 6,1983 containing
- Methods and Procedures of Analysis for TM1-2 Criticality Calculations to Support Recovery Activities through Head Removal: as an attachment to the CRDM - Quick Look Safety Evaluation.
(g) NUEG-0557, Safety Evaluation and Environmental Assessment, Three Mile Island, unit 2, Febzuary 11, 1980. (h) GPU letter 4410-82-L-0007 of September 23, 1962, containing the Safety Evaluation Report for Chgoing Decontamination Activities. i 22
p '
- FOR IDENTIFIMTION PENNYpD g Page 1 of 13 Place: WIT:__ # " M Date:
I, RICHARD D. PARKS, hereby make the following voluntary statement to Investigators J. Vorse and R. Meeks, who have identified themselves to me as Investigators with the U.S. Nuclear Regulatory Commission. I make this statement freely with no threats or promises of reward having been made to me. Investigator Meeks has typed this statement for me. On page 8 of my affidavit, I state that Tom MORRIS told Richard SEIGLITZ that I should be counseled for my negative attitude and that SEIGLITZ related this to a group of Site Operation members, including myself. Those in Site Operations that were present when SEIGLITZ related this were Larry KING, Joe CHWASTYK, Bubba MARSHALL, John PERRY, Joe SMITH, Linda NAGLE, Joyce WENGER, Madan KARR and Swede HOLTMAN of Recovery Programs (RP). In fact, HOLTMAN stated in an ensuing conversation at the time that Site Operations was meeting schedule dates better than anybody else on site. HOLTMAN was the representative of RP on the Head Lift Task Force (HLTF). j Concerning the above matter, I am not aware of the personnel procedure that should be used for counseling employees on negative attitudes at TMI-2, whether they be Bechtel or GPU-N employees. I did not receive any written memos on this matter from Bechtel or GPU. I do recall that on my last performance evaluation Ed KITLER had given me ratings ranging from excellent to outstanding. This performance evaluation was done around the January /Februt.ry time period of 1983. On page 18, I mention that Larry KING, on 2/11/83, informed the Site Operation staff about the contents of a meeting between KING, KANGA and ED GISCHEL on the Polar Crane SER. Those 50 staff members present at that meeting, to the best of my recollection, were Messrs. CHWASTYK, MARSFALL, PERRY, SMITH, KARR and Linda NAGLE and Joyce WENGER. In response to a question by Mr. Meeks, I would describe BARTON's personality or character as it relates to his daily mode of doing business as that of a intimidator. BARTON shouts and is a brusk individual who often threatens to fire an employee if that employee does not follow through with BARTON's wishes or desires. Many times this !s just an every day expression used by BARTON. However, if necessary, in my opinion BARTON would follow up with his threat to fire an employee if he thought it was necessary. 030287022
j
- s. -
Page 2 of.13 BARTON doesn't like to leave a paper trail. When'he disagrees with a - memo, he'will write his comments on the original memo and return the memo to its author. j BARTON, in a February 23rd meeting, asked me if the Revocery Operations Test Manual (AP1047) was the same as the pre-accident test manual. I told BARTON that generically the two were the same. BARTON had approved administrative
-procedures AP1043 and AP1047-for the TMI-2 Recovery Operations. In reference to his stand on the Polar Crane, BARTON turned his back on his previous experience
.at TMI-2, and more specifically, on procedures that were followed on the SDS.
BARTON was the Start Up and Test Manager for Unit-2, and possibly at Unit-1, ! before his duties as Director and Deputy Director of Recovery Operations. On page 19, I mention a meeting in Room 201,and 203 on 2/14/83 on the Polar Crane Load Test. I was not present at thad meeting and the primary source of my information was Larry KING. On page 20 I mention my conversation with Ed XITLER on February 18th regarding KITLER's statement that he had been asked by Rich GALLAGHER to look into trans-ferring me off sitn Those in the Site Operations office who heard me comment about the conversation with Ed KITLER, in addition to Larry XING and Joe CHWASTYK, where Messrs. MARSHALL, PERRY, SMITH and Secretary, Joyce WENGER. When KITLER saw that I was taking his comments very seriously, he tried to down-play the issue in an attempt to cool down the matter. It was also KITLER's l responsibility to originally bring us the issues that I had made concerning the Polar Crane Load Test and the application of procedures.AP1043 and AP1047. On page 23 I discuss the BLIZZARD phone calls to Larry XING, Gloria KING and Benjamin SLONE. BLIZZARD also made phone calls to Ronnie MUCHA in Iowa about the same matter. MUCHA, at that time, was SLONE*s fiance. In my conversations to SLONE about the BLIZZARD phone calls, SLONE had mentioned to me that on or l about February 23rd he talked to RIDER about BLIZZARD's offer. According to t
Page 3 of 13- - SLONE, RIDER stated that Bechtel was interested iri having Quiltech consider-e consulting contract on an upcoming reorganization at TMI-2. On page 27 and 28, I discuss KING's suspension from TMI-2 for his alleged conflict of interest due to his association with Quiltech.. Concerning Quiltech,. in the July / August 1982 time frame, Ed KITLER asked me if I would talk to Larry KING about lining up a job for KITLER with Quiltech at the PALATKA Coal Fire Plant in Florida. I called SLONE on XITLER's request and SLONE handled the matter with KITLER from that point on. Also, during the July / August 1982 time ) frame, Larry KING asked me to line up a typist for some resumes for Quiltech. i I obtained the services of Rose LITTLE and she typed up various resumes that f were generic in nature. I recall that some of the resumes were those of Larry KING, Bill AUSTIN, Kingsly DRAPER and possibly Ken LYON-ARENDS. Also during the July / August 1982 time frame, I recall Rich GALLAGHER asking me when KING was going to leave for Quiltech. ItoldGALLAdHERtoaskKING. { Around the November / December 1982 time period, I remember Ben SLONE talking to me about Joe CHWASTYK's involvement with Larry KING and CHWASTYK's attempt to obtain a position with Quiltech. I know that CHWASTYK attended a Quiltech meeting with KING, SLONE and Gloria KING at the KING's house during this time period. It was also during this time frame that CHWASTYK went to Beaver Valley with John H0AG, a relative of KING's and als'o a member of Quiltech. At Beaver Valley, CHWASTYK contacted Don SKIDMORE of Duquense Light Company, the I licensee at Beaver Valley, about a Quiltech proposal and possible contract at Beaver Valley. CHWASTYK has since told me that when Beaver Valley comes through none of us will have to worry about the way Bechtel is trying to move the schedule ahead and take over things. The 50 staff was generally aware of CHWASTYK's and KING'S involvement with Quiltech. It was also during this time frame that KITLER made a comment to me that Larry KING should be careful because it was starting to get around about KING and Quiltech. I told KITLER that KING was not the most discreet individual in maintaining a low profile on the Quiltech matter. Around February 1983, I recall that Jim THEISING and Bill AUSTIN went on a
. skiing trip. During the Congressional hearing on April 26th, it was stated that
e-Q Page 4 of 13 in February THEISING, while on a business trip, was told a second time about- KING's involvement with Quiltech. Possibly this was the business trip that was refer-enced in the congressional testimony. Sometime during the latter part of 1982 or the first part of 1983, Dick JUBBA of Nine Mile Point, an employee of Bechtel, phoned Larry KING and asked him some questions about Quiltech and KING's involvement with Quiltech. I recall, from conversations with Larry and Gloria KING, that there were two phone calls from JUBBA on this matter. I was present in KING's house when the second phone call was received. I feel that the Quiltech matter was definitely blown out of proportion. In the nuclear energy industry one is always mindful of the various opportunities avail-able for advancement and promotion at other, nuclear sites. In fact I was first hired by GPU to work at TMI-2 in a manner dimilar to how Quiltech operates. ! While I was working for Energy Consultants, Inc., NUS sent a proposal that in-volved my resume to GPU. 'NUS is a job shopper similar to Quiltech. GPU did not condemn my hiring but has condemned KING and Quiltech. - It was during the first part of February that Ed KITLER told me that his transfer to Florida had been arranged. KITLER asked if I would take over his position as Start-up and Test Manager. I immediately talked to Dave BUCHANNON, who was head of Design Engineering for GPU, and told him that I would take KITLER's job only if it were transferred _ to Site Operations. BUCHANNON stated that he didn't know anything about the KITLER transfer and that he would look into it. KITLER j did stay on site. However, he was absent from TMI-2 the week after KING's suspension. l KITLER returned on or about March 8th or 9th. After he returned I asked Dave BUCHANNON how he got KITLER to stay. BUCHANNON stated that he worked out a deal with BARTON to get KITLER's per diem taking care of. Dwight WALKER headed up a Test Work Group meeting while KITLER was gone.
es
)
Page 5 of 13 l KANGA, in his testimony before Congress on April 26th, stated that he first heard of KING's involvement with Quiltech on February 24th and that he,- KANGA, was'on sick leave that day. KANGA stated that he received a phone call on the j matter while he was at home. The phone call was from BARTON, and was made at l approximately 6:00 p.m. I recall Larry KING telling me about a meeting that he had with KANGA, on site, on February 24th at .1:00 p.m. on the containment entry procedure, and that this meeting was cut off for a fire safety meeting. It was during this meeting that KING told KANGA that he was supposed to run the recovery operations at TMI-2 but that it was apparent that THEISING wanted to run the show. LARSON, who was head of Licensing, had earlier informed KING that he was in charge of the recovery operations. At that meeting, KANGA told XING that he was the boss and this fact was to be put in writing. This was in reference to KING being made the alternate to KANGA'and thus putting someone in upper site management on record who met the ANSI standards as site director or alternate site director.
/
In reference to KANGA not being qualified by ANSI standards to be site director, I recall from conversations with Larry KING that both he and Joe CHWASTYK, on or about the middle of September of 1982, went to Lake Barrett of NRC and complained that the Safety Review Group was to report to KANGA but that KANGA, according to ANSI standards, was not qualified to receive an operator's license. Through the grapevine, I heard that BARRETT went to GPU and complained that the internal matters CHWASTYK and KING had brought up to BARRETT should go through the chain of command. It is my understanding that the NRC has never approved the reorgani-zation. I also recall that GPU in testimony to Congress on or about , stated that the reorganization had never been approved. At this point I would like to mention a meeting that was held in early January on- the Sewerage Tank Test Procedures. That meeting which was with KING and THEISING, concerned how to conceal in a quarterly re' port to NRC, the amounts of cesium in the storage tanks. I know that Larry KING had objected to the way the procedures were handled'on the sewerage tank. KING did' sign the procedure when a GPU Enviornmental Inspector reversed his earlier standing and stated that the procedure was legal. Ed GISCHEL, Ken HOFFSTETTER, Cary HORNER, Pam Stoner-COOPER and Carl HARBAC are familar with the sewerage tank matter. l
Page.6 of 13 On page 31. I make mention of the minutes kept by' Ken PASTOR of a 2/28/83 meeting on the Readiness Review Comittee. There is no formalized procedure for taking minutes at TMI-2. The established practice is for the organization 'l calling the meeting and in charge of the meeting to keep the minutes. The minutes are then typed by this organization and circulated to the attendees. If there are any disagreements on the contents of the minutes then the person disagreeing writes a memo on his objections. I recall that KING had done this on occasion and BARTON took exception to KING documenting his objection j i to the minutes. i The minutes of the 2/28 meeting showed that NRC approval should go quickly since NRC comments are already available and should be resolved by the tire the Polar Crane Operating Procedure is submitted to the NRC. I can think of two inctances-where site management has used prior NRC approval in an attempt to obtain Site Operations approval on a specific procedurd. The first instance occurred when Mike RADBILL handed me the Polar Crane Load Test Procedure and stated that it was the hottest thing on the Island. RADBILL also explained that the PORC and the NRC had been involved with the test all along and that neither had any problems with what was in the Load Test Procedures. This happened toward the end of January 1983. Also on March 3rd, during a second meeting on the Readiness Review Committee presentation, THEISING stated that to move structural steel with the Polar Crane had been signed off by everybody and his brother, including NRC. At that point I stated that the procedure should be looked at by the Test Work Group. I have never seen NRC involvement on procedures used at other sites like it is at TMI-2. I have never seen this buy off procedure used in this way at other nuclear sites. 1 also recall that I was given the procedures on the Reactor Vessel Internal Radiation Measurements and told that PORC had already approved the procedures and that I should go ahead and sign off. I noticed that the procedures had not gone through the proper review cycle and I, therefore, wrote a Site Operations
4 Page 7 of 13
. Problem Report on this. I cannot recall the name'of the person that gave me .
the procedures and asked that.I sign off, but his name is listed in my comments on the problem report. Concerning that meeting on 2/28 and the conference afterwards between myself,
. Jim THEISING and Ron WARREN, I received the distinct impression that THEISING was trying to convince us that this matter was going to be taken care in THEIS1NG's own way. During that conference, THEISING wanted to know why Site Operation was trying to assume authority now when they had given it up on things such as the Quick Look. I told THEISING that Site Operations is the responsible group under the license. THEISING then explained that in an accident or deficiency involving matters handled by Engineering, that Engineer-ing would be the responsible party, and would have to assume blame.
BywayofexplanationontheQuickLookPrdedures,IrecallthatLarryKING wrote a memo that Site Operations would cut back on non-vital areas in order to come up with the funds necessary to handle the Quick Look Operation. KING stated in that memo that Site Operations was preparing the methodology and software to handle the Quick Look. BARTON replied that Site Operations was to stay out of the Quick Look, that it was Bechtel's and the Technical Advisory' Group's responsibility. l Also in the 2/28 meeting, THE1 SING made a statement that he could understand why certain people were afraid of a transfer. That comment came about as a result ; of our discussion on NRC examining the Polar Crane Issue at that time and Ed KITLER being called in by NRC and interviewed by Joel WEIBE. We were also talk-ing about Larry KING's suspension in the same context. THEISING's transfer comment came about as a result of comments on these topics. On page 32, I began a series of comments on memos that Joe CHWASTYK and I wrote, basically concerning the application of AP1043 and AP1047 to the Polar Crane Load Test. CHWASTYK was in full philosophical agreement with those memos. l 1 feel that CHWASTYK believed that he was going to be Acting Director of 50 !
- v .
. l J
l Page 8 of 13 fo'r'only two or three weeks. In fact, in a meeting with the S0 staff right after j
-he assumed'the' acting position, he stated that the KING incident would.be over
. in two or three weeks and KING would be back on 'the job. However, after two j or three weeks had passed I got the impression that CHWASTYK's opinion.of the 1 KING matter had changed. I also believe that CHWASTYK, as he attended the var-ious recovery meetings, realized that KING was not going to return and that I was considered an obstacle the same as KING had been. CHWASTYK knew that my wife was dead, as did most of the Site Operations staff. When CHWASTYK made that phone call to Gloria . KING and stated that my wife was trying to dig up something on the child custody case I feel it was CHWASTYK's-indirect way of trying to
~ tell me that I was targeted as KING had been.
I believe that CHWASTYK was replaced as Acting Director of Site Operations by BARTON because-the KING investigation by GP,U had revealed CHWASTYK's involvement with Quiltech. I also understand that it das during this time period that Joe CHWASTYK was taken off a TV commercial that GPU was to put on the air. On page 33, I mention that BARTON accused Joyce WENGER of xeroxing and taking to Larry KING a memorandum that had been missing on February 28, but that had reappeared on the morning of March 1st. The memo in question was the so-called
" Smoking Gun Memo" that KING had wrote to KANGA and BARTON on his' concerns on the Head Lift Schedule and the way things were done.' I think the memo no. was ,
around 069 but I am not sure of this. I recall that on Monday morning, February -
' 28th, Joyce WENGER had made the comment to the 50 staff in general, that the memo was missing from the file and that she was looking for it because KING wanted the memo. On Tuesday morning, the memo appeared back in the file.
On:page 35, I discuss a meeting on March 3rd concerning the agenda for the Readiness Review Committee. It was in this meeting :that Mr. THEISING stated 1 that only a person of limited intelligence would think that the whole Polar Crane aparatus was important to safety. In response to a question by Investi-gator Meeks on my description of THEISING's personality and method of conducting his daily business, based on the meetings that I have attended with Jim THEISING, I believe he is a dynamic person and would remove all obstacles to get the job
\
Page 9 of 13 done. In response to Investigator Meeks' question to describe KINGS personality and methodology of operation I would state that KING is also dynamic; he has a great deal of fortitude. KING also does whatever it takes to get the job done. However, KING is concerned in achieving his job objectives within clearly defined boundaries and if necessary KING would changes those boundaries so that procedural adherance is maintained while still achieving the objectives of the program. On Page 36 and 37, I discussed George KUNDER as being the mystery man who ordered the safety and injection pumps turned off during the March 1979 accident. Most of my information on KUNDER, as the mystery man, is based on the several conversations I had with Joe CHWASTYK on this matter. It was CHWASTYK's impression that KUNDER was in charge of the operating room, or rather of the ad hoc in-charge committee, until about 7:00 a.m., when Gary MILLER arrived and assumed responsibility. CHWASTYK, himself, arrived around 10 or 11:00 that morning. CHWASTYK has tol'd me basically two stories about KUNDER's actions on the morning of the accident. One, that KUNDER shut down the reactor coolant pumps 'because of their vibration. Two, KUNDER shut down the injection pumps due to the indicated high level in the pressurizer. Upon CHWASTYK's arrival in the control room he had to argue to get the ad hoc in-charge committee to restart the injection pumps. At least it was my impression that CHWASTYK was referring to the injection pumps. In addition, the Concerned Mothers of Middletown knew approximately six months ago about the possibilities of George KUNDER being the mystery man and that they relayed this information to Lake BARRETT of the TMI Program Office. On page 37, I state that Larry XING, Joyce WENGER, Joe CHWASTYK and myself were all present when I made my threats to notify the local newspaper identifying KUNDER as the mystery man. I stated that only CHWASTYK has not suffered systematic repraisals as a result of this. Those systematic repraisals are the reprisals that I have outlined in my affidavit. On page 38, I make mention of another meeting on March 4th concerning the containment entry procedure dispute. It was my impression that Charlie HANSON
e Page 10 of 13 of Recovery Programs actually agreed with the sta6d of Site Operations but -- could not contradict the personal preferences of Mr. THEISING. Also in this meeting Bill KELLY mentioned that earlier KANGA had ordered to leave the issue of who is in charge of containment entry as written by Recovery Programs, i.e., that Dave BLAKE was in charge of Containment. By way of information, before January'15th,'all containment work was done by work packages. After January 15th, it was a shift foreman that signed off on Ukis. ' On page 45, I explained that on March 10th I had a discussion with CARL HARBAC, Ed GISCHEL, and another member of the Plant Engineering concerning the fact that ARNOLD had asked Larry XING about my involvement with Quiltech. The other member of Plant Engineering was Jim HENDERSON. On page 46, I mention a 1:30 p.m. meeting thut I had with Joe CHWASTYK on 3/10/83. That meeting was held in CHWASTYK's office'and the only other person that heard part of the conversation was CHWASTYK's Secretary, Bonnie. CHWASTYK started this conversation as we we're walking into his office and Bonnie was sitting right there and would have heard the first part of the conversation before CHWASTYK had closed the door to his office. I also recall that on the morning of March 10th CHWASTYK had a meeting with the Site Operations staff. In that meeting CHWASTYK stated that somebody had been communicating to NRC on a daily basis. CHWASTYK reminded us that we should be mindful of the story of the boy who cried wolf. On page 47, I make mention of Joe CHWASTYK's 3/10/83 phone call to Gloria KING and stated that to my wife trying to dig up some negative information for the child custody case. After I was put on leave of absence, I remember talking to l l CHWASTYK by phone and I told him that I considered this statement to Gloria KING was meant as a friendly warning to me. CHWASTYK did'not make any reply. CHWASTYK had originally called Gloria and asked her about leaks to the press. The press leaks were in reference to an article in the Washington Post, by Susan Stranahan, on the Polar Crane issue. The article appeared before the suspension of Larry KING. On page 49, I discussed my March 15th meeting with Messrs. SANFORD, WHEELER and H0FFMAN. I did not observe any notes being taken during that meeting. However,
Page 11 of 13. Mr. HOFFMAN was~ sitting behind me and it was possible that he took notes during this meeting. When I arrived for the meeting that morning Mr. SANFORD asked me when had I arrived in Gaithersburg and what time I had left Middletown and whether it was the night before or that morning. I told SANFORD that I left that morning. HOFFMAN then asked me what time I left and I told him about 6:30 a.m. I thought these questions were strange, especially in light of the fact that I had been meeting with representatives from the Government Accountability Project Office on the evening before the meeting. I would also like to point out that on Monday afternoon, March 16th, I was cleaning out my desk at work. Bubba MARSHALL, Jim FLOYD and Joe CHWASTYK, as well as Bonnie, the temporary secretary, were present at the time. I had asked CHWASTYK earlier in the day if I could use the Site Operations staff to go through work documents on the head lift and show the hours expended by Site Operations. I wanted to show the ineffectiveness of Site Operations methodology of work because of t,he conflicting head lift and polar crane schedules. CHWASTYK told me that a fask force was going to come up with a total integrated schedule and that the work would not be needed. Also, on or about the March 16th time frame, I attended a meeting on the Inte-grated Schedule with Joe SMITH of Site Operations, Mike SMITH of RD&D and Butch DAUBERT of Recovery Programs. This meeting was set up the day of Larry KING's suspension and after KING had made the headlift schedule a known issue. During that meeting, Mike _ SMITH stated that in October of 1982 he had wanted to put out an integrated schedule but that Site management wanted to work off the head lift schedule. Mike SMITH also stated that RD&D had not received any notification i that the June 30th head lift schedule had been relaxed. DAUBERT stated that the relaxation of the June 30th date was not yet out but that it would be out that week. On page 50, I made mention of the break-in of my apa~rtment. I left my apartment locked up on Monday evening at 9:00 p.m. and I arrived back and found my apartment broken into on Wednesday morning at about 7:30 a.m. To this date, there has been no disposition on this burglary investigation by the Middletown Police.
