ML19322C220
| ML19322C220 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/06/1979 |
| From: | Cobean W BURNS & ROE CO. |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001160640 | |
| Download: ML19322C220 (28) | |
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PRESIDENT'S COMMISION ON THE ACCIDENT AT TEREE MILE ISLAND
______________________________________________a___x DEPOSITION of BURNS &JROE, INC. by WARREN RICHARDSON COBEAN, held at Burns & Roe, Inc.,
633 Industrial Road, Paramur, N e *< Jers2y, on the 6th day of August 1979, commencing et 2:00 p.m.,
before Kathleen Russell, a Notary Public of the State of New York.
BENJ,OIIN REPORTING SERVICE CERTIFIED SHORTHAND REPORTERS FIVE BCEK.%t.tN STREET NEw TonK.NEW YORK 10033
[212] 374-1138 8001169 6 7 0
1 2
2 AP P E A RAN C E S :
3 bb. b_b__bbi_bbb**
4 STEIN, MITCHELL & ME*INES, ESQS.,
Atrorneys for Burns & Roe, Inc.
I' ~
5 1800 M Street, N.W.
Washington, D.C.
20036 6
BY:
GLENN A.
MITCHELL, ESQ.
I of Counsel 8
P RE S ID E N T ' _SCOMMISSION ON THREE MILE ISLAND:
9 WINTHROP ROCKWELL, ESQ.
Associate Chief Counsel 10 MICEAEL R.
HOLLIS, ESQ.
11 Associate Chief Counsel 12 coo D
W A RRE N RI CHA RD S ON C O B E A N, J -
14 havir.g been first duly sworn by Mr. Rockwell, 15 was examined and testified as follows:
16 DIRECT EXAMINATICN 17 BY MR. ROCKWELL:
18 Q
Would you state your full name?
19 A
Warran Richardson Cobean, J.r.
20 Q
Your current employer?
21 A
Burns & Roe, Incorporated.
22 Q
Your current position with Burns & Roe?
23 A
Vice president, Project Operations Division.
1 24 Q
Your current business address?
25 A
550 Winters Avenue, Paramus, New Jersey.
E ENJAMIN R EPO RTIN G S ERVICE e
e
1 Cob o a'n 118 d
$/5 2
Lazo the cpera:cr traLnLng aspect of thLs business, 3
would that ec=e to your attention as the vice-president 4
of the company >at this point?
5 A
- d this regards a ce=pany-wide policy, prehably 6
yes.
As regards a specidic client, not unless he was 7
=y client."
8 Q
We will confir= for the record, Mr. Cchean, 9
that yo u will be available to explain plan: =edidications 10 at TM: 2 in lieu cd covering the='.in detail today.
If 11 you recall, earlier this week during the first part 12 od ycur deposition, you said that you would be available 13 to do that.
We si= ply at this time would like to con-14 firm that for the record.
15 MR. M::Czz ::
For the reeerd, we want to 16 cooperate in any way that we can t:.crevide 17 infor=ation, but we want to avoid duplication 13 and epetition, and we hope that your requests 19 for these witnesses would bear that in sind.
20 (The belev described docu=ents were marked 91 as Cchean Deposition Exhibits 109 and 110 fer no identification, this da:e.)
23 Q
Referring you to what has been =arked as 24 Cobean'.3eposition Exhibit 109, de correctly charac-n-3 terize it as a February 24, 1973 letter frc= Mr. 3arten E ENJAMIN R EFO RTING S ERhtCE S
e e
- i...
1 Cobsan 119 C
T/6 2-of GPU to Mr. Cady and the fact that you received a 3
copy of this letter?
4 A
Yes.
p'
.3 Q
Could you take just a second to look that 6
over?
7 (Discussion held off the record.)
