ML19308C398
| ML19308C398 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/26/1979 |
| From: | Evans D, Toole R GENERAL PUBLIC UTILITIES CORP., NRC - NRC THREE MILE ISLAND TASK FORCE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001230368 | |
| Download: ML19308C398 (44) | |
Text
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f NUCLE AR REGUL ATORY COMMISSION O
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IN THE MATTER OF:
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TMI SPECIAL INQUIRY DEPOSITION DEPOSITION OF RONALD TOOLE 1
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Place - Parsippany, New Jersey Date. Wednesday, September 26, 1979 Pages 1 - 43 h
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8 0 012 3 03c3 naim.nco lk ACE -FEDERAL REiORTERS,INC.
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444 Nenh Capitol Street
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l NUCLEAR REGULATORY COMMISSION THREE MILE ISLAND SPECIAL
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2 INQUIRY GROUP 3
O 4
DEPOSITION OF RONALD TOOLE 5
OF GENERAL PUBLIC UTILITIES 6
by NRC/TMI SPECIAL INQUIRY GROUP TRANSCRIPT OF 7
INTO THE ACCIDENT AT THREE MILE PROCEEDINGS 8
ISLAND 9
10 GPU Headquarters 260 Cherry Hill Road 11 Parsippany, New Jersey Wednesday, September 26, 1979 13 APPEARANCES :
14 DAVID J. EVANS, ESQ.
R. LAWRENCE VANDENBERG 15 ' NRC/TMI Special Inquiry Group i
16 ' JAMES B. LIBERMAN, ESQ.
General Counsel for General Public Utilities 17 DOUGLAS E. DAVIDSON, ESQ.
18 19 20 21 REPORTED BY:
FMRGARET J. TEILHABER, C.S.R.
22 l
23 !
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24 Ace - Fcderal Reporters, inc.
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25
2 1
I'N D E X 2
WITNESS DIRECT CROSS 3
RONALD TOOLE O
4 By Mr. Evans 4,34,40 5
By Mr. Var'enberg 26 36 6
By Mr. Liberman 7
8 1
9 10 11 12 O
is 14 15 l
16 17 18 19 20 21 22 23 24
'. Ace-Federal Reporters, Inc.
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25 l
3 1
MR. EVANS:
This is a deposition of Mr.
2 Ron Toole being conducted by the NRC/TMI Specia L 3
Inquiry Group.
It is being held at the head-O 4
quarters of GPU in Parsippany, New Jersey on 5
September 26, 1979.
6 Present in addition to Ik. Toole is Mr.
7 Jim Liberman, general counsel of GPU, and with 8
him is Mr. Doug Davidson.
9 Also present is Mr. Larry Vandenberg 10 and David Evans of the Special Inquiry Group.
II Mr. Toole, have you had a chance to l
12 read the Witness Notification form and also the 13 letter from Mitchell Rogovin which I have given 14 you earlier today?
15 MR. TOOLE:
Yes, I have.
I 16 !
MR. EVANS:
Do you understand the con-17 tents of those?
18 MR. TOOLE:
Yes, I do.
i 19!
MR. EVANS :
Do you have any objections 20 to proceeding at this time?
21 MR. TOOLE:
No.
O 22 MR. EVANS :
Could you stand and raise l
23 your right hand.
lO 24 sosAto T o o t E, sevio, se,o du1,s or, acco, ding to hee - Fed 2ral Repor ters, Inc.
i law testified as follows:
25i i
4 1
DIRECT EXAMINATION O
2 BY MR. EVANS:
3 Q
Mr. Toole, as a preliminary matter, could you O
4 state your fullename for the record and your current title.
5 A
Ronald Joseph Toole.
I'm the unit superintendent for 6
Units 1 and 2 at Homer City Power Plant in Homer City, Pennsyl-7 vania.
8 Q
Could you tell us what your position was in yout 9
involvement with the Three Mile Island-27 10 A
I was the test superintendent which put me in charge of II the test program in Unit Number 2.
12 Q
Was this what is sometimes called the pre-opera-O i3 tiona1 test program and power ascen,1on test program?
14 A
That's correct.
15 Q
To whom did you report as test superintendent 16 at Three Mile Island-2?
I7 A
I would have been responsible for the project to Dick 18 Heward, who was proj ect manager.
I9 Q
Did you report to Mr. Heward directly while he 20 was project manager?
21 A
The way the test organization is, the test organization 22 l
is responsible up through the engineering chain and I was re-l 23 sponsible to Don Hetrick who was start-up and test manager to 24 l
l' implementation of the test program.
As far as the project it-
%Ce - Fictral Reporters, Inc.
25 !!self, I was task responsible to Dick Heward to support the pro-i l
I
5 Toole - dircet 1
ject manager.
(v) 2 Q
And after Mr. Heward became manager of projects, 3 did you report to someone else?
O 4
A At that time it would have been John Barton.
5 Q
For time reference, could you tell me when you 6 began work and when you stopped working at Three Mile Island-2?
7 A
I would say that I started in September, 1974', when Unit 8 1 completed, and I finished, I left TMI on December 23, 1978.
9 Q
Did you report to Mr. Robert Arnold in any way, 10 either directly or informally?
11 A
In the chain of command, Heward would report to Hirst 12 who would report to Arnold so I would say 'it was in that chain, O
13 v
yes.
14 Q
Did you have any informal contacts with Mr.
15 Arnold directly?
16 A
On occasion, yes.
17 Q
For example, were you involved in meetings on 18 subjects where you and Mr. Arnold would exchange information?
i i
19 'A I would have been involved in meetings as a group where 20 Mr. Arnold participated and I participated, yes.
21 Q
Mr. Toole, who set the test schedule at Unit Num-22 ber 2?
23 A
I would have to say I did.
As far as the way the organ-24 l
ization was set, I was the test superintendent in being the test Ace - Federal Reporters, Inc.
25 l superintendent I was also chairman of what wts called a test i
Toole - direct 6
1 working group which was a committee that had members from B &
2 W as the nuclear steam supply system supplier, Burns & Roe, the 3
design engineer, Metropolitan Edison, the operating company, and O
4 GPU, the test superintendent.
5 That committee was tasked with~ developing the sequence 6
and schedule.
7 Q
How early was that committee formed?-
8 A
That committee probably was meeting in 1972 or '73.
9 Q
-Do I understand that this committee was a.co-10 ordinating committee or did it as a collective body set the Il schedule?
