ML19326D801
| ML19326D801 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/25/1979 |
| From: | Heward R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| NUDOCS 8007030334 | |
| Download: ML19326D801 (55) | |
Text
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1 CR7296 1
NUCL5AR REGULATORY CCDtISSION THREE MILE ISLA:;D SPECIAL 2 l INQUIRY GROUP 3,..............
4 DEPOSITION OF RICHARD U. HE'A\\RD 5
0F 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 Headqucrters 260 Cherry Hill Road II Parsipoany, Nere Jersey Tuesday, September 25, 1979 13 APPEARANCES :
14 ! DAVID J. EVAUS, ESQ.
R. LWPINCE VANDENBERG 15 ;NRC/TMI Special Inquiry Group I
16 l JAMES 3. LI3ERMAN, ESQ, iGeneral Counsel for General Public Utilitics 17 !
! 00COLiS E. DAVIDSON, ESQ.
18.i li 19!4
'i i
20 i i
21 PIiCGTED SY:
PAFaiR'lT J. T7.ILTA3ER, C.S.R.
22i I
23 e
i 24 'l
- e -Fe erat Reserters, tec. l 25 2
- Il 4
0 80070302 k 1
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2 1
1 INDEX 2 !: UIT:'2SS DIRECT 3 iRICIBRDHEWARD 4
By Mr. Vandenberg 4,6,10,16,23, 29,44,'49 5
By Mr. Evans 6,10,15,20,22, 6
29,32,43,45,49 7
8 9
EXHIBITS 10 NUMBER DESCRIPTION FOR IDENT.
II 1108 Position Description 21 l
12 l1109 CORB report 21 13, i
14 l l
15 16 17 18 ii 19!l i
lI 20ll a
21l; li 22!
d P
47 - FC:e?3 Re:ceters, fa:. ',
2 5
4 g,
0 3
l 1
MR. EVA!!S:
I want to note that this is 2
a deposition of Mr. Richard Heward which is be-l, 3
ing conducted by the NRC/TM2 Special Inquiry 4!
Group.
It's being held at the offices of Genersi 5
Public Utilities Corporation in Parsippany, New 6
Jersey, on September 25, 1979.
7 Present in addition to the deponent is 8
Mr. Jim Liberman, the general counsel of General 9
Public Utilities Corporation, and also Mr. Doug 10 Davidson of Mr. Liberman's firm.
Il Precent for the NRC/TMI Soecial Inquiry I2 Group is Mr. R. Lawrence Vandenberg and David J.
13 Evans.
14 Mr. Heward, I'm going to ask yo'u if you 15 had an opportunity to read the Witness Notifica-16 tion form and the letter to you from Mitchell 17' Rogovin wh'.ch I have shown to you earlier today.
I8 MR HEWARD:
Yes, I have.
l9f MR. EVANS:
Do you understand your ri:: hts 20 {
as sat forth in those forms?
2I MR. HEWARD:
Yes, I do.
22 liR. EVANS :
Do you have any objections
- i 23 to proceedint at this time?
!j
'l 2#!
No, l'8 - Fecetal Repst+ers, Inc. I o5 !
MR. EVASS:
Would you stend and raise q
I!-
,1 -
o 4
!.Ij your ri;;ht hand.
2 ja I C H A R D W. - H E W A R D, having been duly sworn accord-3!
ing to Inw, testified as follows:
4
. MR. EVANS :
Mr. Heward, at this time Mr.
5 !
Vandenberg will direct questions to you.
I i
6 ' DIRECT EXAMINATION 7 BY MR. VANDENBERG:
8 Q
Mr. Heward, my questions are going to deal with 9 jthe area of bringing TMI-2 into commercial operations at the end I
10 i f 1978 and to some extent your responsibilities at the site dur-o Il ling that time period.
I would like to start by having you descr:.b e I
12 !forusyourpositionwithGPUin1978andwhoyourecortedtoand
.13 !who ere your i==edicte subordin:tes.
14 A In 1973 my title was Manager of Projects and I reported Ib!co William H. Hirst and my 1:r.ediate subordinates reg:rding the i
16 lThree Mile-2 project were Jchn J. Barton, project menacer.
17
~
Q Can you ::o up the line a little bit more.
18 i
A 3eyond Hirst?
lo l Q
Yes.
i
,.0 !A Hirst recorted to Robert C. Arnold, vice-president of k
21'lL
~4 facneration.
l Q
}.r. Hewcrd, rcrt ycu c.eare of any *possible fincnt 22 23 cic1 inecatives f r bringing T:C-2 cn line before th2 end of 197:?
y 24A no.
4' C - Ftteral Reecrtets, tnc. h
, r *2
- 'o**
!*C I O EhOt [d C uniC NOs the 'ubject of k.
I.
L
1Heward - direct 5
1 la rate case and that there was a test year endinc in December of
\\
2i 19787 l
3'A I believe I was aware that the unit was the subject of a 1
I 4 ! rate case which I think was quite a few times.
I'm not aware of l'a test year.
5 6
Q Were you aware thcc it was a possibility for se-7 curing investment tax credits based on construction of TMI-2?
8 A
No.
9 Q
Did you ever attend any staff meetings with Mr.
10 Herbein or Mr. Arnold where these kinds of things might have been 11 discussed?
12 A
I never attended an: with Mr. Herbein.
I attended each i
13 ljone with Mr. Arnold t
/
hs held conthly, and it might have been 14 discussed there.
I don't recall at t?is time.
15 Q
Did you ever hear emmleyees below you talk about 16hany advantagns to Met-Ed or GPU that might be secured by brincinn n
I!
17 EiI on line?.
18 A Well, when you set out to build a power plant, it's ob-i l
19 0vious that you cant to preduce pcwer with it so it's obviously 20(advant:geous to get the thine on the line as : con as you can and
'I 210 that was the proj ect coal.
Ycu are referring, I take it frem 0
.i 22 h your previous questiens, to financial benefits end I don't re-23 '! call that I was aware of any specific financial benefits.
II i
24]l Q
Were you a. tare ir. a ;:eneral cense?
a-Fece al Recetters. Inc.1 25f A.
Yes, sure.
fHeward - direct v
t t'
1 DIRECT EXAMINATION i
2 BY MR. EVANS,:
3 Q
Let me probe this a little bit, Mr. Heward.
4 When were you first made manager of crojects?
j
~
l 5lA August 1, 1977.
6 Q
Before that
.e, what was your title?
7 A
Proj ect manager.
8 Q
When did you assume that job?
9 A
At Three Mile Island?
y 10 Q
Yes.
11 A
November 8, 1971.
12 q-So it would be fair to say that you have been 13 involved uith Unit Number 2 of Three Mile Island since cot strue, 14 jtion benen at the site?
I 15 iA That's fair to say, yes, except for two years prior to I
16 } no, ember 8,1979 when I was projec~ =anager at Forked River.
I J
l 17h wts not at all involved in Three Mile Island at that time.
4 4
18 Q
Se that veuld be 1969 or so you were involved 1
19i in the Forhed River project?
20.!A That's correct, yes.
!l ii 4 j !i Q
U'aen you first became involved with TMI-2, what h
22 il was the dcte that had been cet for ccmmercial operation?
2afjA I don't reclly rc=2nber.
I dea't rc=cwber when it was.
+
243 It was cubut:ntially earlier than when it went corrercial.
- e - Feserat Repotters, Inc, g 3...
3 'i BY :2. VXJD7.:!3 ERG :
k 3
O' FHeward - direct 7
1 Q
Did you have any understandinc that there were 2'jsome criteria to be_ met for bringing a plant into commercial op-I3'eration?
4 A Yes, I did.
I 5
Q What were those criteria or how did you learn of 6 them?
7 A The cr'iteria defined in a corporate procedure that iden-8 !tifies what is to be reviewed to bring a plant commercial, and llection is that it has to do with the level of training 9
lmyreco 10.and adequacy of the staff and the fact that the systems have been II' completed, tested, 1nd hcve been turned over to the operator and 12 accepted by the operator with acceptable punch list ite=s.
There l *', may be core criteria in that procedure.
I don't recall at the l
14 ' moment.
15 Q
Did you attend any meetints in the last half of l1978 that discussed at what time or how those criteria were goin::
16 i
17 fi' Jto be met?
I:
I8 lA Yes.
I participated in a meetinc in October of 1978.
loi' iThat was the meeting for the Commercial Operation Review Board II F
20 !to make the decisica as to whether or not they censidered the 21 plant acceptabic for commercici operation.
4 92 bj Q.
What was the tiew at that point?
ft 23fA The view.;t that coint was that the pl:nt had only been
~
' 4 i![ tested to 73 perccac power le'.21 and that the finc1 testinp had 9
.:n-rem e.nenm in:. 4 23E"yettobedoneand.ubject to the neceut:ble fin.1 testinc that s
ii C
! Heward - direct 8
I i1! they did centider adequate and acceptable to be classified cr e-I
'." mercial, I
3 !
Q Were you involved in bringing TMI-1 into core.i:r-4 cial operation?
5 A
I certainly was, yes.
6 Q
Was there similar criteria applied there?
7 A
There were but it was not done formally.
It was not a 8
corporate procedure at that time but we did sit down and review 9
similar things on an informal basis at that time to bring Three 10 Mile Island commercial, yes.
