ML19308C397
| ML19308C397 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/25/1979 |
| From: | NRC - NRC THREE MILE ISLAND TASK FORCE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001230367 | |
| Download: ML19308C397 (51) | |
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i N U C L E A R R E G U L A T O R '( COMMISSION i
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IN THE MATTER OF:
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l INTERVIEW OF EARL NAGLE l
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NRC/TMI SPECIAL INQUIRY
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Philadelphia, Pennsylvania l
Date -
Pages Tuesday, September 25, 1979 1 - 51 i
IIbIIf Ifk f )u,'d GatiiEdub,'dih f
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ACE - FEDERAL REPORTERS,INC.
OfficialReponers 8 0 0123 0$sy V
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-Washingten, D.C. 20001 f
NATIONWIDE COVERAGE DAILY j
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CR-7248 AR I
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _x A
J Interview of:
5 EARL NAGLE 6
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _x 7
8 NRC/TMI SPECIAL INQUIRY 9
i 12th Floor Conference Room 10 United Engineers Building Philadelphia, Pennsylvania Tuesday, September 25, 1979 12
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The interview of Earl Nagle commenced at 10:00 a.m.,
and was conducted by Mr. R.
Lawrence Vandenberg and l
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IS Mr. David Evans.
16 Also Present:
Mr. Bernard J.
Smolens, counsel I7 for the witness; and Mr. William Stevens of United Engineers.
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Examination by:
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Earl Nagle Mr. Evans r
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Exhibits:
For Identification:
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Exhibit 1107
" Review cf the Three Mile Islan: Unit 2 15 j
f-Construction Project" 22
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P, 3 Q q p { Q l E Q-E MR. EVANS:
This is a deposition, or an interview
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J on the record, if you will, of Mr. Earl Nagle, being conducted 3
4 by'the NRC/TMI Special Inquiry Group.
It is being held u
at the office of United Engineers in Philadelphia, Pennsylvania 5
n September 25th, 1979, 6
Present, in addition to Mr. Nagle, is Mr. Bernard 7
Smolens, Mr. William Stevens of United Engineers; also 8
present is Mr. Larry Vandenberg and David Evans of the 9
10 SPecial Inquiry Staff.
11 Mr. Nagle, have you had a chance --
12 MR. SMOLEN:
Excuse me, Mr. Evans.
Before you 33 begin your interrogation, the first written notice that we ja had of this interview was in your letter of September 5, 1979 i
15 to Mr. Nagle, copy to me, which we received on September 10, 16 and in that letter and certain other enclosures, this was
' i 17 described as an interview, in effect, that you wanted to l
and we have l
l have with Mr. Nagle to ask him certain questions, 18 19 ;I no objection to that.
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20 In an undated letter that you handed to Mr. Nagle j
this morning for the first time, there was some written 21 22 notification that you regard this as a deposition.
I don't 23 know that there's any magic in the concept of a deposition 24 as contrasted with an informal interview, but I will state 4 AeNast Reporters, Inc.
25 that we do not regard this as a deposition.
We regard this j
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4
.-- whatever the distinction may be:-- as an informal ir.;erview i
2 with Mr.-Nagle.
3 And with that observation, you go ahead.
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4 MR. EVANS:
Off the record.
5
[ Discussion off the record.]
6 MR. EVANS:
Back on the record.
7 Mr. Nagle, have you had a chane to read the witness notification form which I had previously sent to you 8
9 regarding this special inquiry?
10 MRZ NAGLE:
Yes.
11 MR. EVANS:
And as Mr. Smolens has actually pointed 12 out today, I also gave you a letter signed by Mitchell 13 Rogovin of the Special Inquiry Staff.
Is that correct?
14 MR. NAGLE:
Yes.
15 MR. EVANS:
And you've had a chance to read that 16 letter?
17 MR. NAGLE:
I have.
18 MR. EVANS:
Do you have any objections to proceeding 19 other than those stated by Mr. Smolens?
20 MR. NAGLE:
No.
21 Whereupon, 22 EARL NAGLE 23 was called as a witness and, having been first duly sworn, 24 was examined and testified as follows:
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EXAMINATION
[
2 BY MR. EVANS:
3 Q
Would you state your full name for the record, 4
please, and your posii. ion.
5 A
Position with United Engineers?
6 Q
That's correct.
7 A
Earl C. Nagle, Vice President, Group Manager, 8
Construction Division.
9 O
Mr. Nagle, could you outline for us your involvement 10 with the Three Mile Island 2 Nuclear Generating Station as a 11 representative of United Engineers?
12 A
I was project manager for United Engineers.
13 Q
Throughout the length of the involvement of the la company with the unit?
15 A
No.
Best of my recollection, I was assigned 16 December 1970; effectively my work was completed, I think, 4
17 some time in August of '77.
18 Q
And was August of 1977 the approximate termination 19 I of the company's involvement in Unit 2?
20 A
Other than finishing up some work with our sub-l I
21 contractors, yes.
22 Q
Do you have with you today a copy of the contract 23 of United Engineers with the owners of the Three Mile Island jp 24 2 Generating Station?
Ack.J,al Reporters. Inc.
25 A
I've got a copy of the -- what I would consider i
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the original contract between UEC and Metropolitan Edison.
2 0
Would you be willing to make that available to us?
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3 A
Yes, we'll make that available.
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4 MR. SMOLENS:
Yes.
5 On the top of it, there is what looks to be just a 6
transmittal slip from a Mr. Wise to somebody else.
You can 7
read it, and then I'll tear that off.
8
[ Handing document to Mr. Evans. ]
9 MR. SMOLENS:
You're not going to read the contract 10 now, are you?
11 MR. EVANS:
No.
12 MR. SMOLENS:
I just wanted you to see that, 13 because I don't see any point in having the transmittal slip.
14 THE WITNESS:
Are you intending to carry some of i'
15 this away with you?
16 MR. EVANS: That's my intention.
17 MR. SMOLENS:
We'll set aside the things that you 18 want to copy, because we may not be giving you that one, I
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19 y but we'll give you a copy of it.
i t-20 MR. EVANS:
That's acceptable.
i 21 MR. SMOLENS :
Off the record.
(~g 22 (Discussion of f the record.]
