ML20100G619

Notice to Commission,Aslab,Aslb & Parties Forwarding Pr Clark to HR Denton Forwarding Eh Stier Rept Re Alleged Harassment of Rd Parks Per Suppl 5 to NUREG-0680. Svc List Encl

ML20100G619
Person / Time
Site:	Crane
Issue date:	04/04/1985
From:	Blake E GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP), Atomic Safety and Licensing Board Panel
References
CON-#285-386, RTR-NUREG-0680, RTR-NUREG-680 SP, NUDOCS 8504080319
Download: ML20100G619 (75)

Text

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April 4, 1985 R.U QED n t.a u 85 APR -5 A11 :30 i

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 0FFICE OF SECRETARY 00CKETING & SERvict,'

BRMICH 3:

In the Matter of

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METROPOLITAN EDISON COMPANY

)

Docket'No.~50-28.9.,SP _ _

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(Restart)

-(Three Mile Island Nuclear

)

Station, Unit No. 1)

)

Notice to Commission, Appeal Board, Licensing Board and Parties Enclosed for information of Commission, Appeal Board, Licensing Board and parties is copy of a letter from P. R.

Clark, President, GPU Nuclear Corporation to Harold R. Denton, Director, Office of Nuclear Reactor Regulation, dated March 29, 1985, forwarding a copy of a memorandum report from Edwin H. Stier to Mr. Clark providing information regarding the alleged harassment of Richard D. Parks.

Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE b/1.IlML.

/

Ernest L.

Blake, Jr.,

P.C.

Counsel for Licensee cc: Service List Enclosure g4000319850404 g

ADOCK 05000289 h --

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of

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METROPOLITAN EDISON ~ COMPANY

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Docket No. 50-289 SP

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Restart (Three Mile Island Nuclear

)

Station,-Unit No. 1)

)

SERVICE LIST Nunzio J. Palladino, Chairman Administrative Judge U.S. Nuclear Regulatory Commission John H.

Buck Washington, D.C.

20555 Atomic Safety & Licensing Appeal Board Thomas M. Roberts, Commissioner U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Washington, D.C.

20555 Administrative Judge James K. Asselstine, Commissioner Christine N. Kohl U.S. Nuclear Regulatory Commission Atomic Safety & Licensing Appeal Washington, D.C.

20555 Board U.S. Nuclear Regulatory Commission i

Frederick Bernthal, Commissioner Washington, D.C.

20555 U.S. Nuclear Regulatory Commission Washington, D.C.

'20555 Administrative Judge l

Ivan W.

Smith, Chairman Lando W.

Zeck, Jr., Commissioner Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Washington, D.C.

20555 Administrative Judge Administrative Judge Gary J. Edles,' Chairman Sheldon J. Wolfe Atomic Safety & Licensing Appeal Atomic Safety & Licensing Board Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.

20555 l

Washington, D.C.

20555 i

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-Administrative Judge Mr. Henry D. Hukill Gustave A. Linenberger, Jr.

Vice President Atomic Safety & Licensing Board GPU Nuclear Corporation U.S. Nuclear Regulatory Commission P.O. Box 480 Washington, D.C.

20555

-Middletown, PA 17057 Docket ng and Service Section (3)

Mr. and Mrs. Norman Aamodt Office of the Secretary R.D.

5 U.S. Nuclear Regulatory Commission Coatesville, PA 19320 Washington, D.C.

20555 Ms. Louise Bradford

. Atomic Safety & Licensing Board TMI ALERT Panel 1011 Green Street U.S. Nuclear Regulatory Commission Harrisburg, PA 17102 Washington, D.C.

20555 Joanne Doroshow, Esquire Atomic Safety & Licensing Appeal The Cnristic Institute Board Panel 1324 North Capitol Street U.S. Nuclear Regulatory Commission Washington, D.C.

20002 Washington, D.C.

20555 Lynne Bernabei, Esq.

G ver mant Accountability

. Jack R.

Goldberg, Esq. (4)

Office of the Executive Legal

?.555 Connecticut Avenue Washington, D.C.

20009 U.S N c ear Regulatory Commission Washington, D.C.

20555 Ellyn R. Weiss, Esq.

Harmon, Weiss & Jordan Thomas Y. Au, Esq.

2001 S Street, N.W.,

Suite 430 Office of Chief Counsel Washington, D.C.

20009 Department of Environmental Resources Michael F.

McBride, Esq.

505 Executive House LeBoeuf, Lamb, Leiby & MacRae P.O. Box 2357 1333 New Hampshire Avenue, N.d.

.Harrisburg, PA 17120 Suite 1100 Washington, D.C.

20036 4

Michael W. Maupin, Esq.

Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, VA 23212 i

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o GPU Nuclear Corporation C MI 100 lnterpace Parkway f

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March 29,19(4FICE NF SEckETMiY 00CXETWG & SERVICf.

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Mr. Harol.d R. Denton, Director

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Office of Nuclear Reactor Regulation United States Nuclear Regulatory ConWffsTo($ _....__.

Washington, DC 20555

SUBJECT:

THREE MILE ISLAND UNIT 1 DOCKET NO. 50-289 NUREG 0680 SUPPLEMENT 5 My letter of March 12 forwarded infomation provided by Bechtel relative to the portion of Supplement No 5 dealing with alleged harassment of Mr. Parks and requested that it be reviewed and considered by the Staff.

Shortly thereafter I requested Mr. Stier to review that subject and identify for me any additional information on this matter on the public record which had not been cited in Supplement 5 and thus might also have not been considered.

Mr. Stier's memo to me of March 29 is enclosed for your consideration and by copy of this letter for consideration by the Cffice of Inspection and Enforcement review.

Very truly yours, P.R.Cl ark President mak Attachment cc: Mr. James M. Taylorg Dir$ctor NRC Office of Inspection and Enforcement Kennedy P. Richardson, Esquire Thelen, Marrin, Johnsen & Bridges fi

\\ r.H.W.Wahl Bechtel Power Corporation E.L.Blake' Esquire

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Shaw, Pittman Potts and Trowbridge

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GPU Nuclear Corporation is a subsidiary of General Public Utilities Corporation

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TO:

Philip R.

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FROM:

Edwin H. Stier DATE:

March 29, 1985 i

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SUBJECT:

NUREG-0680 Supplement 5 f

. BACKGROUND At your request I have reviewed the portions of NUREG-0680 Supplement 5 (supplement 5) that deal with the alleged harassment of Richard D.

Parks.

I will describe in this memorandum the evidence that is not cited in supplement 5, but l

l is relevant to those issues.

The portions of, Supplement 5 l

dealing.with harassment of Parks are Sections 10.2.1 entitled, y

"R.

D.' Parks Investigation Results" and 10.3.1 entitled, "R.

D.

i Parks' Staff Findings."

section 10.2.1 discusses icur specific allegations made by Parks and cites two sources of evidence:

the Parks affidavit dated March 21, 1983 and the report of a U.S.

Department of Labor (DOL) investigation of Parks' allegations.

Section 10.3.1 h

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of Supplement 5 concurs in the findings of the DOL report that Parks was subjected to harassment by " management officials of

-Bechtel with the knowledge of GPUN."

In addition to resolving

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each of the four allegations of harassment in favor of Parks, Supplement 5 finds that three further actions by TMI-2 management were improper.

This memorandum does not address whether the factual citations in Supplement 5 are correct or whether its conclusions are consistent with the evidence.

Its sole purpose is to identify any evidence known to me and on the public reccrd that I believe.is relevant to the findings in Supplement.

5 and that was not cited in that document.

l In discussing Parks' harassment allegations, Supplement 5 does not cite the evidence contained in our report of November i

16, 1983 entitled "TMI-2 Report / Management and Safety Allegations."

Supplement 5 states in reference to the report:

" Parks' allegations of harassment were not investiga6ed by the licensse and are not addressed in the Stier Report (November 16, 1983, Vol.III, Harassment Allegations)."

(Supplement 5, p.

I 10-19); and "The Stier Report (May 18, 1984, OI Report Ex.102),

although it does review two of Parks complaints in Volume 4, is incomplete in its review of Park's allegation of harassment."

(Supplement 5,

p. 13-10)

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. These statements are essentially correct.

We did not investigate Parks' harassment allegations as such.

However, several of Parks' allegations were ind.<stigated not as harassment issues but rather as issues relevant to TMI-2 management's attitude toward procedural compliance.

Sworn testimony.was taken that bears directly upon whether Parks was subjected to harassment, even though that evidence was-not categorized as harassment evidence for purposes of analysis in our report.

This evidence was not cited in supplement 5 and thus was apparently not considered by the NRC staff.

It should be noted that in other portions of Supplement 5 dealing with the harassment allegations made by King and Gischel, our evidence was cited and relied upon. - This is because our evidence was incorporated into the OI report dated May 18, 1984.

