ML19289G287
| ML19289G287 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/06/1979 |
| From: | Olds G BABCOCK & WILCOX CO., PRESIDENT'S COMMISSION ON THE ACCIDENT AT THREE MILE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 7908160373 | |
| Download: ML19289G287 (58) | |
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_______________________________________x P RE S ID ENT ' S COMMISSION ON THE ACCIDENT AT THREE MILE ISLAND
x DEPOSITION of BABCOCK & WILCOX by G RA NVILLE MORRISON OLDS, held at the offices of Babcock &
Wilcox, Old Fo' rest Road, Lynchburg, Virginia 24505, on the 6th day of July, 1979, 5
commencing at 10:30 a.m.,
before Robert Zerkin, Notary Public of the State of New York.
il 8 9 2. 2 7 8~
BENJAMIN REPORTING SERVICE CERTIFIED SHORTHAND REPORTERS k
FIVE IIEERMAN STREET
$g' 7908160373 NEw YortK. Now voitu 10038
[212] 374 1138
1 2
2 3
E98_a6HC995_E wIL993:
4 MORGAN, LEWIS & BOCKIUS, ESQS.
Attorneys for Babcock & Wilcox 5
1800 M Street, N.W.
Washington, D.C.
20038 6
BY:
GEORGE L.
- EDGAR, ESQ.
-and-KEVIN GALLEN, ESQ.
of Counsel 8
9 10 E9B IHE 99MUI!!I9N:
11 WINTHROP A.
ROCKWELL, ESQ.
Associate Chief Counsel 12 3
a&S9_tasSsuI:
14 RONALD M.
EYTCHISON 15 16 17 18 19 o0o 20 21
~
22
'1892 279 23 24 25 B ENJAMIN R EPO RTING S ERVICE
1 2
3 3
G RA N V I LLE M O RR I S O N O L D S,
4 having been first duly sworn by Winthrop A.
Rockwell, Esq., took the stand and testified 5
as follows:
DIRECT EXAMINATION 7
BY MR. ROCKWELL:
8 Q
Would you please state your full name.
9 A
Granville Morrison Olds.
10 Q
Who is your current employer?
11 A
Babcock & Wilcox.
12 Q
What is your current business address?
A Nuclear Power Generation Division, Box 1260, 13 Old Forest Road, Lynchburg.
Q And what is your current position with l a, Babcock & Wilcox?
16 A
I am a manager of field engineering and services 17 in the Customer Service Department.
0 (Do c ume n t described below herein marked 19 Olds Deposition Exhibit 100 for identification, 20 this date.)
pl Q
Mr. Olds, nave you prepared a resume of your employment education history which you have 33 brought with you today?
1892 280 A
I have.
24 Q
Do you have t now in front of you as 25 BENJAMIN R EPO RTIN G SERVICE
1 2
Olds 4
3 Olds Deposition Exhibit 100?
4 A
Correct, I do.
Q Is it c mplete and up-t -date to the best 5
of your knowledge?
A Yes, it is.
7 Q
Mr. Olds, referling you to your resume, 8
you were the senior project manager for a number of 9
power plants which employed Babcock & Wilcox NSSS 10 systems, is that correct?
11 A
Yes, sir.
12 Q
can you tell me what the role of the Seni r project manager is for a power plant.
13 A
Our Project Department is divided into teams of project managers, and heading each of those is a senior project manager which was the role I ultimately held.
16 Each project team then is assigned contracts as they 17 are written and signed and become the manager of that 18 project for for the company as the company representa-19 tive, so to speak, in that project.
The senior 20 project manager has working for him any number of 21 pr ject managers depending on the number of projects assigned to the team.
n,.
The project manager is the key man there with the senier pro]ect manager being, I guess you could 24 call it, the supervisor over the project, getting into 25 m.
n BENJAMIN R EPO RTING SERVICE
1 2
Olds S
3 the major problems, major commercial terms and so forth.
4 g
Does that relate to all phases of B&W"s involvement in the construction of the particular power
.a plant?
A Yes, it does.
It involves the design, the 7
engineering, the manufacture of the equipment which we 8
manufacture plus the procurement of equipment that we 9
purchase from others, and the delivery of that equip-10 ment to the field, and some involvement with the 11 installation, the testing, and ultimately the accep-12 tance of the unit by the customer.
13 9
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for more than one plant at one time?
A Yes, sir.
As I mentioned, each team as so many project managers, each of wnom is assigned a specific 16 unit, but the senior project manager may have more 17 than one assigned.
18 Q
would the senior project manager be super-19 vising all project management teams in existence at a 20 particular time?
A No.
21 s
Q How many senior project managers would there be?
23 A
At the time I was a senior project manager there 24 were five of us.
I892 28'2' 25 BENJAMIN R EPO RTIN G S ERVICE
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Olds 6
3 g
Was there one person to whom all five of 4
you reported?
A Yes.
-O Q
Who was that?
A It was when I first went to work in project 7
management, Don Habtr, now Fossil Power Generation 8
Division, and let's see, the next one was Carl Thomas, 9
who is now in the German organization.
10 Q
What is the position that this person 11 occupies; what is it called?
12 A
Manager of nuclear projects: I believe that is the present term.
13 Q
Has it been known by another name in years past?
A It could have been.
I am not sure.
16 Q
So if I understand the structure correctly, 17 you have a manager of nuclear projects?
18 A
Yes, and it is department level.
19 Q
Then you have reporting to that person a 20 series of project managers?
21 A
Correct.
Q Who have generally more than one power plant under the scope of their supervision?
A Yes.
24 Q
And then reporting to the senior project 25 F89228.i BENJAMIN R EPO RTING S ERVICE
1 2
Olds 7
3 managers you have project managers who have only one 4
plant?
A correct, and usually has more than one associate 5
p ro j ec t manager working for him, and that creates a team, and there are other people in the team involving 7
scheduling, and so forth.
8 Q
How large would the project manager team 9
be, and I realire you may have to give me a range, 10 and I understand the size of the team may vary, but 11 can you give me an idea.
12 A
On a specific project?
13 Q
Yes.
A The senior project manager and the project manager; thure may be one or two, and I think that is 15 the most of the associate project managers.
16 Q
What I am really looking for is a ball park 17 number rather than going through each position?
IO A
I'd say six to seven, possibly eight.
19 Q
That would be on a project team?
20 A
Yes, correct, associated with one unit.
31 Q
Does that vary during different phases?
A Yes, it varies, you are right, during different s..
phases.
The procurement phsse is a heavy phase because you have a lot of paperwork flowing back and 24 forth.
Once the equipment is delivered and s h'o'w s u p'.
1892'284~
25 B ENJ AMIN R EPO RTIN G SERVICE
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olds 7-a 3
then we start demanning the team because the emphasis 4
is shifting to the field.
MR. ROCKWELL:
Off the record.
5 (Discussion held off the record.)
6 (Continued on following page.)
t 8
9 10 11 12 13 14 15 16 17 18 19 20 21 23 94 1892 285
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RZ 2 LC 1
2 Olds 8
3 (Document described below herein marked Olds Deposition Exhibit 101 for identificatie.,
4 this date.)
a Q
Mr. Olds, referring you to what we have marked as Olds Deposition Exhibit 101, is this an 7
organization chart of the Project Management Department 8
here at B&W?
