ML20238C545
| ML20238C545 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 02/24/1987 |
| From: | Wheeler R BECHTEL POWER CORP. |
| To: | |
| Shared Package | |
| ML20238C505 | List:
|
| References | |
| CIV-PEN, EA-84-137, NUDOCS 8712310073 | |
| Download: ML20238C545 (114) | |
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i OR/GWAL O UN11ED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO: 50-320 ! GPU NUCLEAR CORPORATION (Three Mile Island Nuclear , Station, Unit No. 2) DEPOSITION CF RICHARD A. WHEELER N LOCATION: GAITHERSBURG, MARYLAND PAGES: 1 -10'l DATE: TUESDAY, FEBRUARY 24, 1987
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872455 Ms. Kathie S. Weller Ace-Federal Reporters, Inc. 444 North capitol Street Washington, D.C. 20001 Re: In the Matter of: GPU Nuclear Corporation fd-$ 2.0 M (Three Mile Island Nuclear Station, Unit No. 2) Deposition of Richard A. Wheeler
Dear Ms. Weller:
Please make the following changes and/or corrections
^ to the transcript of Richard A. Wheeler, whose deposition
( testimony was taken on February 24, 1987:
'(
Page Line Corrections 5 3 Delete "all of the startup" 6 10 change "The staff" to "In staff" 10 11 Change " cites" to " sites" 12 10 change "why it is" to "why. It is" 12 21 Change "33" to "27" 12 22 Change "37" to "33" l 15 17 Delete "if" 15 19 Change "Had I" to "I had" O " j
)$ Ms. Kathio S. Waller April 2, 1987 d
g .Page 2 k Page Line Corrections 15 22 ' Delete "or" . 16' 17,18 Change " site" to " side" 26 17 Change "Farley or he" to "Farley. He" 34- 15 Change "but the polar" to'"but Parks stated the' polar" p 34 16 Change "There are" to " Parks stated there i are" 35 4 Delete second "had" 48 6 Change "It is because" to'"In the course" 55 9 Change "and tell him what" to "and have him
~
tell us what" 55 20 Change "He" to " Parks" 74 13 Change "here" to " Parks' deposition" 74 25 Change " notes he says" to " notes. He says"
.l 76 6 Change "Let's participate in a dialogue that I can get on with my career and tell you what.these concerns are so you can go to work on-them and he just didn't participate in it." to " Parks participate in a dialogue which would enable him to get on with his career and tell us what his concerns were so we could go to work on them -- and he just didn't participate in-it."
79 13 Change "Kanga's" to "Sandford's" 90 12 Delete "just" s
-)
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Ms. Kathie S. Weller April 2, 1987 Page 3 Corrections ) Page Line ;
'l 91 2 change " Dick" to " Lee" q
109 3 Delete "while" ! very truly yours, N
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Kennedy P. Richardson-KPR/ws . cc: Richard A. Wheeler George E. Johnson, Esq. J. Patrick Hickey, Esq. O O i -
CR29934.0 1 'KSW/sjg 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ADMINISTRATIVE LAW JUDGE , 4 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x In the Matter of: : 5
- Docket No. 50-320 GPU NUCLEAR CORPORATION' :
6 : EA-84-137 (Three Mile Island Nuclear : 7 Station, Unit No. 2) : 8 - - - - - - - - - - - - - - - - -x 9 DEPOSITION OF RICHARD A. WHEELER 10 yy Gaithersburg, Maryland Tuesday, February 24, 1987 () 13 Deposition of RICHARD A. WHEELER, called for examination 14 pursuant to notice of deposition, at the offices of Bechtel 15 Power Corporation, 15740 Shady Grove Road, at 9:45 a.m. before 16 KATHIE S. WELLER, a Notary Public within and for the District of Columbia, when were present on behalf of the respective 77 par s: 18 19 DAVID R. LEWIS, ESQ. Shaw, Pittman, Potts 20 & Trowbridge 2300 N Street, N.W. 21 Washington, D. C. 20037 On behalf of GPU Nuclear 22 Corporation. 23 KENNEDY P. RICHARDSON, ESQ. l Thelen, Marrin, Johnson
& Bridges 24 One Kaiser Plaza Suite 1950 O) - 25 Oakland, California 94612 On behalf of GPU Nuclear Corporation.
-- continued --
ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Co$erage 80f> 336-6646
2 1 APPEARANCES (Continued): 2 GEORGE E. JOHNSON, ESQ. 3 Office of General Counsel United States Nuclear 4 Regulatory Commission Washington, D. C. 20555 On behalf of United States 5 Nuclear Regulatory Commission. 6 7 8 9 10 11 12 th 13 J 14 15 16 17 1 18 19 20 21 22 23 24 o L/ 25 ACE-FEDERAL REPORTERS, INC. 200 347-3700 Nationwide Coverage 800 336-6646
3 l i j'~') 1 CONTENTS i l . V 2 WITNESS EXAMINATION i 3 Richard A. Wheeler 4 by Mr. Johnson 4 5 6 7 8 9 10 11 12 0 13 14 15 16 17 18 19 20 21 22 23 24 Ch C/ 25 ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage K 4 336-6646
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.PR'OC M R D I'.N G'S 1 .
2 Whereupon, 3 R3 CHARD ANDHEW WHERI,ER 4 'was called as a witness and, having Cirst been duly sworn, S was examined and test i fied as fo))ows: 6 EXAMINATION 7 BY MR. JOHNSON: 0 g Would you please s tate your name and business 9 addresc. 10 A .My.name.is Richard Andrew Wheeler. My business 11 address..is Bechtel Power Corporation, .Bechtel Eastern Power
'.1 2 Corporation, 15740 Shady Grovo Rodd, Ga i th e rs bui"g , Maryland.
13 g And you are currently chief engineer, Startup and e 14 Operating Services, Eastern Power Divis. ion?' 15 A Yes, sir, I am. 16 0 lief ore we went on the record, you had said 17 something concerning the diCference between your current
.18 position and your position in 1983. Could you expl a.i n that, f
19 please? 20 A About mid- May i n 1982, [ assumed the dut.ies as the 21 chief startup engineer. That was my Li ll e up until about a , 22 year and a half ago when we added the operating services j
.i 23 i - Lille.
24 O And cou]d you describe the departments t ha t. you 25 were chief of? i ACE. FEDERAL REPORTERS. INC. 202-347-3700 Nationwide Coverage 8(G336-6646 i
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1 .A .Of the -- l 2 'O 3 'm talking about in 1983. .) 1 3 A Well, all of the s tar tup: we ' re a matrix l I 4 organization, so chief engineers have the staffing .j 1 1 5 res po ns ibil i-Lies Lor projecLa. Projects that required .i 6 startup personnel,-I wau responsible to supply those peop1h : I 1 7 to projects at.that time. ! 8 0 When you say " matrix," .ia. thal what thatI i 9 indicates, tha t you were projec t-oriented? I'm not sure : wha t .; i 10 thal means. l l 11 'A I was s t.af f-ori ented, but I had a'respons.ib5]ity l 12 to projects to support projects by providing personnel t o ', l 13 those projects. 1 9J .14 11u t the organization) matrix.was l Q ! 15 personnel-oriented, s ta f f-orien ted? 16 h . T h a t s correct. ; 17 Q Could you describe the structure, who worked under 18 you and i n what departments, et cetera? : 19 A At the time, I had an assist. ant in the depa rtment 20 1.h a t was also a resident this Gaithersburg. And then I had a 21 statf supervisor that took care of some technical writing. 22 0 Could you give t he nnmen as you go along? 23 A Mr. Vernon Leopard was my assistalit. I believe 24 the staff technico] supervi sor ai the time probab]y was Jrvin 25 Tessier, T-e-a-s-i-e-r. We had some changes back then, but O ace FEDERAL R.EPORTERS, INC. 202-347-3700 Nationwide Coverage 800-3364M6
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1 everybody i :, stil1 in the name position today. I think he
- 2 was in at the time. And he may have'had a doxen engineern 3 performing a variety 01 projecLs, support roten, working for
.4 him.
5 0 okay, these would be. detailed to different ti projects around.the country?' 7 A No, thene would be people o n s t.a f f a nd .i f: a-A project had.a particula r need that they' required some nLaff 9 assistance for,-there was a.technica] group of people here 10 that could bring their expertise to a project.. The. staff 11 f u nct.i ons you may end up having some very ecoteric' area-that 12 maybe there's a specialist on chemistry or .a specialis t on 13 heal th phys i ct: or on tranniormers, something of that nature-
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14 thal thal'particular sLaff person would=be a resource that 15 individual projects could ca)) on. 16" Q And was that a typ i.ca l interface, say, with 37 Itechte1's ro)e 5n the Three M.i2e Is.1and '2 cleanup' project? 10 Would those be technical resources to people on uite? 19 A on a ca)) b a s .i c , yen. 20 Q Who else was working tor you? 21 A Then in the 1Seld jobs, we nad a number of joba l 22 s ta f f ed a t the time in the field, but t.ypically we would end 23 up having a lead engineer in the f.ield that was respons.ible 24 ' f or u ta r tup a f f a.i rs , and so those lead engineers would end up 25 reporting to me for the resources they need, the personne] ACE. FEDERAL ReponTuns, INC. 202-347 37(W) Nationwide Coverage 800-3364M6
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'29934iOL KSW 7 1 thati they needed.
2 0 'I n 1982 und 1983, what was the reporting-3 relationship between you and people at Three Mi.le Islatsi? 4 A My J ead at the site at the t.ime was'Ed K5tler. 1 l- 5 Q And he wan . ca lled -" lead engineer" or ". lead c l 6 startup"? l' l 7 A He was the' project.startup-engineer. 8 Q Did you have others similar typen of lead 9 engineers at other plants in startup capacition? 10 A Yen, we did. l L .11 Q Who else was reporting 1.o you f. rom Threc Mile 12 Island, if anybody? 13 A Kit..)er ic t.he on]y one that reported to me at 14 Three M11e Island. Say i n the matrix organi za tion, 15 Mr. Ki t l er report ed to the . project manager f o; project 16 direction, and to me for support from the home office 17 administrative support.. . Eventually in our project 18 organization, everybody in Rechtet essentially in ma trix 1 1 19 organization has two.bocaen. 20 Q An adminis tra tive support -- i l 21 A Admi n.i s tra t i ve s u ppo.r t , nalaTy administration, 22 tha t kind of thing I was responsible Oor, and 1.he affairs at 23 the projact were handled at ihe projecL.leve]. 24 Q okay, but you are an engi neer You are in charge 25 of both engineer.iog and support ser' vices for your a7ea? O l l ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Cmcrage MO-3364M6
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,- 1 A' Yes.
.2 Q Now, .it.30 my understanding that Richard Parks was s
3 hired-by Rechtel, which Hechtel organizationjI don'L-recall l 'l i
.1 4 right now, but approximate]y in May . of ; 1982.
D.id you have q 5 any. role ~in his being hired? 6 A Yenf cir, 1 did. My predecessor the ch.icf startiup 7 engineer preceding me was a nan by.the name of George: .l l 8 Co]3inu. George had recesved a call from Kit 3er irom.Ed
'9 Kitler at the . job si te telling him that there was an NUS. ,
10 employee, Hichard Parks, that wasJdoing a good job at. the-11 Island and well though t. ot', and he recommended thal George 1 l 12 Jook into ' hiri ng this fe]Iow because the NUS contract,wan 13 expiring, George invited Parks to come in for an interview. l l 14 An iL turns out', ior whatever reason, George wasn't'there the i 15 particular day that Parks showed up. As George's' assistant-
.16 a -t the t .i m e , 3 .interv.iewed Parks and relayed to George when l'
17 he returned the following day, you had a fellow como in here 30 from Three Mile Island,'and nubnequently, George made a'-- 19 filled out a form that we filled out, it is a requent l 1 20 permiccion to hire form,-and Richard Parks wan made an offer. l 21 Q What was your imprension during this interview ot . 22 Parks? 23 A We)), it was pretty much a cursory thing when we 24 have a local recommendation from a job site that tells you 25 this guy it aircady proven in a job here, he in welJ liked by ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage Mn336-M>46
.li 29934,0 KSW. 9 1 a client, we obviously think a .l o t o f: .our leads so when we 2 have a strong recommendation f.or a lead for somebody to 3 continue, the interview was more at a cursory type thing. A-4 nicety t.ype thing.
5 Q A formality? 6 A A f ormality than' i L was a 1st's investigate your 7 competence. We a.l ready had informa tion . tha t -
~8 Q You were relying on Kit]er?
9 A We were relying on input that we had 'firom that 10 point. 11 MR, HICHARDSON: Excuse me, Mr. Whoujer, it is not 12 clear to me, did you indicate that Mr. Parks was at I.he 13 IsJ and a t. that ti me? 14 TiiB WITNESS: I believe so, 15 MR. HICilARDSON: I may be misiakon. You may want 16 to look at his employment applica tion. 17 MR. JOHNSON: He may have been at Shoreham for a 18 period between the time he was an NUS Employee at Three Mile 19 Jaland and when he joined Bechte). 20 MR. R ICII ARDSON : That's my recollection. lie was 21 Wi t.h Nils , but he may have previoun_ly been at TM:1, then had 22 gone lo Shoreham. 23 BY MR. JOHNSON: 24 Q In any event he came f:r o m wherever he was to 25 Gaithersburg? L O ACE-FEDERAL REPORTERS, INC. 202-347-3700 , Nationwide Coverage MXb33M646
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f He drove to'Gaithersburg ti.at particular 1 A Yes. 2 day, so 1 think he was a resident in the Midd]elown area at ) 3 the time. Thal's my recollection of things anyway. 4 Q Pine. That's al.1 we want is your recollection. 1 5 Go he was hired, and I a s ti u me thal was he assigned j 6 to'Md Kit]er? ! 7 A Yes, sir, he was, q 8 O And what centact.s did you have with Mr. Parks from l l 9 Lhe poinL'he was hired, I believe .in approximately May oC' ; 10 '82, unti] approximate]y February 1903, wou]d you say?- ! 11 A It is Lypidal for me to visit the jcb cites to see 12 to t.he weltare of peop]e, their career plans, t. heir growt.h .; 13 plans and this and that. 7 had been at the Island I'm going . for guess once or t.wi c e duri ng tha t year, _ wi th the niiture of 14 LS the clartup. roles and the fact that machinery runu.around the 16 clock and that kind of t.hi ng , Richard Parks was not availab]e 17 Lhe Lirst couple of Limes I was at the job site, so I had no
.18 c on t.a c t wit.h Parks, one on one, t. hat I recall at. all.
19 Q AL all between the time he was hired until 20 a pproxiina te.l y February of '03? i 21 A That.'s right. 22 O Did you through Mr. K i t .l e r or ot.hers have a 23 reporting rela tionship such t. h a t- you got reports about the 24 perf orma ncf- of Mr. Parks? 25 A We have a iormal process of performance e v a .l u a t. i o n a ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800-3364M6
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'. I which'Mr. Killer would have been responsible for, and that's 2 .the"way those things are handled.
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3 Q Would tha t, have been the only tima you had 4 occasion to 1 earn of Mr. Parku' job performance at the 5 Island? 6 A Yes. 7 -Q l'm talking up until approximate]y Februar'y of 8 '03. 9 A Yes. Looking at a normal one f or .new empl oyoen, 10 itI was policy as is indicated or the form'right below'.the 11 duti es perfiormed, there's a reason for evajuation, it says 12 three-month and it was typical-to look at a new employee at' h 13 three months to see how they were doing. This was the f!ormal
.Q 14 form that was used at the t. i m e . It is signed on the second 15 page by 1he evaluator, Mr. Ki13er, and i t i s .a job of- the 16 chief engineer to act as a reviewer on.those particular 17 forms.
18 Q And this is dat.ed 2/1/03? Your signature -- ! I 19 MR. RICHARDSON: For the record I Look the liberty 2a of showing him my copy of the evaluation. I wish it was 21 slapled, but it is a Lwo-page evaluation upper right-hand 22 corner it says under the heading "Hval uati on l'eri od b/27/82 23 to 8/27/82." On the second page, next to what appears to be 24 Mr, Killer and Mr. Wheeler's signature, are the dates, 25 2/l/83. George, do you want to compare? 4 l I i ace-FEDERAL REPORTERS, INC. 202-347-370()- Nationwide Coverage lux)-336446
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.( 1- MR. JOHNSON: Yes, please.
)? 2 My curiosi ty was piqued when I first saw this-as 3 to the .dispari ty be tween the period of the ovaluation and the 4 date of the eval ua ti on . S BY MR. JOHNSON: 6 0 Could you explain why it was that ' t he' evaluation 7 was done, apparently, at least, it was signed by Mr. Kit'ler and yourue3f on February.l', 1983, but!-it covered'a period
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8 - f 9 'from May 27, 1982 to Augus t 27, 1982. . J 10 A No, I just don't have a reco]hection of why it:in x 11 like pulling teeth to get the job site a6pervisors at times-12 to complete these thi ngs, and with a busy'ochedule, but'I 13 simply don't have any recollection as to precisely why that 14 occurred. - 15 Q Do you recall receiving this evaluation from 16 Mr. Killer? 17 A At the time with 140 or.150 engineers, and we l 18 typically have a aLLrition rate at that Lime was probably in i 19 the neighborhood of 33 percent, so you changed so many faces ; l 20 so often and the na ture of s tartup - when I took over as 21 chief engihethr it was a big prob 3 em, we had a 33 percent-22 altrition rate. It is s ti .11 37 percent.per year, so I just l 23 see so darn many of them that I - . 24 Q Is that by the nature of the work that you do? f 25 A very much so. Very much so. It is startup is a 1 1 O J l ACE-FEDERAL REPORTERS, INC. I l 202-347-3700 Nationwide Coserage 800-336-6646 j
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j; 29934.0 VsSW 13-L ;l u I i: 1 very, very tempo ra ry type of. endeavor. l
.2 O la f.t correct, then, to say that you did not f orm l .
l 3 an impression:concerning the competence or performance of i q 4 Mr. Parks other than what's represented. in this form? I 5 MR. H1CHARDSON: Are you saying does he recall I l' 6 receiv3ng information concerning Mr. Parks' comtetence other i j than. wha t is set I? orth in the evaluation that was just 7 8 referred to? - 1
.9 MR. 70HNSON: That's fair. -]
1 10 TilR WITNESS: A couple of mont.hu - 'I'm going to 11 guess.if he was hired in May of '02, that it might have been 12 July or somewhere along there that I received a letter or. 13 piece of correspondence from the project manager,-;11m 14 Thiesing, telling me tha t a Mr. ' King, GPU, I believe he was a 15 GPU operations manager, had personalJy requested 1. hat 16 Mr. Parks'be assigned to the opera tions group at Three Mile 17 Island, in a seconded roJe. 18 HY MR. J O llN S O N : 19 Q Seconded role? 20 A Yes, where he was working as a GPU employee. 21 That's my recollection of the correspondence. I was pleased 22 with the correspondence tha t a person in Ki ng's position 23 would ask fcr one of our people by name, and it was the first 24 Lime we had anybody put into the actua l client opera tions 25 group, so t hat lef t me with a pretty positive impression O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 804336 4 46
\ l l l 29934.0 KSW l4 1 that, you know, i ff a client is asking s pec.i f i ca ll y Ior one of 1 ? our people, ihat's a pretty good omer. . 7 And it was not uncommon for me to l.alk Lo my lead l 4 enqineels on a week.ly basic to cee how things were going or 5 ii they had probIems or wha 1over, so I'm cerlain thal Lhere 1 6 wouid have been rei nf orci ng d.ial ogue fIom K i t.1 e r if 1 her e had 7 been anything rem in a, i 8 Q Do you 1ecalJ Mr. K.i i 1 e r pass.iog on information l l 9 concerning Parks' performance during that period? 10 A On occasions t h a t. 1 talked to Ed, J don't. have any l l l 11 specil?ic dates or any specilic t.i m e s . My whole impreusion l
]'2 was very positive, that thi ng s were going wel.1, and that we i
1 I la had hit ed a good man, 1 14 1 t. was perbapu into 1 ate February of '03 that 1 i l 15 had a conversa tion one Ga t.urday a f:te noon, I received a 16 le1ephone ca11 at home from our operat. ions manager at ihe 17 Lime, Mr Bruner, and Mr. Gruner asked me, he said do you l 10 have a man at Three Mile Island by the name of Richard Pa rk : 19 . and 1 .said ye:, J do, and he says we have some t;hings go.i ng 20 on op t her e now, you don't. have anv plans to t ransf er him do 1 l 21 you and I said, no, :i r, I :lo n ' t , and he said please don't a 22 make any trancfer actiont there and about a week ]ater my 23 direct h o u r; a t. the time, who is nill Adama, called me with 24 the sime conversation, and 1 mid H i 1 1 " n u z >- " 10 u ner ca1Jed tw 2S at home and told me not to I.ra na f e r t.he man and said Iine and O ACE FEDERAL REPORTERS, INC. 20b347 37(X) Nationwide Coserage 800-336W.46
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~. t 1 that was the enc' off the conversation.