Page 12 of 13 On page 51, I mention a March 17th morning meeting,with Mr. KANGA. During that meeting, KANGA told me that he would have licensing and QA respond to my concern on the polar crane. ; On page 52, I make mention of a 1:00 p.m. meeting on March 17th with KANGA and CHWASTYK concerning my removal as the primary site operations member on the Test Work Group for the polar crane project. With respect to KANGA asking me twice to agree that my removal was not an act of intimidation, I will add that after the second time, KANGA gave the memo authorizing my removal to CHWASTYK and asked him to sign this statement. In regards to my signing the Load Test Procedure based on technical content of the procedure only, on the morning of 3/17/83, I had requested from Mike RADBILL more dccuments on the polar crane matter. RADBILL, at that time, told me that my personal vendetta was holding everything up. It was at this point that I then decided to sign the procedure with the technical content proviso. / On page 55, I stated that several sources had shared with me their understand-ing that prior to issuing formal NRC letters, Lake BARRETT would submits drafts of these letters to ARNOLD or KANGA for editing or comments. My knowledge of this practice comes from conversations with Larry KING. KING has stated that the contents of proposed memos are massaged over the phone between BARRETT and ARNOLD or KANGA. KING was present on one occasion when BARRETT called ARN0LD and the conversation was put on the squawk box. The i matter concerned GPU-N's response to a low rated item on the SALP Report. I According to KING, ARNOLD and BARRETT discussed the contents of the memo and how it should be worded. It was also agreed that the GPU wouldn't publicly critize the NRC without first talking to NRC about the matter. l On page 4 of my second affidavit, I stated that on March 22nd, I had a meeting l with Mr. KANGA, Andy WHEELER and Bechtel Public Relations Officer, Doug BEDEL, wherein I was asked if I had a news conference scheduled for March 23rd. I do l l not know how Bechtel found out about my new conference on March 23rd. I know that Joel ROTH of had told me that he had received a copy of the 1 I 1
~
,,..b i Page 13 of 13 affidavit the day before the news conference. I assume that ROTH probably got ~ his copy of the affidavit from a Congressional source. Possibly, Bechtel found out about the' news conference through that same or a related Congressional source. Also on page 4 of the second affidavit, I state that Mr. KANGA, at a press conference, asserted that the Polar Crane had been originally load tested to 500 tons. Based on conversations that I have had with those associated with the pre-operations test and the fact that I could not find any documents on the pre-operation load test for the polar crane, I disagree with KANGA's assertion that the polar crane had orginally been load tested. In fact, when the Site Operations staff was doing research work on the taped drains, referred to in Mr. GISCHEL's affidavit, we found that many of the originals on the pre-operation test procedures for TMI-2 were missing. It is my understanding that these pro-cedures should be kept in fireproof vaults./ I am talking about approximately four years of procet es and test documents, etc., that could not be found. Also missing was the master punch' list for open items on pre-operation tests. It is my understanding that the master punch list is required by law to be kept j on site for five years. I have read the foregoing statement consisting of 13 typed pages. I have made and initialed any necessary corrections and have signed my name in ink in the margin of each page. I swear that the foregoing statement is true and correct. i Signed on at . l l 1 SIGNATURE: i RICHARD D. PARKS Subscribed and sworn to before me this day of , 19 , i at . INVESTIGATOR: 1 Name: 1 WITNESS: __. Name:
Title:
- - - o
.cf Recovery Programs actually ag. reed'with the stand of Site Oper'ations but could not contradict the personal preferences-of Mr. THEISING. Also in this meeting
.3111 KELLY mentioned that earlier KANGA had ordered to Jeave the issue of who it in charge of containment ~ entry the way it was written 'by Recovery Programs, i.e,.,
that Dave / LAKE was in charge of Containment. By way of information, before \ January 15ths#all containment work was done by work pac.kages. After January 15th, %* k it was a shift foreman that, signed off on UWIs. d,. 3 , Also, on or about the March 16th time frame, I attended a meeting on the Integrated Schedule,with Joe SMITH of Site Operations, Mike SMITH of RD&D a'nd Butch DAUBERT
> of- Recovery Programs. ...This meeting was. set.up.the. day .of Larr.y . KING's suspension'
, and after KING had made the headlift schedule a known issue. During that meeting, Mika SMITH stated that in October of 1982 he had wanted to put out an integrated schedule but that Site management wanted to work off the headlift" schedule. Mike SMITH also stated that RD&D had not received any notification that the June 30th headlift schedule
- had been relaxed. DAUBERT stated that the relaxation of the June 30th date was npt ye out but that it would be out that week.
" * ~
in . e Jn'pigT5$T staittd .that ~feveral~soo'r~ces had shared vittr me their understanding t ' that prior to issuing formal NRC letters, Liike BARRti n would submit drafts of--
,these letters to Bob ARNOLD or KANGA for editing or comments. ,
g.;p ~ l My primary knowledge of this practice comes fr'om conversations with Larry KING. KING has' stated .that the contents of proposed communications on occasions have been massaged over the phone between BARRu a and ARNOLD or KANGA. KING was present (
"En ene occasiori when BARRETT called KANGA and the conversation was put on the squawk box. KANGA told BARRETT how management would respond if the NRC cited us for some practice. To the best of my knowledge, I believe KING said BARRETT Iacked off and we weren't cited. Another matter concerned GPU-N's response to a low rated item on the SALP Rep, ort. According to KING, the NRC was upset with GPU-N's critical response. It was agreed that the GPU wouldn't publicly criticize the NRC without first talking to NRC about the matter.-
I have read the foregoing statement consisting of 5 typed pages. I have made and initialed any necessary corrections and have signed my name in ink in the
PLPS %^ DEFrS EXHIBIT Y FOR IDENTIFICATION
.. . ".""!WM"" g7
- ...- .. ~... .
Wit: Nulid $Abd - I, Richard D. Park's, hereby make the following voluntary statement to Investi . 1 gators J. Vorse and R. Heeks, who have identified themselves to me as Investi-gators with the U.S. Nuclear Regulatory Comissions. At the request of Messrs. Vorse and Meeks, the following sta that I will be submitting ontu:p:r:gment = :t THI-2. is one
- of four separate statem '
This statement covers technical concerns connected with o' organizational violations in the cleanup. I make this . statement freely with no threats or promises of reward having been.made to me. . -
. . . . . ,p . .c . . , . . . . .
't . . ~ -
John BARTON, in a February 23, 1983 meeting, aske3 me if the Recovery' Operations Test Manual (AP1047) was the same as the pre-accident test manual. I told BARTON l that generically the two were the same. BARTON had approved admini$trative
~
procedures AP1043 nd AP1047 for the TMI-2 Recovery Operations. In reference to l
*f ' 1 his stand on the' ar Crane, BARTON turned his back on his previous experpence at '
THI-2, and more specifically, on procedur*es thit were followed on the SQK. I bel 4 eve .that-BARTDN ,was..the Start Up.and Test Manager for Unit 2,* and possibly
.at Unit 1, during'their construction phase, before his duties as Of-+~ sgk C
Deputy Director of ?,e. H.ctr;" f; m ti = . Y
,. On page 19 of,my March 21, 1983 affidavit, I mention a mee. ting in Room 201 and 203 on 2/14/83 on the Polar Crane Load Test. I was not present at that meeting and the primary source of my information was Larry KING.
iG ., (~]"In reference to Bahman KANGA not being qualified by ANSI standards to be site
.adirector,.I recall from conversations with KING that both he and Joe CHWASTYK, %.+ \
P T.around or shortly.after the middle of September of 1982, went to Lake.Barrett of
. .HRC and complained that the Safety Review Group was to report to KANGA~but that
' XANGA, according to ANSI standards, was not qualified to receive an operator's license. In this role the Safety Review Group was sub_stituting for the legally
' approved Plant Operations Review Comittee (PORC), which reported to Site Operations (S0). Through the grapevine, I hear that BARRtii went to GPU and complained that
- - __ -.m_____-__ _ - . _ _ o
. ~
.g. .
*h2 internal matters.CHWASTYK and KING had brought up to B'ARRETT should go through'
.ne' chain of commaiH!. It is my understiinding that the NRC has never approved ne reorganizatNn.] ,
At this point I would like to mer: tion a meeting that was held in early, January en the Personnel Access Facility (PAF) Sewage Holding Tpnk. .That meeting, which. . t was held in KING.'s office. also include Jim HILDEBRAND of Rad Con~ and Jim THIESING' ' THEISING was concerned'with,' in effect, how to conchal in a quarterly report to
- NRC, the amount.s of cesium in the storage tanks. When unacceptable cesium levels u _ . , . . .
~~were detected GPU was worried abou.t an NRC fine, because the PAF was being used lilloye *it 'was ^ signed off.~ - ---l ~ - - -- -- - - - --.. . ..
L .. . .-
'I know that Larry KING had earlier objected to the way the procedures were handled en the sewage tank. He felt that the tank could not be used, because it was not
'in compliance with state or local ' laws for' control of radioactive sewage to prevent Mt -from spreading to the environment. I believe that dNG sent a memorandum to hat effect to BARTON. KING told me tFat he refused BARTON's order to sign for urnover of the sewage tank innd suggested that BARTON sign it himself if he felt
..t was legal. -. - - BAR
...Y..ON' refused. ........ . . _ KING was Basing his posttien on the findings from
'a G.PU Environmental Engineer. KING did sign the procedure when t)e GPU Environ-a 3 ', mental Engineer reversed his earlier' position and stated that the procedure was
,,lega.. 1 Ed GISCHEL, Ken HOFFSTETTER, Kerry HORN.ER, Pam Stoner-COOPER, Carl HRBAC, .
.. . m . c. .
.Iton WARREN and Gary CHEVALIER may be familiar with the sewage tank matter.
On page 31 I make mention o he minutes kept by Ken PASTOR of a 2/28/83 meeting
}. cn the Readiness Review Comittee. There is no, formalized procedure for taking . ,,:ginutes at TMI-2. The established practice is for the organization calling the M ting and in charge of the meeting to keep the minutes. The minutes are then '
hhd by this organization and circulated to the attendees. If there are any isagreenent's on the contents 6f the minutes then g the per oggig writes b a namo on his objections. I recall that KING .had done this angoccasion and BARTON
" took exception'to KING documeriting his o'bjection to thi' minutes on at least one ' teasion. ,
she minutes of'the 2/28' meeting showed that NRC approval should go quickly since NRC coments are already available 'and should, be resolved by the time the Polar
4 .
- 2. ' . - 3,-
Crane Operating Procedure is submitted to the NRC. I can think of two instances a
' here site management has used prior NRC.. approval in an attempt to obtain Site Wrations approval' on a specific procedure. The first, instance occurred when -
Niko RADBILL handed me the Polar Crane Load Test Procedure and stated that it was the hottest thing on the Island. RglLgogxgaigth t the g PORC and N hat NRC had been involved with the test'all along and that neither had any problems with what was in the. Load. Test Procedures'. As a result ,he said Site Operatio ,
- should also sign off. . This. happened around mid-February; 1983. ,t e ,Also, on, March 3rd, during a second meeting on the Readiness Review Committee - =-
p._rgsentation for the Polar Crane, I stated that the Test Work Group should approve
.use of the Polar , Crane before it was used to move structural steel. I took this position becau,se I believed that necessary engineeli'ng analyses had to'be perfonned and the crane tested by a test director under controlled conditions, before it was
" used THEISING stated'that the Polar Crane had been signed off 'by ederybody and
, [h'is brother, including NRC, In fact, on March 7 I believe that the crane was used
"~.to nove structural steel, despite' the absence of a. Safety Evaluation Report or Site Nrations sign-off! The bypassing of con *trols'on'the Polar Crane contrasts sharply Y ith-the -controls,,6n use cf -the fuel . handling building. crane in 1981. That crane
~
'was properly controlled, although it is. net used for such heavy lifts as Dthe o. - Polar-M sane. C The use of early NRC approval as a lever to pressure me toF'54Q 'gn
>'[off on procedures is also new for me. I have not had that experience at other c
- .witants. ;;
Q:' I also recall that I was given two procedures on the Reactor Vessel Internal
- ' Radiation Measurements and told that PORC had already approved the procedures and
- e. .
.that I should go ahead and sign off. I noticed that the procedures had not gone jhrough'the proper review cycle and I, therefore, wrote a Site Operations Problem F"iRzport on this.' I cannot recall the name of the person who gave me the procedures w.
~ and asked that I sign off. His name may be listed in my coments on the Problem j irport, or he may have just been acting as a go-between.
j, . Concerning the meeting on 2/28 and the conference afterwards between myself, Jim REISING and Ron WARREN, I received the distinct impression that THEISING was AW 1 rying to convince us that this matter was going to be take' care of in THEISING's own way. During that conference THEISING wanted to know 'why Site Operations was L___._____._______.._____.__
. 1 l
.\
_g_ , I
~
.trying.to assume authority now when they had given it up .on things such as the juick Look. I told THEISING that Site' Operations had to under 10 CFR 50 as the
. esponsible group under the, license. THEISING said that was an improper inter -
pretation. If there were aceident or deficiency involpng matters handled by NTngineering, the NRC would go after the engineers, noTthe operators. The opera-tors were just the people who signed off at the end. I, did not believe him. 3 That was not the las at any of the other plants where I;had worked, and I was not . 1 1 ' ~ aware that the law had bean changed for TMI.
- mummy-.
4, By way of explanation on the Quick Look procedures, I recall that back in early y 1982,-Larry KING wrote a. memo.that . Site Operations would cut _ba.ek, o,n. non-vital areas in order to come up with t.he funds neces.sary,_to handle the Quick took . Op; ration. KING stated in that memo that Site Operations was preparing' the metho-dolo'gy and software to handle the Quick Look. BART.ON replied tha't Si,te Operations , was to stay out of the Quick Look, that it *s Bechtel's and the Technical Advisory Group's responsibility. Site Operations o. yed Mr. BARTON's directive. ::hbeldey e 3
@t the~NRC3hbTila_, review 4eEhtelisd}andp_n_gsf,,t_he-guic,k;L_ook. Acht.el-resolv,e,d.
- he2cutstandJngd+8+ Mon'.2te:QuicTTioTpunchIdstuomui c k,1,yghatdtd sjmposs.i bl eg g
,to!KviIc5iff.filiidieTtHiif2 hey wiirtaQiMp'eTTyf.reviewe4 - .
P@' qTla M.3. s ~ A= f g( '.' -- On page 35(I discuss a meetingg March 3rd.concerning the agenda for the v Readiness Review Committee. I was in this meeting that Mr. THEISING stated that inly a persodif limited ' intelligence would thInk that .the whole Pola~r Crane ap-paratus was important to safety. In response to a question by Investigator Meeks
' concerning THEISING,'s management style, my description of THEISING's personality
'~
and method of conducting his' daily business Is based on the meetings that I have b attended with Jim THEISING, I believe he is a dynamic persan and would remove all Ebstacles to get the job done. In response to Investigator Meeks' question to
. describe ' KING's managementjtyle, personality and methodology of operation, I -
would state that KING is also dynamic; he has a great deal of fortitude. KING also does whatever it takes to get the job done. However, KING only operates within the legal boundaries. If necessary, KING wouldseek to change those boun-daries so that procedural adherence is maintained while still achieving the ob-jectives of the program, rather than breaching them himself. On page h(I make e)\mention
\L&ff -
of another meeting.on March 4th concerning the containment entry procedure dispute. It was'my impression that Charlie HANSON
ki $> s. A argin of each page, I swear that the foregoing statement is true and correct. ' Igned on (> > ". le /983 at n.'3M A A4 . . r
~ '
SIGNATURE: ; d-
- i. ..
' RICHARD, 73. * .. D. . . PARKS /.
- t- .
. r.. - . .
3
,19 h ,
- Subscribed and sworn to before me this d day of - J LJ g' at f f.12 A Ae~1-M"Tb C O, f4 . ; ..
. . - ..-..y.,... . . . . . , . . . . .. . . . .
- .e .
~
f IWESTIGATOR: WE:-]7,3 g,,,a 4, y[g} ,3 _ WITNESS: .
..- NAbiE:
Title:
3 . . 4' .. e .. .. . .. , . . g;;;. - . .g-
~ .p .. . .
s..: e r m..........-
. c. . .
4 .
# M t
4
.O 9
Exhibit 27 nrsNbpomen.1$- lCATION DJ3l *$- '@Yf" . gg,Jd2 IN
.Page 1 of 10 Place: 3 FvCE5DA Mb Dates ~1~ S t,5 to13 I, R CEuD D. PAP.LS , hereby make the f ollowing volunta.ry statenant to Invertigaters J. Verse and R. Meeks, who have identified the=selves as Investiga:crw with the U.S. Nu: lear Regulatery Cc=-ission. At the roquest of Investigators Verse and Meeks, I a= suh=itting separate stacaments f:: dis:inct aspects of their investigation. This statemen: '
concerns hars.ssment-and retaliati== in the TM:-2 cleanup. =ake this staterant freely with no threats'er pre ises having been made to l' m). h& D , IR Yk %P ', . l Cn page S cf cy' affidavit, I state that Tom MO?a:S told Richard SI!GLIT: l :. hat ! should be cou=seled fer my negative c:titude and that SI GLIO: - 1' L- rela *,ed this to myself. Others in Site operatient !SO) who might have M bee.t present when SIIG;;T: relatsd tais were Larry K"'NG, Joe CEWASTIK, j St.cba MARSEALL, Jchn PIERY, Linda NAGLI, Joyce WINGER, and Madan . KAP.R. , A. . I L N Concerning the above r.atect, I am not aware of the ps sonnel procedurs 9 that shocid be used fer cornseling a=p1.cyees en negative attitudes at
.TF.!-2, whether ths'i De 3echtel er G70-N employees. I did not reesive any written menos on the =atter frem Sechtel c: GPU. I do recall that g- en =y last performance evaluation Id K '"LER had given me very good
] retings. This perfcrsance evaluatien was dene around the January /Tehruary s, % time period cf 19?3. I cannot be m=re specific, because .t . K-"'tER did ne :-ive me a ecpy of .he evaluatics. on page 18, I mention that. Larry I NG, en 2/11/23, inf=rmed the Site [' L .Oparations staff individually and generally about the :::ents cf a l l meeting betwee3 K 2G, KANGA, and Id GIO N cn the Polar Crana SIR. i i These SO me=.oers, to the heat cf my racc11ection, were Messrs. CEWASTYK, MARSEAI.L, ?IRRY, .N.TE, KARR, !.,inda NAGLI, and Jcyce KINGIR. In respense
. to a question by Mr. Meeks concerning RARTON's managament style, I i
would describe BAR ON's personality or character as it relates to his
'dnily mode of dein[ husiness as that of an int " dator. SARTON shouts, j usos foul language, and is a brusqua inidividual who ef ten intimidates an empicyee through thrects if that employee does net follow through wi.h -3AR*:'ON's wishes or desires. 'Usually he succeeds in getting his ;
Lway wi.h the a=ployee,, Eowever, S.;J*. TON fol'.cws up his threats against a: a=F.loyee if he thinks it.is. .necessa.ry. SAR**0N doesn': like to leave L .. . . . . . . .. . . . j \
.,~
age : cf 10 ,_ a paper trail. Ofte= when he disagrees wi h a me==, he will write
.~ '.s . -~ =.. . .s c h* c .. .', ' ..'ai me=o a ..' e .~ ~ ~ *. e = .. , .c .' .s a~.~_*. . . .
On{pfge 20,2 mentien my'c:n9ersarien wi_. Id_K ILIR en Februa f 15 regarding R '"LIR 's state =en: that he had been asked by F.ich G.*-s*:.A *"IR to look into transf erring =e off site. He asked me if
- knew what : .
was doing and how big these pe:gle were. I said that I didn't care and would be pre ected by the NR . I was upset and had K "~.IR relea: the c- ent in the Site Operatiens office in fr:nt of 1,arry KING and
. Toe CIWAS YK. Messrs. MARSHAL *,, ?ERRY, SM::E, a=d Secretary cyce hDi IR =ay have everheard pa.rts of the eenversatic: as they arrived fc: work. When T.*"-""4 saw that I was taki=g his c:==ents very serie sly, ho tried to downplay the issue in an attempt to :::1 down the =atter.
It was also K LIR's responsibility to originally bring up the issues , that I had =ade in =y February 17 c =ments c:ncerning the ? lar Crane 7 Lead Test and the ae.rlica ic: of crecedures A? 1043 and A? 1047. _M,u Ichruary 17 c =ments had reflected nega ively en his f ailure te raise the same issues. C= page 23 I discuss the EL:""ARD phone calls to Larry KO:G, Gloria KO"I, [ and Se=jamin SLONI. Upen fur.her reflectien, I believe the calls 7 occurred sc=etime between February 14 and the ti .e *.ar-v KING was ese rted eff-site. SLONI since has told re -**- :--- 2?3 -
- 1 ' ad 'm:
hl= a n"-her of times. 3L ":ARD als: =ade phone calls to R nnie
- .C EA i= Ohio about the same matter. MICIA, at that time, was SLONI's fia=ce. Af ter a c nversation on or around February 23. with SLO I about he EL
- "ARD phene calls, S*ONI had =enti ned to =e that he talked to
.. ~._4 ab ... .. v ..... .n.D. , s c.s e. e .
- n. : 4._4 n g . o .e. ,.,,..e. , R.- r ,,. s.a.e e .a.a. .. .
Sechtel was interested in having Ouilte: censider a censulting centra:: because =f an upe==1.>g reorganization at OMI-2. I advised S*.,0NI ne: to touch that cent.-ac wi-h a sen feet pele.
, On pages 27 and 28, I discuss K NG's suspension fren "'M -2 f or his a.11oged c nfli: cf interest due to his asse:iatien with Ouilte:.
Cencerning Ouil:ee, in the 'uly/Aupus: 1982 time frame id K!- IR asked
=e id venid ta.1% to 1.arry KOiG aho.:: lining up a jcb for T..*- IE wi.n Qu43.e.-. a. .w.e Fu. - - . .N,s e a., .e.t e 2.32.3 e, e,
- ... 4a.a.
. C a., ., e ,a .r e.n...-
. .w
,a
- e. 8 . e.A .u t . . . 0 v..~. .rR a. . eu.e n oa..e
.. e$ es. s. a a.-
.c ..s s .u.a.-ane d me ,
Page 3 cf 10 the matter with K:""".IR f 0= that peint en. Also, d=ing the Only/
'~
August 1952 time frame, Lar- e K3G askef me .t.o l.i.;e up a tv.e. is
- f:
sc=e res=es f : Quilte . ! obtained the ser.-ices of Rose L:0 *I and she typed up various res=es that were generi: in nature. : roca11 that sene of the resu.mes were these of Larry K33, Bill AUST N, Kingsly 3RA?IR, and p=ssibly Ken LYON-AKE:OS. Also during the July / . August 1962 time frame, recall that Rich GALLAGER asked _Me a..- either a5 when K3G was Scing to leave for Quilta=, or if KO;G m Quilte=. . I told GALLAGEIR o ask K NG.* . At the A;:ril 26 congressi:nal hearing, it was stated that F.:. TE 533
} dirst learned of Quilte in Nove=ber 1982. Arcund the Nove=ber/Dece=ber a
y 19S2 ti=e period, I reme=ba: Ben SLCNT. talking to =e ab:ut Joe CHKAS YK's j f.=volve=ent with Larry KING and Cals':"YK's atte=pt to ebrain a position with cuilta=. I knew that CEKAS m atte.def a Quilte: =eeting with K 3G, SLONE, and G10 ia KING at the K3GS' house during this time period. It was also d=ing this " -e frame that CL'ASTYK went to 33cver Valley with John EOAG, a relative of King's and also a me=ber of Quilte:. At 3eaver valley, CHKAS YK contacted Don SK 3MORE of 3 Duquense Light C==pany, the licensee at Beaver Valley, about a Quil:e y proposal and pessible centract at Seaver Valley. Cr n- YK later ::1d
=3 that when 3eaver Valley ca=e th:0 ugh n=ne of us would have to wc::y
( a.bcut the way Bechtel is trying to =cve the schedule ahead anf take over things. The 50 staff was generally aware of Chn'AS YF.'s and K3G's involve =ent with Quiltec. :: was also c=ing this time f s=e that K LIR
=ade a c aent to =e that Larry K3G sh=uld be =areful because it was starting to get around about K3G and Quilte . I told K "'~IR that K3G was not the =ost dis =reet individual about maintaining a low pr: file en the Cuilte: =atter, because he did not believe he had d:ne anything 0
wrong. I believe it is significan that P.:. TEI:5 NG, the head of Recovery Progra=s, chose not to confrent K3G for a= explanati n c to suggest con =se, ling on proper business practices. Instead, he sa: en the ir.f===ation until K 3G ba=ked the 50 staff in challenging Sach el's sh:: =uts en the p:la ::ane progra=, and when KING was s=11difying I
f l - c'ge 4 cf 10 ,_. I his ~ legal resp:nsi.:.lity within the chain =f == c.and. Then ali ef a sudden the issue be arte a major scandal, and si=ultaneously Se:h:e1 attempted to recrni: Kr;G into engaging in serious conflic s of _-_intere st with Cuiltec. Although K3G did not respond to the impr:Per enptation, he was fired anyway.