9 3
7g 13, 10 Q
Does that generally reflect the way this 11 department has been structured for the last few years?
12 A
Yes, very much sc: mostly just people changes.
Q can you tell me who was involved in 13 project management for TMI 2,
to.the best of your knowledge, and please make reference to the organiza-15 tion chart or to the organization chart for earlier 16 years which are available to you, as a help to your memory if you need it.
18 A
Grant Ward was a senior PM.
I believe that he 19 started out as the project manager on that project, 20 with Bob Biesel being the senior PM at the time we
- started, g
f There was a Mr. Fenn Thomason, who was an 22 associate PM, and I am not sure just when he joined 23 the project.
Scott Delicat was also involved with 24 that project at that point.
I believe that is all.I l892'286 BENJAMIN R EPO RTIN G S ERVICE
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Olds 9
3 can tell you from memory.
e 4
Q Would it be helpful to go back, for P'oject Department instance, to 1973 and look at the J
a at that time?
6 A
I am back in 1972 now.
7 Q
You are referring to an earlier organization 8
chart of the Project Management Department?
9 A
Yes, I am.
10 Q
Does that help refresh your ree>llection?
11 A
Yes, this has actually had six teams involved 13 on this organization chart.
Q Does this organization chart that we are referring to show specifically the TMI 2 project team?
A It doesn't show specifically the team, but I 15 happen to know that Team F, which was under Grant Ward, 16 who had that project, Delicat, and Putney I believe was his associate; Delicat was the project manager, 18 and Putney was the associate.
19 MR. ROCKWELL:
I do not think it is 20 necessary to mark this 1972 organization chart, but for the record I will describe it as the g
1972 organization chart for the Reactor s
Department, specifically Reactor Contracts, and 23 there is a project team of which E.
Gu Ward 24 was the senior project manager.
i892'287 25 BENJAMIN R EPO RTING SERVICE
1 o
Olds 10 3
Q Are all of the people listed below people 4
that were working on TMI 2,
to your knowledge?
A No, they were not.
5 Q
But Mr. Delicat was the project manager?
A Yes.
7 Q
What was Mr. Norman's position?
8 A
Mr. Norman was on the Florida project.
9 Q
Mr. Putney was the associate?
10 A
Yes, he was, as I recall.
I am not too certain 11 about that.
12 Q
So we added one name, which is Mr. Putney.
~
D y u recall any other names?
-13 A
Mr. Putney is deceased now.
No, I don't see any other names here which I la, would tie to that contract.
16 Q
When you took over the Nuclear Service 17 Department, what did you understand your job 18 responsibility to be?
19 You took over that assignment in 1975, did you not?
20 A
Yes.
The charge that I had from Mr. MacMillan was to build the department into a profitable organi-21 cation with a goal of increasing profits derived s
from services to the various customers.
Prior tc 23 that time, we h ad treated such paid services as 24 incidental to thr other duties of the department.
25 i f' 92' 288 BENJAMIN R EPO RTING S ERVICE
1 Olds 11 2
My charge, as I say, was to improve the profitability of the department by going after, so 4
to speak, that kind of a market.
5 Q
How was that charge given to you by Mr. MacMillan?
Was that a product of discussion I
between you and him?
8 A
Discussion, yes.
It was not in writing, if 9
that is-what you are asking.
Q I was w ndering whether he would have 10 given you a kind of memorandum saying this is what I want you to do.
12 A
No, he did not.
13 Q
Were there any changes in the structure 14 of the department made at the time you took it over?
15 A
Yes, there were.
He gave me a certain amount 16 of freedom to reorganize or restructure the department, 17 which I did.
I aligned it such as to put emphasis on vari us pr duct lines which I could foresee as being 18 what I would call money-makers.
Q What would those have been?
20 A
I was looking at Operating Plant Services, the 21 testing instrumentation area, and training, of course, s
we already had under way, and then Startup Services 23 Startup Services being staff augmentation, customer 24 staff augmentation, as opposed to startup. services 25 which are sold with the units.
BENJAMIN R EPO RTING SERVICE
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Olds 12 3
Q And the customer staff augmentation would be in the sense that you would supply experts 4
in one area or another to be on site and to work a
with them during their startup operations, is that 6
correct?
7 A
Yes, that is true.
The customers seldom have 8
enough people to start a unit, and they need experienced 9
people to augment their staffs, and this was the 10 business which we were launching into.
11 MR. EDGAR:
Are you drawing a distinction here between that augmentation of their staffs g
and the' services sold under the Nuclear Steam 13 Supply contract?
14 THE WITNESS:
Yes, I am.
15 A
(Continuing.)
Insofar as my department went, 16 the services which I supplied through the Project 17 Management Department, as part of the sale of the 18 unit, was not profitable.
What I am talking about 19 is the selling of services to the customer direct.
Q You have identified, I think, four areas which you thought had the potential ~or were already producing profit in the department.
A Yes.
- 892'290' 23 Q
And those would be Operating Plant
'~4 Services, the testing instrumentation area, training 25 and Startup Services?
BENJAMIN R EPO RTIN G S ERVICE
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A Right.
4 I might go back.
In the testing and instrumenta-5 tion area, tooling also should be there.
6 (Continued on Page 13.)
7 8
9 10 11 12 13
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14 15 16 17 18 19 20 21 22 23 04 Oh[
hi 25 BENJAMIN REPORTING SERVICE
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Olds 13 rz/ew 3
Q At the time you took the department over, 31 4
did you meet with each of the units in the department r the unit managers in the department to review 5
where they stood and what their perception was of what they were doing?
7 A
Yes, I did.
I did it for two reasons.
One of 8
the instructions Mr. MacMillan gave me was to reduce 9
the management overhead of the department, so I inter-10 viewed or worked with each one of them to ascertain 11 his understanding of his job, looking toward a certain 12 combination of units and elimination of some of the
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13 what was the status of the department.
I had the benefit of the previous manager's help, and I also had 1.5 the benefit of the acting manager's help.
16 The department was in sort of a state of flux 17 because the previous manager had moved onto another 18 job and the acting manager had been assigned for some 19 few months prior to me taking the job.
20 Q
As a result of your review, were you able to trim management overhead?
gg A
Yes, I did.
We had nine managers reduced to five.
I reduced it to five, and then subsequently 23 added marketing organization which brought back six.
24 marketing orgagization within Q
Had you had a 23 M2 292 BENJAMIN R EPO RTING S ERVICE
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Olds 14 3.2 3
Nuclear Service before?
4 A
No, we had not.
We had a small group within Marketing Department which was working in that area,
-a but the emphasis in the Marketing Department was on selling NSSS, not selling services; therefore, it was 7
felt advisable to set up a separate marketing organi-8 zation.
9 Q
Did you find that your implementation of 10 a marketing organization in the Nuclear Service 11 Department bore fruit?
12 A
Yes, it did.
13 Q
Where were they most effective in terms of increasing the sales of services?
A Well, in two areas.
I think, most successful, 15 and that was in the startup services, and the second 16 was in the operating plant services; operating plant 17 services possibly because we were getting more units 18 into operation.
We had four units accepted during 19 1974; in 1975 and 1976 these units started having 20, the ir first refueling outages.