That OI report was used as the primary source of.

evidence to resolve all of the harassment allegations considered in Supplement 5.

However, the OI report.did not contain its own analysis of the facts relating to Parks

harassment claims.

Instead, OI accepted the report prepared by the' DOL and incorporated the DOL report in its own report.

- Supplement 5 does not indicate that the NRC staff went beyond the contents of-the OI report in gathering evidence.

Therefore it appears that they r4stricted themselves to the evidence

- contained in the DOL report which was issued before the publication of our report.

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Staff Findings in Supplement 5 The following is a list of the findings in Supplement 5 relating to Parks' harassment allegations.

Each is followed by a summary of relevant evidence that I believe was not considered by the NRC Staff.

1)

"The Removal by Thie; sing of Parks as Alternate Startup and Test Supervisor at TMI-2 on February 23, 1983, was inappropriate." (emphasis added) (Supplement 5, p. 10-17)

This issue was dealt with in our report as a part of an analysis of Parks' allegations concerning the approval of.the Polar Crane Load Test procedure.2 That report contains the following discussion of this issue:

Replacement of Parks as Alternate Startup and Test Supervisor Another of Parks' allegations is that at the February 23, 1983 meeting held to discuss 1..r comments on the Load Test procedure, Thiesi.c 1

Bechtel prepared a report concerning Parks' harassment allegations dated October 1984.

Since their analysis and supporting evidence is clearly presented in that document, I will not incorporate it in this memorandum.

2 TMI-2 Report / Management and Safety Allegations, Vol.IV, Polar Crane Allegations, pp. 79-81 9

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1 informed him that he had issued a memorandum replacing Parks as alternate Startup and Test Supervisor.

The implication is that Parks' removal was an act of reprisal for issuing his comments on

- the Load Test procedure.

Parks also alleges that his replacement was unqualified to act as alternate Startup and Test Supervisor.484 A review of the relevant documentation and testimony indicates that Parks' allegation cannot be supported.

AP 1047 establishes the Startup and Test group and designates the Startup and Test Manager or his alternate as the chairman of TWG.485 AP 1047, Section 2.1, define's an " alternate" as someone having the same " responsibility" and " authority" as the permanent member of TWG.

Therefore, since the chairman was from the Site Engineering Department, his alternate should also be from that department.486 l

According to Kitler, who served as Startup and Test Supervisor and Chairman of.the TWG prior to l

January 1,.1983, there was no one within the TMI-2 organization'other than Parks who was qualified to act as his alternate.487 He testified:

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I needed an alternate, mainly to review and approve return to L

service forms, during my absence.

i Rick Parks, who was assigned to l

Site operations,,was qualified and l

had acted in that position on occasion when he worked for NUS Corp. at the Island.

I requested and received approval from my l

supervisor Dave Buchanan and l

Rick's supervisor Larry King, to l

appoint Rick as m alternate on l

December 6, 1982. 88 As a result, Kitler initially designated Parks as his alternate out of necessity even though Parks was not from the Site Engineering Department as required by AP 1047.489 Kitler testified that in February, Parks insisted on verbatim compliance with AP 1047.

At that time, the way TWG membership was constructed, Site Operations would have had the majority vote, S

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In order to correct this l-imbalance and to maintain a system of checks and L

balances and ensure Site Engineering had a voting l

I member, Kitler decided to update the TWG membership I

to conform to the requirements of AP 1047.490 Dwight Walker, Startup and Test Engineer, had l

commenced employment at TMI-2 in January 1983.491 Kitler believed Walker was qualified to be his L

alternate.- He has been a Startup and Test engineer since 1976.

Prior to that, he was a, design engineer.

Furthermore, Walker was from within the same organization as Kitler, Site Engineering.

Therefore, Walker was more appropriately qualified to be the Startup and Test Supervisor'c alternate.492 Accordingly, on February 18, 1983, Kitler issued two i

memoranda designating Walker as the alternate Startup

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and Test Supervisor and alternate TWG Chairman.493 Kitler stated that the decision to designate a new alternate chairman was his alone.494 This is confirmed by Buchanan and Thiesing.495 Kitler cleared the decision to name Walker as his alternate I

with his supervisor, Buchanan, head of Site Engineering, and a GPUN employee.

But the initiative was-Kitler's.496 l

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Parks has also alleged that Walker admitted to him at a TWG meeting that Walker had little or no knowledge either of the Testing Manual or the Modifications Control Program.497 Walker denies ever making such a statement but indicates that, prior to a TWG meeting, he once told Parks that he had never attended a TWG meeting and asked Parks how the meetings were conducted.498 Thus, according to Walker, Parks has completely mischaracterized the incident and conversations referred to in the affidavit.

(Footnotes, excerpts

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, as Attachment A).

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"Although-there may have been, initially, a valid reason

'for Bechtel to investigate allegations that Parks might j

have been involved with Quiltec, because of his friendship and close' working relationship with King, the March 14, 1983, interrogat' ion of Parks by Wheeler, his administrative supervisor, and Hoffman, Bechtel internal affairs, was improper and constituted intimidation of Parks.

(supplement 5, p. 10-17).

Our report did not specifically cover the March 14, 1983 meeting between Parks, Hoffman, and Wheeler because the meeting involved only Bechtel personnel and was therefore outside of the scope of our investigation.

However, our report did contain evidence that may be helpful in understanding how that meeting came about.

On February 24, 1983 Lawrence King was suspended by.GPUN because of his involvement with a corporation known as Quiltec.

King was a major shareholder and the company's chief executive officer.

His association with Quiltec constituted a conflict of interest because of Quiltec's efforts to recruit employees at Three Mile Island.

Immediately after King's suspension, Robert Arnold, then President of GPUN, began an investigation of Quiltec's activities at Three Mile Island.

Arnold requested that King answer 21 questions concerning Quiltec and he interviewed several individuals who had knowledge of Quiltec activities.

Arnold also received a memorandum dated March 4, 1983 from Larry G.

Santee describing an interview with a secretary at TMI.

In essence, the 4

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m 8-secretary stated that she had been employed by Parks to prepare a number of, resumes for Quiltec.

Many of those resumes were of GPUN employees.

The secretary could not remember all the names

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that appeared on the resumes, nor did she know what connection Parks had with Quiltec or '.ts recruitment efforts.

Arnold questioned King abouc the preparation of the resumes and came away with the feeling that King was giving him a "very noncommittal, nonspecific response."

He had requested that

.Bechtel look into the conduct of that company's employees with

' respect to Quiltec.

It appears that Arnold's request for

-information led to the interview of Parks on March 14, 1983..

On the following day, the results'of the interview were reported to Arnold by Bahman Kanga, director of TMI-2.

Arnold used that information in deciding upon the action to be taken concerning King.

(Relevant excerpts from testimony and documents are attached hereto as Attachment B.)

3)

"The removal by Kanga (Director, TMI-2) of Parks on March 17, 1983, as the primary SO Department representative on the TWG for the reactor building polar crane project was improper.

(emphasis added) (Supplement 5, p. 10-18)

This issue is covered in the section of our report dealing with the Load Test procedure.3 In that report we describe 3

TMI-2 Report / Management and Safety Allegations, Vol. IV, Polar Crane Allegations, pp. 81-84

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the circumstances surrounding Parks' removal as the SO I

representative on the TWG as follows:

Parks' Removal as Primary TWG Member Parks asserts he was being pressured into signing and approving the Load Test procedure as late t

as March 17, 1983.499 He implies that at that time, Kanga removed him as a primary TWG member as a result of his concerns with the Polar Crane Load Test procedure.500 Parks introduces the issue by stating, "Around 1:00 p.m. that day, I informed Joe Chwastyk that I could not approve the polar crane load test, because of the serious violations that permeated the program."501 "Around 3:30 p.m.

that afternoon, I was called back to B. Kanga's office for a meeting I

with him and Chwastyk."502 The subject of the meeting, according to Parks, was a letter of March 17,-1983, removing Parks as primary TWG member for the polar crane review.503 Parks emphasizes he was removed as primary TWG [ representative] for polar crane "only."504 He does not describe what, if anything, happened immediately prior to the meeting or whether he had any prior notice of Chwastyk's letter.505 Parks does state, however, that Kanga asked him twice to agree that his removal was not an act of intimidation.dO6 According to Parks, "I

responded, 'In mv opinion, the intent is well-defined.'"507 Beyond that cryptic remark, Parks does not explain the nature or substance of the conversation with Kanga during the course of this meeting.508 According to Chwastyk, Parks approached him and

" suggested that he [ Parks] may be so close to this project that he is no longer [able] to. distinguish real from perceived problems."509 Chwastyk spoke with Parks and suggested that he consider resigning as primary T'G representative for the polar crane.