12 A
I would say that the way the committee works is we as 13 the test group were, we would develop the proposed test pro-14 cedure, any individual procedure, of which the test sequences 15 were for the power escalation was the procedure.
We would de-16 velop this procedure.
It would then be reviewed by the test 17 working graup, all comments resolved, and then approved by the 18 test working group.
19 Q
So the initial concept was developed by GPU?
20 A
Yes.
21 Q
What role did Mr. Heward have in establishing 22 lthetestschedule?
l 23 A
He was my supervisor.
I was responsible to develop the 24 schedule and then run the test program and procedures per that l Ace -Federal Reporters, Inc.
25 schedule so he monitored me in that capacity.
I 4
Toole - direct 7
1 Q
He would in essence approve the schedule which O
2 you had developed?
3 A
Mr. Heward would not approve it.
As far as signing off 4
for it, Mr. Heward would not' sign for that procedure.
~
5 Q
Can you describe for me b'riefly.how you inter-6 faced with these people from different organizations, and let 7
me try to be more concrete.
Did the people from B & W, Burns 8
& Roe, and these other external organizations answer to you?
9 A
No, they xid not.
10 Q
Describe your working relationship with them, 1I if you would.
12 A
Metropolitan Edison had an operating staff on site of 13 which the unit superintendent or station manager or other al-14 ternates would participate as the test working group member.
15 They reported through a chain that went on up into the Met-Ed 16 operational group.
B & W had a representative on site who was:
17 there to follow through on the B & W interests as far as they 18 would provide us what information as to what their equipment 19 could or could not do.
They were responsible to B & W.
20 Burns & Roe reported off site to Burns & Roe on engineer-21 ing matters.
O 22 Q
For example, the Babcock and Wilcox representa-23 tive on the test working group was a test engineer; is that cor<
24 9
rect.
. Ace-Federal Reporters, Inc. I 25 A
Did he work in the field doing testing?
Toole - direct 8
1 Q
Yes.
O 2
A No, he did not.
3 Q
So the test working group is a management group.
O 4
A Yes.
j 5
Q And not a g oup composed of' test. engineers, 6
A
~That's correct.
The procedure was wri'tten by someone o
7 who was contracted to me, which could have been a B & W person, 8 a Burns & Roe person, or some other.outside contractor or Met-Ed 9
people wrote some and GPU people wrote some.
10 In house I would then review the procedure.
It would i
11 then go into the test working group where it would be reviewed i
12 by people who did not have the responsibility for implementing 13 the test.
It was then given back to me and the people that were 14 under me and my disposition would run the test procedure.
15 Q
Turning now to the actual running of the test, 16 did personnel other than GPU personnel run those tests?
17 A
In some cases yes.
18 Q
Would those people be Burns & Roe test engineers 19 for example?
20 A
I had Burns & Roe test engineers who worked directly for 21 me on a contraer for me, yes.
O 22 Q
What other external organization personnel were f
23 contracted to you as test engineers?
fA I would say people from Stearns and Rogers, people from 24 Ace-Fed ral Reporters, Inc. l 25 ' Multi-Amp, United Engineers; Met-Ed people performed some of
Toole - direct 9
1 the testing and I had GPU people, of course.
I may have had O
2 at some point in the game some Gilbert people.
I'm not positive 3
who they were employed by at the time..
I had some people who O
4 worked for Gilbert and then worked for Burns & Rois later.
)
5 Q
How many people are you talking about as external 6
test engineers in rough figures?
7 A
Forty.
8 Q
How many GPU test engineers?
9 A
Ten.
10 Q
For a total of 50 --
11 A
No, total of 40.
12 Q
Did those test engineers report to.you or their 13 site representatives?
14 A
They reported to me.
15 Q
Turning now to evaluation of tests which had 16 been run, who determined whether a test had been passed within I7 its acceptance criteria?
fA Once a test was completed the test organization under 18 i
I9
! myself would review the procedure for completeness.
It was then 20 submitted to the test working group who reviewed it and then it 21 was signed off as acceptable by the test working group so the 22 final approval was the test working group.
23 Q
Am I correct in understanding that GPU personne L O
24 did the initial analysis as to acceotability?
l Ace -Fedtral Reporters, Inc.
l l
25 l
lA That's correct.
What we did was we implemented it in
Toole - direct 10 1
the field.
We reviewed it.
We corrected any errors and wrote O
it up so you could read it and put it into-the test working 3 group so our initial review is one that says, "Okay, it is ready O
4 for approval."
The test working group then reviewed it.
What-5 ever comments they would have, we would correct or re-test and 0
6 then it would go back and they would approve it.
7 Q
When I say GPU, I probably should be more ac,
8 curate --
9 A
Test group.
10 Q
But we are really talking about a component of 11 GPU Service Corporation; is that correct?
12 A
The start-up and test group, yes.
t 13 Q
Can you tell me how the test engineers, whether 14 i GPU personnel or those external test engineers, who were under 15 contract to you interfaced with Metropolitan Edison people who 16 were necessary to run the test.
17 A
The interface 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day would take place on a ' shift i
18 basis.
I had what was called a shift test engineer who covered j
19 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.
Met-Ed had a shift supervisor who covered 24 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> a day also.
21 In order for a test engineer to run a test, he would
, O 22 have to go to the shift supervisor and get.htm to aliga rh. sys-23 We utilized Met-Ed operations peopl'e to make all sciving tem.
()
24 operations and any equipment starting and stopping.
! Ace - Fsdetal Reporters, Inc.
25 l
If it was in the area of instrumentation whi',h was han-l l
i l
w
Toole - direct 11.
i died separately, Met-Ed had an instrument department run by an O
2 instrument supervisor.
I had an instrument supervisor who we people 3
would tie their instmmentation/with our supervisors to go out O
4 and set up, do a calibration of tests, whatever we were trying 5
to perform.
6 Q
Were there instances in which test engineers 7
would give orders directly to Met-Ed employees?
8 A
I would have to say yes.
To qua11fy it, we would sit 9
down before the shift started and we would take the shift super-10 visor, shift foreman,contro1 room operators, whoever might be 11 required, and discuss in a briefing that this is the way we are 12 going to run this test and then break the responsibilities down.
O i3 1t cou1d we11 be that the eest engineers went oue.ith two eger.
14 ators and gave those two peop1e on location direction, but the 15 responsibility of the operators was to shift supervisors.
16 Q
Do you recal1 there being conflicts ' ween con-17 trol room operators, for example, and test engineers over in-18 l structions to perform a certain test at a certain time?