21 Q
W uld it be possible, with respect to the four areas that you have identified as returning a s
profit to the corporation, to rank them not in terms of gross profits that they returned, but ip, terms of 24
.)hh[ 2h) rate of return?
25 BENJAMIN R EPO RTING SERVICE
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olds 15 3.3 3
MR. EDGAR:
I am going to ask for a state-4 ment of relevance.
MR. ROCKWELL:
We think it may be rele-O vant in terms of the evaluation of the work of the department to show what their profitability t
picture was.
8 MR. EDGAR:
With respect to what work of 9
the department?
10 MR. ROCKWELL:
With respect to the services 11 being offered and the quality of the services 12 being offered.
MR. EDGAR:
I guess I am asking for a 13 statement of the relevance in terms of the Commission's charter.
15 MR. ROCKWELL:
The Commission's e arter is 16 framed so as to charge the Commission with the 17 investigation of the causes and the circum-18 stances surrounding the events at Three Mile 19 Island, stated in very broad terms, and we view 20 this as part of a careful leak at those f acte rs 21 which may have had some bearing.
Obviously, we are not prejudging the situation, but we cannot find out unless we make the inquiry.
MR. EDGAR:
If you will note our objection.
24 A
Could you repeat the question.
1892:294 2s BENJAMIN R EPO RTIN G SERVICE
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16 Olds 3.4 3
(Last pending question read.)
4 A
I would rank the operating plant services as the highest rate of return, but I'd also add that the 5
have a more assured return startup services are more in that there are usually longer assignments, running i
on the order of one to five years.
8 R4 lc Q
What would you rank second as to rate g
of return?
10 A
Rate of return?
I believe startup services 11 would be second there.
12 Q
Third?
13 A
Third, probably training, the reason being that 14 the simulator has been pretty much paid for by 15 previous services.
Therefore, the cost of service one of the reasons 16 is less there.
The reason we were getting into the test equipment and tooling g
was that we felt this might be an entry into plants other than B&W plants for our services.
19 Q
Okay.
I take it this would be No. 47 20 A
No.
4.
- 1 Q
Referring you now to Willse Deposition 22 Exhibit 2, is that an organization chart for the 23 Nuclear Service Department as it existed in 1978?
24 A
Yes, it is.
Q Did you operate the various units, is n.a 1892 295 BENJAMIN R EPO RTIN G S ERVICE
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Olds 17 3
that the correct term?
A These were sections.
4 within the Nuclear Service Q
Sections
.a Department as profit centers in the sense that for accounting purposes, in other words, could you see 7
the performance of a particular section on an 8
accounting basis in profit-and-loss terms?
9 A
Yes, I could, as manager.
However, finance 10 and accounting departments did not specifically 11 break them out quite that way.
}g Q
And I take it that when Mr. MacMillan gave you the charge, that the Nuclear Service g
Department may not have been carrying its weight up to that time, in terms of bringing in income in 15 proportion to the expense of its operation?
16 A
Well, that is not quite the true fact.
Q Okay, explain it to me as you understand it.
18 A
Our major business up to that point had been 19 NSS and fuel.
It appeared that there was a business 20 and we had some business in the service area or the so-called after market.
g Mr. MacMillan wished to emphasize that, to bring in that additional income.
It wasn't that 23 the Nuclear Service Department had not been carrying 24 its weight.
It had been doing what it was set up to o
do, and he saw an opportunity to expand on it and
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Olds 18 3
make additional money for the corporation.
,e 4
Q When you took over the Nuclear Services Department, did you talk with Mr. Elliott and review a
the training?
6 A
Yes, I did.
Norm was manager and remained 7
manager and still is manager today of that particular 8
segment.
9 Q
Can you tell me what his assessment of his 10 situation was at the time you took the Nuclear Service 11 Department over?
A If I may go back in my memory -- I don't have
}g at the time we talked, anything in front of me here I recall that he felt th at here was an ability to 14 expand his operation into the area of requalification 15 training, which was just beginning to become evident 16 that it was going to be a
major part of the business.
18 He needed additional marketing assistance, and 19 he needed some additional help in the administrative 20 area, all of which we fixed.
The simulator needed an upgrade, which we even-g tually pushed through a capital appropriation and got that going.
That has been doing on now for a couple 23 of years.
Further on, we debated and got into the-24 videotaping business, as part of the training, making, 1892'297-2s BENJAMIN R EPO RTING SERVICE
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olds 19 3
training aids as part of his line of business.
~
4 Also much later, recently, in fact, within the 5
last six months or so, after we had some major success in upgrading our simulator, we discussed 6
going into the simulating upgrade business.
7 Our simulator was one of the first ones in the 8
business and had been utilized somewhat as a pattern 9
for some of the others, so it appeared upgrading of 10 the others might be a logical follow-on.
11 Q
At the time you took over the department, 12 did you make contact with anyone outside the Nuclear 13 Power Generating Division to obtain their assessment 14 of the training program?-
15 A No, I don't recall any specifics of that.
16 I know from time to time I had spoken to customers 17 about Norm Elliott's operation and whether or not it was satisfying their needs.
g Q
What did they indicate?
A I got pretty good reports in all cases.
20 Q
Do you recall any specific conversations 21 with personnel from Three Mile Island with respect oo to their assessment of the training program?
23 A No, I do not.
24 Q
Did you form your own evaluation of the 25 Training Department at the time or about'the time 1892 298
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you were taking over the Nuclear Services Department?
A Yes, I did, and it was pretty much satisfied.
4 That is the reason I didn't make any changes in that
.a area except to bring in additional help, which Norm 6
was asking.
7 O
After you had taken over the Nuclear 8
Services Department and were running it, what kind of 9
review did you exercise over the Training Department?
10 A
Not a close review.
I attempted in my reorgani-11 zation to gather some section managers who I felt yg pretty much operated on their own.
We were running on the order of, I would say, 10 to 15 various businesses, so to speak, within the department, and I didn't feel 14 like I could dwell on the specifics of any particular 15 one except where some help was needed.
16 (Continued on Page 21.)
17 18 19 20 21
_n_n 23 24
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Olds 21 sr 5.1 3
Q Were there during the four years, roughly 4
four years, that you were manager of Nuclear Service Department, any occasions when you did have to step in
.a and address yourself to a particular issue or did it run in a fairly self-sufficient fashion during those 7
four years?
8 A
It ran fairly well, except I can recall one 9
specific, where we had some discussions with the plant 10 superintendent, then plant superintendent, at Davis-11 Besse regarding the quality of our instruction, and 12 we took some steps to strengthen the area, in fact, t
the point of moving one man to a different job.
13 Q
Out of the Training Department?
A Out of the Training Department, yes.
Q When was that discussion with the person 16 at Davis-Besse?
17 A
That had to be on the order of two and a half 18 to maybe three year ago.
It is when their operators 19 first started through the program.
The plant super-20 intendent entered the program with him, and it was 21 his assessment of the caliber of our lectures that brought about this particular incident.
Q Who was that at Davis-Besse that made that complaint, do you recall?
04
)hh2 A
That was Jack Evans.
25 B ENJ AMIN R EPO RTING SERVICE
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Olds 22 5.2 3
Q Were his concerns addressed primarily to 4
one of your instructors or did it go to something beyond that?
