ML19308C474

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Deposition of CC Kuehn (State of PA) on 790920 in Harrisburg,Pa.Pp 1-35.790904 Confirmation Ltr Encl
ML19308C474
Person / Time
Site: Crane 
Issue date: 09/20/1979
From: Chin R, Kuehn C
NRC - NRC THREE MILE ISLAND TASK FORCE, PENNSYLVANIA, COMMONWEALTH OF
To:
References
TASK-TF, TASK-TMR NUDOCS 8001240632
Download: ML19308C474 (38)


Text

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O N U Cl. E A R R E G U !. A T O R '/ C O M M I S S I O N O

IN THE MATTER OF:

I THREE MILE ISLAND SPECIAL INTERVIEWS i

DEPOSITION OF CARL C.

KUEHN O

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l i

i Place - Harrisburg, Pennsylvania l

Date - Thursday, 20 September 1979 Pages 1 - 35 T.i.58cn.:

(:02) m-37co l

ACE -FEDERAL REPORTERS,INC.

I Offxc:slRepor:ers 6340 4.t4 North C=pitol Street Washington, D.C. 20001 800 NATIONWIDE COVERAGE - DAILY

1 CR 7189 ree 9/20/79

)

UNITED STATES OF AMERICA 2

NUCLEAR REGULATORY COMMISSION j

3


X v

a In the Matter of:

5 THREE MILE ISLAND SPECIAL INTERVIEWS 6

- - - - - - - - - - - - - -X 8

INTERVIEW OF CARL C.

KUEHN 9

Holiday Inn Town 10 2nd and Chestnut Streets Harrisburg, Pennsylvania jj Thursday, 20 September 1979 12 3:00 p.m.

/~T 13 V

I.PPEARANCES:

14 ROBERT CHIN, ESQ.

COLM L.

EMST 15 FREDERICK HERR ROBERT SCH.WBERGER 16 NRC Special Inquiry Group on TMI 6935 Arlington Road j7 Bethesda, Maryland 18 1

19 20 21

("3 22 wJ l

23 24 eera Reporters, Inc.

Ace 25 i

CR 7189 2

ree 9/20/79 j

C O N T E 11 T S O

2 WITNESS EXAMINATION 3

Carl C.

Kuehn 4

4 5

6 7

EXHIBIT IDENTIFIED 8

1 3

9 10 11 12 O

14 15 16 17 18 19 20 21 22 g

23 24 n

Aceval Reprurs, Inc.

25

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3 CR 7189 ree E R_ Q q E E_ E I_ E E S_

9/20/79

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2 Whereupon, 3

CARL C.

KUEHN g'\\ J 4

was called as a witness and, having been first duly sworn, 5

was examined and testified as follows:

6 MR. ERNST:

Would you please be seated and state 7

your full name for the record and title?

8 THE WITNESS:

Carl C. Kuehn.

My title is State 9

Warning and Communications Officer for the Commonwealth of i

10 Pennsylvania.

Il MR. CHIN:

Mr. Kuehn, I show you what has been l

12 marked for identification as Exhibit 1.

Is this a copy of l

i

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13 the letter sent to you by the NRC Special Inquiry Group j

x_

14 concerning your deoosition here under oath today?

I l

15 THE WITNESS:

Yes, sir.

It is.

l 16 (Kuehn Exhibit No. 1 identified.)

17 MR. CHIN:

Have you read this document in 18 full?

l l

19 THE WITNESS:

Yes, sir.

I have.

i 1

20 MR. CHIN:

Do you understand the information in the {

t 21 letter, including the general nature of the inquiry, your

(~N 22 right to have counsel, and the fact that information you i

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l 1

23 provide here today may eventually become public?

l l

24 THE WITNESS:

Yes, sir.

I do.

l l

'Am Md Reponers, ine, j

25 MR. CHIN:

Are vou reoresented by counsel?

i l

4 1

THE WITNESS:

No, sir.

I am not, p'

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2 MR. CHIN:

I would like to note for the record 3

that the witness is not represented by counsel today.

,_s N-]

4 Mr. Kuehn, at any time during this interview you should 5

feel the need for counsel or to have an attorney present, 6

please advise and we will adjourn this interview and allow 7

you to make arrangements.

Is this procedure agreeable 8

to you?

9 THE WITNESS:

Yes, sir.

It is.

10 MR. CHIN:

Did you bring a resume with you today 11 for this deposition?

12 THE WITNESS:

No, sir.

I didn't.

I would 13

(~')

be more than happy to supply it to you if you so request.

i 14 MR. CHIN:

It is so requested.

Let the record 15 note that Mr. Kuehn will provide us a copy of his resume.

16 i

Mr. Ernst?

t i

17 MR. ERNST:

It would be satisfactory, if you l

18 just wanted to give it -- I guess we'll be interviewing 19 Mr. Williamson and Mr. Crowe next Friday.

If you just want 20 i

to have them bring it, that would be fine.

21 EXAMINATION

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22 t

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BY MR. ERNST:

ts 23 Q

Would you please describe your duties at PEMA?

9 Ace eral Reporters, it c.

25 engineer on a day-to-day-basis are the design of county, I

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I 5

1 local communications systems for emergency management

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purposes and the interface with public safety communication 3

systems throughout the Commonwealth, as well as any warning 7,k) s systems that might be eligible for federal funding through 5

the federal emergency management agency.

6 l

I,_

I,am responsible for providing all state agencies with

/

7-dommunications and warning capability in the event of 8

increased readiness or some type of emergency situation 9

in the state.