W According to Chwastyk:

He thought it was a good idea, so I told him, Okay, I'll draft up the letter and we'll go over it and make sure you agree with it and I'll put it out.510

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, Chawastyk then drafted the letter replacing

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Parks with another Site Operations member, Marshall.

The letter reads in relevant part:

This action is considered appro-priate for the present situation andHis not considered a negative reflection of Mr. Parks' ability,

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The designation of Mr. Marshall should not adversely effect the Polar Crane Refurbishment Schedule.511 Parks and Chwastyk reviewed it together and Chwastyk claims Parks was satisfied with its content.

Chwastyk also indicates Parks may have even edited the letter.512 Subsequent to writing the letter, Chwastyk telephoned Kanga to explain Parks' desire to'be removed as primary TWG Crepresenta-tive]. 513 Kanga substantially confirms Chwastyk'.514 According to Kanga, Chwastyk telephoned him and explained that Parks was under pressure and expressed a desire to be relieved of his duties on TWG.515 Kanga and Chwastyk met with Parks in Kanga's office.

Both also agree that Parks approved of his removal.516 Kanga-in_ describing his telephone call

. from Chwestyk testified:-

Parks was quite nervous that day and that he felt that it would be helpful to Parks if Parks was replaced as primary member for TWG the Polar Crane project only which would reduce pressure on Parks.517 Chwastyk then went to Kanga's affice where they reviewed the letter.

Kanga testified:

I asked him [Chwastyk] if... Parks had indicated any objection to the memo.

Chwastyk told me that he had not, that Parks in effect welcomed that memo 518 4

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Following this discussion, Kanga asked Parks to come to his office.

According to Kanga:

Mr. Parks basically affirmed...

that he understood what the memo said and that it was not being interpreted by Mr. Parks as being intimidation or a reflection on his work.519 Kanga and Chwastyk both state the Chwastyk signed the letter removing Parks as primary TWG Crepresentative for the polar crane following these discussions.520] Neither Kanga nor Chwastyk recall whether Parks in fact'used the words:

the intent is well defined" in response to Kanga's question.521 Both Kanga and Chwastyk agree that Parks left the clear impression that he willingly accepted the letter and his removal from TWG.522 Parks implies that his removal was motivated by his refusal to approve the Load Test procedure.

He presents a description of these events without describing his previous knowledge of Chwastyk's letter and without detailing his conversations during the meeting with Kanga.

Kanga and Chwastyk described l

what occurred consistent with Parks' affidavit except that Kanga and Chwastyk have added details left out by Parks.

Parks was not improperly removed from TWG.

(Relevant footnotes, excerpts from transcripts, and documents are attached heret a as Attachment C. )

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l 4)

"The action by Wheeler on March 24, 1983, placing Parks on leave of absence with pay and prohibiting his entry to the job site without permission from Bechtel was improper."

L (supplement 5, p. 10-18)

We did not investigate this issue, nor do I have, specific evidence to call to your attention.

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"The comments by Barton-(GPUN), during a GPUN and Bechtel management meeting, threatening to fire or suspend Parks for having publicly aired his allegations were improper."

(Supplement 5, p. 10-18)

This matter was separately investigated at your request and is covered in our report entitled "TMI-2 Staff Meeting of March l

23, 1983," dated November 1, 1984.

Our conclusion was that Barton had made statements " calling for the firing or suspension of Parks.

Barton stated that Parks should not be l

allowed back on the Island.

These comments were spontaneous personal reactions and were not treated as recommendations to be decided upon at the meeting."

I understand the November 1, 1984 report was furnished to NRC and therefore it has not been

' attach'ed as an exhibit to this report.

6)

"The comments to Parks by Kanga, threatening him not to publicly state his concerns about the polar crane and telling him thtc another employee who had tried to publicly state his saftsty concerns had been humiliated, clearly represented harassment."

(Supplement 5, p. 10-18) l 7)

"Kanga told Parks that he had put Bechtel in a bad light with a client (presumably by raising safety concerns about the crane) and stood a good chance of being fired.

This, i

l in the staff's view, was a clear threat of retaliation."

(Supplement 5, p. 10-18)

Both of the above comments allegedly were made by Kanga to Parks at a meeting on the morning of March 17, 1983.

We did not investigate that meeting.

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r-Since the morning meeting was attended only by Parks and Kanga, it is not possible to find independent, direct evidence of what took place.

Kanga, in his statement to DOL investigators, has denied making threatening remarks to Parks.

Two categories of circumstantial evidence might be helpful in resolving this dispute.

First, the evidence described above dealing with Kanga's meeting'with Parks and Chwastyk in the afternoon of March 17, 1983 indicates that Kanga's attitude was protective of Parks rather than threatening.

Second, our report of November 16, 1983 contains a great deal of evidence reflecting upon Parks' credibility.

Anyone attqmpting to decide whether to accept Parks' uncorroborated statements should review our report and compare his sworn allegations with the documentary and testimonial evidence we gathered.

In

. addition, the Bechtel report dated petober 19'84 deals extensively with Parks' credibility and should be considered.

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I 484 Parks.

Affidavit. p 25.

1. 83.00, Tab 24.

485 Procedure 1047, Rev. O.

Startup and Test. Section 3.2.1.2.

1. 12.00, Tab 75.

486 Ibid. Section 2.1.

1. 12.00, Tab 75.

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pp 19, 20.

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N9 IDid. pp 19-20.

490 10id. pp 19-20.

Thiesing. pp 55, 56.

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693 Kitler.

IOM 434F8F0002 to Buchanan et al. Desipation of D. Walker 2/18/83.

1. 48.02, Tab 308.

as alternate Startup and Test Supervisor.

Kitler.

ION 43458F0003 to Buchanan et al. Designation of D. Walker as alternate TWG Chairman. 2/18/83.

1. 48.03, Tab 309.

494 Kitler.

7/27/83. p 20.

495 Buchanan. pp 3-5.

1 Tniesing. pp 55-56.

i 496 Kitler. 7/27/83. p 20.

Suchanan. pp 3, 4, 5.

I 497 Parks. Affidavit. p 25.

1. 83.00, Tab 24.

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till current role as alternate startup and test supervisor I was s responsible to identify potential QA' audit deficiencies.

Jim Theising interjected to inform me that I no longer had to He had issued a memorandum that day or the day worry about that.

The new before appointing a new alternate, thereby relieving me.

h d

man, Dwight Walker, had been on the Island less than six mont s an had little or no knowledge either of the testing manual or the modi-He later admitted this to me at a Test fications control program.

$f meeting.

Further, Ed Kitler had Work Group (TWG) d only been startup supervisor since September and did not have a goo working knowledge of the test manual.

Returning to the February 23 meeting, I suggested that the j

issue was whether the polar crane load test procedure was a func-A functional test procedure demon-tional test procedure or not.

strates the total, integrated capacity of a syst.em or component to operationally perform as designed, before releasing it for unlimited it Under AP-104 3 and AP-1047, if it were a functional test, ll use.

vould have to go through the turnover process and through site ope-rations prior to thd test.

I suggested that the polar Management was visibly upset.

'g crane load test could be classified as a construction test, which Freemerman asked if we would could be performed prior to turnover.

still have to perform another test after turnover to satisfy the I said either we'd have to perform functional test require.nent.

or else have the Test Work Group review another functional test, g

TWG could evaluate and approve the procedure prior to turnover.

the load test procedure as the equivalent to a functional test.

TWO of ficially is a review group utilized as a management The 9

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FUM USE IN UNI T 11 ONLY 1047 l

Revision 0 2.0 TEST WORXING GROUP (TWG) 2.1 Members - TWG shall consist of one (1) member and at least o al, ternate from the following organizations:

NOTE:

Alternates shall be deemed to have the same t

responsibility and authority as the permanent members.

• Startup and Test (Chairman).

a.

b.

• Plant Operations Dept.

Plant Engineer,ing Dept.

c.

d.

• Recovery Engineering e.

• • Site Quali surance Mod /Op.

• Voting member 9

• • Voting Member for i to safety test n on 2.2 Princt esponsibilities a.

AdmiMiter the Test P licies and re irements through use of detailed uctions (TI's) led in Appendix A of ual.

b.

Approve TI nt fled *in Append f his manual.

c.

Review a ve test proce r to performance (See r

TI-d.

Review V d approve completed test procedure results (See TI-1).

Establish and approve the scope of the Test Program as e.

contained in the Test Index (See TI-2),

f.

Approve milestone event prerequisite lists (See TI-9).

2.3 TWG Function 2.3.1 The Test Working Group will conduct its business through meetings with the Startup and Test Representative as 4.0 FOR USE IN UNIT 11 OMI v

. _... ~

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FOR.USE IN UNIT ll bNLY 1047 Revision 0 Control Center in accordance with TI 4 or AP 1043 as applicable.

SU and T is responsible for identifying, documenting and 3.1.4 obtaining resolution of problems encountered during test performance (See TI-7).