19 A
Not specifica11y, but when you are running a program 20 such as we ran, there's always communications problems.
That's 21 what you're addressing as a communications problem.
O 22 Q
Were there instances in which M.et-Ed employees, 23 including CRO's, would object to running a test because they ld 24 didn't feel the unit was ready for the test at that point?
l Ace - Feceral Reportets, Inc.
25 lA As far as anytime, it would be brought up and raised to
Toole - direct 12 I
a level above.
Then it would be discussed.
As far as an indi-O 2
vidual operator in the plant turning around and saying that it N 3
not ready, if h~e turned to his supervisor and his supervisor O
4 accepted that he didn't think it was ready, there was a chain 5
to go up to the top and resolve it.
If the supervisor said we 6
are going to do it and support them, it'was done.
7 Q
What is the level above the supervisor?
8 A
It was an operations supervisor and assistant test super-9 intendent.
The operations supervisor would report to operation s.
10 The assistant test superintendent would report to me.
I1 Q
And the next step above that?
12 A
Then it would be on my level and the station manager O
i3 1 eve 1 from xet_sd.
14 Q
And if you two still disagreed --
15 A
I don't believe that that ever happened'.
16 Q
Indulge me for a minute and can you tell me wha 17 would be the next level.
18 A
The next level would be on the level of Dick Heward who l9 was project manager, and Dick K11ngaman -- pardon me -- Sandy 20 Lawyer, who was manager of operations.
21 When you say the specific question, did we ever argue O
22 over whether the plant was ready to test in a specific area, 23 rem saying that didn't happen.
There were items that wou1d go 24 l up through the total chain and be resolved above us where we Y*ce - Federat Reportets, Inc.
25 disagreed on other things.
r Toole - dircet 13 j
1 Q
Items in connection with the testing program?
2 A
With the testing program and adequacy of design of the 3
plant possibly.
O 4
Q Do you recall the instances involving adequacy 5
of the design of the plant?
s 6
A Not specifically, no.
7 Q
Do you believe there exists from your experience 8
a conflict between the operating company personnel and the GPUS 9
start-up group in setting a schedule for the test program, in 10 meeting that schedule?
11 A
No, I do not.
The operating personnel signed off that 12 schedule.
13 Q
What does that sign off indicate to you?
14 A
That it was acceptable to them.
15 Q
During the course of your involvement with Unit 16 2, did people complain to you that you were pushing them too 17 hard to meet a test schedule?
18 A
I don't believe so.
19 Q
If people had such complaints, would you have 20 been the natural person for them to go to?
21 A
It depends on who you are talking about.
If it was Met-O 22 Ed operations people, as far as an operator and instrument 23 technician, he should go to his management.
If it was my people 24 they should come to me.
)ce -Federal Reporters, Inc.
25 i
Q Would you characterize the test schedule and the i
l
Toole - direct 14 1
Unit Number 2 as being fairly aggressive?
O 2
A Are you speaking specifically of an area or the entire 3
program?
4 Q
The entire program.
5 A
The early stages of the program prior to fuel load was 6 controlled by construction, how was construction built the plant.
7 So as far as being aggressive, as soon as a component was ready, 8
we would test it.
To be aggressive by nature, we were' pushing 9
construction to get our needs satisfied so we could test it.
It 10 could only go as fast as they could build it so I don't believe II that was aggressive.
12 If construction worked faster, we might have done it O
13 faster and better.
'4 From the point, from fuel load on, I would say that we 15 approached it in a pretty standard method and we h'ad a set se-16 quence to complete and it was a sequence.
It wasn't'a time frame.
I7 Q
You just stated that you approached in a standard 18 fashion.
Is there such a thing as a standard test program for I9 B & W plants?
20 A
I would say that the B & W plants right now are consider-21 ably the same, yes.
22 Q
Did you have any involvement with Mr. William 23 Spangler of Babcock and Wilcox in the course of your test pro-i 24 l
gram?
Ace - Fsdetal Reporters, Inc.
I 25 l
A Spangler was the start-up and test manager or some l
Toole - direct 15 1
capacity such as that with B & W.
O 2
Q Did you have any involvement with him?
3 A
I had limited involvement with him.
The B & W repre-O 4
sentative on site would have gotten services from Spangler but 5
I would have dealt through the B & W representative on ' site in 6
that I did use B & W people to write test procedures?who would 7
have reported in the chain that reported up through Spangler.
8 Q
I would like to call your attention now, Mr.
9 Toole, to the April 23, 1978 transient at Three Mile Island in-10 volving the main steam relief valves.
Do you recall that tran-Il sient?
12 A
Yes.
13 Q
Following that transient, the plant was down 14 for several months for replacement of the steam valves.
Can 15 you tell me what the test group was doing during.that time?
16 A
We at that time had various incomplete work items and I7 problem areas that we were resolving.
We were also preparing 18 a revised schedule to re-test the plant from ground zero on up I9 due to the relief valves and some other items that had transpired 20 during that time frame.
21 Q
Was it necessary in your opinion to retest the 22 entire plant as a result of the steam valve malfunction?
23 A
We had only completed a limited amount of testing on 24 the plant so anything beyone that had never been done and had ke - Federal Reporters, Inc.
25 to be ccmpleted.
We did develop a sequence to get us back to l
Toole - dircet 16.
I the point where we had thought we ended up testing that was dif-O 2
ferent, that we thought required changes, yes.
3 Q
You are not talking about re-doing pre-operation
~
O 4 al testing of t;'.e-components, are you?
5 A
We had problems on pre-operational testing that we did 6 resolve during that time frame.
I can't cite you specific but 7
there was some problems.
j 8
Q Once the main steam valves were replaced, did 9
this test schedule which you develeped during the down time go 10 into effect?
II A
Yes.
12 Q
Was there an end date on that schedule or was it,
13 again, a list of procedures?
14 A
It's a sequence.
I have a copy if you want to see it 15 what we were working from.
16 MR. EVANS:
Off the record.
17 (A discussion was had off the record.)
18 MR. EVANS:
While off the record, Mr.
l9 e
l Toole has shown us large diagrams of the sequenc l
l of tests to be performed in Unit Number 2.
20 21 Q
Can you characterize, Mr. Toole, the pace of the 22 tests following the steam break, replacement of the main steam 23 valves as compared to before main steam valves malfunctioned?
O 24 The pace of the testing was comparable to the testing A
l Ace -Federal Reporters, Inc.
