ML19256B786
| ML19256B786 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/09/1979 |
| From: | Goldfrank J, Gorinson S, Hilbish J GENERAL PUBLIC UTILITIES CORP., PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 7908290272 | |
| Download: ML19256B786 (74) | |
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PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE ISLAND
.________________-_----____x DEPOSITION of GENERAL PUBLIC UTILITIES SERVICE CORPORATIONbyJOHNF.HILBISH$heldat the offices of the President's Commission on the Accident at Three
~
Mi1e Island, 2100 M Street, N.W.,
Washington, D.C.,
on the 9th day of July,1979, commencing at 9:45 a.m.,
before Irwin H. Benjamin, a Certified Shorthand Reporter and Notary Public of the State of New York.
1908 118-BENJAAZIN REl'ORTING SERVICE CERTIFIED SHORTilAND REPORTERS FIVE ItEEK.%I AN STREL"r NEw YonK.NEW YOttK 10038
[212] 374-1138
n e
i 1
2 2
3 GENERAL PUBLIC UTILITIES SERVICE CORP.:
4 SHAW, PITTMAN, POTTS 6 TROWBRIDGE, ESQS.
(~'
1800 M Street, N.W.
5 Washington, D.C.
20036 6
BY:
ALAN R. YUSPEH, ESQ.
of Counsel 7
8 9 COhBfISSION :
10 STANLEY GORINSON, ESQ.
Chief Counsel 11 12 JOAN GOLDFRANK, ESQ.
Associate Counsel 13 14 000 15 16 J0HN F.
- HILBISH, having been first 17 duly sworn by Joan Goldfrank, Esq., was examined 18 and testified as follows:
19 DIRECT EXAMINATION 20 BY MS. GOLDFRANK:
21 Q
State your full name, please.
08 119
~
22 A John F. Hilbish.
23 Q
And your current addrees?
24 A RD 2, Box 415, Burnville, Pennsylvania.
25 Q
And your current employer, please?
BENJAMIN R EPO RTIN G S ERVICE
e e
1 Hilbish 3
2 A
Metropolit.an Edison Company.
3 Q
And what is your position there?
4 A
Supervisor of licensing.
('
5 Q
Did you bring a resume with you today?
6 A Yes, I did.
7 MS. GOLDFRANK:
I would like to mark as 8
Hilbish Exhibit 1 a resume of John F. Hilbish.
9 (The above-described document was marked 10 Hilbish Exhibit 1 for identification, this date.)
11 Q
Did you prepare this resume?
12 A Yes, I did.
13 Q
Is it a current resume, up-to-date?
14 A Yes.
15 Q
Could you tell me what your responsibilities 16 entail as supervisor of licensing at Metropolitan 17 Edison?
18 A Yes.
19 In that position, I am responsibfe for the 20 licensing of all of our generating stations of nuclear 21 and fossil.
L 22 ra g?
Q Does that entail also licensing q r
23 A No.
2%
Q Could you explain, as your resume indicates, 25 between June '70 and June 1973 you were Research Assistant B ENJ AMIN R EPO RTING SERVICE
s 1
Hilbish 4
2 at Pennsylvania State University.
Could you explain 3
the. substance of that position?
4 A I was continuing my graduate work and at the same
~
5 time held a full-time position with the University in 6
research and as a reactor operator on the research 7
reactor there.
8 Q
Could you explain to me what a research 9 reactor is?
10 A It is a small pool-type triga reactor; no power 11 production, just for test and research.
12 Q
As a graduate student at Pennsylvania State, 13 were"your studies in nuclear engineering a mixture of 14 practical experience and theoretical study or was it 15 purely theoretical study?
16 A It was a mixture.
17 Q
Could you explain the division, how much 18 time was spent in a classroom?
19 A For the actual graduate, most or it, I did take 20 two lab courses, thesis courses, however, most of it was 21 classwork study, and then time spent on my job was with
(
22 work with the reactor.
1908 121 23 Q
Spent at your job as a resaarch assistant?
21 A Yes.
25 Q
Have you had any training while employed by BENJAMIN R EPO RTING S ERVICE
s a
g 1
Hilbish 5
2 Metropolitan Edison since November 15',
1973?
3 A
Yes, I did.
I went totheB6hsimulatorforone 4
week down in Lynchburg, Virginia, approximately 1975.
5 Q
Could you describe that training, please.
6 A It was one week, approximately, approximately 7
half classroom and half on the computer simulator of 8
the mock-up of Three Mile Island.
9 Q
Were you give a test at the end of this one 10 week?
11 A Yes.
12 Q
Is that the only training that you have had 13 since employed at Metropolitan Edison?
14 A I have done other self-study-type programs.
15 No formal training, however, besides that.
16 Q
Can you explain what you mean by self-study?
17 A-Late last year I was in a program to sit for an
~-
18 ' NRC licens e.
However, I was transferred to my new 19 position in January.
There ore, didn'It complete it.
t 20 That was mostly a self-study program where they gave 21 class outlines and you would go on the responses, L
22 questions.
23 Q
This was a class sponsored and taught by 1908 122 24 Metropolitan Edison at the site?
25 A Well, there were two of us in the class, and we BENJAMIN R EPO RTIN G SERVICE
1 Hilbish 6
2 would work on they would hand out a book of,say, 3
10 weeks' material, and then we would go through and 4
prepare that work.
~~
5 Q
Who prepared the booklet?
6 A The Training Department.
7 Q
However, you did not finish that course 8 because you were transferred to your present position?
9 A That's right.
10 Q
Is that correct?
11 A That's right.
12 MS. GOLDFRANK:
I would like to mark as 13 Exhibit 2 a memorandum prepared by J. T. Willse, 14 Babcock 4 Wilcox, concerning a meeting at Babcock 15 4 Wilcox in Lynchburg.
16 (The above-described document was marked 17 Hilbish Exhibit 2 for identification, this date.)
.n 18 Q
We have marked as Exhibit 2 a memorandum 19 prepared by John Willse of Babcock 6 Wilcox.
Could 20 you please look at this exhibit, and as the exhibit 21 indicates, you were present at this meeting, is that b
22 correct?
23 A Yes, I was.
24 Q
Could you tell me why you were sent as 25 Metropolitan Edison's representative to this. meeting?
S ENJ AMIN R EPO RTIN G SERVICE 1908 123
1 Hilbish 7
2 A As supervisor of licensing.
We were contacted i
3 by our proj ect manager approximately three or four 4
days before the meeting.
~~
5 In my position of supervisor of licensing, I did 6
represent Metropolitan Edison at the meeting.
7 Q
Were you told as to what the purpose of the 8 meeting was?
9 A Yes.
B6W did telecopy us a memo concerning the 10 purpose of the meeting, and asked a few questions in 11 response to general questions that the NRC was ', king 12 in relation to TMI.
13 We responded to that and I did go to the meeting.
14 Q
As I understand it, BSW contacted you?
15 A That's right.
16 Q
And you were called to this meeting, is that 17 correct?
18' A Yes.
19 Q
Could you tell me what wa5 discussed at 20 this meeting?
21 A Loss of pressurizer level indication.
L 22 Q
Was this as a result of an occurrence at 23 Davis-Besse l?
24 A Yes.
The meeting was tne result of an occurrence 25 at Davis-Besse 1.
1908 124-BENJAMIN R EPO RTING SERVICE
I Hilbish 8
2 Q
Were two incidents at Davis-Besse 1 3
discussed?
4 A
I am not sure how many.
(
~ ~ ~
5 Q
Do you remember if there was a September 24, 6
1977 incident at Davis-Besse discussed?
7 A I do not know if that incident was specifically 8 discussed at the meeting.
9 Q
Do you know if a Novemb,er 29, 1977 incident 10 at Davis-Besse was discussed?
h 11 A
I am not sure of that date, either.
I know it 12 was generally discussed.
As far as which incident or 13 specific date, I do not recall.
14 Q
At this meeting, was this the first time 15 that you heard of a loss of pressurizer icvel indication 16 incident at Davis-Besse?
17 A-Well, I have heard it befo e, based on the fact 18 that B4W had contacted us p*.or to that to arrange to 19 go to the meeting, so I heard about it-prior to the 20 meeting on the 14th.
21 Q
When B6W contacted you concerning this
(
22 meeting, was that the first time that you had heard of 23 the incident at Davis-Besse?
24 A It is the first time that I can recall, yes.
We 25 did have a similar occurrence at TMI.
In analyzing and 1908 125 B ENJ AMIN R CPO RTING SERVICE
9 Hilbish 1
2 doing research on that, I know we worked with B6W.
that However, I do not recall them mentioning any at 3
4 time.
5 Q
You indicated that there were similar incidents at TMI prior to this March 9, 1979 meeting.
6 7 A Yes.
8 Q
Could you tell me when those: incidents 9 occurred?
I had There is a response to the B6W 1etter that 10 A prepared in preparation for the meeting talking about 11 12 the incidents at TMI 2.
MS. GOLDFRANK:
I believe that a February 8, 13 1979 letter that was prepared by Mr. Hilbish is 14 15 attached to Exhibit 1 which has already been 16 marked.
17 Q
You state that both of these events were Could
..m.,
18' reported to the NRC on licensing event reports.
you tell me who decides whether or not,an event should 19 20 be reported to NRC?
That actually falls under the responsibility of 21 A
\\m.
the Plant Operation Review Committee.
22 And both of these events were reported?
23 Q
24 A Yes.
Did you keep any notes of the meeting you 25 Q
1908 126 BENJAMIN REPORTING SERVICE
1 Hilbish 10 2
attended at Babcock 6 Wilcox on February 14, 1979?