Therefore, we work on a day-to-day bas's 10 far as looking at other state agency communications systems, as 11 work on the complete interface of the agencies with the 12 Pennsylvania Emergency Management Agency.

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We maintain the state warning and communication system 14 for the Commonwealth, a warning system which is the 15 dedicated teletype system which interlinks the state office in Harrisburg and our regional offices with all of the 17 67 counties.

And we work fairly closely on a day-to-day l

basis with the federal emergency agency's counterpart, f

18 19 the army communications command, with communications projects.

20 i

Q How did these assigned functions cha.ge during j

21

'l the first week after the TMI accident?

l'~)h 22 l

A Basically, they remained the same.

My section l

l l

23 l

is assigned to the operations section as a function, and I operated as I norma 11y wou1d in bubbort #f the operations Ac ed Reponm nc.

25 I

of the communications and warning systems.

So basically, i

6 1

it didn't change at all.

(

2 Q

What communications systems were installed or 3

augmented during the one-week period after TMI?

A During the TMI incident, a series of hot line 5

telephones were put in, one to each of the six counties 6

that were directly involved.

And the reason hot line 7

telephones were used was, in the initial hours of the 8

incident, as things progressed, the line load incurred 9

on the state telephone system was such that we had trouble 10 getting down into the county emergency operating centers.

11 At the same time when we did get there, the number of 12 people that were there, it was hard to get the right

(~)

13

(_-

people and the right line.

So we installed six A-4 lines 14 with a hot ring capability to each of the county 15 emergency operating centers.

16 At the same time, we provided a feed to six of the county 17 emergency broadcast stations on a constant 24-hour line, la this to supplement any information that might be deemed 19 necessary by the governor's office for public information 20 during an evacuation, if an evacuation had been necessary.

21 Q

This is a hot line also?

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22 A

This was a constant A-4 line that was opened t-23 continually; constant information was fed down to the 24 f')

key Common program Control station in each of the six Acead Reponees, Inc.

I l

counties.

The theory was that in an actual evacuation I

7 1

situation, the county emergency management agencies would n

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2 supply the key emergency broadcast stations in the county 3

with information to the general public of that county on N-4 which access routes to take and that sort of information; 5

while at the same time over these lines, the state would 6

be feeding the stations supplemental information as to 7

gas information or food rationing or hospital information 8

that the broadcast stations could take off the line and insert them as they felt would be necessary along with the 10 evacuation plans.

11 The state has a communications van which incorporates 12 about 40 different public safety and statewide systems for

/1 13

(_)

the event of such emergencies.

This van was placed into 14 operation approximately Friday morning, the 28th, at i

15 i

around 11:00 o' clock, in support of some elements of the j

16 NRC, the FDA, the state Bureau of Radiological Health, 17 and the State Department of Agriculture, along with some 18 key PEMA, Pennsylvania Emergency Management Agency personnel.

i i

19 The problem being from the emergency operating center in 20 Harrisburg, a constant communication with the federal 21 agencies involved in the initial hours.

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In support of this, it was found that the frequency we 23 were using was breaking up because of the buildings around i

the EOC, so we put a repeater system in in the 460 megacycle A

erst Reporters. Inc.

25 van to supplement the communications.

So that was an l

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8 1

additional system that was brought into play.

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The army communications command supplied the Commonwealth

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with six radio operators and six transmittors as well as receivers that were installed at each of the six county 5

emergency operating centers to set up a semi-secured net 6

in the four megacycle van so we could pass traffic back and 7

forth without using the public safety vans.

8 Our problems during the initial outset were most of the 9

news media brought into the area when they came the 10 small Bearcat home-type scanners that would pick up the 11 information that was being transmitted over the systems 12 that we did have, and some of the information, it was felt r"

13

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at that time, was being misconstrued.

14 As a back up to the system and also to get us something 15 that was out of the capability of the inexpensive. scanners, 16 we went to the army and they supplied with us with backup man power and engineering to put the systems in in a 18 relatively short period of time.

19 Other than those systems, it was basically telephone 20 l as well as the -- we used the national warning system 21 a minimal amount of time.

In Pennsylvania we have two 22 l

('_)

sides to the system:

one, of course, is the national; the j

I other is the state side of the circuit.

Stateside in l

I Ace erst Reporters. Inc.

l 25 the Three Mile Island Nuclear Reactor No. 1 and No.

2.

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9 1

While we did have line load problems with the telephone,

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we never had a chance or never had a situation where we were really out of contact with either reactor site during

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4 the operation.

5 0

I gather there is, but would you explain to me 6

the difference between hot line and open line?

7 A

Well, the hot line was basically a standard 8

telephone installation, except rather than dialing up, 9

once you take the receiver off the telephone, it automatically 10 rings on the other end.

11 Q

But it is a dedicated line?

12 A

It's a dedicated line, and it's semi-secure in 13

('~s) the fact that nobody else is going to get the information.

14 The open line is one that was open continually where 15 information was fed down.

The only reason we went to 16 a hot line versus an open line was the fact that most l

17 of the emergency operating centers didn't have enough l

I 18 j

i people, really, to keep somebody on the phone.

And

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19 we didn't have enough information to be passing back l

20 continually, but yet we had enough that it was too burdensome 21 and too time-consuming to keep on dialing.

i

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22 i

(_ j Q

In the emergency operations center, how many 23 dedicated lines were there before TMI, and where did they go?

A erd Reportm, Inc.

25 A

The only real dedicated line other than the national!

I

10 1

warning system -- and we don't count that as a dedicated

(' h 2

line -- would be an interconnect between the operations 3

center in Harribsurg and the Department of Military Affairs

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4 out at Indiantown Gap.