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23 MR. EVANS:
Back on the record.
Ip 24 BY MR. EVANS:
' ALAerst Reporters, Inc, 25
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Q Mr. Nagle, did you have any involvement in bidding i
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on or ' negotiating that contract which -you have just provided h
2
.to me?
3 A
No.
4 0
When was the first time that you became involved 5
with the project?
6 A
December of
'70.
7 Q
And how did that occur?
Were you called to a meeting 8
and asked to assume the role as project manager?
9 A
Yeah, I was assigned by my boss, Mr. Rebenold.
10 0
Would you spell that last name?
II A
R-e-b-e-n-o-1-d.
l 12 O
Mr. Nagle, when Catalytic left -- excuse me, strike i
13 that.
14 When UE&C completed its work on Unit No. 2 at 15 Three Mile Island, what would be the best date for estimating 16 its completion?
17 MR. SMOLENS:
Would you read that ouestion back, 18 please?
19 I'm not sure that I understand it.
I d on ' t know 20 whether Mr. Nagle did.
i 21 MR. EVANS:
Never mind.
Let me rephrase the 1
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22 question.
23 BY MR. EVANS:
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When did UE&C, in your opinion, complete its work
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25 at Three Mile Island 2?
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A I think our responsibility for construction of
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2 TMI 2 ended about mid-August of '77.
3 Q
And what were the circumstances under which UE&C 4
ended its work at Three Mile Island 27 Had it completed what 5
it had set out to do?
'6 A
Yeah, basically the work was complete.
There were 7
still some punch list-items, some incomplete items of work, 8
which I cannot recall.
9 We did have, as I said before, some work with sub-10 contractors, insulation, some minor items of work.
11 Q
Can you recall how large that list --
12 A
I don't understand your question about what we 13 set out to do.
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14 Q
As specified in the contract.
15 A
Well, I answered that.
16 O
Can you estimate the size of the punch list items 17 which were uncomplete -- or incomplete at the time that UE&C 18 left the job?
1 1
A No, no, I couldn' t estimate that.
l 17 20 Q
Would you say it was large?
21 A
Compared to what?
22 Q
Compared to other units which you've been involved
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24 MR. SMOLENS:
Large is a relative term, and it i
A6vdsra! Reporters, lm.
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The project might be a i
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big project; the project might be a small project; and how
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-you can compare punch lists on a project this size with a 3
punch list on a project of other sizes, I don't know.
And 4
I don't know whether Mr. Nagle can do it.
5 THE WITNESS:
I think the answer to Mr. Evans' 6
cuestion has to be that I don't know at this point.
I don't 7
know the extent of it, and I really couldn't say whether it's 8
large -- it was large or small.
We'd have to do some research
)
9 on it.
10 BY MR. EVANS:
11 Q
You didn't review any documents in preparation for 12 coming here today on your involvement with the project?
13 A
Yeah, we reviewed -- I reviewed some documents, but 14 not specifically that.
15 MR. SMOLENS:
I think what Mr. Nagle tried to do 16 was to assemble as many of the documents as were called for 17 in the September 5 thing.
I don't know whether he reviewed 18 them or not, but I know you did try to get them together.
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BY MR. EVANS:
20 Q
Mr. Nagle, let me just ask one last question in 21 this area and then leave.
- (~N 22 So you don't recall a number, a ball-park number, l
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24 A
No, I do not.
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To your knowledge, was UE&C replaced by another l
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contractor at the Three Mile Island 2 unit?
~2 A
Yes, another contractor was brought in to finish
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up the incomplete items and to do maintenance work.
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4 Q
And -do you know the name of that contractor?
5 A
Catalytic.
6 MR. SMOLENS:
Mr. Evans, you used the word 7
" replaced."
I wonder if that is a correct concept, or was 8
Catalytic to pick up the maintenance aspect of the project, or 9
was the word " replaced" correct?
10 THE WITNESS:
As far as I'm concerned, you know, 11 unless we're going to fool-around with semantics, why, 12
" replace" is okay.
You know, the --
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13 MR. SMOLENS:
Okay.
U 14 MR. EVANS:
Let's go off the record.
15
[ Discussion off the record.]
16 MR. EVANS :
Okay, let's go back on the record.
17 BY MR. EVANS -
18 Q
Mr. Nagle, did you have any contacts with the people 19 :
from Catalytic as there was a change in the contractor at i
20 l the Three Mile L21and 2 site?
21 A
UE&C?
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22 Q
That's right.
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Yes, we did have some contact.
We had interface i
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Could you describe that interface?
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A Well, I started out with a meeting between
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-GPU,' Catalytic and ourselves, GPU describing what they wanted
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- 4 responsibilities were to GPU and Catalytic.
That was a 5
meeting -- I don't recall when it was -- I was at the meeting,.
6 the GPU project. manager was at the meeting, and the Catalytic --
7 I presume he was a project manager -- was at the meeting, and
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8 we set up some ground rules and broadly defined the scope of I
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the work remaining, that is the incomplete construction, because 10 l the maintenance was not our responsibility at any time.
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12 il additional meetings bringing additional people in, lower
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level supervision, to effect an orderly turnover of the 13 I4 !t responsibilities to GPU-Catalytic.
15 O
Do you recall when that meeting was in rough dates?
16 A
I don't really recall.
If I had to guess, I'd
? ;1 F ay it was probably early
'77.
E-Q Fine.
Do you recall the names of the people that attended the meeting other than yourselves?
You mentioned the GPU E
project manager.
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A Okay, now, we're talking about the first meeting I~
23I that I can recall and that was myself, Dick Hewert, R. W.
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A Catalytic's man's name.
I think Bill Gunn, William Gunn, was 25 m
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was there.
I think his title at the time was site project 2
manager for GPU, reporting to Hewert.
And I believe Toger 3
Reynolds was there with me.
4 MR. SMOLENS:
Excuse me.
Now you've been saying GPU, 5
Earl, and I know that in the wings there is also GPUSC.
Now 6
when you say GPU, do 2 mean GPU or might you in some of 7
these instances be meaning GPUSC, which, as I understand it,
?
8 as a separate, although wholly-owned, corporation?