.3 A
No, it was the ability of one of the instructors to actually make an adequate lecture, I might add in 7
a subject which this particular superintendent was 8
fairly well knowledgeable in.
He probably knew more 9
than the instructor.
10 Q
And Evans was the plant superintendent at 11 Davis-Besse?
12 A
Yes, he was at that time.
13 Q
Has anyone other than this one incident you referred to with Jack Evans, has anyone ever made a complaint that came to your attention with respect 15 to the training program offered by B&W?
16 A
I don't believe there were any serious complaints.
17 There were a series of minor complaints which Norm took 18 care of, and I didn't get into that.
19 Q
Did you have any, although I know you did 20 not, you. indicated, exercise a close review function, 31 did you have any periodic update with Norm Elliott in terms of being briefed on the work of the department?
A On the techni* cal part of the work of the depart-23 jgg'}{ ment? Q I am talking about the Training Department. 25 BEN ! AMIN R EPO RTIN G S ERVICE
1 2 Olds 23 5.3 3 A Yes, I understand that. 4 Q Any pa.-t of the work in the department. A ur relati nship was mostly on the business of 5 manpower, profit not the content the department of the program as such, except when Norm wished to 7 make an expansion on his program, for instance. 8 Q Then he would sit down and discuss it 9 with you? 10 A we would sit down and discuss -- is there a 11 needed service; can it be sold; should we be in that 12 part of it? 13 Q o y u recall whether there were any occasions during the four years that you were manager of the Nuclear Service that you and Norm sat down and reviewed the content of the training? 16 A No, I don't believe that was ever done. 17 Q Was Norm Elliott given a general description IO of what his responsibilities were in that period of 19 time in terms of a formal description? 20 A Yes, we have two means of doing that. One is a 31 position description, which describes the job from a personnel standpoint. The other is a duties and responsibilities document, which appears in our manual, division manual, describing the duties. Those were pretty much written by the man who' 25 B ENJ AMIN R EPO RTING S ERVICE
1 o olds 24 5.4 3 was the encumbent at the time, and periodically updated 4 to fit new situations. I frankly don't know whether N rm wr te the one for his department or section or not. 5 Q Was there at any time to your knowledge a reveiw by anyone outside of the Nuclear Power t Generating Division of the content and thrust of the 8 training program, and when I use the term " review," 9 I don't mean it in an informal sense of feedback on a 10 day-to-day basis, but a more structured review. 11 A Not within the company that I recall. 12 Q The question addresses itself specifically t utside the company. 13 A The customers occasionally monitor the training courses, and that is usually from their training la, organization or on occasion a good superintendent will 16 take a look at it because we are training his people. 17 The other, of course, is NRC, which comes in 18 occasionally, not only to take training but also to 19 review the training programs which Norm is putting on 20 for the customers. 21 Q Aside from the observations made by super-visory personnel from the utilities from time to time nn and aside from whatever reviews the NRC made, do you " know whether the Training Department was reviewed as 24 whole or the substance of the trainin wa~ eviewed a 25 '} BENJAMIN R EPO RTING SERVICE
1 2 Olds 25 5.5 3 as a whole by anyone outside the Nuclear Power 4 Generating Division? A You mean as a department or as a section and 5 what it was doing as a whole, a whole service? Q Or a major part of it. 7 A Well, major part.of it, yes, in that the NRC 8 would review the total training program which was given 9 to an operator, for instance. 10 Q Let me start again. What I am trying to 11 understand is let us set aside the NRC and let us 12 set aside the customers and set aside people inside the Nuclear Power Generating Division. Did anybody 13 else, other than these three groups, ever make an evaluation of the Training Department or any portion la, of it? 16 A Not to my knowledge. Perhaps our competitors 17 had taken a look at what we were doing. 18 Q But they weren't invited in? 19 A No, they were not. 20 (Continued on following page.) 21 22 23 24 1892 304 ~ 25 B ENJ AMIN R EPO RTIN G SERVICE
SR le 1 2 olds 26 3 Q otner than yourself and Norm Elliott, would anyone have done a review of the substance of the training program from within the Nuclear Power .a Generating Division? A I don't believe so. There were people who had 7 access and knowledge to what was going on because 8 we did put on internal training programs for engineering 9 people or for nuclear service people or even for 10 some of the management people. But as far as actually 11 coming in and making a formal review, no, I don't 13 believe that is so. Q Mr. olds, sh wing y u what has been 3 makred as Womack Deposition Exhibit 23, do you recognize that as a memorandum from Bert Dunn to 15 Mr. Taylor? 16 A Yes, I recognize it. 17 Q You have seen it before? 18 A Yes, I have. 19 Q When did you first see that memorandum? 20 A I am not sure of the date, but it was immediately after the Three Mile Island incident. gy Q Within a week, something on that order? A Yes, within the week. It was probably more on 23 the order of two or three days. 24 Q I am going to let you keep the exhibit in n- ~D front of you for reference. You had not seen it nor BENJAMIN R EPO RTIN G SERVICE }
1 o Olds 27 ~ 3 heard about it before the accident, is that correct? 4 A No, I had not heard of this in any specific 5 terms. I may have heard about it generally from 6 Don Hallman, who is my section manager in that area, since he was involved with it, but I don ' t know that t I ever had heard of the Bert Dunn concern at that 8 point. 9 Q You say you may have heard about it 10 from Mr. Hallman. Can you be more specific? 11 A No, I can't. The reason I say I may have. I don't recall hearing about it, 12 hedrd about it 13 but Don, of course, would te'11 me occasionally of the things he was working on. He may have mentioned 14 it, but I certainly don't remember tying it in to a la. Dunn memo. 16 Q All right, look for a moment, if you 17 . would, at Page 2 of the exhibit and the distribution 18 there. A Yes. 20 Q Are any of the persons listed on the 21 distribution in the Nuclear Services Department, or were they at that time? 33 A Yes, there are three on here, the three at the bottom. 24 Q Just read those names quickly., 25 1892 306-B ENJ AMIN REPORTING S ERVICE
1 2 Olds 28 3 A Roger Pittman, Jim Phinney and Tom Scott. 4 Q Referring to the organination chart for the Nuclear Services Department, which groups would .a Pittman and Phinney and Scott be in, or are they all 6 P in one group? 7 A No, they are different groups. Phinney was 8 section manager in charge of Operating Plant Services. 9 Tom Scott was in the Plant Startup Services, and his 10 duty was to provide any site documentation, such as 11 procedures or specifications for procedures. Roger }g Pittman was unit manager in charge of Mechanical Equipm nt and Fluid Systems in the Plant Equipment 13 Services Section. 14 Q Is there an R. Davis in the Nuclear is Services Department, or was there at that time? 16 A No, he isn't. Q To your knowledge, did any of these 18 three people bring Pittman, Phinney or Scott 19 to your attention the memorandum or the substance 20 of the concern raised by the memorandum at the time it came out? gy A No, I don't recall that they ever did. Q Would they have brought it to your 23 attention at any time before the 28th of March 19797 24 A No, not to my knowledge. 1892 307 2s B ENJAMIN R EPO RTING SERVICE