5 on Unit Number 1 pace, if you are looking for a comparison in
Toolo - direct 17 1
time frame.
What controls the rate of testing is the plant.
AV 2
If the plant and the pre-regs are all satisfied, the rate of 3
testing is very rapid because testing in most cases is an accumu-4 lation of data.
The problems that are encountered are what 5
cause the time frame to be long in that if you were to run the 6
entire test program that we ran on a plant right after you com-7 pleted it and resolved all your problems, it could probably be 8
done in a week, ten days, and on'the initial run-through, it 9
takes approximately four months.
10 Q
Had Unit Number 2 not experienced.the main stean 1I relief valve problem, can you estimate when the test program 12 would have been completed?
13 A
Probably in September.
14 Q
Do I understand you correctly that when the main 15 steam valves malfunctioned, you had just begun the power as'cen-16 sion testing?
17 A
That's correct.
We only had done the 15 percent testini;.
18 Q
So again, if I understand you correctly it would 19 typically take five months to do the complete power ascension 20 test.
21 A
Typically two weeks at a plateau of which there's four 22 plateaus so approximately eight weeks would not be a bad number, f
Q If I'm correct, testing resumed on Unit Number 23 bJ 24 2 sometime in September of 1978 followin;; replacement of the hee - Federal Repor ters, Inc. i lsteamvalves;isthatcorrect?
l 25
IToole - direct 18 1
A Approximately the 17th of September.
O 2
Q It is my understanding that completion of the 3
test program was declared on the 28th of December, 1978; is that O
4 correct?
5 A
That's correct.
k-6 Q
So the entire power ascension program was essen-7 tially run between those two dates, September 17th and December 8
18th.
9 A
That's correct.
10 MR LIBERMAN:
December 28.
I1 Q
Excuse me.
December 28th.
12 A
That's correct.
13 Q
What in your opinion was a typical length for a 14 test program?
I 15 A
If you were to look at what we predicted before, that 16 would be the time frame.
Two weeks at a power level is eight 17 weeks.
October, November, and December was 12.
We did do the 18 removal of the main steam valve strainers in that time frame, l9 which was not included in that time frame which took approxi-20 mately two weeks.
21 Q
Were you ever instructed to have the test done 22 at a certain data?
23 A
The way the test program was run is we established a 24 I would develop a se-
!' sequence and the sequence was performed.
~. - ~ _ m._. m.
25 quence and then provide a date b, which I would complete it, an i
Toole - direct 19 1
anticipated date.
Those are the dates we were working for.
~
/7 V
2 As far as someone telling me that the program had to be 3
completed by November 1 or December 1 or January 1, no, it was O
4 not.
5 Q
Did you, in fact, develop a completion date for s -
6 the test sequence at Unit Number 2 following the main steam re-7 lief valve problem?
8 A
We had a time frame t.hnt we anticipated making, yes.
9 Q
What was the end date for the test program that 10 you had set?
i 11 A
11/26.
12 Q
And you slipped in that approximately a month?
O 13 A
That's correct.
14 Q
Can you tell me what was the cause of,the slip-15 page?
16 A
One item was the two weeks to perform the removal of the 17 strainers in the system, which was a large maintenance outage, 18 which was to be done -- let me retract that.
That was included 19 in it.
That was included in the 11/26 date.
20 Q
So can you recall what was the cause of slippage?
21 A
It was more than one item.
Are you looking for major 22 items?
23 Q
Yes.
If you can identify one or two major items 24 which changed the date at which you expected to be completed, Ace - Federal Reporteis, Inc.
25 i
that would satisfy my question.
l l
Toole - direct 20 3
1 A
We had a test program going on in which we had a series 2 of penetrations into the steam generator which monitored vibra-3 tion.
They had what was called a Conax connector which on occa-O 4 sion would develop leaks and we would have to cool the plant 5
down.
That caused some of the major delays.
Each time to cool o
6 the plant down you are talking about three or four day duration.
7 We had a ground occur on a generator exciter bearing.
8 That took a week.
9 Q
Took a what?
10 A
A week, from 10/23 to 10/30.
i 11 Q
So let me attempt to summarize by saying that 12 these were mechanical breakdowns which were anticipated and not 13 problems with the test program or the results; is that correct?
14 A
That's correct.
15 Q
Did anyone ever discuss with you the financial 16 impact of completing construction and testing on'Three Mile Is-17 land-2 before the end of 1978?
l 18 A
Not that I remember.
19 Q
Do you recall hearing of such concerns in chan-20 nels other than a direct discussion?
21 A
No, I do not.
22 Q
Are you familiar with an organization called the 23 ! Commercial Operation Review Board?
24 A
Yes, I am.
! Ace-Federal Reporters, Inc.
25I Q
Were you involved in presentations before that e
Toole - direct 21 1
1 board on October.26th, 19787 2
A Yes, I was.
3 Q
During those presentations, did' you review the 4
testing program at Three Mile Island-2?
5 A
Yes, I did.
6 Q
Following that review board meeting, did you 7
subsequently report to a subcommittee of the beard on the test 8
program of Three Mile Island-2?
9 A
Are you asking me was there a subcommittee developed 10 during that meeting that was responsible to review, we were re-1I sponsible to report to?
12 Q
No.
My question was whether you in fact re-13 ported to a subcommittee which was developed.
14 A
Was I responsible for completion of the test. program to 15 someone differentafter that?
16 Q
Answer that question, if you can.
17 A
The Commercial Review Board meeting did not in any way 18 change my reporting.
l9 Q
Let me show you what has been previously marked l
20 as Exhibit 1109 and ask if you recognize this.
I i
21 A
I recognize this.
I haven't read it a'long time.
O 22 Q
Did you receive a copy when it was first dis-23 ! tributed?
24 A
I believe I've seen it before.
Wh' ether I was on dis-
- Ace-Federal Reporters, Inc.
25 tribution or not -- it says here I was.
I've seen it before.
Toole - direct 22 I
Q Let me just ask you what your understanding is O
2 of what is identified here as 5.0, items outstanding.
Under 3
item Test Completion, it has resporisibility". Tool / Subcommittee.
pG 4
A The review board was made up of officers of the company 5
to review in their opinion whether the plant was' prepared for 6
commercial operation.- The day we held this meeting we had the 7
vice-presidents of all the operating departments in our company 8
who attended this meeting.
The decision at the end of the meet-9 ing was that there would no longer be a requirement for all of 10 these people to meet in the same room again to resolve whether 11 the plant was ready for commercial operation.
