ML19343D475
| ML19343D475 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/18/1980 |
| From: | Mullin J BABCOCK & WILCOX CO. |
| To: | |
| References | |
| NUDOCS 8105040600 | |
| Download: ML19343D475 (11) | |
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1 UhifED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION C) 4 THREE MILE ISLAND INFORMATION TASK TORCE 5
DCCKET NO. 50-320 6
Conference Room 7
Power Generation Grcup Babcock E Wilcox 8
3315 Old Forest Road Lynchburg, Virginia 9
10 Deposition of 11 JOHN G. MULLIN 12 called for axamination by the Nuclear Regulatory Commission 13 beginning at 9:35 a.m.
When were present on behalf of the 14 respective parties:
15 For th ?_Escl21I_Eg2nla terr Commissioni 16 TERRY L. HARPSTER, Reactor Engineer JOHN W.
CRAIG, Senior Investigator i
17 Office of Inspection and Enforcement United States Nuclear Regulatory Commission l
18 Washington, D. C.
20555 19 for :stsssi_E_211ssai 20 GEORGE L. EDGAR, ESO.
Morgan, Lewis E Backins 21 1800 M Street, N.
W.
Washington, D.
C.
20036 22 23
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ALDERSON REPORTING COMPANY, INC.
810504o600
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i etacata112s 2 Whereupon, 3
JOHN G. MULLIN O'
4 having been first duly sworn by John W. Craig, Senior 5 Investigator, was examined and testified as follovss jf#
6 XR. HARPSTERt For the record
=y name is Terry 7 Harpster and this is John Craig.
We are engineers with the 8 Nuclear Regulatory Comnission.
We are conducting an 9 investigation to establish the flow of information during 10 the Three ?.ile island accident on March 28th, 1979.
11 The specific purpose of this interview today is to i
12 identify and locate any and all records, notes, facsimile, 13 transmissions, tape recordings or documentations of any sort O
14 generated by ECW employees on ! arch 28th, 1979, that reinte 15 to conversations or communications between EEW employees and 16 Three dile Island, GPU, Met. Ed. personnel or other EEW l'7 employees in the vicinity of Three 511e Island.
18 Do you understand the purpose as I have explained 19 it to you, John?
20 THE WITNESSs Yes, I believe so.
21 EXAMINATION 22 BY MR. HAPPSIER:
23 0
Has anyone either told you or suggested to you
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24 that you should withhold any information from us here today?
25 A
No.
O ALDERSON REPORTING COMPANY, INC.
400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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1 0
What is your position or function in BCW7 2
A Assistant Counsel, Nuclear Power Generation 3 Division, the Babcock and Wilcox Company.
4 0
John, to your knowledge, what efforts have been 5 made to date by BCW to identify and locate any and all 6 records, notes, facsimile, transmissions, tape recordings or 7 documentation of any sort generated by B&W employees on 8 March 29th, 1979, that relates to conversations or 9 communications between BEW employees and Three Mile Island, 10 GP U, Met. Ed. personnel or other BCW employees in the 11 vicinity of Three Mile Island?
12 A
After we learned of your investigation late in May 13 we sent documents which you requested to you.
We gave you 1<4 access to our TMI 2 recovery area files on your visit here 15 late in May.
We provided you copies of materials which you 16 requested during that visit.
17 Subsequent to that visit we continued cur search 18 of files tha t we thought were pertinent and I believe on two 19 other occasions sent you additional files that we believed
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20 you had not seen during your earlier visit.
21 Wa continued to search for documents during the i
l 22 past few weeks and as a result of that search we uncovered 1
23 additional tapes and written documents which we believed
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24 would be of interest to you in your investigation.
25 0
John, the files we looked througn, for the record
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l ALDERSON REPORTING COMPANY, INC.
400 VIRGINI A AVE, S.W., WASHINGTON, o.C. 20024 (202)554-2345
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1 are those files complete now or were they at _ the time we 2 looked through them?
3 A
To the best of my knowledge, those files contained 3
g%J 4 documents generated.in our recovery effort from 3/28/79 and 5 for the next several weeks.
6 0
Are those files complete though or is the effort
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c 7 still going on to catalog that material?
8 A
We don't have an effort ongoing to catalog the 9 material as such, but to the best of my knowledge today the 10 files in the recovery area and the additional files we 11 provided to you are complete.