8 Q
Why is this limitation here in the firs:
9 paragraph of the letter, beginning with the first 10 sentence, it reads:
"This is to confir= =y request 11
=ade at the Tebruary Project Managers Meeting tha:
12 3 urns & Roe concentrate their effer: on =eeting enly 13 those work secpe ite=s that are essential to the 14 cc=pletion of design of TM 2,"
and it goes en.
I 15 vant te know wha
's going on here.
16 A
- n essence, what 3arten is trying to do is 1I to li=it the amount of work under the u=hre11a of 13 en
- -.-.":: ion contract, which is our Work Crder l
19 No. 2555 and 3021, and not pay for sc=e of the tasks 20 that Burns & Roe had been directed ec preceed with 01 by Met Ed: in o.ther words, to try to get Met Id to 1
j 1
99 i
pay for those out of some other =echanis=.
That's o-i 4
wha: I think this thing was the start ef.
i na' subsecuent to this ne=crandum, er maybe al=est e-0 sinultaneously, wa negotiated a task-type centrac S ENJ AMIN R EF:C RTIN G S ERVICE l
I coboan
.120 U.7 2
with Met Ed to do these kinds of things.
3 Q
- n other words, there was a concern here 4
merely to shift the financial responsibility from the 0
0 Se.7.1ce Corporation or GPU to one of its clients, 6
Met Ed?
7 A
That is correct.
8 Q
Who did you deal with as the primary Y
client on this job?
10 A
GPc.
I 11 Q
As a result cf this request of Mr. Barton, 12 wohld it be customary that you would attempt to respond b-to his request as it related to specific areas of 14 Burns & Roe's work, where Met Ed =ay have had a finan-15 cial responsibility?
Would you have custo=arily 16 shifted those ht111ngs of work in tho.s e a:;e as to Met Id?
17 MR. M CHIL :
Mr. Cobean personally?
1B Q
The company.
19 A
If we had a mechanism to bill Met Id, we would 20 have, but we did not have a contract; we didn't have 21 the mechanism to bill.
22 g
to you recall how this issue was resolved?
D.
A Not specifically, but I know that someti=e O'A later, on this issue, we had Work Order 2555, which o-3 Work C de 2555 was the original construction contract.
S ENJAMIN R EPORTING E ERVICE w.
.y.
1 Coboan 1,1 L
4/8 2
Work order 3555 was a work order with GPU for tasks 3
-that were required for first refueling.
These tasks 4
were generally modifications Lo the plant requised as
-s commitments by GPU to NRC to make that modification to o
6 the system by the first refueling.
7 Subsequent and in addition to those two work 3
orders, was another work order with Met Ed for those 9
" plant betterment items" th a t were requested by the 10 plant operator.
11 Now, the ele =ents that fell into the Work Crder 12 3555 were o rp hans for a while in a financial sense, U
in that G?U wanted Met Ed to pay for the=,
and Met 14 Ed wanted GPU to pay for them, and there was some sort 15 of an argument in that regard with the=.
aut that did 16 not in any way influence our progress on the work.
It 1I did influence how we billed for it, however, and we IS kept asking how,. where do we bill this, and that's 19 how we invented We.2 order 3555 which we billed under 20 the same ter=s and conditions as Work Crder 2555, 21 g
Mr. cobean, during this per.iod, and we t
oo are talking about the period of 1978, referring back 23 to your previous answer, when you were talking abou:
Q'A GPU war.hed Met Ed to pay for it, and Met Ed wanted 25 GPU to pay for it, the work under the scope of work E ENJAMIN R EFC RTING S ERhlCE
e Cobean 144 1
needs.
It may have been associated with financial 9u considerations, as well.
For example, it could very easily have been a result of a rate change of erection imposed by a
a inancial need.
6 7
Q But this cutback, as it related to small g
bore piping design,' occurred during the period which we are talking about, in these 3oard minutes, 9
8' 9
9 F**
d 10 A
think co.
L MR. MITCHELL:
am going to ask the yn g
repo rte r to mark these exhibits, right after the exhibit number, for identidication purposes 34 so distinguish the: from the other marking
.i -
as to 3
10 and designa tions of ether exhibits to which y-there were no objections.
yg (Discussion off the record.)