12 There was a defined path as to what we had to do to com-13 plete the plant and prepare it for commercial operation estab-I4 lished of which I was responsible for the test. completion.
15 i The subcommittee of Arnold, Wilson, Herbein and Hirst 16 was to take the place of having this formal meeting at some late r I7 date.
18 Q
So you and the subcommittee had separate respon-I9 sibilities; is that correct?
20 That's correct.
A 21 Q
How did the subcommittee learn of the progress 22 of the test program?
23,A I can't answer that.
As far as a formal method, our 24 Ace - Fscital Reporters, Inc.
25
!' to a milestone, approve it, test working group would approve it i
Toolo - dircet 23.
1 and then that supervision would be notified.
Mr. Hirst is part O
2 of that committee.
I would report my position to Mr. Heward whc 3
would in turn report it to Mr. Hirst.
O 4
Q Let me ask you a couple of more questions about 5
this document which has been identified as Exhibit 1109.
Under 6
criterion 2.6, Testing, the exhibit indicates,that the discussicn 7 was led by you and the minutes of that discussion discuss'the 8
all rods out Boron test and it states that the results were not 9
in good agreement with the B & W prediction.
This matter was 10 resolved satisfactorily by a re-analysis by B'c& W.
II Could you describe what that means?
12 A
Not at this time.
I could tell you what I think it means O
13 but not to tell you exactly what it meant.
14 Q
Can you tell me if it indicates that B & W re-15 calculated an acceptance criteria value?
16 A
I believe that's what it was.
17 Q
Is that normal in your experience with nuclear 18 units?
19 A
It happens on occasion.
I just can't remember the spe-20 cifics of that.
We were off by a number of PPH in Boron from 21 the all rods prediction, I believe.
Going through a re-analysis O
I 22 as to whether it was acceptable, B & W justified it.
i 23 i Q
Again at the same page of Exhibit 1109, there's
~
24 ladiscussionofthefact that the DNBR value'was slightly lower Ace - Federal Reporters, Inc.
lthan expected.
Can you first tell me what DNBR is, 25 i
Toolo - dircet 24 1
A Departure from nuclear boiling ratio.
O 2
Q Can you tell me how that problem was resolved?
3 A
The lower than expected main coolant flow was not re-4 solved.
It ended up as a limitation to.how high in power we 5
could run Unit Number 2 to an upper limitation, 98 percent.
6 Q
So there was no re-analysis of that slow rate 7
as there was a re-analysis of the B & W Boron levels?
8 A
That's correct.
You asked me a question, was it normal 9
to change acceptance criteria.
It's not normal but occasionally 10 it did happen.
II Q
Had the acceptance criteria not been changed, 12 would it have been necessary to make modifications?
13 A
Possibly.
Again, I'll say I'm not 100 percent sure of 14 that incident.
15 Q
Are you familiar with tn'e ' SAR which deals with S
16 the test program involving Unit Number 2?
I7 A
Yes.
18 Q
Do you know what the last test specified in SSAF.
I9 is?
20 A
No, I do not.
21 Q
I believe you testified that you left Three Mile 22 Islar.J-2 on December 23, 1978; is that correct?
23 A
I believe that's correct.
24 Q
Were you present for any tests after that date?
l Ace-Feoetal Reporters, Inc.
25 A
No, I was not.
Toole - dircce 25 1
Q Who was responsible in your absence?
2 A
The assistant test superintendent.
3 Q
And his name is?
O l
4 A
Tom Hawkins, 5
Q Did Mr. Hawkins keep you informed.of the results 6 of the test or had you had responsibility passed to another area?
7 A
The responsibility was passed to him.
I was in contact 8 with him and I was available for any support he needed.
9 Q
Did he call you following the full power gener-10 ator trip test on December 28, 1978?
11 A
Are you saying on the day or subsequent to that test?
12 Q
Subsequent to the test.
O 13 A
on a number of occasions, yes.
14 Q
What was the content of his communication?
15 A
Just to discuss status of the paperwork review and or-16 ganizing the paperwork to be approved by. test working group and 17 information that I needed to supply.
18 Q
Specifically, did he discuss with you the accept-19 ability of running the full power generator trip test?
20 A
As far as the best test that he ran meet the acceptance 21 criteria of the test?
22 Q
Yes.
23 A
I believe that I asked him how the test went and he said
- O 24 it.ent setisfactori1.
7 Ece-Fsderal Reporters, Inc.
25 MR EVANS:
At this time, Mr. Vandenberp
i Toolo - direct 26 l
1 might have a few questions for you.
p 2
MR. LIBERMAN:
This is a good time to v
3 break for lunch.
O 4
MR. VANDENBERG:
Off the record.
5 (A discussion was had off the record.)
6 (Lunch break.)
7 8
(A F T E R N O O N S E S S I O N) 9 MR. EVANS:
I believe just' as we broke 10 for lunch Mr. Vandenberg was going to ask some 11 questions.
12 BY MR. VANDENBERG:
13 Q
Mr. Toole, how many people were in the GPU Ser-14 vice Corporation start-up and test group?
15 A
Approximately ten GPU people.
Approximetely 40 total i
16 people in start-up and test as engineers.
17 Q
Of the GPU people, they were all engineers?
18 A
They were not all graduate engineers.
Q Vas there any concern by any of those ten people 19 20 or by yourself that the start-up unit had wrapped up its work 21 too soon?
]t 22 A
I don't believe so.
l I
23 Q
When did the start-up group actually disband?
j lA De, ends on how much of it yeu are ca1hing aboue.
Tse O
24 l
ce - Fed 3ral Reporters, Inc.
25 i
in l start-up group was held Ats position into January but not every-
Toolo - dircet 27 I
one, nct as a complete group.
There were people assigned to O
2 wrapoing up the start-up. program that continued on.
3 Q
When about were the first people separated from 4
the start-up and test group?
5 A
I guess I was the first; around December 23rd.
6 Q
You worked on Unit 1 prior to your work on Unit 7
27 8
A That is correct.
9 Q
During the time you were assigned to Unit 2, 10 during that whole time you were start-up supervisor?
II A
Test superintendent.
12 Q
Excuse me.
Right.
But you had no other posi-13 tion on Unit 2.
14 A
That's correct.
15 Q
Back in February of 1978~when.the operating 16 license for Unit 2 was granted, could you characterize the status I7 of the pre-operational test program at that point?