90 THE WITNESS:
Well, Hewert and Gunn, to the best i
10 j of my knowledge, worked for the Service Corporation.
11 MR. SMOLENS:
Okay.
12 y MR. EVANS:
Let me state for the record we i
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13 understand the relationship between GPU and GPUSC and we will 13 14 lj take that into account.
15 BY MR. EVANS:
16 :
Q I'm curious, Mr. Nagle, in knowing when you were l
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f'firstinformedthattherewasgoingtobethischangeof l
contractors -- constructors, excuse me.
A Well, I'm guessing again, but it was probably nine months to a yecr prior to that, effecting this in August of l
'77.
- so it goes back about a year prior to that.
It wasn't i
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22lilany surprise.
We didn't know it was going to be Catalytic, 23 but we did know we were going to follow the procedure we did l
h 24 on Unit 1, wherein we carried the construction to a certain l
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25 ; point in completion and a maintenance contractor was brought i
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-aboard to finish up whatever construction items remained, plus 4
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take over-the maintenance.
But that's a guess.
.I don't know 3
when I was first informed of it.
But it wasn't
-- it wasn'.t-a-
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4 surprise, by any means.
We did that on Unit 1.
We had. reasons 5
for doing it on Unit 1.
It worked well on Unit 1 and I'd 6
say, you know, we had no problem that they were bringing this 7
contractor onboard.
We expected it.
8 But as far as when I was first made aware that we 9! were going to do it, hell, it might have gone back two or
- 10 l t three years to when we were doing.t on 1.
11 !
Q Was your arrangement with GPU such that that --
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determining when that change would be made was flexible?
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A I don't really recall whether it was flexible.
I 14. kind of think it was -- we picked a point in time and from 15 il our schedule, work would be complete, construction work would 16 l l
be complete to a point.
And that was established by the
..I hscheduleasitwasatthattime, and as far as flexible, I suppose it might have been flexible, but I really think we L
picked a point in time and at that time point we effected the change.
O Could you estimate for me what percentage of
/~'T 22 ' construction was complete at the time that you left the site?
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23 0 A
That's kind of difficult.
I'd say, as a guess,
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24 90 to 95 percent.
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O How does that compare with the completion, the l
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amount of construction that had been' completed on Unit 1 when
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1.d say Unit 1 was in.a more advanced state of
(")h 4-completion.
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Q Do you have any explanation for the difference, or 6
is that just a matter of different sites?
7 A
No, I. don't have any explanation for it, for the 8
difference.
9 Q
Mr. Nagle, this replacement which we've been talking Nl about of UE&C with Catalytic, if you'll allow me to use that II broad term, do you have any information that it reflected I,
some dissatisfaction on the part of GPU or any of'its
- 1 13
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operating companies with the performance of UE&C?
I4 A
No, I have no information of that nature.
I never 1:
15 ' even heard that.
16 Q
Are you aware --
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A I might add one thing:
Going back to what I said d ' earlier, this is a plan devised on Unit 1 between us.
We collectively thought it worked effectively on Unit 1, so we followed the same plan on No.
2.
And as far as any dissatis-J faction with UE&C,'
I have no knowledge that that entered into
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this decision at all.
22 22 I would think to the contrary. I've never heard i'
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any dissatisfaction expressed as a reason for bringing l
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, Catalytic in to replace UE&C.
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~1 Q
Do you know if when Catalytic came on to the site, m,)
2-it had a number of tasks to do which might be more properly 3
called construction rather than maintenance?
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4 A
I don't recall specifically, but I.would say yes.
5 In addition to maintenance, as I understand it, there were 6,
items of work for Catalytic to do that didn't fall under my 7
definition of maintenance.
There were completion of construc-8 tion.
9 Q
Was that true also for Unit No. 1, that there were 10 matters for, I believe, the maintenance constructor --
II contractor there was Gilbert?
12 A
Kraus.
13 Q
Kraus, thank you.
Was it true that Cross also had G("T I4 things which might more properly be called construction tasks b
15 than maintenance tasks?
16 A
No.
Again, in my opinion, when Kraus came onboard
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on Unit 1, there were only very minor completion of construc-i tion items to be done, and in fact, we might have completed them, fence security, and that type of thing.
I-So, basically, when Kraus came onboard, in my 2i opinion, their function was mainly maintenance.
22 l Q
Do you know whether after Catalytic took over work
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2, it retained some of the craft labor which you j
24 '
had originally hired for the project?
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j 25 A-Ho, I don't know for sure, but I would suspect that t
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they hired people that had previously been in our employ.
2 I mean, you know, it's an area labor pool, and 3
Catalytic ~ operated union, the same as we did.
So the labor
'4 pool would be, I would assume, the same labor-pool.
They used 5
the same labor pool we did.
I don't know that we actually --
6 well, period.
I guess that answers the question.
I don't 7
know who they hired, but I'm assuming they hired the building 8
trades people from Harrisburg.
9 0
I have just one last question in this broad area 10 of transition, and that is that I don't really understand II ! how it worked between UE&C and Catalytic and GPU.
It's my 12 ! understanding from what we've talked about today that perhaps 13 90 to 95 percent of the construction was complete, but there 14hwasstillsometobecompleted.
i 15 Catalytic was principally a maintenance contractor:
16 came in, and had to assume some construction responsibilities.
t "lj Who directed the craft labor, if you know this, in completing ti 1
those projects which were still open when UE&C left the project?
A I don't know.
1 I
2-MR. EVANS:
Could we go off the record for just a i
21 minute?
22
[ Discussion off the record.]
\\
l dq MR. EVANS:
We can go back on the record.
i b) 24 BY MR. EVANS:
' Act -Jerd Reporters, Inc.
i 7'c Q
Mr. Nagle, I'd now like to turn back to your initial i
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1 17 i
1 involvement with the unit, with the project, with GPU.
()
2 Was there a master schedule set at_the outset of 3
your contractual dealings with GPU?
(_-
4 A
Well, I wasn't involved with it at that point.in 5,
time, but I assume there was a master schedule or target 6
schedule.
7 Q
Did you ever see a copy of that?
8 A
I don't know if I saw a copy of the original.
I 9
have some schedules here in response to your request for 1
10 schedules, and I've gotten together everything that.was 11 j available, and we do have some very early schedules in this 12 ! package, and also some of the.later ones.