1 2 olds 29 3 Q As you can see, the Dunn memorandum is 4 addressed to Mr. Taylor. A Yes. 5 Q Do you know what action Mr. Taylor took when he received it? 7 A No, I don't. I'm not sure Don Hallman was 8 brought into the action. I suspect he was brought 9 in by either Scott or probably Scott, since he was '10 responsible for that. He would naturally go to Don 11 Hallman's organization for help in that particular 12 area. 13 Q L king at the structure of the Nuclear Power Generation Division as it was in February '78, who would properly resolve the kind of issues being la, raised by Mr. Dunn in his memorandum, and if you 16 haven't had a chance to review it or if you would 17 like to review the memorandum again -- 18 A I am familiar with its contents. 19 You are asking me, I believe, what is the proper 20 way to handle a concern such as this. We have a 21 procedure. s Q I am talking now about February '78. A We had a procedure in being at that time, which was to handle safety concerns. 24 Q What was that procedure? -1892 70'9' 25 B ENJAMIN R EPO RTIN G S ERVICE
1 o Olds 30 ~ 3 A I am not sure what the proper name of it is, 4 but we have a form which is filled out, a preliminary 5 safety concern, which can be filled out by any person, and it is directed to Jim Taylor in Licensing. Then 6 there is a very set formula that we go through in order to resolve that concern by procedure. 8 I am not sure why Mr. Dunn didn't chooose to 9 present it that way. Had he presented it that way, 10 I believe we would have taken better action on it. 11 We would have been required to take actisn. 12 Q Required by whom? 13 A Required by the procedures. Q Whose procedures? g A The division's procedures. They are monitored l a. by our performance against the proceduras, monito.ed 16 by the Quality Assurance Department. It is part of 17 our quality assurance program. 18 Q How does a person in the Nr4 clear Powe r 19 Generation Division know when and how :o use the 20 form for preliminary safety concern or safety concerns? 21 A Each person in the division is trained in these procedures and changes in procedures,and signs off, which is presented back to the Quality Assurance Department to indicate that people have been trained 24 in these procedures. Therefore, anybody.should know h,? 1, Q f BENJAMIN R EPO RTING S ERVICE
1 2 olds 31 3 how to go about presenting a concern of this kind. 4 Q Have you ever discussed the Dunn memorandum, 5 which is before you as Womack Deposition 23, with 6 Mr. Taylor? A I don't believe I have ever had a discussion 7 with Jim on this subject. O Showing you what has previously been 9 marked as Womack Deposition Exhibit 24, have you 10 seen that? 11 A Excuse me. Are we leaving this other subject 12 now? did you have 13 Q For the time being. Why 14 something you wanted to ask? A Are you going to come back to it? Q I don't know. 16 (There was discussion off the r2 cord.) '7 (Previous question was read back.) 18 Q Would you answer the last question as just 19 read by the court reporter. 20 A I don't believe I have ever seen this before. 21 Q Before today? gg A Before today. Q Have y u ever heard about.it? 3 A No. I thought the Dunn memo was the,first 24 ) h ()/' f}Q' memo in the train. 25 BENJAMIN REPORTING SERVICE
1 2 Olds 32 3 Q Looking at the distribution, other than 4 Mr. Elliott, are any of the persons in that distri-bution in the Nuclear Service Department? .a A Of course, Don Hallman is. This was '77. I believe Ron Finnin was also a member at that point. 7 He is now in Licensing, but I believe at that point 8 he was working for Don Hallman. 9 Q So the distribution on that memo shows 10 three members of the Nuclear Service Department 11 Finnin, Hallman and Elliott? 13 A Yes. Q And Hallman s p siti n tat that time 13 was what? 14 A He is manager of the Plant Perfornance 15 Section. 16 Q He was at that time? 17 A Yes. 18 Q Is he still? 19 A Yes. 20 Q Finnin would have worked for Hallman? A Yes, that is true. ny (Continued on Page 33.) 23 ,4 ,1892 311' ~ 25 BENJAMIN R EPO RTIN G SERVICE
1 2 Olds 33 sr/ew 3 0 Do you recall any of these gentlemen 7 4 bringing the substance of the concerns raised in that
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t Y "" "tt*"ti "? 5 A No, I don't recall their bringing this specific 6 subject up. t Q Should Mr. Telly have filled out a 8 preliminary safety concern form? 9 A Let me review this. As I read this memo, I 10 believe that he had two avenues open to him. One was 11 going into the preliminary safety concern route or he 12 could have originated a proposed site instruction. In fact, this alm se takes the form of a site instruc-13 tion. This would then be reviewed through engineering la. and our own department and be issued as a site 16 instruction to the customer. 17 Q Does the proposed site instruction also 18 fall into a procedural train? T892 Y12 19 A Yes, it does. 20 Q Similar to the safety concern? 21 A Yes, it is a control document. Q To the extent that personnel in the Nuclear 23 - Division understood the concept of a Power Generatinn report of preliminary safety concern, any one of them 24 presumably could have said, "You have got your concern 25 BENJAMIN R EPO RTIN G S ERVICE
1 2 Olds 34 7.2 3 in the wrong format; get it into the proper form so 4 that it is addressed in the usual proceduro that we use here", is that correct? O A Yes, that could have been done or the individual 6 making that statement could have, himself, turned it 7 in as a preliminary safety concern. 8 Q Is it your sense, at least in part, 9 Mr. Olds, that simply the way in which the material 10 was presented, the format, if you will, of the memo-11 randum became a problem in having the issues raised 12 being addressed? A Yes. I d n't want t make that sound like that 13 is an excuse for not handling this because it should have been handled obviously, and I believe it was to 15 a certain extent. The point that I was trying to make 16 was that we do have procedures in place where, if they 17 had been used, it would have forced some action out of 18 the organization, timely action. 19 g Do you maintain a file of preliminary 20 safety concerns, which are plant-specific or do yo.u-h/ maintain a master chronological file? 31 A The file i= maintained over in Licensing, and I am not sure what form these take. Most safety concerns 23 will cut across more than one unit, but I'm not sure 24 whether they keep it in an individual file for each 25 B ENJ AMIN REPORTING S ERVICE
1 o Olds 35 7.3 3 plant or not. 4 Q Showing you what has been previously marked as Dunn Dep siti n Exhibit 36, do you r e c og r,i s e that 5 document? A Yes, I do. I have seen this. 7 Q And when did you first see it? 8 A Well, I first saw it after I heard about the 9 first Dunn memo and weat looking for it. Mr. Hallman 10 supplied me with a copy of this memo, plus some infor-11 mation on what led to this memo. 12 This memo was a result of some meetings held 13 immediately f 11 wing the first memo with certain of our people, certain of Hallman's people. Q Who were the people from iia llm a n ' s group la, that met with Mr. Dunn to produce the prescription 16 that is outlined in Mr. Dunn's February 16, 1978 17 memorandum? 18 A Well, I know that Hallman was in the meeting 19 cersonally, meetings personally. I believe that Frank 20 Walters was in on this. I am not sure who else.migfnt h}[ }lf