That's a hot line type of 5

installation that links key personnel in the emergency 6

operating center in Harrisburg to the staff duty officer 7

out at Indiantown Gap.

8 Q

You didn't have any so-called internal, say, 9

dedicated lines between agencies or something like that 10 also?

11 A

Well, the emergency operating center is so designed 12 that normal, on a day-to-day basis, our people operate

()

out of their own little cubicle.

In that cubicle they 14 are supplied with a six-button key set, two six-button key 15 sets.

Tne first of which is assigned to a PX on the 16 switchboard.

The second is a toll-free nationwide WATS line 17 which is common to all state agencies, their offices.

18

, The third, fourth, and fifth -- depending on what cubicle 19 was assigned or has been assigned to that agency that normally 20 will move in that cubicle should an emergency of increased 21 readiness situation arise -- that third, fourth, or fifth

()

telephone number is always the emergency number for that 23 agency.

So when the Department of Health moves from their Ace 4 cal Reporters, Inc.

25 offices down to the offices at the EOC, when they move right l

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11 l

1 in, the same number you would normally dial for an

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2 emergency situation with the Department of Health would 3

automatically ring down within that cubicle.

They are not

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4 a hot line, but it's a matter of transferring from one 5

agency down to the agency representative in the hot line.

6 This allows the emergency team a number of accesses 7

in and out as far as they are concerned, they can get a 8

call off the switchboard and at the same time they can call 9

toll-free any place.

Or they can use their own emergency 10 number if they want; so it affords them some type of 11 flexibility.

12 Q

But it's not designed to talk from the cubicle

()

to their principal office?

14 A

No, sir.

15 The state agencies, the key state agencies, such as the 16 Pennsylvania Department of Transportation, Department of 17 Environmental Resources, Pennsylvania State Police, and the 18 Pennsylvania Game Commission, are supplied access to their 19 various radio systems from the EOC which isn't a telephone i

20 access or hot ring or hot line, but it is another resource 21 for them to use.

Without leaving the cubicle, they can dial up the intercom 23 in the communications room, and from there they can get p

p y

y e systems.

= Ace yet Reporters, in.

2S Q

But that is a line, that's not radio you're I

4 12 I

talking about?

A\\I A

No.

We do have a radio contact with them.

3 Q

By patching, you mean you go from the telephone 4

through the network to patch into the radio?

5 A

No.

We have the radios physically on-site.

It's 6

a matter of going from the cubicle; without leaving the 7

cubicle, they dial up an intercom and from there we will 8

patch them in the back room, which is maybe 50 yards away, 9

to the system.

10 Q

I guess about three weeks or so after these 11 dedicated lines were installed in the counties, they were then 12 removed.

Can you explain the reasons why?

()

A Normally, under normal conditions, normal 14 conditions for a disaster operation or emergency, once 15 the initial problems are over, which they were during the 16 Three Mile Island incident, the cost involved is, no matter 17 how long we put them in for, we look at an installation 18 cost and we look at 30 days whether we only use the telephone 19 two days or three weeks, up to 30 days we get the normal l

20 l

charge.

Anything on that 31st or 32nd day, we owe another 21 month.

The reason that the hot lines were put in was because of 23 the heavy telephone traffic and the switching problems.

24 l AceU(~\\

And that dropped off shortly after the, I guess, the c Reponen, Inc.

25 first or second of April.

We didn't have the problems with I

7

13 1

telephone switching, and the counties were gearing down I

2 by that time as far as keeping a minimal amount of staff on 3

duty.

There was no need for it right then.

j

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4 0

What is the installation charge and the monthly S

charge on a dedicated line about?

6 A

Normally, we look someplace around $50 for 7

the installation for this type of a system.

Then we're 8

looking at a mileage charge plus the hot ring wire up.

9 We're looking someplace, for this whole operation for the 10 six counties -- installation as well as our cost -- of about 11

$500 for the six telephones to the county, give or take a 12 couple dollars, and somewhere around $600 to $700 for

()

the EBS hookup, energency broadcast hookup.

14 Q

So it's in the range of $40 a month or thereabouts 15 per line?

16 A

Yes.

For instance, the charge to Dauphin County 17 was about $7 a month, but the charge down to York County 18 was S173 because of the terminal interconnection, that 19 sort of thing.

20 0

What was required for the initial hookup 21 physically?

What did the telephone company have to O

2 do2 23 A

Well, physically, in Harrisburg, it fas no real Problem to the telephone company, because the way the system Ace tal Reponen, nc.

25 is designed, telephone system to the building, it was a l

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14 1

matter of just going to one of the boxes in the complex, r~s q) 2 one of the telephone boxes, and dropping six telephones on 3

a desk.

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4 How, in the county installationr-I'm not really sure 5

because I don't know physically where they were located; most 6

of the county operations are the same as the state.

They 7

are in the courthouses for the counties, and usually the 8

number of pair coming in are not too great.

But 9

somebody physically had to go in from the telephone company 10 and make the initial hookup and wire it in.

II The time lag is maybe two or three hours.

It's one 12 thing we've always had good luck with or a good rapport 13

()

with the telephone company.

They respond quite well to 14 our requests.

15 Q

Somewhere I recollect that a need was perceived 16 for these hot lines by Friday noon, thereabout, and i

17 immediately a request was made for these lines.

But then 18 somewhere a statement that perhaps it was as late as Sunday 19 before five of the lines were in, certainly Saturday, and 20 l maybe the sixth line didn't get in till Sunday or so.

21 Is this accurate?

(')

22 A

It could be.

The reason I say it could be is v

23 the e were a number of things going on at the time.