- n. o. a-.. e3 .,a
. . y 39g3 ,. ...,,. -- . " . a . , _. ".'v.
. .e. .". w. a ...d. .o. .d .' .' n.,s. 2 w. . .
on a skiing ::1p. During the c ngressi:nal hearing en April 26, i: , was s.ated that in Tehruary.TEIISCIG, while en a business ::ip, was told a second time a.bcut K3G's involvement with Cuilte:. Possibly this was he business ::1p that was referenced in the congressional testi= ny. Sc=eti=e during the latter part cf 19 62 or the first part of 19E3, I
; Dick JU33A cf Nine Mile Point, an e=ployee of 3ech el, phoned ! arry
$. K3G and asked hi= sc=e cuestions about Q"#i tec and K3G 's involvemen: g with Ouiltee. I recall, f == conversations wid 1,arry and G1cria 7.3G, that there were two phene calls f == .T.;33A on this matter, the second a ound the time K3G was sus > ended. I was in KOIG's house when the P cacond ph=ne call was received. % : feel that the Quilte =arter displayed a dedle standard and was daf*-'tely blown out cf prepc: icn. In the nuclear energy industry ona is always =indful of the various opportunities available f c: b; o,d sn: ament and p c$1cticn at cther nuclear sites. Only tv: GPU e=ployees inft for Quilte=, Mike EI?.1,IEY and Ted F.ICTIR". Seth Of the= were 1Gaving anyvay, however. Furthed,'they approached Quilte: f: a j b. Jt3G did not re: uit the=. In fact, I a= net aware of any instance where KOiG solicited c tried to " seduce" GPU empicyees to verk fc Quilte=, as claimed by GPU at the A;;il 25 cen; essional hearing. Although a nu=ber of G?U e=;icyees had_resu=es with cuiltec, it was always at their own initiative. F := my cenversariens with the=, ; . k=cw that they were lockine f : icbs at 0:.her firms as well. In ny 54 years exeerience with the c =nercial nuclear industry, nothing
.o: urred with respect to Ouil e: that was inconsistent vich ner=al cractices in the indust.f.
In fact, vas 'first hired by GPU in a manner simila: := how Ouil e: cperates. While I was w:: king f== Inergy Consultants, Inc.,.4y subse-qu:nt a=pisyer NUS sent a propesal that included =y resume to G?**
. .**g
--------._-___.________-__--__J
Sac.e 5 of 10 . without first checking with Inergy 0:nsultants. 20.*3 is a job shopper ci=ilm to Cuilte:. ?C did not conde=n my hiring but has cc de=ned K2iG and 0 il:ec. ,T=th er , : ..- TM: e=pleyees such as CHWASTTK and K:- IR were n : fired c: even efficially disciplined, to =y knowledge, fer their a=:ive efforts to eb:ain business f== Cuiltec. It was d=ing the first part of .~anuary that Id KT- IR old me his transfer to Tierida had been a :anged. KO. .*.IR asked if I would.take cver his p sition as Startup and Test' Manager. I i= mediately talked to Dave Buchannon, who was head cf Design Engineering for G?d, and told him that I would take KI-~IR's jcb only if it were transferred to site de Operations. BUCHANNON sta ed that he didn't know anything about the N K:'":.IR transfer and that he would look into it. K:"~.IR did stay on site. 4 4 However, he was absent f == TM -2 the week after KOiG's suspension.
' Af ter he re =ned I asked
.K T.IR re =ned en c: about March S : S.
Dcve BUCHA'OTON how he got KI" .ER to stay. BUGEAICION stated e.at he verked out a dee.1 with 3ARTON to get K-""IR's per die = taken care cf although it was supposed to have run c=. Dwigh: WA*KIR headed up the Test Wc k G cup -- ene of K ""IR's normal duties -- while KIT
- IR was gone. !
u cN KANGA, in his tes.i==ny before Cengress on April 2&, stated that he firs:
. hcard of KING's i=v01vement with Quiltec on February 24 and that he,
<v D KANGA, was on sick leave that day. KANGA stated that he received a N phene call en the matter while he was at heme. he said the phone call was f: = EAR"'ON, and was made at approximately 6: 00 P.M. to the best of my re:011e.c..tio.n.s I also recal',1however, that Larry K3G told me of a meeting hadA Uith KANGA on-site the same day KANGA supposedly was cick, Tehruary 24, at 1: 00 P.M. The meeting c=nce=ed the centain m pr. e en,_
- e t 't Gntry p:-: edre and was cut ef f f== a fire safety meeting., : :: was
-e trm a.P s d=ing c : s-meeting that K2iG told KANGA that he was legally supposed a -% -1 to be in charge of the TM:-2 cleanup, but that it was apparent TFI:50iG sj,. a .
l 1 wanted to run the show. LARSON, who was head cf licensing, the same day *J J> ;:, I had earlier informed K2iG that he was in che. ge of the recovery . : :- op2:atiens. .A the Februa. y 24 containment entry proced=e meeting, u [
. .[. > ]
KANGA also told K3G that he was t.he boss and this f act was to be put w :
) i.
in writing. This was in reference to K3G being =ade the alte=ste to L i,.- n ** 3 KANGA a.nd thus efficially designating s==eene in upper management who j -- a :. .; n 4. . ) W M 4 P- _________m
A r 1
~ ~
.ageI6 of 10
- met the ANSI standards as plant =anager er alternste plant =anager.
This meeting illustrates how TMI-2 =anagement wa.ited :: use Cuiltec egai=s: K3G until 1. mediately af ter his responsibilities a.nf authority wsre finally clarified. It may also demonstrate that Mr. K70;GA was i 2nss than candid with Congress about the Quiltec matter. On page:21 of =y affidavit I refer to a February 28 meeti'.g. At the . m sting EIISING made a statement that he could understand why certain pt=ple were afraid of a transfer. The c==:nent came about as a result of'our discussion en the NRC ava-#:ing the polar crane issue at that time and Id K.T. IR being called in by NRC and interviewed by Joel WIISI.
-)s- W3 also were talking about Larry K3G's ~ suspension in the same context.
Q Wo were told that the NRC was not finding any prcblems with 9.e polar J , crane. TEIIS3G's remark about a transfer, which I falt was obviously directed at me, was a result cf ec=ments en these t= pies. on page 32 I began a series of ec=ments on me=cs that Joe CHWASTYK and b, ' I wrote., basically concerning the application of AP 1043 and AP 1047
- o the Polar Crane Lead Test. chm STYK was in full philosophical y agrrament with these me=cs. I feel that CHWAS*"YK believed he was only V going to be Acting Site Operations Director for a sher time. In a M maating with the SG staff right after he assmed the acting positien, D.s , CESTYK predicted that the K3G incident would be ever and K3G would k b3 back on the job the next week. ,
In fact, en one occasien.during that time ! showed CHWASTYK some meeting minutes and said it was chvious that the pelar crane was not ready. CEWASTYK said I should get the inf===ation to Larry K3G. Ecwever, after a few weeks I got the i=pression that CHWASTYK's opinion of what would happen in the K3G matter had changad. I also believe that CEWASTYK, as he attended the various recove.-y meetings,
. realized that K3G was not going to return and that =anagement c=nsidered me as as chstacle the same as K3G had been. I believe that Cn*ASTYK kssw that =y wife was dead as did most of the 50 staff, because had-niver =ade a secret of that tragedy. When Chn'ASTYK made his phone ec11.to Gloria K3G a=d stated that =y wife was trying to dig up something on'the child custody case, I feel it was En%STYK's indiree way cf trying to tell me that I was. targeted.as K'.NG had been.
.nw
/cge 7.cf 10 I believe that CE G STYK was replaced with 3ARTON as Ac.ing Site Operations Directer becanss G?U investigators en the KING =atter hed spoken with ChGS'"E and discussed his involvement with QU- "IO.
After one such meeting, CEiaSTYK told me that he had.iust attended ene
.~~em,s u cf his last meetings at TMI-2. There was ne_~;; --; ':=f_ disciplinary nction taken against CHWASTYK fo: his activities on behalf cf Quiltec,. .
however. Instead, there was a more subtle respense such as making his. Acting 50 Director s'atus temporary. .I also understand thar during . this time period CTGSTYK was taken of f a TV cocnercial that GPU was
.tc air.
i} Cs page 33 I mention that 3ARTON accused Joyce WINGER of xeroxing and i taking to Larry K3G a memcrandum that had been =issing on February 28 but had reappeared the scrning of March 1. The memo in question was ths so-called "Sm king Gun' Memo" that KING had written to KANGA and g BARTONabout his concerns on the' lack of an Integrated Head Lift Schedule cnd failure to meet previous ce=mitmests. I eh N the me=o = unbar was around 069, but I am not sure of this. I recall that on Menday m=rning-Fchruarf 22, Joyce WINGER had made the cc= ment to the SO staff in general g
.1 that the memo was =issing from the file and that she was 1 coking for it.
M Sh3 also said that KING wanted his copy of the memo. On Tuesday ' h . morning, the memo appeared back in the file. g
~
On page 45 : explained that on March 10 I had a discussien with Carl ERBAC, Ed GISCm and another member cf Plant Engineering concerning th3 fact t. hat ARNCLD had asked Larry KING about my involvement with l Quiltac. I believe that the other me=ber cf plant Engineering was Jim EINDERSON. On page 46 I mention a 1:30 meeting that I had with Joe CEnSTYK on Mar =h 10, 1983. That meeting was held in CEWAS*YK's office and the only other person that heard part of the ccaversation was Ch"ASTYK's cocrataryr Bennie SEERWOO3. CEnS~YK starred this conversation as
~
we we.m walking into his office. Bennie was sit.ing right there and may have overheard the firs. part of the conversation before CEIGS~YK closed the doc to his office.
-------__--_______-______w
y I l age-8'cf 10.- , , , _ - - t -
. I also recall that en the 'same day CEESTYK had previcusly held a mes.i=g with the Site Opacations supervisors. In that meeting CHnSTYT. .
stated that semebody had been co:. unicating to NRC on a' daily basis. CZES""YK reminded us that we should be mindful of the story cf the bey !. who-cried weld. ! l On page 47 I made mentien of Joe CEnSTYK's March 10, 1953 phene ca.11 . l to Gloria KING, when he stated that =y wife was t. ying to dig up sera n3gative information for the child custody case. After I was put en ! leave of absence, I remember talking to CERS"YK by phone.- I teld ' 3 him Shat I had interpreted this statement to G1cria KING as a friendly j war 3 g to me. At the time, CRE STYK did not disagree. C'EWAS*YK had l . criginally called G1cria and asked her about leaks to the press. The ,. l- ~ press' leaks were in reference to an article in the Washincton Post, by Susa.n STRANAEAN, en the G70-Babcock and Wilecx trial.- The art.icle
- 4.
appeared on. Tehruary 13, less than two weth.s before T arry KING was 9 .2spended.
.On page 49 I discussed =y March 15 meeting with Messrs. SANTO M ,
WEIM, and ECTTMAN. I did not observe any notes being taken l ,
!y ;during that meeting. However, Mr. HOTTMAN was sitting behind-me and
, s. When I a :ived m% .'it was possible that he teck notes during this meeting. i
,- der the meeting that ec nine. Mr. SANTORD a.shed me when' I had arrived in i 5 . 'Gaithersburg, whether I had 'left Gaithersburg the night before c: that i
mer ' g, and what time I had left. On page 50 I made mentien of the break-in of my apartment which - I discovered aro_un.d .7: 30 A.M. on Wednesday, March 16, the first time I
. . . {
"fo.tsfned to =y'apartrant a.fter'th.e meeting with
.k. . SANTCRD. I had last
.. ladt the a;:artment on Monday evening, March 4, around 9:00 P.M. hTnen I I returned I noticed that the deadbolt lock en the front doc: was open, c1the:gh I always keep it locked.
- hat
- be hev * '-* L--m e m-n lefh
. .Th3y came in through the patio door, which was still 1.5 inches open.
Th:a lock had been ta= cered with; the marks were still visible. 'I checked and saw that my tax papers'had been g=ne through and restacked neatly in l
nye 9 cf 10 - the wrong order. Scme backgr und infc =ation about the G:vernman: Accountabili y Project had been lying en the ecffee table and aise had been reshuffled. I reper ed this lurela_-v investica.icn to the Middletown police. To this date, there has been no disposition.
;I also wecid like to point . cut that on M=nday af terncen, March 14, I was cleaning out my desk as werk. Subba MARSEA* L , /*in TI,0YD , and .
Jo2 C~ WAITE, as well as Bennie, the tenporary secre;tary, were gresent at the time. Earlier in the day'I had asked CEWASTYK if I could use the Site operations staff := go through wc k documents on the head lif t and show the hours expended by 50. I wanted to research how 'the conflicting head lift and polar erane schedules affected the efficiency I and : effectiveness of 50 wc k, which I believe had suffered because cf M th3 conflicti=g schedules. CEWAST E told me that a task fc ce was a d gcing to come up with a total integrated schedule and that the work
\ would nc be - needed. 4 s
on page 52 I made mestien of a 1: 00 p.m. meeting on March 17 with KANGA andCE*aSTYKconcern5.ngmyramovalastheprimarySiteoperations me=ber en the Test Work Group (-WG) for the polar crane project. I will d add that earlier that day I had met with CEWASTYK on the same subjec . CEWASTYK since has told my a . rney that at the time I agreed with G and welcomed the decision, because I had become too persona.11y involved
= N with and emotional about the pelar crane.: I can state without quastion that.I did not express any such agreement. Indeed, I was
- =' eady preparing a complain. fer the Department of I,ab5 challenging
~
th3 last time my duties had been removed like that. -- en February 23 with the alternate startup and tes superviser position. Further, I' co=plained to Bubba MARS!.ALL that same day about "what had happened with the TWG. With respect to KANGA asking me twi a at the Ma55h,17 nee-iing to agres
'thts my removal was not an act o' d~d "ation, I will add that af ter I refused the secend ti=e t= sav what he wanted, KANGA had CEWASTYK 4
sign en-the spot the memo authorizing =y removal. .
"b "Il>w Lm3 fGat.Iw dqly 2.11gkME m ._a p., - w 3 yg"[
A . k g a e %. l i A sude d ** 6f.. Mi- ***"'
- 5" F.c L
l l t l-1
j
/
iga 10 cf 10 , nave reac .ne teregerng statemen: cens:.s.:ne c: 13 typed pages.
- _ . .
have .ade a ' d d-d aled any necessary cc:recisens and have ss.gned
=y name in ink en the maryin of ea:h page. I swear that the feregeing statemen: is : ue and es rect, te the best cf my knowledge and belief. ,
Signed en dh M t* SS at 'oth c^ ~Mb . s SIGNATUF.I: .s 1 m _ O I.h . N . C . - F.!C'-iAF.D O . PAP.KS l . r ~I 5::bscribed and swe:n t5 befere .e this 05Y day of J%v l , at brTucsSA M f3 .
"N*CsTIGATOR: 1- M/
N A='*; do ua ru oc . M TE"KS w: u ss': .
,r eb,M) . Name'A.n t u. G=xu g
Title:
E4tet tsA::.TC2.E4Gl4E12,G J e-Gudh J
.. , d
e b PtfS Al0f ** EyH\B\T
~ D T\nCM\0N r -- f0R s - c , JENNYSg g ,yy.
19 p
' ~~~,
4 arsea s Page 1 cf 2 W\T; Flace: l h.
"T. , l . , *f- C Date: . ! ?3
., r...:.r.-p
. r. .r.z hereby man.e une ,o.3.ow
. a. ng ve .un ary s:a:emen:
to Investigat:rs J. Verse and R. Meeks, who have identifief themselves
- me as Investigators with the U.S. Nuclear Pegula:Ory Cc 'ssion.
A: the reques: cf Investigators Verse and Meeks I am submitting separate statements for the distine: aspects of their .investiga:icn. This s:stement concerns missing records for werk pending at .he time of tho ""C-2 accident, and failure to maidtain ne:essary co.trols fer p st-seeident modifications through 19 80. I ma.ke this statement freely with no hrea s er premises having been made to me.
;w.: . 2. V l
The* management statements about controls for the cleanup are compromised j by missing records. To illustrate, on page four of my second affidavi
~
,. I str.te that Mr. FI;GA, at a press conference, asserted that the polar
.e 't
; crane originally had been lead tested to 500 tons. Based on c.;.n..v.e..rs..a g c,tio..ns s
.s\ that I have had with those associated with the pre-coeration : tests ^and -
4s the fact that I could not find any documents in the pre-operation Y. 4 Icad test for the polar crane, I disagree with TR;G;s's assertion that i
' tha c.olar crane had originally. been lead tested. In fact, when.the
^
a. Site operati:ns staff was doing research work on the taped drains, , raferred to in Mr. GISC:iEL'S affidavit, we fcund that manv . of the .E i E. s criginals on the cre-operation test ereced= es for TMI-I were rd.ssing. e g - It is my understanding that these procedures should be kep in fireproef vaults. I am talking about app;cximately fcur years worth cf records such as procedures and test docu=ents that could not. be fennd. Also missing was the master punch list for open' items on the pre-operation tests. The punch list identified all the remaining items that still nacded to be finished er resolved after the plan: began eperations. Since there already has been ene accident, I think it is i= perative
- ::ack down the res: Of the dermant problems. It is my understanding j tha: the master punch lis is required to be kept en site for five years.
I believe that the polar ::ane is c::ly one example of a fundamental breakdown in :cntrols en modifications to equipment and c:mp:nents id
- .e TMI-2 cleanup. Fcr example, arou.id November 1980 the startup and test group began research for the startup and tes: program, i
._m______
.)
,~
~ " '
ge 2 ef 21
- During the'proje=t we reviewed'approximately-130 jcb tasks that
~
invelved s=me 1700; modifications significant enough to be formally processed through Engineering Change Modification (ICM)-fer=s.
'~ess.than a dozen of these ECM's had the required test data, or qua:.ity
' assurance records. These fundamental safeguards had been skipped.
Scue of the changes were. Petty. Seme, however, involved significant systa=s in the plant, such as modifications to the decay heat removal n system, low-level waste processing syster., ventilation system, y radiation detection equipment, and waste storage facilities. cf ide ib.L ky u J .2" 4f
]= -44e wanted to i= mediately set up a full testing progra=, but Mr. 3AFOO:s d i
.. informed us of a management decision with NRC approval shortly after N the accident to forego cuality ~
-assurance for modifications. Enile N the decision may.have been justified during the emergency, there was
( -no reason to make it a routine. We invited the NRC to check the test In 1981 a test
. records, but they.did not respond to the invitation. ..
program was established, but it only covered modifications after the approval date of the program. The modifications made prior to the w
; date of'the test program were categorized and turned over without any 3 tasts being peric.med,'to the best of =y knowledge.
N I have read the foregoing statemen: censisting of.two typed pages. I have made and initialed any necessary corrections and have signed my name in , ink in the: margin of each page. I swear that the for,egoing statement is true and correct, to the best of mv knowledge and belief. R $5 Signed en \ d, ?5 t at 7 6 6 da kA d . .
- .O I SIGNATURE: < Cw.,,, .
RICHARD D. PARK 5 l - i
-I , 1923,,
Subscribed and sworn to before me this F n. day of Juiv - I a: :r w c s e.o . A40 . l IrJESTIGATOR: __ .d /// - --- J Name: % ,,,u n A. M grk: - WI""l35 5: If . _) _ sa=e _ L Titie: 5,E ;e4. f. :.f se,w EEE,crE I 1 < l l 4 j, l
7- .
. . _ - . . --- ~
,? *'c, p UNITEO STATES m,
!*,* t . CLEAR REGULATORY COMMI5'ilC A- 3- I wassiscTou. o. c. rossa "
*sA>~ '
% . ,'. . ** $4 ! y 6: N3 Ww bb qpa b (si V_g%
Wq ^ WJA 3 (2 W b . P b M 3 A rm , 2
& . ~ ) W .i J -Y-Q magk sl S JQ
,. > :2 m- -
Au- a y @ o_i ~ h eb te . 1 a me a%s \ t t PLrSW oerrs envoa Y/ , FOR JDENTlflCATION PENNYSANDER, .P.
/
wm s,. s i- 2e 19N
, ~ , - ,
h ( .. n. W^ ' rev - a FOR IDENTlflCAil0N WIT:_/ /* 0 // v0 1 1 P i l l l l
,w,
rIsijst. -
'rb A* CA^** hm.s O -ave a. ~ f*
Ca.d' U Tiao Gnw.buE\ .... L 4.ka.u._q_ 'd *tA A6stsact-c n tss o h t.) A h,$.6_ah.d I ~ N. ug J .s.%.a g s.t. 1
.-_ _. LT.. _14_ .s.i...._u. _t..
l Me._ (2 4._ _' s e n_._d._ _ R_ _. 9 m._.._"._.1_=_.___.... _ %_.. _ { 3M, p ' %._+. __- ________A_4 7
- t. a l. *4- 9 / m. .e..
.. z . _.