13 0
Once you became involved with the project, were
)
14 you involved in setting the schedule?
h 15 A
Yes.
16 0
And did the schedule change substantially through "hthecourseofyourinvolvementwiththeproject?
.I A
Yes.
O Who would work out schedule changes?
A Well, that would be a combined effort between UE&C 1
21 and GPU, as far as the scheduling of the construction work.
i I
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23 Or the scheduling of the suppliers under contract to GPU.
But
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'2 the construction schedule would basically be formulated by Ad+ do nnenen. ine.
25 UE&C, reviewed with GPU, and approved by both of those.
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Q When you say GPU, could you name who your contacts p
2 were in setting that schedule?
v 3
A Yeah, the people tnat signed the schedule, myself O
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and:Mr. Hewert.
After Hewert became project manager.
Subsequent 5
to that, there was a fellow named George Bierman, and I think 6l*he was onboard about a year, after I was assigned, say roughly 7
through '71.
I don't know when Hewert came onboard, actually, 8
as project manager, but I think it was about a year after I was 9
assigned.
0 So if I understand the process, UE&C would draft a 10 schedule for its construction work, then would meet with GPU l
U! and eventually get approval for the schedule that had been set?
A Right.
Br adly that's correct.
O O
Would GPU in any way affect the schedule which you Id I
15 had drafted?
Ask you to move it up or slow it down or modify I6 l it to meet their pacing items?
+
A I think the answer to that has to be yes.
2 O
Could you generalize whether there was a desire on i
the part of GPU to speed it up or slow it down?
E Let me clarify by completing that.
To slow up or q
, speed down the construction schedule which you had set and 2I 22 h, brought to them.
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23 ji A
Not any more than what I would consider normal Q
24 under the projects that I've had.
You have to recall they Aca44 ret Reporters, Inc.
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25 had control or were responsible for the pace of engineering.
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Their review might factor in some things that we weren't aware 2
of.
Engineering, availability.of engineering information, 3
you know, might tend to slow the schedule down.
As we
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conceived the construction schedule, the information might not 5
be available when we needed it, we'd have to modify schedule 6
to accommodate.that, or they'd have to modify the engineering 7
schedule to accommodate the construction schedule.
8 Q
If I understand what you are saying, engineering i
9!
information and services were the pacing item?
10 A
No, they could be.
They were not always.
They "b could be.
U You were talking about GPU review of the schedule 13 dictating an acceleration of the schedule or retarding of the Id schedule, and I think the GPU input was based on the real life, 4
15 what was going"on, rather than some arbitrary decision that, 16 you know, we want it sooner.
IIl Q
As the project progressed, did the availability of the nuclear steam supply system affect the schedule which you were working under?
l A
You want to explain that a little bit more?
Q Simply did the availability of the B&W portions of E
3 i
22 the plant, when those units -- when that equipment could be 22 delivered to the site, did that affect the construction which
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you were doing to prepare for that equipment?
.I 24 F Ace.v~ eral Reporters, Inc.
MR. SMOLEN:
I guess maybe what Mr. Evans is getting !
25 I
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at, what Babcock & Wilcox was doing or didn't.do, did that in AV 2
any way affect your schedule?
Did it slow you up, just to get 3
right to the nub of the thing?
(~)
4 MR. EVANS:
That's right.
5 THE WITNESS:
I don' t ? call that it did, but. I
-6 don't recall that it didn't.
7 BY MR. EVANS:
8 Q
Did corporate financing problems affect your 9
schedules?
10 MR. SMOLENS:
Whose corporate financing?
II MR. EVANS:
Excuse me.
GPU's financing problems U! or financing concerns affect UE&C's scheduling?
O I
MR. SMOLENS:
Assuming they had any.
Id THE WITNESS:
I guess you're talking about cash 15 flow availability of flow, whatever.
I don't know whether 16 they had problems or not, but there was the availability of money -- did affect the TMI 2 schedule, starting in '74, and we have got some -- I have got a summary which you haven't I
seen which I think if you would have no objection, we could e
i turn over to these people.
E, It's a history of the schedule, okay?
We have O
" Ij the scheau1e e=a vou w111 see wae= vou review them, thet --
' J,i
-- g let's call it the original schedule, it's the earliest e
()
schedule I could find.
The completion date, whether it's Ach edirot Reporters, Inc.
{
25 fuel order or commercial operation, is significantly earlier i
l I
d 1
21 I
on'that than it is on the later one.
And we've got a history 2
of.that, to'the best of our ability to accumulate it, and it 3
. asn't accumulated fo. purposes of this meeting.
It was a w
O L/
4
-history that we wanted to have and we do have of our assessment, 5 ! UEC assessment, about what' impacted the schedule, what stretched 6
it out.
7 MR. EVANS: I'd appreciate receiving that, e
8
[ Discussion off the record.]
9 MR. EVANS:
Back on the record.
BY MR. EVANS:
1 II Q
Off the record, Mr. Nagle, I believe you were talk-II I ing about the budget which GPU put United Engineers on in 1974.
13 Could you describe that a little bit more?
,f A
Well, to the best of my recollection, it was some i
15 l
time in mid
'74, probably in a meeting, whether it was formal.
or informal, GPU informed us that the funds available for
,fThreeMileIslandwerewhatevertheywere,werethusandso.
And as I recall, there were, oh, maybe-seven or eight broad 4
)
categories that they had determined and they had budgeted the l
~~
available -- what I assume were available funds for Three
't 2
Mile Island.
They budgeted them in seven or eight broad p
O
'lcetesoriee=awesetaooe=arevieeaitwiththem, e=a U N they wanted us to make an assessment of what impact this would t
)
i have, if any, on the schedule, and we did that.
4 Ach.Arst Reporters, Inc.
l 25 i
0 If there were financial concerns at GPU with regard j
L l
1
22 I
to-its impact on Three Mile Island 2 unit, how would you become 1
1(~)
2 aware of that, other than through the budget which you were put x-3 on?
()
4 A
That,'s the only method, the only thing I could 5
think of.
6 Q
Mr. Hewert, for example, didn't have discussions 7
with you as to the financial problems that the company was 8
having in financing Three Mile Island 27 9
A No.