I know, 2d An4r t Reponers. Inc.

for instance, we did have a problem with the installation 25 in York.

It wasn't that some of the lines weren't hot --

15 1

hot being that they weren't working -- we did have problems I~

2

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with the ring down circuit on them, that they would ring 3

automatically.

But our main concern, of course, was 4

just having contact with them.

5 I could probably say, fairly accurately, it was probably 6

till Sunday till every telephone would ring automatically, 7

but I would say that no more time -- using an educated guess 8

-- it was more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> before some kind of constant 9

contact from this telephone was established with the county.

10 0

So 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> might be a better time frame than 11 two or three?

12 A

I think so, more realistically.

When I say

()

two or three hours, I know within two or three hours after 14 the request, they were physically in Harrisburg in the 15 office there, depending when they could get crews.

I 16 know they were busy elsewhere.

17 Q

So I take it there must be existing wires in the 18 emergency operating center so all you have to do is put 19 in the hand sets?

20 A

We carry 166 extra pair just for that type of 21 situation.

This probably was a little different than most

()

in the fact that our normal operations are coming into 23 a devastated area where a flood or a tornado or something l Ace W Reponen, nc.

has taken out communications, and we're supplementing 25 l

nothing.

Where this operation was in our own backyard with j

1

16 1

the best of communications facilities left to us.

It was

()

2 a matter of supplementing the systems we really had.

3 I don't think that anybody looking at it realistically

()

4 that has had any time in disaster operations, they can 5

really criticize too much the communications that were i

6 involved.

You always get to a situation where there is 7

no disaster emergency operations that you have all the 8

communications you want.

There is just no way everybody is 9

going to get a telephone line when they want it, or 10 everybody has a portable radio to contact somebody they want.

11 But the flexibility was within the system, and the system 12 was never jeopardized, really.

()

Q I guess, physically, then, it's putting in hand 14 sets in the EOC, putting the lines and sets in the counties, 15 and the patching through, however the company does it, 16 with existing wires, just connecting them and get it on 17 through?

18 A

It's a matter of strapping in the central offices.

19 In a lot of instances, most of our emergency operations 20 centers -- when I say "ours" I'm referring to the county 21 as well as the state -- keep extra sets on hand, usually

()

to drop in during an emergency.

Most of them are 23 designed with the telephone wires already in the ceiling, 24

%.x(,)w seporteri, inc. over the false ceilings to drop down over various desks; j

25 so it's just a matter of strapping in the building, strappingi i

i I

i

17 1

at the terminal location or switching facility and right

()

2 back into the various offices you want.

3 Q

Friday the 30th, at 11:00 o' clock, would you 4

characterize it as essentially impossible to communicate with 5

the counties?

6 A

By telephone, yes.

It was pretty difficult.

7 Our time lag out of Harrisburg for dial tone was any place 8

between three minutes on up.

And by that time, we were 9

getting trouble calls, you know, my-phone-doesn't-work type 10 situation.

And it didn't take too long to figure out what 11 we had, but that was unavoidable, really.

12 Q

How could you communicate with the counties then at

()

that time?

14 A

We have the secured teletype system that takes 15 us right down to the county emergency operations center which 16 is straight-through communications where we can type back 17 and forth.

18 0

What is the transmitting speed on that?

19 A

60 words per minute off, of course, a pre-arranged 20 tape.

We can type, but it depends on the typist.

The 21 machine's set for 60.

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(_/

Q You mentioned that you do have continuing 23 arrangements with the telephone company to essentially

("T 24 Aci%.bW Reponen, Inc.

drop everything they are doing and put in lines --

25 f

A Yes, sir.

We've had that in the past, and that's I

l

l 18 1

just an ongoing thing between the state and the telephone

)

2 company.

Like I say, they've always been real good 3

responding to our requests.

4 0

Which company is this?

5 A

This would be Bell, in this particular instance.

6 Bell out of five -- I'm not sure about Perry County, 7

Perry may be United Telephone, and we've got United 8

Telephone in Cumberland County.

Now, United Telephone 9

Company as well as Bell brought in some of their 10 key management people and stationed them in Harrisburg to 11 make sure that they were going to be able to meet the needs, 12 so it wasn't a matter of dealing with sales representatives

()

or an installer.

We were dealing with the people v. hat 14 could move.

15 The initiative was taken on their part to do that, not ours.

16 They felt that the need was great enough; they wanted to 17 make sure something didn't slip through the crack, so they 18 came in themselves.

19 Q

You say you have arrangements with Bell, but I 20 l

assume that the other counties have other telephone 21 companies they have to work with and arrangements also at

()

the other end to see that it happen?

l 23 A

At one time, we had 63 different independent i

Ophe Compades E de ComoWeaM.

1 May be a CO M e l Ace rol Reporters, Inc.

25 off on that.

It's 63 or 65, maybe we're down to 57 now.

l l

t

19 I

This is a problem within the county.

Of course, it's a 2

problem to us if we have to go in the county.

But on a 3

day-to-day basis, the counties deal with these companies.

O V

And in some instances, they get the best of service; in 5

others, depending on the size of the company, we in the 6

counties have the problems.

7 Q

But it is true that PEMA is responsible for 8

adequate communications?

9 A

By the new law, yes, it is.

10 Q

Let's go to the events on Friday the 30th of 11 March.

Do you know Mr. Floyd of Metropolitan Edison?

12 A

ot personally, I talked to the gentleman once 13 Q

on the telephone.

O Once?

15 A

Yes, sir.

16 Q

That answers another question I have.

I7 A

To my recollection it was once.

