ML20024J564
| ML20024J564 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/30/1982 |
| From: | Arnold R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-02, TASK-04, TASK-05, TASK-06, TASK-10, TASK-11, TASK-2, TASK-4, TASK-5, TASK-6, TASK-GB B&W-4044, NUDOCS 8307090323 | |
| Download: ML20024J564 (7) | |
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DEFENDANT'S EXHIBIT U. S. DIST. COURT S. D. OF N. Y.
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UNITED STATES DISTRICT COURT 146 SOUTHERN DIS.TRICT OF NEW YORK
- -x GENERAL PUBLIC UTILITIES CORPORATION, a
JERSEY CENTRAL POWER & LIGHT COMPANY, METROPOLITAN EDISON COMPANY ai d PENNSYLVANIA ELECTRIC COMPANY, a
Plaintiffs, 80 CIV. 1683 (R.O.)
-against-THE BABCOCK & WILCOX COMPANY and J.
RAY NcDERMOTT & CO.,
INC.,
Defendants.
- -x Continued' deposition of ROBERT C.
- ARNOLD, taken by Defendants, pursuant to adjournment, at the offices of Davis Polk & Wardwell, Esqs.,
One Chase Manhattan Plaza, New York, New York, on Wednesday, June 30, 1982 at 10:10 o' clock in the forenoon, before Charles Shapiro, a Certified Shorthand Reporter and Notary Public within and for the State of New York.
DOYLE REPORTING. ING CERTIFIED STENOTYPE REPORTE.1 369 LaxtNGTON AVENUE WAl.TER SH APIRO. C.S.R.
New Yoms. N.Y.
10017 CHARLES SH APIRO. C.s.R.
TEl.EPHO N E 212 " $67*0220
I 224
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s 1
Arnold 2
the safety, code safety valve and not the PORV.
I 3
have yet to find a witness who could give me the name l
4 l of a person on the Met Ed staff who had made that 5
conclusion.
6 Can you he,1p in that regard?
I 7
MR. KLINGSBERG:
I will have to object 8
to the form of the question, only because you 9
are not showing us these documents, and I 10 personally was not at all the depositions that 11 you are apparently talking about.
12 If you are confident that's the 13 predicate of the quest,on, we'll get on with 14 it, but I will have to put the objection on the 15 record.
l 16 MR. WISE:
Okay.
Could I have you ask me the question?
17 A
18 I think I understand the predicate.
it was on 19 Q
Can you tell me who, by name, 20 the Met Ed plant staff that determined before the 21 accident that it was a code safety that was leaking
[
I oo and that the PORV was not leaking?
l 23 A
No, I don't have any recollection of an l
24 individual that made that conclusion.
.i i
Do you have a recollection of the title 1
25 Q
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w w
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1 Arnold 225 2
or general position of the person who made that 3
conclusion, if there was such a person?
4 A
No.
My recollection is that the major 5 1 basis for the validation of an opinion that the plant 6
aupervisory staff had made, that judgment was in the i
7 maintenance work list which was reviewed at routine 8 [
staff meetings on outstanding plant problems.
9.
Q Were you ever advised that at the same i
10 time the code safety had been put on the work list 11 as an item to be covered at the next outage, that Met 12 Ed had also' undertaken to attempt to find or, locate 13 a spare pilot-operated relief valve in the event 14 that turned out to be the valve that'was leaking?'
15 A
That supposition has kind of a familiar I
16 ring to it, but I don't have a acollection of the 17 of that decision or that activity being undertaken 18 and having been reported to me as a result of the
- 19 investigations done.
20 Q
Did you receiv's reports on what the 21 various members of the plant operating staff had I
22 concluded before the accident?
23 A
Is the question did I receive such 24 reports before the accident?
25 Q
No.
226 Arnold 1
You mentioned during some of your 2
3 previous answers that you are. war' today that 4
various members of the plant staff had differing 5
views on whether the PORV was leaking or not; at 6
l e'a s t that's what I understood you to say.
7 A
Yea, sir, that's my recollection.
8 Q
My question now is, was your statement 9
to that effect based on the fact that you received 10 reports as to which members of the staff believed and which members believed something 11 the one thing 12 else?
13 A
My recollection is, in the course of 7
14 discussing the information that was developed from 15 the detailed review that I charted, that members staff before 16 of the staff or some members of the 17 the accident had thought the PORV was leaking, and can recall being associated with 18 the only name I in conjunction with the
'19 those discussions which were I
20 providing with the results of the study is Bernie i
21 smith.
That's a relatively vague recollection, but j
l i
22 that name does come to mind.
23 Q
What was Mr. Sminh's position?
24 A
Mr. Smith was a shift supervisor at the 25 station.
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227 1
Arnold l
l 2
Q I guess what I am trying to clarify, Mr.
3 Arnold, is that you have testified that it was 4
reported to you after the accident that the operating 5
staff had differ,ing views on which valve was leaking.
6 As you have just said, Mr. Smith apparently believed 7
it was the PORV.
8 MR. KLINGSBERG:
I don't think he said I
9 that.
10 MR. WISE:
I am sorry, then I 11 misunderstood.
12 Q
You named Mr. Smith as an individual in 13 the plant operating staff who believed that the PORV 14 was the cause of the leakage, did you not?
15 A
Yes, I did, as an example of some 16 individual members of the staff who I understood 17 thought otherwise, not that there was a broad-based 18 disagreement among the staff on the issue.
staff Could you name me a person on the 19 Q
I 20 who took the opposite position from Mr. Smith, that I
21 is, who said that the PORV was not leaking?
22 A
I don't recall there was any discussion 23 with any of the people involved or any of the people opinio'n as what the investigation 24 who held the sa e 25 came up with" My recollection is that there was some
7 228 1
Arnold 2
discuss, ion about one or two people who had a 3
differing view, but we didn't go through an exercise 4
of listing the names of those who thought it was a 5
PORV and those who thought it was a code safety.
6 And the reason that we even got into it 7
at all was becaus e, as I recall anyway, was because 8
of the differing reports that were given to the NRC, 9
and as part of our discussion on-what information we 10 developed, we were trying to understand why the NRC 11 was giving differing viewpoints.
12 It was not critical to me in terms of 13 what had transpired, so to speak, before the 14 accident, but only in trying to understand what 15 information was developed within the staff and as they went through their 16 provided to the NRC 17 investigation after the accident.
18 Q
After the accident, you became aware 19 that there was an emergency procedure for the i
20 pressurizer system failure at THI-2, did you not?
I 21 A
I became aware of the specific procedure 22 with that title, yes.
23 Q
It was part of the NRC citation that you 24 responded to, was it not?
l 25 A
That's my recollection, yes.
I e
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