2 That piqued. my. curiosity as t.o what wa's going on, 3 a t which ' Lime 1 called Kit.ler and'uaid what's happening, 4 anyt hing with respect. to Parks that I ought.to know,.and he a. 5 said, well, there's some things going on, some persotkaiit.y 6 things going on hure, but nothing of technica) substance, 7 Nothing to be concerned about. .It was over teit procedures 8 on the polar crane. I wa s sat'.ic fi ed havi ng tal ked to Ed that 9 at that po' int in. time,Schat'he thought quite highly of Parks ; 10 f rom a technical standpoint, so I had no other r aason to. 11 .believe that Parks was .anything but doing a competent job. 12 Q D.i c* you ask -- when Mr. liruner-ca))ed you 13 concerning whether you had any plans to transfer Mr. Parks,
.O 14 did you ask h.im why he was asking?
15 A No, I didn'L. 16 Q Did Mr. Hruner explain why he was asking? 17 A No, and I guess over a peri.od of time, i 0 'I knew 18 that.if a person in Bruner's ponition wanted to share 1 19 inCormaLion with me a t an appropriate time, he would. Had I 20 been part of the management practice Jong enough to know that 21 if it was appropriate for Buzz Lo share his thoughts wi th rite 22 he would have or if t her e was a reason to. 23 Q Would you explain lo me how you a nd he Cit into 24 the or ga ni zo t i ona l chart? 25 A We didn't. That.'s why I remember that it was a r. i ACE.FEDERAi REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 6646
I 29934.0 KSW .16 \ 1 Saturday that he called me, because I don't have - I was 2 part of a a engi neer ilig or 40 ni za L.i on a nd Hruner wa n part of , I 3 the project organization, so the project manager teported to l 4 Mr. Hruner and the chief engineers report.ed t.h ro ug h
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5 engineering. 6 0 So that for Three M:1.l e Island when you talk aboui. 7 project ma na ge rs you are t.alking about Rahman and Kanga? 8 A An I recal) J ,4 m Thieuing was t.he proiect ma .la g e r 9 at t.he t.ime. 10 0 And Th i e s .i ng would have r epor Led to H1uner? 11 A Yes. I balieve that was the case. 12 O And your re la t.i onshi p on t.h e organizational chaIt 13 t.o ;-I r . Bruner would only have been through some superi.or 54 level, higher level of managecent? 15 A IL Lypically would have been Chuck Santord as vice 16 preyideni. of HechLel. He had Hi1J Adams reportiog to him 17 from the engineering site and Hruner re po r t i ng to him ti ro m 18 t. h e operationu nite. At the ti me I reporlod t.o Hit] Adamn, 19 so there wasn't anyLhing in my chain ' hrough Bruner a t al i . 20 Q Okay, Adamt was your d i r o c t. nuper vi nor? 21 A Y e ': , ;ir
,.2 O That. heIpu exp3ain i t. .
23 Do you recall when Mr Killer spoke to you 24 concerniog Mr Parka? Was thib -- did you say you i n i t .i a t ed 25 that call > 0 Acn-FEDERAL REPORTERS, INC.
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. idHW '17 1 h- I think I did. My recollection is theil I did,.and.
'2 it very likely because it would be uo uncommon for me'to !
3 rtceive a call from Bruner Lhat it probably happened early in , I
'4 the week beyond. the Saturday this t he. cal]ed, which I.recal]
S is late-February, no I would say between the.probEbly Lhe <
'6 ?last' week 'ot' Pebruary or very, . very early March, . tha t l l
7 conversation would have taken place. O Q Wh'at was the next thing that happened involv.ing.
'9 Parks - tha t you 'becomo aware of ?-
10 A 'The fel]ow by the name of Lee Hofman,. who was.-- I 11 don't. know.what his exact ti tle is. I think it was. chief , i i 12 auditor. Ken, do you know?- 'I don't know Lee's exact tit]e,. 13 but he was what I referred to as -- 14 .MR. R?CHARDSON: Nor do J . 15 THE WITNESS: Internal audiL in San Francisco, 16 somet.hing like that. l 17 BY MR. JOHNSON. i 18 Q 1 w.ill be talking to M1. Hofman and can find out 19 hia title then. Ile was internal auditor in San Francisco an - l 20 far as you know?' 21 A I th2nh thal's t!' u name o f. t he orgt.n.i za ti on . I ' m' 22 no t exactly certai n. I was asked to accompany Mr. Hofman to 23 the job cite. 1 24 Q Hy who? 25 A I'm not abno.lutely sure. I believe it was Chuck
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29934.0 KSW lu 1 Sanford, but it i.L wasn't Chuck.it.was certainly by his 2 concurrence or direction, and we were to go.to'the Ju]and to 3 Lalk with Rick Parks, interview Rick Parks,.and as his 4 admi ni u trati ve chi ei , they ' wanted me to be a:1ong wi th Lee. S Q How was it explained what was going to' happen or 6 why you were going to go? [7 A Wel], t he purpose of the visit. and the intent of 8 the visit, ac I recall, was explained to me by Lee while we
-9 were act ua))y en route to Lhe job site, and he had indicated 10 tha t Mr. Parks - that.he had information that Mr. Parks had- !
1 11 vi03ated the Bechtel directsve 2-3 on ethica1 conduct and was 12 looking into a matter where Parks would have participated'in 13 preparing some resumes or having some resumeu prepared, for 14 an organization called Quiltec which was a job shop that j
' 15 specialized in supp]ying startup. type personne).
16 Q Did Mr. IloEman tell you what he had been doing up 17 unt33 that t iIse? , i 18 A What Mr. Hofman had been doing? 19 Q Yea. In other words, did he make any contact with ] 20 you prior io the day you tIave]ed to ihe 3s]and? 21 A Not that I recall. 22 Q W o .13 , assuming, then, t ha t. wa s the first. isme, 23 what was ha.ppening at the Julana with regard l o' Mr. Parks ; 24 when Qui 3tec was broached? I accume you were driving to ihe 25 Island -- l ACE. FEDERAL REPORTERS, INC. l 202-347-3700 Na'ionwide Coverage 800-336-(M6
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~1 A. Yes.
1 l- 2 0 - 5 n the car wi th Mr. Hofman, did he recount to. 1: 3 you what he had been doing upluntil the day of.that', 1 ! ,4 ' conversation concerning his coming back from fian Francisco? L .5 A No. 'He simply provided the instruct' ions that l-l- 6 asked me to' sit in .the room when he chatt ed with Parke and to 7 Lake some notes and that - he would pretty much conduc t the B meeting himse]f. 9 O Did he mention to you the name of someliody named 10 Rose Rittle? 11 A The first 1.ime I heard that name was from. Parks
~ 12 during the' course of a meeting with him and Parks identified 13 her as a secretary that he had do typiog.
O- 14 The subiect of that matter was not broached Lo'you Q 15 by Mr. Hofman prior to the Parke interview? 16 A 'No, sir. 17 0 I'm_ going to show you nome materials that were 10 int roduced tt, me in discovery by GPU Nuclear. They are 19 Hechtel calculation aheets, farms- 'with wr3 ting on'3t, which 20 says "Eile number 83-104" and the first page s tarts " sequence 21 of events" and then i t staris wi th a ] 3 ega t 3 on . "
. I believe 22 thal this i.s.the handwriting of Mr. Hofman. Does thal seem 23 to be what it is, do you know his handwri ting?
24 A I can't say. I don't know. 2S O Okay, that's similar handwriting on his memo pad. A. U ACE. FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage % 0-336 6646
29934.0 KSW- 20 7' 1 That's how I reached that. conclusion myself. 2 A I had never seen Mr. Hofman's notes. He kept his 3 notes at the Island. -They were h,is own. .In fact, Mr. Parks 4 had asked for his notes and he kept the notes h.imaelf. S Q Have you seen this ,informa tion, t.hi s ma t;erial 6 before? 7 A I' don't be.lieve I have seen thin. 8 Q Okay, this was produced-on November 13, 1986, to-9 the NHC. Thin .i o a chrono 1gy, a sequence.of evenis. IL 10 statea tl'e a1legaLion, and then i t goes a long- with indicates, 11 a c t.i on s and sources, seems to be a summary of what's 12 underneath here. 13 It goes up to February ai,d March 1983'and than 14 there's a n ent ry March 9, 1983, and-it says action Lee Hofman 15 internal audi ting travel to Gaithersburg to start 16 iovesLigaLion. Then says the circums Laor es were-reviewed-17 wilh-A, D, C, D, el cet. era. And-between G and H t.here are 18 Lwo names that are entered in the margin. Says " Nestor."
.19 Who is Mr. Nestor? j 1
l 20 A A riiv3sion manager of personnel. i 21 g And says " Wheeler," which must be you. 22 A Yes. j i 23 0 What t hi . suggests to me is that when Mr. Hofman i 1 24 came to caithersburg on March <>, 19na, he contacted these 25 peo p.l e , Hruner, Saniord, Hue)I, H1iAzard, Ka nya , Loomis, ; O ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-33M646
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(V 1 Flynn, Nestor, Wheeler, Rittle, Pa rks . ' Out you are saying to 2 me that you don't recall him talking io you before you were 3 in the car with him? Tu Loal your L es t i m o n y't ll A My recollection is that the iirst time I 5 understood tha t wha t was going on on the Island and 1,ee and I s y 6 chatted on the way 10 th'e job site. Jt is. a Jong time ind a j
, 1 7 lot at water over the dam, but my first recollection of, 8 chatting wi th 1 ce and ' learning what was hihveningwas in thi \ ,
v. i
'3 car on the way_to the job uite. In fad (,, a number OE the e
i 10 people there I don't - there's a numbel o f. people'hS'..r e that 11 I don't know. I don't know wno blizzard is and fg!)dn't know 12 f.h e Hitt.]e name or Rose R i t t .1 e . )- i c., 13 Q And it indicates on the same sheel, 3-15-83 Ilo f ma n ! l
\) exited wi t h Sanf ord, Wheeler, Nestor 0 5 ,1 1.o'onii n .
\"'
^
14 What d'oe9 s, , 15 that suggest to you or wha t do yot recall based on seeing- l t 1 16 that? 4 17 MR. RI Cll ARDSON : A foundational question has lo be 18 asked. Independent.of the document whether he recalls any 19 such meeti ng.
'i 20 rsY MR. JOHNSON: y 2.1 Q What. I t. suggesti lo me ir 1. hat you met with ;
t 22 Mr. Hofman before - - - 23 MH. HICHARDSON: He indicated he is not t.he author j
/
e g j 24 of tha t documen L. il 2S MH, JOHNSON: 1,e l r.l e -i tl s l ask the queulion. D ' L) 1 ACE. FEDERAL IlEPORTERS, INC. 202-347 3700 Nationwide Ucerag" 800-33MM6 k
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,1yt MR n J?NNSON: p' '7
, N, a' s
1: r.:
'" $.14 you ,cn.ee t wi th . Mr . Ilofman bef ore he J ef t but l , '2 ,Q a
l 3 af ter your interview with Mr. Parks? s , s
) g.
' '4 .,.,':%" MH, ikHAbSON: Ar e you reht. 2 ing 1tophe meet i ng n ._ v t + ap ..
S with Mr.' Parks brh Lhe 14 Lh f or the 'meel'[g c/r ~the' morni ng of 4 6 the-151.h? - g t .y c w
,' 7 MR. 50HNSON: Let's hold'that question.
P, x .; ,
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\
A,,QsBY Mk. JOHNSOfi: ? '
, i. ':
, s ,
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' 9 ,
'b? Whsa you gol Io-~the aite on the 1.j! h wj(t.h t j
t 1 T- QU Mr. Wheeldy;.I assume'l fwas just -- and4dr. Hofman I assume cy ;7 i g W l,;t !$ . 5 t' WasjunkyouandMr, u Hofman 1. hat went? r l '
\
12 A uY e '.. , sir, i L wa s . , v, .4 13 0 And you met Mr. Parks at a trailer'or M room 204 s b* 14 at the job site? ,
. )I )
;5 A 1t was the second f/ Oor i n . the GPil; 1 believe it 16 is c.a1J.ed th lir3"admici# r.a/tive b uil di ej. " i D,
t s.
- i. . s 34
(, _/ .<> 17 , O ( " A)d right, a @'thesh your notes of what transpired i
' ,V 18 at that meeting? -l k.
l'-
\,;
19 A Yes, ni r, U/ey aic. '\
,, ,. r n 20 Q :l L is a document of 10 paga, a t, the'end ofnthe i
'pc j
23 10th page i t. hac your signatu7e and it it dat ed at t he top N 'y 22 March 14, 1983, .ll:00 A m. s
)) y 23 A Yes,.s:r. ,
s !
' ". s 24 O And it s a y :, (?u ee MiJe 1sland, job site room 204, 25 meeting between tiof man, Wheeler, Parks and Mark Kobey'l X i ss X
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.() 1 .A Yes. "
;4 2 3- 02 I wou:1 d )ike to back up a 35ttle bit here- When 3
- q you were di scussing 'your~'<..-rga'niza t ional re ia.t i o n s h ips , was a s
4, ;, 4
~,
s '4; < )i4h'3 named Dwight Walker an eng;lneer who worked for you? LS j. A Yeg, sir, he was.
-l 9l. . .Q 'Do you recall when Mr. Walker-first came to. work .
( 0 7 for yoci 8 MR. RICHARDSON: ny way of clari f ication do you 9 -mean when Mr. Walket' was initially hired by'Hechtel and in 10 that aense under Mr. Wheeler's command, or are you asking 11 3 wlmn Mr. Walker was firs t employed a t TM1? Maybe there'u no 42 dfO.erence, but -- l l 13 ' BY MR. .T O H N S O N : 1 s 1 -q j 14 p-.
-Could you tell t.c was Mr. Walker a Gaithersburg.
,15 employeeLat some point?
l ,- .. l f efi[ t A Yes, oir. Mr. Walker was probably hired wi th P 17 Hechtel a bc .i! ;"5 or 1976. I happtned to be in the office l l' 1!f at t h . t.i k e when he war hired out of 14nn State. He was a l l l 19 graduate nuclear engineer. 1 i 20 0 And did he work from '15 until some later poi nt in l 1 21 Gaithersbury? , l r.H A 1: and out of caithernburg, he was on a variety of l h 2:h cur job sit 9.. again the nature of the s ta t tup work, some H a n n i gni,m otc . ue r e short, coine annionments were :l o nger , but he
?S had let t rhe company at one point, went to work Lor somo ACE-FEDERAL RnPORTERS, INC.
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,. h - 202 347 3 3 ) Nationwide CoveraFe 800-336-(M6
29934.0.- KSW . 24~
'l 'other company and.then returned to us, and my recollection of
'2 Dwight's assignments'in that he: Was at the Parley st ation in
.3 Dothan, Alabama, preceding his transfer to Three Mile Island.
4 Q. When-do'you reca]3 that being? 1 5 A I' don't, sir'. Without going down. and = 1ooking at a j; 1
.6 file, I can't te)) you that. I don't know,
_] a L 7 Q Okay, I'm looking at a. page ' f rom a 'deposi tion of ' -l 5 I l 8 Dav.id R. Huchanan, who was a GPU Nuclear Corporation l ll 9 employee, that goes back to I believe 1983, in which he'was ) 1 10 asked whether he knew a member of the Gaithersburg startup 11 and . Lent department Dwight Walker, and he said yes. And'he i .12 is asked-do you know how Dwight Wa.1ker became an alternate on 13 the startup and tes t department and he answered Dwight Walker 14 came to work i n si t e engineer.ing sometime i n 1902 as the 1 l \ 15 s upervi sor --- 1 16 MR. HICHARDSON: Excuse me. I don't think t hat 's 1 17 fair to the wit. ness Lo seicetively.take a snatch out of prior 18 testimony in t he record when there's other t estimony such as 19 f rom Ki tler indica ting that Mr. Walker start ed in early 20 January of 'H3. I think iL you are going to take ihat 21 approach, you ought to give him the benef i t of~ all of the 22 pri or testimony. 23 MR. JOHNSON: I would be glad t.o do that. I don 't 24 believe I brought Mr. Killer *q deposition with me, though. l l 25 llY MR. JOHNSON: l 9 L ACE-FEDERAL REPORTERS, INC. 202 347-37(X) Nationwide Coverage 8(Xb33MM6
29934~0. KSW= 25:
. 1 .Q To the best of your recollection --
1
- l. 2 MR. RICHARDSON: .The witness han indicated from i to l
p 3 his s tandpoi nt he would have to look at - 1: will be happy to l .. l- 4 make - we ' re . bere in the Dechtel o f'f i c es . Perhapa'we can: 5 check that out for you.
- i. 6 DY MR. JOHNSON:
l l .. i I, 7 Q Do you- recollect that Mr. . Walker-- when he wonL
\
1 l " l 8 to Three Mi.le-Jsland? 1 1 9 A -I can't be sure. As 3 reca.11, it was late .in'the
- l. .
l ! 10 year because it was over Christmas holiday that we brought ' l.
-13 him out of Dothan. !
12 Q Which year was tha L? !- - 13 A End of '83, beginning of. '04, . somewhere i n that l ' ! 14 time Irame. I can verify that with a call. -I just' simply 15 don't remember those daten. 16 MR. HTCHARDSON: Perhaps we ought Lo do tha t., 17 Thone of us who have stud.ied this case we)) know he was there 10 by early '83.
'19 THE WTTNESS: My secretary can give me that j 20 i nforma tion in a heartbeat if you want that information.
21 (Discussion off the reco7d.) 22 MR. ,IGHNSON: Hack on t.he record, please. 23 HY MH. JOHNSON: 24 0 Mr. Wheeler, you just phoned your secretary; is 25 that corr ect? ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide CoveraFe MO-336 6646
29934'.0 KSW . 26; 1 A Yes. 2 Q. 'And what did you learn? 3 A I Icarned tha t at late December, 1982, Dwight 4 Walker was tIranaferred from the Far. ley job sit e, which.is 5 Alabama Power, to Three Mile Island, reporting early January 6 1983. 7 Q Where was Mr, Walker in the chain of command with-O relat.ionship to you? 9 A Mr. Waiker was my site - was the project startup 10 engineer at the Parley job site before reporting to Three 11 Mile Island. 12 Q okay -- 13 A- At Three Mije Island, he would have had a .N 14 reporti ng re lationship to Mr. Kitler. 15 O Do you know t.hc circumstances of why Mr. Walker 16 was tranaf erred from l'arley to Three Mile Island? 17 A The job ended at. Parley or he was the last person 18 we had at that job site. 19 0 Did Mr. Kitler request Mr Walker to be 20 transferred or to be assigned to Three Mile Island? I 21 A My recollection of Dwight's usuignment up there 22 was tha t Dwigh t went into an engineering role that was more 23 engineering-oriented t ha n s ta r t.up-ori en t.ed . Insofar an our 24 start.up departunt went becaoue we proe.assed their time cards 25 and that kind of t h .i n g , t.h e n if I wanted to know something LO ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 80(L336-6646
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? I about how he was performing: or tha t type of adminis tra'tive 1 2 thing, I worked through.the project startup engineer on a job ,
I
-3 site. But-in fact, on'the job site,.he reported to
. 'l 4 Ga))agher, Rich Gallagher, and I think'the GPU gentleman was S Huchanan. -
'{
6 ~Q .Did you.roccivc a requent from Mr. Ga31agher that ~j 7 Mr. Walker be assigned to him or to his department? i 8 A The.best of.my reco)3eetion when I sent resumes to 9 the job site Lhat Dwight's a very capable young man wi.Lh a 10 wel) known, nice record of perf ormance t. hat Rich.Ga))agher 11 said, yes, we would like to have Walker. That's the-best of 12 my recollection. 13 0 Did you get involved in any way w3th the transfer 14 of Mr. Walker-from the role of working for Mr. Gallagher to 15 the clartup and test role?- 16 MR. RICHARDSON: Excuse me. That missLates the 17 record, 1 think. I don't believe there's testimony that 18 Mr. Walker lef t' the capacity of doing work for 19 Mr. Gallagher. There was teclimony tha t. at some point, 20 Mr. Walker did replace Mr. Parks as Mr. Ki t.ler 's alternale, l' 1 21 that in to serve as st.artup supervisor in t he absence of l , 22 Mr. Killer on the site, but your question presupposed a l~ 1 23 complet e shift in responsibilities. 24 BY MR. JOHNSON: 25 O To the best of your knowledge, did Mr. Walker O ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 6646
29934.0 KSW 28 p( h 1 continue to work for.Mr. Gallagher during this winter and. 2 spring of 1983?
-3 A I believe so.