12 0
Are 3CW efforts complete to ensure that we have, 13 either seen or been provided with all records to date 14 rela ted to our investigation?
15 A
I believe that we have either made the documents 16 available to you, have provided them or in the case of 17 certain privileged documents made you aware of their 18 existence and identified them.
So that I would say to the 19 best of my knowledge we have provided you all of the 20 documents available in response to your investigation that I i
21 am aware of.
22 0
What additional efforts, if any, has BCW planned 23 to catalogue or ensure that all information has been gm g_)
24 identified with regard to our investigation?
25 A
We have no overall plan to catalog the files.
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ALDERSON REPORTING COMPANY, INC.
400 VIRGINIA AVE, S.W., WASHINGTON 0.C. 20024 (202) 554-2345
5
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1 We, in response to your investigation, have made a good 2 fiith search of all of the files that we.though t were 3 pertinent, and I would be surprised at this point to find 4 that there would be any additional files.
I think we have 5 located places where documents which you are interested in 6 would be located and have reviewed them to provide documents 7 in the areas which you requested.
8 0
John, have all employees of BCW been queried as to 9 whether or not they were involved in these conversations on 10 March 29th, 1979, with employees of Three Mile Island, GPU, 11 Met. Ed. or other BCW employees in the vicinity of the 12 Isla nd, and, if so, have they been requested to turn in any i
13 notes that they have?
f' 14 A
What do you mean by "all BCW employees"?
15 Q
BCW employees at Lynchburg who may have been 16 involved in conversations with employees of GPU, Med. Ed. or-I'7 other BCW cmployees in the vicinity of the site who may have l
18 either been in the war room or involved in conversations 19 outside the war room on that day?
20 A
My efforts involved putting a list tcgether during-21 your visit here in Nay and going down the list asking most 22 of the people on there whether they had any personnel notes 23 of any sort or whether they were aware of any notes.
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24 My investigation was rela ted prima rily to the 25 people on the list which I identified whom I thought may ALDERSON REPORTING COMPANY, INC.
400 VIRGINIA AVE. S.W., WASHINGTON, D.C. 20024 (202)554-2345
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1 have some notes.
2 0
To your knowledge, has a memorandu= been r~%
3 circulated to all of the BC'4 employees so that rather than V
4 relying on our structuring of a list that if any employees 5 were involved they will be identified and we will have have 6 access to their notes if any were taken?
7 A
No memorandum has been circulated to the best of 8 my knowledge.
9 Q
Have copies of all documentation identified by BCW 10 employees relative to this investigation been provided to us ?
11 A
We have provided copies of documents which you 12 have requested and additional copies which we thought would 13 he of interest of you, but we have not provided copies of O
14 any of the documents which we utve identified as privileged.
15 Other than that we have worked very hard to 16 provide you with anything and everything that, in my 17 judgment, was pertinent to your investigation.
18 MR. HARPSTERs can we go off the record for a 19 m in u te.
20 (Discussion off the record.)
21 ME. HARPSTER4 Back on the record, please.
22 BY MR. HARPSTER:
23 Q
John, we would like to a.sk if 3CW could through 7-~)
24 memoranda or other means formally inquire of its employees N.
25 if a ny were involved in any conversations on March 28th, O
ALDERSON REPORTING COMPANY, INC.
y 400 VIRGINIA AVE, S.W., WASH!NGTON, D.C. 20024 (202)554-2345
7
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1 1979, with employees of Three Mile Island, GPU, Met. Ed. or 2 other B&W employees in the vicinity of Three Mile Island and S
3 also if any notes or other recordings were made of these
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4 conversations or any documentation of any sort related to 5 the accident or generated as a result of these conversations 6 on that date?
7 A
Yes, we will issue such a memo and inform you of 8 tn e results.
9 0
Fine, could you inform us formally in writing?
10 A
Yes, we will inform you in writing of any 11 documents or conversations and so forth, and we will also 12 inf orm you f ormally if no documents are found.
13 MR. HARPSTER:
John?
O 1-4 EXAMINATION 15 BY MB. CRAIG4 16 Q
John, with respect to the availability of 17 documents and the concept of providing them to us, I would 18 like to make it clear that providing us access to files is 19 no t the same thing as providing us information which in 20 pertinent to investigation.