You know, problems is your word, but I don't 10 think we had any prior to this point in time -
I'm talking i
II I about mid '74 -- to the best of my recollection.
I don't i
12 ! recall any discussion with Mr. Hewert to that end, but we did 13 sit down, as I say, with Hewert some time' in mid '74, and 14 reviewed this GPU situation as they determined it, and we i:
15 worked to that end. - They established a budget, reviewed it 16,
with us, and asked me for whatever impact that would have on i
~!! the schedule, if any.
MR. EVANS: I'm going to ask the reporter to mark as Exhibit 1107 a report entitled " Review of the Three Mile 1
I i
E Island Unit 2 Construction Project," prepared by the Touche, 21 j! Ross & Company.
?
22
[The document referred to was
)
f, 23h.
marked Exhibit 1107 for
~
^, e t identification.]
e As(s) erst ' eporters. Inc.
l 25 I
L l
l I
23 1
BY MR. EVANS:
2 O
Mr. Nagle, just let me ask you, have you ever seen a !
[)
3 copy of what's been marked as Exhibit 1107?
I r' 4
A
[ Witness examining document.]
5 No.
6
[ Discussion off the record.]
7 MR. EVANS:
Let's go back on the record.
8 BY MR. EVANS:
9 Q
Mr. Nagle, you told me that you've never seen a 10 copy of Exhibit 1107 before.
Did you have any involvement II in the preparation of that report or any discussions with the 12 ll people who prepared that report?
i I
')
13 i
A Well, I haven't seen it, and I don't know what's in
%. /
\\
14
! it.
We did have some discussions with Touche, Ross relative 15 to Three Mile Island.
P 16 ll MR. SMOLENS:
Whether it went into this report or l
?
not, you don't know?
ThE WITNESS:
That's what I said, I don't know I
what's in it, so I don't know whether that went in
'c, but we did discussion with them relativa to Three Mile.
I 2
MR. SMOLENS:
Off the record.
ll 22l
[ Discussion off the record.]
(')s
\\_
i 21,;
MR. EVANS:
Back on the record.
j eserd Recorters. fnc.24 ll BY MR. EVANS:
i Am 25 C Q
Mr. Nagle, I have a few more questiens in this area.
I!
a 24 I
What role did Burns & Roe have in setting the O
y 2
schedules at Three Mile Island 2 while you were involved in 3
the project?
(
4
'A Well, Burns & Roe, as you must know, was the owner's 5
engineer for Three Mile Island 2.
They -- speaking for the i
6 period of time I was associated with the project, the construc-7 tionoschedule, preparation of construction schedule, the construc-8 tion schedule, was -- the preparation of it was the responsibility 9
of United Engineers, as I said earlier, reviewed with GPU and 10 approved by GPU and by myself.
Burns & Roe didn't have any direct -- they didn't have II N! any people working on the preparation of the construction O
eneau1e, but rer ene1r ro1e, tuer, e==ume, a a e I
schedule of their engineering and the output thereof.
4 15 MR. SMOLENS:
I think you said before that what 16 Burns & Roe did, although you may not have mentioned them by
- name when you spoke earlier, what they did, did have some d-impact on scheduling on constructich.
What Burns & Roe did
~
or didn't do, or the speed with which they did it THE WITNESS:
Specifically he was asking as far U
as the preparation of the schedule.
I think that's what you ji 1
O 22kseia,orwestheemywora2 i
23 h MR. SMOLEN:
No, that's what Mr. Evans asked.
f THE WITNESS:
Maybe that was my words.
Obviously i
l b l
l Aw, emro neoonen, anc.
the pace of the engineering output impacts the construction l
l 25 I
i I
l' 1
i
25 I
schedule.
This was factored in by GPU.
i 2
BY MR. EVANS:
3 O
Let me just ask directly:
Did Burns & Roe repre-4 sentatives attend meetings that you had with GPff, in which S
construction schedules were discussed?
6 A
Yes, from time to time, right, they did.
7 0
Were those meetings held on a regular monthly basis, 8
or just at random intervals?
9 A
No, we had regularly scheduled monthly project 10 review or progress review meetings with' Burns & Roe, GPU, i
II l UE&C in attendance, and of course we discussed schedules at those 12 l meetings.
13
()
Q From the earliest date of your memory with this Id project, do you recall what was set as the date of commercial 1:
15 operation of Unit 27 16 A
No, but I think we can find it in these -- either
.t ij that document we were referring to earlier, or in this stack of schedules.
r l
0 To your knowledge, did that date of commercial i
i
... operation slip through your involvement with the project?
l 1
2
A It didn't 'slhp because of my involvement, but while
()
22 h I was involved, the commercial operation date, if that's sil
" q what we want to use, did slip.
2 I
()
Q What is your understanding of the term commercial
.A m n ~ W S R ne n m.tnc 25 i
operation?
i i
I l
I l
26 1
A My understanding of commercial operation is the (j
2 plant is capable of 100 percent output and it's integrated 3
into the system.
(i
')
4 0
By integrated into the system, do you mean synchronized 5' with the grid?
6 A
Yeah.
Uh-huh.
It's available for 100 percent 7
of power, it's available for use by the system.
Commercial, 8
that's the first time that the 100 percent power is available, 9
and is integrated into the grid.
That, to me, would be 10 commercial operation.
I'm not sure that's everybody else's l
II !
interpretation of it, however.
I 12 !
O Again, focusing on the time where you were beginning fworkontheproject, did you have any difficulty in recruiting 13
(;
i la l craft labor that was necessury for a project of this size?
15 Let me specify:
difficulty recruiting labor for 16 Three Mile Island Unit 2.
l
'~ j; A
The best that I recall, I don't believe we had 2
any problem in manning with craft labor the Three Mile Island 2 effort.
I 0
You use all union labor, I believe you've said
.,before?
- l
(}
22 d A
That's correct.
l m/
l
" pl Q
What is, in your opinion, or what was the most l
24 difficult union to deal with in obtaining enough craft l
9ed RHerms Inc.
l An-
?
e 25 laborers for Unit 2?
i l
I 27 I
A I'll say again, to the best of my recollection, (3
bti_/
2 I don't think we had any particular problem in manning Unit 2.
3 At one point in time, we did have difficulty obtaining 4
steamfitter-welders, but I don't recall whether that was Unit 1 0
or Unit 2 combination.