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Q These would have been meetings between the 9th, which is the date of the Dunn first memo? A Yes. 24 Q And the 16th? 25 BENJAMIN R EPO RTIN G S ERVICE
1 2 Olds 36 7.4 3 A And the 16th, right. 4 Q So Hallman was personally involved; Walters may have been personally involved? 3 A Yes. Q And you don't know of any other name? A I don't know of any other name. 8 Q You believe there may have been others? 9 A Yes. I'm sure there were others, probably out 10 of engineering also. 11 Q Out of Hallman's department probably? 12 A Yes. I think they would probably have been out f Hallman's department, unless Tom Scott might have 13 gotten involved since he was the focal point of these. Q You said that you talked to Hallman about la, what happened. Can you tell me what Hallcan told you? 16 A Yes. When I had heard that there was a memo 17 about the Davis-Besse incident which linked it to the 18 Three Mile Island occurrence, I undertook to find out 19 what had been our involvement in that and, of course, 20 I went to Hallman because I knew this was his area. 21 He told me that they had had the original memo, that they had had I think he said two meetings, but 33 at least some meetings in the next week, which produced I guess I will call it a corrective memo 24 f {g(}} fj} which Dunn issued. .3 e BENJAMIN R EPO RTIN G SERVICE
1 o Olds 37 7.5 3 Then we got busy, and I think maybe, if I can 4 deviate here just a moment, our business is very heavy in spring and fall because that is when the utilities -a like to take their plants off the line. We pretty much empty out the department out to the field and 7 assist them during this period. 8 The next memo that was written on this and I 9 don't know what kind of work went on in the interim 10 Hallman's memo I believe in August, which stated was 11 some concerns. Do you have that? 12 Q Yes, it has been marked as A Deposition Exhibit 37. 13 Q Proceeds A Hallman told ne that they had reviewed the situa-tion among thems e lve :s on several occasions and had come 16 up with some concerns which are outlined in this memo, 17 which he felt should bring Plant Integration into the 18 act because they are the ones who tie the various 19 engineering organizations together, and they are 20 supposed to resolve any cross-discipline co n c e rns. so 21 that is the reason this particular memo was addressed to Karrasch, manager of Plant Integration. g I don't want to go into the content of this except to say there were some concerns abiding which 24 the procedural changes, if I can c a ll.;,th em. th a t, which 18913T6 25 BENJAMIN R EPO RTIN G SERVICE
1 2 Olds 37-a 7.6 Dunn and our people had originated here in these early 3 meetings, and Dunn also told me that he had that on 4 his punch list to get done and had not even had any ,a response from Karrasch, except an occasional conver-6 sation, which I guess took place about two weeks prior 7 to the Three Mile incident, in which Bruce had indi-O cated that he had some work going on and wo uld be 9 getting back to Hallman cor,erning these concerns at 10 the first opportunity. That did not take place prior 11 t the Three Mile Island incident. (Continued on following page.) gn 13 14 15 16 17 18 19 20 21 1892 fl 7 23 24 25 BENJAMIN R EPO RTIN G SERVICE
SR 8 lc 1 2 Olds 38 3 Q Did Hallman indicate whether these nversations that he had with Karrasch betveen the 4 time of his August memorandum and the time o_ the a Three Mile Island accident addressed the specific 6 technical problems that had been raised or had 7 he justmentioned the fact that the issue was pending? 8 A It was on the order of an expedit,ng conversation. i 9 Q Does Hallman rememberhowmany of these 10 conversations he may have had with Karrasch? 11 A No, and I don't believe -- well, I don't know whether he recalls it or not. But I don't remember yg that he mentioned a specific number, except he indicated it was several. 14 Q What is Karrasch's position in Integration? 15 I s ha-th e_ ma n,a g e r ? I'6 A He is the manager of Plant Integration. II Q Did you ever ask Hallman whether he had 18 considered reducing the memorandum of the Dunn concerns 19 to a safety concern form? A N ,I didn't ask him. 20 Q Have you asked anyone who bd.came involved in this? ~ h 22 A No. The thrust of my, if you can call it, 23 investigation of this particular thing was just to 0~4 find out what happened and not the nature of a fix. o5 Q Is it clear in your mind that Hallman BENJAMIN R EPO RTING SERVICE
1 2 Olds 39 3 essentially assumed responsibility for following 4 through on this, following the discussions which resulted in Dunn's February 16th memorandum? a A Well, I believe Hallman feels that the ball is 6 over in the engineering court at that moment. 7 Q At which moment. 8 A At the time of the Three Mile incident. 9 Q Let me go back to my original question. 10 As of the time of Dunn's February 16th memorandum-- 11 and I suggest you pull it out--went out, that involved 13 a revised prescription, did it not? A Right. Q At that time, if it your understanding that Hallman had taken responsibility for following 15 through? 16 A Yes, he had taken the responsibility at that 17 point. 18 Q And I take it that responsibility, 19 according to your perception, remained with nim until 20 he addressed some questions to Mr. Karrasch in. Plant Integration? g q si l ' 1 A That is correct. Q And then is it Hallman's perception that 23 the responsibility at that point then shifted to 24 Plant Integration? 25 BENJAMIN R EPO RTIN G SERVICE
1 2 Olds 40 3 A Well, I believe Hallman's concept at that point 4 was that he couldn't take any further action until he 5 had answers from Engineering on those questions. 6 Q Was there any action that Hallman could have taken other than going over to Karrasch and a saying, " Hey, when are you going to answer my memo?" to force the issue? 9 A Yes, he could have escalated it. 10 Q How? 11 A Through management. 12 Q He simply could have brought it to your 13 attention? A If he had brought it to my attention', I would 14 have gone to Jim Deddens at that point and suggested 73 to him that maybe we had better do something on this. Q Did you ever ask Hallman whether he 17 considered doing that? 18 A No, I didn't. 19 Q Showing you what has previously been 20 marked as Dunn Deposition Exhibit 35, have you seen 21 that document before today? 1892 920 23 A No, I have not. MR. ROCKWELL: Off the record-. 23 (There was discussion off the record.) .4 A (Continuing.) It seems like he is bringing up 25 B ENJAMIN R EPO RTING SERVICE
1 2 Olds 41 3 the same concerns that were brought out in the August 4 memo. No, I was not aware of this. Q You have now had a chance to read what a has been marked as Dunn Deposition Exhibit 35? 6 A Right. 7 Q Did Mr. Walters ever bring up that memorandum to your attention? 9 A Not to my knowledge. 10 Q And Mr. Walters is in Mr. Hallman's group, 11 is that correct? 12 A That is true. Q Or at least as of the time of the writing of that memo? f-1892
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Yes, he still is. 15 Q You now have before you a number of 16 documents, Mr. Olds. Let me try to summarize them quickly in chronological order. There are five 18 documents: Exhibit 24, which is the Kelly memorandum 19 in November '77; Exhibit 35, which is the Walters 20 response to that Kelly memorandum; Exhibit 23, Dunn's first memorandum in February '78; Exhibit 36, Dunn't g second memorandum, seven days later in February '98; and Exhibit 37 is Mr. Hallman's memorandum to Karrasch 23 in August '78. Other than those documents that we 24 just reviewed, do you know of any documents that 25 BENJAMIN REPORTING SERVICE