18 Q

Then was Mr. Floyd the one you talked to on the 19 morning of March 30th?

20 A

Yes, he was.

21 Q

He identified himself?

22 A

Yes, sir.

23 Q

To the best of your recollection, can you O

describe the call?

Am_)ci Reonm, Inc.

A The call basically was, the gentleman identified I

20 I

himself as this Floyd at Three Mile Island, had an uncontrolled 2

release, you're going to need some buses to move these 3

people out.

And my response was, first of all, what people 4

and how many buses.

And he indicated at that time i

5 that it would be the people downstream, that he would take 6

care of his own people.

7 I then asked him if he could give me any information 6

as to the amount of the release, and he told me he didn't 9

know.

And the only other information he could give me was 10 the wind direction which he did at that time.

II I went from my desk, the operations desk, the operations I2 officer, he was on another line; so I went to the Deputy 13 Director, Mr. Williamson, Craig Williamson, and told him I#

basically the same thing that Floyd had told.

15 By that time, Mr. Lamison was off the phone.

Mr. Floyd 16 did have one more request and that was to notify the I7 Bureau of Rad Health that he would, he indicated he would I8 need help.

And he did not say what type of help he would need.

So that was basically how we took it from there.

20 It was my understanding that he contacted Da gain 21 County first.

He had trouble getting ahold of us, but did O

set tar uen-we toec, or c "r e,

=otitiea 8"re "

e 22 23 Rad Health which Mr. Lamison, the operations officer, 24

, O evidently was on the phone with when I had gone in to i Ac(,Joi Reporters. Inc.

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25 discuss the matter of Floyd's phone call.

l l

1

21 1

Q Uow, when you say "he would need some help" --

()

2 A

Mr. Floyd would need some help.

3 0

When he said downstream, what would that mean?

4 Downstream people would have to be moved?

5 A

I would assume by that, it's just an assumption, 6

that it would be down towards the Goldsboro area or he 7

meant downwind rather than downstream.

And it might be, 8

since it's been six months, he might have said downwind 9

rather than downstream.

10 Q

Did Mr. Floyd, at any time, to the best of your 11 recollection, inquire as *:o the state of evacuation 12 readiness of the State of Pennsylvania or of Dauphin

()

County?

14 A

No, he didn't.

He sounded like he was rather 15 in a hurry, and there was very little exchange between the 16 two of us other than his statement and my questions.

17 Q

What were your comments to him or questions?

Did 18 you ask him if he were ready to evacuate or when he might 19 evacuate?

20 A

No, sir.

When I asked him about any information 21 he could give me as far as the amount of the release or

()

the amount of even buses we were going to need, he 23 gave me the wind direction.

And then he basically said in the conversation he would take care of his own people.

Ace vct Reporters, in,

25 And here again, I assumed by that statement that he was, in l

l

22 I

fact, going to take care of his own people.

And if he felt

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2 v

the need to evacuate, which sounded to me being a layman, 3

that he evidently need to by the conversation, that he 4

would take care of that.

S Q

He did say that it was an uncontrolled release?

6 A

Yes, sir.

7 Q

Did he mention whether it would be continuing or 8

not?

9 A

No, sir.

I assumed that it already -- here again, 10 it was an assumption on my part just by the conversation, II that it was in the past tense that it was given to me -- that 12 it had already occurred and it was over with.

And we 13

]

didn't really go into any further talk --

Id Q

Just indicated it was gaseous and what kind of 15 a reading, did he say the amounts of the.eading?

16 A

He didn't know how much and he didn't say in 17 what form.

I didn't ask him what form.

18 Q

He didn't mention the 1200 --

I9 A

No, sir.,

20 0

Was he excited?

21 A

He sounded like he had things to do.

He certainly O

wesn't venicked av eny meens, sut with his procedures, if av 22 23 calling Dauphin County and by having trouble getting through 24

(]

to me, evidently he had his problem.

He just wanted to let AcsVW Reponers, Inc.

us know what was going on and get back to his business.

He l

i

23 1

was very professional about the whole thing, but we had

()

2 a clip conversation which is quite understandable under 3

tne circumstances.

4 Q

But he didn't -- let me make sure I get this 5

characterized properly.

He was in a hurry, professional, had things to do.

Was he overly excited or nervous?

7 A

I sensed he was probably excited to some extent.

8 It's hard to say.

I mean, only talking to somebody once 9

on the telephone, but I sensed he was probably excited.

He 10 was talking quite fast.

11 Q

And then you reported this call then directly --

12 A

Directly to the deputy director.

Q Mr. Williamson?

14 A

Yes, sir.

15 Q

And Mr. Lamison at that time was close by?

16 A

Apparently, he was already talking to the Bureau of Radiological Health.

They evidently had the same 18 information about the same time.

I'm not sure how they got 19 that.

It solved one of cur problems calling them.

20 0

Was there another call that you were aware of 21 from Met Ed about that same time?

(

A No, sir.

I just got the call because I was l

i 23 sitting at that particular desk and that particular line was incomin9 at that time

  • Ace tal Repon m, n.

25 Q

For the record, no, there was no other call?

Or, j

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24 1

no, that you were not aware of any other call?

,7~T 2

's A

No, I am not aware of any other call.

3 I

Q At that time?

-s

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4 A

At that time, yes, sir.

5 Q

Do you know, after this call, do you know who 6

in the PEMA organization called Carl Abraham, public 7

information officer in Region 1, NRC, regarding the 1200 mr 8

per hour reading and requesting advice on evacuation?

9 A

No, sir, I do not.

10 0

What, in your opinion, are the communications 11 inadequacies, if any, identified as a result of the 12 TMI emergency response?