18 A
Prior to issuing the license which permitted us to load I9 fuel, we had a pre-requisite list on which we identified every 20 test procedure that we had intended to run.
Each test procedure 21 on that list had been reviewed and approved by test working O
V 22 group as either a completed test or e partial with acceptable 23 status to load fuel.
24 In addition to that, the NRC had reviewed those pro-bce - Federal Reporters, Inc.
I 25 l
cedures, not all of them, ones that they were required to review, l
l
Toole - dircet 28 1
and considered our test status acceptable for us to load fuel O
2 or them to issue a license.
3 Q
I take it, then, that some portions. of some pre-O 4
operational tests were completed after the OL.was issued.
5 A
That's correct.
6 Q
Can you give me some estimate of the' number or 7
extent of those items?
8 A
The extent would not have been very similar.
As far as 9
the number, I can't provide that.
10 Q
Then, going back to the end of or near the end 1I of 1978 following replacement of the relief valves, were de-12 cisions made to delete or at least substantially postpone any 13 of the originally scheduled power ascension test?
14 A
No.
The piece of paper I showed you s'howed that we did 15 additional testing before we resumed what was originally laid 16 out.
17 Q
What about, for example, the unit acceptance 18 test which was originally scheduled to be done right near the 19 end of the power ascension test program and, in fact, I'm pretty 20 sure it appeared on that large chart you showed us but yet that take 21 was done in 1979.
Did you/part in that decision to postpone O
22 that test?
23 A
You know for a fact it wasn't completed in 1978?
l O 24 i
Q That's my understanding.
Ace-Freers. Reporters, inc.
25 A
I don't know that to be true.
Toole - direct 29 1
Q Could you explain for me the meaning of this O
2 sentence in here.
This is Exhibit 1109, criterion 2.6.
3 "It was indicated that seven tests will not be V
4 completed as.
." -- and so on.
5 MR. LIBERMAN:
Can I ask that you read 6
the sentence completely or that you read into 7
the record completely.
8 Q
"It was indicated that seven tests will not be 9
completed as originally written since an evaluation determined 10 that there were no unresolved problems and none of the testing II omitted is related to Federal, State, or local requirements."
12 A
This was stated during the Commercial Review Board.
13 ' There were seven test procedures at that time that we.had not 14 committed to in the FSAR that we had not performe'd 'and these procedures were developed by us and only reqtlired by us.
15 16 I can give you examples.
We had a pre-treatment plant 17 that would make drinking water on Unit Number 2.
We also had l one in Unit Number 1 that supplied all the water we needed.
18 19 Therefore, we never did get that system in service.
We had a 20 demineralizer that would make demineralized water to fill the 21 condensate system.
The unit one system was quite large and O
22 supplied all our needs.
When we loaded fuel, we had testing to 23 do on the fuel handling equipment that we had some parts that 24 ; we did not complete at the time.
We were able to load fuel, Ace - Fsderal Repot ters, Inc.
j 25 knowing that these two tests were outstanding.
When we received
Toolo - dircet 30 1
the parts, they would be completed later on.
O 2
We had a sampling system that would sample water in a 3
condenser.
On our condensate system you would determine that yc u O
4 had a high conductivity that would tell you you would have water 5
in leakage into the condenser.
This pumping system would, pump 6
from various locations in the conde.nser and tell you' exactly 7 where it was to help you make it easier to locate.
8 There are other methods to locate it but it's harder.
9 That's the type testing that was in there.
10 Q
That's the type testing covered by this refer-11 ence to seven tests?
12 A
Yes.
I gave you five?
13 Q
I think so.
Did you ever from the period Sep-l tember through December perform additional reviews to see which 14 I
15 tests could possib'y be postponed?
16 A
No.
17 Q
We talked earlier about the change in the time 18 periods to perform the scheduled test program.
Could you de-19 scribe your understanding of what was the schedule for about 20 the last two weeks of December.
I realize that you left on the 1
21 23rd but nevertheless I imagine you knew what the schedule was O
22 for the 23rd through the 30th.
23 A
As far as the incomplete tests that had to be performed,
0 2 *-
l i they were the type that were data accumulation in the generator
! Ace -Federal Reportets, Inc. !
25 ' trip.
Toolo - dircet 31 1
Q Were, for example, people working overtime dur-2 ing the month of December right up through the end?-
3 A
We had a group of people on shift work that rotated O
4 through from shift to shift and come in and relieved the shift.
5 that was on.
In the start-up program you always h~ad people that 3
6 are on the day shift that will work extended hours.to cover and 7 provide communications between those four shifts.
8 Q
So you are saying there was almost no overtime 9 in December in terms of start-up people.
10 A
There was overtime. I don't believe that there was over-II time of a hardship nature.
12 Q
You left just before the Christmas holidays, 13 A
That's correct.
I4 Q
Do you recall what the schedule was for that 15 holiday period through the 30th of December?
16 A
What are you talking about?
17 Q
More than the ordinary number of people-on a 18 shift or people working overtime?
I9 A
Did my leaving cause someone to work overtime?
20 Q
No, not did your leaving, just what was your 21 knowledge of t.he schedule at the time you left for the period O
22 remaining in December.
23 A
My knowledge was that there was sufficient people on O
- l hif t to rotate through and cover it by working a limited amount 24 s
Ace - Fed 2ral Reporters, Inc. l 25 ijof overtime.
l
IToole - direct 32 1
Q With that normal number of people with limited O
2 amount of overtime, the remaining uncompleted tests could be 3 easily done, performed?
O 4
A That's corrti_.
5 Q
You mentioned earlier that IE reviewed'or NRC a -
6 reviewed -- I'm not sure which terms you used -- certain test 7 results at the time of the OL issuance.
In +;r:neral, could you 8 describe your contacts with IE inspectors.
9 A
Prior to fuel load and operating license issuing all 10 initial contact by the operating license people the inspectors, 11 pertaining to the test group would have been through me.
12 Q
And after?
13 A
Once the license was issued, the license was issued to 14 Met-Ed.
From that point on, all the inspectors' initial con-15 tacts would be through the licensee which would be the station I
16 ' manage ~.
r 17 Q
Didyouoftennonethelesshaveconversationswita) 18 any inspectors?
19 A
Significant amount.
It's just from the point of license 20 issue the station manager was responsible for tech specs which 21 spell out distinctly how you have to do the operations of the O
22 plant.
All testing still was handled through me.
I 23 l Q
Did people in your organization below you have O
fcontactswithIE?