4 . O .. Are you acquainted w3 th the c. circumstances in which 5 .he took up another assignment in addition to any other 6 ' assignments he may'have had for: Mr. Gallagher in functioning
-7 wi th respect to the s tartup and Les t department at Three Mile 8 Iu]and?
Most of: those kinds of't.h.ings were hand. led on a i 9 A 1 10 project-by-project-basis,.and the deLail of precisely whaL l 11 any individua] .is doing at any given day, it would not be 4 12 ' uncommon al all for a person to do a wide variety of tasks on
,- 13 a particular job site.
14 Q Do you recall Mr. Kitler condu3 ting with you about , Ifi having Mr. Walker be asuigned as'his alternate startup a nd-16 test supervivor during Tanuary or February of 1983? l
'17 A No, I don'L remember anyLhing.specif.ic Lo'that. -
.l 18 In fact, it seemb to me 1haL 3 had conversations about the 19 time frame of the -- or preceding ihe time trame of the Parks 20 matter coming up and Hofman and the i nt ervi ews and no f orth 21 f. hat Hichard Parkn would have been a likely candidate to l 22 replace Mr K i i .l e r . Kitler bad asked me f or a t r<wn s f e r , and 23 I don't recall whether iL was Thiesing or Gallagher, but it l
1. l 24 wouid have been very, very typical Ior me to ca]1 a project 25 manager il I had knowledge that a lead might be requesting a ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 8(433M646
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29 l 1 transfer for whatever.caune'to say,. hey, listen, who would ')
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2 you - t.his in .l_i k e l y ' t o occur, what_'s best for the project', 3 what's happening, who is loaded, who has,too much to do, too 4 . l i t t.l e to do, how do we go about that? 5 Q And'Mr. Ki t.ler_ con tacted you a t 'some point about 6 his leaving and ment.ioned Mr. Parks as-o possil>]e 7 replacement? 8 A Yes, sir, I believe he did. :] 9 Q Do you recall when tha t was approximately? . j q 10 A Probab.l y earl y 'i n '83. j 11 Q Could we= place it befare or after your trip with j 1
-J2 Mr. Hofman to the Island? . 13 A Before. !
14 0 It was belore?- 15 A Yes ,. si r. l 16 Q So it would have been before March 14, 1903? 17 A Yes, sir 18 Q Ilut apart from ihat contact, you don't recall 19 being informed prior to that ca11 t ha L Mr. Parks was being 20 replaced by Mr. Walker in the all. ornate start.up and test. 21 f unc tion supervisor? 22 MR. HTCHARDSON: Wou:Id you please read the .last 23 question. 24 (The repor t er r ead 1 he record ac requested.) 2S THE W'ITNESS: No, sir, I don't have a recollection , 9 ACE. FEDERAL REPORTERS, }NC. 202-347-3700 Nationwide Coverage 8(n336&t6
l i I l 129934.0 i KSW- 30 t: f .; [}-Q:
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1 o f' ' L h a t . , 2 HY MR. JOHNSON: 3 Q: There wouJd not have been a need for Mr. K3t]er to 4 contac t you necessarily in order to have 1.his project 5 assignment made on the Tsjand? 6 MR. RICHARDSON: I think Lhe ques tion - lL 7 MR, JOHNSON: bet me rephrase 3t. 1 m try.ing to . O fligure out what your procedures are. l
. .9 BY MR. JOHNSON:
10 Q Assuming Mr. Kitler did, in fact, designale 11 Mr. Wa3ker in Mr. Parks' place as alternate to him,-would' 12 that have been a function or a decision that he would have' 1 l- ' r. 13 been required to c: lear with you? 14 A No, sir. It would have been handled on a project l 15 basis. 16 Q So it wou]d not have been unusua3 f or him' to do .; 17 that wit.hout consulting you? 18 A It wou:I d not have been unurntal at all. .That would 19 be commonplace a t just about any job site. 20 0 And similar]y, did you becomo aware at t.he t.ime 21 Mr. Walker was ansigned or designated by Mr. Kitler Lo be 22 a] ternate startup and test supervisor that that was being 23 done contemporaneously? Did you becomo aware 24 contemporaneously of Mr. Walker being assigned to work at the l 25 Tuland au Mr. Killer's a l t.e t'na te nLartup and Lest O ace I2EDERAL REPORTERS, INC. i 202-347-3700 Nationwide Coverage 800-33MM6
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~,-f h, [ 1 Supervisor?
.2 'MR . HICilAHDSON: It in not clear. wha t you, mean by 3 " contemporaneous 1y."
4 HY MR. JOHNSON:
~
S .Q At.the time.Mr. Walker was designated to that 6 position. 7 A - A)) . 3 - can gi ve you i s my. sense of thi ngs . If. we: 0 have a' man; tha t seconded to a clietyt's operations - 9 . organ 3zat. ion-then it would seem-)ikely-thai the atartup 10 . organization would be lacking in some assistance,.so.it would seem t o be a very norma),- practical thing to do. 13 12 MR. RICHARDSON: The question waa', when that 13 change was made,. were you '--- did you become aware of: that .
- x 14 change when it was made? s 15 MR. JOHNSON: Right. That in -the questi on.
16 TilR WITNESS : Not that il stands out-o way or 1 17 the other,- no. J don't have'any direct knowledge of' that. L. ! 18 BY MR. J OIIN S O'N : l-19 O' Iu your answer'that you do not reco])ect having 20 any knowledge of it at the Lime? 21 A That's right. I do not have any reco3]ection of: 22 tha t havi ng taken place. 23 (Discucuion of f the record.) .I 24 BY MR. JOHNSON: ; I 25 0 In a slightly different vein, do you recall giving O p ACE-FEDERAL REvonTEns, INC. 202-347-3700 Nationwide Coverage 800-3364 646
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. 1 any sworn statements or ' depositions relat,ing to the Parks
-2 matter, the allegations of Mr. Parks?
3 A I don't'think so. LI obviously have talked to our 1 4 management and so f orth about the matter, but nothing 'in this 5 kind of a forum that~I recall at-all. 6 0 Other than the -- 3 have a statement that - an l-7 affidavit that you prepared. It is signed t.he 2nd of L _ l . j l: 0 October,-1984, Gaithersburg, Maryland. I'm not. going to ask . l 9 you about i t - now, but I assume you recollect giving'that 1
.- I 10 sworn statement?
- l. 11 MN. RICHARDSON: Mr. . Wheeler, take your time and' ,
12 read this affidavit. 13 THE WITNESS: Yes, sir. I agree wi th tha t 14 statement.
'l 5 MR. RICHARDSON: The question simpiy io is this a l
16 copy-of an affidavit which you signed? 17 THE WITNESS: Yes, sir, it.is. 18 MR. .TOIINSON: Can I have it back, please? j i
'39 HY MH. JOHNSON:
20 0 Did you prepa re any o ther s t atements in addition 21 1o this af 1idavit concerning any of your roles or role in-the 22 Parks ma t t er? 23 A Not iha L 1 recal1, sir. 24 g Do you have any noten of your meeting with 25 Mr. Parks other ihan Ihe noten that I showed you momenta7i3y? O ACE-FEDERAL REPORTERS, INC. 202-347-37(K) Nationwide Coverage 800 336-6646
.29934',0 KSW 33 1 A No, sir.
2 MR. RICHARDSON: =Just to make sure my 3 understanding was right,'I~ gather by the 1ast quesLion,
~
4 .Mr. Johnson,.you.are. referring to the meeting an March.14? 5 MR. JOHNSON: Yes. I had to define lhe' document I' 6 was reierring to~on the record. 7 BY MR. .JOHlNO N : 8 Q During the interview with Mr. Parks on March,16, 1 9 assume that from what you said that. you were' asked to come 10 a.long principally l as an observer by Mr. Hofman? 11 A Yes, sir. 12 Q And to take noten? 13 A Yeu, sir. 14 0 .Did he indicate any other role he would 1ike you 15 to play.at the' meeting? 16 A- No, sir. 17 0 Di d you ask any ~ questi ons during that int.e'rvi ew? 10 A Not until such time in the' interview that Parks. 19 t.alked about unfety, at which time, from a technical sence, 20 my allen Lion immediately piqued because thal's an issue which 21 we take enormously seriously and Mr . Hofman ic not an 22 engineer. Ha had another purpone, to 'ake a look a t' breach t 23 of -- potential breach of ethics, and at that point, he would 24 not. have understood the dialogue concerning the safely 25 issues, and immediately after the safety incues were raised, O ACE. FEDERAL REPORTERS, INC. 202-347-370() Nationwide Coverage MO-3364646
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'I although I should say " safety-insues,":he wouldn'L s' hare-2 anything specific whatsoever. 'I asked give me an example. ,
l 3 Give me something that we can put our hands on, and he wanted l l 4 to'say that to a vi ce president. A t tha t. point. i n t.i me in 5 the meeLing we immedia tely arranged for a meeLing for him to-6 do so. 7 0 Did he monLion the po]ar, crane, the problems.with: l 0 Lhe polar crane al least? 9 A Yes, sir, he did. 1 10 Q Was that the first Lime that you became awa re that -) 1 ! 11 he had concerns about the safety of the po]ar crane or t.h e 1 1 12 l'o110 wing of procedures wi th ~ respec t to Lhe polar crane? [ 13 A It was the first t.3me t. hat I became aware that he 1 1 1 14 had a problem with safety issues. I don't remember his exact 15 words in the inLerview, but. the polar crane is not. safe. 16 There are quali ty assurance violations,.and the only _ l. 17 i ndi ca ti ori t.lia l I hind previous to t. hat that there was my i 10 . conversation with Killer saying in there any thing I' should 1 l l 19 know about going on w.ith Mr. Parks after I had talked to 1 20 Mr. 13runer and he indicated well, there's some procedural 21 hassleu on -the crane, but there's nothing of substance there, 22 and I took tha t al face value l l 23 O And was 'Lhat a)) you knew about. the issues that 24 Mr. Parks had raised abou t proceduren on t. h e polar c ra ne'? i 25 A Well, t ha t. 's all I knew. Empi ri ca ll y , 1 was j O ACE FEDERAL llEPORTERS, INC. 202-347 3700 Nationwide Coverage 800-33MM6
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I enormously confident 'in the technical competence of.-the 2 people 5nvo.1ved aL Three Mi3e In3and, I had done sta f f wcirk -
~
3 on the polar crane so I knew every nut and' bolt on that 4 -1a1and got.. looked;at with ineredib)e cerutiny, .I had.had S every confidence in the world that business was being
-6 conducted an normal, and I inferred from the orig.inal 7 conversation with Mr-..Kitler that it w'an.a' matter of 8 personalities or' not undernt anding ii management proccus. iis-9 opposed to anything technical.
10 Q Bot. ween ihat. ca]3 wi th Mr. Kitler and.t.he 11 interview with Mr. 1sarks on March 14, 1983, did.you learn l 12 anything else concerning Mr. Parku' concerns about the.po)ar 13 c raine? Jo A No, sir, I did not. 15 Q in the last paragraph of.your notes on'page 10, 16 which I showed you before, you make some observations about 17 the way in which Mr.' Parks appeared at the ' iirterview, and you 18 wrot.e down come observations about. his f eeli ngs , and-you say 19 at the end, "I find it strange that until now he has not 20 shared any of these feelings with me, his Dechte) on-nite 21 supervisor, and Killer has not indicated a major problem." I 22 take it that t.ha t. reflects 1. hat what he was stating, at least 23 at the second pa r t of the i n terview, was banica11y new to you 24 at the 1.i m e . 25 A Yes, sir, it was, and the comment in simply that e ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-33M646
29934.0-KSW 36 1 if, )all of a suddet', there's a comment concerning safety 2 which seemed t o et i out of the blue, a nct taJks about threats
)
3 during the intervie< cith Mr. Hofman, why would he not have 4 picked up'the telephone and ca))ed me.and said, gee whix, I 5 have a problem hern? lie certainly knew the process, he 6 certainly knew who 1 was, that any employee has that 7 prerogative to go to-the chief. engineer.for help. 8 O So that given that you were his Bechte] 9 supervisor, it.wou.1d have been perfectly appropriate for him j
.i f he had a probJem such as th.is.to contact you?
'I 10 11 A- Absolutely. .
12 O Hu t. he didri' t? 13 A No, sir, he di.dn't. 14 O Could you tell me wha t happened at the conc 3 union 15 of the interview with Mr. Parks, what you did at the 16 conclusion, f ol l ow.i ng it? 17 MR. .RTCHARDSON: Are you asking whaL happened j 10 after Parks left the ineeli ng or -- 19 MR. JOHNSON: Yes. , 20 BY MR. JOHNSON: i 21 Q Once Mr. Parka exiled from the interview, what did 22 you do? 23 A Preci s e :l y . We returned to Gaithersburg, and I'm 24 uure that we muut have informed Mr. Sanford of what had 25 t ra n s p,i red at the meeti ng on the Inland, and the next t O. j
. ACE FEDERAL REPORTERS, INC.
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~29934.0 KSW' 37 1 : morning, Mr. Parks came down here for.the meeting.with Chuck, m
2 Q On the way backl-- 1
-1 1
3 MR.-RICHARDSON: Hy " Chuck,"'I assume you'mean .]
)
'4 Mr. Sanford? I 5 THE. WITNESS: Yes. I'm sorry.
1 I 6 HY:MR.: JOHNSON: j 1 7 Q D.id-you have a d.i scuuu 3 on wi th ; Mr. Hof man l 1 0 concerning the 3nterview with Mr. Parks during.your~ return. j i n 9 . back - tco : Gai thersburg? JO A -I ' m sure we did. I'm sure we conversed about it 11 all the way back, yes. I 12 Q What do you r.emember aboutLthat conversation? 13 A Well, I'm sure that Lee would have asked me, Lee 9 '34 Hofman would have auked me how did I. fee) about'the-t 15 interview. Did he conduct the interview in an appropria te 16 manner? 'J' hose kinds of'thinga that Lee wou]d have asked me
- 17 to make a record-of them, my own notes, in fact.
18 Q Just one second. On the notes, were these notes 19 that we ident.itied earlier made during the interview? 20 A Yes, they were. l-l 21 Q And that lasL paragraph thal we're talking about l 22 on page 10 was that a]uo made then or was that modo .later? 23 A 1 suspect the last paragraph was probably made at 24 t.he conc 1us. ion of the interview. 25 0 Before you left? O ACE-FEDERAL REPonTens, INC. 202-347-3700 Nationwide Coverage 800-336 6646
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-1 A .Bef ore '-
>2 O Hefore y6u 3ert the room where the i ntervi ew : took
~3 place or'--
4 A Yes, sir. 5 Q Getting back to your conversation, do.you' recall I 6 what you Lold'Mr. Sanford concerning the. interview.'on the,.wdy 7 back? 8 MR. RICHARDDON: Saniord or Hofman? 9 MR. JOHNSON: Pardon ~me. Mr. Hofman. 10 THE WITNESS: I don't remember specifically what I , i
~
11 would have told Mr. Hofman. I expect my comments.would have 12 simply' echoed ~ Lhe notes that I took during .the courne of-the 13 meeting. 14' BY MR. .J OH N SON : 15 Q Did you discuss with-Mr. Hofman the specific 16 ' evidence or inf ormation that had come out during ' the 17 interview concerning Mr. Parks contacts with Quiltec? 18 HR. RICilARDSON: Could you read that back, 19 please? l 20 (The reporter read the record as requested.)' .) 21 THC WITNESS: I simply don't remember. That in 22 very proba bl e M1 Hofman not being an engineer, there were 23 certain information li ke wha t is a job shop? What's the 24 marketplace for a job shop and those kinds of things that I 25 would have helped him understand, you know, what that O ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage MXb336-6646
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-Q'u .I tbusiness is alliabout.
]j
,. 2 BY ;. MR . , J OHNSON . D ,i
.3 .Q Do you recall . what you thought concerning. . .n d Mr. Parkn ' arrangi ng to have- resumes typed'by Rose Rittle"'n- o 1
-i 5 Quiltec stationery?' l 1
l -6 A I s uppose that' the 2-1 ' directives '3 n~ Hechtel :are '! [: so well-known, so well supported by the Hechtel family-that-l/ 7 8 i t .5 c just the very nature of.any Bechte] person to be proud 9 of: working Eor the company, and there wasn ' t a ny ..doub L in my. ~i l 10 mind that this'emp3oyee had partic.ipated .in an area that. i l1 11 i m pugned ' .the inlogri ty of Bechtel, and - i 12 Q How did it impugn the integrit.y of Dechtel? 3 7, , I'3 'A WeL1, obviously if we're. helping.somebody.or if he-l 14 wa s ' he.1 pi ng somebody to conduct a busi ness. 'tha't was. i n y j 15 conflict with our client, tha t certainly doesn' t. say much. l 16 Q When you say that he was helping: somebody 'in a L7 business tha t' was in conflict wi th your client, with 18 Dechte3's c l i en t. , are you referring to the request, 19 specifically, to type resumes? ! 20 A Yes. 21 O Wa s there a ny a t her i nf orina t i on tha t. you had at 22 the time you had made tha t observa tion or conclusion on the 23 14th of March, 1983, other than that, Mr. Parks had been 24 involved in the typing of resumec on Quiltec s ta tionery? 25 A Mr. Hofman, my recol.lection in t. hat on the way to
.O ACE-FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Coveragt 8(n334(M6
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- U, 1 the job' site,.Mr. Hofman told me the basic reason for the i .2 inquiry and in tal; king to Parka andlit-~was because of a 221 3 conf lic t .i nvolvi ng L l.h i s _Quil tec l job '6 hop. MostLof:the 4 information-that I rea))y'1 earned came out through'1.ce's=]ine
'5 of-questioning, Parks gave him.thefinformation in the 6 meeting,-so I.. learned the majorit'y of.the information th'at. 1-
~
/ had during the' course of the meeting i tuelf ...
8 Q .50.your observation tha't what you~a'e r feeling I l
'9 about Mr. Parks' invol vement and ' its consis tency with Hechtel ;
't 0 policy.2-1 ,i n based solely on wha t'.you . heard during that 11 interview?
12 A 'i ' I hi nk t ha t 's a pret t y f a i r s tia t emetrL . Yes, sir. -l
- l'3 Q During the interview. did the subject ol 14 Mr. Parks' resume being typed or Mr, Parks' resume being used -
25 .by Qui 1tue come up? 10 A My'reco))ection of'that is thal Parks used hi s . or 17 uuggested that his resume be used as a sample for others to 18, be prepared. l 19 0 hut as far as you recollect, did the subject of 20 Mr. Parks' resume being used in -- for example, in proposals 21 for Quiltec, d.id that come up? 22 A T don't have a recol1ocLion of that, no, ni r. 23 Q And your notes, if th,in had been brought up, do 24 you think it would have appeared in your notes? l l 25 MR. RICHARDSON: That calls for speculation. l 1 I I ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage MXb33MM6
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1 MR. JOHNSON: Let me . jun L ask you t-l i) 2 MR. RICHARDSON: I want'to takelthe ti me to '-~ .
.- 3 HY MR. JOHNSON: _ .- 4 :0 1.et me ask you to t ake t he time : tcriook a t. your =- l S ' no tt4 0.
6 MR. RICHAHDSON: ..If you are no't sure.whether 1 7 somethi ng :i s reflec ted in your notes.from your memory, please 8 take t he time to carefully review your noten. ] 9 THE WITNPSS: Well:, the meeting was several hout"n' 10 - .l o n g , and: I 'm sure tha t I . di dn ' t ' wri te everyth.i ng down .that 11 had. beeti said. I understood that we were' looking for a 1, 2 re]ationship wiih the QuiJ tec matter, and my notes probably- _ 13 reflec t more thiiigs ilirectly related to..that than some'of the
-14 cursory dialogue that .may have been .i mportant af ter the IS fact.
