ML20072H880
| ML20072H880 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/21/1982 |
| From: | Long R GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| References | |
| TASK-*, TASK-01, TASK-04, TASK-07, TASK-08, TASK-09, TASK-1, TASK-4, TASK-7, TASK-8, TASK-9, TASK-GB NUDOCS 8306290793 | |
| Download: ML20072H880 (61) | |
Text
-.
i 417-A i
t INDEX TO EXHIBITS (continued) s 1
B&W FOR IDENTIFICATION PAGE C,
7G6 GPU Service Technical Data Report No. TMI-111, with attached memo dated July 5, 1979 370 707 Document with a three-page covering letter from R.C.
Arnold to Victor Stello, dated December 5, 1979 372 tt Ccontinued on page 418)
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INDEX TO EXHIBITS (continued)
B&W FOR IDENTIFICATION PAGE f(*
708 Document consisting of pages marked with production Nos. 8621 through 8630 372 709 Group of handwritten pages consisting of document Nos.
8858 through 8874 380 710 Multipage document headed
" October 3, 1979 Presentation to EEI Prime Movers" 384 711 Document reading across the top
" Development of Technical Support for the TMI-2 Accident" 389 712 Document with the word " Intro-duction" in upper left-hand corner 389 i
713 Document with heading " Analysis of Technical Support Following the j
Three Mile Island Accident".
389 714 Document with heading "Analy, sis of Technical Support Following the Three Mile Island Accident" 389 715 Document with " Draft" typed at the top 389 716 Document with title " Organization
(_
for Technical Support" 389 j
717 Document, first page being a photocopy of a file jacket with file tab reading "TDR-TMI-102 fx Accident Transient Modeling
(
f Analyses (G. Broughton)"
394
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439 INDEX TO EXHIBITS (continued)
B&W FOR IDENTIFICATION PAGE C *'
718 One-page handwritten memorandum from Ken Lucien to Bob, with attached multipage document 397 719 Interoffice memorandum from Mr.
Zodiaco, with attached document 398 720 Three-page handwritten document headed in the upper right "1025 hours0.0119 days <br />0.285 hours <br />0.00169 weeks <br />3.900125e-4 months <br />, 14 April '79 Meeting with RCA" 403 721 One-page handwritten document dated 1122 hours0.013 days <br />0.312 hours <br />0.00186 weeks <br />4.26921e-4 months <br />, 14 April 79 406 6
722 Two-page handwritten document headed "TMI-2 Incident Ev'aluation Manager" 409 723 Three-page handwritten document dated 16 April 1979 e
410-724 Six-page handwritten document dated 17 April 1979 411 725 Document dated in upper right corner 25 April
'79, top line, reading " Review of G. Miller 14 April '79 forum" 414 45mk *s4 h
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-6 UNITED STATES DISTRICT COURT SOUTHERN D.TSTRICT OF NEW YORK
- -x dot GENERAL PUBLIC UTILITIES CORPORATION, JERSEY CENTRAL POWER & LIGHT COMPANY, f4 METROPOLITAN EDISON COMPANY and k
PENNSYLVANIA ELECTRIC COMPANY, Plaintiffs, 80 CIV. 1683 (R.O.)
-against-
=
THE BABCOCK & WILCOX COMPANY and J.
RAY McDERMOTT & CO.,
INC.,
Defendants.
I
-x Continued deposition of GPU, Nuclear
-?
Corporation, by ROBERT L.
LONG, taken by a-defendants pursuant to adjournment, at the offices of Davis Polk & Wardwell, Esqs., One Chase Manhattan Plaza, New York, New York, on Friday, May 21, 1982, at 9:50 o'cl6ck in the forenoon, before Joseph R.
Danyo, a Notary Public within and for the State of s-New York.
/
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9 DOYLE REPORTING. INC CERTIFIED STENOTYPE REPORTER:
369 t.tx1NGTCN AVENUE WALTER SHAPIRO, C.S.R.
Nsw Ycn x. N.Y.
10017 CHARLES SHAPIRO. C.S.R.
Tzt.rPNo N r 212 - 867 8220
1 421 2
APPea ran ce s:
~
3 KAYE, 9 CHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4
425 Park Avenue New York, New York By:
STEVEN J.
GLASSMAN, ESQ.,
6 of Counsel 7
8-DAVIS POLK & WARDWELL, ESQS.
' Attorneys for Defendants
.9 One Chase Manhattan Plaza New York, New York 10 h
By:
RODMAN W.
BENEDICT, ESQ.,
11 of Counsel 12 13 Also Present:
o 14 DEBORAH JACOBS 1
15 e
16 17 18 19 i
20 21 22 23 f
24 25
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ROBE RT L.
LON G, having been 2
3 previ usly duly sworn, resumed and testified 4
further as follows:
(
5 (16-page handwritten memorandum dated 6
July 17, 1979 was marked B&W Exhibit 726 for 7
identification, as of this date.)
8 (Multipage document, first page headed 9
" Preface" at the top, was marked B&W Exhibit 10 727 for identification, as of this date.)
11 EXAMINATION (continued) 12 BY MR. BENEDICT:
O
13 Q
Do you understand that your testimony 14 today continues'to be under oath?
15 A
Yes.
16 Q
I would like to show you two documents that 17 have been marked as B&W 726 and B&W 727.
18 B&W 726 is apparently a 16-page handwritten 19 memorandum dated July 17, 1979, which reads in the 20 first line on the first page, " Summary of operational 21 aspects."
L 22 What has been marked as B&W 727 is a 23 multipage document, the first page of which reads
[
)
24 at the-top, " Preface," and if you turn in a few pages, v
25 '
the document appears to be dated July 16, 1979.
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1 423 2
Appearance s:
3 KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, ESQS.
Attorneys for Plaintiffs 4
425 Park Avenue New York, New York
(
5 By:
STEVEN J.
GLASSMAN, ESQ.,
6 of Counsel
'~
7 8
DAVIS POLI; & WARDWELL, ESQS.
-Attorneys for Defendants 9
One Chase Manhattan Plaza New York, New York 10 E
By:
RODMAN W.
BENEDICT, ESQ.,
11 of Counsel 12 n/
A-13 Also Present:
s 14 DEBORAH JACOBS 15 16 17 18 19
-20
'21
(.
22 23
- n
(
l 24 As' 25
.2
l 1
422 C:)
2 ROBE RT L.
L 0 N G, having been 3
previously duly sworn, resumed and testified 4
further as follows:
(
5 (16-page handwritten memorandum dated 6
July 17, 1979 was marked B&W Exhibit 726 for 7
identification, as of this date.)
8 (Multipage document, first page headed 9
" Preface" at the top, was marked B&W Exhibit 10 727 for identification, as of thiy date.)
11 EXAMINATION (continued) 12 BY MR. BENEDICT:
O 13 Q
Do you understand that your testimony 14 today continues to be under oath?
15 A
Yes.
16 Q
I would like to show you two documents that 17 have been marked as B&W 726 and B&W 727..
18 B&W 725 is apparently a 16-page handwritten 19 memorandum dated July 17, 1979, which reads in the-20 first line on the first page, " Summary of operational 21 aspects.a 22 What has been marked as B&W 727 is a 23 multipage document, the first page of which reads 24 at the top, " Preface," and if you turn in a few pages, 25 the document appears to be dated July 16, 1979.
l 1
Long 423 9
2 Looking first at what has been marked as 3
B&W 727, is this a copy of the draft of nureg 0600 4
that you mentioned in your testimony yesterday?
(
5 I might note for the record that this document, 727, 6
came from your files.
7 MR. GLASSMAN:
It was identified as coming 8
from his files?
9 MR. BENEDICT:
It was identified by you a ma%ter of fact.
10 as coming from his files, as 11 A
It appears to be.
I don't know with 12 certainty that it is the draft.that I reviewed, but 9
13 it certainly appears to be.
I seem to remember 14 though that there were'two volumes.
There was a 15 health physics volume as well as an operational volume.
16 I don't know whether they were really part of nureg 17 600 or whether physics was a separate number.
18 Q
Is this the operational portio of the 19 draft that you remember?
4 20 A
5t appears to be that, yes.
21 Q
By "this," I meant B&W 727.
22 A
Yes.
23 Q
Could you look at B&W 726 and tell me 24 whether these notes are in your hand?