11 Q
Dick, have you ever been aware of a FERC and 12 before that Federal Power Commissien 120 day rule, sometimes 13. called Elcetric Plant Instruction 9D?
14 A
The 120 day rule vaguely rings a bell in ry mind but I 15 guess I can't'tell you -- I think I knou uhat it is.
Is it a 16 l requirement that the plant is to be in com=cretal operation 120 I7 days after ecking its first power?
18 Q
Is that yet;r underttandir;.?
i 19 iA I'm pulling this out of my head.
I vaguely reeceber 20 something like that and I don't know whether that's the rule or
'1' not.
22 [L Q
Did you ever discu:s that with Bob Arnold?
23 lll A i
l Yes, if that's what it is, I think co.
24 }
Q As far as I kn:w, that's Mut it is.
%-Fe:eral Reporte s,Inc. l 25j A Okay.
120 days?
Is that correct?
That do;_n't sem l
r, a
ti N
i J
O IfhHeward - direct 9
i, I' reasonable.
Maybe that's what it is.
Offhand it doesn't seem l
2 I 7.ike a reasonable time period.
/
3 Q
Did you ever diz:uss with Bob Arnold or others 4 { the running of that 120 day period?
You stated, as I recall, I
5 ! that the beginning of that period was -- how did you put it --
6 when it's first synchronized with the grid.
Was that ever a 7
problem?
8 A
Synchronized with the grid?
9 Q
No, the running of the 120 day period.
10 A
It was not a problem for me in that the objective of II the project was to get the testing donc as laid out in the test 1
r ! program, and in the earticular case of Three Mile Is1cnd-2 ue 13 certainly were unabic to get the testing done in 120 days be-I4fcauseoftheproblemwehadwiththeesinsteamreliefvalves.
15 So no, it was not a prob 1cm with me offhcud.
If you're 16 ll asking me was there a lot of pressure on me to meet the 120 I7 the answer is no.
I6 Q
Did you talk with anybody, thouc,h, chout ucys'to--
19 i let me rephrase that.
1 20!
Did you discuss rich anyone deali.c rith F2?C 21 yto re-establish or stop the running of the 120 day paried?
22 feA I didn't.
1 23 lit Q
Okay.
Thcnk you.
rl 24j (A discu:nien uc; '.d olf c.e racerd.)
= -Fede:al Pe:orters. he. t 25 Q
Mr. Heucrd, b::ek in Msv s of 1973, t-
.'cu :. ;.: 11 i
It a
of i
Y c-
10 j II: ward - direct tlreceivingacopyofamemofromMr.ScolingertoMr. Miller 1
2 I! nd in that me=o there was a section dealing with philosophy 3
that stated:
"We must slow down and proceed forward deliberatel y 4
and correctly.
Senior station management must convey this phil-1 I
5,osophy to shift personnel."
6 Does that ring a bell with you?
7 A
No.
8 BY MR. EVANS:
9 Q
Let me try to refresh your recollection.
On 10 April 23, 1978, there was a transient at the plant involving II. main steam relief valves.
Is that a correct --
l 12 lA Thet certainly is, yes.
13 Q
Fo11cwing that transient, did you receive a car-bon copy of this Seelin;;er me=o which was written' to Gary Millet 14 providing his cen:ments on the transient and procedures at the 15 16l4 plent?
l It's probably likely I did if he wrote it but I don't 17 A
I8l recc11 it nc'..
l!
19 [:
Q You ere typicelly carbon ecpied on those kind i
20ll eg
,,-mcs ia the plent.
j 21 ] A ygg, :3;e 3 c g ;.g e e t,
i 1
22 Q
Did feu file those?
k 23[ 3 7 oc..w.bly did, yes.
c m.E
" i E Y ' '.. V.'.:7; :. 2 ".G :
)
- :< -rewat 9,w:n, ine. :
2I 1 Q
Wr *
.; in e'n;' discus;
- en:2, a*.ain', the last
.1 h
-1
i o
EHeward - direct 11 1
part of 1978', that there was some pressure to declare DII-2 to
.,2!; be in commercial operation because to not do so might put at 3ll risk the allowance of the AFC on the plant, Allowance for Funds fusedduringconstruction?
4 5
A I don't chink so.
I don't recall such a conversation.
6 Q
In these staff meetings you had with Bob Arnold 7
that you attended, what kinds of things were discust.ed relative 8
to either rate cases or relations with FERC or the general sub-9 ject of commercial operation of niI-27 s
10 A
Bob generally tried to keep us informed of testimony that II he gave in various proceedings.
I don't recall specifically any 12 discussions of conversations with FERC.
We talked about progres s
I3 on the various projects and we talked about problems on the var-I4 ious projects that were the kinds of things that should be dis-15 cussed at upper levels to try and assist in the resolution of 16,those problems and maintain progress.
I7 Q
Did those things include establishing a schedule 18b for completion of D11-2?
li
/
19 A
No, because the schedule fer completien was dcne outsid5 20l the scope of staff meetines.
The project staff assessed the
'1 qscheduleandcroposedthat this uss the amount of time they for.:4-22 saw would take to comoleto the remsining testina and that was 93
' i,repertad moscly in other p10ces.
There was a menthly pro;2ress 14 3renort issued-to Arnold that discussed schedule esch me:tth.
. - reestar n 3, tees we. ;
25 3 era w.:s a Iceter to the Board of Director: that di:: cussed t
l IfHewcrd-direct 12 1. schedule each month.
2 I handled project review eeetings each month and we dis-3 cussed schedule with the ec.]er contractors.
i 4
Q Are you saying that you didn't have any input I
5 into the establishment of the schedule?
6 A
No.
I said that the proj ect produced all the input into 7
the estchlishment of the schedulei 8
Q What was your role in that process?
9 A
Well, the project manager reported to me at that time so 10 I approved what he produced, if I thought it was appropriate.
Il Q
Did you ever change what he produced?
12 A
I probably did, yes.
13 Q
Did you ever chenge his estiente of when certrin l
- 14. tests should be completed or when the overall oroject should be 15:, completed?
16 A
I' don't recall a acccific case of that, but that may have h:ppened.
The project ennager has a very long past history 17 p!
18h of beinp the v.:napur of testing, not only'here but elsewhere, I
l9 f and is probcbly as c:: pert as cnybody I know in the establishment 20 of schedule for teet program for a nuclear power plant.
1 You are ir.nf ng you wouldn' t hcve any reason --
21 i
Q a
43 rem implylm, that ic's orebably unlikely.
I den't alusy; 22 i
l 2 3 ' ag7,, yt 3 331=;.,.xccie ccy cud I ri;*:t ha ce nad a difference
) '$ b.at euc tire, but I can' t r#:211 : aperili: caa: of that.
By and
- 9 - F=:etal Re: tters, tec. '-
a 5 !!? lar;;c,. il you 10e' c: ci.e h!.;:ory of.iat ha:pened in the year e
i
$ !!eward - direct 13 i
1 l 1978, the plant was to be c_m.2ercici in the sering.
The April
!<2[23rdtransientputcsubstantialdelayinthat.
There were
-D o3i; other ite=s that c =e up during the su=mer that we had to atteni 1
i 4 i to and the plant tent co=cercial when the test pregram was com-5 pleted.
6 I daresay if it weren't ccepleted until two weeks later, 7
it wouldn't have gone: commercial until two weeks later.
8 Q
You said you had a lot of interface with the 9
different groups there.
That would include the constructor, UE 10
& C?
II A
Yes.
They were on the site in 1978.
12 Q
So that would be Catalytic in that.
13 A
Yes.
l Q
What was the nature of your interaction with UE 14 1
15
& C for the time they were on site?
l 16 d' A UE & C was the conceruction mananer and constructor.
ll I.,
'] They hired subcontractors to do specialty jobs and they hired 13h 1;ber to re jobs thc2ccives.
They essentially verked for ce as it I9 the proj2ct manager for GPU when I was project =cnager.
4"0 ['
3r the eay, there is a project crgcnization rerponsi-
'l 2I I bilieles document that clearly defi.90.5 interfect of UE & C and a
22 the other cj er cc::tr:ctcra with GPU.
^ 3 l";
Q
'J:ich decur nt is th:c?
- !A
't'e cella! Ine ?rej ect Organin.itien std Restonsibilitic s
- e - Fv:eral Re:crte's. In:. '
25 Oueument, cr.d it h:
a er.:l te: number ett:ched to it chich I
l, Mcvard - direct 14 1
Ihdon'treme.T.berwhcitis.
I 2'
TVANS:
Will you be willing to make l
3' that document available to us?
4 1 THE WITNESS:
Sure.
i f
Q When was Catalytic brouthe in?
5 6
A I believe the officini date was September 1st, 1977.
7 Yet I started Catalytic in small numbers on the site as early
~
8 ! as May or June of '77 so we could get an appropriate interface 9
with United.
10 Q
What was the reason for switching constructors?
II A
We did not switch constructors.
What we did was to bring 12 ; en a contractor who would ultimately wind up with the maintenanc e I
13j contract of the finished plant and also act as a completion con,
.o I#
trcetor.
He did the similar thing on Unit 1.
It' worked out i
15 very well.
The only thing we decided on Unit 1 that we wanted 16 to do different on Unit 2 was to bring the guy in earlier and II : ue did that, i
18l Q
Could you give me an estimate of percent ecmple;e i
^
en '!MI-2 ehen the switch wcs =nde.
I:
- " O A h
In t!e nineties.
a 21a li Q
Lou nineties?
