ML19289G285
| ML19289G285 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/05/1979 |
| From: | Stevens H BABCOCK & WILCOX CO., PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 7908160366 | |
| Download: ML19289G285 (50) | |
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________________________________________X P RE S IDE NT ' S COMMISSION ON THE ACCIDENT AT THREE MILE ISLAND
________________________________________x DEPOSITION of PABCOCK & WILCOX by HOWARD HARTMAN STEVENS, held at the offices of Babcock & Wilcox, Old Forest Road, Lynchburg, Virginia 24505, on the 5th day of July, 1979, commencing at 7:20 p.m.,
before Stanley Rudbarg, Certified Shorthand Reporter and Notary Public of the State of New York.
BENJAMIN REPORTING SERVICE l
]f CERTIFIED SHORTHAND REPORTERS l
FIVE BEEKMAN STREET r
NEW YORK.NEW YORK 10038
[212] 374-1138 79 0 816 03CI
1 2
2 3
g;3_gAgCggg_s_yIggg3:
4 MORGAN, LEWIS & BOCKIUS, ESQS.
Attorneys for Babcock & Wilcox 1800 M Street, N.W.
5 Washington, D.C.
20038 BY:
GEORGE L.
EDGAR, ESQ.
of Counsel t
-and-8 BYRON NELSON, ESQ.
9 House Counsel 10 11 ggR_THE_CgMMISSION-1 *"
WINTHROP A.
ROCKWELL, ESQ.
Associate Chief Counsel 13 14 A_ L_ _S O_ P RE_ S E NT :
RONALD M.
EYTCHISON 16 1~
0 18 19 20 21 C-nn 1892 176
~~
23 24 25 BENJAMIN R EPO RTIN G S ERVICE
1 2
3 3
(Resume of Howard 3artman Stevens was 4
marked Stevens Deposition Exhibit 70 for identificction, this date.)
.o H OW ARD HA RT MA N S T E V E N S,
having been duly sworn by Winthrop A.
- Rockwell, 7
Esq., was called as a witness and testified as 8
follows:
9 DIRECT EXAMINATION 10 BY MR. ROCKWELL:
11 Q
Woulu you state your full name, please?
12 A
Howard Hartman Stevens.
13 g
Mr. Stevens, would you state your current business address?
A Babcock & Wilcox, P.
O.
Box 1260, Lynchburg, Virginia.
16 Q
And your current employer?
17 A
Babcock & Wilcox Company.
18 Q
What is your current position with B&W7 19 A
I am a regional business manager in the Nuclear 20 Parts Center at B&W.
31 Q
Mr. Stevens, have you brought with you s-today a resume which we have marked as Stevens Deposition Exhibit No. 707 A
Yes, I have.
Q Did you prepare that?
25 B ENJAMIN R EPO RTIN G SERVICE
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Stevens 4
3 A
Yes, I did.
4 Q
Is it current and complete and accurate to the best of your knowledge?
o A
Yes.
6 Q
Mr. Stevens, were you involved in the design 7
of a control room -- I used the word " package" for lack 8
of a better term, and you may want to refine that in 9
approximately 19687 10 x
- yes, 11 Q
Can you describe for me what the process 12 was within Babcock & Wilcox which led to this control 13 m design in 1968?
r A
Yes, I believe I can describe it in general terms.
15 Q
Please do.
16 A
In approximately February 1968 Burns & Roe and 17 Jersey Central met for the first time, at least as 18 far as we here in B&W are aware, to discuss the 19 general control room arrangement for Three !!ile Island 2.
20 B&W had sold the Three Mile Island 2 plant gi essentially as a duplicate of Three Mile Island 1 in U_.-
1967, and on Three Mile Island 1 B&W had no responsi-bility to furnish control room equipment.
As far as cabinets were concerned, as far as 24
. consoles were concerned, as far as panels were concerned, 2
1892 178 BENJAMIN REPORTING S ERVICE,
1 2
Stevens 5
3 our primary responsibility was to furnish equipment 4
that was mounted on equipment to be furnished by Three Mile Island.
We therefore assumed that our
.a scope of supply would be the same on Three Mile Island No.
2.
7 However, in March of 1968 we received from 8
Burns & Roe a drawing which defined the arrangement 9
of the control room for Thres Mile Island 2,
and in 10 that arrangement was included the definition that B&W 11 would be responsible for supplying the consoles which 13 they at that time designated as No.
4, which was the rea t re nsole, and a vertical panel, which they 13 designated as No. 14, on which control-rod and in-core monitoring information was to be displayed.
15 They also indicated that we would be potentially 16 responsible for furnishing what they identified as 17 Control Console No.
3, on which all of the auxilliary 18 systems were to be mounted.
19 Subsequent to the determination of the responsi-20 bility in this document, in October of 1968, Burns &
Roe transmitted to B&W the specifications for the g}
equipment to be provided in this control room by B&W.
In approximately April of 1969 excuse me.
May I a
1892 179 Q
Sure.
25 BENJAMIN REPORTING S ERVICE
1 2
Stevens 6
3 MR. EDGAR:
Off the record.
4 (There was discussion off the record.)
A In November 1968, B&W transmitted to Burns & Roe
.a their drawings which represented the arrangement of the simulator which B&W was planning to build at that 7
time, and which B&W had been working very closely 8
with Bechtel and Sacramento Municipal Utilities on 9
the arrangement for.
This simulator design did not 10 exactly match the specification and the requirements 11 of Burns & Roe in that it contained many pieces of 12 equipment which one might call miniature or reduced; s
that the size of the console and C.e panel board 13 and the total control room arrangement for the simulator was smaller than that envisioned by Burns & Roe for 15 Three Mile Island No.
2.
16 The thing which made it different was primarily 17 the switchings and other equipment mounted on the 10 consoles, which were specified to be different on 19 Three Mile Island, and whose panel board space required 20 a larger arrangement.
31 But we sent the simulator drawing to Burns & Roe, s_
saying that they were primarily for their information, for whatever use they could make in the process of laying out the consoles for which Burns & Roe had g97 180 24 I
responsibility.
e -
25 B ENJAMIN R EPO RTIN G SERVICE
1 2
Stevens 7
sr/ew 3
In December of 1968 B&W went one step further
- 2 with regard to the simulator layouts and actually 4
r e co mmend ed to Burns & Roe that they use the simulator a
layouts for the Three Mile Island station becauce 6
there was a very definite advantage to Jersey Central 7
in doing so, that advantage being specifically the 8
ability to train the operators on the simulator in 9
Lynchburg with the same basic control room arrange-10 ment and layout that would exist at Three Mile Island.