.- i..f1,e.l 2... .._I.b. .( A st_. _.C.JC.A4.5. . __5" a_A*G. .SM_
_. _. . - . . _ M._ ._ . s ._ # St_u s. ._D___F..o..lt_...US.E. . . . _ _ _ . _ __ ___ (
.._ __t . ..m t. - M H eb N_o __ A.fp4,v.n.L. c.yt.fs___u__sesm sD F. ost __G_.f_u . b..w a d 4,f a_s wd av.de ums ~4 c.kht. .
g ) 1 . w. .. n. e_.w_.w. w F.b . c.veu.5(ed.lv t_a+ ep gus- is /Tutterr cs- AP fo't.1 - acustersm 3 . me.cer%. ._wc - ransaiaa, _AP Too
.. __. . -. . . . . 9 , i .'. n.. _ _ ce. _. v.. .e.r_s.__u.. _psw._.
r %. . _ .s. .o. ..r.e._ir...ea_ c.T. m. _ .__(c.o .
... . ... . -- _ __._ C.a n d. M.,b b.sp % M h .i" . M..... .. f ta . P.f.. w .
. - Does Me ew=. l
. . . . . _ . . . . . . _ ._.___ __ _ fa#U ..'.r.u Ced ' . #a a .4. g ..
. . g4,,, ,,.. PJ s . A.. f 3
%pMh .._W APO ^^= O !.~.I*t Y *- ? W * '- y ts 3 A.s a.. 4.. .. 4... .. A _u er. _.
. - - . .t._. .
4 _. _._.. . . . . . . _ . . . . . _ _ - . . -_G. f. u. . ..-3. %.. . .P.-._s.{._1. "3.._.f cr4
-- - - - ca. l o F sne.f.t.k. ss P. a. s. _ea.nore. St.=ph. .
.._. t.k. '.. Ce_ ..d_.e. sue.d . M
. . _ =-
oua 2.
'Pst.a.c tre_oe F*t _co. m_rn_e.t. a d__.d.o c.umseT. a'.n 4
. . e.F._ t.o. e.a.n.r f.44.r.estas ab..
Com B..."l5TEve7tM
. . . . . . ... .. . _ . . . . . . - . (ATid. ..e. ta4T' _ _ - - _'2 [ d ?_ -. . E. . J T Jdk
- n. ., t
. .N. k '
. - - - . ~ . . . ~ ~ * .. - .-. - -*. *
.. . . __. . . . . . , . , . _ . - ..- q . .m,
.r. . . .. . e. 3.h. G. ."-
M. *
. .....e
.. .. -. a ....c - w _..:.. ._2.. .E g3 y geo -ss-of t.5 r a c T. RWesssL c.Aub#A e/.mim .
To Bki - 3e x Ne w 065s . ( AtAc.L. 4.( l
. l i 1
____. .._1 f2nl __3 0._M $4 ta= -U.-nt '4 Fr.* = _D_ef. Direi.Te A_ uit pmi _ St.T). 66 piewww_ u.E. . I _ _ . . . T o *A. St.sitil so - (t am_. rim .e , s. e. D - rb+ Pk. Be l n_p
~ . . . ..
1 _ . . . _ . . . . . . . . . __.__. __Th.....Bes.k.TW _Lwtsoat a _gd _;6.e_._.wf.o _,
)
4 l W $4 h . . N i
. . _ _ . . . _ . e.k. u i. _A 1e._c_FA_. C. .o
.. (.e.M f.
. .a ,r.s. j i
1
.g..___.- .. ._. .
]
, 1 1 1.
. F.%_ _.. 3'.o.M____tf t.s.e. % 3_-o(e'.t _.F. 8f.ch sit. r e.M. .. A A_T_aws Dieu..N..n ts I
_ _ - . . _ . . . . . . . . _ . . _ _ .._ _ 5 k. E 4 4. ..l. M 4. _A N _
.
- Ca_d.f.JiAns .39cA M. .. 1 l
.. -.. _._ _ _ _ __ . LS*T_'__sc. \\_E_ b_.o_lt " _y__.e. s.s4.5 es. Fe N. tu..t .(.w u_**8 i l
J
.. .. _ j). .L.A.O. c._._o. .F. _._r.4.T.s. .t.t. A. T. 1b_w.Mbu. 4_ _ - - .
)
l l
- .. . . . . . _ _ ... Q . Li.p.k. .
- 68. .. 2#twa.aT .to.. p.. e_F.._ Te..lML_W4. soi4As. . . _. .
. . . __ _. _ . . __ . _M. e O_.L.t.FT._. S. c.k, mal. e te. ..a.
.. . _ . _ . .s . . _ . _ . _ . _ . _ . _ _ .
. .. .. .....__..__. _.._. ..(1).. c.d.A.ss E . w.\1.. M. .. .._W. . _M_M. _A_. .. \_ fb.\t. ...Ps p .. .
E..s.t_hT_i a.*- .. _jb. eb_d.u.\.< __T9_.1.r.arean. n. .
. ..f A. b_% . _ _ .
. _ _ .. ... . . _ _ _ . - . . _ . o. . c. . .w. ..w.k. Sk. d. . M . . . . . .
=h '8' .EQ0E@ Ih. .R'Sk.** OP 6N *E DNA N n eed \M M_,t_s_.
. T. t.4_%. . _ . .AM.. .%.T_~ _~2. -. .
l
- * = * . . . _ . . ...... .. . . _ ... . . . _ . - . _ . _ _ . . _ . ~ . _ . . . . . .
"- *= ~ ~.... _ . . . . _ . . . . . . . . . . . . . . . . . .... . . . _ -... . _ .... .
-- g. -----7 m.._. N ..
* *9
.. ; ; -4.'.:n ;
r .g t ' 0?T L
'; -c
~f PLPS%
DEFTS EXHiiliT rMI, "Tke ~Be.cRTbL CoudecTioo FOR IDENERCADON PENNY SA N.P. wm inwo n ' n }p s s ert.in e. Gro su m Ancess. ATruxpr Ta pe,os Ta Th.
.), Tim, tu. t2 AT w+1 toans c.~peTkaT <= o3k To tinecT l e c i.ao ue $c ~nis* # T"I-2. , ===T.Ture. Auerd==. .*
Med C
- asec6 7ECRIeAMl?.ATI4M3."Tk83 Temet.AnatzATeco h 5cfftb o +ke. "PlactuguT # 3. IC. bu&A AS 8G " Dites.TD R. eE or t. . T a is i. sTin A. p. u . tie s a,c.m e n . * +k e. y=T p vte toaneA.. imed66- Ao coo (4 GPo Tuca eosn. Mae is.a.n. slip er cet en Theim. Neel.Ae "PfadTh To Au Mplagu or AmerHER coa.p Avy ? Tka cia crea. ee entr- 2. is .
w.so so.+k +Ls enmew Ft.uat p*L op. coatuxtis ter % cc.i tiene, mmaE A8PtCD c4 t!eAuof A C 9iTies ow. T kE Zst.uTa . ET W@ht '7"*kkI* T k'T T b '" D'"'E " I ***IA " *N D'**'*" **
~
on.ars kr L.y te.o ta expedw The. c\emop AcT.vms> *i.oh.<A .e.oll dieu.+ly stor.s The p..G.T mats % b M.THen. Maug. Ira Tyra en e. sgtA*. M&1 Adim teua.a.s,+ hut 1,ud Etc.MTbh c.has.j es To GPU son.s Qr(d g a+ ret. 4!tSEk. 4-Lss ca.\eedse pt rs i n u u (. C s in. = t ou s . T L .2, rigom h. p 4o sxActf ec4e. w A +\t Fowing Aased p ovsat e b g + kt. h p mTMe d C Ecs%3 (. I uno R he. m iub ek.c+. 3 -Ass p.id +ka.+- 4c. s4=Jr h sL.S as s sgg t pr ,, J.s to.+k. h.Awt to
== b pnesagt v.ets.). A- m. -
L- p-,r A3yke. outta' Ftaa t.c E. h % tute.wwsd So AAS BecMTM.s hie
.m ou si 2. A<.TWsTi es . IT skooid 6. m .oo A.!se +6+.
mo rt. yo Fuuoinq p% .( h boE , Sec.Hwl's F.cle d 5 end Aa4b bimin i3 gia ic pggT g,c,gTEL ubPit, TRAuSFE4.2.tg ua~=L**_ _ - - _ _ _ _ W ,un _ - _ _ - _ _ _ - _ _ - _ - _ _c.s.,s..,,. _ _ _ _ - _ _ o., _ .% , . - ~ ,.,,..i. e -
.., . l s
i
- t T4s gos Tico %sAts Askiac As The. Founiac steg +ke Dor.
C:>JTtMGr&AIT cfM 'Itc.14TEL 3EC.etveg Nt M0A.sfy 3 '
- e. c ac.a. The .Bec.*Tet ca.GAustaTi.o w as, Fig u l y ranremedsD ta *T%s 'DstasTbt.sLif , GP ) {smo Bes>Tel) MmytMgdt'becib6b L
To TcTall i ?.eFut.llliiemNinTha %IAR CLAME (This cewt-is sees tec no AT The inp ordThe cosrheuununr w lbQ TWe. ' Deos..o t.o es, m a o a i n La.T BecMThL HAos TOTAL outR AoTheR,Yy T bt .:> pe.3=+. L Tka peecua, Tke r hAVE AbD&D dN6R.
%o b u . h T a t e q le j u e 3. Th owiT 1, in-Sole FoucTio44 t s To g couTR.* L R aA c hR. Duilo144 E4 Tit.p a.d teart. k.
petkerresb les ios. The BuilDiuG Tr slood be A.1oTeb rk.T. Ex5TA pa. ion. To Amb Ste:cs The Act.its3T culy TkE Sbs9.T Nrt.e.MA4 (saiTA h5sisTAuce Phm A "3 l i s '12squittog To Supsw. visa Aun coavruat i.csek. tu Am.sAs t.chw.t. rke. 'R*be*Tw/ceAfrAmeT,ee levels 1ke,a pas'ios cadr sumaaT. Ace A$r AAi{ kks.a a A pnm.a enci[/s oF EFFttit.u7 u M oF Foubiam. Tkg Asi,mes.k op. The. 'PokR c.e.* *s is osc.a.sena.g ro Mt.w 7ke cenass % de ueys. rke Mswis 5%e10.5 (. LAs44 A-k ,~ escess op 3Ts stMss m,$ m3
'4eTba)s To G Ai a mer.a s s T e>
Aub "R.Enous Tk.e 'P-s 4.cTert.
\)e%sL MEAb. b MW NA%@**EN N
- _ -
gr. Mm@~Mege_t : p- 3 T% AAve 6ese se.e. a s q Quesrie,os 'hisd we Tks. b 3kr.+T levei oF mAnAisms4r AT TMI. 2 A8L contecamJrj teT4 Yke t. cert.k. put.cca.mte oM Aud TAs tuTE^abeb MsTaoD op i.JN.it. q 4 h e. Pol A t. Cle.AA)G.. 'To DATE Thett gunbms REMMM iguosv_n iq Mqsunar se They cne ceyly cor+4 e4-
.i 3 .
5 <.k.J ols. To itswos %e. ta=amm. vtssat He4b (sTsu sck.Julab r.at. 4% avm 44.ch h MA46tt su s*F heu A4uoouctb To Tkt 1 pa.1o 7 .T L As 1tamentson laOEls man. u, sit \ pm. t. l.lg b< Tb hsy Tb Altmo Tbss As plaua=D) - Amr+kst so-f le- oF ' espic J. %4aaT. . MutA$ig A. Ge4=0cAub pla sf ic Tkt. eps op Th e u: ort.lo Mr %e. eKpses. op. Comynomisq
+La. Ant +k a, d sa% es. 4ke. G==~l Puble .
tTs ist.s ,ie tw, ikwk. rk*T II,sc.km. kes, spe T mer ourel.b toOMts tm teFothe,k a pecs op sooymsJr,:qds: A D ja?r CAusdT in Thu, dade pe.ece Tk*T tok+T -disy heue toaee A=3 A4t4 iaWautg "tta 1:e is S APER . 4 The The tua.y Gro 56 thq Mae "Gaspoomf.Ia . .1B,y Tom,oq ouGR. TLe hys T b T M 3.- t. A A: @ tajemsos Amy cowes. ems E coE4 k tas "el>Ec.4TsrL. "Oona, "%us.sEtwas . IT A *e, 'B s.a a pasT, obTsb (*wb % ate cAmaa h oispwe2
-T-h*T The "R.aAcTea.1bodD9 Su y MAj CouT4 so EMos3 k Fuel To ao c.ameAL , {G"T" "anCATE L (.Ger'WDW"T LCAu'IED Ten ePEA.s M\ f%vR. 13 con b Tb ThE iPtActeit. bdD9 To M*M
- IT E A55tR r-on. w.ew . min _ p m.a Te, p= Tkss Te kappse ux.s To um.k.s ir A pocanoa.AL ~R.aqota.E MEdT 7c, womesa:: mT' A\\ esc
+b. sump 4. qo c.nmc*t. us A & wn.s oPeu , GPO 6 f%neaeb Tkash usn Niet. h vesi- g Aub h ss ,,. a psikts Fa M\ Foot. cl.a e t.s - h a b e. opee).LET-Ob *pam.v +kaT. Somp cai4ecaA.Ty uecer occ.ucs , F=+t. The- Sake oF EksTEo] 'Pte45elvAuiA
% +sa3'cSoghtm A +=nv. rw i,e=3Frub 4he. Ide.dth oF M4. ' D AJ N L Ree MysTsu.t) Med +kasfod +Leist. , Race.d (o,e.t fi+plim wd4.
k 4 . G Pe .. IT . ons The. Coat.utio - ew hto
-A=+ 4ts M4a ,
op Th< c,tos.EED ec. Stegiq Rau;ttet. coolnAir Ray twe.iq 4ke. o.cr.id4e4. a.d nos sig le.bdly ca.usso Moe.s b Amga Te rb. c rt.e Thad Ad'/ o +E8 't. 69)E Ac.Tiou TAkse by M>7oot A ceu se op -dv. AccideM. dAaca gAiw Gfu Do s.ine) Demoon,T+Ts0 Theta- Cyakdh M MAnAgqE A ModsA A bt-
'PIwr ' " dus, 44 <. n u r ecc. J R a p erAr,.a
-*-Lt s tAJdividoI wa. M +he. Meunget. op. Tlv Safeh
~12evica Gri.oy (ct gstay 4tskaD whl Me bsyiL.% op ,
~i2s.mq
- b Apprievg All A,cT. ivmss AT TMI-2. 44 C.ould g j aapra.ba t.s AjoclaAs. Sareg eR Compacats6
+le Sa. % Aub MA LT4 oF %e %blic . IT~ 5611. Ist p m4.d co+ -k4 ets tudsvsdod he, R.anciael. et.at .d esetsven en aus oise. ossa.e , 4ts $ t+d , oF Ceon.5E ht. Fouub
~
4o (w.oWem tn tbbe S4egiq Ot. feas.4en.CooIM M sP eMert.
~12e. nt $ The er has bejk ruvest 4e.of<=deu er Th cwra t s. duou. de accil rf,4L,y:rg5 a: s +J i.5ct-hedel+ e7 +ke. Couvt4n.k s mes4. Rs.ced- Albnq GaaenAL . 64e' met 44at AO: t d 4d' an ,
(tok.3 Fett Wme b pen Me bbe
.cw.a\bGaams.46% Q smd +hy Ap hok.i3 su 44. OmhA hm. .A 54e.4 lookig is
& tven.y Tehs op GPO MMMe.Med) a. $ Roop oF ;
individuals i.eko's Acous ousa Tkt p ct s i. E rt. ge ,c.s h a v t. p,wv.o +La- A* d,J4 ko.ve ccmc==.es wi+k d nuo kuD s e.s 0 ie s;ri A L>re-ThasATe. dry Merincs Tc) Mylvw bo4 Art.e enly C~m_nsD wA WAskinj +Leit. owo HAuDS ] O F +h t. %kott 6 PP AIL. h.Mb EA60tIDf 8GCNI&l FIN 1 l L
8
}l- ptC6 7tofiT.
zus Q +L h ea a s di ,e a s , w , i.o 4rv not a a.ve a,+4aa. pu w + A + c.iram Cwe* Paesine r M.uc .Di<scrett on 7 tut-t.) BacAmg & DisefisAw wilk
.+4<. cla.,vp Ac/,viho A.aa J cA) a.ed saw/ ,4> tookk cu,M Bad rac. Rom n y to nri rt-,a uns x.a 7=ysoma xsou Acid /e*> a esy yar ther in Me-Time Fenne or /19/ is feass a. I us.ucsa in Air.
llusf is Akea ssrbMab s/*w. The p,,ul</rrn of + bis feitexaf stent Slovl/ aerse f.o //none A.up CoruD rfe da'nneuox /f A Comerisse do wves/ym'E -fle 6/CENds ZKf.es9ssO t.o S$/s, Aefre/c ,4f7E4' All' leu.! Cek/Al Ste. e; pee /e .do be fee /e:/ud in d>.e sit ,qqpn swuilolafed becauss FacHrei auxTs , i k f noA~i7~ p a b G/t) is ,l e. Lus,y 4044u.ns$rxj k be Ceccars/sc. i ATixlinanr s I /.swsg gygiffwg DCE,l,vec A%E w fuubwG, ! Arruk unr
- t T s a m a s / / w p a p e r w a ,y N3Jea. rism s,rpsers D Zwane.u 4nts en che w se.leJ le w ind h < w ns uss,. es man. Almr. came esas in c .y lereo rub 3 .
?. s e'* " , w . w e u . . .
CT U Newl\tsT TAsir. Q S q Amonftm . an.a -.. m um. i4.s,y,a so g cen.ca n c~c..os *, I a, t.,ow e, $. wn.wp Au.ioeur wkde oswc, 7ela.t. Ct.Anf 4opfose2>I bes4ED 3 SAFE 3y &Iw2E4EJ Am'**J *" Levu. mm uar Attowiu$ Ait ha b4,=. his im es_ n m __ ___ __--m ~
(a . 14,.a. Gru Mio-Level Aru.LesuT *5 L ett e n. F eu.* Mu$euwT Expanssq c u c. ace we, Yola,e Ca.s u t, b,4 Ac.WIed imj M A*J g endwT. 3 AVNot b $ umstet CocCIWtME 1 i
A% ar.u'T +I Inter Offlee Memorandum
=mi:" EI3 Nuclear .
Sutect DOE TUNDDG OF RX SUILDDG FURGE IIFA FIITER CEANCEDUT usapon 1MI*2 Licensing To M. K. Fastor At the present time we plan to change out the profilters on the Rx Building purge as soon as possible andTha the Decon Experiment. thegrafilter IEFA filters following( repisceaants of these IEFA filters by March 1, 1982).is loaded loaded to 60-80 mR/hr. l NRC (Dr. R. Belissy) had previously indicated an interest in funding all or part of the REFA filter removal and replacement la exchangeBovever. NRC for being allowed to azamine the filters.some roadblocks iiisin getting funds time considerations, we pursue the potential of funding these act v t e by DOE. Dr. Sa11asy has discussed this with J. Riley of DOE and he would be vary Please interested in funding both the pre and REPA filter activities.Because of contact DOE and pursue their funding these activities. timing considerations. this should be dona as soon as possible. Information on anticipated schedule can be provided by Norganisation organization, Please call if you have any further information on the filter loading. questicas.
".e A
l l
TECHNf:AL PLANNING . MEETING MINUTES: (
Participants:
Conference Note No.: CON /T-001 Technten1 Plan _ninc Date: January S.1983 R. S. Daniels Location: TMI-2 Administration Buildi J. C. DeVine Toom 201 G. R. Eidan M T-V. R. Fricke R. L. Gardner . G. R. Skil kan Site Operations K. J. Hofstetter Radiologi:P1 Controls P.1. Ruhter H. K. Feterson EG&G N. W. Spang Recovery Programs W. E. Austin J. Eoldt W. J. Engel T. Fritz C. M. Hansen W. Hopkins C. W. Hultnan R. P. Het2ger N. Osgcod C. L. Reid J. Rodabaugh Sl'BJECT: Underhead Radiation Conditions FURPOSE: To review the results of the Quick Seen measurements, the analytical work done to assess likely dose levels, and the leadscrew examination data, in order to detennine the necessary changes in plans for Underhead Characterization and head lift. _- - -._-___--___-m__
CON /T-001 Conference Note No.: , Techn'ical Planning January 5. 1983 Page-2 1 5 . i [ DISCUSSION _: .. The Quick Scan measurements provided peak A quick readingsf analytical
- 1. radiation in water, under the reactor head. (Ref.1) !
i effort was mounted, to infer the likely source distributionl , could account for the observed dose profile people would have to work during head lift. 2. Mancy Osgood Shesunnarized the analyses indicated the observed performed dose profiles could beby D 4 in Gaithersbu . accounted for y a cmbination of 4 uC1/cc of Cesi l This results 8 ofto25.000 27 uti/to 50.000 uC1/caZ on top of the plenun cover.t a point 5 fe ;
/~ !
indoselevels(unshielded)of1200to4000Rhra above the center of the piens wor. Making different , 1 ilar Henry Peterson described his analysis using !$0$HLD.
- 3. assumptions based on the leadscrew data and fuel comp 00 R/hr to that found in the makeup filters, he estimated 1,000 t dose rate at .the same location, 4.
By comparison.anythedata Head lift Taskusino was ava41ahim, Force basedset a dHferent it rewand ate at' the agw. of
' analysis made befneeiusumptions, that analysis estimated a 40 R/hr location. _
As a result of these analyses it was the consensus to / o .
- 5. the likely dose rate levels when the head is . lifted will b l 5.000 R/hr. which is significantly higher than was p Clear 1v.'u+*a snme- -
present plans to lift the head dry ~-~a+ were aSaae N h.=d developed. chances will need to he made +a +ha. di a t i an 1.v.1, - : take into account these hiah Because of the geometry of the detector andfromsource
- 6. Scan, the detector was reading the sun of all dose contr These include:
many complex sources and surfaces. a. Material deposited on the inside surface of the head Material deposited on Leadscrews
- b. Material deposited on Leadscrew support tubes c.
d. e. Material deposited on control rod guide tube l f. Material deposited on the plenum cover g. Material suspended or dissolved in the water. tota l (items
- 7. The dose Quick Scan measurements can not the hea d l
a b and c above), and which remain behind and are expc is attributable to the sources which is removed (items d, e f and g). t w
4 Technical Planning Conference Note No.: CON /T-001 January 5.1983 Page 3
. t i
how loose _1y adherent the contamination is, merely from the Quick Sean measurements. However, the leadscrew decontamination tests recently
. completed by Ken Hofstetter (Ref. 2) indicate that there is a high probability that the simple underhead flush presently contemplated will not be able to reduce the dose levels by a factor of 30 (or more).
- 8. The provisions of the Technical Plan for " Radiation Characterization ,
Under the Reactor Head" (Ref. 3) were then reviewed item by item, to ] see if they needed to be modified. . The consensus was as follows: J
- a. Radiation measurements, using the water as a differential shield are still necessary to separate the plenum source from the head ;
source. l
- b. Video inspections and sample taking are still necessary to detamine the degree of adherence and composition of loose material, so that the adequacy of flushing provisions can be defined.