3 A
I don't have any notes now of the meeting of 4
February 14th.
The meeting was supposed to be C
5 summarized by Mr. Foster of the NRC.
However, in 6
checking last week, we have never gotten any results 7
of the meeting from the NRC, as far as any evaluation.
8 Q
Did you keep notes and ycu just did not 9
retain them?
10 A I am not sure.
I went back and I found just a page of rough notes from B6W presentation the day before 11 12 the 13th of February as to why we were called to the 13 meeting, and there were just a few things for me to 14 look into, you know, on my set of notes, but I have 15 nothing from the 14th.
16 MS. GOLDFRANK:
Could I have a copy of 17 these notes, please?
, e%-
18 ' ~
MR. YUSPEH:
Sure.
19 Q
You state that on February _13th, the day 20 before this February 14th meeting, there was a meeting 21 held at Babcock 6 Wilcox concerning the February 14th C.
22 meeting.
23 A That's right.
2%
Q Could you tell me who was at that meeting?
25 A Quite a few people from B6W, and most of the people BENJAMIN REPORTING SERVICE 1908 127
1 Hilbish 11 2
from the utilities.
I don't have each of their names.
3 Q
Were people from the NRC at that meeting?
4 A No.
5 Q
Could you tell me basically what was 6 discussed at that meeting?
7 A The same thing that was discussed the next day.
8 B6W just got the people together, discussed the 9 responses that we had sent to B4W, tried to give a 10 little more insight besides the one memo that was 11 telecopied to the utilities asking them to come to 12 Lynchburg, and it was the same subject matter that.was 13 discussed the next day.
14 Q
As I understand it, you spoke for Metropolitan 15 Edison at this meeting?
16 A That's right.
17
'[
Q Did you state, basically, what you wrote 18 in your February 8th letter?
19 A Yes, that's all.
20 Q
You did not go beyond the letter?
21 A No.
22 Q
Page 2 of this March 9, 1979 letter, marked 23 as Exhibit 2, states that with respect to the two inci-25 dents reported at Three Mile Island 2, that "Both of 25 these events were thoroughly evaluated."
BENJAMIN R EPO RTIN G S ERVICE 1908 128
s 1
Hil'bish 12 2
Could you explain to me by whom these were 3
evaluated?
4 A I believe each was evaluated by Metropolitan 7
5 Edison at General Public Utilities Service Corporation.
6 Q
Who at Metropolitan Edison would have 7
reviewed this?
8 A Again, the Plant Operation Review Committee.
9 Q
And who at GPU?
10 A I am not sure which group in Generation, probably 11 the Safety Analysis Group, I am not sure of that.
12 Q
Could you tell me if there was any reference 13 at this February 14th meeting to loss of pressurizer 14 level indication high?
15 A Not that I recall, since our incidence were both 16 low, and that was the experience that we had seen, 17 that's what I was prepared to talk about, and that's w$at 18 I was keying at that meeting.
19
=
Q You do not recall 20 A I do not recall any discussion of pressurizer 21 level high, 22 Q
Was there any discussion at the February 13th--
23 A Not that I recall.
2t Q
On Page 2 of the March 9, 1979 memo, there 25 is a statement in the second to the last paragraph, and 1908 129~
BENJAMIN REPORTING S ERVIC E.
t 1
Hilbish 12 2
Could you explain to me by
~.cm these were 3
evaluated?
4 A I believe each was evaluated by Metropolitan 5 Edison at General Public Utilities Service Corporation.
6 Q
Who at Metropolitan Edison would have 7
reviewed this?
8 A Again, the Plant Operation Review Committee.
9 Q
And who at GPU?
10 A I am not sure which group in Generation, probably 11 the Safety Analysis Group, I am not sure of that.
12 Q
Could you tell me if there was any reference 13 at this February 14th meeting to loss of pressurizer 14 level indication high?
15 A Not that I recall, since our two incidents were both 16 low, and that was the experience that we had seen, 17 that's what I was prepared to talk about, and that's 18 what I was keying at that meeting.
19 Q
You do not recall 20 A I do not recall any discussion of pressurizer 21 level high.
22 Q
Was there any discussion at the February h'--
i908 i
,3 A
Not that I recall.
2%
Q On Page 2 of the March 9, 1979 memo, there 25 is a statement in the second to the last paragraph, and BENJAMIN REPORTING SERVICE-
l i
I Hilbish 13 2
I quote: "The remainder of the morning was spent 3 discussing the consequences of loss of level indication, 4
the differences between DB-1 and the other B4W plants..."
C' 5
Could you explain what discussion occurred ~ ~ ~~
6 concerning the differences between the DB-1 plant and 7
the other TMI 2 plants?
8 A I just remembered two.
One was a difference in 9 auxiliary feed design between the two units, and the 10 other, the Davis-Besse, is apparently not a lowered 11 loop plant similar to TMI.
12 Q
Could you explain the difference in the 13 design of the auxiliary feedwater system?
14 A I am not that familiar with Davis-Besse.
~
15 Q
So just basically there was a general 16 discussion of general differences in design of the 17 plants, is that correct?
18 [
Yes.
19 Q
The last paragraph on Page.2 of Exhibit 2 20 states that Mr. Foster stated that as far as he was 21 concerned, loss of pressurizer level indication was k
22 merely an operational inconvenience and that the loss 23 of pressurizer level was not a safety concern.
24 Do you remember him making that conclusion-1908 f31 25 at the meeting?
BENJAMIN REPORTING S ERVICE
~
14 1
Hilbish 2 A Yes.
In fact, I think that's also B4W's 3 conclusion.
You will find that statement on my page of 4 notes.
~ ~ ~ ~
r k-5 Q
Your notes are being Xeroxed.
6 A As the first sentence.
7 Q
As a result of this conclusion in which Mr. Foster of NRC stated and as was articulated by 8
you that B6W agreed, was there any operating procedures 9
10 changed as a result of that conclusion?
11 A No.
12 Q
Were there any operating procedures occurred changed as a result of the two transients that 13 14 at TMI 2 on April 23rd and November 7th?
15 A Yes, there were quite a few changed.
I am not 16 sure if they were changed directly in relation to loss 17 q[ pressurizer level.
However, based on the April 23rd there were quite a few modifications made and 18 transient, 19 procedure changes as a result of the transient.
- However, I do not know if specific procedure changes were made as 20 21 far as pressurizer level indication.
b Who would have made these procedural 22 Q
190813{
~
23 changes?
At.that 21 A Any of the engineers, technical support.
25 time it would have gone through the plant operation, BENJAMIN REPORTING SERVICE
1 Hilbish 15 2
Review Committee, and would have been approved by 3
the superintendent.
4 Q
As I understand it, technical people would n
5 have drafted these operational procedures?
6 A Or operators.
Essentially, anybody can draft a 7 procedure change, and then it goes to a Review Committee, 8 and then for approval to the Superintendent.
9 Q
Do you know of any, or have you heard of any, 10 other utilities which, as a result of loss of pressurizer 11 level indication transients, have made changes in their 12 operating procedures?
13 A No, I don't.
14 Q
Since the conclusion was made that this was 15 an operational inconvenience, was this conveyed to the 16 operators who had to deal with this matter?
17 A --
I don't know if it got back to the operators.
.w.
18 MS. GOLDFRANK:
I would like to mark as 19 Exhibit 3 handwritten notes from a F~ebruary 13, 20 1979 meeting by John F. Hilbish.
21 (The above-described document was marked 22 Hilbish Exhibit 3 for identification, this date.)