25 A
Yes, they are, i
le
i Long 424 9.
2 Q
Is B&W 726 a series,of notes that you prepared on or about the 17th of July, 1979 relating 3
4 to your review of the draft 06007
(
slightl'y different 5
MR. GLASSMAN:
There are 6
dates that appear at the top of the various 7
pages.
8 MR. BENEDICT:
Mr. Glassman makes a good 9
point.
The document is dated the 17th, the 18th, 10 the 19th, and the 20th, the 22nd*- that seems 11 to be it -- through the course of its 16 pages.
12 Q
So on or about the dates noted or sometime 13 in July?
14 A
Yes, they were notes prepared, from a
15 review of this document,over a number of days.
16 Q
By a review of this document, you mean 7277 17 A
Yes.
18 Q
0n the first page of B&W 726, about two-19 thirds of the way down in the far left margin, there is 20 a notation which reads, "NC," then either a dash or a 21
- dot, "TS."
22 Is that an abbreviation for noncompliance 23 technical specification?
24 A
Yes, that is a notation that indicates 25.
according to t h'e draft report there was a potential for
--.-----.i--..i-..
1 Long 425 9
2 noncompliance with technical specification.
It doesn't 3
say that there was such a noncompliance.
4 Q
In terms of the abbreviation noted here, 5
that does stand for noncompliance technical 6
specification; is that right?
7 A
Yes.
8 Q
Could you turn to what is noted as page 2 9
of your notes, which is in fact the third page of the 10 exhibit, because there is a repeat page(on the second, 11 and note at the top at the far left margin chere is an 12 entry which reads "NC-EP."
13 Is that an abbreviation for noncompliance 14 emergency procedure?
15 A
Yes.
Again, that is an abbreviation for 16 noncompliance emergency procedures.
It doesn't 17 necessarily indicate that that is what there was.
18 Q
Farther down toward the center of that 19 page, there is an entry in the far left margin which 20 reads, "NC-APP B."
21 Is that an abbreviation for noncompliance 22 Appendix B7 23 A
Yes.
24 Q
Is the Appendix B referred to Appendix B 25 to 10 CRF part 507 4
m i
1 Long 426 C\\ j)i m
2 A
Yes.
3 Q
Immediately below that entry, there is an 4
entry which reads "NC-MP."
(
5 Does that abbreviation stand for 6
noncompliance preventive maintenance procedures or 7
maintenance procedures?
8 MR. GLASSMAN:
Throughout these questions, 9
I assume you are just looking for the meaning t
10 of the abbreviation.
You are not,asking a 11 substantive question as to what else it indicates?
12 MR. B3NEDICT:
I am asking what the
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%_/
13 abbreviaticn means.
That's right.
14 A
Yes.
15 Q
would you turn to what is marked as the e
16 third page of your notes, which is the fourth page of 17
.the exhibit.
In the left margin at the top of the 18 Page, immediately below an entry which reads "NC-TS,"
l 19 there is a parenthetical which reads " (Ro s s yes)."
20 Then below that, toward the middle of the page, there 21 is another entry which reads "NC-TS" and then below 22 that it reads " (Ros s no. ) "
23 what is the significance of these entries (7
(,f 24 or what was the significancesof those entries?
j 25 MR.' GLASSMAN:
You are asking for the
1 Long 427 O
. Nn).
2 witness's recollection or are you asking him e
speculate?
3 4
MR. BENEDICT:
I am asking for his
(
5 recollection.
6 A
I don't remember what the circumstances 7
were where I made those notations.
8 Q
At the last line of the page marked as 9
page 3 of your notes, there is a line which reads, 10
" Verify against QB corrections."
t a
11 Does QB Refer to Quincy Billingsley?
12 A
Yes, it does.
O 13 (Multipage document, first page headed
^
"I&E Radiological SON," dated July 19,'1979, 14 J
15 was marked B&W Exhibit 728 for identification, 16 as of this date.)
17~
Q I would like to show you a document marked 18 for identification as B&W Exhibit 728.
It is.a 19 multiple-page document composed of-both handwritten 20 and typed entries.
'The first page is headed'"I&E 4
- 21 Radiological.SOE," and it is signed by Ed Wallace, 1
23 and dated July --
/
23 '.
A That is not signed by Ed Wallace.
A
():
24
_Q It indicates Mr. Wallace's name.- Mr. -
25-Wallace's.name is at the bottom'of the page-and it is a'
y T
T 7-T-'*-
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1 Long 428 O
dated July 19, 1979.
I am only seeking to identify 2
it for the record.
The document appears to be a 3
compilation or a group of comments from various 4
(
individuals with respect to the draft 0600 report.
5 6
Do you recognize this as being a group of 7
comments collected by you sometime in the summer or 8
fall of 1979 relating to the draft 0600 report review which has been marked as B&W 7277 g
10 A
Although I don't remember each of these 11 being received, it appears to be just that, yes.
12 Q
Could you turn to the pages in B&W 78 O
13 starting with the litigation page No. 9544 and going 14 through page No. 9549.
The first page has written 15 on it at the bottom, " comments received from Mike Ross 16 7/2 3/7 9.,"
17 Could you tell me whether these pages fo'r the marginal.notationk we 18 were the source 19 discussed before, the parenthetical refere$1ce to Mr.
l 20 Ross in what has been marked as B&W 7267 21 MR. GLASSMAN: -Are.you asking whether 22 seeing this document refreshes Dr. Long's 23 recollection?
l
's m
(
)
24 MR. BEFEDICT:
Yes, I am asking whether 25
.seeing.this. reminds him that that is-where he
.-4.
.1 Long 429 j-w
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2 got the information contained in the parentheticals n B&W 726.
3 4
A' No, it doesn't, and I don't know whether
(
5 that comment refers to the following pages or not 6
because I don't remember the order in which these were 7
in my file.
8 Q
You can't identify the typed pages g
following the notation relating to Mr. Ross as being 10 comments that you in fact received frod,Mr. Ross?
11 A
No, I cannot.
12 Q
What, if any, role did Mr. Ross have CE) 13 with respect to the review of the draft 14 which has been marked as 727 that you and I discussed 15
. yesterday?
16 MR. GLASSMAN:
Objection as to form.
17 A
I believe I indicated to you yesterday' 18 that there were a-number of people who ha review
~
19 responsibilities.
I remember.that Mike Ross was one 20
'of them.
21 Q
Did Mr. Ross haveat specific area of 22-responsibility?
23
.A
_From my' recollection?
l(~h -
- (,/
24 Q
Yes.
25 A.
I don't know.
~
1 Long 430 O
t e
%,/.
2 Q
Who, if anyone, supervised the review of the draft NUREG 0600 marked as B&W Exhibit 7277 3
4 A
As I told you yesterday, I coordinated
(
5 the collection of the comments on NUREG 0600, 6
Q Other than that, you are not aware of any 7
person who played any supervisory role with respect 8
to assignment of responsibility or resolution of open 65b g
items?
10 A
No, I don't remember.
I 11 Q
What did you do with the comments that you 12 collected including the comments that are'part of
. [h 4
/
9 13 what has been marked as B&W Exhibit 7287 4
14 MR. GLASSMAN:
Objection.
The witness has l
15 not yet related the fact of B&W 728 to the
.16 process'you stated.
17 MR. BENEDICT:
He said it appeared to be 18.
that, and I will take that as the foundation 19 of my question.
20 A
As I told you yesterday, to my knowledge, 21 the comments on NUREG 0600 were conveyed verbally 22
-in a meeting which took place at the Three. Mile Island.
e
- n Q
Other than that, you are not aware of any
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- x.
- 24 other use that.was made of the comments that:you-25 collected?
--<-,,y
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Long 434
,-m A
Not that I can recall.
2 (Two-page handwritten document dated 3
4 July 22, 1979, was marked B&W Exhibit 429 for
(
identification, as of this date.)
5 6
Q B&W 729 is a two-page handwritten 7
document dated July 22, 1979, which reads at the top g
line "NRC sequence of events miscellaneous notes for Keaten task force."
g 10 Are these notes in your han'dwriting?
11 A
Yes, they are.
12 Q
Do these represent additional notes I
~
k i 13 taken by you around the date indicated.on B&W 729 14 with respect to the draft NUREG 0600 which has been 15 marked as B&W Exhibit 7277 16 A
I don't remember preparing these notes.