Responsibilities of Individuals Within Startup and oup.

3.2 3.2.1 Startup and Test Manager.

f ram. The 3.2.1.1 Has overall responsibility.or th o

Plant Ergineering Startup and Test Manager report Manag 3.2.1.2 T

T Manager or his nate is the Chairman of T

~

orts of SU and T Engineers in 3.2.1 s responsible for t he preparatio formance of tes rogram documents 3.2.1.4 Review app 1' le itment docu nts s as the Unit 2

^

Recover 1

, Regulatory G s,

.. to assure that test tments are include i t procedures.

of problems arising during 3.2.1.5 i

nd obtain res f

se of Field Questionnaire etion testing thro n

(AV 1043) and Startup Problem Reports (See TI-7).

3.2.2 Startup Test Engineers Prepare Generic test packages and individual test 3.2.2.1 f

procedures.-

Inform the Shif t Supervisor / Shift Foreman of testing to 3.2.2.2 j

Se performed. Obtain his agreement with the test to be M

performed.

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EDWARD KITLER STATEMENT L

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1 misunderstanding.

The March 28th meeting was to go ahead and 2

document the resolution and have everyone agree to them at 3

one time.

The March 28th TWG meeting did not result in any

{

4 changes to the load test procedure.

5 BY MR. FRECH :

6 Q

Can I ask you did Mr. Parks indicate any reason for 7

his refusal to sign the TWG minutes of February 25, 1983?

8 A

I believe his comments were concerning some of the 9

prior testing done to the load test.

I'm not really too sure.

10 Q

Prior testing done to the load test?

11 A

Well, some of the testing done prior to the load test.

m I think be believed the no load test procedure was a tunctional 13 test, also.

14 Q

Did he ever send you a written memorandum objecting 15 to the TWG miuutes?

16 A

No.

17 Q

As they are?

18 A

Well, he never sent me a written memorandum to the 19 TWG meeting minutes because these meeting minutes were never l

20 issued Shortly after my discussion with Rick Parks, I left 21 for a vacation.

And when I returned, there was no need to 22 distribute the minutes since the whole program had been changed.

23 Q

Also on page 25 of Parks' affidavit, Mr. Parks 24 indicated that Mr. Thiesing had issued a memorandum appointing 25 a new alternate, and I believe where he says alternate, he's

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a KITLER 19 referring to alternate start up and test supervisor?

1 2

A Right.

3 Q

Is that a correct statement?

I issued a 4

A No, that is not a correct statement, 1983, designating Dwight Walker to memorandum on February 18, 5

Supervisor during periods in my behalf as Startup and Test 6

act 7

of my absence.

I Is our document number 48.02 that memorandum to which 8i Q

9 you are referring?

10 A

Yes, that is it.

What was the reason for the replacement of Mr. Parks 11 Q

as alternate start up and test supervisor?

12

.In December of 1982, there was no one, other than 13 A

myself, assigned to Site Engineering that was qualified to act 14 I needed an alternate, mainly as Startup and Test Supervisor.

15 to review and approve return to service forms, during my 16 Lick Parks, who was assigned to Site Operations, was 17 absence.

qualified and had acted in that position on occasion when he la worked for NUS Corp. at the Island.

I requested and received 19 approval from my supervisor Dave Buchannan and Rick's 20 supervisor Larry King, to appoint Rick as my alternate on 21 This was an unusual situation in that you 22 i December 6, 19 82.

have the Startup and Test Supervisor assigned to Site Engineering 1

23 Really, both these f

and his alternate out of Site Operations.

l 24 In January of 1983 j

people should be in the same department.

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25

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KITLER 20 1

Dwight Walker, who was qualified as a test engineer, was 2

assigned to Site Engineering at TMI.

In February Mr. Parks 3

started insisting on verbatim compliance with AP-1047.

At 4

that time, the way the TWG membership was designated, Site 5

operations would have had che majority vote, during my absence.

6 In order to correct the aforementioned misalignment and to maintain, 7

a system of checks and balances and ensure Site Engineering had 8

a voting member, I decided to update the TWG membership and 9

designate Dwight Walker as my alternate.

W Q

Is there any document or procedure which sets forth 11 the requirements for membership to TWG?

El A

Yes, AP-1047.

U Q

And I believe that document indicates that TWG members 14 shall be from a number of different departments on the Island?

2 A

Right.

16 0

Is Section 2.1 of 1047 the section to which you are 17 referring?

E A

Yes, it is.

B Q

Did anyone direct you to replace Mr. Parks as 20 a'lternate for yourself or was this your own decision?

21 A

This was my own decision.

I checked with my 22 supervisor, Dave Buchanan, and ne agreed.

23 Q

Mr. Parks intimates at page 25 that Mr. Dwight t

24 Walker had been on the Island less than six months and had 25 little or no knowledge of the testing modifications, testing

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JAMES THIESING STATEMENT e

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THIESING 56 Ic comments that have not been resolved, most of them in his f avor, 1

than substance.

2 though they were issues of form and format more j

3 Q

Mr. Parks has also alleged that at a February 23rd, t

1983' meeting, you removed,him as alternate Start-up and Test i

4 is supervisor and replaced him with a less experienced person t

~

5 6

that true?

7 A

That allegation is incorrect.

At that meeting (and I 8

can't confirm the date) I informed him that he had been replaced fo r 9

That replacement was done by the manager of Start-up and Test 10 TMI-2, Ed Kitler, in a memo which Mr. Kitler issued.

I.was not 11 aware of his intention to do that prior to his issuing the U

memo.

I became aware that it had happened after he issued 13 the memo.

That was', move to correct an organizational 14 deficiency which existed in that the Start-up and Test i

15 function is a responsibility of Site Engineering.

16 Mr. Parks was assigned to Site Operations organization 17 which is not the organization that's given responsibility for B

start-up and test, ergo the alternate Start-up and Test manager 19 should be a representative of the Site Engineering organization 30 It's not at all clear to me that the gentleman'who was 21 ; appointed alternate Start-up and Test manager is in f act less 22 experienced at start-up and test than Mr. Parks is.

23 Q

At another meeting on March 3rd as alleged by Mr.

M Parks, the Polar Crane was the topic of discussion, and Mr.

25 Parks alleges hat he suggested that the Polar Crane cable was

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WALKER 14

.1 AP-1013 was used.

2 Q

AP-1013 being the electrical jumper and the lif ted 3

lead procedure?

4 A

Yes.

Mr. Walker, to your knowledge, has the TWG reviewed 5

Q 6

the load test procedure?

7 A

I believe so but I wasn't involved in it as a TWG r.

8 membe r.

9 Q

Mr. Walker, moving to a different area of questioning 10 at the moment, your appointment as a startup and test alternate, 11 I believe, who is it that determines that you would be u

appointed as startup and test alternate?

D A

Ed Kitler.

14

.Q Did Mr. Kitler give you any reason why he was

.2 appointing you?

16 A

Not at the time, I don't think he did.

17 Q

Has he ever explained to you why he appointed you?

2 A

We've had some discussions about it, yes, since then.

B Q

And what has he related to you concerning that?

20 A

That the startup and test position is a Site 21 Engineering position and now that I am at TMI in Site I would be 22 Engineering and have the necessary qualifications, 23 the logical one to be Ed Kitler's alternate.

N Q

Had you had any prior a::pc 1:nce cr a stcrtup cad 5

test engineer?

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WALKER 15

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Yes.

2 Q

And where would that have been?

I have essentially been a startup and test engineer 3

A 4

since 1976.

For three years prior to that I was a design 5

engineer.

Before that I attended Penn State where I received 6

a B.S. Degree in Nuclear Engineering.

Did Mr.' Parks discuss with you your appointement as 7

Q 5

startup and test alternate?

9 A

No.

10 Q

Did you ever make the statement to Mr. Parks that you 11 lacked knowledge of the startup and test manual?

d A

Not directly.

13 Q

Indirectly?

14 A

-No.

The conversation I had with Rick Parks was 15 concerning chairing the TWG meeting, that it was my first TWG 16 meeting I had been to and I had felt uncomfortable about it.

l That's essentially all that we talked about.

17

.g IS Q

Just to clarify that and correct me if-I'm wrong, was the nature of the conversation then your unfamiliarity with 19 TNG meetings as opposed to the duties of the startup and test 3) 21 g engineer?

l 22 A

That was all the discussion was about, yes.

Z1 Q

Going back for a moment to the TWG meeting and your

'I responsibility to keep the minutes of that neeting of March 4th, 2A 25 did anyon'e instruct you as to what criteria you should follow in

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Inter-Office Memorandum 4345-83-0002 Gar February 18, 1983 f

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'34 Startup and Test i~

Personnel Coverage Locato" Administration Building

.c

0. R. Buchanan J. J. Chwastyk J. C. Fornicola L. P. King G. A. Kunder I. E. Mu :ert F.. P. Warren C. ring periods of my absence. D. Walker will act in my behalf as Startup and Test Supervisor of Unit 2.