~
23 Q
As indicated, on your notes, in quotes, 21 you state, " Operational inconvenience."Q8 }3) 25 Was this a conclusion presented by B6W? B ENJ AMIN REPORTING SERVICE
1 Ililbish 16 t 2 A Yes, it was. 3 Q Was there any independent investigation 4 into this conclusion ~by Metropolitan Edison? (~ 5 A It had occurred and had been thoroughly evaluated 6 on two previous occasions at TMI 2, and was not thought 7 to be a safety concern. 8 Q Do you know how B6W arrived at this 9 conclusion that loss of pressurizer indication was an 10 operational inconvenience? 11 A It was found at the meeting that they had done a 12 lot of work in this area, and one of the things that 13 had come out of it, I am not sure it is mentioned, I 11 had never seen this memo on top before from B6W, however, 15 B6W had prepared for Arkansas back earlier a safety 16 evaluation on this, which both Arkansas and B4W 17 presented at the meeting. n, IEf Q Do you know what that evaluation entailed? 19 A No, I do not. 20 Q You never received -- 21 A I have 22 Q You have never received a copy of it? 23 A No, I have not. 21 Q Your notes indicate that " Foster will send 25 summary report." 1908 134 BENJAMIN R EPO RTIN G SERVICE
I 17 liilbish I 2 A Yes. Qk You never received a copy of that? 3 4 A No, I didn't. ( 5 Q You state that in the second line on your 6 handwritten notes " Region III investigative specialist." 7 Who would that have been? 8 A James E. Foster. 9 Q And you have written next to that "Possible 19 safety concern." This is in the preparation for the meeting, 11 A Yes. 12 as I said, with BSW. They were trying to tell us why 13 they had brought us down so rapidly to Lynchburg to was a rather unique meeting to be called for 14 meet. It 15 all the other utilities to be called for information 16 and to go to a meeting at B6W on something for Davis-17 Besse. Therefore, B6W was telling us why we were there, 18 would be 19 that a Region III investigative special_ist there tomorrow, and he was looking into the possible 20 and therefore, 21 safety concern of pressurizer level, C that's why he had asked for the information, and B6W 22 23 did not feel that was the case, and will present that 21 case the next day. 1908 135 25 MR. YUSPEH: Didn't feel what was the case? BENJAMIN REPORTING S ERVICE
i' ^ 18 Hilbish 1 THE WITNESS: That it was a safety concern. 2 You state this was an unusual meeting where 3 Q at B6W. Was this the 4 all the utilities were present (~ 5 only meeting -- I said was this was an unusual case 6 A No. What for all the utilities to be asked to go to B4W in 7 really a meeting that was between Davis-Besse and the 8 9 NRC. frequently get together with The utilities quite 10 to be called 11 BSW. However, not for a specific -- not 12 on a Region III investigation. So it was unusual that a specific investiga-13 Q operate tion would call a meeting of the utilities that 14 15 BGW plants? 16 A Could you repeat that. It was unusual that for a specific investi-17 Q that 18 C'$ tion of the NRC into a specific incident g would call a meeting of all 19 occurred at one B4W plant operators of BSN plants? 20 for a Region III investigation, From their region, 21 A say, with-k We have gone to the Commission and met, 22 that,,but NRC with all the utilities, or something like 23 For example, SMUD, this was a Region III investigation. 25 This was a Region III 25 TMI are not in Region III. 1908 136 BENJAMIN REPORTING SERVICE
19 liilbish 1 2 investigation. Could you tell me who asked the utilities 3 Q 4 to attend this meeting? Foster asked C Well, it was a little confusing. 5 A in a information, and apparently B6W was not 6 for the and they necessarily position themselves of giving it out 7 didn' t have all the information requested, and was not 8 responding to Region III, in the position of giving it out, 9 for example, for all their other utilities, so we were 10 for the information from B6W, so 11 telecopied a request B6W really asked us to give the information and then we 12 Not all the were invited to attend the meeting. 13 utilities did attend the meeting. 14 kind of operational Could you explain what 15 Q inconvenience results when there is a loss of pressurizer 16 17 level? You goes below zero indicated. 18' A At that time, it don't have an indication of the level in the pressurizer 19 ~~ 20 at that time. is the operational inconvenience if it 21 Q What b. 22 goes high? it going remember talking about 23 A As I said, I don't 24 high. What kind of inconvenience does th 25 Q BENJAMIN REPORTING SERVICE t
\\ 20 Ililbish 1 h n there is a to the operator in the control room w e 2 loss of pressurizer indication level? time which had 3 at that an inconvenience that 4 A Just have an indica-been relatively short-term, he does not ~ ( 5 reactor trip. tion of the actual level following a 6 The actual level of 7 Q Pressurizer. 8 A also mean that he does not have a Does that 9 Q that full measure of the level of the core covering at 10 11 time? The pressurizer level was the only indica-12 A Yes. verage at that tion of or was an indication of core co 13 is the only water level indication. 14 time. That an indication of the IcVel of And is not 15 Q covering in the core? found that may not be 16 I think since March 28th we 17 A_. ~ .n. ~18 the case. Is that what was explained to the operators 19 Q as a result of this meeting on k 20 That a result of this meeting, no. That was not 21 A it, After looking at the case. 22 apparently is not I am not March 28th, which was the TMI 2 incident. 23 referring to the meeting. 23, 21 So after the two incidents at TMI, April 1908 13 25 Q SERVICE REPORTING BENJAMIN i i
1 Hilbish 21 2 1978, and November 7, 1978, and as a result of your 3 attendance at the meeting on February 14th at B4W, it 4 was not explained to the operators that loss of 5 pressurizer indication may not be an indication of the 6 level of core coverage? 7 A No, that was not explained, nor do I believe ts. t 8 was explained at the meeting that I recall. 9 Q Did you write a memo after this February 14th 10 meeting to anyone at Metropolitan Edison concerning that 11 meeting? 12 A No, I did not. 13 Q Did you discuss it with anyone orally'<at 14 Metropolitan Edison? 15 A I believe I did. Since I had called the superin-16 tendent for the information regarding the memo I wrote, 17 I'think I called him back and briefly discussed the 18 results of the meeting, and that I essentially felt the 19 issue was closed, and that we would bF getting a report 20 from Region III summarizing the meeting, and I would send 21 that out. L 22 Q Who was the superin:.endent? 1908 139 ,3 A George Kunder. 24 Q Could you also explain to me, please, what 25 other instrumentation is availabic to the operators in BENJAMIN REPORTING SERVICE
I Hilbish 22 2 the control room that indicates the level of core 3 covering? 4 A I think that both pressure and temperature are (~ ~~ 5 indications. T2 6 Q Could you indicate to me which is a more 7 reliable indication of the icvel of core covering, 8 temperature, pressure, or pressurizer level indication. 9 MR. YUSPEH: I'm sorry, how many choices 10 are there? 11 MS. GOLDFRANK: Three, as Mr. Hilbish has 12 indicated, there are three ways of indicating a 13 level of core covering. One is temperature, 14 one is pressure, and one is the pressurizer level 15 indication,and I would like him to state which he 16 believes is a more reliable indication of core 17 covering. .~ IEf ' A I don't know which is more accurate. 19 Q Do you know how it was explained to the 20 operators in the control room prior to March 28, 1979 21 as to which indication would be more reliabic?. k 22 A I think quite a bit of emphasis was placed on 23 pressurizer level. 4Q 21 Q Could you tell me whether or not after 25 the February 14th meeting at B6W, whether or not you BENJAMIN REPORTING SERVICE
I Hilbish 23 2 informed the Plant Operation Review Committee of that 3 meeting, and the substance of that meeting? 4 A George Kunder is Chairman of the Unit 2 Plant 5 Operation Review Committee. 6 Q Was he chairman on February 14, 1978 or 7 soon thereafter? 8 A Yes. 9 Q Do you 10 A At that time. 11 Q Do you know if the information that was 12 related at this meeting was incorporated into training 13 of operators? It A I do not know. 15 Q Whose responsibility would that have been 16 to convey the substance of this meeting to the training 17 peo'ple at Metropolitan Edison? 18 A It could have been, you know, I think it could 19 have been anybody, I'm.not sure whose hctual responsi-20 bility it was to do that. I certainly could have done 21 it, PORC could hcVe done it. However, the results of k. 22 this meeting, I don't think really changed anything 23 that we have been thinking before this. These were 21 similar conclusions that we had reached in our evaluation 1908 141 25 on the two previous incidents. SENJAMIN R EPO RTIN G SERVICE
1 Hilbish 24 2 Q In late 'all, 1977, did you have any other 3 contacts with anybody at Babcock 6 Wilcox other than 4 your attendance on February 13 and 14 at B6W? ~~ 5 A Did I have any other contacts with B6W? 6 Q Yes. 7 A Yes. 8 Q Could you tell me with whom? 9 A I had quite a few both on-site and in Lynchburg 10 or, other issues. I would have to go back and try to 11 prepare a list or something. 12 Q Could you tell me if you had contact with 13 a Mr. Walters? 14 A Frank Walters? 15 Q Yes. 16 A Yes, concerning physics testing. 17 Q Was this a one-time contact or did you '$avevariouscontactswithhim? 18' l 19 A What was the date you have mentioned? 20 Q From late fall of 1977. 21 A I think that would have been -- I have a hard 22 time remembering, because I know Frank. He was on site 23 for quite a while, I believe, 1976, and I had worked 21 with him both in '76, '77 concerning physics testing 25 in '77 with his new position and prior to that.he'was B ENJ AMIN R EPO RTING SERVICE
- L
1 Hilbish 25 2 on site during our first refueling outage in Unit 1. 3 Q Did you have contact with a Mr. Kelly? 4 A Not that I can remember. 5 Q A Mr. Dunn? 6 A I believe I attended a presentation he was at 7 concerning small break LOCA with the Commission at 8 Bethesda. 9 y Do you remember the date of that? 10 A No, I don't. 11 Q Was that a presentation done by Babcock 4 12 Wilcox? 13 A Yes. 14 Q And were there people from all utilities 15 that had B6W plants? 16 A Yes. 17 Q And you represented Metropolitan Edison at .~. 18' that presentation? ~ 19 A I was one of the representatives of Metropolitan ~~ 20 Edison. 21 Q Do you remember who else was present from b 22 Metropolitan Edison? 23 A No, I don't. I imagine somebody from the licensing 24 group and somebody from GPU. I cannot remember. 25 Q Do you know if there is a memorandum written B ENJAMIN R EPO RTIN G S ERVICE 1908 143
l 1 Hilbish 26 2 by you concerning this presentation? 3 A No, I don't believe there was. 4 Q Did you relay the information that was ~~~ - 5 discussed at that meeting to anybody at Metropolitan 6 Edison? 7 A I am sure I talked about it when I got back. I 8 don't believe our licensing group factored into the 9 technical specification changes which were reviewed by 10 the operators. I did not prepare anything specifically 11 as a result of those meetings. 12 Q Do you remember the substance of Mr. Dunn's 13 presentation concerning the small break LOCA's? 14 A I believe he was one of the many people -- when 15 the issue of small break LOCA first came out for the 16 B4W plants, I believe that is where I met Mr. Dunn in 17 working on that issue. .n. Iff Q You don't remember any more substantively 19 of what his presentation entailed? 20 A Just the results that were incorporated into our 21 technical specifications, and the action that was L 22 required in B6W plants for a small break LOCA, I would 23 say were the conclusions of his presentation. 21 Q Did he provide you with any summary of his 25 presentation? B ENJAMIN REPORTING SERVICE 1908 144