16 HY MR. JOHNSON: 17 Q Did you ever become aware of proposals - of 38 specific proposals by'Guiltec to variouc utilities or 19 cons truc tors of nuclear power plants? l 20 MR. HICHARDSON: Apart from what Parks said dur.ing 21 the interview? 2? HY MR, JOHNSON: 23 Q Okay, a pa r t f rom wha t you learned at. the 24 3nterview? 25 A No, ': i r . O ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 8(Xb33MM6
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l 1 1 Q Did you ever become aware that Mr. Parks' resume l 2 had been .i n c l u d e <' in a proposal of Qu :i ll t ec submitled to 1 3 Public Serv. ice Electric Tx Gas company in ilopt Creek s ta t. i on ? l 4 A No, s .i r l 5 0 And did you ever become aware that Mr. Parks' j i (i resume had been included in a Quilloc proposal to Duquesne 7 I,i g h t Company? 1 1 1 8 A No, ^: i r . 9 Q Did you discuss Hose Hiit.le's yole in ihe typing 10 of re'umes wit.h Mr Hotman on your trip back from the l 11 interview on March 14? I 12 A No, ait. I don'L belleve so. 13 0 Did you discuss with Mr. Hof man the seriousness of 14 t. b e violation of directive 2-1 with him on that t rip back? I5 A Not to my s pec.i f i c rec o:1 i ec t i on . I t. seems to me I fi that that'. quitr plausible, but- - 17 O Do you reca)1 it beinq - thinkinn it was a l0 serious violation? 19 A No, uil, a nri T think that t.h t e r: .. u i n q decision 20 r e f 1 ec t.n recommendations made i h a t. Pa rk n be :oni i nued 21 plobabIy rofIectr some of t.ha t 2? O Were you conculs.ing your no t.ea on pages 4 :nd 5 23 when Mr Hof ma n in aching for de t a i l: concer'ning what 24 1. ra n s p i red in I. h e typinq incidont, wel e you a l. all uniprined 2% by t he- leve! of driaii thai Mr Hol ma n was pornuing wiih O ACE-FEDERAL REPORTERS, INC. 202-347-37(K) Nationwide Coserare 8(K)-33Mi646
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'l Mr.' Parks?.
'2 A .Noi No, I wasn't. ,
Do you remember any . chanye .or ar.y thing specific 3 Q 4 about Mr. Parks' demeanor during when the discussion gotatite
'S .this kind of, detail?
6 A No. Mr. Parks wasLquite defensive froin the start, 7 and thal didn'L seem to change tbroughout-the course.oE the. 8 -interview. n . . 9 0 okay, could you deceribe .it in any more detai.1 how 10 he appeared to you during the interview? 11 A Uncomfortable, reading the body language that most 12 managers 1 hat'have been trained in nonverbal communication, . 13 signs of nervousneca, discomfort. 14 g Did you consider t. hat he had behaved,. acted in any.
.i 15 way inappropriate]y during the interview? !
l 16 A No, sir. .j . 17 O Hased on what you heard at the' interview from , 10 Mr. Parkn, was it your impreunion tha t Mr. Parks was a'close 19 friend of Mr. King? 20 A Yes, iL was. 21 O And what was t.ha t based on? I 22 A Well, ihe specific asking by King to have Parks ) 1 23 neconded to his organization. I 24 Q Tha L word " seconded," s -e-c - u- n --d ? i 25 A S-r*-c-o-n-d-e-d. ACE-FEDERAL REPORTERS, INC. 202-347-37N) Nationwide Coverage 8(n3364M6 _ _ - - _ - _ _ - - _ _ _ . _ _ _ _ l
29934.0 KSW 40 1 Q You define that as nomet.hing specifically detai1ed 2 into t.he c].ient's organizal. ion? 3 A Yes. In fact, I don't know that an actual 4 seconding .l e t Ler took piace Th a t. ' s perhaps a s upposi ti on on S my part, but typically when we put somebody directly in a 6 client's organization, to t.a k e technical direct. ion from a 7 client, t;h e r e is some sort of a document like that put in
- i. O place 1
9 Q 'I'm sorry for i n t errupt i ng, I just wanttxl to make 10 sure I undersLood i t. . 1] MR. H J Cil A RI)GON : I think there al e .l o o s e l 1 l 1? understandings o f: t.h e term and narrower interpretations of 1 13 the term. Certainly, Mr Parks wan not seconded 1.0 G Pl1N in l l 14 the sense t ha t. GPlIN paid hin salary, for example; is that l 15 correct? l 16 THE WTTNESS: No, they did no t. . l/ MR. RICHARDSON: I think we're in the middle of 1 18 Mr Wheeler': answer t.o the quosLion abaut why he had the l l '9 impression t. h a t Mr Parkn was a c!.ose frlend of Mr. King. 1 ! 20 HY MR. J OllNSON : 1.1 0 That's right You said one wan that he was 22 9econded. Anyt.hing eIne? 23 A Well, in the sense t h a t. Mr Kinq asked Park', to do 24 l.h e s e iesume, for him and Mr Parka Laiked a t>ou l a Mr. Glone 25 t.ha t he w a :, r e s po ns: i b.l e lor hiring. I don't. know exactly l O ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coserage Mn336-6646 l
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KSW 45-1 what that meanL, bul iL.seemed to me that they were-a11 very .
~2 closely' aligned and knowledgeable about this Qu.iltec 3 - orga ni za tion .
.4 'O So you drew an inference.from the fact-th'at 5 Mr. Parka said he was responsible.for Mr. Slone'n work at 6 Shoreham that Mr. Parks was a close f riend of ' Mr. ~ Ki ng?
7 A In the context of the total ' conversa tion as Pa rks 0 uent.on, I. pretty.much f ormed an, opi nion that ;they .were i 9 pretty'close Criends. 10 .Q Did he say he was a close f riend?'
'11 A I don'L reca11 those words specifi.cally, but that 12 was my impression.
-13 MH'. JOHNSON: Let's Lake a'brief. recess.
'14 (Recess.)
15 HY MR. JOHNSON: 16 0 When you returned. Lo Gai thersburg, did you have a 17 meet.ing with Mr. Sanford on the loth of March? 18 A l'm quite sure we would have had a meeting wi th 19 Mr. Sanford to apprise him of what had occurred. I don't 20 know whether that happened thal evening cr-lhe following 21 morning because it would have been preLLy late in the day 22 driving back. 23 Q Where did you speak to Mr. Santord? 24 A Typically, if we had meetings with Mr. Sanford, it-25 would have been in his office, a J i t.t1 e seatino arca ad jacent 4 Ace FEDERAL ReeonTens, INC. 202-347-3700 Nationwide Coverage 800-3364M6
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-KSW-1 'to his office; 2 O It was eit her la te on tlas 14 th' or early on the 3 ISLh?
4 A Vos, sir, I'm sure we would.have appr.ised him.of 5 what had occurred. He was the responsible officer that 6 Mr. Parku was going t o meet with on th'e_15th. 7 Q Do you specifically remember the meeting? You say 8 you are ' s ure --- 9 A Not at a level of detai1 that I cou]d say t hi s 'io 10 exactly what happened with Mr. Sanford, but I'm quite sure-11 that. we would have apprised Mr. Sanford of what had
.12 transpired at that meeting.
13 O Did you give a briefing to Mr.,Ganford or did 14 .Mr. ,Hofman? 35 A 7 'm sure i t would have been a participative type 16 of thing where we both would have pa r t i ci pa ted in the
'17 process.
1_B Q And Lo.the best of your recol.lection, what; did you 19 Lell him or what was told to him?
~20 A Perbaps I'm getting ahead of the s cena ri o . Thero 21 was a poi n t. in time, and il may have been even following the 22 meeti ng that Mr. Danford had with Mr. Parku, when Chuck in 23 his very pleanant fashion solicited, what do you think? My L
1' l 24 response to h.i m , and 1 remember it because 1 thought so much 25 of Chuck Gantord. Ile is a manager that I think you could ace-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 8(Kb336-6646 1
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.1 write-a' textbook about, I said, Chuck, I'm on the fence on 2 this'one and I can't jump very far from the-fence either 3 direction 1 go Chuck said, well, young man, I have been
'4 looking:at'peopIe 20 years longer than you have and I can't 5 get very far ' Erom the fence either, and I think that part of' 6 t hat dialogue ref lected that in the 'fina] decision t.o. keep-L7 Parks on, tha L we weren ' t terribly comf ortable' wi th i t, - we 8 weren'.t.1errib)y comfort.able wi th. a breach in our ethies, . but 9 there was enough doubt that we were going.to give an employee the ' benef i t. of the doubt and I think t ha t '.s 30 typi cal ' of:
1 11 Hechtel, Let's make a decision in favor of the employce and j 12 go forward wi th our work . 13 0 'What were come of the factors t ha t you considered-14 or Mr. Sanford discussed with you i.n deciding which' side of 15 the fence you were going to Jand on? 16 A Well, I think one factor would have been that 17 Mr. Parks was fairly forthright in te31ing us what he did2 10 with Quiltec. Another Eactor was tha t in a fashion thab' - 19 Parks won. hired where he was already there at si te, where we 20 had client recommendations, the typical process when an {
- j. 23 employee is hired where we have a personne] Organization, j l 22 suppose aomebody was hired right here, after the technical 23 conversation with the chief engineer and maybe people on his 24 s ta f ff as appropria te, then that employee would be taken to l
25 personnel and the personnel people would tatk about empl oyeo O ACE FEDERAL REPORTERS, INC. 202-347-37(X) Nationwide Coverage MX)-336 6646
I 29934.0 KSWE 48 1 benefits'and medical and dental and'rgtirement, and one.of 2 the things 1. hat is quite typica] is the' employee ends up ! 4 3 'being told'about'E80 concerns, being Lold about the Bechtel 4 'd.irectives and-signu a paper say.ing that', Jike, if you invent 5 anything while you-are'with Bechtel, iL'is.the property;of 6 HechteJ.. It is because of your emp]oyment you come up with 7 any kind of copyrigh ts or = anythi ng they .are- company 8 ' property. Those- personnel type f orms , ' Parks came down . and - 9 interviewed and then he was act.ually hired in the field, and 10 there was not a personne] organizal. ion available at'Three 11 Mi.le Island to do 1. hose normal thingu, so there is no record 12 .of him havi.ng been briefed on'those kind of l.hings. 13 .Q. Tu ihis whaL you.are referring Lo? This is an 14 Exhibit 2, I think a statement that Mr. Parku.gave t.o the 15 Department oC Labor. Is that the Hechtel.documenL Lhat you 16 are re f erri ng t.o , or one of t. hem? 17 A Yea, sir. That looks like l'L , 'In f ac t, I' m .not -! I' 10 so sure that when I went up to talk to Parks at one time'I 19 didn't- give him a copy of that. 20 Q You mean at the ti me of the interview or sometime 21 later? 22 A It was afIer the fact that my assistant and I went 23 up, and there were a couple or forms thal were missing al 24 that time when we went up to tell him he was to be kept as an , 25 employee I covered Lhose topics with him. O < ACE FEDERAL REraRTens, INC. 202-347-3700 Nationwide G rage 800-336-6646
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'l 1 0 'This.is one of 14he factors you-coasidered, tha t : h'e
-4;'y..
2 had' not .been 'Iormally brief ef about compliny practices prio? .j 4
'"O l- 3 .to his - or , at the time he became a Hechtel ~ employee?g -
y, 4 'A' It.would have~Jeft an element of doubt and 1we- l 4 J 5 wanted to make sur'e that we covered those bases . i, - 6 -MR. RICHARDSON: Are we' speaking.about based on; [ company policies? ' 7 ; l B THE WITNESS: Yes, i
'\ I i
)
I' 9 PY MR. ' JOHNSON: 1 s 10 Q What other considerations were.there? 'N i 11 A 1 don't recall a by' others specifically. l L 12 Q. Had you reacaed a conchuij on -- wel.1, lhece
- (
13 factors that he was forthright about his relationship to-
- 9 14 QuiJtec and:the h.i ri ng prothfiore wh5 ch Mr. Parka became a.
'(' w 15 Hechtel employee under seem to be factors .1eading you Lo juAp ;
16 off on the side'of the fence retaining'Mr. Parks. Were t.here p . 17 other Cactors tha L wenLLa i the other direetQ n, for' examplo, 18 the nature of Mr. Parks' 5 nvolveinent wi th Qui J t ec, for 19 example? 20 MR. RICHARDSON: He has already tent'ified about 21 reasons why he formed an opi nion or f ee ling - tha t. Parks was 22 involved to some extent with Mr. King's conf.lict. of 23 interest. Are you asking him whether there were other . I 24 factors in his mind with regard t.o that feeling or are,we
)
[ \
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25 .l i m i L i ng ihis i nqui ry to factors which were discussed between J t- ) O , 1 l ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
[----------------------------- ;7 \ ' t 7i N i ; .j 5 I 29934.0
- l VS W 50 l t I (- / 1 Mt. Theeler and Mr Sanford?
, 2 MR. Jf 0HNSOid : 1 think that that the .l a n 't pii r t l l
,, 1 wa .c fhe cont.exL in which L. h i : diucu, ion aLarled. t
\
s 4~ MR. R J C H Ms'im ON : 'I' h a t ' ' what I ~t h o u g h t . , 5 MH. .10 H N '. :i .i N : N >u were- discusuing with Mt. Ganford I 6 ihe f a c t o.r S c o nc e r n i n ', f /,0w' f a f fIom the Ienre you would be 7 able io jump, and i asked you 1 L.hink a f l.e r 't . h a t. w h ,; e f ac Lors t > e 8 were you rei e.r r i A; to. So I can ;ee how M.r Richardnon1; i 9 question would como up. t 4 1 .10 RY MR. lOUNSON: r e a ?g'( focu.ing on i h a t. docinionmaking
~
1 Q I'm i
- 1) { }T (l(* (ib ' , d jlb k 1 (" I (I ' ' f(>ll C (lll!l k (} ( [ ( *(} oft t'i ! I)(* f 1 i (I(1, i) [) d jf oll is 1 , s c WI. gave me two factqrn on og s s i tie We rts I.he re tactors on 1, h e
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[T hbee}er Whdi I hC1 oM VMD diiOUU d bOkWeen bIM dnd 8 MT 5 Si1111 o rd c' o it t: < :1' n i i e(1 t. h i > i () L I'< > t k u ' m s s nv o m,mn i ne menooned 1 mo , o yoo. i m b}' ih iN i n n:
~
'O MR ,10i(N S O N : And 'l ' m trying io got olher f ac t o r:.
2] ihat he &y have coneide il d .
? ;q MR. R '(H AW GON : c'o nn i,m red of d i sc u: :ed wiih
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3g 11 / 'Eff. RICHARDSONs If -yc?u ' are saying " cons idered," o *'9, , 1 'th6n he in n.lready b6 yond .b r.s e two'3rdicctedo 'ther factors 5 i n re.Nponsc < to your prior queations. Ms you asking for N s 6 facto:S in addi13on to what'h>:'has a3 ready testified about.so "li far?
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l.)h . 10 MR. RI EARDSON: That's a narrower question. Hefs t 1, . . 11 asking you what factors were discussed with Mr. Sanford. l- ,,
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t 12 THE ,WITjiESS : The on:ly.Other thing I eran recal] : there is that indedd Mr,. Parks reported directl'y to Mr. King,
< - 13 b= '
m l, 14' and so iE mig he=conce.ive<[ that he was repo r t.i ng to his a,xy > 3 15 boss and d h ag"What his bos [, i:old him without much thought i 16 procett:" as to whether i ' . w ,' ra ghi., wrong or-indifferent. I l t . . t7 HY ME, dGHNSON:
,o A , : t Q What did Mr Sanford say to you other than he a3so
]t l 19 based on his additioFtl 20 years of experience, never jumped r y, ,- i f 20 . t.o o rence, what el se did he say about his 1- f ar fro { the
'< o 21 j.
observ~a ticcN" of the situation during that conversation? '! a, ' 1 :) i \ L , / '/ I , ./ t g 22' t .lon't recal) anything specifically beyond that,
' ' i e A li n .
p' a r 33 , qilm sure t h A t. t h a t: e were, as I indicated before, I'm on the 24 admi ni s t ra t.ivu side of the house and there was a project team 25 in place. :( m oure Mr Gant ord was ge t ti ng i n f:orma t i o n I! r o m
'f ACE-FEDERAL REPORTERS, }NC.
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-Q 'l the project as well,-and there were many things that I simply I
1' l- 2 had not been privileged to or had not known about.~them that-l- l 3 I'm sure others must'have.
]
1 4 Q. Did he discuss with you any contacta he had with S Rahman and:Kanga? 6 A Not' to my . reco.13 ecti on, sir. 7 0 Do,you think it is-11-kely-that this conversation l 8 oc' curred after the 1Sth meet i ncj between : Mr. Sanford and 9 Mr. Pa-ks? , i
'10 A I thi nk that's Jike]y. .'
s
. l 1.1 Q Can you describe the circumstances of the meeting l
12 with Mr. Parks that Mr. Sanford attended on the 15th?. I -' 13 A Oh, it was a very open meeLing. I I 14 Q It took p] ace i n Gai thersburg, by the way? 15 A Yes, sir, il did. At the time, our office was 16 utructured a little different than i t in now because'of 17 construction in that area. At the Lime, there was a small 18 conf er ence room between Mr. Sanford and Mr. Komen' officen. 19 Mr. Komes was our division manager at the time. IL took 20 p] ace in that small conf er ence room between t. heir offices. 21 The meeting was very open. Chuck invited a dialogue for . 22 Mr. Parks t.o talk about what happenn' at the Inland. And 23 inquired about we want to get to the bottom of these safely 24 concerns and we want to assure you that that's first and 25 foremost in our mind, l. hat we went those thinga addreised. ACE FEDERAL REPORTERS, INC.
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.. 1 We encourage it. IL is a ma Lter of company policy to-2 ' encourage it. It,was that kind of. dialogue that took ' pl ace, 3 Q Did.the subject of the previous day's interview 4 and-Qui 3tec and Parke invo]vement.'with Qui 3tec come up?
5 A .Mr. Pa rks , a l' one. point,. :s ta ted tha t he though t. he 6 used poor judgment in.hin involvement'there. JHut the focus 7 of the meeting as'I recall it was on who.made threa ts on your 8 person, .and what.are your naiety concerns. 9 Q Did you Lake: notes oft the meeting on March 1S? 10 A No, sir.
'11 Q. Could you ident.if y whose handwrit.'ing' tha t i s? In 12 thal Mr. Sa n f o rd '.s ha ndwri t ing?
o! 13 A Yes, sir, I believe so. I' believe i t in. 14 Q Mr. Hofman was 'also a t this meeting? , 15 A Yes, sir, he was. 16 Q. .And does this appear to be the writing of 17 Mr. Hof man- concern.i ng that same interview? 18 MR. R TCil AR DSON : Well, don't guess or speculate, 19 Mr. Whee)er. If you know. 20 TIIR WITNESS : I don't know. It is on 1.ee's memo 21 pad, so I arstune it'in his.
~
22 MR. R TCEI AR DSON : 1,e t us take our time to study 23 it. 24 THE WITNESS: My reco))ection in that those l 25 statements were made, and I presume that t. hey are I,ee's. l 1 1 l l ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
29934.0'
.KSW S4 1 BY MR. JOHNSON:
2 Q Do you reca)) at t.he meeting on the 15th, 3 Mr. Sanford slating thal he believed tha L Mr. Parks' d involvement in the resume typing incident was a fair]y S serious breach of Bechtel policy and that it was possible I 6 t.haL Mr. Parks might be' terminated f or his i nvolvement? 7 MR. RICHARDSON: Would you read that back, 8 please? 9 (The reporter read the record as requested.) 10 MR. RICHARDSON: Tha t 's a technically compound 11 ques ti on . Are you asking whether that complete statement and 32 the words you used was made by Mr. Sanford? 13 MR. JOHNSON: That's exact.ly what. J acked. Ov MR. RICHARDSON: That's a long statement. You can 14 15 have it read back again if you wish, Mr. Whee]er, j 16 MR. JOHNSON: I w'mld be glad t.o repeat iL. Go 17 ahead. 18 '] HE WITNESS : My recollection of that meeti ng is l 19 that Parks asked Mr. Kanga specifically whether he would be l 20 terminated Ior ih5c Quiliec involvement. ] 21 MR. HICHARDSON: You said "Kanga." Did you ! 22 mea n - - 23 THE WITNESS: I'm sorry, Mr . Canford. That. ] l 24 Mr. Parks auked Mr. Sanford specifically it he was going to 25 be termina1ed, and ('h u c k told him t.ha t hechte) was very, very i l f ACE FEDERAL REPORTERS, INC. J 202-347-3700 Nationwide Coverage 800-336-6646
29934'.0- >
. KSW' 55 4 .
I serious about breaches of ethica, and the way we conduct our 2 business, and that the possib33ity of beiog terminated ior 3 breach of ethics existed, but the inves tiga tion was n ' t over 4 ..y et , and a decision had not been made at that' point. There-5 was.never any aLaLement by Mr. Hanford thal'Mr. Parks would. 6 be terminated at al]. The focus of that _ meeti ng was to f ocus 7 on his concerns, a lack of noletaking,and'that kind of thing, 8 everything. war, done i n an a ttempt to have that einployee come -
'9 Corth and be comfortable and tell him what hin. specific 10 concerns were so we could take care of these a))egations.