- c. The scrape samples on the undersurface of the head should be deleted. because the tool for doing this is not designed, the head surface seems to be quite clean based on dose readings, and any surface contamination is not likely to Le easily _
dislodged based on leadscrew flushing tests.
- d. The choice between pulling a CRDM and cutting a leadscrew ,
support tube should be deleted from the plan. It is preferable to remcVe the CRDM. for the following reasons:
- 1. The support tube cutting tool did not work well when tasted.
- 2. The tube can be cut by plasma arc but this raises too ;
many licensing and safety corcerns to be resolved, so that it could not be available in time.
- 3. The solar crane should become available for limited Veicit lif ts in time to support the underneed char-acterization.
- 4. CRMD's will have to be removed anyway to use an under-head flushing tool.
q l S. CRDM removal allows improved access for inspection devices. ] For example, the Task 8 camera positioner can be used for ) i the video inspection if the CRDM is removed.
- e. A sample of the t.endscrew support tube should be cut from the CRDM that is removed, for radiochemical and metallurgical analysis. l This is in substitution for the scrape sample. !
3 . , s
~
Technical Planning conference Note No.: CON /T-001 January 5.1983 - Page 4 I ACTION ITEMS: A. Analytical
- 1. Model the head structure as a source to determine the dose levels at points near the head after it is mmoved. (H. Peterson action)
- 2. Finalize these preliminary calculations.(W. Hopkins, action)
- 3. Calculate scattered dose off the walls.of the refueling canal, due to plenum source. (W.Hopkinsaction)
- 4. Calculate dose effect of parking leadscrews. (H. Peterson action)
- 5. Prepare a Data report, sissnarizing the assumptions, methods used, and results of the above analyses, to serve as the new design basis for dose rate estimates. (V. Fricke action)
B. Hardware Chances
- 1. Inject decision to pull CRDM instead of cutting leadscrew support tube into head lift /underhead characterization program.
(R. Metzger/C. Hultman action) l
- 2. Change design requirements for Quadrex Flushing tool (C. Reid action Discontinue work on development of scraper tool. (C. Reid action) 3.
C. Procedural Changes
- 1. Issue Rev. 1 of Tech Plan for Radiation Characterization Under the Reactor Head, including the agreed-upon changes. (V. Frieke action)
- 2. Give priority as necessary to be able to remove CROM. (R. Metzger action)
- 3. Select CRDM to be pulled for the Underhead Characterization.
1 (V. Fricke to coordinate with W. Engel .and G. Skillman)
REFERENCES:
4550-82-067, dated 12/17/82
'1. Memo. V. R. Fricke to Distribution.
- 2. Memo. P. E. Ruhter to J. E. Hildebrand, g240-1324. dated 12/22/82
- 3. TP0/TMI-030. Technical Plan, Radiation Characterization Under the Reactor Head. Rev. 0
~
AngW Oy ~ Bechtel Northern Corporation
+
interoffice Memorandum To D. M. 1. eke Oste January it. 1983 Three Mila Island Unit 2 R. L. Rider ,
\ %
Sub g Sechtel Job Fe. 157J7
,3 Boron Dilution of the From of Design Engineering
/ContainmentSusp ;
c p3 Drao-0046 At Gaithersburg . . File: 0290/8420 J l The purpose of this letter is to apprise you of the potential for boros dilution in the containment sump in the seent of a heavy load drop.. l The proposed loaf paths for the movement of heavy loada carry the loads over several syntess, which, if damaged by a load drop, wou3d leak unbor-ated water f.eto the containment sunp causing di3stion of the boron er.ncentsation in the susp. The systems which are currently filled with unborated water include the Desinstalised Vater Systes, the Reactor Building Normal Cooling Water Systes. Reactor Building Fuelear Services Closed Cooling Water System. Reactor Building intermediate closed Cooling Water System and the Fire Service System. The eptions to ritigate leakage of unberated water into the eccesinment sump aver ( o increase the boron concentration in the containment sump so that the boron concentration does not decrease below the present concentration ; j (1700 ppm). o recove the 9mircen of unberated watst. or o drain and cleen the containment susp. I tie recournend that the sources of unberated water be' removed prict to the movement of any heavy loads. However, yeu may utilize any of the above options in order to satisfy operational and time constraints. Be advised that as loss es the question of potential criticality in the containment sump exists, the concern with the parential for boren dilutten in the containment temp will entst and approptista sessures nust be taken. I
F ' l_ _ = , January 12, 1983 ION E9 Mr. Laks DERO.0046 Pcge 2 t It should be noted that the secondary side of the steam generators and [ > feedester piping also contain unborated waters however. Design Engineering ! '_ will determine the disposition of this system prior to the movemout of heavy loads over that system. You are* requested to advise us of how you resolve the probles of potential , bores dilution in the containment sump. This information is requested by February 1, 1983 in order that we can notify the NRC. Should you have any questions, please coatset me. E. L. Rider Manager, Design Engineering
' VA$ dff 0
I
. -~ . . _ _ . . .
= UNIT 83 STafts t 'g NUCLEAR REGULATORY COMMrsslON mammeTon, o. c. neus
,, l %
*** NRC/TH! 83-010
/
rebruary 7,1983 d b , 3 1r. 3. K. Kanga
*t .
i = lirector, THI-2 , iPU Nuclear Corp. -
- 8. 0. Sex 480 .
p tiddletown, PA 17057 i I 3 ear Mr. Kanga: l [ , In response to your letter, 4410-83-L-0024, dated January 28,1983, the NRC has e
=
reviewed your proposal to maintain the doors in ene or both reactor building nie airlocks npen while reacter building recovery activities are in progress c ncur that unimpaced transit through the airlocks will expedi".e the reactor building cleanup and reduce worker exposurs without substantially increasing the risk to the enviro 7. ment.
~
*=d consequences of an airborne release through tae open airlocks are minimal the overall effect of opening the airlocks is beneficial. Therefore,
. Jact to our review and approval of implementing procedures, we appro a thel L proposed action.
Aa stated ir. your letter of January 29,1983, thereisareductioninworker.h exposure are ope % during transit through personnel airlock it when both airlock doo ca Mdiste man-rem SA.Yings CcD be affected by k&4pinf the airlori Open when hat, tor Builcing work is in progress. Airlock M the'equipr. ant hatch airlock, b ids net becn used routinely for reactor building entries. However, the e advantage of using this airlock to expedit,a future retetor building cleanup f operations has been identtfied. It 16 antteipated that airlock fl will be used routinely for reactor building ingress d.He airlock #2 will r,ormily serve as
~
the egrets route. Environmental safeguards associated with opening the airlocks for short per ditcd August 20, 4 of time have been addressed in EPU submittals 16, 19821U,2-810192, arc' in the NRC Hodificatien 1981, and 4410-82 L-0013, dated Septemberand Recovery Operations Plan Chaage, i dated
- of Order, dated September 23,1981, October 7,1982. Based on data ehtsined during . periods when airlock doors were 6 i opened for ther+ the eerioQ, the NRC concluded that, civen scoreern ,
orecedural controls, the doors of both airinch can remBn coen durit;g work activities inside the reactor building without significantly decreasing the - agrein of safety to the general public 07 rorkarr.. . O G w.
- - ~ - ~ _ _ _ _ _ _ _ _
~
e g
,s h
t e de e n s e
/'
eh h il 3 8 sh nst t ta si i t ,W' 3 ugne itri 1 o ui pobgan ehl g xnov
. ~
uo ucioeeti tct
, nrt ihnh1 oint 7
ttec1u a 1 rge eoac y n h o pd h p e r a r ogpewtl oet a e a cnl o w es u i utsgt oef
. r adganadtt ot e oehe y vth t r
. b l e o e )i 1ugesl didrrtea osphn t F
(bnnii)i o ie l c iovu1
- r r i o b ( pb s iohrecs e w i e re rootr ic ottaPr o:elhif dl etl w t Di f fcit v d tmf ans .tttit caew otis ire eaO teo rr
~ ne r ml yd eetl a h o stcao rgm censrr aena gcl yvli eoa ehoui de Drr rtf euefeu t qhi dl el e .Pgo t
setnetceell gtti r gp ebhaua p4 Ryr tP cfdhl l e* 2 e rl s a d. ninsl ew c yeswrl ho) t voti sl roikecsr shci e osk w y kaepM tDI - - t!2lltl f( e s n a g w tvi fyc ot
~
sr.nue s no eidoirldnt)iic3vr raestiali a lt gi t c d da n eed nriahiMa(it ppephse subtddc ts ' eeaag
;s i n oo)xterbl 3e ro sea e
,tt nutr6 dd hen so ( sidcoesei e dr eathnrt u s
tsnotcecco raonorosieb l eo der tperesrr e tn ogok huoo rrdcen tu o h o Uh tl yttarc b t npeltcP o hr Seldeeese.a rs rvt c gt i e t a n r ass ou .ts d htyg s g
)2 ethseaee li n
a a ritd ecch l decskf a (wf tt ghr K utf e daaootos til n.ese,or ae rgp, g
. eb c st mrosn
. orkekiiikikcncnatcmcnin roc pt o e oi ioroidi 3
cicimndle n reit r ri e 6 l
. Uarar Petlt opoiet our Erspatocadsfba
^
\
l
+
" JT pp.P# Inter Offios Memorandum !
tuas February 17. 1983 MI I
...e-, :::::,c;:a r ::f -
ENunlesrasasumuse Tc; J. W. Thiesing. Racovery Programa Locations DtI-2 Plant M 6 RETERENCE: (1) M memorandus N N dated February 10. 1983 (2) R. L. Frees 4 man memorandum m 6 dated February 17, 1983 The eurpose of this memorandus is to summarize the status of M M review of the Polsr Craus Land Test Safsty Evaluation and decument closoout of6 f.ngineering's commaatt which wars rhe sub-ject of Puferences 1 tad 2. -
~
556P?iS !9 muuMIDE cosmumte other than thoes of Wafetenu k. Leva besa rec &lved. Va casuam tha: ca?.tviations are availa W to support { the lu d crop analysis m6mtiened in ths 57.1. The ce -et s ot' Referenca I wera /iscussed extensively at the norninr, asetinc een febrwy it.1985 with Kr. Kanga in attendanco, during ta etternvoc raccing ct.14bruary 11. 1963 vfen ftr. Ranga, on W ef tsynoon of Tobrawy 15. 1983 vich ltr. Bartor.. ud ag&in on the s N rocon of Tabruary 16, 1983 with Meaars. 5arton, tanta. Thiestr g. F mastraan. R!. der And Jackson. As a result of discussions se these meetings. M Engineering agreed to close out the comments of Reference I on the basis of over-riding prograar,atic concerns which in the opinion of program manage-ment overshadowed the technical concarns of Plant Erigineering. It is sur understanding that a management position has been taken to turn the polar crane over after the load test. Although 6'has voiced a fundamental disagreerunt with the Polar Crane Ratest Program, we do not challange the authority of the Office of the Director to proceed with the program as written. 4
~
~
hblhee-MileIsland D S . LeakE0utT .
- q. WIT:
2&Ja# W M[ 4[p)
. . . ..:. .f Susan Q. Stranahan, an editonal wes.ter or
/ 'The Philadstphia Inquirer, has followed theTh I nose on leaoe ao an_ Alicia-Patterson But what emerged from' the trial amounted felloa.
By Sween Q. $wonohon T l j to an invitati a to a House Interior sub THE REALSTORY behind*~N& Egdatory bmm.en's aeci. out at the end oflast year. - the e e budget author four==tM- yearn. to delvi further. I-dent If it at
. th seemedto startsp of the story,and quite a - "D '**** 80-The press mined a it was: evidence that operstors at T50 falsified note The enhaammittee has asked the NRC t an9 significant information on TMI that reports on coolant leaks to the Nucieer Regulatorydone surfaced during the trial,as by wetGPUitselfinore as the status the Commienion;a study ident - which found that "the of the NRC position on p separate M-hiEn suit GPU has (Ued assinet tne gewenment.
ayearbeforetheaccquality a of
- ofoperator ene.- personnel is unhowever, It's unclear, acontinuoushow mech down. NRC offi.
werdtrendduetolackof traines;"by a TMI em, cials will find it in their interest to vohmtow tradstory statements under oath onTuesday.That second $4-bition GPU suit ploys; mdence of an operator dwing on.a qualifying charges the NRC with neghgenee, claiming - examination The setting 6nd formuch else. ens wan'not one of in thess~..c' ths. a novel twist for the corporate world - that the regulators didn't regulate firmly five offklal investigations held on the worst commereal enough, thet if the commineion "had acted nuclear eccidsntin the nation's biotory.hes inquiries with due cete . . . the TMI acekient um by two on, M vai committees, two special inves- nottme occuned."emnent ef&iall, who ha tigative paes's and the Nuclear Ae me losed the R%ulatory Commis.sia l ease says. " A ktif serio.m ac. emi dW not fully deve,1 esma&ns have been made absat she own mmpeteree to this ceATexi:uay in 4w.e thy hariBut row, L,a fedtst carrtmem inthat Mantuttas, henprJ of rponey wm et sede, n no holde he bamd. Geo-New fied Yetki trieishowed ht GN Uni portant data to the MC /dtivmah kal hbik Utili6ca, owne of TM1, was suing Bahmek N billiert the I staff had plemy of opportt.nity to
& Dos, mal:orof theTMInector,see "unthink. u:ility on that and We infractions, call h damages, charging that B&W had ca it didn't take the retter serioesly. When the able risks to human life!' Not seding still for that, NRC] case corew, to cout, hgically sons.
Babco:k & Wilcox retaliated withButischav,e9 t ' to want to of "wiilAdaM know th '?
. or not the NRC interated we aM tha evidem:e about who was at fwlt bqpato in pureviry flow,. Irtlate the inee that January,just esne et (J theas -
hdid not flow foi lato its @n attack during GPU BW litisatin t'nat trie dM produce cock & Wilc6: was 'that it wee setth'ng out of some fascinating informatich. Ar !!emy the trial, GPU Myas, scwoce adviser to the House lotator court for $37 spilhon, and this in the form of rebates on Committee, remarks of thatl aborted court equipment and wevices it would etmtinue'to buy ~ over the.first timearnished battle:"For thee were truth, people the next decade from Babcock & Wircos.whowereinteratedin " the um ot it out." and they wwe detertnined to n S 5 GPU may not have ben eagw to % suit ' against B&W or the NRC. But lawsuits were to saWy tw g ups ht hold get power over the utility: stockholders and sta WASHINGTON POST, Feb. 20,1983, Page C-1'3 public utility comminnions. 1 of 2 Both must be' convinced .ds to the utility did all pay the it could tp seek outade fur
~- -~"-'~%%__ _
- GPU contended that faulty B&W instrue. . The TMI reactor was fnught with prob.
tions caused operators to misread the ' prob- lems from the beginnin6. Startmg in 1979, nearly $1 billion in T!sU cleanup costs and lem. But B&W srgued that any competent Unitr,tootang syntam.lesketat retse that the $3-billion expense of replacement electri. ter should have beerttipped off by the- frequendy exceeded allowable-NRC limita. ' calpower while TMIis out of service. y high temperatures, causdby the NRC rules required thatthen reactor be shut f a Despite d GPU efforts to obtain fed. steam, that the vah was stuck down to determine th cause of such leaks. contributions from other nu, seca . j rra! funds open. o prove it was incompetence - not But Fiske cited NRC findings that TMI ielear users, there appear to be on}y two .B&W's instructions - at fault, Fiske had to opere, tors, to avoid the expense of sh&tdowns, !aources of money - GPU's investors and show that Zewe knew of the high tempera- manipulated the leak rates, falsely certifying l customers Investors aren't standing in line to to the NRC that there was no major problem. tures for a long time and did not respond. ibuy the company's stock ht hves GPU's To begin with, Zewe told Fiske that he When the NRC learned of tk falsified !ratepayers in central Pennsylvania and New hedn't followed GPU's booklet of operating records after the TMI accident, Fiska said, it I l Jersey, who will continue to be assessed for a fined GPU for tk infraction. procedures for abnormal situations as the ac-haubstantial share of the cleanup costa. If GPU
- A GPU audit conducted more than a year eident unfolded. He also said that he had lhopen to win more rate increes it must been told by a control. room colleague that before the accident noted that "tb quality of demonstrate to the utility commissions that it I temperatures had dropped from a high of 280 operating personnel is on a continuous down-irnade good faith efforts to obtain funds frorn . degrees Fahrenheit to 230 degroos,ward trend due to lack of training." Attend.
indicating i lother adorces. t- l to him the valve had closed. . l . So GPU found itself in the courtroom of That version, Fiske said, was different from we at4pera r tramm.g classes, to prepare ; for NRC- u red exams, dropped as low as j Federal District Judge Richard Owen on Nov, ' previous sworn testimony berg, a noted New York law-by Zewe before 13 percent. TMI supervmor of training j
- r. David K! other investigate.,y bodies. On one occasion, GPU, opened the trial by was devoting half his time to studyt for ha lyer retainedpromieirgr to relateFisk said. Zewe hadepisode "a frightening heard tatified thatof the temperature incorrectly.
he had. Fiske also j own operator'6 license, the GP audit ' te misconduct" by Babcock & Wilcox. showed, and wbn he failed the test, he spent recited earlier Zewe testimony before a Sen-a!! his time preparing for a re-exammation. keystones of GPU's neghgence claim were two memm written in February 1979 by ate committee probing TMI. When askd {i e A control-room supervmor,who had to be what he coesidered the " major contributor to o B&W engineer describing a September this aceident," Fiske said, Zewe had re- decertified to the NRC following tb accident. 1$77 incident at an Ohio nuclear plant. The sponded then: " Failure of the operator, my- was found to have cheated on the exam. He I Ohio probiern, also invoMng a loss of coolant self, to adequately detem.ine the electro ' submitted his test with answers in soml to a B&W-built reactor, was indentified and else's handwriting and a different color ink. corrected in 20 minutes. The memo advised magnetic relief valve was still open." ] Fiske accused Zewe of altering his testi- Dupiu au this, Armid defendM tk train- l B&W management to warn other B&W rene. tor owners to revise a. ocy matmetions to mony notto. offset any inference of incompe*. ing m and took exception m Fia's e waming finally I tene on his part. Zewe' denied the charge, statement that TMI management " failed to prevent a recurrence. instui a sense of respect for the training" of was sent out after ther TMf accident.) The saying that his testimony on this occasion was ' memos, Kimgsberg declared,"are the smok- to the best of his recollection. its operators. i This last assertion by Arnold elicited some as Robert B. Fiske Jr., a a abarp remarks kom Judge Owen, who said h,e B&W's a former U.S. attorney for the Southern Dis-
- itrict of New York, who responde!. fe,rcefully.
Th Uvelient evidence about canditiorn at ThTs came during the crcse-examination of $ E*' g- gfh, We expect to prove tht GPU was gut!ty P.obert C. Amold, prentdent of GPU Lelear hunky-dcry'" f,a fscs, sei the judge' "the lnot .nnre!y of ordinary nerhgence, but of Corp. and, as such, TMI's chief erneer. In "I' ; m.kbaneer WJn fut engaged in certain re- Amoldt view, maianance d the TMI renc.' '#*t ' *'* h 9 **' [ '*Y d $McMi.t!O"p,Zm"#n~ F ,7 ac, g t % # ,e %scta,9un 'Mply. % g h6g@ m the recto , he ud, WWs had emer- ning tbmetm wermHable d apaba. g 4 gm g gg g g lger.cy ins'.ructbne availan$e but igriomi them But for svary nestive mem.at by Ar* # 'i E'**"
- in favor of tneir owr, "on the spot, off the noid, Yaks caused with c6r evAnu -. ' va!"eari On Jan/2ii, with the defense still m. th-
{ W4 ad hoe analysis of systera conditions, for ' all drawn Imm GPU's own fHes, from its em- .@ stap M cahg its own mtneaea, @. bhich'. ', . their traini%,hogram~leftlhem ! player'seem crabrom:a during previn in, totallyill-couipped . . , ' vwtigatiors or tra trid itself,2M ficm N?.C ; xdhnly agreed ta rel , It war durin,y crasa-uarninstion of GPl?s documents.This evidemindeed: tion that wan release. l
- The TIS station manager a:fvreed his tu, , public, states t Mtut t nei,one r puty har e6tsWhed myn cit.-me that Fiske built inuch of his l mee.The crts-cuminaten w niism lowe, parin before tb accident thed per m*L> , toc etc was the cause of da TML2 oc.
esnee at the plant was a wrious proWrn. At ' t* tiftsupminT in TMI Uch 2 se 16 time of the time of the eccika 000 to Wuu repetr 4 the accident, wrs an enmp6. By mmt samsmem, th sedemt was At inoue was the temperrtu o of ster.m usks were pendig Wd esttmated uMer faced ,upon a, Weng'ured GPU management surging out of a stuck n vslwon the reac- cross.exarafution that TMI's maintenance by its mereasmgl womed colleagues m the I operators didn't , dre[etbud nuclear mdustry, is had the potential for tor's pressurizer tank. for 1979 had been could easily cut have ap-"several hun-thousand, and [it dragging d,own t.n entire m, dustry that s al. know for two hours and 20 mmutes that the valve was stuck open, allowing much of the proached a million [ collars]," but he con-reactor cooling water to pour out. They com. ' tended that r'eactor maintenance was still suf- Y y g*[.yyy'[ pounded the problem by shutting off emer ficient. all the TMI iravestigations had brought out gency make-w, water. such damaging Information." The question now is whether anybody in WASHINGTON POST, Feb. 20, 1983, Page C-1,3 Congma or elsewhere really has an interest in pursuing thd rest of the stmv,in bringing 2 of 2 out that full"4nvarished tr, about what really happened atThree MIL and. l , M
DFJ.FT FOR MYSTERY MAN AFFIDAVIT
\
On pages 36-37 of my affidavit I expressed reservations at ' George Kunder's role as Plant Operations Review Committee ( " PORC ") and Safety Review Group ("SRG") chairman, in light of the significant l nature of those jobs and Kunder's performance during the TMI accident. I also disclosed that Kunder had been identified in discussions at Site Operations ( " S O ) offices as the man who shut off the High A Pressure Injection ("HPI") pumps. This portion of my affidavit was an extremely condensed introduction to my concerns, both about Kunder's role in the cleanup and the events surrounding the damage to Unit II during the accident. et. Since investigators Meeks and Vors\ are investigating the issue this statement will fully disclose my concerns. I am available for further interviews with the NRC on the relevant underlying analysis. Initially, certain statements from my affidavit must be clari-fled and presented in their proper context. General Public Utilities Nuclear ("GPUN") -- in congressional testimony rununarizing the pre-liminary if niings of the Stier investigation for which it contracted -- attempted to rebut my disclosure by dissecting the literal meaning of individual phrases examined in isoldtion. By expanding my dis-closure through this statament, this confusion should be eliminated. For instance, Bernie Smith discussed Kander's activities at the accident in much more general terms than Joe Chwastyk, who identified the safety injection pumps. Further, the discussions about Kunder and the pumps involved several different actions -- shutting down the Reactor Coolant Pumps ("RCP") and the HPI, or safety injection pumps. (The HPI pumps are also known as the makeup pumps) .