2^ t,j.\\
Lew nineties, mid-nineties, scmewhere.
~
n o :!
~~d Q
Was the switt:h due in any way to any of the Ab' 1
A' 'A
20(.i 1 ll;cucsed th.,
switch at le.2st a yr-ar or more before t-b
0
- Hewcrd - direct I iit happened with the. vice-president and project manager of L'E &
5 il 2 'i C and explained to_him thet t:e had good e.xperience on Unit 1, 1
3 which he participated in that very well, and teld him I thou2ht i
4 we ought to do it a little sooner on Unit 2 and he concurred.
5 This was something that was premetiteced and in eree-6 ment with UE & C.
7 Q
Those discussions were with Earl Nagle?
8 A
That's correct.
9 BY MR. EVANS:
10 Q
Let me ask at the time that UE & C left the site 11 do you have any indication of how many punch list items ere 12 open?
13 A
I'm guessing the number was in the order of 8,000 14 Q
Would you consider that unusually high?
15 A
No.
In my view it was high, hither ' then I expected, but i
16 I would say no for this reason.
Whan Three Milc-1 uent comeer-17 icial, it had 4,000 punch list items.
UE & C left the size 'ust I
prior to the hot ocarations in the test pro 2rcr which reent the:
i 19 j there tras still a lot of things not done, a lot of chint not f
20 j tested.
i I
' 1 l' So if ycu put those two numbers in perspective, I._uid 22.say that it's.not terribly cut of line.
23 ]
Q Do ye.u thinh when the ccepany 1 v n d th:t 8 crc I
were that many punch list itom3 open it
'13 2':? ri 3 2d ?
24
?.e -Pt:eral Reporters, b:. :'
25f A I
en't knew.
It wcs hither th;q IthcuE;it"C' '22 1
9
l Heward - direct 16 1
1 I I don't think it was any serious oversicht or any such thina as l that.
3 Q
Let me ask this cuestion.
Was Mr. Arnold sur-fprisedwhenyoutoldhim"therewerethatmanyopenitems?
4 5
A I don't remember.
He probably was.
It looks like a 6
big number but when you sit down and look at each one of tMse 7
items, you go to one item and it says test number so and so is 8
not complete.
Well, test number so and so hasn't yet been run 9
so, of course, it's not complete and you go down there like 10 that and there's a preponderence of those kinds of items that 11 makes the number so large.
12 You say 4,000 items on a commercial operatign on Unit 1 lisaverylargenumber;well,it is a large number, but when 13 14! you look at the items and you see what they are, it's apparent 15 that they are not serious items.
16 ! BY MR. VANDEF, ERG:
i f
17f Q
You mean that ecst of those items could be re-18[i solved with minimal effort?
19:
A Yes.
As a ratter of fact, a lot cf them didn't have to 1
20 i be reco1ved, may still not be resolved.
If you take an e <tremel y J
21ldl lar;:c and complicated thing such as a nuclear power plant and 22 ].you try and got yourself to the point where you have no punch 23 list ite=s, even if the thin is in operation, it's net cessibi 24 and the reason it's not possible ic you always have a valve a -rewst p,wtm, :ce. V, 251 that's going to lea'x and scrething like that and those items 51:.
N
- i
$Het.crd - direct 17 r
I 'l co on the punch list.
You have electrical racentacles that i
or 2 : don't work /one is needed somewhere.
That's a work list item.
i h
3 It goes on th2 list.
Tae items that were important to safety i
ljand to proper operation of the plant, they got fixed.
4 I
5 (
Q I would like to switch the question to a differ-I 6 !ene area a little bit.
Mr. Heward, I want to ask you if you car
- identify this document which appears to be a Position Descrip-7 1
8 ' tion for you.
Is that correct?
9 A
Yes, I guess so.
10 Q
What was the date of that?
II,A 9/1/72.
12 Q
You've identified that as being the official 13 : Position Description for you at that date.
14,A It certainly looks like it is, yes.
I 15 i
Q Did your official position descriotion change 16 much or at all through 1978 from that time?
l 17 A
I had a different position in 1978 than I did in 1972.
IB I was the manager of projects in 1978.
I was the project man-4 1
I9fagerin'72.
20 Q
On page 2 of this, there's a statement I wish 9Iky you could e:<pisin to us.
Tne idea that then as project manager 9
2' ",: thera's a need to conple te an initial warranty run prior to con-i 23 ('j rarcial operation; could you c:<pisin to us when that = cans.
24 'li A The initial warranty run was c test that was required 2-n:. o
,..m.g 20 ; in the Babcock and Wilcox contreet that verified that the reactcr i
11
.J
!!Heward-direct 18 1lplantwouldproduresoranypoundsofsteamanhour.
1, 2
Q Why_was that made a pre-cendition to co==ercial i
3 l operation?
l 4lA Well, on Unit I which I was working on primarily in 1972 I
5 I I don't believe that any large B & W plant had ever been run and 6 'it was certainly essential for us to verify that the plant that 7 we bought would put out the amount of steam that it was adver-ltisedtoputout,andsoweranthewarrantyrunand,asIrecal 8
l 9
on Unit 1, the warranty run was the la t thing run in the power 10 range test.
II As a matter of fact, I think I believe that the power 12 range testing had all been co=oleted prior to running the war-13 ranty run, and we did the warranty run just prior to commercial I4 ioperation.
Now, on Unit 2, the warranty run uns not as importan L/
15.lan item to us as it was on Unit 1 because once again it still i
16lrequired so many pounds of steam per hour from the plant and the i
I7 l plants, Unit 1andUnit2,areessentiallythesamereactor,yet 1
I8,the Unit 2 reactor operates at a subsecntially higher power level i
I9!then Unit 1; and ainee we had alrecdy run Unit 1 and knew shat j
~
I 90 the cutput was, the certainty of gettine a sicilcr output was 21 !there fer Unit 2.
a 22 i
j As a mattar of fact, ne ran at a su'.x:tentially higher 23 1 j!eutput than what trau warranted.
o 24 ;!
- t - FeJt:31 Re;os tes, Inc. i;
.Q Is tbis initici warr. uty run the same thin;: as h
25 } the Unit Acceptance Test?
5is that another ncne for the sare 0
il d
i i
l at
- heward - direct 19 1
1;! test?
l 2 i A Yce, I think so.
3 i
Q Was this test run in 1978 or was it run later?
l lThereasonIas'r.that is that --
4 5
A Ch, sure.
6 Q
On Unit 2.
7 A
I believe it was run later.
8 Q
The reason I asked that was I seem to recall 9
that in a schedule of the tests remaining to get to commercial 10. operation that Bob Arnold supplied to the Pennsylvania PUC, the i
! Unit Acceptance Test was shown as a milestone pri'or to commer-Il l; cial operation.
12 Did Bob Arnold ever discuss that kind of sched-13 ule with you?
14 A
Yes.
We had always scheduled the warranty run to be 15 l done in the test program.
If you lock at the test program cchec -
I ules going bnck uhcre we got into power rance test, they all lf.i IIlshowadthenarrantyrunbeingrunlateinthetestprogrambut j
el IO h prior to ccer-.ercial.
The wcrranty run was run for the reason n
l9 th t I just : aid;-norely, to verify that we cot the pcunds of I
20 stem per hour out of th.' recetor thct 3 & W edvertised it woule l! produce.
22 I The;.- was ne question Seut gettin: it here and the war-i.
ranty run s. u cimoly c contr:.et obli:ation, if you even rant to
- na!! cc;1 it cn ci.! : tion, becau 2 I think the> contract s:ys if you 7
- ,-Fe:eral Pe:cters,19:. t"!
.. [ don't run it ; cu rim'ly wke F 'r Inst c ay-en t, if,you don,t rur t,
i t.
Ij Heward direct 20 i
i it so many months after it is ready for it, but it was a con-1 I
2 L tract item and it could be run at any ti~- en Unit 2.
3 Q
Do you recall why it was decided not to.un thi 4
test on Unit 2 prior to the commercial operation declaration?
5 A
Well, as you are aware, Unit 2 was delayed for many 6
reasons throughout the years, and I'm here to tell you, we looked C
7 all the time at things that may be in our program that weren't necessary.
Obviously that's our job.
If they aren't necessary 8
9 and they don't provide you something tangib13 for the operation 10 and the safety of the unit and you can delay it or defer it or Il not do it, why not?
I2 And the unrranty run on Unit 2 was an academic enercisy-13 The data had already been taken, I believe, on two occcsiens in I4 unofficial warranty runs.
When the warranty run occurred, it 15 meant we had to make a payment to B & W.
16 Q
Sothedatawasavailableandyouprovedtoyouy-17 self internally that the initial warranty run test could be me:7 I8 A
Oh, yes.
~
I9 Q
And you decided to delay the official cerforman e
'20 ! of that particular test.
21 A
Not only that, we were abic to get 100 megawatt.: or car.'
22 i of power out of Unit 2 more than ne ever tot cut of Unit 1.
23 BY MR. EVANS:
24 Let_me ask a few orcli=I. nary questions.
Q 4:e-Feeerst Repertets,Inc,
--[ Hcward,. you said you p:rticipated in -a meetinu en Cetob. r 26, ni t
'i
" Heward - direct 21 11 1978, a meeting of the Commercial Operation Raview 3 card; is
_2 that correct?
3 A
That's correct.