17 (Three-page memorandum from E.-
G.
- Wallace, 18 dated August 6, 1979, was marked B&W Exhibit 19 730 for identification, as of this date.)
20 Q
I show you a document that has been marked 21 as B&W Exhibit 730.
It is a three-page memorandum 22 from E.
G.
Wallace to a list of people including Dr.
23 R.
L.
Long, dated August 6,
1979, subject:
TMI-2 24 NRC I&E investigation task items.
25 D es this memorandum relate to the review
1 Long 432 R
2 of the draft 0600 which has been marked as B&W Exhibit 7277 3
4 4
MR. GLASSMAN:
Are you asking the witness
(
5 to review it now and tell us what it seems to 6
read?
We can all read it.
Are you asking him 7
whether he received it and recollects what it means?
8
=
9 MR. BENEDICT:
I know how you have 10 instructed your witnesses, sort o'f, and I know 11 how we have gone through these questions, and 12 I think it is pretty evident that I am not asking 13 Dr. Long to speculate.
14 MR. GLASSMAN:
Your question is phrased 15 in a manner that makes a witness take a document 16 and try to read it and tell you what it looks 17 like.
I can do the same thing for you.
Your 18 quest. ion should be properly phrased.
[
j 19 MR. BENEDICT:
My question is properly l
l 20 phrased.
If you don't believe so, make your i
21 objection and be quiet.
(.
22 THE WITNESS:
Can I have the question l
23 reread?
("^
- ()
24 (Record read.)
25 A
I don't' remember receiving this particular
'=
J
1-Long 433 2
memorandum.
3 Q
What, if any, role do you recall Mr.
4 Wallace played with respect to the review of the draft 5
A Mr. Wallace was in the licensing group, 7
section, whatever it was called at that time, and 8
licensing normally put together the responses to 9
NRC requests or requirements.
10 Q
Does seeing B&W Exhibit 73k refresh your 11 recollection as to whether Mr. Wallace had any 12 supervisory role with respect to the review?
13 A
No, it does not.
14:
Q The subject of this memorandum reads, 15 "NRC I&E investigation task items."
16 Are you aware or do you recall today the 17 existence of any investigation with respect to the' 18 TMI-2 accident conducted by I&E during this time period 19 in the summer of 1979 other_than that represented by 20 the draft NUREG 06007 21 A
I am not_sure I understood the question.
22 Q
I will restate it.
23 other than the investigation by the NRC, 24.
-the results of which'are indicated in the draft NUREG 25 0600, what, if any, investigations do you know of that
i i
Long 434 2
the I&E people at the NRC were conducting during the summer of 1979 as it related to the TMI-2 accident?
3 4
A The only other I&E activity I am aware of
(
5 was the one represented in the health physics section 6
of this report, referring to B&W 727.
7 (Letter from Mr. Woodard to Dr. Long, s
8 dated July 12, 1979, and attached ultipage I
9 document, was marked B&W Exhibit 73 1 for 10 identification, as of this date.)!
11 Q
I show you a document marked as B&W Exhibit i
12 731.
It is a multiple-page document covered by a 13 letter from-Mr. Woodard of Pickard, Lowe & Garrick i
14 to Dr. Robert.Long, dated July 12, 1979.
The text 15 of the letter reads, " Enclosed are Xeroxed copies of 16 our commente on the NRC's radiological sequence of 17 events.and I&E's testimony to the Commission on same."
18
,as this review'that Mr. Wood rd sent to you W
19 in July 1979 a part of the review that was b ie ng 20 conducted of the draft NUREG 06007 21 MR. GLASSMAN:
Objection as to form.
I 22 don't know if you are asking for Dr. Long's
)
23 understanding'of'what Mr. Woodard was doing or
-(O-e
_)
24 what-Dr. Long was doing.. It is a most ambiguous 25-question.
The witness can answer so far as he t
-a..
y.
4
1 Long 435 O
2 understands it.
3 (Record read.)
4 A
I don't want to play games with you, but 5
I d n't really quite understand the context of that 6
question.
7 Q
I recognize that B&W Exhibit 727 is only 8
the operational portion, as you have indicated, of the 9
draft of NUREG 0600.
If it helps you in understanding, 10 the NUREG 0600 that was ultimately rele'ased to the 11 public, I will represent to you, included a 12 radiological section, if that helps you in recalling O
13 what Pickard, Lowe & Garrick was doing in the summer 14 of '79 and whether or not it related to the review 15 of the draft 0600.
Maybe now you can answer the 16 question.
17
.A Yes.
With that information that the 18 radiological portion was part of NUREG 0600, this was 19 Part of that review.
20 Q
What, if anything else, did Pickard, Lowe 21
& Garrick do with respect to reviewing material 22 pertaining to the draft 0600 during that summer?
23 A
I don't recall any other involvement that l
24
.they would have had.
25 g
Do you recall that-you were the person
1 Long 436
-s v
2 who was dealing with the people at Pickard, Lowe &
i Garrick with respect to the radiological issues 3
covered in B&W 7317 4
5 A
Yes, I had been from the time when the 6
assignment of the task for that review was part of 7
the accident assessment documentation team.
8 Q
was the review that we have been discussing 9
of the draft NUREG 0600 that was done in the summer of 10 1979 done under the aegis of the ac cid e'nt assessment 11 documentation team?
12 A
No.
O 13 Q
What work was Pickard, Lowe & Garrick 14 doing for the accident assessment documentation team?
15 A
They were working on two reports. One_on 16 on-site.dosesand one on off-site doses.
17 Q
What, if any, other projects did Pickard, 18 Lowe & Garrick undertake with respect to investigation 19 into the Three Mile Island accident during the summer 20 and fall of 19797 21 A
I don't know.
C.
22 Q
Do you know of any other activities 23 they undertook with respect to investigation of the O(_)
24 Three Mile Island accident at any time between the 25 day of the accident and now?
'i' i
1 Long 437 0
2 A
I think we already discussed Mr. Lowe 1
was a member of the Wilson so-called "investipation" 3
4 team that arrived on the Island on March 29.
(
5 Q
other than Mr. Lowe's involvement and what 6
we have discussed in the last few questions, do you 7
know of any other work that Pickard, Lowe & Garrick 8
has done for the GPU system relating to the Three Mile 9
Island accident?
10 A
No, I don't know.
E 11 Q
What, if any, other outside vendors or 12 consultants participated in the review of the draft O
13 NUREG 06007 14 A
The members of the sequence of events j
15 team reviewed the NRC sequence of events.
16 Q
Did that team include people from outside h
17 vendors'or consultants?
f 18 A
Yes.
4 19 Q
. Who did it include?
20 A
If'you mean by who the names of the 21 members of the-team --
22 Q
If you can remember who it was, yes.
'3 A
The only name that I would be sure a
k
(,)
24 that was still on the team.would be Mr. Van Witbeck.
25 Q
other than through individual participation
i Long 438
/~N.
(
l' v
2 in predominantly GPU groups, are you aware of any 3
w rk d ne by utside consultants or vendors with 4
respect to the review of the draft 0600, excluding the
(
5 work by Pickard, Lowe & Garrick we already discussed?
6 A
No, I am not.
7 Q
Do you recall whether MPR Associates did g
any work on it?
9 A
I don't know.
10 Q
Other than Mr. van Witbecks role and 11 People who were working for Mr. Van Witbeck, are you 12 aware of anything that Energy Incorporated did?
O 13 A
I don't know whether they did anything 14 other than that work or not.
?
15 Q
I am going to ask you some questions that 4
i 16 relate to the testimony you gave before the Atomic Safety 17 And Licensing Board considering the restart of 18 TMI-1.
I have put in front of you what, at least to 19 my knowledge, is all of the testimony that you gave 20 before.the restart board, and I will be referring you 21 to pages from time to time.
I would like you to feel 22 free to refer to any portion of your testimony, 23 whether or not it is a page,that I refer to, if you 24 need to do so in answering any of my questions.
25 My.first question would be if you could o
f g
Long 439 if) v 1
k through the.four volumes I have put in front of 2
you and tell me if you can recall giving testimony on any days other than February 11, February 12, 4
(
resruary 23, and resruary is, 1982.
3 A
I don't recall any other before the Atomic 6
Safety and Licensing Board.
3 7
8 Q
Do you recall any other' testimony you gave with respect to the restart of TMI-1, whether in 9
10 deposition or before an administrative llaw judge?