/
hE S EXHIBli FOR IDENTIFICATION N. PENNY AN 7 wit: fu M A' -
, The time frame that I recall Kunder being identified as the man who shut 'of f the safety injection pumps was during March 19 83.
Earlier conversations involved his actions turning off the RCP's. To the best of my recollection, the specific language from , CHWASTYK in March involved a statement that George " shut off the safety injection pumps." I am not sure whether he also used the , words " mystery man" in reference to Kunder. My affidavit should not be read as a quotation in this respect. I did intend to dis-clo'se the meaning of what I had heard, however. It meant that, if true, Kunder was the " mystery man" written about in the press A ctaW I$ o> du; to the GPU - Babcock and Wilcox ("B&W") trial. The trial and news accounts naturally were discussed on site, and the term had come up En ' discussions at the 50 office area. In addition to clarifying the details, I wish to remove any lack of clarity about my motives in raising the issue. I do not and did not harbor any dislike towa::d Mr Funder. He have had a protectional working relationship sinea 1980 ano only had hard feelings once. That ocession was around last Christmas and 25' apcic,gized to him within a few minutes. My grumbling at the time was soon forgotter., Phile I do not wish Kunder ill, I felt that his unique position in the TMI cleanup raised a aerious question about management competence and/cr integrity. The PORC committee which Kunder led had the responsibility to review procedures, although final approval was through Larry King as $6 Director. In this role Kunder and PORC still reported to the SO Director and was one of the resources for the department in TMI's checks and balances. While I was sometimes irritated at delays, it was part of the job. _ ~ - - - - - - -
l .
~
( When Kunder began to serve as SRG Chairman, however, his qual'ifications assumed increased importance. SRG would have more , 1 legitimacy than PORC, because the members #would work full time.
]
Most significant, in my opinion and detailed in another statement, 1 SRG represented an illegal attempt to bypass SO without Nuclear Regulatory Commission approval. The new committee would report to Mr. Kanga. It could now be a resource to rebut the SO position, N40 which simultaneously was stripped of the review base PORC1formerly represented. This organizational switch to SRG occurred around the time pressure was building on SO to approve the polar crane and headlif t
, procedures before our concerns and comments were properly addressed.
g, Due to' SRG's questionable legality and role motivation, the cleanup could be significantly compr'[ sed if the chairman were not sufficiently! ebjective and invulnerable to management pressure j in order to provide an independent review. In those respects, Mr. Kunder's record, especially at the ace:ident, made me doubt. whsthat managewnt had good faith motives to place him in charte of the SRG. To illustrate, Mr. Kunder did not appear objective. He secpeted procedures from Recovery Progratu ("RP'1 with cursc.ry revieve but subjected the 50 ef forts to unnseensary scrutiny on occasions, sugh as with procedures that I prepared and were eventuall) approved for draining the "A" Steam Generator. I felt that Kunder s quick approvals of inadequate headlift procedures could lead to safety hazards, while his meticulous reviews of other procedures created unnecessary burdens on well-controlled programs within the cleanup.
-4 I questioned management appointing Kunder to this position in light of his record at the accident. My concerns about his appointment go beyond whether Mr.' Kunder das the " Mystery Man."
At the accident he also followed procedures literally and shut off the Reactor Coolant Pumps, although there were conflicting signals and indications that literal procedural compliance could be a - 1 mistake at the wrong time. In short, I was concerned that during the accident Kunder did not see the forest through the trees, and l now he would continue that approach as SRG Chairman. I sincerely j believed that tite role of SRG and the qualifications of its chairman were issues about the cleanup that needed to be raised. - I also questioned Kunder's independence from management pressure, due to the events during the accident. " - ' ' i 4 MM ' 1 was concerned
- that Kunder would r.ot feel sufficie.:tly independar.t to challenge the manAgow nt pressure surrounding the headlift. He is vulnerable if he indeed ,
i was responsible for significant dama.ge, If Kunder is also the
" mystery man" he would be even mole vulnerable. i 1
My concerns aboat Kunder's .tndepen4ence were not just hypo
- PsAC thetical. I have disclosed specific questionable *spproval practices ,
in my other statements.
*N edsas== mum =WPmp l w ly m m w ensmummm w l
I knew that at the trial an analysis from EDS Nuclear, Inc. was introduced to conclude that the HPI pumps were not turned on at 5: 41 A.M. (the approximate time at issue in my affidavit). I knew that this analysis was introduced *just before operators Zewe and Fredericks, who were among those reponsible for the HPI pumps, switched their testimony in conformance with the EDS'palcula-Z M sl fHAf'TM f"WAfTMISentep tions.' Operator Faust did not, however. Othe EDS analys*i[ had f M /fl. unproven, incomplete and inaccurate assumptions, which make it [WGA. c,vco ygty// especially questionable as a basis to effectively rewrite the of 7tlef J history or Sequence of Events [500 already published by GPU and not yet/fiv67 AdAcytt /['7#t amended, to my knowledge. Finally, the trial was settled abruptly and unexpectedly shortly af ter the EDS report was introduced. I knew of these developments and the mystery man, because as dis-cussed earlier the trial and its set.tlement was a common topic on site. All of these events convinced me that the " mystery man" issue should be investigated thoroughly. My own review of the EDS report suggests that its c:Oclusions are premature. Access to the rnirevant supporting data is necessary for more definitive conclusions. My evaluation of the EDS report 10 based on the adequacy of its premise. The analysis basically rosts on the premise that the level of the makeup tank also deter-mined whether the second HPI pump, makeup pump "C", was initiated ct 5:41. EDS analy ef and prepared graphs for the makeup tank
- 6,-
t.C 4tt ~ eevees surrounding two times that it concluded HPI pumps were initiated, at 4:02 and 7:20, as well as for 5:41. The graph for 5:41 did not exhibit the same characteristics. Although the EDS analysis is reasonable, it's significance is limited due to the uem J selective use of data and unjustified assumptions, all biased in favor of the EDS premise. . l There are a series of questionable f actors with re'spect to the EDS claim that turning on the HPI pumps at 4:02 accounts for l the graph in its report. In some instances the facts as reported are suspect. For example, EDS asserts that an operator started MUP 1-A and opened MU-VI6b at the time of the reactor trip. But the Sequence of Events tsG&b reports that the evolution did not occur until 41 seconds af ter the reactor trip or 4:01:31 A.M. j Similarly EQS offers no citation for its claim that the BWST suction valve, DH-V5A, opened at 4:02:13. This assumption also
==
1:- is not verified in the SOE.
=
\
1 In facr, the btergency Core Colling System (ECCS), which l E_ l r includes the HPI pumps, did not have to be turned or. a'. all at 4: 02 ; f
-F in order to produce the characteristics en the EDS graph. Alternate l E A uAI. 1 L sources better explain the increase in pressure. IDS did not sa@pE E-p whether the increase in pressure at 4: 02 could have come free E oepning the MtJr Level control Valve (MC-V-9 ) to refill the tank from the Reactor Coolant Bleed Tanks (RCBT), instead of from the HPI pumps. This explanation would be consistent with the require-ments in emergency procedure 2202-1.3 for operators. In other words, EDS failed to consider the possibility that the operators
-7 followedtheproceduresat4:02. Similarly, EDS failed to consider whether at 4:02 water was drawn automatically through the makeup level control valve,. aiJ ain as an alternative to the HPI assumption, s These alternative explanations are even more persuasive when the EDS assumptions are compared with the capacity of the HPI
- pumps and the data provided by EDS. The EDS graph discloses a four inch rise (approximately 280 grams per minute) in the makeup tank during the 26 seconds from 4:02:13 - 4:02:39. That is a sub-stantially higher rise than is achievable " solely from HPI pump recirculation flow.
Finally, even if EDS' assumptions and facts were accurate, the results' demonstrate that conditions were not analogous at 4:02 and 5:41. For instance, different pumps would have been involved. At 4:02 the A&B pumps would have been used. At 5:41 the Acc pumps would have been running. The C pump can only draw from the BWST. Even more rever.aling, the 4:02 incident would have involved ed twitching +two pumps. The 5:41 event would only have involved switching d on the !! pump. The EDS analysis of events at 5:41 is no more definitive. To illustrate, in some cases the analysis is incog lete. On page 12 of its report EDS states that upon ECCS actuation ~DH-VSA was opened. On page 13 EDS states that the injection valves MU-V-16A and. B also opened. Unfortunately, the report f ailed to identify when 4 they were shut af ter 4:02 and plot the ef fectr onegraph. _ ________________m------ - - - - - - - - - - - = - - - - - - - - - - - - - ' " - - - - - - - - - - ~ ^ ' - - - " - ' ' - - - - ' " - - " - - - - ^ - - ' - - ~ - ^ ~ - - - - ~ - - - - - ' - - ' - - - - - -
The 3DS analysis concerning 5:41 concludes that the HPI pumps could not have been turned on at 5:41, since the makeup tank level was only at 59.# However, EDS failed to analyse the # special circumstances then in effect, such as increased letdown h flow, lowered reactor coolant system pressure, and higher tempera-tures than normal. Most persuasive, EDS' conclusions about 5:41 contradict other data in its report. On page 16 of the report EDS stated that a makeup tank pressu e of 39 k847 would have been necessary to achieve the 59" level. But figure 14 in the same report indicates that the 59" le' vel was achievable with 31.5 /7/8.- Finally, the EDS analysis of conditions at 7:20 assumes an initial makeup tank pressure of 27 /k/S , only nominally higher than normal. Thisassumptionfailstoanalygethesevereeffects of the accident; which between 5:30 and 7:20 had led to superheated aneam and significant portions of uhe reactor coolant system in a stehr.a void condition by 6:00 A.M., to two-thirds of the reactor core uncovered by aroand 6:20, to hydrogen generation and half the roncter coelant system free volume in a stonn hydrogen mixturo by around 7.00 A.M. These conditions could well have led to abnormal overpretsrization due to steam arid /or hydrogen in the top of tne makeup tank, a possibility not considered by EDS. I will cooperate fully with the NRC in answering specific questions in more detail about my assessment. I am confident that my analysis can be expanded significantly if I can examine the underlying data relied on by EDS.
I
<- Exhibit'E
< nx .
(
, O mo /&'
asawAALLuj
=P%& FOR IDENTIFICATION y WIT: l% i ,
m E i I; 8 _ . . . .... . . . . )
1 HOBERG, FINGER, BROWN, COX & MOLLIGAN CALENDAR STEPHEN T. COX 2 BARBARA A. ZURAS Ony-//// 703 Market Street, 18th Floor 3 San Francisco, CA 94103 g7 7g i Telephone: (415) 543-9464 4 Fe r (MM l l 5 Attorneys'for Plaintiff 6 1' 7 8 THE SUPERIOR COURT OF THE STATE OF CALIFORNIA , 9 FOR THE CITY AND COUNTY OF SAN FRANCISCO 10 RICHARD D. PARKS, NO. 831 846 11 Plaintiff, RESPONSE TO REQUEST FOR' 12 PRODUCTION OF DOCUMENTS , 13 vs. 14 BECHTEL POWER CORPORATION, PLF'S DE EXHIBli f/ -- et al., FOR IDENTIFICATION 15 PENNY AN N.P. Defendants. ' WIT: # 1 ' jTwfL YA M l'7 18 Plaintiff RICHARD D. PARKS hereby responds to defen-f 19 , dants' Request for Production of Documents as follows: ; I 20 To the extent that plaintiff is in possession of any 21 privileged documents that fall within any of the descriptions of 22 any of the defendants' 53 requests but withholds auch documents l 23 based upon privileges or objections, plaintiff, at the conclusion of this response, has set forth a general description of the l 24 25 privileged documents withheld. 26 Plaintiff assumes that the . defendants in their 53 documents consisting of this 27 requests are not seeking correspondence 28 litigation's pleadings filed by any party, . TA;': Ba?*"- ? ::::::;7;:',, u,....n .,,, ' >n rescesco enas
1 the discovery of admissible evidence and/or seeks irrelevant 2 information and on the grounds that this request is vague, ambiguous and unintelligible. Further, plaintiff objects to this 3 4 request to the extent that it seeks information concerning the 5 content of telephone calls between plaintiff and his attorneys and/or his attorneys' agents. Plaintiff incorporates by 6 7 reference his objections to Request No. 9 and 42. Without 8 waiving said objections and consistent with said objections and 9 to the extent that plaintiff understands this request to pertain 10 to telephone calls plaintiff made or received since terminated by 11 the defendants through the date of the complaint in this acticn, 12 plaintiff will produce what, if any, unprivileged documents exist 13 which are in his possession which pertain to the subject matter 14 as described in this response if the defendants will offer proof 15 as to the discoverability of such information. 16 REQUEST NO. 53: 17 Plaintiff incorporates by reference his objections to i8 Requent No. 1, 3 and 15. Further, plaintiff cbjects to this 19 request to the extent that it is vague, ambiguous and unintel-20 ligible in that plaintiff is uncertain as to the meaning of the 21 phrase "former employers." Without vaiving snid objections and 27 consistent with said objections and to the extent that plaintiff 23 understands this request to refer te plaintiff's employers prior 24 to the time of plaintiff's claims against the defendants and/or 25 other than the defendants, plaintiff is not in possession of any 26 documents falling in the description set forth in this response 27 and/or does not believe that any such documents exist. 28 /// 'l h[^,k 19 L".T,".7:w
,*.*.7: * ".' "
1 The following is a list of privileged documents which 2 may or may not fall within any of the defendants' requests which 3 are being withheld on the grounds that such documents are 4 protected by plaintiff's attorney-client privilege and/or 5 plaintiff's attorneys' work product privileges. The disclosure 6 of the below-listed material is made without waiving said 7 objections and consistent with said objections for the purpose of 8 avoiding a potential dispute in discovery. All references to 9 notes or memos of Thomas Devine are references cf notes and notes i 10 of his thoughts to the file, or memos to GAP file on Parks 11 representations: 12 6
/ ocument A - Thomas Devine's handwritten notes dated 13 July 11, 1983, seven pages, addressed to the file, re: probable 14 legal consequences of Parks' /Bechtel settlement agreement as 15 proposed / copy sent to client Parks.
16 17 Document B - Diary written and maintained by plaintiff 18 Rick Parks for Hoberg attorneys (Barbcra Zurcs) 19 handwritten 19 pages, no copies, re: chronology of events during p5.aintiff's 20 employment with Cataract, Inc., dated December 17, 1984 through 21 May 16, 1985,
. 22 23
[ Document C - Handwritten notes by Thomas Devine, one 24 Page, no date, no copies, re: Devine's notes of conversation with 25 client Rick Parks re chronology events leading to suspension of 26 employment at TMI. 27 28 Document D - Handwritten notes by Thomas Devine dated ,l i ."lE///*' 20
- " Y"."
t 1 May 3, 1984 re: conversations with client Rick Parks re upcoming 2 Parks interview with NRC investigator. 3 4 Document E - Handwritten letter / memo from Rick Parks to 5 Hoberg attorneys (Barbara Zuras) dated July 12, 1984, four pages, 6 no copies, re: chronology of events at TMI/ Cool Water and . 7 consequenet-s to Rick Parks. 8 9 Documents F - Handwritten notes by Rick Parks to 10 attorney Thomas Devine dated June 26, 1985, three pages, no 11 copies, re: GAP's continuing legal representation of Parks / post 12 TMI requirements. 13 14 Document G - Undated memo by Rick Parks to Tom Devine 15 re: historical overview of TMI events since March 23, 1983 16 disclosure, 12 pages, no copies. 17 1g Document H - The following are privileged excerpts 19 deleted from Rick Parks' 1983 diary: 20 21 1. March 31, 1983 - Parks' notes of conversation with attorney Tom Devine re: DOL proceeding.
- 2. April 4, 1983 - Parks' entry as to conversation 23 with attorney Tom Devine re: witness Ed Gishel.
24 3. April 6, 1983 - Entry by Parks re conversation with Tom Devine re: witness Larry King and supplemental affidavit. 25
- 4. April 8, 1983 - Parks' entry re conversation with 26 attorney Louis Clark re: DOL charges.
27 5. April 11, 1983 - Parks' entry re conversation with Tom Devine re congressional efforts on TMI, FBI meeting, 28 additional witnesses. *
.. n~w ,,n n. ",,j,"gf,',", 21 e.........
1 6. April 13, 1983 - Parks' entry re conversation with Tom Devine re meeting with Bechtel lawyers and news media. 2
- 7. April 14, 1983 - Parks' entry re conversation with 3 Tom Devine re: Jim Dejen.
4 8. April 19, 1983 - Parks' entry re conversation with Thomas Devine re: additional NRC submittals. 5
/9. April 20, 1983 - Parks' entry re conversation with 6 Tom Devine re: information needed for DOL for settlement possibilities.
- 10. May 6, 1983 - Parks' entry re conversation with 7
8 Tom Devine re: Kuhns and Spence. 9 /11. May 16, 1983 - Parks' entry re conversation with Tom Devine re: Placier meeting over DOL complaint. ) 10
- 12. May 20, 1983 - Parks' entry re conversation with 11 Thomas Devine re: TMI accident scenario.
12 13. June 6, 1983 - Parks' entry re conversation with Tom Devine re: strategy for employment in future. 13
/14. June 7, 1983 - Parks' entry re conversation with Tom Devine re: DOL strategy.
14 15 (Each of these privileged entries was no more than 11 16 lines of diary page, no copies, dated as specified). 17 Document I - Thomas Devine's draft of allegations for 18 Parks' affidavit reflecting Devine's conversations with Rick 19 Parks, no date, eight pages, no copies sent, re: George Kunder 20 and TMI pump shutdown. 21 22 Document J - Parks' memo to GAP attorneys re: Parks' 23 analysis of testimony of GPU/Bechtel employees dated March 31, 24 1983, 17 pages, no copies issued. 25 26 Document K - Handwritten draft by Thomas Devine 27 re: allegations for Parks' affidavit reflecting conversation with 28 Rick Parks, four pages, no date, re: pump shutdown at TMI, no i
^ 22 3 M A# RET STR(ET -
- ,*:c'::L".'"
- _ _ _ _ _ _ _ _ _ _ _ _ -~ - - - - - ____.--. _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _
l i 1 1 copies issued. 2 3 / Document L - Thomas Devine's handwritten notes and thoughts to file, November 22, 1983 re: NRC continuing i 4 5 investigation of GPU/Bechtel role in TMI pump shutdown, five 6 Pages, no copies issued. 7 8 Document M - Notes by Rick Parks to Tom Devine, nine 9 pages, re: review of December 29, 1982, EDS nuclear report, no 10 date. 11 12
^/ Document N - Thomas Devine's 11 page handwritten memo 13 re: outline of arguments re technical problems of TMI pump 14 shutdown / George Kunder, no copies issued.
15 16 ' Document 0 - Thomas Devine's draft for a letter and/or 17 outline for a letter intended for NRC commission re: technical 18 aspects of TMI, harassment of employees, dated Ncvember 10, 1983, i 19 eight pages, no copies issued. 20
?1 , Document P - Thomas Devine's notes re: his analysis of 22 May 2, 1983 meeting with NRC re: Rick Parks' TMI allegations, 11 23 pages, no copies issued.
24 25 /ocument D Q - Thomas Devine's handwritten notes and analysis re: April 27, 1983 meeting with NRC re: Parks' 26 27 allegations re technical aspects of TMI and harassment of Parks, 28 24 pages, no copies issued. . MOSI"' 23
- " "ll,",
-L----_______-____ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , _ _ _ _ _ _ _ _ _ _ _ _
1 Document R - Thomas Devine's handwritten notes to file 2 re March 24, 1983 conversation with Rick Parks re: harassment at 3 TMI, one page, no copies issued. 4 5 [ Document S - Thomas Devine's April 22, 1983 handwritten 6 notes re: his thoughts about next step in Rick Parks ' legal 7 representation, one page, no copies issued. . ( 8 1 9 / Document T - Thomas Devine's handwritten notes dated l 10 April 19, 1983 re: conversation with Rick Farks re ECM's data, I 11 three pages, no copies issued. l l l 12 13 Document U - Thomas Devine's outline for Rick Parks' 14 affidavit - - points raised - - evidence to support based upon l 15 discussions with Rick Parks, four pages, no copies issued. 16 17 Document V - Metra by Billy Gartner, paralegal of GAP 18 dated March 13, 1963 re: conversation with Rick Parko regarding 19 legal representation concerning Bechtel harassment, two pages, no 20 copies issued. 21 22 ' Document W - Notes of Thomas Devine dated March 14, 23 1983 re: conversation with Rick Parks re legal representation of 24 Rick Parks / Rick Parks' history at TMI, three pages, no copies 25 issued. 26
/
27 / Document X - Notes of Thomas Devine, dated March 15, 28 1983 re: conversations with Rick Parks re Parks' history at TMI, IECS *' 24 n:::::
..':.:.,',l ,
1 I I technical aspects of TMI, 11 pages, no copies issued. 1 2 Document Y - Thomas Devine's notes dated March 17, 1983 3 4 re: continuation of meeting with Rick Parks re history at Three 5 Mile Island / technical aspects of Three Mile Island, three pages, 6 no copies issued. 7 Document Z - Thomas Devine's notes dated March 18, l'983 8 9 re: conversation with Rick Parks re Three Mile Island witnesses 10 and employees and upcoming press conference, one page, no copies 11 issued. , 12 13 Document AA - Thomas Devine's notes dated March 23, 14 1983 re: conversation with Rick Parks re role of certain Bechtel Polar Crane dispute / pump shutdown, NRC 15 employees re 16 investigation, three pages, no copies issued. 17
/ Document BB - Thomas Devine's notes dated March 29, 18 19 1983 re: conversation with Rick Parks re status of DOL complaint, 20 one page, no copies issued.
21 Document CC - Thomas Devine's notes dated April 11, 22 23 1983 re: conversation with Rick Parks re potential witnesses 24 among Bechtel personnel, one page, no copies issued. 25 Document DD - Thomas Devine's notes dated April 11, 26 27 1983 re: confidential meeting with James Barber, Pennsylvania 28 House of Representatives, re TMI public health threats, one page, M 0f!*' 25
.. = ::
- ,'.:.:..:.=.
)
1 no copies issued.