11 At the same time we also raid that using the 12 equipment that had been specified, the console space for the B3W equipment would be 13 feet 7 inches, that is Console No.
4, and that the panel board would be approximately 4 feet 11 inches.
15 In April of 1969 Burns & Roe submitted to B&W 16 their designs for Consoles 3 and 4 and stated that it 17 appeared to them that these two consoles were very 18 closely linked together functionally, and that they 19 would like to entertain the idea of adding Console 3 20 to B&W's scope of supply.
(Continued on following page.)
31 22 23 24 25 1892 181 BENJAMIN R EPO RTING S ERVICE
I 2
Stevens 8
- 3 3
A (Continuing)
And at this point B&W was invited rs/ew 4
to bid on Console No. 3 as well as the ones which were already designated to be in our scope of supply.
O They also stated at that time, the drawings which they gave us of Consoles 3 and 4 incorporated 7
the concepts which we submitted to them -- excuse me, 8
bat may I strike that last sentence.
9 Q
You cannot strike it from the record, but 10 you can indicate what you want to revise, 11 A
I'd like to say that at this point that is all 12 that they gave us in April of that year.
13 In May f 1969 B&W provided Burns & Roe with a layout sketch of Consoles 3 and 4 because Burns & Roe had asked us to combine these two together in a single functional design.
This was submitted as a sketch, 16 and again was designated in our mind as preliminary 17 primarily for the information of Burns & Roe to aid 18 them in the layout of the console.
19 In August of 1969 Burns & Roe then sent us their 20 preliminary console layout for Panels 3 and 4 and told us that they incorporated at least the concepts which 31 s-we had given them in May of 1969.
There were differ-ences between th B&W drawings that had been submitted in May and the final -- excuse me the preliminary 24 arrangement that Burns & Roe gave-us in August of that 25 BENJAMIN R EPO RTING S ERVICE i892 182
1 2
Stevens 9
3 year.
These were due primarily to the fact that Burns 4
& Roe, who were the final decision making authority a
on control room layout, had elected to make a somewhat 6
different arrangement than B&W had given them.
7 However, the changes that they made were at all times 8
acceptable to B&W and at no point did B&W find any 9
major faults or flaws in the arrangements that Burns 10
& Roe had sent us.
11 We made subsequently some comments which were minor in nature.
We did not make any major comments 13 on the layout or the concept of that layout, and as a result approximately one year later in August of 1970 14 B&W submitted to Burns & Roe the design of Consoles 3 15 and 4 along with drawings and specifications for these 16 panels which were going to be used for manufacture of I
the panels.
18 It would be safe to say that ct this point the 19 b asic concept of the control room layout had reached 20 the point where it was ready to go to a vendor for bids, and that all final decisions on the arrangement 3
at that point in time had been made by Burns & Roe, 22 and that B&W concurred that this arrangement was 23 functionally acceptable, was operable, and could be 24 incorporated into the control room in an acceptable 1892 18,5 23 BENJAMIN R EPO RTIN G SERVICE
1 2
Stevens 10 3
fashion.
In 1970, the design of the control room essen-4 tially went into a hiatus and subsequent to 1970 very lit ~le was done until 1972 at which point Burns & Roe 6
incorporated some modifications into the consoles 7
which basically consisted of equipment that was within 8
their scope of supply which they wanted incorporated 9
into B&W's scope of supply; that is, the panels 10 supplied, the consoles supplied by B&W.
11 MR. ROCKWELL:
Off the record.
12 (Discussion held off the record.)
Q We have now brought the chronology up to 1972, Mr. Stevens.
14 Do you stop at that point because then you 15 went on to something else?
16 A
Yes.
In actual fact, the changes that were 17 made in 1972 were made at the time when I had already 18 transferred to BBR in Germany and the details of those 19 changes and the reasons behind those changes are 20 unknown to me at this time.
gy Q
So what you have done, in giving us the chronology that you have just finished, is to take the s
matter of the TMI 2 control room from the time you 23 first became aware of it up through your departure 24 from the scene?
BENJAMIN R EPO RTIN G SERVICE
1 o
Stevens 11 3
A That is correct.
4 Q
Could you tell me who the principal actors were at Burns & Roe with Khom you had dealings during a
this period of time in relation to the issues that we 6
have been discussing, namely control room design.
7 MR. EDGAR:
Off the record.
8 (Discussion held off the record.)
9 A
Throughout the time when the layout of the 10 consoles from B&W's point of view was within my respon-11 sibility we dealt with one man at Burns & Roe whose 13 name for the moment escapes me.
I will get that name for you at the conclusion of this session.
q.
Q Do you recall what his position was with Burns & Roe?
15 A
He was an instrumentation and control engineer 16 responsible for many facets of the instrumentation and 17 control for the plant, the layout of the console was 18 only one of many things which he did at Burns & Roe 19 in the way of control room layout.
20 Q
Did he have a particular title or was he known as an instrumentation and control engineer?
31 A
At this point I do not recall his official title.
Q Where was he based?
Was it in Oradell?
23 A
It was in New Jersey at Burns 24 Q
I believe that Oradell, New Jersey is the 1892 185 25 BENJAMIN R EPO RTING S ERVICE
1 2
Stevens 12 3
headquarters of Burns & Roe.
Does that sound right to 4
you as to where he would have been?
A' I believe that is correct.
3 MR. EDGAR:
That would be Oradell, New 6
Jersey?
7 A
Is that it?
8 Q
Yes.
9 7
Yes.
10 g
Did you review,Mr. Stevens, in preparing 11 the chronology, this new sequence of events that we 12 now have, any documents in order to reflect the times and specifics that you have given to us?
13 A
I reviewed some documents, but by no means did I go to the files and search diligently through the files 15 for specific documents.
The documents which I 16 reviewed were those related to the chronological events 17 which I have given here.
18 MR. ROCKWELL:
Off the record.
19 (Discussion held off the record.)
20 (Documents described below herein marked, gy respectively, Stevens Deposition Exh.. bits 71 through 85 for identification, this date.)
Q Mr. Stevens, you now have before you 23 Stevens Deposition Exhibits 71 to 85.