I Hilbish 27 2 A I i:r.a g ine h e d i d, a t least viewgraphs. I do not 3 remember them. 4 MR. YUSPEH: What is the answer to the 5 question? 6 THE WITNESS: I imagine he did. I do not 7 have them with me. 8 Q Do you know if you would have them at 9 Metropolitan Edison? 10 A I am not sure, since I just transferred to a new 11 position in January, and did not bring those kinds of 12 files with me. 13 Q So they would not be in your personal files, 11 if there was any? 15 A That's correct. 16 MS. GOLDFRANK: I would like to request 17 that if those have not already been produced, that 18 we be provided with copies of any type of memoranda 19 or information that was provided at that meeting. 20 MR. YUSPEH: Could you desc~ ribe which 21 meeting we are talking about? 22 MS. GOLDFRANK: A meeting at the NRC and 23 Bethesda concerning Babcock 6 Wilcox presentation 21 by Mr. Dunn on small break LOCA. 25 THE WITNESS: Including Mr. Dunn, I think \\h B ENJAMIN R EPO RTING S ERVICE
I fiilbish 28 2 there were probably fi re or six people from BGN. 3 MP. YUSPEH: Do you know the approximate 4 date? 5 MS. GOLDFRANK: I'm sorry, Mr. Hilbish 6 diiin ' t remember the date of that meeting. It 7 was since late fall 1977. 8 Could we have a brief recess. 9 (There was a five-minute recess.) 10 Q Concerning the presentation at the NRC by 11 B6W on small break LOCA, do you know if anybody else 12 that attended that presentation from Metropolitan 13 Edison prepared a memoranda? 14 A I am not sure. 15 Q You never received a copy of a memoranda 16 prepared by anybody else? 17 A Not that I am aware of. 18 Q Since late fall, 1977, have you had any 19 contact with a Mr. Ray of B6W? 20 A The name does not sound familiar. 21 Q Mr. Taylor? 22 A I believe he would have attended the same meeting, 23 and I believe he was at the meeting we discussed. I 21 know he sent out the memo for the meeting as manager 25 of licensing. Again -- BENJAMIN REPORTING SERVICE
1 Ifilbish 29 2 Q For the February 14th meeting? 3 A Yes. Again, at this time I am sure that I have 4 had some contact with Mr. Taylor. I do not remember 5 specifically which meetings. 6 Q Do you remember, generally, what your 7 contact with him would be about? 8 A Licensing-related issues. 9 Q Do you remember any specific conversations? 10 A No, I don't. 11 Q IIave you had any contacts since late fall 12 1977 with a Mr. Karrasch? 13 A The name is not familiar. 14 Q With Mr. Hallman? 15 A Yes, I have. Again, related to physics testing. 16 Q Was this a one-time contact or various 17 contacts? 18 A Various. 19 Q Do you remember generally what those conver-20 sations concerned? 21 A Physics testing for -- the latest would have been k 22 March, April of 1978, concerning physics testing. 23 Q Would you have made memorandums of those 21 contacts? 1908 147 2a_ A No. PENJAMIN R EPO RTIN G SERVICE
I liilbish 30 2 Q Would they have been telephone conversations 3 or -- 4 A Yes. 5 Q -- or in person? 6 A Telephone conversations. 7 Q And no record would be made of those 8 telephone conversations? 9 A No. 10 Q Have you had contact with a Mr. Kane since 11 late fall of 1977? 12 A Yes. Again, in his licensing position, I am 13 sure he was involved with these meetings. 14 Q Which meetings? 15 A For example, the small break LOCA or this meeting 16 of pressurizer level indication. 17 Q Those are the only two times you spevifically 18 remember? 19 A That I remember, yes. 20 Q Have you had contact with a Mr. Swanson? 21 A Not that I recall. ( 22 Q Do you ha, any knowledge whether any 23 operators at TMI had knowledge of the Davis-Besse-24 transient in September 24, 1977 prior to March 28, 1979? 1908_ 148 25 A No, I don't. BENJAMIN REPORTING S ERVICE
t 1 Hilbish 31 2 Q On your handwritten notes that are marked 3 as Exhibit 3, you have in quotes " Operational 4 inconvenience." Could you tell me who first used th.it c ( 5 term? 6 A No, I can't. 7 Q Had you heard it before attending the 8 February 13, 1979 meeting? I 9 A Not that I can recall. 10 Q Are you familiar with what is called the 11 generic problem? 12 A Not in that aspect, no. 13 Q Are you familiar with what would be labeled 14 a generic problem of a nucicar plant? 15 A Yes. 16 Q What does that mean to you? 17 A One that would affect all of a similar design. 18 Q Would you state that loss of pressurizer 19 indication would be a generic problem on a BSW plant? 20 A Not necessarily. I am not that familiar with 21 the other plants. Some of the other plants had not ,( 22 experienced it before. 23 Q Yet at this February 14, 1979 meeting, there 24 were representatives of at least three other utilities 25 that had B6W plants? 1908 149 BENJAMIN R EPO RTIN G SERVICE
i 32 Hilbish l A Yes. they had a loss of l indicated that That l Q p:essurizer indication? weren't However, there were some that 3 A Yes. experienced they had not l indicated that I That chere. a t four 7 that. If there were representatives of did have a loss of pressurizer IcVel Q 8 utilities that a generic problem? 9 call that indication, would you not 10 Not necessarily. 11 A Could you explain why not? It Q each case. 12 I think you would have to look at the conclusions 13 A However, again, certainly could be. i ce, it was an operational inconven en 14 indicated that indicate that 15 it did not and not a safety concern, and 16 was a generic problem. hat In other words, you explained before t I? it Q occurred in more 18 was something that a generic problem Now, are you 19 type of plant. one plant of the same an operational inconvenience 20 than is not saying that only if it 21 a generic problem? all the other 22 is it it would affect I said that 23 A First So I said it would affect plants, not more than one. And I am sure 21 a generic basis. all the other plants on 908 150 25 SERVICE R EPO RTING 8 ENJ AMIN i
1 Hilbish 33 2 you could have a generic operation inconvenience 3 problem. I am just saying some of the plants had not ? experienced this be fore, and it was concluded that it ( 5 was not a safety concern. 6 Q So you are saying that a generic problem 7 would have to occur at every BGW plant? 8 A Of similar design. 9 Q Not just more than one? 10 A I would say if it happened at one plant or more 11 than one you could have a possible generic problem, but 12 I think it would have to affect more than one to be a 13 generic problem. 14 Q And the fact that the loss of pressurizer 15 level indication occurred at four plants of B6W design, 16 would that indicate to you that this was a generic 17 problem? 18 A Yes, it could. Again, as a result of the 19 conclusions of the meeting, I am not sure it was a 20 problem, as you state. 21 Q Because the conclusion was that it was an k' 22 operational inconvenience? 1908 151 23 A That's true. 2% Q So that once it was concluded it was an 25 operational inconvenience you would not say that is a BENJAMIN R EPO RTIN G S ERVICE
1 Hilbish 34 2 generic problem? 3 A That's true. 4 MR. YUSPEH: That whole line of questioning, 5 I presume, goes to John liilbish's personal under-6 standing of terms like generic. There is no 7 presumption on your part that he necessarily is 8 an expert on generic problems versus other kinds 9 of problems, is that correct? 10 MS. GOLDFRANK: Yes. 11 MR. YUSPEH: You want to see what his 12 personal understanding is. 13 MS. COLDFR.\\NK: Yes, I want him to talk 14 from his personal knowledge and experience. 15 Q Could you explain to me what a licensee 16 event report is? 17 A It is the vehicle to report a reportable occurrence 18 to the NRC. 19 Q Is an operation inconvenience considered a 20 reportable event? 21 A Not necessarily. An operational inconvenience 22 could be very widely d.efined. A specific case was. 23 reported, since there is a specific tech spec on 24 pressurizer level, and if based on failed equipment, 25 we would enter the action statement of the tech fin 38 152-BENJAMIN R EPO RTING S ERVICE
1 Hilbish 35 2 it would be reportable on a licensee event report. 3 Q If a specific tech spec is violated, wheiber 4 or not it is an operational inconvenience, it is then ( 5 reported on an LER? 6 A If it falls into the reporting category of 7 Section 6 of tech specs, yes. 8 Q And who determines whether or not an event 9 is a reportabic event? 10 A The Plant Operation Review Committee. 11 Q Who drafts the LER that the Plant Operation 12 Review Committee then reviews? 13 A Normally one of the members of the Plant Operation 14 Review Committee. 15 Q You are familiar with the Plant Operation 16 Review Committee? 17 A Yes, I am. 18 Q PORC? 19 A Yes. 20 Q Are you presently a member of PORC? 21 A No, I am not. 22 Q Can you tell me when you were a member of 23 p0RC? 21 A Approximately 1974 through the end of 1978 when I 25 was trans ferred. 1908 153 S ENJAMIN R EPO RTIN G SERVICE
1 Hilbish 36 2 Q Therefore, once you became supervisor of 3 licensing, you no longer sat as a member of PORC? 4 A That's correct. 5 Q Could you tell me who determines who are 6 the members of PORC? 7 A The superintendent. 8 MR. YUSPEH: Superintendent of what? 9 A Of the unit. 10 Q There is a PORC for Unit 1 and Unit 2 at 11 Three Mile Island? 12 A Yes. In that same period, I served on both. 13 Q Is that usual that people can serve on 14 both? 15 A Yes, it is. My position, I was reactor engineer 16 for bo th units. 17 Q Could you tell me how many members are 18 there of PORC? 19 A It differs between the units slightly. They 20 are specified in writing. The lists are available. 21 Q Are they required by any Government regula; 22 tion? 23 A Technical specifications, yes. 21 Q And those technical specifications set 25 forth hcs many members there will be? 1908 154 B ENJAMIN REPORTING SERVICE
1 Hilbish 37 2 A Yes. 3 Q Do they also set forth the type of person 4 that will sit on PORC? ( 5 A Yes. 6 Q Could you tell me 7 A As prl.ary members, yes. 8 Q Could you distinguish what you mean by 9 " primary members"? 10 A The quorum must be made up of three primary 11 members, one of which is the chairman or vice-chairman, 12 and/or at least three. The meeting must have five 13 members and no more than two alternates. 14 Q So there are primary members and alternate 15 members? 16 A Yes. 17 Q And there must be at least three primary 18 members at a meeting? 19 A Yes. 20 Q And how many people must be at a meeting? 21 Must you have alternates at a meeting? L 22 A No. 23 Q You must just have three primary members 21 at a meeting? 190.8 155 25 A A quorum consists of five members of which three B ENJAMIN R EPO RTING S ERVICE
i 1 Hilbish 38 2 must be primary as a minimum. 3 Q Who determines who are the alternate 4 members? ( 5 A Again, they are determined in writing by the 6 superintendent. In Unit 2, tech specs requires that l 7 the alternate members i>e designated in writing by the 8 PORC chairman or vice-chairman, t 9 Q Could you tell me the type of person that 10 would sit on PORC as a primary member? 11 A Superintendent of technical support, supervisor 12 of operations, supervisor of maintenance, lead mechanical 13 engineer, Icad nuclear engineer, lead electrical engineer, 14 lead I6C engineer, supervisor of radiation protection,
- 15 and the list is in tech specs.