- 2=
3 Document EE - Thomas Devine's notes dated April 11,
.4 1983 re: meeting with Congressman Geikus, one page, no copies 1
5 issued. 6 i 7 Document FF - Thomaa Devine's notes dated April 11, 1983 re: meeting with Mr. Johnston re: Quiltec " conflict of-8 9 interest," one page, no copies issued. l 10 Document GG - Thomas Devine's notes, no date, re: 11 12 documents of Larry King, one page, no copies issued. i 13 . 14 Document HH - Thomas Devine's notes of conversations 15 with Mr. Hoeff dated April 13, 1983 re: legal representation of i 16 Rick Parks, one page, ne copies issued. 17 18 Document II - Thomas Devine's notes dated May 10, 1983 19 re: meeting with GPU lawyers Stiers, Nulets, and Frick, nine l 20 Pages, no copies issued. 21 ' Document JJ - Thomas Devine's notes to Rick Parks and l 22 23 file dated Mey 10, 1983 re: instructions to Rick Parks re meeting 24 with GPU lawyers. 1 25 26 Document KK - GAP memo from Marya to Thomas Devine re 27 message from Rick Parks for Thomat Devine re: Harrisburg, 9 28 Pennsylvania visit dated April 8, 1983, one page, no copies ! 3 mota.s:own, a e a:oWGAN ]6 aOm.. . TPOft4tl2N
- AInst crasst Mac.CCO
... ....... 94103
1 issued. 2 3 Document LL - GAP memo to Billie Gartner from Marya Y. 4 dated April 8, 1983 re: potential Parks' witness willing to 5 assist one page no copies issued. 6 7 Document MM - Notes and memos of Thomas Devine's GAP staff, no dates, re: Bechtel/GPU potential witnesses and what 8 9 those witnesses know regarding Parks' allegation against Bechtel 10 (Bonnie Sherwood, John Perry, Ron Warren, Mark Kobi, John Auger, Hrbac, Jim Floyd, Ron Brinkley, 11 Joyce Wenger, Carl 12 William Marshall, George Clements, Joe Chwastyk, Ed Kischel, '
' 13 George Kunder), no copies issued, 69 pages.
14 !' 15 Document NN - Memo from Mimi Yoon, law clerk of Thomas Devine to Rick Parks' dated Nove:nber 16, 1983 re: 16 17 introducing herself and enclosing documents to transcript of 18 Public hearings held in Herrisburg, Pennsylvania, concerning 19 Polar Crane at TMI - 2 (over 300 pages) memo, one page, no copies 20 issued. 21 DATED: March 3, 1986 HOBERG, FINGER, BROWN, 22 COX & MOLLIGAN 23 ( A By \ ~ BARBARA A. ZURAS l 25 Attorneys for Plainti Q 26 27 28 iE E Zl** 27 L':::::' C;".l.%
1 P, ROOF OF SERVICE BY HAND DELIVERY 2 I, the undersigned, declare: 3 I am a citizen of the United States, over the age of 18 4 years, and not a party to the within cause. I am an employee of 5 Hoberg, Finger, Brown, Cox & Molligan, and my business address is 6 703 Market Street, 18th Floor, San Francisco, California, 94103. 7 I caused the attached RESPONSE TO REQUEST FOR PRODUCTION OF 8 DOCUMENTS to be served by hand delivery on March 3, 1986, by 9 engaging a messenger service to deliver a true copy of it in an ) 10 envelope addressed to: ) 11 12 13 14 Steven L. Hock, Esq. ) Daniel P. Westman, Esq. 15 Thelen, Marrin, Johnson & Bridges Two Embarcadero Center, Sof.te 2200 16 Gan Francicco, CA 914111 17 I 18 19 4 20 I 21 22 23 I declare under penalty of perjury that the foregoing is 24 true and correct , and that this declaration was executed on 25 March 3, 1986, in San Francisco, California. 27 hT' ' Ann Doherty } I';"lf, *
..:::='
~
4 VERNMENT ACCOUNTA ~ M PROJECT . institute for Policy 5tudies . 1901 Que Street. N.W.. WesNngton. D.C. 20009 (202)234 9362 R
. March 23, 1933 'l; D FTS ' 'I
, EW18 T i FOR IDENilflCATIOi The Henorable Nunzio J. palladino PENN,Y SAJDER RP.
Chairman WII:K W uWp d 87 -- U.S. Nuclear Regulatory Commission ~ Washington, D.C. 20555 .;
Dear chairman Palladino:
The Government Accountability Project (GAP) is representing'y Mr. Richard Parks, a senior startup engineer at Three Mile Island (TMI) - Unit II. Our decision to represent Mr. Parks in based 'on a 56-page affidavit he provided* over the weekend, as well as veri-fication interviews with additional witnesses who supported both his charges 4.nd personal credibility. , In his affidavit Mr. Parks discloses, inter alia,1) safety-(l . - related modifications to equipment and components without full prior
- engineering and appreval; 2) quality assurance violations through ,
issuance of test and administrative 7rocedures without prior re,-
, view and approvals 3) plans to us,e taa poix.r crane without con =
ducting all necessary safety tests and conclusions: 4) severa haraes-ment and retaliation mo inst those who internally challenged these vio 4 tions, including investigation sad dismissel for utterly p:c= textual, previously-unrefined offenseur and 3) NRC collusion eith the T.inonduct. Based on his experience, Mr. Parks believes that these practices were intentional. 52 also believes that they compromise the system of organizaticar.1 chf4cks and balnnees at TMI. The dispute resulted from a ranage:nent attempt to conduct additionni radiation vs.titoring Without falling behind schedule Mtor it was discovered ard reported on January 6,1983 that radiatipn 1.evels under the reactor T*ssel
.are'30 times higher than previously estimated. ,
', ; 1.
We are alarmed that Mr. parks' experience mirrors that of so many other nuclear workers who' have contacted us. He reports Instead, that your agency has >f ailed to aggressively pursue his concerns. NRC representatives violated his conil.dentiality, flatly refused-to investigate his charges of reprisals, and rejected h:.s allegations ; on flatly inaccurate grounds contradicted both by NRC notes ans cor- i
? orate QA records issued at the same time. Perhaps most disturbing, 1 he reported a practice at TMI for NRC representatives to provide l the licensee with advance draf ts of Commission documents, and vice versa. Af ter a consensus was reached, the " official" version would be released. .- ,
\
1
--- - - -_-____-_~_ __ -__ ., _
l. 4
.i chairman Palladino March 23, 1983 ,
U.S. Nuclear Regulatory Comission .;.
- p
- l:
l , il:i The continuing allegations of "NRC-u tility collusion are shat'- taring public confidence in the Comission. Mr. Parks, and'GAN want to cooperate with the NRC. As a reruit, we are subenitting, his affidavit for your review. Unfortunately, to date Comission rap-resentatives have not responded to Mr. Pauks in good faith. Asla rnsult, we have advised Mr. Parks not to comunicate further with the NRC until we can negotiate with the Comission to ensure that objective, independent technical and invest.igative staff will be assigned to his case. I look forward to your prompt response. , I l' Sincerely -
,2 !,v Thornas Devitm ) -
TD/aa Legal Director . enclosure . I i
.l
! il
.+ .
- O e
II e 0 g- ! s l M ok ., 1 s
'P. g. i *
}4*., O' ,
% RICilARD D. PARKS t;E'K'i % h .'s m
~
7QK?fT' 'I EDUCATION i AcRla E2 U. S. Navy, Nuclear ' Power School / Prototype h_, it ,' b d J U.S. Navy, M achinist Schooling . Richland Community College . ET/M+VF.' EXPERIENCE NUS Corporation,1980 - Present D _EXHIBti f Energy Consultants, Inc. - 1980 FOR IDENTinCATION ACF Industries -1979 PERNY SANDER)tP. Consumers Power Company,1978 -1979 / red /b19 N 1,-> Ullnols Power Company,1977 - 1978 w;T. guAK<J U. S. Navy, 1970 - 1977 NUS - Responsible for providing consulting engineering services to utility plants during construction, startup, and operation of power plants. These services include the preparation and implementation of test procedures, operetIng procedures, and test assistance for new and oparating power stations. Currently assigned to the Shoreham Nuclear Power Station (826 MWe BWR). Pr! mary responsibility is as Senior Engineerin charge of radwaste systems, including the organization and coordination of efforts of radwaste systems test engineers in the daily administration of test group setivities. Other responsibilities include supervising the preparation and set up of test tetivities, systems, supervision and maintenance surveillance after the checkout and initial
- operational tests and instrument calibrations. Also evaluate the validity and accept-ability of test results, write preoperational and acceptance test procedures and supervise actual testing.
Previously assigned to Three Mlle Island Unit U Recovery Team. Primary respons!bil-itles included development and implementation of funettonal test procedures for the Submerged Demineralized System (used for containment cleanup) and other plant recovery systems. Served as Acting Startup Manager and Test Working Group Chairman while test manager was In extensive training program. Assisted in establishing, issuing and revising of test manual including work authorization' process, inspection, startup testing and turnover to plant staff and implementing Recovery Test Frogram and procedures consistent with Reg. Guide 1.68, Site Technical Speelfications and quality assurance program. Provided assistance to Plant Recovery Operations Director in the capacity of Operations Engineer. ECI - Assigned as a test engineer to Beaver Valley Power Station Unit I during an extended refueling and retrofit outage. Duties included preparing and performing test procedures for existing and newly modified systems that have been upgraded to recent requirements. Wrote and performed system design operational performance tests on post-TMI retrofits including the solid state protection system, quench spray /reefre spray five year testing. Wrote rec!re spray heat exchanger leakage test and performed this DBA test. ACF Industries - As Electrical Maintenance Supervisor directed fac!!!ty maintenance personnel in both preventive and corrective maintenance functions on production equipment.
- Nt.JS CORPORATION
l i t' . T; .g '.- RICllARD D. PARl(S
% 4 1
l I** PAGE TWO I . .
,* Consumers - While in the position of Shift Supervisor participated in the resesreh and'
- development of plant operational, administrative, abnormal and surveillance pro-cedures. ' Completed 30 weeks of training to support cold !!eeming on NSSS and BOP systems. Served as the group leader for the operationut and text group. .
n!!nols Power Company - Developed operational, administrative, emergency a.nd sur-veillance procedures as a plant reactor operator during unit construction. U.S. Navy - Trained and served as machinist in the nuclear power progra'm. Promoted to division Leading Petty Offleer respomlble for maintenance of both the primary and propulsion plants, divisional records keeping, and training of power plant personnel.
/ signed as training instructor at a navy surface nuclear prototype .
1+ G e e 9 4 4 e o _ _ _ - _ _ _ - - . _ _ _ - - - - . - - - - - - - - - - - - - - - - - - - - - - - - --' ~
---r _S ~~ __? hailler 3ntorporatch . Consultants ' Route 7 Box 90 G Lynchburg, viretnia 24503 3 04) 3844115 l Duquesne Light Company General Purchasing Department One Oxford Center, 301 Grant Street Pittsburgh, Pennsylvania 15279 Attn Mr. ft.C. Schopper
Dear Mr. Schopper,
In accordance with your Inquiry #3609 % , please accept the enclosed proposal for Startup assistance for Beaver Valley Unit 2. If you require further information, or have any questions, please feel free to call. i Sir erely,
/JonM.Hoade Business Manager ES UMBR FOR IDENilf! CATION PENNY ND .p, wm L<nue gib--
RESP. Ex. 31
1
.)
y ! j 4-;
.(f)Liilter 3nrarp'arated I Consultants -
Route 7 Box 90 G Lynchburg, Virginia 24503 (004) 3M4115 s BV-3609h9 l i PROPOSAL FOR STARTUP ASSISTANCE FOR 1 1 DUQUESNE LIGHT COMPANY'S BEAVER VAT 7 Y POWEA STATION i
)
f' l 1 1 l- , 1 l l l l e
l l BV-360949 I Introduction The Quiltec Corporation (Consultant) is pleased to submit this proposal to the Duquesne Light Company (Owner) for the purpose of I . Providing Startup and Test Assistance for the Beaver Valley Power Station.
=
The Quiltec Corporation is a group of highly trained, qualified and experienced personnels dedicated to providing the best available services at reasonable ecst to the power industry in general, and - nuclear power in particular. i - The terms and conditions contained herein are the Contractors proposal only, and may be modified with concurrence of both the Owner and the Quiltec Corporation. E 1 e (1) . EE
s i
. 1 BV-360949 .j II Scope of Service The Quiltec Corporation will provide the services of qualified i individuals to supplement and assist the Beaver Valley Unit 2 Operations Startup Personnel in the planning and implementation,n of all phases of the Nuclear Operations Department responsibilities for the startup of Beaver Valley Unit 2. These services shall include, but not be limited to, the following: ..
A) Conduct tests as required to support the Startup and l Test Program. This testing shall be conducted entirely by Consultant personnel or in conjunction with and/or i by utilization of, Owner personnel as required by the owner. B) Provide Pls.nning and Scheduling services to support i Startup and Test Activities. l C) Develop documentation to support Startup and Test activities inciudingi
- 1. Startup and Test Procedures .
I
- 2. Operating Procedures .
3 Emergency Plans and Procedures
- 4. Maintenance Procedures (Including Instrument and Control). -
i D) Advise and assist the Owner in administration and supervision of the Startup/ Operations Departments activities to insure, efficient, cost productive operations in compliance with state, local, federal and company rules and regulations. , t I Resume's of contractor personnel to be supplied to the Owner are l included as Attachment 3 to this proposal. 1 i i (2)
\
i Ev-360949 l IV Compensation and Payment i A) Compensation
, As set forth in Attachment I to this proposal.
B) Payment
- 1. Consultant shall submit weekly time sheets and/or 3 expense reports if applicable, detailing hours and expenses to be charged to the Owner.
- 2. Consultant shall be paid within fourteen (14) days after submittal of time sheets / expense reports.
3 The Consultant will notify the Duquesne Light Company when eighty percent (80%) of total cost is reached. 4 Invoices are due according to the terms stated and agreed to by the Owner and Consultant. Owner agrees to waive the right of offset from any future liability incurred for services rendered. (4)
r - BV-3609% V Warranty Contractor shall perform the services specified with the degree of skill and care that is required by customarily accepted good and sound professional practices and procedures at the time the work is performed to insure that all work is correct and appropriate for the purpose intended. q In the event of any error, omission or other professional negligence, or any breach of the above warranty, the sole and exclusive respon-sibility of Consultant shall be to re-perform the deficient work at its own expense, and Consultant shall have no other liability whatsoever. (5) S
BV-3609% VI Insurance Protection In order to protect our clients, as well as our employees, a complete insurance package is.provided at no additional cost to our clients. The following types of insurance will be verified to our clients through an Insurance Certificate at the limits established by the client: Workmens Compensation General Public Liability Automobile Liability. (6)
s By-360949 l ATTACM. MENT I l COMPENSATION 17 D e following consultant personnel and grade levels are submitted for evaluation for the Beaver Valley Unit 2 Operations Startup Group Job Positions indicated in Duquesne Light Company's Inquiry #360949 Consultants " Employee Classifications, Grades and Rates" are included as Attachment 2.' Resumes for each of the below listed personnel are included as Attachment 3 to this proposal. Beaver Valley JOB p0SITION H&$[ Consultants Grade Engineer. Nuclear Operations-Maintenance T.R. Osterhoudt 4 M. Hamby 2 Engineer. Nuclear K.C. Lionaron 3 operations-Instrument J.L. St. Clair 1 and Controls G.T. Allbrook 1 Engineer. Nuclear K.P. Draper 5 Operations-Planning and Scheduling Engineer. Nuclear B.G. Smith 4 Operations-Testing J.R. Floyd 4 R.D. Parks 3 J.M. Kidwell 3 L. Tankersly 3 Technical Advisory J.J. Chwastyk 6 Engineer-Joint Test Group Supervisor (7)
1
' BV-360949 ATTACMMENT 3.
Quiltec Corporation Epployee Classifications. Grade and Rates g CU_ OSSIFICATION R R l per hour 1 Apprentice Engineer j 2 Assistant Engineer M per hour Associate Engineer per hour 3 4 Engineer g per hour 5 Senior Ena;ineer g per hour Senior Advisory Consultant per hour f 6 i i
- _., _ '"^ _
l
'. 3V-3609%.
Compensation continued
- 2) All work rformed beyond a normal eight (8) hour day or a for ) hour week or Owner recognized holiday shall be at times the hourly rate quoted above.
- 3) Living expenses shall be billed at the rate of gg per day per Consultant employee.
- 4) The owner shall be responsible for the additional costs l accrued in connection with this service as described below: 1
- a. Initial expenses - day initial living expenses. Ac us oo d lodging expenses incurred will be billed at cost. Such reimbursement of actual expenses shall be in lieu of Living Expenses defined in A.3,above.
- b. Travel expenses and Initial Transportation ten -
The Owner shall pay each Consultant for travel between the work location and the employee's home for every weeks of assignment. In lieu of travel ex es, a one time Initial Transportation fee of may be paid.
- c. The Owner shall pay the Consultant for actual transportation and lodging expenses incurred during approved travel in support of this proposal.
- d. The Owner shall pay the Consultant for personal automobile use at the rate of g cents per mile for owner authorized travel.
(8)
l
'.(f) Hiller 3ntarporated ConeuNants Route 7 Sox 90 G Lynchburg, Virgima 24503 (804) 3644115 BV-360949 1
ATTAC}UENT 3 RESUAE'S 3
'. Uk fIf UfMI OIU I CNnuHents Route 7 Box m2 G Lyneneurg, Virgima 24503 (804) 3444115 THOMAS R. OSTERHOUDT, JR.
EXPERIENCE: 1 January 1981 - Present Vornser Engineering Inc. - Chief Designer Manager of Design / Drafting Department responsible to oversee and coordinate design engineering activities and per- ) sonnel on the development of Fluidized Bed Coal Combustion unit with cogener-ation capabilities on small to medium (10,000 to 120,000 lb/hr) industrial plants. Responsibilities include main-taining Document Control System. Esti-mating Manpower requirements, proj ect review analysis for compliance with budget and sche.duling and monitoring of work quality r.nd compliance to ASME Boiler and pressure vessel codes. Posi-tion requires contact with customer, suppliers and field erection and test personnel with intimate understanding of installation problems and a ' knowledge of engergy production equipment. September 1979 - GPU Nuclear - Consultant Septe:ber 1981 ~~ Recovery Project Engineering Manager (6/80 to 9/81) responsible for all project engineering activities assoc-isted with the recovery of Three Mile Island Unit II. Responsibilities in-eluded interface with vendors, archi-tect/ engineers, NRC, Operations, Main-tenance, Radiation Control, and Licens-ing. Also responsible for budget, scheduling, work performance evaluation performance to budget, and schedule evaluation. Recovery Engineering Project Engineer (9/79 to 6/80) responsible for the Sub=erged Domineralizer System. Act- _ ____ - _ _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - ~- _
THOMAS R. OSTERHOUDT JR. Page 2 ivities included mangement of vendor engineering, design and fabrication effort, coordination of site construc-tion activities, development of sys-ten description, initiation of licens-ing documents, specification of testing and quality requirements, development of procedures and specifications, work and budget scheduling on $15 million Radwaste System. February 1979 - Nashua Corporation - Consultant September 1979 Responsible'for development of Test Program and Manufacturing Evaluation Program on electro-mechanical equip-ment. August 1974 - Helix Process Systems February 1979 Manufacturing Proj ect Engineer (12/77 to 2/79) responsible for manufacturing and testing activities on Nuclear Radwaste Systems. Field Proj ect Engineer (7/77 to 12/77) in charge of installation, start-up and testing of two-unit Off-Gas System at Taiwan Power Company's Chinashan Nuclear Generating Station. Field Project Engineer (7/76 to 7/77) responsible for inta11ation. start-up, and testing of Oyster Creek Nuclear Station Off-Gas System. Also performed as a Start-up and Testing Engineer for Jersey Central Power and Light, the plant operator, on the installation of a new Auxiliary Boiler and a new Liquid / Solid Facility. Test Engineer (1/76 to 7/76) on Off-Gas Cyrogenic Separation. Gas Stripper, and Gas Chiller equipment. Design Engineer (8/74 to 1/76) respon-sible for packaging of Skid Mounted Gas Processing Systems. Responsibilities included piping layout and support. instrument selection, and interface
' THOMAS R. OSTERHOUDT JR. Page 3 with existing plant systems.
April 1974 - August 1974 JBF Scientific - Consultant Design of piping and pump system for ocean-going oil spill recovery craft. April 1971 - Thermo Electron Corporation'- Designer April 1974 Responsible for piping and instrument design on Plutonium Test Reactor. July 1969 - Raytheon Company - Designer April 1971 Responsible for piping and structural des;ign for Missile Site Radar System. June 1968 - Sunbeam Electronics - Lead Avionics July 1969 Designer April 1966 - Inland Motor Company - Design Chief June 1968 January 1966 - Sperry Microwave - Lead Instrument Ap.-11 1966 Designer August 1965 - RCA Electronic Data Processing Center - January 1966 Designer - July.1964 - Phillips Incorporated - Assistant Con-August 1965 struction Manager July 1963 - Florida Power and Light - Maintenance July 1964 Flanner , July 1960 - Pratt and Whitney Aircraf t - Design ( July 1963 Draftsman ED"ATION: ' 1975 - Framingham State College. Framingham. Present Massachusetts. Currently working on B.S. in Physics. 1971 - Bedford Institute, Division of Fitchburg 1972 ! State College. Math and Computer Courses. 1 1961 - Palm Beach Junior College, Lake Werth, 1961 Florida. Evenings: Completed 80% of ' two-year A.S. Program l l I i l a
)
Page 4 THOMAS R. OSTERHOUDT. JR. Additional Courses:
- True Position Tolerancing and l Dimensioning
- Supervision and Management Course
- Shop Math
- Metallurgy of Common Manufacturing Materials
- Valve 3. election and Sizing
- Instruasnt Application
- Design of Gearing and Gear Trains
- Refrigeration Courses (resulted in Mass. State License)
- Technical Writing Course
- PERT
- Basic Electronics Course
- Programming in Basic
- Water Chemistry Control and Ion Exchange Course
- Radiological Controls Course
- Basic Health Physics Course
- Course in Low Specific Activity Waste Packaging
.(QMk1II3NEUIf0IUffb Coneuttents _
Route 7 Box 90 G Lyreburg, Virginia 24:03 (404) 384 0115 ' MICKEY R. HAMBY EX PERIENCE: May 1982 - Present Florida Power & Light - Technical Staff Engineer Qualified Shift Technical Advisor with a SRO. Participated in local and integrated leak rate testing. Presently writing procedures and reviewing Plant Modifications to insure compliance with rules and regulations, technical specifications and applicable codes. July 1980 - May 1982 Three Mile Island Nuclear Station.- Technical Specifications Compliance / Results Engineer. Review Technical Specification surveillance results and plant oper-ations records to evaluate compliance with the Technical Specifications. This includes trend analysis and recommendations to prevent non-compliances. Report non-compliances when discovered to Plant operations Review Cdamittee and prepare Licensee Event Report as required. Serve as a full time member of the Plant Operations Review Committee to perform safety reviews of procedures, reportable events, plant operations and 50 59 safety evaluations. Worked as an Operation Engineer during startup of Submerged Domineralizer System. The tasks performed included assisting Start-up and Test department, writing Operating and Emergency Pro-cedures required for operation and interface with the NRC during their final approval checks. Qualified to operate the Submerged Domineralizer System, high level water domineralizer system and the Eqicor II System, inter-mediate level water domineralizer system. Obtained SRO license.