24 Do I understand correctly that in preparing 25 i892 186 S ENJ AMIN R EPO RTING SERVICE
1 2
~
Stevens 13 3
the chronology which you gave at the beginning of your 4
deposition you had reference to all of these Exhibits and you reviewed them in preparing that chronology?
o A
I referred to all of these documents with the 6
exception of the " Standard Guide Specification,"
7 Exhibit 71, which I did not refer to in the earlier 8
statements, but which I did assemble during the period 9
of time when I was reviewing the panel board design 10 issue.
11 g
could we go now through each Exhibit, and 12 I will ask you to do this because you are most familiar wtih these documents, and please give the Exhibit 13 number and then give the information necessary to identify it specifically, and let us start with Stevens 15 Deposition Exhibit 71 Would you please ide r.ti f y it.
16 A
Exhibit 71 is the B&W Standard Guide Specification 17 for Control Room Design Criteria.
18 This document was developed during the course of 19 our work with Bechtel and Sacramento Municipal Utilities 20 District, to develop the simulator and the Rancho Seco control room design arrangement of consoles, panels and 31 control room.
n_n Q
Should we give the date or some of the 23 numbers on this document to distinguish it from other 24 versions of it that may exist?
1892 87
.o SENJAMIN REPORTING SERVICE
1 o
Stevens 14 3
A This particular document is dated December 20, 4
1968.
It represents the culmination of the work that was done through 1968 in the development of that 5
control room design.
- 4 Q
Please proceed to Stevens Deposition 7
Exhibit 72.
Would you please identify it.
8 A
This is a drawing submittal form from Babcock &
9 Wilcox to Burns & Roe, dated November 7, 1968, and was 10 used to transmit the drawings for B&W's simulator with 11 a note that this inforntion was developed in connec-12 tion with our simulator and they are furnished for Burns & Roe's information only, to be used in the 13 design of the TMI 2 control room.
Q Am I correct that this transmittal which you are referring to as Stevens Deposition Exhibit 72 16 transmits nine drawings?
17 A
Yes, there are nine drawings.
18 Q
Are the nine drawings the drawings that 19 have been marked Stevens Deposition Exhibits 73 t'. rough 20 817 21 A
Yes.
Q Can you describe generally to me without g
going through each of the nine drawings that were transmitted what they deal with.
24 A
Yes, these drawings represent the console and 25 1892 188 B ENJAMIN R EPO RTIN G SERVICE
1 2
Stevens 15 3
panel arrangements along with the control room arrange-4 ment for the PWR simulator to be built in Lynchburg,
.3 On each drawing is a numbered arrangement of components on the face of the consoles and panels and 7
a listing of what each of the numbers represents.
8 Q
I take it each drawing deals with a 9
different panel of the control room?
10 A
Correct.
Each drawing represents a different 11 segment of the panel, and they are on the plan of the 12 control room arrangement.
13 Q
Referring now to Stevens Deposition Exhibit 73, is that drawing No.
136027?
A Yes.
15 Q
What portion of the control panel does it 16 cover?
17 A
It covers the right center of the control console 18 which handles condensate feedwater and turbine 19 generator operation.
20 Q
Referring you to Stevens Deposition Exhibit gy 74, is that drawing No. 136025?
A Yes.
s..
~~
Q What portion of the control room does it 23 cover?
24 A
It covers the left center of the control console 25 1892 189 BENJAMIN R EPO RTING S ERVICE
1 2
Stevens 16 3
on which the coolant system is operated.
4 Q
Referring you to Stevens Deposition Exhibit 75, is that drawing No. 1360247 0
A Yes.
6 Q
What portion of the control room does it 7
cover?
8 A
That is the right rear panel No. 3 on which the 9
electrical switching equipment is mounted.
10 Q
Referring you now to Stevens Deposition 11 Exhibit 76, is that drawing No. 136023?
13 A
Yes.
0 What section of the control room does that 13 cover?
14 A
That covers the right rear panel No. 2 on which 15 the plant cooling water equipment is operated.
16 Q
Referring you now to Stevens Deposition 17 Exhibit 77, is that drawing No. 136022?
18 A
Yes.
19 Q
Tell me what portion of the control room 20 that covers?
A This is the right rear panel No. 1 on which the gy turbine generator equipment is mounted.
Q Referring you now to Stevens Deposition 23 Exhibit 78, is that drawing No. 136021?
24
^
'e=-
)00,7 190 o
23 BENJAMIN R EPO RTING SERVICE
1 o
Stevens 17 3
Q What portion of the control room does that 4
cover?
A That covers the center rear section of the
.a console on which the reactor and ICS auxilliary is 6
mounted.
7 Q
Referring you now to Stevens Deposition 8
Exhibit 79, is that drawing No.
1360207 9
A Yes.
10 Q
What portion of the control room does that 11 portray?
12 A
That is the left rear panel No. 2 on which the engineered safeguard equipment is 1 cated.
13 Q
Referring you now to Stevens Deposition Exhibit 80, is that 136019?
15 A
Yes.
16 Q
What portion of the control room does this 17 drawing apply to?
18 A
That is the left rear panel No. 1 on which the 19 plant aux 1111 aries are located.
20 Q
Finally, referring you to Stevens Deposition Exhibit 81, is that drawing No. 136026?
gy A
Yes.
s Q
What portion of the control room does that 23 refer to?,
24 A
That refers to the central console on which the 25 1892 19i BENJAMIN R EPO RTING SERVICE
1 2
Stevens 18 3
reactor and integrated control system equipment are mounted.
4 Q
Referring you to Stevens Deposition Exhibit a
82, can you identify that Exhibit?
6 A
Yes, that is a letter addressed to Burns & Roe 7
from Babcock & Wilcox, dated December 13, 1968 in 8
which B&W comments on the specifications for the panel 9
boards which were sent to B&W by Burns & Roe on 10 October 30, 1968, and in which B&W identifies that its 11 console No. 4 will be approximately 13 feet 7 inches 12 in width, and its rear panel is 4 feet 11 inches in w i d t h.,
and recommends that the B&W simulator drawings 3
be used as the basis for the TMI control room arrange-ment because of the advantages accruing from simulator 15 training on similar equipment.
16 Q
Referring you now to Stevens Deposition 17 Exhibit 83, is that drawing No. 307557 18 A
Yes.
19 Q
What does that refer to?
20 A That refers to the auxilliary systems control gy panel No. 3 as B&W 1 aid it out in 1972.
Q Referring you now to Stevens Deposition s,
Exhibit 84, is that drawing No. 30756?