16 Q You stated that there would be technical 17 people on PORC? 18 A Yes. 19 Q Could you elaborate on that, please? 20 A Most of the positions I just gave. I said the 21 unit superintendent on technical. He serves as a PORC 22 chairman. 23, Q When you served on PORC, were you chairman 21 or vice-chairman at any time between 1974 and 1978? 1908 156 25 A Yes. BENJAMIN R EPO RTIN G SERVICE
t 39 Hilbish 1 2 Q What position did you hold? different i 3 A Both the chairman and vice-chairman at l 4 times. 5 Q Do you remember the dates? 6 A No, I don't. 7 Q How often does the PORC meet? normally meets quite a few times during the 8 A It Written minutes are prepared, which include the 9 week. 10 times for the meetings. 11 Q Does it meet every week? 12 A The requirement in tech specs, I believe, is to meet no longer than on a monthly basis. However, it 13 14 normally meets at least once a week, usually more 15 frequent. 16 Q Could you tell me what the function of PORC 17 is at Metropolitan Edison for Unit 2? 18 A The responsibilities in PORC are to advise the 19 superintendent of the unit of all nuclear 20 safety-related matters. 21 Q~ So that the PORC reports to the superintendent k-22 of the unit? 23 A That's right. 1908 157 21 Q And to fulfill this function, what type of there formal 25 information is directed to PORC; are BENJAMIN REPORTING SERVICE
I liilbish 40 2 channels set up so that information gets to PORC7 3 A Yes. There are both formal and informal. I PORC reviews all the nuclear safety-related procedures, 4 ( 5 procedure change requests, and that would be a formal 6 syst ni where the form is sent to PORC, reviewed. 7 PORC would recommend it for approval. The superintendent 8 would approve it. 9 Q Once PORC recommends approval, is tbc 10 superintendent's approval of that review a rubber stamp 11 or is it more substantive? 12 A More substantive. t 13 Q Are you aware of what type of review he 14 undertakes? 15 A No, not really. 16 Q With respect to the procedure change request 17 that are directed to PORC, what kind of review does PORC 18 undertake? 19 A Pretty detailed review. Normally, the engineer 20 that is responsible for that area would present it to 21 PORC. For example, an electrical procedure would:nced 22 a lead engineer who would present that in that discipline 1908 158 23 to PORC. 24 Q Is it an oral presentation or a written 25 presentation? B ENJAMIN R EPO RTING SERVICE
41 Hilbish 1 The procedure change request would be wri' ten, i 2 A 3 and' depending on it, he would bring that and go over, i it orally. and attend a meeting with the people, present 4 would (~ Ilowever, you know, the procedure change request 5 6 be written out. 7 Q And that procedure change request would be given to the PORC members prior to this lead engineer's 8 i i 9 presentation? 10 A In some cases; in some cases, if it was short 11 enough that it could be passed around or just explained, 12 copies would not be made. llowever, there are cases where copies are made, 13 given out beforehand to all the PORC members that will 14 15 be at the meeting. Would there also be a memorandum explaining 16 Q the reason why these procedure change requests were being 17 18 made? 19 A On the form, there is a space on the procedure A form for the reason for the change. 20 change request specific memorandum is not necessarily generated. 21 What constitutes PORC approval of these 22 Q 23 procedure change requests? 21 A PORC does not approve procedure change requests. 1908 159 25 PORC recommends approval. BENJAMIN R EPO RTIN G SERVICE
4 42 I liilbish 2 Q Recommends approval to the superintendent? 3 A Yes. ? Q And how many members of PORC would be (? A 5 required to recommend approval, or is merely one 6 person enough? 7 A It would be the quorum. 8 Q A quorum is needed to recommend approval? 9 A Yes. 10 Q And do you know what weight the superintendent 11 gives to PORC approval of these change requests? 12 A No. 13 Q Do you know of times when PORC has recommended 14 approval and the superintendent has not accepted that? 15 A He has come back for questions and comments, yes. 16 Q Could you explain the relationship between 17 the PORC for Unit I and the PORC for Unit 2? 18 A The responsibilities are similar. Some of the 19 members do serve on both. However, they are two 20 separate review committees. Does PORC itself ever initiate procedural 21 Q L 22 changes or does it merely review drafts that have been 23 draf ted in other places within the unit? Many times one of the lead engineers 'or in any 24 A 25 of the other disciplines could initiate a change request. 1908 160 BENJAMIN REPORTING SERVICE
43 Hilbish 1 2 and bring that to PORC to present. 3 Q Would PORC, itself, at a meeting initiate i 4 any change request? ~ 5 A It could. Anybody could. G Do you know of any incidents where PORC, 6 Q l 7 itself, has initiated? know of any specific incident. 8 A I do not MS. GOLDFRANK: I would like to have marked 9 as Exhibit 4 minutes of a Unit No. 2 Operations 10 267. Review Committee, Meeting No. 11 (The above-described document was marked 12 Hilbish Exhibit 4 for identification, this date.) 13 14 Q Would you please look at the minutes of 4. 267, which has been marked as Exhibit 15 Meeting No. at a This indicates that J. F. Hilbish was present 16 correct? 17 meeting on May 8th, is that 18 A Yes. at that meeting? 19 Q Do you remember being present 20 A No, I don't. Do you have any reason to believe that you 21 Q indicates that you ( would not have been there since it 22 23 were present? 25 A I have no reason to believe that. 25 Q And there is a (p) besides your name. BENJAMIN R EPO RTING SERVICE
I liilbish 44 2 Does that indica +- that you were a primary member? 3 A Yes. 4 Q And the (v-c) after your name indicates that ( o you were a vice-chairman, is that correct? 6 A Yes. 7 Q As you indicated there always has to be a 8 chairman or vice-chairman present at a PORC meeting? 9 A That is true. 10 Q Could you tell me if the items m i scussed in 11 the last column indicated the items discussed at that 12 meeting generally or are they specifically lined up 13 next to an individual's name that was in charge of 14 discussing that particular item? 15 A Generally. 16 Q If you look at Page 4 of Exhibit 4 under 17 " Reportable Occurrences / Violations" the fourth one 18 down concerns LER 78-33/1P(1T)." 19 It states "PORC has reviewed and concurs 20 with responses being forwarded to the MGQA in regard to 21 LER's 78-33/1P(1T) and 78-34/1P(1T)." 22 Could you tell me what the review of those 23 LER's consisted of? 1908 162-21 A It would have consisted of a review of the wording 25 of the two attachments here in Attachment 8, which B ENJ AMIN R EPO RTING S ERVICE
1 Hilbish 45 2 consists of the two licensee event reports in rough 3 draft. t Q And would that have been the individual who 5 had draf ted this report would have written a presenta-6 tion to the PORC? 7 A Yes. 8 Q Do you know who drafted this report? 9 A Yes, I do. 10 Q Could you tell ne who drafted it? 11 A I did. 12 Q Therefore you gave the presentation to 13 PORC? 11 A Yes. 15 Q Why were you the individual that drafted 16 this particular report? 17 A I was nuclear engineer at the time, and I reviewed 18 the transient, and prepared this write-up for the pre-19 sentation concerning the transient. 20 Q And in the presentation, would other PORC 21 members then ask you questions? 22 A Sure. } 23 Q As to what your conclusions were? 24 A Yes. 25 Q How would you have gathered the information BENJAMIN R EPO RTING S ERVICE
1 Hilbish 46 2 with respect to what was entailed in this report? 3 A From working with the unit superintendent and 4 various people on PORC and GP Service Corporation. 5 Q Do you remember which people in particular 6 you worked with? 7 A No, I don't. 8 Q Would there be any record of that? 9 A No, not that I am aware of. 10 Q You would not personally have kept notes 11 of people you contacted or discussed this with? 12 A No. 13 Q So the only memorialization of this inci-14 dent would be on the Licensee Event Reports in terms 15 of your conclusions? 16 A Yes. On this first one, on 331T, yes. I did 17 not prepare 341T. 18 Q Do you remember what specific questions 19 were asked at your presentation? 20 A No, I don't. 21 Q Would there be any record of those specific 22 questions? 1908 164 ,3 A No. 24 Q So once the PORC has reviewed and concurred 25 with 78-331P, 1T, all they state is the summary statement BENJAMIN REPORTING SERVICE
1 Hilbish 47 l 2 that they have reviewed and concurred, is that correct? 3 A That is correct. 4 Q There is no memorialization of the specific l (' l 5 discussion, of the substantive discussion that was had 6 at that meeting? 7 A That's correct. '3 8 Q If you look at the memo dated May 5, 1978, 9 which is attached to these meetings, signed by 10 Mr. Seelinger, PORC chairman of TMI 2, he states "These 11 are being forwarded in the ' handwritten' state because 12 we feel that these should be forwarded to the NRC as I 13 soon as possible..." 14 Could you explain if this was usual that 15 handwritten LER's were forwarded to the NRC? 16 A No, this was not forwarded to the NRC in handwritten 17 state. The normal vehicle of getting an LER out would 18 be from the PORC chairman to Mr. George Troffer, as 19 stated in this memo. Since all these reports actually 20 go to the NRC through the Licensing Section, and George 21 Troffer -- the Licensing Section does report to 22 Mr. Troffer, so these would have been typed in Reading 23 at the time R.A. Lengel worked in the Licensing Section. 2% He was working on getting it typed and out under our 1908 165 ,a-vice-chairman's signature. BENJAMIN R E PO RTIN G SERVICE