19 (The below described documents wer2 narked as Cobean Deposition Exhibits 115 to lla, 20 sy for identification, as of this date.)
n
\\'
g Q
Mr. Cobean, referring you now to what has n
93 been marked as cobean Deposition Exhihit 115 do I o4 correct *y identify it as a letter frc= A.
S.
- Can, 3 9 project manager to Mr. 3arton of G?U Services, which E ENJAMIN R E CRTING E ERVICE w e-m M_
O
1 Cobean 146
.o January of 1979.
3
.A This one looks like the entire report, 4
whe*eas,.the rest of them only have one page.
~
5 MR. so Lrs:
The record will reflect 6
th a t E xhib it 118 is apparently the entire 7
monthly progress report that was trans=itted S
8 by Mr. Dam and directed to J?U of which 9
Mr. cobean received a copy.
10 g
- want to direc your attention to th e 11 beginning of each of these =on:hly progress repor:s, 12 Mr. Cobean.
For example, looking at Exhibi: 115 13 under a heading which says, " Monthly ?: ogress Report,"
14 listed as number 1 it says, "The status of Burns &
i 15 Roe work supports the planned plant commercial 16 cperation date o f Septembe r 3 0, 1978."
17 Number 115 has the same sea emen:, tha: is.,
13 "A planned plant commercial cperation date of 19 september 30, 1978."
20 Now, referring to' Exhibit 117, under the 21 same heading, number 1 it says, "The status of 22 Burns & Roe's work supports the planned plant 23 co=mercial date of october 31, 1978."
24 inen referring to the final exhibit, which is 25 number 118 under the name "sasic Heading," it says, S ENJAMIN R EPO RTIN G S ERVICE
- )
../
1 Cobonn 147 2
"3&R complete i task required to support the planned 3
. plant com=e:cial operation date of 12/30/78."
4 My question specifically is what caused the 5
changes in the planned plant commercial operation 6
date during this period?
7 A
I don't-recall, but it is probably s o m*. chin g g
to do with the prediction of how long it would take 9
to do e,srtain construction activities.
10 g
Who sets the planned plant eemmercial 11 operation date?
12 A
The client.
D Q
Therefore, any targeted date would be 14 set by GPU?
15 A
That is correct.
16 Q
What is the practice by which GPU 17 arrives at that decision?
How did they ce=e cc tha:
18 decision? ~
19 A
Principally, by analysis of the construction 20 schedule.
21 Q
What is Burns & Roe's input or i= pact I\\ ;
22 into that decision and that analysis by GPU as 23 to what date co==e rcial operation is to commence?
2?
A Cur input is usually involved with quantities.
25 As an exa=ple, we estimate that there is over
+
guoe em l
l
Cobean 148 2
four million feet of cable to install in the plant.
3 The e astructor says' it akes him Y number of 4
man-hours to put in a cable, to install it and'they
(-
5 come out with a dace.
If installing cable happens 6
to be on the critical path he will arrive at a 7
date when he will be finished with the work.
g That is the way Burns & Roe gets involved in it.
9 c.
Are you recuested by the client, in 10 this case CPU, to evaluate the status of the plant 11 or project and in turn sub=it to GPU your "c=c=ents 12 regarding any planned plant operation date?
[3 A
No.
14 Q
Do you =ake any recommendations or 15 suggestions to GPU as to when you believe that 16 the plant will be ready for co==ercial operation?
17 A
No.
18 g
aid you in this case?
19 A
No.
20 7
Were you ever involved in any discussions 21 with any GPc personnel as it related to any of k.'
22 these planned plant commercial operation dates that r
l 23 were scheduled?
l 24 A
Yes, that was discussed er the elements of t
25 it was discussed a: every project =anager's =eeting.