A I d n't recall any deposition.
I did 11 12 appear before the administrative law judge.
O 13 Q
Which judge was that?
A Judge Mulholland.
14 15 Q
What was the subject matter of your 16 testimony at that time?
I 17 A
Some general information on the training 18 Program and some information on procedures on the 1
19 administrati on of examinations.
20 Q
Was this testimony given as part of Judge Mulholland's investilgation into allegations of cheating 21 22 n licensing and other exams by TMI personnel?
23 A
Yes.
24 Q
What date or approximately when did you 25 give that testimony?
4 1
Long 440 1
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a.
N J')
2 A
It was early in 1982.
Q Did you receive a copy of a transcript of 3
4 that testimony?
(
A Yes.
5 6
Q How long did you testify?
7 A
Approximately two hours.
8 Q
Returning to your earlier testimony before I
the Atomic Safety and Licensing Board, I would like to g
E 10 turn your attention to the volume which is dated 11 February 11, and particularly to the written testimony i
12 that appears-immediately after page 12,140 in the t ex t.
O 13 MR. BENEDICT:
We have not, received a copy i
~
14 of the t'estimony that Dr. Long says he received l
15 a copy of, the testimony that he gave before 16 Judge Mulholland, and I can't axamine him 17 with respect to that testimony before I have 18 seen it.
1 19 MR. GLASSMAN:
It is obviously unresponsive, 20 as to time, and it has not been requested by
/
21 you.
You had notice of those hearings, and
(
l 22 you were well able to request them.
i I
23 MR. BENEDICT:
We may have to go to the 24 judge on the issue of. responsiveness and the 25 time element, the relevance to this litigation.
[
c,4 3
1 Long 441 O.
2 When we do, I just want you to be advised that 3
Dr. Long may be subject to being recalled.
4 MR. GLASSMAN:
You can advise us of
(
5 whatever you think you would like to advise us 6
of.
As I just stated --
7 MR. BENEDICT:
Having reviewed Judge 8
Mulholland's 9
MR. GLASSMAN:
I would appreciate it if f
10 you would stop continually interrupting me in the 11 middle of a statement.
12 MR. BENEDICT:
It is hard to tell when O
13 your statements end.
14 MR. GLASSMAN:
Aside from the nature of your 15 personality, I would like to get on to the merits.
16 As I just stated, the material that you just 17 alluded to is not responsive to any-requests 18.
in the litigation.
If there should be requests 19 for further documentation, we will treat them s
20 as we have all other requests and be cooperative 21 where at all possible in providing appropriate 22 information.
23 MR. BENEDICT:
I hope that'is true.
I am
/s:( )
24 not disputing that at this time.
I am simply 25 advising you that I am not going to attempt to s
__.__._____________.__________.m
1 Long 442
/
s examine Dr. Long on his testimony at this time,
'2 because I haven't been provided with a copy of it.
3 MR. GLASSMAN:
You haven't asked for it.
i 4
MR. BENEDICT:
If there comes a time when 5
6 Dr. Long's testimony is required with respect 7
to issues of cheating and allegations of cheating, 8
he may be subject to recall.
9 MR. GLASSMAN:
You can make whatever 10 statement you want.
You haven't* asked for the 11 document, and if you ask for it 12 MR. BENEDICT:
I will ask for it right
\\_/
2 13 now, and we will continue and I will examine him 14 Monday morning about it, if you can provide me 15 with it this evening.
l
~
16 MR. GLASSMAN:
You know very well this is 17 a waste of time and colloquy.
You have been 18 advised of the Mulholland proceedin s for some 19-time now.
You were aware of the report of the 20 administrative ~1aw judge.
You had ample time to 21
. request it before Dr. Long came here this week.
22 You had ample time during this testimony to 23 request any document you wanted.
If and when
- q) 24 we receive the request in the form that we have 25 always received it from you, we will respond.
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1 Long 443 fs
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2 If at that point you find it necessary to recall Dr. Long or to ask for any particular witness, 3
4 -
we will address that at the time in the course of 5
our normal proceedings.
6 MR. BENEDICT:
My comments with respect 7
to that are I recognize what you say.
With 8
respect to the Mulholland findings, Dr. Long's g
name nowhere appears, nor doec his title.
There 10 was no reason to believe that he' bad given 11 testimony, based on the publicly available 12 information on this testimony.
I therefore O
V 13 request his testimony now.
I will not terminate i
14 this dcposition today, until such time as we have 15 had a chance to examine that or any other 16 material in Dr. Long's possession relating to the 17 allegations of cheating, and then we will resume 18 after we have had a chance to examine the 19 document and determine whether any questions 20 have to be asked.
21 MR. GLASSMAN:
You can proceed on whatever 22 basis you feel appropriate.
Dr. Long is here 23 this week.
As you advised me before, you were
(_,
24 going to finish today.
Dr. Long is prepared to l
25 testify at length, and he continues to do so.
l m.
f v
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'l Long 444 A
.'Q) 2 MR. BENEDICT:
I agree that he is here 3
today.
I also agree that the practice in 4
these' depositions is to attempt to finish our
(
5 depositions as soon as possible.
I was not 6
aware of his testimony until this minute.
It 7
was impossible for me to ask for something that 8
I was not aware of until this minute.
9 MR. GLASSMAN:
We will see.
Continue 10 with your questioning.
11 BY MR. BENEDICT:
12 Q
Turning to pa'ge 4 of your written testimony,
, (_.)
13 the top paragraph, which is a full paragraph, at the 14 top of page 4, reads, "All training associated with 15 GPU Nuclear Corporation's nuclear facilities is 16 coordinated by the director - training and education 17 of the nuclear assurance division of the GPU Nuclear 18 Corporation located in Parsippany, New Jersey.
The 19 director - training and education's areas of management
~
20 responsibility include the training departments for 21 TMI-1, TMI-2 and Oyster Creeks the corporate training 22 department; and the GPU Nuclear Corporation system 23 laboratory."
T,)
24 At the time you gave this testimony, 25 were you the director of training and education?
. L.
'l Long 445
/-
\\,_).
2 A
Yes, I was.
3 g
was there any similar overseer of training 4
in the GPU system prior to the Three Mile Island
(
5 accident on March 28, 19797 6
A No, there was not.
7 Q
Looking down immediately below that, to
'8-the first sentence in the second paragraph on page 4, 9
it reads, "The activities of the training departments 1
10 located at each of GPU Nuclear Corporation's facilities 11
'are coordinated and reviewed by the corporate training 12 department."
13 What is the corporate training department?
14 A
A small training department that is located 15 in Parsippany.
16 Q
Did such a department exist in Parsippany, 17 whether by that name or another, prior to.the 18 accident on March 2', 19797 o
19 MR. GLASSMAN:
You are talking of such a 20 department in name or function?
21 MR. BENEDICT:
In function.
22 A
No, it did not.
- 23 g
I think Mr. Glassman's. point is well taken.
24 When.I refer to whether something was done before, I 25 am referring to its function, not to'whether.the i
1 Long 446
%J 2
actual individual is the same person or whether the title is the same.
3 4
Looking to the bottom sentence in that
-(
5 paragraph, the sentence reads, "The technical content 6
of training programs is defined by the technical 7
functions division and agreement is obtained from the 8
supervisor of each group receiving training on the 9
scope and content of applicable programs."
10 What is the technical functions division, 11 or what was it when you gave this testimony?
12 A
Technical functions division is a support 13 division of GPU Nuclear.
It primarily has the 14 engineering support capability and the licensing 15 responsibilities.
16 Q
Did such a division exist within GPU
~
17 prior to the Three Mile Island accident? -
18 A
Yes, it did.
19 Q
Did it have the same name?
Do you recall?
20 A
Yes..
21 Q
Was it part of GPUSC7 22 A
Yes.
23 Q
Did its function, to your knowledge, t
N
( )
24 change following the Three Mile Island accident?
25 A
Yes.
1 Long 447 m
(v) -
2 Q
How would you describe the changes that 3
you are aware of?
4 A
Prior to the accident, technical functions
(
5 provided construction and engineering support for
~
6 all three of the GPU operating companies, including 7
both fossil and nuclear stations.
Beginning with the 8
formation of-the TMI generation group in August 1979, 9
that division became part of the TMI generation group 10 and turned over the support of the fo s s'il stations to 11, the operating companies.