4 Q
Did you see the final report of what has been 5
called the CORB?
6 A
The what?
7 Q
The CORB.
8 A
Is that the Commercial Operation Review Board?
9 Q
Yes.
10 A
Yes, I saw the final report.
11 Q
Would you identify this as that doen=ent?
12 (A discussion was had off the record.)
13 A
Is there an appendix in this?
i I4 Q
Yes, I believe when you look at the very end.
15 A
Okay.
Yes.
16 MR. EVANS:
Could I ask you to mark this I7 as Exhibit 1108 and to =crk the orevious docu-18
=ent that was shown to Mr. Hevard as 1109.
19 i
(Exhibit 1108 and 1109 cre m rked for I
i 201 identification.)
il 21 MR. EVANS:
Just to clarify.this, what '-
22!
been =:rked for identification is 1103, titled i
l 23' Cenercl Public Utilities ? sitien Ocscription, 24 and it's a positien description fcr "r.
R.
'.l.
e -Fe:eral Recorters. lac. I 25 Hew rd, Junior, and uhst h..s been :- r'wd for 1
lr d
I eward - direct 22 H
1 1
l identification as 1109 is titled Recert of Revie:
2
~
Bgard for the determination of technical and 3
organicationni readiness for placing Three Mile 4
Island Unit 2 into commercial operation.
5lBY MR. EVANS:
6 Q
Mr. Heward, in Exhibit 1109 there is a discussio n 7 of the testing program and it's my understanding that this dis-8 cussion is really the minutes of the meeting that was held on 9 October 26 at the site, and as I will show you, it states in 10 this section that seven tests that were originally scheduled to I
11 !be done at Unit 2 were canceled or eliminated be'. use they were 12 determined not to involve any Federal, State or local require-13 ments.
Would you look at that.
14l NR. LIBERMAN:
Mr. Evans, don't you want 15 to also note that the same sentence says that 16 there were no unresolved probicms?
1 17 MR. EVAMS :
That's fair.
18 Q
My only cuestion is these seven tests, are they i
I9 in addition to the Unit Acceptance Test or is the Unit Acceptanca i
20 Test one of them?
li 21 f A I don't remember.
L, 22 h Let me ask if these tests, than, are cf the ser.c Q
i
,,.! nature in your mind as the Unit Acceptance Test.
~~j
~
A 24 !; A Yes, that's correct.
We did look and I think I even
-u - Femat Routet. inc. ll 25ll insticated locking to ' find out if we had -- and we did this a
- t it l
i
S 11eward - direct 23 I
Ifnumberoftimes--ifwehadanytestsinourpregramthat be-9 l
2 f cause of new information that was available from other units i
if
[thathadbeenrunorchangesinrecuirements,whatever,that 3
l: we had tests that we could avoid doing, we should o=it them frorr 4
5, the program.
6 Q
Would it be fair to say, then, that every test 7 which was run on Unit 2 was necessary to meet a Federal, State 8 cr local requirement?
9 A
No.
10 Q
What was the criterion for eliminating a test?
II A
Well, the criterion was that it was not a requirement 12 from some regulatory activity, it was not needed by us to satis-l~fyourselfregardingtheacceptabilityoftheunit, and possibly I3 Id other industry information had come into play in the intervening years since we put that in the test program that did not require 15 16 I any further test or data to be taken in that area, so we took That's a general statement of the criteria.
"aybe I7 Ilthem out.
I8 l Ran Toole can be mere specific.
I9h3YMR.VMIDE!!3ERO:
Q Dick, you mentioned earlier that in setting the 20 t
21 cchedule for T.II-2, you noctly always accepted the schedule pro i
of 1970.
22 posed by the project menager, particularly the last part 2! Did the project motuger have the resocasibility te interface a
st that time?
24!, with Catal f tic and 3 6 W and Ourns 5 2c
- ! - Fageral Re::ttars, lec. ;l 25 j! ;
- yc3, 9
h.
g I
Heward - direct 24 t
i 1
Q So the project =2nacer was responsible for coor-2 4 dinating th,e inputs _of all those various groups?
3 ;A That's correct.
4 Q
And assessing their impact on the schedule.
5 A
Yes.
6 Q
Who was the highest management official tnat 7 ever made changes or provided specific input to the schedule for 8
TMI-2?
9 A
I'm not sure what answer to give you.
It could have 10 been Mr. Hirst or Mr. Arnold.
i 11 Q
No one above Mr. Arnold.
12 A
T don't know.
Not that I'm aware of.
I'm sure Er.
13 1Dieckamp was aware of what the schedule was because he psrtici-14 - pated in a number of reviews from time to time to undcrstand 15 what was going on at the site, but I can't say whether he ever i
16 input any information into the schedule.
I7' Q
When the operating licence was grant 2d for Unit i
I8h2inFebruaryof1978,isitycurrecollectionthat the terms is l9 of the operating ticence required certain tests or cert in work L
20 g to be ecmoleted uithin specified t: :.e frames?
'i 6
91 1 o! A No.
3 02-je Q
".is there any time conditien associated with an:,
'l 3
part of the CL?
-.s
f A Uo.
n -rows ee:wws, tr.e.1 20 Q
Alec with rcrard to the opera
- na licen3e, whet J
f n
f
I Heward - direct 25 1l uas the meed of the ecmeany in February?
Were people anxious i
I 2]andinahurrytoget that operating license?
You said there 3' were about 8,000 punch list items outstanding at the time.
4 A
No.
I believe I'said the 8,000 punch list items were 5
outstanding when Catalytic took over which would have been Sep-j i
6 ! tember of 1977.
I believe a good many of the 8,000 had been 7
worked off by that time.
As a matter of fact, I believe that 8
most of them had been worked off by this time and it certainly 9
was our desire to get the operating license and proceed with 10 the test program.
II Q
When you say they were worked off by that time, you mean they were resolved prior to February 8th of 1978?
12 13 A
Yes, most of them.
The maj ority were.
14 Q
Do you recall any meetings with NRC inspectors 15 from the office of the Inspection and Enforcement regarding the 16 approximately 8,000 item punch list?
I7 A
No, but I do recall that there were meetings of NRC iu-spection with our te::t croup to review the cutetending ' punch 18 l
I9[d list prior to the coarating
_ cense.
I'm certain that h;;poened 90 'j!
Q Can you describe the substance of those meet-l a
inns?
What were NRC's conec: ens at t :.. : time?
21 d
22 h A I did "c attend the meetinps but the concern was the a
f n3[fpunchlict it:ms r:rainine needed to be screened to ascertain 24 if any shculd hold no issuonce of the cocratint licena and in-
- ,-P mu n nnm, inc,,j
'5 deed they u('"Jed with US that ther? Shuuld not bc Gny th0re th3; e
i i
I heward - direct 26 E
1!! would hold up the operatin;: license issuance.
2^
.Q Who_did that review to determine if there were 3
any that should hold up the OL?
4 A
Who was it, the I & E inspectors?
It was the I & E inspector that did the screen-5 Q
6 ing?
7 A
Yes.
8 Q
Rather than you as the licensee?
9 A
Wait a minute.
I didn't say that.
What I said it was 10 the I & E inspectors came in to verify our decision that those Il punch list items should not hold up the operating license.
12 Q
I'm a little confused about that February, 1978, 13 time period.
There were still some pre-operational tests to be 14 completed at the time the OL was granted; is that right?-
15 A.
No, I' don't think so.
Q Atid all canstruction was complete prior to the 16 i
I7l granting of the OL?
1S' A
Yes.
Q Did, in your view --
l9 l
20l A
Just a minute.
Construction was complete but bear in Ii 21j mind chare are always modifications and punch list iters thst n
22 have to be worked and at that tire there were cuch thin:s bein2 j
li 23l worked.
i I
h itees relate to pre-cocratier.;l.1 2N Q
Do the punch list
,-recerat new:ers,inc. li 25f tsst items perhaps?
i.
p I!
Heward - direct 27 1
A Some ray.
2 Q
Let_me strike at this directly.
Do you think 3
that when you got the OL for E!I-2 that that, because you then t
4 !had to live under a set of tech specs and the conditions of the 5 OL,_did that hinder in any way the completion of ounch list itec s 6
' relating to work normally done before the granting o,f the OL?
7 A
No.
8 Q
It didn't.
9 A
No.
10 Q
Who do you think really had the final say on
/
II when TMI-2 went commercial?
12 A
The chairman of the Commercial Review Board, Bob Arnold.
13 Q
As I understand the situation, GPU Service Cor-
{poration was acting to cerform all the power ascension tests anc I4 15 Metropolitan Edison was the licensee who operated equipment that
, needed to be cperated to perform a test and resoonsibility for 16 t
would I7 I the unic/ transfer to Met-Ed upon a commercial ooeration declara-I8,. tion, whereas prior to that point it was the responsibility of li I95GPUServiceCorporation.
I 20 j Am 7 carreeg7 21f A No.
There's ene e::ceptien and th::t is frcm the time 22, the OL was issued until com ercicl, the operr. tor had the respon t
23' sibility to t're Ccem3 ;sion to perform u: der the terms of the 24!, license and thct was a rerpensibility that GPU Service Corpora-
- 2 - Federal Rt;orters, le:. l 25 i tion could not assume.
h it3
9 l
[Heward-direct 28 Il q
Q In lcte 197S as Manazer of Projects ycu were 2 4 working for which ecmpany?
t 3{A GPU Service Corporation.
i 4
i Q
Did you see any signs -- weli, struggle'is too 5
harsh a word -- but any dichotomy between the service corpora ~-
I 6 ! tion and Met-Ed, the service corporation perhaps wanting to com-7 piece the plan and turn it over to Met-Ed and Met-Ed perhaps J
8 -saying " Hey, we don't want to accept this plan'until everything 9
is totally done"?