1 2 olds 42 3 we just reviewed, do you know of any documents that relate to the issues addressed there. which exist? 4 A No, I don't know of any others. O Q Your investigating, your inquiry has 6 turned up no other memorandum, letter, notes or -- 7 A I did not turn up the earlier ones, no. I knew 8 about the three memos and about the conversation 9 between Hallman and Karrasch. 10 Q I am just concerned that we have a com-11 plete documentary picture, and to the best of your 73 knowledge, that is the complete documentary picture? A That is the complete documentation. Q To your knowledge, Mr. Olds, were the 14 concerns expressed by any of the gentlemen in any 15 of the five documents that you have before you, which we have just summarized on the record, communicated l,' to your operating utilities before the accidenjgig }}} 18 Three Mile Island? 19 A No, not the specifics of this. 20 Q After the accident, was the prescription in the Dunn February 16 memorandum transmitted to utilities or something akin to it? 22 A Something akin to it, yes. 23 (Continued on Page 43.) 24 25 BENJAMIN R EPO RTING SERVICE
1 2 Olds 43 3 Q D yu know when that was transmitted? 9.1 sr/ew A It was transmitted within two or three days 4 after the Three Mile inciden_. 5 MR. ROCKWELL: Off the record. 6 (There was discussion off the record.) 7 (A brief recess was taken.) 8 MR. EDGAR: These are the site instructions 9 to which he referred (indicating). 10 THE WITNESS: The upper one is the site 11 instructions with all the approvals on it. The second one is a form in which it goes out gg to the customer. That is the first memo that 13 went. 14 (Documents described below were marked 15 Olds Deposition Exhibits 102 and 103 for 16 identification, respectively, this date.) 1I Q Mr. Olds, showing you what has been marke'd 18 as Olds Deposition 102, would you please identify th a.t l892 '523 19 document for the record? A Yes, this is the site instruction which was put 20 together to caution our other operating customers on x use of the high pressure injection system. 22 Q For identification purposes, this is an 23 April 4, 1979 memorandum from Fairburn to the distribu-24 tion shown on the memorandum, is that correct? 25 BENJAMIN R EPO RTIN G S ERVICE
1 o Olds 44 9.2 3 A That is correct. If I might, a site instruction 4 comes into our shop and is issued to the cognizant service managers. There is a service manager associated 5 with each operating customer. Then he converts that to a letter, such as this, 7 to each specific customer. 8 MR. EDGAR: The letter to which you refer 9 is a letter dated April 4, 1979, TMI-79-47, 10 from Fairburn to Met Ed. That is an example? 11 THE WITNESS: That is an example, yes. 12 A letter went to each of our customers in this f rmat. 13 Q We are referring now to Olds Deposition Exhibit 103. Would you identify that document, please? 13 A This was a revision to that same procedure or 16 cautionary note to allow the operator alternates to 17 the 20 minutes operability period, which wa,s specified a 0 in the original one. ') hh2 }24 ' 19 Q And for the record, the document would be 20 identified as an April 19, 1979 memorandum from 31 Mr. Brazill of Plant Integration to Messrs. Ham and Fairburn in Nuclear Service, is that correct? g A That is correct. 23 Q And then the supplemental operating insture-24 tions to which the memorandum refers is the second page 25 B ENJ AMIN REPORTING S ERvlCE
1 o 45 Olds 9.3 3 of the Exhibit, is that correct? 4 A That is correct. 5 Q And nce again there is a sample letter of the kind of transmittal used to send the supplemental operating instructions to the operating utilities? 7 A That .s correct. 8 Q There is a third page of the Exhibit. 9 A That third page is a letter. The fourth page is 10 the supplemental operating instructions. 11 Q To your understanding, was the supplemental 12 operating ins'etuction referred to in Exhibit 102 and 103 drawn essentially from the prescription that 13 Mr. Dunn had sent out in his memorandum? A I don't know that there was a direct tie. 15 Q Was the Dunn memorandum referred to when 16 the supplemental operating instructions in Exhibits 17 s' c P 102 and 103 were drafted? been.t8 9 2 'T' 2 5' 18 A I can't make that tie. It may have 19 Q Do you know, Mr. olds, whether anything 20 was done in Mr. Hallman's shop b3 tween Dunn's February 31 16, 1978 memorandum and Mr. Hallman's August 3, 1978 x memorandum, in regard to addressing the issues raised in the Dunn memorandum? 23 A Yes, there was work going on there which origi-24 nated the concerns which were stated in the August memo. 25 BENJAMIN R EPO RTING SERVICE
1 2 Olds 46 9.4 3 Q Was any of that work reduced to writing? 4 A Not to my knowledge. 5 Q Has Mr. Hallman told you specifically what they were doing during that period of four to four and a half months 7 7 A He has related to me that most of his manpower 8 was tied up in the field, and that he didn't have an 9 opportunity to work on that to the extent that he would 10 like to, plus there was another problem which was 11 causing us considerable concern at that point. 12 Q What was that? A That was core tilt. 'Two or three of our 13 operating plants were experiencing a core tilt, which didn't have a ready explanation, which has since been la, explained. 16 Q Have you talked with Mr. Karrasch about 17 his role in addressing the issues in the Dunn memo-18 randum? l 1892 326-19 A No, I haven't. 20 Q Was Mr. Hallman's group in your view the 31 appropriate group to follow up on the concerns raised in the Dunn memorandum? .o.n A .:s, to take the lead with help from Engineering. Q Showing you what has previously been marked 24 as Dunn Deposition Exhibit 38, have you seen that 25 BENJAMlN R EPO RTING SERVICE
1 Olds 47 o 9.5 3 document before today? A No, I have not seen this document. I have heard 4 of some of the information in it. O Q When did you first hear about that document 6 or about the existence of it? 7 A I would say it was within the week after the 8 incident at Three Mile. I might say that the subject 9 of the loop seal was discussed in my presence on some 10 occasions, casual conversations, not specific. 11 Q At what time was this loop seal discussed? }g A This would have been during the Three Mile incident r after the Three Mile incident. 3 Q At any time before the Three Mile Island accident on March 28, 1979 did you become aware of some-15 thing which was popularly known as the Michaelson 16 report? 17 A No, I did not. 18 Q I take it you became aware of it f.o ll o,wi n g ' f. g ( 19 the accident? 20 A Following the ident. a ny Q To your knowledge were any of the documents relating to the Dunn memorandum or the subject matter addressed by those documents, was any of that trans-23 mitted or conveyed to the NRC before March 28, 19797 24 A Not to my knowledge. 25 B ENJ AMIN REPORTING SERVICE