23 A
Yes.
1 y / )-
O) 00 1
o4
/-
Q What does that refer to?
25 BENJAMIN R EPO RTING S ERVICE
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Stevens 18-a 3
A That is the layout of the plant control panel 4
No. 4 as B&W 1 aid it out in 1972.
Q And lastly, referring you to Stevens
.a Deposition Exhibit 85, could you please identify that Exhibit.
7 A
This is a letter from Babcock & Wilcox to Burns 8
& Roe, dated August 5, 1970 in which comments on the 9
control console layout are transmitted.
10 (continued on following page.)
11 12 13 14 15 16 17 18 19 20 21
~
.n.o.
23 24 1892 193 25 BENJAMIN R EPO RTING SERVICE
RZ 5 le 1
0 2
Stevens 19 3
Q Mr. stevens, can you tell me what if any 4
role was played by Metropolitan Edison in the history 5
and dealings that you described at the beginning of this deposition?
6 A
B&W's interface relative to the design of the i
control room and the consoles for which B&W had respon-8 sibility was with Burns & Roe.
Burns & Roe, in turn, 9
interfaced with Jersey Central and/or Metropolitan 10 Edison, GPU in general and I therefore have no 11 knowledge of the role that either Jersey Central or 12 Metropolitan Edison played in the design of this con-13 trol room since they did not take an active part at the interface that we had with Burns & Roe.
14 Q
Did you know who at Metropoliten Edison la.
or Jersey Central was making decisions or contributing 16 in the area of control room design?
17 A
No.
18 Q
Is it a fair statement to say that the 19 final product for the final design in the TMI 2 con-20 trol room was a product of the input both of Burns 21
& Roe and of Babcock & Wilcox?
/
A Yes.
The final arrangement of the control room n
was the product of inputs from both Babcock & Wilcox and Burns & Roe, but the final decision-making process 24 in every case rested with Burns & Roe, who had that 25 i892 194 BENJAMIN R EPO RTIN G S ERVICE
1 2
Stevens 20 3
responsibility.
4 Q
Is it your opinion that Burns & Roe was 5
elear about the fact that they were making final 6
decisi ns?
A Yes, and they so stated in a letter to B&W 7
in April of 1969.
Q Is that one of the letters that we have 9
before us?
10 A
I believe not.
11 Q
Do you have a copy of that letter?
12 A
I do not have it here in this room.
13 Q
Do you have it available to you where you 14 can find it?
A Yes.
yg MR. ROCKWELL:
May we please have a copy of that.
17 MR. EDGAR:
We will produce it.
18 Q
Mr. Stevens, do you recall who wrote the 19 letter and to whom it was addressed?
20 A
No.
Normally, letters between Burns & Roe and 21 B&W were addressed from the project manager at Burns gg
& Roe to the project manager at B&W.
I assume this N'
letter, therefore, followed this same pattern.
g Q
You were the project manager at B&W?
A No.
The project manager to which I refer was 1092 195 BENJAMIN R EPO RTING SERVICE
1 o'
Stevens 21 3
the project manager for the TMI project totally.
4 Q
You were the project manager for the 5
control room design, is that correct?
A My role at TMI 2 was the manager of Instrumentation 6
and Control Section, responsible for all instrumentation 7
and control systems, which included the design cf 8
the control room a= one of many responsibilities.
9 Q
Were you involved at all in a decision 10 to change the window in the pressurirer water level 11 indicator to narrow the window from what it previously 12 had been?
Are you familiar with at at all?
13 A
If you can continue with the question, I say be able to answer it in more detail.
34 Q
It is my understanding that at some point 15 the range of level in inches shown on the water 16 pressurirer level indicator in the control room was 17 narrowed to some extent and that that change was 18 then incorporated from that point forward in all 19 B&W designs.
20 Are you familiar with that change at all?
21 A
I was responsible for the instrumentation and control systems throughout the entire period wher. we 33 were developing the instrumentation for the steam g
generator.
We modified the instrumentation on the steam generator several times before the fina BENJAMIN R EPO RTING SERVICE
1 o
Stevens 22 3
arrangements were selected.
4 Q
You realize I am referring to the 5
pressurizer?
A Oh.
I am sorry.
I am answering the wrong 6
question.
t The same thing is true of the pressurizer.
8 The pressurizer instrumentation was modified on a 9
number of occasions as we were developing the con-10 ceptual design, which began in approximately 1965 11 or 1964.
I do not, however, recall specifically the 12 details of the change to which you are referring, 13 which is the r. arrowing of the window.
In the design of the pressurizer, there are g
basically two factors which must be considered.
MR. EDGAR:
Off the record.
16 (Discussion held off the record.)
17 A
(Continuing.)
Earlier you had asked for the 18 name of the Burns & Roa representative with whom we 19 dealt on'the control room arrangement.
I have since 20 obtained the name.
It is Charlie Gotilla.
3}
Q Did the NRC, during the time period that we have been discussing, which is approximately 1968 39 to 1972, have any standard of criteria which were applicable to control room design?
24 1292 197
^
23 BENJAMIN R EPO RTING SERVICE
1 2
stevens 23 3
g Were there any standards that you were 4
required to meet other than those standards which 5
your respective organizations set forth, i.e.,
Burns
& Roe, Babcock & Wilcox, and possibly Metropolitan 6
F Edison?
.t A
Before I answer this question, I would like 8
to clarify the answer to the previous question in 9
the sense, no, with regard to arrangements.
There 10 were many criteria that the NRC applied to control 11 rooms, for example, in the area cf ventilation and 12 isolation and the ability of the operator to continue 13 operation in a radiation environment in the plant itself.
14 -
Q I am talking more about layout.
la.
A No criteria regarding the layout of the control 16 room from the NRC.
17 With that clsrification, could you repeat the 18 last question.
19 (Record read.)
20 A
No.
21 Q
Referring to the period, 1968 to 1972,
.4/
was there a standard design in the industry for panels n3 or control rooms?
n 19o?
198 V/-
A No.
24 Q
Who selects the light color logic in the 25 BENJAMIN R EPO RTING SERVICE
1 o
Stevens 24
~
3 design that was finally used at TMI 27 4
A The architect-engineer, Burns & Roe.
5 Q
Do you understand the basis or rationale f r the light color logic that was selected by them?
6 A
Yes, I do.
7 Q
Could you explain it.