24 Ace - Fsatral Reporters, Inc.
25 lA Yes.
The contacts with IE are on an expert basis.
You l
l
Toole - direct 33
?
I get to a system such as the control rod drive.
They would send r
k 2
a control rod drive expert in.
They have a principal inspector 3
and an assistant.
Again, I would be dealing with the principal O
4 inspector.
His expert would deal with my best prepared individ-5 ual.
3 6
Q The test working group, I believe you said, con-7 tained a representative from B & W.
Was that Lee Rogers?
8 A
That's correct.
Lee Rogers.
Lee Rogers or an alternate.
9 He did have an alternate on occasion.
10 Q
Just finally, Mr. Toole,-there was a memo writ-1I ten May 4, 1978, from Mr. Seelinger to Mr. Miller.
You among 12 others were listed there as CC and in that memo there was a O
13 section entitled " Philosophy" and I believe that it read:
"we 14 must slow down and proceed forward deliberately and correctly.
15 Senior station management must convey this philosophy to shift 16 personnel-G.P. Miller /R.J. Toole prior to start-up."
17 MR. LIBERMAN:
Can I interrupt.
Is a 18 copy of that memorandum available?
19 MR VANDENBERG:
Off the record.
20 (A discussion was had off the record.)
21 MR. VANDENBERG:
Mr. Libermati, I'll be i
22 glad to send you a copy of the memo itself.
23 Q
Mr. Toole, based on this excerpt from this May 24 4, 1978 memo, can you give me any comment on what that meant
, Ace-Federal fleporters, Inc.
25 i to you.
I
r Toole - direct 34 1
A I can't tell you what that means to me without the rest 2
of the memo.
As far as an excerpt, I don't know what the sub-3 ject was.
4 Q
You don't recall this?
5 A
No.
3 6
MR. VANDENBERG:
I have no further ques 7
tions.
8 MR. EVANS:
I'll be brief, jus-t a coup 1a 9
of follow-ups.
10 BY MR. EVANS:
11 Q
Mr. Toole, did you ever feel that your test 12 start-up group was understaffed?
O n
i No.
1 had run unit Number 1 or had been responsible in 14 Unit Number 1 with far greater numbers of people.
I limited 15 the number of people on Unit Number 2 because there was only a 16 limited number of personnel you can adequatel'y control.
17 Q
Was there the same amount of work to be done on jUnit 2 as on Unit 1 in completing the test program?
18 19 A
Probably more.
20 Q
So it would be fair to say that to get more 21 work done with fewer people, those people had to work more hours?
22 A
That's not true.
23 Q
Could you explain to me how it was done?
O 24, A 1f you have smareer peop1e who can communicate better, RCc-Fedtral Repotters, Inc.
l 25 you can do more in 1ess time.
Toole - direct 35 1
Q Did you believe you had smarter people who could O
2 communicate better'in the start-up program in Unit 2 than of 3
Unit I?
4 A
Yes.
5 Q
Just before you left Unit 2'in' December, 1978, 6
were you aware of an instruction from Mr. Robert Arnold regard-7 ing work on the unit over the Christmas holidays?
8 A
No, I was not.
9 Q
Mr. Toole, have you testified before any other 10 official bodies investigating the Three Mile Island. accident or 11 its consequences?
12 A
No, I have not.
13 Q
Is there any information which is in your posses-14 sion or control which you believe should be brought to the at-15 tention of this inquiry in connection with the tenting at Unit 16 Number 2 and its scheduling?
17 MR. LIBERMAN:
I have to object to that 18 kind of question.
It seems to me that that's 19 a combination of are you still beating your wife 20 and what do you know that you think you ought i
to tell us that you haven't told us.
I don't 21 O
22 know how anyone ever answers either of those 23 !
questions adequately.
I haven't any objection O
i 24 to anything specific but it seems to me that Ace - Fedtral Reporters, Inc, j 25 that's more general than you need, at least I i
Toolo - direct 36 I
hope it is.
2 MR. EVANS:
Off.'the record.
3 (A discussion was had off the record.)
O 4
Q Mr. Toole, I'm going to withdra(i the earlier 5
question.
Let me ask if there's a statement other'than what 6
you've made before us here today which you'd like to.make.in 7
connection with this inquiry.
8 A
I have the answer to the previous question as to what 9
we did to resolve the Boron concentration on the all rods out 10 Boron.
We had four fuel assemblies in the core which had gado-11 linium pins installed in them.
When B &.W did the initial all 12 rods out Boron concentration they did not take into account the O
i3 fact of the gado11nium.
14 When we did not satisfy the acceptance criteria, they 15 determined the gadolinium pins were installed'in the reactor
.I 16 and reca1culated the all rods out Boron concentration and the 17 results were then acceptable.
18 MR. EVANS :
Mr. Liberman, do you have 19 anything to add or any questions to ask of the 20 witness or any clarifying statements?
21 MR. LIBERMAN:
I have a' couple that I 22 think might help the understanding there.
23 CROSS EXAMINATION O
24 Sv MR. t1BzRMAN:
ce - Fedtral Reporters, Inc, j 5
4 Q
Mr. Toole, what was your role in connection
Toole - cross 37 1
with the TMI start-up program?
O 2
A I was the test superintendent.
3 Q
Did you develop a test program, a start-up and 1
O 4
test program, for TMI-17 5
A I was the assistant test superintendent in TMI-1 and I 6
was involved in TMI-1.
7 Q
Did you develop such a program for TMI-1 or was 8
such a program developed?
9 A
It was developed by the testing group of which I was 10 part of, yes.
I was involved in it.
1I Q
Could you describe in a general'way how that 12 test program was set forth?
O me 13 A
You want/to go back to what I feel was the development 14,of the test group?
I 15 Q
Yes, please.
16 A
We had three people from GPU assigned to the Oyster 17 ' Creek station when it started up of which I was one.
At the 18 completion of the Oyster Creek project, the three people were 19 sent to different areas to be brought back together to be the 20 nucleus of the start-up group at TMI-1.
21 I was sent to TMI-1 to get started on developing a schec O
22 ule and getting systems turned over and the test program laid i out.
William Behrle was sent to Oconee which was the first B&
23 0
\\
24 l W unit to participate in the program with the Oconee staff to l Ace - Fedtral Reporters, Inc.
25 ' determine how that program was performed and what were the good l
Toolo - cross 38 1
and bad points of it.
O 2
The third member was Tom Hawkins.