SENJ &fN R EPC RTIN G SERVICE
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1 Coboan 149 2
Q What would be the gist of those 3
discussions?
4 A
Well, th e gist of the discussions would be r
5 the plan to complete :he plan t as a critical path 6
that goes through, for example, the production of 7
cable pull slips and the pulling of the cable and 8
the terminating of the cable and the energi=ation 9
of each'of the individual wires.
10 In that process we would need to provide facts 11 to the constructor who was: responsible to p ro vide a 12 schedule, that you will complete this work on D
that date and you would include the nu=ber of 14 pull slips that he could expect to get, the dates 15 by which he could get the=,
the number of ter=ination 16 slips he would get and when he would get those.
17 Q
What is th e first date that you can 13 recall that was set by GPU :o begin plant commercial 19 operation?
20 A
I don't try to remember those dates.
You know, 21 just referring,to these things I would say the first 22 date was Septa =ber 1973, but ! know there were s
23 previous dates.
24 Q
You are aware that there were previous 25 dates?
E ENJAMIN R E.:C RTI N G SERVICE I
a h
i 1
Coboan 150 2
A Yes, but I don't re=e=ber the dates.
i 3
Q You =en tioned earlier tha: this 4
v==1d nor= ally b e discussed a: the project =an a ge r,' s e'.
5
=eeting?
6 A
The ele =ents of the issue, the issue is always T
to get the plant built and get it build safely 3
and on tine within budget.
We would only talk 9
thout those tight places, those within the critical t' e project =anager's =eeting.
10 areas at n
11 Q
During your time as project =anager, l
- aving the coordination responsibilities fo r the B
project, what was your understanding of when 14 co==ercial operation was Oc begin at this plan ?
1~
.3 A
As ! recall, when I first joined Three Mile 16 Island and got =y feet on the ground as to what 17 ve were targeted at, I think it was the su==er or 3
th e fall of 1978, so=e ti=e in that area.
That
.-is was our targeted date for ce==ercial operation.
02' That see=s to support this Septe=ber 1978 date.
El I =ay be wrong, but that's just.=y recollection.
22 In the s"-
e r o r f all, I believe the year was 1973, C3 h=t I a= not certain of that.
C' Q
To =ake sure that I completel under-C3 stand where you were in the picture at this ti=e, i
l S ENJ AMIN R E.=C RTIN G S ERVICE 1
m
1 cobaca 151 2
what was your position and responsibility, say 3
beginning September of 1979, as it related to this 4
project?.
m 5
A September 1978?
6 Q
Yes.
7 A
I was division director.
8 Q
Of which TM 2 was your project?
9 A
one of the projects.
10 Q
As division directo? you had primary 11 r e s p o n s ib ility, fro = Burns & Roe's viewpoint, 12 for the; coordination and direction of this project, 13 is that correct?
14 A
No, my project manager did.
In this case 15 it was Mr. Dam, but he had that responsibility to ne.
16 Q
Mr. Dam reported directly to you?
17 A
That is ccrrect.
18 Q
And to no one else?
19 A
that is correct.
20 Q
What discussions, if any, took place 21 in September of 1978 with GPU in the context of
_/
22 meeting the Septe=ber 30, 1973 planned plant operation 23 date?
24 A
I don't know.
I really don 't know the answer 25 to that, because it is apparent that it wasn't in E ENJAMf N R EPO RTIN G S ERVICE
-- ~
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1 coboen 152 2
september.
It was sometime between July and August.
3
.The ec=mercial operation date was shifted from 4
S e p t e =b e r the 30th to October the 31st.
3 Q
What is your understanding of the 6
reasons specifically for that shift?
7 A
don't have an understanding.
As I said 8
before, I think I would get that is the result 9
of a ney estimate to complete cons :ue ion work.
10 Q
Ead Burns & Roe's work been completed 11 by Septe=ber of 19 73?
El A
No.
You can tell the work for commercial 13 operation =ight have been completed.