6 To the best of my recollection, I don't think that 4
7 had any impact on Unit 2 schedule, and we solved that problem.
8 0
How did you solve it?
9 A
We solved it by dealing with the local union and the international.
We also advertised, set'up a recruiting 11 campaign, brought welders in from other parts of the country, 12 l if you will, with the cooperation of the UA, United Association,
)
13 and the local.
14 j Q
Mr. Nagle, are you familiar with an incident c
15 involving a faulty weld that was uncovered in an anchor bolt at Unit 2?
II A
No.
Q Were you aware that the NRC investigated such a faulty weld?
~ ~ ;i A
No.
4 2
O Are you aware of when I say anchor bolts -- let me O
- ,ask, are those everywhere in the unit, or in egecific erees of 22 23 f; the. unit?
I A
No, anchor bolts are throughout the plant.
Acs-ed Rmonm, i.
Q One last question in this area:
Were you contacted i
l
28 1
by anyone from the NRC in March of 1978 in co.mection with 7-j 2
an investigation into welding that had occurred at Unic rio. 2?
3 A
No, I parsonally wasn't contacted by NRC relative j
4 to welding on Unit 2, and I doubt, best of my knowledge, no 5
one in UE&C was.
6 Q
I'd like to turn to a slightly different area now 7
and ask you a couple of questions about the subcontractors 8
who worked with UE&C at Unit No.
2, and I'd like you to 9f explain briefly, if you can, what area of respons'ibility or 10 l work these subcontractors were involved in.
II Could you tell me what AC&S, Incorporated did under El subcontract with UE&C?
(
13 A
To the best of my knowledge, AC&S is an insulating
! company, and they did certain portions of the insulation.
Id 15 MR. SMOLENS:
You used the phrase, Mr. Evans, 16 "under subcontract with UE&C."
Sometimes these people, as I l
l 1
'~]understandit, may have worked as subcontractors for UE&C, but because of the nature of the UE&C's operation, very often they would be direct contractors with the owner.
1 i
Now I'm not sure as to the status of the company 2I that you just mentioned, whether they would be a subcontractor 22 or whether they would be a direct contractor with the owner.
l 23 l BY MR. EVANS:
i 9eral Reporters, Inc.
a O
Let me attempt to avoid the legal distinctions Ace-r t
25 and just ask what you know of their work at the site.
l t
I,
29 1
Can you tell me what Conam Inspection Division of (f
2 Nuclear Energy Services, Inc.f did at the site?
3 A.
The main thrust of Conam's work was the non-m 4
destructive testing.
5 0
Can you tell me what Oliver B. Cannon & ~'on, Inc.
6 did?
7 A
Painting contractor, special coatings.
8 Q
Can you tell me what M.
J.
Doyle did at the site?
9 A
Heating, ventilating and air conditioning.
10 Q
Mr. Nagle, did UE&C prepare a final report, either i
II I to GPU or for internal distribution, on its work at Unit No. 2 12 af ter it completed its responsibilities there?
13 A
When you say final report, any kind of final report?
[}
14 Q
A summary of its work and involvement at the site.
15 A
Well, we talked earlier about a summary of the /
16 schedule, okay?
We also have a final revised estimate and
- cost report prepared in accordance with the format that GPU I h established.
Best of my knowledge, these two documents are the T ' only ones that fit the general description of what you're i
21 ' talking about as far as final report.
(T 22 Q
Did GPU request from you a specific report after s/
23fyourworkatthesiteended?
[)
24 A
Yes, and that's the one I referred to.
We call it as
-a n.,-
25 the Metropolitan Edison Company TMI Nuclear Station Unit No.
30 I
Final Revised Estimate and Cost Report.
2 Q
Is that in any way comparable to a final accounting 3
of the contract, monies owed between the parties?
(
)
'o 4
A Which parties?
5!
O GPU and UE&C.
6 A
No.
7 Q
What is its purpose?
8 A
Its purpose is it's basically a history of the cost 9f estimate, if you will.
I guess that's not correct. It's i
10 the final cost report and revised estimate.
II Q
And you're willing to make that available to us?
I2 l A
Sure.
Well, not today.
I don't know how in the
()
13 hell we're going to reproduce that, but we can make it available.
xs if Incidentally, all the documents that we have are 14 15 also in the possession of GPU, to the best of my knowledge.
16 i At least they were given copies over the course of the job of
" [ all the documents that we're looking at today.
l
'* R. SMOLENS:
I think what Earl's getting at is I
you may nave -- I don't know, either you or some of the other folks working on this, may have some of the stuff that you're q asking us for.
Not that we will use that possibility as a E
i 22 [I reason not to furnish them, I don't think.
l J
22 d BY MR. EVANS:
1 Q
Mr. Nagle, let me ask you if any of the reports 7
A
.d Ruonm, lu.
l I
25 !contractedtobuildaplant, and he's asking, you know, when
-41 I
did we expect to leave?
At fuel load, commercial operation,
~
f3 2
y so forth?
Is that what you're asking?
3 MR. VANDENBERG:
Exactly.
4 MR. SMOLENS:
And what I was suggesting was that 5
your notion as to when you would be leaving or when you would
'6 be completed, your notion as to when that would occur would 7
change from time to time, I thought.
Or am I wrong?
8 THE WITNESS:
The date would change, right.
9 MR. VANDENBERG:
The date would change, but would 10 the event change?
1 THE WITNESS:
I don't think the event would change.
I l
Now let me just reiterate what I said. You know, 12 O
' ata='t e rt1cie te i= writi=e the co=*r ct-o e=e== z 4
I#
don't know really what the intent was of the contract, but I t!
15 would assume the intent was that we were to carry the construc-6 tion of the job from whatever the -- you know, construction 1
f
"!, permit, or we did some limited work authorization type of 4
!! stuff from the time we actually started to work in the field through commercial operation, my definition of it.
Recognizing I that, you know, basically -- not basically.
If you're going 2: q to load fuel, the plant is complete.
Okay?