1 Ifilbish 48 2 Q Is it usual for these LER's to be reviewed I 3 in handwritten form? 4 A Yes. This, I believe, was due to the time ( 5 involved. It was quite a lengthy one, and also with 6 the reporter requirements to get this out, it was just l 7 forwarded in the handwritten state. 8 Q But was it usual for these to be forwarded 9 in the handwritten state? 10 A No, it wasn't. < 11 Q Why was this particular one of concern that 12 it was forwarded in handwritten s tate? 13 A Due to the IT behind it, I assume it was a follow-up 14 14-day report, based on the April 23rd transient, and I 15 imagine that May 5th is-pretty close to the 14 days. 16 Q So it was because of the time period? 17 A Yes. 18 Q Not the subject matter of the transient? 19 A No. I am assuming it was due to the time frame. the written follow-up is required to be 20 Prompt report, 21 sent out within 14 days. This transient occurred on ( April 23rd, therefore, I imagine May 5th is close'to the 22 23 i4 days. 1908 166 21 Q Could you explain to me then what the' number 25 78-33/1T stands for, how would that number have been SENJAMIN R EPO R TIN G SERVICE m=
49 I liilbish 2 assigned? 3 A 78 is the year. 33 1s the numerical sequence for LER, and IT is the NRC designation for a prompt 4 5 report follow-up. IP would be the immediate notifica-6 tion. IT is the follow-up of that prompt report which 7 is required within 14 days. 8 Q 33 means that there were 33 LER's filled 9 out prior to this? i 10 A Not necessarily. It means there were 33 numbers l 11 assigned prior to this. 12 Q Could you explain that difference then? On a few occasions after a number is assigned, 13 A 14 it may be determined not to be reportabic. At that 15 time that number is just lef t blank in the records. 16 Q There is an attachment, I believe it is 17 Attachment 11 to meeting minutes of No. 267. It is letter dated May 2, 1978 from Babcock 6 Wilcox to 18 a 19 Gary Miller. Are you familiar with this? 20 A I had seen the memo before, yes. 21 Q In his first sentence he states: "In 22 accordance with your request for the evaluation of 23 specific areas of concern following the subject plant B4W has completed a preliminary review of 21 transient, 1908 167 25 the effects of the supplied data." BENJAMIN R EPO RTING SERVICE
50 liilbish 1 f 7m Is this usual that you would request 2 l transient? BGW an analysis after a plant i 3 Yes, I believe we have asked them for evaluations, 4 A They especially during the starter program, yes. 5 In this case, have people on site with all the date. 6 we asked them to evaluate specific areas. 7 unusual? So this May 2, 1978 request was not 8 Q i 9 A No. Who would have decided which specific areas 10 Q have BSW were of concern to Metropolitan Edison to t 11 analyze those specific areas? 12 imagine the request came from the Superintendent i 13 A I l I 14 of Technical Support. this time? l Which would have been whom at l 15 Q Jim Seelinger. that time? l 16 A Who was also chairman of PORC at 1 17 Q I l 18 A Yes. Do you know why the specific areas were I, 19 Q \\ 20 chosen? g No, I don't. l' 21 A Were you consulted since you were the 22 Q ient? individual that had prepared the LER on this trans 23 I do not recall. l68-21 A recall being consulted by 25 Q You do not SERVICE BENJAMIN REPORTING l
1 Hilbish 51 2 Mr. Seelinger? 3 A That's right. 4 Q Do you know if every transient that occurs, ( 5 that B6W was asked to perform an analysis? 6 A I do not know. 7 Q Who would decide which transients B5W should 8 analyze? 9 A The request would go from the Superintendent 10 of Technical Support or the superintendent. 11 Q So that they would be the particular 12 individuals that would decide whether or not a B4W 13 analysis was appropriate or necessary at that time? 14 A Yes. 15 Q Would Metropolitan Edison do an independent 16 investigation of the specific areas that it asked B6W 17 to analyze? 18 A In certain areas, yes. We did concerning the 19 April 23rd transient. 20 Q Do you know which specific areas you did 21 an independent analysis cT? ( l908 169 22 A No, I don't. 23 Q Would timre be any written records of -- 24 A There is a rather lengthy GPU service company 25 report summarizing the April 23rd transient. B ENJ AMIN R EPO RTIN G SERVICE
I Hilbish 52 Q Do you know who prepared that? 3 A The Safety Analysis Gro'up in GPC. 4 MS. GOLDFRANK: I would like to request ( 5 a copy of that, please, which would be a 6 memorandum prepared by GPU on the April Za, 7 1978 transient prepared by the Safety Analysis 8 Group. 9 Q Did you, in preparing your LER, review the 10 May 2, 1978 analysis from BGW? 11 A Yes, I am sure I did. 12 Q-Did you accept it, the analysis, as a 13 conclusion or did you initiate any further analysis on 14 the part of BGW or Metropolitan Edison? 15 A Not that I am aware of. 16 Q You accepted their analysis? 17 A Yes. 18 Q Did you have any contact with Mr. Rogers 19 of B6W who prepared this report concerning specific 20 questions? 21 A Not that I'can~ recall. 22 Q Would there be any written memorandum of 23 contact that you had with Mr. Rogers concerning this 21 report? 70 25 A Not that I am aware of. B ENJAMIN R EPO RTING S ERVICE
t 1 Hilbish 53 2 MS. GOLDFRANK: I would like to mark as 3 Exhibit 5 minutes from a Unit 2 Operations Review 4 Committee, Meeting No. 275. 5 (The above-described document was marked 6 Hilbish Exhibit 5 for identification, this date.) 7 Q Would you please look at the minutes from 8 Operations Review Committee, Meeting No. 275. The 9 minutes indicate who was present at this meeting, and 10 your name does not appear as attending that meeting. 11 Were you still at work on July 5th, 6th, 12 and 7th, 1978? 13 A Yes, I was. 14 Q Do you remember why you were not at this 15 meeting? 16 A I was on vacation. 17 Q What position were you on the PORC at that 18 time, were you still a primary member? 19 A Yes. 20 Q You were no longer vice-chairman? 21 A Not during this week, no. L 22 Q Since you were on vacation during that 23 week, would they have made another primary member a 21 vice-chairman? 1908 l7I ~ 25 A Yes, they would have. B ENJ AMIN R EPO RTING SERVICE
1 Hilbish 54 2 Q So when you came back after vacation, you 3 would continue to be vice-chairman? 4 A Yes. 5 Q Is that correct? l 6 A Yes. 7 Q to this exhibit indicates a 8 finalized report concerning your reactor trip ES 9 incident at 4/23/78, and it indicates that a copy was 10 sent to you? 11 A Yes. 12 Q Do you remember receiving this copy? 13 A Yes. 14 Q Did you read the finalized report? 15 ' ' A Yes. 16 Q Would you have received a copy of this 17 report because of your position on PORC? 18 A Yes, and as nuclear engineer. 19 Q The other people that are indicated having 20 received copics, were they members of PORC? 21 A Some, not all of them. ( 22 Q The ones that are not members of PORC, why 23 would they have received a copy? 21 A Some are in GPU, some are in our home office in 25 Reading, some are in operations at the Island. I see 1908 172 ~ BENJAMIN REPORTING SERVICE
1 Hilbish 55 2 listed all t'he shift supervisors. And some are in 3 PORC. 4 Q Is it usual that a finalized report of an (~ k 5 incident would be forwarded to these people that are 6 not members of PORC9 7 A Oh, yes. 8 Q Every incident, once there is a finalized 9 report, that report would be forwarded to these 10 individuals? 11 A No, I can't say this is standard distribution; 12 however, I think that it is not uncommon to go to other I 13 members besides PORC. 14 Q Do you know why it was decided that this 15 report should be sent to these particular individuals? 16 A No, I don't. 17 Q Who would have made that decision as to 18 whom it should be distributed to? 19 A I i;nagine Seelinger. 20 Q He, individually,or PORC as a whole? 21 A I don't know. 22 Q When you are present in a PORC meeting, and 23,there has been a finalized report, has there been any 24 discussion as to whom those finalized reports should 25 be sent to? ]908 'l7} B ENJ AMIN R EPO RTING S ERVICE
i I 1 Hilbish 56 2 A I don't recall. 3 Q Would you please look at Page 14 of this 4 report. [ 5 A Yes. 6 Q It indicates " Recommendation / action items" 7 A Yes. 8 Q Do you know if these were reviewed by PORC? 9 A I was not at the meeting. I wouldn't know. 10 Q So you do not know the substance of that 11 review? 12 A No, I wasn't at the meeting. 13 Q Did you, after receiving this repcrt, 14 would you have or did you discuss the report with any-l 15 ' body? 16 A Yes, I am sure I did. 17 Q Do you remember whom? 18 A Members of PORC and GPU. 19 Q Do you remember who specifically? 20 A No, I don't. 21 Q Would there be any written memorialization t. 22 of those conversations? 23,A No. 21 Q Did you write a memorandum as a result of 25 reading this report? 1908 174 B ENJ AMIN R EPO RTIN G S ERVICE