Probably was, 14 but there was more work to do that would not have 15 interfered with commercial operation.
16 Q
Did you receive, during the fall of 1975, 17 any =emoranda, telecoms, or were you involved in any 13
=ee ings er conversa:Lons wherein the clien:
19 expressed a concern about the change in the planned 20 operation date from september through Oc ober and 21 from Oc:cher through November?
22 A
Yes.
I don't recall.
I am certain that it was 23 discussed. Whether I was there at the discussion or 24 not a
no pocitive of that ei:her.
25 g
Let =e nake sure : understand precisely l
E ENJ AMIN
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1 Cobean 153 2
for the record.
During this period of ti=e when 3
-:h e clien: had set a s ep t e mb e r 30, 197a date, 4
then later changed that to October 31st, then
(-
5*
changed it to No ve mb e r o r D e c emb e r 30, 1978, 6
you had no discussions, you cannot recall any 7
, discussions or meetings you held with the-client, 8
wherein the client expressed its concern about the 9
constan: changing of these dates?
Is that your 10 understanding?
11 A
don't recall any specidic discussiens.
I as UZ certain that the fact that the dates were changed D
was discussed and discussec probably at project 14 manager's meetings.
In all likelihood I was, no 15 there at the project =anager's meetings, but : am 16 not certain.
17 Q
would Mr. Da= have been there as your 13 representative?
19 A
Yes.
20 Q
Did Mr. Dam-report to you during tha:
El period --
22 A
Yes.
23 g
any ed the client's concern abou:
24 the cc'.stant changing of these dates?
25 A
- am sure if the clien expressed a concern EENJAMIN R E;:CR LNG S ERVICE
1 Cobean 154 9
about it do Burns & Roe or Oc Mr.
Oa=,
I am 3
certain he did.
4 Q
Are you saying that you are not aware 5
ef any concerns that were voided by the client 6
regarding the changing of the planned plant 7
commercial operation date in th e fall of 1978?
8 A
I did not say that.
I s aid I did no recall 9
any specific concern in the context of these 10 specific date changes.
The client was always 11 ccnce rne d and always expressed a concern abou:
12
=eeting a commercial operation date.
That was B
his principal goal in life, to make that co==ercial 14 operation date in some way with this project component.
15 I= this stage of the ga=e, as I recall, 16 the design as reported in these reports was 17 essentially complete.
We were just doing little 13 tasks, little punchlis: items.
19 Q
Are you saying tha: during this period
'20 that, although the cli
- =ay have expressed some 21 specific concerns, you are not aware of them at this 22 time?
l 23 A
- do not recall them.
24 Q
You do nce recall Mr. Oa= having l
l 25 expressed to you any ccncerns related to him by the l
E ENJ AMIN REFCRTING S ERVIC E l
t
1 Cobean
.155 9
clien ?
3 A
No: as a specific evene.
4 Q
Were any of your s up e'rio rs or did an.y.
m 5
of your superiors here at Burns & Roe at anytime 6
co==unicate with you either in writing or at a 7
meeting or a telephone conversation any specific 8
concern expressed by GPU of the changing of the 9
planned date of commercial operation?
10 A
No.
11 Q
Oid you ever discuss this changing 12 of the targeted date with any of your superiors?
13 A
Yes.
14 Q
What was the extent or the gist of 15 those discussions?
16 A
objective was to keep Ken Roe personally.
17 infor=ed of what was going on.
So, I wculd teli 1
13 him, keep him inforned as to any significan:
19 changes in the project status as he las: understood 20 them.
21 Q
Was this obj ective, that is, keeping
]
22 Mr. Roe I take it Mr. Roe is the president?
l 23 A
And chairman of the Board.
1 1
24 Was.this objective of keeping Mr. Roe 25 infor=ed of the fulfill =ent of this objective at i
l l
i SEN AMIN R E.:C R~1 N G S ERVICE I
1 Cobean 156 o
Mr. Roe's recues ?