12 Q
Other than changes in its place within the O'
13 organizational structure of the GPU system, do I 14 understand you to be saying that the difference that 15 you recognize was that they had given away their 16 responsibility with respect to fossil plants?
17 A
They did that over a period of time, so that 18 they were after that transition period pro iding 19 technical support to the nuclear plants.
20 Q
Did the technical functions division 21 decrease in size or staffing following the distribution 22 of its responsibilities with respect to fossil plants?
23 A
I don't know the exact staffing patterns of (o) 24 that division.
- 25 Q
The first sentence of the last paragraph
i 1
^
Long 448
,a N
2
'on the page reads, "The corporate training department 3
is the organization which coordinates the development 4
of common training needs of the three GPU nuclear
(
5 facilities, e.g.,
radiological control training."
6 Did you understand at the time you 7
prepared this testimony that the common training needs 8
would also include thermal dynamics, heat transfer, 9
or fluid flow?
10 A
Those topics, among many others, are 11 common to both BWR and PWR plants, yes.
12 Q
So they would be subjects that would be v
13 coordinated by the corporate training department?
You 14 understood that?
15 A
Yes.
16 Q
Turning to the next page of your written 17 testimony, the only full paragraph on that page. reads,.
18 "The director - training and education with assistance 19 from the t'echnical functions division and the corporate 20 training department is actively reviewing and upgrading 21 the simulator training programs for GPU Nuclear 22 personnel."
23 What, if any, work was done prior to the-b
\\_/
24 Three Mile Island accident with respect to reviewing 25 and upgrading the simulator. training programs for
1 Long 449 O
2 operating personnel in the GPU system?
3_
A with the exception of the information 4
that we discussed the other day, that there was some
(
5 consideration given-to simulators, I don't know what 6
work was done prior to the accident.
I did not have 7
responsibility.
8 Q
,Looking down the list of things that are 4
9 indicated in the following sentences in that paragraph, 10 do you know whether prior to the Three Mile Island 11 accident there was any effort made toward the 12 preparation of behavioral learning objectives for O
13 simulator training?
14 A
No, I don't know.
15 g
what, if any, activity do you know of that t
16 occurred prior to the Three Mile Island accident 17 related to clarification of objectives for.the 18 training provided at the B&W simulator in Lynchburg, 19
-Virginia?
20 A
I don' t-have knowledge of what the interaction 21 between TMI and Lynchburg was prior to the accident.
22 Q
Turning to page 6 of your written 23 testimony,-the first sentence in the paragraph starting l ! O)
L
'(,
24 in the middle of the page reads, "The director --
25 training and education provides policy guidance to all
~4
1-Long 450 7-~t v
1 2
of the educational and support organizations for which he is responsible."
3 4
That would include your responsibility with
(
5 respect to the training at TMI-1 of operators, 6
the training at TMI-2 of operators, and the training 7.
of oyster Creek operators; is that correct?
1 8
A-Yes.
9 Q
Are you aware of whether there was any one 10 individual who had this responsibility 'or policy f
11 guidance prior to the Three Mile Island accident?
12 A
There was not someone who had responsibility 13 for both TMI and Oyster Creek.
I don't.know whether 14 the Jersey Central and Met Ed organizations had 15 somebody with responsibilities for their particular 16 company..
~
17 Q
Was there anyone within GPU, to your 18 knowledge, separate from Metropolican Edison, who 19 was responsible for providing policy guidance to 20 training'of-Metropolican Edison operators?
21 A
I don't know.
22 Q
At the time you gave this testimony, 3
23 Dr. Knief reported to ycu; is that right?
/~T
_- (,.
24 A
Yes.
)
25 g
In Dr. Knief's individual written testimony g-
1
~
Long 453 p)-
2 in the testimony that was admitted before the ASLB 3
on page 11, there is a sentence toward the bottom of 4
the page which reads, "The manager of training has
(
5 established an industry experience review procedure L
6 whereby significant events at other nuclear plants are 7
identified and information thereon routed to the l
1 8
cognizant supervisors for incorporation into appropriate 9
training-programs."
10 Did any such-program exist anywhere within l
11 the'GPU system prior to the accident on March 28, 19797 12 A
I don't know whether it did or not.
i O l
13 '
Q What is your understanding.of the content 14 of the industry experience review procedure or the 15 method by which it accomplishes its task?
16 MR. GLASSMAN:
Objection as to the form.
17-I have not the foggiest idea of what this 18>
multiple question is driving at.
19 MR. BENEDICT:
I am morally certain that 20 you understand _ full well what it means, but 21 I will restate it.
22 -
Q What is; the industry experience-reviewprocedure-23 as it is indicated to exist in this sworn testimony?
24
,MR.
GLASSMAN:
Objection to the form.
25 A
The industry. experience review procedure
~
-l"i i -
__________.____________----a_--_
'2--
1 Long 452 m
2 is a procedure that describes how the training 3
. department is to handle and incorporate industry 4
experience review items as they are provided to them.
(
5 Q
Is it a written procedure included within 6
the corporate procedures of GPU Nuclear?
7 A
The procedure referred'to here is a 8
TMI training department procedure.
9 Q
Do you know whether this procedure is 10 new since the Three Mile Island acciden't?
11 A
I don't know what the training department 12 at TMI had prior to the accident.
(~)
\\'
13 Q
Focusing now rather than on the function, 14 just as an exception to our general rule, rather than 15 the function that the industry experience review 16 procedure has and considering instead the specific 17 procedure, do you know whether that procedure is 18 new since the Three Mile Island accident?
19 A
No, I' don't know.
20 Q
To your knowledge, in the TMI training 21 department today, is there an accumulation or volume 22 of procedures by which the department is supposed to 23 function?
(mv) 24 A
Yes.
-t 25 Q
Does this collection of procedures have a d
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1 Long 453
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2 name?-
3 A
TMI Training Administrative Manual.
4 Q
Who would you ask today if you wanted to
_(
5 get a copy of that?
6 A
I have my own copy.
7 Q
Do you know whether it was provided to 8
your counse1 at' the time you were asked to produce
~
9 documents with respect to this litigation?
10 A
No, it did not exist at that time.
I 11 Q
When is your first recollection of such l
12 a manual existing?
~
13 A
Sometime toward the end of.1981.
14 Q
Do you have any knowledge as to whether 4
15 any efforts were made to implement a procedure similar I
16 in function to the industry review procedure prior to i
17 the Three Mile Island accident?
18 A
I have no knowledge of what was done prior 19.
to the accident in training.
20 Q
could you turn to'page 29 of.your written 21 testimony.
In your testimony in this deposition to-22 date, you have mentioned that you became aware 23 sometime following the Three Mile Island accident
~X.()
24 that some consideration was given within~GPU to the 25 :
acquisition of:a simulator for the TMI facilities.
4
++
-r--
c-.
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~
1 Long 434 2
Other thar. the box of documents you told me y u were given -- was it by Mr. Hetrick?
3 4
A Yes.
(
5 Q
What other knowledge do you have with 6
respect to that consideration prior to the Three Mile 7
Island accident?
8 A
I don't recall having any.
9 Q
Do you know whether Mr. Hetrick was 10 involved in the consideration prior to %he accident?
11 A
Yes, but I don't know what his involvement 12 was.
O' 13 Q
Other than Mr. Hetrick, do,you know of 14
-any other GPU system employee or officer 'who was 15 involved in the consideration of the acquisition of 16 a simulator prior to the Three Mile Island accident?
17 A
I' don't know of the others.
18 Q
Other than Mr. Hetrick,_ whom would you ask-19 if you wanted to find out who was involved in that j
i 20 consideration?-
21 A
I would start with him.
22 -
Q Turning over to page 30 of your written r
L 23 testimony, this seems to be a discussion about l
l t'~T j ()
24 something indicated as OARP,-which is operator
~25-accelerated requalification or retraining program.
Is
=-
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s
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l-1 Long 455 l
2 that correct?
3 A
One or the other.
I 4
-Q Which one?
Do you recal1~t
(
5 A
since you used both, no, I don't remember.
6 Q
At the bottom of the carry-over paragraph, i
f-7 there is a sentence which reads, "The TMI-1 training 1
1 8
department provided guidance to B&W for the simulator 4
i i
g training objectives and reviewed the training plans."
k 10 With respec't to preaccident, training, do t
i 11.
you know whether the training department at TMI 12 participated in providing guidance to B&W for simulator 13 training objectives and reviewed the training plans?