1 Hilbish 57 2 A No. 3 Q Do you know what happened to the specific 4 recommendations contained in this report? ( 5 A (No response.) 6 0 Do you know if they were implemented? 7 A I do remember discussing that item. I am sure 8 it was followed. I am not aware of each and every 9 response. 10 Q If you look at Page 15, number 1 says 11 " Solve relief valve discharge piping expansion joint 12 problems - GPUSC Toole/ Levin prior to startup." 13 Would that be the individual responsible 14 for seeing that particular equipment change? I'5 A Yes. 16 Q Do you know what type of follow-up was 17 done as a result of these recommendations? 18 A I am sure PORC followed it. That one specific 19 item was completed. 20 Q So that PORC would be charged with the 21 responsibility of insuring that~these~particular ^ ( 22 individuals assigned to do that task would fulfill that 2j3 task? ]gG8 }/$ 24 A
- Yes, PORC did; I would say the unit superin-25 tendent was responsible for it, but PORC did follow these BENJAMIN R EPO RTING S ERVICE
I Hilbish 58 2 items. 3 Q So that PORC would report to the unit superintendent as to whether or not these particular i 5 things were impicmented or completed? 6 A Yes. 7 Q If you look at Page 16 under " Training." 8 A Yes. 9 Q Do you know if Mr. Floyd did fulfill 10 these particular requests? 11 A No, I don't. 12 Q How would these particular requests for 13 changes be communicated to Mr. Floyd? 14 A Through this memo. 15 Q He would have received a copy of this memo? 16 A Yes, he did. 17 Q Is that J. R. Floyd? 18 A V s, it is. 19 Q And the date May 10th, is that the date by 20 which he was to have done this? 21 A I assume. 22 Q And do you know what Mr. Floyd's position 23 1908 176 was at that time? 21 A Supervisor of Operations, Unit 2. 25 Q And would his responsibilities have included B ENJAMIN R E PO RTIN G SERVICE
l 1 Hilbish 59 2 training operators? 3 A On shifts as far as in the control room, yes. 4 He is not in the Training Department. (?- 5 Q Would this information have been relayed j 6 to people in the Training Department? 7 A Yes, it was. 8 Q And who in particular on the copy list 9 was in the Training Department that would have received 10 this? 11 A R. W. Zeckman. 12 Q he was the individual at Metropolitan Edison 13 who was in charge of training? 14 A He is on site in training, yes. 15 Q Anyone else on that list? 16 A I am not sure of the date, since some of the 17 positions have changed. 18 Q And why would this particular information 19 under training be sent to Mr. Floyd or assigned to 20 Mr. Floyd as his responsibility of carrying out as 21 opposed to Mr. Zeckman? \\_ 22 A I imagine due to the timeliness to try to get it 23 out, since also a copy of this also went to each shift 21 supervisor so they could do it on shift, instead of 25 getting it as they went through on their training shift, i908 177 BENJAMIN R EPO RTIN G SERVICE
60 I Hilbish 2 in the Training Department, to try to get it to them 3 immediately. even though the primary responsibility 4 Q But this during the operating was given to Floyd to implement -3 6 shift, would you assume that this would be incorporated I also into their training? 8 A Yes, and I think that appears here later on in 9 Item No. 4. 10 Q And you believe that was implemented? 11 A I am not aware of it. aware whether it was implemented? 12 Q You are not 13 A That's correct. Is this the usual channel of communication 14 Q should be in training as to information that 15 to people a memorandum or a finalized 16 communicated to operators that report of an incident would be sent to them with I? 18 recommendations attached? is one way that we had done it, yes. 19 A It in which it 20 Q Could you give me other ways 21 is communicated to them? L the Training Department presenting 22 A The staff at 23 it, The staff of the Training Department pre-21 Q senting new information in their training? )g 25 BENJAMIN R EPO RTING SERVICE
\\ i 61 Hilbish 1 2 A Yes. l for Well, how would information that, 3 Q he formal instance, PORC knew of, be communicated to t 4 t? channel through to the Training Departmen I 5 i copies of procedure changes and They do get are reviewed by PORC in the 6 A change modifications that 7 for training. 8 Training Department So that once PORC has completed its review, 9 Q review, copies { tuu. and the superintendent has accepted Department? 10 i of all changes would go to the Train ng 11 All safety-related changes, yes. \\' operational inconveniences that I' A How about l' Q i 14 cause changes? safety-related, yes, it will go. If it was 15 A Only if it was safety-related? s i l 16 Q is PORC's responsibility. Yes, since that 17 A PORC if there was information that What 18 Q safety related, it was not determined that 19 reviewed that to training, also? information be sent 20 would that lated It could, but PORC only reviews safety-re 21 A 22 procedures and change modifications. Who makes the determination whether or l t 23 Q l s it is safety related? 21 h are As far as the procedures are affected, t ey 25 A S ERVUCE R EPO RTING BENJAMIN 1908 179 I
v 1 Hilbish 62 2 all described in procedures 1001 whether they are 3 safety related or not. 4 Q And who makes that determination pursuant ( 5 to those provisions? 6 A It is determined, the basis of which is a regulation 7 guide, which is determined by PORC long ago, and approved 8 by the superintendent in that administrative procedure. 9 Q Who was the particular individual that would 10 determine whether or not a procedural change request 11 falls within the purview of safety-related items? 12 A The way it is normally done, if it applies to 13 a safety-related procedure, it is considered a safety-14 related change. 15 Q Who would make that decision? IC A It is already listed by procedure in 1001 in the l'7 administrative regulation. It defines which procedures 18 are safety related. 19 Q Could you explain then how exactly it 20 defines which procedures? 21 A By number. Each -- b 22 Q So that if a procedure with a specific 23 number, if a change is requested with respect to that 21 procedure, then it is automatically determined to be 25 safety-related, and then would be sent to PORC, is BENJAMIN REPORTING S ERVICE
I 1 Hilbish 63 f 2 that correct? 3 A Yes. l 4 MS. GOLDFRANK: I would like to mark as 5 Exhibit 6 Operations Review Committee, Unit 2, i 6 Meeting No. 286. 7 (The above-described document was marked 8 Hilbish Exhibit 6 for identification, this date.) 9 Q I would like you to look at what has been 10 marked as Exhibit 6, which is the minutes of Metropolitan i 11 Edison Company, Unit 2 Operations Review Committee, 12 Meeting No. 286. It indicates that you did attcnd 13 this meeting on September 20th, is that correct? 11 A Yes, it does. 15 ' Q As a primary member and as vice-chairman, 16 correct? 17 A Yes. 18 Q If you look at Page 4 of these minutes, 19 you will note the summary statement that "PORC has 20 reviewed the responses being forwarded to MGQA in regard 21 to the subject reports, and this is in reference to 22 LER 78-33/lP(1T)"; correct? 908 181 23 A Yes. 2% Q Do you remember what that review consisted 25 of? BENJAMIN R EPO RTIN G SERVICE
I 64 1 Hilbish 2 A No, I don't. 3 Q Would it have been similar to the other t review of LER's concerning a presentation by the 4 individual who drafted that, questions by the PORC? 3 6 A Yes, it would. Q Could you tell me what MGQA stands for? 7 8 A Manager of Generation Quality Assurance. Q If you look at Attachment 5 to these 9 10 minutes, it seems to indicate that there was a revision 11 to LER 78-33, is that correct? 12 A It indicates that. 13 Q Could you explain to me why there was a 14 revision of this LER? 15' A No, I can't at this time. 16 Q You did not make those revisions? 17 A Not that I recall. Q Would M.B. Bacillia make those provisions? 18 A Probably not. He is the PORC secretary. 19 Q You do not know who make those revisions? 20 21 A No, I don't. And PORC did review and approve and 22 Q that he accept these 23, recommend to the superintendent 't revisions? 908 iM 25 A Yes. BENJAMIN R EPO RTING SERVICE
65 liilbish I revisions are made 2 Q IIow is it usual that 3 to an LER? form There is a block on'the 4 A It can be done. l' 5 for revision number. 6 Q Is it done frequently? 7 A No. l Do you know why in this particular instance i 8 Q it was necessary to have a revision? 9 I would have to go back and find i 10 A No, I don't. I 11 out what was changed. be The reason why it was changed would not 12 Q j incorporated into this attachment? l 13 14 A It does not appear to be. find out why Where could you go back to 15 Q there was a revision of this I.ER? 16 the change was. To Revision 1, and find out what I 17 A would tell you what the change was? 18 Q And that 19 A Yes. also explain why it was necessary 20 Q Would it 21 to have a change? (' Not necessarily. 22 A Would the reason why it was necessary to 23 Q have a revision be incorporated anywhere else? s 21 1908 183 25 A It may. B ENJ AMIN REPORTING SERVICE