10 A
Met-Ed certainly didn't wish to accept anything until II >it was complete.
Indeed, they did sign off to accept every sys-12 tem in that plant prior to it being completed.
i 13 Q
To your knowledge did officials frem Met-Ed ever I# say " Hey, wait a minute, I don't think it's ready to turn over I
15 to us"?
16 i A Certainly.
I7 i
Q Can you give me a for instance?
J 18 A
No, but in the various system turnovers that we had, I':r I9.sure there were times when Met-Ed felt that t'
not ready to i
]'cakethisryttembecause,andthebecauseswereresolvedbeLucen 20 I!thestart-upendtes: 3roun and the operater, cnd when they were 2!)receivedtheytechthesystem.
There was no system shoved dcun 3,P
" ltheir hrocts as far as I kncu.
b
- 40 0
i:
Q Did Nt-Ed raise cny of those kinds of concerns e -re:erai ne:ertees,8:. ;l 25" durin; the mu:h of Deceb tr,1973, on nny particular system er s
i
I!, !!eward - direct 29 1,I.! set of systems?
2 )A Not that I_know of.
No, they didn't have to ign for 3
turnover and receipt of a system unless they were satisfied that 4
the punch list was small enough and inconsequentia.1 enough to 5
accept the system.
6 BY MR. EVANS:
7 Q
Let me pursue this.
Who signed off for Met-Ed?
8 A
I'm not sure.
I think it was the superintendent but 9
I'm not certain.
10 Q
Mr. Miller?
II A
Yes, I guess Miller was the superintendent then.
- Yes, 12 I believe he was.
I3 Q
If a ilet-Ed operator end a GPU test engineer I#, disagreed over an instruction, what was the next ' step in making 15 a decision?
)
16 ' A Well, it would go to the project manager and the station l
I7l manager, but I don't think that ever occurred.
I6 Q
You don't believe there was ever a disagreenent?
l9I A No, I don't.
I believe that the two of them sat d ~:n il 20 and thrashed it out between them until they got it settled.
I'm 21 reasonably sure on Unit 1 that was the case, and I was a lot a
li 22'I;; closer to it than obviously --
t 931 MR. IVANS:
Ceuld we no cif the record.
1 Ii 24h (A discussien was had off the reccrd.)
. e - Fe:eral Repor ters, inc. ]F 25 sv m. vA m m ac:
il
I fHeward-direct 30 1
Q Dick, I'm going to show you this report which si 2 U was marked in a preyious deposition as E:.hibit Mu=ber 1107, the
'l l3 '; report by Touche Ross Company.
Have you seen that before?
4 A
Yes, I believe I have.
V 5
Q In that report there arerfnclusions that con--
6 struction momentum and productivity bottomed out in mid-1977 just 7 prior to replacement of UE & C by Catalytic and it goes on to 8
further talk about morale being quite low at that point.
9 Was that true?
10 A
Yes.
I Q
Why was that occurring?
Do you know?
II 12 A
Well, when you take a group of people working for a com-I3 peny ifno have been employed for approximately ten years on a I# project and the project comes to a close, why, they realize that 15,before long they may be out of work and morale drops and that's
.i 16 something you get at the end of every project.
'7 I You see, that was another motive for brinting the com-li
'Npleticacoatactorearlysothatremeoftheemployeescouldsee
'i I
the a: tion'of this guy eccing in.
Scre of them were picked up 20 h on th6sc tales beccuse they needed ocoole.
They did scee local 21!lhirin:. -I believe that that's a benefici:1 thinz to do.
{
~'
22 Otherwise, pecole lose their motiv: tion if they see the 0
'3 ths
~ $ end ecoing and they tend to lose incentive n.d you never get l'
-;1 - %dr3! flestars, ta:.,! j ob d one.
.s
,3[
Q
' Is this the hind of thin.2 you discussed with "r i
0
I i
31
- Heward - direct
.I I l!:agia of UE & C?
2 lA Oh, sure, yes.
There is an incentive for a,cuy who sees 3 ; a maintencnce contractor for a nuctber of years beyond commercial l opert: tion. If he works hard he may get picked up by that com-4 5
cletion contract.
6 Q
You mean picked up in the sense of being con-7 ; tinued as a maintenance contractor and working with them?
I 8
A Yes, that's right.
9 Q
There was also a conclusion in this Touche Ross 10, report that the project control, at least early on, of TMI-2 was
'II weak.
Did you during your time, both as project manager and as 12 manager of projects, see a change in the roles among G?U Service 13j Corporation, Met-Ed, and the constructor, whether it be UE & C I4l and Catalytic?
15 A
Yes, but that's a comolex question.
Firstofall, Met-}d 16 was responsible for the project management of that job until 17 October of '71 so there was a decided change in role at that i
18 l time when the service corporation took over resocncibility for 19 I;; the project and I uould say that I did see a change in the ef-I jl fectivenes of the control that we e:tercised during the period
'10
-llofconctruction.
I wculd say our control became greater as time 22 iia vent on.
o,1a "E
Q
!! hen you say our, you mean --
.,.A CPU Service Corpor9. tion.
- it - Fe:etal Recotters. Inc. g 25]
MR. E7 ANSI Let's take a five-minute
.I
.i i
K 32
- l. Heward - dire::
l-recess.
2 l (Five-minute recess.)
l 3 : BY MR. EVANS:
4 0
Mr. Heward, in what has been marked as Exhibit 1109, the 5 i CORB report, section 2.5.2 of that document contains a discussic,n 6
of a screen c2tage.
Do you know when that screen outage was 7
held at Unit 2?
8 A
I'm not sure I recall exactly but I believe it was very
?
late in the test program, if not after it was completed.
I be-10 lieve it was -- I'm sorry.
I don't remember.
II THE WITNESS:
May I have that.
12 (Counsel producing.)
13 A
I have a schedule here or a chronology of the testing 14: program that tells me the screen outage occurred 'about mid-Novet t-15 ber.
16 Q
Can you tell me tiny the screen outage is con-I7 : nected with the test program?
I 18llA Sure.
When you start uo a power plant, you place cer-I l9l.tcinscreensinfluidsystemssothatanyresidualdirtorfor-t 20 ei;:n objects that micht be in the system won't go through the j
yi
-psystem.
Thev vill be teken out of the screens, so citer you d
22 0 have run your components ' specified time by t're manufacturer, II 23l!theyaresatisfiedthatc1] 1cose dirt end so forth that may n0
': carry c.way h.2s niready carried away and occh: to be on the
- t -F :gral Re:Of tets. Inc. ]
253screene, so there is n time in the test program where you shut i
t I.
'i Henard - direct 33 1 ; denn for the ccreen cutage.
i 2 i On Unit 1 it was after the testing was co=picted.
You 1
3 ' take the screens out and you 1 cave the= out and that's the re-4 lationship of the screen outage with the test program.
5 Q
Is it true to say that at D!I-2 the screen outa;;e 6
was not planned but it was in - fcet done during a period af down-7 -time caused by another occurrence?
8 A
Well, it's not fair to say it wasn't planned because it 9
had always been planned.
10 It appears from the chronology I have that there may II have been another problem at that time that caused us tc proceed 12 with the screen outage rather than delay it.
13 Q
Can you tell me what is meant in Exhibit 1109 I4 when it says that plans exist to blitz deficiency list durin:
15 the screen outage.
16 A
Sure.
What that means is that during the period of the I7 screen outage when the equipment is not being run, the plant is I8; not being run, it's the intention to brin,n in a larger'then nor-I9l, mal number of crafts so that the nunch list items can be worked i
20 with a larger fcree.
Possibly it means two shifts overtime, i
21jthathindofthing.
It 's more than a norn:21 work effort.
li 22 !'
Q Do ycu recall in feet at T'.II-2 hov runy c.ddi-1
-;"i tional pec?le wre brcught in?
i
'e. !!;A
';o, I don't.
a - remat nsenm, e:. ll 25i l-Q 3ct it's yeur recoilecticn '.hr.:
ore people W r" i
s li-l
Heward - direct 34 I
brought in.
2' A I remember _ reading that ite=.
I guess I ccn't truth-3 fully say that I remember that more people were brcught in.
I think at that time I was'socnding a good deal of my time on 4
5 Forked River and probably thct's why I don't re=cmber that.
6 Q
Did Ron Toole report to you?
7 A
No.
Ron Toole reported to the start-up and testing man-8 ager and in 1978, late 1978, I believe that was Don Hetrick.
i 9 l Prior to August of 1977, it was John Barton.
I 10 !
Q And both Mr. Barton and Mr. Hetrick reported to 11 you?
12 A
No, they did not.
13 Q
Would you piecse continue the chain of command.
Id A
Hetrick reported to Bachofer, I believe, who was the 15 ; directer of operctions, and I believe that was subsequent to I
16 i August of 1977.
I I7l Prior to August of 1977, I rec.'.11 that John Carton re-fportedtoRonWillines,whowastheasaaaerofan2ineer'ine.