3 A
I don't know.
That is an understanding that 4
we had about keeping him infor=ed.
5 g
oid you discuss this procedure of keeping 6
him info rmed with Mr. Roe?
7 A
Yes, as to how he best wanted to have it happen.
3 He told me to use =y judgment in letting him know 9
what wai going on.
10 Q
when did these discussions with Mr. Roe 11 take place?
12 A
On a non-scheduled basis, whenever thought it E3 was important or whenever he thought it was i=portan:
14 to get together.
15 g
Can you think a moment and give =e some 16 specific times in which these discussions took place?
17 MR. MITCEZLL:
The time fra=e, you mean?
18 Q
ies.
19 A
No, I canno: answer tha:.
- don' know how 20 to answer that.
21 g
Did you have any of these discussions 22 with Mr.
ice in the fall of 1973?
23 A
I am sure : did, I don't resemb e r the specifically.
24 c
In any of those discussions, did Mr. Roe c
25 indicate to you tha: GPU was worried or concerned about i
E ENJAMIN R E;:C RTIN G S ERVICE
1 Cobean 157 2
getting on-line commercially some time that would 3
be before the year ended in 1978?
4 A
- a= not sure whether he info rmed me of that 5
or : informed.him of that.
su: I know that 1:
6 was important to GPU and I know that I informed 7
him that it was i=portant to GPU f o, accounting 8
reasons, if for no other reason, to try to get the 9
plan c.;-line ecumercially before the end of 1978.
10 Q
From what source or fro = where did 11 you derive, assuming you inf o rme d Mr. Roe, for exa=ple, 12 where did you derive your knowledge of GPU's 13 concern, as you stated for accouncing purposes er 14 whatever purposes, of commencing operation before 15 the end of 1978?
16 A
Well, I was in con act with varicus ne=bers of 17 GPU on essentially a constant basis, unstructured 13 and further= ore, ny prefect =anagers kep: ne informed 19 of the results of meetings that they had had.
'20
- read all the meetings' notes, all the 21 telecoms, of all the project nanager's meetings 22 that ! did not attend.
I kept myself appraised 23 of what was i=portant and : had personal contacts 24 within gPU that I talked to en a non-structured 25 but relatively consisten: repetitive basis.
I had E ENJAMIN R E CRTING 3 ERVICE
.M
s 1
Cobonn 137-A o
contact with the vice president o ' Gene ra tion,
as an example, in GPU.
a 4
(Continued on next page.)
n.
3 6
7 S
9 10 11 lo la
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ol en Ud od
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Cobean KR4dil 1
,158 n
Q Referring to this unstructured, and 3
you have characterized it, or as needed discussions 4
with your contacts in GPU, we are referring to this 5
issue of GPU's concern to com=ence operation by the 6
end of 1978, is that correct?
7 A
Yes.
They made it very clear to all project g
participants that this objective should be made, 9
if at all pos sible.
10 Q
what did you understand that request 11 y GPU to mean, if at all possible?
12 A
We ought to not spare any effort in trying to
[3 sake sure that we get it.
Find out the, problems cf 14
=aking those dates now so that we had an opportunity
/
15 to try and scive the problem be fore it became a 16 prohibition to =ake the commercial operation date.
17 Q
Can you recall whether there were any 13 meetings with the vice president o f Generatien of 19 GPU that you referred :=, wherein, this issue was dis'ussed, that is, the meeting that you attended er 23 c
21 Mr. Dam attended?
90 A
With the vice.cresident of Generation?
Z3 2
Yes.
24 A
!. don't remember any specific meeting, nc.
25 Q
Was the vice president of Generation at S ENJAMIN RE CRTING S ERVICE l
l 139 4-2 1
Cobocn 2
GPU the persen wne was primarily responsible for 3
the decision on this date, for the co=mercial 4
ope ation date?
O 5
A
- would guess 6
MR. MITOEELL: Oon't guess.