14 A
I don't know.
In that statement you read, 15' it does refer to the OARP training in particular.
16 Q
Further down that page, I will read from 17 the paragraph immediately below the sentence we just 18 -
read:
"In the fall of 1960, four trainees participated 19 in an eight-week ' cold license' training program for 20 replacement operators.
This program-was closely 21
' monitored by.GPU/ Met:Ed personnel.
During the last
- 22 six weeks,.a licensed SRO shift foreman or supervisor-23 participated and assisted the B&W staff in relating =
(
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o
? he simulator performance to actual.TMI-1, plant t
. 24
- 25 '
-*Xperience.">
+
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...., _,. ~.
., -..... ~. _....
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1 Long 456 1
\\
2 DC,you know whether prior to the Three Mile 3
Island accident GPU or Met Ed ever sent licensed 4
SRO shift foremen or supervisors to the B&W simulator
(
5 to assist the B&W staff in relating simulator 6
performance to actual plant experience?
+
1 7
A I don' t know whst' th'a practice was prior 1
4 s
8
' to thei accident. --,
j 4.
,N s
Q Isn' t it a f act tha t you know that this 2
g.
3 s
10 practice was new after the Three Mile Voland accident?
i 11 MR. GLASSMAN:
I think it bas been asked 4
3
~
1
- 'If and answered in a~different form.
s'
]('
13 MR. BENEDICT:
You direct the witness not i
14 to answer?
j-4 s.
3 I'
% 15 MR. GLASSMAN:
,' You can try'ag'ain.
16 A
-I don't know whether that is.a fact or not.
j i
j
- 17 Q.
I would like to refer your attention to
.e l-
'18
.testimonyifurther or - live' testimony glien,on February
.O l
~~7,.
19; 11, 1981. nIn particular, to page 1'2',278 and lines 18 T
20 through 22Tof that page..
This is Dr. Long :testif ying, s
sc 21
- "One of~the; key and very fifst' recommendations.to k
h 3
l-
'22 come,out of that. effort was.the~determin'ation to have I"t 9
. N-l, v
23 a? licensed shift foreman ~present full-time ~with:
i'.
s
!3 24 '
each - 'during each week of the subsequent [ six ' weeks r-i 25 (of; training.. That has worked;very effee ively forlus."
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1 l
1 Long 457
()
2 Does that refresh your recollection as to the fact that you knew that sending shift foremen 3
4 or shift supervisors to the simulator at B&W to
(
5 supervise and participate in simulator training was a 6
new idea or new occurrence after the Three Mile Island 7
accident?
8 A
That is not a correct characterization 9
of what that is talking about.
10 Q
What is it talking about? (
11 A
It is talking about the situation that 12 involved people reviewing the'first two weeks of that
{
13 eight-week training program and deciding based on those 14 first'two weeks which occurred in 1980 that to continue 15 that program for the next six weeks, there should be a e
16 shift supervisor or shift foreman present.
17 Q
Is it your understanding today that GPU 18 intends to continue to send shift supervihorsor shift 19 foremen to assist in simulator training?
20 A
I don't know whether they have continued 21 to do that or not.
It should be noted that that 22 also referred to training of new operators, not 23 previously licensed operators.
em (v) 24 -
Q Do you know whether'the practice was 25 continued or. utilized for or duringLthe simulator Y
< + +
f w
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l 1-Long 458
(~h.
U 2
training of currently licensed operators?
A In the training of currently licensed 3
4 operators, the shift supervisor and shift foreman
(
5 g
as a team along with the ope rators.
6 Q
In other words, the simulator training is done on a shif t basis-or by shif ts?
7 g
A For the requalification training, yes.
9 Q
The next sentence in that paragraph back 10 on page 30 of your written testimony rdads, "Also 11 during each week a representative of the TMI and 12 corporate training departments or technical functions 13 observed several days of both the classroom and 14 simulator secsions."
The next sentence goes on to say, 15
" Exit critiques were provided to the B&W training 16 center supervisory personnel and significant 17 improvements incorporated as the program progressed."
18 Are you aware of any instance prior to the
-19 Three Mile Island accident where representatives of 20 either the TMI or the GPU training groups or departments
-21 went to the B&W simulator and observed-its function?
22 A.
I don't know what the practices were prior 23 to the'TMI-2 accident.
\\
(,)~
24 Q
At the time you gave this testimony, you 25 were the director of training and education; is.that
g Long 459
..O 2
correct?
-3 A
Yes.
4 Q
And you have subsequently taken the title
.5 of director of nuclear assurance; is that correct?
6 A
Yes.
7 Q
Which has as part of its charge the 8
management of the' training and education group?
9 A
Yes.
10 Q
At any time since you originally took the i
11 job as director of training and education in 1980, 12 have you made any effort to review the, training 13 practices within the GPU system prior to,the Three 14 Mile Island accident as they axisted?
15 A
I have looked at the reports from the 16 many'different people who looked ~at the training 17 program.
ILdidn't do a separate examination or.
18 investigation'of my own.
19 Q-I would like to refer you_back to your 2'O testimony at page 9 of the written testimony, the 21
~1ast paragraph immediately above the entry relating to 22'
- Mr..Knief, "In sum, Dr..Long has had extensive j
23 technical experience in nuclear reactor operations;
..,r's:-
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124.
- extensive experience _as an. educator; and. extensive L25
-management experience.
.He is also familiar'with W-n-.
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i 1
Long 460 (V
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2 personnel at GPU Nuclear Corporation and understands 3
the nature of and the basis for the changes in the 4
training organization since March 1979."
(-
5 What was your basis for understanding the 6
changes in the training organization since March 7
19797 8
A I had prepared for me a table which 9
identified all of the criticisms that had been made, 10 all of the suggestions for changes tha( had been 11 made, all of the recommendations that had been made 12 by all the different groups that had reviewed TMI 13 training.
That gave me a rather extensive list of 14 the experience prior to the accident wher'e it was i
15 relevant to what should be happening after the
]
16 accident.
17 Q
Who, to your knowledge, was the most 18 knowledgeable person with respect to the organization t
19 and content of training at Metropolitan Edison prior.
20 to the Three Mile Island. accident?
21-A-
I don't know which;of.the people that were 22 involved would be classified-as-the most knowledgeable 23 person.
/s
$ )c 24 Q
I. don't mean to hold you;to that
' 25 classification. 'Who are'the three people who you 4
4,*
1 Long 461 s
j'"'N U.
2 would think to be the people who know the most about 3
that subject?
4 MR. GLASSMAN:
Objection.
(
5 MR. BENEDICT:
I will explain it.
I think 6
Dr. Long is hesitating about the word "most."
7 Q
Who is someone who is very knowledgeable 8
about that subject?
9 MR. GLASSMAN:
I object again.
I am not 10 sure whether the question is dire'cted to who 11 might have conducted studies after the accident 12 or who was'around before or who has firsthand, 13 secondhand or tenthhand knowledge.
The question 14 is rather vague and general.
If yoO are asking, 15 as you did in your last question, who would Dr.
16 Long think is knowledgeable 17 MR. BENEDICT:
I can't ask Dr. Long anything
.18 other than what he thinks.
I am se king who 19 Dr. Long would go to if he was interested in 20 finding out what the condition of the training 21 program was prior to the Three Mile, Island' 22 accident.
23 A
Mr. Zechman would be one of the people that
.,ng i
(v) -
24 -
'I would talk to.
25
-Q Is'there anyone else you can-think.of?
l u.
l 1
Long 462 2
A Mr. Tsaggaris.
3 Q
What was, as you recall, Mr. Tsaggaris' 4
position prior to the Three Mile Island accident?
5 A
At one point, he had supervisory 6
responsibility over Mr. Zectuan.
I don't know exactly 7
. when that was.
8 Q
Was Mr. Tsaggaris aGPU employee as opposed 9
~o a Met Ed employee?
5 10 A
No, he was a Met Ed employee.
11 Q
Is Mr.Tsaggaris s tillwith the GPU system?
12 A
No, he is not.
.tO-13 Q
Do you know where he is today?
14 A
Ke is with a company called Energy
' 15 Consultants Incorporated.