I Hilbish 66 2 Q Do you know where else it would be 3 incorporated? 4 A I misunderstood the question. 5 Q You stated that by comparing Revision 1 6 to this revision you could understand what was revised, 7 that it might not necessarily explain why it was 8 necessary to have this revision, and I am trying to 9 ascertain whether or not the reason why it was necessary 10 to have that revision would be incorporated in any other 11 document. 12 A Not that I am aware of. 13 Q There would not be a memorandum prepared 11 by the person who write the revision that would not be 15 attached to these PORC minutes? 16 A Not that I am aware of. 17 Q Is it possible that there would be? 18 A It is possible. 19 MS. GOLDFRANK: Could you please mark as 20 Exhibit 7 minutes of Metropolitan Edison Company, 21 Unit No. 2 Operations Review Committee, Meeting b 22 No. 79-02. 23 (The above-described document was marked 24 Hilbish Exhibit 7 for identification, this date.) 25 Q Could you please look at the minutes of SERVICd 908 184 B ENJAMIN R EPO RTIN G
l 1 Hilbish 67 2 Meeting 79-02 of the Operations Review Committee that 3 has been marked as Exhibit 7. 4 A Yes. (l 5 Q The minutes indicate who was present at 6 this meeting, and you are not listed, is that correct? 7 A That's correct. 8 Q Were you no longer a member of PORC as of 9 January 8, 1979? 10 A From approximately the 1st of January or 2nd on 11 I was working in Reading. My position became effective 12 on the 15th of January, and at the end of this period 13 I was also on vacation. I was not present. I am not 14 sure as of this time, since I was just switching jobs, 15 whether I was listed as a member or not. 16 Q 1 to the minutes concerns 17 LER 78-65/99X, and is report forwarded as indicated by 18 a cover memorandum. You received a copy of this, l9 correct? 20 A Yes. k. 21 Q Do you remember receiving a copy of this? 22 A No. 23 Q Have you ever read this report? 21 A I am familiar with the transient. I do not 908 \\SS 25 recall reading this. B ENJAMIN REPORTING SERVICE
l I Hilbish 68 T4 2 Q Why would you have received a copy of this 3 particular report? 4 A Through either my position as nuclear engineer (~ 5 or supervisor-licensing approximately at the time this 6 was generated. 7 Q Could you explain to me what 99X s tands for? 8 A Yes. Since there was an ES actuation on this 9 that requires a special report by tech specs within 10 90 days, and the 99X which means special report. 11 Q Do you know what kind of a review was e 12 entailed? 13 A I was not at the meeting. 14 Q And you did not have discussions with any-15 body that was at the meeting concerning their review 16 of the LER? 17 A No. 18 Q If you would look at the narrative on the 19 back page of the LER, the last statement says: "None 20 of the events above were reportable as a result of the 21 November 7, 1978 reactor trip transient." 22 Could you explain to me what that means 23 "None of the events were reportable"? i908 186 21 A What it means is that PORC had determined that 25 through this sequence of events presented here, they B ENJAMIN R EPO RTIN G S ERVICE
l 1 Hilbish 69 t 2 determined that none of those items were reportable as 3 a violation of tech specs. However, this report was 4 generated as a general requirement any time there is a 3 safety inj ection ac tuation, a special report, 99X must 6 be sent in. 7 Q Sent in to the NRC? 8 A Yes, and that's what this is. 9 Q Is this the reason why at the February 14, 10 1979 meeting at B5W, that you attended, you indicated 11 that this November 7, 1978 reactor trip transient was 12 reported? 13 A Yes. It is referred to in the fifth paragraph 14 on that page. 15 .Q Did you feel that there was a particular 16 concern as to the incident at Davis-Basse as to why 17 BGW had a meeting on February 14th at its offices 18 concerning the loss of pressurizer indication? 19 A No. However, we did feel, the utilities repre-20 sented did feel that it was somewhat unique to be 21 involved with Region III, I6E Division. 22 Q Did you raise that at the February 13, 1979 23 meeting with B4W? 21 A And 14th, with the Commissioner. 25 Q And what was the explanation given? 1908 187 B ENJ AMIN R EPO RTING S ERVICE
j 1 Hilbish 70 2 A If I recall, the explanation was that the investi-3 gation essentially did not realize -- was not expecting 4 all the utilities to come in from California, Florida, 5 Pennsylvania, to the meeting. They were just request-6 ing information, and as I stated in the BGW memo, thanked 7 the utilities for their cooperation. We gave them the 8 information. They had just requested the information 9 of BGW, and did not realize that B6W would ask the 10 utilities to come to the meeting present themselves. 11 Q So B4W asked you to come to the meeting, so 12 it wasn't your concern or your particular interest that 13 you felt or Metropolitan Edison felt that somebody 14 should be at that meeting? 15 A That we did. We could have -- I did respond 16 prior to the meeting to the memo, that we had 17 referenced. We could have left it there and answered 18 the questions. However, we did feel we should send '19 somebody to the meeting. 20 Q Who made the decision that it was significant 21 enough to send somebody to the meeting? C 22 A I did. 1908 188 23 Q You made that decision? 21 A Yes. 25 MR. YUSPEH: Was this before or af ter the BENJAMIN R EPO RTIN G S ERVICE
I Hilbish 71 2 invitation to go to the meeting? 3 THE WITNESS: No, the first time we had 4 heard about it was with the invitation, please l' 5 answer the questions, send them down to us, and 6 ,the meeting is in three or four days. It happened 7 within a very quick time frame. 8 Q Why did you think it of significant concern 9 to attend the meeting personally? 10 A The other utilities were, and I felt, as long as 11 our data was being used, that we should be there to 12 answer any questions or to help, you know, in any way 13 we could. 14 Q How did you know other utilities were going 15 to attend? 16 A In talking to B5W, and setting up the meeting, 17 they said they were planning to attend. 18 Q So you had spoken with B6W and they informid 19 you that representatives from other utilities would 20 attend? (- 21 A Yes. 22 Q Do you know specifically the difference 23 between the two incidents that occurred at Davis-Besse 21 in 1977? 1908 189 25 A No, I ion't. B ENJAMIN R EPO RTING S ERVIC E
a I Hilbish 72 2 Q You don't know? 3 A No. 4 Q At this time, those are the only questions ( 5 that I have. I would like to say that we will recess and 6 at the moment do not anticipate calling you back for any 7 further questions, but it is possible that at a later date 8 we would want to arrange for further scheduling. 9 MR. YUSPEH: Okay. Could I ask you on the 10 record the requests that you made. You would like 11 two things from us: one is a set of slides or other 12 materials related to a presentation at the Nuclear 13 Regulatory Commission in Bethesda by Babcock 6 14 Wilcox, in which a Mr. Dunn participated on small 15 break LOCA's,_sometime after the fall of 1977. 16 MS. GOLDFRANK: Yes. 17 MR. YUSPEH: And the other is a memorandum 18 that is presumed to be in the files of GPU related 19 to the April 23, 1978 transient prepared by the 20 Safety Analysis Group? 21 MS. GOLDFRANK: Correct. 22 (At 12:15 p.m. the deposition was adjourned.) 23 Subscribed and sworn to 21 before me this day JOHN F. HILBISH 7 i908 190 23 B ENJAMIN REPORTING S ERVICE
'l 1 73 2 ggggg 3 lfITNESS DIRECT CROSS REDIRECT RECROSS 4 John F. Hilbish 2 ( -a 6 7 E[g[gils 8 HILBISH _F_OR IDENTIFICATION PAG _E 9 1 Resume of John F. Hilbish 3 10 2 Memorandum prepared by J. T. Willse, 6 11 Babcock 6 Wilcox, concerning a meeting at Babcock 6 Wilcox in 12 Lynchburg 13 3 Handwritten notes from February 13, 15 1979 meeting by John F. Hilbish 14 4 Minutes of a Unit No. 2 Operations 43 15 Review Committee, Meeting No. 267 16 5 Minutes from a Unit 2 Operations 53 Review Committee, Meeting No. 275 17 6 Minutes of the Operations Review 63 18 Committee, Unit 2, Meeting No. 286 19 7 Minutes of Metropolitan Edison 66 Company, Unit No. 2 Operations 20 Review Committee, Meeting No. 79-02 21 22 000 23 1908 191 2, 25 B ENJ AMIN R EPO RTIN G SERVICE
e .e I 74 2 STATE OF NEW YORK ) ) ss: 3 COUNTY OF NEW YORK ) 'I I, IRWIN H. BENJAMIN, a Certified ( 5 Shorthand Reporter and Notary Public of the 6 State of New York, do hereby certify that the 7 foregoing deposition of JOHN F. HILBISH, was taken 8 before me on the 9th day of July,1979. 9 The said witness was duly sworn before the 10 commencement of his testimony; that the said testi-11 many was taken stenographically by myself and 12 then transcribed. 13 The within transcript is a true record of 11 the said deposition. 15 I am not related by blood or marriage to 16 any of the said parties, nor interested directly 17 or indirectly in the matter in controversy, nor 18 am I in the employ of any of the counsel. 19 IN WITNESS WHEREOF, I have hereunto set my 20 hand this 'l ' day of July, 1979. 21 (,_ 22 . + ~.. ,(-_ I RWIN H. ' NJAMIN, CSR 2' 1908 192 25 l B ENJAMIN R EPORTING SERVICE
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