A The logic behind their arrangement was that 9
all things which were considered either c.
or open 10 would be colored reds all things which were off or 11 closed would be colored green.
The operator could 12 therefore determine by looking at the console, when 13 he saw it red, it was on or open, and when it was
}4 green, it was off or closed.
This particular standard is not followed by 15 all utilities, but it is one standard which is 16 commonly used throughout the industry and was not in 17 disagreement with the criteria that was set by B&W 18 for its own rimulator in Lynchburg.
19 (Continued on Page 25.)
20 21 s-
.n.o.
23 24
'Og toQ7 ie n-a iu,_
BENJAMIN R EPO RTING S ERVICE
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Stevens 25 rz, 6.1 3
Q Just so I get it straight, green is off 4
or closed?
A Yes.
5 Q
To some extent, the selection of those colors for those indications might be considered to be contrary to normal human experience in the use of 8
colors red or green for such simple things as traffic 9
lights, for instance?
Do you ha'.e an; reaction to that?
10 A
Yes, I have a personal reaction to that.
Il Q
What is it?
12 A
There is no question in my mind but that consis-13 tency is a thing which an operator needs to do his job best.
It makes no difference whether that consisteney consists of a set of criteria set up, like red and l a, green for traffic lights, green meaning go and red 16 meaning stop, or whether red means on and open and 17 green means off and stop.
The important thing is 18 consistency, so that when the operator is presented 19 with an operational situation he can look at the board 20 end say the consistency that I see here is consistent 21 with my understanding of what red and green mean.
As Q
How about his consistency of how he inter-prets red and green at work and how he interprets red and green away from work?
24 A
I find no conflict in that situation at all.
25 1907
? [J tuem m
BENJAMIN R EPO RTING SERVICE
1 2
Stevens 26 6.2 3
The human body adapts to his environment and the situa-tion he finds himself in.
When he spends eight hours 4
each working day working in an environment where red
,a means one thing and green means another thing in the 6
work environment, this should not be for him a signi-7 ficant operating problem.
8 Q
The design of the simulator which you 9
described in your initial narrative, you indicated 10 that that was the product of the collaborative efforts 11 of Babcock & Wilcox, Bechtel and Sacramento Municipal Utilities District, which is a utility, is it not?
17 A
Yes.
Q And Bechtel is an architect-engineer?
14 A
Yes.
15 Q
In that design process were any outside 16 experts brought in, in the area of what is known as II human engineering or man-machine interface?
18 A
No.
19 Q
Was there any consultation during that 20 design effort with people who had worked or had experi-ence with the design of control panels in the aircraft g
industry?
A To the best of my knowledge, no; certainly with 23 B&W the answer is no, and I do not recall that those 24 on the team of Bechtel and Sacramento Municipal 25 1892 201 B ENJ AMIN R EPO RTING SERVICE
1 o
Stevens 27 3
Utilities District were familiar with aircraft industry 4
practices, but it is possible.
f Q
Was there any consultation with people
.a familiar with control panel design or cockpit design in the space industry?
7 A
No, with the same qualifications that I have just 8
given.
9 Q
As one who has been involved in control 10 room design, do you think that it would be useful to 11 see what lessons might be learned by consultation with 12 people having experience in aerospace cockpit control 13 P""*1 d**19"?
A I will answer the question as engineers typically answer questions by saying you can always learn some-15 thing from somebody if there is something you are not 16 doing or they are involved in something that you are not 17 involved in, but it is my opinion that it is extremely 18 difficult to adapt aircraft and space technology to 19 the utility industry particularly with regard to 20 layout and size of equipment because the aircraft and 31 space industry are forced to concentrate all the infor-mation in front of a seated operator who never stands, m.
who sits for a finite period of time whereas the 23 operators in a power plant are at their seats eight 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, are free to move about, and the equipment must 25 1392 202 B ENJ AMIN R EPO RTIN G SERVICE
1 2
Stevens 28 3
be maintained periodically and they must have access 4
and, therefore, the compression of instrumentation and
/
control equipment into a very small space is not
.a forced upon the utilities and, therefore, I believe it would be unwise to do so.
The one thing which the 7
industry, the aircraft industry, I think, can contribute 8
to power plant control room design would be the 9
conventions for direction of motion of equipment such 10 increase is up or to the right or forward and as 11 decrease is to the left, backward or down.
This type 12 of convention, I think, can very well be carried in 13 the power plant because it lends itself to logical human responses to emergency situations.
Q The views you have just expressed would not limit the value of what could be learned with 16 respect to information display, would it, and the 17 technique for information display and presentation?
18 A
The display of information to the operator even 19 in the aircraft industry changes periodically.
For a 20 long period of time the aircraft industry dealt with ol meters which rotated clockwise and counterclockwise.
's There was then a long period of time in which vertical motion meters or thermometer-type instruments became quite popular, and there is today a trend away from 24 that kind of instrumentation back to the things which 1OG7_
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1 2
Stevens 29 3
go clockwise and counterclockwise because in many 4
cases they do not get the kind of response from the operating crews that the designers intended.
a Therefore, it is not always possible to draw the conclusion because the space or the aircraft industry 7
does it, that it is always right and correct and, 8
therefore, immediately adaptable to the power industry 9
which 1.
concerned with equipment which must last for 10 many more years than the design of aircraft equipment.
11 Q
I don't think my question suggested that 12 what the aircraft or aerospace industry does is 13 always right.
The question is, rather, the concerns you expressed about sizing do not limit your ability to examine usefully the A
No.
16 the types of information display and Q
17 presentation mechanisms employed in the aircraft and 18 space industries to see what may be useful er applic-19 able in nuclear power plant control rooms, does it?
20 A
No, I think that statement is correct.
It does 31 not limit our ability to look at those concepts.
I believe, however, that experience has shown that those ss concepts can be applied to power plants only in a very limited way at most.
4 iOQ9
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RZ 7 le 1
o
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Stevens 30 3
Q Do you know of anyone or any organization 4
or institution which has taken a comprehensive look U
at the available technology for control rooms, in 6
terms of human engineering, man-machine interface, 7
and evaluated what if any application or use it may g
have in the nuclear power plant control room setting?
A I have no knowledge of such an organization 9
because I have not been actively involved in instru-10 mentation and control room design since 1974.
I 11 believe this question should be addressed to someone 12 else for answers.
13 Q
who?