And not necessarily just in

(~3 13 1m,,j PEMA, although I'm sure that's where you're most familiar, 14 but maybe in other organizations, other state departments?

15 A

Well, not directly as a result of TMI -- although 16 TMI plays a good bit or portion of it -- there is a 17 deficiency in the Commonwealth for fast communications between 18 the state and the various counties involved in an 19 interconnection of other state agencies, other than just 20 PEMA, into the counties or, in this, case, not necessarily 21 l

the facility but representatives of the facilities or state

(')'

agencies that are operating.

22 1

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23 Whether this is accomplished by state NAWAS system or

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a hot line type of system, that's certainly a need.

Although, 25 here again, it has it drawbacks as far as being line I

25 1

line controlled.

We see the problem cropping up in almost C) 2 every operation that we have when we have to get down to 3

the county 1.evel.

We feel that an integrated communications

, ()

4 i

type system within the Commonwealth that interlinks all the 5

county emergency operation centers as well as the state 6

agencies through the facilities of PEMA, since this is 7

what we're tasked to to, would be most beneficial.

8 The drawbacks to TMI directly were the overloading of 9

the telephone system, the commercial telephone system, which 10 will happen in almost any disaster in the first initial 11 moments.

There has been a lot of criticism of communications 12 in TMI, but I don't think people realize the flexibility

()

of the systems that were available.

There were some systems 14 down, when the telephone

.e item went down, but there was 15 no time that the state was out of communications with the 16 facility.

17 The national warning system side of the circuit was 18 operable.

However, we only used it two or three times that 3-19 we had a need to.

Otherwise, we had commercial lines.

20 We had our backup communication systems,.our repeater 21 system that we utilized.

We don't like to have to take s

()

ti:ae to bring these things into the field to use them, 23 out the comunications were there.

It was a matter of

.itilizing them.

, Ac; ni Reporters, in.

25 I think one of our problems was more of public information

26 1

rather than communications.

And that's kind of all r^s (x ')

2 lumped together, but there is an interconnection between, 3

an information flow between the various federal and state N-]

4 agencies as well as the facilities that have to be undertaken.

5 in an ophration like this.

I think there was, evidently, 6

from what we can find out, some problems as far as 7

inner agency talking between fed and state and facility.

8 But this was not a hardware communications type problem.

9 This was an information-flow type problem.

10 The support is there as far as the federal government 11 for communications and within the private sector for 12 communications in operations.

We just have never gone

(~'

13

()

into an operation where we had everything that we were 14 looking for.

As you look down the line, whether it's 15 an integrated communications system or anything we're 16 looking at, when we get in another TMI or another disaster, 17 we're going to be lacking for communications.

We're just 18 not going to have enough.

19 TMI was probably better because it was in our own backyard.

20 Had it been at Peach Bottom or Beaver Valley, we would not 21 have the facilities available to us that we had in

(^

22

(_)

Hariisburg, communications-type facilities.

There would have 1

23 been a great time factor involved in moving our systems out into the field and finding a suitable operations center to Ace rd Reponers, n l

25 operate.

I b

i

27 1

I think we were quite fortunate with having it at TMI if

(

2 we had to have it, just from that standpoint.

3 Q

This national warning system, I think you called 4

it, is that a hard line system or radio net?

5 A

That's a hard line system.

That's one of the 6

greatest fallacies with the system, we try to stay away 7

from hard line facilities as much as we can because of 2

our type work.

All it takes is somebody coming home late 9

at night from a cocktail party to knock out a good portion 10 of the communications system in the state by hitting a 11 telephone pole.

That's why we like to see the integrated 12 radio system.

But the cost involved in such a system, 13 n) right now, is astronomical.

(

14 And the hot line telephone is usually the first thing 15 we put in when we go into an operauion, because within 16 the first few hours, the logistics problems are so great.

17 After that, they have a tendency to fall down.

But within 18 a 24-or 48-hour period, that's usually when we' re bringing 19 supplies in, it's when we've got to have a constant, almost 20 l

24-hour contact with the counties that makes it so l

21 l

hard.

That's why we lean towtrds this system, because right

()

now, it was the only option available to us that was fast.

23 Once we set up the secured network that the army helped Provide us, we Could have passed the same type of information Ace

}:t Reporters, Inc.

25 within the initial few hours.

But it took time.

They l

l

28 1

brought in people from Texas and Michigan to do this, so

()

2 we had quite a time lag involved.

3 Q

I guess it seems a little bit of a concern that the 4

only mode of communications, assuming a jamming of the b

exchanges, the only mode of communications is one PEMA 6

dedicated teletypewriter that all departments have to use 7

and everything else, at 60 words a minute.

8 A

Other than the state agency radios, and there are 9

very few other than the ones I mentioned earlier, there is 10 no communications into the counties that is not a dedicated 11 line by teletype or that is not a telephone.

In the 12 past, we've used quite successfully the radio amateurs,

/^T 13 t.m/

but we have a real problem with this in the fact that thev 14 are, number one, amateurs; number two, we either don't have 15 enough people to operate or we've got too many people to 16 operate.

And then we have a real problem with the control 17 of the type information coming in and going out that is 18 needed and the way that the network is operated and the 19 way sometimes the information is misconstrued.

We have 20 those type of problems.

21 And it's not a reliable type situation.

We had radio j ()

amateurs that volunteered their services in the counties, t

23 in Dauphin County which was one that I know used radio r^

24 Acb)ad Reponen, Inc, amateurs from their emergency operation center down to the 25 mass care center they had in Hershey.