So the way I O
u=aer te=a tai du i=e==
e=a the wer : ve worxea o= thie
. ji
" d and other nuclear plants, at fuel load construction is a
b l complete.
You're not going to get a permit to load fuel if Acewerci Reporters. Inc.
l 25, your construction is-not complete.
Okay?
I
42 1
We did have, perhaps not when that contract was
()
2 signed, but we did have some people involved under the direction 3
of GPU in their test and start-up. program, probably even through
~
)
power range testing, but saying again it would be my assumption 4
5l when we contracted to do the work, it was from start of the 6
construction through commercial o'peration.
At that point in 7
time we were finished, recognizing that we had very, very little, 8
input other than start-up engineers working with GPU from 4
9 fuel load to commercial operation.
I 10 BY MR. VANDENBERG:
11 Q
During the last couple of years when you were 12 there at the TMI site, who was your prime contact from the 13 GPU companies?
[}
14 ]
A Mine?
b 15 '
O Yes.
16 A
Dick Hewert.
Q And could you also describe your contacts, Mr.
l
'.2. Nagle, with NRC during your time you had responsibilities for 3
TMI 2?
MR. SMOLENS:
Mr. Nagle's personal contacts?
i 21 ;
MR. VANDENBERG:
Yes.
22 MR. SMOLENS:
Okay.
}
23 ;
THE WITNESS:
Well, I had very little direct c
24 contact with NRC.
You're talking about me, personally, or l
(~}
, www.mi peponm. ine.
{
25 the UE&C organization, or both?
~.
43 I
BY MR..VANDENBERG:
2 O
Why don' t we do both?
Let's do both.
x 3
A Let's do both.
That's easier.
O N.
4 We had no direct contact with AEC or NRC at Three 5
Mile Island, other than through the owner.
Basically our 6
contact was during the periodic audits, NRC audits.
We were 7
asked to participate in whatever manner-the owner decided was necessary in the audits, and
'the exit interviews, and a 8
9f disposition of any findings.
10 There was no unilateral associr. tion or contact i
II I between NRC and UE&C.
That's to my knowledge.
.O When you say unilateral, you mean any contacts,
{}
that you just decided to contact NRC, and there was none of 3
I
,fthat?
15 A
Not to my knowledge.
16 0
Were you present for any testing of components or I other kinds of testing of equipment at TMI 2, as opposed to f
the construction?
A UE&C?
"~
Q Yes.
2i ;;
A We did -- we had a -- some 30, 35 test and start-()
up engineers working directly with GPU.
This was separate 22 1
from our construction effort.
I f~3 24 O
Under a separate contract or part of the same Acie,+ crol Reporters, Inc.
-25 l contract?
l I
l
44 I
A I think it might have been an amendment, okay?
And nk-it might have been an amendment to this contract or to Unit 1 3
contract, I'm.not-sure.
But that's immaterial.
But the point O)
(.
4 is we did have 30, 35 test, start-up people working on the 5
GPU test, start-up' organization under the direct supervision 6
of the GPU test. superintendent, if you will.
7 O
And they may have been working on Unit l?
8 A
They worked on Unit 1, they worked on Unit 2.
9 0
Thank you.
10 Did UE&C experience any difficulties in purchasing 11 t'
materials that were needed to construct TMI 2?
12 l A
What sort of difficulties?
m 13
)
Q Difficulties in getting materials on time; difficulty 14 in obtaining materials at all; difficulties with quality.
a 15 A
I think the answer to all those has to be yes.
16 I don't think they were abnormal difficulties, but, you know,
.t"!i obtaining materials is always a problem.
Timely delivery n
thereof.
i-0 Was there one kind of material that was especially a
- problem?
-mp A
Not that I recall.
We didn't, you know, we didn't 22l1l purchase everything for Three Mile Island, and I'm not
(~N s,)
i 23 l!l prepared to list things that we did buy.
But in general, the t
n 24 u engheered -- what I call engheerd hems were puchased Ace +Jurci Reporters, Inc.
25 by the owner to specifications written by their engineer.
l l
l
45 I
Nuclear. steam supply system is one; turbine generator pumps, 2
valves.
In the main, any of_that engineering equipment was 3
purchased by GPU.
Actually it was purchased by the member (m
4 companies, either Met Ed or Jersey Central, to requisitions 5
by Gilbert or Burns & Roe.
6 We did buy some valves, small valves, reinforcing, 7
that type of thing.
But I'd say we didn't have any more than 8
the normal difficulties.
9 0
Do you recall who the UE&C purchasing agents were 10 for the TMI 2 project?
Il !
A Well, we had some -- we had Home Office purchasing.
l I2 !
What do you want?
Names?
13 0
Yes.
l I4 j A
Home Office Purchasing, our purchasing manager is 15 Ed Case.
Home Office buyer, early on, I think was Art Gilbert, 16 and we have field purchasing agents on most of our jobs, and
.!g we did at Three Mile Island 2, and we had several during the U P course of the job.
Joe Cane, and any of the other names escape me.
But we had three or four others.
I O
I have one last question, Mr. Nagle.
Could you 1
E describe the change, if any, of the responsibilities for c
c==tr"cti =
2
#9 uz'c cro service c re reti
"a O
23 (( Metropolitan Edison, as the project progressed?
b-24 1
A Do you want to restate that?
I don't understand Acolerst Reporters, Inc.
25 what you mean.
3 l
l I
46 I
O Did you see any change in the division of
/*
(_)
2 responsibilities for completing TMI 2 among UEC, GPU Service 3
Corporation, and Met Ed?
Did one of those companies perhaps O
4 take a larger share of overseeing or directing the project?
5 A
Compared to Unit 1, did you say?
6 Q
No, just compared to the time you started your work 7
there.
O MR. SMOLENS:
Larry, I take it what you're asking 9
Mr. Nagle is whether there was during the time that he was 10 involved in the project, a shifting of responsibility from i
11 ' one or another among those three entities that you mentioned.
Is that what you are asking?
(}
13 MR. VANDENBERG:
That's another way of saying it.
lf MR. SMOLENS:
Whether there was any shifting of L
15 responsibility to or from UE&C, Met Ed, GPUSC, I think were 16 the three.