16 Q
Where does Energy Consultants hang its 17-
- shingle, if you know?
~
18 A
Somewhere in the Pittsburgh area.
I don't 19.
.know whether it is actually a-Pittsburgh address.
20-Q About how long has it been' since lir.
- Tsaggaris left?-
22 A
It has been at least a year ago. -
. Z3 Q_
Could you turn.to page 12,145 of your oral-(G i )-
24 testimony.
That is still in February 11. - There is a
-25 question.which begins on line 7 which reads', "Are you s
1 I
's-6 q
1 Long 463
+
2 planning to purchase a full replica simulator of the TMI control room - control rooms, I should say?
3 4
" Answer (Witness Long)
Yes.
The 1981
(
5 budget for the training programs includes $400,000 g
to begin the effort of developing specifications and 1
7 initiating the acquisition of a replica simulator 8
for TMI-3."
9 Does it continue to be true that the GPU 10 system intends to buy a full replica si'mulator for 11 TMI-J7 12 A
Yes.
13 Q
The next question and answer down read:
14
" Question:
What is the time schedule on that?
15
" Answer (Witness Long)
The manufacturers 16 at the present time indicate delivery times of 3-17 to 36 months from the time an order is placed.
We 18 are hoping to have fully developed the sphcifications
~
19 and request bids in the third quarter of this1 year, 20 so we are talking about approximately four years."
21 Did you complete specifications and request
' bids in the third quarter of 49817 22
.j A
No,.we did not, p
/.
( j,.
24 Q
Kas that process occurred to date?
25
.A No.
1 1
Long 464
- p. '
2 Q
There has not yet been a request for bids?
3 A
It may be on my desk right now waiting 4
for review.
(
5 Q
Is it still your understanding that there 6-is still a 32 to 36 month lead time after the bids 7
are requested or bids are in?
8 A
I don't know whether there has been a 9
change in that or not.
10 Q
Turning t'o page 12,260 -- actually I would 11 like you to refer back a couple of pages.
This is a 12 rather long and involved series of questions which O
13 appear to relate to some method of utilizing a computer 14 for training purposes, and'I want you to be confident 15 you recognize the content of these questions, because 16 I am going to read an answer and a portion of another 17 answer.
Obviously if Mr. Glassman thinks something 18 ~
further should'be read, he can put it in.
19 Have you had a chance to generally 20 familiarize yourself with the testimony around page I
21 J2,2607 l
(
22 A
Yes, I have.
23 Q
I would'like to read your answer.which I
r
-( 3)
.24 begins on-line 13. of that page,
It reads, " Witness L
25 Long:
And we display that' data on a cathode-ray tube A
}
1 Long 465 2
display in color and there is a fairly well defined 3
trajectory when you plot pressure versus temperature."
4 What was the data that was ' displayed on.
(
5 the cathode ray tube?
6 MR. GLASSMAN:
What was displayed?
What 7
would be displayed?
8 MR. BENEDICT:
What did he mean when he g
said "that data"?
10 MR, GLASSMAN:
We are talking about 11 something in the context of this testimony 1
l 12 that was being considered or discussed in this'
~
. O l
13 testimony of February 19817 t
I 14 MR, BENEDICT:
That's right.
15:
A The data plotted is hot leg temperature 16 versus RCS. pressure and cold leg temperature versus 17
' steam generator pressure.
I 18 Q
Were these data plotted versus time?
j 19 A
No.. They are plotted 11n time but not 20 versus time.
21 Q
In other words, it was a graph that had.an 22 ordinate and. abscissa and one-of them was time?
'23 A.
!No.
24 Q
.Was it a graph?
- 25 A
The graph has an ordinate'which is
~ w<
1 Long 466
/
i-V 2
temperature, and the abscissa is pressure, and at the 3
beginning of a transient, you have a certain temperature 4
and pressure.
A minute later you may have a different
(
5 temperature and pressure, and you plot that, so you 6
get a trajectory that change's with time.
7 Q
The answer goes on to read, "That pressure 8
versus temperature plot will go from 100 percent power 9
to a normal shutdown condition along with a fairly e
10 well defined path, unless something unusual is happening.
11 "Dr.
Jordon:
I see.
12
" Witness Long:
For example,,
a loss of L}
l 13 coolant accident.
It will deviate very s'gnificantly 14 in a short time.from that path."
15 Prior to your recollection at this time, 16 did you ever compare the actual data from the TMI-2 17 accident of March 28, 1979 to the normal hot shutdown 18 or the path defined going from 100. percent power to 19 hot shutdown?
i 20 A
Yes.
l-21,
.Q Did it deviate very significantly in a 22 short period of time?
-23
.A Yes, it does.
C\\
(_/
24-Q Turning-to the next page, 32,263,-your
~
. 25 answer continued, and again I am going to only read
+:
1 Long 467
(
A
~
a Portion of it.
If you think there is any more that 2
should be added, please do so.
Starting on line 14, "This method of analysing plant behavior was taught 4
(
in the operator accelerated retraining program where 5
6 the operators were taught to make these plots by hand, because it is not a rapid time."
7 Are the plots that you referred to in that 8
sentence the same plots that you were discussing as 9
10 appearing n the cathode ray tube screen, except Prepared by hand?
11 12 A
Yes.
13 Q
Yu then go on and say, "You can do it 14 every 30 seconds, just take the data and plot it."
Does that mean that the temperature-15 16 Pressure. relationships would be plotted at-30-second intervals?
17 l'8 A
Yes.
19 Q
Finally, you say, "And they found it very 20 helpful in understanding the plant behavior, so we have gotten very positive response back from the 97 22 Perations personnel that this is a real useful_ device."
In line 19 when you say "they," are you 23 24 referring back to the operators-who were trained in 25.
.the operator. accelerated retraining program?
l 1
Long 468
-O V
'2 MR. GLASSMAN:
What period are you talking 3
about?
4 MR. BENEDICT:
When he gave this testimony
(
5 in 1981.
6 A
Yes.
7 Q
Are you aware of whether or not this method 8
of analyzing plant behavior was ever taught to the i
9 operators prior to March 28, 19797 10 A
No.
I think it was developed jointly 11 by B&W and GPU Nuclear following the accident.
12 Q
So it is your understanding that it wasn't m
13 taught prior to the accident?
14 A-
'Not to my knowledge, but I don't know the 15 content prior to the accident.
16 Q
What did Mr. Newton do in 1981 at the time 17 of this testimony?
What was his job?
18 A
His job was supervisor of operator 19 training, including both licensed and auxiliary 20 operators.
21 Q
Was he a GPU Nuclear employee?
22 A
At that time we were still in a transition 4
23 -
stage.
I don't know whether he was on the Met Ed
, L-h. / l 24 Service Corp.Epayroll.
There were no GPU Nuclear l
25 employees as~such at that time.
2-.
w e
e
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1 Long 469 O
2 Q
Did Mr. Newton report either directly or 3
. indirectly to you at this time?
4 A
He reported to Dr. Knief who reports to 5
me, or who reported.to me.
6 Q
There is a question and answer which 7
appears on page 12,267 through page 12,268 where the 8
respondent was Mr. Newton.
I would like to read that.
9
" Question:
You talked somewhat in your 10 oral testimony about on-the-job training, and I am 11 wondering, is that -- is that on-the-job training 12 similar to the Navy program having a ca11" it says O.
13 "hard, I believe it should be " call" -- ", card having 14 a guy qualify on various watch stages or as an 15 alternative qualify in performing certain functions 16
-before he can become a supervisor of that function?
17
" Answer (Witness Newton) :
Yes, sir, 18 it is very similar.
In fact in the task heet that 19 we are building right now, they are not complete, 20 but the task sheets that we are building for the
.21 auxiliary operator program-where auxiliary operators 22 are specifically assigned to four or five - different 23 1ocations, the_ task sheets are functionally -- for
~
24 example, secondary plant operations.
There is a task 25
. sheet, if you~will, a call card for that.
The task 9
_______-___----x-
1 Long 470
, ll V
i 2
sheets for the control room operator's card are not
-3 broken down further into, say, specific panels, 4
because that is not the nature of how they do their
(
5 job.
They do their job essentially encompassing the 6
l control room as a whole and the task sheets are forned 7
that way.
But the sheets themselves are very, very i.
8 similar to the Navy call cards, almost, I guess, about 5
9 as similar as I could make them without actually e
10 writing Navy terms in there."