14 A
Mr. Castanes would be in a better position to 15 answer that question than I because he is currently 16 active in the design and specification and procurement of instrumentation and control for B&W today.
7 Q
Did the design you came up with, with Bechtel & SMUD for the simulator and for SMUD itself 19 involve a sizing down of the control room panels and 20 switches from the conventional size that had generally 91 been used before that in power plant control rooms?
~
22 A
Yes, and again I must give a qualified "yes" 23 because there has 5een a large spectrum of power plant 24 control room designs from the very large to the very small.
The design for the simulator was certainly n.
1892 205 BENJAMIN R EPORTING SERVICE
1 o
~
Stevens 31 3
smaller than the larger designs, but by no means was it as s.'all as the smallest designs that have been 5
used in special design applications in the power 6
plant industry in-previous years.
7 Q
Do you have any understanding as to why the choice was made by Burns & Roe to go with a g
larger-scaled control room at TMI 2 than the scaling g
of the con *.rol room which would have resulted from 10 adoption of your simulator design?
11 A
No personal knowledge.
l'
~
Q Do you have any impression as to why 13 that choice was made, or any opinion?
14 A
My opinion is that the utility industry is by 15 nature a very conservative industry, particularly "here operation of the plant is concerned, because 16 of their obligation to meet the demands of the 1 4 electrical grid and the inability of the utilities 18 to store electricity, and it therefore must be 19 generated when it is demanded.
20 The utilities, therefore, tend through their 91 conservatism to be somewhat slower in response to v.
22 the state of the art for fear that in adopting the 23 state of the art, they will create a problem in g4 their ability to respond to the network, and so they tend to move slowly, and control room design is one
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BENJAMIN R EPO RTIN G S ERVICE
1 2
Stevens 32 3
of those areas in which they have traditionally 4
moved slowly, and you will find more control room 5
consoles throughout the utility industry which lean t ward the concept that what was used at Three Mile 6
Island, that is, the large pistol-grip switches to a
operate pumps and somewhat smaller switches to operate valves, simply because that is the way it was 9
done before, and it worked, and with no motivation 10 to change it and a risk involved in changing, they 11 tend to stay with it.
12 There is a second factor involved, and that 13 is that the operators themselves tend to keep control 14 room designs somewhat they way they are because an 15 operator inherently says to himself, "When I am 16 starting a big piece of equipment, I like to have a cig handle in my hand, and I realize the consequences i,t of my act when I do it, and when I have something that is smaller, I like a slightly smaller switch,"
19 and many of the trends and changes in control rooms 20 to what I would call miniaturized equipment have "I
been resisted by the operators because they lose
~
22 this sense of perspective of big equipment versus 23 little equipment, and I know from personal experience 24 in Germany that they have gone to ultraminiaturization in control rooms and have been forced by the operators' BENJAMIN R EPORTIN G SERVICE 1892 207
1 2
stevens 33 3
reactions to this ultraminiaturization, which in the 4
worst case involves the starting of very large pieces J
5 of equipment with a switch a quarter of an inch in diameter, and the operators rejected this and said, 6
"We must have something larger."
7 They also rejected the very small indicators 8
which went with this concept and asked for large 9
indicators so they could see the critical and important 10 measurements without reaching over the panel and 11 squinting, so that there is no magic in reduction 12 in size from the operator's point of view if you 13 carry it to the extreme, which is to reduce it down to the point where it is all cramped together and 74 reaches the point of difficulty in sorting out what you have, so the operators have resisted this 16 for these reasons.
17 The utilities have resisted this because of 18 their conservatism, and it is my opinion that Burns 19 simply reflecting that type of conservative
& Roe were 20 approach in consideration of the operators' opinion 21 from the past.
(Continued on Page 34.)
on 23 24 1892 208 23 BENJAMIN R EPO RTING SERVICE
1 2
Stevens 34 rz/ew 3
Q Here in this country, do you have any 8.1 4
specific examples which would illustrate the point you made that operators have resisted miniaturization?
.O A
No, I can't cite any specific examples.
I would 6
have to say that there is a general impression which 7
has been derived from a look into the control rooms of 8
many different power plants over the years, and is not 9
based upon any single power plant or any single conver-10 sation with any individual utility, but rather is the 11 summation of a look into many power plants over many 13 years of experience with the power business.
Q D
y u have a personal opinion as to the, 13 and I use the term advisedly, the usefulness or the value or the appropriateness of the SMUD design in 15 contrast with the TMI 2 design?
16 A
Yes.
17 Q
What is it?
18 A
This is a personal opinion.
I believe that the 19 design of a control room which looks more like the 20 Rancho Seco design or the simulator design, as the case 37 may be, is easier for one man to operate during normal ss operation of the plant because the one man can scan within the breadth of his arms all of the information 23 that he needs to verify thct the plant is operating 24 properly.
When you get into emergency situations,
'OQ) 7 ps g iu,-
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1 2
Stevens 35 8.2 3
every utility plans to bring into the control room 4
supplemental personnel.
They may either be already in r
the general area or quickly available on call, and any g
control console which does not provide enough room for these additional personnel to gain access to the panels and the information which are necessary to 8
permit them to assist the operator through this period 9
of emergency, this reduction in size to that point 10 would be detrimental to getting the plant through the 11 emergency situation.
12 Conversely, during that same emergency a panel which is spread out over a very large area, a a. '
think 13 it is very difficult to define what the word "large" means, becomes more difficult during normal operation l a, for a single man to scan, and during emergency opera-16 tions requires more people to maintain a safe operating 17 condition.
18 I,
therefore, believe there is an advantage to 19 reduction in size, but that advantage would be very 20 difficult to measure in quantitative terms.
It is a 31 qualitative matter, and if you consider the number of C-power plants in the United States whose control rooms are large and whose equipment instrumcatation and control equipment is laid out on large consoles and 24 panels and their records of operation, I doubt 5
i007_
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BENJAMIN R EPO RTIN G S ERVICE
1 2
Stevens 36 3
seriously that you would ever be able to find any 4
quantitative measure to verify this very qualitative 5
feeling that I have that it would be somewhat easier to operate when it is slightly smaller.
Q I take it in your view that the SMUD design, 7
given the various factors that you have been describing 8
to us, represents an optimum design?
9 A
I could not say that it is an optimum design.
10 Q
I meant with respect to size?
11 A
Oh, size.