I3 I9, Q
Let me sch the cucation this
- y.
Hev trould yot i
i 20! be ende aware of concerns th.: Mr. Toole had in running the test
'i 21 ! program,.
i y
22{A Uhen I was croj ect r nager c.<.d Toole ";s the superinten-li 23 dent, he uns under
..f crerati.
21 c v. 21, a;:'m.th not under
,.a(my functional directl,and h2 'as th".
"nder :: rcon'c c.mratie -
n - Ft:etM Reperters, lac. ].
25 f al control when Ha rt. n ws.-
".'m prej ~.'.
unpr
..d that'. how d
9
't
!Heward - direct 35 i
1hbecausethereweremeetinpsheldt.ithtestsuperintendentat a
i 2 ; high frecuency.
He-participated 'in our review meetings and he 3 ' was centinually advising us cf things that were of concern to 4 i him.
Their trailers on site were immediately adjacent to one 5
another and'it was a close relationship.
6 Q
Did Mr. Toole ever report to you major problems 7
with running the test program as it had been set forth?
8 A
If you can restate that question, I am not sure I under-9 stand the question.
10 Q
Through your operational interaction with Mr.
Il Toole during the course of these meetings, would he outline the 12 problems which existed with meeting the test schedule which had I3 been set?
I4 A
Oh, yes, but if your question is did he ever come to me 15 + and say " Gentlemen, I can't ec=plete the test program" the answ er 16 it is no., he never said that.
I7 Q
Did he ever say "I need more pecole to complete I8hthetestprogram"?
I9 ll A I'm sure he did, yes.
20 Q
Did he ;tet the cecole?
- i 2I h A Probably did, yes.
I did not provide pecple for Toole, a
22 h I assisted if he had a problem getting people in helping him to I
23)lgge pgepig, il 24(
Q We provided the people?
-:, - nwu anonm, ac. y 25l: A The peopic would cenerally be provided by his iretedicte a
b;
l 36 llHeward-direct 1
1i sunervisor or by contractors.
'de had significant contractor
-2 assistance from the. start-up test group.
3 Q
What were the names of the contractors?
4.A United Engineers Constructors, Babcock and Wilcox, 5
Stearns Roger, Burns & Roe, HTS.
Ihere may have been others.
6 I don't recall'.
7 Q
All those people from various organizations re-8 ported to Mr. Toole?
9 A
Yes, they did.
10 Q
Do you know if Mr. Toole's start-up test group II was required to work large hours of overtime?
12 A
They were.
\\
13 Q
Did any of those people ever complain about worl-.-
l 14 ing those many hours?
15 A
Everybody complains about working evertime.
16 q.
Was any consideration given to extending the 17ltestschedulesothat larger numbers of pecole and rore hours IS lwouldn'tbenecessary?
l 19 f A No.
That was never a een:ideration.
Tne consideration i
20! was that the people that had to work these hcurs that were ex-21 ' empt people were given additional pay.
22:
Q In your opinion did the test procram suffer be-
-h 23 cause of that increcced staffing?
24[ A Because of the increased staffing?
a - re rat Re:erivs. iac. l 2
Q Yes.
1
.i a
j C Heward - direct 37 1
A
'Jhat increased staffing?
2 Q
As_I understand what you've told =e here today, 3
more contractors were necessary to assist Mr. Toole in ecmplet-e 4 !ing the test program, i
I l
5 A
You have possibly interpreted my statement to mean that 6
as time went on we had to seek the help of additional contractor s.
~
t 7
Q That's my understanding.
l 8
A That's not correct.
9 Q
Would you correct my understanding.
10 A
The original intent of the start-up and test group was Il to incorporate the services of all daose contractors.
GPU 12 doesn't maintain a permanent start-uo and test group of a size i
13 l that is required to start up and test the nuclear power plant.
14' So we supplement our staff with contractor help.
15 Now, where we were shorthanded for some reason or another i
lo ! and we needed mere people, ue would get thau frem these con-i 17 l tractors, but the personnel demand rose and fall throughout the litestprogram,dependingonwhatwasgoingonandduringthe 18 19[i period when we had the mainstream safety valve outage, the de-a 20 = ands on the test people siccked off considerably so they had 2I0 a substantial period there when they were not workine the same 3
ll 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> that they would hava otherwise.
k 23d Q
Did any test engineers other tF n Mr. Tecle cce-li 24( plain to you directly about the te-t schedule m the worhir.2 cr - remai neronm, inc. J
.o5 conditions that they were subjected to?
t es
Ieheward - direct 38 1
fA Yes, I believe I recabl complaints about the test sched<
I i
2 ule and the extension of the project schedule.
I don't reccli 3
I that anybody complained about the working conditions.
4 Q
What was your respense to the comolcints?
5 A
There ist,'t much one can do about the problems one runs 6
into except fix them and let me tell you, when a guy signs on 7
for a test program, the people that we hired have been through 8
it before.
They know what to expect.
I know what to expect 9
because I've been doing this kind of thing for over 20 years.
10 ; Some of these guys haven't been doing it that long but they knov II what to expect.
12 Q
Does the name Rick Butler mean anything to you?
13 A
Say again?
14 Q
Rick Butler.
15 A
No.
Who is Rick Butler?
16, Q
That's not important for the question.
t I7 Mr. IIeuard, did either UE & C or Catalytic ever IOkprovideGPUorGPUSwithacertificateofcompletion?
h 19 ":i A I don't know.
61 20l t
Q In ycur experience with these units, is that i
a.
21 ' normally the case that after completing the construction a 22 'i ccruificate of ecmo. lation of cenetructicn is c. rovided?
23 E jj A I don't ever recall having seen such a thing except with 2AE Individuni contractors on the Forked River proj ect.
When a sys-3-Femai necer:m. me. ;
25 j c.,.'s cceplazad and n d hed for punch list items and they uere 5
1 E
.: Heward - direct 39 f'
s l!; wallied frem end to end fer punch list iterc, paint en pipe, nuts i
2 ! not tight on the hangers, all that kind of thing, and one gets i
i3pthroughallthat, it's a superfluous thing to ash for a certifi-4 cate of completion because we take it piecemeal system'by syster l
5
' building by building, so the answer on systems and buildings is 6
yes, we get that.
That's part of the turncver package, but 7
there's no such certificate that I can recall ever seeing that 8
says yes, I built you one plant; it's all done, because it wasn' t 9
all done.
They left before it was finished.
10 Q
Who is they?
II A
UE & C.
12 Q
What about Catalytic?
13 A
They haven't icft yet.
I4 Q
Would you characterize a portion of their work 15 as'being censtruction work?
16 A
Yes, I would.
i l
Q
' For thct constructicn ucrk they do not provide I7 i
I6kacertificate.
I I9d A Sc=a thing.
It's building turncver, yes.
1 20 Q
No ferr:1 piece of paper.
21'
-lA I don't think so.
22 I
l Q
As both rroject r.anager and cauacer ef projects 93a
" ll with come oversight rerpensibili ; for Iheca "ile Isle:nd-2, 4
,bl uculd you bc sucre of union probl ert, thet th; constructors were 44 - FOd3:31 Re:ettets, lac. 4"
^5 ~ havinc?
1 4
k.
lHeward - direct 40 1
1 !A Yes.
1 2
Q Do you knew if there were. any problems in attrac t-3,ing and holding the necessary amount of craft laber in buildinz 4
Unit Number 27 5
A There was n' point in time when the local crafts could-6 not supply enough pipe fitter welders and we had to request then 7 to go outside their local and bring welders in.from Baltimore 8 and New York and other places like that and you run into that 9 with a small labor pool and it does happen and you have to make 10 other arraiigements.
1I Q
Vno took the responsibility for recruiting those 12 additional people?
13 A
Tne crafts did that.
Tncy did th=t when UE 6 C uant to I#
them and said we are short by this much.
You've not been able 15 to. supply them.
I require you to have other means to supply 16 these, people.
They did.
They go to other locals and get the I7fpeople.
I I6)
Q Once that additional recruitinz has been done, I9,there was satisfactory staffing?
20 A
Yes.
21 i
Q Let me ask just a few quastions about what wa h
- 2 [ previously discussed, the April 23rd,1973 transient.
Were you i!
23] involved in the discussion fellcuing that transient to repl ce e
24l the Loner an valves?
-a re m ni Re m e m, m:..-
-.p CPA Yes.
4
- l L
l'leward - direct 41 l!
1 I
Q nno would you say made that decision?
i 2 :A My recollection is that. between recommendations cade.by l
3. Ron 'Jillic=s and by me that Bob Arnold made that decision.
4 Q
Can you describe for me the contacts that you 5
had, if any, with the Lonergan Company itself following the 6 l transient.
1 7 I A Shortly after the transient, a week or two later, I con-8 ducted a meeting with the president of Lonergan Company, their p 9
chief engineer and others to ask them what their opinion was of 10 ithe failure.
II Subsecuent to that, there were numerous phone calls.
I 12 believe I participated in one or two =cetings where their repre-I3 j aantatives ca=c here to talk to us and subcoquently participated i
14 in a meeting regarding a litigation with Lonergan.
15i Q
Following the transient, it's my understanding I
16: that a number of valves were removed and sent to the Lonergan I7 Co:t.pany; is that correct?
I8 l A That's correct.
I9 Q
Do ycu recall approxi=ctely what time period this 90!
j was?