11 Are you aware of whether or not task sheets 12 similar to those described here by Mr. Newton were in 13 in Three Mile Island training prior t,o the use 14 Three Mile Island accident?
15 A
I don't know whether they had_anything 16 similar or not prior to the accident.
i 4
4 17 Q
Did you have any role in supervising Mr.
18 Newton's project with respect to the creation of these 19 task sheets?
~
20 A
I did not have any direct role, no.
21 Q
You didn't' review his work or comment on it?'
22 other'than managing as manager, did you have any role 23 7
. with respect to these?
-A-
-I reviewed both the-auxiliary operator 25 and the' control. room operator training. programs that
.t
..-,0.,
1 Long 474 fm
(_)
2 were eventually developed by Mr. Newton and approved 3
by Dr. Knief.
4 Q
So that would include reviewing the task
(
5 sheets; is that right?
6 MR. GLASSMAN:
You are assuming the witness 7
had knowledge of that particular item.
8 A
I am not sure whether the task sheets were 9
part of the program description that I reviewed or not.
10 Q
Are you familiar with what Mr. Newton is 11 discussing here as task sheets in a general sense?
12 A
Roughly.
I don't have any familiarity
/~
13 with the Navy sheets.
14 Q
Not the call cards, the task sheets that 15 were being created by Mr. Newton at the time he was 16 giving his testimony, you were aware of that work; is 17 that right't 18 A
Yes.
19 Q
Turning to page 12,293, in your' testimony 20 on that'page in lines 18 and 19 you refer to something 21 called the OARP review committee report.
What is
-L 22 that report?
23 A
That was a report prepared by a committee
.i
/h j-24
,of consultants that GPU hired and asked to review the i
v.
25 OARP p.?ogram.
1 Long 472 2
Q Is that report, or in the course of your 3
testimony was that report sometimes called the Uhreg 4
report, U-h-r-e-g?
(
5 A
Yes.
6 Q
Is that the name of a person who was 7
involved in preparing the report?
8 A
-Yes.
9 Q
Who was on the OARP committee?
10 A
Dr. Robert Uhreg, ProfessoE, Rick Gardner, 11 Dean William Kimel, Mr. Richard Marshak, and Dr. Julian 12 Christensen.
()'
13 Q
What professional or academic affiliations 14 did these people have?
15 A
Dr. Uhreg was a vice president of Florida 16 Power-& Light.
I am referring to their positions at 17 the time ' of_ this committee work.
Professor Gardner 18 was a professor emeritus from Syracuse University.
19 Dean Kimel was dean of engineering at the' University of 20 Missouri - Columbia.
Mr. Marshak was manager of the 21 nuclear power training program located at the MaGuire 22 station.
.I don't know his exact title.
Dr.
23 Christensen wasua consultant with an engineering firm.
l l : p) 24 Q
Was Dr. Uhreg the chairman of this group?
,v-
-25 A
Yes.
l-
^-
i la
1 Long 473 2
Q Who established the OARP review committee?
3 A
Mr. Lawyer identified and organized that 4
group.
5 Q
Was the committee report presented to the 6
Atomic-Safety and Licensing Board considering the restart 7
of the Unit 17 8
A
,Yes, it was an exhibit presented to the 9
- board, t
10 Q
What, if any, responsibility did you have 11 with respect to the preparation or review of the 12 report prior to its submission to the ASLB as an exhibit?
13 A
I met with the committee on a, couple of 14 occasions for discussions of their work and to answer 15 questions, and I reviewed one or perhaps more drafts --
16 I don't remember -- of the report.
17 Q
Who, if anyone, else who was employed by 18 GPU or the GPU system had responsibility with respect.
19 to this report prior to its submission?
20 A
Primarily Mr. Lawyer, who was manager of the 21 TMI training department at the time-the report was
{?
22 finalized.
Z3 '-
Q
'Where would you look today-for any prior j
p b-)
24
' drafts _o.r-material that you had with respect to your 251
.~ review function?
m w.
1 Long 474 r'%
2 A
As,far as I know, they would be in the 3
file boxes provided in this litigation, if there were 4
any that were in the files at the time the files were 5
boxed up.
6 Q
When do you recall doing the review 7
function that you mentioned or performing the review 8
function?
9 A
The spring of 1980.
10 Q
so it was almost a year before your 11 testimony before the board?
12 A
Yes.
(3) 13 Q
I would like to direct your attention 14 now to the volume of testimony dated February 13, 1981, 15 and in particular to page 12,727 of that volume.
16
~ There is some testimony here by someone designated as 17 witness Christensen.
Who was Mr. Christensen?
18 A
That was Dr. Julian Christensen, a member 19 of the review committee that we were just discussing.
20 Q
There is a question and answer at the top 21 of.the page which reads:
L.
22 "By Mr.Dornself:
Dr. Christensen, the 23 operators are on watch when they are on shift, are
's /
24 they allowed to' study procedures and refresh their 25 training when they have nothing else to do?
,r.
,w..
~ -
_q-_
1 Long 475 h
\\J 2
" Answer (Witness Christensen) :
I think that that is more appropriate for Dr. Long.
3 4
"Dr.
Long:
Yes.
When they do not have 5
specific assignments on the hoard, they are involved 6
very often in on-the-job study and training."
7 At the time you gave this testimony in 8
February 1981, did you know whether the union 9
agreements pertaining to operating personnel permitted 10 the assignment of off-shift homework?
11 A
It is my understanding that the union 12 agreement does not allow cpecific assignment of
~
13 off-shift homework.
14 Q
Do you know whether that was true prior 15 to the Three Mile Island accident?
16 A
I don't know what the history of the 17 union agreement is.
18 Q
You don't know whether the same agreement 19 is in effect that was in effect prior to March 19797 20 A
I don't know.
21 Q
At the time that you participated in the 22 preparation of the written testimony and gave the 23 oral testimony that appears in the four volumes in A
\\
l 24 front of you during the month of February in 1981,
_j 25 were you aware of cheating or allegations of cheating
su 1
Long 476
~ms) 2 on NRC licensing exams by TMI personnel?
3 A
No, I was not.
4 MR. BENEDICT:
With the exception of
(,.
5 issues that may or may not be relevant related 6
to the Mulholland report or findings, I have 7
no further questions.
8 Do'you have any cross?
9 MR. GLASSMAN:
Are you done with your 10 questioning or not?
11 MR. BENEDICT:
Yes, I am done with my 12 f,
questioning except for anything relating to
( -
13 issues pertaining to what is covered in the 14 Mulholland testimony.
15 MR. GLASSMAN:
I have no questions at this 16 time.
17 (Time noted:
12:05 p.m.)
18 19 Robert L.
Long 20 21 Subscribed'and sworn to before me L
22
'this day of
'1982.
23
\\_)
24 25
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+-
P
.n 1
477 1,.
CERTIFICATE f'
2' u
ii STATE 0F NEW YORK
)
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- ss.:
+
COUNTY OF NEW YORK
)
4 h
I, JOSEPH R.
DANYo
, a Notary
\\.
.v o
i Public of the State of New York, do hereby certify that the continued deposition of ROBERT L.
LONG was taken before me on May 2 i, 1982-consisting of pages 420 through 478
- E 10 I further-certify that the witness had been previously sworn and that the within 13 transcript is a true record of said testimony; That I am not connected by blood or marriage with any of the said parties nor interested directly or indirectly in the matter in controversy, nor am I in ths employ of any of the counsel.
IN WITNESS WHE?. EOF, I.have hereunto 'et my s
19 i
.i
[
day of
(/v a 2
/9f0 hand this-
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21 OO Wh
$WA l
'SEP R.
DANYO 24!
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n.
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478
-,A;-
INDEX WITNESS PAGE i
r.
Robert L.
Long, resumed.
422
'(4 EXHIB IT S B&W FOR IDENTIFICATION t
726 16-page handwritten memorandum dated July 17, 1979 422 l
727 Multipage document, first.page headed " Preface" at the top 422 728 Multipage document first page headed "I&E Radiological SOE,"
dated July 19, 1979 427 729 Two-page handwritten document dated July 22, 1979 431 730 Three-page memorandum from E.
G.
Wallace, dated August 6, 1979 431 731 Letter from Mr. Woodard to Dr.
Long, dated July 12, 1979, and attached multipage document 434 t
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