Because this is l

l l

29 1

segment and it's a PEMA problem as well as it is a county

()

2 problem.

When you set up a mass care center in a county 3

this size or any county, normally the public safety services a

like the police, the fire, the ambulance, usually have 5

fairly decent services.

They can talk to their cars and 6

so forth.

But when you move out of your. normal day-to-day 7

operation, you move in a high school, chances are we don't 8

have enough telephone lines in a high school to handle a mass 9

care center.

So we have to go back to the amateurs or 10 the CB clubs to provide us that information back to the 11 county so it can get back to the state.

12 It's a situation we don't like to be dependent on, but

)

we realize that right now that's our only backup.

It 14 wasn't necessary, as far as the state was concerned, during 15 the Three Mile Island incident, to use a link from the 16 state to the counties by radio amateurs -- especially with 17 the type of information that we were passing at that time.

18 0

I see where you might be successful in 19 using radio amateurs, but I wonder about CBs?

20 A

It depends on the county and the organization.

21 We have some counties that utilize the services of CB

(

clubs quite well and can't use amateurs because of the 23 type organization, or they won't work together.

Than we

(~N 24 l

have others who can't use any.

It depends on the makeup

, Ac'J nt Reporters, Inc.

25 I

of the various clubs or organizations.

I i

30 Usually, when you get in a situation like a flood or a

(~')'

tornado or this type of problem, you've usually got more 2

w.

people that want to volunteer services than you really 3

(A have need for.

A lot of the county directors don't want to 4

~/

get involved with those type of operations.

5 In the TMI, it's a different situation.

We're dealing 6

with in unknown.

We didn't have the overburdening calls 7

that we normally have from radio operators saying, Well, 8

I wculd be more than happy to donate my time, or, I'll 9

do this.

I don't know what the counties had, but we had 10 11 very little.

MR. ERNST:

Anything else that you would like to 12 IA 13 say for the record?

G

't a THE WITNESS:

No, sir.

MR. ERNST:

Any observations?

15 THE WITNESS:

I think we've covered everything 16 37 quite well.

I just go back to the, I don't think the communications situation was a bad as a lot of people would 18 19 like everybody to believe it was.

It certainly wasn't 20 l

as satisfactory as everybody would like to have it, but here again, at no time was anybody cut off from the outside 21 world.

'T 22 V

BY MR. ERNST:

23 24 Q

I guess the counties can't even talk to themselves,

!Am rst Resmrters, ine.

25 can they, except by telephone?

j i

31 1

A They can talk to themselves on the teletype.

()

2 O

They can?

3 A

But you can' t send a message from Erie to Philadelphia by teletype without having it interconnected 5

through Harrisburg.

In this case -- and I would have to look 6

at my circuit diagrams -- there's four counties to a 7

circuit.

For instance, Cumberland, Perry, and Dauphin, 8

and I'm not sure, but it could have been Lancaster on there 9

as well, could have talked to each other without going 10 through the main switching complex in the federal office 11 in Harrisburg.

So they did have some contact back and 12 forth.

()

They're a little bit more fortunate in the f act that 14 most of them either share these public safety police and 15 fire frequencies, or they are so close in proximity that 16 they use the scanners to cross-ban with the other counties.

17 So as Dauphin County is transmitting on 3390 and 18 Cumberland is on 4606 megahertz, they just talk back and 19 forth over the scanners to each other.

So they really 20 had better contact with each other than the state does 21 with them.

f SI)N 22 ti The counties, really, for the most part, are in fairly 23 decent shape.

They can take care of themselves.

The 24 Acef )\\

state supplies Communicatons on a limited basis to its own L d Reporters, Inc.

21 agencies, but try to get them interconnected when we don't I

1

32 1

have any hard line capability, and that's where we're really

(

2 nailed to the wall.

3 MR. CHID:

I just have one clarifying question, Mr. Kuehn.

I want to take you back to your earlier 5

i testimony about Friday morning's call from Mr. Floyd.

6 You said Mr. Lamison was on the line with BRP getting this 7

same information?

I I

8 i

THE WITNESS:

I believe so.

To clarify it, 9

when I left the telephone to pass on the information, 10 I went to Mr. Lamison who was on the phone at that 11 particular time.

I then went to the deputy, and then 12 by the time the deputy and I got back to Mr. Lamison's

()

office, he already had the information from the Bureau 14 of Rad Health.

15 I'm assuming, when I was looking at him to get his 16 attention, that he was getting the same information.

But 17 at that time, he did have the information of the 18 uncontrolled release.

How he got it, I'm assuning he got it i

19 from Rad Health, but he did know Rad Health had it l

20 when I got to his desk.

21 MR. CHIN:

By "same information" are you talking

()

about --

23 THE WITNESS:

Same information Mr. Floyd had l

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24 1

' Ace Iqal Reporters, Inc.

given me just moments before.

25 MR. CHIN:

About their plans to evacuate the f

i

33 1

island?

/~

THE WITNESS:

About the uncontrolled release 3

and needing the buses to move people out and that he would take care of his own people.

5 MR. CHIN:

You say Mr. Lamison was getting this 6

same information from BRP?

7 THE WITNESS:

He was getting the information from 8

BRP that they were aware of the uncontrolled release at 9

the island.

Now, I don't know if they had the rest of 10 the information as to having to evacuate or the buses.

11 MR. CHIN:

So same information applies only to 12 the uncontrolled release?

()

THE WITNESS:

Yes, sir, only to the uncontrolled 14 release.

15 MR. CHIN:

Nothing else?

16 THE WITNESS:

Not that I am aware of.

17 MR. CHIN:

That's all I have.