I was assigned to 3
Parisppany to work on various projects associated with start-up O
4 and test.
5 We were reconvened at the Island.
Tom Hawkins~came 6
earlier than Behrle and participated in the pre-operational. stages.
7 Behrle was returned to the site in the capacity in which he 8
wrote the sequence for start-up and test from the beginning of 9
high functional testing through fuel load through the power es-10 calation.
II Our experience at Oconee and at Oyster Creek put' us intci 12 developing a sequence of testing as I showed'you, earlier that 13 we would use and satisfy all review committees plus the NRC and 14 use to explain to our management where we were and where we were 15 going.
16 That sequence was used on Unit Number 1 and used very I7 effectively.
That was the same sequence essentially with some 18 l modification from our experience that was used in Unit Number 2.
I I9 Q
This sequence reflected a vo wme of some kind?
20 A
Yes.
One test procedure covers hot functi cal, one 21 covers fuel load, and one covers the power escalation program.
22 MR. LIBERMAN:
Off the record for a min-i l
23 l ug,,
l, 24 (A discussion was had off the record.)
- Ace - Federal Reporters, Inc.
25 Q
I think my question was this.
Was the test pro-
Toolo - cross 39 I
cedure reflected in a documen* >* some kind?
O 2
A The test procedure is a document that is approved by 3
the test working group.
4 Q
Does that in turn lead to some.~other docume1t 5
that shows a subsequent, the tests and the steps?
6 A
The procedure is the sequence of testing.
If you look 7
at step one in the procedure, it would say to do these steps 8
and these other procedures.
If you looked at the drawing, it.'s 9
the same thing graphically presented.
10 Q
So that the drawing presents the relationship; II the document itself describes what the procedure is; is that 12 :c orrect?
13 A
That's correct.
If I were to look at this --
14 l
Q What is this,just for the record?
15 'A If I were to look at the graphical presentation, I would 16 see on a 40 percent power plateau a test which says' 824 in core I7 detectors at 40 percent power section 9.3.
18 l
Q What does section 9.3 refer to?
I9 A
It's a section of TP824.
The controlling procedure that
' this represents graphically was TP number 821.
Step number 9.4.9 20 21 of procedure 821 was this test of in core test.
22 i
j The next step of 621 would be 9.4.10 which would be see l tion 9.2ofprocedure810,incorepowerdistributionat40per-24 I cent.
%ce - Federal Reporters, Inc.
i i
25 !
Q So that by means of a test manual and the graph Le i
i 1
I
Toole - cross 40 1
representation, you had a clearly understood sequence of test 2
procedures and their application?
3 A
When you refer to test manual, we had-a document that O
4 was referred to as the test manual which described our organi-5 zations and the procedures we would ues.
What I believe you are 6
referring to is the test procedure 821.
7 Q
Was the sequence and completion of the various 6
steps in that sequence controlling with respect to the level of 9
plant operation?
10 A
What I think you are asking me is would the plant have 11 to be in a specific condition to support the sequence?
12 Q
Yes.
13 A
Yes, the plant would have to be..in specific conditions 14 to support the test procedure and it was defined in the test 15 p,rocedure what the conditions would be.
16 MR. EVANS :
I have one question as a 17 matter of clarification.
18 BY MR. EVANS:
19 Q
Would it have been possible in your opinion for 20 Unit Number 2 to go commercial before completion of the test 21 program?
22 MR. DAVIDSON:
Maybe, Mr.. Evans, you car t 23 define what you mean by commercial.
We had this O
24 prob 1em before.
hee-racerai Reporters, inc.
25 l
MR. EVANS:
I'll accept that.
t
Toole - dircet 41 1
Q Would it have been possible for the unit to go 2
into commercial operation as that term is used by the GPU Com-3 mercial Operation Review Board before completion of the test O
4 program?
[
5 A
I believe that if we were to reach a power plateau and 6
had some reason by which we would not be able to go on above 7
that power level for some period of time, if we properly pre-8 sented it to the NRC upon their review and acceptance, we corld 9
declare the plant commercial at a lower power level, commercial 10 being, which I'm not an expert, a commitment to the grid that II we will run at 40 percent power.
Q Recognizing that the term commercial operation 12 13 has a number of uses, is it your understanding that the NRC has 14 some responsibility over which a unit may go into commercial 15 operation?
16 A
The standard tech specs as issued provide our license.
I7 We could interpret the standard tech specs in a fashion that 18 l might allow us to be commercial at some lower power level.
Of I9 course the NRC is responsible to determine are we making the 20 correct interpretation.
If we could interpret that we could rutt 21 at 40 percent power but could we not satisfy the license require-O 22 ments, then we would not be allowed to do that.
23 !
MR. LIBERMAN: Is n ' t it fair in that connection to -- this O
24,1sn.t a question; it.s a comment that the Nac.s August 3
- Ace-Frozral Reporters, Inc. l 25 release describing the Three Mile Island-2 accident contains a l
i
Toole - direct 42 1
foott.ote which makes the point that some plants have been "de-2 clared commercial" or something like that at levels less than
~
3 100 percent power level but this was not the case in the case O
4 of TMI.
I guess that that release distinguishes, didn't make 5
a distinction between 98 percent and 100 percent.
6 MR. EVANS:
At this time, Mr. Toole, we 7
vill recess this deposition rather than termin-8 ate it and the reason is that at some point in 9
the future we may want to ask you additional 10 questions.
It's not our intention at this-time 11 to have that need but if new information should 12 turn up we would like you to be available to us.
()
13 I want to thank you for coming today and partic-14 ipating in this deposition.
15 (The deposition is recessed at 2:10 p.m.)
16 17 18 I
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22 23
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24!
Ace - Fedital Reporters, Inc.
25
a 43 CERTIFICATE 1
I, MARGARET TEILHABER A Notary Public and Certified O-2 Shorthand Reporter of the State of New Jersey, do hereby 3
certify that the foregoing is a true and accurate transcript O
4 of the proceedings in the above-entitled matter as reported 5
by me stenographically on the date and at the time and p1' ace 6
hereinbefore set forth.
7 I DO FURTHER CERTIFY that I am neither of counsel nor 8
attorney for any party in this action and that I am not in-9 terested in the event nor outcome of this litigation.
10 i
11 12 13 l
g c y,,, (,,a f.z l
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A o,tary Public of New-Jersey t
i 15 16 17 18 l
19 20 21
()
22 23
()
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- Ace-Fedetal Reporter, Inc.
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