I would like to ensure that any 21 information that is identified as pertinent to our 22 information either by you or by us will in fact be provided 23 to u s.
In the past you have provided all information in a
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24 timely manner that we have requested.
I am concerned about 25 information that we don 't request because we don't know of its ALDERSoN REPORTING UOMPANY, INC.
400 VIRGINIA AVE. S.W., WASHINGTON, o.C. 20024 (202) 554 2345
_ _ _. _., ~.
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I existenre.
2 A
Among tne information that we provided were a few 3 documents that fit that category.
I am thinking of certain 4 memos which I don't believe were in our TMI 2 recovery 1
5 files.
It is our intent to provide you with documents that 6 we believe are pertinent to your investigation as well as 1
7 making files available.
4 8
We have attempted very diligently to provide you 9 with the documents that we think are germane to your 10 investigation and helpful to you in it.
11 MR. HARPSTER:
John, we have attempted to compile 12 a list of all persons who made contact with Three Mile 13 Island, Met.
Ed., GPU or BEW employees in the vicinity of O
1<4 Three Mile Island on March 28th, 1979, or who were present 15 in the war room on that date.
16 Here is a copy of the list we have compiled.
For 17 tne record this is the same list we have shown to Don Roy, l
18 Dick Kosiba and Jim Deddens.
Is there anyone else who you l
19 think belongs on this list whose name is not indicated on it?
20 (The list was handed by Mr. Harpster to the 21 witness.)
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ALDERSON REPORTING COMPANY. INC.
f 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554-2345
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1 (The list consisted of the following namesa 2 Rogers, Flint, Schaedel, Winks, Twilley, Kelly, Deddens, 3 Roys Womack, Taylor, Kostba, Karrasch, Spangler, Dempsay, 4 Kennedy, Dunn, Hallman, Olds, Ward, Pletke, Culverson and 5 Wandling.)
6 THE WITNESS:
No, not to my knowledge.
7 BY MR. HARPSTER:
.r~
8 0
We have explained the purpose of the interview 9 here today and you have indicated your understanding of it.
10 Based on this understanding do you have any additional 11 information that might be useful or pertinent to our 12 investiga tion ?
13 A
No, but as we promised earlier if at any point we O
14 were to uncover any information that was we wou:d certainly 15 let you know of its existence as quickly as possible and 16 provide you with it.
17 MR. HARPSTER Thank you, John.
18 (Whereupon, a t 9:50 a.m., the taking of the 19 deposition of John G.
Mullin concluded.)
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ALDERSON REPORTING COMPANY, INC.
400 VIRGINIA AVE, S.W.. WASHINGTON, D.C. 20024 (202) 554-2345
10 O
i 2
I have read the foregoing pages 3
through inclusive,
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4 which contain a correct trans-5 script of the answers made me 6
to the questions therein 7
recorded.
Signature is subject 8
to corrections.
9 i
10 DONALD H. ROY l
11 12 13 14 i
Nota ry Public in and 15 I,_
16 for the State of Virginia, do hereby certify that I am 17 notarizing and witnessing signature for the Deposition of 18 ER. DONALD H.
ROY on this day of 1980.
19 20 21 Notary Public in and for the 1
l l
22 State of Virginia 23 24 My Commission expires 25 l
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ALDERSON REPORTING COMPANY, INC.
_ __-,-,__ _-2345 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554
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or s:rvo'^sx arrortta 2
I, Mary C. Simons, stenomask reporter, do hereby 3 certify that the testimony of the witness which appears in 4 the foregoing deposition was taken by se in stenomask and 5 thereaf ter reduced to word processing by me; that said 6 deposition is a true record of the testinony given by said 7 witness; that I is neither counsel for, related to, nor "J employed by any of the parties to the action in which this a
9 deposition was taken, and further that I am not a relative 10 or employee of any attorney or counsel employed by the 11 parties thereto, or financially or otherwise interested in 12 the outcome of the action.
13 14 Y
'* N 15 Mary C. Simons 16 Stenosask Reporter 17 18 19 20 c
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4 ALDERSON REPORTING COMPANY, INC.
400 VIRGIN!A AVE. S.W., WASHINGTON. D.C. 20024 (202)554-2345
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