O d-E. J. Kitler Startup & Test Supervisor Unit 2 Site Engineering EJK/.jaa cc:

J. W. Thiesing

p. D. Walier t

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Inter-Offico Momerandum

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[r 6 1 Nuclear Procedure AP1047 Startup & Test Manual TWG Membership

.:3'M Administration Butiding D. R. Buchanan J. J. Chwastyk 3'

J. C. Fornicola L. P. King G. A. Kunder E. E. Mu.mert F.. P. Warren

• n accordance with paragraph 2.1 of the subject procedure, Startup and Test membership on TWG will be:

E. J. Kitler (Ve-ber)

D. D. Walker

~( Al terna te)

E. J. Kitler Startup & Test Supervisor Unit 2 Site Engineering 1 EJK/jaa cc:

J. W. Thiesing D. D. Walker e

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O DAVID BUCHANAN STATEMENT e

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Ruchanen 3

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1 A

'My name is David R.

Buchanan, B-u-c-h-a-n-a-n.

2 Mr. Buchanan, by whom are you employed?

P 3

Q 4

A G.P.U. Nuclear Corporation.

And how long have you been employed by G.P.U. Nuclear?

Q 5

6 A

slightly over three years.

What is your current capacity with G.P.U.?

7 Q

8 A

The Manager of Site Engineering.

And how long have you held that position?

9 Q

Since the date of organization which is September 1, 10 A

n 1982.

12 Q

Mr. Buchanan, are you.f amiliar with the Start-up and 13 Test Department?

14 A

Yes, I am.

catchersburg; Start-up 15 Q

And do you know a member of the 16 and Test Department, Dwight Walker?

17 A

Yes, I do.

Do you know how Dwight Walker became an alternate on 18 Q

the Start-up and Test Department?

s I

Dwight Walker came to work in Site Engineering sometime 20 A

21 during the. fall of.82 as the Supervisor of my Facility and Sometime I think after the first of the year, 22 Liaison Group.

although I'm not sure of the date, Ed Kitler approached me with l

21 i

the general topic that he was the chairman of the Test Working f

24 Group, and his alternate was Rick Parks, and he wanted to know 25

- oricta a i.onia erronnwa senv!ct. me tooo mancer rr wec. ra moi uso awaios ca i.soo.2 rctas

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Buchanan 4

1 if I had any concerns with Rick Parks being the alternate 2

because Rick is in another department, and his availability 3

would also depend upon his workload from his own supervisor, l

4 and did I think it would make better sense to have Dwight 5

Walker be the alternate since he is qualified, and since he 6

works for me I control his time.

7 And I said it sounds like a good idea, why don't we 8

do that.

That way I have better management control.

So then, 9-as I recall it, I got into a discussion concerning who gets to 10 make that decision, who has that responsibility.

Ed felt since 11 he was the Chairman he had the responsibility, and I said fine, 12 you have my agreement, let's go do it.

I saw no reason to 13 bother Thiesing with it, the subject is something Thiesing did 14 not need to get involved with, and it seemed like a pretty 15 minor thing to be doing.

16 Q

Would it be accurate then to state the decision was a

17 made between you and Mr. Kitler?

18 A

That's correct.

19 Q

Did Mr. Kitler discuss Mr. Walker's qualifications 20 for the position?

21 A

Yes, he did.

I questioned Ed as to what were his 22 qualifications and what are the requirements.

He had gotten 21 from Dwight, in anticipation of my question, his resume, 24 and Ed and I sat down and looked it over and compared it 25 with the rules, and I was satisfied that he'had

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Buchanan 5

1 the prerequisites.

Did this replacement of Mr. Parks by Mr. Walker in any f

Q 2

way reflect upon Mr. Parks' performance?

3 4

A No.

It was just wanting to be in a better position of controlling the man's time.

l

.5 Did Mr. Parks ever complain to you about he being 6

Q replaced by Dwight Walker?

7 Rick Parks never talked to me about it.

8 A

9 Q

Are you' aware of Mr. Parks' allegation in his affidavit that Mr. Thiesing was responsible for it?

jo 11 A

I remember reading that.

To the best of your knowledge, is that an inaccurate 12 Q

13 statement by Mr. Parks?

i 14 A

It is inaccurate.

Mr. Buchanan, are you familiar with the Modifications 15 Q

16 Control Group?

17 A

Yes, I am.

18 Q

What is the Modifications Control Group?

It's a group within Site Operations that is respon-19 A

sible for_ handling the paperwork associated with Plant 2c 21 modifications.

They receive ECM's from the engineering group, get them approved, get them issued to the Construction or l

22 zi Maintenance Department.

Then upon completion of the job, they take care of the software associated with getting the modifica-24 tion turned over to Operations.

25

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Bechtel North American Power Corporation Engineers -Constructors 15740 Shady Grove Road Gaithersburg, Maryland 20877-1454 i

301 - 258-3000 CONFIDENTIAL March 4, 1983 Mr. Robert C. Arnold, President GPU Nuclear Corporation Post Office Box 480 Route 441 South 17057 Middl.etown, Pennsylvania

Dear Mr. Arnold:

l d you will In accordance with Mr. Kanga's instructions, enc osesets of notes to reco (2)

One set of notes find signed copies of two1983, with Rose,Rittle.

terview on March 3, i

is from James Troebliger and the other set is m ne.indicating The tone of the interview was set by Mr. Kanga byshe was not f

d to L. P. King's l

to Ms. Rittle that we were soliciting details from her with regar possible conflict of interest.

h us.

,Ms. Rittle was open and cooperative wit

. I am available to discuss these notes with you at your convenience.

Yours.truly, 5

Larry G. Santee Manager, Program Controls i

LG5:ms Enclosures (2)

(w/ encl.)

cc:

B. K. Kanga J. Troehliger (w/ encl.)

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Inter Offico Ucmorcndum Data March 3, 1983 Subject INVESTIGATION REGARDING L. P. KING INTERVIElf WITH ROSE RI'ITLE 83/053 Location TMI - Human Resources To Memorandum for Record On this date, Larry Santee of Bechtel and myself interviewed Rose Rittle, a Bechtel employee who was involved in the typing of resumes under the direction of Rich Parks.

During the surser of 1982, Ms. Rittle was requested by Mr. Parks to type resumes of a number of individuals on the stationary of Quiltec.

Ms. Rittle was instructed to type these resumes during non-working hours and to keep everything she was doing very confidential.

Ms. Rittle remembers typing at least 25 resumes, most of wh',ch were resumes of GPU employees.

She specifically remembers typing the res unes of Larry King, Ben Slone, Mike Herlihly, Ted Rekart, Bill Austin, William Henry, III and Ken Lionarons.

Ms. Rittle -was paid $75 for. typing the res mes.

She believes it took her 15 to 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> and that" she did it using company equipment.

Ms. Rittle stated that she did not view this as unusual at that particular

~

time because she had been asked in the past to type resumes.

She said that she had notified no one of this assignment until yesterday, March 2,1983 when she asked Bill Austin what was happening with the Larry King situation.

Bill stated that it involved Larry's efforts with an outside consulting firm, Quiltec, that may compromise his effectiveness with GPU.

Ms. Rittle stated to Bill that she had remembered typing resumes on Quiltec stationary and that Bill's resume was one of the many that she typed.

Rose stated that Bill Austin was quite surprised and stated to her that during 1982 Ben Slone had requested a copy of Bill's resume but Bill was uncertain of the disposition of'it.

Both Larry. Santee and I recorded a written transcript of Ms. Rittle's answers to our questions and had her sign both written transcripts at the end of our interview.

We also requested that if Ms. Rittle had any resumes of the individuals mentioned or had any stationary belonging to Quiltec, if.she would please provide that information to Larry Santee.

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vestigation Regarding L. P. King In Interview with Rose Rittle Page 2

..o 1

-l in judgement when l

It is the writer's opinion that Ms. Rittle made an error i i i

of company she was asked to type the resumes, specifically her ut l zat onB i

d stated Kanga gave Ms. Rittle a brief overview of the Larry King situat on anI believe it property.

to her that we were seeking her cooperation.

king her cooperatiion that we were not investigating Ms. Rittle, but solely see i

Mr.

on information relative to a fair and conclusive evaluation relat King.

s oebligej J.

Ar ta Manager - Human Resources ree Mile Island JT/pir

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ROBERT ARNOLD' STATEMENT 9/12/83 i

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32 AMLD Arnold Did you take any further steps to daternirLe Q

g the motives or the specific finding of Thiesing's 2

investigation of r.ing's association witit Quiltec?

a 3

I did not at that time pursue directly Dr.

/.