7 A
- would think that his project =anager would S
be the guy to put it together.
9 MR. M::cHELL:
Mr. cobean, answer these 10 questions as to what you know.
Nc: guess, think, 11 suppesitions and speculations.
12 Mr. Hollis is not interested in that.
D know the Co==is s ie n i s not.
14 Q
Whb was the vice president of Generation?
15 A
Mr. Arnold.
16 Q
Why would you have been contacting l~
Mr. Arnold instead o f someone else?
13 A
secause he is my contac.
19 Q
Was he your counterpart, so to speak, a:
20 GPr?
21 A
Yes.
us 20 Q
So, as a result of the contacts and 23 the conversations you had with GPU personnel, 2?
Mr. Ar-old among others, did you have the distine:
25 impression or unders tanding that GPU wanted to E ENJAMIN R E. '" RTIN G S E,R. VI C E p
' "' O 4-3 Coboan
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2 start operating this plant before the end of 1973?
3
.A If a: all po s s ible, yes.
4 Q
You mentioned earlier in a response _ o 5
=y question about seme of the reasons that =ay have L
6 heen related to you in the course of these discussions 7
as to why GPU wanted to co==ence operation before the 8
end of the year, you mentioned the fact for 9
account?ng purpos e s at a =ini=u= GPU wanted :o 10 co=mence operation, is that correct?
11 A
- didn't say th a t.
I said accounting purposes 12 or for whatever reason.
D MR. HOLLIS:
Can you find that answer 14 and read i: back to me?
15 I want to make sure what Mr. cobean is 16 saying here.
17 (The record was read by the reporter.)
18 MR. HOLLIS:
Let the record reflect that 19 we took time to go back and find exae:1y 20 what Mr. cobean had said, and in tha l
21 context of discussing whatever reasons there l
l l
22 were relayed or communicated to him by GPU 23 or any other source, tha: Mr. cobean stated 2?
and quote:
"They were important to OPU 25 for accounting reasons, if fer no o th e r reason."
E ENJ AMIN R EPC RTIN G S ERVICE
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Cobocn 141 o
Q Going back to my earlier question, 3
Mr. Cebean, what did you dean earlier when you 4
said tha: the commencing of===mercial operation 5
before the end of 1978 was impor:an: :o GPU der 6
accounting reasons, if der no other reason?
7 A
That's very simple and very appar n: to anyone 8
that knows the Reading structure and e lectric p ublic 9
4:lli:Les.
10 g
Could you explain that?
11 A
The costs incurred on the constructica of 12 power plants enters the rate base only whe..: the 13 plant has com=enced ecmmercial opera:icas and the 14 rate base then allows the public utility to start 15 obtaining money from the customer, frc= their 16 customers for :he investment made in building that 17 power plant.
13 catil tha: time, the funds generated to 19 provide the design and the construction edforts 20 al=os all =cce from internal working capital 21 irrespective of this investment or from money N
/
"a that is borrowed.
23 one thing that is i=portan: :o unders:and 24 is tha-at no time during the period that I was 4
25 associa ed wi:h Three Mile :s;and dif c?u :ake EEN AMIN
- i E.:C RTIN G S ERVIC E 1
.-e-=
em
4-5 1
Coboan 162 3
wha: I consider even in retrospect to be unsafe or 3
. unwise steps in the process of ge::ing the projec:
4 completed so that the. plant could be declared 4
'~'
5
- m*::ial in c d*: Oc :ake advan:598 of the 6
a Counting system as I just described tcyou.
7 They had a certain number of construction activities 8
that they had to complete.
9 They had all of the Testing Program to 10 satis f actorily pe rform, plus they had to comply 11 with all of the licensing activites demanded by 12 th e NRC.
They did that and they did it religicusly L3 and they did it well.
14 The construction, the design, the construction 15 and the testing o f the power plant a no time, 16 did think, gotashortehanged.