.i 91 h A May.
22 Q
tJas the Lonergan Cccoany told that it had a cer-23 tain period of tire in which to ccmolote !.cs analysis of the 24h val ra to vuur knculedge?
aream n:mm. inc. F 25 y ;
7 pically, to my.knowled;te -- I'm really guessing be-7 c
I II Heward - direct i?
I 1! cause typically we assess a problem like that and we t:culd cell
-y 2Ilthem,Look,hereisaproblemthatwewentyoutolookatand I
3 ne would like to have an answer in so many days, so enny weeks, i
i l and I am quite sure we did that, out if the question is did ther 4
5 have a drop. dead date to have the things fixed, the answer is.
p V
no, because there's no way you can give them that.
6 :
7 Q
Did the company have a drop dead date for Loner" 8
gan?
9 A
Did.we have a drop dead date for Lonergan?
10 Q
A date at which it would no longer consider the 11 ability of Lonergan valves to fulfill their function.
12 MR. LIBEIM N:
Can I interrupt :Just a j
13 second.
Unless it's absolutely indispensable 14 to your interrogation, your deposition, I'm i
15 troubled because we have pending litigation with 16 l the Lonergan Cccoany.
I don't want to foreclose l'
I7l any avenue but I have trouble because the.t ? are I3 areas that I think Mr. heward has not been in-
.i l*0 volved.
MR. EVANS:
Well, Mr. Ecuerd, I uilt in-2i;r struct you, too, only to answer cuestions which a
22 you have perscnal kncwledge of and I don't want
' 3 "ll to oush you beyond what you were involved in a
24$
perconelly, but I cm interested to knc t if there
- - re:ersi pe:ortv2, in:. ll 25{
was a date to your knowledge after which you il k,
e
,fievard-direct 43 i
I would not consider, the comoany would not con-r-
2 sid,er the Lonergan valves.
3 Now, let me state on the record, if you t
4 would re'ther that Mr. Heward would not answer 5
that cuestien, I can accept that.
6 MR. LIBERMAN:
I want to cooperate in 7
every way that I can.
I can tell you that there 8
is correspondence in which I participated in the 9
preparation of which Mr. Heward was not involved 10 that did exercise contractual remedies against II Lonergan Company.
12 MR. EVANS:
Let me withdraw the question.
13 Off the record for a minute.
l#
(A discussien was had off the record.)
15 :BY MR. EVANS:
16 Q
Mr. Heward, you've tectified earlier today that k,
I7 j you didn't have any knowled7,e of rate base matters or tax mat-I8 ters or other general fincncini conciderations sinich effected I9l completin.: Unic Muc.ber 2 by the end cf 1973.
Is that a correct 20 l!l statement of what yeu've teld us?
'llJA Ocher than the fact that I was awcre that while the plant 22 5 9 AFDC uco collectcd and it ceased to
!! as under constr.::ticu th;:
23 be later en, I thi".k thet's a fcir statement, yes.
24 l1 0
Let me fc11.u that up for a tainute.
Ecu do vou ce - ro:erai Re:or:4rs. i..e. i{
25 $ perceiva i..rD0?
Is it a pravie= for you as either the ereject Y:
y
I!Heucrd - direct 44 I
lj mcr:ger or manc;cr of projects?
2 A-No, i
3 l Q
Let me ask if during the time period, that is 4, the last six months of 1978, you attended any meetings of GPUS S
Board of Directors and officers?
6 A
No.
I did hcve meetings with Bob Arnold who is an of-7 ficer.
Possibly others from time to time but not on that sub-8 ject.
9 Q
Did you have any meetings during the time perioc 10 with Mr. Holcombe?
11 A
No.
12 Q
Did you have any meetings during the time period 13 with Mr. Graham en this topic?
14 A
No.
.15 ' EY 42. VANDENBERG:
l 16[
Q Mr. Heward, the original estimated date for com-17f! pleting TMI-2, I think, was quite early 1975 or so.
I 16 !A I don't remember.
It was a lot ecrlier than 1973, tha:' s i
19!l for sure.
il 20p Q
In the Toucho Ross report the in-service dates l
21ll are often nc:rly always given in terms of May of a given year h
22 j :nd this is informatica that I presume Touche Ross received fron n
'*jGPU.
ishy was : hat tiu t in-sarvice date was always encrested as 2.h M.iy or M y 31 of a iien year?
' Federal Rent:ers,110..i
- 3:
I could caly coa:ula:c.
( a.
a
'l
n f
45 iHevard - direct t
i MR. LIBERMAN:
Can I call to your cecen-I 2
tion the fact that there was discussion of that 3
matter in the cross-er.cmination of Touche Ross 4
and rebuttal testimony in the Pennsylvania pro-5 ceeding which I fcrnished you which you may want 6
to look at.
At least I believe I furnished it 7
to you.
8 BY MR. EVANS :
9 Q
Mr. Heward, following the replace =ent of the 10 Lonergan valves, what I understand to be Dresser valves, did yot.
II notice a charge in the attitude either at the site or here at 12 corporate headcuarters regarding Unit Number 2?
13 A
I dcn't think so.
14 Q
Was there more cf a desire to complete it in i
15 I, 1973 than before?
l*'hA During 1978 there was always a desire to complete it in I7lll 1973.
Originally in 1978 the in-service date wcs May or June.
l i!
I8k Q
Let me ask it this way.
Were recole e:ttremely h
IU! dienecointed by the failure of the Lonergan valves?
i 20 A
Certcinly.
Of course.
That 's a terrible disappointment.
Q I uculd like to clarify one thing.
We were 21
'd2 i' tel'.-ing earlier today about the test nr: gree and the tests t hich
?
14
.I 23y were i.isted *n cna ferm or ancther and I an going to atte=ot to 22'1 uish het:een the various lists ci te :s to b2 performad.
distrc
- - n m e ne:: m s, m..
__~
- $ I t '.5.ty underner.ndinr,.here w:s a list o! tests which GPUS had M,
9
1?
E heward - direct 46 1
itself establiched to be run; i's that correct?
i 24 A Yes.
2 3
Q There was another list, maybe even an identical- -
4 excuse me.
5 jA There was no other list.
There was a single list.
6 Q
Are you aware of commitments which were made to 7
the Pennsylvania Public Utilities Commission to complete certalu 8
tests?
9 A
I don't think so.
10 Q.
Are you aware of any regulatory impact other t
11{thanindealingswiththeNRCtocomp'.etethetestprogramat 12 Unit 27 I
13 A
I have a vapue recollection of discussion -- no.
I don' t
14 have any recall on that, nc, 15 Q
Are you sware that there were tests specified 16 in th.e final safety analysis report which is presented to the I
17 i NRC?
I ISj A y,3, Il i
I9J Q
Is that of tests identicci to the list of testa il 200whicharelistedintheinternalGPUSprocedures?
21l A
No, I dcn't think so.
I think the test program itself n
e2 h - very likely had more tests in it than were listed in the finsi r
?1-!i safety analysis report.
The cervission is interested in seeing t
2#" that you co=mitted to certain tests nd those tests must be l3 - Ft:t?3t P300f ters. ht.,
-,,, addressed to the anfety malysis report.
The test protrom ever-
- i C
't
~
l! lieward -. direct 47 i
j all 'is established by us and a decision to do so many trips I
2 j from certain power levels is curs, so long as you meet the var-3 ious re;;1uatory requirements, so we produce the test program 4'
to suit ourself.
5 Q
So to clarify this on the record, if you will 6
agree with me 'that the FSAR contains one list of tests and Met-7 Ed's internal ^ procedures may be another list of tests, those 8
may not be ar. identical list.
9 A
That's probably right, yes.
10 Q
Were you present for the full power generator II l trip' test at TMI-27 12 A
go, 13 Q
Do you know when it was performed?
I4 !A From the appearance on the chronology, I would have to 15 say it was done in either November or December but I do not 16 I know when.
I7 )I Q
Let me attempt to refresh your recollection.
I8fWouldDecember 28, 1978, be a realistic date for that test?
I9 A It may very well be, yes.
It copears that we were at 4
d
^0
' ji full ocuar up to the 28th, so that may be, yes.
R 21 {
Q Can you tell =c where the full power generater 2' 4" trip to:t fits into the FSAR lists of test to be perfcrmed?
a 23i!sA
., 0 in 9 '8 '.
1 Q
C:n you tell me where it fits into the GPUS
. e - Fe e:21 Petorters, ir:. ll h inIC_*!*.J1.110 t of t03 00 te b0 perfCreedi
[
?
1 l Mcword - direct 48 I
1[ A Well, it certcinly doesn't fit in crior to going to 100 i
2 (
The power escalation crogrcm is one that occurs percent power.
3 in steps up to ful power so it would certainly be in the Icete:
4 stages of the test program, only after schieving the 100 percent 5 ! power.
i 6
Q In your opinion is it normally necessary to 7 successfully co=plete the full power generator trip test in 8
order to declare a unit in co=mercial operation?
9 MR. LIBERMAN:
Can I object to the ques-10 tion for clarification there.
Commercial opera-II tion in terms of GPU corpoiste procedure or --
)
12 is that what your reference is or sc=e other I3 connotation?
I4 MR. EVANS:
Yes.
My reference is the 15 report of the Commercini Operation Review Board 16 criteria.