4 h5 Thiesin.'s motive or ticin..

I did agree sometine at c

probably the ucek o'f -'ebruary 28th uith Chcrles 6

Sanford, S-a-n-f-o-r-d, vice president at Bechtel's 7

Gathersburg office, to have an internc1 auditor cone, 8'

of Bechtel cone to the site and intervieu pecolo on 9

Bechtel's pcyroll who night have been involved trith it.

10 I'u not quite sure in ny cind ri,~,ht now to tract f

33 extent that uns set up in the first half of IIarch s

12

,r.nd to what entent it transpired subsequent to ; arch

~

{

13 23 when 1*r. Parks cade his s11esccions, but ny ::crch. 21 j

g4 i

to !*crch 15th the auditor indicates that pr or mem 15 i

uas at the site.

16 I did encourar,c l'r. Sanford for Bechtel to pursue 17 Dr. Tciesinf s role in developing this information and 18 the appropriateness of how he hcadled that.

19 the i'nvolveaent of :~r. 'Iting A,cin, I felt that 20 with Quiltec had to be dealt trith on its narits and 21 l

while I might disasree with how Dr. Thiesing hcndled 22 the inf r=ation he had had relating to that issue, it 23 didn't change the accountability that

r. :ing had for 24 uhatever his conduct had been.

25

• '**d.

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Arnold 33 3

Q Did you ever get any feedback from the l

auditor's investiration concernine: Iting'.s association 2

uith Quiltec?

3 g

.i TTell, as I indiccted in ny :Iar~ch 21, ' 03 ne a,

4 I uns told on :-Iarch 15th orally by 1:r. Ihns;a that the 5

internal auditor uas told by Mr. T.ichard Parks, I'-a-r-h-s, 6

that' Parks had arranc,cd for about a dozen resures to g

7 8

be typed at the reques t of ;Ir. King.

I don't recall receiving any other inforuction 9

about King's involvement with Quiltec as a result of g

10 f

t'?e cuditor's efforts.

11 12 Q

Lid you nahe any independent chech of the ticinr, or circunstances under uhich the GPU 1:uclear 13 e c.ployees left GPU ;iuclear to go to norh for Guiltec?

l 14 t.

Yes.

I had lir. ililson and the Hunan F.csources b

15 b

PeoP e. develop the chronology of, the ticin, of the l

i 16 chronology of the last feu veeks of erployment of ecch 17 of several forncr GPC e-ployees that went to ucrh 18 19 uith Quiltec.

Thct information, along uith information that I 20 J

}

received froa Policek, led me to conclude that at lecst 21 e

r. P.ekart and '.Ir. Herlihy, H-c-r-1-i-hy, hcd been 0

22 recruited from GPC! b" Bechtel..

23 The recruitment of them had involved findin-or 24 btaining er.ployment for then ct LILCO's Shorehe plcnt 25

. ~.

49 ARNOLD Arnold individuals of organizations with t hich ue typically do g

business or individuals uithin other veility coupanies.

2 I.~e instructed our recruiting agencies and 3

conduct &the advertising car..paigns that we did

___4 h

directly to =cke known ;;enerally within the industry 5

of the needs that we had, of the interests that we had, 6

and anyone that approached us, tre trould generally talh 7

8 trich the 1.

Houever, if they fell trichin tha categor, of 9

current e:1ploynent that you describe in your question, 10 3

it tras cy policy to gain their permission to let their gg 8

canage tent know that ue trere discussing with then the 12 possible offer of ecployment before proceeding a.nd 33 u hing such an offer.

}

14 a

Q Did you coccunicate that policy by 15 e

cer.orandun?

16 A

IIy recollection is that in '00 or ecrly 'G1 17 ue did put out such instructions in t:ritin..

18 Q

At a meeting that you had trich I*in- 'rou 19 inquired' about Parks' activities in behcif of Quiltec 20 r

to hcvc sone restries prepared.

t-

=

21-g Do you recall thct inquiry?

22 A

Yes, sir.

23 Q

Iinat was your purpose in inquirin.7 about crhs' act M eles?

25 1

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y Qe s g*

50 ARNOI.D Arnold I,

I-;y purpose was to probe the completeness and j

straightfort:ardness of the response I had gotten from 2

r

Sng on 12rch 9.

3 4

Q Can you e::plcin that?

4 e-In ene letter ch=c I soc frou :r tun: dated O5 IIsrch 9th, t hich is attachment C to the :* arch 21 ceno 6

to file, ::r. *.ing states in response to question '.To.

1G 7

as to that Cana3enent e~ployees of GPIJ or Bechtel were S

aware of his involvement uith Quiltec, that onl:' t-o 9

sechtel e=ployees hcd such knowled,c, a l'r. Jubin, 7

10 f

J-u-b -i-n, and "Ir. I;itler, 10-i-t-1-e-r.

11 8

As indicated in my !! arch 21 cero, ~ en :2rch 15 12 I uas told about the activities on the part of 1*r.

13 Parks in having resumes typed.

I was. surprised ce the l

14 r,

lach of identification of ::r. Parks in :Ir. I;ine:'s 8

15 n

08 o and my recollection is nov, nou is that I talked 2

16 to ;'r. I',ing about that in our neeting of :Icrch 9 17 because I thought I hcd his response in front of me

}

18 and uas readin, it and ashed the question at that eine.

i 19 1

That vould not be consistent with the :Iarch 21 20 neuo that I didn't knou about until Isarch 15th, and 21 absent perhaps being able to go back and loch further 22 R

at uhen some infor stion uas available to me, I c an ' t 23 be sure that my recollection is correct rather than the l

24 ccao of : arch 21's account of it.

~l 25 1

M e

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51 ARNOLD

/.rnold.

But I did remember querying !!r. Kin,3 as to l

3 Mr. Parks' involvement with him and whether Parks also 2

knet: chout his, ".ing's, involvetent wit Quiltec.

3 I certainly re=cr:Ger eclhing with hin cbout it 4

h5 for. the purpose of seeing tihether I should be confident that ".Ir. I'dn3 had been completely straightforuard trich u

6 l

CG-7 I think the explanation may be that I kneu 8

about Mr. Parks ' involvement in developin the resunas 9

as a result of the information I got on attachr.ient 10 12 to cy neno of ;*crch 21, and as I thinh about it bach, gg I think that the sequence was that :Is. F.iddle hcd

=

12 identified on ~ arch 3 that she 'had prepcred the restr.tes 13 at the rcquast of :.Ir. Parhs, had been pcid the $75 14 i

for doins it, but thct I didn't have any infornation 15

2. Parks ' account of that incident or of that on 16 activity on rdddle's part, but that I.

c:: c.cre g7 subsequent to 1: arch 4 of the preparation by ;:s. %~.dle 18 of the resumes and that had been at the request of 1:r.

19 Parks and that 1:s. F.iddle had been paid for it.

20 I think that formed the basis for my questionin:,

l 21 l

f ;*r. King as t inat :r. Parks'. involvement or 22 h uledge had been and tinich I think took place on or 23 during our nectinc of l'. arch 9.

24

~

I thinh that subsequent to that and after hcvin7 25

.M L..l., :

u.

52 ARNOLD Arnold f

received tract tres really a very unsatisfactory anstrer I

3 from Mr. 7.ing on :* arch 9, I got the information as to Y

2 tince ?crhc told the sechtel people had been the t

~

3 clearer,more active circu-. stances and sinich indicated a 4

f h.~

5 involvement by i~ing in arranging or havin~, Imottledge of the crranging of the preparation of the resucos 6

he had achnowledged to ce on I arch 9th, and than 7

d rade the tended to stren;:then ny conclusion that I ha 8

right decision in deciding to ternincte hin.

9 I realize that there is c brief description Q

10 of t: hat ".ind said to you on Iarch 9th about his l

11 cssociction trith the preparction of those resunes,

12 but could you doccribe, as best you cen, tract he told 8z

- 13 you in response to your question?

.j 14

' cll, let ne say that es I discuss the response s

A 15 I

to cuestion 10, I generally ~had the impression thct, 16 lly scyin;: that t:cil,let ne scy ';::. d.ing tcs specifica 17 tfar.t and ti. o didn' t hnot:

he wasn't really sure tino knett 18 cnd he ::as very reluctant to identify cnybody by ac-.c,

19 h issue.

thct he didn't positively knou hard knowledge of t e 20 Tae sense thct I got from the conversction tras 21 that he thought there trere others within the 22 very vell nicht have kno:m and ory,anizction that 23 reluctant to nane probably did hno:7,- but that he wc 24 thet-25

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Arnold 53 AMOLD

.hile I don't reccll his specific words, ny senso 3

in ashins about Parks was that he scid Parks =ight have 2

Y kno;n.

e saan't really sure.