It is optimum to this extent:
It can 12 be operated by one man during periods of normal opera-ti n and yet it all ws additional personnel access to 13 both the consoles and the panel during those periods when emergencies can be expected such as startup and l a, shutdown without cramping the ability of those addi-16 tional people to gain access to the controls that they 17 need to assist the operator during those periods of 18 time.
If it were much smaller it would begin to cramp 19 the additional operators and to that extent I do 20 believe that design is optimum.
31 Q
Do you think mimic busbars or mimic busses ss have value?
A My personal belief is, yes, in certain circum-stances, but not in e ve ry case.
24 Q
How about for TF~ ??
1892 211 25 SENJAMIN R EPO RTIN G S ERVICE
1 o
Stevens 37 3
A There is a mimic panel at TMI 2 in the makeup 4
and letdown area, and I believe that mimic is helpful t
the operator in operating that portion of the 5
system.
Q How about mimics in other areas of the 7
system?
8 A
I don't like to generalize with respect to this 9
particular subject, but I don't know any other way to 10 answer the question.
11 It is my belief that mimics can be helpful to 12 the operator in certain cases but every operator becomes used to the conditions to which he is exposed 13 in any control room, just as any pilot becomes used.
to his aircraft and any automobile driver becomes used la, to his automobile, and the existence or the non-existence 16 of a mimic panel in my estimation is not a significant 17 contributing factor in the ability of the operator to 18 do his job better when he is familiar with the control 19 room arrangement.
It is, however, extremely valuable 20 for new operators who are not familiar with that 21 particular control room who have, perhaps, been trained on a simulator which is a different arrangement no and it helps him to realize the relationship between the controls and the system that he is controlling, 24 but once he learns that relationship the mimic really o-3 1ono 79 BENJAMIN R EPO RTIN G SERVICE
1 2
Stevens 37-a 3
contributes no longer to his ability to do the job.
4 It is simply a reminder.
(continued on following page.)
5 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 v
22 23 24 1892 213 25 BENJAMIN R EPO RTING S ERVICE
SR 9 lc 1
2 Stevens 38 3
Q How do you apply all that to TMI 27 A
I apply it to TMI 2 only to this extent:
The 4
mimic panels which are there are limited to only one area of the console.
6 I do not believe that the addition of that one 7
mimic makes a significant contribution to TMI 2 in 8
the overall.
It could be deleted without seriously 9
hampering the operations of TMI 2.
10 conversely, more mimics could have been added, 11 for example, in the feedwater area without signifi-cantly improving it.
73 As I said a moment ago, my feeling is that the new operators are the ones who benefit the most 14 from mimics, and I do not know, and I am not aware now, 15 and I never was aware how many operators which enter 16 the TMI control room represent new operators versus 17 those people who are experienced with the operation 18 o'f the TMI 2 reactor.
19 Q
Do you know whether operators were con-sulted at all in the design of the TMI 2 control room?
20 A
No, I do not.
Q Am I correct in understanding that on a reactor trip, you may have a number of alarms which 23 come off or which sound simultaneously?
7 24 A
Yes.
25 o
Those alarms are received and silenced B ENJAMIN R EPO RTING SERVICE
1 2
Stevens 39 3
all together by the pressing of a single acknowledge button, is that correct?
4 A
That is my understanding of the TMI control a
console.
I believe the acknowledge buttons are on 6
the central console.
I am not aware of any other 7
acknowledge buttons on any other console.
- However, 8
there may be some in the turbine area.
I do not have 9
specific knowledge of that, since we were not respon-10 sible for the design of the turbine area.
11 Q
Is that method of acknowledgement something 12 which B&W would concur in as a matter of design?
13 A
I can't speak for Bsw in this matter since I am no longer responsible for this area.
74 15 Q
How about at the time you were responsible?
A At the time when I was responsible, I believe 16 that we carried out multiple acknowledgement buttons 1,4 in the plant, yes, i-the plant where we were respon-18 sible for the design, so that only a section of the 19
~
simulator was silenced with the acknowledge button, 20 leaving the other sections still active.
"1 However, we did not at that time have any 22 objections to a different philosophy.
We were aware 23 on TMI 2 that the alarms were silenced with a single 34 button, and it did not cause us any concern.
We did not at that time object, and no thoughts of alarm were
.3 1} 2ke'] B ENJ AMIN R EPO RTIN G S ERVICE
1 2 Stevens 40 3 raised in our mind as a result of the decision on 4 the part of the architect-engineer to use a single 5 acknowledge button. 6 Q Was any thought given in the design of P the control room of TMI 2 to the situation which 7 might arise in a serious emergency where literally dozens of alarms might be sounded in the space of a 9 few minutes, and the capacity of the operators in 10 such an emergency to absorb and make sense out of a 11 substantial number of alarms sounding within a very 12 short period of time. 13 MR. EDGAR: Could you read the question 14 back. (Previous question was read back.) gg A To the best of my knowledge, no specific attention was directed to this particular phenomenon 17 on the part of B&W. I cannot state that it was not 18 considered by Burns & Roe in their design of the control 19 room because I have no knowledge of their intent nor 20 their concerns between themselves and Jersey central 21 or Met Ed. ng Q In light of the TM7 2 accident, do you think that that is a subje t which could usefully 23 be given some attention? iOO2 2)b< IV A Yes. 25 B EN. AMIN R EPO RTIN G SERVICE
1 2 Stevens 41 3 Q Do you know whether the B&W design that 4 was submitted and ultimately recommended to Burns 5 & Roe included indica **on of high-pressure injection 6 flow n the front or the back of the main console? A It was on the back panel in the same area as i the engineered safeguard equipment. I should further clarify, however, that this 9 engineered safeguard panel was located immediately 10 behind the equipment for operating the pumps, so 11 that the operator could see that in the same 12 position as the pump operation. 13 (Continued on Page 42.) la 15 16 17 18 19 20 21 no 1OO9 )\\ ~ u tuiu 23 24 25 BENJAMIN R EPO RTIN G SERVICE