18 MR. SCHAMBERGER:

In that same time frame, with the 19 attempt -- or at least the reputed attempt -- of BRP to get 20 back to PEMA after they had made a judgment or an assessment 21 that there really was not a major problem and were unable

()

to do so by phone, is it your position or your belief or 23 suspicion that it would have been or should have been 24 (g

l Ac?L ' Reporters, Inc.

Possible to get through by phone if the BRP people had known hJ 25 the right route to go?

Is it a question of people information I

i

34 1

rather than hardware, essentially, that was responsible?

2 THE WITNESS:

Well, we had a hardware deficiency 3

for a short period of time, but I don't know who from the s

BRP would have been trying to get back individually.

And this S

is just my own opinion and certainly not of the agency's, 6

it depends on the type people you're working with within an agency, how well or how familiar they are with your 8

cmergency operation procedures.

9 Normally, when we deal with the Bureau of Rad Health 10 as an agency, we're dealing with four or five key people.

11 During this particular period of time, there were a number 12 of people f rom BRP that were working in another building,

~

f^T 13

(_)

in the Fulton building.

And depending on who it was that 14 was making the call or the judgment at that particular time, 15 would depend, I think, on a great deal of what the lag 16 of information coming back into PEMA was.

17 If it were somebody else that was not normally assigned --

18 MR. SCHAMBERGER:

To condition your response, 19 assume that it was either Mr. Gerusky, Miss Reilly, or 20 Mr. Dornsife?

21 THE WITNESS:

It's possible that the switchboard

(

was tied up.

They certainly are very well familiar with the 23 procedures.

I can't say at that particular point in time

(~h 24

, A$Jers Reponen, Inc.

there was a hardware problem, but I would take almost 25 anybody's word for it that during that time segment there was I

35 CR 7189 ree j

9/2p/79 a problem with the equipment.

I just have to assume that.

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2 MR. SCHAMBERGER:

That's all I have.

3 MR. HERR:

Nothing.

4 MR. ERNST:

In conclusion, let me say this is 5

an ongoing investigation.

Although we've concluded the 6

questions that we have for you today, there is a possibility 7

we might have to ask further questions at some later time.

8 We will, however, try to assure that this doesn't happen.

9 But for that reason, instead of terminating this 10 deposition, I will just recess it.

11 I do wish to thank you very much for your time and 12 for your assistance in helping us with our inquiry.

13 J

THE WITNESS:

Thank you.

14 MR. ERNST:

Thank you.

I 15 (Whereupon, at 3:50 p.m.,

the taking of the 16 deposition was concluded.)

17 18 Carl C.

Kuehn 19

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20 21

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22 23 24

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KUGNM - Emg iT e *

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UNITED STATES 8

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,o NUCLEAR REGULATORY COMMISSION k# p f WASHINGTON, D. C. 20555

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B-September 4, 1979 A

In Reply Refer to:

b 4.

NTFTM 790904-06 s

kuAn df% &

S Mr. Carl C. E..-

Warnings & Communications Officer Pa. Emergency Management Agency Room B-15), Transportation & Safety Bldg.

P. O. Box 3321 ~ ~ ~ ~~

~ ~~

Harrisburg, Pa.

17105 i

Dear Mr. Keene:

I am writing to confirm that your deposition under oath in connection with the accident at Three Mile Island is scheduled for September 20, 1979 at 3:00 p.m.,

in a meeting room at the Holiday Inn Town motel, 2nd and Chestnut Streets, Harrisburg, Pa.

Please bring with you a copy of.your resume and any documents in your possession or control regarding TMI-2, the accident or precursor events which you have reason to believe may not be in official NRC files, including any diary or personal working flie.

(V)

The deposition will be conducted by members of the NRC's Special Inquiry Group on Three Mile Island. This Group is being directed independently of the NRC by the law firm of Rogovin, Stern and Huge.

It includes both NRC personnel who have been detailed to the Special Inquiry Staff, and outside staff and attorneys.

Through a delegation of authority from the NRC under Section 161(c) of the Atomic Energy Act of 1954, as amended, the Special Inquiry Group has a broad mandate to inquire into the causes of the accident at Three Mile Island, to identify major problem areas and to make recommendations for change. At the conclusion, f its investigation, the Group will issue a detailed public report o

setting forth its findings and recommendations.

Unless you have been served with a subpoena, your participation in the deposi-tion is voluntary and there will be no effect on you if you decline to answer some or all of the questions asked you.

However, the Special Inquiry has been given the power to subpoena witnesses to appear and testify under oath, or to appear and produce documents, or both, at any designated place.

Any person deposed may have an attorney present or any other person he wishes accompany him at the deposition as his representative.

You should realize that while we will try to respect any requests for confiden-tiality in connection with the publication of our report, we can make no guar-V antees.

Names of witnesses and the information they provide may eventually become public, inasmuch as the entire record of the Special Inquiry Group's investigation will be made available to the NRC for whatever uses it may deem v

}D TY 6 10 {B D

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0-appropriate.

In time, this information may be made available to the public voluntarily, or become available to the public through the Freedom of Informa-tion Act. Moreover, other departments'and agencies of government may request J

access to this information pursuant to the lriva'cy Act of 1974.

The information i

may also be made available in whole or in part to committees or subcommittees of

'g' 1

the U.S. Congress.

If you have testified previously with respect to the Three Mile Island accident, it would be useful if you could review any transcripts of your previous state-ment (s) prior. to the deposition.

Thank you for your cooperation.

Sincerely, e

.I i

L M

Mitchell Rogovin, Director NRC/TMI Special Inquiry Group 4

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