- _ - _ - _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _- _a
l l I
\
31ICKEYR.MAMBY No2
.May 1978 - July 1980 _U.S. Navy - Nuclear Power Engineering Officer.
Officar Candidate School - Graduated distinction 6th in class of 191. Navy Nuclear Power School - Graduated ! 3rd Nuclear in class of 89 Power Training Unit - Qualified ( as Engineer Officer of the Watch in land based Nuclear Power Plant. Qualified 2nd in class of 88. During maintenance shutdown served as crew shutdown co-ordinator, responsible for maintenance and testing performed on crew. - Submarine School - Graduated U.S. in top Navy 10 % of class,. Received honorable discharge, July 3, 1980. May 1976 - Sept. 1977 Southern Sizing Company - Quality Control Manager. Responsible for all quality control testing on incoming and outgoing products. Supervised on techniciah June 1974 - May 1976 ITT Rayonier. Inc. - Shift Supervisory Chemist. Responsible for supervision of all quality control and'inprocess testing of pulp products. Supervised fifteen technicians. CUCATION: June 1974 University of South Florida B.S. in Chemistry, GPA 3 22/4.00.
s
.(Quilter 3nrarporatch MaJte 7 Box M G Lynchbur0. Virgima 24503 . 404) 3644115 KENNETH C. LIONARONS EIPERI ENCE:
May 1981 - General Public Utilities - Senior Nuclear Present Engineer Recovery Engineering, Cognizant engineer on various plant modification and con-struction projects for the damaged Three Mile Island Unit 2. Responsibilities include concept development, engineering design. construction supervision, start-up and turnover to Operations Department. Project engineer on radvaste processing studies for D.C.E. including the study and removal of contaminated resin and asserted radwaste from inaccessible high-rad areas by remote means. Serving as the senior staff instrument and centrol engineer responsible for maintenance, design and modification of instruments-tion and modifying systems to provide surveillance on changing plant config-uration. The above duties involve directing activities of various architect /' engineers, union and non-bargaining per-sonnel, and interfacing with sponsoring government representatives. June 1977 - Consolidated Edison - Senior Engineer May 1981 Proj ect Leader - Special Proj e cts. Project Leader for major projects affecting reliability, economy, or government-man-dated operational and hardware changes. Supervised staff of 4 engineers and 13 technicians. Frequently utilized as Technical Superintendent for month long periods in fossil-fired and nuclear plants, which involved supervising instrument and control, performance, and che=ical engi-neering groups. Responsible for planning,
1 KENNITH C. LIONARONS Page 2 scheduling, budget, logistics, procedures and startup for operations and major plant projects. Projects included:
- Redesign and remodification of all instru-mentation to provide compatibility for computerized efficiency of chemical and
- operational sonitoring in 6 fossil fired plants.
- Specification design and installation of generator core-monitoring equipment in 7 generating plants.
- Eddy current testing of Indian Point
#2 steam generator and all enjor heat exchangers.
- Supervision of the startup and accep-tance of a $12 million waste treatment facility.
January 1972 - Technician / Associate Engineer - Indian June 1977 Point Nuclear Station Operati'ona Technician at Indian Point #1
-and Startup Technician at Indian Point
#2. and System Startup and Acceptance at Indian Point #3. Responsible for testing, modification and operation of instrumen-tation and operational systenst check-out and acceptance of systems, including . '
reactor control, chemistry, domineralizers, radvaste evaporators and other auxiliary systems. Performed chemical and radio-chemical tests necessary to insure safe, efficient operation, optimal water treat-ment, fuel cladding integrity, and radio-nuclide monitoring. During this time was promoted to a management position and acted as liaison between Westinghouse and Con Ed for acceptance, startue and hot functiona.1 testing of chemical instrument and radwaste systems. July 1968 - Chemical Engineering Technician January 1972 Initially employed as a technician. Opera-tions/ Chemical Engineering. Responsible for design fabrication, and installation of instrumentation, and instrument / con-trol systems, as well as automated sampling
l KENNETH C. LIONARONS Page 3 l l and chemical analysis equipment, in 8 fossil and 2 nuclear generating statiens. . 1 EDUCATIQN: January 1978 Richmond College, C.U.N.Y. ! Graduated - BS in Engineering Science Completed course requirements - MS in
, Engineering Economics January 1975 Staton Island Community College Graduated - AAS in Mechnical Technology June 1968 Queens Vocational High School Graduated - Technical Diploma - Special Program in Automation / Instrumentation h
l
. (fjatiter 3nrarpbratch ;
Onneuttants Maste 7 Box 90 G Lynchburg, Virgima 24503 (804) 3664115 JOSEPH F. ST. CLAIR EXPERIENCE: July 1982 - Present A.R. Criscuolo & Associates. Inc. Nuclear I & C Procedure Writer Develope I & C Procedures in the start-up organization at Waterford III Nuclear Generating Station, Killona La. Quali-fications for this job require technical expertise in all forms of instrumentation associated with a Nuclear Generating Station. Responsibilities included pro-cedure. writing for astrology lab equipment. techrical advisor to start-up and I & C department. Familiar with all N.R.C. regulations Q.A. requirements and IEEE specifications. Certified level II as per N.R.C. Metropolitsa Edison Company GPU 1980 - July 1982 , Nuclear.I & C Maintenance Forman
, Supervise a multi-diciplinopost accident maintenance force at T.M.I. Unit No. II.
This included instrument technicians, electricians, nochanics and welders. Also acted as liasion and technical advisor between the utility and the Department of Energy. Responsibilities included corrective and preventative maintenance on all equipment associated with the T.M.I. Unit II clean-up, recovery and normal plant equipment. 1979 - 1980 Nuclear I & C Technician Helped install and claibrate post accident clean-up systems such as EPICOR. Also reponsible for setting up Three Mile Islands first astrology lab. Duties also included
Page 2 JOSEPH F. ST CLAIR l being on several reactor building manned entry teams designed to moniter. Trouble-shoot and oliviate problem areas. 1977 - 1979 Nuclear I & C Technician Duties consisted of general plant work such as correcting design errors, loop a calibration weather station and security system calibration, writing procedures and ordering spare parts. Participated in the Unit No, I (1979) refueling outage. 1973 - 1977 Nuclear I & C Technician Duties consisted of start-up system check out and general plant maintenance. Worked on and familiar with all general plant instrumentation such as recorders. controllers, valves, positioners, trans-mitters, gauges, switches, etc. Also worked on specialized plant equipment such as control rod drive. radiation monitoring equipment, reactor protection systems and the plant integrated control system. Participated in the Unit No. I start-up and refueling outages. January 1971 - Nuclear I & C Technician March 1973 Underwent instrument technician training program at the T.M.I. training center. Training consisted of formal classroem and in plant training on systems. instru-monts and components. Some of the sub-jects studied included physics, math, chemistry, electronics, pheumatics and hydraulics. Also assisted start-up engineers during het functional testing of plant integrated control system, reactor protection system and safety features actuation system. May 19 - 1971 Auxiliary Bay Operator In charge of operating support equip ent designed to influence the generated power output of the plant. Responsibi-lities entailed placing the correct
Page 3 JOSEPH F. ST. CL IR equipment on the line in the proper sequence to maintain megawat demand. Also worked as a mechanic in the mech-
. anical maintenance department during a change over from coal to oil.
January 1969 - Western Electric - Pield Engineer May 1969
' Modifications to Post Branch Exchange
) and Central Telephone Exchange equip. ment. This entailed engineering and re-designing of existing equipment. Spent two weeks at Post Branch Exchange School in Mechanicsburg, PA. March 1968 - North Electric Co. - Electronic Technician January 1969 Install and sodify crossbar Relay and Electron System Telephone Exchanges. Helped install the central telephone exchange in Hershey, PA. Vent to two weeks of wiring and soldering school. Vent to three weeks of crossbar relay and telephone exchange school. Mar:h 1966 - Central T.V. - Television Service February 1968 Technician Repaired televisions, radios and stereo systems. This was a part time job while I was attending Gateway Tech. (Electronics) EOUCAT!ON: Washington High School, Washington. PA , June 1961 June 1966 - March 1968 Gateway Technical Institute. Pittsburgh, PA, (Graduated - Specialized Technology in Electronics) January 1971 - Three Mile Island Nuclear Power and Instrument Training School March 1973 Lebanon Valley College, Annville. PA, August 1979 - (Working towards B.S. in Physics) December 1981 Nuclear Engineering Technology - Home 1970 Study Course Electro / Hydraulic Turbine Control School 1972 1972 Foxboro Electronic and Pneunati: School
)
JOShys 7. ST. CLAIR Page 4 1973 Bailey 7,21 - Integrated Control System 1973 Nuclear Power Preparatory Training 1973 Eberline Radiation Monitoring Systems 1974 Bailey 855 - Computer School , 1977 Leeds and Northrup Recorder and Controller School M!1:7 ART: l June 1961 - U.S. Marine Corps - Corporal (E 4) January 1966 Communications Specialist Duties included maintenance and repair of field communications and associated equipment. Granted a top secret security clearance for overseas assignments. Hencrable Discharge. 9 _ ._-_ _ - _ . - - _ - _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ^ ~~ ~
. (Quilter 3nrarporateh Geneuttants g .
RmJte 7 Sm 90 G j Lynchtpurg, Virgime 24fc3 l (804) 3M4115 l OEORGE T. ALLBR00K i January 1982 - Waterford III Nuclear Power Plant { Present Instrument Technician , ; Working on systess in check out and start up. Working towards fueling and start up of unit. June 1981 - Texas City Refinery - Instrument January 1982 Superintendent Supervised twelve (12) technicians in complete change out of control room to Fisher A.E. Square. Worked start up on line processing of unit. Jar.uary 1981 - Arkansas Nuclear One. Instrument June 1981 Technician Worked in unit I and II on fuel outage. Worked on systems needed to complete outage and restart of both units to operational outputs. January 1980 - Three Mile Island Nuclear Power Plant January 1981 Instrument Tecr.nician January 1980 - Three Mile Island Nuclear Power Plant November 1980 Instrument Technician Mercury Working to supplement Unit II instrument shop. To help in the containment of Unit II. Maintaining needed systems cf Unit II. Will move to Unit I for technical check of instrument systems in preparation of startup. January 1979 - SECO International. Peru - Instrument January 1980 Superintendent In charge of installation. calibration, and start up of installations in the petroleum operations in Peru for Oxecidental Petroleum.. Also, instruct the local personnel in insta11stien
1 I Page 2
'. GEORGE T. ALLBROOK and calibration for startups.
May 1977 - Three Mile Island Nuclear Power Plant - January 1979 Instrument Startup Engineer Mercury Worked to supervise Unit II's Maintenance Shop. and also to include new scdification 1 of systess. Moved to Unit I for a fuel
- outage to pull leak rate of major primary )
- and secondary systems working into startup and bring up of unit to operational outputs.
February 1971 - Instrument Calibration Foreman - Planned. May 1977 supervised. controlled, and coordinated the activities and tasks of 5 to 12 instrument calibration technicians on a variety of petro-chemical process control systems. Working in conjunction with engineers. supervised the installation and maintenance, testing, and final implementa-tien of control systems for international and local companies. Other duties included bench and field testing and calibration of transmitters, controllers. levertrols. recorders, test gauges, intergrators, pres-sure switches using the latest test equip-ment. Performed electronic loop checking which included leak and function testing. hydraulic pressure checking. and installa-tion of air signal lines. Additional re-sponsibilities included the training of subordinates in proper fitting. installation of air signal lines, troubleshooting tech-niques, and ascertaining that installation and maintenance specifications and require-ments are net. May 1976 - Epic Instruments. Inc. - Instrument Startup May 1977 Technician December 1975 - M.W. Kellor. Shell Refinery - Instrument May 1976 Calibration Foreman January 1975 - Carpenter Construction Co. Shell Refinery - December 1975 Instrument Calibration Technician February 1974 - Cresent Instrument company - Instrument January 1975 Calibration Technician June 1973 - Southwest Construction Company - Instrument February 1974 Calibration Technician February 1971 - Instrument Titter - Local Union No. 211 June 1973
' GEORGE T. ALLBRbOK Page 3 December 1967 - Pipe Fitter's Local I Apprenticeship School -
February 1971 Pipe Fitter's Local Union I. New York City. Pipe Fitter's Apprenticeship Program. Sche:1 and working in all areas of pipe fitting. November 1964 - Helicopter Crav Chief. U.S. Aray - Entered November 1967 Viet Nas as crew chief of a UHIB helicopter. Flow with the helicopter and maintained flight worthiness. During this extended
- tour, I took over as Maintenance Sergeant in charge of the unit's rotary aircraft and the supervision of 30-45 sechanies. To insure proper maintenance was performed and the company's air worthiness so flight operation could be maintained.
EDUCATION September 1974 - San Jacinto Jr. College, Houston. Texas M3y 1977 Major: Instrument Technology September 1968 - Suffolk Community College, Long Island NY January 1969 Major: Mechanical Engineering 3?I!*AL TRAINING 1971 - 1972 Instrument Calibration and Maintenance Course - Diploma 1964 - 1965 Seven U.S. Army Military schools - Diplocas
- Air Frame and Structural Aircraft Systems - January thru March 1965
- Reciprocating Engines - March thru May 1965
- Lycoming Turbine Engines - May thru July 1965
- Electronic Systems, troubleshooting
- and repair course - July thru August 1965
- Hyrdaulie Systems. troubleshooting and repair course - August thru September 1c65
- Fixed Wing Maintenance Course - September thru October 1965
- Ro*.ary Wing Maintenance Course - Cetober thru December 1965 Total hours 1200.
gi;!!ARY SERVICE November 1964 - U.S. Army - Rank SP 5 Maintenance Sergeant 1965 in charge of helicopter maintenance f,FF 1:ATIONS Pipe Fitters local 211 American Legion V.F.W.
.nstruments Society of America
;(QUk1ff[ 3NENIhh IUkIh Ceneuttants _
Rwte 7 Box 90 G i Lynchburg, Virginia 24503 (804) 3s4411s KINSLEY P. DRAPER March 1980 - GPU Nuclear Corporation - Lead Operations Present Planner - TMI Responsible for all planning and scheduling functions associated with the construction, testing, operation and outage coordination of the Submerged Desineralizer System September 1979 - GPU Nuclear Corporation - Planning Engineer February 1980
. Rework and reschedule maintenance and construction schedules, schedules manpower, estimate labor and evaluate progress for construction and maintenance contracter at Three Mile Island Nuclear Power Plant Unit II Nove=ber 1978 - Florida Power Corporation - Planning August 1979 Engineer Estimate costs, estimate labor manheurs, schedule labor, evaluate progress and estab.
lish cost controls for maintenance contract:.- at Crystal River Unit 3 N0 clear Power Plant June 1978 - Florida Power Corporation - Scheduler and October 1978 Planning Engineer Temporary assignment to Florida Power Corp. to rework and update unserviceable planning and scheduling systems in use for outage caused by Burnable Poison Rod debris in Steam Generator System April 1978 - American Electric Power Company - Planning May 1978 Engineer Estimated costs, scheduled labor, established cost controls, evaluated progress and pro-cessed change orders for Cook Nuclear Power Plant Steam Generator Modifications March 1975 Baltimore Gas / Electric - Field Planner Evaluate progress and reschedule planning for Calvert Cliffs Nuclear Power Plants outage modifications and maintenance
' ' Page 3 KINSLEY P. DRAPER contracts, determine progress for cost I control and invoice payments, material l purchasing and warehousing. Also acted as the supervisor during the civil and structural installation phase of several projects for Huntley Corporation 1968 - 1972 Acme Constructors Inc. - Chief Estimator and Field Supervisor Turnkey constructors for manufacturing plants, refineries, banking f acilities ,
computer centers and airport utilities in Florida, the Caribbean, Central America and the northern coast of South America. Responsibilities were to prepare bid packa6es for final presentation, bid contracts and negotiations. coordination of steel, mechanics and electrical estimates, supervision of subcontracts for the purchase and control of special mechanical items, takeoffs and pricing of siteworks, foundations archi-tectural, structural and steel erections costo estimates and pricing 1961 - 1964 Slab Manufacturing Co. - Plant Manager Supervised machine shops, velding, concrete precast plant and training of personnel for erection, installation and manufacture of lightweight concrete prefabricated low cost housing. Designed houses, prefabrication panels, velded frames and electrical, plumbing and service components. Redesigned machinery, jigs and solds used in pilot plant, analyzed operational costs of methods and procedures for operation plant 1951 - 1961 Caribe Supplies Inc. P.R. (partti=e & fullti:i
- Field supervisor. Supervision of constructive:
installation and maintenance of service stations Calor / Emag Frankfurt / Main Germany - 1957 - 1958 Work Student Graduated Apprentice Machine design E000A*!ON: Rhode Island School of Design Industrial Design B.F.A. 1961
- - - - - ~ - _ _ - - , _ _ _ _ _ _ - _ _ _ _ _ _ _ _
Quiller 3nrarporatch Caneuttants g Rate 7 Sox DO G Lynchtrurg, Virginia 24503 (804) 344 0115 BERNARD G. SMITH EIPERI ENCI 1958 - Metropolitan Edison Company - TMI Present 1981 - Present Manager. RadWaste Operations - Responsible for the novament of all radioactive and processed water including resin preparation, processing, and preparation of expended resin vessels for shipment. This includes the operation of the Submerged Semineraler System and teh Epicor II processes. Super-vise approximately fifty men. Maintain SRO license. 1978 - 1981 Shift Supervisor - Particips'rd in and supervised the shutdown and ecS)down of the TMI Unit II Reactor. Was involvad in the decontamination of the entire facilit j. Also was involved in the testing and operating of the new Plant Recovery System. Supervise approximately forty technical employees. Maintain current SRO license. 1974 - 1978 Shift Supervisor - Was directly responsible for the operation of two nuclear power plants on shift with responsibility for the entire site as senior person on the site. Maintained an NRC cross license for both units. Wrote and reviewed operating procedures and instrue-tions of Shift Foreman and Control Roo Operators for the Unit II preoperational test program. 1968 - 1974 Shift Foreman - Directly responsible for the operation of this nuclear power plant on shift. Supervised operators on shift and participated in Unit I preoperational test program. Wrote and reviewed operating pro-cedures and instructions of Control Roe = Operators. Organized, prepared, and taught a 42 week in-house training course on nuclear theory and plant operation. Attended Pennsylvania State University for a nuel. ear theory : curse
\
BERNARD G. SMITH Page 2 as well as numerous vendor training courses on power plant equipment. 1959 - 1968 Control Roca Operator - Responsible for operations in the Control Room of the two fossil plants. Participated in the pre-operational test program and start-up of Unit II. Gain diverse experience in all aspects of operations including Pump Roe = , Operator. Unit Boiler Foreman, and Turbine l Operator. Lineman - Initially joined company in the capacity of Lineman. Functioned in all areas I of line construction including house servi:es, j transmission lines, distribution, substatio:. l vork, and towers. Was involved in both old l and new construction. I 1957 - 1958 Staples Line Construction - MI1ITARY: 1955 - 1957 United States Army - Served as Sergeant in the military as a heavy weapons specialis-4
{ guater 3itrariaratch Consultants Maste 7 Box M G Lynchburg, Virgima 24503 (804) 3M4115 JAMES R. FLOID EIPERIKNQ[: 1979 - Operations liasion for the Recovery Office Present of General Public Utilities at Three Mile Island Unit 2. Provde interface between Bechtel and Plant Operations to accomodate the decontamination and data acquisition tasks. Review and observe entries into the Reactor Building. Conducted a detailed - review of the events surrounding March 28,197 1975 - Supervisor of Operations at THI-2 for 1979 Metropolitan Edison Company. Directed a staff of approximately 70 persons to learn the unit and acquire NRC licenses both SAO and RO as well as Auxiliary Operators. Wr:te, reviewed, executed, and revised test, startt , operating, energency, and surveillance pro-cedures. Engaged in Emergency planning and drills. Served as a member of the Plant Operations Review Committee. Maintained a two unit Senior Reactor Operating license. Reviewed and implemented the Technical Speci-fications. Conducted the pre-op and functions tests for the startup of this 950 MWe unit. Directed the initial fuel leading, initial criticality, and power escalation testing including commercial operation. 1971 - Supervisor of Operations at THI-I. Sace 1975 as above except SRO license on Unit I only. Served in this capacity through the cocpletion of the first year of commercial operation. 1968 - Engineer - TMI-I. Served as Nuclear Engineer 1971 to learn / review the unit. Participated in system description and procedure preparati:n and review as a member of the Plant Operatiens Review Consittee. Assisted in operator training. Reviewed digital computer pr:gracs. Served on ANS30/50. 1965 - Supervisor of Operations and Tests at 19o8 Saxton Nuclear Experimental Corporation f:r e
I
*
- Page 2 4
,. JAMES R. FLOYD General Public Utilities. Directed the operating staff of this 23.5 MWt Westinghouse one loop nuclear steam supply system to generate 5 Mwe into the PJM grid. This uni-was used exclusively by Westinghouse as a-research and development platform for fuel, cladding, and fuel pin pressurization experi-monts. It also incorporated a supercritical test loop, i.e. steen at 4000 psi, 750 F.
and 15 gps, to remove heat from uranium fuel. Westinghouse also used the facility for customer training during the 1960's so that we the operating staff had a continuous active interface with trainees. Saxton was the first consercial nuclear reactor to use boren for chemical shia control operation and for selected chemical regulating control operatien Maintained a SRO license. Student at Columbia University. Received a 1964 - B.S. in Chemical Engineering. Employed part-1965 time (20 hr/vk) as a Research Assistant in the Nuclear Engineering Department working for Prof. Melkonian. Fabricated solid state silicon detectors for use in basic research of the fission process. 1958 - United States Navy - Electronics Technician 1964 list class. Nuclear Reactor Plant Operator / Technician. Leading Reactor Control Instructe: at A1W, Idaho Talls, Idaho during 1962 - 1963. Attended Instructor Training school. Quali-fied on all watch stations. Instructed the Naval Officers in the areas of reactorGrad-control. instrumentation, and nuclear safety. usted from thr Officers Training Program in Vallejo California. 4 _ _ _ __________m _
y
)
Quilter 3nrarporatch Route 7 83 90 G Lynchburg, Virgaio 24503 (804) 384+ 15 RICHARD D. PARKS IIPERIENCE: j 1982 - Present Bechtel Northern - Senior Startup Engineer Respons.sle for providing engineering services to utility plants during constructi:n startup, and operation of power plants. Ser-vices incl}}