1 o Stevens 42 sr/ew 3 Q can an operator standing at the main 10.1 4 control console read HPI flow as measured on the back P""*17 5 A I do not know the answer to tnat question because O I have no knowledge of the specific location for high i pressure injection flow on TMI 2. I know only that 8 it is not included on any of the panels which were 9 supplied by B&W. 10 Q Are you familiar enough with the TMI 2 11 control room design 12 (There was discussion off the record.) 13 Q D y u know why the high pressure injection flow gauge was not on the panels supplied by B&W in light of the fact that high pressure injection flow is clearly a component within the scope of. supply of B&W? 16 A I have no specific knowledge as to why it was 17 not located on these panels, but I do know that this 10 omission was specifically pointed out to Burns & Roe 19 in response to the designs which th e:- se.t to us. 20 MR. EDGAR: Also I would lixe raise a ow 21 p int of clarification. I don't believe there is any factual basis established to say that B&W gg supplied all of the HPI equipment. There are breakpoints and interfaces in that scope of 24 supply. 25 '092 ?10 Ius wIO BENJAMIN R EPO RTING SERVICE
1 2 Stevens 43 10.2 3 (There was discussion off the record.) 4 THE WITNESS: Referring back to the issue on one of the previous questions of the location .b of the indicator for high pressure injection, we noted as Item 5 in Exhibit 85, that the indi-7 cators for high pressure injection were not 8 shown by Burns & Roe on their drawings of Panels 9 3, 4 and 14, and we stated, "It is assumed that 10 these will be mounte d on the engineered safety 11 features panel". 12 Q Do you know where the controls in the TMI 2 control room are located for the HPI throttle 13 valves? 14 A No. 15 Q Are you familiar enough with the TMI 2 16 control room to tell us whether the auxilliary system 17 panel was installed as or per the recommendation that 18 B&W made? 19 A I need a clarification of that question before 20 I can answer. Do you mean the auxilliary panel which we supplied as panel No. 3 or do you mean another panel, g} which was supplied by Burns & Roe? s. Q As you supplied it. 23 A Now would you repeat the question? 24 (Previous question was read back.) '89,7 219 25 i BENJAMIN R EPO RTING S ERVICE
1 2 Stevens 44 3 A I believe that the question is still not clear enough to be able to answer it in a meaningful way. 4 The recommendations for the auxilliary panel which 5 B&W made are reflected in the drawings which B&W 6 submitted to Burns & Roe. 7 (There was discussion of f the record.) 8 Q Mr. Stevens, the nine drawings identified 9 as Stevens Deposition Exhibits 73 through 81 were, as 10 I understand it, transmitted to Burns & Roe initially 11 for information purposes, and those drawings show the 12 design of the B&W simulator and SMUD design, is that Correct? A Yes, that is correct. 14 Q And that subsequent to their transmission 15 to Burns & Roe for information purposes, B&W took a 16 position that it was recommending adoption of those 17 designs for use in the TMI 2 control room, is that 18 also correct? 19 A That is also correct. 20 Q And, therefore, if we wish to determine to what extent those designs were incorporated in the gy ultimate TMI 2 control room, it would simply be a s, matter of comparing the drawings to the control room 23 as it exists today? 24 092 220 A That is correct. BENJAMIN REPORTING S ERVICE
1 2 Stevens 45 3 Q Mr. Stevens, have you made any statement in 4 connection with your knowledge or understanding of events surrounding or arising out of the TMI 2 acci-O dent, and by " statement" I mean anything that you 6 wrote or anything that you said that was reduced to 7 writing? 8 A No. 9 MR. ROCKWELL: We are going to recess your 10 deposition at this time, Mr. Stevens. We are 11 recessing it in order that we may recall you 12 f r further testimony should that be necessary. We don't anticipate it will be, but we can't be sure. That is why we are recesssing it. Thank 14 you for your cooperation. 15 (The deposition adjourned at 9:05 p.m.) 16 17 Howard Hartman Stevens 18 19 subscribed and sworn to 20 before me this_________ 21 day of_________________ 22 1979 23 34 Notary Public 25
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BENJAMIN R EPO RTIN G SERVICE
1 2 46 3 I-N-D-E-x 4 3119288 Eb_r*Si / 5 Howard Hartman Stevens 3 6 P 7 E-x-H-I-B-I-r-S 8 9 STEVENS DEPOSITION 10 rgg_IgEN;IIIc6TI9N P39E 11 70 Resume of Howard Hartman Stevens 3 12 71 B&W Standard Guide Specifica-12 tion for Control Room Design criteria dated December 20, 13 .1968 14 72 Drawing submittal form from 12 Babcock & Wilcox to Burns & Roe 15 dated Ncvember 7, 1968 16 73 Draw'.ng No. 136027 12 74 Dra(ing No. 136025 12 17 Draw ng N 136024 12 18 76 Drawing No. 136023 12 77 Drawing No. 136022 12 20 78 Drawing No. 136021 12 21 79 Drawing No. 136020 12 no 80 Drawing No. 136019 12 ~~ 23 81 Drawing No. 136026 12 24 82 Letter dated December 13, 1968 12 to Burns & Roe from Babcock o- & Wilcox '09,_2 )) ~ io m-BEN LAMIN R EPORTIN G S ERVICE
1 2 E-X-H-I-B-I-T-S 46-a (Continued) 3 4 STEVENS DEPOSITION FOR IDENTIFICATION pA_gg 5 83 Drawing No. 30755 12 6 84 Drawing No. 30756 12 7 85 Letter dated August 5, 1970 12 from Babcock & Wilcox to g Burns & Roe 9 10 11 12 13 14 U 15 16 1~ 18 19 20 21 23 24 )u ~) n-3 BENJAMIN REPORTING SERVICE
1 o 47 ~ / 3 C-E-R-T-I-F-I-C-A-T-E 4 STATE OF NEW YORK )) ss: COUNTY OF NEW YORK ) 5 We, ROBERT :ERKIN, a Notary Public of the State of New York and STANLEY RUDBARG, a Certified 7 Shorthand Reporter and Notary Public of the State of 8 New York, do hereby certify that the foregoing 9 deposition of HOWARD HARTMAN STEVENS was taken before 10 us on the 5th day of July, 1979. 11 The said witness was duly sworn before the 12 commencement of his testimony; the within testimony was taken stenographically by ourselves and then g transcribed. The within transcript is a true record of 15 the said deposition. 16 We are not related by blood or marriage to 17 any of the said parties, nor interested directly or 18 indirectly in the matter in controversy, nor are we 19 in the employ of any of the counsel. 20 IN WITNESS WHEREOF, we have hereunto set our hands this 6th day of July, 1979. ny 1o0,? 24 ~ lv -{ ROBERT 4f--- /'yk-- 22 23
- RKIN W- - - -
24 STANLEY RUDBARG, CSR 25 BENJAMIN R EPO RTING S ERVICE}}