11 MR. RICHARDSON: You just mentioned lack of note-12 taking. 13 THE WTTNESS: I didn't take any notes. I don't' 14 remember -- that pad that I just looked at looks like Chuck 15 did some ddodling, but there wa sn ' t any, Mr. Parks, tell me 16 ' exactly what you said kind of thing where it would'have been-17 i nti mi da t i ng . It wan anything but. Mr. Sanf ord indeed 10 opened the door for that employee to tell us wha t he had to. 19 say and have us-go solve a problem that. he would-have come up 20 with. He jus t never got specific where we could do 21 a ny t h.i ng . 22 RY MR. JOHNSON: 23 g Are you aware of any employee who was subjected to 24 disciplinary action for doing work on his -- after hours work 25 on t.he job using typewriters, el. cetera, f or doi ng resume ACE F'EDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-3364646
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'1 writing or anything like that?'
2 MR. RICil AR DSON : Excuse me. Are you referring..to 3 any kind of after hours work? An employee.using a typewriter ') o after' work 3ng hours to type a letter to a friend? There
'S would be en infinite variety of use of a company typewriter i 6 af ter hours.
7 BY MR. JOllNSON: 8 Q Are you aware of an emp.loyee being subject to ;
.9 disciplinary action Co" using company typewriters.or having a 10 secret ary type somethi ng on her own t.ime after hours'on 11 company equipment for an employee?
12 A No, sir. ; 13 0 Did Mr. Sanf ord duri ng that Mar ch 15 i nt ervi ew 14 indicate what it was tha t wan- concidered the serious breach 15 of Becht e:1 policy? 16 A Would you repeat that, please? 17 O To your recollection, did Mr. Sanford d e n c r.i be
- f. 18 what it was that he conuidered to be a fairly serious breach
'19 of Hec h t e:I policy that Mr. Parks wac i nvol ved in?
20 MR. RIClf ARDSON : You are asking whether 21 Mr. Saniord said somet hi ng in that regard during t.h e meet 3ng 22 with Mr. Park:4 on t.he morning of the 15th? 23 MR. J ollNSON : Yes. fL 24 THE WITNRSS: T don'L reca]1 Mr. Sanford having 25 made any reaI iusue of the OuiJtec buni nen s The focus was a ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6646
~29934.O KSW S7.
1 at that point-on safety, and the threatening' behavior that 2 Parku had spoken about the previous day. I th. ink at that' 3 point i t was a foregone conclusion that Parks had told un-4 what his involvement wi th Quiltec had been. 5 RY MR. JOHNSON: 6 0 Did you attend any other meetings.after:the. March 7 15 interview with.Mr. Parks, Mr. Sanford apart from the.ono' 8 you indicated y'ou re' m ember having n conversation with-9 Mr. Fanford about the fence, do you recall any other: meetings 10 in which the subject of di sposi tion of Mr. Parku' i nv o.1 v e men t
%11 with Quiltec and policy direcLive 2-t was. discussed?,
12 MR. RICHARDSON: Are you asking whet her, after the 13 March 15 mee ti ng' a bou t which he han just testified,-he 34 participated in any other discussions with anybody or wi th 15 Parka or - 36 BY MR. JOHNSON: 17 Q Did you have -- 18 MR. R]CHARDSON: Are you having discussions with 19 Parks w.ithin the ambit of your question? 20 fiV MR. JOHNSON: 21 Q 1 believe you did have some subsequent discussions 22 with Mr Parks. .I'm not trying to ask you about those. What 23 , I mean in here in Gaithersburg, did you have any other 24 discunnions concerning what to do with Mr. Parks other than 25 the one you d e s c r.i b ed talking to Mr. Sa nf ord? O ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 4 646
( 29934.'0'
'KSW 50 1 A Not that'I specifically recall.,
2 Q How about that you generally reca))? 3 A It is.very possible there was some-dialogue.on the-4 te.lephone or whatever. I just simply don't remember. 5 ,
-Q .Who made the decision, as.far as you know, what to 6 -do with Mr. Parks?
7 A Ultimately, Chuc'k Sanford'did. 8 Q Do you know the circumstances -~when did.you 9 Cirst Icarn'of his decision? 10 A On or about the time that I went to'tho' Island to 11 tell Mr. Parks of the decision. 12 Q That was about Mcych 22? 13 A Yes, sir. I would guess tha t tha t's pretty close. 14 Q So'between March 15 and March 22, Mr. Sanford l l 15 i ni:ormed you that he made the determination to retain, 16 Mr. Parks? 17 A I suspect that's'a pretty f a.i r s tat.ement . I 10 simply don't recall the details of how it came to pass. 19 Q Did Mr. Sanford have any ol.her conversations wi th 20 .you other than the one you described concerning your input 21 into that decision? 22 A On t he -- I will put .i t this way. Prior to my 23 actually getting in the ca r and going to the Island to tell-24 Mr. Parks, Chuck had requested ihat I be sure to cover the 25 appropriate Rechtet d i re-c i.i ves , con ti nue to invite a dialogue ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Covertge 800-336 #,46 l'
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-1 and safely issues, keep tha t door open. Just I think-the 2 general guidance on carry.ing out the policien that we.a))
3 pretty much knew verbatim'anyway. 4 O That's a discuccion of how to present the decision 5 to - or company policy to Mr. Parks. . I.was asking did you 6 have any.other discussions prior to or concerning-the 7 determina Lion of; retaining .Mr - whether to ret'a in him with-t i 8 Mr. Sanford? No, sir, j 9 A 10 O' Are you-aware of. any other persons that 11 Mr. Sanfiord consulted in reaching his decision? 3 12 A Not specifically, si r, n o .. 13 Q Mr. Parks reters in a statement tha t he gave to
- l. 14 your trip back to the Island. I believe it was. hack.1.0 the 15 Island. On the 22nd of March to Lalk to Mr. Parks. Do you 1 16 recal) such a meet i ng?
- l. 17 A Yes, sir.
L la Q It did take place at Three Mile Island? 1 19 A Yes, sir. l 20 0 1 believe you wrote out some notes of that l l
- 21 meeting, and those have been provided to me in discovery. It i
I 22 seems as though several versions of it actual:ty were l 23 provided. (J ud er the heading of "Postmeeting Notes, 1 ! l 24 3-22-83." Does that indicaie ihat ihese were notes thal you 25 made atter that meetinq? l r ACE FEDERAL REPORTERS, INC. I l l 202-347-3700 Nationwide Coverage 800-336-6M6 _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ . . J
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'ggy 60 h- 1 A Y e s , ..s i r .
.2 Q And Mr. Vern 1,eopard who worked for you was at j 3 Lhis. meeting too?.
L4 A ? shat's correcL. S 'Q Was there anyone else there? 6 A No,.uir. Jus t t he three of us. 7 Q Did Mr. Parks ask tha t you have' anybody else in-8 the roon? 9 A No, ci r, he didn.'t. 10 Q- Where did this take place? 13 A Jt was in a. conference room on the accond ' f 3 oor 'in 12 the building,. administration building. Conference room or 13 Kanga's office. I don't remember. We had an empty off. ice
.@ and'it was in tha t vicinity of the building.
14 15 Q Did you have any conversations with Mr. Kanga 16 concerning_Mr. Parks between March 15 and March 22? 17 A Not that I specifica))y reca)). 18 Q Did you have - 19 A Kanga was Jocated at the Island, of courne, so - 20 Q You wouldn't have bumped into him? 21 A No. 22 O Did you perhaps have a te]cphone conversation in 23 which you discussed the substance of Mr. Parks' meeting with :- 24 Mr. Saniord and yource]f on t.he 151h? 25 MR. RICHARDGON: Could you read that question O I1 ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336R46
I 29934.0 .q KSW- ;61 1 back, please?
.2 (The reporter read the record au requested.)
3 THE WITNE3S: I don't recall that specifically, i 4 but agiiin, Mr. Sanford had a project organization that was ) 5 reporting to him, so -- 6 BY MR. JOHNSON: 7 'Q Go it somebody was going'to contact Mr. Kanga to 6 i nf orm hi m of - the' saf ety. concerns , it would be more likely to 9 'have been Mr. Sanford than you? 10 A. Yes, sir. j 11 Q In these notes that you made, you say in the first 12 page he mentioned Jim Thiesing as a person causing'him g.
%7 13 distress. That's kind of an opaque ref.erence. Do you reca))-
14 any more specifics-about that statement? Lj 15 A At some point i n the dialogue wi th Parks, he 16 indicated L' hat Thie:s ing chall enged the statements that he had - 17 made in - I believe there there were four pages o l' notes on 18 thi polar vJane. I think most of those notes were procedural 19 in nature, and some of ihem were questionc'rather than 20 statements where Pa rks just .: imply did not or had not done l. 1 ! 21 any invesisgation himself, just. brought these things to i l 22 light, and what I viewed and everybody else involved that I 1 23 know of seemed t.o view as a typica) management process of L 24 dialogue to resolve the problem, Parks took offense at. 25 O So this is a reference to some conf 3iet. that ACE FEDERAL REvonTeas, INC. 202-347-3700 Nationwide Coverage 800-3364M6
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-( Mr. Parks had with Mr. Thiesing regarding those commenta?
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1 2 A Yes, sir. 3 O He di dn ' t mention ariy threat.u or-derogatory ! 4 statements tha t' Mr. Thiesing made to him? 5 A No, sir. 6 O Here i t. says on.t.he second page Parks said he-7 resented being investigated and expressed-this was.an attempt' 8 to cover up his comments on safety. -Do you recalf that 9 s ta temen t? 10 A Yes, sir. 11 _Q Do you recall what you responded to Mr-. Parks? 12 A I asked him to be specific. Give me an example. 13 In'_the meetings with Parks when he.ta.lked about this-broad 14 brush riatety issue, when you asked him tor a s p e c i lii c , he 15 complete]y got. away f rom i t. There was n ' t. anythi ng 1.here. 16 The man just absolutely refused to speak to an issue. He 17 would give you this overa.11 ba))oon statement and when you 10 tried to invite the additional dialogue, he just simply - 19 there wasn't anything there. 20 Q But specifically, with respect to the sta tement 21 here that you indicated he resented being investigated, do 22 you recai1 your response to him? 23 A Wel3 -- 24 MR. RICHARDSON: Are you asking - 1 think yo'i are 25 presupposing the question was asked. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 3364M6
29934.0' lKSW 63 1 MR. J OlINLiON : No, I'm not prestipposing a 2 ' question. 3 BY MR. J O H N !i O N : 4 Q The notes indicate Parks stated'that'he. resented' S being investigated. Did you respond lo that? 6 A -On that particular day that we asked, first'.T 7 think up on.the front part ot the : mee ting .we told him .tha t he 8 was going t o be retained, that while we were very serious 9 about' the . Bech tel ethics and so ' f orth, . tha t il was not of a 10 magnitude that warranted dismissal, but there were a few 11 things we want;ed to talk abou t, make sure he understood and 32 'get baclk.on track. 13 I endeavored very much so that afternoon.to. win O.- 14 this. employee, to get him ott this merry-go-round he.got'on.
'35 Let's talk about these 1.h i ng s , let's get them washed out, 16 let's:get back to productive work, and I was very,.very 17 di sappoi nt ed that I didn't succeed in that effort. I' pride I 10 myself on communication with my peop.le and I thought I had.
19 him won to say, come on ano participate, but I think at that 20 point in Lime, he had so much water over the dam that he 21 couldo't t ur n back, but. there just. wasn't any forthrightness 22 with us at al.l. 23 0 So at this meeting there was a marked difference, 24 as far as you could see, between your meetings on the loth 25 and 15th and t hin one? lt seems to me that you were O ace. FEDERAL REPORTERS, INC, ; 202-347-3700 Nationwide Coserage 800-336 6646
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.( 1 impressedcat leas t on the lo th witti his' fot thrightness.
i Now 2 you are saying by the-22nd you thought he was not'being 3 forth-right. 4 MR. RICHARDSON: Excu p e - :n e . He~ previous)y
-5 Les tified that Mr. Parks was not_ forthcoming in the sense.of 6 not being speci fi e abouL sa f ety 3 usues on the 15th, March 7 15th, 8 MR.' JOHNSON: l' would 3 3 ke to-hear this from the 9 witneau.
10 THE WITNESS: When we asked on.the 15th, when l-11 Chuck Sanford asked for specific things-that we'could' 12 approach to go to work.on on the 15th, there wasn't anything L m .l3 there. P*1rks couldn't give him any specifics. Again, i t was- -j i' .
.I 1 14 very, very consistent when you asked Mr. l'a rk s pl ea s e te] .1 me 1
15 something we can work on, there jus t -- he avoided tha t' very 16 much so, and -- 1
.I 7 HY M R ., JOHNSON:
la g Do-you recalJ this part, the page before this l 19 diagram, the siLe organization diagram, it says he went back 20 l.o lhe threat busi ness ci ting Kanga 's reli evi ng him of. 21 responsibilities. Do you recall him making that statement? 22 A Yes, sir. l 23 0 Do.you recal] whether you responded to it? 24 MR. RICHARDSON: Take your time, Mr. Wheeler, to 25 review the entire context of your notes. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 33fr(M6
'29934;0 KSW 65 1 THE WITNESS: In the sense that up fronL we had 2 told Rick t.ha t he waun't go.ing to be terminated, and 3 Mr. Sanford certai nly never threa tened to cease his 4 em p.l oy m e n t. . He gave him a forthright answer that yes, the 5 i te c h t.e.t c a rec tiven , we're setious about them and we have not
'6 conc.luded our investigation, but certainly a vio}ation of 7 thcae directives could on cause for Lermina tion, but there 8 was no direct threat made to Parhu about his employment at 9 any point in l-ime.
10 BY MR. JOHNSON: 11 Q You were specifically referring to the meeting on 12 the 15th? 13 A Yes, sir. 14 0 .llid you, at. any time, :investigat.e 1he charge tha L 15 Mr. Parks makes on this page, and I don't know, it is the-16 next to 1 a s t. page, wi th respect 1o Mr. Kanga, in wh3ch 17 Mr. Parks you indicate t.h a t - i l s a y s I asked him if 18 Mr Kanga had exp.lained t he si tua tion and if he agreed that i 19 he wouLd be besL suiLed in another role unLi1 his presenL 20 situation set.tled down. He said he was told, not asked, and 21 Lhat it. was an act of in timida tion agai ns t him f or speaking I: 22 out about safety. W.i t.h speci f.i c ref erence to the facts that 23 Mr. Parks is a .l l ud i ng Lo, 1. hat is that Mr, Parks would be ! 24 be l. t.er suited in another role, I -t h i nk this is a ref erence to ; 25 his removal trom review re sponsibi l 1 Li es wit.h respect to the l l l L ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800-336-(M6
t 1 29934.0-f XSWl 66 ! I Lp
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1 po l a r c ra ne . o 2 Firut. of al], in that a reasonable assumption of I l'. 3 what's being referred to there? ] i 1 . l 4 MR. HIC 11 ARDSON : Take your time, Mr. Wheel er, Lo. ! l i. L S study the paragraph. , It does refer to a letter which you may l l 6 also wish to refer to. , 7 .MR. JOHNSON: Is the 3-21' letter available? l 8 MR. RICHARDSON: Sure. Sure. It is a letter from 9 Parks to Kanga. i 1 l' 10 HY MR. JOHNSON: 11 0 Do you remember my quest. ion? I 12 MR. RICHARDSON: I think the witness is still , t l 13 reading the notes,
'MH , JOHNSON: Take your time.
14 Sure. l- 15 THE WITNESS: My recollect. ion of the paragraph and l 16 so forth is that. Parks and Kanga had had a meeting where 17 Parks agreed thet he was best suited in another role at the 18 ti me . Then he d.id a compl ete flip on the thing with this 19 correspondence. My intent that afLernoon was to bring thiu 20 emp]oyee into an active dialogue to fl ush out any saf ety - 2i ques Lions thal could have been and let.'u gel back to the 22 pr ac ti c e of doing businens and conducting business. So if I 23 ended up in a line of ques tioning wi th Rick as to try to win 24 a confidence and i nvi t e an honent dialogue wit.h the man that 25 seemed to be leading to an adve rca ria l type or raising his ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-3364M6 i
4 , 299'34;O
- KSW. 67-1 ire, I would pursue.another approach. My' intent was to get 2- Lhia employee t.o . i e] ] us'what was botherina him upeci f 3ca]ly 3 so we. had something to work on a nd I think the following 4 paragraph i n pretty much .i ndi cating that. I asked himLto 5 provide: me with 'speci fic i tems on sa fety, let's get back to 6 that issue, and there'was just nothing'there. . ..
't 7 HY MR.' JOHNSON:
8 Q' My original-question had to .do wi th whether you 9 had any conversations wi th Mr. Kanga about the subjec t of 10 that. March meeting whi ch - - , 11 A T don't recall any such conversation with Kanga. 12 O I take it, then, even t. hough you didn't speak.to 't 13 Mr. Kanga between the 15th and the 22nd according to your 14 re c ol ] ec t .i on , tha t somehow you. go t --- 15 MR. RICHARDSON: Excuse me. I think he testified 16 that he doesn't remember. .! 17 HY MR. JOHNSON: la Q Iu it possible that you did speak to him? 1 19 A IL is quite possible. l i 20 Q llow would you have formed an impressi on about what ; i 21 Mr. Parks had agreed to al t.he meeting on March 17 if you had j 1 j 22 not spoken to Mr. Kanga? 23 MR. R I C il A R D S O N : Excuse me. He hasn't -- your 1 24 question presupposes a premise which he has not a'f f i rmed . He 25 test.ified he has no present recollection of a conve rs a ti on ACE FEDERAL REPORTERS, }NC. I 202-347-3700 Nationwide Coverage 800-336-6646 __ - -- 3
[ 29934.0 KGW 60-
-. .. i V 1 with Mr. Kanga. 'lle has not denied that there could have'been-
/
2 a conversation. q 13 HY MR. J O flN S O N : 4 0 I was auking you borore about-whatLfactua.1
]
5 underpinning you had to discuss,this whole issue about the(21
~
6 of. March .1etter about Mr. Parka supposedly agrecing't. hat'he . ; 7 would be becL suiLed in another. role. I*m jusL trying Lo; i
.8 find out., you know, where were you coming.firom?-- What-did you 9 know abou t. tha t? j
.i '
10 A- :It is quite possible that Parku raised the issue 11 in.the' meeting. I'aimply am too fuzzy. Four years-is-ia long: ; 12 time l.o try to' remember the course of details.
,e 13 Q Whether he-voluntarily wanted to be. removed or' T I 14 whether he was removed is very .important in thia case and if -!