SR 1 o Olds 48 3 Q Have you had any conversations with anyone 4 else other than the ones you already described in regard t the handling of the Dunn memorandum? 5 A Yes. 10 lc Q Let me recapitulate so we are clear. 7 As I understand it, you have talked to Mr. Hallman, 8 and I am not sure whether you talked to anyone else. 9 A No, I haven't mentioned that I have talked with 10 anyone else. After I had taken some steps to find 11 out what was going on, Mr. Kosiba asked me to do }g just what I had been doing, and that was to get to the bottom of it and find out w.sa t had happened. g This I had done, I thought, till I saw all these memos here today. 15 Q Did you talk to anyone else besides 16 Mr. Kosiba and Mr. Hallman? 17 A No. Mr. Kosiba and Mr. Hallman, that is correct. 18 Q You indicated that the preliminary safety 19 concern reports are the proper -- 20 A In my opinion that would have been the proper way to handle this. 1892, '128 ~y n Q To handle the Dunn memo? A Yes. 23 Q Why, if that was a recognized procedure 24 here at the Nuclear Power Generation Division, didn't 25 BENJAMIN R EPO RTING S ERVICE
1 o Olds 49 3 someone,of the 12 to 20 people who may have been 4 exposed to either the Dunn memorandum or the Kelly 5 memorandum or the Walters memorandum or the Hallman em ra dum, reduce the question to that format so 6 that it would be resolved within the accepted pro-cedural framework of the Nuclear Power Generation 8 Division? 9 A I can't answer that, and I haven't asked why 10 it was done. 11 Q Mr. Olds, have you made any statements 12 since the accident at Three Mile Island reflecting 13 y ur knowledge or understanding of any of the events relating to or arising out of the Three Mile Island g4 accident, and by "a statement," I mean anything that l a, has been reduced.to writing, either something you have 16 uritten yourself or testimony or an interview which 17 you may have given which was reduced to writing. 18 A I haven't had any occasion to give any testimony. 19 We did have a visit from two of the members of the 20 NRC group, which is going through the lessons learned 31 program, but to my knowledge, that hasn't been reduced a 2 to writing. .n.o r. I892 329-Q Was it taped? 23 A No, it was not taped. They took notes, and I 24 haven't seen the results of the notes. It was sort 25 B ENJAMIN R EPO RTING S ERVICE
1 2 Olds 50 3 of a round-table discussion, if you will, not too 4 formal. 5 Q Have you written down any account of, 6 f r instance, your understanding of the handling of the Dunn memorandum? t A No, I haven't. That was all verbal. 8 Q Have you written down any other informa-9 tion relating to your understanding of events connected 10 with Three Mile Island? 11 MR. EDGAR: Like causes? 12 MR. ROCKWELL: I don't know. 13 (There was discussion off the record.) 14 Q While we have been off the record, Mr. Olds, you have indicated in response to my question 15 about statements that you have done an evaluation, which was requested by Mr. Kosiba, of the B&W response? 17 A Yes. 18 Q In the recovery period? 19 i A Yes. 20 Q could you make a copy of that available }hC)2 331 21 to us? ~ 33 A Yes, we can make that available. Q Are there any ther statements, as I have 3 defined them, which you have made since the accident at Three Mile Island? 25 BENJAMIN REPORTING SERVICE
1 2 ~ Olds 51 3 A No. That is the only thing that has been reduced to writing. Of course, we are looking at 4 our operation and have had numerous conversations .s on how can we do things better, so we can in the future handle such incidents in a more expeditious 7 fashion. There is some of that work going on. But 8 as far as I know, nothing really in writing. Let me 9 give you a "for example." 10 Q Proceed. 11 A While I was upstairs, one of the fellows came 13 to me and told me that he had finished an evaluation f ph ne sts t establish a tie line with each of 3 our operating plants. That sort of thing is going on. (A brief recess was then taken.) 15 Q Do you know of anyone else, Mr. Olds, 16 other than yourself, who has made an inquiry as to 17 the handling of the issues raised by the Dunn memorandum? 18 A No, I don't know specifically. I suspect that 19 there are others, but I don ' t know that for a fact. 20 Q D y u know anyone who has talked to Mr. Karrasch about his side of the handling of t'he g matter? 1892 931 = A No. 23 Q Mr. Olds, could you describe for me the 24 shift in your responsibility that occurred at the 25 B ENJ AMIN R EPO RTIN G SERVICE
1 2 Olds 52 3 time in February 1979 when Nuclear Services Department 4 was reorganized and renamed " Customer Service U*P"#t"*"*"? 5 A Yes. When the Customer Service Department was set up, we joined the Nuclear Service Department and 7 the Nuclear Parts Center, which were two separate 8 departments within NPGD, with the in-service inspec-9 tion organization, and our construction company in 10 Copley, Ohio, into a new department, we also broke 11 out from the Nuclear Service Department the training 12 organization, the marketing organization and the test
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"*"t ""d t 11"9 "98"i "ti " i"t thr** "*" P 13 sections, I guess you will call it, which gave Mr. Kosiba a direct line into those, as well as what 15 then became Field Engineering and Service, what was 16 remaining of the Nuclear Service Department, In-House 17 Service Inspection and Parts Center. 18 Q Tell me what shifts, if any, occurred in 19 your responsibility at the time of that reorganization. 20 A My scope was narrowed to Operating Plant Services and Startup Services, as well as a new func-gy tion of Maintenance Engineering, plus some additional unit functions directed at radiation exposure control, 23 plant efficiency, renewed emphasis on availability of 24 the plants in operation, and we have since added another o function of outage scheduling, which we presume or BENJAMIN R EPO RTIN G S ERVIC E. 1892352
1 2 Olds 53 3 would think would become a business segment. 4 Q Mr. Olds, at this time I am going to recess your deposition, leaving you subject to recall 5 for further testimony, should that appear to be 6 necessary. We don't have any present plan to recall 7 you, but if we find we need to, we will let you know. 8 Thank you very much for standing by and coming in. 9 We appreciate it. 10 (The deposition adjourned at 12:20 p.m.) 11 12 5EEEvIII; R5EEIi5E 5I22---- 13 Subscribed and sworn to before me this,___ day of 14 '979* 15 16 17 Notary Public 18 19 20 21 22 T892 333 23 24 25 BENJAMIN R EPO RTIN G SERVICE
1 2 54 3 IE9E3 4 3139ess _g{gegg 5 Granville Morrison Olds 3 6 7 8 E. X_ H_ _I B_ _I T_ S_ 9 Olds Deposition for Identification Pace ~~~-----~~~-~~~~~~ ~~^~ 10 11 100 Resume of Granville Morrison Olds 3 101 Organization chart of Project 8 gg Management Department at B&W 13 102 April 4, 1979 memorandum from 43 Fairburn to distribution shown 14 103 April 19, 1979 memorandum from 43 15 Mr. Brazill to Messrs. Ham and Fairburn 16 17 18 19 20 21 32 .? '3 i892 334' 24 25 B ENJAMIN R EPO RTIN G S ERVICE
1 2 55 STATE CF NEW YORK ) 3 ) ss.: COUNTY OF NEW YORK ) 4 We, ROBERT ZERKIN, Notary Public, and a STANLEY RUDBARG, Certified Shorthand Reporter 6 and Notary Public, of the State of New York, 7 do hereby certify that the foregoit deposition of BABCOCK & WILCOX by GRANVILLE MORRISON OLDS 9 was taken before us on the 6th day of July 1979. 10 The said witness was duly sworn before 11 the commencement of his testimony. The said testimony was taken stenographically by our-gg selves and then transcribed. 13 The within transciipt is a true record 14 of the said deposition. 15 We are not related by blood or marriage 16 to any of the said parties nor interested 17 directly or indirectly in the matter in 18 controversy, nor are we in the employ of any 19 of the counsel. IN WITNESS WHEREOF, we have hereunto set 20 -((f ~ day of July 1979. our hands this 21 18v,2 335.. j* s/ / '/ l. w. 12 _______'s ,e ROBERT ZERKIN 23 -q SEkf -Q /Y'I i / f 24 EiKNPEP R55HI C ~5fC --- 25 BENJAMIN REPORTING SERVICE}}