'q THE WITNESS:
Well, I only go back to December '70.
At that time, as I mentioned earlier, I dealt with the Met Ed l
project manager,
-ay?
GPU Service Corporation, I had no' contact with him.
I've not even sure they had a service 2
9 corporation at that time.
And I think that continued for
(}
about a year with this fellow Bierman.
He was the project 22 3
23 0 manager for Met Ed, if you will.
1
' (~)
24 Ad.c./ero Reporters, im.
Subsequent to that, the service corporation was
{
25 to the best of my recollection, and they changed
- formed, I
I I
~
47 I
the management of the project from Met Ed to GPU Service Corporation.
And at that time Bierman left, and Hewert came in.
2 3
He was an employee somewhere in their system, but he wasn't project manager for Three Mile Island 1 and 2, when I first d
5 got onboard, and I think it was about a year later the 6
service corporation was formed and implemented.
And some time 7
shortly thereafter, Hewert was assigned as project manager, 8
and Bierman went elsewhere.
9 That's the only change that I can think of.
10 BY MR. VANDENBERG:
i Il !
O Did that change affect the kind or quality of l
UldirectionthatUECwasgiven?
O A
Ye h, I think it did.
At least the change in individuals.
I don't know whether it had'anything to do with I
I#
I is 15 the corporate change or not.
But, you know, in my opinion, 16 Hewert was a more astute manager than Mr. Bierman was.
i BY MR. EVANS:
I Q
Final question:
You mentioned the involvement of UE&C test engineers.
I [ Did you receive reports from them in addition to their direct i
2'.[ line authority to the GPU people?
22 A
Let me try to answer that this way:
22' The best that I recollect, they got their (O33
3 technical direction and their day-to-day work assignments from Ac.,wu.i aeponm. inc. 4 l GPU test supervisor.
They were on site, they were UE&C 25 t
- - ~... _ -
48 I
employees, so administratively we controlled them through
)
2 our resident manager.
I don't recall receiving reports 3
directly.
Reports would be available to me.
I may have 4
received copies of them, but I'm sure that the -- I'm not S
sure what kind of reports you're talking about.
There were i
6 many kinds of reports, but the -- we have a manager of that 7
test start-up group in the home office, and all of our test 8
engineers are assigned to projects by him, and they work -- they 9
report directly to him.
10 l So in this case they'd be working their day-to-day i
11 { work at Three Mile Island under GPU test supervisor, but they 1
12 1 also have a parallel reporting responsibility back to their
()
manager here in Philadelphia, which doesn't mean that every 13 Idjreportthatwasgenerated--atleastIdon't think so -- came il 15 back here, but they were all available.
16 O
And you personally didn't look at those tests --
i
.. llwhen I mean report, I mean the results of the tests which they h
d'.were involved in, and it's my understanding that those might find their way back here.
A Yeah, they could be available, they could find i
2I J their way back here.
e
()
22 h MR. SMOLENS:
This is start-up testing we're 23.ltalkingabout, is it?
a
.(
2#l THE WITNESS:
Yeah, I kind of think that -- yeah, I
Aerward Remrters, loc.
l I
25 test results and so forth were not reported on a case basis i
l
49 I
back here.
I'm sure there was a reporting responsibility on r.
(]
2 a monthly basis or a weekly _ basis between our.had test l
3 start-up man and his manager back here in Philadelphia.
's) 4 As far as I was concerned, there was,no great need 5
for me to get reports of the test start-up program.
It 6
wasn't my responsibility.
It was the responsibility of the 7
test start-up program, lies sclely with the GPU Service 8
Corporation and test superintendent.
9l BY MR. EVANS:
1 10 l Q
Let me ask you Mr. Nagle, as a representative of II UE&C if you'd be willing to locate those monthly reports for t
i us and make them available.
13 Q
A Which monthly reports?
I# )
Q The monthly reports which I understand you ro i:
15 suggest were made available --
16 MR. SMOLENS:
May have been made available.
., i, I!
BY MR. EVANS:
l' t
d 0
-- may have been made available, Mr. Smolens has corrected me -- to your start-up, manager of start-up services l
here at UE&C from the people at Unit No.
2.
I I
21 ;!
A Yeah, if they do exist, we'll make them available.
22 I Q
Q Fine.
Thank you.
23 A
Remember, now, I said I would assume that they l
A u(
had some reporting responsibility back here.
l erd Reporters, Inc.
25 O
I understand, and I'm not asking you to create i
l 1
50 something that doesn't exist.
But we'd like to see it.
f I
/'J 2
(
A Okay.
3 Q
Mr. Nagle, have you talked with anyone else with regard to the Three Mile Island 2 accident?
The President's 5
Commission, or any other investigation group?
6 MR. SMOLENS:
Excuse me.
Do you mean official 7
organizations?
You don't mean cocktail party chitchat or 8
i things of that sort, do you?
You mean has Mr. Nagle been 9
interrogated by folks much as you are doing now?
Is that what 10 I you mean?
11 1 MR. EVANS:
I accept that definition of the question.
I 12 1 l
THE WITNESS:
No, I haven't, no.
BY MR. EVANS:
l 'a l
j Q
Do you have any other information regarding the o
15 Three Mile Island plant or the accident which should be made 16 available to us?
A Not to my knowledge.
Q Do you have any areas you think we should be looking at in the future as we continue this investigation?
l
~~h A
No.
I Q
Mr. Nagle, at this time, barring any further 9
()
questions or any comments that your counsel would like to 13llmake, I'm going to recess this deposition, rather than l
2 terminate it.
It is our intention to Complete all our l Act jed Reponers, I 25 questions here today, but if we uncover new areas in the L
I i
51' I
future which we'd like to go into, we'd like to call on you.
2 2
- 3 again.
3 I will note for.the record that Mr. Smolens 4
believes-this is not in the formal sense a deposition, but 5
nonethel'ess I would like to leave this open, should the need 6
arise for further questions.
7 A
I don't have any --
8 MR. SMOLENS:
It doesn't require any comment, Earl.
We will take note of your comment, Mr. Evans.
10 MR. EVANS:
Thank you very much.
11 i i
[Whereupon, at 12:30 p.m.,
the deposition i
12 !
l was adjourned.]
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