15 you can remember anything speciCic about i t, it is important 16 that you'te)) me. 17 MH. RICHARDSON: Well, he indicated that he told-18 Mr. Parks as stated in these notes, he asked him whether 19 Parks had, in fact, agreed to 1. hat change. Parkn being.taken_ 20 -oft as the primary site representative concerning the polar 21 -crane, so he has al ready testi f i ed about -- 22 MR. JOHNSON: He didn't t.esti0y -- Mr. Richardson, 23 please, I want Mr. W h e e .l e r ' s testimony, not youro. 24 MR. RICll AR DSON : I'm trying to gel a clear 25 question Irom you. F ace-FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 800-336-6646
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29934.0: KSW 69 D d 1 MR. JOHNSON: You are supplying the witness with 2 information which he did not refer to. l. 3 MR. HICHARDSON: He already has. You have already 4 covered that. I'm trying to make cicar, are you now asking-l S him what source or sourcen did he have' tior wha tever knowledge l-l 6 .Mr. . Wheeler had concerning the March 17 mee Ling? In that 7 what you are pursuing? 8 MR. JOHNSON: Yes. 9 BY MR. JOHNSON: 10 0 I assume when you met with Mr. Parks you had this L 11 letter; is that correc t? 12 A If I had that letter, it probably would have been 13 included in my noLes. I probably did not have that letter. 14 If i t was a sore point with Mr. Parku , thi s parti cul ar area, 15 I was simply pursuing a dialogue which would get him to tell ; 16 me what was bothering him so we could get it out on the table 17 and go about a management process of resolving 1.he issue. 10 Q J understand you have explained to me several j 19 . times what your purpose was. My put pose is here to try to 20 fiod out wha l, 3n fact, you knew about the dio.logue or i 1 21 whatever, the meeting, conversa tion, between Mr. Parks and i 22 Mr. Ranga t h a t ' t, referred to in this l e t ter dat ed March 17, 23 They have had a meeting and Mr. Kanga apparently believes 24 that Mr. Parks agreed that what was best s ui ted for him was 25 another role, and Mr. Parks in you r conversa t ion wi t.h him did
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-KSW 70 f; \ 1 not. What I'm trying to find out from you is what the source.
ll 2 of your informittion was about Mr. Parkn' agreement =that il f 3 was best.that he get another role. l 4 A I apoJogize, but I just.l-nimply don't recall the 5 upacifies of that arena. The specifics a's I read this-letter 6 and see these not.en were handled-as a matter of a project t-L i 7 concern on the project. Reing brought in, as I was,.in an. l l
- l. 8 admini strative capacity, my task was to try to curface 9 concerns and' learn about 'them at Lhat point in time, and so I 'l
[ l 10 may have had a reco))ection that, hey, this Jetter existed. l '1 I obviously did, and'that,.okay,.tell me about i.L. If this I 12 is s td ] ] bothering you or if you are ut.33] writing-13 correspondence ' that conflic ts wi th something you previously 14 stated, let me know so I can help you. 15 g You were not looking backwa rd, you were l ooki ng 16 forward. Is tha+ the impreccion you are giving me? 17 A Absolutely. I want.ed this guy Lo come forward and 10 get back to work and be a product.ive member. 19 Q It wasn't of much concern-Lo you the exact details 20 of the past. You want.ed to move forward into come kind of' 21 productive relationship? 22 A What was of concern with me won if there was an 23 outsta nding sa fety issue there I wanted to know about it and 2d I was never abJe to elicit that candid dialogue from Parks. 25 he just simply wouldn't give us anything we cculd go to work 1 O ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80(k33MM6 i 1
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'29934.0 KGW 71 r
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2 O flut what was bother.ing him f. hat. he wanted to 3 discuss with you i t sounds like to me was this pressure he 4 was getting or he says. nets of intimidation. .'Did you 5 perceive'that thal was.something worth dincussing? 6 A' Yes, I wanted him to.te)) meexact3ywhat[wason 7 his mind so that, in ffact, at a point in the meeting Ifasked-l I. 8 if he wanted me to br.ing internal audit to take a Jook at l l 9 specifics and'we'll get all ot the parties together and take 1' 10 a 3cok at the whole process, and he backed of'f-of .that'as 11 well. I.just couldn't get the man to participate. 12 O D3d you ever fo))ow that mdtter up after the talk, l 13 that is with Kacga, about whether,.in' fact., he had pressured j 14 Parks? 1 15 'A No, sir. At t.h e conclusion of the meeting, then-l
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16 the rapid chain of events occurred where the next day be 1 17 ended up i n. a pub]ie forum and so the who]e thing took a 18 different twist the following. day. 19 Q Maybe it would be good if you would describe as 20 you recall the sequence 00 events from the conclusion of that 21 interview un ti l the time that you handed Mr. l' arks thi s letter of March 24, 1983, informing him that he was 22 23 suspended, a 24 A You mean af ter the meet.ing on the 22nd? 25 0 Yes. What was the sequence af events tha t you ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 4 646
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1 . remember? 2 .A There was a meeting at'.the end of the day that GPU 3 had a.rranged concerning'a Congressional-scheduling or.' . i 4 Congressional hearing so that when'we concluded with i 5 Mr. Parks at 3:00 or 3:30 in~the. afternoon, we.went~from that 6 meeting-into this ather. meet.ing where 1'beiieve it was
.- 7 Mr.' Arnold. addressed Lhe group.and that was all quite 8 esoteric :to me. I really didn't.know what was going on there
(. 9 in terms of Congressional hearings, but Parks was one of the l 1 10 people that was invited'to attend that. t.hing and I happened-11 .Lo ait in on it,. and so Mr. Arnold gave those people some ; l 12 .i nf orma ti on , and then beyond that meeting, a public relationn 'f 13 man, I believe from general public', made it knpwn that this l 14 was goi ng to be a wha t do you ca3 3 i t, a news conference in i
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15 Washington, D.C. the Collowing day that Parks was going.to' ~ 16 pa r t.i c i pa te in. 1 17 Q When was this? 10 A The same afternoon. Mr. Parks was ca] led by . 19 Mr. Kanga-to come lo his office and I don't remember who I 20 asked him the question, .is a news conference going to take
]
21 place tomorrow and he said yea, it was and he was dismissed 1 I 22 at that poi nt . 23 0 You were there at t.h a t poiot?
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24 A Yes, sir. 25 0 1,e l me stop you f or a second. In Mr. Parks' l l 1 , O i ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 4 46
29934.0
'KSW . .73 1 s ta teme n t., I think'this-goes back to your meeting on_the 2 22nd, if you wi13 bear with me we']1 just back up. He.
3 a ttributes to you a s ta tement as follows: Mr. Wheeler said-4 my concerna had Mr. Steven Hechtel, Jr.'s personal 5 ' a ttent ion. And Lhen it says they anked it I wanted internal 6 affairs investigation of management, wh.ich I said would-be 7 appropriate. Do you recall tha t pa rt oE Lhe interview?- 8 MR. RICHARDSON: There are neveral elementu 9 there. The ques tion is compound. I think iL would be 10 helpfu] to break iL down.
'11 RY MR. JOHNSON:
~
12 Q Do you remember bringing up t.he name of Mr. Steven 13 Recht.el, Jr.? ; 14 A No, sir. The only area that, Mr. Bechtel's name 15 would have been said a t all is Mr. Hechtel's signature in on 16 the bottom of the direct.ive 2-1. 17 Q Do you know. .do you have some idea how 18 Mr. - wn)), strike that. 19 You showed him a directive with Mr. Rechtel's i i 20 signat.ure on i t.? 21 A Yes, sir I covered Hechtel direct.ive 2-1 as part 4 22 of tha t meeting with him. 23 Q Did you say this was comething that Mr. Hechtel 24 was very concerned with, that policy? L-25 A That's quite po:i s i b l e !
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I 29934.0 KSW 74 m i 1 l .Q To the best of your knowledge, did Mr.- Hechtel, l 2 Steven Hechte), Jr., know anything about ' Mr. Park s, . oi ther. 3 Mr. Parks' safety concerns or Mr. Parks' conflict of interest 4 situation at the time? 5 A~ I'm not aware _of his knowl edge of: any of that, nor ) 6 do I know his communication chain. I simply don't know that.
- ]
1
'7 Q Now you said that just. before 3 asked you about ]
I 8 the sequence of events tha t ycu asked him if as indica ted in -{
)
9 your notes that Mr. Parks wanted an internal audit to be 10 performed, and I Lhought you said that Parks said no. 1 11 A That's. exactly right. Any time you were going to. ] i 12 bring the parties together where he had to get specific he i 13 woul d not parti c.i pate. Tha t. sta tement i n here i s false. 14 MR. RICHARDSON: Your prior question, I'believe, 15 had reference to his notes, and I want to clarify one thing. 16 When you say Parks said no in response to 'your question -l 17 concerning pursuing an internal audit i nves ti ga ti on , do you 18 recall whether he expressly said no, or he gave any other I 19 response? 20 THP. WTTNESS: W e .i 1 , I t.h3nk it is very, very ; 21 apparent thal Mr. Parks had already decided a course of 22 action irrespective of that mee ti ng, and so he was on this 23 merry-go-- r ou nd that he couldn't get o f f; a t that point in 24 1ime. My noten iodicate, and :1 have signed those notes, I 25 believe those notes he says he wilL decide what to do on his s ACE FEDERAL REPORTERS, INC. i 202-347-3700 Naticawide Cmerage 800-336-6646
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-29934 '0L KSW 75 1 own and take his own action. But he re f:u s ed to participate.
2 That's the bottom.]ine of the whole issue. When we offered 3 to resolve his issues, t.o s u r f a ce those issues, get them-in. 4 an open forum, so they could be-approached in a logical 5 ~ management fia s hi o n , he just ref'uned to participate. 6 RY MR, JOllNSON:
. l 7 Q The-very last line above your signature says:
1 i
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1 0 " Parks told me he was i nt erested . i n an assignment a't Wo] f l l 9 . Creek." What was your reaction to that? 10 A Wolf Creek in a nuclear sit e in Kansas, and the 11 a tartup program was ' i n i ta infancy there, was jusL really 12 beginning. .I was very, very disappo.inted leaving the Island 13 and finding ~out that this whole process that he had gone- .; i l 14 through duping us a)) the way because there were flashes.in 1 15 the interview where I Lhought I finally have this guy -l 16 listening to me and he's very unsure o f- himself, very unsure 17 whether he wants to go through with.this course he is taking 18 and I thought I had won him over .into the process and he said i 19 I would be interested in a Wolf Creek assignment. So there 20 were periods of time during the course of the interview where 21 I thought this guy is going to come over the fence and be 1 22 responsive and that was one of the jobs he was aware of 23 coming up in our organization, and unfortunately, he didn't 1 24 choose to Lake that course. l 25 C! Wha L do you mean by thal, hin going public I ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 6646
29934'.0-JKSW- 76 1 precluded t! hat courue? 2 MR. RICHARDSON': I'm not. clear, cou3d you read 3 that last' answer back, please? 4 (The reporter read th'e. record-as requested.) S THM WITNESS: By " going that. course," whaL I 6 really mean is t hat J e t. 's par't.ici pate :i n a dinlogue 1. hat I 7 .can get on with my career and tell you what.these concerns 8 are so you can go to work cm them and he just didn't 9 participate in it. 10 HY MH. . JOHNSON: 11 Q Once you learned t@at he was goi.ng public,.did you 12 conuider t. hat to preclude his reassignment to Wolf Creek? 13 A No, sir. O. 14 0 Did you consider that. his reassignment. m.ight be a 15 way out of the si tua tion? 16 MR. R.ICHARDSON: Wait. Okay, the ques t.i on i s -
.I i
17 MR. .TOHNSON: I would appreciate i L. ifl you didn't' 18 repeat the question. Do you understand the question? 19 THE WlTNESS: I think 30. t . 20 MR. JOHNSON: I'm asking the questions, not your 21 allorney. I f: you a tl.o rney wan ta Lo ask you questions he han 22 a perfect right. 1.0, but not. while l's asking the questions. 23 MR. RICHARDSON: I resent what, you are saying 24 about what I'm trying to do. My job is io make sure that I ! 25 clear questionn are asked, and i paused because momentarily 1 l LO L l ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 336-6646
29(334.01 - \ ' KSW i 1 .wann'L sure'whaL the quostion was as to whether you were 2 aski ng '.hi m whether . Park s wa s going public prec.1'uded,that t < 3 assignment or'whether lye considered thal $p, ting public-4 Lprecluded t hat assigrunent. Those are t po dif f erent poi nts
-5 and 1 rea.lize you did have the worduNonsidered" in there.
t
'6 MH. JOHNSON: Could.you.reaQ back my question, 5
9 3 please? - *, i p (! l 8 (The reporter read the: record as requestedi) 9 THE WITNESS: The answer,to that is no. . Ti /i t 10 wasn't an appropr.iate consideration at that point in tirac. 11 For one thing, the Wolf Creek assignment was simply a l N,
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12 question that I wouJd get from.any eng,ineer. Hey, I
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13 unders tand this one is coming up, coubt t be considered-for s ',
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It. was in that. context t. hat I.took the question. In 14 it. , 15 fact the Wolf Creek startup program was managed by the 16 c:1 i ent , no anybody considered for that. assignment wou]d have . i U <. { % s 17 had to go through the very formal process of submitting a la resume, and 23 companies parti ci pa ted N n the ut artup
.19 ul ti ma tely a t Wo t t Creek and the clit.nt made all decisions on
(, 20 who pa rti ci pa t ed or who did not. i 21 HY MR. JOHNSON: S 22 0 1.et's return to the sequence as you were 23 ' recounting it to me. We had gone as far as I think late on' 24 the 22nd, and somewhere after the discussion about a 4 l 25 committee appearance or something of that sort. Could you y \ ACE-FEDERAL REPORTERS, INC. ' 202-347-3700 Naticawide Coverage g f 930: % 6646
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4.KSW 78 , j'* , a_yg , .k q f 1 ' continue Crom that point? What were the chain of events? t . g 2 A lleyond an i nf orma t ion meoling whi ch 1' indica t ed'
.. A ~
3 , was prelly esoparic to me becauseti didn't have'any i i 3
.s 4 background that Lhn peor;1e on the' project. did. 3 thinh.it. '\
'f;g t .6 w a.G in 'a conference rool.hadjacent to Mr. Kpnga's office, he ,
., 6 L/! I Lit ~ t ; (i ~came out of' C) Pere and wt [ .intd 'K6 nga 's of f 3 ce. And.a man l l,A
.X t s
7 came'lo 1
, o )- ,e 1 don't knowfthe gentleman's names.but a man came
'E )r c I 8 it Mr.~Kanga'r r,4J3ch that wa'c, 1~ au 1' understand it, was.a j
,w t ,. s .. .
-.4 9 tq % ic relations ' m,in Cop General Public Utilities and U i s '; f[ Ng 10 announced to Mr. Yang ,'t.hP.t.theTO WaU a news Conference
'J '
L 5 5 11 scheduled the following day in Washington, D.C. t o; >
'1.? !; g! Q :t a that Doug3as Hedo.1 I ? s 3' '
'}1f
,5' I didn't. know the gentl ema n ,
13 A I don't know, s i .r . i
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14 Parkbwas ca))ed to Mr. Kanga's ofTice and he conf ir.'ned tha t 4 i : I 15 ,
,t whi'ch> point he was dismissed, Q , i f 16 i 0 You mean he was dismissed from the o f f 5 c a '.'
Aq ,,.t
^
Pardon?
} p ,
,J7 A
e i-s s\ .,$ 1 - 18 .g yR. RICHARDSUN: What do you mean by li o m i s s ed ? s 19 THE NCNEGS: He was told thal he could go bm@ Lo 20 'Nin job. -i ^
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'\ \ 21 s4 M1/ . l JOHNSON: 's i,
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b !, 22 And he lefi Thmk Yba L ha ppened af( er that? r [i 1 3 . I 23 y A We came bach to Gaithernburg, Vern 1.copa rd and I
- i ' i iq- 24 came back 11 Gaitheruburqr '
4 g g 3 1 25 g What. was the nex t 't h i ng that happened? What wan y -s h ' 4 4
-y I
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79 y, - y.c f 7 sg~ - i, 4 3 ,; . .. j o. - 1 4, "j < - your.next involvemetW.with the . Parks matter?
-y' yt .
"q tev7
2 . b. I: had ,gone . 6adite the. job site to deliver a-l f .
. +
4 J-3 M.A d to Parke Uhich
, -4 s f i E s.
4 ,I E x c ui: e" 'w e . Would you atart that agai n?- 4 .' K w . .4. ,.<y u , y, ,
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i 'n54... 3F ( h'Y I e.sM,.back to --- I . carried a ~ le t ter which. I l l ,, r s- nn. , .+ e 16]=[sijned te?]3 ng him -tha t he .would be placed on pai'd leave 'of f , .
- absence ' o f f uthey .is i f,e whi a.e LSe public-allegations that he ls m. Qlf '
I / q, } 'i-is
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J@y.g ) 8 made werey he.inq .i nves ti jated . + i .M S >l , r /. 9x .e =
/ < 9 t ,.N6w did'you come _ to. write thal letter?
f I.: 1 f' 10 .The 3hlter ' Oaa, Dit that point in. Lime, prepared by g fn 1
'. s. . ,
othn"s. .T/ don *L:kno': thelpersortige. 11 Certainly : the . legal m,c L 12 a.ta f O war.'id cb ; ,<e. ' be' ia involved and,-of courne, witho l,- - 13 - Mr. [angahs conc urrench , I. .s.i gned the le L ter,' and I delive red ( i + I % ..E L
- 14 iL YU Mr. Jarha. i l i I 15 M '%kio gr v.h you the l ett er f or your signature?-
)
J y 1' .\ . , 16 ( MR, F ICH A R DW)N ! Who physically. handed him the. Y r N -(17 J e i!.ter? 31
/ s . . . .
18 'MN. JOOp$0M Yec.
, si s ,
19 , g ' T W: WJ rtiESS : I don"t remember precisely whether
- i. . /. 0 se 4
it -la s our divss$on coaquel or whether it was Mr. Sa n f o rd . 21 It was prob.tbly fojether, joi ntly when 1 actually signed the 22 3nt.ter and delivered i t to Mr. Pa rk s . 23 ! ', BY NLt . J OHN W)N : t i , !- q'- l 24 O Did Mr. mtpford - - did you have a discussion wiLh l l 25 Mr. Ua n' o rd concarni,w) 1.he n ig:> i ng a t thin letter?
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s, .. i29934.0-LKSW , 80 1 1 A' Yes'. 2 M R '. R1CHARDSONi M r '. Whee]er,-1'm going to
. .I 3 admonish and remind you that insof.'ar as you had.auch i 4 discussions i n the presence of Hechte] 's n'ttorneys those .I i
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5 -discussions'are privileged, but if-you'did have a discussion 6 outside the presence of the attorneys, then 'you nay describe 7 those discussions in response to Mr. Johnson's questions. .I H Perhaps wo ought to have lhe question ~rcad.back. ; 9 (The report.er read the record ar reques ted. ) . 10 HY MR. JOHNSON:
<l 11 'Q Was an. a ttorney present a t t.lial discussion?
12 A ,7 don't remember specifica.lly whether.there was or 13 was not. 14 O CouJd you describe ihat conversation to me? 15 A As I read the 1 citer i tse:1 f: , I understand and 16 agree wit.h the content. of the-Jetter. What actually took 17 place in a dialogue at that time I don'L recall. 18 0 1 must confess, I read the letter, and I found .i t 19 very uninformative about the circumstances that led up to 20 it. 21 MR. HICHARDSON: W e ] 'l , t.ha t is Mr. Johnson's 22 rhe tori ca l a roumont a t i ve p re f:a c e . That:'s not a ques tion. Do 23 you have a question about the letter? 24 BY MR. JOI(NSON: 25 0 .I ' m trying to .f i n d out, you say you didn't write j O ! ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 4 46
29934.0 KSW-. . . 81 , l ,l 1 it'.yourself; in.that correct? 2 h, Tha't 's correct. .i l 1 3 Q Do.you know who.draf?ted it? 'j i 4 MR. RTCllARDSON: He'has already answered that
..j 5 question. !
6 BY MR. JOHNSON: j i 1 To the bes t of? your recollec tion this was dra ff ted-7 O 8 by a lawyer? 9 A A lawyer-or group of ., l 10 MR,. RICHARDSON: Are you asking.Whether a, lawyer i l 11 completely ~ composed the en t.i re . letter with noninvolvement by. ! 12 people who are not lawyers? 13 .BY MR. JOHNSON: O 14 Q Your f!irst answer was "by others." That's not 15 very .i nf orma t.i ve . Can you try to improve on that a .l i tt.l e ? 16 A Un fio r tu na t el y , I can't -- 17 MR. .H1CHARDSON: I reuent the 5 mp.licai . ion tha L he 10 is not-intiorming you. He in tes ti f?y ing to his best 19 r ec ol l e c t.i o n .
- 20 MH. JOHNSON: I'm not impugning or anything. 1'm l
21 asking him to probe his recollection. 22 Tile W1TNESS: 1 don't hnow who would c.1 aim L. 1
- i. 23 authornhip on the letter.
1 24 HY MR. JOHNSON: l l 2S Q Did Mr. 3a n tio rd i ndi ca t.e lo you that the O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Cmerage k(4336-6646
29934;0 KSW 82 1 sentiments of Mr. Arnold were a factor in Lhe' determination
-2 to.take t.he decision represented by t.hi s J e tt eri 3 A No, sir,-he did.not. I have no recollection of 4 t.ha l .
$ Q Di d - he ment. ion that he had been inf!ormed by anyone 6 a t GPU Nucicar that they were aware that you were about to 7 iasue thia .1 e tt er?
I 8 MR. HICHARDSON: 'Aga5n, Mr. Wheeler, you are not - 9 at liberty ' to disclose any informa tion or atatenents which 10 -were made in -the presence of attorneys, but if such 11 slat.ements were made outside thal context you'.may respond,to 12 the questioni.
.13 THE WITNHSS: 1 3 i mp.1 y don ' t kTiow ,
O-- 14 RY MR. JOHNSON: 15 0 You don't know what.? 16 A T d'on't know if Mr. Sanford and Mr.' Arnold.had any 17 c onversa ti ons . I'm not aware of any of' those details. 18 Q Fair enough. Did Mr. Sanf~ord direct you to uign 19 ihat let.1er? 20 A T unders1 cod signino ihe .1 e t.ter wa:, a manacement 21 procesa. T'm part of Hectcel, Mr. Sa n t'o rd in an otficer in s 22 the company which 1 report to. ] happen to agree wi t h the 23 contents of the Jetter. As the f unc tional department manager 24 f or ihat particu.1ar individua1, 1 had no problems ai all 2S signi.ng that IcLter. O ACE FEDERAL REPORTERS, INC. l 202-347 3700 Nationwide Coverage MXb33MM6
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29934.0 KSW 03 l 1 Q You didn '.L a nswer the ques Lion.- direc Li y 7 though.