Ee was very noncocrc.itt:1 3

ab ut t when I initially brought up Mr. Parks ' nm.:c,

4 cnd then I told hin about IIr. Perhs having arranged trit".1 5

Tiddle to do the t> pins and to have the resunos preparec' 6

and then he achnouled;;;ed that that had tahen place and 7

that he rectly didn't hnou, or let no say it a little 8

dil2erently. that he acknouledge:' thct he had pcid Parh:

9 saic noney _*or hcvin; sone res~unes prepared, but that h:t 10 had done that basically ct Slocne's inceructions and he t

l 33 didn't really knou the circumstances or the specifics.

12 IIe ucs just acco:rtodating Iir. Sloane ir: providini a 13 Quiltec chech to Parks.

14 s'

Ha also said, as I recall, that he didn't realic e

15 i

it tras a Bechtel secretary that had done the typinr.

16 T.e hai thought it tras : friend of Pcrhs who had done 17 the typin, a friend not associated t.-ith either of our 18 co=0anies that had done the typing.

19 I

Generally, c very noncorr. ital, nonspeci ic respo r,c 20 I

" hiU*

21 Q

In hi responses to you King indicceed 22 that he served as an advisor to Quiltec and inplied 23 that he had no active role in runnin.* the company.

~

24 Assts.in-thct that uere true, uould thct hcvc 25 i

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099 Parks.. Affidavit. pp 51, 52.

1. 83.00, Tab 24.

500 Ibid. pp 51, 52.

1. 83.00, Tab 24.

501 Ioid. p 52. #83.00, Tab 24.

Chwastyk. pp 156-159.

502 Parks. Affidavit. p 52.

1. 83.00, Tab 24.

503 IDid. p 52.

1. 83.00, Tab 24.

504 101d. p 52.

1. 83.00, Tab 24.

i 1

25 Ibid. p 52.

1. 83.00, Tab 24.

U l b 6

IDid, p 52.

1. 83.00, Tab 24.

507 Ibid. p 52.

1. 83.00, Tab 24.

• 9

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50 8 Ibid. p 52.

1. 83.00, Tab 24.

509 Chwastyk.

8/4/83. p 156.

510 IDid. p 156.

511 Cnwastyk. p 156.

Replacement of Parks on TWG (for IOM 4200-83-147 to Kitler.3/17/83.. #48.00, Tab 112.

Cnwastyk.

polar crane project) by Marshall.

512 Cnwastyk. 8/4/83. pp 156, 157.

513 Iold. p 157, 514 Kanga. 7/25/83. pp 73, 74.

515 Ibid. pp'7 F74.

516 Ibid, pp 7F74.

Chwastyk. 8/4/83. p 157.

o 6

.p I___*_

a l.

7/25/83. p 73.

517 Kanga.

t.

j 518 Ibid - p 3 Chwastyk.

IOM to Kltler. 3/17/83.

1. 48.00, Tab 112.

t 519 Karga.

7/25/83. p 74.

Cnwastyk.

8/4/83. p 157.

Cnwastyk.

ION to Kitler. 3/17/83.

p 1.

1. 48.00, Tab 112.

l 520 Karga. 7/25/83. p 74.

Cnwastyk. 8/4/83. p 157.

Chwastyk.

IOM to Kitler. 3/17/83.

p 1.

1. 48.00, Tab 112. -

I 521 Karga. 7/25/83. p 74.

I Chwastyk. 8/4/83. p 157.

1 522 Kanga. 7/25/83. p 74.

Chwastyk. 8/4/83. p 157.

4

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PARKS AFFIDAVIT 1

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^ ~ ~ On Thursday, March 17, at 8:00 a.m., Mr. Ranga had me in for a two-and-a-half-hour meeting about the letter I had delivered the

i I informed him that to date I still had not received a day before.

catisf actory response to my concerns on the polar crane; that I otill had serious problems with it; and that I was being pressured to approve the load test.

~

Kanga said his door was always open if I felt intimidated or threatened, but that any further reas'surances would be up to Mr. San-f ford.

Neverhheless, he warned me not to go public with my concerns.

He said that once before things had gotten much worse for an employee

>l

~

who had tried that and was " humiliated."

He said it could be as long f

as two weeks before any decision was reached on me about Quiltec.

He volunteered that it was unfortunate, but other individuals like He said myself had come to Bechtel without any indoctrination.

khat was a problem he would have tb resolve.

He said that he had to send a report to Bob Arnold describing how the issue with'me had been handled; that I personally had put Bechtel in a ba'd light with a client; and that as a result I stood a good chance of getting fired.

Kanga did, however, promise that the Licensing 'and QA depart--

ments would sul:mit written responses to satisfy my concerns on the

~

polar crane.

I told him that failure to ensure reviews required by the QA Manual and applicable standards, procedures and regulations i

constituted an unreviewed safety question.

I said this was especi-ally true, since we worked at TMI Unit II and had told the world

~ f that public health and safety were our top priority.

Mr. Kanga We finished the meeting.

was becoming openly nervous and agitated.

. A,~ ~

- T~C1 TY

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52 -

k.

Around 1:00 p.m. that day, I infermed Joe Chwastyk that I because of the serious could not approve the polar crane load test, I added that I did not find violationsthat permeated the program.

ritten for anything technically wrong with how the procedure was w But it did not address the major issues raised in what it covered.

J We had' just been going through the motions.

the review cycle.

Around 3:30 p.m. that afternoon, I was called back to B.

The subject Kanga's office for a meeting with him and Chwastyk.

dated that day from J. Chwastyk.

4200-83-147, of the meeting was IoM It stated that effective immediately Mr. Marshall would replace me ilding as the primary 50 member on the TWG Q for the Reactor Bu The memorandum continued, Polar Crane Project.

This action is considered appropriate for the present situation and is not considered a negative reflection of Mr. Park's ability, conduct or per-formance.

The designation of Mr. Marshall should not adversely affect the Polar Crane Refurbishment Schedule.

l was At the meeting Kanga asked me twice to agree that my remova I responded, "In my opinion, the an act of intimidation.

f

. -- - J not intent is well-defined."

As I lef t the room I told Mr. Kanga that They were too late.

I had reconsidered after speak-I had already signed the procedure.

ing with Chwastyk earlier and signed with the proviso " based I took this step because technical content of the procedure only."

and I did not want to pursue a personal vendetta about the program, f my the approval in this form was consistent with the substance o is a

" Approval based on technical content" earlier position.

It does not imply either that all required topics,

generic term.

d.

have been covered,. or that QA requirements have been followe

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4 JOSEPH CHVASTYK STATEMENT e

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CHWASTYK 156_

1 I'll show you another document, our document number

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2 339, the second page which purports to be a letter from you to Mr. Kitler dated 3/17/83.

The subject matter is TWG Member-f 3

4 ship.

l h i

I'll as you to take a look at it, please.

5, 6

A I remember the letter.

l r[

7 C

What is the letter?

Would you identify it, please.

o A

The letter is the TWG membership and it basically

(

removes Mr. Parks as the primary Site Ops. Department Repre-9 l

sentative to the TWG for the Polar Crane Proj ect.

10 11 Q

Would you tell us how that letter came to be docu-e ment 339?

Well, Mr. Par..s came to me with some concerns he thought A

t.1 he had in relation to the reactor building Polar Crar.e.

We 14 discussed those concerns and I was able to put them to rest.

15 Mr. Parks then suggested that he may be so close to 1,;

this project that he is no longer to distinguish real from i

l 1;

13 perceived problems.

I suggested then a possible means of He j

getting out of that was removing him from that project.

19 i

thought it was. a good idea, so I told him, Okay, I'll draft m

up the letter and we'll go over it and make sure yo.u agree l

.i 21 I

with it and I'll put it out.

I did that, drafted up a letter.

He reviewed it and l

g I don't may even have made some comments or changes to it, y

/

remember, but this was as a result o.f that.

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"That" being document 339?

Q t

Now, during this time because of Mr. Parks' A

Yes.

2' involvement at that time directly with Mr. Kanga I thought 3

I did that, and to call Mr. Kanga and inform him of this.

4 Mr. Kanga asked me to come down and he wanted to review the 5

6; letter first.

t I did'that, and he decided he wanted to talk to Mr.

-l Parks, so he called Mr. Parks down and we went over the letter, i

e 'l That's when I signed the document with both Mr. Parks and Mr.

9i As a matter of fact, this is the meeting to l Kanga right there.

d h

that I referred to earlier that as Mr. Parks left he ma e t e i

11 ;

comment about signin6 something for technical content only.

12 '

Did you sign letter number 339 in the presence of Q

,)

1:;

Mr. Kanga and Mr. Parks?

1:

ti -i i

A Yes, I did.

t 13 Did Mr. Kanga question Mr. Parks concerning this Q

16 th ',

letter?

isl A

Yes, he did.

Do you recall what Mr. Kanga's questions of Mr.