I7
]A For nuclear power plant, you unnt to do that test in 18 l ycur test program to verify that it's en accept:ble transient i
I9jtotheplant, and I would say that it's nor:211y prer, rammed to 20 be done during the test progree end therefere prior te comr.::rci t
t i
operation, yes.
22 j q
75 7 y.derstand what you've said, it's your cpi;.-
t
- 3H the entire test pro 3rna cnd, again, tying this to t.he o
,, ion thst pb D 'A ? GPUS internal list of tests, the internal tett crc; rem, did :ht:
- - Fue at Regerte s, be, ta 25 f entire tos program should be cceplaced prior to :h? e ? '"erc l 1 11 ff t
a o
ti!Heward - direct 49 I
II. operation.
Is that cccurate?
t i
2l A Only to the e. tent that you consider the test to be a 3
mcndatory test.
Prior to mcking the plant availabic commerciall y
.I think that you might consider puttine a plant into ecmmercial 4
I 5 I operation at a power level icss than 100 percent and take an 6 ' outage later on and complete the higher level testing.
I think 7
thct's a possibility.
It's not something we did but I think 8
' it's something you could do.
9 For example, I don't see why you couldn't go up to 50 or 10 75 percent power range testing and if the power were needed, run II t'ne plant at that level first or a reduced level for a period of; i
i 12 time in co=creial operation and then tske an outage and comoleep i
13 : your higher power tests.
I think that's possibic.
I don't knotd 14 : whae nakes it impossible.
15 (A discussion tras had off the reccrd.)
16 lI SY MR. EVANS:
I I7 Q
Just one last question uith respect to the full I6; power generator trip test.
Were you involved in cny discussions I:
I9Ias to the pcstponement of that test beycad 1978?
hl 20
!! A I don't remember that.
- )n 9
I,SY MR. VANDES3 ERG:
il 8
'2 !!
j; Q
Dick, did anybody at any time c:: ress to you
," s' concern that the tect cretram uma bein: nursued et tco quick a nace or was being ruth 2d or that the tests were just beine echcA e -Nem pe:mm, ine. :;
25 uled in too chcrt a time?
t
E Heward - direct 50 1
A Well, let =a tell yeu that when ycu schedule a thinc 2 llikethis,theright way to do it is aggressively.
You should 3
bring the plant along as fast as you can, 4
When I say that, I mean within the context of it being 5
safe to do so and ready to do so.
K w, there is a full spectrun 6
of what people think is necessary to be ready to do so.
You arc 7
always going to get a diversification of opinion as to whether 8 you are going too slow or too fast, I believe.
9 I've seen that for many years and particularly when you 10 have people that have a lot of procedures to get ready, it's II ' more comfortable to give them more time to get the procedures 12 recdy.
But if you proceed and review the things as you go alon; 13 and make sure that what they have is adequate to proceed rather I#
than what makes everybody real comfortabic, I think that's the 15 way to proceed with completion of the plant.
16 Q
Are you sort of saying that schedules are cade 17 to be broken?
18 ' A No, I don't mean that, but what I think you should do li 19 fi-is schedule the program in a w:y that you think you can meet it p without having serious thints go wrong.
My recollection of hev
- 10;the Unit 2 program was scheduled is it fit the actual conditieno i
22 N '
qonUnit1andIthinkifyougolooket the schedulas that we i
234hmadeonUnit2,thedurationsweretakenfrcmwhatweachieved I
t 24f on Unit'1.
We had a very mooth test prource on Unit 1, ccm-e
~
- :t -Ia00f 31 Re;0f tets, MC. n 5
peratively spc'1 king.
)
i
il!.w.rd - direct 51 Il So I'm sure you can find a lot of pecole who think the il2 " ching was pushed too f ast, but we had the history of c'aing it in 3 ithat time period on Unit 1.
4 Q
You think, then, that the differences between of 5l Unit 1 and Unic 2 weren't/any significant, wouldn't in any sig-1 6 'nificane way affect test time periods or schedules?
7 A
Well, we had perturbations in starting up Unit 1 but we 8 4didn't have any real big items such as the safety valve problem 9
affecting Unit 1.
10 Q
And also with regard to NRC, did vw know of any II 1 cmoloyees or workers at the site no expressed a concern to say 12 !something'to an I & E inspector but then declined for one reason I3 or another?
I4 ;A I only know of one case with it.
I guess the case I knc v 15 ! of the guy did'tnik to or write a letter to the I & E inspector 11 16L and we posted the notices on the site conspicuously to tell peop le I7A hat-that was their right.
I know of no case uhere a guy wanted t
IS to and was afraid to and didn't do it.
t I9 !
Q Which case are ycu referring to uhcre it heo-20 pened?
2I A-We had a report from an em:1oyee that had been there some
\\!
22 [: years ago who said that he had drilled a hole inside the contain-i!
23 In:nt cnd hcd hit reinforcing steel or soccthin;: like that and he 2
dida': feel the anchor rany,e was quitn right.
I den't ree.crber
.e - Feders Rentters, Inc. y 25 j a11 the details.
ii d
0,
[Heward dirce 52 e
If Q
This is the one that was subsequently investi-
'i 2 1 gated by I & E in March of 19787 lA I don't knor when but it night have been March of 1978.
3 4
I lItwasinvestigatedandIbelievewedidfindthatwehada 4
i lfcultyanchorandfir. edit.
5 MR. VAUDENBERG:
I have no further ques-6 7
tions.
8 MR. EVANS:
Mr. Liberman, do you have 9
any questions or remarks you would like to make 10 on the record?
II MR. LIEERMAN:
I want to be sure you 12 were furnished with a copy of the document called 13 Three Mile Island Deter =ination of Technical and 14 l brganizationci Readiness for Placing Three Mile i
15 Is1cnd Unit 2 into Commercial Operation dated 16 October 26, 1978.
I7 MR. EVAUS:
I believe we have been ft.
18 nished a copy of that.
Would you like me te e I9k it in:o the r: cord?
20 MR. LIBER:BN:
No, I juct wanted to be l
2I sure t'.st you kr.cu the document c:.isted ' cccuse o
I
- y h, you h:Jn't centi. rad it and you did refer to an L
23'E n p p :d i.. which.ca in : conse a follow-up on 4
thi c.;eument.
24 :
+. - rami nemm w.,!
25j s,q,
- y.MJ
Off the record.
1 3
i i
i l
II 53 f
I I
l jj (A discussion was had off the record.)
b 2l MR. EVJdiS:
I've asked Mr. Libar=an if i
3 i
he
- d anything to add.
4 MR. LIBERMAN:
I guess I would like to S i add one other thing.
I think the term "commer-6 cial service" has been used in such a variety 7
of ways that I would like to clarify that this i s
8 now one of four contexts in which it has been 9
used.
10 The document Mr. Etward identified pre-11 viously, which I believe is -!ocument 1109, re-12 ferred to commercial service in the sense it was 13 used by the GPU Service Company Internal Commer-14 ciel Operation Review Board.
It is a document 15 l which has no governmental connotation as such.
I 16j The' term commercial operation has been i
17 used also as a shorthand for the time when a 16 unit vill be transferred frem construction werk l9f in progress to utility plant in service for FEP.C 3
20 accounting purposes and there was an earlier 2I reference to that and to the Electric Plant In-i l;
s
.i 22 !
s truction 9D.
234 The term commercial service' is used alsc 4i; b
2'n s on a different centent in terr.s of cert:In ta::
a -rece ai ne:2,ters. inc. ?
'5!
treatment for depreciatien end investment. tax 0
'l 3
..e
. 3
}
54 1
credit purposes.
In that centext is is a col?o-2 quialism.
It is not a term which is used in the 3
regulations under the Internal Revenue Service.
4 Finally it is used in terms of again a 5
shorthand for the status for interconnection 6
dispatching purposes by the PJM.
7 I would like to clarify that my under-8 standing is that all of Mr. Heward's testimony 9
has been directed to the first of these senses 10 and not to any others; is that, correct?
11 THE WITNESS:
Yes, that's correct.
12 MR. EVANS:
At this time, Mr. Howard, 4
13 I would like to thank you for being present here I4 today.
We are going to racess this deposition 15 rather than terminate it on the possibility that 16 i we might want to ask you additional questions I7 !
at a later time.
I would say we will mcke every 18 attempt not to need to ask additional questions, I9-but should th:t become necessary, we would like f
to have you available to us.
20 i
21 Thank you very much.
t 22!
(The depositien is recessed at 5:30p.m.!;
23
,,,w,,
n 24 ii
- 7 - Fe:,ral Repertets, lec, )-
- 259 i;
E n
((
e
~
o,e i.
35 l
1 CERT!77CATE t
2 I, IMRGARET TFII,HABER A Nocary Public and Certi-3 fied Shortharid Reporter of the State of New Jersey, do hereby
}certifythattheforegoingisatrueandaccuratetranscript 4
5 of the proc.a Jings in the above-enti:1ad matter as reported 6 by me stenographically on the date and et the time and place 7 l hereinbefore se: forth.
8 I DO FURTH:R CERTIFY that I am neither of counsel nor 9
attorney for ent party in this action and that I am not in-10 terested in the event nor outcome of this litigation.
'l 12 13
/f/
c,l,$,-
14 7
/ ' ;
.q, 15 A Notary Public of lieu Jersey 16 17 I
18 19 i
)
20 21l 22!!
23 fl l
il 24h
- - F :eral 4e ortees, 'ac.
i 25.i I