17 Q
During this pe riod, the fall of 1978 18 or before then, did you have eenversations with 19 Mr. Arnold or any other GPU personnel in reference IO to this accounting concern, as you have described it?
21 A
Nothing directly about that, just about
/
22
-getti~ng the clant completed.
f 23 Q
During the fall of 1978, in your position 24 as vic. president with TMI 2 being one of the projects 25 under youre responsibility, dif you na:<e any trips EENJAMIN R E CRTING S ERylCE
4-6 1
Cobocn 1*3 9
down to T.MI?
.A During when?
.v.a.
.ge._ve-
..s. e a_.
_so 3 w.h. e n 5
you were vice presiden.
6 A
- don't re call, p rob ab ly.
7 Q
During this period, that is, 1978, 8
what was the policy regarding overtime work on this 9
project that you were aware ef?
10 A
construe:Lon overtime?
11 Q
Construction or whatever. Let's just take 12 construction overtime ~.
13 A
- don't recall.
It varied fr== time to time.
14 sometimes there was limited overtime on specific 15 authorised activites by the client and those obviously 16 were the ones that were on the critical path.
17 And that was true for either Ingineering or 13 Construction.
19 Q
Taking Inginee ring as the focus, 20 what was the policy in 1973 from the engineering l
21 viewpoint or at.3 urns & Roe's peint of view as a
s
~/
4-
~~'ated.to this project?
23 A
To minimica overtime.
24 C.
Was that policy in effect during the i
n-
_a
.a_. oa
.s 3 ~e S,.
EENJAMIN R E.:C RTI N G 3 ERVICE
~ _, _..
3.,
e.3 %
4-?
1 Cobocn
.o A
believe so, but : think that has been our 3
policy right along.
We have not had a policy since 4
I have been associated with Three Mile :sland to 5
- 7 :: =aximi e ove:21:e-6 Q
Who =ade that policy decision?
Is tha:
7 a surns & Roe decision?
8 A
Yes, that is a general policy decision on th e 9
part of Burns & Roe right now.
10 Q
sas the client, GPU ever expressed, 11 during the 1978 period, any concern about overtime 12
- o you?
13 A
- don't recall any such discussion, but 1:
14 could have happened.
15 Q
Were you aware of any discussions tha:
16 GPC =ay have had or co=ments GPO =ade in reference 17 to oversine by the construe: ors or other s involved 18 in the.::0 ject, besides Burns & Roe?
19 A
No.
20 Q
During the fall of 1978 and as talking 21 about September to December, from your vantage C
02 poin as the vice president having T.M 2 as one 23 of your projects, was there a lo: of overtise work 24 perfe rn ed by Burns & Roe personnel?
l 25 A
- don't reme=ber, but : don': think so.
There S ENJAMIN R E:C RTIN G S E.iVIC E
+
I
f e
4-5 Cobocn e
3 may have been specific overti=e, say in stress 3
.in order to get some stress repor: co= pie:ed, 4
but don't recall anything as a generalized 3
thing.
I am positive that therewas so=e generally 6
within the project.
7 Q
what about as it re late d to the construction 8
cf the plant?
9 A
The overti=e by the co ns tructo r?
10 Q
Right.
11 A
I am not aware, I wouldn't be.
12 Q
You never had any discussions or heard 5
of any dis cussions regarding overtime during tha:
14 period on the part o f the constructors of the p ro j e ct ?
15 A
don't recall.
16 (The below described document was marked 17 Cobean Deposition Exhibit 119 for identification, 13 as cf this date.)
19 Q
Referring to what has been marked as 20 Cobean Deposition Exhibit 110, do : correctly 21 characterise it as a memo from Mr. Herbein to
.~
/
22 Mr. Klingaman, among others, regarding the TM: 2 23 surns & aoe proposed Plant Description Manual of 2?
which ;yu received a copy of, is that correct?
25 A
Yes.
S ENJ AMI N R E. C RTING E ERVIC E w MM e
M sg
-