Q 19 Parks were?

m and He asked Mr. Farks if Mr. Parks agreed with it, I

A

[.

Mr. Parks made some off the wall comment.

21 He implied to me, 22 and I think Mr. Kanga took it the same way,that he agreed.

23 i He also discussed the letter with Mr. Parks and I

24 i tried to make sure that Mr. Parks knew thct it was not any I

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CHWASTYK 158-

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kind of a reprimand of any sort of any kind of discriminatory 2

action.

Mr. Parks, like I said, was very quiet throughout 3

the meet!.ng.

When Mr. Kanga asked him d'irectly if he agreed 4

and does he understand, Mr. Parks said something I thought 5

at the time was strange, but again my impression was that he 6

did agre,e with it.

That's when I signed it.

7 Q

Was Mr. Kanga informed either by you or by Mr. Parks '

8j as to what triggered this letter?

t 9

A Yes, I talked to Mr. Kanga prior to Mr. Parks gettir.g 10l there and we discussed that.

11 '

Q Mr. Kanga was informed as to Mr. Parks' concerns?

l 4

ui A

Yes.

f l

)

1:1 Q

I'll ask you to turn to page 52'of document 83, i

14 please.

The first paragraph begins, "Around 1:00 p.m. that a

nI day I informed Joe Chwastyk that I could not approve the Polar 16 Crane load test because of the serious violations that perme-17 i sted the program."

m, By "that day", he was referring to March 17th.

Do

.a !

you recall Mr. Parks making such a statement to you on March 3n the 17th?

if 21 A

I think that's the subject of which I related to 22 earlier about he had some problems and we sat down and went 23 through each problem individually.

I don't know what the last aftwosentencesmean.

l-l s

Q Again, you're not aware of what he -

"ne" meaning i

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GEIGER 4 LORia REPORiiMG SERvtCE. INC.1000 MARKET STREEf. M ARRISOURG. PA.178 01 PHO 'E 8717s 234 2109 t

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CHWASTYK a

159 Mr. Parks -- means by approved based on technical content 1

2 only?

A

-No.

3 I'm going to show you two documents, number 8 and Q

4 i

number 9, each of which purports to be a Unit Work Instruct on 5

I would ask you dealing with the Underhea'd Characterization.

6 to look at those documents, please.

7 L

I (Witness complies.)

6l A

Having looked at documents 8 and 9, do you recall Q

9 whether you saw documents 8 and 9 in the past?

10 I vaguely recall 8.

Yes, I vaguely recall both, A

11 I

and I signed both.

tz :

Document number 8, is that the document you indi-

~

Q 1:1 cated you recall?

14 ;

1 A

Yes.

nj Document number 8 was signed by SRG on 2/16/83 and 16 i Q

signed by CC on 2/24/83, is that correct?

i 1;,

A That's correct.

18l Is that your signature on document 8?

Q 19 A

Yes, it is.

m Is there any date by your signature?

Q 21 A

No, there isn't.

22 Mr. Parks makes the allegation that this document, i

Q l

document 8, was reviewed by PORC SRG prior to it being sub-m l

I 34 i

groups.

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BAHMAN KANGA STATEMENT e

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if I could. And'that is an allegation raised by &. Parks that he was replaced as a primary TWG me=ber for the Polar Crane and the sequence of 2

So what I would ask you is first of all', was 3

events that occurred there.

&. Parks replacaA as primary TWG mecber?

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A.

That is correct.

And how did that.come aboutf 6

Q.

Okay, look at the mmo that was written by &. Chwastyk and l

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A.

o there is a mmo written or a letter written by &. Parks. Also,there 8

is a Parks' letter or menn, I believe it is to Sanford, sane date: See 9

Exhibits A and B hereto, which are copie.s of a letter frcxn &. Parks to 10 11

&. Sandford dated March 16, 1983 and a menorandtzn from &. Chwastyk, to &.

12 Kieler dated March 17, 1983. I had a telephone call from Joe Owastyk, and

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he mentioned to me that he felt that P_ arks was quite nervous that day and 13 that he felt that it would be helpful to Parks if Parks was replaced as 14 primary umber for TWG for the Polar Crane project only, which would reduce 13 16 pressure on Parks.

I asked him if he had discussed the me:o or that action with 17 Parks and he told me that he had, and I asked him to bring the meco and 18 19 discuss it with me in same detail. Joe Chwastyk came to my office and I I asked him if in i

looked over the me:o that;be had written but not signed.

20 his discussion with Parks, Parks had indicated any objection to 21

'Chwastyk told me that he had not, that Parks in effect welemd 22 the memo.

that me:c, and I asked Chwastyk if he had mada clear to Parks that this was 23 not in any way a reflection on his performance, and that we were not in any

'4 way downgradin6 &, Parks.

And Chwestyk told me that yes, &. Parks understood 26 PHONE 178 78 2341809-6 LIGER 4 LORIA REPORTING SERVICL IMC 1000 IR ARKET STREET. MARR!SsuRG..PA.17101

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that.

The reason why I was concerned about Mr. Chwastyk's 2

action was that that very morning, Mr. Parks had reviewed with 3

me a letter that he had written to Mr. Sandford dated March 16, li and which he,had brought to my secretary on March 16 and 4

requested me not to send it to Mr. Sandford until Mr. Parks had 5

6 a chance to talk to me.

So I had a discussion that very 7

morning with Mr. Parks regarding his concerns on.how he was a

being treated and regarding his concerns on intimidetion.

I 9

I did not want the memo from Mr. Chwastyk to be 10 interpreted as an act of intimidation.

After discussing this 11 with Mr. Chwastyk, I asked Mr. Parks to come to my office and I 12 went over the same items as I described to you earlier to make 13 sure that Mr. Parks understood that this was not a reflection 14 on his performance, that it was not a step down for him and 15 that it was, I wanted to be a hundred percent sure, that it was 4

l' not interpreted as an act of intimidation.

Mr. Parks basically

- 17 affirmed my understanding that he understood what the memo said 18 and that it was not being interpreted by'Mr. Parks as being

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19 intimidation or a reflection on his work.

p 20 After that, Mr. Chwastyk signed that memo in the 21 presence of Mr. Parks.

22 Q.

What was Mr. Parks' response to you as to whether he was in agreement with his removal as primary member on TWG on I

23 24 the Polar Crane?

25 A.

Firstly,.he's not removed from TWG, all this does is s

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KMGA 75 d ry o replace him from o primorg member to essentially a secon a

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it is just for that This is not removing him from TWG, 2

member.

Mr. Parks In the discussions that we had, Polor Crone project.

3 gave me to understand that he understood the memo and he never O

i td indicated to me any concern regarding the memo, never ind ca e 5

to me in that particular meeting that he would consider that as 6

a reflection on his perforesnce or on act of intimidation by 7

Chwestyk or myself.

B either Mr.

I'd like to ask you o question 9

G.

Moving from that area, and in concerning the underhead characteri=otion if I could, 10 Mr.

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particular whether or not Mr. Devine, Jack Devine and oe 11 Thiesing discussed with you their, Mr. Devine's preliminorg 12 the assumptions concerning the chorocter of radiation that 13 indic at ing reactor vessel had and a memo that Mr. Devine issued

• 14 diation that the preliminary results indicate 30 times more ra 15 initial assumptions 7 16 than the 17 A.

Yes, they did.

l either Mr. Devine or Mr.

Did they discuss with you, 18 0.

that they would continue with Quick Scan to I Thiesing or both, 19 itional verify these preliminorg assumptions and do add 20 28 onelysis?

they had written a s.sn.o to 02 A.

Yes, they did.

In fact, Thiesing, Mr. Devine and me which was discussed among Mr.

23 tion to myself, and essentially I approved their recommenda 24 continue the work as for os the removal of the head was f

25 concerned on the original premise but to perform on evoluotion PHONE (717p 234 2109-26 4EIGER a LealA REPORTING SERVICL INC 1000 MAREE7 STREET. HAR O

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Inter Offloo r!!cmorcndum 3/17/83 J.

.to:

h TVG Membership ubjoct:

4200-63-147 E. Kitler. Supervisor of Start Ip Lo ca t ier.:

TMI/... Site Operations u.;

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and Test Bldg. 222 Effective im=ediately, please consider W. Marshall as the Primary Site Operations Departnent representa:ive to the T'G.

Mr. Marshall will replace Mr. E. Parks as the primary menber only for the Reactor Building islar Crane prefect.

situation This action is considered a pr Triste for the present considered a negati.e reflection of Mr. Park's and is not ability, conduct or performance.

The designation of Mr. Marshall should not adtersely affect the Polar Crane Refurbishment Schedule.

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.1:e 0 era:irne 2..c::rr, (Acting) fj JJC/bjs i

cc:

W. Marshall R. Parks J. Barton B. Kanga File 4

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