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j 2 ..Did Mr. Sanford direct you to sign the letter? t a
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l' - 3 MR. RICHARDSON: Well, are you asking whether he. ) 4 was ordered to sign t.he letter, whet.her he was asked to sign 1 5 the letter? There's a difCerence.
~6 MR. JOHNSON: 1'm just trying to get the facts.-
l-l 7 7 f you can. describe them i.n your own words better than ILcan,- 0 go ahead. .! 9 Tile WITNE!iS : T ~ signed the letter.as.part of a' I p 10 management. process. I was certainly not direct.ed to sign l- 11 anything. I. ' m part.of the management. team here. :It?was a l-J2 normal' management process. ] i 13 HY MR , '-J OHNSON : 1 Prior to signing it you did have a conversation i 14 Q i 15 with Mr. Sanford? 16 A Yes. I wouldn't have the authority to send a 17 letter l i l< e Lha t wil.hou t a ppropria le ma nagnmen t. .; 18 Q What war your - 19 MR. RICHARDSON: Did you complete your sentence? 20 11Y MR. J ollNSON : 2] Q Do you want to finish your answer? 22 MR. RICHARDSON: He said "I would not have had the 23 a u thori ty to send a letter l i k- thu; wi thou t" - 24 THE W:ITNESS: A pprop ri a t e ma na g t 'a nn t knowledge and 25 consent. 9 ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 8(n3364M6 2
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KSW Bd I liY MR. . JOHNSON: 2 O This action was not .i nit ia ted by ~ you 3 t ak'e = i t-l 3 'i: rom your previous answers?' 4 A No, sir, it was not. S Q In'other words, it is correct thati it was not
-6 . initiated by you. Did.Mr. Sanford tel.1 you.that the 7 suspension was on his-authority?
8 A -3 don't remember Mr. Sanford'saying anythingllike-9 that. I think tha t I can infer that. j 10 0 Do you have a copy 'of the letter? I 11 MR. RICil ARDSON : Yes,'righL'here. 1
~12 iiY MH. JOHNSON:
13 p I would like you to read it so I can ask you a g.- 14 question about 11. Have you read it to yourself a l rea dy.? 15 A Yes. 16 MR. HTCHAHDSON: I have 10 until 1:00. If'there's-17 much longer, I think we ought to have a lunch break and 10 resume, but if you are heading 1.oward the barn - 19 MR. JOHNSON: It is fine with me. 1,et 's go abou t 4 20 10 more minuten and see where we are. 21 HY MR. JOHNSON: t 22 O l'm looking al. the third sentence -- i 23 MR. RICHARDGON: Mr. Wheelor, have you finished ! 24 reading the l e t t.er? l l 25 THE WITNESS: Yes. l g Ace. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-3364M6
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' 29934.O.
KSW- 85. l' .HY'MR. JOHNSON: 2 0 -"In order to insulate you'from even the appearance-3 of.. auch conduc t a nd to assure 1the-continued eff~ectiveness of 'I 4 " a ] .I personnel at the sit e, we are p]ac.i ng you on an 5 indefinite leave of absence with pay,"' et cetera. 6 ilow do you urMerstand the f 3 rct ' part. of that 7 ' sentence which says "in order lo-insulate.you from even the 8 appearance of such conduct"? q 1 9 .A Well, Mr. Parks had made.a number of statements'in U 10 a pub 1ie forum ihat cha)3enged many of his coworkers,-their 1J integriLy, people thal were doing a very professional 1 job. 12 When that many people are involved at the Island with the 13 enormous scrutiny that everything had there, frustrations run O 14 a 1i tt le higher. A job 1 hat, in any ot.her.nuc) car.ni1;e in 15 the country, would have been done by an engineer and maybe 16 have one review, at lhe Island typical 3y had a dozen reviewn, 17 no it wasn.'t uncommon for personalities to surface-a little i 18 more in that. kind of an env.ironment, and with Mr. Parks 19 - impugning t he digni ty and the professionalism of hia )j 20 coworhers to prec.1ude any ponsib.i1.iiy ihat. disparaging 21 c o m m e n t.:, maybe would be made to him tha t he would construe as 22 more haransment, we thought; it best to pui him atri of- harm'u 23 way. That's the intent of that centence. I 2d Q Did you connu11 wiih anybody concerning Ihe 25 factual premise t.ha t. you just made? Did you consuIL wit.h , b l 1 i ACE-FEDERAL REPORTERS, }NC. 202-347 3700 Nationwide Coverage 800-33MM5
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.'29934.01
.KSW' ' 8 '6 -
1 'anybody concerning whether'whal.you justorelated to'me was, 2 in fact, t. rue? W 3 A I -- 4 MR-.'HICHARDSON: Again, Mr. Wheeler, I have-to-
-5 remi nd you of the a ttorney-client' privilege.
6 THF WITNESS: 'All ri g h t . I understand the content 7 . of. the le tter and I signed it. 8 HY MR. J Olf NSON : 9 -Q That's not'my.quesl' ion,'though. Did you consult 10 with'anybody about the factual accuracy of what you just 11 said, that i s, -tha t i f: ~ he retu rned to the :siLe he would be 12 subject to comments, et cetera.
'13 MR. HICHARDSON: Well, he hasn ' t cha rac terized O 14 that as a fact.. :l t in a concern about something which may 15 happen. It is a little unclear what you'say wit.h regard 1.0 16 consu11 ting about the factua] accuracy.
'i' 17 MR. JOHNSON: I would suggest to you tha L. i L is JB not a fact. It 5 a a premise tha t. 's 3n your ]etter. I'm 19 asking you, did you have any factual basis for that?
20 MR. RICHARDSON: Above and beyond what he hau 21 a1 ready I.es L i f i ed Lo? 22 MH. JOHNSON: However he wa n t.s t o answer the 23 quesLion. I 24 MR. HICHAHDSON: We]1, :I ' .n trying io get some
.25 elucidation from you. Are you asking for information beyond I
ACE-FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Coverage 800-316-6646
2 9' 9 3 4' O _ ., KSW 87 l 1 ' wha t he ' has . already.- tes tifi ed .to? 2 MR. JGUNSON: Not necesisari 3 y. 3 THE WITNESS: I don'L think.I can predict what . J4 'would have happened w3 th any inore certainty.than anybody elso I
. . l 5 wi th a . crys tal bal l but we did not want:it to happen and l 1
l 6 f urther complicat e an a.1 ready comp.licat ed af f air. i 7 HY MR. JOHNSON: i 8 0~ What Im trying to C.ind'out is what was your basin .) 9 for that belief? 10 MR, H1 Cll ARDSON : Wel l, he has a] ready tIestified
-11 . about ;fils assessmen t of Parks ' at fidavil and the allegatioris 12 which he made to 1.he news media. 'Are you asking him for what 13 basis he had beyond that?
O 14 MR. J011NSON: 1,et me put it another way. 15 BY MR. JOHNSON: 16 Q Taking what Mr. Richardson said, was that the 17 basis that he made statements to the media? Waa-the basis 1H for your want i ng to pr otec t Mr. Parks from the possibi]ity of 19 harassment the fact that he had made statements to the media? 20 A I suppose that'n a factor. 21 Q Any other factors? 22 A No, cir. 23 0 Did you conn:ider whether the ac t ion itself might h 24 be cons trued as discri mina Lion or adverse ac tion of a 25 haraccing or intimidating nat.ure? ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage MO 336-6646
'29934.0-KSW 80 I 1 MR. RICHARDSON: Are you referring to the' decision-2 suspending Parks as set forthfinLthe 3etter?
3 MR. JOIINSON r Yes. 4 'THE WITNESS: It. seemed to.be t.he bents course of. 5 action. The, man.was suspended with pay. And he was told i that we.would be in contact'with him an the a]3egations were 7 resolved, and the isnues studied. The.Bechtel policy is j I 8 ~ pret ty clear on anybody.'s ability t o dinnent is encouraged'in 9 our.Hechtel directives. We were merely' carrying out a 10 . process that.is very well known to every manager.-in Bechte). 11 Any. employee has any. right to surface concerna, and;-- 12 BY MN. JOHNSON: 13 Q But a t the risk of being suspended?- That's my I O: 14 clu eE ti on . Did i t occu r to you 't. hat you. were . suspending
- 15 somebody for raising. concerns?
l; 16 A- 'No. No, thd intent..of ihat was 1or the protect.3on 17 'o t the employee and an a_ course of action determined'iihat 1 18 that's the appropriate direction to gc. I 19 Q Hut you did nay. that one f actor t hat you could l l 20 think o .1 was the fact 1.h a t. h e had made his public statements, 1 21 and this was to protect him from reaction to those 22 s t.a temen ts ? 23 A Yes, sir. 2 /l Q So although you didn't necennarily drafi 1.h i a , you 25 ag reed wi t h every thi ng thal *s in here? t. l Le Ace-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
-29934.'O
'KSW 89
'l A Yes , 's i r , I do..
2 MH. J OHNSON .: Why don't wo break for-~1unch? I
, i
~
3 don't think I-have. Loo much more, but I-think il would be
~
4 besL."3f'we take a break for J unch. 5 (Whereupon,.at 1:00 p.m., the deposition ~was. 6 recessed, lo be' reconvened at 2:00 p.m. this same day;)' 7 8 9 ] 10 11 12 13 Le l' 14 15 l ! 16 { 17 H l- ! 38 .i 19 I 1 1' l l- 20 21 22 1 23 24 25 I
'e ACE FEDERAL REPORTERS, INC.
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' "29934.0 .
j l l KSW 90 l p
'l ' AFTERNOON SESSION' (1:10 p.m.)
2 Whereupon, 3 ElCHARD A. WHEEISR 4 resumed Lhe stand and, having been previously duly sworn, was 5 . examined and t esti fied f urther as foilowa: 6 EXAMINATION (Con Lin ued) 7 HY MR . ' J OIINSON : l 8 -Q If we can. return to t he in t.erv i ews that'Mr. Hofman 9 was conducting when he came from San Francisco'to investigate l 10 the Quiltec matter, did you participat e in. any .3 nterviews l' 11 other.than the one.LhaL was with Mr. Parks?' 32 A No, just the only one I was in'was with Parks. 1 13 0 Did you participate in a phone conversation with l .
'14 Mr. K3 t3 er wi th Mr. Hofman which, 1.believe, took place that i
1 15 you.were in-a hole 1 room or a mote 1 room aL the time with 1 ! l6 Mr. Hofman? 1)O you reca13 nuch a conversation? l 1
- j. 17 MR. RICHARDSON: When you say " participate," do 10 you mean l i s teni ng in during a conversation or -
l L. 19 BY'MR. JOIINHON: 20 0 Do you yemember such a conversation, whether you i 21 participal.ed or not? l 22 A 1 don't remember the ci r c ums t.a ncen , but we had 23 called Killer, I think that I.ee and I ended up slaying up 2 /l there in a Hosi of Ame ri ca hotel one night. 1or one reason or
~25 ano t.he r . I don't remember the circumstances o f: Ihe thing, g
ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage Mn3364646
l .-
- 29934.,0 .
KSW- 91 1 but'I think.he made'a' phone call to Kitler and I'm not sure .)
- -2 that Ki1.1er was-home. We-had Lo find a phone number for Dick l'
l' 3 to. contact-him, bul I don'L remember what that scenario was 1 l l I 4 all abobt l L 5 .Q Hef ore I ~ get i nt o the substance'of that, did you l 6 have any'other similar conversations with any other CPU or l 1-1, 7 Hechtel employees of Ihat. sort, in ofher words, ielephone t-1'
'O conversations in which you were on the line with-Mr. Hotman?
9 3 Not. that. I'm aware of. Not that I recall. 'l 1 ] l 10 - Q But Killer you were? 1 1 11 ~A I don't even remember the nature o f. Lhe-ca]1 to 12 Killer. l l 13 Q You remember a call to Ki t.l er, though?
@ 14 A I remember thal we made s o a.e Pind of'a call'to- .
15 Killer. l 16 Q We)), he remembered .it. too, in a deposition thal 17 he participated in on January 13 of this year. You say you 10 don't remember what the content of that conversa tion was? . 19 A No, I just don't. ] Do you r emember whether i t. had to do with Quiltec? ,l 20 Q J l 21 A I don't. I jus t - it. has just been too much i
'1 22 wat.er over t. 't e dam.
23 O Appar ent1 y accor di ng to the atatement of , l 1 24 Mr, Kitter, in hia depos i Lion, he had a conversa tion wi Lh 1 l 25 Mr. Kanga. He said "1 had the dincuncion with Kanga and t o.i d ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Covecage 800-336 4 46
'29934.0 KGW 92
'I him exactly what I had -done as far as Quiltec was . concerned 2 and then Jater on I contacted my supervisor and Dick. Whee.ler 3 and asked h im - wha t was happening. "
4 fio you'reca)) Mr. K.itler cal].ing you concerning. 5 what was happening about Quilt.ec? 6 MR. RICHARDSON: . Excuse me, I think'.there's a.much 7 larger context to tha t tes timony than what you rel~er Lo. 1 . 8 Will you give the wituens-the benef.it of t h a t'?'.
.9 MR~. JOHNSON: I don'L think it will be that 10 informative,.but if you care to.look at?5t,- you can.
.It sort' i
11 of goes back and forth discussing conversat. ions ha had with : 12 you and Mr. 'Hofman, and t hen al so wi th Mr. Kanga. It in not 13 in good order, I started asking ques tions page 109'oC his
- e. 14 d e po s .i ti on . If you.vant to read from there, go ahead.
1 15 .(Discussion o00 the record.) 16 THE WITNHSS: Your question again, sir?
-17 BY MR. JOHNSON:
18 Q Did reading this transcript of the Kitler 19 deposition ref resh your recollection at all of the 20 c i rc um s ta nc e s, of your d.iucussions with Mr. Killer? L 21 MR. RICHARDSON: Discussions, which discussions l l 22 with K3 tier? l l-23 11Y MR. JOHNSON: 24 O Mr. Wheeler, when you read t hi n t ra ns er.i p t, did it l 25 refresh your recollection of having conversations with 1 O ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverap 800-336 6646 )I
. .. j
'29934.01 KSW- 93 l 1 Mr. Ki Ller concerning Quiltec which you ma'y have had -with. him 2 -in the period appr6ximately.-March.1983?
'3 A I can't remember the specific conversation, but as.
4 I i ndicated earlier, i t was ' commonplace f or me .to ca)) my-5 leads on occasion, I do remember that Hofman wanted.to get 6 i n ' touch wi th' Ki tler and, an 1 have an opportunity to think 7 about i t, I thin'k I even had to call ny secretary to findfout 8 where h.is home was'no we could get a number to call him.at 9 home in.the evening. The nature of the conversation.1 can 10 only-second guesu because we were -- my time wi th Mr. Hofman 11 was to investigate Mr. Parks' breach of ethics i n 2 - l, so:it' 17 is-a logical concl usi on that tha t 's - - that the conversation 13 may have heen there, but I simply don't remember those 9 14 detaiju. 15 -Q- But it was during the context of that trip that
~
16 you had the conversation with Mr. Ki t. t e r? 17 A- Yes, sir. 18 Q I see. He didn't remember precisely the gict of 19 the conversa tion ei ther, but toward the end of thi:r 20 d .i n c u s s i o n , t.here is a reierence at the bot. tom of page 114 21 where it says "I had the discussion with Kanga and told him 27 exactly what J had done as far ac Ouiltec was concerned, and 23 then la ter on, T co n ta c t.ed my cupervisor and Dick Wheeler and 24 anked him what was ha ppen.i ng , and he told me after the 25 discursion I had wi1.h Ka nga tha t apparently Chuck Sanford got ACE. FEDERAL REPORTERS, INC. 202 347-3700 Natiaru:!d: C:;verage 800-336-6646
29934.0 KSW 94 1 .involvedLin thic-to'o, and he said ' tha t Chuck Sanford made a 2 statement to him, you, that.-1 had not donc anything ihat 3 anybody else hasn't done working for'the company." J
'4 My question'to you is do you remember Mr. Sanford- i 1
. ;1 5 making 1. hat' statement to you?
6 A I don't remember Chuck .upecifica))y saying'that, 1 7 but what.I think1that'that's with respect'to'la that the .I 6 s t.a r t u Ii business ha s i ts.~ hazards . . Contracts end. It -in a. )
)
-9 business. tha t' this year wit.h 162 men'in the department we~
10 transferred almont. 440, coithat t.e.1]n you almost everyone in I 11 the department got t. ra mi f e r red three Limes in the given- I 12 year. With the .very uncert ain business aspecta .in the. 13 startup field, everybody has their. resume out to.everybody, O. 14 and I ' t.hi nk ' t ha t that. statement j u u t. simply ref.locts 1.ha t. j ob 15 shops had Mr. Ki tler's _ resume as well as our own - you know, 16 other people. Tha t.s t he on] y thing 1 can read .into that. l' 17 Q And that wouldn't have been t. hat unusual? 18 A That would not have been that ununual. 19 Q Ge tting back to the March 22 meeting that you had 20 with Mr. Parks in which we went. over t. hat. earlier and also 21 the fact that you had no tes, let me jus t show you t.h e s e notes 22 again. I'm sure Mr. Richardson has anothe1 copy as we)), but. l l 23 since there seems t: 0 be more than one version, I think l 24 there's some not.ation somewhere in here t hat you recopied 2S them. is this like t.he original version of your notes and 1O I ace FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6646
'I i
l 2993'4.'O . l lKSW 95 l l i .1 Lhen you copied tihem over to'a neater form later? 2 A Yes. 3 .think t. hat'what I ended'up do.ing is junt I 3 joLLing'some things that jogged my memory as I was chatting j
-4 with Mr. Parks and then on the way back .3n the car.tried'to 5 put. down;the process of how.I went-about the convernaLion, .
6 .and it.was-pretty sloppy, so just to facilitate those people - 7 t. hat had to figure out where I was-coming from, I;put it in a .j i
'O final form. l 4
9 Q 'So you didn't take'these notes during the' meeting; j 10 you made an effort, Il sounded like, to either not'have notes 11 at the meeting or to take noten at the meeting. . l 12 MR. RICHARDSON: Which notes.are we talking about? e
'13 14 MR. JOHNSON: Noten of the meet.ing -- I think one I
-1 '
~
15 . ver:ilon ac tual l y does say "pos Emeeti ng notes" a t . the top. 1 (> Yes. One version of it is -- j i 17 HY MR. JOHNSON: ' 18 Q Are 1.hese a separate set of notes from these other I 19 notes? l 20 A W e 1.1, on the way up to the site, I put an agenda , i 21 Loget.her. I wrote il on the way to the site, no I put the ; I 4 22 kinds of things I want.ed to talk about into an agenda, these j 23 items here. 24 MR. RICHARDSON: Excune me. Heforo you - I think 25 we have to be careful for the record we're lookirug a t a page O ! ACE-FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Coverage 800-336 6646
29934.0
.KSW4 96 ;
'l
'l tha t'says a t the " top-agenda items." Are you saying.all.of 2 the~ wording on this page wau' written before --
[ 3 .TilR WITNESE: No, I. ..sc ribbl ed on -tha t ' du ri ng the - 4 cource of the conversati on an 'I remembered things, but I. I 1 5 simply ended up having a number of things, the status o0 the 6 empl oymen t.,. the llechtel direc L5 ve, - the things that I.. wanted' 7 to cover'while I was t.here and invita dialogue'on and I think l Y 8 tha(,-pretLy much.if. you read:these notes, you wi)) find'it-l 9 Collows i.n pretty much the same order, t (~ .. 10 BY MR. JOHNSON: l 11 ~Q So you came in with an agenda as far-as I can 1 12 underst:and it? 13 A Yes. 14 Q What was the mnemonic -- l 15 A It was -j us t a reminder to me, here's a mnemonic 16 agenda. It was just a road map for me.to make sure I didn't 17 fail to talk abou t things. 18 Q You are talking about this picco of paper without 19 the notes scribbled on i. L ? 20 6 Down through letter of March 21. 21 MR. R ICil AR DSON : I'm conEused. There's another 22 page tit 1ed " mnemonic." 23 HY MR. JOHNSON: 24 0 The one that sayn " mnemonic" seems to be part of 25 your recopied notes. Does it refer to some other page? 9 ACE. FEDERAL REPORTERS, INC. ( 202-347-3700 Nationwide Coverag 800-336-6646
;299.34;0 KSW' 97 1 MR. RICHARDSON: Wait a minute. I'm'not sureEhe.
2 said..that. In.:(he page w.ith:t.he, heading " mnemonic" uomething
.3 you wroi.e af ter the mee ting ; wi th Mr. . Park s o r.' he f o re' or 4 dur'3 ng. or what?.
5 Tf1H WITNESS: 1.think some were, . 3 ff memory... served 6 me --- 7 MR. RICilARDSON': Wiiy don'icyou:take your time to 8 review these things careCully. 9 THE WITNESS: Wel], i t -is pretty clear-I wrote
. 1
. 10 the agenda and mnemonic on the way to the site. In other.
- 11 war da -
12 HY MR. ;f oliNSON : 13 0 What was . the mnemonic? That's the part I couldn't 9 14 undercLand. . 15 A The. manner in which I addreas - thingu r ather. than . 16 speaking entirely off the cuCE, I wanted to orchestrate 17 thoughts t.ha t 'I knew ahead of Lime and so th.in looks 1.ike the 1 18 rough of tha t mnemonic, and-I referred.Lo it as such in the 1 9' up front not.es. l 20 Q When did you prepare this sheet? I l 21 ft on the way to t.he s.ite. i 22 Q When you r ei er to 1. h e page - 4 23 MR. R ICil h R DSO N : Can I just bring one t.hing cul? i 24 I'm not. trying t.o be obut'ructive, bu t. there are a 1of of 25 pagen in thir pack. That's why it is prudent to proceed O
)
ACE FEDERAL REPORTERS, INC, 202-347-3700 Nationwide Coverage 8(n336-6646
2 9934.0,
~Ksw 98 1 slowly. I notice there's a - page which has neal pri nting;
'2 dated March 22,;190'3- which.has "mne'monic" in.thel upper 3 1e0trhand. corner, and I: notice'two pages later you have'
'4 another page - which .i s ~ not qui te so neat,'if. I may cay that, 5 has some underlining, and al'least the beginning of the page 6 starts with the-uamewordu.-
7 MR. JOHNSON': 1-: don't know if I have the same
'O arrangement.of pages you do.
a 9 MR. R ICil AR DSON : It.is not clear t..o me whether Mr. . i i 10 Wheeler wrote out the page on the way up.there and perhaps q 11 the neater page is some thing he may have wri.tton af ter lLhe 'I 12 meeting. I 13 THE. WITNESS: -Abno]utely, after the meeti ng .Il
- a. '14 wrote the- nea ter page so somebody could figure outwhat my i
j i 15 acri bbli ng was about. 16 HY MR. JOHNSON: 17 Q .The-page that haa the under.15ned parts starta wit.h 10 the words'"our internal auditing process has," Lhat was 1 19 prepared before the meet. sng? 20 A- Yes, sir. l 21 Q And this page which says " mnemonic" underlined, 22 "our internal audit process has not Lo" - el ce tera , el 23 cetera. That was prepared afterwards? 24 A Yes, sir. I 2S Q Specifica))y it says "our internal a ud.i t. i ng i i
- a O
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.'29934.0: 1 KSW- 99 'l
.l 1 process has.not-to date turned'up. wrongdoing or your part'of 2 a magnitude which warrant.s dismissal."- I'm reading from the 3 . redraft of' mnemonic. '"Mr. GanCord requesled me to tell you 4 that you'wi].1'not be dism.isued un] ens new. evidence turns up 5 which would require another assessment."
6 Is this what you caid to Mr. parks?- 7 A Yes,.nir. 8 Q ']n some supplement.a] i interrogatory : responsen th'at . 9 GPU Nuclear filed in thiu . case. as ' representing supplemental 10 'responsen by Mr. Arnold, the f 0110w.i ng statement is - .I wi:13
- . 11 read two sentences and show you the language. Arnold i l'
i 12 ' concluded accordingly lat.e ,in the. afternoon of March 23 that l I l 13 G l'U Nuclear could not fulfill its obligations f or expeditious l !: 34 complet. ion if parks remained a L the ni te. Mr. Arnold l l . . 15 reviewed-with Rechte] management his judgment tha t Parks had l . 16 by his. personal attacks caused condit. ions that' required a l'. 17 temporarily barring him from the uite pehding investigation-(. 1H of hin allegations. With specific reference to the stat.ement .) 19 tha t Mr. Arnold reviewed, my question to you is did he l l 20 consu l t. with you as pa r t of - d 1 r j 21 A No. l 22 MH. H I C11 A H DGON : l lust a moment. This is an 23 excerpt Irom -- 24 MR. ;1 0 H N S O N : Fr om a supp.lement.a] responce filed 25 by - I think Mr. I,ewis actually may have prepared that. O ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage MO-336-6646 I - . _ _ _ _ - _ _ .
29934.0 KSW 100 fl MR. RICHARDSON: I would.like you Lo read-Lhis: l 2 en Lire excerpt. bef ore you. respond to that question, ! I 3 THE WITNESS: What's the so stafC?' 4 MH. JOilNGON: That. meann " site operations." 5 BY MR. JOHNSON: 6 0 D.i d . M r . Arno.ld review that i nf ormation wi t.h you?
~l 7 .A No, sir. J
~
8 g Do'you know who.he-referred'to when he-sa.id "with 9 Rechtel management"? 10 MR. RICll AHDSON : Don't guesc or specu. late. 11 THE WITNESG: 1 don't. know. 12 IlY MR. JOHNSON:
'13 Q Don't be afrai.d to give an answer. You don'L'have .O 30 to specu] ate lo give an answer if you know.
15 A I just simply don'L know, you know, a specific 16 person, I can't name a speci fic person. J 17 'O Who was Mr. Arnold's counterpart in the Bechtel ;i j 18 organization that he dealt with on matters related to TM3-2? 19 A Chuck Sanford was the responsible ofCicer for 20 TM1-2 here at llechl.el. f 23 0 Did Mr. Sant ord rela te to you any conversation 22 tha t he had with Mr. Arnold on the subject? 23 A Not that I reca)) . 24 Q I may have covered this before, but let me ask you 25 again: Did you have any 1 ole in t.he deci a.i on to interview j I 1 ACE. FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coverage 800-33MM6 L- _ - _ _ _ _ _ _ _ _ _ - _ _
w .. . p 29934204
.KSW- 101 1 Mr. I! arks concerning Quiltec?
2 A No, sir. 3 'Q - Di d you hav.e . any i ole in t he r:eassignmtint' of 4 Mr. Parks.after.he left TMI-2?- 5 .A .Inhofar as'the mechanics of the transfer,.. yes. 6 0 Whdt were those mechanical aupacts? 7 A T don't remember the details of how it. came to O pass that Mr.. Parks wanled to.go back.to work,,and _there was 9 some ki nd of an agreement reached that we would put him back 10 to work'on a job-site, wheret!pon I called my counterpart
~
11 . offices in San Francisco, Ann Arbor, 1,ou Arige) es , .naying ' havn 12 you .got an opening for s tartup engineer, and indeed.there was 4 33 'an openi ng a t the' Coolwa ter coa 1 ' gasi fi cation plan t in :) 14 Ha r s. tow , Ca.lifornia. That informa tion .was presented to 15 . Parks, and he decided.to accept that assignment ~and I.went 16 through the mechanics of the transCer. 17 O Did you nave any role in-the -- I understand from 18 what you are saying that this occurred after the settlement 19 wan reached between Mr. Parks and.Hechte) concerning the Dol. 20 maLter.
'd 21 A Ves, uit. l
~
22 O Prior to that, were you involved at al,1 in the i 23 determination of what to do with the matter that wan l l 24 addressed in your March 24, 1983 J e t.ter ? You nay in the 1 l 25 March 24 letter that the ma t i;e r is under review. In other i I e i l l I ACE FEDER AL REPORTERS, INC. 202-147-3700 Nraionwide Coverage MX)-3364M6 I i
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- KSW . 102 J
1 - w o nia , he was placod on leave with' pay, I believe. 2 A Yes.
.3 0 Were you a parti ci pa nt 3 n the ' determinate ons J Lha t.. j l
4 appear to be contemplated by this 1eller'as to what his 5 ul ti mate. sta tus was, going to be? 6 A No, I wasn'L, i 7 0 Who was, to the best of your. knowledge? 1 1 0 A' That would s tric tly be an assumption that the l 9 . project tcam wab handling a project ~ matter. 10 MR. RICII ARDS O N : ' Excuse me, I thought you were
.13 asking about. the ultimate decision concerning Mr. Parks' 12 statun. i 33 MR. ;1011NSON : Yes. There's a reference -
l- .. 0 14 MR. RICil ARDSON : Or were you referring to the 15 words "revi ew of the a] ] ega ti ons "'? 16 IlY MR. JOHNSON: 17 0 What I was actually thinking of in "we're pl a c i ng .' 10 you on an in definite leave of absence wi t.h pay. 'We.will be 19 -in touch wi t h you wi t hin 30 days with regard to the status of l 20 our review of your allegations." Did you understand it as l l 21 tha(, per l.a i ni ng to Ihat? Di d you parti ci pa t.e in that. review V 22 of thir, mat ter and review of your allegations that's referred ( L l 23 to in this Jetter? 24 A The extent of my involvement essent.ially when 25 Mr Parks went ofL aiLe iha L pr'e L ty much concluded my 9 ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336WA6
l J 1 29932. 0, KSW -103
.1 involvement inLLhe matter-until nuch time tha t- I reansigned
'2 him, q
'i 3 Q I see. Fair.enough. '
IL 4 'Mr. Pa rks, in his 'supplemen tary af Cidavit, I 1 l 5 . bei 3 eve, mentions that he contacted you on tw'o occas.ionn- ,j , 6 after' he le0L_the site on March 24. Do you recall'his calls i 1 7 to'you? i 8 A I don't roca.11 bia~ cal]a specificar]y,.but 1.here
.- 9 would have probably been a record of some sort made of them.
l 10 Q Do you have a record oi.them?' l'
-11 A No, sir.
12 0- . Wha L k3 nd of record were you' rei err 3 ng to ' then? 13 A If my secretary would have Laken the call 'she '- 9 14 would have made a telephone memo, or I wou.1d havo~ document.ed 1 i i 15 something in the way of a telephone call, but I don't 16 remember specifica.lly. :I remember ham cal. ling and saying
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17 what's the status of where I am, and beyond that, I really 1 18 . don ' t. remember the deta il s of the i h .i n g . I 19 Q Did he - 20 A IInti) cuch t.3 m e an we reusnigned him, the' answer 21 had to be from me was that the investigation is nLill ongoing { 22 and there was very liLtle else I could have answered. l 23 Q No word yet, something like. thal? l 24 A Yes, sir. . 1 l 25 0 :I take iL from this Jette) t hai. in dated March 24 i l 9 ACE FEDERAL REeonTens, INC. 202-347-3700 . Nationwide Coserage fm336-6646
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29934.0
. KSW '104- -q 1 tha t you signed _ it on March 24'. Is-thdt true'%o the~best of I 2 your' recollection?
3 A Yes, sir. 4 Q Prior t o si gni ng - that, di d you read the S6 -page 5 af Cidavi t of .Mr. Parks? 6 A I don't reca)) reading.the entire.affidaviL. .I 7 had information in bits .and pieces with respec t to the i 1
'8 affidavit, but it wan so broad.an'd aweeping.thht it was going 9 to take som'e time to get through tha t thing.
10 Q Did someone supply you with excerpLs?.: 11 A I'm certain that aEler the f ac t a t one time 'or . 32 another I have seen a lot of the correspondence, -bul -- j 1 13 Q I mean before you signed;the;lotter.
.O 14 A I -
15 MR. RICll ARDSON : What do.you'mean'by "showed him 16 excerpts"? l 17 MR. JOHNSON: I don't know. He to.ld.mo that-10 someone probably showed him excerpts. 19 MR. RICHARDSON: 1,et's have the answer read back. 20 (The reporter read the record au requested.) p. l 21 IlY MR. J OllN SON : 22 Q My question is what were you referring Lo, "I had 1 23 b.itu and pieces"? 24 A W o .l l , Mr. Parks made his statements a matter of 25 public record. It went before the news media, un you picked 1 ACE-FEDERAL REPORTERS, INC. I 202 347 3700 Nationwide Coverage tux)-336 6646 J
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-KSW '105 ll i
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'h 1 up from the news media thene broad stat.ements thal were quite
-b 2 inf.lammatory, and with-my. persona) know3edgeLof.how things i
.( -1 3 were processed and the. process at the Ir& nd,'having had my -)
.. 1 4 ' staff'do come work, I knew-the meticulous . leve)-' otD detail ;
o; l
-5 thal everything was..done with'on the 3%ndand:over the i J4 I
'6 coursetofimy associat. ion with KY. Parl$f Wom ~ .the first
l Ay 9 ] 7 interview wi th Mr. Hofman until iL became apparent Lo'un that i i 8 rio matter wha t kind of .an avenue' that we invi ted a meani ngf.u3: 9 d i a lo'g ue wit h :. the gent leman - tha t . he wypt not ready-Lo' play
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10 ball,Lthat he'had his'own course.of action set and that all. I 11 our ef forts were futile. So _I can assd<ae. f rom ' empi rical d 12 informat3an, from actual participat31n in 1.hu project' months' 13 before all of thly situation came to pass, I firmly believed
=s 1'
.14 that there was:a . management process in pauce that would have 15 't urned every alone there was to turn ovthe to make sure thi,ngs 1 s , ,
16 wero.done ri gh t. . Nobody, i n my es ti ma t i on', at thal Inland, 17 would have done anything clue. It.would have been , 18 . foolhardy. It was such;a pub]ic. spectacle as it was.
.I.~
I, 19 Q You were confident that the allegations in 20 Mr. Parku' aLfidavi1 were incorrect? ) 21 A Yes, I was. I was convinced, in my own mind, the,b l 22 they were not correct. 23 MR. JOHNSON: Thank you. I do appreciate your , i i 24 a t tenti on in taking your time. 25 EXAMINATION
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129934.0- M ,
, TKSW 106
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2 0 ( l' mfjht ask you one quest i on, Mr . Wheeler. 2- A Y N.Il right. .i l' Qs I} I ,i 4 y ,Q- I be.1ieve in.your noten of the March /G meeting '
? .
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g w i 1.h . M r . Parku, I'm reterrini].Lo the page which, a L the Lop, 4S t
.( ~6 hd5 "agunda itemD." ,
I$ Af ., 7 k A Yes. W
'8 $ Q I be.lieve this .is the page where.you indicated 'l e -
f.
} Lhat you made certain'not'es during Lhe course!of the meelLingi 10 Aext to some of the. headings which you had placed on the page 11 prior to t h e ,$u e e l i n g . I'notica at thel bottom of Ahat*page
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12 there's tv/crence to a Kannau approach. Do you tee th,at? -1 is 1 4.} s
, , 4 11 s% A Yes. I t was - .,
y Il k O .3f I can - my question 'ia, can.you tell u rj , if 'O t i .. I5, - you recall, wha t wa s said between you and Mr. Parksi d L. u
' 16s.
> connection witht. hot relerence t o a Kan 2an 'appWudrd '
;. .\ <>;
17 A We yere trying to-invite a dialoguu from Parks to. 10 Le31 us about'cafety issues. In tryi ng to- win 'hi u 'i I g r. I
'19 confidence, get him t,o t.alk about thene things, and 'l l
'?
' Kr l 20 specifically - and assur e him that. we did hvarything in our 4. {
21 arsenal, everything in our power to bring uafety issunu to a, 22 conc]esion, I cited a siiualson ut. the Wo]f C1eek job s i t<e in t 23 Vfnsas where one of the s t.al lup engineers , a f.ellow by the 24 na q of liob Gass, aad nome concerns about chemi stry apa t he 25 approach to f lushing or cleaning piping i n t ernal s ,' ob l o )
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c . , , s' o 3( ; l}l t . 29934.'f' r M/. KSW 107 l Q '. .1-s 1 1 .4 , jy - y/ though t -b9/was on target and'tpoudnt thal-he had t.h:3 Q r
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/[' . 2l 1potiennal (or a s:i tuat ion which would not have' led 't o the i
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t [ ' 1 . // - cleaning of..the pipe as appropria te. Ho Celt like he was ; j rI l
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l g V..g + ' that thought' l 3,, - .; get';)ing
;- stonewa.1 led on.sil,e by his' supervisors -
"5 ' he ways going overboard with a. direc ta on.
3
$ .,'6 .
I was so incensed when Bob ca). led .me about it that 7 this wan the thi ng going ' on, or at least alleged ' Lo go on,
)! .
fl 1. hat ~I Wi.l D oh n flirplalle .thill Same a f ternoon .or next niorna ng ; 9 Yjofyooutandresolve the issue, and.indeed it was concluded !
' The extent:on a c a f:ety 10 just.the way'it should have been.
11 issue can't remain lef L open to ques tion. It has to be 12 reco]ved. I took my project engineer and his assistant- to 13 Lask over the event unti1 that issue was resolved and I stuck O 14 with ii unti) it was over and I c i t.ed that,particular example 15 Lo Rick to say, we don't leave those things alone. You have 16 a problem.we want to know about them. Here's an example of 17 one.that wa; taken care of. l
-18 MR. RICHARDSON: That's al] I have.
19 EXAMINATION 20 BY MR. JOHNSON: 21 Q It was your impression at this 3-22-03 meeting, h 22 l.h o u g h , l ie t things had progressed beyond ne c i mpl y somebody 23 raining a!ety oncerns and having them resolved, there were 24 so many morc l a ye:r ? of charges of intimidation, haraunment 25 and so on that he 1 Jn't bite on tha t approach? ( l ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6646
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.,__ ._ -- _ -. - . = _ - - _ - _ . - - _ _ _ _ _ _ _ _ - _ . - ___ ____ - _ _ -
29.934.'O KSW' 108 _b ' 1 MR. RICHARDSON: The preface of your quesLion
-2 .makes .it a ]iit3e bit confusing as t o what you are geiting 1
3 a t. . 4 MR. JOHNSON: That he d.id not respond favorably.
'i You say you' were tryi ng thin approach, and he didn't respond 1 1
6 to!st. Is that your answer? 7 THE WITNEGS: 1 I hink tha L Mr. Parkn was a1 ready. ! H on a merry-go-round that was going much too fact for him. He- ! , i
$ h'ad chosen a course oC-action Lhilt he had vacilla ted on 10 whether to come back,'whether to stay,..but.'I thi nk he just 11 go t hi mself mi red so deeply and didn' t have 'the. l 1
12 sophistication or the wherewithal or the forthrightness or f 13 the integrity or whatever to junt Einally say I got caught up 14 .in my own lie, and come back and say, let's get on with the 15 business of business. I did everything I knew to win that 16 man's confidence, 1. 0 ask him about these safety issucu, to 17 get him to tell me about them and I was unsuccessful with 18 him. In every forum that he was asked about specif'ics, the1e 19 wasn't any meal on Lhe bone to go aller. He simply wouldn't 20 give us anything to work with, and after the fact, learning. 21 that. he had been on this courne in duping us al1. along, 1 22 f el t pre t.ty bad abou t it. I was just. dingunted with i t. . 23 BY MR. JOHNSON: 24 Q When you say he got caught. up in his own 1ie, what , i 25 are you referring 1. o ? , ACE-FEDERAL REPORTERS, INC. 1 202 347-3700 Nationwide Coverage 800-336 6646 {
I 29934.0 KSW 109 1 A I'just think Mr. Parks chose'a-di.rection at some 2 point in timo and i t .i u obvious.from has answers and h.in 3 correspondence.and things he had already'in place thatLwhile 4 .he was tryi ng to play a game ,wi th uu , we were being used. 5 There wasit ' t ali intent to re:tolve ali issue. 6 MR. JOllNSON : Thal's a.]1. Thank you.. 7 (Whereupon, al 3:00 p.m., the deposition was. L l. 1
.8 concluded.)
9 10 _ . _ _ _ . _ _ . _ _ _ _ . _ _ _ _ . _ _ _ . _ _ . _ _ _ _ _ l 11 HICilARD A. WifEELER. 1 l1 12 l 13 O 14 15 1 16 17 i 18 19 l 20 l 21 22 1 23 24 l- 2S O ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-3364M6
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-CERTIFICATE OF NOTARY PUBLIC & REPORTER i
S 0' I, KATHIE S. WELLER , the officer before whom f I the foregoing deposition was taken, do hereby certify ;j
.t that, the witness whose testimony appears in the l
foregoing deposition was duly sworn by me; that the testimony of said witness was taken in shorthand and thereafter reduced to typewriting by me or under k g t my direction; that said deposition is a true record ! l of the testimony given by said witness; that I am t
.{
neither counsel for, related to, nor employed by { 1 any of the parties to the action in which this deposition was taken; and, further, that I am not a relative or employee of any attorney or counsel I O employed by the parties hereto, nor financially - or otherwise interested in the outcome of this action. k l [ t GN1Ll) Notary Public in and for tlie
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b2 l District of Columbia { f My Commission Expires 11/14/89 I l i I 1 I f O . . . - _ _ . - _ _ . _ . . _ . . _ . _ _ . .. -. . _ - _ . - _ _ _ _ - _ _ _ _ - _ _ - _ _ - _ _ _ _ . - - - - -}}